EASA AND THE IMCR - NEWS
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CAD test - This is amazing news. I just saw an example on You Tube and while of course you can't trust the colours on You Tube, it was fascinating to see how much I could follow. How long can you "miss" in the test? Any idea?
Deadline - My understanding now, if I understand it right, is that the IMC finishes on the 8th April 2012 for good and that if you want to get the rating you must have your rating approved and added by the CAA by that date. Also AOPA made a comment that I found, that said that EASA had confirmed grandfather rights for IMC holders so I'm hoping that is correct.
As always though, isn't it frustrating how hard it is to find simple answers! Thank you guys, without there being such a great community no one would be able to work out anything.
Deadline - My understanding now, if I understand it right, is that the IMC finishes on the 8th April 2012 for good and that if you want to get the rating you must have your rating approved and added by the CAA by that date. Also AOPA made a comment that I found, that said that EASA had confirmed grandfather rights for IMC holders so I'm hoping that is correct.
As always though, isn't it frustrating how hard it is to find simple answers! Thank you guys, without there being such a great community no one would be able to work out anything.
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I don't think anybody really knows, but having a recently validated IMCR in April 2012 would not be a bad idea.
In this business, much hangs on grandfather privileges and various other paper collection devices.
Flying itself is relatively easy
In this business, much hangs on grandfather privileges and various other paper collection devices.
Flying itself is relatively easy
....EASA had confirmed grandfather rights for IMC holders....
is it correct that the IMC will need to have a current renewal at the 8th April date?
What is quite clear from the latest NPA is that in order to obtain "grandfather rights" the holder of the rating will have to meet the JAA IR standard
As IMC rated pilots are not trained to the IR standard, very few will achieve any grandfather rights without spending a considerable amount of money. The Test will be conducted by an IRE, who charge twice as much as existing PPL FEs, and be twice as frequent (12 as opposed to 25 months), resulting in a price hype by a factor of 4 to begin with.
It is highlighted in this Regulation that Member States should aim at allowing pilots to, as far as possible, maintain their current scope of activities and privileges. The Agency already discussed this issue with the CAA UK and industry experts in order to identify possible options for UK IMC holders. The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held. This would allow the existing UK IMC holders to continue to exercise their IMC privileges.
A high uniform level of safety is ensured by requiring the applicants to pass exactly the same skill test as established already for the IR in Part-FCL.
Sub Judice Angel Lovegod
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Whopity,
I think that your argument is entirely misguided. The authorities are finding a convenient way to package IMCR privileges into a constrained EASA world.
The IMCR will remain the IMCR in all but name.
As I understand it, all IMCRs, current or not, will be grandfathered. But any which way, the CAA has no history of applying a new FCL regime at zero notice. If they say that IMCRs have to valid on a certain day to be grandfathered, there will be enough notice for people to get renewed by that date.
What I find a bit sad about all this paranoia is that the CAA has never behaved as dishonourably as posters are suggesting. Essentially they support the IMCR, and are doing their best to retain it. EASA are co-operating in that venture. Why do we have this constant background noise of "they must be out to cheat us"?
The officials in the CAA are probably reading this thread. They are real people, with homes and families, trying to do their jobs in our best interests despite EASA pressure. Demonising them like this must be making them wonder why they bother.
I think that your argument is entirely misguided. The authorities are finding a convenient way to package IMCR privileges into a constrained EASA world.
The IMCR will remain the IMCR in all but name.
As I understand it, all IMCRs, current or not, will be grandfathered. But any which way, the CAA has no history of applying a new FCL regime at zero notice. If they say that IMCRs have to valid on a certain day to be grandfathered, there will be enough notice for people to get renewed by that date.
What I find a bit sad about all this paranoia is that the CAA has never behaved as dishonourably as posters are suggesting. Essentially they support the IMCR, and are doing their best to retain it. EASA are co-operating in that venture. Why do we have this constant background noise of "they must be out to cheat us"?
The officials in the CAA are probably reading this thread. They are real people, with homes and families, trying to do their jobs in our best interests despite EASA pressure. Demonising them like this must be making them wonder why they bother.
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Controversial...
