So how would the IMC rating be grandfathered?
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So how would the IMC rating be grandfathered?
The CAA FAQ says we'll have to wait and see how the IMC rating will be dealt with by EASA. AOPA feel confident that the verbal assurances given so far by EASA will be honoured.
But there isn't any indication of how this would be implemented.
I wondered if it would be helpful to have a clear proposal or understanding of what the options are and of what the PPL/IMCr holders would prefer (ignoring the leave as is option which might be everyone's first choice).
The main factors are probably the two types of licence JAR/UK and type of aircraft EASA/non-EASA
Those with the rating today would either have it on a UK CAA or JAR licence. For the JAR, which automatically becomes an EASA licence, would the existing rating simply be recognised or will a separate UK licence also be needed?
For those with CAA UK licence today, perhaps this could be used as now, but would need a EASA licence after the derogation period.
I can't quite figure out if the use of a rating on a separate national licence could be used at the same time as an EASA licence to fit an EASA aircraft. I guess it can be whatever is enacted in the ANO.
But there isn't any indication of how this would be implemented.
I wondered if it would be helpful to have a clear proposal or understanding of what the options are and of what the PPL/IMCr holders would prefer (ignoring the leave as is option which might be everyone's first choice).
The main factors are probably the two types of licence JAR/UK and type of aircraft EASA/non-EASA
Those with the rating today would either have it on a UK CAA or JAR licence. For the JAR, which automatically becomes an EASA licence, would the existing rating simply be recognised or will a separate UK licence also be needed?
For those with CAA UK licence today, perhaps this could be used as now, but would need a EASA licence after the derogation period.
I can't quite figure out if the use of a rating on a separate national licence could be used at the same time as an EASA licence to fit an EASA aircraft. I guess it can be whatever is enacted in the ANO.
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Please get it into your head that under EASA there will not be any form of IMCR its dead, buried, capput, gone.
No new PPLs will be able to go along and say "Can I get an IMCR please in the UK?".
It doesnt exist! All that EASA have said is that as far as they are concerned existing IMCR pilots in the UK can carry on with its privalages! That is very different to a recognised rating in Europe or the UK! It will no longer exist.
End of story!
Pace
No new PPLs will be able to go along and say "Can I get an IMCR please in the UK?".
It doesnt exist! All that EASA have said is that as far as they are concerned existing IMCR pilots in the UK can carry on with its privalages! That is very different to a recognised rating in Europe or the UK! It will no longer exist.
End of story!
Pace
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Even as "grandfathered; rights, I don't see how one could attach the rating to an EASA licence. IF it isn't attached to an EASA licence, how will the bi-annual check ride be administered?
One possible option:
1. The European Parliament sanctions the provisions of JAR-FCL 1.175(b) being taken into European Law. Including the same restrictions of use as currently apply.
2. National authorities issue the relevant 'EASA' IR (and IRI for suitably qualified FIs) with the caveat 'Restricted UK' - the restrictions being identical to those currently in place for the IMCR (and, for the IRI (Restricted UK), the requirements for removal of the 'no applied instruments' restriction).
But all rather too easy for the 'Befehl ist Befehl' people of the Tower of €urobabble in Köln!
The FCl.008 NPA isn't now expected until September 2011; there is an intention to hold some form of 'workshop' intended to 'streamline the process' - we must ensure that this does not inhibit the normal comment response procedures!
It will be possible to add a UK IMCR to a United Kingdom pilot licence even after the leaden hand of €urocracy has descended upon us - but for use only on non-EASA aircraft....
1. The European Parliament sanctions the provisions of JAR-FCL 1.175(b) being taken into European Law. Including the same restrictions of use as currently apply.
2. National authorities issue the relevant 'EASA' IR (and IRI for suitably qualified FIs) with the caveat 'Restricted UK' - the restrictions being identical to those currently in place for the IMCR (and, for the IRI (Restricted UK), the requirements for removal of the 'no applied instruments' restriction).
But all rather too easy for the 'Befehl ist Befehl' people of the Tower of €urobabble in Köln!
The FCl.008 NPA isn't now expected until September 2011; there is an intention to hold some form of 'workshop' intended to 'streamline the process' - we must ensure that this does not inhibit the normal comment response procedures!
It will be possible to add a UK IMCR to a United Kingdom pilot licence even after the leaden hand of €urocracy has descended upon us - but for use only on non-EASA aircraft....
One hopes not in its current form, given that the EIR is 1/3rd more training, for the ability to fly IMC en-route only, with no approaches.
I can't honestly see how you can safely teach and permit somebody to fly IMC en-route without the ability to fly an approach?
G
I can't honestly see how you can safely teach and permit somebody to fly IMC en-route without the ability to fly an approach?
G
Even Australia, the only country which currently has an 'EIR' (the 'Private IFR'), allows the inclusion of 'Flight Procedure Authorisations' (which may include instrument approach privileges) within the Rating - most schools refuse to train for the PIFR without FPAs!
Quite what the FCL.008 NPA will include is not yet known. Extended discussion about the so-called 'EIR' at this stage is nugatory.
Quite what the FCL.008 NPA will include is not yet known. Extended discussion about the so-called 'EIR' at this stage is nugatory.
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I think that if one looks purely at the extra privileges, I think the EIR proposals (from the little that has come out about them) are very useful, because this rating would transform the ability to do long distance VFR flights across Europe.
