IMC - what's the latest ?

[Hugh_Jarse]

Anyone know the latest on the IMC ? Are they still set to scrap it in a year or so ?

Apologies if I'm ploughing a well trodden path ... it doesn't apply to me so I haven't been keeping my eye on it : but I was talking to a guy yesterday about IF who said he'd like to do it, but didn't know if it was still worth it. I know that one or two on here used to be very close to the subject ...

[Mike Cross]

Latest is that the EC have given EASA a kick up the backside and told them to stop re-inventing the wheel.
AOPA news here (http://forums.flyer.co.uk/viewtopic.php?f=26&t=57845).

[BEagle]

Quite so, Mike!

Currently the UK IMCR does not form part of EASA part-FCL's NAP17b proposals. However, the EC commissioner responsible for all transport matters is a supporter of the UK IMCR, as is an influential MEP.

So EASA now has a working group with the catchy name of FCL.008 who are looking at the future of instrument qualification requirements in Europe.

FCL.008 includes UK representation, so you'd think that we could be reasonably assured that the future of the IMCR was being well protected....

WRONG!

One of the UK representatives has been advocating a cruise-only IMCR called the 'En-route Instrument Rating'. This requires the same theoretical knowledge requirements as the proposed PPL/IR, but has no approach privileges. The person who dreamed up this lunatic idea considers that there should be 'almost certain' VFR conditions for take-off and landing (whatever that means), so the EIR holder can then go and play airliners without being concerned about going IMC in the cruise.

AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR and has asked IAOPA to tell the FCL.008 group that the UK advocate of this EIR does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.

Much is going on behind the scenes to protect the UK IMCR and to ensure that it has a viable future. So if anyone is considering training for the IMCR now, my advice would certainly be to go ahead!

In any case, there's a good chance that EASA will heed the well-deserved handbagging they received from the EC and will remove their attentions from sub-ICAO licences and ratings.

[Pace]

The person who dreamed up this lunatic idea considers that there should be 'almost certain' VFR conditions for take-off and landing (whatever that means),

Beagle

They obviously now realise the safety aspect of the IMCR so dont know how to argue away the IMCR.

Hence my concern is a very watered down European IMCR which is no way could be classified as an instrument rating.

On previous postings I have always advocated pushing for an FAA like IR for PPLs as my concen was that pushing for a European IMCR would not get what we want.

My post in that thread feared that offering a very watered down IMCR would get them off the hook of addressing a proper PPL /IR while infact giving us nothing.

My post in that thread invisaged an enroute IMCR with approaches only on a declared emergency this doesnt seem that far away?

The problem is that nothing in flying is black or white VMC or IMC. It is easy to say assured VFR at destination but VFR at destination can easely be minimal VFR in minimal VMC which in no time can change to IMC.

Are pilots expected to be jumping from IFR to VFR just to suit regulations?

Are PPLs expected to add risk to suit regulations? IE is it safer in minimal VFR to approach an airport you dont know in terrain you dont know in minimal VFR or to stay IFR with vectors or a proper procedure.

The answer is pretty obvious. They need to stop playing politics and come up with a sensible PPL IR that is achievable for the working PPL and in the name of safety.

Pace

[englishal]

The answer is pretty obvious. They need to stop playing politics and come up with a sensible PPL IR that is achievable for the working PPL and in the name of safety.
...which will never happen.

Can you imagine EASA accepting an IR with one ground exam, taken on a computer whenever you want after self study and some ground school from your CFII?
Can you imagine EASA only REQUIRING 15 hrs of instrument instruction, the rest of the "instrument time" made up however you want (safety pilot for ex.)?
Can you imagine EASA giving credit for previous instrument time?
Can you imagine EASA allowing rolling currency requirements?
Can you imagine EASA allowing a lapsed IR to be revalidated by FI and NOT examiner?

If you can imagine EASA allowing this lot then you do have an IR akin to the FAA IR. Unfortunately they would NEVER allow 99% of this and so we will NEVER have an IR akin to the FAA IR.

What really needs to happen is for the Gold Plated JAR IR to be re-hashed and a new ATPL flight test and ground exams introduced at 1500 hrs. That way those of us who don't want to fly a Boeing don't have to meet Boeing standards or requirements.

[Hugh_Jarse]

Who is the "UK representative" who is calling for the cruise-only rating ?

[Fuji Abound]

One of the UK representatives has been advocating a cruise-only IMCR called the 'En-route Instrument Rating'. This requires the same theoretical knowledge requirements as the proposed PPL/IR, but has no approach privileges. The person who dreamed up this lunatic idea considers that there should be 'almost certain' VFR conditions for take-off and landing (whatever that means), so the EIR holder can then go and play airliners without being concerned about going IMC in the cruise.

AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR and has asked IAOPA to tell the FCL.008 group that the UK advocate of this EIR does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.

Are you referring to a member of FCL.008? No one on the committee represents themself.

Where is the statement from AOPA to which you refer?

[Pace]

Englishal

Can you imagine EASA

My problem is I cannot imagine EASA doing much at all :ugh:

I cannot imagine EASA taking on the IMCR in its UK form as a European wide rating or for that matter creating anything that steps on the toes and existing structure of the IFR world that exists at present.

I can imagine EASA looking for a way out from the fact that the IMCR does improve safety in the GA/PPL community.

I can see them offering a gesture as a very watered down meaningless rating with the same name as the IMCR. Then they can turn around and say "there you are a European IMCR so your now happy". The fact that it is a bare ghost of its former self wont matter an iota to them.

I dont know what the answer is maybe just to say " No we need this in the UK on safety grounds and will NOT abolish it in the uk, full stop".

But other than tea and biscuits and appoving burps dont expect anything from EASA like you said i cannot imagine :sad:

Pace

[Whopity]

From the latest AOPA Newsletter:
EASA is overwhelmed with problems of its own making, having rewritten huge numbers of aviation regulations and sought to introduce new restrictions without any real reason for them...

...... EASA has received 13,000 objections from industry. Some 40 percent are from helicopter operators ...

The EC’s patience with EASA is running out. Deputy DGTREN director Zoltan Kazatsay wrote an impatient letter urging EASA to stop reinventing the wheel and added: “The Commission believes the time has come to take clear decisions to steer the Agency in a different direction. In this respect it is essential to carefully consider the alternative of going back to the original structure and wording wherever possible of JARs and ICAO requirements, which should be transposed into Community law.”

EASA’s ‘new direction’ is expected to be announced in the next two months

[Pace]

EASA is overwhelmed with problems of its own making, having rewritten huge numbers of aviation regulations and sought to introduce new restrictions without any real reason for them...

...... EASA has received 13,000 objections from industry. Some 40 percent are from helicopter operators ..

Great maybe EASA will go and fade away as a bad job. The FAA could always cover the position until something better comes along.... sort of stand in :D

think how much money the industry would save without all the quangos beurocrats meddling and wrecking everything at present and at vast costs all round.

Pace

[bookworm]

In any case, there's a good chance that EASA will heed the well-deserved handbagging they received from the EC and will remove their attentions from sub-ICAO licences and ratings.

...which will result in the end of the IMC rating with no replacement whatsoever.

[BEagle]

No, it won't. Competence for sub-ICAO matters would be devolved to national authorities under the principle of subsidiarity. The Basic Regulation might need to be amended to support this, however.

There is an alternative strategy should the EASA €urocrats fail to accept the UK IMCR as it currently stands.

The pain problem is that the bumblers at EASA cannot understand that you don't need the same levels of training to operate to IMCR minima as you do to IR minima - and that such IMCR minima are entirely adequate for the vast majority of private pilots.

[pa28r driver]

so here i am, still none the wiser........
ive already put on hold my imc training... after doing a number of hours already.the impression i got was that easa was going to introduce a form of (light ppl ir) but im not sure exactly where i got that from.......
so whats the general consensus of opinion from you knowledgable people
should i think of booking and continuing my imc or should i wait .......in the hope that easa will slide slowly and painfully into total chaos and therfore somebody in command in whitehall /brussels or wherever these eurocrats reside will suddenly look up from his/her expenses claim form and realise that easa is just a croc of timewasting and expensive paper generating quango upholding cr*p (rant over .....but it felt good )
id love to continue with the rating but im reluctant to spend money that may result in a non rating in a couple of years
thanx for looking
best regards to all
pete

[Fuji Abound]

It is rare to find a rating lost without some form of grandfather rights - in fact I dont think it has ever happened. Moreover all those people who have spent £x on a rating and find they have lost their priviliges (if that were to happen) are going to be prettied annoyed. I suspect there would be a rather unpleasant backlash.

Perhaps that helps answer your question.

[pa28r driver]

thank you Fuji
my thoughts entirely, however easa seems to be riding roughshod over us all.
regards pete

[Fuji Abound]

They may, we will have to see, but if they do, you, I and several thousand other UK pilots may still have something to say. If it all goes wrong all hope is not yet lost.

[1800ed]

I share the same concerns as 'pa28r driver'. I'd like to do my IMC some time in the future but am concerned about what EASA are going to do with it. It seems silly that they're making such a hash of things; because I'm sure there are other pilots out there who share the same concerns and thus being put off doing valuable training.

(But thanks for the rational explanation Fuji!)

[London Flyer]

Disregarding the regulatory considerations, it has been stated on this forum many times that the skill set provided by good IMC training (and maintained through including IMC sorties with your VMC flying) is something that cannot be taken away from you. It enables you to deal with the obvious - entry (inadvertent or not) into cloud - as well as those conditions where although the conditions are technically VMC, instrument skills give you comfort: water crossings with no apparent horizon, hazy days where the VV is fine but horizontal visibility is terrible.

It's a fun course. Go for it. The ground exam is not difficult (but many people prefer to study beyond the requirements for the theory exam - Air Pilot's Manual Vol. 5 is good for learning about holds etc. that are not required for the IMC skills test).

[stickandrudderman]

When would "now" be a good time?:ok:

[Shunter]

Anyone who wants to do an IMC rating, but decides to hold back or abandon it due to what may, possibly, sometime in the future happen as a result of EASA is rather stupid IMHO. The skills are invaluable and it will be years before anything happens. If it happens.

[JTN]

LondonFlyer's comment is very valid (and thanks for the EDDI chart - managed to get there before they closed it :cool:). The skills the rating generates are far more important than the rating itself IMHO. Those of us whose licences are not held on the UK register have no chance of such a rating, yet I and many of my friends undertake regular instrument-based flights with instructors and safety pilots and informal ground-school to prepare ourselves for the conditions the IMCR covers.

I suspect EASA will come to some arrangement (perhaps grandfather-rights, perhaps some "fudge"), but either way don't be put off the training.

[421C]

Beagle, apologies in advance that I'm in a rush and don't have time to phrase my reply as politely as I should. You and others take the subject seriously, so perhaps some facts might be useful, although I know they are always a nuisance when they get in the way of a good rant.

Firstly, you refer to individual, personal stances taken on FCL008. I can only conjecture a reply, because, as I understand it, the workings of this group, like any such group during its working phase, are confidential except for agreed releases of information into other domains. Therefore your are either
a) making this up
b) posting details in the public domain that are a breach of confidence by you or someone along the chain of chinese whisperers who gave you this "information"

I will use your method of typing 'wrong' spelt in capitals.


FCL.008 includes UK representation, so you'd think that we could be reasonably assured that the future of the IMCR was being well protected....

WRONG!
I agree. You'd be totally wrong to think that. One thing that is in the public domain is FCL008's terms of reference, which I am sure someone who feels strongly about its inner workings would have read. The scope of FCL008 was not to "save the UK IMCr". It was to review the IMCr and other national IFR ratings to see if there was an EASA-wide analogous qualification that could be agreed. The EIR was the best such structure that could be agreed. The proposal that the UK IMCr should be adopted across Europe is not acceptable to the rest of Europe. It simply isn't. And FCL008's job was to find a proposal that was. The individual who worked on that succeeded in a difficult task


This requires the same theoretical knowledge requirements as the proposed PPL/IR
WRONG!


dreamed up this lunatic idea

You should write to Australia's NAA and tell them an enroute instrument qualification is 'lunatic'/'chocolate tea pot' etc etc. They have been labouring under a delusion that it's a safe and effective stepping stone to a full instrument qualification.


'almost certain' VFR conditions for take-off and landing (whatever that means)

I'll tell you what it means. You take-off VFR. You plan to land somewhere and the forecast has to give you reasonable confidence you can do that VFR. You make this sound bizarre and unfathomable, but hold on.....it's what you do flying VFR. That's why it's an Enroute qualification.


AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR

No-one has claimed it is. The only rationale for the EIR is that it is the best EASA-wide sub-IR qualification that could be agreed.

Saving the UK IMCr is a different matter. A while back, it seemed there was no scope for countries keeping national qualifications. EASA made it clear that they were taking over sole jurisdiction for all pilot licensing and if something wasn't in EASA-FCL, it couldn't exist. It now seems to have back-pedalled on this, and there may be a prospect of the UK hanging on to the IMCr. If this happens, great. If not, and the ranting of the UK IMCr militants kills off the EIR, then the IMCr community will be left with nothing except the full IR.

The best reason to keep the IMCr in the UK is that it is a good qualification which works and is proven. The worst reason is the IMCr-militant-ranters position that the rest of the aviating universe are dangerous lunatics for not supporting the IMCr everywhere in Europe. It's just laughable to Europeans to hear a UK minority proclaiming the rest of the world is wrong and out of step with the UK.

does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.

And who do you speak for? At least the people on FCL008 know what they are speaking about. FCL008 is not a save-the-IMCr-crusade. It's a group to develop EASA-wide IFR amendments to EU-FCL. The IMCr is not acceptable to Europe as an EASA wide qualification. So what should that group have been doing? If what you report about FCL008 is true, I am glad this "individual" is there. It sounds like he is able to grasp the basics of terms of reference and purpose of a specific regulatory body.

Instead of lambasting FCL008 people for something they are not empowered to do (save the IMCr) and criticising them for doing their best on what they are empowered to do (find acceptable EU-wide amendments to FCL) why don't you just go and save the IMCr yourself.

brgds
421C

[BEagle]

If the Aussies had the IMCR, they wouldn't need to consider the absurd chocolate teapot rating either!

If you keep up with the aviation press, it is quite easy to elicit the current FCL.008 stance.

It is specifically because of this lunatic EIR idea that I am indeed involved in 'saving the IMCR'.

The only rationale for the EIR is that it is the best EASA-wide sub-IR qualification that could be agreed.

That is no justification. The whole idea of this absurd 'EIR' is nonsense. Recently AOPA's General Aviation requested readers to respond with their opinions about the idea.

Guess how many were in favour of the EIR?

You can find out in the next edition.

[421C]

If the Aussies had the IMCR, they wouldn't need to consider the absurd chocolate teapot rating either!

