IMC: 'Hung out to dry by our own side'
 

summary of AOPA article in December magazine:

EASA recently held a working group meeting to determine, inter alia, the future of the IMC rating. The UK was represented by a Mr Jim Thorpe of Europe Air Sports and Deputy Chairman of PPL/IR Europe

Despite there being 23,000 current holders of the IMCR, Mr Thorpe has managed to convey to his European colleagues that there is no support for the rating in the UK :eek:

The Europeans have mistakenly gained the impression that the IMCR is equivalent to an IR with just one fifth of the training . . . . and that we can all trolley around up there in the airways with their commercial traffic. No wonder they are so opposed to it with this blatently misleading briefing that has been coming from certain quarters (possibly attached to the entirely independent PPL/IR org who of course have no agenda of their own to peddle :rolleyes:)

Thorpe has told them 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" (no doubt this silly concept was dreamt up by a certain Mr J Thorpe - £25 explanatory manual available from all good bookshops)

At the meeting, the only person who tried to raise the UK GA's overwhelming support for the IMCR was Dr Michael Erb of AOPA Germany but he received no support from the UK delegates and so "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"

Sadly the meeting had been nobbled so as to exclude AOPA UK - all our seats were filled by Thorpe and his cronies.

Fortunately, the Germans seem to have a full measure of integrity not only demonstrated by Dr Erb, but also the Deputy Head of Rulemaking, Mr Eric Sivel, who was obviously surprised by the cleverly orchestrated hatchet job on the IMCR by the UK delegation . . .. . . . . and has agreed to meet urgently with AOPA UK "to ensure there are no further misconceptions about the UK rating".

Frankly I think current members of PPL/IR Org and Europe Air Sports should urgently change their management and to recruit exclusively Germans who seem to have adopted en masse our British sense of fair play. We, on the other hand, seem to have turned into a bunch of weasels . .. . .. . .. .

However, should you wish to abandon your IMC rating and to head in your Warrior for the Airways with a full-on gold standard IR then please contact Mr Thorpe at [email protected]

Drambuster

If this is true (and I am not suggesting it is not) PPL/IRs membership should have the guts to call an emergency meeting and sack Mr Thorpe. There are a few on here that are PPL/IR members - it will be interesting to hear what they intend to do. (I was a member and resigned over this issue).

AOPA UK should write to FCL008 and make their position clear. They should ensure their letter is in the public domain. There are more than a few AOPA UK members on here - it will be interesting to hear their intentions.

I am support of the IMCr, however, the latest magazine (if it is really reflective of the AOPA leadership) demonstrates how catastrophically they have been managing this issue.

AOPA UK seems to have had a view that they didn't need to lobby the CAA/EASA/Dft/ et al to agree to national ratings being attached to EASA licences (and all of the other strategies to keep the current IMCr running post EASA FCL). With a very naive view that the words "Review the requirements of the IMCr and other national IFR ratings, conclude if there was a need to develop an additional European rating...." meant "find a method to retain the current IMCr unchanged" AOPA UK seems to have sat on its backside wishing for an impossible outcome.

Then to present as fact a clearly risible argument, that in no way match what their membership wants continues the simplistic, at best, campaign.

Certainly the vocal UK supports want the vast majority of the privileges of an IR, and specifically they DO want to plan IFR flights in proper IMC, they DO want to execute approaches in controlled airspace, they DO want to fly in controlled airspace (but accept they can't fly in Class A) (and would object vigourously if the air carrier airports moved from Class D to C airspace). They DO want to have the right to fly these approaches down to the same MDA and DH (but to a higher minimum vis).

Mapped into Europe, these are 'essentially the same as those of the IR' and 'allowing IFR flight in controlled airspace'.

They then go on to say

Which just perpetuates the 'its a get you out of trouble rating not something you use to plan to fly in IMC' - While there are no doubt many who use the IMCr in this way, THE OBJECTIVE of saving the IMCr is to save the ability to plan and fly in IMC and shoot approaches!

This rhetorical strategy very badly misrepresents the objectives of saving the IMCr and as negotiations unfold will be demonstrably untrue (the enroute rating with some training of approaches as an emergency procedure - would accomplish AOPA's quoted objectives - BUT THAT ISN'T WHAT PEOPLE WANT!!!)

Hopefully AOPA has woken up to the challenge and will get its act in gear to negotiate the ability to attach national differences or sub-ICAO ratings to EASA licences!!

