IMC proposal
 

Do I hear on the grapevine (and the F***r forum) that there is a concrete proposal from the EASA working group concerning the IMCR for europe? An enroute rating which requires VFR when you depart and land....?:rolleyes:

Some members of the FCL.008 group have indeed proposed such a lunatic chocolate teapot rating....

Nothing like the tried and tested UK IMCR! It would require the same theoretical knowledge requirements as the PPL / IR, yet would include no instrument approach privileges whatsoever.

We did this one a few weeks back. The idea did not go down to well amongst the save the IMCR brigade (may I add justifiably so)although sadly its exactly what I personally was fearing would come out of EASA.

Do a search and you will find a lot on the subject already discussed.

Pace

I don't think that is at all the case, Beagle. It may be worth reviewing the proposal, as published in e.g. Flight Training News some months ago.

I am in two minds about this thing.

On the basis that an extra privilege is always a good thing, this would be a fantastic thing for European private pilots.

The catch for UK pilots is that one could not fly approaches with it, which represents a significant loss of privileges. The other catch is that while UK's "liberal" VFR departure arrangements (anything above OVC002 is OK) VFR departures are not possible from Class D airports in lower than about OVC012-015.

IMHO there needs to be a basic IAP say an ILS... tricky.

Class D VFR departure minima are 1500 feet broken or overcast and 5k Vis.
Special VFR departures require minimum 10k ( without an IR/IMC rating)

Thus, 1501 feet and 5.1k means no problem. 1499 feet and 9.9k means no go.

Perverse but that's UK air law for you....:rolleyes:

IO540, the proposer of the absurd chocolate teapot rating stated:

My bold lettering for emphasis. 'TK' means theoretical knowledge.

'Almost certain that a departure and arrival could be conducted under VFR' is wholly unacceptable. I invite the originator of this nonsense to define, to the satisfaction of any legel weasel, what is meant by 'almost certain'....:hmm:

The entire EIR concept is ridiculous - fortunately opposition to the idea is growing, both nationally and internationally.

The Visual Flight Rules require the following limits inside controlled airspace:

Note in particular the provisions of 3(a)(iii). The average spamcan driver only needs to be clear of cloud and in sight of the surface under VFR in a Class D CTR but must have 5km in-flight visibility.

Beagle

Almost certain I would guess would be based on the fact that your departure must be in VFR conditions plus a margin to return in VFR conditions.
This would all be based around actuals and TAFS.

Your arrival would have to be forecast as VFR Conditions in the TAFS as would your diversion airfield plus the relevant time margins to remain that way.

The reference to "Almost certain" is simply that nothing to do with weather is ever certain.

My guess is that this would be based around actuals and TAFS which could easely be placed in a legal form.

I could see them concocting a special emergency for the rating where if the almost certain failed to materialise you would be radar vectored onto an ILS and airfield where there were high minima. You would be a special case and treated that way.

For me the stupidity of all this is the fact that you will have to do all the IR studies and exams. This is the very thing that has put working pilots off a european IR.

The flight test is a piece of cake but months and months if not years of ground studies dealing with irrelevant material is the main reason pilots run off to the FAA IR instead.

Pace

Yes, the weather would have to be by the TAFs - a bit like the FAA 1/2/3 rule for having to have a planned alternate when IFR.

Re the TK requirement - this statement refers NOT to the present 9-exam (PPL/IR) TK but a supposedly much reduced version, appropriate to private IFR flight. Obviously I agree that if the present TK was involved then the whole scheme would be just plain silly - you may as well get the full IR :)

A remaining thing I don't like is that this proposed rating will still have to be taught by professional FTOs, not by your old PPL school. This is a MAJOR issue, as IMHO the majority of UK PPLs are not within practical driving range of a commercial pilot FTO for doing a flight the same day. And if you introduce hotel residence then the whole thing becomes highly unattractive. You may as well take a cheap flight down to say Greece and do the full IR down there. A huge reason why the FAA IR has such a penetration among US pilots is that they can do it as a natural continuation of their training.

On the plus side, when I look back on my long VFR (pre-IR) trips across Europe, some of which had ~ 700nm legs out of the UK, most of them could have been done under this proposed IFR rating, and they would have benefited hugely from the enroute IFR clearance. Only on one or two did the IMC-R (which I also had) get used to get back in.

