PLEASE READ THIS AND HELP SAVE GA IN THE UK - Save the IMCR
 

THIS IS VITAL TO EVERYONE NOT JUST THOSE WHO MIGHT AT SOME TIME CONSIDER AN INSTRUMENT RATING.

PLEASE AT THE VERY LEAST TAKE THE TIME TO READ THIS THREAD AND THE OTHER ASSOCIATED THREADS AND GIVE YOUR SUPPORT.

EVEN IF YOU DONT HAVE ANY COMMENTS TO MAKE HAVING READ THE THREAD PLEASE AT LEAST RECORD YOUR SUPPORT.

IT REALLY DOES EFFECT EVERYONE.

A report in Flight Training News suggests UK pilots will no longer have the benefit of an IMC rating when, or shortly after, EASA takes over FCL.

http://www.*****************/default.asp?sourceid=&smenu=81&twindow=&mad=&sdetail=283&wpa ge=1&skeyword=&sidate=&ccat=&ccatm=&restate=&restatus=&reopt ion=&retype=&repmin=&repmax=&rebed=&rebath=&subname=&pform=& sc=2209&hn=ftnonline&he=.co.uk

There is little if any news to suggest that the IR will be made any more accessible for the average private pilot.

It is possible the UK s unique arrangements for night flying could be under threat.

For those with a CAA life time license these licenses will be effectively revoked. The new EASA license will have to be renewed every five years - a purely cash generating exercise.

HISTORY

The IMC rating was introduced during the 1960s. Before then a private pilot was entitled to fly outside of controlled airspace in IMC without a instrument rating. It was felt this was dangerous. The regulators accepted an IRing was beyond the means of most private pilots. The IMC rating was therefore made available to UK pilots as a national rating. Since the rating was introduced some 50 years ago there has been no evidence produced to suggest the IMC rating is unsafe. Many pilots over the years have found the IMC rating provides an excellent way of developing their instrument skills beyond the basic elements taught during the PPL.

PURPOSE

The IMC rating is often promoted as a “get you out of trouble rating”.
It has always been restricted to UK airspace and to flights outside of class A airspace. In addition to enabling the pilot to fly in IMC it also permits flights in VMC when the in flight visibility is less than ideal for a pilot with more limited instrument skills.

Practically there are many pilots who use the rating to enable them to legally transition from flying beneath to on top of a layer of cloud. There are others who will fly part of a sector in IMC and a few, with experience, who will use the full privileges the rating confers.

Our climate offers relatively few days when there is not some cloud in the sky. Whilst metrology has improved, our climate is significantly influenced by the close proximity of the Atlantic ocean and the prevailing south westerly winds. Consequently forecasts are not always accurate.

It would seem patently obvious that UK pilots should be entitled to undertake further training which at the very least would enable them to cope with un-forecast changes in the weather. They should also be able to plan their flight to take advantage of the safest conditions - for example flying at higher altitudes in good visibility rather than scud running beneath the base.

Controlled flight into terrain remains one of the greatest causes of aircraft accidents and almost always results in the pilot and passengers being killed. There is ample evidence to suggest that these accidents are far less likely to occur if pilots are trained and licensed to fly in IMCs.

For these reasons there are many pilots who consider the loss of these privileges to be disastrous. There are those who believe so far as UK pilots are concerned it will be the single most dangerous development in licensing that has ever taken place.

If this is allowed to occur there will be many pilots who have held an IMCR for many years who are no longer able to fly through cloud. They will often find they will have to decide whether to continue the flight in conditions that they consider unsafe or break the law. There will be many new pilots who through their own mistakes, or as a result of inaccuracies in the forecast, find themselves in conditions with which they are unable to cope. For these pilots the outcome is usually fatal, whereas with accessible instrument training beyond that provide by the basic PPL, this need not be so.

Who does this effect?

In summary, whether you are training towards your PPL, you have a PPL but are not considering an instrument rating at this time, you are considering an instrument rating, you have an IMCR or IR or are considering or have a night rating this effects you now because of the wide ranging impact it will have on GA in this country in more general terms.

It effects you if you own an aircraft that is equipped to operate in IMC, even if you don’t currently use it in this way. The market for these aircraft in the UK if these changes are adopted will suffer because very few pilots will be able to use them for their intended purpose.

It effects you if you are a member of a flying school or run a flying school. IMC training provides a valuable source of income and contributes towards the running costs of the school, the instructors and the infra structure. In exactly the same way so does night training.