You're right. It's not just Europe - it must be that the Aussies, and all the other 100 ICAO countries (or whatever the number is) except the UK are chocolate teapot lunatics for not having the IMCr. Even if you believe this, you must see why outside the UK it's perceived as a ridiculous, laughable position.

That is no justification
You are right. It's not a justification. There's nothing to justify. It's a factual outcome of the FCL008 process, the best sub-IR qualification the group could agree on was the EIR. No-one is telling you that it's better than the IMCr for the UK or a replacement for it if the IMCr can be saved. Go and save the IMCr, as I said.

Recently AOPA's General Aviation requested readers to respond with their opinions about the idea.

I don't need to. I can guess. I can also guess if you asked AOPA members whether we should scrap all the EASA regs and just cut and paste everything from the FAA, they'd prefer that. I would. But it's a hopeless cause. Just like getting EASA to accept the IMCr across Europe.

The point of the FCL008 proposal is
a) that it's something European pilots might want as better than nothing - because they don't have an IMCr to save (and forgive me if it comes as a surprise that FCL008 had to consider the interests of non-UK pilots too)
b) that it's something that UK pilots might want, as better than nothing, if the IMCr can't be saved.

I just don't understand your hostility. I can understand why you might prefer the IMCr, or even strongly prefer it. But your remarks about lunacy and chocolate teapots are just ranting.

One thing I do like about the European attitude is the airspace issue. We accept the IMCr in the UK because we accept that vast swathes of low level airspace like the London TMA and the CI zone should be Class A and that all airways should be Class A - totally barred to VFR traffic and non-IR holders. This would be considered chocolate teapot lunacy almost everywhere else in the world. The very fact that a light aircraft might want to fly in an airway is so extraordinary to you that you castigate it as "playing airliners". This is a uniquely parochial UK perspective and I am very glad it prevails in few other places. It would be bafflingly lunatic to most other countries. That's, in part, why our IMCr is so silly to them.
Enroute IFR is much easier to train for than instrument departures, arrivals, holds and approaches. Ask any IR candidate how much they struggle with the "flying along the airway" part of the IR. Yet we have a qualification which is sub-IR that permits all the difficult parts of the IR and not the easy ones. This, anywhere other than the UK, is chocolate teapot lunacy. We accept it because we accept the default undertone in the UK that the sky belongs to NATS and the airlines and they can keep inconvenient users out - because there can be no other reason for the prevalence of Class A. EASA does not accept this kind of "user segregation by airspace" and I am glad they don't.

brgds
421C

[BEagle]

Rant all you like, but any so-called 'instrument qualification' which runs the risk of the user being unable to make an instrument approach because the 'almost certain' VFR conditions turn out not to be is just plain absurd.

Who is going to be brave enough to try to define what 'almost certain VFR' actually means?

The UK has 40 years of proof that the IMCR saves lives - the rest of Europe certainly should listen.

FCL.008 talks about 'preserving grandfather rights' for the UK IMCR and the 'wonderful opportunity' to spend thousands of pounds 'upgrading' to the PPL/IR. Nowhere have they said that they support the retention of the UK IMCR; the lunatic EIR is not an acceptable alternative and needs to be strongly opposed by anyone with any concerns about safety.

[Captain Stable]

I agree with BEagle about the (unnamed) bEurocrat's sticking his silly, uninformed nose in.

From conversations I have had with various people "in the know" and others actively involved in EASA negotiations, it appears to me (and others) that the likelihood is that not only will the IMC rating continue, but will be recognised in Europe, with other states introducing their own equivalents.

The format of the IMC rating may well change, however, and in other, similar situations those with grandfather rights on any change of legislation have never to my knowledge been let down. That is reason (1) why people should IMHO continue their training.

Reason (2) is that the requirements may be stricter in the future, although I believe the privileges that go with it will remain unchanged. You would therefore have to work harder for your rating in the future.

Reason (3) is that, even if the IMC should vanish below the surface without trace and nobody with one be approved to do anything beyond standard VFR flying, the IMC training is good discipline. The abilities that come with the training will stand anyone in good stead should they find themselves having inadvertantly departed VMC. Let's face it - SEN APP is not going to refuse an ILS to a PPL (deceased IMCr) if they have, from no or little fault of themselves, suddenly found themselves VMC "on top" and the only way down is an instrument approach through a thinnish layer if the alternative is that they spend the rest of their lives looking for a hole to descend through. Should someone need an ILS in such circumstances, it would be very much preferable that the pilot has been trained to carry it out rather than "busking" it untrained.

There is no point whatsoever to an "enroute" IMC rating with no approach privileges or training. If you get into IMC enroute (or even if it's only VMC "on top") you need to get clear of that weather somehow. So not having approach privileges and training is lunatic. What is also lunatic is the "almost certain" stipulation - one can only assume that the idiot who recommended this is not a pilot.

[IO540]

My only input here ;) is going to be to say that almost everybody who takes a significant pre-emptive action in fear of threatened future legislation if that legislation appears unpopular and exceptionally aggressive yet bringing no personal brownie points to those forcing it through is going to lose their money.

The most obvious examples are of people who went N-reg (in preparation for the FAA IR) and then, when the DfT threatened to kick out N-reg planes after 90 days' parking they got scared and went back to G (£10,000 perhaps??) and thus have scuppered their IFR privileges for a few years and possibly much longer.

The "UK IMC" issue is a similar sort of thing.

As others say, things are invariably grandfathered into something else...

I would definitely do the IMCR.

[tmmorris]

One statistic I haven't seen (AOPA - perhaps you are listening and could ask?) is:

Of those who hold an IMCR, how many wish they could afford an IR?

In other words, for how many of us (like me) is an IR what they really want, but they simply can't afford the money and time off work to get one?

I suspect the number is very large.

Tim

[BEagle]

tmmorris, it's probably not just the cost, there's also the disproportionate theoretical knowedge requirement.

But really - something like 25 hours more training, a test with the CAA plus CPL-level exams just for 200 ft or so lower at Decision Height and the right to bumble along airways?

No thanks - the IMCR fits the bill perfectly for very many people.

[dont overfil]

It is frustrating to be barred from class A especially places like WAL when travelling north/south, but without the IMC rating, even with its limitations, I would probably have given up flying years ago due to the number of cancelled trips.
The senario of being based in the flatlands under the London TMA as opposed to being based in Scotland is very different.
DO.

[Fuji Abound]

A little history. Prior to 1970 PPLs flew in IMC outside CAS (such that CAS existed). These pilots held no rating and received no training as part of the PPL. The more sensible took some instruction and flew VDF let downs.

It was decided that training and a formal qualification made sense. Of course many pilots had already acquired the ability to fly on instruments. They were grandfathered into the new IMC rating by test alone; everyone else undertook 10 hours of training and a test.

I doubt the merit of comparison with other countries. In those days GA was strong in the States and reasonably strong in the UK. The US went their way and devised an Instrument Rating that was widely accessible. In our indomitable way we devised a rating that enabled the private pilot to continue doing what he had always done, but kept him out of the airways. In other countries, such that GA was a popular pursuit, pilots continued to find there own way on top of the cloud much as they continue to do today. South of the UK they rarely had the need to fly in the clag and north of the UK – well they just didn’t.

For those reasons the IMC rating is unique to the UK.

It has stood the test of time – and what better test is there? Its safety record is exemplary, some say there has never been an accident involving an IMC rated pilot in instrument conditions, and some say there has been a very few accidents. Which ever are right it is a remarkable success story.

EASA was mandated to enable a common regulatory framework among member states. That meant out would go national ratings and in would come single European ratings. The trouble is no one told the French. They rather liked there mountain rating and weren’t about to have Johny Foreigner. landing on their altiports any more than they were going to have us teach them to ski. Ah yes then there was the Brevet de Bas, they were also not about to give that up without a fight. No one else in Europe really cared about the Frog’s rather quaint ratings – after all they didn’t have mountains, or if they did, they didn’t have many mountain airports, or if they had both, they didn’t have any GA.

They did however care about the instrument rating. The professional pilots associations that dominated EASA certainly didn’t want amateur pilots playing with the big boys and, in any event, they didn’t understand the IMC rating because, after all, they didn’t have it. If those dumb Brits. had a death wish that was up to them, but they weren’t going to do it in their airspace, nor where they going to Lord it up in EASAs airways while everyone else played catch up.

The trouble was no one thought to ask us. Worse still, no one thought to establish whether their preconceived ideas had any foundation. Regulatory impact assessment – what was that? Event the bastions of the UK GA community didn’t really know what they thought or which horse to back.

EASA received their first surprise when two and half thousand British pilots petitioned the PM and generally caused quite a rumpus about the threatened demise of the IMC rating. Timothy Kirkhope one of our MEPs and a keen pilot waded in. An “emergency” meeting was called in London hosted by the CAA and EASA at which EASA acknowledged they were not about to so readily kill off the IMC rating.

EASA then went into closed session. Committee members were required to sign confidentiality statements and the leeks started – so much for open Government.

So where are we? EASA realise the IMC rating is a hot chestnut. They have to placate the Brits. but they don’t really want the Brits well, erhm, being cowboys.

Of course we Brits know we are not cowboys – well any more than the French who just punch through the clouds to get on top with a shrug – I neeeever saw any cloud.

Fortunately there are still lot of pilots in GA in the UK. Sadly they come and go, and the turnover is high, but many put themselves through an IMC each year, renew their rating for many of the years they remain in GA and come to appreciate why the IMC rating is so important.

If enough keep the faith those doubters in Europe will not have their way, but we may need to be prepared to fight for our rights.

Sorry to have bored you.

[1800ed]

Good post :ok:

[FREDAcheck]

Of those who hold an IMCR, how many wish they could afford an IR?Not me. I'm sure I could afford IR if I wanted to, but I don't really want airways or other Class A flying, and wouldn't use it enough to remain sufficiently current.

However, I fly IMC enough for the sort of flying I do - which means keeping to my own very conservative minima.

[IO540]

I don't really want airways or other Class A flying, and wouldn't use it enough to remain sufficiently current.

Paradoxically, and this is the great secret of the IR ;) , flying "airways" is a lot easier than using the IMCR to its full in UK Class G.

It is not unusual to do a 5hr flight and log 10 minutes of instrument time on it. The rest is VMC on top in sunshine.

The IR gives you IMC privileges, obviously, but the equally practically important privilege is the implicit whole-route IFR clearance. You can fly across Europe, knowing nothing about controlled airspace, or even countries. The other day I did a 6:20 flight across half a dozen countries and barely noticed the changes.

[bookworm]

What is also lunatic is the "almost certain" stipulation - one can only assume that the idiot who recommended this is not a pilot.

Does JAR-OPS1 (or EU-OPS now) not require that before you depart on an IFR flight the weather at either your destination or an alternate is forecast to be "almost certainly" above your operating minima? Is that also mindless bureaucracy that couldn't have come from a pilot?

[Fuji Abound]

I'll tell you what it means. You take-off VFR. You plan to land somewhere and the forecast has to give you reasonable confidence you can do that VFR. You make this sound bizarre and unfathomable, but hold on.....it's what you do flying VFR. That's why it's an Enroute qualification.

Let’s examine how this might work in the UK.

Firstly, the TAF is not going to tell you “if almost certain VFR conditions” will exist at your destination.

It will tell you if the cloud is scattered, broken or overcast – at any rate so far as the lowest layer is concerned. It doesn’t necessarily tell you much about higher layers.

Now for the VFR pilot that is all fine and Dandy. His intention is to stay below the lowest layer. He doesn’t really mind if the scattered turns into broken or the broken into overcast. What he does care about is that the Met boys don’t get the base wrong and he finds himself squeezed between the terrain and the base.

The IMC pilot’s modus operandi is a little different. Our man is worried about getting himself up into the airways. He is not too bothered what he finds in the airways because within reason he can now fly through cloud. However he wants to ensure his let down is “almost certainly going to be VFR”. The forecast was scattered at 1,000 feet so that seemed good enough. The trouble was the met boys didn’t tell the clouds who decided a little more organisation was called for – scattered became broken, how often have we seen that. Now our man is flying the approach, but what should he do – he feels comfortable following the procedure, but there are more than a few pesky clouds in the way. Perhaps he will dodge around and between them – yep that should be fun. Trouble is no one told the radar controller that EASA had just invented the dodge and weave approach.

That is a simple example. In the real world there are all sorts of different examples why who ever dreamed this one up has no idea what they are talking about. The funny thing is they don’t even realise that some at EASA get exactly what they wish – the effective end of the IMC rating and no meaningful change to the IR. Its brilliant – Sir Humphrey at his best.

God save us if if we end up with this sort of silly instrument en route rating.

[FREDAcheck]

God save us if if we end up with this sort of silly instrument en route rating.Exactly.

With an IMC rating, I would not plan to fly an instrument approach on my own with forecast cloud base below 1000 feet. But on a journey of more than an hour, say, a TAF of BKN010 can turn into a METAR of BKN005. Now the IMC rating teaches bad-weather circuits with a cloud base of 500 or 700 feet, but how do you get down from IMC to VMC well below MSA? That's why an IMC rating must enable pilots to fly an instrument approach.

[421C]

Beagle,

You keep saying "almost certain", a choice of words which I don't believe anyone would put in a piece of regulation. Please give your source or reference. FCL008 has not finished AFAIK, so I doubt any final wording is settled. Something like "the forecast indicates" is more likely, I would have thought.

any so-called 'instrument qualification' which runs the risk of the user being unable to make an instrument approach because the 'almost certain' VFR conditions turn out not to be is just plain absurd.

What about the so-called "Private Pilots License", which (just about everywhere except the UK) allows holders to fly in VFR above IMC. You probably aren't going to claim almost every non-UK PPL is 'chocolate teapot lunacy'. How is the VFR on top scenario different? You find yourself above a solid layer. Big deal, you got a weather forecast that indicated VFR at your destination or somewhere enroute. So that's where you establish VMC in sight of the surface.

We don't need to look far to wonder why other countries might oppose the IMCr. Your utter intolerance for the EIR is a good illustration of how parochial people's reactions are to unfamiliar qualifications. I am agreeing that you might prefer to IMCr and only debating your view that the EIR is "lunacy/dangerous/choc teapot" etc. Why should Europe be interested in how well the IMCr works in the UK any more than you were interested in how well an Enroute qualification works in Australia. You dismissed it without a moments consideration.

Have you ever stopped to consider how the IMCr might appear to other countries, especially countries who actually apply the prinicple of equal access to airspace for all users, rather than the UK's Class A segregation?
The IMCr gives holders all the privileges of an IR (except for some departure minima) but its standards are below the ICAO minmum for an IR, and that minimum is a pretty undemanding one. It lets you accept a SID or STAR or Hold in controlled airspace without necessarily having ever been shown a terminal procedure plate, let alone having been trained or tested in terminal procedures. You don't think the words dangerous-chocolate-teapot-lunacy might spring to their minds as readily as they spring to yours?