Overall, I am in two minds about what to think about this. I do think an ILS should be a part of it, otherwise how the hell do you deal with the case of a really duff TAF? I believe the Australian one has an SRA in the basic module, but SRAs are apparently extremely rare in Europe (I don't recall seeing one). One can always get vectors down to the MVA but usually the MVA is way above the VFR minima...

I have the impression that there are a lot of misunderstandings about the current theoretical IR(A) requirements. You have to take 7 written exams. For these to pass you need the ATPL books.

But you only need to know certain parts of these books. Every time you come across a topic that has "commercial jet operations" written all over it you'll see in the notes provided by EASA that this topic is outside the scope for PPL/IR. Even for the much feared meteo exam.

I did the course in distance learning and it costed me 2 half-days at the FTO for evaluation. Luckily I knew the material and I didn't need extra tutoring. But the important thing is I did it at home, in my own time. I passed the exams at the first attempt. I can't say I really needed to study things I found irrelevant. OK, maybe the license-requirements-bit in "Law".

In my opinion the theoretical exams are hugely over-estimated. It is still a lot to learn,
but how you do it is totally up to you.

10540

The stupidity is that regardless of approaches you will have to be trained to fly on instruments for letting down through cloud. Flying in CAS will also mean flying to IFR tolerances so a stronger instrument training than at present.

Not seeing the ground will mean you will have to navigate using nav aids, airways points etc. In case the whole lot goes pear shaped you will still have to be trained on instrument landing procedures in case of an emergency.
So????

I must admit I never like the idea of transitioning from IFR to VFR. That is a known risk area.

I was never for saving the IMCR for just the reasons portrayed and have had many arguements here for my views. I always feared you would end up with a gesture IMCR and having made that gesture a way out for EASA ever having to make a proper achievable PPL IR.

As is said " Be careful what you wish for".

Pace

TWR

Be honest how long did the distance learning take 2 weeks??? I know people who have tried the whole ATP and are still at it after 18 months.

I also know a very experienced jet pilot on an FAA ATP who gave up with lack of time and motivation. He started off well then work and family problems meant he shelved the lot.

I also ask if that is the case how do you explain so many going the FAA IR way instead?

Pace

And then we get to the difficult bit.

The weather during Mr. EIR's flight was pretty much as forecast. However, at his destination and for any airport within distance of the fuel he has remaining, the weather is OVC008.

Mr. EIR departed in all good faith having checked TAFs and METARs, but the weather stubbornly refused to co-operate and the front did not clear. He has not been trained to fly an instrument approach, and may not legally fly one. His aircraft is suitably equipped, having ILS, ADF, DME, Pitot heat etc.

But he hasn't been trained.

In 30 minutes or so his situation will rapidly become an emergency due to low fuel.

So, in order to save his life, he has (a) to break the law and fly outside the privileges of his licence and (b) fly a procedure for which he has received absolutely no training whatsoever. If he screws up the approach and has to go around, he will be straight back into the murk, already stressed and worried, will have to transfer back to instruments.

You estimate - what are his likely chances of survival?

Speaking for myself, I would far prefer him to be IMC rated. Otherwise we are sacrificing his life for bureaucracy.

Captain Stable

Good points but there is another! He may take off VFR in good weather. He may have brilliant weather at his destination but enroute on top of an overcast he develops a problem! he needs to land! he checks the weather at the airfields near him! Overcast 200 600 metres vis what does he do?

Pace

It took me 4 months of daily study, combined with a full time job to be ready for the exams. Since it is my hobby and the books were fluently written, motivation was no factor.

I too know people who have tried the ATPL and they succeeded. Even after 18 months. That is a matter of personality and is true for whatever studies you take up.

TWR

Well done but your last statement about personality says it all. You have to be the type who will dedicate a block of time every day to the studies and we are not all like that. Working people with families also have priority commitments attached to their work or families which puts a ? over dedicating a block of time every day.

You could argue and his has been tried that all that study makes for better IR pilots. That has been proved to NOT be the case much to the dismay of EASA as in a major study the EASA and FAA pilots were compared with neither being safer than the other. The conclusion was that the training was different but the end result the same.

Pace

Being a safer (= better ?) pilot has more to do with currency and skills than with theoretical knowledge. I'm happy with the "story behind things" I got during the study.

But it's a choice you as an individual make. I think there is a big difference in saying that the EASA IR reqs are waaaay over the top for a PPL/IR and the fact that some people prefer a "need to know"-course and spend their time rather on practice than on study.

