[SteveC]

Sorry Ncik, your point is completely lost on me. What exactly are you trying to say. All I can see is you quoting out of context.

You do not need to make any point to the FCL.008 group on AOPA's behalf as AOPA is fully represented on the working group. Last I looked YOU were not involved with the FCL.008 group, I certainly have not seen your name on any of the working group documents or the minutes of the meetings.

Perhaps you would care to share your agenda here?

[nickwilcock]

Steve, the IC expressed concern that the 'official AOPA view' was not formally stated anywhere. When FTN published the latest FCL.008 'progress report', this concern reached a stage where clarification was urgently sought, particularly given the so-called 'EIR' proposal.

This clarification has now been achieved; you may expect an official statment shortly but, rest assured, AOPA UK recommends adoption of a new EASA part-FCL Rating with privileges no less than those of the UK IMCR, subject to airspace conditions and language proficiency requirements.

The official line is similar to the quote I gave, which was taken from the 'June 2009 AOPA update' thread on the FLYER AOPA forum.

[Timothy]

Nick,

I believe that the "official AOPA position" is that they support the FCL.008 initiative, but will strive to maintain the IMCR as a national difference.

I am sitting within 6' of both Martin Robinson and Pat Malone as I write this.

[nickwilcock]

In which case, will you please ask Martin to read his e-mails!

[pmh1234]

As many others I'm colorblind. I can therfore not get the night rating and not get the instrument rating.
I can though get an IMC rating.
Please remember to include the option for colorblind people to fly with the two new ir ratings, but limited to day only.

[nickwilcock]

As you will no doubt recall, the so-called EIR which Jim Thorpe has proposed to FCL.008 is allegedly based on the Australian Private IFR Rating. Here is some information about the PIFR rating privileges:

What are the limits of a grade of the PIFR rating?

(a) the holder may only fly a single-pilot aircraft with a maximum take-off weight of 5 700 kg or less;

(b) unless otherwise authorised under subparagraph (c) the holder may:

(i) take off only during day time in VMC; and

(ii) fly below LSALT during departure and arrival only if the aircraft is clear of cloud and flight visibility is at least 5 000 metres;

(c) the holder may fly the aircraft to the extent only that the holder is authorised to do so by a FPA entered in the holder’s personal log book.

Note subparagraph (c). An important part of the Australian Private IFR Rating is the inclusion of Flight Procedure Authorisations (FPA). These extend the privileges beyond the basic minimum and can include instrument departure, instrument arrival and instrument approach procedures.

There is no such similar provision in the EIR advocated by Jim Thorpe. This is the fundamental reason why so many people oppose the EIR - it includes neither instrument arrival / approach procedures nor any proposals to add these to the basic EIR. Whereas the tried and tested UK IMCR does.

However, the EC Transport Department’s Administrator of Air Traffic Management, Jyrki Paajanen, has announced that the European Commission plans to leave the designation of airspace below FL195 to individual nations, using the seven ICAO designations as a foundation but allowing states a degree of flexibility to adopt sub-categories of airspace as they see fit. There is no logical reason, therefore, why the current UK IMCR should not be proposed instead of the wholly unacceptable EIR, with the proviso that it will be for individual nations to state the conditions under which it may be used in their national airspace. The only minor tweaks needed to the current UK IMCR are mandatory approach minima (rather than 'recommended' minima) proportionate to the training, experience and testing of the pilot, plus a small addition to the current single paper multi-choice examination to include international operations.

It is, of course, essential that any pilot flying under IFR should be clearly understood both by associated ATC organisations and any other airspace users. This must therefore dictate a requirement for such pilots to hold at least ICAO Level 4 English competence when flying internationally, or an equivalent national standard when flying entirely within national airspace. Having heard the stumbling RT incompetence of a European PPL/IR pilot attempting to fly an approach at Hurn (I was waiting to meet his passengers) - and the frustration this caused to ATC, it is a requirement that clearly must be included.

FCL.008 must not be under any misapprehension - the EIR is most assuredly not a 'solution' to the 'IMCR situation' in any way, shape or form. To propose such a widely opposed concept to EASA would merely provide EASA with hundreds of hours of nugatory effort in the analysis of the thousands of objections that it would undoubtedly receive. Since EASA is already struggling to meet deadlines for their reply to part-FCL comment responses, presenting a concept guaranteed to attract yet more objections would hardly be reasonable. Particularly since the EIR concept has been subject to virtually no formal industry consultation.

The time has come for FCL.008 to listen to the volume of opposition and to abandon the EIR concept. Eric Sivel has stated that they will have failed in their defined objective if they do not present an acceptable solution to the UK IMCR situation and it is abundantly clear that the EIR concept is very far from providing an acceptable solution.

[bookworm]

There is no such similar provision in the EIR advocated by Jim Thorpe. This is the fundamental reason why so many people oppose the EIR - it includes neither instrument arrival / approach procedures nor any proposals to add these to the basic EIR. Whereas the tried and tested UK IMCR does.

and

FCL.008 must not be under any misapprehension - the EIR is most assuredly not a 'solution' to the 'IMCR situation' in any way, shape or form.

You don't seem to be capable of reading even as far as the first paragraph of what Jim writes and says.

In response to AOPA’s concerns, Jim Thorpe says, “It would have been helpful if the UK branch of AOPA had made any concrete suggestions whatsoever at the start of the process when they were invited in person to do so. Neither did they take up my two recent offers of a full briefing so they would be in possession of the facts. If they had they would then understand that the EIR is not intended to replace the IMC. (my bold)

To keep deriding the proposed EIR on the basis that it is not an appropriate replacement for an IMC rating is about as sensible as deriding the bicycle because it doesn't provide a transportation solution for fish. I would have thought that you might have apologised to Jim by now for the misrepresentation of his views you have plastered over this and other forums, based on your own misunderstanding of his proposal.

