It’s been almost two years since FTN broke the news that the future of the UK’s Instrument Meteorological Conditions rating (IMCr) was to be outlawed from 2012 by proposed rules from Europe’s new aviation regulator, the European Aviation Safety Agency (EASA).

FTN’s bombshell provoked impassioned debate amongst pilots and in particular between those on either side of the argument of the relevance (or otherwise) of EASA to private flying in the UK. Now, a working group set-up by EASA is about to put forward proposals for a new ‘En-route Instrument Rating’ (EIR) which, while not a replacement for the IMC rating, would for the first time make instrument flying privileges available on a Europe-wide basis to  pilots who do not hold a full Instrument Rating.

The UK IMCr is a rating that has provided many thousands of private pilots with extra instrument flying skills over and above what is learnt in the basic PPL syllabus. An IMC rating holder can fly in cloud and poor visibility, track radio-navigation aids and make instrument approaches, albeit to higher minima than those applicable to an Instrument Rated pilot. These privileges can be exercised in most classes of UK controlled airspace (including the Class D airspace that surrounds many UK airports), but does not grant access to Class A airspace, making most Airways off-limits. It’s a decidedly British affair however and apparently the rest of Europe wants none of it. According to those present at the original meeting, when the implementation of a pan-European IMCr was first proposed, the UK was out-voted by 11 to 1 against its introduction. Having never had such a rating themselves, Europe’s other aviation communities were aghast that a rating could exist that allowed PPL holders to ‘mix it’ with commercial operators in controlled airspace in IMC. Evidence in the form of CAA safety statistics, which showed that during the 39 years the IMCr has been in existence there has been no problems with IMCr pilots mixing with commercial traffic, apparently fell on deaf ears, as did the fact that over 25,000 IMCrs have been issued to date and only one controlled flight into terrain (CFIT) accident to an IMCr pilot has occurred.

Meantime, the news that the UK IMCr was on its way out led to an outcry by UK pilots, who wrote letters of protest to their MPs and MEPs, petitioned the Prime Minister for its retention and demanded that the CAA intervene on their behalf. The problem however was that it wasn’t the UK’s regulators, or even EASA, who needed persuading that the IMCr should remain, but rather the rest of Europe, and they remained vehemently opposed to it.

With a pan-European IMCr looking dead in the water for the time being therefore, EASA decided to park the debate for a while and concentrate on less controversial ratings, such as a mountain rating for the Netherlands [and the rest Europe, Ed]. The IMCr debate wasn’t about to disappear though, so in early 2008 EASA formed a working group called FCL008, to review the existing requirements for the Instrument Rating and to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules. The group, made up of a number of representatives from Europe’s national aviation authorities and independent aviation associations, was also tasked with looking at the requirements of the UK IMC rating and other national qualifications for flying in IMC and reviewing the existing national requirements for cloud flying in sailplanes.

In May of this year Jim Thorpe, a member of FCL008 and chairman of PPL/IR, an organisation dedicated to the interests of pilots operating light aircraft under IFR in Europe, outlined for FTN the consensus that the group had reached. According to Mr Thorpe, the proposed Enroute Instrument Rating (EIR) would allow private pilots to fly under Instrument Flight Rules (IFR) en route, in any class of airspace, anywhere in Europe. However, the privileges of the EIR would not extend to making instrument approaches in IMC, so all arrivals would have to be made in accordance with Visual Flight Rules (VFR) – which is only possible in Visual Meteorological Conditions (VMC).

According to EASA spokesman Dr Daniel Holtgen, following a final FCL008 meeting due next month, the proposal is likely to be put forward to the EASA management board. Assuming acceptance of the proposal, EASA will then draft a Regulatory Impact Assessment (RIA) and then develop the final text for inclusion in a Notice of Proposed Amendment (NPA), which the Agency would aim to publish by the middle of 2011.

So it’s a success story for the pro IMCr lobby therefore? Yes and no, would appear to be the answer.

