IMC - what's the latest ?
 

Anyone know the latest on the IMC ? Are they still set to scrap it in a year or so ?

Apologies if I'm ploughing a well trodden path ... it doesn't apply to me so I haven't been keeping my eye on it : but I was talking to a guy yesterday about IF who said he'd like to do it, but didn't know if it was still worth it. I know that one or two on here used to be very close to the subject ...

Latest is that the EC have given EASA a kick up the backside and told them to stop re-inventing the wheel.
AOPA news here.

Quite so, Mike!

Currently the UK IMCR does not form part of EASA part-FCL's NAP17b proposals. However, the EC commissioner responsible for all transport matters is a supporter of the UK IMCR, as is an influential MEP.

So EASA now has a working group with the catchy name of FCL.008 who are looking at the future of instrument qualification requirements in Europe.

FCL.008 includes UK representation, so you'd think that we could be reasonably assured that the future of the IMCR was being well protected....

WRONG!

One of the UK representatives has been advocating a cruise-only IMCR called the 'En-route Instrument Rating'. This requires the same theoretical knowledge requirements as the proposed PPL/IR, but has no approach privileges. The person who dreamed up this lunatic idea considers that there should be 'almost certain' VFR conditions for take-off and landing (whatever that means), so the EIR holder can then go and play airliners without being concerned about going IMC in the cruise.

AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR and has asked IAOPA to tell the FCL.008 group that the UK advocate of this EIR does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.

Much is going on behind the scenes to protect the UK IMCR and to ensure that it has a viable future. So if anyone is considering training for the IMCR now, my advice would certainly be to go ahead!

In any case, there's a good chance that EASA will heed the well-deserved handbagging they received from the EC and will remove their attentions from sub-ICAO licences and ratings.

Beagle

They obviously now realise the safety aspect of the IMCR so dont know how to argue away the IMCR.

Hence my concern is a very watered down European IMCR which is no way could be classified as an instrument rating.

On previous postings I have always advocated pushing for an FAA like IR for PPLs as my concen was that pushing for a European IMCR would not get what we want.

My post in that thread feared that offering a very watered down IMCR would get them off the hook of addressing a proper PPL /IR while infact giving us nothing.

My post in that thread invisaged an enroute IMCR with approaches only on a declared emergency this doesnt seem that far away?

The problem is that nothing in flying is black or white VMC or IMC. It is easy to say assured VFR at destination but VFR at destination can easely be minimal VFR in minimal VMC which in no time can change to IMC.

Are pilots expected to be jumping from IFR to VFR just to suit regulations?

Are PPLs expected to add risk to suit regulations? IE is it safer in minimal VFR to approach an airport you dont know in terrain you dont know in minimal VFR or to stay IFR with vectors or a proper procedure.

The answer is pretty obvious. They need to stop playing politics and come up with a sensible PPL IR that is achievable for the working PPL and in the name of safety.

Pace

...which will never happen.

Can you imagine EASA accepting an IR with one ground exam, taken on a computer whenever you want after self study and some ground school from your CFII?
Can you imagine EASA only REQUIRING 15 hrs of instrument instruction, the rest of the "instrument time" made up however you want (safety pilot for ex.)?
Can you imagine EASA giving credit for previous instrument time?
Can you imagine EASA allowing rolling currency requirements?
Can you imagine EASA allowing a lapsed IR to be revalidated by FI and NOT examiner?

If you can imagine EASA allowing this lot then you do have an IR akin to the FAA IR. Unfortunately they would NEVER allow 99% of this and so we will NEVER have an IR akin to the FAA IR.

What really needs to happen is for the Gold Plated JAR IR to be re-hashed and a new ATPL flight test and ground exams introduced at 1500 hrs. That way those of us who don't want to fly a Boeing don't have to meet Boeing standards or requirements.

Who is the "UK representative" who is calling for the cruise-only rating ?

Are you referring to a member of FCL.008? No one on the committee represents themself.

Where is the statement from AOPA to which you refer?

Englishal

My problem is I cannot imagine EASA doing much at all :ugh:

I cannot imagine EASA taking on the IMCR in its UK form as a European wide rating or for that matter creating anything that steps on the toes and existing structure of the IFR world that exists at present.

