difference in IR and IMC rating

[pilotho]

hey guys,

about to get my PPL if the uk weather permits!

anyway, after the training i would like to get more ratings, although i dont really get the difference with IR and IMC rating.

if i have an IR rating would that mean i could fly in IMC anyway and wont need to do IMC training? or do i need IMC before i can actually start IR training?

[nouseforaname]

The IMC rating is a relatively straight forward rating that has a minimum of 15hrs flight training and a ground exam, which you would take in similar cirumstances to any of your PPL exams (if you have taken any).

The IMC rating allows you to fly IFR but there are limitations in what airspace you can fly into under IFR. People will probably come out with that in a post no doubt.

The Instrument Rating at present consists of 7 ground exams that must be taken at the CAA office in Gatwick and a minimum of 55hrs flight training in prep. for the IR. Basically it costs a fortune and takes F**ing ages. I'm almost certain you don't have to have an IMC rating prior to trying to get an IR

BUT there is a loophole...you can get an FAA (North American) Instrument Rating which must be done in the US but it's pretty straight forward just one multi choice ground exam and a flight check ride and your away. You can only fly IFR in the UK/Europe if you are in a FAA reg.'d machine.

hope this helps mate.

[IO540]

IMC Rating is UK airspace only. It's easy enough to get though. You also can't go into Class A airspace (which isn't a real issue in the UK, at the level of aircraft type which a PPL is likely to be flying) and you need 1800m visibility for takeoff and landing (which isn't a problem either; it's really only fog that goes below that).

The full JAA (European) Instrument Rating is rather more than 7 exams. The ATPL version is 14 exams; the PPL/IR is (I think) about 10 but some have been combined into a single sitting. The study material is 3-4 feet of paper thickness; I've seen it. It's a truly massive undertaking in terms of a chunk of life dedicated to it and the required feat of memory, which almost nobody does unless they want to fly commercially. There are also additional medical requirements even for just a PPL. Flying is 50hrs min for single and 55hrs min for multi engine IR and that is probably the easiest part! The IMC Rating training does not count towards the flying requirement but there is a committee working on that right now and it appears this (together with a approx 20% ground school reduction) will be one of the changes.

The FAA (American) PPL/IR route is the popular option for private flying with an IR. The FAA IR study material is about 2" thick and can be done in say 6 months if you also have to work and have a life. But to get worldwide privileges you need an FAA registered aircraft, which tends to imply buying one (lots of $$$). Existing ICAO (i.e. done almost anywhere in the world) instrument training counts towards the FAA IR requirements.

Whichever way you look at it, if you want to fly in a way that needs an IR, you will find it hard to rent a plane that's good enough, so your budget needs to be that much bigger. The school may not put it quite like that though :O

If you have the budget to pull this all off, consider doing an FAA PPL only initially. You can fly a G-reg plane on it, worldwide, VFR. You get an FAA medical (plenty of UK based doctors). Then, you can add the FAA IR to it. The UK CAA or the UK flight training scene are not involved at all; in fact due to recent restrictions you will have to go to the USA for the PPL. UK PPL training will count fully towards the FAA PPL training requirements (aren't the Yanks generous; you can't do this the other way round).

[Hour Builder]

The full JAA (European) Instrument Rating is rather more than 7 exams. The ATPL version is 14 exams; the PPL/IR is (I think) about 10 but some have been combined into a single sitting.
Sorry, but thats wrong. (or badly worded)
The IR (A) rating has 7 exams....end of! There may be 10 subjects, but there are 7 passes required to have IR (A) theory.
a) Air Law/Operational Procedures
b) Aircraft General Knowledge
c) Flight Performance & Planning
d) Human Performance & Limitations
e) Meteorology
f) Navigation
g) Communications (IFR)
There is no JAR ATPL version of the IR (A) rating that is any different from a JAR PPL (A) version. If pilots are going commercial after having a PPL, they do all the ATPL exams as these include all the IR (A) exams. However when nouseforaname said their are 7 IR (A) exams, he was correct.
HB

[High Wing Drifter]

The IR (A) rating has 7 exams....end of! There may be 10 subjects, but there are 7 passes required to have IR (A) theory.
I too thought it was 10 exams for some reason...May some of the exams are combined. I thought the layout was:
Air Law and Ops Procs are two exams.
Nav is two exams (Gen and Radio)
Aircraft General Knowledge is two exams (Systems and Instruments)

Live and learn. Would explain why you have to do the lot again for the ATPL.

Madness!

[S-Works]

There are 10 subjects to study but the some of the exams are combined into a single session. these are

Flight Perf & Planning
Air Law & ATC Procedures
Human Perf & limits

The single exam subjects are:

Aircraft Gen knowledge
Navigation
Met
IR Comms

I have one sitting left (hopefully!) in 4 weeks. The subject matter you study is the ATPL material, you are just asked less questions on it at the actual exam. There are also certain sections you can omit (not that places like Atlantic bother to tell you) that are also not in the exams. These are things like Mach meters, AC electrics etc.

[High Wing Drifter]

The relevant part of the JAA Site: http://www.jaa.nl/licensing/jar-fcl.html

[Kolibear]

The most important rating to get after your PPL is your Confidence & Experience rating. Once you have that one, then you can think about getting all the others.

[IO540]

Interesting. I wonder if this has been in a state of flux recently. I could swear blindly I have been told by several JAA ATPL and PPL/IR candidates, over the past 1-2 years, that an ATP sits 14 exams and the PPL sits about 10. There was also a period of time, early in JAA, when no separate PPL syllabus existed.

Anyway, the key point remains: the JAA IR is a huge undertaking. The FAA IR is very significantly easier on the ground school, and probably similar on the flying difficulty (some say it's harder; I certainly found it very hard).

[S-Works]

As I said above Peter I am coming to the end of a year long journey on mine and nothing has changed during that time. The number of subjects is 10 but the number of exams is only 7. The problem of course with more theory being crammed into fewer exam questions is you have a greater likelyhood of getting it wrong due to the vast amount of useless information you have to learn!


But yes the JAR IR is a huge undertaking compared to the FAA. But at the end of the day if you want to fly European aircraft at this time you have no choice. The driver for me was that I have a superbly equipped G reg aircraft that I did not want to put on the N reg. I also fly an IFR equipped twin and my co operators have no desire to go N reg so the onus is on me to become compliant.

At least the FAA training gives great preperation!

[phnuff]

Personally, I started my IMC about 25-30 solo hours after my PPL and found that the main thing that I got out of it was a great deal more accuracy in my flying and as such even though it is UK only, and I still dont tend to fly in IMC much, I considered it very worthwhile.

For me as someone not intending to go pro, IR never really entered my mind

[IO540]

Indeed, the full IR is really for European touring.

Very little point in doing it otherwise - unless one has commercial ambitions.

[pilotho]

hey guys, very good advice

i am thinking of going into commercial training. does that mean i have to gain a PPL IR before i can get CPL training?

what is the difficult part of IR in terms of flying?

[High Wing Drifter]

pilotho,

You can do the IR after the CPL, that means that you get a five hour credit off the IR training req. If you do the IR before the CPL, you get a 10 hours credit towards the CPL. It all gets very complex. The best way to navigate through the veritible myriad of options is to buy this: http://www.ppl-atpl.demon.co.uk/

[funfly]

The basic PPL restricts you to 'in sight of surface' but an IMC allows you to fly in all VMC conditions which in some situations allows flight out of sight of surface (as long as you are 1000' from cloud).
Interesting point is that 'permit' aircraft are allowed to fly under VMC conditions therefore an IMC is of value even if you fly a 'permit' aircraft.

[MikeJ]

FunFly makes a lot of sense. If you are going professional, the IMCR is irrelevent. But for the PPL, apart from the 1800m vis limit on runway, in the UK the IMCR gives all the privileges of an IR in all airspace class D and below.

Even for a permit a/c, an IMCR holder has much greater privileges than those without. eg in the CI zone SVFR, an IMCR has min 3K vis limit compared with 10K for those without. And boy, do you need it! That 'goldfish bowl' in haze over the sea can mean you just have to fly on instruments even when well within VFR vis limits.

But beware, instrument flight NEEDS currency (in US terms). Its no good going 2 years between IMC renewals without regular instrument flight, and expect to be able to cope!

Mike

[IO540]

"If you are going professional, the IMCR is irrelevent"

Not 100% true. You could be going for the bizjet pilot market - legitimate as it is probably a more interesting job than driving airbuses. You do your own flight planning, get a huge variety of destinations, meet some interesting (and wealthy) people.

Many or most bizjets are N-reg, and IMCR training counts towards the FAA instrument time. You would be doing an FAA ATPL.

[tmmorris]

all the privileges of the IR in class D

Not quite true, MikeJ. The 500ft (precision) or 600ft (non-precision) minima are mandatory for an IMCR holder. Not to be confused with the advisory extra 200ft which you are encouraged to add to the published minima - that's advisory, not mandatory.

Tim

[IO540]

They are advisory, not mandatory. Check the ANO. They are not in there.

[tmmorris]

What document are those in, then? I can't now find them anywhere.

Tim

[IO540]

The 500/600ft figures have appeared in various CAA advisory flyers, in the IMC Rating written exam (very naughty as they are not in the ANO and therefore not law) and in the fullness of time they have passed into aviation folklore, alongside not leaning below 3000ft, GPS being prohibited for primary nav, GPS being prohibited full stop, GPS not working due to "terrain shielding" ("Safety" Sense Leaflet #25) etc :O

The CAA issue various bits of paper; for example they tell you to add 1/3 to the POH takeoff roll if it is grass, another 1/3 if the grass is wet, etc. Not wholly unreasonable stuff, for certain types of landing gear anyway, but not law and that is a crucial distinction.

[Justiciar]

The IMC is very useful and providing you keep current with flying IMC makes you safer. I have a session with a friend or instructor periodically when I fly on instruments from just after take off to DA/MDA on instrument approach.

An acquaintance of mine has done the FAA IR. He is used to doing academic courses including oral exams. He described the FAA IR skills test as the most dfficult exam he has ever done. A two hour oral exam was followed by the practical test where he did various things such as airways flying, various approaches etc. without being told in advance anything about what he was going to do.

The FAA IR is perceived, wrongly it seems, to be easier because there is only one exam, a lower total hours flying requirement and you can count instrument flying done previously towards your hours, up to a limit (not sure what it is!). The JAA IR is more tedious because you have 7 exams (£55 each)usually done in two sessions, plus compulsory 2 weeks (done separately) of consolidation at a ground school. The cost of the academic side is probably about £2,000 and then you have the flying! With the FAA IR you can home study and then do the single exam at any flight training organisation.

The flying you do for the IR you do is the same whether you are PPL only or going for a CPL/ATPL, though some PPLs go for the single engine IR, which is 5 hours less. The only medical requirement for the IR above a PPL is a special hearing test.

[tmmorris]

in the IMC Rating written exam

No doubt that's why I thought it was mandatory, then. I did have a look in the AICs and there's nothing there, certainly.

Tim

[giloc]

What document are those in, then? I can't now find them anywhere.
Tim

They're in the UK AIP, AD 1.1.2 – Aerodrome Operating Minima. Also in CAP507.

[GroundBound]

If you have an IMC rating, and fly IFR in IMC, does the aircraft equipment also have to be IFR immune?

I understand it costs a lot to maintain an a/c as IFR immune, if so, how many clubs/owners have truly IFR immune aircraft?

Just a thought :\

GB

[Justiciar]

does the aircraft equipment also have to be IFR immune

I think what you are refering to is "FM immune". This applies to the radio and VOR/Glideslope equipment, but not to the ADF, which is not FM. This is a rather crazy ICAO standard based on the belief that FM equipment can be affected by other signals and so produce misleading readings. The fact that ADF is subject to many more influences does not seem to prevent the almost religeous attachment to NDB approaches over GPS:{

Many aircraft have FM immune equipment and I don't think there is any additional cost of maintaining them over non-FM immune. Not having FM immune means that you cannot do an ILS or VOR approach in IMC (but you can legally do the far less accurate NDB/DME approach).

Of far more importance is the lack of de icing or anti icing on most single engined GA aircraft. This severely limits flight in IMC for substantial parts of the year. So for that matter does not having an auto pilot as prolonged flight in IMC is very taxing without one.

Unless you plan prolongued tours or business trips in Europe IFR and have the right sort of aircraft then an IR is an expensive luxury. As has already been said, you can fly IFR in all UK airspace except class A with an IMC. Personally, I would not plan a flight which involved any significant IMC on the back of an IMC rating - flying IFR does not of course mean that you are in IMC.

[tmmorris]

Giloc - thanks, I knew it was mandatory... assuming the AIP carries the force of law... Does it?

Tim

[giloc]

Giloc - thanks, I knew it was mandatory... assuming the AIP carries the force of law... Does it?
Tim
Well, it can do where it 'notifies' something referred to in an article of the ANO. However, that is not the case here. In any event, what the AIP says wrt to AOM is this:

"Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach."

I find it hard to interpret that as anything other than a recommendation!

[IO540]

Re FM immunity, this is worth checking but my understanding is this:

It is mandatory for IFR in controlled airspace. This means Class A-E.

Most planes available for self fly hire are not FM immune, which is why PPL-level instrument training usually takes place under VFR and keeping out of CAS, and if they go into CAS, in IMC.... well.... it's a case of ask no questions tell no lies :O

So I think that flying the typical old wreck, you could fly an ILS into Biggin (VFR or IFR) but not into Bournemouth. Into the latter, you would have to do it as a practice approach under VFR conditions.

This is a big reason why the GNS430 is popular: you get an FM immune radio, VOR and LOC. People certainly aren't buying it for it's superb large legible moving map display :O To replace a couple of conventional radio/nav receivers with FM immune ones is a few k, which is why nobody does it unless they have to.

Unfortunately, once you start looking up the mandatory equipment requirements for IFR in CAS, you find you need an ADF too... and a DME.

On the IMCR minima, I agree with giloc; it's a recommendation. It says so.

[High Wing Drifter]

Regarding FM Immunity, it looks as if the previous wording has been revoked and this wording issued: http://www.caa.co.uk/docs/224/srg_gad_FM%20immune%20GE4.pdf

My reading is that wording for a/c < 5700kg, non FM comms are not an issue, but non-FM ILS/VOR are restricted to VFR only regardless of airspace. Non-public transport flights may have only a single non-FM immune ILS/VOR in CAS. Therefore, as there are no requirements to carry radio nav aids in Class G, the CAA would prefer you to DR in IMC! However, the implication is that you can use your non-FM immune VOR in uncontrolled airspace because the authority can never doubt otherwise.

AIC Pink 87 is very badly worded. It suggests that even non FM Comms in any aircraft must be placarded and limited to VFR only and it refers to a long time defunt AN 84.

[bookworm]

Thanks for the reference HWD.

One could argue that explanatory note 4 is just that, but it does make it harder to argue that flying an ILS does not require an ILS receiver, even though Schedule 5 does not mention it explicitly!

The placards required by AWN 84 limit non-immune equipment in light aircraft to "LA Class 3", which permits their use "for the facilitation of any flight outside controlled aispace under IFR or VFR". That would seem to meet the requirements of paragraph 2 of the directive.

[IO540]

We are getting a long way from the original subject, though I suppose the essential difference between the IMCR and the IR is the ability to fly IFR abroad....

This leads to equipment requirements abroad. These are in each country's AIP, in the GEN 1.5 section.

A UK CAA concession might be worthless in practice.

[DFC]

The 500ft precision and 600ft non-precision absolute minima apply to IMC rating holders and are mandatory and the ANO says so.

Article 49 clearly says that pilots of non-public transport aircraft are not to descend below the notified minima unless the required visual references are established and maintained.

Notified means: Information set forth in a document published by or with the authority of the CAA and entitled Supplement (NOTAM)
or AIP and for the time being in force. (my emphasis).

AD 1-1-6 of the AIP is very clear saying that "This section of the AIP specifies the notified method of calculating Aerodrome Operating Minima (AOM) for the purpose of
Article 39 (Public Transport Aircraft not registered in the United Kingdom) and Article 40 (Non-public Transport Aircraft)."

(The article numbers were changed in the last ANO amendment.)

The AIP goes on to say;

3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC
Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State
in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.

To put that in simple terms;

The ANO says that pilots must comply with Notified minima. Notified means published in the AIP or NOTAM etc and the AIP says that the 200ft addition is advisory but that the absolute minima of 500ft precision and 600ft non-precision are mandatory.

That is the legal basis and that is why they are mandatory and why they are in the exam still.

Thus ILS with 200ft DH will mean 500ft DH legal minimum for an IMC holder.

---------

As for FM immune requirements.

There is a very simple way to think of the FM issue pertaining to ILS and VOR equipment. If it is not FM immune it is U/S.

If you would not rely on a U/S instrument or navigation system to navigate in IMC or make an instrument approach in IMC then you would not use a non-FM immune system.

DME and ADF are not limited by the requirements. Thus I would not see a probem with flying to a destination in class G airspace where the approach would be an NDB or NDB/DME and if required by law, the alternate also had an NDB or NDB/DME procedure available. eg Blackpool.

However, regardless of airspace, flying an ILS or VOR procedure with U/S equipment would be illegal.

There is no law that says one can not fly an aircraft in VMC using visual navigation while looking at the indications on an unserviceable ILS or VOR indicator. That is the legal basis of IMC training in VFR - the instructor is visual and navigating visually and can ensure the safety of the aircraft.

People are silly to pay for training with U/S equipment even if it is for the IMC rating. Many operators have used FM immune as an excuse to push up prices but never fitted the equipment.

Regards,

DFC

[FlyingForFun]

DFC,

Your interpretation of the relevant part of the AIP seems to be one of two possible interpretations. Your quote, but with the emphasis in a different place:3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approachWith the emphasis this way round, the word "recommended" could be interpreted to apply to the whole of the paragraph.

The word "absolute" does not have to mean mandatory; my dictionary gives a number of definitions of the word, including "not relative" and "independent". So I think there is a valid argument for the "absolute" to mean that the addition of 200' to the minima is the first part of the recommendation, but then there is an independant minimum, which is not relative to the first part, of 500' or 600' as appropriate; both of these are included in the paragraph which, as a whole, is merely "recommended".

That's certainly the way I read the paragraph when I first came across it, and it's the way several other people I know interpret it too, but I can also see how it might be interpreted the way you describe. (My dictionary also gives alternative definitions of "absolute" as meaning "unrestricted" or "complete" which would fit in with your interpretation.)

FFF
--------------

[windy1]

Good last point. If it was law, wouldn't it be written in legalese - long sentences with no commas to avoid precisely that kind of confusion?
But if its in the ANO, you ignore it and you have an incident then it will be that much harder to avoid problems with your insurers and charges of negligence. Isn't the highway code similar? Not "law" but if you don't comply, you open yourself up to more problems than otherwise.

[DFC]

Flying For Fun,

Nice try and I am sure that many IMC holders would like it to mean that. :D

The interpretation of the statement in the AIP does not revolve around how you read the paragraph with regard to the words recomended or absolute. The important word I am told is in fact but.

Check your dictionary for a definition of the word but.........conjunction - however, on the other hand.

Thus in simple terms the IMC rating holder is recomended to add 200ft to all minima however (on the other hand) the absolute minima is 500 precision and 600ft non-precision.

For your interpretation of the paragraph to work, the word but would have to be removed and replanced with and

Here is your interpreataion;
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, and with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.

However, the actual words are;
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.

I do agree that the paragraph can be confusing but the training material, teaching of the rating, the exam and the CAA all follow the common line that 500 precision or 600 nonprecision are absolute minima.

Personally, I find that this is not simply a wording problem- an ILS wih no obstacles and IR hoder's DH of 200ft will see the IMCR pilot use a DH of 500ft minimum. An extra safety margin of 300ft.
Now add in some serious obstacles and terrain and make the IR holders DH 600ft. The IMCR holder can now use 800ft DH. A much reduced safety margin despite the fact that the environment is less forgiving!

It would be far simpler for pilots to understand, for pilots to calculate and also far safer if the IMCR holder was simply required to add 300ft to the IR rating holders minima regardless of approach.

Regards,

DFC

[bookworm]

AD 1-1-6 of the AIP is very clear saying that "This section of the AIP specifies the notified method of calculating Aerodrome Operating Minima (AOM) for the purpose of
Article 39 (Public Transport Aircraft not registered in the United Kingdom) and Article 40 (Non-public Transport Aircraft)."
(The article numbers were changed in the last ANO amendment.)
The AIP goes on to say;
3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC
Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State
in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.
...
That is the legal basis and that is why they are mandatory and why they are in the exam still.

How would you explain then, that the wording "absolute" in the AIP (formerly Air Pilot) 3.3.2 is unchanged from well before the introduction of Art 40 (or its corresponding number on introduction, 32A)? Why would the word "absolute" mean "mandatory" as differentiated from "recommended", when before 1990 there was no legal basis for mandating aerodrome operating minima for non-PT flights, and all minima in the AIP were recommended for non-PT flights?

[DFC]

To recomend an absolute minima or to require an absolute minima does not change the use of the word absolute.

The simplest way to look at it is;

If a person is doing the flight test for the issue of an IMC rating uses a minima of say DH 300ft on an ILS where the IR minima is 200ft they will fail for flying below the absolute minima of DH 500ft. This would be very unusual because the minima are discussed in the briefing and the flight will not depart until the candidate uses appropriate minima from the AIP. That means absolute minima of 500ft precision and 600ft non-precision.

So if it is a requirement to be complied with in order to pass a test then it is a requirement to be followed after the rating is issued.

Should the candidate make it known that they are going to use the AIP minima for the test and then use lower minima after passing, there would be a question regarding their being fit to hold a licence.

Regards,

DFC

[IO540]

Failing a checkride on that merely means that the examiner has formed the same opinion as lots of others; fair enough. It's only a once per lifetime checkride anyway.

[rustle]

Failing a checkride on that merely means that the examiner has formed the same opinion as lots of others; fair enough. It's only a once per lifetime checkride anyway.

??

IMC renewal every 25 months isn't it?

[DFC]

IO540,

As rustle says there is the initial test and then the renewal every 25months or less.

Examiners can not base a clear cut fail / pass with regard to minima on personal opinion. The reason being that the candidate who failed for using a DH of 300ft when it should have been 500ft (IR holders DH 200ft) could appeal to the CAA. Thankfully such an appeal is a waste of time because the CAA will simply say that the absolute minima which must be used is 500ft DH.

So with the CAA saying that the absolute minima is 500ft DH and 600ft MDH, the Examiners using that as a standard, the instructors teaching that as the way it is to be done do you honestly think that they are all wrong?

The IMC rating will not be round in the long term. Changes in airspace and European licensing will ause the end of the IMC rating or make is unuseable. What we are waiting to see is if a second class IR for those that can't get the IR will have requirements that are simpler to apply such as IR minima plus 300ft and RVR/VIS+1000m. That kind of limitation would be easy to understand, easy to apply and easy to understand.

Regards,

DFC

[Fuji Abound]

Not this old chestnut again!

My examiner has asked the CAA whether the minima are advisory or mandatory - the answer was they advisory. We ignored the advisory limits at my last renewal, and I was very happy to do so.

The CAA will tell you they recommend the IMCR as a "get you home rating". I would agree in terms of the standard set by the initial test and the underlying training. However the rating on grant entitles you to fly hard IFR with sector to sector IMC to minima. Thats tough with the basic IMCR training.

DFC - I have no idea what the test standard has to do with what the ANO or the CAA have to say about this issue. You pass your driving test with having never driven on a motorway, but you can do so the day after you pass.

DFC - "The important word I am told is in fact but."

By whom are you told this????


DFC - "The IMC rating will not be round in the long term. Changes in airspace and European licensing"

- who says, or is this just speculation on your part?



