Two interesting developments:
The German Ministry of Transport has informed the CAAs of the German Bundesländer that the EASA FCL definitions of "flying for remuneration" which would exclude the widespread cost sharing are not to be applied in Germany and the previous model can continue.
According to the IAOPA newsletter, the UK are fighting for keeping the IMCr. So killing the IMCr doesn't seem to be a done deal. Very interesting data point is that the fatal accident rate in the UK is apparently half of that in Germany and one third of that in France. I find that hard to believe, does anybody have data on this?
Interesting.
As to point 1 (remuneration), it appears that Germany now uses the FAA model, i.e. the principle of 'common interest',mitigated however by 'close friends an family'. Guess you could never prove otherwise... Anyway, looks like some sanity prevails in Germany.
Point 2: lies, damn lies and statistics.... (Churchill, I believe). I also find that hard to believe, would be interesting to see the datasets, i.e. what type of a/c and flights (commercial?) are included.
I can see some truth in the claim that the IMCr helps with the safety record. 95% of the German PPL holders (i.e. those without IR) know (because they have been taught) that when they enter a cloud, they are practically dead. However, looking at the accident reports, VFR in IMC does not strike as the major cause of fatal accidents. I think this claim is wrong.
An IMC rating will not only be a huge benefit if you enter clouds but also in marginal VFR conditions.
The loss of positional awareness, or having to allocate most of your capacity to figure it out, would make you a less safe pilot. It would also wear you out rather quickly.
Quite a lot of UK PPL fatals are due to IMC entry. And very very few IMCR holders kill themselves in IMC when flying as per standard IFR. I would suspect that other countries have a much higher death rate in those specific circumstances. I have certainly seen some French stats in the past confirm that.
For those that can read German, here's the letter sent by the German Ministry of Transport to the EU Commission.
This is quite remarkable. First they state that according to the EU directive, cost sharing is no longer permitted. Then they write how that negatively impacts aviation in Germany (aeroclubs) and that there are plans in the EU working groups to adjust this in the future. Finally they conclude that Germany will therefore ignore this provision of the directive and will continue as before.
Showing the EU the middle finger and ignoring a directive is not something I would have expected. It seems like they are certain the EU will adjust the directive (they actually ask for confirmation of that in the letter) and decided that the negative consequences of banning cost sharing until then are more severe than breaking the EU treaty.
Now we need a similar letter by the UK ministry on the IMCr...
Showing the EU the middle finger and ignoring a directive is not something I would have expected.
Me neither, but it's about time. Mind you, I am very EU- and Euro-friendly in general (been indoctrinated as a child by going to a European School :-) ), but what's enough is enough.
And regarding the IMC rating, I have yet to see a comprehensive statistics that proves it's safety gain. On the other hand, the idea of lots and lots of uncontrolled IFR traffic in IMC around me makes me shiver ...
Showing the EU the middle finger and ignoring a directive is not something I would have expected.
I think it's a brilliant move, especially from Germany.
Does EASA FCL really ban cost sharing?
The UK has a cost sharing system for G-reg and I have not heard of that being threatened.
The USA also has a cost sharing system for N-reg but that it illegal to use in UK airspace, because the ANO exemption for PPL cost sharing applies only to G-regs (so I never cost share myself). So even a D-reg (e.g.) cannot cost share while in UK airspace (which is bizzare).
On the other hand, the idea of lots and lots of uncontrolled IFR traffic in IMC around me makes me shiver ...
There are no known civilian midairs in IMC in the UK since WW2.
The reasons for this are probably
So I am very comfortable in IMC 
What feels less good is approaches in Class G, where (in VMC) somebody flies straight through the ILS platform, non-radio. If the platform is higher than 2000ft AAL then they are 100% legal.
The IMCR has served UK pilots well, since 1969. It is quite easy to get. I got it a year after the PPL, as soon as I got the TB20, in 2002, and it served me brilliantly, also on VFR trips into Europe where I could legally fly VMC on top. But I am very certain that a KEY aspect of it is that you can do it at your old PPL school. The proposed CBM IR will remain crippled by the restrictive-practice-loaded FTO system, most of which is not interested in anything but the ATPL "dump €50000 here, Sir" sausage machine. I don't think most Europeans realise that the relatively huge penetration of the FAA IR in the USA is due largely to its easy logistics. The IMCR isn't thorough but virtually all pilots adjust their mission profile according to their ability (those that don't tend to get killed) and this is true for the IR also, whose more rigorous training is completely wasted a few months after the checkride. The IR introduces no theory knowledge of relevance over the IMCR and in flying you are only as good as your currency.
However the IMCR works in the UK only because of UK's extensive Class A, from which IMCR holders are banned (they can do IFR in D,E,F,G). If you introduced an IMCR in say France or Germany, where there is little or no Class A, it would be an IR in all but name and would throw the whole "IR = professional pilot" edifice out of the window, which we can't have, of course......... So EASA's position of "no IMCR unless every EASA country has it as well" was always complete bull and everybody always knew that.
The link earlier in this thread to AOPA says that EASA has decided to withdraw the cost sharing prohibition. So it looks like Germany is simply deciding not to implement it in the knowledge that it is about to be removed anyway.
Colm