I can imagine EASA looking for a way out from the fact that the IMCR does improve safety in the GA/PPL community.

I can see them offering a gesture as a very watered down meaningless rating with the same name as the IMCR. Then they can turn around and say "there you are a European IMCR so your now happy". The fact that it is a bare ghost of its former self wont matter an iota to them.

I dont know what the answer is maybe just to say " No we need this in the UK on safety grounds and will NOT abolish it in the uk, full stop".

But other than tea and biscuits and appoving burps dont expect anything from EASA like you said i cannot imagine :sad:

Pace

From the latest AOPA Newsletter:

Great maybe EASA will go and fade away as a bad job. The FAA could always cover the position until something better comes along.... sort of stand in :D

think how much money the industry would save without all the quangos beurocrats meddling and wrecking everything at present and at vast costs all round.

Pace

...which will result in the end of the IMC rating with no replacement whatsoever.

No, it won't. Competence for sub-ICAO matters would be devolved to national authorities under the principle of subsidiarity. The Basic Regulation might need to be amended to support this, however.

There is an alternative strategy should the EASA €urocrats fail to accept the UK IMCR as it currently stands.

The pain problem is that the bumblers at EASA cannot understand that you don't need the same levels of training to operate to IMCR minima as you do to IR minima - and that such IMCR minima are entirely adequate for the vast majority of private pilots.

That Rating
 

so here i am, still none the wiser........
ive already put on hold my imc training... after doing a number of hours already.the impression i got was that easa was going to introduce a form of (light ppl ir) but im not sure exactly where i got that from.......
so whats the general consensus of opinion from you knowledgable people
should i think of booking and continuing my imc or should i wait .......in the hope that easa will slide slowly and painfully into total chaos and therfore somebody in command in whitehall /brussels or wherever these eurocrats reside will suddenly look up from his/her expenses claim form and realise that easa is just a croc of timewasting and expensive paper generating quango upholding cr*p (rant over .....but it felt good )
id love to continue with the rating but im reluctant to spend money that may result in a non rating in a couple of years
thanx for looking
best regards to all
pete

It is rare to find a rating lost without some form of grandfather rights - in fact I dont think it has ever happened. Moreover all those people who have spent £x on a rating and find they have lost their priviliges (if that were to happen) are going to be prettied annoyed. I suspect there would be a rather unpleasant backlash.

Perhaps that helps answer your question.

That Rating
 

thank you Fuji
my thoughts entirely, however easa seems to be riding roughshod over us all.
regards pete

They may, we will have to see, but if they do, you, I and several thousand other UK pilots may still have something to say. If it all goes wrong all hope is not yet lost.

I share the same concerns as 'pa28r driver'. I'd like to do my IMC some time in the future but am concerned about what EASA are going to do with it. It seems silly that they're making such a hash of things; because I'm sure there are other pilots out there who share the same concerns and thus being put off doing valuable training.

(But thanks for the rational explanation Fuji!)

Disregarding the regulatory considerations, it has been stated on this forum many times that the skill set provided by good IMC training (and maintained through including IMC sorties with your VMC flying) is something that cannot be taken away from you. It enables you to deal with the obvious - entry (inadvertent or not) into cloud - as well as those conditions where although the conditions are technically VMC, instrument skills give you comfort: water crossings with no apparent horizon, hazy days where the VV is fine but horizontal visibility is terrible.

It's a fun course. Go for it. The ground exam is not difficult (but many people prefer to study beyond the requirements for the theory exam - Air Pilot's Manual Vol. 5 is good for learning about holds etc. that are not required for the IMC skills test).

When would "now" be a good time?:ok:

Anyone who wants to do an IMC rating, but decides to hold back or abandon it due to what may, possibly, sometime in the future happen as a result of EASA is rather stupid IMHO. The skills are invaluable and it will be years before anything happens. If it happens.

LondonFlyer's comment is very valid (and thanks for the EDDI chart - managed to get there before they closed it :cool:). The skills the rating generates are far more important than the rating itself IMHO. Those of us whose licences are not held on the UK register have no chance of such a rating, yet I and many of my friends undertake regular instrument-based flights with instructors and safety pilots and informal ground-school to prepare ourselves for the conditions the IMCR covers.