Fortunately if it is withdrawn at least existing holders will get grandfather rights to son of IMCR or will they just be given a full PPLIR - I for one will be seeing my MP if not!

[3FallinFlyer]

If I already hold an IMC rating (as I do) but decide to take an FAA IR to fly my N-reg in airways and in Europe, can anyone see any point in keeping the IMCR valid? As I see it, I can fly with greater than IMCR privilages in the UK in a G-reg aircraft if I have an FAA IR. It just seems wrong to let something that I put so much time, effort and money into getting (and keeping current) lapse.

[IO540]

A good question.

The main scenario I can imagine where one might wish to keep a valid IMCR (and, by implication, a valid UK/JAA PPL and a valid CAA medical) is where one feels one can't keep up with the FAA currency requirements of 6 approaches in the past 6 months. Then, if your FAA IFR currency lapses, you can continue IFR in the UK on the IMCR privileges.

However, an aircraft owner should be able to easily maintain the 6/6 currency, but someone who is renting, and/or short of money, perhaps cannot. And very few non-owners will be flying under an FAA IR.

A rather more theoretical scenario is where you really believe that the UK Govt will succeed in their proposed prohibition on long term parking of N-reg planes in the UK. Then you would need to revert to the IMCR to have any IFR privileges at all. Or if EASA manages to do the same; however they have lately been indicating they would prefer the carrot route rather than the DfT's stick route.

I was planning to let the 150-quid UK medical lapse. I will keep paying for the JAA PPL every 5 years. It's easy enough to arrange a ride every 24 months which, in one flight, gives you the FAA BFR, the UK PPL renewal, the IMCR renewal all on one flight of an hour or so. Then, AIUI, if I ever need the UK stuff again, I will just pay up for the CAA medical.

"I can fly with greater than IMCR privilages in the UK in a G-reg aircraft if I have an FAA IR"

Sadly not. An FAA IR in a G-reg gives you IFR privileges in the UK but only in Class G, whereas the IMCR gives you IFR in D-G.

An FAA IR holder can purchase the IMCR from the CAA for just the cheque payment, but he also needs a valid UK or JAA PPL to attach that to...

[rustle]

If I already hold an IMC rating (as I do) but decide to take an FAA IR to fly my N-reg in airways and in Europe, can anyone see any point in keeping the IMCR valid? As I see it, I can fly with greater than IMCR privilages in the UK in a G-reg aircraft if I have an FAA IR. It just seems wrong to let something that I put so much time, effort and money into getting (and keeping current) lapse.
AIUI you don't have any greater privileges than a vanilla PPL from your FAA IR on its own in a G-reg.

You would qualify for an IMC rating on the basis of your IR, but you'd still have to renew it every 25 months or revalidate your FAA IR through flight test (not just 6 approaches in 6 months) and re-apply for an IMC.

[slim_slag]

If I already hold an IMC rating (as I do) but decide to take an FAA IR to fly my N-reg in airways and in Europe, can anyone see any point in keeping the IMCR valid?If you want to perform instrument letdowns into airfields without a published approach you should keep your IMCR valid. You cannot do that with your FAA IR, 91.175 forbids it. Even then, if you are flying an N-reg part 91 applies, so you might not even be allowed to do it even with an IMCR.

[3FallinFlyer]

Thanks for some very good points, I think I'll keep the IMCR current for the time being. I am interested in the concept of being able to take an IMC checkride and BFR in one flight that would also qualify for the 2-yearly 1 hour with an instructor for the JAR PPL requirement. Pressumably, this would need to be done with someone who is both a CAA examiner (for IMC renewal) and an FAA instructor qualified to sign off the BFR in an N-reg aircraft.

[Fuji Abound]

3FF - correct and there are a few of these around - a very good guy at Oxford for example who will do your IMCR, FAA BFR and CoA (or whatever it is called these days) in the same check ride.

Mind you I gather some are getting a bit picky now the CAA thinks it should give some guidance on the material that should be included in the CoA :} .

[IO540]

"91.175 forbids it"

I did point this out to the FAA instructors and examiners in the USA recently, and their view is that this applies only in airspace where you need ATC clearance for flying the procedure.

In the USA, one has Class E down to a very low level (700ft or 1200ft; I can't remember the rules) which means that most or all of the IAP will require ATC clearance (because E is CAS for IFR).

But if you did the descent wholly in Class G, the view was that you are free to do what you like.

In any event, one can legally fly at the MOCA, which (in non-mountainous terrain; another expression which means one thing here and another over there) is 1000ft above the highest elevation within 4nm. This amounts to a DIY IAP with a 1000ft MDH, doesn't it?

"Pressumably, this would need to be done with someone who is both a CAA examiner (for IMC renewal) and an FAA instructor qualified to sign off the BFR in an N-reg aircraft."

One can do it all in a G-reg, but for JAA stuff needs a JAA instructor rating, the FAA BFR needs a FAA CFI rating, the FAA IPC needs an FAA CFII rating, doing any paid work in any aircraft reg in UK airspace needs the JAA instructor rating, and doing any paid work in an N-reg needs the DfT permission :O

There are dual JAA+FAA instructors around, but expensive, and you still need the DfT permission of doing it in an N-reg (unless he does it for nothing).

I hope I got that right.....

[slim_slag]

This amounts to a DIY IAP with a 1000ft MDH, doesn't it?It would depend on the altitude of the obstacles surrounding the destination airport and the direction you were coming from, but almost inconceivable that it could be as low as that. look at 91.179. The more I think about it, using a FAA IR and N reg at a field with no published IAP is more restrictive than using an IMC in a G reg at that same field. Getting back in, you can do it legally with a lower cloudbase in a G reg/IMC.

[IO540]

Clearly 91.179 (b) is what applies to Class G and I don't see the problem, assuming the word "turning" is the same as "manoeuvering" which is what one does when landing.

I agree that on a strict reading one probably gets better privileges for a DIY IAP with an IMCR (in a G or N) than with an IR in an N-reg.

The IMCR should be valid in an N-reg (I have checked with both the CAA and the FAA) and additionally the FAA permits the exercise of foreign license privileges (FAR 61.3). So the full privileges of an IMCR should work in an N-reg. But we've been around this one before :O

The practical question is how low would you go on a DIY IAP anyway? 1000ft is a reasonable MDH. I know lots of people go lower, especially using the unpublished IAPs which exist at various UK airfields; sometimes these were real IAPs at one stage and were "lost" when ATC left, others are approved only for use by based commercial ops. Most have been CAA-surveyed.

[bookworm]

To recomend an absolute minima or to require an absolute minima does not change the use of the word absolute.

On that much, I think we can agree. ;)

[S-Works]

we all know that DFc has an ABSOLUTE viw that he is always correct, when most of the time his interpretation is just that his interpretation......

However for a man who does not fly (he cant possibley fly with the time he spends making up rules and speculating) he does pretty well at interpretation....

:cool: :)

[High Wing Drifter]

I think DFC is right. The lowest DA for an IMC pilot is 500' + PEC and the lowest MDA is 600. I admit to having to rummage through my notes and the Thom book for confirmation. I was taught to add 200' to the OCH and use the greater of 500'/600' and the OCH+200 and then add the PEC for a precision approach. If I recall my conversations with the CFI correctly, the adding 200' bit is recommended. the 500'/600' is a must.

[S-Works]

DFC is wrong, I and a number of others have it in WRITING from the CAA that they are ADVISORY limits and not legal limits. The only LEGAL limit is the 1800m horizontal vis.

There is a lot of myth generated on these and other forums. Dont you know it is a great British tradition to make up new and ever more restrictive laws and live by them? The French have many flaws but at least the know when to ignore stupidity.

Someone pass me the salt please.....

[IO540]

"Trevor Thom book for confirmation"

The last thing I would use a TT book for is confirmation of some relatively obscure point of aviation regs.

"If I recall my conversations with the CFI correctly"

Likewise. Most instructors don't understand any of this stuff, no need to.

Much of the ANO is badly drafted anyway, and the CAA has issued countless flyers which are equally ambiguous and which don't make it clear that something is advisory. I don't know why they do that. I suppose they have a number of people in there who like writing all these flyers and who can't be bothered to pass everything by their legal department. I know they can do it right, because some of their stuff is very well written, and has obviously been gone over.

The aviation mags will (usually) publish any old nonsense without checking (unsuprising; are they going to pay an aviation lawyer for an opinion on each point?) so this stuff makes its way into airport bars. The copious number of online pilot forums just keeps propagating the stuff...

[rustle]

DFC is wrong, I and a number of others have it in WRITING from the CAA that they are ADVISORY limits and not legal limits.

Would you mind posting that?

If it's a paper letter can you scan it and post the image (I'm happy to host the picture if needs be)

If it's an email can you paste it (including the date and name of the signatory).

It isn't that I don't believe you (it makes no odds to me if them's the rules) but it should settle the argument once and for all. ;)

[S-Works]

what and take the fun out of the argument.......:p

[High Wing Drifter]

I too would like to see the written record that contradicts the AIP! WRT to the perennial CFI and instructor bashing, it is far more likely that I misunderstood or have confused my memory of the instruction :\

[slim_slag]

IO540, I know there is a lot of nonsense written on here, and I am sure I am responsible for some of it, but it simply beggars belief that in order to justify the breach of clearly written regulations you can assume the word "turning" is the same as "manoeuvering" which is what one does when landing'. Why can it be that most instructors don't understand any of this stuff, no need to when they don't give you the answer you want, yet you will say I did point this out to the FAA instructors and examiners in the USA recently, and their view is that this applies only in airspace where you need ATC clearance for flying the procedure. when an instructor does give you the answer you want?

How do you expect an FAA instructor to understand the way airspace is used in the UK, I can only assume your questions were leading and you stopped once they agreed with you. Your knowledge of the FARs is fundamentally lacking.

[Justiciar]

Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.

Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to a recomended minimum of 500 for a precision approach etc.

The AIP does not itself lay down a mandatory minimum restriction on descent below a certain altitude - this is defined in the legislation which is the ANO, which prohibiting descent below the published minima. The AIP is where those published minima are to be found. Had there been a separate (different) restriction on IMC holders then the place to find it would be the ANO, not the AIP.

Taking the point a stage further, the penalty for a breaching the requirement in the ANO is a fine. The only offence created is breaching Article 49, which refers only to descent below the published minima for the particular airfield and approach. There are no separate published minima which apply to IMC holders and therefore no sanction for any breach of the DA + 200' etc.

[IO540]

SS

We were discussing two separate issues:

1) Does 91.175 prohibit descent below the MSA other than on a published IAP, in any airspace including uncontrolled

2) Are the IMCR minima mandatory or advisory

I posted the view from an FAA examiner relating to 1) above. I think that he (and this one was a particularly senior one) would know more about it than I would know just reading the FAR/AIM. I agree with you that 91.175 sounds like there is a blanket ban, but I reported an informed view in the USA that in Class G you can do what you like (out there). The other point is that you can fly IFR/IMC down to the MSA (in Class G, without ATC clearance, both in the USA and in the UK) and if you are visual then you can make a visual approach; do you disagree with that?

As for 2) well this one will run and run. I am with Justiciar; having been in business for best part of 30 years I have seen more legalese than I've had Kentucky Fried Chickens and that para was written by an amateur who doesn't even have a decent grip on English grammar. It was not written by a lawyer. That doesn't mean it isn't law, in which case why is it not in the ANO? Everything else IMCR-specific (the 1800m, the no Clall A bit) is in the ANO. Justiciar provides the answer to this.

In general, UK instructors are a very poor place indeed to ask regarding any legal details. I could write for far longer than I have time for, listing the complete and utter bo110cks I have had from them. One instructor told me I could train for the initial IMCR in a particular plane which was on a Private CofA, so long as I owned more than 1/4 of it. Much later I discovered he was involved with the other owners, doing training for them charged as "ground school". Very very hard indeed to know who one can trust in this business. Most instructors live in their own little world, training Joe Public day after day, in between thumbing through airline job adverts. This stuff is way above most of them.

The CAA doesn't make this any easier, with all the advisory stuff they put out which is made to look like it is mandatory. I think a lot of it is written in a kneejerk reaction to some event somewhere...

Finally, to be practical about this, it is unenforceable because nobody can tell when you, the pilot, actually got visual. Unless you have a CAA official sitting in the aircraft. So this isn't a real issue, unless you want to create more traffic on the server. The important thing is to do it safely.

[Fuji Abound]

IO540 and SS

I feel you come from different view points. SS maybe that of an instructor and IO540 the instructed.

There are some excellent instructors - I have come across a few who have a very good understanding of aviation law, never mind the experience to instructor at a very high standard. Sad to say that is not my general experience nor the experience I find of most other pilots.

As with any exam based instructor qualification of course they have achieved a minimium standard but equally that does not mean they have the same in depth knowledge of many of the contributors on this forum.

The debate about the IMCR minima is a case in point where even we cannot agree on the correct interpretation (although I am in no doubt they are recommended minima).

The fact of the matter is that there is a whole bunch of instructors who are far less experienced than many on this forum - IO540 is quite correct.

:)

[slim_slag]

Fuji,
There are a lot of instructors on both side of the Atlantic who are just bumps on logs building time. But I was not crticising instructors. What I was criticising was the attitude that

a) I am right, and I found an instructor that agrees with me, so I am right
b) I am right, and I found an instuctor that disagrees with me, so the instructor is wrong.

IO54O,
The only interpretation of the FAR's that matter comes out of the FAA General Counsel's office, or the judge who is going to hear your case for violating a FAR (probably 91.13). What I attempt to do is provide interpretations citing from and quoting the FARs, I don't cite unnamed instructors/examiners or emails from unknown FAA staff. I also try not to redefine words like 'turning' to mean 'cleared to land'. I encourage people to read the FARs themselves, as in general they are very clear, for legal stuff anyway. You should know anyway this if you have an FAA IR.

SS
We were discussing two separate issues:
1) Does 91.175 prohibit descent below the MSA other than on a published IAP, in any airspace including uncontrolled.
.......
I agree with you that 91.175 sounds like there is a blanket ban, but I reported an informed view in the USA that in Class G you can do what you like (out there).

It doesn't sound like a blanket ban because there are exceptions. The exceptions do not include class G airspace. 3FallinFlyer asked a question, I warned him that if he wants to move over to an FAA IR then he should be aware that he cannot descend below the MEA in IMC in class g unless there is a published IAP and it appears he found my answer (citing the FAR, not some unknown individual) useful. If you want to stop these threads from repeating ad nauseam then don't jump in and post nonsense and I will not be forced to point out to people like 3FallingFlyer that you are wrong.

OK? :ok: :)

You cannot do what you like in class G airspace. This is a major and fundamental misunderstanding of the FARs. If in weather below VFR minimums, you can fly IFR if rated but you do not need to file a flight plan, and you do not need an ATC clearance (FAR 91.173), that's about it. Minimum altitude rules certainly apply (91.177). You need an IR. Your plane needs to be equipped (91.205). Hardly you can do what you want.

The other point is that you can fly IFR/IMC down to the MSA (in Class G, without ATC clearance, both in the USA and in the UK) and if you are visual then you can make a visual approach; do you disagree with that?

I agree with that. I disagree with your claim that this is 1000 AGL, it will be higher than that. If you are using an FAA IR you can descend to the relevant MEA in cloud, but not below. Below the MEA, unless on a published IAP, you mustfly VFR, minimums are prescribed in 91.155.

I agree that you will probably get away with it but that was not the point of my answering 3fallingflyer's initial question. If you just said "I'm busting the rules and don't care", then that is fine but you didn't. You tried to justify your breaking the rules by misinterpreting them.

If you really understood the FARs and wanted a discussion relevant to 3fallingflyers actual question you should cite 91.703 (a) (3) and not some unnamed instructor/examiner. Even then, you would still be wrong :)

[DFC]

To the person who asked who I got to explain the meaning of the excerpt from the AIP and who said that the word "but" was important - the answer is a person with an english language degree and absolutely no flying experience and hence no pre-conceptions.

Feel free to forward the paragraph to the plain english society and ask them.

--------

Justicar,

You said;

Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to a recomended minimum of 500 for a precision approach etc.

Should that not have said;

Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to an absolute minimum of 500 for a precision approach etc.


The fact that you had to change the wording in order to make the paragraph read like it is all a recomendation only goes to support the point of view that the 500ft DH and 600ft MDH are absolute minima and since they are minima and notified in the AIP, they are covered by Article 49.

but is not a qualifier, it is a conjunction! ;)

------

What everyone seems to miss in the argument is that it is often the case that an MDH of 600ft is less than 200ft above the IR MDH. The minima for the IR pilot permit an approach in IMC to be continued to MDH. The IMC holder can use 600ft as long as it is not less than the IR minima.

--------

Whatever anyone agrues what has to be agreed is that;

1. The IMC rating holder is not trained according to the sylabus to fly a precision approach below 500ft. DH or a non-precision approach below 600ft MDH.

2. The majority of holders of the IMC rating are in the situation where the AIP recomends that they do not attempt to make an approach and of the remainder a high proportion of those would have to make additions to the IMC minima to allow for not being totally current with the type of approach procedure.

That makes the idea of an IMC rating holder who flies the average number of PPL hours per year doing an ILS in IMC down to 200ft and expecting to be in a position to safely land as remote.

If one wants to operate as if one holds an IR regardless of airspace then there is only one answer - get an IR.

--------
There is no such thing as a home made Instrument Approach! There are quite a few cloud break procedures and those of us that use them have CAA permission to do so. Anyone else is illegal for a number of reasons but the most important one from my point of view is that you could hit us!

The only people who should be in IMC below MSA are;

1. Pilots on special VFR flights (in a zone of course!)
2. Pilots making an approved public or private descent.

Everyone else is endangering their aircraft.

IO540 is correct to say that there is nothing wrong with descending to MSA and being visual there, (Note that I said visual and not VFR) continue descent visually. Of course the MSA is usually 1000ft above the highest obstacle within 10nm of the indicated position of the aircraft.

------
I note that everyone is very reluctant to name these CAA officials and FAA officials who say certain things. However, if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAA and post their reply here for us all to see.

-----

What about the pilots who get the IMC on a single and then use it on a twin. Now there is an accident waiting to happen!

Regards,

DFC

[bpilatus]

hey guys,
about to get my PPL if the uk weather permits!
anyway, after the training i would like to get more ratings, although i dont really get the difference with IR and IMC rating.
if i have an IR rating would that mean i could fly in IMC anyway and wont need to do IMC training? or do i need IMC before i can actually start IR training?

Perhaps the first thing to say is that reference to instrument ratings is normally controversial. The writings above demonstrate just that. My advice would be to obtain the PPL and go learn how to fly. When you have 50+ post PPL hours consider an IMC rating. If you obtain an IMC my advice would be go learn how to use it. When you have 250+ post PPL hours consider an IR.

With an IR you can fly a G reg ship anywhere in the world in controlled airspace in any weather. You don't need an IMC to do a IR but it would be helpfull, for practical purposes . Expect to take 12 months to obtain an JAR/IR. As some folk have mentioned perhaps a practical option is the FAA version. This will restrict you to an N reg ship, but will allow you the same privileges as mentioned above. With an IMC you may be able to do the entire thing (FAA rating) in the States in a couple of weeks at a fraction of the cost.

An IMC is a UK rating. It doesn't allow flight into class A but is a very useful rating for the PPL, perhaps I should qualify that and say a 'current' PPL with regular IMC practice.

[Fuji Abound]

DFC

A number of contributors on this forum, including at least one solicitor interpret the legislation as advisory, a number, including yourself as mandatory.

However strongly you may hold to your view it is quite apparent that the legislation is ambiguous at best and a worst appallingly drafted. I suspect if you had asked the plain English society to look at the drafting they would have come up with a number of better ways of saying the minima were either mandatory or advisory depending what was in the mind of the legislator. Ultimately if push came to shove the courts would be guided by the CAAs "official" line which, as much as you might wish otherwise, would clearly seem to be the minima are advisory BUT the judge would have to be satisfied in his mind that the intention of the legislation was clear. It seems to me that would be a difficult count on which to be satisfied. I doubt the judge would have the slightest interest in consulting the plain English society!

This issue had been rumbling on for years now (I seem to remember that it was certainly discussed as many as five years ago on this forum). One would suspect that if the CAA's view was not as many have expressed the CAA might have found ample opportunity to carnify their interpretation of the legislation.

Your argument that IMCR pilots are not trained to the same minima standard as an IR pilot really does not wash as justification that they should not be permited to operate to the same minima as a pilot with an IR, however much that might seem common sense. The fact of the matter is I do not honestly believe anyone could successfully argue an IMCR pilot is trained to fly a hard IFR sector, with a departure and arrival to minima. Yet subject to the debate about whether or not the IMCR minima is "higher" there is no doubt the qualification legally entitles you to do just this.

"If one wants to operate as if one holds an IR regardless of airspace then there is only one answer - get an IR"

Of course as you know full well this is nonsense. The IMCR is an instrument rating - or if it is not then all that time spent flying on instruments is pretty pointless. It does not cover instrument skills in the same depth as the IR, but other than this debate about the minima, it legally enables the pilot to operate in UK airspace in exactly the same way as an IR holder with the exclusion of class A. In my view excluding the pilot from class A is a complete nonsense. If the pilot is judged safe to operate in class D with other commercial traffic one suspects there is less risk with their operating in class A given the aircraft is up to the job. One suspects the class A exclusion has far more to do with commercial considerations that safety. Even more bizarre is the fact that an FAA IR holder has no rights in UK airspace unless operating on the N reg or unless he has been granted an IMCR but in which event the IMCR restrictions remain.

Practically you should see the standard of some newly qualified IR holders particularly when the approach does not go to plan. Ask commercial training captains on how many occasions they have had to “save the day”. Both ratings, are a license to learn, the IMCR a license to learn more, perhaps!

What one can say is this issue is just the tip of an iceberg of poorly thought out legalisation which was creditable in its intention when enacted but has become hopelessly corrupted by the vested interests and commercial pressures of the regulators who have long forgotten that the principle concern should be the safety of pilots and of the public.

Many regards

Fuji abound!

[slim_slag]

I don't think I'm really qualified to say too much about the CAA side of things, but for me DFC has by far the most persuasive argument on what you can legally do with an IMCR. At least he has provided an argument (with references) which gives the relevant part of the AIP the legal force of the ANO. His argument that the 'but' is key is very persuasive. I still reckon he works for a regulator :) Fuji is quite correct though, it's all very badly written.

[FullyFlapped]

I note that everyone is very reluctant to name these CAA officials and FAA officials who say certain things. However, if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAA and post their reply here for us all to see.

Hmm. DFC, tell us, how many times have you claimed to have the absolute inside track on various things (eg, ATC unit procedures) and then refused to state the basis of your so-called "knowledge" .... pot to kettle, over .... Also : does the use of "we teach" now proclaim an instructor status ?

I am an IMC holder who - brace yourself - doesn't any longer believe that I know the answer to the minimums question. I have had my head filled with "absolute knowledge" available from the instruction/flying school/pundit crowd, and I have had so many varying opinions that I have come to the conclusion that I'd be no worse off raising the question on this forum - i.e., I'm not likely to find a definitive on here either !

Let's face it, you ask an what should be a simple enough question of aviation law, and receive a clutch of opinions regarding sentence construction. You ask for subject literacy, and receive (probably dodgy) answers relating to linguistic literacy.

Good fun this may be, but those who sign up to this forum should be made very, very aware that there are as many duff opinions as facts to be found here ... which may of course include the one I've just expressed ! :D

For what it's worth, I tend to keep to the 500/600 mantra unless I'm bloody sure of what I'm doing and where I am ... Wrong ? Possibly. But I'll wait for the for the proof. And for what it's worth, that won't be provided by someone with a 3rd in English language ....

FF :ok:

[Justiciar]

they should always work to an absolute minimum of 500 for a precision approach etc.

