While I agree with your general logic, the FCL.008 group (which has a range of interests represented) seems to feel it is potentially acceptable (after all, most of Europe allows VFR pilots in these environments and it is not involving IFR in what most countries would perceive as the high workload/ high risk (to self, people on the ground, other aircraft as a result of reduced separations in the approach and departure) phase of flight
I am lead to believe this is one of EASA's 'Die in the Ditch' points. To pass a law in their area of competence which explicitly allows individual states to ignore the law is against a fundamental principle that European Law must be applied to all of Europe. This one thing is probably (IMHO) the most difficult item to get accepted due to potentially far reaching implication on the whole nature of European Integration. (see below for the converse)

(I am not a Euro-lawyer so someone else may be able to provide a reference or refute this point)

Three points,
1 - Option 3 is clearly the 'best' IMCr option for current IMCr pilots who use it as a UK only IR - is it the best achievable? Is the CAA/DfT steeled to have this as their 'Die in the Ditch' position.
2 - Class A airways is a British Anachronism, you should forget they exist in the context of any euro regulation.
3 - I believe enabling a privilege is much easier for Europe to accept on a national level than restricting a privilege. So saying

'Euro-Car licence holders can drive Vans in the UK' is an extension to privilege and would be reasonably received.

'Euro-Car/Van licence holders can not drive Vans in the UK' would be a fundamentally unacceptable restriction of a privilege extended to all Europeans.

I think that's 100% correct, but EASA doesn't run the universe. They just run a load of committees, whose proposals are published, go for a comment phase, and then go to the EC for lawmaking.

The known universe is run by the European Commission. That is a bunch of politicians, who work in a different way to the EASA types. This is why when say Cessna wishes to protect the N-reg scene in Europe (which is probably pretty important to their high value jet sales) they are not going to type up a Response # 13556 to some EASA proposal. They will spend 5 figures on a lobby firm operating in Brussels. That's where it all happens (or not) in the end.

It is this lobbying that has successfully brought the EASA proposals to the surface of the political whitewater (or foaming cesspit ;) ) and resulted in the recent open rebuke to EASA which - if the press reports mean anything - will probably result in all hot potatoes going on the back burner and should result in my "status quo" option above.

421C

You either know something the rest of us dont or you are very out of step - as is Dave Roberts who now seems to have disappeared from the debate I might add. (I wonder why?)

AN official from the European Aviation Safety Agency has said the UK IMC Rating "is as important to the UK as the Mountain Rating is to Switzerland" leading to hopes that it will be saved. However, support for a 'lite' Instrument Rating for GA pilots appears to be ebbing away.

The admissions came from EASA's Deputy Head of Rulemaking, Eric Sivel, during a meeting with the International Aircraft Owners and Pilots Association (IAOPA), and are contained in IAOPA Europe's latest 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 is also looking at the long-running saga of the Instrument Rating that was achievable for the average GA pilot. Asked whether the simplified IR was a realistic possibility this time, M Sivel said he did not know. "There is a lot of opposition to it. The pilots unions and the airlines say don't touch it - if anything, make it more difficult."

This is what was said only this month. That seems completely out of step with some of the views expressed here. Either we should believe and rely on what emanates from EASA officials or if EASA is allowing officials to mislead us then clearly EASA is not fit for purpose. At the moment I am prepared to give EASA the benefit of the the doubt -

there have just been too many people in too many officials position saying "a way must be found" for a way not to be found.

Not surprisingly I have much less hope of an IR lite - and this would appear to support my lack of hope. It has been talked about for all the years I have been flying (too long) and before that. It has never really come to pass. I recall Bose telling us of the sweeping changes that were going to take place - of course nothing happened of consequence. They may tinker with the requirements, but tinkering I suspect is all it will be.

With regards the IMC as a well informed journalist has jsut commented:

That may well end up being a very convenient way out for all concerned particularly as EASA are struggling with the work they have in hand anyway and moreover it rather conveniently would encapsulate the French mountain rating, the Brevet de Bas and the gliding community that fully intend to carry on flying in cloud despite the fact that they are not required to hold any additional rating to do so, and nor do they conform to IFRs or the move towards compulsory use of transponders.

