Fuji Englishal

I am talking about a full IR with full IR privalages other than flight into RVSM airspace.

One which EASA could not regard as to lower standards with lower privalages.
I mentioned 3 week full time exam course, obviously the more grandfather rights and allowances the better but we have to be realistic ;)

One fear EASA must have is that if they give nothing there would be an even greater move to FAA N reg already a thorn in their sides.

Pace

Looks like this is the consensus, right?

IR "lite" to be used in combination with a PPL:
- Should have the ability to execute a full IFR flight "in the system", including departure, en-route, arrival and approach in all classes of airspace (except RVSM airspace).
- Students should be able to train for this IR within the club environment, no mandatory groundschool for instance, no FTO requirements.
- One or just a very few ground exams, preferably administrable in the club environment.
- If there are minimum flight hours requirements, existing training/qualifications (IMC!) should be accepted towards that requirement under certain circumstances.
- Vastly reduced ground school topics - only the things applicable to a PPL/IR.
- Medical class II sufficient?

Acceptable limitations to warrant the reduction in requirements vs. the full IR:
- Private flight only. Even if the holder of the IR also holds a CPL, CPL privileges cannot be used while under IFR?
- SEP/MEP classes only. For SET/MET/TR aircraft, a full IR would be required.
- No RVSM airspace, no Oceanic airspace?

Furthermore:
- Would it be OK if this were an EASA (non-ICAO) license, only valid within EASA countries? I personally would not mind that.
- Would it be OK to limit the IR "lite" only to precision approaches, with non-precision approaches being allowed after specific sign-off from an instructor?

Fuji wrote:

"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."

No it is not (on both counts). The process is well publicised and established, and is common to all other EASA working groups. Experts are appointed, the group does its work behind closed doors and then an NPA is published for public scrutiny and comment. The comments are then reviewed by EASA and a newly formed review group including user reps and a CRD published for further public scrutiny. Then EASA publishes its Opinion on the proposals to the Commission at which point final representations are made through the channels open to the pan-EU representative bodies (that's what we do, not petitions to No 10 which is waste of time IMHO) ahead of political discussions by member states' representatives. That's pretty open government compared to many alternatives I can quote, even in the UK.

If you want a committee rule-drafting system that is open to thousands of participants and commentators then life is far too short and we would never get any proposals. It would be chaos. The answer lies in getting 'your people' on the committee in the first place, through the appropriate representative body. Even as long ago as the Greeks and the Romans they had worked that one out. Its called politics.

Whilst I can of course criticise much of what EASA is doing, why it is doing it, and often we do through the appropriate channels, at the same time I respect the process that is in place and the officials who implement the process. We work with it to get results, not against it.

Please get real, Fuji.

Ah I see ;)

But this could easily be solved by limiting it to "not for commercial ops, not for use above FL250". That way *most* N reg or potential N operators who use the rating for private flying (irrespective of what licence they hold) would probably not be N reg. You could say "private privileges only" but that may weed out certain groups who could benefit from an IR(L) like this (FI's spring to mind)....unless worded carefully. Not suggesting that FI's could teach this, just that as example you are an aerobatics FI - the weather may be crap but good enough to climb ontop.......

Cheers...

Yes Dave, I'm sure that's correct. But it isn't satisfactory.

We know (or we've been told here) that the none of the experts appointed are there to support the interests of IMCR holders, and everyone says "Europe won't accept the IMCR so that's that".

This is an issue of great importance to many UK PPL holders, and it doesn't (or needn't) have any negative impact on the rest of Europe. I'm not looking for our representatives to accept European opposition, I'm looking for them to keep on pressing until we get some sort of (acceptable) accommodation. And yes: I've been there myself, done that got the tee-shirt (and war-wounds) from EU committees (not aviation ones), and when it really matters to you it's surprising how often you can win unwinnable battles. There's always an acceptable compromise (and I don't mean the en-route rating).

I don't get the impression that anyone representing the UK considers the IMCR is worth fighting for. Not enough to make a nuisance about. Other countries do that (quite properly) on issues that really matter to them.