Perhaps the key word here is "should". Using this word merely emphasises that the AIP is a recommendation and not a rule. any statute imposing a requirement which would be backed by criminal sanction would use the word "shall". My wording was paraphrasing the wording of the AIP and not an attempt to manipulate it as DFC appears to think.

The point is this: what happens to a pilot with an IMC who descends below the DA/MDA before acquiring visual reference? What is the sanction? The answer is nothing happens to him, because the ANO does not prescribe any separate penalty or sanction for breaching the 500/600' minima. The AIP cannot create any separate sanction for breaching this "limit" because it is not legislation and cannot lay down penalties or sanctions as the ANO does. It is merely descriptive of the aerodrome limits. There is no separate and distinct limit for IMC rated pilots.

since they are minima and notified in the AIP, they are covered by Article 49.

They are not "notified". What Article 49 actually says is:

"an aircraft to which this article applies when making a descent to a runway in respect of which there is a notified instrument approach procedure shall not—

(a) continue an approach to landing on such a runway by flying below the relevant specified decision height; or

(b) descend below the relevant specified minimum descent height;"

So, the restrictions are defined by the "notified instrument approach procedure". There is nothing within the "notified instrument approach procedure" which distinguishes between the IR and IMC rated pilot. The "notified instrument approach procedure" is defined by reference to the design and layout of the aerodrome and its terrain. It is specified by the AIP for different types of approach and Article 49 is then applied by reference to that published procedure.

The question of whether IMC rated pilots are actually trained to descend below that altitude is completely separate. Nothing discussed here should be seen as an endorsement of ignoring the AIP. But the question was whether the 500/600' figure was mandatory or advisory. My view is that it advisory. That is not to say I would ignore the recommendations.

[bpilatus]

There is of course a practical consideration, one can hardly expect a pilot to remain aloft because he can not satisfy the MDH. It is important that s/he can descend safely, regardless of cloud base and visibility.

Having said that from my casual observations I suspect that the vast majority of PPL/IMC holders are not current and don't fly in IMC or if they do depend on the autopilot (there is nothing wrong with using the autopilot provided the pilot can also fly hands on). The IR is a package it concerns more than simply flying. Weather (and its effect on the flight and aeroplane) is studied in some detail, far in excess of what an IMC pilot studies. A pilot having to use his rating below the minimums (whether IR or IMC) has probably not prepared adequately and may not know how to.

There is a tendency that the IMC rating will become a get out of jail card. Too often an IMC instructor renewing a PPL's rating is keen to demonstrate how to perform procedural approaches.

For what it's worth I am also a believer in the 500/600ft min for an IMC and perhaps equally controversially that it should only be used in the UK airspace. There are some that believe it can be used abroad to fly above cloud.

[IO540]

"There is a tendency that the IMC rating will become a get out of jail card"

Not that one again, please :yuk:

A pilot with an IMCR who has not flown for a year is going to be as useless as a pilot with an IR who has not flown for a year.

3 things that matter:

currency on type
currency on type
currency on type

Now, how many of each sort are there hanging around airfields?

Most PPLs don't fly anywhere really (most chuck it in pretty fast). I therefore suspect most IMCRs are well out of currency, too. One big reason is that one cannot at all easily rent a plane that's legal for IFR in CAS, never mind one that someone with a brain would want to fly in IMC.

The vast majority of IRs are also either lapsed or their currency is zero. Most are in the hands of ATPL hour builder instructors who did the IR by banging a Seneca around for a while, plus sim sessions, passed the ATPL exams and, when they are not thumbing through airline job ads, are trying to hour build by flying in perfect VFR between the four creases in their chart next to a student.

There is a tiny group of noncommercial IRs flying around Europe. Practically all of them are owners, and they will generally be current (most owners are current especially those who can fly IFR).

There is a much bigger group of G-reg owners who don't have an IR but have the IMCR. Most owners of something reasonable will have a job/business and cannot possibly do the JAA IR.

I reckon if you picked 100 pilots who have just arrived on some IAP, and stripped out the commercial ones, you would find the good IMCR pilots vastly outnumber the good IR pilots.

An IMCR pilot who had a half decent instructor can fly everything in the IR flying syllabus, except SIDs and STARs and those are easy. The reality of Class A is nearly all RNAV i.e. a BRNAV GPS.

[bpilatus]

IO540, if the IMC is to be a serious rating then instructors should place more emphasis on assessing a pilots competence. Demonstrating, once every 25 months, how the ILS should be flown is probably not doing the pilot a favour.

I think you need some factual information to back up your other points, these appear to be personal thoughts.

[Fuji Abound]

bpilatus

Unfortunately the ANO does not use the word should.

With regards evidence, the FAA IR does not require renewal as long as you are able to self certify currency.

I know some don’t like the comparison between us and the States. However the fact remains there are hugely more private pilots in the States flying in all sorts of conditions. You mention evidence - well look at the evidence from the States regarding the use of the IR by private pilots and also consider the accident statistics. For me it is a pretty persuasive model that their system works - and works very well.

In Europe there a a significant number of pilots operating N reg. I cant remember the last time I saw an N reg accident here in IMC conditions. Moreover I also cant remember a significant number of accidents involving pilots with an IMCR in IMC.

DFC writes about the IMCR not being with us much longer. Perhas it will not be but I wonder if anyone will bother to do a regulatory impact anaylsis if the rating is withdrawn and if they do I wonder whether anyone will consider what the safety implications are?

[bpilatus]

Fugi, at the risk of being controversial I'm inclined to say that you are merely supporting 540 with more personal opinions. If you want to make a valid point please do so from an authorised source. I have no problem with the FAA/IR, as you say it is possible to self certify. Un/fortunately this isn't the case with the JAR/IR. Which is best is another issue, perhaps we can let the reader decide as opposed to trying to persuade.

[FlyingForFun]

DFC,

A couple of quotes from your last post which I think need some further comments:That makes the idea of an IMC rating holder who flies the average number of PPL hours per year doing an ILS in IMC down to 200ft and expecting to be in a position to safely land as remoteThat is probably true. But exactly the same is true of an IR holder doing an average number of PPL hours per year.

On the other hand, there are plenty of IMC-rating holders who do far more than the average number of hours. They might even have had training in flying an ILS down to 200'. (I am certainly happy to give this kind of training to my IMC students, although it is not on the syllabus and will not be tested, and when I do so I of course point out the relevant recommendations and the requirement for currency.)

The rating (IMC or IR) a pilot holds does not necessarily reflect on the currency or ability of the pilot.

On an unrelated note:if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAAIn a recent thread, I was asking about the possibility of using the localiser for guidance on the outbound leg of an ILS procedure with a procedure turn. My colleague had already asked Steve Oddy for his opinion, and his opinion was that it was allowable. I then asked PPRuNe for further opinions - and someone posted a very detailed reply describing why Steve Oddy was wrong, because the localiser coverage does not extend to the height required to fly the leg. I just went back to that thread and checked who it was that posted this information, which I'm sure is correct but which was in direct conflict with advice from a CAA staff examiner. It was you..... ;)

FFF
--------------

[High Wing Drifter]

FFF,
That is probably true. But exactly the same is true of an IR holder doing an average number of PPL hours per year.
Agreed with the caveat that it is a matter of degrees. As you know the IR training is much more rigourous with much greater demands for accuracy and arming the pilot with many more techniques to maintain accuracy and situational awareness. I suspect, that an IR pilot would be considerably safer than an IMC pilot with only the same amount of VFR only time since IR/IMC training, the longer the gap, the more so. That doesn't mean to say the IMC pilot would unsafe, but I wouldn't feel comfortable comparing the two ratings in such a way.

[Fuji Abound]

bpilatus

- nothing like a bit of controversy :ok:

"Which is best is another issue, perhaps we can let the reader decide as opposed to trying to persuade."

I wasnt aware that I was passing any opinion on which is best? I was simply making an observation on one very limited aspect in response to your point that there was some magic in requiring and IR pilot to renew every year. My point was it doesnt happen in the States. I am not aware of any evidence that by renewing an IR every year the pilot is "safer" - are you, or is this another personal opinion?

I am also struggling to see what other personal opinions I have given - although of course thats part of what PPRuNe is about anyway. I read the US and UK AAIB reports every month, I also follow the stats published in American Flying and other sources. My perception is as I set out in my post - a personal opinion, well maybe, because I have not referred to a statistical study, but the reports are there for all to read. If you have reached a different conclusion maybe you would like to share that.

[IO540]

Just some random thoughts.

There won't be any "official" data on this - who is doing currency surveys in this business? It's just pretty obvious looking around. There is however plenty of data on the CAA website showing that each year about 100x more people get an IMCR than an IR (NON commercial).

The CAA have really good data on licence/rating lapsing but they don't publish it. If I was them, I wouldn't publish it either.

An FAA IR needs to have done 6 approaches in the past 6 months, to fly under IFR. That means you have to be doing more than that, of course, otherwise the oldest approach you did will be just about to "drop off the end". You've got to be doing something IFR every fortnight, more or less.

A JAA IR has to sit a checkride every year, but he may not have flown for a whole year before that. Is that better? We could argue about that but I don't think it is better. We all know the examiner won't fail you unless you do something pretty bad.

The biggest enemy of all this is lack of currency... currency costs serious money, and decent planes cost even more money, and money is in a very short supply in this business. Just look around your local airfield.

If the IMCR is abolished, we will still have every "instrument capable" pilot flying in cloud en-route, just like they do abroad at present. One just can't do an IAP and one can't depart from a towered field if it's sub-VFR. A very poor case for safety! I am 100% certain that nobody would have the ba11s today to introduce the IMCR (the IR training business would be up in arms about it, wouldn't they, Slim-Slag?) but equally I don't believe it will be abolished. Not until there is an accessible "IR" and probably a comprehensive airspace review to something like the US model.

[bpilatus]

the end". You've got to be doing something IFR every fortnight, more or less.

My colleague does all 6 at once (in VFR) to set himself up for the next 6 months. I have been P2 (purely to act as lookout) but it all got a bit scary (he was using the CDI in reverse) so I suggested he take an instructor.

[slim_slag]

That's correct bpilatus, IO540 is incorrect. The majority of FAA PP/CP with IR's who want to remain current legally will head out every six months to do their holds and approaches under the hood in one flight. I would say most PP/CP IR in the states don't fly in clouds very often, and at the small plane level are used to get through cloud decks more than anything else, not shooting approaches to minima. This does happen of course. Once you have the rating you are expected to use your own common sense in deciding how to use it. You have to remember that getting an IR in the States is often just rating collection, another goal to keep you interested in flying.

[Fuji Abound]

"Once you have the rating you are expected to use your own common sense in deciding how to use it."

That is such an important statement.

As we all know the aviation industry is probably the most regulated of any.

Doctors, dentists, lawyers, accountants and a host of other professionals are not tested at interval. I appreciate if they have any sense they will undertake ongoing professional training and in some case are required to demonstrate they have done so to their regulatory authority. I also understand that in some cases there is an effective ongoing peer review.

As has been commented in the States no revalidation of an IR is required if you meet the currency requirments. In the UK revalidation is required every 12months. The States have always had a biannual review, for years we have not. Is there evidence that revalidation improves safety, is there evidence revalidation should be every 25 months, every year, every six months, every .. .. .. Where do you draw the line if a line should be drawn, and do you draw that line on some arbitary whim - once a year sounds good, and will go down well with the examiners!!

I have a pretty high regard for peoples common sense particularly if they have shown the ability to become a pilot and go on to get an IRing. On the whole if people are not current and have in the first place been properly trained to understand the risks of not being current they will go and get some training and certainly will not be shooting approaches to minima. Of course there will always be bold pilots and I suspect with all the currency checks in the world there will still be bold pilots who are prepared to exceed their own currency abilities.

[IO540]

"getting an IR in the States is often just rating collection"

I suggest you go and do an FAA IR before posting such generalised drivel.

On the currency, it's true that one can knock off the 6 IAPs under the hood with a safety pilot, but few aircraft owners who fly for real to real places need to do that. And those that don't don't need to, so there isn't a safety issue. Just like with PPL training; most people never get to use it, so the fact that the training is mostly cr*p (relative to the legal privileges of a PPL) doesn't cause any problems.

If every PPL went off and flew to privileges, ATC would collapse (under the infringements), and the training establishment would get shut down pending a complete review of the syllabus.

If every JAA IR went off and got into the plane they can (some rented spamcan, no good for IFR and probably illegal for IFR in CAS) and flew it to his privileges, the result would be similar; perhaps slightly less bad.

As I've said, currency is the key and unfortunately aircraft ownership is the key to currency.

This is the real problem which most IMCR holders struggle with. It's not a problem for IR holders because.... there are so few of them it doesn't matter.

[bpilatus]

Slim, you may be correct about the objectives of American pilots, I have never flown in the States so I am unable to comment.

As a matter of fact if a FAA/IR pilot converts his rating here he gets an IMC, provided he has not obtained one previously. A JAR/IR holder however gets a FAA/IR in the States subject to a small test. This may be something for Pilotho to bear in mind.

[IO540]

You can get an IMCR if you have an FAA IR, just by sending the CAA a cheque, but you also need a UK/JAA PPL (and a JAA medical) to attach the IMCR to.

[Dr Eckener]

DFC,

MSA is 1000' above within 5nm of the aircraft, not 10nm as you state. Generally agree with most other comments you make, although you seem to have gone quiet on this one since FFF's comments.:E

[slim_slag]

Justicar, good to see some actual citations of documents to back up your argument. May I ask a question or two?
You quoted Article 49 (5)(a) and (5)(b) and concentrated on "notified instrument approach procedure", but not the 'specified... height'.
Specified is defined in (7) as (7) In this article “specified” in relation to aerodrome operating minima means such particulars of aerodrome operating minima as have been notified in respect of the aerodrome or if the relevant minima have not been notified such minima as are ascertainable by reference to the notified method for calculating aerodrome operating minima.There is the word 'notified' which DFC mentioned.

In 155 (Interpretation) is says

Notified’ means set out with the authority of the CAA in a document published by or under an arrangement entered into with the CAA and entitled ‘United Kingdom Notam’ or ‘Air Pilot’ and for the time being in force

Ah, there is the reference to the AIP, so the minima specified in the ANO are to be found in NOTAMS or the AIP. Surely that gives the AIP more than an advisory document status, sounds like it is where the ANO tells you to find the minima for an instrument letfown. Doesn't that make it law?

Now, getting to the AIP again 3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.

There is the 'but', which I think makes 500/600 absolute. Therefore, as it's referenced by the ANO as being where you find these numbers, that makes it mandatory to add 600/600ft to a published approach.

I think that's what DFC said, and it's hard to see why he is wrong. Why do you think he is?

Another question.

49 (7) has two parts. The first is In this article “specified” in relation to aerodrome operating minima means such particulars of aerodrome operating minima as have been notified in respect of the aerodrome I am assuming this is when there is a published IAP.

it goes on to say.

or if the relevant minima have not been notified such minima as are ascertainable by reference to the notified method for calculating aerodrome operating minima. I assume this is when there is no published IAP, one of these DIY approaches we hear about.

So if is this is the case, where is the "notified method for calculating aerodrome operating minima" to be found? Wouldn't this determine the MDH for somebody performing a DIY instrument letdown in class G. If this is not to be found, or the calculation hasn't been made using that notified method, then is an instrument letdown below MSA actually allowed? DFC made reference to this too, that DIY letdowns below MSA are illegal.

So, my other question is, what authority does anybody have to descend below MSA if they only have an IMCR (or IR) if there is no published (notified) approach?

[bpilatus]

Slim, an interesting submission but I have to confess at feeling slightly punch drunk. Personally I prefer to adopt a practical approach but I recognise that these matters should be aired if for no other reason to demonstrate just how confusing it all is. In answer to your last question I give myself authority in the interest of self preservation.

[slim_slag]

Ah, bpilatus, emergency authority of pilot in command, you can do almost what you want then, but I think you have to tell the authorities about it and they may come asking annoying questions :)

It sure is a tortuous route to the conclusions, and I don't know a vast amount about the UK system, but nobody has yet said where it goes wrong. All the people who come up with folklore about what you can do with the IMCR have gone quite :) This subject will come up again so I'll bring it up then.

So having thought about it even more, I now think the CAA rules are basically the same as the FAA rules for flight in class G, and that's no instrument descent below MEA/MSA in class G unless you are on an approved letdown. On published instrument approaches, the IMCR minima are higher by the amounst prescribed in the AIP, and these are legally binding minima. Unless somebody can demonstrate otherwise using an argument with cites regulations :ok:

[2Donkeys]

I now think the CAA rules are basically the same as the FAA rules for flight in class G, and that's no instrument descent below MEA/MSA in class G unless you are on an approved letdown.

That is true for the US [relying on FAR 91.175(a)]

There is currently no such requirement under the CAA regime. IFR flights outside controlled airspace are simply required to comply with the "Rules of the Air". For IFR flights, these waive the "no flight below MSA" rule when the aircraft is engaged in take-off or landing - with no requirement for the landing to be accomplished using a published procedure.

Should the CAA wish to bother a pilot in the UK for such an action, they would need to think in terms of something more generic - Endangering an Aircraft or its Occupants, for example.

2D

[slim_slag]

Thanks 2donkeys,

I am guessing you are basing your argument on the following..

Minimum height
29. Without prejudice to the provisions of rule 5, in order to comply with the Instrument Flight Rules an aircraft shall not fly at a height of less than 1000 feet above the highest obstacle within a distance of 5 nautical miles of the aircraft unless:

(a) it is necessary for the aircraft to do so in order to take off or land;

If you are using this to say you can do what you want if you are taking off or landing, then can you descend to 100ft AGL in cloud? Is there actually a MDH if there is no published approach?

[2Donkeys]

That is in essence what I am saying.

The simplest case is a private airfield with no ATC and no published approaches. There is no rule to restrict a GPS-based home-made instrument approach down to such a field. Minima apply to published approaches.

Note, that I am not attempting to cloud the issue with the specific privileges of the IMC rating, where as we know, landing or taking off in less than 1800m is not permitted.

By focusing on the simplest case of a private field, I am also removing some of the other confusing practical issues, such as the Management of an Airfield denying authority for an aircraft to land below certain weather minima.

If the argument is focused on this simplest case, I think you'll find that there is nothing in legislation to prevent such an approach. This is not to suggest that it is sensible or safe.

2D

[slim_slag]

Thanks again 2D.

If the argument is focused on this simplest case, I think you'll find that there is nothing in legislation to prevent such an approach

What about Article 49 (7)

(7) In this article “specified” in relation to aerodrome operating minima means such particulars of aerodrome operating minima as have been notified in respect of the aerodrome or if the relevant minima have not been notified such minima as are ascertainable by reference to the notified method for calculating aerodrome operating minima.

My italics.

The relevant minima have not been notified as there is no published approach. So minima have to be calculated "by reference to the notified method for calculating aerodrome operating minima"

I'm guessing that is PANS-OPS. So sure you can do an instrument letdown in class g where no published IAP exists, but it has to be designed to the standards set out in PANS-OPS. Does anybody do this?

[2Donkeys]

Slim_Slag

You make a good case however, the purpose of 49 (7) is to define the use of the word "specified" in that particular Article.

"Specified" in the context of this article, is used uniquely in relation to aerodromes having published approaches. It is covering the case in which an aircraft must fly a published approach into an aerodrome which does not calculate/promulgate approach minima. This would be relevant in particular if descending into a foreign airport for example.

2D

[slim_slag]

2D,

A published approach without any minima? That would be a strange animal, never seen one of those, but that could just mean I haven't flown in most places. I don't see anything thet says 49(7) is only for aerodromes having published approaches, but if that is the basis for saying you can fly a 0/0 approach to a class G then fair enough. Very peculiar for a regulator like the CAA, who are generally far more strict than the FAA on supposed safety matters, to let that one get past :)

Cheers

[2Donkeys]

It's not easy is it Slim_Slag?

49(7), as you quoted it starts by saying:

"In this article “specified” in relation to aerodrome operating minima means"

So, the purpose of what follows is to define what they mean by the term "specified", throughout this Article. Nothing more or less.

So the next question is, when do they use the word "specified" in Article 49?

And here is the answer:

an aircraft to which this article applies when
making a descent at an aerodrome to a runway in respect of which there is a notified instrument approach procedure shall not descend from a height of 1000 feet or more above the aerodrome to a height less than 1000 feet above the aerodrome if the relevant runway visual range for that runway is at the time less than the specified minimum for landing.

My bolds. You'll note that specified only applies in this instance to a runway with a notified instrument approach procedure.

And here it is again:

...an aircraft to which this article applies when
making a descent to a runway in respect of which there is a notified instrument approach procedure shall not:

(a) continue an approach to landing on such a runway by flying below the relevant specified decision height; or
(b) descend below the relevant specified minimum descent height;
unless in either case from such height the specified visual reference for landing is
established and is maintained.


Once again, my bolds. Once again, "specified" only applies to a runway with a notified procedure. And that's it. Two "specifieds" to which 49(7) applies, neither of which relate to making unpublished approaches.

I hope that clears it up.

So far as published approaches with un-notified minima are concerned, this is not nearly as rare as you might imagine. You won't find minima as such in the UK AIP charts. You get OCHs and OCAs from which you are required to apply maths to determine your minima. Jepp and Aerad do this for you (to a point). Some other countries take a similar stance, by publishing the constraints, leaving it for the aircraft operator to determine the minima which apply to his flight.

So far though, still nothing to convince me that you have found a law prohibiting descent below MSA other than on a published approach, but I am open to offers.

2D

[DFC]

DFC,
MSA is 1000' above within 5nm of the aircraft, not 10nm as you state. Generally agree with most other comments you make, although you seem to have gone quiet on this one since FFF's comments.:E

The important word that I used is indicated.

If you simply measure 5nm each side of track and check for obstacles then there is the posibility that you will be less than 5nm for the edge of the area checked because of system errors and you not flying to the exact mm on the chosen centerline. Thus 10nm allows for a maximum RNP5 enroute error.

Of course you could sit down with PANS-OPS and accurately calculate the errors and use the exact figures to reduce the area to be considdered.

As for FFF's comments - Annex 10 provided a clear black and white written statement that was at odds with what the Examminer said and at the time I said that it would be odd for an examminer to fail someone for using the BPL outside of the DOC while permitting / advocating using the LOC outside of the DOC. I am still waiting for those that claimed to have CAA advice regarding IMC minima being advisory to name names (as FFF did) or publish written evidence.

---------

What everyone regardless of position agrees on is that the whole thing is confusing. Thus I propose that it be re-written to a very simple statement;

"IMC rating holders in current practice shall add 300ft and 1000m to the applicable IR minima".

That would make the ILS (IR single pilot 200ft / 800m) a 500ft / 1800m IMC minima and the lowest possible. Everything else requiring higher DH / MDH and higher Visibility / RVR.

Any comments regarding that?

Regards,

DFC

[IO540]

Delete (or define) "current practice"

[slim_slag]

2D,

I accept your interpretation than 49 does not apply to airports with DIY approaches. :ok: I still think the minima for an IMCR holder when shooting a published approach (as found in the AIP) are not recommended but mandatory.

I still don't feel beat up :)

So far though, still nothing to convince me that you have found a law prohibiting descent below MSA other than on a published approach, but I am open to offers. Let me think about that one :)

[2Donkeys]

I still think the minima for an IMCR holder when shooting a published approach (as found in the AIP) are not recommended but mandatory.

I have deliberately avoided commenting on that one. Your "no descent below MSA" comment was much easier to deal with. :p

The IMC rating and its conditions of use are in effect, rather than by design, scattered around a number of places (two parts of the ANO and AIP) each of which uses language which fails in small degrees to interlock fully. It is this lack of interlock which gives rise to the testosterone-filled debates that Pprune is so famous for.

