IMC Rating - Lobby your MP

[Mike Cross]

The following has been produced by AOPA UK as a suggestion for lobbying your MP, elements of it will also be of use elsewhere.

You can easily find out who your representatives are by clicking here.

SAVING THE IMC RATING – THE SALIENT POINTS WHEN WRITING TO YOUR MP

Explain why you did an IMC Rating and add any personal experiences that you may have had with it.

Include some or all of the points below as well as any you think will help this cause.

EASA does not want to ban the IMC rating. It has worked to obtain a European consensus on it, but some countries don’t agree.

The IMC rating is one of the significant factors contributing to the UK’s high GA safety rate, which is far better than the rest of Europe - France has some 90 fatalities a year, Germany about 80, the UK 20 to 25.

It is designed to save low-time pilots from the consequences of running into bad weather, a greater problem in the UK than in most of the rest of Europe because of our maritime climate.

The abolition of the rating is an unintended consequence of an administrative change. It is not a matter of standards or safety – quite the opposite. It is a matter of bureaucratic tidiness, and it calls for a political solution.

The CAA has been operating the rating for 40 years, during which time it has been audited at least 20 times by the International Civil Aviation Organisation, which has never expressed any concern.

There is no credible suggestion that it is unsafe, and there is a mountain of evidence that it makes better pilots and has saved many lives.

The IMC rating is supported by every major aviation organisation in Britain, from the British Air Line Pilots Association to the General Aviation Safety Council and the Guild of Air Pilots and Air Navigators.

While EASA is still discussing the rating, it cannot adopt it without the unanimous agreement of 27 states. An administrative omission currently prevents the UK from offering the rating to British pilots in UK territory. A device must be created to allow this, and this must be arranged through the political process.

[Fuji Abound]

I think this is an excellent initiative and everyone should make the effort to put pen to paper.

It is only a letter.

We have all moaned about it enough.

It is time to do something about it.

I think everyone who writes should post on this thread something along the lines:-

LETTER NOW GONE

[my_business]

Good Job
but to mach worry for something that is not going to end !

IMC remains

Something from inside.

Happy New Year!!

[S-Works]

ah, another sciolist.

[my_business]

I love you too.
Good to know who is who.
Maybe i`m but hei ..my_business

Just wait and see!

[Pace]

My business

There is NOT a chance that the IMCR will be removed from the UK I totally agree with you.

There will be dancing in the streets, we saved the day! victory! when in reality there never was a risk of loosing it.

What we will have lost is the greater prize of a far more achievable European IR. We have been fighting the wrong battle.

Pace

[Islander2]

What we will have lost is the greater prize of a far more achievable European IR. We have been fighting the wrong battle.

Hopefully, the two will not prove mutually exclusive; and there's no fundamental reason they should if the IMCR campaign is focused on its retention as a UK-only rating.

If they do conflict, however, it's too much to hope that the vocal masses in support of the IMCR will appreciate how much more important an FAA-style IR could potentially be to European GA, if (and that's a massive 'if') it were conducive to achieving anything like a US percentage of IR-rated private pilots across Europe. Sad to say, this is a once in a generation opportunity that could be blown if the puerile level of argument exhibited in February's Pilot Magazine encroaches on the EASA debate.

[AdamFrisch]

Islander2 - I could not agree more.

All this energy spent on keeping the IMCr should have been spent lobbying JAA to get an achievable IR instead. We must stop being so insular and inwards looking and realize we're part of JAA and will be so for a long time. Let's make it better, influence it, make it good.

Because, fully implemented, and with a US style IR the JAR licenses could be a tremendous thing. Total freedom to work and fly anywhere in the world without hassle, pretty much. Renewable anywhere etc. That's something to strive for.

[Mike Cross]

I have no idea why people should feel that campaigning to save the IMC will have any detrimental effect at all on a more readily achievable EASA compliant IR. There is a general consensus across EASA land that we should have one and all the indications are that the NPA when it comes out will propose one and AOPA is on record as supporting it.

Those who hold the UK rating are naturally concerned at potential loss of their hard-earned privileges.

[derekf]

It's important to separate lobbying MPs and the work AOPA is doing in trying to get the IMCR rating kept in some way in the UK from the work going on in FCL008 (which includes AOPA representative) to generate an NPA for a more attainable IR.

Both sets of efforts/campaigns need supporting and one should not confuse the two.

