CAA proposal for ANO amendments for EASA

[Pace]

Fiji
Under the present proposals the IMCR is already dead and buried.all the grandfathering rights do is to close a blind eye to some people carrying on a practice restricted to the uk.
There will be no IMCR as such ! No new PPLs of the future will be able to get one as it won't exist.
Some victory? Just a false olive branch given with a big laugh by EASA
Here there could be hope by taking EASA to court for endangering the lives of pilots by removing it without putting an equivalent safety rating for pilots in it's place.

PACE

[IO540]

My take is that some people will do the IR conversion, most won't (that is evident from speaking to FTOs; the conversions are running at a very low level) and over the next 2-3 years either the proposals will in effect melt down or there will be some political solution, in which case we may be able to abandon the new IRs and just let them lapse.

The problem is that it is not wise to rely on this if you need IFR capability seriously.

Of course all the assorted axe grinders reading this are laughing their heads off. FUD rules, as always.

[nick ritter]

Hello

Sorry if I sound like a complete moron – but can someone please help explain in English what is going to happen with the IMC post this April 2012 date?

If I have one – which I do – what do the new rules mean for me?

Will I be able to use its privileges in the UK going forward or is this a complete unknown still?

If it is scrapped what will happen when it is time to revalidate? Will those who have it just be able to continue to use it without any revalidation?

Sorry if this is somewhere buried in these past 5 pages, I have tried to read through most of it together with articles in various monthly magazines and still walk away having no idea

Thanks in advance

Nick

[IO540]

The short answer is that nobody knows.

It was scheduled to die in April 2012 but proved to be such a political hot potato that EASA has said it will be able to continue for those who already have it on that date.

No actual regulation has yet appeared saying this, but this looks like the most likely outcome.

[BEagle]

Currently the situation is unknown.

However:

1. Grandfathering of existing IMCR privileges is highly likely.
2. EASA will release their long-delayed FCL.008 NPA in the late summer.
3. If the NPA does not include a satisfactory solution for the future of IMCR privileges within UK airspace, EASA will be told to explain their failure to the European Parliament.
4. Never say never.

Very regrettably, the UK representatives on FCL.008 failed to be sufficiently assertive regarding the IMCR. This failure must not be repeated!

However, it will be possible to continue to include the UK IMCR in 'new-style' UK pilot licences for use ONLY on Annex II aircraft with Certificates of Airworthiness (e.g. Chipmunk, Tiger Moth, Bulldog).

[Pace]

10540

EASA have never said the rating can continue! Only that existing holders can continue to exercise it's privileges ! Subtle difference but a big difference. The IMCR will no longer exist.

Pace

[peregrineh]

I am about 1/3 through my IMCr - I am pressing ahead, a relative novice pilot I am only doing it to take myself to the next level and increase my understanding of flight - I have to say I am not overly keen on flying in IMC conditions!

[IO540]

Nobody actually likes to fly in IMC for extended periods, and it is hard work without an autopilot.

What it gives you is a big mission capability improvement, and a very big safety improvement generally because you can now plan every flight fully "IFR", navigate it using radio nav (GPS, etc) and complete it safely if the conditions happen to be not VFR.

Even if you like flying in nice weather, instrument capability is highly valuable and remains so even if you cannot use it legally abroad. Night flight, haze, etc can be 100% legit on a plain PPL but they require a full instrument flight capability to be done safely.

[englishal]

Reading this thread and others absolutely convinces me that I will never have anything to do with EASA pilot licensing or aircraft registration within the EU

I quite agree. If post 2012-2015 EASA make such and ARSA of themselves to effectively kick out foreign reg aeroplanes and certificates for EU residents then I will:

a) Become a non EU resident and continue to fly as per normal when I am home for 182 days per year AND dump all my EASA qualifications. (i.e. continue as I am now but not bother to have anything else to do with EASA). I will keep the aeroplane on the N reg.

or failing that

b) stop flying in Europe.

HOWEVER, if EASA was clever enough to come up with a simple conversion route to EASA equivalent certificates and mutual recognition and ease of implementing FAA STCs (as most aeroplanes are American), then I would convert and possibly put my aeroplane back on the G reg.