And if it's not true, should AOPA "call an emergency meeting" and sack those who have persistently libeled Mr Thorpe?

Who are they talking about here? If you talk to European PPLs and explain what an IMCR is, I think you will find that most of them would love to have the privelleges of an IMCR available to them.

As posted in the original opening thread , the Germans seem to have a handle on what the IMC entails , how did the negotiations end up with someone that is clearly not there to lobby for the IMC , that is the question I would liked answered

Sadly this says quite a bit about the effectiveness of AOPA UK when they fail to rustle up an invitation to the meeting.

I can visualise Ron Campbell turning in his grave. RIP Ron - if you can!

P.P.

and if it is true will Mr Thorpe have the integrity to resign given that presumably he is well aware of the No 10 petition that we organised last year signed by more than 4,000 pilots.

Of course as I have said before if these meetings were open to public scrutiny like our own select committee meetings we wouldnt have to speculate whether or not it was true - so much for open government. It rather makes you wonder what would come to light if we examined their expense claims. :)

Surely this is a classic example of UK Aviation with numerous minority groups all pushing their own agendas with no regard for the broader community. It also illustrates how badly UK GA is represented!

With no IMC, rating more people will be killed chancing their arm in marginal weather, due to the lack of training.

This is a subject that is rather important to me (and many others) so, at the risk of sounding flippant, WTF is going on and can anyone point me towards hard facts rather than unhelpful mud-slinging?

If you look at how EASA works it's processes are in fact transparent. Though I admit that navigating their website and finding the right bits is still a nightmare.

You must also see things from the European standpoint, which emanates from Brussels and indoctrinates the Commissions executive agencies such as EASA.

Remember that EASA is still very new in regulatory terms. Their remit is being widened in stages; first was a/c manufacture and maintenance, next Air Operations, then Licensing and this will be followed by airports and ATC. Each stage is presaged by a change in European Law; adoption of the Rules follows a period of public consultation.

Pre-consultation working groups are formed BY INVITATION from EASA to draft Implementing Rules, Acceptable Means of Compliance and Guidance Material.

This has been going on for quite a long time and it has always worried me how little awareness of the process and consequences for UK aviation there is. And I mean some organisations as well as people like you and me.

The problem for EASA is that they don't know who to talk to. The know they don't want to talk to existing national entities like our CAA in isolation, because the EU is inclusive and wants the industry view as well.

A bit like when you move to a new area it's not easy to know which is the nice part of town and which to avoid.

Some organisations have simply played a better game of being good Europeans, doing the Brussels coffee-shop-lobbying culture, and elevating their stature so that EASA give them an invite. Others have been less successful. It's a people thang:) as much as technical competence or ones domestic standing. Anyone getting to know M. Sivell (he's French I believe) has literally 'swum the channel' as he's quite a character.

Another problem is the way we Brits have previously responded to Notices of Proposed Amendments (NPAs). Sending a response along the lines of "over my dead body" 3479 times is not the way forward and actually irritates the poor workers who have to include these in the Comment Response Document (CRD) and guess what? Those all counted as 1 reply.

Contrast this with responses that; raise an objection, explain how the Basic Regulation creates the problem, the Enabling Rule further adds confusion and how the Implementing Rule is too detailed and then proposes viable AMCs to provide proportionate levels of safety.

Which would you prefer to deal with? Answers on a 50 euro note to me please.

Things are happening now in Cologne which will affect UK aviation for years to come. All I can say is log on to the EASA website, look for the Rule Making pages and respond appropriately. I have to warn you that some battles may already be lost, though.

Sir George Cayley

Sire George - I am in abosultely no doubt you tell it as it is.

However I am fed up with this sort of politics, as are I suspect a lot of people. It is up to those that sit on these committees to go out and listen to pilots views, take note of things like the No 10 petition and the views of our own CAA. If they dont they have failed - it may not do us much good in the long run, but it still needs to be said.

If 3479 individual responses (or whatever, I know its a made up number!!) from different people do indeed get counted as one response because the premise of the reply is similar, then there truely is no democracy within Europe. The fact that 3479 people have responded in a similar way should tell them something!!:suspect:

I will say it again - Tell any European PPL what an IMCR is, and then ask them whether they think its a good idea, and you will get a resounding "YES, wish we had that!!" in response.

Now, how does one get that response over to those in power in EASA?

What difference would that have made? You want everyone to listen to your views, but in an endless stream of posts and threads I have never observed you take any feedback or input whatsoever. Your own listening capacity appears to be zero.

