EASA publishes draft IMC flight 'Opinion'

[jxk]

ref: ERSA (European Road Safety Association)

In the cause of unity and standardisation everyone will drive their cars on the left and speak English within Europe!

[bravobravo74]

As far as uk imc I understand that it is the clear intention .. and even maybe rightly so .. to go for 1 set of rules

As for the opinion that disallowing the IMC rating is justified by the facilitation of greater European standardisation, I couldn't disagree more.

Why should flying be made less safe for British pilots just because our provisions aren't common to other states? The idea epitomises European bureaucratic nonsense. If indeed the IMC rating is compromised by EASA then, irrefutably, safety will have been sacrificed for the convenience of the regulators.

[A and C]

Political correctness

You only have to look at the accident statistics to see that the UK is up with the best of the world, the problem is that we can't offend those in Southern Europe who miss the mark by some distance.

So rather than be shown up by those Brits it is more politicly correct to seek to drag the UK system down to the same low standard.


Its European harmonization of a sort !

It's UKIP for me because the Tory did nothing much to help safeguard the IMCR and other national interests.

[englishal]

what is your problem?

Eurocratic Bulls*it! In everything we do these days.

PS does ANYONE know how these rules will affect our NON EU EASA members, ex. Norway?! Surely as non EU residents.......

[Pace]

Is it really that bad loosing the IMCR?

To address the safety issue, the Agency proposes a competency-based instrument rating (CB IR) and an en route instrument rating (EIR) for private (PPL(A)) and commercial pilot (CPL(A)) licence holders. The proposed changes are expected to increase safety with regard to the accident category of controlled flights into terrain (CFIT) by establishing a better accessible IR, thereby enabling more European General Aviation (GA) pilots to commence this type of training. The proposed new ratings will amend the training and checking requirements in Annex I to Commission Regulation (EU) No 1178/2011 (Part-FCL). The associated decision will also amend AMC and GM to this Regulation and Annex VII to Commission Regulation (EU) No 290/2012 (Part-ORA). More specifically, the proposed CB IR course will contain a reduced theoretical knowledge (TK) syllabus appropriately reflected by a different level of TK examinations and a reduced amount of instrument flight instruction time when compared with the existing IR courses. The EIR requires less training, but nevertheless consists of more comprehensive flight training when compared with the basic instrument flight module of the existing IR. The EIR is considered an EASA MS only rating as it is below ICAO SARPS. As the EIR only provides en route IFR privileges, the Agency envisages that this rating will serve as a module to be credited towards the IR using the proposed competency-based route.
Both CB IR and EIR include provisions for crediting a certain amount of instrument flight time under instruction outside of an ATO or prior PIC instrument experience on aeroplanes. To evaluate this prior training and experience, a pre-course entry assessment will be required at an ATO. Moreover, as a result of consultation, the maximum amount of instrument ground time on an FNPT II for the CB IR was increased, the specific English language requirement for IR (and EIR) holders (FCL.055 (d)) was removed, an IFR-by-day restricted IR for PPL holders was enabled by making the night rating prerequisite flexible, and additional crediting provisions and reduced requirements were established for third-country IR holders.

If EASA stick to the above is this not in fact a big victory? a full IR which is easily obtainable and not only opens up IMC flying departures and approaches in the UK but Europe wide too with an almost swap for 3rd country IR holders?
Think lunch in le Touquet on **** days

I was never even 2 years ago a supporter of retaining the IMCR for the simple fact that it would deter the fight for an FAA style IR in Europe.
As long as EASA are good to their word that looks like what we have achieved.
As I posted before the IMCR was an excellent UK rating but maybe it had past its sell by date and could never be sold to Europe! That was the problem!
So lets be positive and excited by what appears to be on the table.
If like many you fly N reg on an FAA IR the conversion should be a doddle

Pace

[BEagle]

To lose the IMCR would be a crime

Pace, you can rejoice in the C-b M IR all you like - but it would still be a wholly disproportionate price to pay for MOST UK pilots who don't want to play airliners in little spamcans, they just need a safe way of coping with UK weather.

The FI who needs to pop up to VMC-on-top to teach S&L 1/2 can do that with an IMCR - the added cost in time and money for 60% of the current IR syllabus would be completely disproportionate. Have you even looked at the difference in cost between obtaining an IMCR and a C_b M IR?

Goudou knows that certain Member States will certainly vote against the draft Opinion in its current state, due to their concerns about the EIR. Equally, others may vote against it for its lack of flexibility. It is not possible to vote for selected parts of the draft Opinion, it's all or nothing.

