[peterh337]

Yeah, fair points and my own IMC-R usage was like that too, but we will have to see....

However -

what use are class A privileges to a PA28 driver with a Navcomm, ADF and DME if he isn't prepared to lash out another £8k plus on BRNAV kit which talks to his Mode S, when all he wan't to do is cut across a low bit of airway or TMA.

that isn't the way it would work, IMHO.

The PA28 driver with a Navcomm, ADF and DME cannot do a great deal right now, because (taking the description literally) he cannot fly an ILS, and being able to navigate enroute using VORs only his work is going to be well cut out. He really needs a panel mounted GPS and the vast majority of those are IFR units. Also the GPS does not talk to the Mode S transponder which is a standalone item and is mandatory for practically all IFR around Europe. A BRNAV approved GPS installation is required at/above FL095.

I think the vast majority of UK pilots who fly IFR, legally or not, are using a GPS and it is probably a pretty good one.

The other thing is that cutting across a bit of a TMA is not going to work either because the minimum crossings are above FL090. This rating would involve filing a Eurocontrol IFR flight plan, which is VFR to IFR and then back to VFR and which specifies the waypoints at which you expect to change over. Getting an ad hoc clearance into UK Class A is not going to work in the same way and for the same reasons (COMPUTER SAYS NO) that it does not work today.

If the rating included an SRA then everything would change as to the utility in UK airspace.

But yes there is a lot of detail to be worked out if this goes ahead. One is getting the acceptance of European ATC to pilots why will be filing IFR enroute-only; this won't affect the enroute sector controllers who are already working low and slow FL100-FL200 traffic flying in that great big airspace void, but the approach controllers will have to work differently. Another is the lack of BRNAV approvals in the bulk of the GA (but otherwise IFR capable) fleet. The Mode S battle is lost anyway; you have to have it for IFR.

Finally I think UK non-IR instrument pilots will carry on doing what they do at present, anyway, enroute where it is unenforceable. That utility is not going to go away, in practice.

[IMCR]

We fought a long and hard campaign on this issue when it orginally arose.

More than 3,000 pilots signed up on our web site and as some will remember the No 10 petition received a great deal of support.

There were those who assurred us that the matter was better dealt with by them and we were in safe hands - and perhaps we are.

Time will tell.

However be assurred if the outcome is less than satisfactory I fully intend to pursue the case.

I find it extraordinary that matters such as this are dealt with in closed session with members required to sign letters of confidentiality. Closing matters such as this to public scrutiny is as dangerous as MP's closing their expense accounts.

I suspect given the assurances made by EASA and the CAA at the press conference called in London if pilot's feel their rights have been unreasonably curtailed and they feel sufficiently passionate the last has not yet been heard.

As a by stander at present I also feel compelled to comment that our representatives are prepared to committ to changes which either they themselves feel are justified or because they feel it is the lesser of a series of worse alternatives. Who in fact do they represent in reaching that position? I am far from convinced that the opinions of their own membership or the wider GA pilot population has been sought. They indeed place themselves in an invidious but dangerous position.

[peterh337]

It's just the way EASA works, and we are stuck with EASA because the UK signed up to the Common Market (1955) which later became the monster we have now.

EASA appoints committees, made up of industry "experts", and these committees put together proposals. The committee is set up to work quietly and in confidence, to prevent direct lobbying of the persons.

However, the finished committee proposal is just a proposal. The EASA Executive can just chuck it away, or amend it as they wish. This can work both ways; sometimes the committee produces something which is no good and it has to be re-done.

Even though the committee proceedings are supposedly in secret (evidently it leaked out in this case) EASA is an agency of the European Commission and is thus is vulnerable to top-level political pressure, from Brussels and the various governments etc. This is where the big names are lobbying. You won't find Bombardier for example submitting a comment to some EASA proposal on the EASA website. They will go straight to the top, and that kind of lobbying is also done not exactly openly because no politician wants to lose face by being pushed into some position publicly.

This whole thing has still got years to run, and will obviously become much hotter nearer the threatened date (2012). This is a bit like the EASA FCL proposal (the one just finished which strips EU residents of foreign license privileges) - there is simply very little (no??) precedent in aviation anywhere for stripping off pilot privileges without some kind of adequate (and sometimes exceedingly generous) grandfathering. I am therefore optimistic in the long term. At the same time nobody in the know (not me) is going to reveal their hand until the last minute.

[Timothy]

Representation, as such, is being done by you, IMCR. EASA have set up a committee to discuss this, and the various individuals invited to that committee have taken advice from people around them, but no claim is made as to representation.

Many of us feel that the outcome, if it is as currently framed, will be very beneficial to the widest number of GA pilots.

However, there will, I assume, be a period of consultation, and if 3,000 people write in saying that we should leave things as they are then that input will have to be considered. However, the input from other people from all over Europe who would have access to privileges way outside their current grasp would also be looked at.

