EASA AND THE IMCR - NEWS
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As someone doing the IMCr at the moment before the Euro idiots dispense with it, from all the talk on this thread, and as someone who lives in the North of Scotland and doesn't fly to France/Europe every weekend - can someone explain to me how an En-route IR which doesn't enable the pilot to accept an IFR approach, is a benefit over the IMCr which does albeit only within the UK.
With the weather such as it is up these parts, I'm certainly intending to use the IMCr in anger, and I'm in a very active syndicate where several of the members already do, and spend large amounts of time keeping very current on it so they can.
An EIR will be pointless - aside from being able to simplify the flying from A to B by going IFR rather than VFR, and that's only going to make sense on longer journeys anyway, if the weather has to be guaranteed VMC at the other end that's going to limit the utility of the rating. And even worse, if it is VMC when I set off, but deteriorates en-route, I could be possibly left with having to try to get VMC without an IFR approach at the other end.
So, how is this a *good thing* if you're not constantly popping over to the continent or somewhere with better weather?
With the weather such as it is up these parts, I'm certainly intending to use the IMCr in anger, and I'm in a very active syndicate where several of the members already do, and spend large amounts of time keeping very current on it so they can.
An EIR will be pointless - aside from being able to simplify the flying from A to B by going IFR rather than VFR, and that's only going to make sense on longer journeys anyway, if the weather has to be guaranteed VMC at the other end that's going to limit the utility of the rating. And even worse, if it is VMC when I set off, but deteriorates en-route, I could be possibly left with having to try to get VMC without an IFR approach at the other end.
So, how is this a *good thing* if you're not constantly popping over to the continent or somewhere with better weather?
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Slopey,
Despite 90-95% of the thread taking the form of 'IMCr versus E-IR', the E-IR is not a replacement for the IMCr.
The proposals are for a more accessible 'full' IR, and the E-IR needs to be seen as a module of the 'full' IR. The fact that you exercise the privileges of this [E-IR] module is a good thing because...
1) it may well suit some people and the sort of flying they do. If it doesn't suit you and you want full IR privileges then;
2) you can use it to build 15 hours PIC (IMC) and considerably reduce the training for the 'full' IR (to 10 hours).
Despite 90-95% of the thread taking the form of 'IMCr versus E-IR', the E-IR is not a replacement for the IMCr.
The proposals are for a more accessible 'full' IR, and the E-IR needs to be seen as a module of the 'full' IR. The fact that you exercise the privileges of this [E-IR] module is a good thing because...
1) it may well suit some people and the sort of flying they do. If it doesn't suit you and you want full IR privileges then;
2) you can use it to build 15 hours PIC (IMC) and considerably reduce the training for the 'full' IR (to 10 hours).
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Ahhh - apologies, I'd mis-read along the discussion that the plan was to morph the IMCr into the EIR, which for me anyway would be a significant loss.
I take it the (as far as we know) plan then is to grandfather the IMCr privileges, but to count it towards an EIR which in turn could be counted towards the IR requirement?
I take it the (as far as we know) plan then is to grandfather the IMCr privileges, but to count it towards an EIR which in turn could be counted towards the IR requirement?
Sub Judice Angel Lovegod
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For two years a small number of reactionaries have tried to make that the conversation, but it is not. They are utterly different.
You will be able to grandfather the IMCR and you will be able to count it towards the EIR or IR.
You will be able to grandfather the IMCR and you will be able to count it towards the EIR or IR.
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''I take it the (as far as we know) plan then is to grandfather the IMCr privileges, but to count it towards an EIR which in turn could be counted towards the IR requirement?''
The NPA doesn't detail how this might be done but the suggestion appears to be that those with an IMCr will continue to be able to exercise those privileges, and that the IMCr will, in some way, count as credit in the new modular system.
So, in your case, you'll be able to do what the IMCr currently allows you to do, and you'll have a much more accessible route to a 'full' IR if you want/need the additional privileges.
The NPA doesn't detail how this might be done but the suggestion appears to be that those with an IMCr will continue to be able to exercise those privileges, and that the IMCr will, in some way, count as credit in the new modular system.
So, in your case, you'll be able to do what the IMCr currently allows you to do, and you'll have a much more accessible route to a 'full' IR if you want/need the additional privileges.
Thread Starter
Therefore, I would have thought the proposals for the IR would be the same whether someone holds a PPL or a CPL.
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.
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.
