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What happens to the IMCR after April 2014

I think it's about time for a slightly more controversial topic on here

What do people think will happen to the IMC rating after April 2014? It's already officially called the IR(R) and training continues to be offered, exams taken and ratings issued as before (even if they just have a new name). AOPA say the victory has been won, but it seems to me there are still several threats to its long term existence.

For example, after April 2014, a few things might change. As I understand it,

1) while grandfather rights are protected, it's still not yet officially agreed that new IR(R)'s will be minted after that date.

2) I've also heard it said that instruction may only be given by an instrument rated instructor (IRI) rather than any flight instructor with an IMC themselves. This might mean you have to go to what today is a commercial flight training school (with associated higher costs) than a registered facility, even if they are both called ATOs in the future. Or that IMC instructors will have to go and get themselves a full IR, with the attendant costs - reducing the pool of available IR(R) instructors.

3) I'm also a bit unclear if the same examiners can conduct the test and/or renewals, or whether they need additional ratings (eg a full IR rather than IR(R)).

Can anybody clarify the situation?

FlyerDavidUK, PPL & IR Instructor
EGBJ, United Kingdom

A very good question David and I think its fair to say that nobody knows the answer including the CAA. What AOPA and the CAA push for is not necessarily what they will get from Europe.

The IR Restricted is a unilateral declaration made by the CAA on the basis of a meaningless promise at a European meeting a couple of years ago, it is by no means set in concrete and EASA my well say Non!

Much depends upon the outcome of the NPA when the committees have finally reached a comatose state (they call it comitology which roughly means when they have all fallen asleep). Both AOPA and the CAA have made sound proposals but that means nothing. Of the 3 possible options put forward in the NPA, the most logical one to succeed is the Competence based IR which would of course allow IMC time to be counted towards an IR but realistically on cost grounds there will only be a limited number of takers.

It has never been possible for an FI with an IMC rating to teach for the IMC rating and is never likely to be. The training course to teach for the IMC has always been exactly the same as that required to teach for an IR, the only difference being that under EASA you need 200 hours IFR before you can even take the course this will mean that there will soon be a shortage of FIs who can teach instrument flying.

We can debate as much as we like but realistically we can only guess at an answer. Just remember the S in EASA has nothing to do with Safety! One thing that is almost certain is that over the next 10 years we will see a steady increase in number of weather related accidents.

One thing that is almost certain is that over the next 10 years we will see a steady increase in number of weather related accidents

This line struck me. Why do you think that? I am not sure if I agree / disagree with that. Probably disagree given how much infomation about weather can be gleaned off the internet or if your lucky on your smartphone / tablet while airborne. I am curios though....

It has never been possible for an FI with an IMC rating to teach for the IMC rating

That really suprises me, especially when I recall who taught me

The "CFI" who taught me, and also examined on my PPL skills test, never had more than a PPL, and had been grandfathered all the way, via the BCPL route etc etc.

Why do you think that?

IMHO because IF the IMCR is deleted, people who have it will continue to "use" it, without any revalidations. Also, while formal training will not be possible, informal training will continue and probably become quite a big thing, in the UK Class G setup where VFR v. IFR is almost entirely ambiguous.

I think Tumbleweed has it spot on.

What I find is that the most helpful way of looking at EASA etc is to mostly forget "aviation" and try to look at the politics.

Start with a boxed set of Yes Minister DVDs

And my take on the IMCR is that the CAA definitely wants to protect it (because they know full well people will continue flying in IMC, but won't be able to land by overtly flying an IAP, so they will do "VFR long final" arrivals, with some flying the IAP when there is e.g. IR training traffic up there, in IMC, and the others doing some DIY job) but they don't do what the French do which is stick a finger up to Brussels. The CAA is IMHO keeping its powder dry and playing the game carefully.

The threat of disintegration of the EU has helped massively. EASA has had to change to a partial "listening mode". If the EU had remained strong, EASA would have ridden over everybody, just like they were doing in say 2008 when Eric Sivel stated at a meeting (which I was at) that the IMCR can survive only if every EU country wants it.

Administrator
Shoreham EGKA, United Kingdom

The whole EU/EASA thing is the result of a quick one night stand. Ben

Few things being mixed up here!

FIs with only an IMC have always been able to teach for the IMC. The entry requirements for the IRI course were lowered for FIs who only wanted to teach for the IMC, the IRI course was still the same. Under EASA this waiver isn't there so any new FI wanting to teach for the IR(R) will need the 200hrs IFR to do the IRI course, ie. no will qualify or bother. Us FIs and FEs who have IMC/IR(R) teaching and examining privileges continue to have this and it is grandfathered onto our licence at EASA conversion.

FI/FE(A) always willing to help!
Oxfordshire / Glocs

FIs with only an IMC have always been able to teach for the IMC

Vigidriver, I had thought that was the case, although my own IMC instructors did have hunreds if not thousands of hours of IFR, so would continue to hold those privileges. Potentially it seems there could be a dearth of IMC instructors if the 200 hours IFR experience comes in to play. IMC training is often done in VFR conditions where IFR wouldn't be logged.

The CAA is IMHO keeping its powder dry and playing the game carefully.

Well, it seems to be succeeding so far and I'm sure a lot is going on behind closed doors that we don't know about, and which may not be so effective as public debate. However, I wouldn't want pilots think the battle has been completely won, where there remains uncertainty about these significant points.