But it's true that I can't tell the difference in reality between FAA and EASA-rated pilots.

TWR

The difference is maybe that in Europe the emphasis is more towards career flying while in the USA GA has always been far more prominant.

Many areas of Europe have had negligable GA and the politics are not motivated towards rich men and their toys as many would see it.

Like any professional Career whether its being a doctor vet etc there should be some sort of university degree and in some ways the ground studies appear to be an attempt at creating a quasi university degree in flying for professional pilots.

Where does that leave the PPL in Europe? I am afraid the PPL in Europe doesnt really figure much in the equation and is eyed as the lowest of the low and that probably poses the biggest problem of all.

Pace

The problem with the theory is that most of it is gash, and completely irrelevant to GA pilots. 90% of it gets core-dumped as soon as the exams are over. The only bits I really remembered were from the Met exam.

You CAN'T do this with the FAA IR, as you get a VERY severe oral grilling before you even get into the aircraft to do your flight test. No such grilling is undertaken in Euroland.

That is where you an I differ in opinion. Year after year EASA revises the theoretical requirements (read; reduces the topics to be known for the exams) in a more or less logical manner. The days one had to study worldwide climatology and INS etc etc are gone. And the actual questions are no brain-teasers neither.


It is nowhere near a university level (even for the ATPL). That was different in the pre-JAA days, when you were required to be able to design you own jet-engined aircraft with astronavigation tools and such. At least it was in Belgium...

Instead of criticizing EASA for what the IR could be (FAA alike) I'd like to congratulate them (already) with the job they've done over the years. My impression is that from time to time they tend to be open for improvement.

TWR

If that is the case they should design a course which you attend full time for 2 weeks. At the end you come out with all the exams signed sealed and delivered. Another 2 weeks if you want ie a month in total you come out with all the ATP exams completed and signed off.

That scenario is perfectly achievable with the same quality of PPL/IR or ATP.
When EASA do that? :D

Then the working man can take two weeks off and the ground studies are done and dusted for his PPL IR :)

Pace

What do you define as quality ? Personally I find a broader background knowledge a better quality that I don't find in the FAA-system. I can't say it makes me a better/safer pilot because I don't know that. The EASA-ppl/IR and the FAA-ppl/IR are not the same / have different qualities. Pick the ones that suit you most. The outcome should be the same: we move in the same airspace and we all know what we are talking about.

I can't imagine studying the IR(A) in two weeks. But honestly I can't even imagine doing the basic PPL theory in that timeframe...

I would love if the IMCR in the UK was extended around Europe. I'd be first in the queue to get it.

If an enroute IMC rating became available, but didn't include any instrument approaches, then I'd probably still get it, but I'm not so sure how often I'd use it.

At present, my licence allows me to fly VFR on top of an overcast (provided I can get up there and back down VFR). However it's a privlidge that I rarely use. It's something that I only do when I must, and always only when there are sufficient holes visible to get back down. I won't fly on top based on my destination being clear of cloud.

So all this additional rating would provide me would be the ability to climb on top and desend in IMC, (I wouldn't need to be VMC). The problem I see with this, is that I'd only NEED (not necessarily want, but only NEED) this privlidge when the cloud base was very low. Ie. I'm not happy below the cloud base, and want to find nicer weather above it. Now if I choose to use this rating to get above it, it might be difficult to get back down if the cloud base is so low enroute.

Of course as the rating is current proposed, it's pretty much irrelevant. VFR on departure, and VFR on arrival.......I can do that on my basic PPL, flying above an overcast. What I can't do is fly IMC enroute, but that's hardly much of an advantage.

I just can't see myself flying IMC enroute, or above an overcast with no way down, and now approach training or privilidges, while trusting that the weather won't change at my destination. It would only be a matter of time before I found myself in serious trouble.

dp

I'd be happy with a EIR which allowed me to take off, fly IFR in all classes of airspace and then shoot a precision approach at the other end. Piece of cake.

Maybe one could then add new approach "ratings" to the ticket, like get "GPS" or "VOR" rated?

There should be a minimum of a Precision approach capability as frankly anything else is a waste of space.