NPA 2001-16A, para 1.1
Although the initial starting point for this task was to develop a more accessible instrument rating for PPL holders, the Agency agrees with the proposal of the rulemaking group not to limit the new ratings to PPL only. As the Agency expects that these ratings will also lead to an increase of VFR rated CPL holders taking up the training for one of the two new instrument ratings, it is proposed to widen the scope and to allow CPL holders to also receive training for these ratings.
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Billy
just a few hints
EASA have come up with a legal stumbling block regarding existing employed FAA licenced pilots in Europe so all this stuff having to hold dual licences can only apply to new commercial pilots not pilots who are already employed. EASA have accpeted that!
Second the whole impetus is now towards a Bi Lateral agreement.
Third 2014 will be changed to a later date
My source is very accurate
Pace
just a few hints
EASA have come up with a legal stumbling block regarding existing employed FAA licenced pilots in Europe so all this stuff having to hold dual licences can only apply to new commercial pilots not pilots who are already employed. EASA have accpeted that!Second the whole impetus is now towards a Bi Lateral agreement.
Third 2014 will be changed to a later date
My source is very accurate
Pace
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Basically employment on N Reg aircraft in Europe by it's citizens is legal established practice. You cannot legislate against EU law which protects your rights to that employment without recourse.
There are also legal problems for older working pilots in the present structure regarding age discrimination laws.
My source is very reliable. 2014 is out of the window with the earliest date as 2015 but more likely 2016 and there is a genuine Bi Lateral agreement behind all this
I could add a lot more but won't
Pace
There are also legal problems for older working pilots in the present structure regarding age discrimination laws.
My source is very reliable. 2014 is out of the window with the earliest date as 2015 but more likely 2016 and there is a genuine Bi Lateral agreement behind all this
I could add a lot more but won't
Pace
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I recall speaking to at least two barristers who think there are various legal avenues possible, in the CPL/IR / ATPL paid pilot arena and possibly others, and it doesn't suprise me, but nobody should be going public with where these might lie 
Years ago, a sovereign country could do as it wished and Crown Immunity (or the locally named version of it) prevented its Govt being sued for any economic loss, but things are not quite the same in the EU today.
Years ago, a sovereign country could do as it wished and Crown Immunity (or the locally named version of it) prevented its Govt being sued for any economic loss, but things are not quite the same in the EU today.
A question concerning the IMCR.
It appears that the proposal is to grant an IMCR holder a restricted IR. Will this IR Lite, or whatever it is to be termed, allow access to Class A airspace ?
Many thanks, jez
It appears that the proposal is to grant an IMCR holder a restricted IR. Will this IR Lite, or whatever it is to be termed, allow access to Class A airspace ?
Many thanks, jez
What would be much more interesting to me is whether the EASA grandfathered IMCR would be useable outside of the UK?
G
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since the IMCR syllabus does not include flight in airways
The IMCR offers IFR privileges for UK airspace classes D,E,F,G.
"Airways" is a nonexistent concept as far as pilot privileges are concerned. If you can find a piece of enroute airspace which is Class D (I believe there is some in Scotland) then you can fly in it on the IMCR, under IFR.
It is true that the IMCR syllabus does not include SIDs and STARs but they are nothing to do with the airspace class. Bournemouth has both and is wholly in Class D so an IMCR holder could fly a SID or STAR there legally. (The fact that these procedures lead in or out of Class A eventually is another matter).
It appears that the proposal is to grant an IMCR holder a restricted IR. Will this IR Lite, or whatever it is to be termed, allow access to Class A airspace ?
The current proposals, just out, are the FCL008 ones: the EIR and the IR.
Both will allow flight in all airspace classes.
The EIR will have no instrument approach privileges so it is for enroute IFR only.
The grandfathering path from an IMCR to the EIR or to the IR is AFAIK not yet known.
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What would be much more interesting to me is whether the EASA grandfathered IMCR would be useable outside of the UK?
As much as it might be a boon for everyone else, I doubt they'd do that!
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This debate runs and runs both here and on Flyer I've almost given up following it.
I think the short answer is that if you try to do too much you end up with a qualification which is an IR in all but name, which is not politically acceptable.
Frankly (and I have had an IR since 2006 and have used it extensively around Europe) a properly trained IMCR is 99% of the way to what you need to know. The SIDs/STARs are just a tiny piece of trivia which take 5 minutes to explain. The rest is all operational knowledge, which nobody is formally teaching anyway...
The full IR and the historically inflated training package, especially the grotesquely inflated European version, is very much a matter of an emperor being start naked, but nobody can say that.