Fuji,

I agreed with much of your post, except the bits about the Moutain Rating and the Brevet de Bas.
What possible objection could anyone have to the Moutain Rating? So why criticise EASA for adopting it?
But you must know why EASA couldn't accept the IMCr as a European rating. Airways and many very large airports are not Class A in much of Europe. If you think the UK experience of the IMCr is so good that EASA should have accepted it, then why not start with our own CAA and get them to accept IMCr privileges in UK airways and the London TMA. Then we could tell Europe why they should accept the IMCr in their airways and large TMAs.
The Brever d Bas is another example of intolerance. It must be dangerous and lunatic to not allow our sub-ICAO IFR qualification, but it is dangerous and lunatic to allow someone else's sub-ICAO VFR qualification.

brgds
421C

[421C]

Fuji, my previous post ccrossed with yours....


Now for the VFR pilot that is all fine and Dandy. His intention is to stay below the lowest layer


...however I think it answered it. The point is that VFR pilots everywhere else in the world don't have to stay below the lowest layer. They can fly VFR on top. So your UK scenario of the EIR holder getting into trouble is tested all over the world by hundreds of thousands of PPL holders who could fly VFR on top and have analogous issues about landing VFR - and who may have practically no IFR training if things don't work out weather-wise.

So just as you ask people outside the UK to accept the IMCr works, is it possible for you to accept that pilots can be in or above a cloud layer enroute and through sensible weather planning still land under VFR, based merely on the experience of practically everywhere else in the world.

As I said before, the struggle you and Beagle are having with this EIR concept should entirely answer the question as to why people reject the IMCr. People reject unfamiliar qualifications, and, it seems to me, the most militant IMCr campaigners are the quickest to cry wolf on qualifications and practices unfamiliar to them.

[FREDAcheck]

421C,

How does a pilot with an en-route IMC qualification get safely position himself or herself for a visual landing if cloudbase is below MSA? In practice this would seem to mean TAFs forecasting cloudbase of at least 2000 feet, to ensure it doesn't actually go below 1000 feet, in which case why bother with the IMC rating? You can comfortably fly VFR below cloud.

I don't think there's any such thing as "virtually certain VFR" at the destination, not in the UK at any rate, unless the weather is so good as to make the en-route IMC qualification irrelevant. The "chocolate teapot" analogy seems pretty apt to me.

[Pace]

421C

I started a thread called Scrap the IMCR or something like that arguing the fact that trying to save the IMCR would play right into the hands of EASA with those proposals that is what appears to be happening.

EASA would purely take what is available already in Europe, tinker with it a little and call that the EIMCR but it would not in anyway resemble what we have in the UK in any shape, form, or manner.

The other option in my thread was to make the IR more attainable to the working pilot who doesnt have the time to study for exams for a couple of years in their free time and much of it having little relevance in a practicle sense in flying in the IFR system.

The flying standards should be the same as the full IR but the study time more relaxed and directed at PPL IR flying rather than 747 over the world flying.

We all know the FAA IR is much easier for the time stretched PPL to achieve.

We all know that safety comparisons between EASA and FAA IRs show that neither is better or safer than the other but the EASA variety is more directed to a profession in aviation and on a sort of university study basis.

The big problem with all this is the PPL is given very little importance in the scale of things unlike in the USA. Many European countries had hardly any GA and many were actaully opposed to GA.

The massive costs imposed on aviation by quangos and regulators echoes what happens in European society which is obsessed with the big brother state so we are all on a loosing battle as our freedoms and individuality are eroded day by day :sad:

Pace

[BEagle]

The source of the ridiculous 'almost certain' came from the following extract submitted to FCL.008 by one of its UK members, who also admits to proposing the Chocolate Teapot Rating:

I came up with the concept of an En-route Instrument Rating. This would allow access to all classes of airspace in line with the EASA principal that license privileges should not be defined by airspace class.

The associated weather limitations would be such as to make it almost certain that a departure and arrival could be conducted under VFR.

Read FTN and/or GA to find out more......

[Fuji Abound]

The point is that VFR pilots everywhere else in the world don't have to stay below the lowest layer.


I agree, but the conditions must be such that they can maintain VMC for the entire route including the departure and arrival segements. Whilst many may bend the rules, in new EASA parlance the clouds have to be pretty few and far between to meet the legal requirments. You can forget about departures or descents with broken forecast.

The law aside the more adventurous VMC pilot will successfully dive through the gaps in the clouds to maintain VMC but I dont want pilots doing that in my ATZ thank you.

I fly aeros; when we topple the AI above a broken overcast finding a way down through a small gap is not a problem, but it sure as hell scares many PPLs to death.

As I said earlier the modus operandi of an Instrument Rated pilot is quite different. He is not concerned about flying an approach down to 1,000 feet. He is not interested in dodging between clouds having been flying on instruments for the last hour. In fact the last thing he wants is an unusual attitude.

It is just madness to expect him to dodge the broken bits at 1,000 feet during the arrival segement - indeed a recipe for disaster just so he can claim he was VMC thoughout the approach segement.

In reality I dont believe that whoever dreamed this up has got any concept of real world flying on instruments with the weather we have in Northern Europe.

As to the mountain rating, I agree, teasing aside, I have no objection with the French keeping it.

[FREDAcheck]

I started a thread called Scrap the IMCRWith friends like that...

Joking aside, I know that's taking your views out of context, but neither an en-route IMC rating with VFR arrival nor an "accessible IR" cuts the mustard.

As lots of us are saying, an "almost certain" VFR arrival is a fantasy.

Equally, an "accessible IR" isn't really accessible to the majority of PPLs unless it's virtually as accessible as the current IMC rating. Most IMC rating holders would probably not use it enough to remain current (=safe) in airways, SIDs, STARs etc. I'm all in favour of making the IR more accessible, but that's not enough.

The IMCR is an en-route IMC qualification but allowing instrument approaches to conservative minima. That's what we need, it almost certainly saves lives, and it's worth fighting for. On safety grounds alone, I really hope our representatives face down any opposition to its retention in the UK.

[421C]

The IMCR is an en-route IMC qualification but allowing instrument approaches to conservative minima. That's what we need, it almost certainly saves lives, and it's worth fighting for. On safety grounds alone, I really hope our representatives face down any opposition to its retention in the UK.

I agree with you. I think the IMCr works well in the UK and I don't think any EASA qualification will be a direct substitute for it - either an EIR or a more accessible IR. So I hope the UK can find a way to hang on to it because EASA isn't going to accept it and despite the campaign, I don't see the UK leaving the EU over it.

As lots of us are saying, an "almost certain" VFR arrival is a fantasy.
And I am saying that an en-route qualification isn't fantasy. It isn't fantasy because an entire country (Australia) seems to know something you don't. It isn't fantasy because pilots fly VMC on top and arrive VFR. It isn't fantasy because IR and IMCr rated pilots fly enroute IMC today to arrive at VFR-only airports the whole time. How often do they have to divert to their IFR alternate? Rarely. And an EIR holder would need a sufficiently good forecast to turn that rarely into a very rarely indeed; just as, amazingly, VFR pilots manage to fly in marginal VFR and very rarely need an instrument approach.

On the other hand, who cares. No-one is trying to "sell" the EIR to UK IMCr pilots in order to stop them campaigning to save the IMCr. I only hope that campaign's pleas are heard by people more tolerant and broad-minded than the IMCr campaingners themselves.....I still find it ironic that their imaginations can't stretch to en-route IFR but expect others to stretch to understanding why the world's least-demanding IFR qualification (the IMCr), granting the same privileges as the IR for all the most demanding IFR tasks, is a "life-saver" whilst any other proposal is lunacy/fantasy/chocolate teapot/danger/ etc etc.

Keeping the IMCr in the UK is a good thing because it has been shown to work. Not because any other formualtion for any other country is unworkable. The FCL008 initiative for an accessible IR is a potentially great step forward, and the EIR is a further step to make the accessible more accessible - by giving people an interim stage, to learn some basic instrument flight skills and build some experience in undemanding IMC. It is not particularly intended to be a qualification vast numbers of people would want as their end goal. But some may want the ability, on a marginal day, to fly through or in a layer rather than underneath it, when the forecasts suggest this can be done safely. Heaven forbid that some pilots in some countries might have aspirations different from those of UK IMCr holders who want nothing more and nothing less than the IMCr privileges.....

rgds
421C

...and another thing. When is AOPA going to publish its IMCr survey findings? Since Approach privileges are so critical to IMCr holders and En-route IFR privileges on their own are so worthless, no doubt that survey will show most IMCr holders regularly flying instrument approaches in IMC.....let's wait and see....

[FREDAcheck]

And I am saying that an en-route qualification isn't fantasy. It isn't fantasy because an entire country (Australia) seems to know something you don't. It isn't fantasy because pilots fly VMC on top and arrive VFR.
What they may know but I don't: how do they ensure that there will be a hole in the clouds at their destination? Perhaps that works in Australia, I don't think it would in typical UK weather.
It isn't fantasy because IR and IMCr rated pilots fly enroute IMC today to arrive at VFR-only airports the whole time. I can speak only for myself, but I always have an alternate with an instrument approach to enable a safe descent through cloud if the cloudbase is below MSA. Either I land at my alternate, or (if the weather is good enough) rely on visual positioning from the instrument approach to the VFR-only destination.
How often do they have to divert to their IFR alternate? Rarely. And an EIR holder would need a sufficiently good forecast to turn that rarely into a very rarely indeed; just as, amazingly, VFR pilots manage to fly in marginal VFR and very rarely need an instrument approach.I think that the difference between "rarely" (but I can safely do it) to "very rarely" (because I'm not qualified to do it) is vast.

We're talking PPLs in typical SEPs and UK airspace, cruising between 2000 feet and about FL060. In the UK, if you are IMC (or VMC on top of overcast) at that sort of height then you generally can't say with any certainty that cloud base at your destination will be above MSA.

The thing is: if the cloud base is definitely going to be 2000 feet or more, you don't need en-route IMC as you can fly VFR below. If the forecast cloud base is less than 2000 feet, then there's a significant risk that it may turn out to be less 1000 feet, which makes a descent through IMC without an instrument approach risky.

Clearly we're not going to agree on this, but I don't think an en-route only IMC qualification is any practical use, and worse: it encourages dangerous practices.

[Captain Stable]

Furthermore, you cannot say that something that works in one country (e.g. Australia) will therefore work in the UK, where airspace is different, climate is different, terrain is different etc. etc. To try to extrapolate from one country to another is nonsense.

[421C]

Fredacheck,

how do they ensure that there will be a hole in the clouds at their destination?

The same way pilots everywhere else in the world do, who fly VFR on top on PPL privileges. They use weather forecasts and weather observation.

Furthermore, you cannot say that something that works in one country (e.g. Australia) will therefore work in the UK, where airspace is different, climate is different, terrain is different etc. etc. To try to extrapolate from one country to another is nonsense.

I wasn't doing that. I used the Australia example to counter Beagle's instant dismissal of the EIR as a fantasy/chocolate teapot nonsense with the obvious example that a sensible country like Australia (that has much in common with the UK in terms of the culture of regulation and FCL) has found an enroute rating workable. I know Australia is different, but how exactly is it different such that a qualification that works there is utterly unworkable here?


The thing is: if the cloud base is definitely going to be 2000 feet or more, you don't need en-route IMC as you can fly VFR below

How about when the cloudbase is 2000' for your departure and 2000' for your arrival but is lower somewhere enroute. Is this so amazing a possibilty? Of course not. The longer your trip, the more likely you are to be uncertain about enroute weather, or risk some very marginal scud-running.


I don't think an en-route only IMC qualification is any practical use, and worse: it encourages dangerous practices.

The fact you can list some scenarios where it isn't of practical use doesn't mean anything. It's equally easy to list many scenarios where it is sefl-evidently useful, to be effectively a VFR pilot as far as weather forecasts at arrival and departure airports are, but to be an IFR pilot enroute. Everything from the instructor or aerobatic flyer who wants to pop-through a 2000' layer for training through to someone who wants less restriction and less uncertainty flying long VFR trips. No-one is claiming any particular level of "usefullness" for the EIR, certainly not as high a level as an IR or IMCr, merely that it's usefulness is not zero as the "chocolate teapot" camp claim.

[IO540]

Does the Australian "IMCR" not have an SRA as the basic module privilege?

I believe that the proposed "enroute IMCR" would be fine if its first module had an SRA. Otherwise, it doesn't add up to me because in any case where the destination is not VFR (but was forecast such otherwise the flight would have been scrapped) the pilot will have to declare a mayday - but he will not have the skills to fly any IAP. The mayday will legalise the situation but the pilot is likely to get killed if he cannot get down without losing control or whatever.

I think of this stuff in terms of what I would teach someone as the absolutely basic requirement if I cared for them. It would be a "PPL" with an ILS. But I think that is just too radical in this case in which politics is 90%.

[englishal]

I don't know what the big deal is with "approaches". Surely the more dangerous phase is departing INTO IMC?

If they are so keen to limit the EIMCr then limit it to precision approaches - even a well trained monkey could fly an ILS..

[Fuji Abound]

421C

You have laboured the "Australian experience" with which you are clearly familiar. I assume you have flown in Australia and are aware how their instrument training works?

Well when this came up before I made it my business to see how the Australian model works.

I wonder whether your experience is the same as mine?

I would be interested to know your thoughts on what GA pilots do in Australia if they want an instrument rating and how many hold a command instrument rating.

It worries me when we refer to other models. It is all well and good if we really understand those models and can point to some sound material on how those models work but I dont see our being pointed in the direction of any substantive studies - infact I dont even see our being pointed in the direction of any studies at all.

Would you like to do so?

You refer to AOPA UK's IMC survey. That would be the one that has been running for an eternity. That would also be the one that was devised largely by the pilots on Flyer. It was a good idea, but sadly has been totally discredited. Any statistician worth his salt will drive a cart and horses through the way the questions were formulated, the promulgation of the survey, the controls to prevent duplicate replies, the effect of "leaking" data and, if we ever see the results, their interpretation. To do these things properly costs money and sadly that is something AOPA UK does not have - or at least they are not prepared to invest it in this particular direction. Sadly I know of more than a few wags who have completed the survey - shall we say with their tongue very much in cheek.

[421C]

IO540,
We don't know the EIR syllabus, so I don't know whether it includes some emergency use of IAPs in the training.

But the key answer to your point
Otherwise, it doesn't add up to me because in any case where the destination is not VFR (but was forecast such otherwise the flight would have been scrapped) the pilot will have to declare a mayday - but he will not have the skills to fly any IAP.
is that this potential scenario exists today with the vast majority of the world's PPLs who have VFR-on-top privileges. They are equally vulnerable to destination forecasts changes and just as untrained to fly IAPs.