I've always believed the vertical minima to be advisory, but I am happy to hear the arguments on both sides - they are certainly well rehearsed now. :)

2D

[englishal]

You are all very good at quoting rules and regulations ;)

1. The IMC rating holder is not trained according to the sylabus to fly a precision approach below 500ft. DH or a non-precision approach below 600ft MDH.

Why not? The usual rules apply, if the needle is out by the specified amount of deflection (personal limit / ½ / full scale), you execute a missed approach. I'm sure there are IMCR holders out there capable of flying an ILS down to 20', and IR holders who are not even capable of getting to minimums (because they are out of practice, or can't afford to remain current ;) ).

[slim_slag]

You are all very good at quoting rules and regulations ;)And ignoring them :) It's the interpretation that is causing the fun and games.

I'm sure there are IMCR holders out there capable of flying an ILS down to 20'I note the word 'capable', but even the FAA won't let you do that. You can get Cat II authority with a bog-standard spamcan and PP-ASEL/IR, but you aren't ever going to do 20ft for real so how do you know you can? It's not the same under the hood with a safety pilot, think you will be calm and collected when the altimeter say 50ft and you still aren't visual?

[englishal]

I note the word 'capable', but even the FAA won't let you do that
Yea I know, but there may come a time when breaking the rules may save your life.....I know I'd give it a go if the alternative was worse ;)

Most nice aeroplanes I fly have an autopilot. Fly the ILS on the AP, when the G1000 reads 20', chop the throttle and George (...sorry, the AP) will keep pitching up and you may even make a perfect landing. If not, at least you may only break the aeroplane......:)

[2Donkeys]

Do that without the ILS being safeguarded and you may very well bend the aircraft and yourself in a way that will make "the alternative" indistinguishable.

2D

[slim_slag]

Fly the ILS on the AP, when the G1000 reads 20', chop the throttle and George (...sorry, the AP) will keep pitching up and you may even make a perfect landing. If not, at least you may only break the aeroplane......:)How does George know he's at 20ft? Don't tell me your plane has radalt too, lol. Well, if you believe what you read on web sites, it would be legal for IMC rated George to descend to 20ft in UK class G, so why not try it?

[englishal]

All depends on the situation and how likely you are to die doing something else ;)

George doesn't know the height, but as you chop the throttle, George will have to keep pitching up to try to keep on the GS, but as there is no power he will eventually induce a stall.....hopefully by which time you'll be within 1" of the runway, so in otherwords he has just flared for you.

The nice thing about the G1000 is you can read off the "numbers" very accurately. Of course not being a Rad alt, you may find that 20' is actually -10' but assuming you have current pressure and you set it accurately, you may get away with it.

I can't try this in the UK as George lives in America :D

[2Donkeys]

Lets leave aside the issues associated with using an autopilot below its authorised minimum height (If we're talking N-reg for the moment, that is published in the flight manual supplement)

As you fly down the ILS, the sensitivity of both localiser and glideslope increase significantly. As you fly down to the runway below the ordinary Cat I DA, that sensitivity will rapidly increase to the point where is defeats the ability of GA autopilots to make the necessary adjustments with appropriate timeliness.

An altogether better plan, would be to fly the aircraft manually, with the FD displaying in approach mode. That way, you can decide if you want to continue all the way to the ground.

2D

[Fuji Abound]

DFC and others

I can now confirm that the CAAs official interpretation of the "IMC minima" is that the whole sentence is advisory, including after the "but". I have their interpretation in writing and I am satisfied their interpretation is specific and clear.

I am not prepared to quote the name of the person giving the interpretation or to reproduce their letter here because I have not asked their permission to do so.

[High Wing Drifter]

Fuji,
Good stuff and good to know. I guess that settles it then. I'm not sure why the CAA would mind you showing us the relevant wording in the letter though :confused:

[S-Works]

Funny old world eh! Did I not state exactly the same several pages ago?

But then of course it would of denied the barrack rooom lawyers the opportunity to spout off and impress us with there knowledge or lack of.....

I have great admiration for people like DFC who spend a great deal of time and effort trying to convice us there intrepetation is correct! Personally if I have a question regarding the rules I just write to the CAA who have always answered in a timelly manner with what I assume is the correct information (I base the assumption on the fact that it would be the CAA prosecuting me for an violation) so if I have the answer from them it could provide some sort of defence!!!

High Wing if you really want to see it in writing for yourself, you could do what the rest of us did and email them, answer came back in 48hrs. [email protected]

:)

[slim_slag]

bose x.

It's hangar talk, all a bit of a laugh, that's all. And who is worse. Somebody who crafts and posts an argument which is proven wrong by a regulator as they will always be right, or somebody who comes along and says 'I told you so' ?

Well Fuji, seems like I was wrong. No, not about the interpretation, wrong when I said DFC worked for a regulator :). I thought he had the inside track, still think his argument makes more sense than any I've seen, need to see yours before I can comment :) So he doesn't work for the CAA, from his 'prop deice' answer he obviously doesn't work for the FAA, I guess he must be an airline pilot!! :)

[3FallinFlyer]

To change the subject slightly, could anyone advise on how I stand flying in IMC with an IMCR (or JAA IR come to that) in an N-reg a/c in the UK? I heard today off of a very knowledgable FAA instructor that wherever in the world you are, you must have an FAA IR to fly an N-reg in instrument conditions. This is contrary to what I have been led to believe up until now :bored:

[DFC]

IO540,

Leave "in curent practice" in and define it. How would one define it? Having made that type of approach in IMC/under the hood/FNPT2 in the last 28 days as a starter?.....if not then add another 300ft and 1000m to the minima?

-------

You are all very good at quoting rules and regulations ;)
Why not? The usual rules apply, if the needle is out by the specified amount of deflection (personal limit / ½ / full scale), you execute a missed approach. I'm sure there are IMCR holders out there capable of flying an ILS down to 20', and IR holders who are not even capable of getting to minimums (because they are out of practice, or can't afford to remain current ;) ).

look at the situation like this;

1. The rules say no lower than 500ft DH for an IMC rating holder.

As a result of this, the training sylabus requires that pilots are trained to fly a precision approach to a minimum DH of 500ft; and

The Skill Test to obtain the rating involves being tested on the ability to fly a precision approach to a minimum DH of 500ft.

If you go over the 15 hours in training because you are having problems with flying the ILS below 500ft then you could be in a position to claim your money back because that is not a required part of the sylabus. ( Think of it like taking 100 hours to get your basic PPL because it took 40 hours dual for you to master instrument approaches! - you would ask for a lot of money back since they are not a required part of the sylabus.)

If you fail your Test because you were unable to fly the ILS below 500ft then you can complain about the conduct of the test.

and finally but probably more important to this discussion;

If you have an accident while flying below 500ft in IMC on a precision approach with an IMC rating - you can not claim that you were not properly trained because it is not in the sylabus, you can not claim that the CAA should have chekced your ability because it is not required. That leaves you with no one for you, or the insurance company to blame but yourself.

However, if the permitted minima were less than 500ft, you could claim that you did not receive the required training - but they are not and you can not............or atleast you can but you will win the lotto before you win that one against anyone who can put a good argument to the Judge about training, demonstrated ability, safety, attitude and rules! Perhaps you should look up the original proposal documents and the initial idea that was the birth of the IMC rating - ask AOPA for more info!

---------

Fuji,

I am not prepared to quote the name of the person giving the interpretation or to reproduce their letter here because I have not asked their permission to do so.

Go on. Ask them. I can guarantee that they will give their permission. :D :D

The reason why I ask is that training providers would be very interested in this new development and would be taking time to consider the implications in terms of training standards, sylabus and potential advertisement :) , not to mention revision of course notes and from the Examiner's position, revision of the written exam and skill test standards.

:D

---------

3FallinFlyer,

I will have to check again but my understanding is that you must hold an IR to fly an N reg aircraft IFR. The FARs say so. To my understanding that means an FAA IR or an IR issued by the country where the aircraft is operating.

Regards,

DFC

[tmmorris]

I wonder if the CAA intended to make the 500/600ft limits mandatory, but actually the wording of the ANO 2000 failed to do so? Thus they are in the position where they wish it was mandatory, they intended it to be so, they would like us to believe so, but when you put them on the spot they have to admit that it's not?

I have to admit that DFC's case is coherent - the training syllabus, the test standards, the written exams all hang together - but there is the undeniable fact that the CAA have told people the limits are advisory.

Tim

[bpilatus]

If the cloud base was 50ft below the MDA or DA how else could one get down and who is measuring anyway. Surely this activity (instrument approaches) can only be subject to to advisory heights.

[Fuji Abound]

DFC

You are wrong.

You have quite clearly set out your case and why you consider there to be an absolute minima.

The regulators interpretation of the legislation is contrary and clear - the minima is a recommended minima. It so happens that a number of us have always agreed with their interpretation.

As an aside it is noteworthy that with regards the departure minima the ANO uses the words “shall not fly .. .. ..”. It seems to me if the draftsmen was capable of using such clear and unambiguous English where the IMCR holder is to be restricted to certain minima he was equally capable of saying and distinguishing between an advisory statement and a mandatory requirement!

There are many areas of law in which the regulatory authority will set out their understanding of legislation where there may be doubt. Tax law is full of examples. That does not absolutely mean the courts would have reached the same view, however as others have said it does mean if you adopt the interpretation of the regulatory authority you will not be criticised or prosecuted for a breach of the regulations. I happen to believe the courts would reach precisely the same interpretation.

It is my personal view the regulatory authority has it absolutely correct and the legislation is sound. I would be very concerned should it ever change. I am personally happy applying the IR minima and will continue to do so.

As I think Bose also commented, I was very impressed how quickly and clearly the CAA replied to my correspondence (and I might add that has consistently been my experience on issues such as this). If you don’t accept that I have correctly represented their reply you should write to them yourself.

I can now also add that I have since discussed the matter with my insurers and they have confirmed they accept the minima as recommended and that there is no “breach” of the conditions of my policy where a pilot with an IMCR operates below the recommended minima. Again, in my case you are wrong.

I do not accept your contentions regarding the training industries “take” on this issue. As I posted previously my instructor took the trouble some time ago to obtain clarification from the CAA although in fact both before and after his view had always been the minima were advisory. Whether or not others have done so is wholly academic. The schools teach a syllabus, and the regulatory authority deems that syllabus appropriate to determine on test whether a candidate should be granted the rating.

Finally your arguments about the IMCR syllabus are for me bizarre and so are the conclusions you reach. Moreover this is the second time in this thread you have “trotted out” the same argument. An exam is designed to test certain prescribed abilities of the examined. It provides no guarantee that the successful candidate will be capable of doing everything the qualification permits - the only guarantee it provides is that the candidate has met a certain standard. As I mentioned earlier, and to take a very simple example, when you pass a driving test you are not tested on your ability to drive on a motorway and indeed you are unlikely to have demonstrated you can drive the car above 50 mph. The day after the test you can of course go and kill yourself and half a dozen others on the motorway (God forbid).

It is very well understood by examiners and pilots that the IMCR initially sets a less rigorous standard than an IR. That is why there are these recommended minima, and that is why the CAA has always recommended that a newly qualified IMCR holder should consider the rating as a “get you home” or “get you out of trouble” license. However, the regulators in their wisdom also (fortunately) had the sense to realise that there are some private pilots who will use the rating in earnest and will achieve a standard of flying that is better than many IR holders.

So in short you are wrong DFC. The only reason I have repeated that you are wrong is because you have raised an important issue and we have all had an good debate on this matter. Rightly I believe the matter has been clarified and I think it is important that interested pilots are aware. However much as you disagree I do not believe you should go on setting out a position that is simply wrong because some people might actually believe you!


Whilst posting I take on board the comment that were the intention of the legislator different? I don’t believe this to be the case at all. I think if you look at the history of the IMCR it is quite clear what the legislator had in mind and it is quite clear why an 1,800 departure minima should apply. In fact whilst I don’t agree with the class A restriction it is also clear why at the time this restriction should also have been applied. Whilst I know there are many examples of appallingly drafted legalisation I do think this is not one of those cases.

[S-Works]

I do like that term "DFC you are WRONG" it warms my heart.

If you actually read his last post it has gone from being "illegal" to "the training does not support minimum approaches". I look forward to the next line he trots out to support his argument.

<Go on. Ask them. I can guarantee that they will give their permission. >

It would be much easier for DFC to actually ask the CAA himself instead of pontificating or is he scared getting the answer from the horses mouth will sink his arguments?

Personally my original IMCR training was actually done by the same guy who is doing most of my current JAR IR training and he believed strongly in the IMCR as a proper tool and trained me and all of his students to minima. In the 1400hrs between doing the IMCR and deciding to do the full IR (to give me access to the airways as my plane is equipped) I have flown over 200hrs by sole reference to instruments and carried out many approaches to minima. But in real terms it is rare to have to fly to minima as the weather is not that bad, however when I take off I am happy that I can get back down at the other end.

[IO540]

Good stuff...

It's debatable whether one should make the privileges of the IMCR dependent on currency.

While this is a plausible safety argument (and always remember that "safety" can be used to force just about anything through; a bit like "do you agree that convicted child molesters should be able to work as PE teachers") it would remove IMC privileges from the great majority of PPL/IMCR holders. Most UK PPLs are already struggling to clock up something like 20-30hrs/year, VFR.

It would amount to a back door abolition of the IMCR.

One needs to decide whether to support the IMCR, or kill it off. If you want to kill it off (on "safety" grounds) then you ought to kill the basic PPL too, on the same patently obvious grounds that the usual training falls way short of its privileges. In reality one has to assume that pilots have the sense to not do something that's dangerous.

I would support a currency requirement for the IMCR if one got Class A privileges, but there is no way that would happen. The IR training industry would vigorously campaign against any such proposal; the fact that almost no UK PPL is doing a JAA IR being beside the point.

To change the subject slightly, could anyone advise on how I stand flying in IMC with an IMCR (or JAA IR come to that) in an N-reg a/c in the UK? I heard today off of a very knowledgable FAA instructor that wherever in the world you are, you must have an FAA IR to fly an N-reg in instrument conditions.

A year or so ago I wrote to the CAA with exactly this question. Their reply was that it is up to the FAA to decide which (if any) of the IMCR privileges work in an N-reg. So I wrote to the FAA and their reply was they they regard the IMCR as "equivalent" to the FAA IR. For those that are going to jump at me over the last sentence, DFC no doubt et al, let me remind them of the obvious caveat that the IMCR privileges are themselves limited by the ANO to be well below those of the FAA IR (i.e. no Class A, 1800min vis) but it does mean the IMCR appears fully valid in an N-reg. One cannot really go any further than this is clarifying this old chestnut.

Tied up with this is the other old chestnut whether an FAA PPL holder (an FAA PPL has automatic night privileges, normally) can fly in the UK at night (whether in N or G) given that UK night is normally IFR. I have never seen this one answered, and now that I have the IR it doesn't concern me anymore.

On a related tack, the supporting case for flying an N-reg with a UK PPL with the night qual/rating is

FAR $61.3 (a) (1) says: "when operated within a foreign country, a current pilot license issues by the country in which the aircraft is operated may be used"

and of course that provides a supporting case for the IMCR privileges in an N-reg, too, unless one goes for the anally retentive argument that a "license" is not the same as a "rating" in the above context.

[DFC]

Fuji,

I am quite contented with my position and have clearly demonstrated tangible evidence to support the case.

The CAA says "seeing is believing" and we are waiting to see your communication or identification of the CAA member of Licensing Staff that replied to you as you (and BOSE) say.

Until then we have the tangible evidence on one side of the debate and hearsay on the other.

Nice to know that your insurer is available to provide a considered response so early on a Saturday morning. :)

As for telling other people - I have been doing that for decades - as have many others in the training industry. Until the CAA change the position, we will continue to do as before. We also expect students being told such information to take heed and use the information provided. Otherwise instructors are wasting their time. If the CAA change the position, the training industry will change the information included in lessons.

From a potential liability point of view, I would be far happier to incorrectly advise pilots to use minima which are more on the safe side of any legal limit than have the posibility that I was advocating or promoting using minima that are less than the established ones.

-----

bpilatus,

If the cloud base was 50ft below the MDA or DA how else could one get down and who is measuring anyway. Surely this activity (instrument approaches) can only be subject to to advisory heights.

You can not depart for a destination where the minima are below what is required unless you have planned for two available alternates where the weather (actual and forecast) is going to be above minima within a good time period round the ETA.

Even if the weather at destination is above minima, you still need to have an available alternate with appropriate weather that you can divert to should you not be able to land at the destination.

To use a destination with no alternate theweather has to be very good - something like VMC from MSA to the airfield.

One can not start an approach or continue below 1000ft AAL if the weather is below minima.

All those issues are deigned to prevent ducking under, multiple approaches going lower and lower and such like which in the past have contributed to accidents.

As for those "who is measuring?" - 6' X 6' X 3' is not a measurment you want to encounter too soon - which you will if you reguluarly duck under.

Regards,

DFC

[Fuji Abound]

DFC - ah well, I give up :)

You obviously believe you are correct so I doubt anyone will persuade you otherwise.

For me what is really worrying is that a pilot can be so dogmatic in his opinion without recourse to the legal regulator.

:confused:

What you should do is 'phone or write to the CAA - but you are obviously not going to.

Anyone else who is interested just write or phone the CAA and talk to Flight Ops - GA. I guess you will get the same answer as I - the whole sentence is a recommendation and for guidance. More to the point the answer I got was not glibly given - leaving you wondering whether the person was sure of their position but came after consultation at the most senior level and was in writing. In my view beyond any doubt.

Oh and insureres work on Friday.

My own view is if I am not sure of the position and there has been sensible debate that makes one question ones earlier understanding go get the answer - thats the responsible stance to take - and if I had been wrong I would have been equally as happy to say so. I have been wrong plently of the times in the past :) .

[S-Works]

Of course Fuji and I could now be accused of being in collusion as we have both bothered to ask the question of the regulator.

Go on DFC try asking them directly yourself, you never know you might even enjoy being corrected......:) :cool:

[Keygrip]

I'm not at liberty to post the individuals name without his permission (and the CAA rules tend to say "No direct information on Pprune"), but...

I used to do many, many IMC rating skill tests and always used the mandatory figures of 500 and 600 as per DFC's argument.

When I moved to the USA - and kept doing those tests - I ended up flying aproaches to runway 05 at lakeland Linder Regional Airport, here in Florida.

As per the mandatory figures of 500 and 600 we ended up doing the go around at just short of two miles from the threshold.

Tampa approach (119.9) went ballistic, every time, as we were screwing up their plans for the guys ahead of and behind us.

During one of the annual school inspections, I asked the man from the CAA for his advice on how to deal with the mandatory figures of 500/600 for IMC rated pilots without screwing up ATC.

His reply was simple, "They aren't mandatory figures - they are only advisory.. The LIMITS for an IMC rated pilot is the same DA, published directly on the chart, as for an instrument rated pilot".

Advisory! (Bluddy good idea - but advisory).

[IO540]

"the CAA rules tend to say "No direct information on Pprune"

I wonder what the thinking behind that is (seriously).

A related subject is why so few manufacturers participate in internet newsgroups (or other types of forum) dedicated to a particular hardware or software product. I am an electronics hardware/software engineer, and have seen such forums fill up with the same questions over and over and over, often degenerating into long debates full of completely useless speculation - yet a single post from the horse's mouth would have settled the matter.

There are a few forums where the manufacturer does participate and they work extremely well, to everybody's benefit.

Obviously the principal in question needs to assign an employee to the task, and the employee needs to have slightly more than 2 braincells, otherwise the participation will do more harm than good. These days, many companies in technology (especially the main players in consumer IT) seem to have problems with placing a single person with >2 braincells into any customer-facing position, but I would not think the CAA would have this problem.

[rustle]

Obviously the principal in question needs to assign an employee to the task, and the employee needs to have slightly more than 2 braincells, otherwise the participation will do more harm than good. These days, many companies in technology (especially the main players in consumer IT) seem to have problems with placing a single person with >2 braincells into any customer-facing position, but I would not think the CAA would have this problem.

2 problems with that (esp. the CAA)

1, people would complain about their money being wasted employing someone to sit on the internet all day;

2, no matter who it was, the topics would still rage forever as people thought of more and more bizarre ways the law could be interpreted.

The only test is in the Courts, and then the only real test is in the highest Court that can/will hear it.

[Keygrip]

I wonder what the thinking behind that is (seriously).

My uneducated guess is two fold - various persons at the Ministry of Aeroplanes will have their own interpretation of the words (just like FFF and DFC). There is a department called "requirements" (used to be called "Policy") that makes these decisions and "the editors decision is final". They would be the only ones that could put their name to it - but in this liability culture of sue for megabucks at the drop of a hat, what would happen if say, Gromit flies his PA28 into an obstacle at 400 feet because he was out of touch with doing ILS's. Lawyer sees post from CAA saying Gromit was entitled to do it when lawyer thinks AIP is mandatory. Who's problem?

Other snag would be how do you know - on a board like this - that whoever is posting as the CAA actually IS the CAA?

[bpilatus]

Rustle, that's the first sound advice I think I have read on this forum. Please get more involved. There are too many people shooting from the hip and putting a hole in another pair of slippers.

[DFC]

Fuji and Bose,

Ok I get the idea.

On Tuesday I make a posting saying that the CAA have agreed with my position but I can't post the reply or name the person who provided the answer.

Do you honestly think that would change your position?

No?.....why not?

Again I say that I have no problem changing my position based on the CAA's change in position. You say you have the evidence - I call your bluff is one way of putting it, and put up or shut up is another :)

----
IO540,

The rules do indeed say - no direct information on PPrune.

Employees of the CAA are not permitted to post on internet forums in their official capacity even in response to situations such as these.

Even if the question was posted in "The Times", a response would have to be sanctioned by management and approved by press officer before being sent for publication.

However, to explain this situation, if you ask me a question and I give you a reply. You then post the answer on PPrune and name me, that is no problem because I would not have provided any direct information on PPrune - you could have been totally unrelated to any debate and I would have no way of linking you to a debate unless you told me you were IO540.

That would not apply however if the information I gave to you was covered by a security marking or confidentiality marking eg "Medical in Confidence", "Commercial in Confidence" etc.

Imagine you as a member of a club ask a question of the CAA and they send you a response with no security / confidentiality marking. Do you not think that you would share that response with other members of your club, perhaps even post it on a notice board. - No problem it is all about improving understanding and safety.

However, it is nice to ask so that the person who provides the answer so that they can be sure they have the authority to make such a statement or pass you onto someone who has or even retract their statement. :)

Regards,

DFC

[Fuji Abound]

DFC

Let me be clear.

I am not prepared to publish the letter I received from the CAA because it was addressed to me, in response to a question I asked. It has nothing to do with whether or not I am entitled to “pin it up”, simply that I consider it discourteous to pin up a personal letter - forget the old text book legal hooey.

You appear to believe I have an interest in who is “right” or “wrong”. The fact of the matter is that I was curious to know the “correct” position. We all enjoy a good debate, and there is a fair bit “tongue in cheek” but I think as professional pilots we also value our credibility - I am sorry that line has been crossed.

For those who are interested and to be absolutely clear I am completely satisfied on the basis of a written reply to my correspondence with the CAA a pilot with an IMCR can legally operate to the same landing minima as a pilot with an IR. If anyone wants to so satisfy themselves as I have said before write to the CAA - flight ops - you will know it is the same person - his surname made me smile anyway. Of course should you get a contrary reply, as DFC suggests, you can always PM me.

.. .. .. And to end on a lighter note - DFC, on this one you were wrong yesterday, you are wrong today, and because the legislation will not get changed tomorrow, you will still be wrong in the morning, but curiously I suspect you will be happier thinking you are right, so it is best left that way!

:) :) :) :)

[IO540]

"The only test is in the Courts"

I agree; however the possibility of somebody getting taken to a Court for descending below the 500/600ft "minima" (IF they were law) is nil. This stuff is completely unenforceable because nobody can prove when you got visual.