I suspect EASA will come to some arrangement (perhaps grandfather-rights, perhaps some "fudge"), but either way don't be put off the training.

Beagle, apologies in advance that I'm in a rush and don't have time to phrase my reply as politely as I should. You and others take the subject seriously, so perhaps some facts might be useful, although I know they are always a nuisance when they get in the way of a good rant.

Firstly, you refer to individual, personal stances taken on FCL008. I can only conjecture a reply, because, as I understand it, the workings of this group, like any such group during its working phase, are confidential except for agreed releases of information into other domains. Therefore your are either
a) making this up
b) posting details in the public domain that are a breach of confidence by you or someone along the chain of chinese whisperers who gave you this "information"

I will use your method of typing 'wrong' spelt in capitals.

WRONG!
I agree. You'd be totally wrong to think that. One thing that is in the public domain is FCL008's terms of reference, which I am sure someone who feels strongly about its inner workings would have read. The scope of FCL008 was not to "save the UK IMCr". It was to review the IMCr and other national IFR ratings to see if there was an EASA-wide analogous qualification that could be agreed. The EIR was the best such structure that could be agreed. The proposal that the UK IMCr should be adopted across Europe is not acceptable to the rest of Europe. It simply isn't. And FCL008's job was to find a proposal that was. The individual who worked on that succeeded in a difficult task

WRONG!

You should write to Australia's NAA and tell them an enroute instrument qualification is 'lunatic'/'chocolate tea pot' etc etc. They have been labouring under a delusion that it's a safe and effective stepping stone to a full instrument qualification.

I'll tell you what it means. You take-off VFR. You plan to land somewhere and the forecast has to give you reasonable confidence you can do that VFR. You make this sound bizarre and unfathomable, but hold on.....it's what you do flying VFR. That's why it's an Enroute qualification.

No-one has claimed it is. The only rationale for the EIR is that it is the best EASA-wide sub-IR qualification that could be agreed.

Saving the UK IMCr is a different matter. A while back, it seemed there was no scope for countries keeping national qualifications. EASA made it clear that they were taking over sole jurisdiction for all pilot licensing and if something wasn't in EASA-FCL, it couldn't exist. It now seems to have back-pedalled on this, and there may be a prospect of the UK hanging on to the IMCr. If this happens, great. If not, and the ranting of the UK IMCr militants kills off the EIR, then the IMCr community will be left with nothing except the full IR.

The best reason to keep the IMCr in the UK is that it is a good qualification which works and is proven. The worst reason is the IMCr-militant-ranters position that the rest of the aviating universe are dangerous lunatics for not supporting the IMCr everywhere in Europe. It's just laughable to Europeans to hear a UK minority proclaiming the rest of the world is wrong and out of step with the UK.

And who do you speak for? At least the people on FCL008 know what they are speaking about. FCL008 is not a save-the-IMCr-crusade. It's a group to develop EASA-wide IFR amendments to EU-FCL. The IMCr is not acceptable to Europe as an EASA wide qualification. So what should that group have been doing? If what you report about FCL008 is true, I am glad this "individual" is there. It sounds like he is able to grasp the basics of terms of reference and purpose of a specific regulatory body.

Instead of lambasting FCL008 people for something they are not empowered to do (save the IMCr) and criticising them for doing their best on what they are empowered to do (find acceptable EU-wide amendments to FCL) why don't you just go and save the IMCr yourself.

brgds
421C

If the Aussies had the IMCR, they wouldn't need to consider the absurd chocolate teapot rating either!

If you keep up with the aviation press, it is quite easy to elicit the current FCL.008 stance.

It is specifically because of this lunatic EIR idea that I am indeed involved in 'saving the IMCR'.

That is no justification. The whole idea of this absurd 'EIR' is nonsense. Recently AOPA's General Aviation requested readers to respond with their opinions about the idea.

Guess how many were in favour of the EIR?

You can find out in the next edition.

