AOPA and IAOPA clarrify their position on the IR and IMCr

[Fuji Abound]

It is well worth reading these articles which help to set out IAOPA's and AOPA's position on these very important issues.


http://www.iaopa.eu/mediaServlet/sto...ct09/p5-20.pdf

[englishal]

I never really understood IAOPA. As I am a member of AOPA US, does this mean I am a member of IAOPA?

[S-Works]

AOPA is a franchised organisation in Europe with each country having its own AOPA organisation licenced to use the AOPA name.

IAOPA is an overarching organisation that uses experts from within the national AOPA's to act as a single voice rather than trying to have one from each branch.

[IO540]

From that PDF:

As forecast in the August issue of this
magazine, it’s back to ICAO and the JARs
unless there’s a pressing safety case against
them. Third country operations, which
promises to be a battlefield, goes to the back of
the queue.

Sounds good to me

[sternone]

Good news.

[IO540]

Indeed - but never count your chickens until they hatched. That AOPA newsletter has a great article about how the UK CAA managed to avoid "excessive loss of work to EASA" and how this included collaboration with other European CAAs who were facing the same threat.

The EU organisations are staffed with very bright people (with the money they pay, they can afford the brightest - if not the most customer-motivated) and will be very skilled players in work creation.

[Mike Cross]

I never really understood IAOPA. As I am a member of AOPA US, does this mean I am a member of IAOPA?

In this case it's IAOPA Europe, which is the European AOPA's working together.

Being a member of AOPA US does diddly squat for anything in Europe. Bizarrely some people think it does.

IAOPA and IAOPA Europe are there to represent national AOPA's in the case of IAOPA Europe to the EU and its aviation organisations like EASA, in the case of IAOPA to ICAO, on which it has a representative.

It's a bit like the BGA where you are a member of a Gliding CLub, which is affilliated to the BGA. That doesn't make you a member of BGA.

[FREDAcheck]

Dr Michael Erb of AOPA Germany, attempted to get the group to develop a follow-up to the IMC rating when it met in Cologne on May 28th, but FCL-008 refused. Instead, it has flown off on a baffling tangent by introducing the idea of an En-Route Instrument Qualification proposed by Jim Thorpe of Europe Air Sports which would allow a pilot to fly in IMC on airways, but would not allow him to land other than in full VFR conditions.

Glad to see AOPA share the views of many of us about Jim Thorpe. I'm sure he's done great things for PPL/IR, but his proposals risk doing enormous damage to the interests of a much greater number of flyers with IMCR. As AOPA says, it's unlikely the airlines would accept his en-route IR, so his proposal (if pursued) will merely see IMCR buried. A cynical person might wonder if Jim knows that.

[Fuji Abound]

I wonder what Jim Thorpe's mandate is?

Does he represent the interest of PPL/IR or does he represent himself? I assume the former unless he was co-opted as a self proclaimed expert.

If he represents PPL/IR is it the case that the membership supports his position and if they do how have they signified they do? If they dont they should instruct him accordingly.

I ask because I always find it very odd when it would seem someone is so out of tune with those they represent.

I think it is important that the associaiton with PPL/IR is clear (if it exists). Its very easy for such organisations to disassociate themselves from an individual who is there with their mandate. If PPL/IR agree with Jim's stance they should have the guts to say so and be damned (or not).

(Forgive me if PPL/IR and their members have / have not already proclaimed their support for Jim - I dont know the answer which is why I am asking)

[mm_flynn]

Originally Posted by From AOPA link

It is widely believed, still, that it [the IMC] is a ‘poor man’s instrument rating’ which allows access to controlled airspace and will clutter the ILSs of Europe with light singles

The more vociferous critics of FCL.008 seem to want to use the IMCr in exactly this way.

FCL.008 is a European working group, not a 'save the UK IMCr' group. That is AOPA UK's roll and the referenced document makes clear that AOPA UK is on the case to save the IMCr. However, it is pointless to put the IMCr on the agenda for Europe without some understanding of the reality of the airspace and regulation differences. It is equally silly to try to legislate a European rating that is then locally banned by all countries other than the UK! (unless of course it is a necessary fudge to save the IMCr - but at least it would be a conscious fudge rather than a waste of legislative time)

It is predominantly the UK that uses low level Class A to separate GAT and CAT activity. Most other countries allow these activities to co-exist in most/all airspace below FL195. As such, a Euro-IMCr constructed along the lines of the UK IMCr, would be exactly what the AOPA link says it wouldn't be. It would allow people access to pretty much every cubic meter of airspace outside Italy and the Paris TMA. It would be equally reasonable for the rest of Europe to insist the UK reclassify all Class A airways below FL195 as Class D/E.

[BEagle]

Not all that long ago, the ANO used to include restrictions on certain Class D airspace inside which mandatory compliance with IFR by IMC rating holders was not permitted.

For example, you could legally scrape over the cliffs into Cardiff VFR below a low cloudbase, but you couldn't fly an ILS in IMC.

This was later amended, so that only Class A airways are now off-limits to IMC rating holders; SVFR is permitted in Class A CTRs, but not in airways.

AOPA's point is that it would be entirely up to national airspace authorities, not EASA, to decide whether an Intermediate IR could be used in whichever part of their airspace they see fit. As is currently the case in the UK for the IMC rating.

[FREDAcheck]

FCL.008 is a European working group, not a 'save the UK IMCr' group.

Maybe not in those words, but its Terms of Reference include:

Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges

[englishal]

Not all that long ago, the ANO used to include restrictions on certain Class D airspace inside which mandatory compliance with IFR by IMC rating holders was not permitted.

And this is where I believe the "...only outside controlled airspace" limitations for foreign IR holders came from.