A plain PPL could fly in solid IMC all the way across Europe, answering "maintain VMC" to every ATC instruction to do so, and provided he kept OCAS, descend down to say 800ft over the sea at some coastal airport and then call them up for a normal VFR approach. Plenty of people around Europe (where there is no IMCR and the JAA IR is the only option) do this, especially those with modern "permit" type aircraft which can be technically very advanced. You need a good understanding of weather so you don't get caught, and due to the need to do a DIY descent into VMC non-radio and do it safely, it works only for some destinations. And again there is no chance of getting done for it because nobody can prove there wasn't a hole in the cloud.....

Back to the subject of IMCR minima - the CAA has no difficulty publishing a flyer which interprets the ANO in readable language (the well known "public transport summary" one) for the purpose of PPL Cost Sharing etc. This subject is evidently close to the heart of the CAA, as they really go after anybody encroaching on the (more closely regulated and much more CAA-fee-producing) AOC territory. For some bizzare reason they have chosen to leave a lot of other stuff unclarified. I suppose it suits them; more options if prosecuting somebody for other stuff. But I still don't get it; unless the pilot is thick and admits to having flown in cloud or whatever, he cannot possibly get done for it. The 1800m minima for the IMCR is something else of course; very clearly recorded at any towered airfield.

Personally I would not publish personal correspondence either; it's bad manners unless names are deleted. Also, of course, even ifnames are deleted, the man at the CAA will discover the identity of the person who posted it here :O Which will in turn restrict one's ability to speak one's mind on here.

[bpilatus]

There are no bad manners involved. Unless the correspondence says private and personal (which I doubt) there is no reason why the contents can not be made public. It seems unlikely the CAA would not want public information made er.. public, particularly if it means one letter will answer another dozen.

It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not.

[Fuji Abound]

"There are no bad manners involved. Unless the correspondence says private and personal (which I doubt) there is no reason why the contents can not be made public. It seems unlikely the CAA would not want public information made er.. public, particularly if it means one letter will answer another dozen."

As I have said before if you are really interested write to them, and obviously you and DFC will be very happy to post their reply here. It took me three days to get a reply - it really is not that difficult.

I cant quite believe there are certain contributors prepared to comment who presumably have some interest in the matter who cant be bothered to write. One can only guess for some reason they dont want the reply that will be given or they just enjoy a pretty pointless debate.

"It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not."

The legislation was specifically quoted in the reply. Ultimately it is of course their interpretation of the legislation but with an IMCR I would be very happy flying to IR landing minima with the letter from the CAA in my flying bag.

[IO540]

"It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not."

Very difficult to get done for it if you have such a letter.

Unless the writer made an obvious mistake, but here we are talking about legislation so ambiguous and difficult to comprehend that even insurance underwriters' lawyers refuse to give a view on it (yes I have tried that one a number of times, with all the usual subjects plus others).

[DFC]

Let me be clear.
I am not prepared to publish the letter I received from the CAA .............

For those who are interested and to be absolutely clear I am completely satisfied on the basis of a written reply to my correspondence with the CAA a pilot with an IMCR can legally operate to the same landing minima as a pilot with an IR. If anyone wants to so satisfy themselves as I have said before write to the CAA - flight ops - you will know it is the same person - his surname made me smile anyway. Of course should you get a contrary reply, as DFC suggests, you can always PM me.


Here is another important quote;

As these are anonymous forums the origins of the contributions may be opposite to what may be apparent. In fact the press may use it, or the unscrupulous, to elicit certain reactions.

You appear to believe I have an interest in who is “right” or “wrong”. The fact of the matter is that I was curious to know the “correct” position

You say you are an IMC rating holder and you use IR minima. I think that having to use a minimum DH of 500ft and MDH 600ft would restrict your flying. That is one heck of an incentive to have a certain answer.

I have stated many times that I am willing to change my position but that decision will be based on evidence of a CAA statement. As a person who has held an IR for a very long time, I can indeed honestly say that I have no interest in which answer happens to be the final one.

Until then. :D

Regards,

DFC

[High Wing Drifter]

I popped the question to the CAA. I'll post the reply when received.

[slim_slag]

bosex, It's not a letter from your mistress, it's a letter from the bleeding government quango regulator. Publish it or shut up :) If you don't then I shall go back to arguing my case, and the board will not thank you for that..

[S-Works]

argue away......... :}

[bpilatus]

Gentlemen, there might be more important things in life

[DFC]

Wow!

Lost count of the number of posts that have disapeared.

Someone must have posted something untrue or something they should not have not. :D

You'll have to say that all again Fuji. :D

Regards,

DFC

[BRL]

Someone must have posted something untrue or something they should not have not. Well, the boss has deleted a load due to 'Descending into personal sniping' so there you go. This doesn't look like it is heading anywhere at the moment, I will give it a day or so to see where it heads off to.

[slim_slag]

Well, not sure if any of mine went AWOL or not, forgot what I said anyway. Not wanting to ingratiate myself, but I think BRL does a great job moderating this forum.

This doesn't look like it is heading anywhere at the moment, I will give it a day or so to see where it heads off to.bose-x did throw down a challenge, but I cannot be bothered.

So would we agree that the order of importance is

1) Case Law as written by judges
2) Letter of the Law as written by the legislative branch (i.e ANO/CFR 14)
3) Written interpretation from the authorised representative of the regulator (FAA General counsel/don't know CAA equivalent)
4) Advisory document published by regulator (AIM/AIP)

and at about

999,999,999) I've got a special email/phone call from somebody who claims to work for a regulator but I'm keeping it secret but I promise you it overrules everything in 1-4 above.

Even so, does a special phone call really count for much anyway? A CAA official was recently reported to say that you should use the localiser when outside it's guaranteed reception volume, so do we care what the regulator says in personal emails? And even usually persuasive people in the 'prop icing' thread claimed (4) trumped (1).

I still like the 'but' :)

[Fuji Abound]

I would like to clarrify my position one final time.

The reason I have decided to do so is that I agree with BRL - this thread has degraded into personal snipes - I think that is to be regretted.

There has been some very interesting and constructive debate on this thread about whether or not the recommended landing minima for an IMCR are the same as an IR holder with a recommendation that higher minima are used, or whether the higher minima are compulsory.

I admit that I had also understood it was the former. Others disagreed.

It seemed to me this was an important issue that we could all benefit from being clarified and so I telephoned the CAA.

In my view the response from the CAA was first class. Firstly they consulted internally and I believe at a very senior level. They then wrote to me officially setting out precisely and clearly the question I had asked and informed me that the whole sentence - before and after the “but” dealing with IMCR minima were advisory. I then asked my insurance company whether cover would be endangered by operating to IR landing minima where the pilot has an IMCR and not an IR as is the case for some of my group members - they confirmed that cover would not be endangered.

I have been asked to publish the letter I received form the CAA. I am not prepared to do so. Firstly, the correspondence between us was personal. I feel it would be an abuse of that understanding to publish their reply. Secondly, the correspondence from them asks that the reply is not copied to any other person - a tag I had not noticed in the first instance. Some have suggested “publish and be dammed” others have said I am quite entitled to publish not with standing the views I have expressed. I respect but do not agree with your views, please respect mine.

Some have suggested that IMCR holders should not rely on my post. I would agree. Given these are anonymous forums I could be making the whole thing up or I may have misinterpreted what the CAA have to say. Some also say the final test is the courts.

In the first instance you will have to make your own minds up. You may wish to take into account that a number of other contributors on this thread have reported they have received the same interpretation from the CAA. You may also wish to take into account that I have set out clearly the basis of the exchange of correspondence and the reasons why I am not prepared to publish their reply. Most importantly, I and a number of others have made it clear that you only need to write to the CAA yourself and doubtless you will receive the same reply. Should you decide to do so and feel it would also be inappropriate to publish their reply you might like to report your conclusions here.

For those who say whatever the CAA’s interpretation the Courts are the final arbiter, I would also agree - of course they must be. However, I think the Courts would find a letter from the CAA setting out their interpretation of the legislation pretty persuasive.

Finally, and this is not intended as a snipe, just a statement of my opinion, I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others. You are of course quite entitled to doubt their integrity but I believe before expressing those doubts here it would be as well for them to write to the regulator themselves to establish whether their doubts are justified or if they cant be bothered to do so, keep their doubts to themselves!

[DFC]

.........I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others. You are of course quite entitled to doubt their integrity but I believe before expressing those doubts here it would be as well for them to write to the regulator themselves to establish whether their doubts are justified

Yes I did say debate the subject and not the person.

I accept your appology.

Regards,

DFC

[High Wing Drifter]

I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others.
I'm not sure exactly to what this refers to. But in my own mind, I must see confirmation from the CAA before I accept anybodies word on the subject that contradicts my training and the apparent alignment of my training with the wording in the AIP. It isn't a matter of integrity, it could be a matter of interpretation, a matter of how the questions was phrased or anything that I can't think of right now. I still haven't received a reply BTW.

[Fuji Abound]

OK - I take the wind ups in good spirit and will not pass comment :) .

I think pretty much everything reported on PPRuNe is an expression of opinion or interpretation.

As we have seen on this thread even the legislation is a matter of interpretation.

I still find it staggering that there is an interest in arguing a case when there is a clear suggestion that those arguing may be wrong. I would have thought it just obvious that if you have any interest at all you ask the regulator for their interpretation for yourself. You may disagree with their interpretation and that would be an interesting debate. You may believe that a contributor has misrepresented the position for any of the reasons suggested but wouldn’t you just want to make sure? In that way the whole discussion is moved on rather than becoming a pretty pointless argument of "I am right, I don’t care what any one else says, and I will go one telling every one I am right even if that results in more new pilots also believing something for the wrong reasons".

I suppose one of the reasons I feel so passionate about this is I always remember one of my instructors telling me something that was fundamentally and worryingly wrong. As many might I never the less believed he was right for a very long time. It was only through PPRune and doubts raised by a contributor that I finally wrote to the CAA for clarification. I would reiterate that I accept they are not the ultimate authority but I am far more comfortable if I have a letter from the CAA which sets out to me clearly their interpretation of the position particularly when it seems to me there is obviously some doubt.

Finally I think it is helpful to serious debate if a quote is to be made that it is in context. My point I thought was quite clearly put - it is pointless to the debate that we say a contributor might just be misleading everyone, surely far better to either set out why we disagree (and I appreciate this has been done on this thread in terms of the interpretation of the legislation) or in so far as the case in point goes report that we have written to the regulator and a contrary opinion has been received. Simply to say I don’t believe what a contributor reports would seem pretty pointless unless you just enjoy a good wind up!

High Wing Drifter has "popped the question" and I think it will be far more interesting to learn what he has to tell us when he gets a reply.

[rustle]

I then asked my insurance company whether cover would be endangered by operating to IR landing minima where the pilot has an IMCR and not an IR as is the case for some of my group members - they confirmed that cover would not be endangered.

It is the unqualified sentences like those above that make me think either the question was wrong or the answer is. :8

If your insurer actually said/wrote what you wrote above, where do they differentiate the min 1800m viz requirement for an IMC holder as opposed to the min 800m viz for IR-SPA?

[bpilatus]

It is quite easy to get a response to support ones preconceived notion/s. Surely though it's all a bit academic. Private pilots shouldn't be pushing their luck nor should they be endangering the lives of their passengers with such irresponsible behaviour.

[IO540]

That's a good comment, Rustle

Unfortunately for the person asking, it is possible to obtain all kinds of replies from regulatory bodies, if you ask the right (I mean wrong, of course) question.

(It's a bit like the patent office - you can get a patent granted on just about anything so long as it is reasonably specialised. The examiner will probably not spot that there are a dozen cases of prior art, all known to anybody actually working in the business.....)

Unfortunately for the person answering, the answer could get them into serious trouble if the person asking uses it in his defence one day. And he can certainly do that.

That's why, when I ask questions on something like this, I always go to a lot of trouble to very clearly state the regulatory background and why I want to know the answer. Then, when the answer comes, you are much better able to rely on it, should you need to one day.

I have thus obtained affirmative written answers on:

CAA: The IMC Rating is not limited to any aircraft reg (and is thus valid in an N-reg if the FAA doesn't mind)

CAA: The removal of the "sight of surface" requirement, which you get when you get an IMCR, is valid worldwide, even though the IFR privileges of the IMCR are limited to the UK

FAA: The IMC Rating [within its own limited privileges, and in an N-reg] is equivalent to the FAA IR

plus some other very interesting stuff...

Looking at the way Fuji writes I am pretty sure he did write his questions in a non-misleading manner.

The practical bottom line is that approach minima are unenforceable, because nobody can prove when the pilot got visual. It is in other more readily visible areas where the CAA might wish to go back on a previous written reply saying it is "OK". I believe they have done this, or rather the DfT did it for them, in a particular situation last year in connection with the old Article 115, but I won't say.... :O

[Mixed Up]

The practical bottom line is that approach minima are unenforceable, because nobody can prove when the pilot got visual.

But "proof" isn't required to gain a prosecution - "proof beyond all reasonable doubt" is. Three witnesses, including Wing Commander Gordon Prentice Rtd out walking his dog, the "I've never seen anything like it in my thirty six years of aviation" pillock in the tower and the "I don't rate IMC's" IR-rated pilot who landed his Commanche twenty minutes later would be all this required.

[DFC]

OK Fuji, I have it in writing that the CAA's position on this matter is the same as my position.

End of debate. :rolleyes:

Regards,

DFC

PS: IO540, did you hold an IMC rating when you started training for the FAA IR? If you did then why did you need any training as you already had an equivalent rating. You should have saved yourself a lot of money and just asked for the paperwork to be issued on the basis of the equivalent rating. :D

What do you think the FAA would say if some person in the CAA said you could fly an N reg PA28 with a microlight licence? I think that they would be asking who gave the CAA authority to decide who can fly US registered aircraft and also asking when the FAA can start saying who can fly G registered aircraft.

[Fuji Abound]

OK DFC that is very helpful to know.

Just so we are all clear you are saying that you have written to the CAA and they have replied to you in writing that the landing minima for a pilot with an IMCR is 500 feet for a precision approach and 600 feet for a non precision approach. In other words these are legal minima and not recommended minima.

Perhaps you would confirm I have understood correctly that this is what you are saying the CAA have confirmed they are in agreement with?

Maybe you would also like to PM me and let me know who replied to your letter and I will PM you who replied to mine. Doubtless we can then jointly take up the matter with the CAA together with Bose-X and establish why their interpretations conflict.

[bpilatus]

(It's a bit like the patent office - you can get a patent granted on just about anything so long as it is reasonably specialised. The examiner will probably not spot that there are a dozen cases of prior art, all known to anybody actually working in the business.....)


That's why, when I ask questions on something like this, I always go to a lot of trouble to very clearly state the regulatory background and why I want to know the answer. Then, when the answer comes, you are much better able to rely on it, should you need to one day.

Firstly, my experience is that patents aren't granted quite so freely and attention will no doubt be focussed by the opposing parties who hold similar patents.

Secondly, have you ever had to rely on any of this 'aviation' knowledge which you are gathering? Indeed has anyone writing on here ever had to quote chapter and verse in their defence? Presumably things change and interpretation alter over time, with change in policy and case law which suggests that it is a moving target.

[FullyFlapped]

I have to say, I think this is incredibly sad. Fully grown men (I presume) banging heads and trying to score points rather than co-operating over trying to establish the truth of the matter - and to all of us who have an IMC, and are current, this matters - a lot. I sincerely hope DFC does what Fuji has asked and shares names - but to be honest, I'm not holding my breath.

For what it's worth, I disagree with DFC's position on the "magic sentence" : the lawyer in me believes that the sentence reads that the additional heights are advisory - but DFC would say that I have an IMC, so I'm therefore biased.

I also disagree (bear with me) with Fuji's statement that :-
I finally wrote to the CAA for clarification. I would reiterate that I accept they are not the ultimate authorityWhy ? The CAA are the undisputed fount of UK aviation knowledge in most people's eyes. Hauled into a court, I would unhesitatingly argue that the "test of the reasonable man" would confirm this, and that basing my interpretation of a very badly worded sentence on an authorised and verified source within the CAA would seem an extremely sensible thing to do !

Anyway, I continue to watch this thread in the hope that there is an outbreak of common sense before long. I'm afraid, however, that with the stances adopted by some of the contributors, this is looking increasingly unlikely ...
FF :(

[drauk]

Surely though it's all a bit academic. Private pilots shouldn't be pushing their luck nor should they be endangering the lives of their passengers with such irresponsible behaviour.

I think this is the most ridiculous statement in the whole thread. For a start, it's loose talk: a "private pilot" can have an instrument rating - is the suggestion that unless you fly commercially you can't be skilled enough to use a 200' DH? And even leaving that aside, surely it doesn't take a genius to figure out scenarios whereby it is not at all academic - i.e. that the ability exists by virtue of training but the rights by which one happens to be flying a particular approach is that granted under the IMCR?

Comments like this represent elitist nonsense which in turn helps only to stifle General Aviation in the UK.

[DFC]

What I did not do was send an email that turned into a phone call that resulted in a letter that included an email confidentiality clause. :}

The students will continue to be taught the same correct safe information that they have been taught since the IMC rating came into being.

They will also be reminded as I have just been that the CAA's written position clearly says that the IMC rating is not designed for prolonged IMC flights planned to be terminated with an approach at an aerodrome where the weather is at minima. The IMC rating provides training in a basic skill designed to get a pilot out of troubble and is not a substitute for an IR.

Not (quite) a quote of course.....would not do that now would we.....but it is what the CAA have put in writing!

Why have the privileges in the ANO in that case? Now that is a question I also ask! :confused:
---------------

To get back to more important matters,

What does everyone think of a proposal to make the following the legal and clearly expressed minima for IMC rating holders in current practice;

1. DA(H) to be not lower than IR published DA(H) plus 300ft
2. MDA(H) to be not lower than IR published DA(H) plus 300ft
3. Visibility/RVR to be published IR minima + 1000m
4. Take-off minima to be ceiling = IMC approach DH+100ft and Vis / RVR 1800m or the approach Vis/RVR if higher
5. Requirement to teach and in practice to comply with the increased planning minima for alternates.
6. IMC rating limited to Single engine unless test done in Multi engine.

As an example, the result of the above at Blackpool runway 28 would be;

ILS DME = DA528, DH 500, RVR 1800 / 2000m ALS out
LOC DME = MDA 700, MDH 672, RVR 2200m / 2500m ALS out
Circle to land south of 10/28 = MDA 740, MDH 706, Vis 2500m
Circle to land = MDA 880, MDH 846, Vis 2500m

Take-off minima ceiling 600ft and Vis/RVR 1800 with the ILS available.
Take-off minima ceiling 800 and RVR 2200m if the GS is U/S. etc

Very easy to work out from the charts. Easy to apply.

More importantly, it links departure minima to that required to return if something fails eg alternator failure. This is something that very few IMC rated pilots seem to take into account or understand. It also allows some margin for efato in a single.

I know that some would not be happy with the higher minima but the safety case would easily show that such an easily applied system would be more safe and thus an improvement on the current system while any regulatory impact study / industry consultation would show that based on current teaching and CAA advice, there would be no adverse effect on safe operators.

Regards,

DFC

[IO540]

Time to stop feeding the trolls on this thread, I think.

[Fuji Abound]

"I have to say, I think this is incredibly sad. Fully grown men (I presume) banging heads and trying to score points rather than co-operating over trying to establish the truth of the matter - and to all of us who have an IMC, and are current, this matters - a lot."

I am so glad at least someone is prepared to take a sensible stance! Thank you.

I don’t suppose I will get the PM from DFC anyway.

However it would seem that DFC has received in writing contradictory advice from the CAA.

I have therefore written to them again asking them how the reply they sent to me can be promulgated. I shall let everyone know what reply I receive.


"Why ? The CAA are the undisputed fount of UK aviation knowledge in most people's eyes. Hauled into a court, I would unhesitatingly argue that the "test of the reasonable man" would confirm this, and that basing my interpretation of a very badly worded sentence on an authorised and verified source within the CAA would seem an extremely sensible thing to do !"

Actually FF I do agree with you. As I think I said previously in the event of proceedings on any matter, not just this, I suspect the judge would find a letter from the CAA as pretty persuasive - moreover, you cant quite imagine the CAA mounting a prosecution against a position they had outlined.

So far as the reminder concerning the design of the IMCR is concerned this is all pretty dull - I made this point pages ago and we all know the CAAs stance on this one. I agree with their stance and have always said so. That however is not the issue.

Some other examples that might be equally justified:

The PPL is not designed from a six hour cross country trip through Europe,

The driving license is not designed for the just qualified driver to do six hours on European motorways,

and most importantly,

The IR is not designed for a pilot who is not current to undertake the same flight as a pilot with an IMCR who is very current.

What really must not be forgotten in all this is that the IMCR was originally introduced by some very wise people who realised that in this country a private pilot is safer if he can undertake training ro enable him to fly in marginal weather. I think we all agree the training is not as comprehensive as for a pilot with an IR. We may even agree there is a big disparity between the training for an FAA and our IR in so far as the private pilot is concerned.

However training can mean very little in terms of developing skills, and I think the CAA rightly recognised this in drafting the legislation and supplying the interpretation they have and are able to see past the vested interest of some instructors and the training industry.

Why.

Find me a doctor, a lawyer, a dentist, or a Corgi gas fitter who is not better at his job than when he passed his exams. Yes I know there are a few that are worse! However in the vast majority of cases they are far better because their skills and practical application has improved with use and currency just as is the case for an IMCR holder who uses the qualification regularly. In fact be in no doubt they are significantly better than some IR holders I have flown with who are not current!

I recall well when a pilot with 600 hours to his credit (I think it was 600 hours) enjoyed some significant exemptions with regards IR training. It was in my opinion a retrograde step when that was changed.

Not only do I not agree with DFC proposed changes but I have a few of my own.

Firstly the legislation works perfectly well as it stands. In my experience instructors are very good at emphasising the need for caution to IMCR pilots. Secondly when pilots end up flying hard IFR sectors it is for one of two reasons - they have misinterpreted the weather or feel they are sufficiently current to undertake the flight. I don’t have proof, but how many IMCR holders who are current do you hear getting into trouble and how many accidents can you point to? (And I do read all the published accident reports every month). For those that have misinterpreted the weather, unfortunately that is always going to happen - it is the biggest reason pilots get into trouble and has nothing to do with whether or not they have a current IMCR or a lapsed IMCR.

My own proposals are that a pilot who has an IMCR and 600 hours total time of which at least 100 hours are instrument time, and of which 30 hours are instrument time in the last twelve months should on test by an approved examiner be entitled to be granted an IR restricted to private use. Students would be recommended to undertake a minimum of 10 hours further instrument training before the test but with an absolute minimum of 5 hours further training. If they did not undertake the further recommended training but past the test they should still get the rating!

[IO540]

Excellent proposal, but would never get past JAA. And an IR which doesn't get past JAA is going to be worthless.

There is a JAA committee working on a "private IR"; they are still debating whether to cut down the ATPL ground school by 10% or 20%... a complete waste of time.

The IMCR would never come into existence today, either. It dates from another age altogether.

[OVC002]

"Students would be recommended to undertake a minimum of 10 hours further instrument training before the test but with an absolute minimum of 5 hours further training"
Would that be a recommended absolute minimum or a mandatory absolute minimum::}

[Julian]

There is a JAA committee working on a "private IR"; they are still debating whether to cut down the ATPL ground school by 10% or 20%... a complete waste of time.

They should scrap the ATPL exams with respect to obtaining an IR as they are a complete waste of time.

Introduce a single exam specifically testing the pilots knowledge of operating under IR conditions and not how many fire extinguishers you need on a 747!!!

Julian.

