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Jim's own perspective may be read here.
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I see he talks about
all the negative rubbish to be found on PPRuNe Incidentally, do tell him his PPL facts are years out of date. Still, he does at least say that it is 'a personal view'...... |
it is a very dangerous game making statements such as these (and I could refer you to quite a few more) if you were never able to carry them out some of the group experts were in favor to develop a similar rating as the UK national IMC rating This is what our Government said with the full knowledge of the CAA and the DTi. No mention there that the priviliges on the IMC rating holder could not be protected. EASA has agreed to establish a rulemaking group to consider proposals for a similar rating at the European level If the UK government believed that FCL008 was tasked with saving the IMCr, then no doubt it's own representative on FCL008, from the UK CAA, would have filed a minority report to this effect and objected to any breach in the terms of reference. Why don't you ask them, since you are relying on this government paragraph? Anyway as I have said before discussion is a complete waste of time - you dont know what you are talking about anymore than most other people |
421C
You raise some very good points. Timothy Thank you for that link. We shall just have to wait and see. |
The Euro-skepticism and downright hatred in the UK towards anything beyond its own shores is frightening at times (unless that someone happens to be a cheap Pole doing your house up for next to nothing or sweeping the floors at the local NHS ruin, that is - then it's OK).
What is the problem? An EIR is a nice halfway step towards a IR where all the hours count should you want to upgrade at some point. It's also something that's easily obtainable, can be done at any flight school and relatively cheap. And when they day comes when you feel you need it, you do a bit more training and upgrade to an IR. What's not to like? Oh, the IMC, yes. Well, that will get grandfathered in somehow, of course. It's obviously not just going to be rendered invalid overnight. It might in a worst case scenario just be a grandfathered in to a EIR - and although that's slightly unfair perhaps, grandfathering you in to a full IR would simply be unfair to everyone else with a real IR as you don't have the training required. At best, it stays a national rating that you can use just like you do today. I'm amazed at the arrogance and scorn lavished upon our fellow Europeans for not immediately falling on their knees and adopting the beloved UK anomaly, the IMC. Once all this EASA stuff is integrated across Europe in two years, then it will be a marvelous thing. How quickly we forget - I remind you what a royal pain in the a** it was to fly anywhere else but in your own country just less than 5-10 years ago. Not to mention the costs and time professional crews had to endure if they ever wanted to work anywhere else. Despite the imperial tendencies and transatlantic flirtings, last time I checked the UK was in Europe. You don't have to love it all, but at least stop hating it all at all times. |
For the avoidance of doubt, here is the full text of the article in General Aviation magazine referred to above.
The battle to save the IMC rating has entered a new phase, with the EASA working group charged with examining the issue having dodged its responsibilities while seeking to hammer another nail in the rating’s coffin. Despite its terms of reference the group, called FCL-008, has wound up without addressing the issue of the IMC rating and now believes it to be a dead duck. AOPA maintains the rating is a lifesaving qualification which is in large measure responsible for the UK’s excellent GA safety record, despite Britain’s notoriously changeable weather, and must be preserved. AOPA has arranged an urgent meeting with EASA’s Deputy Head of Rulemaking Eric Sivel on December 2nd to ensure there are no further misconceptions about the rating, and has begun a programme of lobbying in Europe and the UK to support its retention. In particular, it is pointing out how FCL-008 failed in the task it was set, and is asking EASA and the CAA to clear away the confusion that surrounds the issue of whether a European country can create a one-state rating and attach it to an EASA licence, which would allow the CAA to maintain the IMC rating in the UK. EASA personnel have given conflicting advice on this, and the CAA is equivocal, but it’s become too important to allow such fudging. Some 25,000 IMC ratings have been achieved, and 23,000 IMC holders still had valid medicals as of 2008. The CAA says that in 27 years, only one IMC rating holder has been killed in actual IMC. AOPA has received unqualified support for its campaign to save the IMC rating from the British Air Line Pilots Association, the Guild of Air Pilots and Air Navigators, the RAF Flying Clubs Association and other organisations, but non-UK delegates at FCL-008 have gained the impression that Britain does not care about it because the IMC rating has been misleadingly portrayed to them. The Europeans have mistakenly gained the impression that the IMC rating is equivalent to an Instrument Rating with one fifth of the training, that few people in the UK support it, and that British pilots will prefer a proposed ‘En Route Instrument Rating’ for which a course of theoretical exams must be passed before the holder is allowed to fly in the cruise in IMC, with no approach and landing training or privileges – a travesty of what the IMC rating seeks to do. FCL-008’s terms of reference were headed ‘Qualifications for Flying in Instrument Meteorological Conditions’ and included under section 3, Objectives: ‘Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training, but also with limited privileges.’ However, in a letter seeking explaining his position to AOPA, delegate Jim Thorpe of Europe Air Sports claimed it was never tasked to look at the IMC rating. “The terms of reference of FCL 008 have always been public,” wrote Mr Thorpe, chairman of PPL-IR. “They might be summarised as proposing a more practical and accessible system for private pilots to fly IFR in Europe. While they are informed by the UK IMC experience it was never within the group’s remit to consider the IMC within the UK.” This runs directly counter to the stated understanding of Eric Sivel, EASA’s Deputy Head of Rulemaking, who told IAOPA in an open meeting in October that FCL-008 had been tasked to look at the IMC rating situation and the proposal for a simplified IR, and if it did not produce a workable solution to the IMC problem, then it had failed in its purpose. In his letter, Mr Thorpe goes on to make a number of assertions about the IMC rating which, while highly dubious, have become the accepted view at FCL-008. *“the IMC rating essentially offers the same privileges as an IR on the basis of 20% of the training.” *“the position where its privileges are essentially the same as a full IR but the CAA has consistently advised pilots not to use the privileges they have themselves granted is ludicrous” *“most of the arguments in (the IMC rating’s) favour, such as its role in enhancing safety and the unique nature of UK weather cannot be credibly substantiated by the facts.” Antipathy The background to the setting up of the FCL-008 Working Group is worth reviewing. Those invited to take part were Morten Keller of the Danish CAA, Mike Dobson of the UK CAA, Mathieu Burgers of the Netherlands CAA, Raimund Neuhold of an association called IAAPS, Jean-Benoit Toulouse of the European Cockpit Association, Jim Thorpe of Europe Air Sports (and PPL-IR) Andrew Miller of Europe Air Sports (and British Gliding Association) Pierre Podeur of Europe Air Sports, and Dr Michael Erb of AOPA Germany. The secretary was Matthias Borgmeier of EASA. AOPA UK was not informed until after the places had been filled. Before FCL-008’s first meeting, Mr Thorpe asked for a meeting with Martin Robinson of AOPA UK to make sure he did not object to Europe Air Sports, an umbrella group of aviation organisations, having so many representatives on FCL-008 while AOPA UK had none and IAOPA only one. At that meeting he gave no indication of any antipathy to the IMC rating. Martin Robinson told him AOPA UK would not object to the number of Europe Air Sports people on the group (which would have been a fruitless exercise anyway), but reminded him that the IMC rating was vital to the UK and there should be no move to undermine it. AOPA UK, he added, was not seeking to foist the IMC rating on the rest of Europe, as some had claimed, but it was extremely concerned to retain it, or else adopt a rating with almost identical privileges, in Britain. In the event, the only person to try to get a serious discussion of the IMC rating going was Dr Michael Erb of AOPA Germany who, briefed by AOPA UK, tried to have the matter reopened on several occasions. He got no support from the UK delegates, and it was decided to give the IMC rating no further consideration. Dr Erb felt unable to press the issue of a UK rating further in the face of opposition from UK delegates. Mr Thorpe maintains that despite the fact that AOPA UK did not have a seat on FCL-008, responsibility for supporting the IMC rating fell solely to AOPA and was nothing to do with him. In his letter he says. “From the start it has been AOPA’s responsibility to lobby for the retention of the IMC.” But where else was the rating officially under discussion? He goes on to attack the IMC rating in uncompromising terms. “I believe that most of the arguments in its favour such as its role in enhancing safety and the unique nature of UK weather cannot be credibly substantiated by the facts. Nevertheless pilots and flying schools like the rating and it can equally be said that negative impacts are also anecdotal. The position where its privileges are essentially the same as a full IR but the CAA has consistently advised pilots not to use the privileges they have themselves granted is ludicrous. It is in the great British tradition of daft compromises. It has been cobbled together over time ending with something that no one would ever have designed from first principals (sic) but which somehow works.” Prejudice Martin Robinson says: “The idea that the privileges of the IMC rating are essentially the same as those of the IR is so wide of the mark that IMC rating holders must be aghast. Many of those things that have been presented to FCL-008 as ‘facts’ are nothing more than prejudices masquerading as truth; there’s been no research, no intellectual rigour, nothing more than assumption piled on presumption, which would be comical if it wasn’t for the fact that consigning the IMC rating to history would put pilots in danger. It cannot be allowed to happen. “When Mr Thorpe says claims that the IMC rating improves safety ‘are not supported by the facts’, what facts is he talking about? If he would like to meet some pilots who owe their lives to the rating, I can provide them. The purpose of the IMC rating, to save pilots who inadvertently fly into IMC by helping them keep control of their aircraft and returning them safely to the ground, has been utterly misrepresented to FCL-008 and to Europe. “The notion that no-one in Europe supports the IMC rating is