Irv Lee wrote:...MUST be usable in ALL airspace (inc class A)...
With the patchwork quilt of airspace structures that is Europe it is difficult to see how there could be any rational airspace limitation. The inclusion/exclusion of class A is only of relevance for the UK and Italy. I am sure the CAA would be relaxed about IMCr flight in airways as that is what the IMCr would allow in much of Europe - so it wouldn't make sense prevent that in the UK.
I also think focused agitation directed at decision makers and pointing to the actions they can take is a much better use of peoples energy than un-directed frothing.
I'm watching with interest. I made what I thought were reasonable comments. They appear not to be accepted as such.
If the end result of FCL008 is that "the high bar IR" with the OTT academic exercise of a TK syllabus remains as the only option, then FCL008 will have failed.
Since the S in EASA stands for Safety, I hope those in charge have long since realised that Europe isn't one single environment. Different criteria apply in different bits. Switzerland and areas around need mountain training. The UK needs IMC training, which is probably not vital in Italy, Spain etc.
If the IMCR goes, and the achievable IR doesn't replace it, I think civil disobedience will then be the order of the day. In other words, pilots will fly in IMC if they think they are capable. Some will be, some won't, but there will be no checks or training. Only the "responsible" (like most on here) will shake their heads in sorrow and give up their IMCR privileges (or are they rights?)
Im sure if you go back a few years, you'll find a comment in the forum pointing out that the choice of the word 'safety' was a political gizmo so that they can do whatever they want, and the public and press will say 'but it's the safety agency...'
If the IMCR goes, and the achievable IR doesn't replace it, I think civil disobedience will then be the order of the day. In other words, pilots will fly in IMC if they think they are capable. Some will be, some won't, but there will be no checks or training.
110% with you there...
Only the "responsible" (like most on here) will shake their heads in sorrow and give up their IMCR privileges (or are they rights?)
ALSO, it's probably time to introduce the subject of money and hope they understand that concept as they don't seem to understand the concept of progressive safety steps for all. Who is pushing for our 'French Farmers' clause? What I mean by that is if there is any euro ruling that disadvantages french farmers, there are huge amounts of compensation available to them. At the moment I can teach IMC. I won't be able to go IMC in future or teach the EIR 'cos I won't have one. So.... "Where's me 'comp' ????"
FCL.008 set their own 'rule' from the start for whatever came out of FCL.008 MUST be usable in ALL airspace (inc class A), and in doing so, they were pandering to the 'rich set', (certainly not a 'twit' set!) and ignoring an opportunity to provide real achievable safety stepping stones (plural) up from the bottom for all, so at least hobby pilots could afford to step up someway, and the richer set could progress further. The current information suggest it's a safety opportunity for all that looks like it been 'avoided' by deliberate manipulation of initial parameters.
That's completely false. I think you are entitled to post whatever accusations and conspiracy theories you want, but I feel equally entitled to say "complete [insert colourful idiom]". Firstly, the "rule". I am not sure there is such a rule, and I certainly don't think it was set up on FCL008's own initiative, but I have read that EASA have a principle that all qualifications should be applicable to all airspace classes in the standard ICAO way. This is hardly a shocker and perhaps a good thing. Airspace class and design is still a national prerogative, and they might want to avoid publishing harmonised EASA FCL regs and then individual countries manipulating the airspace. Secondly, the motive. "Pandering to the rich set". This is both an accusation of bad faith and dishonesty in representation, which I believe to be false. I believe the people you are accusing acted in good faith in the interests of all GA pilots. But even if I didn't, the motive makes no sense at all. If a mythical "rich set" lobby had staged a secret coup over FCL008 (it's all very Dan Brown, perhaps they were a sect called the "Instrumentati") why on earth did they propose a more flexible and accessible IR? Bluntly, that is not in the selfish interests of any IR holder - JAA or FAA. An FAA IR owner/operator will, in most cases, have the time and money to do a JAA IR if they had to. Any existing IR, having jumped through the traning hoops, finds the existing infrustructure in Europe pretty friendly and accessible. Under 2tons, you pay no charges and can file and fly to your hearts content all over Europe - in part, I suspect, because so few people do, that the tiny 'rich set' (as you call them) have little impact on the various IFR resources and capacities. A more flexible IR might bring more people into the system and impose more restrictions. Ironically, however, despite your silly accusation, I have never met a PPL/IR who didn't think the IR should be more accessible to people who don't have one and the supposedly "elitist" PPL/IR Europe group does a very odd thing for an "elite", which is to campaign to make its "elite status" less elite. Thirdly, the mythical alternative that was "ignored". You say "a safety opportunity for all that looks like it been 'avoided' by deliberate manipulation of initial parameters". What exactly was that? Without a description, how can we judge? There are only 7 airspace classes. Which restriction would have provided this magical Euro-solution? Class A? Well that doesn't work in countries who have Class E/D airways. If the UK, with its 30 year experience of the IMCr won't let IMCr holders in Airways and major TMAs, why on earth do you expect other countries to? Get your friendly CAA contact to open up UK Class A to IMCr holders and then they can preach to Europe about the IMCr. The Class A restriction also wouldn't help Italians, for example, ever get much above 1000' in most of their country. Or is EASA meant to ignore non-UK pilots? How do you think they might have felt about FCL008s terms of reference in that case? There are over 500 posts on the other IMCr thread and I don't think a single one of them has produced this magical "could have been accepted by FCL008 if not for the evil conspiracy" solution. See my long post on this page viewtopic.php?f=1&t=54995&start=480.