It just doesn't seem to matter enough to our guys, or to anyone on FCL.008, which is why I wonder if the membership of FCL.008 may not be consistent with the objectives in its Terms of Reference.

FREDAcheck

Maybe then we should argue for a special case UK only IMCR on thye basis that our maritime island weather requires such a rating?

I frankly think that anything European is a non starter. I would love to be proved wrong but lets get real.

As far as a full IR that is another matter and I am sure there are many who would love to have an achievable IR?

Why have so many abandoned Europe and gone to all the trouble of registering N?

EASA hates N reg in Europe but instead of sitting down and thinking why? and should we crush N reg by offering something more attractive their way is to try and ban something which offends instead of looking at why?

As in any market in the free world the way forward has to be to offer something better, cheaper and more attractive not to take a heavy stick and a big brother one at that!

The IMCR is unique in the UK but we will never get the Europeans to accept it.

We do have an opportunity to get something hammered out closer to an FAA type IR which would be better? ;)

Pace

Hi Pace,

Fine with a UK-only IMCR; a Europe-wide one would be great, but if other countries are opposed to it then I realise that's unrealistic. But a compromise that allows the UK to keep the IMCR - even if it's a bit of a fudge in EASA licensing terms - would be OK.

And I'm also fully in favour of a "sensible" IR training scheme, but I don't know enough about that to offer any more of an opinion.

Will someone tell a technical ignoramous how to show a 'quote' in blocked blue shading as all you experts do. Please!!

David, there are two ways (the same way in two forms, really) - either copy and paste the words you want to quote, highlight them and then select the little icon above the reply window that looks like a beige square speech bubble. http://images.ibsrv.net/ibsrv/res/sr...itor/quote.gif

Or start and end your quote text with [ quote] and [ /quote] respectively. (Without the space before the 'q')

If you want to be really cute, you can put the person that you are quoting's name in the code at the start, like this:

[quote="David Roberts"]


P.S. I, for one, really appreciate your readable and informed input here. Thank you.

Like this :}

hoodie is FAA-helpful

englishal is EASA-helpful

:}

Exactly. More than 5,000 pilots supporting the IMCr who are being sidelined. That is a dangerous game, not least because I fully intend it will turn into 5,000 individual letters to EASA. That may take some managing.

Forget the IMCr, the name is not important, but what we must strive to achieve are acceptable grandfather rights for existing IMCr holders into a rating that grants similiar priviliges which is not the EIWR as propsoed.

For those that may not remember we caused somewhat of a stir last time - we may excel ourselves this time if the need arises.

So what is the point you may ask? Why the passion? The IMCr is one of the best things that happened to encourage safe GA in the UK. Every single European I have spoken to (that is actually a private pilot and flys) and there are more than a few WHEN they understand the rating are envious of what we have.

I shall be more than happy if EASA come up with an acceptable IR but the history of Europe doing so is against that wish - in the alternative I shall be very pleased to be proved wrong.

As I said before, I think there will be a last-minute reprieve for the IMCR, using some political fudge to save EASA's face on "total European standardisation".

I am sure the UK CAA will support this.

They have said so (I went to that 1/08 CAA/EASA presentation and made copious notes) and it would make sense too, because they know damn well that all that a removal of the IMCR would do is stop UK holders overtly asking for the approach...... a bit like I can't overtly ask for a GPS approach because my IFR GPS is not approach certified (it fully works but I don't have the POH supplement with the proper wording) but I could sure as hell fly the same track (especially if it is all in Class G ;) ).

So you will have traffic flying the IAP/ILS non-radio, (well, they will make a "long final" call, as they are "VFR" ;) ) which is probably OK (as they say, when god made the sky he made plenty of it) but it is going to make some high up people awfully nervous, especially when they get a TCAS warning ;)

Also, aviation has a decades-old precedent, worldwide I am sure, for never stripping any pilot of privileges. Stuff always gets grandfathered - sometimes with a generosity that defies any logic or the subject's actual training record.