also misplaced. I believe it stems from German opposition to the Instrument Weather Rating proposed under the JAA, and has become a truism. Many NAAs and pilot groups around Europe would welcome an IMC equivalent – they’ve simply never been asked. “Furthermore, given that under EC airspace proposals it would be possible for states to decide whether an IMC rating was useable in their own airspace, it seems that FCL-008’s decision to dismiss it out of hand is particularly unfortunate. It would have been far better to present the truth and try to change some minds. Some opposition to the IMC rating was expected, but we didn’t expect to be hung out to dry by our own side. “This issue needs to be put in context. EASA has publicly stated its commitment to banish the N-register from Europe, and one of the major reasons so many people fly N-reg aircraft on FAA licences is that the FAA IR is far more sensible and achievable than the European equivalent. Change needs to come in pursuit of EASA’s stated aim. At the same time, noisy opposition to the IMC rating has come from the European Cockpit Association and some NAAs. It would have been an act of political courage for EASA to go against it – far better to create a Working Group that would kill off the rating and carry the can, then EASA could shrug its shoulders and say it did its best. “The question now is exactly how to save the IMC rating. Our first step is to sit down with Eric Sivel early in December to clear up any misconceptions he may have about the UK position on the rating and to point up the fact that FCL-008 has not done its job. At the same time, AOPA is working at the European Parliament and the European Commission to marshal support for the rating, and we have already had positive responses from the most senior figures in the EC’s transport department and a number of MEPs. In particular, the CAA needs to stand up and be counted. It’s no use trying to be all things to all men – that’s one of EASA’s problems. Were it not for EASA, the CAA would not be sitting down and discussing the need to kill the IMC rating – why do they acquiesce to this? We need an unqualified expression of support from the CAA, and I would also like to ask Europe Air Sports whether their delegate actually speaks for them. “The FCL-008 proposals will be transformed by EASA into a Notice of Proposed Amendment, at which point consultation will be invited and we will be ready. AOPA’s postbag in support of the IMC rating is bigger than any it has had before, and at the correct time we will mobilise that support in a targeted letter-writing campaign. I believe that despite the obstacles it is possible to reverse the situation and I will expend any effort to do so.” |
Timothy,
Thanks for the link. Very illuminating to hear first hand what Jim Thorpe actually thinks, rather than hearsay. It does seem incredible that a representitive of PPL/IR, a minority interest organisation (328 british members), who is so brazenly hostile to the future of a rating which has served uk pilots so well, can pop up in such an important commitee and purport to represent the interests of British IMCR holders. As a member of AOPA, I am disappointed by their choice of representitive for this commitee and am curious as to why the opinion of the membership was not consulted at an early stage? I particularly enjoyed Mr. Thorpes comments about how the unique european ratings were all so understandable (mountain ratings, et al) and how there could be no logical argument for the IMC on the grounds of there being unique and changeable weather patterns in the UK as a result of our maritime climate and being a small northern european island, as the weather in germany and sweden is just the same. I shall leave it to some of the professional met folk on this forum to explain why this point of view is incorrect - suffice to say that I think that Mr. Thorpe needs to re-sit his met exams... I expect that next he'll be telling us that the Brevet de Bas is a terrific idea, and that VFR-on-top privilage allowed to a French vfr PPL is great because in europe, there will always be a hole in the cloud at the end of the journey to descend through. The net result of this promises to be that IMCR holders will have a useful rating taken away and, if we're good little boys, we may be allowed to sit the full IR theoretical knowledge exams, submit to retraining and re-sit a flight test in order to gain an EIR - which will be markedly inferior and less useful than the rating we already enjoy. I predict that two things will happen as a result of this; 1. Yet another group of pilots and aircraft from the european register to the American register 2. That pilots will simply fly IFR without any rating, in the absence of an attainable, useful, european rating and people will be die as a result. What a shame. |
As a member of AOPA, I am disappointed by their choice of representitive for this commitee and am curious as to why the opinion of the membership was not consulted at an early stage? In the event, the only person to try to get a serious discussion of the IMC rating going was Dr Michael Erb of AOPA Germany who, briefed by AOPA UK, tried to have the matter reopened on several occasions. He got no support from the UK delegates, and it was decided to give the IMC rating no further consideration. Dr Erb felt unable to press the issue of a UK rating further in the face of opposition from UK delegates. |
IMCR and IR
I find the politics surrounding this debate criminal. We are talking about promoting flight safety and perhaps saving peoples lives, and all we are hearing are various European bodies trying to outdo each other in ''my way is best'' arguments.