[nickwilcock]

Don't take my word for it - take the words of EASA's Eric Sivel:

The EASA Working Group FCL008 has been set up to look at the IMC Rating and if it does not produce an acceptable solution to the problem, it will have failed in its task.

Hence my strong objection to the daft 'EIR' proposal. It has diverted effort from resolving the IMCR situation and has also given the rest of FCL.008 (and others) the misleading impression that the UK has 'given up' on the IMCR. Which we most assuredly haven't.

[bookworm]

Hence my strong objection to the daft 'EIR' proposal. It has diverted effort from resolving the IMCR situation and has also given the rest of FCL.008 (and others) the misleading impression that the UK has 'given up' on the IMCR.

I can see how you'd perceive it as a distraction. However, if the training requirements for the IR itself are modified so as to make it attainable -- which appears to be what FCL.008 has spent the bulk of its time on -- there comes a point at which a limited rating, as an end in itself rather than as a stepping stone to a full IR, becomes pointless. The IR itself becomes the "acceptable solution", just as it is in the USA.

Your enemy in this is not Jim Thorpe, nor any of the rest of us who would like to make the requirements for the IR commensurate with its privileges as a tool for safety. It's that group who would elevate the IR to the status of a gold-plated rite of passage that artificially distinguishes the "airline god" from the "amateur". And against that enemy, I will stand beside you and fight just as vigorously as you.

[GrahamB]

In the theory of it, bookie, I think we would all agree with you.

However I think people are, with some justification, cynical about promises emanating from EASA. If a proposed PPL/IR really were to be as accessible as the FAA IR or the IMC rating are currently, then I don't think there would be any cause for complaint. I'd look forward to the training and the commensurate expansion of my priviliges.

I just don't get a warm and fuzzy feeling that it's going to turn out like that, though.

[johnm]

I'm 20 hours into a European IR having passed all the exams and having held an IMCR for some time.

The only difference between IMCR and IR is a little bit of airways radio protocol a few holds and practice as far as I can see.

The problem stems from the European view that it's part of the commercial ladder and not a stand alone qualification.

[KNT754G]

The only difference between IMCR and IR is a little bit of airways radio protocol a few holds and practice as far as I can see.

Plus of course about £2000 for the ground school/written exams, about £15K for the mandatory 55 hours of flight training then almost another £2000 for the flight test including hire of a twin (if doing MEP IR)

THAT is the major stumbling block to widespread IR take up in EASA land; Ridiculous written exams content and an amount of flight training that takes no account of pilot ability and previous instrument experience.

[bookworm]

However I think people are, with some justification, cynical about promises emanating from EASA. If a proposed PPL/IR really were to be as accessible as the FAA IR or the IMC rating are currently, then I don't think there would be any cause for complaint. I'd look forward to the training and the commensurate expansion of my priviliges.

The way I see it is that we've probably got one chance in our lifetimes to make this right, and get an IR that offers private IFR in Europe the same opportunities as it has in the USA. I can understand the mindset that views that as a risk i.e. that going for the big win of an achievable IR risks losing something like the IMCR that might be easier to keep. However, I think both aspects of that are illusory: supporting efforts for an achievable IR doesn't mean giving up a fallback position, and moreover that 'keep the IMCR as a local rating' fallback position is so fundamentally incompatible with the objectives of EASA that it will be even more difficult to bring about than an achievable IR.

What frustrates me is that it's those who already have IRs that are fighting hard to make the IR more accessible and facing such entrenched opposition from those who may have the most to gain from such a change. And so far, that's the only opposition there is...

[Keef]

I take your point, bookworm.

I have a CAA IMCR, an FAA IR, and no intention of spending any significant amount of tinme or money to add a JAA IR. I doubt I have that many flying hours in front of me anyway. My FAA CFII remarked that I had several times the number of "IMC flying hours" that he did. (Some Skygods who have never flown with me or near me have told me that I'm a cr@p pilot and need to spend some time training with them, which I have no intention of ever doing - for IR or otherwise).

If there's an EASA PPLIR that can be done with a brief academic course and a written or two (like the FAA IR) followed by a few hours training (less than ten hours, say) subject to an IR instructor signing me off as "ready for test", then I'd go for it. That's how the FAA system worked in my case: a few training hours and tasks for the "recency" bit, and into the checkride.

If I have to go through the academic and examination palaver the "Voeten group" have, and then stooge around the sky under the hood for 25 - 55 hours to build up some bureaucratically-mandated "training experience post whatever", then I'll opt out. There are some N-reg aircraft in groups in the South East: they just aren't as nice as the Arrow I fly.

But of course EASA isn't likely to produce such a "tailorable" PPLIR. The EIR doesn't do it, in my view, since the approach part is (to me) the most important. The IMCR works perfectly, but of course to the Eurocrats it "wasn't invented here" so must be banned, unlike the "brevet de base" and the "qualification montaigne".

I shall watch with interest, but not a lot of hope. N-reg seems to me to be the most likely answer - or just hang up the headset.

[KNT754G]

What frustrates me is that it's those who already have IRs that are fighting hard to make the IR more accessible and facing such entrenched opposition from those who may have the most to gain from such a change. And so far, that's the only opposition there is...

Totally contrary to the way I view it.

Many with IRs are fighting to make it HARDER to get one, not wanting the great unwashed ever to be able to achieve their skygod status.
Those with IMCr, generally, would love an achievable IR.