Finally I am pretty fed up of those who promulgate the usual nonesense about the rating being unsafe. Why pander to the detractors and ignore the evidence. I wouldnt mind your doing so if you (or they) had any factual basis for doing so.

This is what our own CAA has to say about the risks in TMA:

No suggestion there then that pilots with their IMC rating are causing chaos in class D airspace (effectively the appraoch segement for nearly every airport in the UK from which CAT operates).

Anyway it is still more than two years away IF they meet their deadline. I will worry about it nearer the time.

Fuji

As in any comittee many people hold different views and may express those views. That does not mean that they are official EASA statements or policy.

It is probably likely that under the regulations alllowances may be made for "special needs". You mentioned the mountain rating and it is probable that a special needs excemption would be the cleanest way out on the IMCR.

As for the IR Lite you may well be right as NONE of this is about safety and never has been. It is more about protectionsism, self interest and politics.

The whole history of Europe and political leaning has been anti individualism and to have no freedom of the skies.

Given the European leaning its natural instinct is control not freedom. Stick the masses in large commercial people carriers. The big Brother state.

So yes you maybe right the way forward for Europe and aviation will probably be further tightening and restrictions especially against the percieved wealthy individuals who own or fly private aircraft but that isnt good for any of us the IMCR is insignicant in comparison to what we should be fighting.

I am afraid the IMCR is a Red Herring and one where we will end up shooting ourselves in the foot for fighting a blinkered battle.

Pace

I'm not sure that it would be impossible, and Euroland could do it without losing "face"......

For example if limited to "private privileges only" - which is what the FAA would do to a Euro licence holder - then it needn't impact on "Commercial" aviation in Euroland, which after is is where 99% of the current IR's come from. If the rules then stated that the Foreign IR holder then had to renew their Euro IR (based on) the same way as normal IR holders then in fact it'd actually generate European business.

For one to fly commercially in Euroland, one would still need to do the Euro IR.

Firstly, you should understand that there isn't a cat in hell's chance of anything 'FAA' being accepted as an EASA way of doing things. If you thought antipathy towards the UK IMCr was bad enough, anitpathy towards anything 'N-reg' or 'FAA' is many times worse. So forget comparison with the way they do things on the other side of the pond.

'Private privileges only' would, quite rightly, be vehemently opposed by all FIs. So forget that for a game of soldiers, englishal, it'd NEVER be accepted.

It is pretty obvious from various responses on this thread that some come from the PPL/IR mafiosi with their blinkered support for the lunatic 'EIR'. Fortunately many of us in the real world are now working with the authorities both in the UK and in Europe to ensure that the actual UK GA view of such a chocolate teapot rating is made plain to EASA.

There are a couple of strategems, both due to other EC proposals, which may well allow us to demand that this whole issue is be put on ice until the potential effects of these proposals have been properly studied.

bEAGLE

I for one have not indicated an FAA IR in the UK I have indicated an easier to achieve IR which doesnt drop standards which is a little closer to an FAA IR.

As to yourself in the real world good luck as you will equally never achieve anything vaguely like the UK IMCR European wide either.

Your best hope is that the CAA refuse to do anything on the IMCR on the grounds that to elimate it would cause a drop in safety to VFR pilots in our unique weather.

That arguement and tactic doesnt take an Einstein to work out or suggest but Good luck and carry on with the tea and biscuits.

Pace

Pace

Now come on Pace, you dont really mean that. One of the ways we run our politics is for senior officials to indicate policy partly of course to assess the reaction but partly to indicate in which direction policy is likely to evolve.

Eric Sivel is no ordinary person - he is deputy head of rule making. I suspect he is an experienced enough person to know exactly what he is saying.

In the same way the Prime Minsister's office however much we may mistrust politicians is not inclined to respond to petitions in a way that is unsubstantiated particulaly when they specifically refer to having consulted with EASA, the DTi and the CAA.

We need to be very careful. There are those who would rather see the demise of the IMCr or its son or daughter for all the wrong reasons. You can bet there are some on this forum. After the comments I have read by EASA, the CAA, the Dti and others, only some of which I have reproduced I have a little more faith. Unfortunately there may also be individuals on committee with less apparent agenda; it is important the voice of private pilots is heard that we will not willingly accept the impostion of regulations that have no case basis in safety, are without regulatory impact assessment and are a restraint of priviliges already held.