I am not saying the EIR is brilliant and flawless. Frankly, I tend to think the ICAO system works pretty well when sensibly implemented, so the ideal answer is an accessible full IR, like the FAA one. But any EASA accessible IR is unlikely to be as accessible as the FAA one, so there does seem to be an argument in favour of an intermediate step if one can be found. Europe won't accept the IMCr, because it doesn't work in European airspace (ie. they won't accept it any more than the CAA would accept IMCr holders in Class A). The FCL008 group tried to find an acceptable intermediate qualification. I can't think of a better one that would be acceptable to Europe, so I guess it seems like a good idea to me.

brgds
421C

[Fuji Abound]

I can't think of a better one that would be acceptable to Europe, so I guess it seems like a good idea to me.


I guess that about sums up EASA - we are so bereft of ideas it is the best we can come up with - so everyone will just have to put up with it.

What a very sad iditement of the whole process - and we are prepared to go along with it.

Even the most elementary of discussions sets out all the reasons why it is a silly idea. You have some really experienced instrument pilots and instructors on here telling you it will not work. EASA needs to wake up and smell the coffee - it is them that is out of step with everyone else.

Lambs to the slaughter comes to mind.

They may well get what they think they want - but it doesnt mean it makes any sense.

[BEagle]

Europe won't accept the IMCr, because it doesn't work in European airspace (ie. they won't accept it any more than the CAA would accept IMCr holders in Class A).

AOPA UK's alternative proposal is that the UK IMCR should become a part-FCL Rating, whose privileges may be exercised in categories of airspace 'where so permitted by national law'.

So, for example, in the UK that means no Class A airways and only SVFR in Class A CTRs. Other EC states could just as easily decide where it may be used, for example 'for IFR enroute navigation only' or whatever restriction applies under the law of the land - not something EASA has any jurisdiction over.

Whereas the proposed Chocolate Teapot Rating would be a mere dumbing down to the lowest common denominator. The concept is an utter crock.

[421C]

Would you like to do so?
Nope. You're putting me in a position I haven't taken. I joined this thread to reply to opinion that the EIR was chocolate teapot lunacy/fantasy. I just made the point that Australia has a qualification with some analogies to the EIR.

I am happy to learn from you in more detail what the Australia experience tells us about the EIR. Please tell me.

brgds
421C

[FREDAcheck]

The fact you can list some scenarios where it isn't of practical use doesn't mean anything. No, you misunderstand me. I'm saying that the scenarios where it is of practical use are rare in UK weather conditions. How about when the cloudbase is 2000' for your departure and 2000' for your arrival but is lower somewhere enroute. Quite true. My point was that such occasions (where you can virtually guarantee cloud base above MSA at the destination, but where it's known to be below en route) are much less common than those where the cloud base at the destination may also be below MSA.

More important, this sort of rating would encourage pilots to set out on journeys that they may not be able safely to complete.

One of the factors that makes IMC flight potentially significantly more dangerous than VMC (in sight of the ground) flight is the fact that you can't see what's below you. You don't get the immediate warning that you should turn back. You rely on forecasts and judgement to, well, guess if it's safe to complete your journey. Without the safety net of an instrument approach to descend through cloud, personally I think IMC flight (or VFR on top) is substantially more risky than VMC. We don't need these extra risks, but we've got a solution: it's the IMC Rating.

[421C]

Even the most elementary of discussions sets out all the reasons why it is a silly idea. You have some really experienced instrument pilots and instructors on here telling you it will not work

And I thought replying to points made to me was the traditional way of having one of these discussions, which I have done.


I guess that about sums up EASA - we are so bereft of ideas it is the best we can come up with - so everyone will just have to put up with it.



So what is your better idea? You have neither convinced me the EIR is dangerous or unworkable, nor has Fredacheck convinced me that it's useless.


AOPA UK's alternative proposal is that the UK IMCR should become a part-FCL Rating, whose privileges may be exercised in categories of airspace 'where so permitted by national law'.

And what about the EASA principle that FCL priviliges may not be prescribed by national law? That seems a good principle to me, because it may protect us from special interests in individual countries banning all sorts of things. But if that helps keep the IMCr then that's fine. It doesn't stop FCL008 trying to find an intermediate rating that is acceptable across all EU airpsace. Why are the interest of those who want the ICMr kept exactly as it is totally sacred, and the interests of Europeans (and Brits) who might want to fly IFR enroute between VFR destinations utterly silly.

[421C]

Fredacheck

No, you misunderstand me. I'm saying that the scenarios where it is of practical use are rare in UK weather conditions

No, I was only disagreeing with the view that it was of no practical use. I can see plenty of scenarios where it is useful. I'm not saying it's more useful than the IMCr, only more useful than nothing between the PPL and the IR if the IMCr campaign fails, and more useful than nothing for European pilots who won't have access to the IMCr.


IMC flight (or VFR on top) is substantially more risky than VMC. We don't need these extra risks, VFR on top is perfectly acceptable in the rest of the world (I know the rest of the world has an awful habit of being out of step with the UK, so they must be all wrong....)

but we've got a solution: it's the IMC Rating.
The EIR is an alternative to nothing between the PPL and IR for all the other pilots in Europe who won't have access to the IMCr "solution" and for UK pilots if the IMCr solution fails. It also might have value for UK pilots who might actually want to fly long trips in airways outside the UK without worrying about enroute weather, as long as their destination is VFR.

[BEagle]

And what about the EASA principle that FCL priviliges may not be prescribed by national law?

EASA itself has already proposed 'where permitted under national law' in other areas. So what is sauce for the goose....

In any case, the IMCR privileges would be universal. But airspace regulation varies from country to country. National law would limit where the rating could be used in those nations who decide their airspace structure is such that they would only permit en-route IFR (or whatever other limitation they would wish to apply to their airspace).

[Fuji Abound]

And I thought replying to points made to me was the traditional way of having one of these discussions, which I have done.

Agreed. However, if few people are saying its black and a few thousand are saying its white the few must ask if they are out of step.


And what about the EASA principle that FCL priviliges may not be prescribed by national law?


May I refer you back to the Mountain rating. What do you do if you want to land at an altiport in Italy or Spain?


I am happy to learn from you in more detail what the Australia experience tells us about the EIR. Please tell me.


You see that is the point. It is easy to justify changes by reference to other models, far harder to produce solid evidence that these models have anything to offer. The danger is that if they are mentioned enough we all believe it without thinking to check for ourselves whether there is any substance in the argument. How many on EASA are doing just that?

[FREDAcheck]

421C,

Perhaps we agree on facts, but we differ on the priority we attach to them.

I consider an en route only rating to be substantially inferior (less useful and less safe) than the IMC Rating and not a satisfactory compromise. Dare I say it: I'll bet my view is the majority one among UK PPLs.

I'm appalled at the thought that UK representatives might consider en route IMCR acceptable as an alternative, and I hope this is not the case. To have an en-route IMC rating in addition is great, if other countries agree. But it should be clear that preserving the IMCR in the UK is a precondition for the UK. If other countries can have national ratings (e.g. altiport) then the UK can.

[421C]

I consider an en route only rating to be substantially inferior (less useful and less safe) than the IMC Rating and not a satisfactory compromise. Dare I say it: I'll bet my view is the majority one among UK PPLs.
Of course you may say it. No-one was claiming the EIR is superior or safer. I was just disagreeing with the more extreme chocolate teapot/fantasy/danger opinion.

I'm appalled at the thought that UK representatives might consider en route IMCR acceptable as an alternative, and I hope this is not the case. No-one's saying it's "acceptable". My understanding is that FCL008 were asked to review sub-IR quals to apply to all EASA countries, and since none of them accepted the IMCr, the EIR was the best interim qualification they could design.

preserving the IMCR in the UK is a precondition for the UK A "precondition" for what? Not leaving the EU in a huff? EASA's jurisdiction is already European law.

If other countries can have national ratings (e.g. altiport) then the UK can.
The Mountain rating is not a national rating - it is an EASA-wide rating. I don't know of any national ratings.

[Captain Stable]

421C, there is nothing to stop the UK filing differences with EASA. However, there are other fish to fry. One is actually having the IMCr recognised in other EASA states if possible.

I'll rise to your bait - your suggestion that an EIR is preferable to nothing between the PPL and the IR. I disagree. I think it will encourage people to fly in conditions for which they are neither qualified nor trained and lead to a false sense of security. I can't remember ever being flying in a spamcan over the sort of distances they fly when the weather has been VFR for departure, down to less than 2000' enroute and "virtually certain" VFR at destination (or alternate).

And with no approach privileges, how are people supposed to let down? Just descend through the murk and hope?

The "virtual certainty" of VFR weather at destination will (possibly) occur on a maximum of two days per annum in the UK. The rest of the time, "virtual certainty" in the accuracy of TAFs and their timing is a falsehood that will sucker in far too many people. I can just hear the barristers discussing "virtual certainty" and the likelihood of weather forecasters getting it right to that extent in the courtroom wherein is held the Subsequent Inquiry.

Sorry - but not only is it a chocolate teapot, it's a thoroughly dangerous one. I speak as someone whose first training after PPL was an IMCr, holds an IR with rather a lot of hours in elephant's backside conditions (=grey and ****ty) and now also instructs people in how to hold it all together when things go pear-shaped. As a fairly new PPL/IMCr, I also managed to fly inadvertently into IMC Wx - and was bloody glad of the training I had received that got me out of it without turning inverted and throwing a rather nice Arrow at the ground at a higher-than-usual rate of descent. An EIR would not have achieved that.

[Fuji Abound]

The Mountain rating is not a national rating - it is an EASA-wide rating. I don't know of any national ratings.


It is? You dont need it to land at any other altiport in Europe so far as I am aware? The only nation that wants it is France.


My understanding is that FCL008 were asked to review sub-IR quals to apply to all EASA countries, and since none of them accepted the IMCr


Really? The CAA say they support the IMCr and so does AOPA UK so I wonder who is not telling the truth. I wonder why we should be suspcious of committee behind closed doors - open govenrment, hmm.

A "precondition" for what? Not leaving the EU in a huff? EASA's jurisdiction is already European law.

Indeed. The poll tax was law, now there is a thought. Whether UK pilots have the courage to take on EASA will remain to be seen but it really doesnt matter.

Anyway, debate as you will, nothing is about to happen just yet. The gauntlet has been laid at EASA's feet, it remains to wait and see how they respond. It could be a very long while before very much changes. :}

[421C]

nothing to stop the UK filing differences with EASA
Yes there is. I thought it was that you can't just "file differences" with European law the way you do with ICAO. Otherwise, why don't AOPA just write to the CAA saying "please file a difference to retain the IMCr in the UK" and the CAA can write back "OK, wilco" and then we can stop worrying. I'm not saying it can't happen - in fact there seems to be increasing hope that it can, but if it's easy, then I must have missed the explanation and look forward to hearing it.


I'll rise to your bait It's not a bait. What is it that is baiting, apart from not agreeing with some of the views that sounded a bit extermist to me? I don't feel strongly in favour of the EIR, I am most in favour of the ICAO system and it's proportionate, US-style implementation. I think the fact that Europe has needed to invent all sorts of intermediate and sub-ICAO qualifications (NPPL, RPL/LPL) is a travesty. EASA should just have made the PPL and IR accessible and ICAO compliant, without the various European overlays and gold-plating that don't really add anything to safety.

However, given we are where we are, EASA at least have a working group trying to find an intermediate qualification, and I think it's worth more consideration than the experts in this thread have given it.

I can't remember ever being flying in a spamcan over the sort of distances they fly when the weather has been VFR for departure, down to less than 2000' enroute and "virtually certain" VFR at destination (or alternate).
I don't know what everyone means by "virtually certain". It certainly doesn't have to be more certain than the certainty to fly VFR on a plain PPL. Are you seriously saying that you can't conceive of being at a departure airport in VMC, with VMC forecast at destination but IMC enroute making VFR unlikely or inconvenient. I've turned back on many trips when the enroute murk was such I couldn't continue, where my destination was forecast VFR.

The "virtual certainty" of VFR weather at destination will (possibly) occur on a maximum of two days per annum in the UK. The rest of the time, "virtual certainty" in the accuracy of TAFs and their timing is a falsehood that will sucker in far too many people. I can just hear the barristers discussing "virtual certainty" and the likelihood of weather forecasters getting it right to that extent in the courtroom wherein is held the Subsequent Inquiry.
So how does anyone fly VFR in the UK, given how hopeless the chance of being able to expect VFR at your destination is and all the legal pitfalls it involves? You're just making up an interpretation of weather planning minima that is absurd, and then pointing out is is absurd.

And with no approach privileges, how are people supposed to let down? Just descend through the murk and hope?
Exactly the way that people everywhere else in the world fly VFR-on-top and then descend VFR to land, or exactly in the same way that people (including IMCr holders) fly enroute IFR in and out of VFR airports.

a thoroughly dangerous one
Your willingness to use your experience and qualifications to judge an unfamiliar qualification, that no-one has actually published any syllabus, standards or other details for, as "thoroghly dangerous" will at least help you understand why people outside the UK, as experienced and qualified as you, judge the IMCr as "thoroghly dangerous". People make judgements like that.
You think people can be safely taught to fly instrument approaches to IR minima in a 15hr IMCr course and to fly enroute IMC OCAS safely and yet an unspecified course, which might well have as much approach training as the IMCr (not difficult, I remember doing a few ILSs and a few SRAs on mine) but only enroute privileges is bound to be "thoroughly dangerous".

brgds
421C

Fuji
It is?
Yes it is. See the EASA FCL NPA document. It's in there as an EASA rating IIRC. This means no-one in Europe objected to it.
Unfortunately, they do object to the IMCr.


The CAA say they support the IMCr and so does AOPA UK so I wonder who is not telling the truth
My "none of them" meant EASA countries, not FCL008 members. I understood that in FCL001 the IMCr was rejected by all the participants except the UK ones.
I wonder why we should be suspcious of committee behind closed doors - open govenrment, hmm.
Perhaps we should be less quick to jump to the conspiracy theory....re my prior answer

[BEagle]

You think people can be safely taught to fly instrument approaches to IR minima in a 15hr IMCr course

You still don't seem to have grasped the point that IMCR holders neither expect to fly to 'IR minima', nor wish to. The training for the IMCR to fly to IMCR minima is entirely proportionate, as 40 years of practical experience has conclusively proved.

I held IRs on various aircraft for about 30 years. Rarely did I ever need to fly to 'IR minima' - on most occasions the IMCR would have been sufficient.

[IO540]

even a well trained monkey could fly an ILS..

I agree and this is why I would make flying an ILS a part of the "IO430 PPL" :) but this is not the challenge here. The absolutely fundamental challenge on the entire "how to make the IR more accessible" proposal, going back over the few years that I have been watching the GA scene, is nothing to do with matching training to the actual mission requirements. It is nearly wholly political/emotional: the European regulators have nailed the "professional pilot" flag to the "IR" mast and this is why the IR has never been made significantly more accessible. In the USA, the "professional pilot" flag is nailed to the "ATP" mast which is where it belongs, and anybody can get an IR as a natural step after doing their PPL.