[Cacophonix]

Because, fully implemented, and with a US style IR the JAR licenses could be a tremendous thing. Total freedom to work and fly anywhere in the world without hassle, pretty much. Renewable anywhere etc. That's something to strive for.

Amen to that (what a wonderful world that would be) but failing this the IMC should remain!

As for the Pilot Magazine article it seems that what was argued there was that while a European rating that allowed 'en route' IFR would be a step forward, a rating that did not emphasise the significant details (and skills) of an instrument approach and landing could be a license to kill oneself (or did I miss the point)?

[Islander2]

Originally Posted by Mike Cross

I have no idea why people should feel that campaigning to save the IMC will have any detrimental effect at all on a more readily achievable EASA compliant IR.

The problem potentially arises only, I believe, if the great uninformed on this subject lobby their MPs without making the vital distinction urged by derekf (post #10 above) and, in so doing, cause a shift in focus of the IMCR campaign to one of trying to get it accepted as an EASA Europe-wide rating. It is perhaps regrettable that the 'lobby your MP' briefing note makes this distinction rather inadequately and in a way that's likely to be overlooked by many.

In most European countries where, unlike the UK, Class-A airways are not the norm, there would be little practical distinction in the privileges of a UK-style IMCR (with its 15 hours minimum instrument time) and an ICAO-compliant IR (requiring 40 hours minimum instrument time): just the higher absolute minimum visibility criterion of 1800m for take-off/landing (cf 800m landing and 150m take-off for ICAO IR in a SPA, unless using a suitably low-height-certified autopilot). It is, therefore, in my opinion (and in the opinion of many others who have thought about this seriously), impossible for the two ratings to coexist across Europe. Any attempt to get them to coexist on a pan-European scale will inevitably result in a significant reduction in priviliges for the IMCR holder.

And the potentially detrimental effect of that, Mike, is EASA viewing a downgraded IMCR as a possible substitute for the more accessible ICAO-compliant IR that FCL.008 has proposed.

Which is not the same as claiming that retention of the IMCR as a UK-only rating is an unworthy objective ... indeed, IMHO it is worthy of the very best fight AOPA UK can muster. Nobody with an interest in achieving this objective should take on trust from my_ business and Pace that this is a fait accompli.

[FREDAcheck]

Islander2,

I'm sure you are not suggesting that IMCR holders are uninformed. (Who are you suggesting is uninformed, by the way?).

However, when I write to my MP I shan't be mentioning the IR, as in my view it doesn't really help to try to address multiple issues in one letter. Better to try to cover one issue succinctly.

[Islander2]

I shan't be mentioning the IR, as in my view it doesn't really help to try to address multiple issues in one letter. Better to try to cover one issue succinctly

Well, that's already completely missed the point I was making, which has nothing to do with mentioning the IR but everything to do with being clear on the objective of the lobbying, i.e for the IMCR to be retained as a UK-only rating not for it to be adopted European-wide.

[FREDAcheck]

Islander2, I'm not sure I understand you because I'm not "...making the vital distinction urged by derekf (post #10 above)..." as it's not relevant.

However I agree with derekf's point:

It's important to separate lobbying MPs and the work AOPA is doing in trying to get the IMCR rating kept in some way in the UK from the work going on in FCL008 (which includes AOPA representative) to generate an NPA for a more attainable IR.

I think FCL.001 and .008 are quite capable of dealing with the latter issue, but have deemed (we keep being told) that a Euro-wide IMCR is impossible, even though it's in the remit of FCL.008 (Irv Lee has some pretty cutting things to say about that in the flyer AOPA forum).

Therefore the laudable goal of a Euro-wide IMC rating is, alas, beyond the reach of most European pilots. It might just be possible for us to continue it in the UK.

[Mike Cross]

Islander2

AOPA is suggesting people lobby their MP's not their MEP's

EASA does not want to ban the IMC rating. It has worked to obtain a European consensus on it, but some countries don’t agree.

While EASA is still discussing the rating, it cannot adopt it without the unanimous agreement of 27 states. An administrative omission currently prevents the UK from offering the rating to British pilots in UK territory. A device must be created to allow this, and this must be arranged through the political process.

The proposal accepts that there is opposition to it being adopted EASA wide and that therefore it won't be. It suggests that a device must be created to allow it as a UK only rating. You're absolutely right regarding the airspace issues, the current privileges are based on the UK system of airspace classification and would not be workable across EASA. The decision not to harmonise lower airspace classifications means that priviliges based on ot can't work.