Surely the UK IMC rating can remain intact in the UK by CAA approved grandfather rights,it is a lifesving qualification and hopefully will lead some rating holders to go on to the full IR. The crux of the problem is, the UK IR having far too much technical content fopr the PPL user. We have a perfectly good template for change in the FAA IR model where the exam content is tailored to the knowledge needed, but the flying test remains the same as the professional qualification. If the statistics are read in the USA we do not find scores of USA IR holders falling out of the skies. Holding both a JAA and FAA rating I found the FAA test superior and far more practical, ie no more interminable NDB holds and letdowns and proper testing in modern GPS procedures. ( I believe the CAA still do not have examiners who can test GPS approaches in an Initial IR Test) We live in a fantasy world where I can fly happily around Europe in the Airways with my N reg aircraft with my FAA IR, But if I get a paint brush and change the N for a G the same aircraft with the same avionics is now banned from IFR in Europe. The attitude of officialdom in the UK also needs pushing into the 20th. Century. I wrote a year or so ago to the CAA SRG department, asking the reason for their continued aversion to an FAA style IR for PPL holders. In his reply, the CAA Flight Operations Capt, stated as one of his reasons, that the FAA rating was not suitable for European weather conditions! I received no reply when I asked him why the United Airlines B777 Capt was therefore allowed to fly into UK airspace with the selfsame FAA IR. It is incredible that EASA fiddle with politics when peoples safety is at stake. Common sense and air safety should come first. |
No doubt the response to that consultation from UK IMCR holders will highlight the working group's failure to adequately seek or consider their views. Jim Thorpe Having read very carefully Mr Thorpe's explanation I have seldom seen a more confused and muddled paper which is so riddled with inaccuracy and misconception. Is it any wonder FCL008 were so poorly informed about the IMC rating. I suspect that Mr Thorpe has had a very different agenda all along. The British member's of PPLIR should call for his immedaite resignation. As I said before, presumably lead by Mr Thorpe, FCL008 have clearly completely ignored their own terms of reference. That in itself is an appalling state of affairs and unfortunately will bring in to question whether the committee has acted unconstitutionally. |
If the proposed EIR is accepted and (with additional training) pilots will be allowed to fly airways, out of sight of the surface, to find a hole in the cloud at the destination airfield to land VFR, no doubt French pilots will be grandfathered an EIR as they enjoy all these privileges already on a basic VFR PPL??
To quote IAOPA’s last e-newsletter: “M Sivel agreed that given British weather, the UK IMC Rating was as important to the UK as the Mountain Rating is to Switzerland, and some way had to be found to maintain current safety levels under EASA. The EASA Working Group FCL008 had been set up to look at the IMC Rating, he said, and if it did not produce an acceptable solution to the problem, then it had failed in its task.” FCL008 may not have been tasked with saving the IMCr but they darn well need to come up with an acceptable solution. As seemingly bona fide reports imply that Mr Thorpe is not accurately representing the UK support for the IMCr, I will, for one, be sending a letter to EASA’s Deputy Head of Rulemaking Eric Sivel today. Personally, even though Mr Thorpe says “claims that the IMC rating improves safety ‘are not supported by the facts’ ”, I can think of several accidents where an IMCr might have avoided fatalities. How many pilots will die because Mr Thorpe thought “responsibility for supporting the IMC rating fell solely to AOPA and was nothing to do with him”?? |
no doubt French pilots will be grandfathered an EIR as they enjoy all these privileges already on a basic VFR PPL?? Most of the world can fly VFR above a solid overcast. |
"An urgent meeting has been arranged between AOPA UK and EASA's Deputy Head of Rulemaking Eric Sivel on December 2 to discuss, inter alia, the UK's IMC Rating, which has been totally misrepresented to the rest of Europe by vested interests pursuing their own imperatives. Some 25,000 UK pilots have taken the IMC Rating in the last 27 years. It is a 15-hour flying course which equips pilots to maintain control if they accidentally enter IMC and to get their aircraft safely back onto the ground. It confers no rights to file IFR, no extra access to airspace, and no additional privileges beyond the PPL apart from absolving the holder from the UK requirement to remain in sight of the ground. "
Well worth repeating from IAOPA - my bold. |
Worth repeating only because it's utter rubbish.