The GA IR community's interests happen to not be all that divergent however, from the professional pilot unions etc. One gotcha is that if you "water down" the ICAO IR then the regulators could then use this as an excuse to water down the privileges, reducing them from the present totally unquestionable full IFR-anywhere, to something lower - but anybody with an IR knows that any privilege reduction would render the full IR pretty useless. The whole point of an IR is to get the free IFR flight procedure, with ATC working for you, etc.

this potential scenario exists today with the vast majority of the world's PPLs who have VFR-on-top privileges. They are equally vulnerable to destination forecasts changes and just as untrained to fly IAPs.

That is absolutely true; however I think there are other factors at work which help ensure that the rest of Europe and indeed the world is not exactly covered in wreckage of all the pilots who had normal plain ICAO PPLs (i.e. without the UK CAA's "in sight of surface" restriction for VFR):

IMHO the vast majority of pilots who in theory can fly VMC on top don't do it because this requires totally competent radio navigation, which is not AFAIK taught properly anywhere.

A plain PPL cannot climb legally through IMC, and this fairly drastically cuts down the # of people who will end up trying to do a hard VFR letdown at the far end.

My talks with some French pilots suggest that very very few of them actually use their VMC on top legal right. Not a lot of long distance touring goes on in France anyway...

Finally, some pilots who might fly VMC on top under "VFR" are instrument competent but have not got the IR and they fly "VFR" in IMC as necessary. In the UK this is pretty common. These are going to do DIY letdowns where nobody will catch them (hopefully).

So I do think that this proposed EIR needs an SRA which after all is no more than flying a heading and altitude as directed by ATC - in IMC and a plain PPL ought to be able to do this anyway.

BTW some googling suggests that the Australian IFR Rating is here (http://www.casa.gov.au/wcmswr/_assets/main/download/caaps/ops/5_13_1.pdf).

[FREDAcheck]

I wonder why we should be suspcious of committee behind closed doors - open govenrment, hmm.Generally, when something is done behind closed doors it's because someone has something to hide - if only that they don't want to be held accountable for their decisions.
Perhaps we should be less quick to jump to the conspiracy theory....re my prior answerWhen something is going on behind closed doors, if you can't see the conspiracy, it's generally because you haven't looked hard enough.

[Fuji Abound]

Perhaps we should be less quick to jump to the conspiracy theory....re my prior answer


Why? Select committee hearings are held in public. Why should EASA hold these meetings in private and gag the participants?


Yes it is.


It isnt - EASA havent yet "adopted" any national ratings.


My "none of them" meant EASA countries, not FCL008 members. I understood that in FCL001 the IMCr was rejected by all the participants except the UK ones.



Either they all did, or they didnt. If the UK didnt (and still doesnt) then they didnt all reject the IMCr.

I've turned back on many trips when the enroute murk was such I couldn't continue, where my destination was forecast VFR.

The thing is if you set off IFR you are entitled to fly with IFR reserves. Turning back may not be an option. In another thread in another place I gave an example of a flight of less than an hour. The departure TAF indicated scattered at 1,500 all morning, by the afternoon it changed to broken at 1,100. The METAR about 40 minutes before departure indicated broken at 1,000 feet. By the time I arrived it was overcast at 700 feet, and IMC from ten minutes after departure at 1,500 feet. The weather at the departure airport was below minima by the time I arrived at the destination and the destination also had a strong wind warning and strong winds of which there had been no mention at all in the earlier TAF or METAR. The destination was at minima but there was the alternative of a number of close ILS IAPs. If I had an IMC rating I would have gone with the forecast. If I had an EIR I would have gone with the forecast. If I had been coming up through Europe I would have gone with the forecast.
Another aircraft was returning to my destination after a local VFR flight. He remained below the base and the flight was legal if, perhaps, not prudent for some.

The EIR as proposed by you is not based on a sound safety case (if it is please set out the case for us all) but on political expediency. If EASA legislates for reasons of political expediency and not safety we are all doomed and the process is broken.

I reiterate if you want to engage in debate then please set out the safety case for the EIR. Time has already set out the case for the IMCr - I know of no better judge.

Would you also like to set out your credentials. You appear to be soliciting opinion and formulating a defence of the EIR - what is your interest?

My interest is already on record.

[blagger]

In my opinion, the critical point that has been missed is a robust analysis of the actual use of the IMC and motivations / intentions of the people who get and hold it. Without any decent data of this ilk, everyone is largely talking from opinion and we can only rely on a feeling that the original IMC 'requirement' remains valid and is satisfied by the current IMCR. The AOPA survey was a brilliant opportunity to tackle this, but with no results out I fear it could be too late to influence the debate and I struggle to understand what 'requirement' the FCL008 committee are working towards satisfying.

Again in my opinion as an FI, I reckon 80-90% of the people who get the IMCR want it for the skills to go flying in poorer vis [than they would fly in with a vanilla PPL], to get up on top of broken cloud layers and for the confidence that they can get down safely if they end up in IMC. It is my third point that has really attracted every IMCR holder I have ever known. Indeed, on many PPL [non IMC holding] checkouts and currency checks I get people asking to try an SRA or ILS for the experience.

I bet if we lose the IMCR and end up with the EIR, people will not bother with the EIR and we will see unofficial IMC 'courses' spring up where people can experience some IAP tuition with an FI for emergency use only.

[FREDAcheck]

Fuji,

I find your example of changing TAFs quite common. A few weeks ago I went to Shoreham. The TAFs showed something like BKN012 but BECMG SCT020 before I got there, and continuing to improve all day. It was similar all over the S East, and I had no reason to doubt the TAFs. When I got there (less than 2 hours later) it was OVC007. According to the plate, the MSA for the 25nm circle round Shoreham is 2100.

Nuff said?

[421C]

You still don't seem to have grasped the point that IMCR holders neither expect to fly to 'IR minima', nor wish to. The training for the IMCR to fly to IMCR minima is entirely proportionate, as 40 years of practical experience has conclusively proved

No Beagle, you quoted me out of context and missed my point. My point was that if Approaches can be taught to the IMCr standard so satisfactorily in the relatively short IMCr course, who is to say that they couldn't be taught to a "emergency use only" standard in an EIR course. I was replying to the convinction that the EIR must be "thoroughly dangerous" because it doesn't permit Approaches. But no-one has said it couldn't include training for Approaches as an emergency. Perhaps it could include the SRA training IO540 mentions. I don't know. I only know I disagreed with the reaction at the start of this thread that the EIR was fantasy/chocolate teapot/dangerous etc.

Fuji,
In another thread in another place I gave an example of a flight of less than an hour
Your example proves what point? Pilots can get caught out by weather worse than forecast. Well, that can happen to VFR pilots and IR holders. So we tell a story about an IFR flight whose destination and alternate were forecast above minima, but both got fogged in. Or about a VFR flight with good weather forecast but where the pilot got caught out by bad weather. Does this mean VFR PPLs and IRs are thoroghly dangerous?


The EIR as proposed by you is not based on a sound safety case (if it is please set out the case for us all)


I'm not proposing it. I joined this discussion to reply to Beagle's comment:
The person who dreamed up this lunatic idea considers that there should be 'almost certain' VFR conditions for take-off and landing (whatever that means), so the EIR holder can then go and play airliners without being concerned about going IMC in the cruise.

AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR and has asked IAOPA to tell the FCL.008 group that the UK advocate of this EIR does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.I didn't detect any great depth of analysis here which required me to have written a safety case before I could post my comments. Tell me if the forum etiquitte is otherwise.
When and if the EIR is proposed by EASA I guess we'll all have a basis to judge whether its safe or dangerous or useful or useless. Of course, apart from those who've already made their minds up before anything detailed or final has been published.

Would you also like to set out your credentials. You appear to be soliciting opinion and formulating a defence of the EIR - what is your interest?
I wouldn't. I'm not. I'm replying to Beagle's point I quoted above, and then the follow-on points that ensued. But probably time to give it a rest.
brgds
421C

[BEagle]

I have shown you, 421C, that a UK member of FCL.008 admitted guilt for having proposed this Chocolate Teapot Rating nonsense - and no-one else who has posted on this thread has supported it.

You were trying to defend the indefensible. Quite why, I do not know, since the EIR proposal has been supported by no-one apart from this one FCL.008 member - whose opinion must be considered his and his alone and not the consensus view of the wider UK GA fraternity.

[Fuji Abound]

Pilots can get caught out by weather worse than forecast.


That is not the point it demonstrates.

It demonstrates that instrument rated pilots very rarely get caught out by the weather going below minima but they would get caught out by this type of artificial minima.

In my experience IMC rated pilots, and indeed the majority of IR rated pilots, when flying GA type aircraft do not "push" the minima. I cant think of a single occasion when I have arrived and the ILS has been below minima. Indeed it is rare to find these conditions on days (note days) on which GA pilots typically fly.

I also cant think of a single accident involving an IMC rated pilot during the approach segement of a flight but I can think of many involving pilots with an IR. Whatever IMC rated pilots are doing they seem to have developed a pretty good means of flying approaches to the same minima as pilots with an instrument rating. Given the population of GA IMC rated pilots in the UK is more than 10 times the size of those pilots with an instrument rating they would seem to be doing a pretty good job.

What evidence do you have they are not?

I am sorry to keep referring to evidence, but it seems to me this is the crux of the issue. Those seeking change HAVE NO EVIDENCE to support the changes they seek. I am happy to accept change if there is good reason, but change for change sake is a very bad idea.


I wouldn't.


That is a problem. Your argument has little creditability without.

Moreover for all we know you might be "representing" one of those arguing for the adoption of the EIR? If you are you should have the courage to nail your colours to the mast.

[Brendan Navigator]

The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.

Most of the posts here do not reflect the actual situation and so we have the argument revolving about the ability of a chocolate tea pot to hold ice cold tea.

"Saving" the IMC Rating is a very bad point to pitch. The idea that it is essential to private GA operations in the UK and even if EASA does not agree, the UK should be able to keep it just for UK pilots gets countered by the fact that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence. Is it an essential safety requirement or not? Make up your mind. Don't ask people to accept something that you won't do yourself.

The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc

Someone said that the IMC rating was essentail because it made it safer for the pilot who accidently enters IMC. They claimed that the enroute proposal would kill them. How? Can't they both complete a 180 degree turn and fly back to VMC? Why would the holder of an enroute rating be less likely to retain control in IMC compared to an IMC rating holder?

More and more, people arguing in favour of the IMC rating are assisting those that do not like the idea. They are doing this through lack of knowledge of how other countries approach safe VFR flying.

In many other countries Marginal VFR is cloud between 1000 and 3000ft and visibility between 5K and 8K. For most people in the UK they will say that in that case they fly in marginal VFR for most of the year. However, when looking at the proposal look at what other countries call good VFR conditions - 3000ft and 8K+.

Under ICAO and most other country's requirements one can not commence a VFR flight unless it is VMC all the way to destination. Would all those that jump up at this point and say "that would ground us on most days and what is wrong with a look see" think for a moment what that attitude says to other countries - countries you are relying on to get this qualification.

The whole argument about the French requirement for a Mountain Rating disdplays what is wrong with those putting forward arguments to "save the rating". Everyone needs to understand the vast difference between a country having a requirement for pilots to hold a rating to do something compared to a national rating. The requirment to hold a mountain rating is a national issue - France may require it while Italy may not. However, the ability to add a mountain rating to any EASA licence is not a national issue and there should be nothing stopping an appropriately qualified German instructor teaching a Spanish pilot for the rating and having it included on a licence issued in the UK so that the pilot can use it in France (where it is required).

As for the proposed conpromise. Most commentators here do not seem to understand the principles involved.

Most non-UK countries permit VFR flight out of sight of the surface without any extra requirements. Some palces have VFR over the top ratings.

However, the proposed rating is not designed to enable VFR on top or replace that ability. Pilots without the rating will still be able to operate VFR on top. The rating entitles the pilot to fly continuously in IMC while enroute. There is no requirement for a "hole in the cloud" at the start or at the end. The cloud can be solid from 3000ft to 30,000ft. The overriding principle is that VFR conditions must exist at departure and destination. Everyone here talking of the problems with a TAF showing cloud at the MSA and the pilot arriving at MSA only to find that they are still IMC, have not taken into account the fact that according to many countries cloud below 3000ft is marginal VMC and cloud below 1000ft is IMC.

In the UK one is never far from an aerdrome included on the Volmet. Using that element of the FIS on it's own provides the pilots the ability to ensure that weather conditions are not vastly different from what they expected. The Shoreham example again plays into the hands of those opposed to the IMC rating. An aerodrome close to the sea and someone is surprised that the cliund could be low and visibility poor? Even the Frenach post warnings for Le Touquet etc about such happenings and pilots select alternate aerodromes well inland.

The discipline in the instrument pilot revolves to a large expent around the ability to set minima and adhere to them. If they are 300ft or 3000ft, it makes no difference. If they are 1800m or 8000m makes no difference. One adheres to the minima or stays on the ground. The cround that jumps up at this point and says that would ground us for most of the year have to be asked would it? Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?

As I see it the proposals are very simnple;

PPL - VFR - limited to VFR conditions at all times. Can fly VFR on top.

PPL with Enroute IMC - Limited to VFR arrival and departure. Can file and fly IFR (IMC) enroute regardless of airspace.

IR - Can fly IFR departure to arrival.

The argument that having to operate with minima of 3000ft and 8K would do nothing for most pilots who fly at 2000 to 2500ft ignores the fact that the UK system where VFR pilots rarely climb above 3000ft is at odds with many other country's desired method of operation.

The UK airspace limits VFR operations in the FL60 to FL115 band. However, everyone needs to be aware of what the future holds for European Airspace before being able to put up a convincing argument.

Should the UK retain the IMC rating - as an addition to an NPPL - what happens a few years later when European airspace proposals sound the end for non-IR qualified pilots in controlled airspace?

Serious proposals for an "IMC"-like rating have to take into account who the holders of such ratings are going to be and just as importantly (but forgotten by many) what type of equipment will they be using.

Let's have EASA grant an IMC rating to all. Then require a flight plan for all IFR flights and all IFR flights to have mode S and BRNAV. So suddenly the rating issue has gone - the equipment issue is nothing new - but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.

Is that what you really want?

Bren.

[421C]

Beagle the EIR proposal has been supported by no-one apart from this one FCL.008 member - whose opinion must be considered his and his alone If this is true, then why on earth are you worried about it? It will never get through FCL008 or any other rulemaking. End of story.


Fuji,
That is not the point it demonstrates.

