IMC: 'Hung out to dry by our own side'
There are 2 main ways ahead:
Either to develop an IMC rating (or whatever you wish to call it) which everyone else in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.
The whole 'my Rating is better than yours' nonsense needs to stop. Whether people want an IMC rating or an IR should be up to them; personally I wouldn't ever want to fly a spamcan on European airways, but others might.
It came as an obvious surprise to M. Sivel to learn that, whereas an FAA PPL IR holder is never retested, an IMC rating holder has a mandatory re-test with an Examiner every 2 years.
Presumably the PPL/IR Europe group consulted those of its members who only hold IMC ratings to elicit their opinions before presenting its opinion through the EAS delegate on FCL.008?
Either to develop an IMC rating (or whatever you wish to call it) which everyone else in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.
The whole 'my Rating is better than yours' nonsense needs to stop. Whether people want an IMC rating or an IR should be up to them; personally I wouldn't ever want to fly a spamcan on European airways, but others might.
It came as an obvious surprise to M. Sivel to learn that, whereas an FAA PPL IR holder is never retested, an IMC rating holder has a mandatory re-test with an Examiner every 2 years.
Presumably the PPL/IR Europe group consulted those of its members who only hold IMC ratings to elicit their opinions before presenting its opinion through the EAS delegate on FCL.008?
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Either to develop an IMC rating (or whatever you wish to call it) which everyone else in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.
Either to develop a more GA-accessible ICAO IR which everyone in the EC can obtain.
or to establish a process by which the IMC rating may continue to be issued and used purely in the UK post-EASA.
The reason for the "ICAO IR" is that there is zero chance of European acceptance unless one has equal in-flight competence with IR pilots. There is room to play on what constitutes applicable/relevant theory, where the training is done, etc (and FCL008 appears to have done some of that) but there is no room to play on in-flight competence which basically means an identical checkride, plus ICAO minimum training compliance which is no big deal at just 10 hours.
Sub-ICAO, any country can do what it likes but the EU position is that this is not allowed.
Australia has its own "IMC Rating" kind of thing but Australia is not in the EU (very wisely
).
No, the so-called 'accessible IR' is a different issue. I am talking purely about the IMC rating.
People should STOP saying what is or isn't 'ever going to be acceptable in the rest of Europe' - the question is more basic. Do you or don't you want something in Europe which gives identical privileges to the UK IMC rating - which you can use where the airspace authorities allow?
Incidentally, I hear that there is considerable resistance to the 'accessible IR' from airline pilot unions - they want less spamcans in 'their' airspace, it seems. Having listened to the stumbling incompetence of a 'continental' PPL/IR holder trying to fly an approach at Bournemouth once, I do see that they may have a point.
The Australian PIFR developed from the original Australian 'EIR' proposals and now include Flight Procedure Approvals (e.g. instrument approach procedures) after completion of additional training and testing requirements......
People should STOP saying what is or isn't 'ever going to be acceptable in the rest of Europe' - the question is more basic. Do you or don't you want something in Europe which gives identical privileges to the UK IMC rating - which you can use where the airspace authorities allow?
Incidentally, I hear that there is considerable resistance to the 'accessible IR' from airline pilot unions - they want less spamcans in 'their' airspace, it seems. Having listened to the stumbling incompetence of a 'continental' PPL/IR holder trying to fly an approach at Bournemouth once, I do see that they may have a point.
The Australian PIFR developed from the original Australian 'EIR' proposals and now include Flight Procedure Approvals (e.g. instrument approach procedures) after completion of additional training and testing requirements......
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Incidentally, I hear that there is considerable resistance to the 'accessible IR' from airline pilot unions - they want less spamcans in 'their' airspace, it seems.
Having listened to the stumbling incompetence of a 'continental' PPL/IR holder trying to fly an approach at Bournemouth once, I do see that they may have a point.
I wonder how many IR holders could pass an initial IR check ride - and indeed why they would want to. I know I probably couldnt if I turned up tomorrow claiming I was a first time student and wanted to take the test.
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Bookworm
Well, I have enjoyed the debate with you and everyone else. Thank you.
There have been some very good points made (from both sides of the fence).
The one thing about which none of us can be entirely certain is what will actually come out of EASA. They have the opportunity of rewriting the rule book which does not come along very often. Either they will grasp that opportunity and really produce a worth while change or they will fail in their mission.