The IMC rating confers the right to file IFR in class D and E airspace (as well as classes F and G, which, on a technicality, is also possible for PPLs without an instrument qualification within the UK), the right to fly (and to plan to fly) in cloud. If AOPA UK wishes to introduce to Europe a rating (based on a 15 hour course of IF) whose only privilege is to "absolve the holder from the UK requirement to remain in sight of the surface" then they should go ahead. I doubt they'll get many takers though, given that with a 25 hour IF course you'll be able to get an IR. |
Can someone please explain to me something, minus all the mud-slinging. Under the proposed EIR:
1.) At the time of takeoff your METAR at departure and TAF at destination look VMC so you're legal 2.) Enroute you hit IMC and using your swanky EIR skills manage to continue. 3.) The weather takes a turn for the worse and your destination and alternate are under cloud but above the IMC mimuma. With your old IMCr your would have had the skills to peform and ILS etc..... .....What do you do with the EIR???? Make up your let down OCAS without an approach aid?? Decsend into VMC outside the ATZ and maybe under the range of radar coverage??? |
Fuji - I am totally lost now.
Are you saying the bold is what should be defended, which is a bit bizare as the elimination of ISOS will just happen under EASA and no one will complain or restrict a training scheme that adds no privileges. Or are you making the point that IAOPA and possibly AOPA UK have lost a grip. |
I think he is making the point that the stuff in bold is absolute claptrap. It is amazing that an organisation which supposedly understands and represents the views of UK GA has completely and utterly got it wrong. Someone in a position of influence should point out this very significant factual inaccuracy. If this statement reflects the level of understanding that appeared at FCL.008, then the whole lot need to hang their head in shame.
Pointed question - what is AOPA UK doing to amend this IAOPA statement? Isn't Martin Robinson the link? :ugh: |
I'm a bit bemused by Jim Thorpe's paragraph on grandfather rights. He only considers two possibilities - that an IMC rating holder might be allowed to take the full IR TK exams and end up with just an EIR; or that an IMC rating holder would be given a full IR with no further requirements. The former is a rip-off; the latter is clearly a paper tiger, as no-one has seriously suggested it.
It has always seemed to me that one of the biggest problems for IMCR holders wanting to go for an IR is that they receive no credit for IMC flight they have already undertaken, either the 15+ hours to get the IMCR, or subsequent flights in IMC - even tests undertaken with an examiner. If I could be credited with 15 hours for the IMCR course, say 6 hours for the three renewals I've done since, plus perhaps 10 hours max for other IMC time logged, I'd be more than half way to the requirements for the IR. If you added into that a more sensible TK exam with self-study a la FAA IR, I'd call that fair and I might actually afford it. It's not that I don't want an IR. It's just been out of my reach and up to now an IMCR isn't even a stepping stone. Tim |
I think he is making the point that the stuff in bold is absolute claptrap. Jim Thorpe I am dismayed with the way Mr Thorpe has behaved for a number of reasons. Firstly, he comments in his "write up" on PPL/IR that these are his personal views. It is well know that Mr Thorpe is the protagonist of the EIR. He is also a member of FCL008. He is not entitled to personal views or at least not that he should publically air at this stage in the process. Secondly, either the EIR has been so poorly thought out that he cannot setout in his "write up" how he believes it will work which beggars belief, or he already knows the rating will be worthless other than as a stepping stone to a full IR in which case he should be honest enough to say so. Thirdly, if you consider the whole "write up" not only does it contain numerous inaccuracies but is terribly biased. All together posting this on PPL/IR was very badly conceived and I would have thought some of the more responsible members of that organisation (Bookworm as one example comes to mind) would have cautioned him not to go to press. |
Fuji,
I am even more mystified.
Originally Posted by Fuji Abound
(Post 5354482)
Yes
Jim Thorpe
Originally Posted by Fuji Abound
(Post 5354482)
Secondly, either the EIR has been so poorly thought out that he cannot setout in his "write up" how he believes it will work which beggars belief, or he already knows the rating will be worthless other than as a stepping stone to a full IR in which case he should be honest enough to say so.
CGB - The clap trap comes from GA magazine, not from the people on FCL.008 - who clearly did understand the current privileges of the IMCr and how those might map into a European rating - as compared to the author of the quoted text. tmmorris - Jim is suggesting that most IMCr holders who use their IMC in anger should with nil or modest training pass the IR flight test and therefore should be allowed to do so. He has a view (and I have no personal basis to agree or disagree) that the IMCr TK requirement is a bit light for world wide operations and there should be a verification that people have extended their knowledge to that sensibly required for IFR flight by way of the TK test. For people in your situation, this seems a fantastic opportunity, all your time counts, for very little extra work you get a full IR and can substantially expand your geographic scope. |
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