It demonstrates that instrument rated pilots very rarely get caught out by the weather going below minima but they would get caught out by this type of artificial minima

In which case your point is not relevant to what I was saying. I wasn't saying that instrument rated pilots often get caught out by weather minima. I was saying exactly what you are saying - that both VFR and IFR pilots are able operate safely despite the inherent uncertainty in weather forecasts.

they would get caught out by this type of artificial minima.
It's not an "artificial minima". It's the same kind of planning every non-UK PPL is exposed to every time they venture VFR on top, out of sight of the surface. The forecast weather has to indicate that they will be able to get back down again in VMC.
Show me the studies and evidence of PPLs with VMC-on-top privileges "caught out" by not being able to descend to land VMC. There are hundreds of thousands of them in the USA. If it is so utterly fraught with risk and danger, there must be evidence in the US. If it is anything like as risky and dangerous as you say, there must be articles, advisory circulars, NTSB reports all supporting the dangers you are so convinced of.

In my experience IMC rated pilots, and indeed the majority of IR rated pilots, when flying GA type aircraft do not "push" the minima. I cant think of a single occasion when I have arrived and the ILS has been below minima. Indeed it is rare to find these conditions on days (note days) on which GA pilots typically fly.

I also cant think of a single accident involving an IMC rated pilot during the approach segement of a flight but I can think of many involving pilots with an IR. Whatever IMC rated pilots are doing they seem to have developed a pretty good means of flying approaches to the same minima as pilots with an instrument rating. Given the population of GA IMC rated pilots in the UK is more than 10 times the size of those pilots with an instrument rating they would seem to be doing a pretty good job.

What evidence do you have they are not? I am not saying that IMCr pilots are not doing a good job. In fact I am agreeing with you that they do a good job. My point is that if they can be trained to do such a good job on IFR approaches in the IMCr, then why couldn't EIR holders be trained to safely handle an IFR approach in the event of the emergency situation created by weather being systematically worse than forecast.
That's my only point on this, in reply to the specific argument that the EIR must be 'thoroghly dangerous' because EIR holders might end up caught out by unexpectedly worse weather.


That is a problem. Your argument has little creditability without
I am happy for whatever points I make to be judged, ignored, disagreed with, or whatever, on their own merits or lack of. If you want a forum where people should declare their quals before they venture an opinion, then my impression is that PPRUNE isn't the one. If those are your rules for engaging in a discussion, then I will understand why you won't want to continue this one.


Moreover for all we know you might be "representing" one of those arguing for the adoption of the EIR? If you are you should have the courage to nail your colours to the mast.

Well, I'm not. I am doing what I think this forum is intended for. I read it and I have an opinion. I post that. We exchange replies.
I am happy to be guided by the moderators if there is some special rule about replying to you, or posting on this particular topic. Or for that matter, if I should stop posting because I am outnumbered by posters with opinions different from my own.

I am sorry to keep referring to evidence, but it seems to me this is the crux of the issue. Those seeking change HAVE NO EVIDENCE to support the changes they seek. I am happy to accept change if there is good reason, but change for change sake is a very bad idea.
The crux of what issue? I am sorry, but I am confused by some of your replies. I sense you are writing in reply to points you want someone to have made, so you can wheel out your reply. But the problem is no-one is making those points.

What is the change "they" are seeking and have no evidence for? If it is the "abolition of the IMCr" then no-one is seeking a change; unless it is a change that has already happened when a) the EU gave EASA powers over FCL and b) EASA published the FCL NPA without an IMCr in it.

If the "change" is the introduction of the EIR, then my understanding is that this is a concept or early stage proposal - in fact, if Beagle is right, it is nothing at all except the workings of a lone person unsupported by any other stakeholder or FCL008 member. Nevertheless, the concept can be discussed in principle, which is what we are doing.

brgds
421C

[FREDAcheck]

Brendan,

I think I understand all the words you are using, but it's the sentences that are giving me trouble. Much of what you say doesn't make much sense to me, and what I do understand I disagree with.
The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.This is what gives the UK Independence Party growing support in Britain. I used to be an enthusiastic European supporter, but it's this grinding down to the lowest common denominator. Europe should be about enabling, but it's actually constricting. What should be a liberal ideal is an illiberal bureaucracy."Saving" the IMC Rating is a very bad point to pitch. Why?The idea that it is essential to private GA operations in the UK and even if EASA does not agree...No one is saying it's essential. It's just a very good idea, and increases safety....the UK should be able to keep it just for UK pilots gets countered by the fact that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence. Is it an essential safety requirement or not? Make up your mind. Don't ask people to accept something that you won't do yourself.As I say, this is a misrepresentation of what people are saying, so this point doesn't follow. The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etcNot relevant. The point is that most of the time you can't rely on cloud base above MSA, so you need the safety net of the ability to divert to a field with an instrument approach, and the ability to use it. Someone said that the IMC rating was essentail...No, not essential but a useful aid to safety...because it made it safer for the pilot who accidently enters IMC. They claimed that the enroute proposal would kill them. How? Can't they both complete a 180 degree turn and fly back to VMC? Why would the holder of an enroute rating be less likely to retain control in IMC compared to an IMC rating holder?That point is valid, but doesn't alter the main points made on this thread.More and more, people arguing in favour of the IMC rating are assisting those that do not like the idea. They are doing this through lack of knowledge of how other countries approach safe VFR flying.I really don't follow this. We're not trying for force other countries to do anything - it's other people trying to force us to do something (get rid of the IMC Rating) that we're upset about. In many other countries Marginal VFR is cloud between 1000 and 3000ft and visibility between 5K and 8K. For most people in the UK they will say that in that case they fly in marginal VFR for most of the year. However, when looking at the proposal look at what other countries call good VFR conditions - 3000ft and 8K+.

Under ICAO and most other country's requirements one can not commence a VFR flight unless it is VMC all the way to destination. Would all those that jump up at this point and say "that would ground us on most days and what is wrong with a look see" think for a moment what that attitude says to other countries - countries you are relying on to get this qualification.
What people do or do not do in VFR is very interesting, but I don't see the relevance to an IMC Rating.
The whole argument about the French requirement for a Mountain Rating disdplays what is wrong with those putting forward arguments to "save the rating". Everyone needs to understand the vast difference between a country having a requirement for pilots to hold a rating to do something compared to a national rating. The requirment to hold a mountain rating is a national issue - France may require it while Italy may not. However, the ability to add a mountain rating to any EASA licence is not a national issue and there should be nothing stopping an appropriately qualified German instructor teaching a Spanish pilot for the rating and having it included on a licence issued in the UK so that the pilot can use it in France (where it is required).You'll have to forgive me, I don't understand the bureaucratic implications of what you are saying. I sounds gobbledygook to me. We should be starting with what we want to achieve, and writing rules around that. It sounds as though we're doing the other way round. "You can't do it because of the rules." Well, if the rules don't allow it, change the rules. This is the tail wagging the dog.
As for the proposed conpromise. Most commentators here do not seem to understand the principles involved.

Most non-UK countries permit VFR flight out of sight of the surface without any extra requirements. Some palces have VFR over the top ratings.

However, the proposed rating is not designed to enable VFR on top or replace that ability. Pilots without the rating will still be able to operate VFR on top. The rating entitles the pilot to fly continuously in IMC while enroute. There is no requirement for a "hole in the cloud" at the start or at the end. The cloud can be solid from 3000ft to 30,000ft. The overriding principle is that VFR conditions must exist at departure and destination. Everyone here talking of the problems with a TAF showing cloud at the MSA and the pilot arriving at MSA only to find that they are still IMC, have not taken into account the fact that according to many countries cloud below 3000ft is marginal VMC and cloud below 1000ft is IMC.Sorry, can't see the relevance.
In the UK one is never far from an aerdrome included on the Volmet. Using that element of the FIS on it's own provides the pilots the ability to ensure that weather conditions are not vastly different from what they expected. Have you flown in the UK? That simply isn't true. The Shoreham example again plays into the hands of those opposed to the IMC rating. An aerodrome close to the sea and someone is surprised that the cliund could be low and visibility poor? Even the Frenach post warnings for Le Touquet etc about such happenings and pilots select alternate aerodromes well inland.Perhaps you missed my point, or are you saying that no one should ever assume VMC at a coastal airport? The point I am trying to make is that flying with an en-route IMC qualification but no ability to fly an instrument approach if necessary would very severely limit the occasions on which one can safely fly IMC in the UK.
The discipline in the instrument pilot revolves to a large expent around the ability to set minima and adhere to them. If they are 300ft or 3000ft, it makes no difference. If they are 1800m or 8000m makes no difference. One adheres to the minima or stays on the ground. The cround that jumps up at this point and says that would ground us for most of the year have to be asked would it? Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?This is true, but misses the point. Of course all sensible pilots fly within sensible limits. This is about extending those (safe and sensible) limits by a considerable degree.

As I see it the proposals are very simnple;

PPL - VFR - limited to VFR conditions at all times. Can fly VFR on top.

PPL with Enroute IMC - Limited to VFR arrival and departure. Can file and fly IFR (IMC) enroute regardless of airspace.

IR - Can fly IFR departure to arrival.

The argument that having to operate with minima of 3000ft and 8K would do nothing for most pilots who fly at 2000 to 2500ft ignores the fact that the UK system where VFR pilots rarely climb above 3000ft is at odds with many other country's desired method of operation.

The UK airspace limits VFR operations in the FL60 to FL115 band. However, everyone needs to be aware of what the future holds for European Airspace before being able to put up a convincing argument.

Should the UK retain the IMC rating - as an addition to an NPPL - what happens a few years later when European airspace proposals sound the end for non-IR qualified pilots in controlled airspace?

Serious proposals for an "IMC"-like rating have to take into account who the holders of such ratings are going to be and just as importantly (but forgotten by many) what type of equipment will they be using.

Let's have EASA grant an IMC rating to all. Then require a flight plan for all IFR flights and all IFR flights to have mode S and BRNAV. So suddenly the rating issue has gone - the equipment issue is nothing new - but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.

Is that what you really want?

Bren.
I'm sorry if you feel insulted by my comments, and I don't mean it personally, but as you can tell I feel quite angry about this. We feel let down. We have a perfectly workable rating in the UK that increases the ability of PPLs to fly, enhances safety and increases skill.

What we see is a lot of bureaucratic nonsense and intolerant people telling us we can't do it, just because other people in other countries don't want it. So what? Why should that stop us doing it? Don't tell me, I know the answer.

[Fuji Abound]

The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.


EASA are considering a sub ICAO IR – call it what you will. The IMCr is just that. The proposed EIR is also just that. Since a sub ICAO IR is on the cards the issue is not whether the member states agree to adopt one, but the form it will take. How has that form been reached? By all means let’s have a discussion about the evidence on which the Commission has relied. Doubtless proper studies have been commissioned? Presumably the Commission has evidence that demonstrates there is a higher accident rate among IMCr pilots whilst flying the approach. Why is it every time the discussion turns to hard evidence most advocates go very quite?

that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence.

They can’t add an IR either. It might just be something to do with the reduced medical – do you think?

The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc

Nonsense. The majority of IR holders do exactly the same. Consider for just one minute how much time the average IR holders spends on instruments and how much they spend flying visually.

Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?

Please point us to the evidence that indicates the existing minima for IMCr holders is unsafe. Unless you have evidence its just words – you can set whatever minima you like and of course everyone can adhere to those minima, but they mean nothing. Minima exist to protect the pilot because the EVIDENCE shows that for a pilot that is current descending below the minima is unsafe. If the pilot is not current he should revise his minima – it matters not what name appears on his rating.

but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.

And do you imagine that is not exactly what they already do, rating or not, or what they will continue to do. After all I wonder if EASA is about to stop gliders flying in or near cloud.

En route IFR is a serious business. I see nothing wrong in ensuring those that do it are adequately equipped – that seems to me a far more reasonable safety concern.

As a barrister told me there are only three things that should count in determining a case:

EVIDENCE, EVIDENCE, EVIDENCE.

So lets see it - otherwise it is all hot air.

EASA can do what they like for all the wrong reasons, if they do they are not fit for purpose, it will not stop them - I know that, but it is no less lamentable.

[Captain Stable]

Two comments sum the entire thing up for me.
We have a perfectly workable rating in the UK that increases the ability of PPLs to fly, enhances safety and increases skill.EASA are considering a sub ICAO IR – call it what you will. The IMCr is just that. The proposed EIR is also just that. Since a sub ICAO IR is on the cards the issue is not whether the member states agree to adopt one, but the form it will take.As has been pointed out, EASA WANT a sub-IR rating. No other country in EASA has had one up to now AFAIK.

We have one. It works very well. It is good training for PPL pilots, and is a good second step after PPL issue. WTF is wrong with EASA using the same spec? Why do we have to ditch a perfectly good rating and substitute an EIR which (in the opinion of at least a significant minority, if not a majority) is not fit for purpose, does not achieve what is wanted, and will possibly erode safety? Let's face it - the IMCr has proven very useful, very safe. If it ain't broke, don't fix it. And don't substitute it for something that might well break very quickly.

[Final 3 Greens]

One comment sums it up from where I am (a Brit living in Europe)

Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.

[Brendan Navigator]

FREDAcheck,



This is what gives the UK Independence Party growing support in Britain


I think that we can safely say that the UK Independence Party is as relevant to Europe as the Scilly Isles Independence Party is to the UK! :)

For something that is relevant - have a look at how the sport aviation sector organised itself, put it's case forward and acheived quite a lot.

While on that topic I must point out that the UK has the equivalent of the French Brevet and there is no evidence that it had been dangerous in the UK so why would it be a problem?


No one is saying it's essential. It's just a very good idea, and increases safety.

No, not essential but a useful aid to safety


Ok. Why is a very good idea and something which is a useful aid to safety not available for the NPPL holder?

"Fuji Abound" thinks that it could be medical related. What extra medical requirements do IMCrating holders have above the standard class 2? - None. IR holders only have the audiogram to do.


You'll have to forgive me, I don't understand the bureaucratic implications of what you are saying


I am saying that the French Mountain Airport Rating is not a national rating now so why should it be in the future. You as a UK pilot are required to obtain the rating before operating to the designated aerodromes. All EASA are going to do is enable you to have it on your licence even if that licence was obtained in the UK.

The Mountain Rating is actually a restriction of your privileges. The IMC rating is an extension of your privileges. Do you see the difference?


What people do or do not do in VFR is very interesting, but I don't see the relevance to an IMC Rating.

Sorry, can't see the relevance.


That is the whole point I am making. People pitching for an IMC rating do not understand the relevance of many factors related to how things are done.

If I might explain;

Let's say VFR conditions= Cloudbase 3000ft+ and Visibility 8Km+

Marginal VFR conditions= Cloudbase 1000ft - below 3000ft and Visibility 5K+

IFR conditions= Cloudbase 500ft - below 1000ft and Visibility 3K+

The minimum safe altitude IFR is 1000ft above the obstacles.

If the weather is VFR according to the above then when at the minimum IFR level, one should be 2000ft below the cloud. The weather is going to have to be quite a bit different from expected before we are faced with IFR conditions at 1000ft above the airport. To have that happen at both the destination, the alternate and every other airfield within range is in the remote range.