Last May Jim took the trouble to get permission from EASA to publicise the interim outcome of FCL008. It was clear and NOTHING has changed to provoke this recent torrent of bile.

1. FCL008 was not proposing a Europe-wide IMCr for all the reasons that have been articulated to you ad infinitum

Martin Robinson himself said in the GA article "AOPA UK 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"

2. FCL008 did not have access to any mechanisms to create either a national-only rating or a "limited by national discretion" rating

3. Therefore, the only two outcomes of interest to an IMCr holder that FCL008 could achieve would be a more accessible full IR, and a sub-IR rating that was acceptable/workable across Europe. The EIR was the best such rating that could be agreed.

All of this has been in the public domain since May. If you or AOPA, or Eric Sivel for that matter, had some mechanism for "saving" the IMCr consistent with 1 and 2 above, then you should have publicised it. The AOPA article admits that they don't know what the mechanism should be - yet castigates FCL008 for not having some magic potion to come up with such a mechanism.

Given it has been clear for 6 months now that FCL008 was not going to "save the IMCr", why don't you, as a self-proclaimed IMCr campaigner, tell us what you have been doing to achieve this objective? Similarly, AOPA UK appear to have sat on their backsides for 6 months and woken up now to an outcome and terms of reference they have known about (through their IAOPA representative) for most of 2009. An "urgent" meeting with Eric Sivel in December 2009. What have they been doing all year?

The rest of the AOPA article is irrelevant. It deals with some recent personal comments about the IMCr made by Jim Thorpe. He is not the "UK" representative, he is a European representative who happens to be from the UK. Amazingly, FCL008 had topics other than the IMCr to work on - gliding and the full IR. What makes the IMCr nutters think there should have been some FCL008 "vetting" so that only someone who had a prescribed set of opinions could sit on a committee?

I happen to like the IMCr because I both believe it is safe and effective, and personally had hundreds of hours of IMCr-holding flight in which I used the rating to the full. I hope the rating can survive, but I despair over the mix of obtuseness, naivety and malice shown by some IMCr campaigners; especially in this attack on Jim.

The man isn't a huge fan of the IMCr, his comments are balanced in the sense of acknowledging strengths and weaknesses. Big deal. Wake up and accept that some people think the IMCr is not great. Despite my personal and positive experience, I have heard first hand from too many experienced IFR instructors, whose views I respect, that the standard of many IMCr holders they fly with is poor or, even, shockingly poor. No matter how many "FACTS" you post, you are not going to sway first hand experience of this sort that will shape people's views.

brgds
421C

The only possible counter to my points above are the Eric Sivel comments which imply that FCL008 both had the mandate and the tools to "save the IMCr" but chose not to use them. I believe this to be plainly and simply untrue. I do not know whether Mr Sivel was misreported, misinterpreted or misguided in this respect. I suspect we will find out.....

By the way, little of Drambusters interpretation is true

ahhhh I can feel a long bashing thread coming up.... misrepresentations, lies, anger, cries, reminds me of a scottish club and inhouse flying school falling out less than a year ago.....

Carry on, there s not much happening in the news anyway, I love all of you!
:ok::ok::ok::ok::ok::ok::ok:

Quote:

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During the transfer of the JAR-FCL requirements into the proposal for EASA Implementing Rules, the FCL.001 group and the MDM.032 group (dealing with better regulations for General Aviation) came to the conclusion that the existing requirements for the Instrument Rating seemed to be too demanding for the PPL holder. Additionally some of the group experts were in favor to develop a similar rating as the UK national IMC rating with lesser requirements than the current requirements for the Instrument Rating (IR) which allows the pilot to fly in circumstances that require compliance with the Instrument Flight Rules (IFR) but in certain airspace categories only.

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EASA's terms of reference.

One wonders why they even contemplated developing a similiar rating if it was impossible. Nore carefully no mention of approach limitations. Perhaps they didnt know what they were doing when they drafted their own terms of reference or perhaps they have chosen to ignore their terms of reference.

Quote:

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The Civil Aviation Authority (CAA) has been successful in ensuring that the UK IMC rating will remain in place during the four-year transition period, from the national regulations on flight crew licensing to the regulatory system governed by European Aviation Safety Agency (EASA). EASA has agreed to establish a rulemaking group to consider proposals for a similar rating at the European level. The Department for Transport will be working closely with the CAA and EASA to identify a solution, prior to the end of the transition period, to ensure that the privileges of IMC rating holders are protected.