You're right. It's not just Europe - it must be that the Aussies, and all the other 100 ICAO countries (or whatever the number is) except the UK are chocolate teapot lunatics for not having the IMCr. Even if you believe this, you must see why outside the UK it's perceived as a ridiculous, laughable position.

You are right. It's not a justification. There's nothing to justify. It's a factual outcome of the FCL008 process, the best sub-IR qualification the group could agree on was the EIR. No-one is telling you that it's better than the IMCr for the UK or a replacement for it if the IMCr can be saved. Go and save the IMCr, as I said.

I don't need to. I can guess. I can also guess if you asked AOPA members whether we should scrap all the EASA regs and just cut and paste everything from the FAA, they'd prefer that. I would. But it's a hopeless cause. Just like getting EASA to accept the IMCr across Europe.

The point of the FCL008 proposal is
a) that it's something European pilots might want as better than nothing - because they don't have an IMCr to save (and forgive me if it comes as a surprise that FCL008 had to consider the interests of non-UK pilots too)
b) that it's something that UK pilots might want, as better than nothing, if the IMCr can't be saved.

I just don't understand your hostility. I can understand why you might prefer the IMCr, or even strongly prefer it. But your remarks about lunacy and chocolate teapots are just ranting.

One thing I do like about the European attitude is the airspace issue. We accept the IMCr in the UK because we accept that vast swathes of low level airspace like the London TMA and the CI zone should be Class A and that all airways should be Class A - totally barred to VFR traffic and non-IR holders. This would be considered chocolate teapot lunacy almost everywhere else in the world. The very fact that a light aircraft might want to fly in an airway is so extraordinary to you that you castigate it as "playing airliners". This is a uniquely parochial UK perspective and I am very glad it prevails in few other places. It would be bafflingly lunatic to most other countries. That's, in part, why our IMCr is so silly to them.
Enroute IFR is much easier to train for than instrument departures, arrivals, holds and approaches. Ask any IR candidate how much they struggle with the "flying along the airway" part of the IR. Yet we have a qualification which is sub-IR that permits all the difficult parts of the IR and not the easy ones. This, anywhere other than the UK, is chocolate teapot lunacy. We accept it because we accept the default undertone in the UK that the sky belongs to NATS and the airlines and they can keep inconvenient users out - because there can be no other reason for the prevalence of Class A. EASA does not accept this kind of "user segregation by airspace" and I am glad they don't.

brgds
421C

Rant all you like, but any so-called 'instrument qualification' which runs the risk of the user being unable to make an instrument approach because the 'almost certain' VFR conditions turn out not to be is just plain absurd.

Who is going to be brave enough to try to define what 'almost certain VFR' actually means?

The UK has 40 years of proof that the IMCR saves lives - the rest of Europe certainly should listen.

FCL.008 talks about 'preserving grandfather rights' for the UK IMCR and the 'wonderful opportunity' to spend thousands of pounds 'upgrading' to the PPL/IR. Nowhere have they said that they support the retention of the UK IMCR; the lunatic EIR is not an acceptable alternative and needs to be strongly opposed by anyone with any concerns about safety.

I agree with BEagle about the (unnamed) bEurocrat's sticking his silly, uninformed nose in.

From conversations I have had with various people "in the know" and others actively involved in EASA negotiations, it appears to me (and others) that the likelihood is that not only will the IMC rating continue, but will be recognised in Europe, with other states introducing their own equivalents.

The format of the IMC rating may well change, however, and in other, similar situations those with grandfather rights on any change of legislation have never to my knowledge been let down. That is reason (1) why people should IMHO continue their training.

Reason (2) is that the requirements may be stricter in the future, although I believe the privileges that go with it will remain unchanged. You would therefore have to work harder for your rating in the future.

Reason (3) is that, even if the IMC should vanish below the surface without trace and nobody with one be approved to do anything beyond standard VFR flying, the IMC training is good discipline. The abilities that come with the training will stand anyone in good stead should they find themselves having inadvertantly departed VMC. Let's face it - SEN APP is not going to refuse an ILS to a PPL (deceased IMCr) if they have, from no or little fault of themselves, suddenly found themselves VMC "on top" and the only way down is an instrument approach through a thinnish layer if the alternative is that they spend the rest of their lives looking for a hole to descend through. Should someone need an ILS in such circumstances, it would be very much preferable that the pilot has been trained to carry it out rather than "busking" it untrained.