That is why when people who use that philosophy for VFR operations look at giving people something more they think that giving people the ability to fly IFR enroute will greatly assist their operation.

I have flown in the UK. There are many aerodromes on the 4 volmets. Many more have ATIS. The FIS can provide weather for many more. Making the argument that it is hard to keep abreast of the weather at destination and alternate(s) while enroute IFR does nothing for the IMC case - it is required at the moment to ensure that the IMC minima are OK. So nothing changes there.

Far too many things that are used by people as reasons why the IMC rating is good and the idea of the enroute rating is bad do nothing more than place the "cowboy operation" in the minds of the regulators who are going to decide what happens.

Finally remember that it is not the foreign pilot that needs to be convinced. It is the regulators.

Pilots think - hey great idea I can........

Regulators think - OK so how will the ATC service cope with all these pilots choosing to fly from Shoreham to Oxford IFR via the airway system because they can.

Bren

[Brendan Navigator]

Why do we have to ditch a perfectly good rating


Because no other European country's regulator thinks it is a perfectly good rating?

Bren

[Fuji Abound]

"Fuji Abound" thinks that it could be medical related. What extra medical requirements do IMCrating holders have above the standard class 2? - None. IR holders only have the audiogram to do.

What are the differences between an NPPL medical and a JAR medical applicable to PPL holders?


The rest of Europe doesnt think it is a good idea


Thats OK then.

EVIDENCE, EVIDENCE, EVIDENCE.

Lets see it then?

[FREDAcheck]

Sorry Brendan, I can see we're not going to agree on much. I don't have much time for the UK Independence Party, but they are gaining support, and it's what is seen as unnecessary standardisation and bureaucracy that drives their support.

I am saying that the French Mountain Airport Rating is not a national rating now so why should it be in the future. You as a UK pilot are required to obtain the rating before operating to the designated aerodromes. All EASA are going to do is enable you to have it on your licence even if that licence was obtained in the UK.

The Mountain Rating is actually a restriction of your privileges. The IMC rating is an extension of your privileges. Do you see the difference?No, I'm afraid I don't. I need the Mountain rating to fly to certain airfields in France. In the UK you need to have an IMCR (or IR) to fly IMC. And the difference is?

Your long explanation of VFR limits really makes no sense to me. Or rather, I can't see the relevance. I don't even think you're inference is right. I can explain my view much more succinctly:

a) To undertake an IMC flight with only en-route capability requires near-certainty of cloud base above MSA at the destination (or alternate).

b) To undertake an IMC flight with an IMC rating requires near-certainty of cloud base above 500 feet AGL (assuming the destination or alternate has an ILS).

In the UK the number of occasions the weather meets (b) is many times the number of occasions it meets (a).
I have flown in the UK. There are many aerodromes on the 4 volmets. Many more have ATIS. The FIS can provide weather for many more. Making the argument that it is hard to keep abreast of the weather at destination and alternate(s) while enroute IFR does nothing for the IMC case - it is required at the moment to ensure that the IMC minima are OK. So nothing changes there.That's right but not relevant. My point is that you can't safely set out with an en-route only IMC capability unless you are virtually certain that the cloud base at your destination or alternate will be above MSA. As I explained above, that occurs much much less frequently than the IMC Rating minima for an instrument approach. That's why we want the IMC Rating.

[Captain Stable]

The Mountain Rating is actually a restriction of your privileges.No, it isn't.

You appear to think that NPPL holders need a Class 2 Medical. They don't.

You appear to think that, if the enroute weather is fine, you can set out for your destination. Not so.

Sorry, Brendan, but your case is riddled with inaccuracies, misunderstandings and plain nonsense. You have destroyed your case yourself.

[Final 3 Greens]

The Mountain Rating is actually a restriction of your privileges. The IMC rating is an extension of your privileges. Do you see the difference?

To clarify, what I think Brendan is saying is that a UK PPL does not contain any restriction on landing on high altitude airports, whereas the IMC rating adds the ability to fly in conditions not permitted by the PPL.

To give a concrete example, I was entitled to fly VFR to Big Bear in California (6700amsl) as PIC, on the basis of my converted UK licence, but I could not to fly in IMC as my license privileges did not include that and I didn't hold an IR.

Obviously I took specific training to tackle the challenges arising from the mountain flying involved to get to to Big Bear, but no rating was mandatory to act as commander.

Seems pretty clear.

Having looked at photos of a French altiport, I completely understand why the DGA requires a rating for these operations, but nonetheless, this does not affect Brendan's logic.

[FREDAcheck]

If I understand it correctly,
a UK PPL does not contain any restriction on landing on high altitude airportsbut
the DGA requires a rating for these operationsso you just have to know that there's a restriction not actually written in your licence.

Whereas the UK PPL doesn't include IMC, so you know you can't fly IMC without an additional rating. Well that's a wonderful bureaucratic nicety.

So if we just didn't say that the basic PPL didn't include IMC capability (but put it in the rules somewhere) then it would be OK?

You're kidding me, aren't you! This is Sir Humphrey at his finest.

There's no F in Great Britain, but there is in France; that's another difference. That's another good reason why an Altiport rating works in France but the IMC is no good in Britain.

[Final 3 Greens]

FREDAcheck

so you just have to know that there's a restriction not actually written in your licence.

That's what you have to know when you operate in foreign airspace.

Whereas the UK PPL doesn't include IMC, so you know you can't fly IMC without an additional rating. Well that's a wonderful bureaucratic nicety.


Which PPL does specify instrument conditions flight within its privileges without a specific rating? (Maybe there is one, I don't know)

The IMC and the altiport ratings are both anomalies, as they exist in certain states only.

I am not arguing that the IMCR is a bad rating (in fact I think both it and the altiport rating make a lot of sense), but it seems there is concensus for adopting one and not the other.

That is the realpolitik from where I am sitting.

I have no intention of getting involved in the main debate, but I do wish all IMCR holders the best of luck in retaining your rating.

But if you are to do this, you do need get your logic straight or the bureaucrats will cut you to pieces ;)

[Shunter]

Don't know about PPLs, but was it not the case that the old CAA CPL used to come with a lifelong IMC rating?

[FREDAcheck]

But if you are to do this, you do need get your logic straight or the bureaucrats will cut you to pieces It's logic, but not as we know it Jim.

[FREDAcheck]

That wasn't my point, and I'm sure you know it:ok:

My point is that logic making this a key deciding issue in why the Altiport is good but the IMC rating is bad would make sense only to a bureaucrat.

[Final 3 Greens]

FREDAcheck

I actually didn't get your point, please rest assured I don't wish to wind you up.

So I'll delete the last post, with my apologies for misunderstanding you.

As to the point you are making, I believe that 421c has already answered that, so little point me adding to the noise levels.

[FREDAcheck]

F3G - similarly, I'm not trying to pick a fight. Sorry if I seemed confrontational, too. I've spent many years on various European committees, and I'm well used to people giving higher priority to bureaucratic rules than to what we're actually here to achieve. I could cite many quite comical (and money-wasting) examples. At times it's impossible to hide one's frustration.

[BEagle]

Well, here's a classic reason for an IMCR. Today's TAF for an aerodrome gave 080718Z 0809/0909 21012KT 9999 BKN018 BECMG 0809/0812 FEW040. Given that, I'd happily set off to fly there VFR at 1000 ft agl and enjoy the view en route. No need for any IMC, just a healthy regard for Rule 5.

Which would have been fine, except that the METAR later showed 080850Z 20006KT 9999 BKN013 20/17 Q1017 BECMG BKN018 and then 080950Z 21010G21KT 9999 BKN012 20/17 Q1017 BECMG BKN018.

There was no indication of such a low cloudbase on the TAF and I wouldn't particularly wish to fly under VFR in those circumstances - so would have climbed to VMC on top, followed the GPS track and asked for a SRA to visual on arrival.

Seemples!

But with only a chocolate teapot rating, I'd either be stuck going round and round looking for a hole, in order to try to squeeze in at low level - or would have been obliged to weave around the hills and towns underneath with the ever-present 1000 ft rule in mind. Not nice to be stuck on top waiting for the weather-guessers' alleged BECMG to make its eventual appearance....

And whence cameth the unforecast 21 knot gusts?

[dont overfil]

This proposed "chocolate teapot" rating is surely what a private pilot in the UK had, (and the French still have) in the days before the IMCR.
DO.

[EastMids]

IMHO EIR would be a useless rating for many IMCr pilots. I fly out of an airport full ATC, and ILS and NDB approaches. Despite this, very few IMCr pilots I know plan long trips in IMC. I would suggest that these IMCr holders, like myself, more consistantly use the approach aspect of the IMCr rather than their enroute capabilities. We use the IMCr to legally and safely get home when the weather unexpectedly drops below VFR minima, or when the weather forecast suggests a changing mix of IMC and VMC over the time when we expect to get back - in such cases, sometimes we get back VFR and sometimes we need the ILS, but we almost always have that nice safe instrument option we've been trained to do and regularly practice.

On the other hand, if I were the holder of an EIR and get close to home and find I'm in the IMC period, I would presumably have to hold or divert. If I have to go elsewhere because an EIR does not allow me to land at home base, my alternative to the nice safe ILS may well be to fly further in IMC conditions and maybe let down into marginal VMC and grope my way into a nearby GA airfield that has no instrument approaches.

A

[S-Works]

Which would have been fine, except that the METAR later showed 080850Z 20006KT 9999 BKN013 20/17 Q1017 BECMG BKN018 and then 080950Z 21010G21KT 9999 BKN012 20/17 Q1017 BECMG BKN018.

There was no indication of such a low cloudbase on the TAF and I wouldn't particularly wish to fly under VFR in those circumstances - so would have climbed to VMC on top, followed the GPS track and asked for a SRA to visual on arrival

That is a VFR METAR, great viz and easy under VFR. I would be quite happy mooching around in the Auster in those conditions. There is nothing in that METAR that would have me needing an IMC rating.

[BEagle]

If the aerodrome was in the middle of a large plateau, then I would agree. However, it isn't - and to get there means crossing some significant hills to the north. Fine with a BKN018, I certainly agree. But not BKN012.

The point is that the BECMG 0809/0812 FEW040 hasn't happened, neither has the BKN018 - at 1150Z the METAR gave 081150Z 22011KT 9999 BKN015 21/17 Q1017 NOSIG.

You cannot trust such a UK TAF with sufficient assurance to guarantee a VFR trip - whilst you (and I) might be prepared to do so, we always have that insurance policy of an instrument qualification to fall back on if it all turns to worms. But the poor sap with a chocolate teapot rating would have to decide whether to press on and hope that the weather-guessers' incorrect forecast wasn't going to deteriorate still further - or whether to climb up to VMC on top and then hope for a hole.

[Pace]

I tend to agree with Beagle on this one. Mixing flying VMC and instrument nav on top and then trying to change that to VFR navigating with ground features is a risky business. Well broken clouds become not so well broken. Cloud thickness changes as do bases and tops as well as freezing levels.
Visibility below clouds change.

I knew a VFR pilot friend who flew to scotland with the intention of dropping back down through cloud having elected to fly VMC on top. His intention was to find a hole and continue to land VFR and in VMC. Amongst the densely packed clouds he found his hole and could see the ground below. Spiralling down he found himself surrounded by hills and poor vis in drizzle and much lower cloud than he imagined.

He saved himself by spiralling back up from whence he came. he then announced his predicament as a non IMCR pilot and was vectored to safety.
Even for experienced pilots changing from IFR to VFR is a fraught game if the weather is marginal VFR. Having been used to flying on instruments and with nav aids the change to marginal VFR can be disorientating. Much better to have a procedural approach than to be scratching around in the murk half lost.

The problem with flying is rarely do you get what you expect and unless you and the aircraft are equipt to deal with a multitude of scenarios you are asking for trouble. Flying pure VFR. Lowering cloud and vis is obvious. You can always turn back or divert. Flying VMC on top you cannot always see what is going on below and that is the danger.

I myself flying a twin in france left Paris in clear blue skies and sunshine for a coastal destination also in cavok. I couldnt believe my eyes flying VFR when scud cloud appeared which then went solid I was sure it must be localised and continued on top. I changed to IFR when I realised it was not localised and landed in 400 overcast off an ILS at my destination. A front had slipped slightly more south East than predicted.

Pace

[Fuji Abound]

Pace

I think that is an excellent post that could only be made by someone who has done it.

For me that sums up very well the difference between the theory so often reproduced by the arm chair bureaucrats and the average IMC or instrument rated pilot who is not flying every day and in all conditions, who knows his limitations, and is not a Sky God.

[Brendan Navigator]

Does anyone think that other European countries what people flying in the IFR system who do not understand that;

A Metar and TAF only relate to the aerodrome and it's immediate surroundings. The hills to the north are not part of the Metar or TAF - especially if the final approach is not over those hills.

Becoming in a TAF means that you can not be sure of the conditions changing until the end of the period if it is an improvement but it is taken to be the start of the period for a reduction

Cloud Broken 1000ft Becoming 1000 to 1200 Broken 2000ft means that you can not rely on it being BKN 2000ft until 1200 or later.

Cloud Broken 2000ft Becoming 1600 to 1800 Broken 1000ft means that you can expect Broken 1000ft from 1600 or even perhaps slightly before.

One can't complain about the TAF and the METAR when one is expected to make decisions based on both forecasted and actual met.

A wind of 210 at 10 Knots gusting 20 knots is reported (and forecasted as) 21010. The gust is only added when it is more than 10 knots above the mean.

Finally, the UK low level forecast chart was forecasting the following for the middle of England during the period described. (Yes it was amended but that was done during the night);

20 Km. Nil. ISOL 3000m BR/DZ LAN til 10Z

SCT / BKN SC (mod turb) 015/040 ISOL BKN/OVC ST 004-010/015 LAN TIL 11Z

Now I would never call those conditions suitable for VFR. Seems that the METARS show that at the aerodrome it was not as bad as it could have been. Note that the chart gives cloud AMSL but the TAF / METAR are "AGL" at the aerodrome.

So please come up with some rational arguments for the rating rather than trying to make people think that the lot over there should have their licenses taken away if they can't even work out the weather. Even the BBC got the winds right!!

The IMC will never be saved if the only reason for it is that of the very tiny percentage of Europeans that want it, a small percenatge can't work out the weather or the other case being we want to fly to low minima because that matches the weather.

Don't forget that this proposal is for recreational flying. It is not for any form of commercial flying. Recreational flying does not have to be able to get from A to B on a Saturday morning when the weather is bad. They can go play golf and do the fun flying another time.

A flying club does not have to fly when the weather is not suitable for VFR. There are no paying passengers. There is no commercial need. Recreational flying may benefit from a sub - IR qualification. But for recreational flying is it essential?

Those are the walls that are going to have to be climbed over. Lobbing chocolate tea pots full of misunderstood weather over the wall will do nothing to remove that barrier.