I've met him, close up, and I would agree with the above.

However, EASA is just an agency of the Euro Transport Commission and will do what they are told in the end - regardless of what proposals its committees have developed.

Fuji "as is Dave Roberts who now seems to have disappeared from the debate I might add. (I wonder why?)" [David please, I am not Cameron.]

Because I have been busy actually working until I decided to take a look this evening at the forum, as 'relaxation'. But I am not replying right now as I am still busy working......or supposed to be!

Other than:
1. 421C has it right.
2. AOPA probably needs to change tack if it is not to blow it.
3. The DfT / CAA almost certainly wrote the response to the No 10 petition. That answer was already available directly from the CAA for those who took the trouble to ascertain their view by sensible discussion. QED

Well I'd accept it, as would probably 90% of people on here. At least it'd give many more people the opportunity to fly IAW IFR in Europe. Something I can't currently do due to the lack of an N on the back of the aeroplane, and despite being as qualified as many of the CAT pilots out there.

Anyway, that is not the issue. The issue is that we have a great opportunity to improve upon the IMC rating. I'd rather the IMC disappeared, but in return we got a useful Eurowide mini IR. I'd be happy for access to "all classes of airspace" and be happy to just fly ILS approaches. At least then I could cross the channel at 10k rather than 3499'.

Well done. Glad to hear it.

Oh goodie, thats all right then, now we know the rest of us will roll over and accept the position.

Glad they have had the guts to stand up for what not only they but their members believe in.

I know, I know all petitions are a complete waste of time. As I said earlier I will mention it to Gordon next time I see him. Oh, perhaps you might mention it also to the 4,000 odd pilots that signed the petition.

How many GA pilots in the UK are members of your organisation?

I dont mind what you call me and doubtless will. :)

Seriously, you may have to take the view that you have no alternative to play politics. Fortunately I dont and I will argue for the IMCr in the UK or an acceptable replacement which the EIR is not. I might fail but I still believe it is the right thing to do.

Anyway, I am done here, time who tell how this one plays out.

Fuji,
Then why do you trott out your thing about how safe the IMCr even when no-one has said it's unsafe? I repeat. No-one on this thread has said the IMCr is unsafe.

Can you not understand that the following two positions are not inconsistent?
1. People accepting that the IMCr works safely in the UK with the UK's specific Class A structure and the Class A limitation of the IMCr
2. People outside the UK not accepting the IMCr in their airspace which has a different structure in which Airspace Class limitations can not achieve the same effect they have in the UK.

A number of posters, myself included, have tried to explain our understanding of why EASA isn't going to take the UK IMCr and turn it into a European qualification, and why the basic principles of EU standardisation mean that they didn't just draft EASA FCL NPA17 with a "UK only" qualification, and why, subsequently, FCL008 wasn't able to do so either.

Now, as we have all said, there may be "secondary" methods of getting the UK to hang on to IMCr privileges through transition/grandfathering/opt-out whatever. It would be great if there was such a mechanism. I just don't know what it is.

No-one said it was a waste of time. It's your thing again of replying to points no-one has actually made. I only said I didn't believe any petition was going to make EASA publish a Europe-wide IMCr. David pointed out that the reply to the petition didn't seem to add anything to the established CAA position on the subject. That doesn't mean it didn't raise awareness etc.

It does seem that there is an inconsistency here. I don't understand it any more than you do. Could the weak link be the reporting of these comments?

Quote:

---

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.

---

The other issue may be in the "acceptable". Acceptable to whom?

This really does read like some sort of odd paranoia. If you have read comments by EASA, the CAA, the Dti, AOPA that give you "faith" then why don't they just turn their faith-giving comments into action? What mysterious force of darkness is preventing them?
The truth I believe is that, in principle, a lot of people are sympathetic to the IMCr but, in practice, no-one has worked out how to preserve it.