[Fuji Abound]

OVC002

Glad you spotted it - just me having a little fun -sad I know.

IO540

Sadly you are correct and as cynical as I am.

[IO540]

Julian, I think the FAA thought of that one first :O

There is exactly zero prospect of getting a "private IR" out of JAA. It may be only when EASA takes over FCL, and if some of their officials' statements (along the lines of a "straight swap" from an FAA IR to a JAA IR) come true, that anything might happen. Even then, it will happen only as a result of the growing N-reg activity in member states.

[Julian]

Yep, see someone has already done all the hard work them - all they have to do is implement it :}

[DFC]

"and to all of us who have an IMC, and are current, this matters - a lot."...............
Some other examples that might be equally justified:
The PPL is not designed from a six hour cross country trip through Europe,
............
and most importantly,
The IR is not designed for a pilot who is not current to undertake the same flight as a pilot with an IMCR who is very current.

What really must not be forgotten in all this is that the IMCR was originally introduced by some very wise people who realised that in this country a private pilot is safer if he can undertake training ro enable him to fly in marginal weather.

You said you had no real interest in which way the answer went. Why not then agree with a system that in effect puts in place an easyily understod method for calculating minima which also covers some areas missed currently. Are you really that reliant on IR minima that such proposed minima would cause you a problem?

The PPL is designed to enable a pilot to plan for and having done all the planning exectute a round the world trip VFR. The JAR sylabus covers all the international standards etc and if that is not covered then the problem lies with the teaching of the sylabus rather than the licence itself. No one says that a UK PPL needs to know the requirements for flying in Canada but they should know the worldwide AIS system and how to obtain the information they need.

Talking about some current pilot being of a better standard than an non-current one makes no difference. You have to compare like with like.

If one was to follow your ideas with regard to the use of ratings and licenses, you would no doubt support the removal of all restrictions to minima and start flying to CAT 2 minima.

As for the reason why the IMC rating came into being - it certainly was not to permit pilots to fly in marginal weather.

No safe pilot will ever intentionally put themselves in a situation where they fly in marginal weather. - That is why it is called marginal!

Regards,

DFC

[IO540]

I promised to not feed the trolls but I just don't have enough willpower :O

The PPL is designed to enable a pilot to plan for and having done all the planning exectute a round the world trip VFR

:O :O :O :O :O :O :O :O :O

Yeah, right..........

[Fuji Abound]

"No safe pilot will ever intentionally put themselves in a situation where they fly in marginal weather. - That is why it is called marginal!"

Marginal for the VMC pilot.

"Why not then agree with a system that in effect puts in place an easily understood method for calculating minima which also covers some areas missed currently."

In my view the present system is very easily understood with may be the exception of redrafting the "but" clause more clearly. I see no evidence for restricting the existing privileges.

"The PPL is designed to enable a pilot to plan for and having done all the planning execute a round the world trip VFR."

You got to be joking! I must ask the next newly qualified PPL to plan and set off on a trip to the south of France.

"Talking about some current pilot being of a better standard than an non-current one makes no difference."

It makes every difference in the world. I fly with a pilot who has 10s of thousand of hours, ATPL multi crew and single IR - he wouldn’t fly to IR minima and nor would I with him at his present level of currency and he tells me so every time.

"If one was to follow your ideas with regard to the use of ratings and licenses, you would no doubt support the removal of all restrictions to minima and start flying to CAT 2 minima."

With respect you are missing the point. There are quite different skills in play flying to CAT 2 notwithstanding the different interplay with the FDE to enable the operation to be performed. One would therefore expect wanting to ensure a demonstrated ability on type.

There is no difference in skills play or equipment in flying to a 250 foot minima in stead of a 500 foot minima, although I would of course agree the tolerances must be more precise. In my view any instructors who during an IMCR who does not ask the pilot to demonstrate an approach to IR minima are negligent. I don’t mean negligent in law but negligent because they should know they are (or aren’t capable) of flying to minima. Unfortunately I cant guarantee with the present quality of forecasting and with all the diversion planning in the world that a pilot with an IMCR having departed with the comfort that minima will be above 500 feet, will never in fact find they are lower - can you? Every time I fly a practise approach it is to minima - every time. Every time I fly with any one else for a practise approach it is to minima (unless of course it goes wrong or they are not yet at that stage!)

[Ni Thomas]

What does everyone think of a proposal to make the following the legal and clearly expressed minima for IMC rating holders in current practice;
1. DA(H) to be not lower than IR published DA(H) plus 300ft
2. MDA(H) to be not lower than IR published DA(H) plus 300ft
3. Visibility/RVR to be published IR minima + 1000m
4. Take-off minima to be ceiling = IMC approach DH+100ft and Vis / RVR 1800m or the approach Vis/RVR if higher
5. Requirement to teach and in practice to comply with the increased planning minima for alternates.
6. IMC rating limited to Single engine unless test done in Multi engine.
DFC

1.Disagree
2.Disagree
3.Disagree
4.Disagree
5.Agree (with reservations)

Personally, I keep very, very current with my IMC allowed IFR flying. Consequently, I would be extremely annoyed, dismayed and frustrated to be placed in a position whereby your suggested NEW, and in my view, wholly unwarranted minima, were ever introduced and had to be observed.
I also consider it disengenious of you to solicit views in this manner. The results would be open to potential abuse. What where/are you going to do with the results? Bolster your arguements? Use them to 'persuade' the CAA to change the law?
Sorry, but I'm disappointed in you.

[DFC]

Fuji,

Marginal VMC is Marginal VMC for any pilot.

You got to be joking! I must ask the next newly qualified PPL to plan and set off on a trip to the south of France.

If they have been properly trained they will already know that they need to consult the French AIP and will already know what the various airspace classes mean and the requirements to file a flight plan, how to do so (or where to find that tinformation) and when an ATC clearance is required and when lifejackets / raft is required (or where to find that information) not to mention how to navigate visually. What else is there for the basic PPL flying VFR in good weather?

I don’t mean negligent in law

So that means that they are not negligent then.

Unfortunately I cant guarantee with the present quality of forecasting and with all the diversion planning in the world that a pilot with an IMCR having departed with the comfort that minima will be above 500 feet, will never in fact find they are lower - can you? Every time I fly a practise approach it is to minima - every time. Every time I fly with any one else for a practise approach it is to minima (unless of course it goes wrong or they are not yet at that stage!)

That is a disturbing statement. Mostly because you clearly state that having set a certain minima at the planning stage you will fly lower if the weather is worse than planned.

The point that is being missed because it is not well covered during the IMC course is that if you are flying to an airfield and have a planned minima of 500ft / 1800m and the actual and forecast weather seem to indicate that this is possible then your alternate must have a higher margin above the minima there so that you are unlikely to end up with both airfields below minima.

If the minima are less than you planned for before you start the approach or pass through 1000ft, you don't continue the approach - you hold for improvement or divert. The whole reason for the approach ban is to prevent pilots doing exactly what you say - arriving at 500ft still in cloud and making a decision to go lower just to get visual.

If you set off to a destination that is below minima but you expect it to improve, you need two alternates which are going to be above minima - simply again so that you do not get caught out.

I know much of it is down to training and unclear instructions but many of the things you say go against all the normal procedures for IFR IMC flying and it only bolsters the point that IMC holders are not equipped for such operations.

Perhaps pilots place too much reliance on the forecaster and met observer. The rules require that you consult the available information. However the interpretation and use of that information is up to the Captain. The forecaster will never say don't fly today. That decision is up to the aircraft commander.....so don't try to pass the buck if the decision made is incorrect.

Each year, I divert on occasions because the weather is below minima. What professional pilot does not. Sometimes that diversion is initiated long before destination. It is less usual for an approach to go missed and then divert because of the weather - wastes fuel, pax moan and you end up at the alternate anyway without the transport which could have been arranged had one planned in advance. I have never and never will arrive at the minima planned and not being visual try a bit lower.

Yes we practice approaches and will do them to minima - the minima we will use for real. No point in saying that you will use a DH of 500ft in anger and spend a taining hour bashing the ILS and missed approach with a DH of 200. Two reasons -
1. The missed approach profile you are acheiving in training is not the same as the one you will end up with in the real situation - you will be higher, will reach the altitude restrictions quicker and will be further back from the runway when you start it.
2. If you use look up at 200ft and take in the outside picture, this will not be anything like the picture you will get at 500ft again because you are in a different location at a different height.

-----------

Ni Thomas,

The reason for making the suggestion in public was to permit discussion and objection from people. I do not know how a proposal to change the system could bolster a debate about the current system.

What do you suggest for items 1, and2? If you say IR minima would you support a further training requirement to acheive this?

If one uses the 500ft/600ft absolute or plus 200ft whichever is higher then one is in the position of using minima that put you closer to the obstacles when they are significant than when they are not. i.e. Approach to a runway in a flat desert has a MDH of 300ft and the pilot uses 600ft. Down the road there is the same type of approach with some nice big hills, trees, pylons etc and an OCH of 500ft so that pilot uses 700ft. This means that the more challenging the approach in terms of obstacle environment, the closer the IMC holder gets to those obstacles while the IR holder has a consistent approach to such situations.

That is one area that needs to be looked at regardless of which view one holds.

Remember point 3 comes about because of the minima in 1 and 2. You can not use a minima of 600ft and expect to see the runway environment when you are 2nm from the threshold and the vis is 1nm. That leads to flying level at 600ft MDH and trying to spot the runway which will happen at less than 1nm which puts the aircraft in an position of being too high to land and too low to circle!

I am very surprised that you disagree with item 4.

As you are aware, many IMC pilots depart in weather that may be 600ft ceiling and 1800m..........but they forget to check that they will be unable to return and will not have planned for what to do. They have made allowance for an engine failure......but what about a suction failure shortly after going IMC at 600ft...........not great if IR approach minima are MDH700 and the nearest diversion is 1 hour away.

As to what the results will be used for? This is simply using a good oportunity to get a straw poll of what people would think of having to use certain minima.

Regards,

DFC

[drauk]

DFC, can you cite any sort of evidence that there is a problem with the current arrangements? One doesn't hear much on the various online forums about IMC-only rated pilots getting themselves in to trouble though I don't know if that means it does or doesn't happen.

What I do know and what you seem to be missing is that there are quite a lot of pilots around who legally have to operate within the confines of the IMCR but who have been trained to operate to IR minima, namely all the people with FAA IR who don't fly in N-reg planes. If one interprets the infamous sentence as a recommendation rather than mandatory, everybody (except you?) is fairly happy - as stated elsewhere the IMC training and lots of published information makes it clear it isn't designed for planned continued operation in IMC so inexperienced instrument flyers tend towards the higher minima whilst the FAA IR crowd can operate to the minima to which they have been trained.

[Fuji Abound]

"Marginal VMC is Marginal VMC for any pilot."

Did you miss we are not discussing VMC?


"If they have been properly trained .. .. .."

Not many flying schools will let a PPL go cross channel without a cross channel check - that is just your starter for 10, I suspect we can think of a host of reasons why a newly qualified PPL should hesitate before setting off for the south of France. I leave others to put forward a few suggestions!!!!


"So that means that they are not negligent then."

Afraid not.


"Mostly because you clearly state .. .. .."

I did not clearly state any such thing.


"so don't try to pass the buck if the decision made is incorrect."

I am not - however as IO540 said on another thread clearly there are some pilots who think they know more than professional forecasters who have spent their lives forecasting the weather and have more data available than we. I am very happy you second guess the forecasters, I tend to rely on their forecasts unless I have a very good reason for not doing so.

You should take a look at how the commercial forecast decision making process operates and you will have a better appreciation of the issues.


"but many of the things you say go against all the normal procedures for IFR IMC flying and it only bolsters the point that IMC holders are not equipped for such operations."

I do not even remotely see the wisdom in a newly qualified pilot setting off for the South of France, so we clearly do not agree on normal VFR procedures and so we have fundamentally different views of what happens in the real world and I suspect we have fundamentally different backgrounds which impact on our respective views.


Drauk - I too would love to see some evidence. So many of the regulatory changes come from an over zealous and protectionist training industry who are more concerned with protecting their own egos or commercial advantage than from any basis in quantitative evidence that the changes are justified. This thread is a very good example where it is quite clear the industry (in some cases) is prepared to go on teaching bad practices and incorrect air law. If you wish to change the legislation start by setting out what problems the legislation is currently causing and then what changes might be introduced to solve those problems.

In the day job fortunately the over inflated egos have all but disappeared but it is still rife in the training world of the PPL industry.

DFC would clearly like the legislation clarified, and he is absolutely right - I believe it has been, but others do not. I hope it will be because at least those whose teaching is based on incorrect assumptions can correct their training - which must be for the good of all concerned.

Once the position is clear, there may be those who consider the minima too low. They will have to produce evidence to support their argument and even then there remains a fundamental chicken and egg problem - if the legal minima had been correctly applied and taught during training would any of the problems that they might identify actually exist. Until and unless those conditions can be satisfied any desire to change the legislation can only be based on the most dubious motives!

[DFC]

I do not think that the means by which one obtained a rating should change the way in which the rating is used.

Currency, personal ability, aircraft, environment can all provide factors that change the minima used.....but the amount of training one needed to (or decided to) complete in order to obtain an IMC rating should not be a factor.

Are you suggesting that we should have a multi tiered IMC rating? Get the rating with 15 hours training use certain minima, fly more hours to obtain the rating and have different minima?

How would you differentiate between the pilot who struggled and just got there in 50 hous training and the pilot for who it was a breeze but did lots of extra training that is not part of the sylabus?

Perhaps there could be a two tiered system - 15 hours training - high minima, 50 hours training and some exams - IR minima with the posibility to use the 15.

Of course the FAA IR holders will not rely on the IMC rating for long as once they have gained the required experience (75 hours IFR) they will go for the JAA PPL/IR so the pilots in that group are only going to be there for a very short period if they keep current and have any sense.

Regards,

DFC

[Fuji Abound]

Yes, DFC, but with respect you are still missing the point.

Whether the IMCR training is adequate to enable the pilot to embark on what he is legally entitled to do is debatable - IMO it is not. It is no more or less debatable than for an IR. Would you put a newly qualified ATPL in command, have you seen what some of them get up to when an approach goes wrong? No of course you would not. They have the protection of multi crew operations and the commanders experience.

In the same way you would IMHO no more want to send the newly qualified PPL off to the South of France the day he qualified and fortunately the vast majority would not go.

I know I keep coming back to the analogy but how many people felt uncomfortable the first time they drove on a motorway or drove abroad.

An IMCR is a license to learn. I find no evidence that the vast majority treat it otherwise. In fact fortunately the accident rate for pilots with IMCRs using their rating appears very low. The training is very good at emphasising - “recognise the boundaries of your training and experience”.

For me the evidence that the level of training is adequate is reflected in the accident statistics in the same way that there is no evidence of a problem with the landing minima being recommended.

As you know IR training sets out to achieve a different purpose. The emphasis has always been far more on procedural flying seeking to get the pilot to a level where he should be capable of hard IFR sectors within the system and be substantially ready to use that knowledge to its fullest extent.

No one has ever pretended the IMCR seeks to achieve the same goal. Its aim is to ensure the pilot is able to fly competently on instruments in benign conditions and without anything substantially going wrong. It is a license to learn and IMHO achieves this goal very well. For those who are prepared to learn it provides an achievable means of “serious” and safe IFR operations.

Consider the actual life of the average PPL - he qualifies, he is legally entitled to fly to the South of France but he doesn’t yet have the experience to do so. His longest flight was one of his cross countries around the local home page - all reasonably familiar territory with procedures to which he is accustom. At some point he goes with a friend or instructor cross channel. He has done a bit of instrument training of course but he has never been over water before. He has hopefully been up on poor viz days but the ground has always looked like the ground and the sky the sky and of course there is a horizon in between. You get the picture. Having got that under his belt he has “qualified” to go cross channel and his local rental will tell him so. It is not another rating - he was always legally entitled to do it. France beckons and of course he goes to L2K - no instructor now. Oh, the language is a bit different, no one mentioned that during his training, and the ATIS is in two languages, good thing he listened to the whole recording. The procedures are a bit different too - these French seem terribly laid back. Has he moved up another step on the ladder? Finally a longer trip beckons. He keeps on waiting for the right weather. Finally it looks good but it is a five hour trip with a stop on the way. The controller wants him to report 50N, what is that all about, something about ORTAC, where has London info gone, no one wants to talk to me(!), oops there is some high ground, my training around London never mentioned that, a bit of rotor, I read about that but it seems different in the flesh, oh and the vis is looking a bit dubious, that certainly wasn’t forecast, better sort out a diversion on the hoof. You get the picture. He has moved up another step.

So what ratings has he got now? Ah but he is still a “mere” PPL, unofficially cross channel, high terrain and foreign operations rated. All in the PPL syllabus - I don’t think so!

Move on and he gets an IMCR. His instructor taught him to fly IR minima - well at least he has seen that and understands the potential problems of not dealing with that accurately - he now wishes he had similarly been taught about the problems of that short hop across the channel . SIDs - he has heard of those, never did any, and he is back to his PPL days cross channelling again. Ah, his good old instructor suggests getting a SID or two under the belt, and after a while he is pretty comfortable with that - another step up. And so we could go on.

A license to learn - a good license, no need to change anything, no multi tiered system, any more than the PPL is multi tiered.

[IO540]

The problem with comparing the IMCR with a Euro IR is that the two were meant for very different things.

The IMCR was designed to be of real use to private pilots. Most of these are "old" people - few people under 40+ have the money to do any real flying, so there aren't complicated exams for example because few people in that age bracket would be able to do them, due to lack of time.

The IR, as formulated in Europe, has always (well as long as anybody I know can remember) been designed to be study material for young men with plenty of time, very little money, who want to be airline pilots.

The FAA IR misses out vast swathes of knowledge but covers everything that a private pilot needs to fly IFR in the same airspace as the big stuff. Anything extra (like knowing which buttons in a Citation do what) is dealt with by a Type Rating, which is how it should be.

[DFC]

Fuji,

You would not believe what some "ATPLs" try to do! There are two types of ATPL holder;

The ones who "qualified" under the old CAA system having flown nothing more than a C172. Probably what you would call a licence to learn; and

The ones who obtain one under JAR with lots of multi pilot time required.

Will one be better than the other....possibly but not always the one you would expect! However, they both have to operate to the same minima.

If there is an ATPL in the right seat, and they are the handling pilot for the sector, there will be occasions when the Captain must according to the rules do the approach / landing regardless of their ability. Depending on the make-up of the crew, the minima may be higher for certain airfields where CAT2 or CAT3 minima are available. Note I said regardless of ability. The reason is safety.

Ask a current co-pilot what they would do if their allowed minima were 500ft but the Captain suddenly decided to use another operator's minima of 400ft because they were not visual at 500? I don't think that you as a passenger would like to fly with that type of individual.

As for accident stats; Here is a widely distributed quote from the CAA:

All but one of the pilots killed when they lost control in IMC were flying in instrument conditions without an Instrument Rating. This is extremely unwise to say the least. Possibly they believed that their IMC rating was sufficient........

Unless you use very high minima indeed (CAVOK), you can not reguluarly depart for a flight that involves an approach in IMC without having a probability of prolonged flight in IMC.

Filing to depart IFR and not being able to fly the SID due to lack of ability, lack of currency or lack of training is simply not acceptable. Does anyone seriously expect ATC to put in extra work to accomodate such situations. Furthermore does anyone expect that the other aircraft behind should be delayed while ATC provide some extra service to the IMC holder? ATC should tell the pilot to return to the apron and wait until a VFR departure becomes available.

Same goes for having to hold in IMC for an extended period - something that can happen on any arrival in IMC. Does anyone think that the IMC rating holder who can not fly a hold should get vectors to final while everyone else holds?

Should IMCrating holders who do not understand the approach ban clutter the arival pattern with approach and go-arrounds when it is below their minima?

Or do IMC holders who can not join the arrival route or standard holding patterns via class A expect ATC to give them a vector ahead of all the other inbounds?

The objections to minima that reflect the average ability, the statements of ducking under chosen minima when not visual, the expectation that one can file and fly IFR without the ability to fly in IMC for long periods in "challenging conditions" in the UK (which is all winter and much of the "Summer"!), the lack of knowledge regarding diversions including planning to return after a departure all go to paint a very poor picture of the average IMC rating holder.

If people what the IMC rating to survice the oncoming onslaught in terms of ATS service providers, airspace changes and EASA regulation, they have to project the best image and that is not being done currently.

The IFR flying environment in the UK has vastly changed from the days when the IMC rating was conceived. many regional airports that only had a bit of an SRZ and few commercial flights now have class D and a steady stream of IFR inbounds via the airways. Many other airfields are not only busy but their standard holding pattern(s) are in Class A airspace.

As little as 10 to 15 years ago certain aerodromes did not permit IMC holders to fly IFR in their airspace. Perhaps it is time that the CAA looked at aerodromes in Class D and the effect IMC holders can have on the standard IFR traffic loadings. Then perhaps some aerodromes could be put back on the list of aerodromes where IMC holders can not make an approach except in an emergency.

As for the driving comparison.........does france publish an equivalent of the AIP for Drivers and do many drivers actually check the rules before flying in France? Do you fly on the left of the centerline in England and to the Right in France? NO. Bad comparison!

-------

IO540,

I wonder how people can have time to complete say 60 to 70 hours in what has to be benign good VMC weather doing a PPL with lots of exams but then think that it is impossible to find the time to do the IR with probably far less flying with less requirement to match bookings with such good weather and the posibility to complete the majority in a sim not to mention far fewer exams?

Excuses such as those will not get the system changed.

Any mini-IR would have to comply with ICAO requirements or at least satisfy the requirements to pass a safety case showing that it would not have any effect on regular IFR flights in the system........that problem will always bring us back to the current IR.

If the IMC had more clearly laid down minima which were easily applied without having to be an expert reader of the ANO and the use of the IMC rating was not open to the critisims I highlighted above then it is possible that people from places like Austria, Germany, Italy, Spain and Ireland would see an advantage. Currently all they see are the critisims above and images of pilots flying in IMC waiting to be the next accident. Not an image that is going to make progress in Europe.

Has anyone ever done what the CAA advise and asked if they can use the IMC rating to fly IFR in any country outside the UK?

Regards,

DFC

[Fuji Abound]

DFC

I have enjoyed our debate which has become a bit one to one.

Whilst I have taken on board some of the issues you raise, I have to say I dont understand a lot of the points you make, particularly in the last post.

I beg to disagree with your views and I am simply not convinced that they are born from any real world application of the issues.

I also dont think you will find a lot of support for them here, but that is for others to judge.

Finally I am not convinced any evidence has been forthcoming to support your views. There is an old saying - if it isnt broken then dont fix it. The IMCR has served a great many pilots for a very long time without any obvious problems. The one thing I do know is whenever I am GAing in Europe I hear repeatedly we wish we had the IMCR. Sadly, what many do becasue they dont have the rating is break the law, and that is not acceptable.

On this one we will have to agree to differ!

The thread remains important in so far as the debate about IMCR landing minima are concerned. At the risk of repeating myself I am satisfied the landing minima are recommended not mandatory. I have asked the CAA whether anything can be posted here or else where to clarrify the matter for others and I will be back to report what they have to say on this issue. In the mean time make your own mind up or write or phone the CAA - they really are rather nice people!

Until then .. .. ..

[HelenD]

I am currently training for the IMCR and I have been taught holds in case I ever have to use them. I have been told that examiners in our area will include a hold in the test, probably not a bad thing. I did ask about SID's as they are mentioned in Thom 5 and I was avdised that I did not have to worry about them. With that in mind if anyone feels that IMCR pilots should be able to fly SIDs then they should loby the CAA to include SIDs in the IMC syllubus and test. I am happy with the minima that is given for IMCR pilots but what I am not happy with is people trying to tell me that I am allowed to fly down to the publised minima. 500ft absolute minima is low enough for my liking and I cannot see myself flying below 800ft in reality without being visual.