Timothy you've got a great point on this. Although perhaps rather than all of this
its more a plea for information that is less than forthcoming. I would much prefer some sort forum where the CAA clearly and frequently provides updates on this matter. Understandably the EASA changes involve a lot more than GA and the IMCR; but a little information or a statement on the CAAs intent would keep many of us warm and fuzzy.
Now, sit comfortably with a stiff tipple because I fear what I'm about to suggest is probably going to upset the apple carts of some readers...
(My emphasis)
To me this reads that the IMCR will become an 'IR-Restricted'. This term has been bandied about previously and probably will be again. So I feel a comparison is needed (and this is where unpopularity begins).
Not ideal but the best way I can think of comparing this is to the FI rating. An FI is an FI; with or without restrictions. For example, FIs may have 'no night' or 'no applied instrument'. Does this mean that they cannot instruct? No. In the sense of IMCR/IRs the restrictions would reflect what we are already doing, UK OCAS only, IAPs permitted UK only.
IO540 has stated here what I was afraid of saying. Both the IMCR and IR are similar. It is the extra 35 hours required for a full IR that causes contention, and of course 35 hours can be completed in a sim! However IMCRs are not for the commercial airline crew. They are for the GA community that want to be able to fly on PPLs when the weather is less than perfect to hour-build? Go places? Travel for work? As an addition to IO540s comment above, I was taught SIDs, STARs (as far as possible, and actually my approach for the IMC flight test was a STAR), and flew to an IR standard for probably 70% of the training, a credit to my instructor and what a fantastic job he did! I like to think every instructor that teaches something so safety critical, leaves questions of training standards irrelevant. The content of the IR is all encompassing, and so it should be if you want to sit in front of 300 paying passengers or more, 6 miles skyward, hurtling along at 500mph, without looking where you are going! 
background noise of "they must be out to cheat us"
Now, sit comfortably with a stiff tipple because I fear what I'm about to suggest is probably going to upset the apple carts of some readers...
Quoted by Whopity
The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held.
The most favourable solution seems to be that a Part-FCL licence and an IR will be issued with certain conditions on the basis of a specific conversion report in order to reflect the current privileges held.
To me this reads that the IMCR will become an 'IR-Restricted'. This term has been bandied about previously and probably will be again. So I feel a comparison is needed (and this is where unpopularity begins).
Not ideal but the best way I can think of comparing this is to the FI rating. An FI is an FI; with or without restrictions. For example, FIs may have 'no night' or 'no applied instrument'. Does this mean that they cannot instruct? No. In the sense of IMCR/IRs the restrictions would reflect what we are already doing, UK OCAS only, IAPs permitted UK only.
Posted by IO540
One is not allowed to state the truth that the UK IMCR is a full IR in all but name, and only the UK's extensive Class A separates the "amateurs" from the "pros". An IMCR holder who has been trained by a real IFR-flying instructor will be able to fly any published approach plate for any airport in the world. SIDs and STARs are not covered but are relative trivia. Nearly the entire difference between the IMCR and the IR is the currency of the holder and his aircraft capability and equipment, but that is nothing to do with the bits of paper.
One is not allowed to state the truth that the UK IMCR is a full IR in all but name, and only the UK's extensive Class A separates the "amateurs" from the "pros". An IMCR holder who has been trained by a real IFR-flying instructor will be able to fly any published approach plate for any airport in the world. SIDs and STARs are not covered but are relative trivia. Nearly the entire difference between the IMCR and the IR is the currency of the holder and his aircraft capability and equipment, but that is nothing to do with the bits of paper.
Posted by Whopity
As IMC rated pilots are not trained to the IR standard
As IMC rated pilots are not trained to the IR standard
Last edited by GeeWhizz; 12th Nov 2011 at 00:03.
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The officials in the CAA are probably reading this thread. They are real people, with homes and families, trying to do their jobs in our best interests despite EASA pressure. Demonising them like this must be making them wonder why they bother.
I can see his point. It seems to me that if the French can just pull an IR out of thin air just because they wish to (apparently without endless months of committees, debates, meetings etc...)and seemingly get no complaints from Europe, then the CAA could have just said from day 1) "The IMCR will be grandfathered for existing holders" or "The IMCR will remain in place for use in UK airspace". Maybe the French weren't following the rules to the letter, but so what.