Actually regarding the EU - since the CAA came up with this wonderful ARC (Airworthiness Review Certificate - like a never expiring CofA), our annual costs when G registered went up 44% over night due to the £800+VAT ARC fee. This means that a "no rectification required" annual on a very simple SEP cannot be done for less than £3100 when VAT is taken into consideration (£1800 for the annual + ARC fee + VAT). I must say I am very glad not to be subject to this additional £1000 pa, so maybe I'd reconsider going back to the G reg....

[Justiciar]

very simple SEP cannot be done for less than £3100 when VAT is taken into consideration

Sounds right. Our very well cared for PA28-180 cost £5,100 for maintenance last year, to include a new beacon!

[BEagle]

The IMCR will no longer exist.

Pace, there is still time..... Either EASA wises up to fulfilling their political commitments or we 'go nuclear'...

[BillieBob]

since the CAA came up with this wonderful ARC (Airworthiness Review Certificate - like a never expiring CofA)

Actually, it was EASA that came up with the ARC, not the CAA.

[Jim59]

Nobody actually likes to fly in IMC for extended periods,

IO540

I love sweeping generalisations...

[IO540]

Life would be so boring if one had to caveat everything

Are you looking for an answer?

Out there, there is always somebody who enjoys something. I live below a hill, on top of which is a car park, and all night we see flashing lights up there. Even in +TSRA, they are up there doing their stuff. I have no idea what they are doing of course, but they seem to be quite determined

I quite like hand flying in IMC for practice but, operationally, for long distance flying, it is not the way to go if one has a choice, due to icing, turbulence, having to fly at/below Va, cannot avoid CBs unless one has radar, etc.

[bookworm]

However:
1. Grandfathering of existing IMCR privileges is highly likely.
2. EASA will release their long-delayed FCL.008 NPA in the late summer.
3. If the NPA does not include a satisfactory solution for the future of IMCR privileges within UK airspace, EASA will be told to explain their failure to the European Parliament.
4. Never say never.
Very regrettably, the UK representatives on FCL.008 failed to be sufficiently assertive regarding the IMCR. This failure must not be repeated!

You and Malone still repeat this misleading assertion. FCL.008 was not tasked with finding "a satisfactory solution for the future of IMCR privileges within UK airspace". The terms of reference are clear:

Review the existing JAR-FCL requirements for the Instrument Rating with a view to
evaluate the possibility of reducing these requirements for private pilots flying under
Instrument Flight Rules. This evaluation shall take into account the ICAO Annex 1 SARPs
for the issue of an IR.

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.

The "UK representatives" (as you put it) were not on FCL.008 to "be assertive regarding the IMCR". They were there, with everyone else, to find a solution that was a European rating. As you well know, the IMC rating does not fit the bill.

Subsequently, you and Martin Robinson have apparently got some commitment from EASA to retain IMC rating privileges within the UK. Congratulations. But that's a separate issue. You should not expect to find proposals for doing so in the FCL.008 NPA, as it was never part of its remit. It was tasked with thinking more broadly than you have been prepared to do, about the safety of GA pilots outside the UK, and how the safety benefits of instrument flying, which we have access to through the IMC rating in the UK, can be shared with them.

If you persist in decrying the progress that FCL.008 has made simply because they didn't agree exactly with your point of view, you risk ending up in a situation where there will be no IMC rating, and the IR will remain unattainable for PPLs.

[BEagle]

bookworm, Sivel gave the assurance at the Kingsway meeting in front of industry and the CAA.

Although the FCL.008 ToRs were poorly drafted, EASA's political assurance was later repeated to the European Parliament. The fact that they subsequently failed to ensure that FCL.008 needed to respect this assurance is wholly theirs.

The NPA, when it finally emerges, will be assessed against AOPA's declared policy.