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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.

421C - 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.

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 - time will tell and the battle lines will be drawn. If there is the will to resist these changes then indeed the changes will be resisted but it is not yet the time. :)

I always thought that the PPL/IR Europe organisation were some kind of elitist group who looked down their noses at IMC holders.. Looks like i were right!

Anyone fancy forming an elitist PPL/Night rating group?:E

Of course PPLs think it is a good idea (and certainly in the UK it is a better idea than just flying around in IMC with no training - which was what happened before the IMCr!). BUT - none of your National CAAs have in the past 27 years shown the slightest interest in implementing their own IMCr (which they were totally at liberty to do). It can hardly be a surprise then when the National CAAs get aggregated into EASA they still have no interest in implementing an IMCr.


Blathering on forums, Number 10 petitions, writing to FCL.008, dark threats, etc. are going to wind up with the IMCr holders being left behind. Only realistic lobbying of the key decision makers is going to achieve the objective of retaining all of the current privileges of the IMCr.

You guys need to choose your lobbying point and lean heavily on the CAA and Mr Sivel and/or whoever else is critical to making a decision - you need to give them a 'decidable option' - otherwise you will be left in the same lurch the UK government always leaves people in with a 'We tried really hard but sadly couldn't reach agreement...' as they sell you out.

PS - no one is 'holding their noses' up at IMCr holders - but the IMCr holders need to fight their battle not hope some Euro committee will save them!!

Until this weekend I thought AOPA UK were leading that battle - based on the magazine article they appear to have been leading from an armchair.

Jim's own perspective may be read here.

I see he talks about He really knows how to seek support for his 'EIR' outside the narrow confines of the PPL/IR group.....sorry, PPL/IR 'Europe' as they now are.

Incidentally, do tell him his PPL facts are years out of date.

Still, he does at least say that it is 'a personal view'......

No. These statements are quite harmless. They commit to nothing. The "dangerous game" is the one you are playing, which, through some combination of naivety and/or optimism, is to clutch at any straw and convince yourself that someone has committed to "saving the IMCr".

What do you extract from that, other than some people thought it was a good idea? Didn't the AOPA UK representative on MDM032 present a proposal for the IMCr and have it firmly rejected by that group? So the minority views of "some group experts" did not prevail.

Quote:

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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.

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And no mention that they would, either. It simply is a loose reference to the FCL008 ToR's.

Quote:

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EASA has agreed to establish a rulemaking group to consider proposals for a similar rating at the European level

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That is the UK government wording, and not the wording of the EASA ToRs. It depends on what you interpret by "similar" and its usage here is perhaps misleading. Why do you need to look to some paragraph from the government on FCL008's ToRs, when they have been published in full in the public domain for a year now and the same point (FCL008 is not mandated to save the IMCr) has been repeated endlessly to you. How do you think this is helping the IMCr cause?
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?

Quote:

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Anyway as I have said before discussion is a complete waste of time

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If you think the discussion is a waste of time, then take your own advice and stop posting on the subject. But if you post, I will reply when and if it takes my fancy.

-

Quote:

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you dont know what you are talking about anymore than most other people

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I don't claim to be any more or less informed or authoritative than any other poster on PPRUNE, which is an informal discussion forum and not some international aviation court room.

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.

AOPA UK did not have a seat on the working group and was therefore not in a position to nominate a representative. Neither did PPL/IR. The seats, as is normal with EASA, were allocated to European representative bodies. AOPA UK were therefore represented by Dr Michael Erb of IAOPA Europe. Jim Thorpe represented Europe Air Sports.

The pupose of the working group was to come up with something that can eventually be translated into a NPA, which will go out to public consultation. 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.

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.

Well said Mike - I have no doubt.

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”??

That's not a privilege of the French in particular. It is a lack of the UK CAA requirement to be in sight of the surface.

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

Yes


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.

You can't seriously imply that Jim is writing the bold for IAPOA. That piece of clap trap is virtually word for word from Pat's rant in GA.

The EIR was very clearly not proposed as a replacement for the IMCr but as a stepping stone to an IR, Jim's article makes very clear FCL.008 could not come up with a set of rules that would meet the constraints they were given, continue the mini-IR capabilities of the IMCr in the UK and make sense/be accepted in the rest of Europe. Jim has honestly said so, in print. You can agree or disagree with the outcome and his views, but attributing false statements and insinuating he has failed to be honest is ridiculous.


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.