Freda,
I can see how some of that looks contradictory. I think there are two levels in how European laws and rules operate. Firstly, there is a "Primary" level - the regulations that are standardised across Europe and become EU law. Then there is the "secondary" level of national deals/opt-outs/exemptions/whatever that uses a variety of other mechanisms and legal/political methods. EASA's draft rules, developed by the FCLxxx Working Groups, are at the "Primary" level. At that level, I don't think you can have national exemptions etc. I don't know what can be achieved at the "Secondary" level - perhaps a lot - eg. keeping the IMCr or attaching approach privileges to an EIR etc.

brgds
421C

421C

I am sorry for my robust response to David. I will be frank when saying it dismays me when commentators like David appear to have given up on the IMCr and any replacement (the EIR is not a replacement). I wouldnt mind if he was in step with UK pilots (and even many outside the UK) but I honestly believe he is not. What may or may not be politically achievable is one thing but there are times when you should reflect the wishes of your members. I am not convinced that AOPA supported the UK IMCr two years ago but I suspect if they did not they realised they were out of step with their members and have now had the "guts" to nail their colours to the mast.

Quote:

---

But if the Agency is now instructed by the EC to leave sub-ICAO/JAR licences to the national authorities, then its future in the UK appears to be secure.

---

As I stated earlier here is one possible mechanism. There are others if the Commission wish to use them. We should be pushing for them to do exactly this.

I could set a number of solutions that I believe would be acceptable but there is little point until we have a better idea in which direction EASA will go. One possibility would be a Euro wide EIR with sub-ICAO approach and departure priviliges granted by the CAA in UK airspace.

With regards to the IMCr I understand the safety case perfectly well. If an IMCr holder has demonstrated that they can safely negotiate the arrival into Glasgow what makes you think he cant do so into Maastrich? In fact I think you are entirely wrong - it is the EIR that extends the priviliges of an erst while IMCr holder in Europe because European airspace is not compatible with IMCr holders operating off airways. The reality is many are uncomfortable with a rating that they perceive as being equivalent to an IR lite by another name - which also many do not want in Europe (or historically the UK). The IMCr rather neatly side stepped the issue by keeping IMCr holders out of class A. An EIR with approach and departure priviliges on the face of it does neither. However the imposition of a height restriction and higher minima might have been a better approach to placating the IR lite by another name brigade. In fact it is interesting when you tell some that the minima for an IMCr holder are the same as for an IR - quite simply they are horrified. I suspect the wording the CAA adopted in the ANO was very cleverly drafted.

So much better progress could have been made on this issue if our representative organisations had not just caved in before the first hurdle. Let it not be forgotten how powerful a lobby GA could be. Their numbers are far far greater than all the European commercial operators combined and nearly every single one is a voter. Many are politically or economically active and therefore very influencial. I was pleasantly surprised how relatively easy it was to ask over 4,000 pilots to sign the No 10 petition - that is more than the membership of AOPA UK. I was surprised how with only a little education European pilots were arguing the case for a Euro instrument rating with approach and departure priviliges. It should be to the chagrin of so many of our representative organisations that on these big and important issues they could not find a way of working together, of educating European pilots of the benefits of an IMCr style rating and on lobbying the Commission rather than walking away from the campaign as we have seen on this thread.

As they say in American its the difference bewteen their starting from "of course we can" and our starting from "of course we cant".

Fuji

Part of the problem we have is a misunderstanding eg what the IMCR is. You Beagle and many others see it almost as a British instutution, a rare species which faces extinction and must be saved at all costs.

In reality and this is how the Europeans see it it is a very low quality rating designed to get you out of trouble with minimal instrument training and exams.

Do the Europeans who dont have that rating want such poorly trained pilots in cloud risking a collision with commercial traffic? Because that is how they will percieve it.

UNTIL the day we start to realise that the IMCR is only a set of standards to be met in instrument flying which could be greater or less then we will get no where.

The Europeans have their own IR and viewing the IMCR as a set of low standards far below their IR they are not going to accept it Europe Wide.

As it is purely a set of instrument flying standards and exams as is the IR you can only argue to increase those standards or decrease the IR percieved standards to get something universally acceptable.

We are all after the same thing maybe its just our perception of what we are trying to achieve which is different.