[Pace]

Bookworm

In previous postings I was always opposed to trying to save the IMCR not because of it's proven safety benefits to the VFR pilot but because I felt it would detract from an achievable European PPL IR.
That should have been EASA s target and the best way of removing N Reg in Europe.
Sadly EASA has lost it's way from
It's mandate of safety and is so wrapped up in it's own bureaucracy, rulemaking and self interest that it is now threatening the lives of pilots by it's political rulemaking.
There is no reason on earth why EASA could not copy the FAA PPL IR in total bar European Airlaw but sense doesn't come into their dictionary.
We have been promised so many things only to find that they were empty promises to appease the people they are supposed to represent and to smooth the way for passage through to law for their own ends not aviations good.

[IO540]

Sivel gave the assurance at the Kingsway meeting in front of industry and the CAA.

I was at the meeting and wrote up some detailed notes afterwards, which I posted in ppl/ir (and anybody can have them if I can find them).

Sivel said a lot of things, including direct answers to my questions afterwards, but he says a lot of different things to a lot of people. Like Goudot, the overwhelming evidence is that neither can be trusted as far as you can throw them. But neither of them actually runs EASA; the outfit is driven by several other people also, and they have their own other personal agendas...

There is no reason on earth why EASA could not copy the FAA PPL IR in total bar European Airlaw

This is not possible precisely because it is American. The whole thrust of EASA is to stick a finger up to America, to force them to sign various treaties on the EU table.

Unsuprisingly, America is not too keen on this kind of thing, especially as they can so clearly see that EASA hardly speaks for the countries which signed up for the con called the "Common Market" all those years before, and this is even before the effective disintegration of the EU which we are seeing today, where more than half the countries would leave if they could, but they can't because the whole edifice has been set up so that if somebody leaves, the whole lot comes crashing down.

[bookworm]

In previous postings I was always opposed to trying to save the IMCR not because of it's proven safety benefits to the VFR pilot but because I felt it would detract from an achievable European PPL IR.

I agree. If done in the wrong way, a campaign to save the IMCR might well detract from an achievable European PPL IR. But I don't see why the two campaigns, if carried out constructively and reasonably, could not work side by side.

Both you and IO540 read a malicious intent into the issue that is absent in reality. EASA is overstretched and underfunded, and wants the simplest and quickest possible solution to any problem consistent with what it believes (sometimes mistakenly) is safety. In the case of FCL, the simplest and quickest solution was transposing JAR-FCL. But the issue of the gold-plated IR was highlighted in FCL.001, and so we got FCL.008 to deal with it. A source close to EASA suggested to me that without the complications of the IMC rating rant and the enroute IR proposals, this would be done and dusted by now. But it's not, and now there's a real possibility that the baby is thrown out with the bathwater, because EASA doesn't have the time and attention to deal with it properly.

The NPA, when it finally emerges, will be assessed against AOPA's declared policy.

As far as I can read, AOPA UK policy is:

1) Support for the concept of an EASA part FCL/ICAO level IR with proportionate theoretical knowledge requirements.

2) Opposition to any future instrument qualification which does not include approach privileges.

3) Insistence upon the retention of UK IMCR privileges within UK airspace

4) Recommendation for the benefits of the UK IMCR be clearly explained to the rest of the EC

Provided 2 (I wonder who pushed for that one ) is not allowed to eclipse 1, and you don't expect 3 to be part of the FCL.008 NPA, I can't see a problem.

[englishal]

EASA is overstretched and underfunded, and wants the simplest and quickest possible solution to any problem consistent with what it believes (sometimes mistakenly) is safety.

Why does it take EASA so long? Why is it under-funded? Is it because it has to employ vast quantities of faceless bureaucrats who draw a salary and expenses to draft silly, unworkable documents?

It I were the boss of some company drafted with designing a new flight safety system in Europe, I'd ask the FAA for help seeing as the FAA has a) the most number of pilots in the world under their oversight, b) the most number of aircraft under their oversight, c) VAST experience in rule making and enforcing, d) huge experience in all things aviation.

In fact I'd ask for their cooperation in trying to implement a similar system in Europe and even negotiate with the FAA to technical assistance and offer in exchange bilateral agreements to make a seemless transition between Euro and North American airspace (surely the volume of CAT between Europe and NA is the highest in the world after all).

But it is not about airsafety - it is about trade and protectionism.