Pressure will be brought to amend this stupid document - and if that delays your precious 'FAA-style IR', or the conversion of flags-of-convenience IRs obtained elsewhere for use in foreign-registered aircraft, then you can thank Goudou for not heeding the EASA Managment Board's call for flexibility.

In its current form, this document deserves to be rejected.

[Pace]

BEagle

The EIR would achieve the ability to climb on top to do air work!

2 years ago I argued that EASA would never approve a part IR unless it was a modular step towards a full IR.

That appears to have been the case in presenting the EIR although I have my own doubts on a part IR without approach and departure privalages.

Until the fat lady sings nothing is set in stone and I have concerns that all these promises will get watered down or an excuse why not given at some point!
It all appears to good to be true.

Hence why it is vitally important that efforts from talented people like yourself should be put to making sure an FAA style IR goes through as well as an EIR and not fighting for something which IMO could never happen.
The other concern is member states scuppering the lot in petty squabbles and self interest.

I really do not like being correct as I have flown with an IMCR for years and know its benefits but we really do need to make sure the IR and EIR go through or we are all stuffed

There are approx 11000 N reg pilots in Europe! Most because of the FAA IR so its not true that pilots cannot afford or want a full IR and an FAA IR is not a lot more effort to achieve than the IMCR
If the whole thing was scuppered then EASA would be forced to do something on safety grounds as they are a safety agency not an anti safety agency.

My dream has always been to see a harmonization of FCL worldwide which is right and proper and the IMCR was too insular
We should be looking to winning the war not a minor battle and loosing the war
In the process because we are focused in the wrong direction

Pace

[BEagle]

The EIR would achieve the ability to climb on top to do air work!

The theoretical knowledge requirements for the proposed EIR are the same as those for the proposed C-b M IR: roughly 60% of the current IR.

The IMCR is not being proposed for anywhere except where it is currently available - regrettably, some appear to have missed that point.

[Pace]

But is that still a viable option or now realistically a dead duck ?
What are the options now of retaining it other than the UK taking a French like stance and saying NON? Historically something we rarely do!
Two fingers and stuff you we are keeping it whether you like it or not !!
Will that happen ? NO !
BEagle I know this has been your baby for some time what are the options to resurrect this back into a reality knowing EASA!
I do not trust them one inch! Smiles and yes yes then NO and we did our best not our fault !
They have an agenda! Con people to keep the piece, make false promises and always have an excuse at the end to get out!
I too am
Not confident on the IR or EIR and globally I see it as imperative that FCL becomes closer between nations to an eventual common standard

Pace

[Silvaire1]

I see it as imperative that FCL becomes closer between nations to an eventual common standard

Seems to me that's what will happen, effectively. EASA is finding, and will find, that naive political one-upmanship relative to FAA is a losing battle. They will then save face by allowing reasonable conversion from FAA certificates to their own gold-plated "EASA as Part of the New EU Ruling Class" licenses. The effective standard for European pilots will be (remain) the FAA standard because they will train to that standard before converting.

Eventually politics must succumb to economic reality, even if that means maintaining the illusion of supposed 'leadership' and the elite class of bureaucrats that want to justify it, and the paychecks it gives them.

[Legalapproach]

Beagle

"Ein Volk, ein Reich, ein EASA!"

At least then our licences would be valid for a thousand years without having to pay for the privilege of renewing them every five years.

[Level Attitude]

Not sure of the Law on this one:

The CAA has said that an EASA Licence will be valid for
Annex II aircraft (it didn't have to).

The CAA has said it will continue to issue IMC Ratings on
National Licences (it didn't have to)

Can the CAA not say that National Licences will allow pilot
privileges on EASA aircraft in UK Airspace only?
Hence allowing IMC privileges if someone holds both a
National Licence and an IMC rating.

[stuartforrest]

On a positive note

I keep reading all this stuff and I don't get it. I think it would be great to make the switch to a simpler instrument rating for all. I don't mind being forced to do some more studying to change my IMCR to an IR. I just don't get what the grumbling is about. Obviously there is change but they are only proposing the new IR because pilots moaned that the old one was too hard to complete!

Does anybody know when this could become law in reality. Are there any proposed dates. Its seems to have gone on for many years.

[Whopity]

I just don't get what the grumbling is about.

Then wait and watch because without the IMC there are going to be more DEAD BODIES than before, when those with no training attempt to fly in marginal weather. Throwing away a well established rating that is even recognised by insurance companies as improving safety, in favour of an expensive alternative that few pilots will take up, is not just lowering the standard, its grossly irresponsible!

