EASA AND THE IMCR - NEWS

[IO540]

2. The C-B IR is a good proposal. People should comment on any Learning Objective they feel to be superfluous.

There were a number of superfluous areas left in there, which I commented on (like the one asking where you would find "Flight Level Zero" - what kind of a trick Q is that?) but I think the wider issue there is that the proposed reduction in the TK syllabus makes this proposal extremely vulnerable as a whole. You only need to post some comment in the prof pilots' forum here about some of the utterly bogus JAA IR TK stuff and see the vigorous comments defending the TK. These people are going to lobby hard to re-instate the old TK. This is why I decided to do the JAA IR now.

'Third country' IR conversions do not mandate theoretical knowledge examinations in the NPA, 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 from the pre-flight planning and in-flight conduct of the C-B IR Skill Test.

The words "demonstrate knowledge" have been in the regs for far more years than I would know about, and it has always meant sitting the exams.

So unless you know "something" is in the cooking, I would not expect this to change.

I agree 100% than an FAA-style oral exam would be wonderful because basically any experienced IFR pilot would pass it straight off. But an oral exam (instead of writtens) would terrify most of those passing through the fATPL factory - because they have virtually no flying experience, never mind any IFR experience, by the time they sit their 14 exams. And there are big commercial interests (the FTOs) riding on that. I realise that the CBM IR TK is going to be a different process to the ATPL TK, but that in turn gives ammunition to those against the CBM IR by claiming that the holders of the latter have done a "lesser" IR. Such an assertion would be bogus (because some 90% of the JAA ATPL TK is a load of bollox irrelevant to any form of aviation) but that belief will be held by all of the FTO establishment and nearly all of the transport pilot population Which is why I am doing the JAA IR now. I think the CBM IR is a great proposal but I think it is politically very vulnerable.

[bookworm]

The words "demonstrate knowledge" have been in the regs for far more years than I would know about, and it has always meant sitting the exams.

FCL.725 (b) Theoretical knowledge examination. The applicant for a class or type rating shall pass a theoretical knowledge examination organised by the approved training organisation to demonstrate the level of theoretical knowledge required for the safe operation of the applicable aircraft class or type.

(1) For multi-pilot aircraft, the theoretical knowledge examination shall be written and
comprise at least 100 multi-choice questions distributed appropriately across the
main subjects of the syllabus.

(2) For single-pilot multi-engine aircraft, the theoretical knowledge examination shall be
written and the number of multi-choice questions shall depend on the complexity of
the aircraft.

(3) For single-engine aircraft, the theoretical knowledge examination shall be conducted
verbally by the examiner during the skill test, to determine whether or not a
satisfactory level of knowledge has been achieved.

[FlyingStone]

Originally Posted by bookworm

FCL.725 (b) Theoretical knowledge examination. The applicant for a class or type rating shall pass a theoretical knowledge examination organised by the approved training organisation to demonstrate the level of theoretical knowledge required for the safe operation of the applicable aircraft class or type.

Last time I checked IR is neither class nor type rating - I could be wrong though.

[englishal]

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.

Surely for a 3rd country IR, the fact that the applicant has already passed both theoretical and oral as well as flight test for the 3rd country IR should be considered sufficient "theoretical knowledge".....as it is now for the IMC rating. (EDIT: I have just re-read what you said and that is exactly what you said )...

The oral and flight test should be sufficient for the examiner to accurately gauge the person.

[IO540]

Yes but then you will be doing an "FAA IR" and you can't do that because "we are Europeans and we need European solutions" (the words of one prominent EASA official).

[GeeWhizz]

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!

What formal proposal is this? What was contained within it? What potential solutions are being considered? Which areas will the CAAs workload be reduced? Where has the CAA stated they will not abandon IMCRs?

These are just a few questions that someone at the CAA should be answering for the GA crew. And refers directly to previous pleas for information. I'm not suggesting that these questions aren't be answered, merely that the answers are kept under lock and key. Answers that should be made freely available to prevent the rumour mill from grinding.

[bookworm]

Last time I checked IR is neither class nor type rating - I could be wrong though.

You're correct. The point I should have made more clearly is that this is a precedent within Part-FCL for the word "demonstrate" to mean a verbal test by the examiner, not a theory exam.

[BillieBob]

Answers that should be made freely available to prevent the rumour mill from grinding.

Forgive me, but I don't see why the CAA should be in the least concerned about whether the rumour mill is grinding or not.

[GeeWhizz]

BillieBob you're absolutely correct. But I'm not sure keeping quiet on these topics is a great way to keep GA pilots with their hard earned ratings, on side.

[IO540]

To be fair to the CAA, they are right to keep silent on this intensely political stuff.