According to Nick Wilcock, member of the AOPA’s instructor committee, the proposed EIR is a “ridiculous Chocolate Teapot Rating”. Writing in AOPA’s General Aviation magazine, Mr Wilcock says he “questions the sanity” of anyone of who advocates an instrument qualification that restricts the holder from making an instrument approach into their destination airfield. The EIR pilot will only be able to exercise the privileges of an EIR if the Terminal Aerodrome Forecast (TAF) for the destination airfield indicates that the arrival could be conducted in visual conditions. The UK IMCr has no such restriction and holders are permitted to make instrument approaches in IMC. Mr Wilcock’s concern is that considering the vagaries of the British weather it would be all too possible to depart on a flight in IMC confident in the knowledge that the TAF for the destination airfield indicated that a visual approach was possible, only to then find that the weather had closed in by the time they got there. “Since when has there been anything ‘almost certain’ about UK weather?” asks Mr Wilcock. Supporters of the EIR point to studies that suggest that the vast majority of IMCr holders have never planned a flight in ‘hard’ IMC, and in particular rarely fly instrument approaches ‘for real’, and hence this might not be such an issue.

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. There was never any possibility of a UK style IMC working in Europe with its very different airspace. Nonetheless, AOPA, in the shape of IAOPA, have their own German representative on FCL 008 and he has been fully supportive of the whole process.

“The natural home of anyone who uses the IMC intensively will be the flexible IR. After all the USA, whose system is so admired, has found no requirement for an IMC like qualification. The EIR was seen more in the context of a stepping stone for pilots in the other 25 European states who previously had nothing other than a commercially orientated IR on offer.”

“It is simply factually inaccurate to state that nowhere in Europe has weather like that in the UK,” continues Mr Thorpe. “If the EIR proposal is such an impossible way of operating, no one has told the thousands of pilots throughout Europe who fly VFR on top and descend without any instrument qualification at all. In the UK in the early days of the IMC rating it was often used in exactly this way. The airspace in which it was valid was defined in an ANO schedule and relatively few airfields with instrument approaches were accessible to the IMCr holder so regaining visual conditions prior to landing was common practice.”

One other significant difference between the existing UK IMCr and proposed EIR is the theoretical knowledge requirement. For pilots undertaking the IMC course the theoretical knowledge requirement is relatively un-intensive, comprising just a single written exam. For the EIR however, it is proposed that the theoretical knowledge requirement will be the same as that required by pilots undertaking the full Instrument Rating (IR). There is a significant twist however. According to Jim Thorpe, much work has been going on in FCL008 towards producing a PPL IR more relevant to the type of flying undertaken by private pilots. Jim has told FTN that the proposed PPL IR theoretical knowledge learning objectives will be half those currently required for the JAA IR, with studying expected to be undertaken primarily by distance learning. FTN also understands that the flying training requirements for the EIR, which will be roughly equivalent to the existing IMCr, will not have to take place at an approved Flight Training Organisation (FTO) but can be undertaken with PPL schools operating as Registered Training Facilities (RFs). It is also expected that some or all of the training required for the EIR will count towards a full Instrument Rating, making the EIR the sort of ‘stepping stone’ rating towards an IR that the IMC used to be. All this conjecture comes with a health warning however, that until the finalised proposals are published, all information about them is unofficial and in part guess-work. Nevertheless, supporters of the EIR point-out that it may well offer a significant business opportunity to UK flying schools who may well be better placed to offer training for it than schools in other European states where there is no previous experience of instrument flying training for private pilots.

And if the EIR is not designed to replace the IMC rating, where does that leave the thousands of UK pilots who hold an IMCr, or are thinking of gaining one? The prospect of their hard-won ratings becoming worthless after 2012 – the expected implementation date of the new EASA pilot licensing rules – is not appealing. Nevertheless, supporters of the IMCr say that as it is a UK-only rating, the UK CAA has it within their power to extend the life of the rating by some way. Even if no new IMC ratings could be issued after 2012, existing IMCr holders could be granted so-called ‘grandfather rights’ that would allow them to continue to use their IMCr for many years after the 2012 deadline. Indeed, FTN understands that just such a proposal has been put to the UK CAA who have, in general, been sympathetic to the cause of the IMCr.

So, the IMCr may live on much longer than seemed the case two years ago. The outcry over the threat to its existence may now lead to a new pan-European ‘mini-IR’. European pilots may at last have access to an attainable PPL IR. Or none of this may come to pass. The debate about instrument flying for PPLs in Europe, which had been mostly quiet for the better part of 18 months, looks to be heating up again.