As I think I have made very clear the early signs are not very good. To be fair they have not been helped by co-opting advisors who clearly wouldnt know and IMC rating if they flew into one (as but one example). As is so often the case with this sort of process if you are hijacked by all the usual bad eggs before you even get started dont be surprised if you end up with a result they wanted but no one else did.
Rather like an episode from Yes, Minister, if you co-opt the "right" people to any committee you can get whatever result you want. What is far more dangerous is when you dont really know what result you want so you put people in charge who havent got a clue, other than their own interests. Then the lunatics are really running the asylum
Anyway, that really is me done.
We shall just have to wait and see.
I have no doubt we will return to the debate when there are any more developments.
What I have found interesting is there are some contributors to this thread that I would have had on my committee before the thread started and would not now, and others for whom the reverse very definitely applies. It does at least just show how difficult it can be to get the measure of people.
(I know thank goodness it is not my committee, hat, coat etc.
)
Well, I have enjoyed the debate with you and everyone else. Thank you.
There have been some very good points made (from both sides of the fence).
The one thing about which none of us can be entirely certain is what will actually come out of EASA. They have the opportunity of rewriting the rule book which does not come along very often. Either they will grasp that opportunity and really produce a worth while change or they will fail in their mission.
As I think I have made very clear the early signs are not very good. To be fair they have not been helped by co-opting advisors who clearly wouldnt know and IMC rating if they flew into one (as but one example). As is so often the case with this sort of process if you are hijacked by all the usual bad eggs before you even get started dont be surprised if you end up with a result they wanted but no one else did.
Rather like an episode from Yes, Minister, if you co-opt the "right" people to any committee you can get whatever result you want. What is far more dangerous is when you dont really know what result you want so you put people in charge who havent got a clue, other than their own interests. Then the lunatics are really running the asylum
Anyway, that really is me done.
We shall just have to wait and see.
I have no doubt we will return to the debate when there are any more developments.
What I have found interesting is there are some contributors to this thread that I would have had on my committee before the thread started and would not now, and others for whom the reverse very definitely applies. It does at least just show how difficult it can be to get the measure of people.
(I know thank goodness it is not my committee, hat, coat etc.
)
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This whole process is of course nonsense, born out of a desire to "harmonise" everything, which in turn comes from the continental habbit of being unable to trust anyone else to get things right, in this case the individual countries of europe, without pages of regulation. They are re-inventing the wheel, as of course we have already a perfectly good set of international standards, called ICAO. JAA added little to what ICAO offered and EASA will be similar. As each country already allows holders of ICAO licences to fly the aircraft from that country in another's airspace the EASA licensing will add little beyond allowing the national of one country to fly another country's aircraft in that airspace.
As all countries of the EU should be assumed to be able to train their nationals in accordance with ICAO there is absolutely no benefit to the ICAO process which cannot be addressed by simply ensuring mutual recognition of national ICAO standard licensing within the EU. Anything sub ICAO can be left to the discretion of the country concerned (wasn't that what we had about a thousand years ago, until JAA came along!).
There we are, problem solved. I can't see what the fuss was about
Sooner or later this country has to say enough is enough (I happen to notice the other day a quote from the EU that the cost benefit of the single market to business in the EU is about £160 billion; the cost of compliance with the rules is £600 billion
).
As all countries of the EU should be assumed to be able to train their nationals in accordance with ICAO there is absolutely no benefit to the ICAO process which cannot be addressed by simply ensuring mutual recognition of national ICAO standard licensing within the EU. Anything sub ICAO can be left to the discretion of the country concerned (wasn't that what we had about a thousand years ago, until JAA came along!).
There we are, problem solved. I can't see what the fuss was about
Sooner or later this country has to say enough is enough (I happen to notice the other day a quote from the EU that the cost benefit of the single market to business in the EU is about £160 billion; the cost of compliance with the rules is £600 billion
).
I note that the President of European Air Sports has now stated (my bold text for emphasis):
This is a most welcome statement. EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%. One must thus query why the EAS delegate on FCL.008 does not appear to have presented his own organisation's clear policy in repsect of the IMC rating.
Since AOPA (UK) knew that EAS supported the continuance of the UK IMC rating, it was hardly unreasonable for AOPA to expect that this EAS policy would be presented at FCL.008 by the EAS delegate.
