EIR, IMC rating and Jim Thorpe

[Fuji Abound]

In response to AOPA’s concerns, Jim Thorpe says, “It would have been helpful if the UK branch of AOPA had made any concrete suggestions whatsoever at the start of the process when they were invited in person to do so. Neither did they take up my two recent offers of a full briefing so they would be in possession of the facts. If they had they would then understand that the EIR is not intended to replace the IMC. There was never any possibility of a UK style IMC working in Europe with its very different airspace. Nonetheless, AOPA, in the shape of IAOPA, have their own German representative on FCL 008 and he has been fully supportive of the whole process.
“The natural home of anyone who uses the IMC intensively will be the flexible IR. After all the USA, whose system is so admired, has found no requirement for an IMC like qualification. The EIR was seen more in the context of a stepping stone for pilots in the other 25 European states who previously had nothing other than a commercially orientated IR on offer.”
“It is simply factually inaccurate to state that nowhere in Europe has weather like that in the UK,” continues Mr Thorpe. “If the EIR proposal is such an impossible way of operating, no one has told the thousands of pilots throughout Europe who fly VFR on top and descend without any instrument qualification at all. In the UK in the early days of the IMC rating it was often used in exactly this way. The airspace in which it was valid was defined in an ANO schedule and relatively few airfields with instrument approaches were accessible to the IMCr holder so regaining visual conditions prior to landing was common practice.”
One other significant difference between the existing UK IMCr and proposed EIR is the theoretical knowledge requirement. For pilots undertaking the IMC course the theoretical knowledge requirement is relatively un-intensive, comprising just a single written exam. For the EIR however, it is proposed that the theoretical knowledge requirement will be the same as that required by pilots undertaking the full Instrument Rating (IR). There is a significant twist however. According to Jim Thorpe, much work has been going on in FCL008 towards producing a PPL IR more relevant to the type of flying undertaken by private pilots. Jim has told FTN that the proposed PPL IR theoretical knowledge learning objectives will be half those currently required for the JAA IR, with studying expected to be undertaken primarily by distance learning. FTN also understands that the flying training requirements for the EIR, which will be roughly equivalent to the existing IMCr, will not have to take place at an approved Flight Training Organisation (FTO) but can be undertaken with PPL schools operating as Registered Training Facilities (RFs). It is also expected that some or all of the training required for the EIR will count towards a full Instrument Rating, making the EIR the sort of ‘stepping stone’ rating towards an IR that the IMC used to be. All this conjecture comes with a health warning however, that until the finalised proposals are published, all information about them is unofficial and in part guess-work. Nevertheless, supporters of the EIR point-out that it may well offer a significant business opportunity to UK flying schools who may well be better placed to offer training for it than schools in other European states where there is no previous experience of instrument flying training for private pilots.

I also posted this on the darker side (the other side is always the darker side depending which side you are posting from!) but I think it is worth a wider audience.

It leaves me wondering why or how Jim Thorpe is in part representing the interests of UK GA?

[BEagle]

AOPA knew that Thorpe was proposing this ludicrous idea as long ago as February this year....

However, you may rest assured that strenuous efforts are now being made to lobby FCL.008 and others to rip up and throw away the so-called EIR and instead to promote a lightly modified form of the UK IMCR which should be acceptable to the rest of the EC.

Sadly though, the damage done by Thorpe's EIR has given the wholly wrong impression to the rest of FCL.008 that the UK had 'given up on the IMC Rating' - which, of course, it hasn't.

Thorpe's EIR was allegedly based on the Australian Private IFR Rating. However, it does not include one of the main parts of the PIFR, which is the ability to add various 'Flight Procedure Authorisation' items to the PIFR - including instrument departure, arrival and approach privileges.

[421C]

AOPA knew that Thorpe was proposing this ludicrous idea as long ago as February this year....

Amazing. Not. AOPA is directly represented on FCL008, by one of the few people who work full time for AOPA in Europe.

However, you may rest assured that strenuous efforts are now being made to lobby FCL.008 and others to rip up and throw away the so-called EIR and instead to promote a lightly modified form of the UK IMCR which should be acceptable to the rest of the EC.

So what strenuous efforts have been made by AOPA on FCL008 to date? Why do you endlessly snipe at Jim Thorpe and what he has done. Why not tell us what AOPA has been doing on FCL008 for the last year?

brgds
421C

[BEagle]

AOPA UK is not directly represented on FCL.008; representation is made through the IAOPA representative.