The CAA have been tight bastards (especially in their medical department) in holding up a high bar to the initial entry into flying, but once you got "in" they have always bent over backwards to keep you in.

Ditto. I may not agree with you (:)) or at least may not like what you tell us, but I do appreciate you and others keeping us informed.

Freda, (to your post #75)
I think the wording is pretty unambiguous (my underline).
They did consider whether there was a need to develop an additional European rating. They agreed there was. They defined that as the EIR.

They also reviewed the existing JAR-FCL requirements for the IR and proposed a more flexible training route.

There was no bad faith in any of this process as far as I can see. It's simply not true to say that the IMCR was ignored, because the outcome of the review wasn't what you want. It's not just some faceless bureaucracy who thinks the IMCr is not acceptable across Europe, people who genuinely care about GA and making it flexible and accessible also think so. It's been explained so many times, I don't know what the point is of doing so again, but I will try.

There are some unique features that make the IMCr "acceptable" in the UK. Primarily, it's that Class A is very prevalent - including all airways and large TMAs - even some not very major ones like the CI Zone. Secondarily, we have a fairly undemanding IFR environment - for example, very little terrain, relatively few thunderstorms, little night flying (because GA airports close early).

Plenty of countries in Europe have low-level airways which are Class D or E and large TMAs which are Class D or C. They won't accept the IMCr in their airways and major TMAs anymore than the CAA will in the UK.

Therefore the IMCr can not work in Europe. Isn't that pretty obvious?
No-one has proposed a definition of IMCr privileges that would work across Europe without the qualifier "where permitted by national laws". But that is a massive qualification which EASA can not accept (as I understand it). Therefore, it isn't that the IMCr was rejected out of hand - it was simply that no workable proposal was found. Without the UK's unique partition of Class A the IMCr becomes......an IR for all practical purposes.

The problem with all the "privilege limitation" options is they are completely misguided in the correlation they draw between limited privileges and training requirements.

Take BackPacker's proposal in post #82
It's just a definition of the current IR with some meaningless tweaks. The current IR confers no commercial privileges, it confers the privilege to fly in IFR. The commercial world has its own processes and training for an IR holder to be able to use those skills in public transport. Similarly, there is nothing, nothing at all, in the 50/55hr JAA IR course specific to Type Rated aircraft. This "limitation" is meaningless. Likewise, RVSM has its own specific training requirements - there is nothing in the JAA TK or flight training for RVSM. Or Oceanic operations in IFR (eg. MNPS across the North Atlantic).

BackPacker's "limitations" are effectively those of the full ICAO or JAA or EASA IR - which can't be used in Commercial flight without a Commercial license, or on a turbine aircraft without a Type Rating, or in RVSM/Oceanic airspace without the specific crew training/ops approval. Therefore, this "consensus" proposal is for a full EASA IR. And FCL008 have proposed making that more accessible by removing the remnants of Theory that are not specific to the privileges granted (there is some commercial and turbine stuff in the IR exams currently) and making the training more accessible for private pilots.

Beagle's "limitations" are equally minor in relation to the IR syllabus. Adding a couple of hundred feet to minima is a tweak along one single attribute of IFR. It does not transform the training requirements. The minima are system-based anyway. They are not linked to training requirements until you get into specific approvals for CAT II/III.

Of course, in the UK, adding 200' to minima does mean that pretty much any blunder on LNAV will keep you clear of terrain and obstacles in most places. The rest of Europe simply isn't like that. Flying around the terrain surrounding some airports in Spain, France, Switzerland and Italy on an instrument approach, 200' or 250' added to minima makes little difference to the risks. The brutal truth is that the only thing which makes sense systematically across Europe to fly instrument departures, arrivals and approaches is an Instrument Rating.