This all supports the point I made to Eric Sivel last week; clearly the FCL.008 group did not represent stakeholder opinion, hence the data EASA now has from them is fundamentally flawed and should be firmly rejected.
We have a published guiding principle which our members endorsed some years ago with the advent of EASA, which is 'The guiding principle for the transfer of governance from national authorities to a European authority should be: “what is permitted and conducted safely today in individual countries should continue to be permitted under the new regime." '
I guess that guiding principle covers the point quite well as regards the IMCr. The stance we have taken is that we support the retention of the IMCr in the UK, and if it is possible to negotiate its wider acceptance beyond UK shores we shall do so. Equally however we have been active over several years in Europe in pressing for a more accessible IR compared to the present JAA IR. Hopefully that will be one of the final outcomes of the work that has been going on this last year.
I guess that guiding principle covers the point quite well as regards the IMCr. The stance we have taken is that we support the retention of the IMCr in the UK, and if it is possible to negotiate its wider acceptance beyond UK shores we shall do so. Equally however we have been active over several years in Europe in pressing for a more accessible IR compared to the present JAA IR. Hopefully that will be one of the final outcomes of the work that has been going on this last year.
Since AOPA (UK) knew that EAS supported the continuance of the UK IMC rating, it was hardly unreasonable for AOPA to expect that this EAS policy would be presented at FCL.008 by the EAS delegate.
This all supports the point I made to Eric Sivel last week; clearly the FCL.008 group did not represent stakeholder opinion, hence the data EASA now has from them is fundamentally flawed and should be firmly rejected.
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what is permitted and conducted safely today in individual countries should continue to be permitted under the new regime
Like many things relating to Europe, this is a very expensive solution looking for a non existent problem. Even the Commission suggested this recently when it told EASA to stop re-inventing the wheel. The principle of individual licensing regimes set to an international standard is so well established that it is difficult to see what this process is adding to either cost or safety, since non EU countries' nationals will continue to fly in EU airspace using their own licences. The continuation of national licences and ratings will have a zero impact on the single market so what is the entire process about? What it is about is Europe getting its fingers into every aspect of national life, asserting itself at the expense of individual countries.
If they wanted a sub ICAO sport pilot licence (whatever you choose to call it) then they should have focussed on that and simply validated national ICAO licences across the whole of Europe, which could be done so simply and cheaply compared to this bureaucratic gravy train which is now rumbling along gathering speed.
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EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%
since non EU countries' nationals will continue to fly in EU airspace using their own licences
The latter is the ICAO option, which I believe means citizenship. The whole thing is bizzare.
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Quote:
"EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%
The only way to dig up 320k pilots in Europe is to count every lawn mower including the one in my garden shed, and every parachute"
But if you look at the list of the sectors of light aviation in my posting 'elsewhere' (I tried to avoid posting the same in two places) you will see that EAS's membership constituency isn't just aeroplane pilots i.e. the sector debating the IMCr / IR. It covers a much wider range. For example, there are approximately 85,000 glider pilots (with a club and private glider ownership of c. 22,000 aircraft) in Europe, who through their national gliding associations are members of the European Gliding Union which is turn is a member of EAS. The same principle applies to hang glider pilots, microlight pilots, parachutists etc. There may of course be some double-count in the c. 320k referred to as some people are active in more than one sector, but that doesn't alter the figures materially. Fortunately (from one point of view) many of our constituent members are not affected by EASA as they operate Annex II aircraft, and remain, for the forseeable future at least, under national regulations. The ones that are affected by EASA are aeroplane pilots / owners, gliders, balloons and helicopters in categories > the Annex II threshold.
"EAS claims to represent around 320000 pilots and owners, of whom the PPL/IR Europe group are only 0.125%
The only way to dig up 320k pilots in Europe is to count every lawn mower including the one in my garden shed, and every parachute"
But if you look at the list of the sectors of light aviation in my posting 'elsewhere' (I tried to avoid posting the same in two places) you will see that EAS's membership constituency isn't just aeroplane pilots i.e. the sector debating the IMCr / IR. It covers a much wider range. For example, there are approximately 85,000 glider pilots (with a club and private glider ownership of c. 22,000 aircraft) in Europe, who through their national gliding associations are members of the European Gliding Union which is turn is a member of EAS. The same principle applies to hang glider pilots, microlight pilots, parachutists etc. There may of course be some double-count in the c. 320k referred to as some people are active in more than one sector, but that doesn't alter the figures materially. Fortunately (from one point of view) many of our constituent members are not affected by EASA as they operate Annex II aircraft, and remain, for the forseeable future at least, under national regulations. The ones that are affected by EASA are aeroplane pilots / owners, gliders, balloons and helicopters in categories > the Annex II threshold.
