Fuji

been abroad for 3 days so missed this thread :hmm: I think reading over the posts that we are missing the point getting wrapped up in detail.

Yes there are strong proven safety benefits that come from the IMCR but to the VFR pilot. That cannot be stressed enough. The IMCR can in NO way be seen as a MINI IR.

Ok there are those who use it OCAS as one. Usually very experienced pilots who have added their skills over time. For the majority it is a get out of trouble rating no more no less and that is where its safety benefits come from.

Europe could get around the safety angle by incorporating mandatory IFR traing into the PPL syllabus and use the arguement that some instrumenent training adds to safety FOR THE VFR PILOT.

Europe will never ever buy our IMCR as a mini IR. The Europeans are not going to have what they see as poorly trained PPLs risking a collision in IMC with a commercial carrier.

They will expect all in IMC in CAS to be flying to a set standard.
In that light the IFR on top with visual departure and landing is the most we can expect with a European IMCR.

A european IR for PPLs which has the same flying requirements but with un needed elements removed from the study side is the only realistic way we are going to fly IFR in Europe.

If anyone is expecting more frankly we are kidding ourselves. Who is mandated to do what is irrelevant as the on top suggestion is exactly what I predicted for a European IMCR ages ago in these forums.

As I stated then we need to push for an EIR which is achievable rather than shooting ourselves in the foot following a red herring called an EIMCR.

Pace

Pace

Politics is about the art of the possible. A Euro wide IMCr maybe impossible.

Politics is also about keeping the rabble happy. There will be a lot of UK pilots who have spent £4K or more on an IMCr who will be pretty annoyed if they cant use the rating, the more so those that read the words of EASA / CAA when they briefed the press in London two years ago. EASA could have got away with this one (if they wanted) if there was a safety case for abolishing the IMCr - but there isnt.

It is going to be very interesting to see what they conjure.

Of course it is. It is an instrument qualification which includes instrument flying privileges for departure, cruise, arrival and approach segments.

The only restictions applying are use in Class A airways, use outside the UK and 'recommended' approach minima.

Approach minima to lower levels than those recommended for the IMC rating
require a higher instrument scan rate and corrective flying skill due to the reduced beam width of the approach aid closer to the ground. That's why, for example, inexperienced pilots in the RAF holding 'White' IRs are obliged to use higher minima than their more experienced colleagues holding 'Green' IRs.

The UK IMC rating requires proportionate levels of theoretical knowledge, medical requirements, training and testing commensurate with the rating privileges.

It is NOT, as some would try to advocate, a 'get out of trouble' rating. Whereas the daft 'EIR' would certainly be a 'get into trouble' rating.

1800m? :ouch:

[/Pedant mode off]

It does seem a bit bizarre though. Pilots with IMC ratings are happily and safely operating through the UK on an almost daily basis. They are not bumping into other aircraft and there is no evidence (is there?) of increased erosions/level busts or breaches of regulations by IMCr pilots operating under IFR.

So, where is the evidence that an IMCr (or IR-Lite) would be unsafe in all CAS?

Recommended approach minima, but absolute meteorological minima for departure and arrival.

mm_flynn wrote:That's not what the Terms of Reference say. Making IR more sensible is just one objective. Considering the need for a European IMCR is another.

PACE wrote:Pace, I'm sure you're not suggesting that a bit of extra IFR training in the PPL sylabus obviates the safety benefit of IMCR (as that certainly wouldn't be true unless the IFR training were 15 or 20 hours IMCR-like training) but I'm not quite sure what your point is here.

IMCR training not only increases the poor weather ability of a PPL, but also increases the poor weather awareness, or it has in my case, anyway. I believe this means that IMCR holders are less likely than basic VFR PPLs to fly in weather below their capability.

As Fuji says, politics is the art of the possible. Imposing an IMCR on Europe may not be possible. A long-term exception for the UK ought to be, provided UK reps on FCL.008 don't give up on us. And I really hope Jim Thorpe comes to regret ever supporting the en-route but can't land rating; as BEagle says, this is not only counter to UK interests but it's a dangerous proposal.

mm_flynn and Pace

Spot on with your comments #60 and #61.

Fuji – re comment #59

People are nominated and appointed to EASA working groups as EXPERTS in their own right, not as representatives of any particular organisation. Though of course it is known ‘where they come from’ so to speak. The nominations are done generally by the OFFICIALLY RECOGNISED pan-EU representative bodies such as IAOPA Europe, Europe Air Sports (EAS) and ECOGAS for the lighter end of the GA sector.

EAS nominated Jim (of PPL IR Europe) in August last year plus two of the other members of the FCL.008 group, one of whom is a UK gliding specialist and the other French.