I think the EIR is a valuable proposition because of the reduced training requirements relative to the full "FCL008 IR". In that respect it is wholly an additional privilege which does not detract from any other.
Whether it is valuable enough relative to the training effort difference to the full IR is a personal matter. It's a bit like whether a £100k plane does "enough more" for you than a £70k plane.
I would never go back from the full IR (just see how much easier flying with the full IR is, comparing VFR and IFR trips) short of losing my medical, but taking myself back to my VFR-only days (albeit with the IMCR), the EIR would give me a very valuable capability increment for long trips.
There is an argument that the EIR won't benefit many people, in that its chief selling point is the ability to fly VMC on top enroute, which is not practically possible in CAS (due to Eurocontrol / ATC issues) below say FL070-090) so some reasonable level of aircraft capability is required for that. But it will be no worse than the IMCR which allows you to fly around the UK, in IMC, OCAS.
I've almost given up following it.I think the short answer is that if you try to do too much you end up with a qualification which is an IR in all but name, which is not politically acceptable.
Frankly (and I have had an IR since 2006 and have used it extensively around Europe) a properly trained IMCR is 99% of the way to what you need to know. The SIDs/STARs are just a tiny piece of trivia which take 5 minutes to explain. The rest is all operational knowledge, which nobody is formally teaching anyway...
The full IR and the historically inflated training package, especially the grotesquely inflated European version, is very much a matter of an emperor being start naked, but nobody can say that.
I think the EIR is a valuable proposition because of the reduced training requirements relative to the full "FCL008 IR". In that respect it is wholly an additional privilege which does not detract from any other.
Whether it is valuable enough relative to the training effort difference to the full IR is a personal matter. It's a bit like whether a £100k plane does "enough more" for you than a £70k plane.
I would never go back from the full IR (just see how much easier flying with the full IR is, comparing VFR and IFR trips) short of losing my medical, but taking myself back to my VFR-only days (albeit with the IMCR), the EIR would give me a very valuable capability increment for long trips.
There is an argument that the EIR won't benefit many people, in that its chief selling point is the ability to fly VMC on top enroute, which is not practically possible in CAS (due to Eurocontrol / ATC issues) below say FL070-090) so some reasonable level of aircraft capability is required for that. But it will be no worse than the IMCR which allows you to fly around the UK, in IMC, OCAS.
Thanks for the replies. So, it appears that IMCR grandfathering has yet to be resolved, but the consensus is that holders will be granted some form of instrument flying privileges, for the whole of Europe, roughly equivalent to existing IMCR privileges.
With reference to your comment, Slopey, "But if a grandfathered IMCr was usable outside the UK, that would effectively make the EIR pointless", as I understand it the IMCR will no longer exist as of April 2012, so the EIR will become the only sub-IR entry route for instrument flying.
As the IR 'Lite' will be for IMCR holders only and should afford the same privileges as currently granted to IMCR holders (but across the whole of Europe), it seems to me that getting an IMCR before the April 2012 cut-off date would be a wise move.
Regards, jez
With reference to your comment, Slopey, "But if a grandfathered IMCr was usable outside the UK, that would effectively make the EIR pointless", as I understand it the IMCR will no longer exist as of April 2012, so the EIR will become the only sub-IR entry route for instrument flying.
As the IR 'Lite' will be for IMCR holders only and should afford the same privileges as currently granted to IMCR holders (but across the whole of Europe), it seems to me that getting an IMCR before the April 2012 cut-off date would be a wise move.
Regards, jez
Another thought.
If, as it currently appears, the EIR isn't available until 2014/2015 (and presumably the IR Lite for IMCR holders), wouldn't it be wise for the-powers-that-be to allow IMCR training to continue until such time as the EIR and IR Lite comes into being ?
If, as it currently appears, the EIR isn't available until 2014/2015 (and presumably the IR Lite for IMCR holders), wouldn't it be wise for the-powers-that-be to allow IMCR training to continue until such time as the EIR and IR Lite comes into being ?
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Yes, that is self evidently correct.
I gather that EASA will allow (gosh we need to be grateful for small mercies from these characters) an individual country (e.g. the UK in this case) to adopt national differences to an IR, and this is how the IMCR would continue in the UK only, as it is now.
I gather that EASA will allow (gosh we need to be grateful for small mercies from these characters) an individual country (e.g. the UK in this case) to adopt national differences to an IR, and this is how the IMCR would continue in the UK only, as it is now.