On a plain PPL, you are constrained all along the route by ATC allowing you into CAS. So the flight becomes a sequence of "negotiating sessions", where you beg each controller to let you into his private piece of CAS. The obvious alternative - sticking to Class G - is usually impractical (on a long route e.g. UK to Croatia) because it forces you to do massive doglegs, and silly stuff like flying 1000ft above the Alps, at FL129.
With the EIR, the pilot gets the whole-route clearance implicit on a Eurocontrol flight plan. So he can do a very smooth and predictable high altitude flight, above the clouds, on oxygen, etc.
But, like the plain PPL, he is not authorised to request an instrument approach (short of a mayday).
What I cannot see is how this will fit into the grand scheme of things in practice, firstly because an IFR approach controller naturally expects traffic to make the classic IFR transition from enroute to STAR to IAP (or the radar vectored version). Whereas an EIR holder will often complicate his life by requesting a radar letdown to the base of the MVA (but still trying to land at the same runway as everybody else) but no lower because that would be an "SRA" which is not allowed and, if not visual then, will either end up doing a DIY letdown and cause some big hassles, or declare an emergency and go for the official approach.
The training of the "strategy" would also be interesting. The more advanced PPL holders have developed various ad hoc strategies, which are not taught anywhere. A lot of these involve DIY letdowns.
Obviously instrument approaches will have to be trained otherwise this rating would be a death sentence for many. But then you get the standard flight training dilemna: if you train something too well, the pilot might use it, but he can't legally do so. This is why instrument flight in the PPL is limited to a 180-deg escape route - a disingenuous ignorance of the fact that clouds don't really care what papers you have
But we have done this one to death so many times. After the original EASA-sanctioned info release, nothing else has come out and nobody actually knows what the proposal will look like.
Re the IMCR, I am sure the UK CAA will find a fudge, which they would be fools to publish until the last minute.
EASA's authority is going to decline continuously over the next few years, so keeping your powder dry is a smart move.
On a plain PPL, you are constrained all along the route by ATC allowing you into CAS. So the flight becomes a sequence of "negotiating sessions", where you beg each controller to let you into his private piece of CAS. The obvious alternative - sticking to Class G - is usually impractical (on a long route e.g. UK to Croatia) because it forces you to do massive doglegs, and silly stuff like flying 1000ft above the Alps, at FL129.
With the EIR, the pilot gets the whole-route clearance implicit on a Eurocontrol flight plan. So he can do a very smooth and predictable high altitude flight, above the clouds, on oxygen, etc.
But, like the plain PPL, he is not authorised to request an instrument approach (short of a mayday).
What I cannot see is how this will fit into the grand scheme of things in practice, firstly because an IFR approach controller naturally expects traffic to make the classic IFR transition from enroute to STAR to IAP (or the radar vectored version). Whereas an EIR holder will often complicate his life by requesting a radar letdown to the base of the MVA (but still trying to land at the same runway as everybody else) but no lower because that would be an "SRA" which is not allowed and, if not visual then, will either end up doing a DIY letdown and cause some big hassles, or declare an emergency and go for the official approach.
The training of the "strategy" would also be interesting. The more advanced PPL holders have developed various ad hoc strategies, which are not taught anywhere. A lot of these involve DIY letdowns.
Obviously instrument approaches will have to be trained otherwise this rating would be a death sentence for many. But then you get the standard flight training dilemna: if you train something too well, the pilot might use it, but he can't legally do so. This is why instrument flight in the PPL is limited to a 180-deg escape route - a disingenuous ignorance of the fact that clouds don't really care what papers you have
But we have done this one to death so many times. After the original EASA-sanctioned info release, nothing else has come out and nobody actually knows what the proposal will look like.
Re the IMCR, I am sure the UK CAA will find a fudge, which they would be fools to publish until the last minute.
EASA's authority is going to decline continuously over the next few years, so keeping your powder dry is a smart move.
Obviously instrument approaches will have to be trained otherwise this rating would be a death sentence for many.
Please remember that any formal 'EIR' proposals are as yet unknown.
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It could be grandfathered the way the CAA deal with people who have an IMC rating based on a foreign IR. I have a bit of paper in my license wallet stating that (or something like) "The holder of UK/PP/ASDCBFG is exempt from the requirments of the ANO section XYZ for the requirement to have passed an IMC rating flight test".
I don't see why they can't print something similar stating "The holder of EASA license XYZBDHBDEB is exempt from some bit of the ANO and is allowed to fly IFR in class D airspace and below while in UK airspace".
I don't see why they can't print something similar stating "The holder of EASA license XYZBDHBDEB is exempt from some bit of the ANO and is allowed to fly IFR in class D airspace and below while in UK airspace".
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What the CAA can't do is do something which explicitly contravenes some EU law. But that still leaves loads of options.
And the bottom line is that the UK can do what it likes and the EU is (especially these days) not going to do anything about it.
And the bottom line is that the UK can do what it likes and the EU is (especially these days) not going to do anything about it.
Here is a view; I can't say that I agree with some big chunks of it, and if this is the fellow who was attending EASA meetings for Europe Airsports and PPL/IR, I can see why there was so much fuss. Regardless, and despite disagreeing with a lot of it, it's worth reading to aid your understanding of the position.
G
G
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That article does not appear to be dated but is probably well over a year old.
This is not meant as a pos or neg comment but a year is an awfully long time in politics, especially in EASA politics which runs mostly on horse trading of unconnected propositions.
The FCL008 IR has a great promise but it has a long passage ahead of it.
This is not meant as a pos or neg comment but a year is an awfully long time in politics, especially in EASA politics which runs mostly on horse trading of unconnected propositions.
The FCL008 IR has a great promise but it has a long passage ahead of it.