France has the advantage of being French i.e. they are very polite in the open and when the door closes they stick their middle finger up and do as they please. This is an effective way of dealing with the crooked gravy train riders who are in charge of the EU, but the UK CAA doesn't have the balls to do stuff which is quite so crude.

I am sure a way will be found to preserve the IMCR, but you won't hear about it till the last minute. So much s**t has hit the fan over the EASA proposals to shaft IMCR and FAA IR holders that EASA had to do under the table deals with MEPs to get enough votes, and the under the table stuff would have been assurances that such and such will be solved amicably.

[BEagle]

GeeWhizz, those of us representing AOPA, BGA, EAS, LAA and PPL/IR who are working with the CAA to try to find a way to retain the UK IMCR for the future are NOT going to publicise each and every stage of our deliberations in case we run into regulatory brick walls and have to resort to different tactics.

You will just have to trust us. Sorry, but that's the way it is. There are enough stupid rumours doing the rounds and I am NOT going to give the opportunity to some village idiot to spin his own incorrect intepretation of matters which are somewhat sub rosa.

[GeeWhizz]

In BEagle we trust!

[IO540]

There is a fine video showing Seebohm (an EU official who likes his lunches) saying (paraphrasing) that there are areas in aviation where there is no regulation, and therefore they need to create some.

[Timothy]

In BEagle we trust!

I have to tell you that BEagle is doing a bloody good job (backed up by an array of well informed helpers.)

Both AOPA and PPL/IR will be putting in reasoned responses to the NPA. It is great to be able to report that the two organisations are working closely together, and are very much on the same page. This is not a time for there to be any division in the ranks of those representing PPLs, and there is none.

You are going to have to trust us, to a large extent. That is what we are for, and why you pay us your subs.

If this goes well, this will be the greatest advance in PPL licencing in the 40 years since I have been flying, certainly since the IMCR, and we hope to demonstrate to you that membership of organisations like AOPA and PPL/IR really pays off in these once-in-a-generation times.

[SDB73]

Is there not a whole hill of "guilty until proven innocent" going on here?

I think it's important to voice opinion of how things should be. But blanket calling people self-serving scum even before they've actually presented the final regulations is a bit strong.

As a UK PPL/IMCr, who flies a G reg, I have to say I'm all-for the current LIKELY changes, and feel pretty strongly that enough importance is being placed on allow me to continue to use my privs, and probably give me a sensible route to far MORE privileges.

I can understand FAA/IR's getting upset to a degree, but in SOME ways - being brutally harsh - the whol FAA/IR/N-reg thing has always been a LITTLE BIT of a "loop hole" rather than the way it was always supposed to be.

In motorsport we often use the term "The spirit of the regulations", and as soon as you try to use the letter of the regs to your advantage, knowing that it wasn't what was originally intended, it's always a short lived benefit. I know this doesn't 100% apply here, but it's close.

Either way, who don't we just show ourselves to be gentelemen and offer solutions.. I know that if I were in charge I'd respond way more favourably to that, than to being called a crook!

[BEagle]

No thank you, Silvaire1. The next thing would be talking about 'aloominum' or saying "Have a nice day" to everyone.....

Timothy, thank you for your kind words! The main frustration at the moment is having to cope with unqualified comments from those who simply haven't bothered to understand what's on offer.....

[Johnm]

Very well, suffer on in ineffective and confining isolation - it is a European specialty.

EErrr excuse me how do you think half the planet's population ended up speaking English and most of South America Spanish and Portuguese. Where was the first digital computer developed, where was the first steam engine built, who developed the automobile and first flew (no it wasn't the Wright brothers in the US, they were Johnny come Latelies) where was gravity discovered the telescope invented........

[Johnm]

Silvaire I don't think we'd disagree about the European Commission and its institutions, happily there's still plenty of European activity that isn't controlled by the commission, through aviation isn't one of those sadly.

[BillieBob]

happily there's still plenty of European activity that isn't controlled by the commission

Give it time, my boy, give it time.

[cockney steve]

I'm all for the "septic's" regulatory system, if it means we can adopt their "experimental" and "sports / light aircraft " categories.

OK, so single-seat microlights are now released from a lot of the onerous red-tape compliance -issues, but there's no cheap way to fly rotary in the UK..... OK, For the pedants, the possibility of lower-cost rotary -flight is denied us, as are many of the innovative delights of the USA.

Sorry for the thread-drift,- but their liberal attitude also appears to apply to their other legislative areas.......if you want to risk your own neck, it appears that they'll let you.

IMCR appears to be a pragmatic solution to those to whom the cost/time of obtaining a full IR is prohibitive,yet need a legal method of flying in weather defined as IMC.

The"hobby" of GA seems to be grossly over -regulated in the UK,perhaps that's why it remains an elitist ,minority activity.