Democracy, innit?

[IMCR]

Democracy, innit?

As such, democracy as we know it in Europe.

I however support your view - we might just end up with a solution that is acceptable to all. (or the majority at any rate).

[Flyingfemme]

If, of course, there are any pilots or GA aircraft left by the time they actually make up their minds.........

[Keef]

I'm with FF.

I suspect that by the time the EIR appears, I'll have hung up my headset.

It would be nice to be able to fly around Europe in IMC, even if we need a 1000 foot (or whatever) cloudbase for approaches. I suppose that's not markedly different from the "higher recommended minima" that the CAA publishes for the IMCR.

If the outcome is thus, then I'm waiting to hear (when it's decided) what is the minimum descent height in IMC for the Euro-IMCR. IR minima plus 200 - 300 feet wouldn't be bad. 5000 feet would be pretty useless.

[KNT754G]

Whilst I do not relish the prospect of losing my IAP privileges I have to admit that only in a very few cases would this actually have lead to a flight cancellation.

The majority of my IFR flights (on my IMCr and IMCr Instructor/examiners ratings) have departed in Class G VMC and landed also in such. In fact "clear of cloud, with the surface in sight, flight vis 1500 metres" would be an improvement on my current minima, 1,800 metres for take off and landing!
OK CAS minima are higher.

So a restriction that I must be VMC at take off and landing (or even at 1,000 AAL) would not cause HUGE inconvenience.

I suspect, as with all these things, the devil will be in the detail and we have to see what actual take off and landing minima are proposed.

[peterh337]

5000 feet would indeed be useless, but if going to an airport which has radar, you would likely get their MVA (minimum vectoring altitude).

An SRA would be much more useful and amounts to the same thing as vectoring down to the MVA but would take you lower down, and rather importantly flying towards the runway But this is an "instrument approach", not a VFR approach.

The MVA could be very high, in places where there is terrain around (though not very close to) the airport.

If going to an airport which has no radar capability, then I would expect the SSA to be the figure at which you are supposed to get visual.

I have no idea what kind of MVAs the enroute IFR controllers work with. In the UK, the service is invariably terminated when you descend out of CAS. This is not the general case abroad, but I still think the enroute controllers will not get involved with any special services. It would be the approach controllers who would do the letdowns.

Anything other than the above, I don't see how it would fit in with the existing IFR environment. And absolutely nobody, anywhere in Europe, is going to create any new infrastructure to support this new privilege. It will just have to work with the existing systems.

[flybymike]

What do we suppose is the percentage of airfields which currently have an ILS or other instrument approach but which do not have radar?

[Timothy]

It would not take long to count and calculate, but it is many, many more in France and elsewhere in Europe than here. Even here there are quite a lot (Shoreham, Gloucester, Lydd for the first three that pop into my mind, but there are plenty more.)

[Chilli Monster]

Even here there are quite a lot (Shoreham, Gloucester, Lydd for the first three that pop into my mind, but there are plenty more.)

That'll be you off MATS part 3's Christmas card list - he's very proud of his ACR430.

[Brooklands]

Even here there are quite a lot (Shoreham, Gloucester, Lydd for the first three that pop into my mind, but there are plenty more.)

That'll be you off MATS part 3's Christmas card list - he's very proud of his ACR430.

What Timothy forgot to say was its spelt Gloucester, but its pronouced Cranfield

Brooklands

[Timothy]

...um yes, that was it

[nickwilcock]

You will have no doubt noted the following from the 'June 2009 AOPA Update' thread:

IMC rating

EASA’s FCL.008 group is working towards a two-tier IR structure which envisages an ICAO-compliant instrument rating with reduced theory tests, and an ‘en-route’ IMC rating which would allow holders to fly in cloud in the cruise. AOPA has been in the forefront of moves towards a more attainable IR for years, but it opposes any plan that would effectively kill off the UK IMC rating while replacing it with a less safe, less useful qualification at additional cost. The prime purpose of the IMC rating is twofold – first, to ensure a pilot maintains control after inadvertently flying into IMC, and second, to get him safely back onto the ground. An en-route rating which does not teach and allow the practice of instrument approaches is no substitute. Opposition to the IMC rating in Europe has centred on the idea that flight in IMC is illegal outside controlled airspace in some countries; how then is an en-route IMC feasible? IAOPA continues to insist that either the full IMC rating is made available by EASA in those European countries who want it, or the CAA ‘files a difference’ with EASA to retain the rating in the UK only.

This means that AOPA UK's view is that the so-called 'EIR' is unacceptable. I have asked for this to be confirmed, so that the UK representatives on the FCL.008 group will then be made formally aware that AOPA UK does not support

...a brand new, non-ICAO, rating which allows the holder to fly in any airspace in Europe under IFR, but which does not allow approaches...