I have spent a couple of hours this afternoon looking again at the article entitled “IMC, IR, EIR – past, present and future” in the PPL/IR magazine.
It refers to the IMC rating as a “least bad compromise” and to IMC rated pilots flying less capable aircraft (is a fully capable aircraft – pressurised, de-iced, etc., - a requirement for joining the “instrumenti” sect?). It says that, as the UK is the only country that sees a requirement for such as rating, then this is irrational (so ignore it?) and argues that there is no credible evidence to support the safety benefit of the IMC.
If this is how the IMC rating was presented to the FCL.008 committee, can you understand why IMC rated pilots are not happy? Far from being balanced, the article presents a negative view of the IMC rating. Was that part of the horse trading (To quote the article “It’s a horse trading process across a wide spectrum of political objectives”) to obtain a more accessible PPL/IR.
If the IMCr had been presented as “Hey Guys, we Brits are miles ahead of you. We have years of experience in operating a sub-ICAO instrument qualification for pilots who fly aircraft in IMC at lower levels (because they don’t have / can’t afford de-ice boots, pressurisation, etc..) and, guess what, there are already pilots from other EU member states who have taken the course just to improve their flying skills. It allows pilots………..” I wonder if the commitee might have thought differently? I could go on but it has all been said on other threads and forums.
Who says that article is piece of advocacy for the IMCr or how anyone should have presented the IMCr? I read it as an explanation, after the fact, of why we are where we are with the IMCr and why Europe isn't going to accept it.
So, in an article with some plus and minus points, if you focus on the minus points you don't exactly get the full picture.
Bald Sparrow wrote:to IMC rated pilots flying less capable aircraft (is a fully capable aircraft – pressurised, de-iced, etc., - a requirement for joining the “instrumenti” sect?). It says that, as the UK is the only country that sees a requirement for such as rating, then this is irrational (so ignore it?)
No. You have missed the point. The point is about the contrast between the 15hrs of training for the IMCr vs the 50hrs for the IR, given that the IMCr usage profile could be an equally or more demanding one. I don't need to argue it, just read the paragraph: "Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited, are accorded effectively the same privileges within the UK as pilots who are deemed to require about 50 hours of training within an approved organisation. IMC holders operate in the lower levels with worse weather, generally flying a less capable aircraft. They have less comprehensive ATC services and use airfields with fewer facilities. Often they have little chance to stay current and are subject to less frequent renewal checks than holders of the IR. It is not hard to see that this seems rather irrational if you live anywhere else in the world since no other country has seen a requirement for an IMC like rating. On the other hand it must be said that the IMC has in practice continued to generate few problems and is well liked"
and argues that there is no credible evidence to support the safety benefit of the IMC.
It doesn't argue, it says that the oppsite argument is made (as it endlessly is, just read the threads), that there is a safety benefit, but that the author has been unable to find the evidence. "It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents. One might argue polar opposites. It encourages partly trained pilots to enter conditions that they cannot cope with or it enables pilots to avoid situations which would have been dangerous if they had not held the rating." If you feel so strongly about it, where is this evidence? I personally believe a lot of things about safety that I can find no credible evidence for. I happen to believe the benefit of the IMCr, but have no evidence for it - just as I happen to believe that for the trips I fly, a twin is safer than a single, but I have no credible evidence for it. Our opinions are fine for our own personal uses - but the article's point is that the oft-repeated claim that "the IMCr saves lives" doesn't have any particularly compelling evidence to support it, so why should Europe believe this?