I certainly will 'endlessly snipe', as you put it, at Thorpe's utterly absurd pet hobby-horse, the 'EIR'. He cannot be unaware that the 'EIR' concept has been lambasted over recent months and that no-one supports it. Yet he continues to push the absurdity of the 'EIR' through FCL.008 with neo-evangelical zeal.

You will have to wait and see whether AOPA UK's efforts to change FCL.008's thinking on the IMCR situation will bear fruit - but work is ongoing as I write....

[421C]

AOPA UK is not directly represented on FCL.008; representation is made through the IAOPA representative.

Fine. So tell us what AOPA UK's indirect representation on FCL008 has been for the year (?) FCL008 has been running.

[BEagle]

421C - are you an AOPA member?

If so, e-mail the Chief Executive and ask him.

[421C]

Why won't you post an answer to this simple question? You are hardly shy about posting on this subject, and it seems to me a fair and reasonable question. Either you don't know what AOPA UK has been doing, which seems odd given your intensity on the topic, or you do know and can't or won't say.

BTW I am a member of AOPA UK.

[vanHorck]

Beagle

I am not a member of the UK AOPA (being Dutch) but I do have an IMC.

What has AOPA UK indirectly done in the lobby in this last year on the subject?

You write:
...you may rest assured that strenuous efforts are NOW (my capitals) being made....

What do you mean by NOW ? Was AOPA UK too late off the starting blocks?

[S-Works]

Pam Campbell has represented AOPA indirectly at FCL008 after AOPA UK did not get a place on the group which I always found a bit strange as it is a UK rating after all.

Beagle you clearly have an axe to grind over this issue as both your emails and forum postings have been aggressive and downright rude about Jim Thorpe. Whatever your opinion of the situation and FCL008 as a group that is uncalled for.

Regardless of how you butter up the situation, it has been made clear that the EASA and the European NAA's have no stomach for the IMC and in order to try and get something through Jim Thorpe put forward a solution that was not torpedoed by the group. Whilst it was not an ideal solution it was one that had a potential.

We all know that the simple solution would be for it to be accepted European wide using the 'where allowed' clause that you trumpet regularly about. However if it was that simple why has it not been adopted?

[Johnm]

We all know that the simple solution would be for it to be accepted European wide using the 'where allowed' clause that you trumpet regularly about. However if it was that simple why has it not been adopted?

This is a committee set up by a bureaucracy, simple is not a word in the vocabulary in use.

[BEagle]

Beagle you clearly have an axe to grind over this issue as both your emails and forum postings have been aggressive and downright rude about Jim Thorpe. Whatever your opinion of the situation and FCL008 as a group that is uncalled for.

bose-x, yet again you appear unable to differentiate between criticism of an individual and criticism of his policies or proposals.

I'm sure Jim Thorpe is a perfectly charming person; however, the damage wrought by his 'EIR' proposal deserves every criticism.

In this context, it is interesting to note the difference between the original PIRR proposal and the version ulitmately delivered. And, of course, there was an opportunity for everyone in Australia to respond to the Notice of Proposed Rule Making published in 1998.....

[vanHorck]

Beagle,

Any chance of an answer re. my questions?

I ted to agree with Bose X here. I took felt there was a harsh undertone towards Mr Thorpe in your criticism.

Let's cool down a little and accept we all try to find solutions, and we may not always agree with other people s attempts.

Trying to work towards a solution seems better to me than doing nothing about the problem at hand

[S-Works]

bose-x, yet again you appear unable to differentiate between criticism of an individual and criticism of his policies or proposals.

I can indeed differentiate which was the very reason I made comment. As VanHorck says, cool down a little and reflect on what you write. This is clearly an emotive subject to you, but personal abuse is not called for and will not change anything.

If you wish to take issue with me directly then I suggest you save it for me in person for the 5th December. We can discuss directly my ability to understand the nuances of human interaction.

[englishal]

I seem to have lost the plot with regards to this whole business....

I'd actually like to see a EIR which is aimed at the PPL, grandfathing previous instrument time, distance learning, using flying clubs.....I'd actually find it more useful than an IMCr as France is on my doorstep so to speak.

I'd hate to see a national rating disappear though and I don't see why it should just vanish with no alternative.