Anyway I am not complaining, I have a valid IMCr, based on a foreign IR.
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What is quite clear from the latest NPA is that in order to obtain "grandfather rights" the holder of the rating will have to meet the JAA IR standard
The content of the IR is all encompassing, and so it should be if you want to sit in front of 300 paying passengers or more, 6 miles skyward, hurtling along at 500mph, without looking where you are going
It seems to me that if the French can just pull an IR out of thin air just because they wish to (apparently without endless months of committees, debates, meetings etc...)and seemingly get no complaints from Europe
What I find a bit sad about all this paranoia is that the CAA has never behaved as dishonourably as posters are suggesting.
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The restricted privileges IR seems to me to be an ideal solution as it reflects the UK reality that IMCR holder can do anything an IR holder can do except fly IFR in Class A, B or C. If the restrictions are stated in those terms and the UK limit conveniently forgotten, then the Class E airways and class D airports of Europe would be available too 
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That's because the new French IR is not an EASA FCL qualification, just as the IMCr isn't. They won't be valid under EASA FCL and will need a conversion deal also. The UK could also pull such an IR out of thin air too, at present, because EASA FCL is still not in force and won't be until next spring with the variations transition periods following.
I think that your argument is entirely misguided
One subtle difference - the French IR "lite" will be so far as I understand it, ICAO compliant - so useable worldwide, whilst the IMCR isn't and won't be.
Individual states have the right to do their own ICAO compliant things and because it's ICAO compliant allow it to be used worldwide.
There are a lot of examples of this - for example the UK has BCAR 31 which is an ICAO compliant code for large public transport hot air balloons.
G
Individual states have the right to do their own ICAO compliant things and because it's ICAO compliant allow it to be used worldwide.
There are a lot of examples of this - for example the UK has BCAR 31 which is an ICAO compliant code for large public transport hot air balloons.
G
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The French IR is a curious thing.
On the face of it it "has" to end when EASA FCL comes along.
But there is no way the French were going to set this up, with all the supporting infrastructure, only to terminate it in April 2012.
They obviously plan to carry on with it.
And if you look at today's EU power balance, in the wake of the Greek de facto default and the Italian near-meltdown, - it is basically Germany and France calling the shots. Germany is not going to tell France to not do something, and nobody else counts anyway.
The UK, OTOH, has a very long history of being very honourable and following the letter of every treaty they sign... well in the last few decades, anyway
The political climate in the EU is changing, despite EASA clinging onto its gravy trains, but the UK doesn't have the balls to take advantage of it. They could do so, in today's climate, but they won't.
Or maybe the CAA has plans but are keeping their powder dry, which is what I would do
We live in interesting times, not just in aviation
On the face of it it "has" to end when EASA FCL comes along.
But there is no way the French were going to set this up, with all the supporting infrastructure, only to terminate it in April 2012.
They obviously plan to carry on with it.
And if you look at today's EU power balance, in the wake of the Greek de facto default and the Italian near-meltdown, - it is basically Germany and France calling the shots. Germany is not going to tell France to not do something, and nobody else counts anyway.
The UK, OTOH, has a very long history of being very honourable and following the letter of every treaty they sign... well in the last few decades, anyway
The political climate in the EU is changing, despite EASA clinging onto its gravy trains, but the UK doesn't have the balls to take advantage of it. They could do so, in today's climate, but they won't.
Or maybe the CAA has plans but are keeping their powder dry, which is what I would do
We live in interesting times, not just in aviation
The political climate in the EU is changing, despite EASA clinging onto its gravy trains, but the UK doesn't have the balls to take advantage of it. They could do so, in today's climate, but they won't.
Or maybe the CAA has plans but are keeping their powder dry, which is what I would do
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Some of us, including a few on this forum, took the trouble to attend (a) the EASA workshop in Cologne on NPA 2011-16 on 30th September and (b) a CAA workshop on NPA 2011-16 on 9 November.