Pace

True.


.. but there you have it, if you had said "who perceive such poorly trained pilots", I would have agreed with you. The evidence is however poorly trained you or they think they are the evidence does not support you. I just dont understand how intelligent people can so readily ignore the evidence. I recall being told many years a go when a case comes to trial only three things really matter - EVIDENCE, EVIDENCE, EVIDENCE.

Show me the evidence that IMCr pilots are unsafe and I will agree with you. Put the IMCr on trial that it is unsafe and I believe you would fail. Is the training standard for the IR higher - yes of course, but for all sorts of reasons that does not mean it is safer.

Let me ask you this - how many pilots with an IMC have you flown with Pace?

The second issue is do away with the IMCr and what do you think will happen to flight safety? Do you really believe the IR will become more accessable - if it does all well and good but the evidence is not persuasive. Do you think the EIR is an realistic alternative - I dont. Please read the French study because it is a reasonable piece of evidence of what happens when you effectively prevent pilots gaining an instrument qualification. Please consider the history of the IMCr and why it was originally introduced against a great deal of opposition, just as now. The opponents were wrong.

Fuji,

Your argument is much more persuasive with regard to retaining the IMCr for the UK than extending the IMCr privileges.

It is a well supported fact that VMC->IMC incidents are significantly less frequent in the UK then France (and that UK GA is about twice as safe overall). The IMCr is almost surely a significant contributor to this - In any event, it means UK GA utility is much higher then French and Safer (A win win!). There is therefore a pretty solid case to say removing this from the UK will be a massive backward step in Utility and safety (and I don't think anyone has argued against this).

Unfortunately, it is readily demonstrable that the training for the IMCr is significantly less than the IR and excludes subject areas that are deemed by ICAO, Europe and broadly everywhere in the world as relevant to IFR operations in general. So I think Pace's statement is undeniably true - There of course is the question - is it relevant?.

To that end, you are labouring under a misapprehension as to the safety of the IMCr. I have never found the original CAA source of only 1 IMCr accident in IMC. It is patently untrue as even a modest analysis of accident data will show. This is not to say the IMCr is unsafe (exposure data isn't available, it is almost impossible to demonstrate relative safety), and the accident rate for IMCr and IR holders both is fortunately very low (I refer only to UK operations because of the consistent data and relevance to the IMCr). I attach a summary analysis of the last 10 year CAA report on GA accidents. You can see these accidents are rare, and only one was an approach (which from recollection was to low minima and at night). You will note, there is not a single PPL/IR (once again no data suggests the relative flight hours of less than 7.5 tonne ATPL, CPL, PPL/IR, PPL/IMC operations).

This analysis is from the decade after Pace's friend's accident - and overall the accident count related to current IMCr/IR holders was lower for this decade than the previous.

Nothing above says the IMCr is unsafe, equally, nothing suggest that extending the IMCr to a Eurowide rating (with the consequent increase in variety of environments would maintain the safety level). Although, it may increase the safety in France from its current relatively low level.

The case for retaining the IMCr is, I believe, demonstrably sound. The case for getting it accepted around Europe is (IMHO) lacking almost totally in facts - hence the unending depate.

Pace

I don't think I agree with some of this.
Where is the evidence for the alleged European perception

- by pilots
- by regulators

It is clear, from informal surveys, that a large % of European pilots would give their right arm for an "IMCR".

You are no doubt right about the regulators though.

I don't agree with that one. I had my 20hrs of IMCR training and at the end of that I was able to correctly fly absolutely every plate that you might have stuck under my nose.

When I started IR training (in Europe) I was flying Eurocontrol routes, with an IR instructor in the RHS to make it legal, and right from the start I knew every bit as much about "IFR" as he did.
Again... need to examine the detail. Enroute, GA flies in the big void between the MEAs (FL070 min, FL100 realistically due to routing issues) and practical oxygen ceilings i.e. about FL200, with a few at FL250. The routings don't get allocated to busy areas anyway. Only in terminal areas will the traffic potentially mix but they are under tight radar control and any monkey with a half decent plane can manage that. And nobody without a half decent plane will be flying IFR anyway - one of the many self limiting aspects of airspace usage.