PPL IR had been active in making representations to EASA well before FCL.008 was set up.

Jim is an expert on the IR. His mission and that of PPL IR, which is a member of both EAS and AOPA UK (afaik), was to have a better replacement for the JAA IR. Nothing more, nothing less. Which BTW looks like it might be realised, but we have to wait for the NPA. There may be pleasant surprises that the proposed new IR will be more accessible for those who would go for the IMCR in the UK. But I won’t enter the technical debate as others will be better qualified to comment on that in due course.

No one was nominated (afaik) and no-one appointed to FCL.008 with the specific IMCR retention or Europeanisation of the IMCR agenda. That would something for AOPA to do through IAOPA Europe, who as far as I am aware nominated Michael Erb of Germany who is on the group.

One has to ask the question as to whether anyone was actually nominated by an organisation other than EAS to be the IMCR expert but not accepted for the IMCR. EAS did not see it as its job as EAS is a pan-EU organisation looking after the interests of air sports and non-commercial recreational pilots across 27 countries, not just the UK. And we had to focus on other issues that needed solving in FCL.008 so there were limits how many people we can effectively secure places for.

As another point, one should treat with a certain (large?) degree of caution comments attributed recently to one of the EASA officers at a publicised conference, to the effect that ‘if IMCR does not happen from within FCL.008 it is that group’s fault’. That is being somewhat ‘economic with the realité’, to be polite.

As I have said to others, tactically the IMCR interests need the UK CAA on your side. There is precedent in principle in the Basic Regulation 216 for having something ‘where national rules allow’ as well as the provisions of Article 14.

One lesson on all this is of course that folks should get involved with the organisations that do have access and influence at EU level, and in advance not arrears, rather than grinding their teeth through a forum. But then I would say that wouldn’t I? As some have said, politics is the art of the possible, which is what EAS practices mostly. With some success in other areas.

In case there is any doubt, I support the retention of the IMCR but the way to achieve that is not how the majority of scribes here suggest.

DGR
President, Europe Air Sports

Dave,

Are you saying that no one on FCL.008 sees their remit as pressing for the IMCR, despite the fact that this is one of the four objectives of FCL.008?

"Pressing for" the IMCR? Ahem...

Thank you for a good summary.

I am interested to know how you believe it should be achieved?

In the event it is not achieved, I am interested in how you think the CAA and the various representative bodies including your own will react if there are a great many IMCr holders who are a little upset that their views have not been represented given the numbers that signed the No 10 petition and given the "assurances" announced by the CAA and EASA in their press briefing.

It occurs to me that it is all to easy to argue that the UK IMCrated pilots are in the minority in Europe. I would argue that since there is almost no private IR flying in Europe as an inclusive part of the total population of private pilots entitled to fly on instruments UK IMCr pilots are a significant member and should be represented as such. If they are not the very constituition of FCL008 may be questionable.

bookworm wrote:Well, the objective for the IR requirements also starts:Sounds similar wording to me.

Either way, Dave Roberts seems to be suggesting that no one on FCL.008 sees it their role to make progress on this objective. So who is, or is FCL.008 going to report back "Sorry, we don't have any expertise or interest in one of our 4 objectives, so you'd better form another group to do this."

For Dave to say:really isn't a good reason to ignore one of the 4 objectives they are mandated to deal with.

Please read between the lines of what I said, very carefully, with perhaps one other bit of info. I understand - but I may be wrong - that right at the beginning of FCL.008 the experts were told 'IMCR Europe-wide - no chance' by an EASA official. Hence an alternative tack was taken I guess. Not a case of the experts not taking up the IMCR cause.

No one ignored that objective. As I understand it, FCL008 has agreed and proposed
1) a significantly reduced TK syllabus for the EASA IR, to reflect only the specific privileges granted by the IR
2) a Competency-based training process to exist in parallel with the Modular and Integrated routes. This would allow some training outside an ATO and some experience building to count towards the total needed to take the test.

This has the advantage that the actual TK Exams and the IR Flight Test are identical for all candidates, so no-one can say that private operators have "lower standards", but it does mean that the process of getting an IR may be more accessible for candidates for whom the current Modular course is too inflexible. There is precedent for such a Competence-based approach under the JAA, eg. converting an ICAO IR to a JAA one. Of course, Competency-based doesn't necessarily mean less training; for some candidates it may mean more than if they undertook a full-time Modular course; but at least the flexibility is there.

The Enroute IR is the proposal for an 'intermediate' step to allow someone to build experience, and to have some use as an enroute-only qualification.