In 1916 Capt Smith -Barry RFC invented Threat Error Management; ICAO didn't discover it until 1994, EASA some time later. In the UK the weather is a Threat, for many years we have Managed it with the IMC rating, now EASA who are new to this game, are making a fundamental Error by failing to recognise such a well established Threat for political expediency.

[englishal]

I am not sure about dead bodies, but what you will get are people flying "VFR" in IFR conditions and telling ATC they are "VFR" You could never be prosecuted for this as only the pilot can report flight conditions.

There are something like 10,000 FAA certificate holders in Europe, the VAST majority of them hold an FAA IR (as it was the reason to get an FAA cert for most of us). I really wonder what EASA's thinking is - Is it a grudge against the FAA? Are they that petty?

The FAA system is tried and tested, and whether you talk about maintenance, certification, or whatever, IT WORKS. Why don't EASA just accept this fact, make their life easy and by a copy of the FAR/AIM and say ok, this is how it is going to be....and copy the book.

Actually I know why not....Job Creation. Big salaries, expenses, trips for the boys and girls - Paid for by US. I have a poster stuck on the wall of my office at work says "HOLD A MEETING, FEEL IMPORTANT; OFFLOAD DECISIONS" and then "MEETINGS - THE PRACTICAL ALTERNATIVE TO WORK" I might send a copy to EASA.

Actually this whole EU thing p*sses me off on principal. Actually so much so, that I have even inquired about an internal company transfer to the USA....Then I can have my big house, with the local airport a few mins away, and my N reg Super Commander parked in the hangar and no Eurobull !!!

[Ellemeet]

Well that really helps.

It means a quantumleap forward in terms of an accessible ir.
It means you can actually start using your imcr abroad as well if you have it transferred to EIR
It means you get a very easy way in to a full easa ir..
It means you will lose the right to do an approach.

Mmm well if **** weather was unexpectedly encountered than you can allways claim force majeur and do the approach anyway.

You claim the Faa ir is so muchbetter ... And I agree .. But the practical training is completely the same as in Europe. The difference is the written part and at least that got a lot better. The FAA ir requires a lot more training than the imcr and still you did it.

Be happy with all the plusses. Imcr where you can make an approach throughout europe was never going to happen.

The only thing I disagree with is, that if the uk CAA has allowed it and it seems to work fine than let this "national thing" remain in existence within their borders.

Imc will continu to take lives ., also from rated pilots. It proves that it should not be messed with .. And yet rated and unrated pilots continu to do just that.

[Pace]

Ellemeet

And I agree .. But the practical training is completely the same as in Europe. The difference is the written part and at least that got a lot better. The FAA ir requires a lot more training than the imcr and still you did it.

To fly in CAS we have to be trained to a standard while any instrument training is better than none to operate safely in CAS is a lot to do with surveillance and a lot to do with trust that everyone is where they should be doing what they should do not a half trained loose canon creating Havoc.

Yes some IMCR pilots are as good as equivalent IR pilots because they have survived to the point where experience took over.

The proposed EIR is fine but there has to be a get out of jail option if it all goes pear shaped at either end.
Maybe a Tyro type call with an immediate vectoring by ATC and a ban on such flights where enroute airports report beow 1000 foot cloudbases ?

Pace

[A and C]

Whopity

You make the case for the IMCR superbly ! Just a pity that EASA are too busy playing petty politics to act as a SAFETY AGENCY and listen to common sence.

[Bob Upanddown]

In another forum, people are suggesting that the EIR plus the IMC (IR(R) as will be on the EASA Licence) is a wonderful result.

The people suggesting how wonderful the EIR will be are members of PPL IR, the very organisation that (if we believe what is posted on their site) suggested the EIR (with no approach privileges) as an alternative to the IMC (with approach privileges).
The EIR is fine for flying airways. And how many people flying on an IMC have something suitable for UK airways?? (ie above FL100, with 8.33 radios, IFR approved BRNAV....etc - very few)

It is a question of politics and no-one in EASA will admit the best solution for light GA is an FAA style IR. Even your CB IR will be more expensive to obtain and maintain.

I seriously think a judicial review (if there is such a thing in the EU) is called for as this is a case of politics over safety.

[piperarcher]

The EIR is fine for flying airways.

I cant see why you cant take off VFR from x airfield, land VFR at y airfield and en-route fly in or out of cloud, in our out of CAS (with approval in CAS of course), using the semi-circular rule and IFR terrain avoidance rules as you see fit. I don't think the EIR is forcing anyone to fly airways is it?