My main reasons for doing the IMC is to aid me flying when the vis is arround 7K or below - legal VFR but not that good, I also want to fly above the clouds as the air is smoother up there most of the time. Given the choice of having to fly a hold or orbit for more than 5 mins I would choose the hold any day. Incidently if I had the time and money I would do the IR though I would still stick to the IMC minima.

[IO540]

Helen

There is a reasonable reason for not dealing with SIDs and STARs in the IMCR syllabus: the IFR privileges of the IMCR are specifically limited to the UK, and no Class A, and over here there is little or no prospect of flying one of these procedures without going in or out of Class A.

Actually flying one of these is easy - it is no more than a list of climbs / descents / turns and someone who covered the IMCR requirements properly can fly them OK.

The way one uses the IMCR in the UK, one doesn't need to fly SIDs/STARs. One flies mostly in Class G, occassionally popping into a bit of Class D.

In this context, holds are very rarely flown in reality; they are taught because you have to be able to do them, they form parts of some instrument approaches, and they are great for separating the men with hairy chests from those without :O

[DFC]

Fuji,

Here is a free lesson.

Aviation risk management has a very well defined and widely known decision path.

1. Perceive the Hazards - Pilot, Aircraft, Environment, External Factors

2. Process Risk Level - Consequences, Alternatives, Reality, External Factors

3. Perform Risk Management - Transfer, Eliminate, Accept, Mitigate

One of the biggest hazards is peer pressure to fly faster, fly lower, fly in poor weather, use lower minima.

To use IR minima when one does not hold an appropriate Instrument Rating does nothing for risk management.

-------

IO540,

Many UK airfields in class D have SIDs that are designed to get the pilot into class G. It is simply not acceptable that pilots filing IFR can not fly a SID because the notified ATC IFR capacity is based on all IFR pilots being able to fly the procedures.

Having a flow restriction in place because there are IMC pilots about will not wash well with the service provider (who work hard to avoid any delays) or the Dept of Transport who have to answer to airlines asking why their flight 123 had to holds while (as they see it) an unqualified pilot jumped the que.

Are we going to find that legislation will prevent pilot exercising their IMC ratings in class D?

What about when the future airspace changes happen? Will Euro airspace permit non IR holders to fly IFR IMC? NO.

Regards,

DFC

[IO540]

DFC, you are spouting nonsense again.

The IMCR is not valid (for IFR) outside the UK, so your sentence "Will Euro airspace permit non IR holders to fly IFR IMC? NO." is meaningless. It doesn't matter what the rest of Euro-land thinks of the IMCR; the CAA can do whatever it likes in its own back garden - just like they have done with the NPPL, or non-expiring UK PPLs.

I don't think you fly a plane for real. If you did, you would know that a SID usually takes you to an airways join, and a STAR does the opposite. This stuff is mostly Class A over here. Very different abroad (may not be Class A) but the IMCR isn't valid for IFR abroad so it's moot.

In fact, most SIDs/STARs are not actually flown (or not fully) because one is usually under radar vectors....

A properly trained IMCR pilot can fly any SID or STAR. They are a piece of cake. It's just a short chunk of route, from A to B to C etc. You fly the chart or description. No rocket science.

[DFC]

The UK will in time have Euro Airspace. It has started with Class C replacing the national class B that the UK uses for the upper air and will extend to the lower levels in time. The Single sky for Europe project is something that you need to be aware of as something like the French system in the lower levels would not be great for the IMC holder (able to fly IFR in class E) but could be the end of the IMC rating - the powers that be are not going to have IMC rating holders effectively being given access to UK airways by European directive when they can not fly IFR IMC outside the UK. The will use pilots comments about ducking under and such like as a lever to get rid. Get the idea.

I'll ignore your typical childish insult and simply refer you to the following;

Stansted Barkway 4R and 2S departures

Luton K, M, N, P and R, S, T, U and Victor departures.

Examples of departures that are designed to take the flight out of controlled airspace.

Never mind departre procedures designed to leave controlled airspace. The fact is that any pilot filing IFR should be able (personally and legally) to fly the appropriate SID to a point where it is convenient for ATC to get the aircraft out of controlled airspace taking into account other users. Operators will not stand for being delayed by unqualified pilots expecting something special from ATC.

I know that an IMC rating holder can not fly in class A. many operators both UK and abroad operating at UK airports would simply say that if an IMC rating holder can not fly in Class A and the SID takes them there then simply hold them until they can depart VFR (in appropriate weather).

Not many IMC rating holders operate to/from Stansted. However the current system allows it and people can be suckered into situations that they do not fully understand or more importantly do not realise the consequences of what they do.

The important words in your final statement is "properly trained".

It is a bit of a quandary for the CAA.

Restrict the IMCrating to Class G would please operators that moan about delays from unqualified pilots. Many would say that most IMC operators operate in class G with only a few infrequent exceurions into class D.

However, it is not as simple as that.

Many training organisations are based at airfields in Class D and provide IMC training using instructors that only hold IMC ratings. A ban would reduce their revenue. The every increasing numbers of flights to regional airports will cause more Class D to be established and in time it would be a race between the UK putting more class D in plance and the Single Sky as to which would be first to finish off the IMC Rating.

Possible advances in GPS could help somewhat. However, it is not going to be simple.

The CAA have had a proposal on the back burner for a few years to remove the requirement for ATC at any arfield with a published instrument approach procedure but the kickback would be making it a requirement for all procedures used (including private ones) to be published.

Want to invest in something and are a GPS believer, invest in procedure design because when GPS is approved for NPA, it will be a requirement for an approved procedure design organisation to organise the surveys and draw up the procedure before it can be used.

Isn't it about time that the CAA got out a bit more like the FAA and did ramp checks. The did it years ago.I remember the CAA checking qualifications of pilots landing in Jersey when the weather was not exactly nice.

Regards,

DFC

[Julian]

Of course the FAA IR holders will not rely on the IMC rating for long as once they have gained the required experience (75 hours IFR) they will go for the JAA PPL/IR so the pilots in that group are only going to be there for a very short period if they keep current and have any sense.


Why would they???

They may not want to spend 12+ months and £3500 on pointless exams and then more £££ on the extra 15 hours training and flight test when they already have a perfectly good IR - why not just join an N reg group or hire an N? Thats what I would call having sense and an extra £10k in the bank!!!!

I would have thought that the only ones who may take the route you are suggesting (and I take it you mean an IR in addition to the PPL as the much talked about PPL/IR still doesnt exist), are those who are going all the way on the JAA side to go Professional.

For those not going Pro they will then have the extra exam rides, etc to keep it valid - another waste of time and money! Something else the FAA have got right basing it on experience but there again if the CAA followed this lead they would lose out on the massive cash cow they currently have.....:}

[bpilatus]

I would agree with 540 the IMC rating is only applicable in UK airspace. I do not subscibe to being able to fly out of sight of the surface (IMC) when overseas.

In connection with a couple of recent points; an IMC holder can leave via a SID provided he doesn't enter Class A. If the SID goes into class A at some point he would have to make clear to ATC that he isn't able to comply. I suspect that if s/he made this clear before departure it is unlikely that he would be given a SID departure. If he only discloses the limitations of his licence when in the air I can imagine the controller wouldn't be too pleased.

DFC, filing IFR does not mean one has to depart via the SID, excluding class A. For the avoidance of doubt IFR has nothing to do with met conditions. A basic PPL holder can file IFR.

Julian, whilst you consider the exams might be meaningless surely the majority of the subject matter is worth learning about.

[IO540]

BP

This is regurgitating old stuff all over again, but the IMCR gives you two distinct things: (a) IFR privileges for Class D-G (limited to UK only by the ANO), and (b) the removal of the in sight of surface requirement (no geographical restriction). I have this in writing from the CAA, as have many others, and it is well established by now.

The reason this keeps coming up is the way the ANO is written in this regard, as a collection of restrictions in different contexts and different places. If there was a section stating: "Privileges of the IMC Rating are: ...." it would be clear.

You make a good point about not being given a SID. From what I have come across, if the ATCO is also a pilot (many are, even today) and is trying to be helpful, and suspects the pilot is an IMCR one, he might give a departure clearance which lists the SID bit by bit ("after departure, climb to 2000ft, then turn to DET...") rather than give the SID name which would be usual if doing it properly. Once, departing airways from Biggin, I was given a long list of stuff which was the exact SID :O

I don't think a non-IR PPL, keeping legal, would get very far on an IFR flight plan starting with a typical SID departure... :O

Julian is right, and the negligible stats on IR issue to UK NON commercial pilots confirm it.

As for the ATP subject matter, the question is whether it is all needed for the private flying context. One can always make a "safety" case for anything additional. Like "do you agree that children should be protected from abuse" anyone disagreeing is on a hiding to nothing.

[Julian]

Julian, whilst you consider the exams might be meaningless surely the majority of the subject matter is worth learning about.

Nope, not at 12 months study time and a lot of expense! I would also disagree in that a majority of the subject matter taught on the ATPLs is related to IR flying - 14 x A4 lever arch files taking up a small library space :sad: .

If I wanted to learn the excess information out of interest I would buy a book for £30.

As I have said before, what we need is a stand alone exam for the IR which concentrates purely on IR issues and not areas which are covered by other licences and/or ratings.

Julian.

[Fuji Abound]

I am pleased to say that I have received a very helpful reply from the CAA with regards IMCR landing minima.

Firstly, if anyone wants written clarification that the landing minima are recommended and not compulsory then please email the CAA from:

[email protected]

Secondly, you should watch GASIL!


For fear of repeating myself, you can rely on your own interpretation of the legislation, believe hearsay or DFC or even me for that matter, or you can write to the CAA - it is up to you.

[Rivet gun]

Wow, what a thread.

Of course Fuji is right about the advisory nature of the IMCR DH/MDH. It has always been that way since the IMC rating was invented. When I did my IMCR there was no mandatory DH/MDH at all for non public transport flights, but now the IR minima are mandatory. The 1800 m vis is mandatory.

There are various ways to get IMC rating privilages in addition to a PPL holder doing an IMC rating course. For example a current airline pilot with a CAA issued JAR ATPL (not uk national ATPL) may want to put an IMC rating on his licence if he wants to fly a single pilot aeroplane on his days off. This he will get without need for training or testing assuming he has a airline LPC in the previous 24 months.

Should a current ATPL holder voluntarily restrict himself the advisory DH/MDH? Of course he would be advised to be in current practice with single pilot instrument flying before shooting approaches IFR for real.

[DFC]

Julian,

First I should have used 100 hours as the figure and not 75!

All this talk about taking years and such like to study for what are relatively simple exams not set at the ATPL level is either utter tosh or if it is a true statement says something about the learning abilities of people who hold other instrument qualifications.

The exams are very easy. Perhaps some of those that have passed them would like to make out they are difficult or represent some great educational experience but they do not. Or perhaps the providers would like that perception in order to justify their fees.

---------

Bpilatus and IO540,

Much of what you talk about regarding SIDS clearly show that you think it is OK for unqualified people to get more out of the system to the possible detrement of the qualified. Training flights are given a lot of sympathy by operators but even with that they must take the lowest priority. However when it is not a training flight, people are not happy that the capacity of the system is reduced by people who expect some form of special treatment.

Does anyone honestly think that an operator who pays through the nose to fly IFR is going to be happy waiting at the hold while the ATCO does what IO540 says in explaining a SID to someone who does not hold an IR and does not pay (as they see it).

IMC holders are often their own worst enemy;

Operating to minima that are not backed up by any form of training, checking or safety case.

Ducking under when not visual at minimums.

Using a one size fits all minima regardless of the procedure or environment.

Operating on the basis that holding is optional in the IFR environment!

Expecting special handling from ATC

These are all issues that can only help people who want to justify the restriction or withdrawl of the rating.

Will EASA issue IMC ratings? - Not in the plan at present. What then?

The IMC rating if used properly could be used as a shining example of the kind of things that could be acheived by establishing a Europe wide mini-IR with well defined high minima. Unfortunately I do not think that anyone in their right mind would try to use the IMC rating as a shining example of anything other than confusion, poor operating practices and placing an inappropriate extra load on the ATS system for no return in terms of safety.

As I said previously, the IMC rating needs a big image change and the place to start is by putting in place appropriate, clearly defined, easily applied and well understod minima.

Regards

DFC

Fuji,

We are not deaf. No need to daily repeat yourself. Why is it that I have simply said a long time ago that if evidence is produced to show that the CAA have changed their position then I will happily accept that and left it there while you can not stop repeating, repeating, repeating the same hearsay while being unwilling to accept that there could be another position.

Don't keep asking the CAA the same question. Ask them to let you pass on the information provided to fellow pilots. They will not object.

[IO540]

RG

A small point, but do you have a reference for the grandfather method of getting an IMCR?

A colleague who is a current UK (old CAA) ATPL and a training captain looked into this recently. He reported that he gets an automatic IMCR if he has the old CAA (not JAA) ATPL. The JAA ATPL is worthless for this and a different process needs to be followed, and it may depend on whether a UK PPL was ever held.

Another way to get an IMCR is with the old CAA (not JAA) CPL. You don't even need to have ever held an IR. And if you are really really ancient, you could have got the CPL through grandfather rights from a BCPL, which you could have got through grandfather rights from the good ole days when a PPL could teach a PPL (30+ years ago?). So you can be an instructor teaching the IMCR, without you ever having received instrument training. Even if true, I'd think these must be few and far between now.

Fun stuff :O

The process of getting a single crew IR is also simpler if going from an old UK multi crew ATPL, than from a JAA multi crew ATPL. I know somebody who has just done that.

[Julian]

DFC,

I think you are missing my point that a pilot wanting to study for an IR should not have to go through all that cr@p!

£2000 for the course and then £60 per exam to the CAA, plus 2 weeks B&B if you dont live nr a training provider. So now our £12000 JAA IR has become something approaching £15-16,000! Dont forget that there is a mandatory minimum numbers of hours study as well!!!

All this talk about taking years and such like to study for what are relatively simple exams not set at the ATPL level is either utter tosh or if it is a true statement says something about the learning abilities of people who hold other instrument qualifications.


No-one is saying the exams are difficult, in fact its widely acknowledged that they are roughly A Level standard. Its the amount of information they want you to absorb that takes the time. Go on any provider website and you will see 9-12 months quoted for self study and if you look on these forums you will see that is what students generally allow.

Maybe you can explain why, even though the exams are easy, you think someone should pay for exams he may never use rather than have an IR exam and study for ATPLs at a later date if they want to go that route?

If you want to argue about the merits of JAA IR Vs abilities of people who hold other instrument qualifications then you need to start up another thread as that one has been done to death numerous times on here. :zzz:

[Send Clowns]

Slight correction to IO540's, to avoid a common confusion. The IMC rating gives the privilege to fly IFR in IMC in class G airspace. You can fly IFR in VMC in class G airspace without it (and I would encourage anyone who is thinking of going commercial to do so as it instils some discipline) - otherwise you could never use your night rating outside controlled airspace! I would also add that if I recall correctly, like the IR it reduces the visibility requirements for flying SVFR from 10 km to 3 km.

What he said about SIDs and STARs was spot on, and the comment on safety culture very true!

[Fuji Abound]

“Operating to minima that are not backed up by any form of training, checking or safety case.”

Your position has always been the landing minima are mandatory not advisory - unless you have now changed your position? If you were correct no one is ducking under the minima. As you are not correct then still no one is doing what you allege. Moreover if the training is incorrect I think you should tell the instructors so, that is where the problem is and doubtless when the CAA carnify the position in GASIL those who didn’t know will be in no doubt.!

“Using a one size fits all minima regardless of the procedure or environment.”

What is that all about then? Minima are always based on the procedure or environment.

“Ducking under when not visual at minimums.”

So I assume you have the evidence that IMCR holders are routinely doing so?

DFC - it really is not personal, but you infer you are an instructor, and then you infer the CAA have given you a different interpretation of the legislation and so I thought it helpful to tell you who to contact and to PM me so we can sort out why you have been given one explanation and I quite a different one. It seems to me so simple that technical threads such as these should reach a conclusion if at all possible and clearly this one can and nearly has.

I know you don’t “like” the IMCR and that is fine - as I have said before I happen to strongly disagree with many of the reasons you have set out and on that we will have to beg to differ.

At least I am very pleased to see you are very close to conceding you were wrong on the IMCR landing minima - I guess the weight of evidence eventually becomes compelling!

Oh and dont worry if you do eventually concede the point - I am sure we will all look forward to your posts as we do now.

[bpilatus]

BP
This is regurgitating old stuff all over again, but the IMCR gives you two distinct things: (a) IFR privileges for Class D-G (limited to UK only by the ANO), and (b) the removal of the in sight of surface requirement (no geographical restriction). I have this in writing from the CAA, as have many others, and it is well established by now.


a) presumably you mean IMC, in class D-G. At the risk of repetition anyone can fly IFR, even a NPPL.
b) I hadn't realised that the CAA had dealt with this. Thanks for pointing it out. Can you shed any light on flying airways (IFR, at odds and even FL. Not +500ft) in France for a IMC pilot. I think it is class E below 11,500ft and D above. Presumably this is ok for an IMC pilot.

Julian, I think we'll have to agree to disagree. If I understand you correctly you see no point in learning what you consider unrelated, superfluous material. Most (all) vocational courses worth their salt push the boundaries to give the student a rounded and comprehensive understanding. Interestingly I never hear of anyone complaining about the depth of PPL subject matter yet one could equally ask why it is all necessary.

[IO540]

BP

The IFR privileges of the IMCR are limited to UK and certain dependent territories only. It's in the ANO, but as usual it's phrased in the negative so you have to rummage around to find it. The 2005 ANO is at

http://www.opsi.gov.uk/si/si2005/20051970.htm

So you can't use it to fly IFR outside the UK, end of story. Not even in VMC.

As for France, their "airways" are just lines on the chart; you can fly them VFR up to FL195 (in general). Class D base is usually at FL115, IIRC so below that it is even less of a problem. You'd fly them at even+500 or odd+500 as normal for VFR.

Flying these routes VFR is the easiest way to fly in France, not least because they avoid most of the vast amount of restricted/prohibited military airspace which covers France. That's why their bases are usually FL065 or so.

Whereas in the UK "airways" are usually Class A.

In fact the whole business of VFR is far easier outside the UK.

There is a vast volumetric difference between the ATPL study material and the PPL study material, in terms of what someone with a job and a life can manage to swat up. If you believe that people should be loaded up to the limit to sort men from sheep (a widely held POV especially in the very traditional world of aviation where things should be "hard", where old grey haired men tell you that you can fly to Mongolia with just a map and a compass) that's one thing, but ask yourself how the FAA manages to run a private (PPL/IR) population which exceeds the rest of the world's PPL/IR population by at least an order of magnitude, on about 1/10 of the ground school but learning everything that's relevant, and without a statistically worse accident record? I've done the FAA IR and it is about 6 months' study - hard (especially with the thorough 2-3hr oral you get just before the checkride) but managable in the overall context of everything else including the commitment which aircraft ownership inevitably involves. The JAA ATPL study material is managable only in the context of someone with years to play with, while waiting for a P2 seat on a cargo turboprop, or a 737 if they get lucky.

[Fuji Abound]

540 - and of course the FAA IR is a far better test of the pilots skill flying an actual IFR sector than ours - but then thats another debate.

Far easier to pass our IR flight test and far easier to pass the FAA IR theory - guess who has got it the right way around.

[Rivet gun]

IO 540,

For those of us who have a UK national CPL or ATPL the privilages of the IMC rating are contained in the privilages of licence itself as defined in the ANO (also a waiver of the 1800 m vis rule). There is therefore no need to add a IMC rating to a UK national CPL or ATPL and there is no revalidation requirement. Training to at least IMC rating standard was part of the CPL even without the IR.

With the JAR professional licences the situation is different. There are no instrument flying privilages in the licence independant of the IR. Most people getting a JAR CPL/IR will do their initial IR single pilot and thus have full IR privilages for the first 12 months.

In airline operations the pilot will revalidate his IR as part of a multi pilot LPC. This does not count for revalidating single pilot IR privilages, and therefore for single pilot flying the licence reverts to VFR only.

In order to be nice to airline pilots who want to fly light aircraft on their days off, but who don't want to do a single pilot IRPC every 12 months, the CAA allows a IMC rating to be put on a JAR CPL/IR or ATPL. This IMC rating would of course be valid for 25 months from the initial IR skill test.

The question is, does the airline multi pilot LPC count in lieu of a IMC rating flight test for revalidating the IMC rating? I have found one link which suggests it does, and this comes from a certain examiner in the BOH area who was previously associated with the CAA. However I could not find the reference in the current LASORS.

http://www.flightexaminers.com/FAQs.htm

As far as SIDS go, I think if a IMC rated pilot wants to fly IFR out of a airfield in class D which has SIDS that clear the zone to class G it would be his responsibility to ensure he was competant to fly the SID. Most such SIDS are not complex or difficult.

I know of no STARS which arrive direct from class G into class D so if the standard holding stacks are in class A, the pilot (however qualified) arriving from class G should expect that he might be instructed to remain clear of controlled airspace until he can be fitted in the traffic. In that case he just has to hold on any convenient VOR DME fix that keeps him outside controlled airspace.

There is plenty of precident in the licencing system for pilots being lawfully allowed to do things which they nevertheless should not do without first acquiring additional competance beyond the training syllabus. Aerobatics and close formation flying are examples. Flying a SID on an IMC rating, or indeed flying to IR DH/MDH on an IMC rating fall into the same category.

[rustle]

Far easier to pass our IR flight test and far easier to pass the FAA IR theory - guess who has got it the right way around.
Can you detail these differences that make our flight test so easy please, or are they in a secret email from the FAA/CAA/EASA/JAA/Kelloggs? [delete as applicable]

I'm always keen to learn new stuff, and this is certainly new.

TIA ;)

[Julian]

BP,

I think we'll have to agree to disagree. If I understand you correctly you see no point in learning what you consider unrelated, superfluous material. Most (all) vocational courses worth their salt push the boundaries to give the student a rounded and comprehensive understanding.

Yes that is exactly the view I hold!

Imagine if when you did your A Levels you wanted to get Maths A Level, but to geti t you also had to study French, Biology, Car Mechanics, Home Economics and Indonesian Basket Weaving. If you pass them all you get your Maths Level ....... fine you are a more rounded person but completely pointless course and nothing to do with the end objective!!!!!!!

As IO540 says there are vast differences in PPL & ATPL. PPL takes someone who knows absolutely nothing about aviation and teaches them the technical & theoretical knowledge required to operate an aircraft in UK Airspace. I will agree that there were some bits nearly sent me to sleep whilst reading through the TT books but on the whole the PPL study was relevant.

I do not think that giving a student superfluous material to study is pushing the boundaries of the student - more likely just boring them to death and costing them a lot of time/money. If the exam was IR specific you could very easily push them - and you would be pushing them in the relevant areas!

The time/cost element is a big reason why a lot of pilots are going the FAA route. The FAA IR is not superior or inferior to the JAA one but is certainly a whole lot cheaper if you take the ATPL exams into account as well as the exam is included in the FAA course - £4,000 Vs £15,000.

Suggest you read 'The Killing Zone' if you have not already. There is a very good reason why the FAA decided to make the IR more accessible to pilots by reducing the number of hours required to commence the course and it had the desired results. Would be a big leap forward if we followed suit....

Julian.

[IO540]

The FAA IR written exam is (as I wrote) perhaps 6 months study to reach a 90%+ pass mark (assuming a competent IMC Rated pilot), doing it in between work and other stuff.

An IMC Rated pilot who "knows it all" would get about 50-60% in the FAA IR exam; not anywhere near enough to pass.