No-one ever promised that FCL008 would "save the IMCr". That has been totally clear from the start and has been repeated on various fora for months. FCL008 set out to find a training process for the full IR acceptable across Europe and an intermediate qualification acceptable across Europe. The EIR may be. The IMCr isn't.
If there had been an objective to "save the IMCr" they would have written that in FCL008's ToR's, instead of "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"

So instead of sniping at FCL008, the "IMCr campaigners" and AOPA UK should have spent the last year doing what they claim their aim is, ie. "Saving the IMCr", by whatever mechanism they think can achieve that -and which FCL008 never was. I imagine people who feel strongly about the IMCr would love to know what progress has been made in the last year of "IMC campaigning".

A little difficult I would hazard while we all await the deliberations of a committee shrouded in secrecy and mystery - is this really what open government has come to?

421C,

Correct me if I'm wrong, but I understand you to be saying that FCL.008 was intended to carry out its objective to review the requirements for IR, but to ignore the objective about IMCR (or at best pay lip service to it).
That is, the IMCR isn't acceptable.
But given what you say about the attitude to it, reviewing the requirements of the UK IMCR is a bit pointless, as we already know that the answer is "you can't have it".

You seem to be saying that the requirement to "Review the existing JAR-FCL requirements for the Instrument Rating" will produce results, whereas the requirement to "Review the requirements of the UK IMC rating and other national qualifications for flying in IMC" won't. (The en-route IMC rating is a pointless and dangerous fudge.)

The uncharitable amongst us might assume that FCL.008 is merely an exercise to stop IMCR holders whinging without actually doing anything for them. Sort of Euro Sir Humphrey at his best.

Amongst many things yes. I did try to point out a long time ago that EASA were never going to accept the IMCr........

Indeed you did, and you also said you supported the IMCr as have AOPA.

I am not quite sure why AOPA UK and the CAA are supporting the IMCr if they are so clearly out of tune with the rest of Europe. I do hope they are not simply playing politics. :)

Fuji

I dont really understand what "supporting the IMCR" means. That sounds a bit like save the whale. ie it is something in a distinct shape or form which needs saving.

By save the IMCR are we suggesting in its present UK form for that is what the IMCR is? If thats the case forget it as it will never happen.

The best we will get is a very watered down version of the IMCR which is there in name only.

The danger with that is that it will deflect from getting a more easely achievable instrument rating for the PPL as EASA will make a empty gesture tell us that we now have an IMCR and then forget an achievable European PPL IR.

In my mind the best route forward would be for a modular IR ie a junior version for below RVSM airspace with maybe allowances for experienced pilots to apply for a pre test test. If that is passed then you can take the full examiner IR flight test.

On the exam side a cut down version more designed towards the PPL and able to be completed in a full time 2-3 week course.

That IR could then be added to for Commercial ATP Privalages.

In my mind that is what we should be focusing on and not chasing something that will not happen.

Pace

Pace,

This is still WAY WAY WAY over the top, and shows typical "European thinking".

Whay have a "pre test test"? Just go for the test and if you fail then you require remedial training and another test.

Why have a "3 week course" for the exams? Nothing is rocket science and I self studied for the FAA IR and FAA CFII exams from the Jeppesen Instrument Commercial manual. No big deal.

UNLESS the EIR has: A precision approach, the ability to self study for the exam, allowances made for previous time and qualifications, the ability to train at your local flying club then it is a non starter and a waste of time. You'll just get previous IMCR holders / Foreign IR holders flying illegally "vfr".

If the aim is to encourage new pilots to get an Instrument qualification then the "course" needs to be as easy, cheap and least hassle as possible.

What really needs to happen is to have this EIR, with a precision approach capability, which can then be upgraded later on.

Pace

Well, we will have to disagree on this one.

I believe the UK IMC holders are a very powerful lobby. I think that if the IMCr is abolished (without satisfactory grandfather rights into an acceptable replacement) there will be a great deal of discontent. I also think given the stance both the CAA and EASA have taken there will be a legal issue. (I recall your expressing similar concerns regarding the potential loss of FAA priviliges).

None of us seem to really know what will come out of EASA. Personally I am hopeful a solution will be found with which the majority will be happy - and I dont think that will be the en route IR.

In the mean time we can only wait and see.

A few on various forum seem to enjoy hinting at what may be proposed. I learnt a long time ago - either disclose what you can in an open and honest way or say nothing. It is precisely for this reason that the way in which FCL008 has conducted itself is a disgrace. It is important to open government that the committee stage is open to public scrutiny. It seems to me in this case it most certainly is not.

Still I keeping on reminding myself that it is a complete waste of time debating this matter until we know what is proposed other than I suppose it keeps the issue in the public domain. I think I should hold my peace now.