If the IMCr had been presented as “Hey Guys, we Brits are miles ahead of you. We have years of experience in operating a sub-ICAO instrument qualification for pilots who fly aircraft in IMC at lower levels (because they don’t have / can’t afford de-ice boots, pressurisation, etc..)
and Europe would have replied "thanks Guys, we also have such a qualification, the Instrument Rating (it is also trained and tested at low level on non-pressurised, non-deiced aircraft). We made it 50hrs training because that's what we think is right for such privileges in Europe. You don't need to tell us how "miles ahead" you are with your 15hr rating, we are aware that the ICAO IR has a 10hr minimum, and that the FAA IR has a 15hr minimum too. Thanks, but no thanks.
and, guess what, there are already pilots from other EU member states who have taken the course just to improve their flying skills. It allows pilots………..” I wonder if the commitee might have thought differently?
And perhaps the reply to this would have been "great, the very fact people undertake the training without gaining any privileges means that the "safety benefit" of the IMCr can continue because people can undertake the training irrespective of the rating"
I could go on but it has all been said on other threads and forums.
421C - I'm just sorry you have to devalue yourself with the tactics shown.... I think enough people recognise them now, and when I see such things, it just makes me think I might not be 100% correct, but I must be getting close....
firstly 'rich twits' - take someone's view point, change it slightly to ridicule it, and then present in onwards as if it's the original... a sort of malicious Chinese Whispers done deliberately, hoping others don't spot the difference.
Secondly, your long post on Xmas Eve - let's not complicate things, what I think has happened is:
a) the IMC rating could never have passed FCL.001 - and the people with IMCs never even knew what was going on, due to enforced secrecy - I'm assuming it was that, not lack of integrity or conspiracy. Now if you put a rating into a process it cannot pass, pilots have a reason to feel cheated.
b) there was a lot of anger when this FCL.001 result came out, and the anger was eventually dampened down with 'calm down and EASA will let FCL.008 examine the situation and see what it thinks', so the anger died and hope came back. What was never said at the time was that FCL.008 was working under secretly agreed parameters that meant it couldn't 'pass' there either as anything we would recognise as an IMCR. what I think happened was that FCL.008 very early on decided that the initial parameters it had agreed to (ie: whatever it comes out with must be usable in all airspace) and the IMCR that it had suddenly found dumped into its lap were incompatible, so it just decided to get on with its main task for the next few months and try and come out with a simplified I/R and something that we hear is an en-route I/R, but I don't believe this is a development of the IMC rating, it's just a product of months of work by FCL.008 compatible with its agreed scope. I've no idea why it couldn't say back in January that it could not work on the IMCR, but I do wonder if again, the answer lies not in integrity or conspiracy, but the 'handcuffs' they are working under. For all I know, it could be legally very costly for someone in the group to say what is going on. However, again, when you put a rating into a process it cannot pass, pilots have a reason to feel cheated.
What the IMCR really needed was not being dumped on FCL.008 who were there for other purposes, it needed a proper look at it with a blank canvas, which is not what FCL.008 could ever give it, yet EASA damped down the post-FCL.001 anger and protest by giving the impression that it could. I put my views into the feedback on FCL.001, which was all to do with making achievable steps up from the PPL for pilots to improve their skills to levels they felt they needed and could afford..
I've no reason to question the integrity of the people working in these groups, I only know one (or perhaps I know more, but don't know I know), I assume they were working to agreed rules that were not publicised at the time outside the group. Jim Thorpe is getting a lot of abuse - possibly through the malicious Chinese Whispers route, but I happen to think he's a very honest person with integrity. We don't agree on things, (for example, forget EASA, we don't agree on how PPL Nav should be taught), but we can have a pint together and just accept we don't agree, and disagreeing doesn't mean one of us is dishonest, it just means we have different views, but I wouldn't take his views and do a 'chinese whispers' hatchet job on them
Irv Lee wrote:421C - I'm just sorry you have to devalue yourself with the tactics shown.... I think enough people recognise them now, and when I see such things, it just makes me think I might not be 100% correct, but I must be getting close....
firstly 'rich twits' - take someone's view point, change it slightly to ridicule it, and then present in onwards as if it's the original... a sort of malicious Chinese Whispers done deliberately, hoping others don't spot the difference.