Much depends upon the outcome of the NPA when the committees have finally reached a comatose state (they call it comitology which roughly means when they have all fallen asleep)

So is comitology the same as a "sleepover"? i.e. a party where you wake up the next day wondering what you had said and agreed to, and whether you'd been sh*fted

It's all very well for EASA to say the CBM IR option might supercede the IMCr in due course, but given the glacial progress (now over a year since the NPA was issued, and still no CRD published or publication date indicated), the arctic ice-cap will have melted before this is in place!

I just checked on the EASA website for any timetable or progress report on that. Apparently a "frequently asked question" (http://easa.europa.eu/flightstandards/faq.html#instrumentratingtraining) is

Is it correct that EASA is actually working on the training and checking requirements for the instrument rating?

The answer, posted in April 2012, was that the NPA had been published in September 2011 and that in the coming months the Agency will review the comments received and evaluate which elements have to be amended and changed.

Digging further into the RuleMaking Program documentation on the EASA website shows there has been some considerable slippage in the program.

The 2012-2015 Rule Making Program Inventory (http://easa.europa.eu/rulemaking/docs/programme/2012-2015/RMP%202012-2015%20and%20inventory.pdf) page 7, has two entries for the CBM IR program. The first (RMT.198) has an end date of Q2 2012, the second (RMT.199) has slipped by 12 months to Q2 2013. They both have the same description, so I can't quite differentiate between them.

The later 2013-2016 Rule Making Program (http://easa.europa.eu/agency-measures/docs/agency-decisions/2012/2012-013-R/4-Year%20RMP%202013-2016.pdf) is worse. It lists the tasks to be completed in 2013 and planned for 2014-2016. Again the same two entries appear, but the dates are even more vague. RMT198 is due to be completed in 2013, while RMT199 is now 2014.

Such vague planning and continuing deferment suggest this won't happen this year. While that is not unusual for EASA, is there anything that can or should be done to increase the pace and attention given to this task?

FlyerDavidUK, PPL & IR Instructor
EGBJ, United Kingdom

This line struck me. Why do you think that?>

If you reduce the ability of people to be trained in a specific skill the base level of ability in that skill will inevitably deteriorate. People will chance their arm in bad weather and those with the required skill will survive, those without it are less likely to. The accident statistics already tell us that, those with IMC training are safer than those without it!

Regarding teaching for the IMC, pre JAA, in order to upgrade from AFI to FI their was a 7 hour "Upgrade Course" which was the course that later became the 5 hour JAA IRI Course thus, all FIs were trained and qualified to teach for the IMC. This ceased with the introduction of JAR-FCL, the course became optional and many FIs didn't bother to qualify as it was an additional cost that could not be recovered. The experience level for the course was never reduced, it simply wasn't increased to the level required to become a JAA IRI.

The CBM IR will be here when it is here

I have always thought that its political vulnerability is high - mainly because it is (quite rightly) not limited to a PPL.

I say "quite rightly" because if it was limited to a PPL (like the new French IR is, apparently) that would lead to the creation of a "second class IR" which individual countries could then prohibit from certain airspace classes.

The problem with not limiting it to a PPL is that it is set to become the default route for the IR portion of a CPL/IR.

Currently, an FTO gets 55hrs minimum (ME IR) out of every punter, no matter how brilliant he/she is. That is a great deal of money!

With the CBM IR route, the 55hrs will shrink to just 15hrs. There will be 40hrs minimum instrument time (that's an ICAO requirement IIRC) but any previous logged time you have will be usable towards that.

A completely fresh punter will still take around 50hrs (hard to do an IR in much less than that, frankly, unless you remove NDB procedures from both training and the flight test in which case it shrinks substantially) but all those who are entering the FTO CPL/IR machinery at some later stage in their flying life will be spending a good deal less money than they had to previously.

That is why I did my FAA IR to JAA IR conversion when I did it (a huge long tome, I know ).

Actually I did it deliberately to finish before April 2012 in case the 15hr conversion route got terminated on that date (it was a risk) but now we know it is continuing as before, so everybody has, roughly speaking, till April 2014 to finish it if they want to avoid any known risk.

I think anybody who really wants European IFR capability ought to just get on with it now. There is no suggestion that the CBM IR skills test will be any different (again, this is obviously necessary for the above reasons). The 7 written exams can be banged on the question bank in a few weeks' worth of evenings, max. The biggest drawback is the 50hrs (SE IR) of dual training which you are forced to grind through regardless of your previous experience. But if you haven't got that experience, the incremental work of the full current JAA IR, over what I believe will or might emerge under the "CBM IR" label, is not significant if you really want that capability and can use it after you get it (suitable plane and funding etc etc).

It also means that doing the IMC Rating is as worthwhile as it ever was, because IMHO we could be looking at a period of regulatory stagnation in which everything in the "instrument flight" department is postponed and the current status quo continues because IMHO the CAA is not going to let the IMCR to be terminated without a replacement in the bag.

Just my opinion

Administrator
Shoreham EGKA, United Kingdom

Currently, an FTO gets 55hrs minimum (ME IR) out of every punter, no matter how brilliant he/she is. That is a great deal of money!

When this was first introduced nobody wanted it. The initial statistics were interesting, there were more first time passes with the old 40 hour approved course than on the new 55 hours course! Excessive amounts of STD time with not enough flight time was the probable cause.

The Competence based 40 hour IR is a move back to common sense, the old unapproved route worked well for decades. With no sign of the NPA conclusions it shows EASA have little interest in the matter.

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