So what is the alternative to the EIR? Well, actually it’s relatively simple in concept. EASA has already proposed that certain regulatory proposals should apply ‘where so permitted under national law’, so AOPA considers that the very same principle should apply to the IMCR. Within Europe, there are widespread differences both as regards categories of airspace and the flight rules which pertain within such airspace. For example, flight in IMC outside CAS is forbidden in certain Member States, whereas flight under IFR is mandatory at night in the UK. There is no uniformity, neither is there likely to be for many years. Even if airspace categories were simplified and unified across the EC, there is no guarantee that the flight rules applicable within such airspace would be. Hence AOPA’s position is that there should be a part-FCL Rating, with privileges no less than those of the UK IMCR, which could be used in Member States ‘where so permitted under national law’. In other words, if a non-UK EASA PPL holder wants to fly in the UK using such a Rating in Class G airspace, he/she would be quite welcome to do so subject to possessing adequate English language proficiency. But if a UK pilot wanted to visit a country which had decided not to accept the Rating in their airspace for whatever reason, then that would be entirely that nation’s right. No-one would be ‘forcing the UK IMCR on Europe’, instead they would be offering it as a model of a safe sub-ICAO instrument qualification which Member States might wish to consider accepting in appropriate areas of their national airspace.

You are right about the 7 exams; sorry...

But

is way way way over the top for the operational TK actually required for IFR flight - especially knowing how little present fresh JAA IR holders know about operational stuff.

4 months daily study is obscene.

Well, there's your solution :ok:

That is quite a shift from their previous position, which was total uniformity across the EU.

Beagle

If that was the case then that would be to admit that EASA does not exist.
What you are saying and correct me if I am wrong.

Each country can have its own regulations and its up to the other member states to decide whether or not to accept those individual regulations? a free for all and no EASA? Oh well sounds brilliant :ugh:

Thats great as back to the good old days I can trundle over to Ireland and get my FAA ATP converted to an Irish ATP as before a free for all around Europe.

Pace

I think the status quo should remain.

That would please everybody who is actually FLYING :)

I still cannot get my head around the (as proposed by EASA FCL) precedent of stripping currently licensed and active pilots of their privileges. This has AFAIK never been done, anywhere, in the past.

I am not sure whether the proposal was drafted by a bunch of "out of touch with reality" non-flying axe grinders in a closed room, or whether they got legal advice (which would be pretty complex, given the ICAO / international aviation issues) and found they can pull this off. My money would be on the former, because the relevant parts of the proposal are clearly poorly drafted (e.g. "residency" is not defined) and if they really did the full legal/political due diligence they would have done a better job of drafting it afterwards.

Chaps

This is a very important debate and even more important it is aired regularly so the changing population of private pilots is well aware of what is at risk and why.

However, it is also important that we are conscious very little will happen until EASA finally release their proposals on FCL generally and on the future of the IMCr specifically.

At that point in time it is even more important that if we do not like the lie of the ground we are prepared to "do something about it".

It seems that NPA17 comments to EASA have now passed the 30000 mark - each of which must receive an individual response.....:ooh:

Can anyone really see all this being settled by 2012?

Time to rethink the Basic Regulation and to devolve competency for sub-ICAO matters to national authorities under €uropean subsidiarity principles.

They will have a job but anything is possible with unelected and almost unaccountable quangos which operate behind closed doors with every member sworn to secrecy so unless one breaks cover none of us have any real idea what forces drove the legislation in the first place.

Democracy - I dont think so.

Last time they didn't get individual responses. EASA broke them down into some basis questions and responses, and simply said that these group of people were included in this answer etc.

Let's get things right. EASA has not proposed this. The Basic Regulation (216/2008) used this phrase in the context of the GP medical. The Basic Regulation is a Commission-drafted proposal that was passed by the Council and the Parliament. It is primary EU law, which is why it is called a Regulation. And the reason that phrase got into the Regulation, as distinct from the Implementing Rules - the next level down of lawmaking -for FCL, which rules are being drafted by EASA for Commission review / approval, was because the UK DfT negotiated it on our (particularly UK) behalf in 2007. I know, because.......

So for the AOPA solution for the IMCR to work may be the Basic Regulation would have to be changed. That's not to say it would have to be; there are other ways of adapting the legal framework, so maybe it - retaining the right to use IMCR in the UK but on an EU licence - will be one solution.