That said, here's an alternative approach of my own

There might be scope for wording similar to that proposed for the Mountain Rating

From the NPA from FCL001:-

"FCL.815 Mountain ratings
(a) Privileges. The privileges of the holder of a wheel mountain rating or a ski mountain rating are to
conduct flights to and from surfaces designated as requiring such a rating by the appropriate
authorities designated by the Member States."

Given that what is to prevent an NPA that says
""FCL.xxx IMC rating
(a) Privileges. The privileges of the holder of an IMC rating are to conduct flights in circumstances that require compliance with the Instrument Flight Rules in national airspace where such a rating may be used as defined by the appropriate authorities designated by the Member States."

That way the UK CAA could designate Class D and downwards and everyone else could do whatever they want (including not designating any airspace) - simples!

[Whopity]

All this energy spent on keeping the IMCr should have been spent lobbying JAA to get an achievable IR instead.

I have an achievable IR, obtained in the good old days of unapproved training (do as much as you need to pass the test). That does not alter the fact that the cost of maintaining it is high compared to maintain IMC privileges which is zero if you hold a UK professional licence.

Many FIs; FICIs; FEs and even FIEs operate on the basis of in-built privileges; they do not fly airways and therefore do not need to maintain a current IR, its simply not cost effective. A number hold a MP IR but not a SP IR.

The proportion of PPL holders who would attempt an achievable IR is likely to be considerably lower than the number who attempt an IMC rating, so the net result will be more pilots with less instrument training. That will lead to more DEAD bodies!

Whilst I would support a more ICAO based approach to the IR, we must not do that at the expense of a rating that has improved safety for the majority.

[Pace]

Whopity

The point we are all missing is that on safety grounds the IMCR was never in threat. Who would take the responsability for just one death because the rating had been removed in our liability culture?

What always had a big question mark was expanding the IMCR into other European Countries or getting them to accept anything which had the privalages we enjoy in the UK.

So those who will wave flags that the IMC has been saved in the UK have kidded themselves big time. Their battle lines and save the IMCR committees are a joke and a sad one at that.

The question that should be is what have we achieved in making access into Europe in anything but VFR weather more achievable for the PPL and in these days of high cost in an economical and time effective way?
The answer to that is NOTHING.

That is the biggest lost opportunity and biggest chasing of a Red Herring I know!!! So what are we supposed to be Lobbying our MPs MEPs for???

[mm_flynn]

Originally Posted by Whopity

Many FIs; FICIs; FEs and even FIEs operate on the basis of in-built privileges; they do not fly airways and therefore do not need to maintain a current IR, its simply not cost effective.

??? what is the cost beyond a 1 hour per year check flight (and of course the level of practice necessary to maintain the skills to pass a check ride).

This is not taking away anything from AOPA's very good framework and a movement forward to actually doing something positive to influence the political process!

I would second Islander's point that maintaining a focus on the (IMHO) achievable objective of allowing the UK IMCr to continue in UK airspace is critical.

[IO540]

The proportion of PPL holders who would attempt an achievable IR is likely to be considerably lower than the number who attempt an IMC rating, so the net result will be more pilots with less instrument training. That will lead to more DEAD bodies!

Whilst I would support a more ICAO based approach to the IR, we must not do that at the expense of a rating that has improved safety for the majority.

So much of this debate has been turned over and over here and elsewhere that it's hard to say anything relevant

But one thing not often mentioned is that - taking UK IFR flight as a whole - the IR has a much narrower applicability than the IMCR. The IMCR is usable by the spamcan rental/syndicate scene, whereas the IR is much less so, due to insufficient airways-flight equipment.

This is because in the UK Class G one can fly IFR freely, with almost no specified equipment and in practice a handheld GPS does the job. And even if non-radio IFR in Class G was banned, it could never be enforced so anybody doing it will carry on doing it. One doesn't need an IR for this. The IMCR is practically required for landing on an official instrument approach, but enroute nobody knows what you are doing.

The IR is applicable to aircraft owners who tend to carry better equipment and fly "proper IFR". My guess that in the UK there are no more than a few hundred of these.

The question then becomes: what if the IR was as accessible as the IMCR? Well obviously then there would be no difference, but this is not going to happen! For example the IR annual test is always going to be harder than the IMCR one.