I agree, but that is no reason to describe the IMCR in the adverse terms.

It happens to be a bit of a throw-away qualification for many pilots, because the incentive you have to keep something is according to how hard it was to get it.

If, to get the IR, you have to spend well over £10k, a huge amount of residential hassle, give away your left bollo*k, etc, then you will keep it. So.... how many pilots with a valid IR can you see? Very very few - except high net worth private owners, and those using it for a living. Even most instructors let theirs lapse - until they get an airline job offer.

Whereas the IMCR has been much more accessible, as a natural post-PPL qualification which one can do at one's old PPL school. Just like the FAA IR is in the USA, actually :) But it also means that a lot of people did it and did not look after it.

The key to getting a private IR which achieves any meaningful penetration in Europe will be

- a greatly cut down ground school
- doable in any PPL school (incl. checkride)
- demonstrated competence i.e. not the 50/55hrs minimum dual time
- training doable using a hood (not the stupid CAA screens)

This has all been done to death before but I just like to jump in when somebody has a go at the IMCR :) It served me well for a few years, and I even got a written confirmation from the FAA that it was valid in an N-reg, so I was able to move the plane to N while training for the IR.

>This has all been done to death before but I just like to jump in when somebody has a go at the IMCR<

10540

It may appear that I am having a go at the IMCR when infact I am not. I too enjoyed the IMCR for years and used it in anger.

I would add that for a basic PPL without experience the training for the IMCR is not sufficient for the rating to be used as an OCAS mini IR.

The majority of IMCR holders do use it as a safeguard for VFR flying and not in anger.

The safety benefits are pushed a lot in these threads but lets be clear these safety benefits are to VFR pilots NOT safety benefits to flying in IMC. There is a subtle difference.

I have no fears that we will loose the IMCR in the UK there is too strong a safety case for that to happen.

I have NO confidence at all that it will ever be accepted in Europe. Trying to make the IMCR a European target will only achieve any possibilities of a greater prize an achievable IR to be missed. That will be a LOST OPPORTUNITY.

So against the IMCR? NO! Do I see a larger prize YES! Can we loose that prize by chasing something we will not loose anyway YES YES YES.

Pace

What if we were to take Jim Thorpe's EIR, and make two significant changes:

1. The airlines don't seem to want to share the airways with EIR trained pilots. But under JT's proposal that is exactly what they would be doing, without restriction. In order to allay their fears, suppose we said that the EIR would not be valid in airspace classes, A, B and C.

This would three effects:
A) it would effectively ban all EIR holder from airspace across Europe above FL195 (which is all moving to class C, most of it is already there). For the airlines this largely means no mixing it with EIR holders enroute which has to be a big improvement for them over JT's proposal.

B) it would ban EIR holders from busy terminal airspace, which tends to be class A or C.

C) it would allow regulators in countries that did not want EIR holders mixing it with commercial traffic the option of upgrading their class D airspace to class C, and effectively ban EIR holders from controlled airspace. Those that did wish to allow them could downgrade any class C to D. There isn't all the much difference between Class D and C anyway.

As for class E-G, well VFR pilots are already mixing it with commercial traffic here, and don't even require transponders nor two way comms!

Of course this would also allow EASA to have it's one size fits all for European airspace.

It would surely also be much to the 'safety benefit' of the airlines.

Regulators would have little cause for complaint, as they could effectively ban EIR holders from controlled airspace by upgrading class D areas to class C (They will be mixing it with non-transponding, non-radio VFR traffic in class E anyway, so I can't see much objection to mixing it with EIR traffic which will have to have a transponder, and will have to have two way comms).

2) In return for the above, EIR holders would be allowed to do approaches in IMC. Of course this would only be in airspace classes D-G

This would make the rating (as a stand alone rating) much more useful, as it would allow the rating to be useful in itself, in classes D-G.

It would allow those working towards the full IR to practice approaches to less busy airports.

From the airlines prospective they would only be mixing it with EIR holders at less busy airports (airports in airspace Classes D-G).



Would this have a chance of succeeding?

Would the banning of EIR holders from Class A-C cause logistical problems?

dp