Now as regards FCL.008, that task group's work is quite separate from the main FCL proposals which are currently being reviewed in the light of the comments received from the recent NPA consultation. The review groups include 'industry' experts, including some from the GA community. The planned publication date of the CRD for FCL is March 2010 (medical part 2 months later) when all will have another opportunity to comment further on the revised proposals. EASA is still planning, under recent strict direction from the Commission, to deliver the FCL Opinion to the Commisson by mid 2011 for the start of implementation by April 2012. However, there is a strong possibility that the GA elements will be spread over the following three year period. This is particularly necessary to allow time for member states / NAAs to provide grandfathering transitions from some national licences, as well as get their heads around the final rules once they are published in the OJ in late 2011 or early 2012.

The FCL.008 NPA is expected in the first half of 2010, and then you can comment. Until then much of this speculation is misplaced. The EASA rules of engagement prevent me from correcting mis-placed speculation but one of the FCL.008 group members is planning to publish some real information soon, with the agreement of EASA. At the latest count I think there may be a pleasant surprise, and not a 'chocolate teapot', even if the UK centric views of a few are not fully realised as regards a pan-EU IMCR.

The UK CAA is, I am led to understand, fully behind trying to preserve the IMCR. How they achieve that remains to be seen, but the influence it has is not to be underestimated.

I say once again, the work of the officials at EASA, work which is at the bidding of the EU and within the constraints of EU law as delivered so far by the political classes, is not all bad. Some of it is, but not all. The recent change of EASA's direction at the behest of the Commission might just bring some light at the end of the tunnel. But until it does we do not give up our work in representing the interests of GA, particularly the non-commercial sectors.

In my view, the hope that sub-ICAO licences will be 'returned' to member states is but wishful thinking, because if for no other reason the aircraft within the scope of EASA airworthiness rules, already in place, and flown by pilots with sub-ICAO licences, would also have to be removed from EASA control. I can't see that happening. The other reason is the Basic Regulation would have to be amended, and that would be a significant stepback from the broader and political EU agenda, nothing to do with EASA.

Thanks for the response, David - most helpful. I watch and wait with interest.

I was aware that this topic had been 'done to death' on this forum, but one of the 'other places' suggested that there was a concrete proposal on the table. I now understand that this is not yet the case.

Best regards, Saul

David

In your opinion concerning foreign reg aircraft flown by foreign licenced pilots in Europe, could these pilots be discriminated against by as it was put "residency" rules?

ie at the top end of GA there are many foreign reg corporate aircraft and jets flown by foreign licenced pilots in Europe. The European Pilots earn a living from flying these aircraft but could be discriminated against and loose their income because they happen to be European rather than American.

On the lower end of GA many aircraft are owned and flown on N reg! could those private pilots/owners suffer hardship and financial damage through regulations which inhibit their operations and with no redress?

Maybe not so much to do with the IMCR but especially with Private N reg small GA a lot to do with it.

May I add getting rid of N reg has been tried many times before and failed. Surely the best way to get rid of N reg in the so called "freedom of choice and free world" is to put something more attractive in place?

Pace

David,

The €urocrats can dress it up however they please, but if has been used for one element, they would have a difficult task opposing the idea that the same clause could equally be applied to other elements.

Anyway, 30000 comments and counting would indicate that the whole of NPA17 is a total and utter crock and that EASA should be sent back to the drawing board as regards part-FCL.

Yes hopefully use that clause to eliminate the whole European thing lock stock and barrel and all go our seperate ways as its done nothing to further the expansion of aviation in Europe top to bottom. :D
Then just incorporate the tried and tested FAA system which would have saved the industry Billions of Euros over the years and I am not just talking about FCL.

Pace

Sadly ...
 

No committee ever wants the obvious solution. Far too boringly sensible to further the members' careers.

But if they can find a formula that will work but is so complicated in its structure that nobody realises it boils down to very nearly - but not quite - the obvious solution, that might be a safe career builder. Especially if they use lots of long sentences.

But hey, they only affect the bits of paper I carry, and the journeys I can set out on. They can't stop me getting and keeping current in skills that might save my life one day.

I think that they should go back to the 1500hr check ride for ATPL issue.
It is nuts to expect someone from a pilot factory with 200 hrs in an aeroplane (and 50 in the sim) to be at a standard "capable of commanding" a 747 with 400 souls onboard .....

By all means make the candidate sit ATP exams then and learn everything there is to know about the 737 FMS and nat tracks when they have built up some real world experiece.

....which is what many people realised years ago, pre-JAR....

Then there wouldn't be all this nonsense with the gold plated JAA IR which for the average PPL is far to gold plated.