Irv, Your post on an earlier thread (your italics)
Ands how many of the people that have taken IMC courses are actually interested in flying in Class A? All that will do is to guarantee the training costs double, but admittedly, the 'all airspace classes all over Europe' idea will benefit the 'where shall we go this weekend darling - Geneva or Chambery?' set.
led to my earlier comment. If it upsets you, I will happily retract the "twits" bit, but I do think your opinion on the FCL008 motives and process ("secret parameters", "pandering to the rich") is silly, but I will try and keep the ridicule to a minimum.
Secondly, your long post on Xmas Eve - let's not complicate things
I was complicating nothing, I was replying to your statement that
I do believe FCL.008 set its own 'ground base' to deliberately exclude the possibility of a sensibly enhanced IMC rating, which I know was what (some) senior UK CAA people believed was right. FCL.008 set their own 'rule' from the start for whatever came out of FCL.008 MUST be usable in ALL airspace (inc class A), and in doing so, they were pandering to the 'rich set', (certainly not a 'twit' set!) and ignoring an opportunity to provide real achievable safety stepping stones (plural) up from the bottom for all, so at least hobby pilots could afford to step up someway, and the richer set could progress further.
Since you commented on my "tactics", I'll tell you what I think of yours. You picked up on my "twit" comment for an earlier post but avoided replying to the substance of what I wrote. Instead you wrote another piece on secrecy/secret parameters/FCL008, albiet a different one from the previous one.
Previously, you said "FCL008 set their own rule from the start....pandering to the rich set". I refuted that because I thought it was silly. Now you are saying something different, that "secret parameters" were imposed on FCL008. This is a different claim and I still don't think it's true. But, again, you didn't answer my question. If you think the "airspace class" issue was a secret parameter that hobbled FCL008, then tell us what airspace restriction from the "blank canvas" could have created a Euro IMCr? You claimed earlier there was one ("a safety opportunity for all that looks like it been 'avoided' by deliberate manipulation of initial parameters"), so, as I asked previously, tell us what this was?
If anyone has an idea of how to construct a euroIMCr that 'makes sense' it would be great to know. I think 'makes sense' means
has a privilege limitation proportional to the training/testing reduction proposed
has a set of privileges that can operationally work
has general use in Europe- that is could sensibly be used in many/most countries
does not rely on 'where permited by national law'. This may be a way to retain a UK IMCr, but we already know all other countries have chosen not to follow the UK (and could have) so are not likely to approve this now - so this isn't a sensible proposal for a European rating
Irv Lee wrote:... it's probably time to introduce the subject of money and hope they understand that concept as they don't seem to understand the concept of progressive safety steps for all. Who is pushing for our 'French Farmers' clause? What I mean by that is if there is any euro ruling that disadvantages french farmers, there are huge amounts of compensation available to them. At the moment I can teach IMC. I won't be able to go IMC in future or teach the EIR 'cos I won't have one. So.... "Where's me 'comp' ????"
Ah but then they would want proof of how much you have earned teaching/testing for the IMCr over the past N years and then would check how much tax you paid on that!!!
There are two ways to argue with a woman.
Neither of them work!
SteveC wrote:And which is totally pointless as there will never be a EuroIMCr. There is no place in the IFR system for such a 2 tier system.
And it is posts like that that give the IMCr crowd the view that they are being hung out to dry.
So far no one has articulated a good answer to the question 'what would a Euro IMCr look like', but a number of posters seem to think there is an answer - I am just prompting those (such as Irv) to try and articulate their proposed privilege/training mix which could work pan european and which FCL.008 or .001 could have proposed. (I personally think it is a very difficult challenge - but others seem to think there is an answer if it was just represented correctly)
You may believe the rating is and should be doomed, I believe the IMCr holders should sensibly fight their corner, and many of them are not. (it makes no odds to me - other than I hope they will fight my corner if the time comes). They are wishing for an answer rather than defining what are possible answers and how to get there (as the whole thing is political rather than constitutional or physical - there are no impossible answers just easier and more difficult).