I wish you luck because in the absence of anything else you really need it.

[Captain Stable]

Pace, excellent post.

Brendan, you alternate between the irrelevant and the bleeding obvious.

This thread is not about interpreting TAF and METAR and whether people do it accurately or not. For the purposes of debating the IMCr we have to assume that people do.

The thread is about whether or not the IMCr should be kept and, if so, how we go about doing so and if not, what should replace it.

As far as I can tell, most of the educated opinion here (and I vainly include myself in that) is that it should be kept, somehow, and that bEurocrats who know llittle or nothing about aviation should wind their necks in.

Brendan, you last few paragraphs are the ultimate in stating the obvious and preaching a load of clever-sounding total rubbish. Please desist.

SoCal, thanks for that. The problem here is not whether or not people require an alternate, but the licence privileges that would permit flight VFR "on top" with an instrument approach at the end - either to a landing or as a cloud-break procedure to continue VMC on to destination. The situation in the USA is very much easier, since your IR is roughly equivalent to our IMCr.

[BEagle]

Brendan, thank you, but with 40 years of flying behind me, I'm pretty sure that I do understand TAFs, METARs and their limitations. The point being that yesterday's TAF was clearly over optimistic and the 'BECMG' never happened during the entire period stated. Which is not uncommon.

As for Don't forget that this proposal is for recreational flying. It is not for any form of commercial flying. Recreational flying does not have to be able to get from A to B on a Saturday morning when the weather is bad. They can go play golf and do the fun flying another time.

A flying club does not have to fly when the weather is not suitable for VFR. There are no paying passengers. There is no commercial need. Recreational flying may benefit from a sub - IR qualification. But for recreational flying is it essential?


What complete nonsense. Flying clubs need to teach students the essentials of visual attitude flying. Groping around in the murk won't achieve this; frequently a climb out of the haze layer or through cloud to VMC on top will allow an FI to teach exercises such as EofC 1/2, S&L 1/2, medium turning etc which would otherwise have been impossible. Then at the end of the exercise a quick radar to visual or a quick instrument approach back at base.

Think about gliding activity. With a cloudbase of 2999 ft, a tug pilot can release a glider 'clear of cloud' at 2998 ft. But without an IMCR, if the cloudbase is 3001 ft, then the pilot has to remain in VMC which means releasing no closer than 1000 ft to any cloud - 2001 ft in this case. That will cost the gliding community in the UK £millions. What do they do in Europe? Basically, they lie. They give a gallic shrug of contemptuous indifference to the law and just do what they like.

There may not be 'paying passengers' at flying clubs or gliding clubs, but there certainly are paying students and members. All of whom would be greatly affected by the loss of the UK IMCR and the introduction of this stupid 'EIR' chocolate teapot rating.

[Pace]

since your IR is roughly equivalent to our IMCr.

Cannot agree with that statement. The FAA IR is equivalent to the UK IR in the flight portion of the training and what can be done with it.
The big differences between the two FAA IR and EASA IR are in the ground studies.
The European IR works its ground studies more like a university degree requiring a lot of time and energy which working people cannot afford while the FAA system is much easier to achieve. Both are equal in other respects while the IMCR is not like either in any respect and does not allow airways flying.

Part of the problem we have is in the name IMCR. Save the IMCR is a bit like save the lesser spotted quagamingo :) The IMCR is a set of flying privalages based on training schedule to a certain standard. That Standard is low.

Can you sell those privalages and standards to the Europeans? The answer has to be NO! Could we sell a low level IR not directed at future airline pilots and RVSM airspace with the resultant lesser ground training requirements then possibly YES!

Could we get the Europeans to let the UK be a special case in keeping the existing IMCR? who knows maybe.

Pace

[FREDAcheck]

Brendan,

Yes we do understand what you are saying. It's not the point we are making. It really is nothing to do with our ability to work out the weather. You are clearly having difficulty understanding us.

Taking into account forecasts, and allowing for considerable uncertainty in forecasts, but I don't know how to express it more simply:
a) To undertake an IMC flight with only en-route capability requires near-certainty of cloud base above MSA at the destination (or alternate).

b) To undertake an IMC flight with an IMC rating requires near-certainty of cloud base above 500 feet AGL (assuming the destination or alternate has an ILS).

In the UK the number of occasions the weather meets (b) is many times the number of occasions it meets (a).
Do you understand this? If not, please let me know, and I'll try another way.

This greatly increases the utility (and safety) of an IMC rating.

If you don't think this matters, please explain why you are hostile to the idea that the UK should continue a rating that has been shown to be effective. Never mind the rules of EASA, please give me a moral reason why should the rest of Europe stop the UK doing something which is useful to the UK, and does absolutely no harm to the rest of Europe?

[Pace]

If you don't think this matters, please explain why you are hostile to the idea that the UK should continue a rating that has been shown to be effective. Never mind the rules of EASA, please give me a moral reason why should the rest of Europe stop the UK doing something which is useful to the UK, and does absolutely no harm to the rest of Europe?

Fredacheck

I would agree with that! The UK is a special case in the fact that we are an island under maritime influence and hence more liable to poor viz and low cloud than many of our European neighbours who have many more VFR days than we do.

In that respect the IMCR is much more needed here and in Ireland than for instance Spain or a lot of the drier continental European countries which are not influenced by maritime airflows and temperatures that we have.

In that respect EASA should allow "special case" allowances for countries which are unusual to the standard and have special needs.

Pace

[Captain Stable]

It's off thread, but I disagree with your disagreeing with me, Pace (if you can follow the convoluted grammar!)The FAA IR is equivalent to the UK IR in the flight portion of the training and what can be done with it.The latter part yes, granted, but not the first. As a current holder of both a UK and a USA ATPL/IR and a former holder of an IMCr (back in the days when I was a "mere" PPL), and having trained students under both regimes to all levels, I feel qualified to speak from personal experience, and I maintain that the training and testing standards of the FAA IR are pretty much those of the IMCr.

[julian_storey]

I should have thought that the tidiest solution would be to 'grandfather' everyone with an IMC rating an Instrument Rating issued with a restriction such that its privileges may be exercised only outside of controlled airspace.

[BEagle]

The IMCR is a set of flying privalages based on training schedule to a certain standard. That Standard is low.
(sic)

No, the standard is NOT 'low'. The IMCR is examined to a specific standard and is not a simple test.

The theoretical knowledge requirements, flight training and testing for the UK IMCR are entirely proportionate for the privileges the rating confers.

julian storey, do you consider Class D airspace to be 'controlled airspace'? Many IMCR holders fly instrument approaches in Class D airspace and do so entirely safely. 'Grandfathering' is unacceptable - the IMCR must continue to be available in the UK to any PPL holder who wishes to include it in his/her licence irrespective of EASA's desire for €urocratic lowest common denominator regulations with disproportionate regulatory requirements.

EASA has yet to deliver anything of any conceivable benefit to the UK GA fraternity.

[Pace]

Captain stable :)

Maybe years ago when you could buy anything in the USA and half the examiners instructors with it, but things are very different nowadays and have been tightened up considerably.

Examine the training requirements and tolerance requirements of both IRs compared to the IMCR and they are no where near the same. What makes the EASA IR harder in flight training requirements than the FAA IR done by the book?

Again off topic examine the major study carried out between the two systems and the resultant ATPs are equal in the safety stats.

Pace

[Pace]

No, the standard is NOT 'low'

Beagle by low I meant in comparison to an IR hence EASA would see it that way if you tried to sell the IMCR as a Eurpean rating.

EASA would also see it as treading on the IRs feet and a lowering of standards.

Hence I support the retaining of the IMCR but differ to many here in the fact that i cannot see EASA ever accepting it and wonder whether a low level IR for Europe would be more achievable? with maybe a special case IMCR for the UK or individual countries who prove they have a special weather case to need it.

I agree the standards are not low for what the IMCR was intended for.

Pace

[neilgeddes]

I should have thought that the tidiest solution would be to 'grandfather' everyone with an IMC rating an Instrument Rating issued with a restriction such that its privileges may be exercised only outside of controlled airspace.


Sounds like an excellent idea presuming controlled airspace means A and C, not D

[Pace]

I should have thought that the tidiest solution would be to 'grandfather' everyone with an IMC rating an Instrument Rating issued with a restriction such that its privileges may be exercised only outside of controlled airspace.

Sounds like an excellent idea presuming controlled airspace means A and C, not D

The whole point of the IR is to fly in CAS. To achieve an IR means you are trained to a standard layed out for aquisition of an IR and pass relevant tests to prove your ability in knowledge and flying skills to meet those standards.

How can the few handful of hours hours required and large flying tolerances allowed for the IMCR meet any of the IR requirements?

Reading all the posts in this thread my guess is becoming that the best way to save the IMCR is to argue a "special Case" for the UK due to the minimal VFR days compared to most of Europe and the poor quickly changing weather associated with the maritime influence around our islands.

Anthing more European wise is wishful thinking.

Pace

[mm_flynn]

Sounds like an excellent idea presuming controlled airspace means A and C, not D


And this is one of the really big problems the Europeans have with the IMCr. Their airspace isn't sealed off like a water tight drum from IMCr holders like the UK CAT airspace is.

You need to be comfortable arguing the IMCr is an appropriate rating for flying into Heathrow and flying through the London TMA - because that is what we are implicitly asking Europeans to agree with - or to fundamentally restructure their pretty standard use of airspace to match the UK's unique approach to airspace!

---
I know this issue can be dodged by allowing individual states to allow/not allow the IMCr, or for it to be a UK only rating (i.e. the status quo), but this is diametrically opposed to the decisions already made by EASA and implicitly agreed by the British Government (in that they are in the EASA process)

[julian_storey]

I'm planning to start my IMCr in late October and I'm really looking forward to it.

Just a couple of slightly 'off discussion' questions:

1. How much do airports like Southend or Cambridge charge for practicing instrument approaches (when not based at the airport)?

2. Would TT vol.5 be a good textbook for the course and exam prep?

Many thanks


Hello,

Assuming that you can take a couple of weeks off work, you might be better off getting an FAA IR instead.

The cost will be similar, you have FULL IR priviliges in an 'N' reg aircraft and the CAA will 'give' you an IMC on the strength of it (they charge you £80 for the paperwork).

Worth considering! :ok:

Julian

[DBisDogOne]

CliffordFW:

1: Don't know about Cambridge but did my IMCr last month and used Southend, I think it was £18 per NDB/ILS approach. (might be that plus VAT - can't recall).

2: TT Vol 5 is very good, also get the IMC confuser too to back this up and make the exam easy. Most of the exam by the way is a flight plan/PLOG affair so brush up your planning and dust off/practice with your whizz wheel if rusty!

Good luck with your IMC, it's not as easy as people (usually those who've never done it....) will have you believe but is very rewarding and your general flying will improve too (accuracy etc).

[jez d]

Clifford, while Julian's idea has merit, I would recommend you wait until EASA have published their Notice of Proposed Amendment (NPA) for oversight of third-country aircraft/operators (due out at the end of the year), before you undertake an FAA IR.

Rumour has it that this NPA will include new regulation which will effectively ban EU residents from flying N reg aircraft in EASA land. This opens a whole can of worms, not least the fact that FAA IR holders will no longer be able to use their ratings to fly IMC in Europe. This, I suspect, is the real reason FCL008 was instigated - to look into an EASA PPL-biased IR that European FAA IR holders could convert to, and had little to do with saving the IMCr.

Having said that, EASA have been given a severe telling off by their EU political masters recently, who have effectively told the Agency to stop re-inventing the wheel, adopt JAR FCL, and leave the remaining sub-ICAO licences and ratings to national authority oversight.

My hunch is that the IMCr will remain as a UK-only rating, and a European PPL-biased IR will eventually emerge in about five years time.

Rumour has it a new mission statement from EASA is due over the next few weeks.

Regards, jez

[julian_storey]

Clifford, while Julian's idea has merit, I would recommend you wait until EASA have published their Notice of Proposed Amendment (NPA) for oversight of third-country aircraft/operators (due out at the end of the year), before you undertake an FAA IR.


Even if this 'N reg ban' does happen and I accept there is a chance that it might, Clifford will STILL have his IMC rating (issued on the basis of his FAA IR), will have been trained to a higher level and will have spent very little more money than if he had just got himself an IMC rating here ;)

[jez d]

Agreed, other than my aversion to giving business to those across the Atlantic at the expense of the UK flight training industry.;)

The alternative of course would be to undertake the IMCr in the UK and then upgrade to an FAA IR. I believe the FAA still recognises the UK IMCr and permits a reduction in the IR training requirement accordingly? The UK CAA, naturally, refuses to acknowledge the IMCr in the same fashion and requires one to undertake the full JAA IR course, irrespective of how much IMC flying experience one has. :ugh:

[julian_storey]

The UK CAA, naturally, refuses to acknowledge the IMCr in the same fashion and requires one to undertake the full JAA IR course, irrespective of how much IMC flying experience one has.

One would expect no less :*

[Pace]

Rumour has it that this NPA will include new regulation which will effectively ban EU residents from flying N reg aircraft in EASA land.

Jez

Various bodies have tried this countless times and failed. To attemp the above would breach discrimination laws and many others. You mention N reg but what about IOM?

I am not knowlegable on aviation law but listened to such a lawyer who described the impossible minefield that regulators would have to cross to achieve those aims so forget that it wont happen.

Pace

[jez d]

Hope you're right Pace, but how does the FAA get away with it then?

[IO540]

The FAA does allow foreign reg planes to be based in the USA, and I know of UK pilots who emigrated there, with their G-reg planes, and were OK.

IIRC, more recently, there are some TSA issues with this, along the lines of having to give notice for some flights. But I have no details.

Of course, nobody is going to be crazy enough to keep a G-reg in the USA indefinitely because they have to keep digging out a CAA LAME to sign it off, or an EASA 145 company. A huge waste of time.

And as regards licensing, the FAA practically hands you FAA licenses! You can either have a 61.75 PPL with the Foreign Pilot IR exam route, or you can use all your foreign training (no matter where done, who with, in what reg plane, in Mongolia, etc) towards FAA licenses.

The FAA is extremely generous.

EASA is hoping to sign a reciprocal treaty with the FAA but this presupposes the FAA allowing N-reg planes to be flown in the USA on EASA licenses - which will never happen. As I say above, the FAA effectively avoids this situation arising in the first place, by offering an extremely generous US-taxpayer-subsidised license conversion policy, but EASA pretends this doesn't exist and "only a reciprocal treaty will do". Typical idiotic dig your heels in Eurocrap, and IMHO there will be a humiliating climbdown.

[Pace]

Jez

Neither you or I are lawyers or understand the American legal system versus the European legal system. I would not even try to give reasons why.
All I know is that various countries have tried before and given up.

EASA is already in a shambles and appears to be yet another quango of people who dont know what they are doing as we already have found out.

Pace