The EIR is the only "partition" of IFR privileges that FCL008 could come up with that made sense. And I've yet to read a better proposal from the IMCr campaigners which doesn't conflict with the basic premise of
a) no national variations on FCL privileges
b) no minor or practically irrelevant tweaks in the full IR privileges used to "justify" major reductions in the qualification requirements

But the question is what fight? I think most reasonable people accept why Europe won't have an IMCr valid across Europe - and FCL008 was about Europe-wide qualifications. FCL008 is a positive outcome for IMCr holders, given an EASA-wide IMCR is just not supportable, possible or realistic. It's positive because it proposes a more flexible/attainable IR and a sub-IR qualification (the EIR) to allow some IFR privileges and a stepping stone to the full IR. That's a big improvement on the original FCL outcome. The irony on the EIR is that all the knee-jerk "chocolate teapot" attacks may actually be counter-productive because the EIR may just be a more acceptable way for the UK to "maintain the IMCr difference", by adding IMCr approach privileges to it within the UK.

Instead of all the pointless angriness and finger-pointing, someone who really cared about the IMCr would get real about what is possible. David Roberts has articulated the process very well.

The best outcome for IMCR holders may be
1. grandfather rights for existing IMCr holders to continue with their privileges indefinately, at best, or for a multi-year transition period
2. transition credits towards the full EASA IR
3. UK-only "extension" of IMCr approach privileges to the EIR

I don't know which of these is possible, but it seems like the best avenue to pursue. Otherwise, if you think 5000 signatures is going to produce a Europe-wide IMCr, you are deluded. All the 3 above are UK CAA issues - not EASA or FCL008 ones. IMCr campaigners should be focused on achieving these objectives rather than trying to win battles on PPRUNE already lost in the real world.

brgds
421C

!
 

Very well said C421.

For Fuji, BEagle, FREDACheck and all of the other passionate IMCr holders. Jawboning about a group that is looking at European solutions and has a TOR which any objective reader would agree does not include 'Ensure there is no compromise of existing IMCr holder privileges) is a sterile exercise. Waiting for an output from this group (which is a multi year process as David pointed out) is just letting opportunities slip.

Your time would be much better spent working effectively with the CAA to ensure you and they have solid legal and political opinion about which of
is the best stand for the UK and CAA to choose to save the UK IMCr.

I believe the UK AOPA is engaged in this. I assume you are all members, so get involved with a proactive solution - because no European focused process is going to come up with a solution that is 'UK gets to keep IMCr!'

European IR
 

Surely the best solution is to have a suitable PPL EASA IR modelled on the FAA IR with a European ground school sylabus. I fly an N Reg. turbo-prop single here and around Europe. The owners 20yr old son with about 250hrs experience, completed the FAA IR training in 4 weeks. He now flys IFR quite safely all over Europe.
The exams being tailored to the job in hand . No Loran Consol and 'draw a gyro horizon instrument', interminable NDB holding and approaches. I have competed both the UK ALTP and FAA IR flight test and the FAA was by far the more useful test. Including GPS, I don't think the CAA has an Examiner yet qualified to test for GPS Approaches!
The huge percentage of US PPL's with an IR versus the 1-2% in UK tells the story.
It will never happen, but just authorise the FAA IR for use in any ICAO Country.

421C

I have heard more than a few times that petitions to No 10 are a waste of time. This was our Government’s response.

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.

Please note the very clear statement at the end of the communiqué.

Now imagine someone embarking on the IMC rating during the transition period as many are and spending £4K or more on securing an IMC rating. The CAA, EASA and the Dti have stated they will be working together “to ensure that the privileges of the IMC rating holders are protected”. Please note they haven’t said they are working together to “try and ensure”, which they could well have done.

If you were the average UK pilot who really isn’t that interested in politics but was about to invest £4K would you have taken comfort from this assurance given by our Government with the full support of the CAA, EASA and the Dti?

Please note that as matters stand a pilot might well send off his rating application to the CAA at the end of the transition period – a rating that will legislative changes aside remain valid for 25 months. If an acceptable solution is not found it will be interesting to see exactly how legislation is adopted which will enable his rating to be revoked within its life.