It effects you if you are involved in the operation of an airfield. How many days are too poor for pilots to fly unless they have an IMCR or IR. On these days almost no flying will take place.

It effects you if you are involved with the manufacturer or maintenance of aircraft or the aircraft industry in general. The demand for aircraft equipped to operate in IMC will all but vanish.

In fact it effects everyone.

Many of us feel very strongly we need to do something about it before it is too late.

What you should do?

I have suggested that the following is a list of some of the actions we could take.

1. Write to Diamond and the other GA manufacturers in Europe - there are a few. I would point out that they shouldn’t bother making any IFR equipped aircraft because other than the few schools teaching the IR and the even fewer PP with an IR the market will die. They charge a lot more for an IFR fit, and guess what, that translates into profit downstream. They are very influential.

2. I would write to the flying schools and I would ensure there were flyers with every letter. I would have a web site from which these flyers could be printed so students and members could lobby their flying schools. I would point out the significant loss of income that will ensue because there will be no IMCR to teach. (You can forget the average flying school teaching the IR if you have any idea what is involved).

3. I would write to every single one of my members if I was AOPA, PPL IR, PFA etc. I would encourage them to write to their MP, Euro MP, EASA members and the CAA and raise the matter with their flying schools, groups, clubs etc. I would make sure they knew exactly how to do so, what they should consider saying and where they should write.

4. I would write to my MP, my Euro MP and whoever I could at EASA and make a complete and utter nuisance of myself. I know a fair amount about planning. People will tell you the planners ignore all the emotional and unsubstantiated objections they receive. Well they don’t. If they come from enough people and people of influence at the very least it causes the entire application to be carefully reviewed, as much as they might like to ignore them. I am not suggesting the complaints should be emotive, avoid it if you can, but it doesn’t matter if you cant. I would do it now. Make a complete nuisance of yourself now.

5. I would prepare a well researched document about the IMCR which would deal with why it was introduced, the benefits it has brought, its safety record etc and I would ensure this is in front of every member of EASA that was relevant, and every flying school I could get hold of in Europe.

6. I would launch a wide ranging complaint about commercial operators activities in open FIR and the way in which this was encroaching on GA. My purpose would be to make it quite clear to the commercial operators that if they want our help with widening their access to airspace we had better see some reciprocation.

7. Whilst I was about it I would may sure that the risk to the night rating, life time licenses and maintenance organisations where all spelled out.

8. I would ask everyone to sign a petition - and sign they should not because they were intending to do and IMCR or had one, but because of the impact of the wider reaching changes on GA that EASA will have. On the basis of what I read be I am in no doubt whether intended or not this represents a sustained attack on the way we do GA in the UK and it should be ignored at our peril.

9. I would make sure I had the support of all the GA mags, that they really understood what we were about and why the campaign was so imprortant.
10. I would ask everyone for a tenner or whatever amount was appropriate so I was properly funded and I would be prepared to mount a legal challenge.

Where do we go from here?

The purpose of this thread is to gather support, exchange views and to take the message to EASA that we object to the loss of these privileges in the strongest way.

There is already a lot of discussion here.

http://www.pprune.org/forums/showthread.php?t=302466&page=5

Fuji

The link to FT news doesnt seem to work. Not sure why.

This hopefully will work better.

BB

Well done FA :ok:

Is someone going to start a petition? I can try to help between work commitments if you need it...and where do you want me to send the tenner ;)

Cheers

Activate action
 

Fuji,
Normally I am reader rather than a writer in flying fora. But this threat of loss of IMC has galvanised me to action.

I fully support you. You have proposed a very good & comprehensive plan.

To get the poltical and commercial engagement going with MPs & GA vendors we need to establish a list of email addresses & old postal addresses. Then lets share template letters and activate as many people as possible to send them..I assume that the pilots associations and magazines have the contacts. What we need is co-ordinated & concerted action.

Peter

The French Lesson
 

Apologies for a similar posting in other fora, but I think the "French Lesson" is of vital evidence to us, literally a matter of life-and-death. It needs to be distributed as widely as possible.

The IMC rating in the UK, like the Instrument Rating in the USA, has democratised the life-saving skill of being able to fly and land on instruments safely.

There is evidence from France which suggests that our fatal accident rate COULD DOUBLE with the loss of the IMC rating.

This report was commissioned by the french ministry of transport, and was published in April:
http://lesrapports.ladocumentationfr...00415/0000.pdf

It shows that GA in France has twice the number of fatalities than either the UK, or the US (4.2 fatalities per 100,000 hours, versus 2.0 in the UK, and a similar level in the US)

Why?