In the past the IMC rating did not allow IFR "in controlled airspace" but airspace which is now class D was not defined as "controlled", with "controlled" referring to Class A only.

When airspace was re-classified, and JAR came about, the IMC rating was redefined to include "controlled airspace, class D and lower" however the definition for foreign IR holders was omitted, probably by accident. The reason I reckon it was a clerical error was because the CAA used to have on their website that "foreign IR holders can exercise the same privileges as an IMC rating holder". However because of an omission (i believe) in the ANO the "outside CAS" limitation was never updated for foreign IR holders, and as "Class D and below" is now referred to CAS, and not just class A, then this effectively banned them from any airports in class D airspace (IAW IFR).

I haven't looked for a while, but I believe an IMCr attached to a CAA licence could also still have this limitation somewhere in the wording.

[BEagle]

Nope, Schedule 8 clearly explains the restrictions which apply to both UK-lifetime PPLs / BCPLs and to JAR-FCL pilot licence holders who do not have IMC ratings included in their licences.

I don't know what applies to foreign licence holders; my understanding is that the FAA views the FAA PPL/IR as equivalent to the UK IMC rating in G-reg aeroplanes.

[IO540]

Not all that long ago, the ANO used to include restrictions on certain Class D airspace inside which mandatory compliance with IFR by IMC rating holders was not permitted.

For example, you could legally scrape over the cliffs into Cardiff VFR below a low cloudbase, but you couldn't fly an ILS in IMC.

This was later amended, so that only Class A airways are now off-limits to IMC rating holders; SVFR is permitted in Class A CTRs, but not in airways.

I am reliably informed by someone who has been digging around this a lot longer than I have that the words "UK only" were also missing from the ANO, not many years ago, on the IMC Rating IFR privileges

The bizzare thing is that the CAA was free to put out an ICAO Difference on the IMCR. Had they done so, it woul dhave been valid worldwide except where the airspace owner objects.

my understanding is that the FAA views the FAA PPL/IR as equivalent to the UK IMC rating in G-reg aeroplanes.

Not heard that one anywhere. The FAA told me, in writing, that they regard the IMCR as equivalent to the FAA IR (within the limitations of the IMCR itself of course i.e. UK only, no Class A etc).

The privileges in a G-reg are up to the CAA, not the FAA. As regards how the CAA views the FAA IR, to the extent that for £70 or so an ICAO IR holder can buy himself an IMCR. In the case of the FAA IR he needs to be within his IPC (i.e. the CAA disregard the FAA rolling currency rule). He also needs a UK/JAA PPL or CPL, a UK medical, etc. It's not a terribly useful maneuver but a G-reg pilot gets IFR privileges for Class D, whereas with an FAA IR he would have them only in Class F-G (which is close to useless for going places).

[Fuji Abound]

I am reliably informed by someone who has been digging around this a lot longer than I have that the words "UK only" were also missing from the ANO, not many years ago, on the IMC Rating IFR privileges

Yes, but it is only within the grant of the national authority to allow IFR with a non ICAO rating regardless of the registration, notwithstanding that an FAA IR whilst an ICAO rating departs from the ICAO standard by a long list of differences as do many other IRs.

If DGAC were to tell you they accepted the IMCr for IFR ops then you would be good to go in the same way that if you are a non European national they will recognise your FAA IR in a G reg aircraft.

[IO540]

This is rather irrelevant but I don't see how the IMCR (no Class A) is sub-ICAO any more than any IR (with some other limitation say no commercial use and needs to have one's left goolie weighed every 6 months) is sub-ICAO.

If you take the IMCR and remove the fairly recently added "UK only" limitation, it is totally equivalent to a full IR - in any country in which Class A is either missing or not operationally relevant (i.e. all except UK and Italy, in Europe).

In terms of how the syllabus matches all-airspace full-IFR operational requirements (let's forget for now that the IR syllabus is woefully inadequate for real GA/IFR) the only really big bit missing from the IMCR is SIDs/STARs, and they require the amazing ability to ..... wait for it ..... READ the piece of paper with "STAR" in the top RH corner

It's all about the politics of professional pilot status in Europe, which for historical reasons has become closely attached to the IR. It should actually be attached to the ATPL (which is how it works in the USA) but Europe has structured the ATPL into a free gift to any fATPL pilot reaching 1500hrs with the MCC time etc. So, since the ATPL is basically a bogus thing over here for anybody with a RHS MCC job, they had to tie professional pilot status to something suitably elitist, and the IR is the only thing that's left. The CPL is a VFR-only exercise which "anybody" can pass, eventually, but by itself it is useless.

[BEagle]

Yes, the platinum-plated UK IR was once described to me by a CAA Examiner as "The last chance we have of weeding out someone who wouldn't be suitable for the airlines".....

Suitability for commercial employment should more reasonably be assessed as part of a commercial pilot licence test, whereas assessment of the applicant's ability to fly an aircraft by sole reference to instruments should be the sole function of an instrument rating test.

Neither is there any logical reason why an initial IR Skill Test must be conducted by a CAA Staff Examiner.

[IO540]

Neither is there any reason for the IR to be taught only at professional FTOs.

If you don't go for demonstrated competence, the whole thing is bogus.

"Industry interests" is what that bit is about.

And this prevents penetration of the GA market, because most pilots are not within "same day drive there and fly" distance of a pro FTO, so are looking at a residential deal.

Another very simple thing the FAA has got right (freelance instruction and freelance (FAA DPE) checkrides).

[bookworm]

Suitability for commercial employment should more reasonably be assessed as part of a commercial pilot licence test, whereas assessment of the applicant's ability to fly an aircraft by sole reference to instruments should be the sole function of an instrument rating test.

So, given that you agree with this, why are you selling out by proposing a limited IR with artificial restrictions?