This is what Timothy Kirkhope said almost exactly two years ago:

“Scrapping the IMCR would be disastrous.”

Jacques Barrot responded that he shared Mr Kirkhope’s concern and would be at his disposal to ensure UK pilots were not prejudiced.

http://redirectingat.com/?id=42X487496&url=http%3A%2F%2Flesrapports.ladocumentationfr ancaise.fr%2FBRP%2F074000415%2F0000.pdf

You should read this report.

It shows that GA in France has twice the number of fatalities than either the UK, or the US (4.2 fatalities per 100,000 hours, versus 2.0 in the UK, and a similar level in the US)

Do you not realise what will happen if the UK does not find an acceptable solution?

This is what EASA said in their terms of reference document in 2008:

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.

From which it would seem clear that in 2008 the position was no where near as clear cut as some would suggest unless of course we are expected to ignore EASA’s own terms of reference.

We must forget the emotion connected with the IMC rating. It matters not what the son of the IMC rating is called, what matters is that its privileges are proportionate to the needs of pilots who already hold an IMC rating and proportionate to the needs of pilots in Europe who aspire to fly safely on instruments.

I would implore anyone who reads this thread not to give up on the IMC rating. It is vital that if we are asked to accept a rating that is unacceptable we do not simply cow tail to the political process but are prepared to argue our case. Some would simply have us give up, but then that is always the simplest solution to any problem. I think EASA has already said enough to make it very uncomfortable for them, the CAA, the Dti and a few other organisations if they don’t find an “acceptable solution”.

Well said, Fuji.

421C, I don't doubt the facts in your post (95), but I don't agree with some of the interpretation, and what seem to be the underlying assumptions.
I don't agree that the EIR can be regarded on its own as an acceptable outcome. It must be explicit that:
as you suggest later. Without that, I don't consider FCL.008 have met their objectives.
Option 3 is fine (so long as it really is equivalent capability to the IMCR). Options 1 and 2 are not good.
I'm not suggesting it's bad faith, but given that everyone is busy telling us that the IMCR is not going to happen old boy be reasonable don't ask for the impossible, it amounts to being ignored. This is not simply because the outcome isn't what I want. I simply don't agree that they have done what they were asked.
Doesn't that doom the EIR as well?
To be blunt, EASA must be persuaded to accept it. You also say:
Where are these basic premises defined? Thing is, you say (twice) that local exceptions aren't allowed, but then finish by suggesting: "3. UK-only "extension" of IMCr approach privileges to the EIR".

I think I agree with you that this option 3 - a permanent UK IMCR - is all we can hope for, but given that EIR seems a non-starter (as it would allow flight in non Class A airways, which you say isn't going to happen), then a UK extension to a non-starter is a bit of a chocolate teapot.

I'm sure you are not confused, but the points you are raising of EASA's views, and the views of other countries, are rather confused and contradictory. Still lots of opening for a compromise that gives us a continuing IMCR in the UK, I'd say. And of course, let's try to get training for a proper IR fixed, too. But as well as the IMCR, not instead of.

It is up to each State of aircraft registry what privileges a foreign license or rating gives on an aircraft of that registry.

What you are asking is for say Germany to accept any ICAO IR (just the FAA one would appear discriminary) for a D-reg, for all airspace class.

This would be totally logical but is politically impossible. It would fly in the face of European protectionism (which goes back decades but is why e.g. JAA was set up in the first place) and a raft of elitist attitudes. It will never happen. In JAA-land, only one (rather far away) country ever accepted an ICAO IR in that way and they stopped it a few years ago. The CAA accepts it which also exceptional but only OCAS which is useless.

The politically possible outcomes are

- a European private IR, gradually hacked together under political pressure to reduce the foreign reg scene, and probably together with an attack on the latter scene, to make it "stick".

- a status quo (a climbdown)

The 2nd one is politically the easiest, because nobody actually loses anything except face, and one can always blame that on somebody else. Nobody would gain anything from attacking the foreign reg scene, either. Politicians have to think short-term and what credits they can earn by doing something.