Part of the reason is because both we and our American cousins have a large proportion of private pilots trained to fly on instruments, while the French PPL is almost strictly a visual flyer with no training or access to the safety of IFR when the weather turns bad.

So they have a far higher proportion of VMC to IMC related accidents: both loss of control and "classic" CFIT.

The sort of accidents which led to the introduction of the IMC rating in the UK by wise people, and there are plenty amongst the pilot population and their passengers (no doubt some reading this forum) who owe their lives to the IMC rating.

The report makes several recommendations, amongst which, relevant to this discussion, are the need for an accessible IR for private pilots in France; an IMC rating if you will.

Amongst interesting points in the report, is the fact that 80% of Accidents are due to "Human Factors". Furthermore when human factors were studied in depth, an analysis of 60 such accidents in france found that:

"The great majority (43 out of 60, with 98 fatalities) took place in unfavourable weather, underlining the problems with lack of training, over-confidence, poor decision-making and pre-flight preparation.

All areas which are dealt-with by the IMC rating.

It would be worth one of our representative bodies going to the expense of formally translating the "French Lesson".

This is excellent.

I am happy to help with this in any way that I can.

In addition to Fuji Abound's excellent list, would we do well to complie a list of MPs who understand and are sympathetic to light aviation? I believe that Lembit Opik for example holds a PPL.

I had a go at drafting a template letter on the other thread, but I don't have enough information. Here it is again, modified a bit. Forgive the repetition, but I'd appreciate help.

It needs to be fairly pithy if MPs or MEPs are to read it. But can anyone help with the bits at the bottom please? What are we asking our MPs to do? We need to state what (precisely) we want them to do. What order, statute or whatever they should oppose. If we don't suggest what they should do, then sure as heck they won't do it.
PS - If the experts think this is not an appropriate form of letter, please draft something better.

Tmmoris

We all need this:

MEPs can be found here:

http://www.europarl.org.uk/uk_meps/MembersPrincip.htm

(second link down if you Google 'Who is my MEP' :-) )

Tim

Absolutely - you beat me to it!

Also this would be useful:

http://www.theyworkforyou.com/

(finds your MP and allows you to contact them directly)

Tim

Thank you.

Do you have a contact?

Do we have any others?

Lembit Opik's details as follows . . .

http://www.libdems.org.uk/party/peop...mbit-opik.html

He holds a PPL and less relevantly was engaged to Sian Lloyd the weather girl and dated one of the 'Cheeky Girls' :ok:

A Google for 'MP pilot licence' produces of course Opik but also:

Grant Shapps (Con) - Welwyn Hatfield
Gerald Howarth (Con) - Aldershot (also Shadow Defence minister)

but there must be more, even if they are lapsed.

Tim

Thinking about it, Lord Tebbit has more than a passing interest in aviation and was an airline pilot before entering politics.

He seems to like a scrap with the Europeans and could be a useful chap to get on side.

Don't think he ever dated a 'Cheeky Girl' though ;)

though there's a danger that like many airline pilots he thinks the IMCR is a dangerous waste of time!
Tim

There's also the conventional appeal to human rights - in a liberal democracy the idea is that we don't take away someone's right to do something without a good reason.

I think we need to start with a list of pilots willing to support resisting the dropping of the IMCR.

What about a web site with some background information and a place where you can register your email address?

Excellent ideas.

One thing I would point out however is that we need to save the powder for when it will have the best effect.

Currently this stuff is in what might be described an early committee stage within EASA. These committees are stuffed with highly prejudiced people who are for the most part out of touch with GA - even if they ever were in touch with it.

Fortunately, these committees, whose representatives are not elected and whose makeup we cannot hope to influence anyway, are not the most harmful stage of the legislative process. It is what comes afterwards.

Let me also add this is all tied up with the N-reg issue, because the FAA option would be a natural escape route for the more determined IMC Rating holders. So if you fly an N-reg or know somebody who does, this affects them too. The two issues are closely linked.

Fuji,

Well done.:ok:

And Pilot H, very interesting French Lesson.... I guess we need as many hard facts as possible.

Thanks for starting this thread, you have my full support.

Maybe we should get the Cheeky Girls onside too;)

Thank you - 3Y and I0.

The French lesson is very a superb contribution.

Please keep the comments coming.

I am going to see if we can roll out a petition and a dedicated web site if I can.

Anyone like to get something going on Flyer please!