Sub Judice Angel Lovegod
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BEagle,
You said on Saturday that you were going to grow up, stop the sniping and work towards a united approach.
Can you just not help yourself?
You said on Saturday that you were going to grow up, stop the sniping and work towards a united approach.
Can you just not help yourself?
Timmy old thing, do please stop being so unreasonably offensive.
David Roberts has kindly put the record straight and has made the official EAS viewpoint very clear. That is to support the continuance of the IMC rating.
It is hardly unreasonable to expect an EAS delegate at FCL.008 to promote the EAS viewpoint, just as the IAOPA delegate promoted the IAOPA viewpoint. My question is simply "Why didn't he?".
David Roberts has kindly put the record straight and has made the official EAS viewpoint very clear. That is to support the continuance of the IMC rating.
It is hardly unreasonable to expect an EAS delegate at FCL.008 to promote the EAS viewpoint, just as the IAOPA delegate promoted the IAOPA viewpoint. My question is simply "Why didn't he?".
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You said on Saturday that you were going to grow up, stop the sniping and work towards a united approach.
Beagle and David
I am very glad you asked and David has clarrified his position. I have to say that I was very uncomfortable where David stood - all credit to him for giving such a clear explanation and more importantly having the courage to enter into the discussion on this forum in the first place. It is a shame we do not see some of the other "players" so willing to subject themselves to public scrutiny. I take my hat off to David for having the courage of his convictions to engage with people on this and other forums. Thank you Dave.
That said, I would still like to know whether David sees the stance taken by Mr Thorpe as being compatible with position he now sets out and why he feels Mr Thorpe choose to publish his review of the work of FCL008 on PPL/IR rather than else where.
Fuji, you are probably confusing meetings. Timmy's quote has nothing to do with our EASA meeting.
At the meeting AOPA et al. had with Eric Sivel earlier in the week, I made it abundantly clear that, in my opinion, the final FCL.008 memorandum did not represent stakeholder opinion with regard to the IMC rating. That has now been positively confirmed de facto by David's statement.
It is clear that both EAS and IAOPA both support the UK IMC rating.
Unfortunately there are some individuals who continue to obfuscate and to throw smearing allegations at others, whilst making no worthwhile contribution of any material benefit whatsoever themselves. Sad, but true. But they can, of course, be ignored. And should be. I'm not a bible-basher by any means, but Matthew 7 vv3-5 spring to mind:
Whether EASA comes up with a so-called 'more easily attainable PPL / IR' is nihil ad rem. What is of much greater importance is that the UK IMC rating must continue to be acceptable in UK airspace, at the very least.
At the meeting AOPA et al. had with Eric Sivel earlier in the week, I made it abundantly clear that, in my opinion, the final FCL.008 memorandum did not represent stakeholder opinion with regard to the IMC rating. That has now been positively confirmed de facto by David's statement.
It is clear that both EAS and IAOPA both support the UK IMC rating.
Unfortunately there are some individuals who continue to obfuscate and to throw smearing allegations at others, whilst making no worthwhile contribution of any material benefit whatsoever themselves. Sad, but true. But they can, of course, be ignored. And should be. I'm not a bible-basher by any means, but Matthew 7 vv3-5 spring to mind:
And why beholdest thou the mote that is in thy brother's eye, but considerest not the beam that is in thine own eye? Or how wilt thou say to thy brother, Let me pull out the mote out of thine eye; and, behold, a beam is in thine own eye? Thou hypocrite, first cast out the beam out of thine own eye; and then shalt thou see clearly to cast out the mote out of thy brother's
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Whether EASA comes up with a so-called 'more easily attainable PPL / IR' is nihil ad rem.
No, I hadnt that meeting in mind.
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What is of much greater importance is that the UK IMC rating must continue to be acceptable in UK airspace, at the very least.
That is very unlikely to be in question! Its not the least which will be the lost opportunity but the most. The most without doubt will NOT be a European IMCR.
Pace
I'm not a bible-basher by any means, but ...
"give us serenity to accept what cannot be changed, courage to change what should be changed, and wisdom to distinguish the one from the other"