It is clear to me that both the CAA and EASA want to find a solution for grandfathering the IMCR for UK pilots of EASA aircraft beyond the date when the final EU IR becomes effective - which in practice will not be until at least 2013 probably. In my view, since the new IR (and EIR) will not be in place by the implementation date of Part FCL (8 April 2012 - but deferred effectively in the UK until 1 July 2012 and beyond for transition periods) pilots have to be able to continue using existing national instrument ratings (including JAR IR) until the new rules are in place. This should include the IMCR for UK airspace only. Any other scenario would be daft, as it would be regulatory gap which I highlighted to EASA some 4 years ago when pressing for what became the FCL.008 working group task.
There are often many uninformed critics on this forum - and other forums - who still persist in accusing the members of FCL.008 of 'missing an opportunity'. That is frankly not correct (I am being very polite), as has been explained several times by those in the know. The IMCR was NEVER a candidate for transposition to an EU IMCR, period. However good a rating it is.
What is crucial now - apart from getting the IMCR grandfathered - is to support the NPA 2011-16 proposals which are a major step forward for non commercial aviation. If we do not register our support through the CRT process on the EASA website, be sure that there will be plenty of 'other interested parties' who may want to kill off the proposals. On a pure numbers count they could win due to the consultation process and protocols EASA is bound by. You may of course wish to make some suggestions for improvement of the proposals for the IR and EIR, but whatever, support them in general. This opportunity for a change to the JAR IR will not come again for many years.
It is clear to me that both the CAA and EASA want to find a solution for grandfathering the IMCR for UK pilots of EASA aircraft beyond the date when the final EU IR becomes effective - which in practice will not be until at least 2013 probably. In my view, since the new IR (and EIR) will not be in place by the implementation date of Part FCL (8 April 2012 - but deferred effectively in the UK until 1 July 2012 and beyond for transition periods) pilots have to be able to continue using existing national instrument ratings (including JAR IR) until the new rules are in place. This should include the IMCR for UK airspace only. Any other scenario would be daft, as it would be regulatory gap which I highlighted to EASA some 4 years ago when pressing for what became the FCL.008 working group task.
There are often many uninformed critics on this forum - and other forums - who still persist in accusing the members of FCL.008 of 'missing an opportunity'. That is frankly not correct (I am being very polite), as has been explained several times by those in the know. The IMCR was NEVER a candidate for transposition to an EU IMCR, period. However good a rating it is.
What is crucial now - apart from getting the IMCR grandfathered - is to support the NPA 2011-16 proposals which are a major step forward for non commercial aviation. If we do not register our support through the CRT process on the EASA website, be sure that there will be plenty of 'other interested parties' who may want to kill off the proposals. On a pure numbers count they could win due to the consultation process and protocols EASA is bound by. You may of course wish to make some suggestions for improvement of the proposals for the IR and EIR, but whatever, support them in general. This opportunity for a change to the JAR IR will not come again for many years.
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There is no doubt David that you are right and the FCL-008 IR should be supported.
Taken in isolation, it is the first time in anybody's living memory that the IR gold plating has been rolled back in any way at all.
However, EASA would have had a very easy ride on it had they not first shafted, with a totally arrogantly and politically motivated decree which does not even bother to pretend to be in the name of safety, the FAA IR community, forcing it (on current proposals, anyway) to do an IR conversion course of some sort.
For a converting pilot, the existing ICAO IR to JAA IR conversion is a pretty significant amount of work, and doing the FCL-008 IR is not going to be much less work than that, by the time factors such as exam question bank availability, and the need to do training to meet the flight test requirements are taken into account. I am halfway through the latter and it is basically 1960s type of flying.
My only comments were on the EIR and they were that the ban on STARs will place VFR traffic where ATC simply don't want it, etc. I suppose, however, that a workaround will be to file a DCT from there, to some convenient waypoint. That will work in countries where DCTs are allowed by Eurocontrol.
Taken in isolation, it is the first time in anybody's living memory that the IR gold plating has been rolled back in any way at all.
However, EASA would have had a very easy ride on it had they not first shafted, with a totally arrogantly and politically motivated decree which does not even bother to pretend to be in the name of safety, the FAA IR community, forcing it (on current proposals, anyway) to do an IR conversion course of some sort.