Julian,

Lembit is already aware of the IMCR situation and has pledged his support in an article in the latest issue of FTN.

I suspect however, that little will happen before a Notice of Proposed Amendement (NPA) concerning the IMCR is released in the New Year by EASA.

I suspect that this is the cause of the majority of accidents in most countries. I think we need to be careful in the way we draw conclusions. The report is interesting and highlights that more regulation does not equate to better safety. It points to the better fatality record of the less regulated ULM sector and also concludes that flights from within the strong club environment generally result in fewer accidents. The report is an argument for devolving downwards the responsibility for flight safety to 'local' organisations. It comments on the unsuitability of a regulatory system aimed at the professional pilot for regulating leisure flying.

The report is not unfortunately an endorsement of the IMCR ! It points out the relative similarity of accident rates in the US and UK. Whether that can be turned into an argument for an IMCR I doubt. It may be an argument for a more easily obtainable IR, but the report does not say so. It seems more to support the concept of a sports aviation licence (lightly regulated but with a safety and skills ethos being strongly promoted at local level), which may or may not be ICAO compliant and I would guess would be restricted to day VFR, but I bow to others with far more knowledge on this aspect than I have.

It may be an argument for a more easily obtainable IR

Since there is close to zero prospect of getting a significantly more easily attainable IR in Europe for some years, I would say that makes it a reasonable supporting case for the IMCR.

Yes, the assumption that the choice is either (a) a euro-wide IMCR or (b) no IMCR at all anywhere, is fundamentally flawed and totally stupid.

But that is how Europe is working in this instance.

They would probably like to mandate that we all have greasy hair like the Italians, but that would be politically difficult :)

I do not have any idea whatsoever why national ratings cannot continue. It just seems a pointless piece of political ideology.

The likelihood of a Euro IMCR is prop 0.1%. The airspace structure in Europe does not support the IMCR type flying like the UK. French Class D airways for example, germany has no concept of IFR flight outside CAS etc etc.

If you are going to continue with this crusade you have to actually decide what exactly you want and stick to your guns. You also REALLY need to get an understanding of the rule making process rather than just shooting from the hip.

As IO points out there is very little sense in pointless rule making, yet the Europeans are fond of signing up to pointless stuff. Look at Galileo.....

Agreed. Surely the objective should be the maintenance of national ratings for use in that country's airspace? There seems to be a dawning recognition even in the EU that people are being turned off by the top-down regulatory approach and that devolution of regulation and responsibility is the way forward (as mentioned in the French report, above). The one size fits all approach no more suits us than it would the French with their mountain ratings and there may be other countries who also have their own licneces and ratings which they are equally attached to.

What you mean back out of the agreements that we have already signed to hand over regulation to Europe? Keep the current system of 'common' standards with national control?

We would have had the opportunity to respond and make representation, even forming a working group to try and make the IR more available in the event of the loss of the IMCR.....

I think what Justiciar is suggesting is that national ratings would stay under EASA, but only be valid in one particular country.

For example, the IMC rating would simply be an EASA rating, which could be attached to any EASA licence issued by any EASA country, but would only offer privlidges within UK Airspace. I could add an IMC rating to my Irish issued EASA licence, but I could only exercise it within UK FIR's.

Likewise a UK issued EASA licence could add an Altiport rating to it, but again it would only have privlidges within French airspace.

Specific 'local' ratings for on an EASA licence....seems to make sense.

dp

dp, Thats exactly what we had under JAA (which worked fine in my mind) but under EASA we do not have this option. Under JAA the national authorities were responsible for licencing with there own ANO etc but fitting into the JAA framework.

Under EASA we now have a European aviation authority that will have a european ANO and issue a European licence. It is because EASA are the licencing authority now and they have declared there will be no national differences that we have the issue.

We have signed our rights away completely.

The Norwegians have it right.....Get all the benefits of Europe while remaining outside of the EU...

Nice fjords, too.

If you read the report fully, you will see that it does indeed argue for a more easily obtainable IR, which is about all they can do, hamstrung as they are with airspace and rules which could not permit an IMC rating.

It also cites the British NPPL as a good thing (in the context of a sidestep from JAR-FCL) Given these points, and the fact that their fatal accident rate is twice as bad as ours, it is an endorsement (albeit tacit) of the IMC rating, and shows where we will be without it.