There is no point whatsoever to an "enroute" IMC rating with no approach privileges or training. If you get into IMC enroute (or even if it's only VMC "on top") you need to get clear of that weather somehow. So not having approach privileges and training is lunatic. What is also lunatic is the "almost certain" stipulation - one can only assume that the idiot who recommended this is not a pilot.

My only input here ;) is going to be to say that almost everybody who takes a significant pre-emptive action in fear of threatened future legislation if that legislation appears unpopular and exceptionally aggressive yet bringing no personal brownie points to those forcing it through is going to lose their money.

The most obvious examples are of people who went N-reg (in preparation for the FAA IR) and then, when the DfT threatened to kick out N-reg planes after 90 days' parking they got scared and went back to G (£10,000 perhaps??) and thus have scuppered their IFR privileges for a few years and possibly much longer.

The "UK IMC" issue is a similar sort of thing.

As others say, things are invariably grandfathered into something else...

I would definitely do the IMCR.

One statistic I haven't seen (AOPA - perhaps you are listening and could ask?) is:

Of those who hold an IMCR, how many wish they could afford an IR?

In other words, for how many of us (like me) is an IR what they really want, but they simply can't afford the money and time off work to get one?

I suspect the number is very large.

Tim

tmmorris, it's probably not just the cost, there's also the disproportionate theoretical knowedge requirement.

But really - something like 25 hours more training, a test with the CAA plus CPL-level exams just for 200 ft or so lower at Decision Height and the right to bumble along airways?

No thanks - the IMCR fits the bill perfectly for very many people.

It is frustrating to be barred from class A especially places like WAL when travelling north/south, but without the IMC rating, even with its limitations, I would probably have given up flying years ago due to the number of cancelled trips.
The senario of being based in the flatlands under the London TMA as opposed to being based in Scotland is very different.
DO.

A little history. Prior to 1970 PPLs flew in IMC outside CAS (such that CAS existed). These pilots held no rating and received no training as part of the PPL. The more sensible took some instruction and flew VDF let downs.

It was decided that training and a formal qualification made sense. Of course many pilots had already acquired the ability to fly on instruments. They were grandfathered into the new IMC rating by test alone; everyone else undertook 10 hours of training and a test.

I doubt the merit of comparison with other countries. In those days GA was strong in the States and reasonably strong in the UK. The US went their way and devised an Instrument Rating that was widely accessible. In our indomitable way we devised a rating that enabled the private pilot to continue doing what he had always done, but kept him out of the airways. In other countries, such that GA was a popular pursuit, pilots continued to find there own way on top of the cloud much as they continue to do today. South of the UK they rarely had the need to fly in the clag and north of the UK – well they just didn’t.

For those reasons the IMC rating is unique to the UK.

It has stood the test of time – and what better test is there? Its safety record is exemplary, some say there has never been an accident involving an IMC rated pilot in instrument conditions, and some say there has been a very few accidents. Which ever are right it is a remarkable success story.

EASA was mandated to enable a common regulatory framework among member states. That meant out would go national ratings and in would come single European ratings. The trouble is no one told the French. They rather liked there mountain rating and weren’t about to have Johny Foreigner. landing on their altiports any more than they were going to have us teach them to ski. Ah yes then there was the Brevet de Bas, they were also not about to give that up without a fight. No one else in Europe really cared about the Frog’s rather quaint ratings – after all they didn’t have mountains, or if they did, they didn’t have many mountain airports, or if they had both, they didn’t have any GA.

They did however care about the instrument rating. The professional pilots associations that dominated EASA certainly didn’t want amateur pilots playing with the big boys and, in any event, they didn’t understand the IMC rating because, after all, they didn’t have it. If those dumb Brits. had a death wish that was up to them, but they weren’t going to do it in their airspace, nor where they going to Lord it up in EASAs airways while everyone else played catch up.

The trouble was no one thought to ask us. Worse still, no one thought to establish whether their preconceived ideas had any foundation. Regulatory impact assessment – what was that? Event the bastions of the UK GA community didn’t really know what they thought or which horse to back.