For a converting pilot, the existing ICAO IR to JAA IR conversion is a pretty significant amount of work, and doing the FCL-008 IR is not going to be much less work than that, by the time factors such as exam question bank availability, and the need to do training to meet the flight test requirements are taken into account. I am halfway through the latter and it is basically 1960s type of flying.
My only comments were on the EIR and they were that the ban on STARs will place VFR traffic where ATC simply don't want it, etc. I suppose, however, that a workaround will be to file a DCT from there, to some convenient waypoint. That will work in countries where DCTs are allowed by Eurocontrol.
Thread Starter
Re. the NPA:
1. The sailplane cloud rating will suit sailplane pilots; however, it must be carefully worded to avoid inappropriate use by TMGs using it as a 'poor man's IR'. The other problem is that is doesn't cater for tug pilots needing to operate close to cloud; under present proposals they would need to hold an EIR, which is clearly disproportionate.
2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous. Theoretical knowledge examinations for 'Third country' IR conversions are not mandated in the NPA: it proposes merely that the applicant can demonstrate that the requisite level of knowledge has been achieved. So please suggest ways of achieving this when responding to the NPA. My opinion is that the Examiner can make sufficient assessment of an experienced FAA IR holder by observing the applicant's pre-flight planning as well as the practical in-flight conduct of the C-B IR Skill Test, perhaps with a few oral questions where necessary. Which, incidentally, is the way I used to assess pilots when I was conducting IR tests on the VC10 in the RAF.
3. The EIR will require diligent pre-flight planning and a Z-type FPL which includes VFR-to-IFR and IFR-to-VFR transition points in the Route section. It will also require a good standard of radio work. Correctly used within its privileges, there is no reason to doubt that the EIR can be used safely. Particularly as a stepping-stone towards the C-B IR.
4. NPA 2011-16 does not include provisions for the national needs of several Member States, including the UK whose IMCR is not provided for - and that is something we cannot accept. So a meeting was held at Gatwick on 9 Nov at which a formal proposal was handed to the CAA. The aim being to secure a solution which will satisfy the national needs of all Member States - and which would greatly simplify the UK CAA's workload in several areas. The UK CAA also stated that, contrary to rumours rife amongst certain parts of the GA community, they would NOT be abandoning efforts to find a solution to the UK IMCR - so if you hear silly rumours such as "Oh well, the CAA will palm us off with the EIR and won't bother with the IMCR", please tell the rumour monger to STFU, because it simply isn't true!
1. The sailplane cloud rating will suit sailplane pilots; however, it must be carefully worded to avoid inappropriate use by TMGs using it as a 'poor man's IR'. The other problem is that is doesn't cater for tug pilots needing to operate close to cloud; under present proposals they would need to hold an EIR, which is clearly disproportionate.
2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous. Theoretical knowledge examinations for 'Third country' IR conversions are not mandated in the NPA: it proposes merely that the applicant can demonstrate that the requisite level of knowledge has been achieved. So please suggest ways of achieving this when responding to the NPA. My opinion is that the Examiner can make sufficient assessment of an experienced FAA IR holder by observing the applicant's pre-flight planning as well as the practical in-flight conduct of the C-B IR Skill Test, perhaps with a few oral questions where necessary. Which, incidentally, is the way I used to assess pilots when I was conducting IR tests on the VC10 in the RAF.
3. The EIR will require diligent pre-flight planning and a Z-type FPL which includes VFR-to-IFR and IFR-to-VFR transition points in the Route section. It will also require a good standard of radio work. Correctly used within its privileges, there is no reason to doubt that the EIR can be used safely. Particularly as a stepping-stone towards the C-B IR.
4. NPA 2011-16 does not include provisions for the national needs of several Member States, including the UK whose IMCR is not provided for - and that is something we cannot accept. So a meeting was held at Gatwick on 9 Nov at which a formal proposal was handed to the CAA. The aim being to secure a solution which will satisfy the national needs of all Member States - and which would greatly simplify the UK CAA's workload in several areas. The UK CAA also stated that, contrary to rumours rife amongst certain parts of the GA community, they would NOT be abandoning efforts to find a solution to the UK IMCR - so if you hear silly rumours such as "Oh well, the CAA will palm us off with the EIR and won't bother with the IMCR", please tell the rumour monger to STFU, because it simply isn't true!