The books and the computer revision aids come to perhaps £100. The actual exam costs about $100 if sat in the USA, or about £230 if sat in the one place I know of in the UK that still does it.

I think the exam content was about 95% relevant to actual flying. In comparison, Trevor Thom (for the PPL) manages perhaps 50%, if that.

Funnily enough, a UK/JAA PPL who has done the 7 or so exams would never pass the single FAA PPL written exam either. I've done al that stuff, and there is extra stuff in the FAA exam, on instrument nav for example. Nor would he pass the FAA checkride, most likely.

An accessible IR will probably never happen in Europe. There are too many people in too many positions who think that if you share the airspace with ATPs then you should have sat the same exams. Like the "child abuse" argument, this is hard to argue with. The FAA method is miles outside the box for these people.

There is another thing which prevents a number of pilots ever doing the JAA IR: the stupid JAA audiogram test. This is in the Class 1 medical but is chucked in if you do a PPL/IR too. I know of a number of people who have one ear (only) that is out of spec; all of these cannot ever do a JAA IR but all of them could (medically) be 747 captains in the USA. This is not ICAO and is not FAA; it is just Euro-style gold plating for no apparent purpose other than sorting men from sheep. The CAA has put out a proposal to relax the db limits (basically, to bring the initial limits down to the renewal limits) but this has been out for a while.

Thanks to ICAO, and to all the rich and influential people that own N-reg turboprops and bizjets (N-reg piston GA doesn't count at all in this), we have the FAA option and it may well be around for a long time.

If it wasn't for ICAO, there would be just two kinds of flying in Europe: VFR, and airlines. Plus oddball privileges like the UK-only IMCR.

[2Donkeys]

Has anybody heard of "GroundHog Day". This thread has certain similarities ;)

[Fuji Abound]

Rustle

You are of course correct.

If I told you I would have to shoot myself, having shot you first! :)

Love the bit about Kelloggs though, made me smile!!

(PS a good paper could be written on the subject "compare and contrast the content of the FAA and JAA written IR papers" - there is already some material available from the posts on this thread - when you have finished watch all the vested interests surface)

[rustle]

Can you detail these differences that make our flight test so easy please, or are they in a secret email from the FAA/CAA/EASA/JAA/Kelloggs? [delete as applicable]

I'm always keen to learn new stuff, and this is certainly new.

TIA ;)

Rustle

You are of course correct.

Now I really am confused :confused:

Which bit am I correct about? :ooh:

[Send Clowns]

IO540

I'm afraid I have to call you on the FAA PPL exam/flight test, and comment on the IR (I never did the latter, so can go no further). I did the FAA PPL when I was 19 and did not have a huge amount to do to get a good pass in the exam, and I passed the flight test well despite not thinking I had flown to my own standards. I did the JAA PPL exams when I had a lot more experience (180 hours fixed-wing, 150 rotary+sim time), and brushed up to do it, and subsequently I have done a lot of classroom teaching for it. It was a lot harder than FAA, and correctly studied (i.e. not just using the confuser to direct the study) it contained everything covered by the FAA exam, including instrument navigation which makes up 20% of the Nav exam.

I have been a flight instructor, and any of my students would pass the FAA PPL flight test. They might be confused by the figure 8, but they'd do it to a high enough standard and that is a pointless exercise if ever I saw one!

On the IR, I have a friend who is an IRI here but also has an FAA ATP. He compares the overall FAA IR (which he had on a CPL before his ATP) with an IMC rating (which he has been teaching for years). I cannot say anything in detail about the exam as I have not taken or taught either. I agree you'd have to study because the law is different and I assume the exam has some extra content, but flying is basically the same anywhere otherwise!

I also agree that there should be a more accessible PPL IR here, perhaps based on a broadening of the IMC. However the airspace that most would then want to use that they can't with an IMC is getting crowded - it's where I do most of my flying.

Fuji

One of my plans when the company I taught groundschool for went bust was to ask teh CAA for sponsorship to do a PhD on JAA groundschool training. A study of that detail is required.

[DFC]

Fuji,

My position remains that the IMC absolute minima are mandatory. It is the use of lower minima that I was talking about.

People have here in this thred admitted to flying lower than 500ft because they are not visual at 500ft. That is called ducking under.

Ir minima are indeed based on procedure design and the obstacle environment etc. However, as many IMC holders use a minima of 600ft MDH and 1800m RVR on a large number of approaches using different approach aids, different approach lighting (if any) and vastly different obstacle and operating environments provided that the minima is not lower than the published. That is the point I was making.

To say I don't "like" the IMC Rating is rubbish. Why would I teach people to do things that I don't like. What I say is that it is in need of a drastic revamp.

To compare the FAA IR and the JAA IR one would need to hold both. That leaves you out on both counts. :D

-------
IO540, Fuji and Julian,

There is no point in talking about the ATPL exams when thinking of the IR. There is no link. There is no requirement to study at ATPL level. There are courses of ground training available from a reputable provider that is specific to the IR. Loot it up and ask them.

The topics examined are;

Air Law/ Operational Procedures (1 hour)
Aircraft General - Systems (15min), Instruments/electronics (1 hour)
Flight Planning and Monitoring (2 hours)
HPL (30 minutes)
Met (1 hour 30 minutes)
navigation - General (30 min), Radio Navigation (1 hour 30)
IFR communications (30 min)

7 areas in which one must demomnstrate knowledge in 8 hours 45 minutes. Compared to 14 Areas in over 20 hours for the ATPL.

Can anyone honestly say that pilots should not have to demonstrate the above knowledge before being given an IR? Don't the FAA cover the same topics?

The IR training system has not significantly changed in subject matter and level of training pre and post JAR-FCL. Yes the prices have gone up and that is a problem. However, I can not see how many people studied in their own time with not much study material available and put in the same amount of flying and had to undergo the same medical checks to obtain an IR 10 years ago but now there is a perceived problem. I think that it could be argued that with well structured and available ground training plus the use of FNPT2s, the training for the IR is actually easier than it was 10 or 20 years ago. So why are today's pilots finding it difficult?

------
IO540,

It is an ICAO requirement to meet Class 1 medical hearing requirements for the IR.

-----

Julian,

Please let us all know where it was you could get FAA IR training for under $50 per hour.

Regards,

DFC

[Julian]

DFC

The topics examined are;

Air Law/ Operational Procedures (1 hour)
Aircraft General - Systems (15min), Instruments/electronics (1 hour)
Flight Planning and Monitoring (2 hours)
HPL (30 minutes)
Met (1 hour 30 minutes)
navigation - General (30 min), Radio Navigation (1 hour 30)
IFR communications (30 min)

7 areas in which one must demomnstrate knowledge in 8 hours 45 minutes. Compared to 14 Areas in over 20 hours for the ATPL.

What complete tosh! You have quoted the time required to sit the exam - not the study time....completely irrelevant! Its like saying we could have cut out all that school work for years and just turned up for tha last day of exams.

There is no point in talking about the ATPL exams when thinking of the IR. There is no link.

At last it has finally dawned on you!!!!!!
Get rid of the ATPL exams with respect to the IR and replace it with a relevant course of study and exam.

Please let us all know where it was you could get FAA IR training for under $50 per hour.

Not sure where you get this from as 4k = $6400 (@1.6) and that equates to 125 hours instruction according to your rates of $50 (maybe you need it :E ). I paid $35/hr for the instructor and $90/hr for the aircraft in Long Beach CA and the guy is still there. He also has an agreement with a UK airfield so you can start your training here and then finish in US and undertake your flight test there if time is an issue with you and you cant do the whole course there.

Said guy is also a JAA Instructor and also has an agreement with another FTO in UK who will undertake the 15hr conversion for you to convert to the JAA IR on your return - assuming you have done those swathes of exams :}

[Fuji Abound]

"That is called ducking under."

No its called going on and on and on and .. .. .. repeating myself. I think we have got to grips that you have one view and those of us with our Kelloggs have a different view - best left at that.

"That leaves you out on both counts."

It leaves me out on every count, I don’t actually fly, just keep on dreaming and studying the books.

"What I say is that it is in need of a drastic revamp."

We do know. The trouble is you haven’t produced any evidence to support your argument, other than all these mythical IMCRs ducking under non existent minima, getting themselves lost and flying the wrong way around non existent SIDs.

Rustle

"Which bit am I correct about"

All of it.

On to serious business.

As 540, Julian and others have commented a very simple comparison of the FAA IR and JAA IR theory demonstrates, the JAA is far more difficult to pass. More difficult to pass does not mean more difficult to pass academically. I cannot imagine how anyone who had done either, let alone both, could possibly argue a contrary case. There is also a hint - if the electorate dont vote for you there could be a reason.

Why do almost no private pilots do the JAA IR now. Consider how many took and passed the exams last year!!! Frankly it is a disgrace.

There are far too many who go on supporting this ridiculous system (and would make the IMCR all but worthless as well) while GA is slowly dying on its feet.

Imagine some of the most changeable weather in the world and yet there are some who would delight in perpetuating a system that struggles to get a double figure number of private pilots instrument qualified!

Forgive me but those proponents cannot honestly examine their conscious and believe this is a sound system.

[DFC]

7 March;

Not this old chestnut again!
My examiner has asked the CAA whether the minima are advisory or mandatory - the answer was they advisory. We ignored the advisory limits at my last renewal, and I was very happy to do so.


Followed by today;

It leaves me out on every count, I don’t actually fly

I think that we can leave it there! :D

---------

Julian, I was intentionaly using the exam times which should have been obvious. The reason was that the exam time is a good indicator of the depth of questioning (or the number of multiple choice questions).

I say that the ATPL exams have nothing to do with the IR because that is currently the case. Look up who provides groundschool for the IR and ask them.

Your figures for the PPL/IR take-up in the system should include the full system. What are the European wide figures now compared to pre JAR-FCL?

One of the reasons for the poor take-up could be the bad press that people who never did the course put out and unfortunately people believe rumours.

Also, many of the figures quoted do not include air fares, accomodation, exams, paying for groundschool, etc etc which knock large chunks off your quoted figure. Add to that your other half and the kids complaining about you using the family's holiday for flight training. For many, it is actually easier and more cost effective to do the IR in Europe.........note that I said Europe.

Regards,

DFC

[IO540]

Fuji

There are far too many who go on supporting this ridiculous system (and would make the IMCR all but worthless as well) while GA is slowly dying on its feet.

Very well put, but this is what we have - aviation is run for the most part by old farts who believe that making things HARD separates men from the sheep and that's how it should be. Not just the UK; in some ways the CAA could be classed as "progressive" but when you have a German on some committee, reading rule 3345 out of his little book of life's rules...

DFC

The exam times are irrelevant. The FAA IR is a broad subject, takes a good number of months of study but is a 2hr (or so) paper. The FAA CPL is 3hrs. None of these relate to how much one needs to know. Even the single FAA PPL exam (2hrs, IIRC) requires wider knowledge (of stuff related to flying) than the 7 or so (IIRC) CAA PPL exams. And not many people doing the stuff in the USA "pay for ground school" because you don't do that; you normally get the exams out of the way before going out there.

[Julian]

I was intentionaly using the exam times which should have been obvious.

Yes it was and as I said it a completely pointless comparison, exam times tell you nothing about subject matter or the fact that for the ATPL you are required to undertake an approved course of study (750 hrs rings a bell but I stand to be corrected on that).


I say that the ATPL exams have nothing to do with the IR because that is currently the case.

We agree on this point - hence my point (which now feels like banging my head against a wall) - why make someone take a load of exams that are nothing to do with the rating he is studying for?


One of the reasons for the poor take-up could be the bad press that people who never did the course put out and unfortunately people believe rumours.

Dont buy this one. Its just not accessible to get an IR easily unless you have lots of time and money in the UK.

The cost of training for the IR in the UK is astronomical, as we have already said the course itself is roughly £12000. The higher up the ladder you go the more you pay. For the SAME instructor that you had for you PPL at £25/hr is not £50/hr - in the US its the same no matter what rating you take. I always paid $35/hr. EFT quote £350/hr in a BE-76 for IR training, same at school I use would be $160 + $35 = $195 or roughly £120, 2-3 hours flying and you have paid for your tickets over!


Your figures for the PPL/IR take-up in the system should include the full system. What are the European wide figures now compared to pre JAR-FCL?

I never quoted any figures for PPL/IR take up.


it is actually easier and more cost effective to do the IR in Europe.........note that I said Europe.

Here you are talking about the JAA IR, still at Aerofan in Spain you will looking at 10k +3k exams so we are back up around the 13k mark.

It may be easier when wife/kids cant be talked into a holiday in the USA whilst you go flying but surely if you do outside the UK then you will have the same problem - i.e. talking them into a holiday in, say, Spain whilst you go flying....

[IO540]

I wasn't flying back then but I gather that the PPL/IR takeup was greater say 10-20 years ago, due to other routes available around the ground school.

I vaguely recall (perhaps somebody can fill in details) that if you had 700hrs total time you could skip the ground school and just turn up for the exams.

If you look at any group of non-FAA PPL/IR pilots today, you find that nearly all of them did their IR many years ago.

DFC - can you supply a reference for the Class 1 audiogram (with the current JAA limits tested at four frequencies, in each ear separately) being ICAO for all IR?

Somehow I doubt it, because the CAA is already known for having recently allowed an IR to be awarded to somebody who failed the initial but passed the renewal limits - this is exactly their 2005 proposal as it happens - provided he did the whole IR first and passed it. A rather onerous way to do it I think, especially as you do the exams and the flying and they could have refused........

The comment about somebody having done both doesn't really apply because nobody will do both in full unless they are a masochist. You always do a conversion. The JAA to FAA one is easy - the FAA doesn't have the protectionist issues to worry about. The FAA to JAA is a lot harder but you still skip most of the flight training requirement.

[DFC]

IO540,

The reference is Annex 1. My version is at amendment 166.

"2.6.1.5 Medical fitness
2.6.1.5.1 Applicants who hold a private pilot licence shall
have established their hearing acuity on the basis of compliance
with the hearing requirements for the issue of a Class 1
Medical Assessment."

The CAA may have found a way round the rules by doing come clever timings with the issue of the rating or they may have restricted the pilot to G reg aircraft (see the latest GASIL).

----------

Julian,

Repeat after me. "I do not do any ATPL exams to get a JAA IR"..........and again. :)

The IR exams are actually set at CPL level. That is why you need to say again "I do not do any ATPL exams to get a JAA IR" :)

Yes on the good old days there was no requirement to do any study at all, instructors were certified by GAPAN and the CAA had high failure rates in their exams. Then there was a requirement for a signature before you could sit the exams and guess what? some organisations insisted that you had to do their course before they would sign the chit.

You do not say that any of the topics covered by the IR exams are not relevant to the IR holder do you? If so can you please explain.

-------

To get back to the IMCR, does anyone else wish to add their comments about the minima I proposed (pro or con)?

Regards,

DFC

[Dimensional]

http://www.asmh37.dsl.pipex.com/deargod.jpg

:{

[Julian]

DFC

Repeat after me. "I do not do any ATPL exams to get a JAA IR"..........and again.

The IR exams are actually set at CPL level. That is why you need to say again "I do not do any ATPL exams to get a JAA IR"

The 7 theoretical exams you are undertaking are ....guess what.....from the ATPL course!!! So you are doing ATPL exams!!!


Then there was a requirement for a signature before you could sit the exams and guess what? some organisations insisted that you had to do their course before they would sign the chit.


The FAA require a logbook endorsement as well before you are allowed to undertake the IR oral/checkflight from your instructor so nothing new there.

Dont think you have made a convincing argument at all why or the need for 7 exams for one IR rating.

[DFC]

DFC
[I] Dont think you have made a convincing argument at all why or the need for 7 exams for one IR rating.

Which of the exams are not relevant to the IR pilot?

--------
Dimensional,

Inspired post.........great contribution to the debate. Don't like the debate, don't click on the topic!

Regards,

DFC

[Julian]

There will section on each which are relevant but as we keep going over also a lot of superfluous bumpf.

If the FAA can produce perfectly adequate IR pilots with a single exam you explain to me why we need 7 ????

As has been stated before you cant justify it or the cost!

P.S. I now taking you are actually admitting they are the ATPL subjects after denying it for several posts?

[IO540]

Dimensional

:O

However, if you deleted all posts on subjects which have been done to death before, most posts on pprune and most posts on flyer.co.uk and most posts on every other pilot forum would be deleted.

Same if one deleted all posts containing zero information. On some forums there would be positively nothing left at all. At least here, people occassionally come up with useful stuff.

[JonWhitehouse]

Hey,
Apologies if any of this has been said before, but just to clarify.
On a PPL, you can get the JAA IR or CPL or both, by passing the 14 exam papers, in no more than 6 sittings. i.e. in some sittings you will take more than 1 exam.
Once these are complete,and you have at least 150 hrs total time, you can start training for your chosen license/licenses.
If you want an airline job, your will need both CPL and IR (otherwise known as a frozen ATPL until 1500 hours total time acheived)
If you want to fly for cash in any other function-instuctor, crop spraying, reconnaissance etc, you can just get the CPL and save yourself £13,000 or so.
It is even possible to get an IR on a PPL! but it is expensive, and carries no possibility of payment.
Again, apologies if this was said before, it applies only to the JAA system. reference Oxford Air Training www.oxfordaviation.net or any other training provider for any other information.

regards

Jon

[Sans Anoraque]

Anyone else noticed that Pilotho hasn't made a post since he started this thread.

I wonder if he's given up and gone home?

[Dimensional]

True, but at this stage people are just restating their facts. I don't think anyone is going to agree on this until the CAA produce a definitive answer.

TBH we could pontificate until the cows come home drawing up new rules for this sort of thing, but it isn't likely to be enacted any time soon...

At least I got you both to agree on something! :8

--D (current IMCR stude, and loving it...)

[High Wing Drifter]

Hi Guys,

Response from the CAA is that the IMCR limits are advisory as said before so new news I'm afraid. The test is conducted to those limits. My training is consistent with the CAA's advice. The training may include a descent down to system minimums if the instructor has the required privileges. If you choose to ignore the CAA's advice and you have a problem the word of caution from the CAA as your actions could be construed as reckless and as such can be used against you. The CAA's view, reasonably strongly put, is that it is simply best practice and common sense these advisory limits are adhered to. There was no mention of experience in the equation, but I guess a recklessness charge would have to be based on currency, experience and by how much below the advisory minima you elect to descend.

The CAA were uncomfortable with me simply pasting the email as a response as they don't wish to get involved in anonymous debates on the internet so I have paraphrased. But rest assured as someone who thought otherwise I was wrong, I have been corrected to my satisfaction.

Cheers!

[IO540]

If you choose to ignore the CAA's advice and you have a problem the word of caution from the CAA as your actions could be construed as reckless and as such can be used against you

That appears obvious, but I wonder if there is any case law in this area.

In particular, it would be interesting to know how much weight an opinion from the CAA would carry because they are the CAA. I say this because a lot of what they write is dross; for example much of their advice on GPS in Safety Sense leaflet #25 is nonsense, was written by some map&compass amateur, and would never stand up in the face of expert evidence.

There are numerous "factions" within the CAA; some sensible, some very traditional and anti anything modern. It would be interesting to see if any of this has come out in case law. The FAA has a far bigger case law selection to fall back on.

The CAA must be well cheesed off with Pprune and all the other pilot forums on which they so deliberately choose to not officially participate. But they must be reading them all.

[Fuji Abound]

HWD

I am so glad someone else bothered to write AND set out the CAAs interpretation.

I hope we can now all agree the IMCR minima are advisory. Only fly to IR minima if you are current - whether you have an IR or IMCR - no surprises there!

Thanks for such a gracious post as well, refreshing to see.

:) :) :) :) :)



"To get back to the IMCR, does anyone else wish to add their comments about the minima I proposed (pro or con)?"

I think the evidence (which I have derieved from an analytical analysis of the subsequent posts) suggests

NO

What we dont know is whether:

1. no one can be bothered to comment,

or

2. the proposals arent worth comment.


Answers on a Kelloggs pack.

[Mixed Up]

On various posts for sometime I think DFC has expressed considered arguments, not all that I have agreed with, that been met with practical frustrations by IO540 et al. Let's fetch the personal bickering to a close and find some common ground. Much time is spent on this forum, but no one really cares about opinions. You should get together (I mean in a practical and geographical sense) with the sole aims of devising what are the real aspirations of the British/European instrument flyer, agreeing an appropriate training/examination regime to achieve that safetly and then to lobby for it. I think DFC has influence and inside knwowldege and IO540 has drive - together there's a team!

Who knows, there could be a couple of OBEs or even peerages in it ... particularly if you have spare bob or two (as clearly IO540 has :O ).

[Fuji Abound]

Mixed up

I would so much like to agree with you but here is a thing.

The GA community has already solved the problem for itself. Most pilots who want to fly instruments in Europe hold an FAA IR. The FAA IR is an ICAO compliant IR which few would disagree achieves an acceptable standard.

For those that do not want to fly instruments in Europe but do want to get around safely in the UK the IMCR provides an acceptable alternative - its only real draw back is the class A restriction but then again flying airways is often more trouble than it is worth.

The real problem is that there are those who would like to put any form of IR out of the reach of private pilots - period. The reason they wish to do so has absolutely nothing to do with safety, and has nothing to do with any “problems” with the system as it presently stands. Consider for a moment some of the posts on this thread and the way in which when the arguments are challenged no analytical evidence is forthcoming to satisfy those challenges. There are those that actually support the present theoretical training regime and will spend the rest of their life defending it, not because they have any evidence at all that it produces a better pilot. It is this philosophy that first has to be shown wanting - there might then be a chance of a JAA IR modelled on the FAA system.

With repsect to DFC I honestly believe he supports the current IR system and would like to see the IMCR become less useful - I dont think he is your man. If, and I repeat IF, the IMCR does not produce a pilot who is adequately trained, improve the training, for goodness sake dont devalue the rating!!

[DFC]

HWD,

I wonder who replied to you!

We advise you to not go below 500ft, it is not mandatory but if you do we will consider it reckless. A clear example of what IO540 calls tosh.

How many other things can you do that the CAA say constitute reckless endangerment but are not clearly outlawed?

The reply you got also says that the instructor can use system minima "if the instructor has the required privileges". Since the instructor will have to hold an IMC rating there is no if involved so where does the "if" come in?

Who ever said that simply said that the CAA thinks you can do what you like (we might consider it reckless) but as long as we don't catch you it's OK. Not a very safety concious statement from the regulator.

Head, block, chop! :D

Regards,

DFC

PS; Julian. Give Atlantic Flight Training a ring and ask them about the IR exams.

[IO540]

Mixed up

This is already happening but, due to EU politics, not in a useful direction.

There is a JAA committee looking into a "reduced burden private IR"; the latest is that they have taken about 20% off the ground school (which isn't going to make any practical difference; a complete FAA-style overhaul is needed) and will allow IMCR instrument training towards the 50hr (55 for ME) flying requirement (which won't make any difference to anybody who can actually afford to fly IFR into Europe, which a full IR is all about.

EASA will take over FCL in a few years' time and various officials have said promising things like they plan to do a swap of an FAA IR for a JAA IR. This is a bombshell of course and is unlikely to happen.

It's however just possible that the increasing N-reg population in member states will push EASA into doing something as sensible as that. They would have to take on board FAA certification also, and that means accepting FAA STCs and not just the present stupid system of enabling the US-based STC holder to apply for an EASA approval (which most US-firms can't be bothered to do).

But I've written all this before...

[Fuji Abound]

"Head, block, chop!"

Dont be so hard on yourself. :)





"I wonder who replied to you!"

Obviously not the same person who replied to you then!

At least whoever it was (ssssh we shall never know) may have spoken to the same person that replied to Bose, and 540, and me.

[Julian]

Give Atlantic Flight Training a ring and ask them about the IR exams.

Ask them what??? :}