EASA received their first surprise when two and half thousand British pilots petitioned the PM and generally caused quite a rumpus about the threatened demise of the IMC rating. Timothy Kirkhope one of our MEPs and a keen pilot waded in. An “emergency” meeting was called in London hosted by the CAA and EASA at which EASA acknowledged they were not about to so readily kill off the IMC rating.

EASA then went into closed session. Committee members were required to sign confidentiality statements and the leeks started – so much for open Government.

So where are we? EASA realise the IMC rating is a hot chestnut. They have to placate the Brits. but they don’t really want the Brits well, erhm, being cowboys.

Of course we Brits know we are not cowboys – well any more than the French who just punch through the clouds to get on top with a shrug – I neeeever saw any cloud.

Fortunately there are still lot of pilots in GA in the UK. Sadly they come and go, and the turnover is high, but many put themselves through an IMC each year, renew their rating for many of the years they remain in GA and come to appreciate why the IMC rating is so important.

If enough keep the faith those doubters in Europe will not have their way, but we may need to be prepared to fight for our rights.

Sorry to have bored you.

Good post :ok:

Not me. I'm sure I could afford IR if I wanted to, but I don't really want airways or other Class A flying, and wouldn't use it enough to remain sufficiently current.

However, I fly IMC enough for the sort of flying I do - which means keeping to my own very conservative minima.

Paradoxically, and this is the great secret of the IR ;) , flying "airways" is a lot easier than using the IMCR to its full in UK Class G.

It is not unusual to do a 5hr flight and log 10 minutes of instrument time on it. The rest is VMC on top in sunshine.

The IR gives you IMC privileges, obviously, but the equally practically important privilege is the implicit whole-route IFR clearance. You can fly across Europe, knowing nothing about controlled airspace, or even countries. The other day I did a 6:20 flight across half a dozen countries and barely noticed the changes.

Does JAR-OPS1 (or EU-OPS now) not require that before you depart on an IFR flight the weather at either your destination or an alternate is forecast to be "almost certainly" above your operating minima? Is that also mindless bureaucracy that couldn't have come from a pilot?

I'll tell you what it means. You take-off VFR. You plan to land somewhere and the forecast has to give you reasonable confidence you can do that VFR. You make this sound bizarre and unfathomable, but hold on.....it's what you do flying VFR. That's why it's an Enroute qualification.

Let’s examine how this might work in the UK.

Firstly, the TAF is not going to tell you “if almost certain VFR conditions” will exist at your destination.

It will tell you if the cloud is scattered, broken or overcast – at any rate so far as the lowest layer is concerned. It doesn’t necessarily tell you much about higher layers.

Now for the VFR pilot that is all fine and Dandy. His intention is to stay below the lowest layer. He doesn’t really mind if the scattered turns into broken or the broken into overcast. What he does care about is that the Met boys don’t get the base wrong and he finds himself squeezed between the terrain and the base.

The IMC pilot’s modus operandi is a little different. Our man is worried about getting himself up into the airways. He is not too bothered what he finds in the airways because within reason he can now fly through cloud. However he wants to ensure his let down is “almost certainly going to be VFR”. The forecast was scattered at 1,000 feet so that seemed good enough. The trouble was the met boys didn’t tell the clouds who decided a little more organisation was called for – scattered became broken, how often have we seen that. Now our man is flying the approach, but what should he do – he feels comfortable following the procedure, but there are more than a few pesky clouds in the way. Perhaps he will dodge around and between them – yep that should be fun. Trouble is no one told the radar controller that EASA had just invented the dodge and weave approach.

That is a simple example. In the real world there are all sorts of different examples why who ever dreamed this one up has no idea what they are talking about. The funny thing is they don’t even realise that some at EASA get exactly what they wish – the effective end of the IMC rating and no meaningful change to the IR. Its brilliant – Sir Humphrey at his best.

God save us if if we end up with this sort of silly instrument en route rating.

Exactly.