I say again there is no point in having a look at what a euroIMCr might look like as it is not going to happen, not now, not ever!!!!! EASA have made that perfectly clear. Eric Snivel who changes his answer depending on who asks the question is no help. I have spoken to the Head of Licensing many times on this subject and he is adamant that there will never be a euroIMCr because they see it the same as 421C has said many times, there is no way of differentiating between it and an IR and they do not have a case for a two tier system.
What we would be much better doing is working out how to keep what we have as a UK only rating. To this will require the CAA and the DofT to lobby EASA to change the basic rules (law) to allow attachment of a national rating to an EASA licence. That is going to be the sticking point as they don't have the political will to do so. They are going to need to be forced to do so by a concerted political campaign which will involve a lot of MP's questions. Writing to MP's now is a waste of time with a General Election coming as if the current incumbents are ousted then the effort is wasted. Post election is the time to start lobbying.
SteveC wrote: I have spoken to the Head of Licensing many times on this subject and he is adamant that there will never be a euroIMCr
If this is true then I think there is reason to feel stitched - as in Irv's comment 'when you put a rating into a process it cannot pass, pilots have a reason to feel cheated'. I certainly have always believed that there was an honest intent to look at a sub-ICAO IR (i.e. a 2 tier system) and that the EIR (for all its perceived faults) was proposed within an EASA context that was created in good faith.
My reading of 421C, BW, et al's comments has always been that they argue the impracticality/ lack of any sensible proposal for creating a privileges set that would be satisfactory to UK IMCr holders and justifiably have a significantly lower training/testing requirement than the proposed IR - with the EIR being the only semi-logical answer (which I think would be received much better if it was not viewed in the context of people loosing the IMCr).
The supporters of the IMCr often say 'if it had been presented better', 'if it was looked at with a blank canvas', etc. then EASA would evaluate it differently. I am confident EASA fully understand the current UK IMCr and are in the same boat as 421C, BW, you (and me) in thinking 'this isn't going to work across Europe'. I am equally confident that most (all I have read) proposals for a limited IR (i.e. Euro IMCr) actually have no meaningful limitations vs the IR. Hence the motivation of the post, does anyone have a view as to what privilege/training mix would work and be sensible relative to the IR privilege/training mix. I don't expect any idea (if there where some - they would already be floated) but it would help people understand the question was reviewed in good faith (which I still believe, despite your comment) and that there just wasn't anything more sensible than the EIR as a half way house. Once people get through that position, they can move onto your next comment.
SteveC wrote:What we would be much better doing is working out how to keep what we have as a UK only rating. To this will require the CAA and the DofT to lobby EASA to change the basic rules (law) to allow attachment of a national rating to an EASA licence. That is going to be the sticking point as they don't have the political will to do so. They are going to need to be forced to do so by a concerted political campaign which will involve a lot of MP's questions. Writing to MP's now is a waste of time with a General Election coming as if the current incumbents are ousted then the effort is wasted. Post election is the time to start lobbying.
with which I totally agree and have said so many times.
I have spoken to the Head of Licensing many times on this subject and he is adamant that there will never be a euroIMCr
If this is true then I think there is reason to feel stitched - as in Irv's comment 'when you put a rating into a process it cannot pass, pilots have a reason to feel cheated'.
Mike, I disagree. This implies that FCL008 was under an obligation to pass or fail the IMCr. Who ever said the IMCr was being "put into a process" that it could "pass"? No-one. The FCL008 ToR's were clear. "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". There's no obligation to "pass" or "fail" anything, not even an obligation that any intermediate rating need be proposed. Anyone who "feels cheated" should look to whoever set up their false expectations for what FCL008 was about. The EIR and flexible IR are a mitigation for the loss of the IMCr (mitigation = lessen or to try to lessen the seriousness or extent of) and I don't think anyone ever suggested that FCL008 could do more than attempt a mitigation. Of course, there are IMCr holders who think that anything other than a full mitigation is "not acceptable", or that FCL008 will have "failed" without a flexible IR that meets their personal criteria for reasonableness. Fine. There is a big difference between being unhappy, or deeply unhappy, at the outcome of a legitimate process and being "cheated" or the various other accusations, conspiracy theories etc.
FLYER Exhibitions
as that is what the IMCr would allow in much of Europe - so it wouldn't make sense prevent that in the UK.
Login / Register