[dublinpilot]

I'd actually like to see a EIR which is aimed at the PPL, grandfathing previous instrument time, distance learning, using flying clubs.....I'd actually find it more useful than an IMCr as France is on my doorstep so to speak.

Are you aware that it would not allow you to fly an instrument approach?

[mm_flynn]

Originally Posted by dublinpilot

Are you aware that it would not allow you to fly an instrument approach?

Remember, quite a lot of people are flying from fields that don't have instrument approaches anyhow. I don't do a lot of flights that need an approach below the local MSA, but I do an awful lot of flying where remaining legally VFR is a pain (and sometimes would be unsafe). In addition, the whole enroute process is so much easier on an IFR flight plan at FL100 than trogging through the dirt, dog legging around CAS or getting a series of ad hoc transits. In the context of the reduced requirements proposed for an IR, the EIR seems to have a point as a stepping stone, and addresses the concern a number of UK FI raised that they frequently need to 'pop through a layer'

I agree it is not a replacement for the IMCr, and AOPA UK are leading the charge on a method to retain that ... but it is virtually inconceivable the rest of Europe will agree to an IMCr (unless you count agreeing to the principle ... but not in their airspace! - which may well be an approach to retaining the UK IMCr).

You only need ask yourself, 'Why are IMC holders so comfortable about not having access to the airways, and why does the UK not allow an IMCr in the airways?" and then think about how the answers would apply (or more accurately not apply) in most of the rest of Europe to understand why an IMCr has little chance of being implemented outside the UK.

[englishal]

Are you aware that it would not allow you to fly an instrument approach?

Well that is the really stupid bit. The rating should at least incorporate a precision approach.

'Why are IMC holders so comfortable about not having access to the airways

Are they? Give me access to airways any day.

I wonder why they couldn't just come up with a proper IR "for private privileges or training purposes only", with an upgrade course necessary for anyone wanting to fly 747's using it?

Would seem eminently sensible to me, allow distance study, one private IR exam based upon the FAA one (as in computer based, easy to book etc...), only 15 hrs of *required* tuition or a foreign IR/IMC in lieu of.....training at a small flying club etc etc....Then there would be no problems with ATC issuing clearances one cannot comply with, and those wanting to go on to fly CAT could do so with a bit of extra training....Surely this this would even please the Eurocrats?

[BackPacker]

I'd be very interested in such an IR. And I would not even mind if they would limit such an IR to below certain airspeeds, or below certain altitudes. For instance the oxygen level (FL100 or thereabouts) or the RVSM level. Or non-FIKI only.

You want higher, faster, bigger, FIKI, get the big boys IR.

But I see no value in an EIR if you cannot depart or arrive in instrument conditions. Particularly the non-instrument arrival will lead to a lot of situations where people misjudged the situation and get "boxed in" by their license privileges.

[englishal]

I'm not sure you could place airspace limits really unless it was say 18000', otherwise ATC might issue clearances that one cannot comply with. Plus I'd like to cruise in the high teens for best TAS and to be clear of the weather and many private aeroplanes can cruise at 20,000.

But they could limit it to "for use not above 250 kts, not authorised for Turbojet aircraft" or something if there was a need. The IR upgrade could then form part of a type rating which most aeroplanes of this nature would require.

But I think a limit of "not authorised for public transport operations" would be good enough to differentiate between a Public and Private IR.

[BackPacker]

That's why I would not choose the altitude limit arbitrarily, but connect it to something that, in practice, is a limit already. Without oxygen/pressurization you cannot fly above a certain altitude (except for a short while in FAA-land) and without RVSM capability in the plane the upper flight levels are forbidden anyway. So those would make natural limits for an IR-light, since you don't have to explain a lot more to the controller if you get such a clearance.

I'm just looking at my club environment where we have a bunch of stock standard PA28s, 172s and a DA-40. Most of them IFR equipped and certified. That's the kind of airplane that a lot of PPLs would want to do their IR-light in. And that's probably what they're using for their IMC today in the UK in any case. They rent, not buy. And as a result of which, even if the airplane has the capability to cruise above the oxygen level, there's no club which rents oxygen cylinders, masks, regulators and stuff along with the plane.

We are primarily looking at a pan-European replacement for the IMC so I think you've got to look at what the types of airplanes are, and the experience levels of the pilots who use the IMC.

And as I said, if you want more capability, get the full IR.