With an IMC rating, I would not plan to fly an instrument approach on my own with forecast cloud base below 1000 feet. But on a journey of more than an hour, say, a TAF of BKN010 can turn into a METAR of BKN005. Now the IMC rating teaches bad-weather circuits with a cloud base of 500 or 700 feet, but how do you get down from IMC to VMC well below MSA? That's why an IMC rating must enable pilots to fly an instrument approach.

Beagle,

You keep saying "almost certain", a choice of words which I don't believe anyone would put in a piece of regulation. Please give your source or reference. FCL008 has not finished AFAIK, so I doubt any final wording is settled. Something like "the forecast indicates" is more likely, I would have thought.

What about the so-called "Private Pilots License", which (just about everywhere except the UK) allows holders to fly in VFR above IMC. You probably aren't going to claim almost every non-UK PPL is 'chocolate teapot lunacy'. How is the VFR on top scenario different? You find yourself above a solid layer. Big deal, you got a weather forecast that indicated VFR at your destination or somewhere enroute. So that's where you establish VMC in sight of the surface.

We don't need to look far to wonder why other countries might oppose the IMCr. Your utter intolerance for the EIR is a good illustration of how parochial people's reactions are to unfamiliar qualifications. I am agreeing that you might prefer to IMCr and only debating your view that the EIR is "lunacy/dangerous/choc teapot" etc. Why should Europe be interested in how well the IMCr works in the UK any more than you were interested in how well an Enroute qualification works in Australia. You dismissed it without a moments consideration.

Have you ever stopped to consider how the IMCr might appear to other countries, especially countries who actually apply the prinicple of equal access to airspace for all users, rather than the UK's Class A segregation?
The IMCr gives holders all the privileges of an IR (except for some departure minima) but its standards are below the ICAO minmum for an IR, and that minimum is a pretty undemanding one. It lets you accept a SID or STAR or Hold in controlled airspace without necessarily having ever been shown a terminal procedure plate, let alone having been trained or tested in terminal procedures. You don't think the words dangerous-chocolate-teapot-lunacy might spring to their minds as readily as they spring to yours?

Fuji,

I agreed with much of your post, except the bits about the Moutain Rating and the Brevet de Bas.
What possible objection could anyone have to the Moutain Rating? So why criticise EASA for adopting it?
But you must know why EASA couldn't accept the IMCr as a European rating. Airways and many very large airports are not Class A in much of Europe. If you think the UK experience of the IMCr is so good that EASA should have accepted it, then why not start with our own CAA and get them to accept IMCr privileges in UK airways and the London TMA. Then we could tell Europe why they should accept the IMCr in their airways and large TMAs.
The Brever d Bas is another example of intolerance. It must be dangerous and lunatic to not allow our sub-ICAO IFR qualification, but it is dangerous and lunatic to allow someone else's sub-ICAO VFR qualification.

brgds
421C

Fuji, my previous post ccrossed with yours....

...however I think it answered it. The point is that VFR pilots everywhere else in the world don't have to stay below the lowest layer. They can fly VFR on top. So your UK scenario of the EIR holder getting into trouble is tested all over the world by hundreds of thousands of PPL holders who could fly VFR on top and have analogous issues about landing VFR - and who may have practically no IFR training if things don't work out weather-wise.

So just as you ask people outside the UK to accept the IMCr works, is it possible for you to accept that pilots can be in or above a cloud layer enroute and through sensible weather planning still land under VFR, based merely on the experience of practically everywhere else in the world.

As I said before, the struggle you and Beagle are having with this EIR concept should entirely answer the question as to why people reject the IMCr. People reject unfamiliar qualifications, and, it seems to me, the most militant IMCr campaigners are the quickest to cry wolf on qualifications and practices unfamiliar to them.

421C,

How does a pilot with an en-route IMC qualification get safely position himself or herself for a visual landing if cloudbase is below MSA? In practice this would seem to mean TAFs forecasting cloudbase of at least 2000 feet, to ensure it doesn't actually go below 1000 feet, in which case why bother with the IMC rating? You can comfortably fly VFR below cloud.

I don't think there's any such thing as "virtually certain VFR" at the destination, not in the UK at any rate, unless the weather is so good as to make the en-route IMC qualification irrelevant. The "chocolate teapot" analogy seems pretty apt to me.