A few relevant parts loosely translated:

"JAR - FCL: A training system poorly suited to private pilots
The JAR-FCL training system is concieved as a professional qualification structure, because it aims to train pilots from ab-initio and bring them to a professional level, (CPL, or ATPL) whether by the integrated route or the modular route. In this second case, the training for a PPL constitutes the first step on the route to becoming a professional. The training programme is therefore conceived and implemented with this view, without being particularly adapted to pilots who consider the PPL as their goal...."

"Certain countries, such the United Kingdom, becoming aware of limits of JAR-FCL decided to impliment a National Private Pilot Licence, whose privileges, naturally, can be exercised only within UK airspace.

It is in this framework that we look towards private IFR flying: even though the JAR-FCL Instrument Rating concerns probably a very limited number of Private Pilots, due to the implicit requirements and costs (maintaining an appropriate level of currency requires regular practice on relatively complex aircraft), it doesn't make it less true that the qualification itself is percieved as very difficult to obtain. The major obstacle cited, with good cause, is the theoretical training, the requirements for which appear dis-roportionate to real need.
Henceforth, nothing should oppose the implementation of an Instrument Rating theory appropriate to the PPL"

.. .. .. and the answer is,


we are going to try and get a national difference agreed.


On an aside issue, I was pondering how EASA intends to enforce its new ANO. Presumably this is to be left to the respective national authorities (who will effectively be EASA satellite offices). For example, a pilot is accused of low flying - will this still be prosecuted through the local magistrates court?

On another side issue what will happen to the special exemption permitting pilots to operate in class A without an IR for the purpose of parachuting, glider launching or high performance civilianised jets? Are these to be national differences, rights abolished or exceptions?

Good luck. I hope you succeed. Who will you be approaching to get this exemption?

I am curious about the Class A airspace exemption you mention, please can you point me in the direction of it?

Yes you are quite right about prosecutions etc, they will be left to the local CAA office with European visibility.

Yes, you are right - that is the trouble with speed reading a 62 page document in French :oh:.

It mentions the content of the extensive theoretical element as not being suited or necessary to real conditions. It also suggests that a reduced theoretical knowledge could be devolved down and be administered by local organisations.

All this supports what I believe bose-x and others have been arguing for, a review of the training requirements of the IR across the EU which only incorporates those elements necessary for the IR and places other airline orientated parts in their proper place, i.e. in the CPL or ATPL exams. There have already been some changes to the theory element in JAR-FCL 1 but these await implementation by the CAA (bose-x will shoot me down if I am wrong on this).

We have to fight for what is achievable. Reading what has been said it seems that national ratings will go - we should not be wasting time arguing for something which is not achievable in the current legal structure (and I doubt the UK will or can withdraw from EASA). Can any country file national differences as they can under ICAO? I don't know the answer nor what would be involved in doing this.

What we seem to have is support from other countries, e.g. France, for the idea of devolving down the implementation of EASA licensing requirements and training. We could therefore see exams administered at local level as in the PPL training. We already have a split in the practical training requirements. Perhaps we should be building on this.

I think there is a significant danger in that line of argument.

It is simply that the IMCR will go as part of early implementation of legislation but will not be "replaced" in a hurry, or at all, with a "simplified" IR.

History would seem to predicate that there is not an appetite for a simplified IR.

Personally, I think this would be a very wise alternative and I wish Bose and AOPA very well in their quest.

EASA has a mission statement:

"Our mission is to promote the highest common standards of safety and environmental protection in civil aviation."

The abolition of the IMCR hardly promotes safety, especially if it is not replaced with an alternative. Moreover, arguable for those with an IMCR already adequate for their purpose withdrawing their existing rights without offering an immediate alternative is contrary to EASAs mission.

This is where you miss the point entirely. In the opinion of the rule makers you already have an option for flight in IMC it is the IR. It is the only option that the rest of Europe have. So as far as they are concerned this is a non issue. It is only because you have the IMCR that is so easy to obtain that the IR looks so difficult and while I completely agree the accessibility is not that great which is the fault of our own CAA to a large extent, the IR is not difficult to do.

Like I said I am just pragmatic. However I really do wish you the best and will watch with great interest your progress. Mostly to work out where to insert the 'I told you so's'........ :p

II am afraid that those two sentences defeat your own argument. There will be, under EASA no legal basis for the preservation of national licences and ratings. It is not a question of arguing for the use of a power to allow the continuation of national licneces: there is no such power, as I understand it. The only way of doing that would be by the UK withdrawing from EASA. I doubt that is possible or likely.

Certainly, changes will take some time. How long have the changes to FCL 1 taken? Several years, I suspect. But then the CAA is not noticable by the speed of making changes to legislation.