EIR, IMC rating and Jim Thorpe

[Fuji Abound]

In response to AOPA’s concerns, Jim Thorpe says, “It would have been helpful if the UK branch of AOPA had made any concrete suggestions whatsoever at the start of the process when they were invited in person to do so. Neither did they take up my two recent offers of a full briefing so they would be in possession of the facts. If they had they would then understand that the EIR is not intended to replace the IMC. There was never any possibility of a UK style IMC working in Europe with its very different airspace. Nonetheless, AOPA, in the shape of IAOPA, have their own German representative on FCL 008 and he has been fully supportive of the whole process.
“The natural home of anyone who uses the IMC intensively will be the flexible IR. After all the USA, whose system is so admired, has found no requirement for an IMC like qualification. The EIR was seen more in the context of a stepping stone for pilots in the other 25 European states who previously had nothing other than a commercially orientated IR on offer.”
“It is simply factually inaccurate to state that nowhere in Europe has weather like that in the UK,” continues Mr Thorpe. “If the EIR proposal is such an impossible way of operating, no one has told the thousands of pilots throughout Europe who fly VFR on top and descend without any instrument qualification at all. In the UK in the early days of the IMC rating it was often used in exactly this way. The airspace in which it was valid was defined in an ANO schedule and relatively few airfields with instrument approaches were accessible to the IMCr holder so regaining visual conditions prior to landing was common practice.”
One other significant difference between the existing UK IMCr and proposed EIR is the theoretical knowledge requirement. For pilots undertaking the IMC course the theoretical knowledge requirement is relatively un-intensive, comprising just a single written exam. For the EIR however, it is proposed that the theoretical knowledge requirement will be the same as that required by pilots undertaking the full Instrument Rating (IR). There is a significant twist however. According to Jim Thorpe, much work has been going on in FCL008 towards producing a PPL IR more relevant to the type of flying undertaken by private pilots. Jim has told FTN that the proposed PPL IR theoretical knowledge learning objectives will be half those currently required for the JAA IR, with studying expected to be undertaken primarily by distance learning. FTN also understands that the flying training requirements for the EIR, which will be roughly equivalent to the existing IMCr, will not have to take place at an approved Flight Training Organisation (FTO) but can be undertaken with PPL schools operating as Registered Training Facilities (RFs). It is also expected that some or all of the training required for the EIR will count towards a full Instrument Rating, making the EIR the sort of ‘stepping stone’ rating towards an IR that the IMC used to be. All this conjecture comes with a health warning however, that until the finalised proposals are published, all information about them is unofficial and in part guess-work. Nevertheless, supporters of the EIR point-out that it may well offer a significant business opportunity to UK flying schools who may well be better placed to offer training for it than schools in other European states where there is no previous experience of instrument flying training for private pilots.

I also posted this on the darker side (the other side is always the darker side depending which side you are posting from!) but I think it is worth a wider audience.

It leaves me wondering why or how Jim Thorpe is in part representing the interests of UK GA?

[BEagle]

AOPA knew that Thorpe was proposing this ludicrous idea as long ago as February this year....

However, you may rest assured that strenuous efforts are now being made to lobby FCL.008 and others to rip up and throw away the so-called EIR and instead to promote a lightly modified form of the UK IMCR which should be acceptable to the rest of the EC.

Sadly though, the damage done by Thorpe's EIR has given the wholly wrong impression to the rest of FCL.008 that the UK had 'given up on the IMC Rating' - which, of course, it hasn't.

Thorpe's EIR was allegedly based on the Australian Private IFR Rating. However, it does not include one of the main parts of the PIFR, which is the ability to add various 'Flight Procedure Authorisation' items to the PIFR - including instrument departure, arrival and approach privileges.

[421C]

AOPA knew that Thorpe was proposing this ludicrous idea as long ago as February this year....
Amazing. Not. AOPA is directly represented on FCL008, by one of the few people who work full time for AOPA in Europe.

However, you may rest assured that strenuous efforts are now being made to lobby FCL.008 and others to rip up and throw away the so-called EIR and instead to promote a lightly modified form of the UK IMCR which should be acceptable to the rest of the EC.

So what strenuous efforts have been made by AOPA on FCL008 to date? Why do you endlessly snipe at Jim Thorpe and what he has done. Why not tell us what AOPA has been doing on FCL008 for the last year?

brgds
421C

[BEagle]

AOPA UK is not directly represented on FCL.008; representation is made through the IAOPA representative.

I certainly will 'endlessly snipe', as you put it, at Thorpe's utterly absurd pet hobby-horse, the 'EIR'. He cannot be unaware that the 'EIR' concept has been lambasted over recent months and that no-one supports it. Yet he continues to push the absurdity of the 'EIR' through FCL.008 with neo-evangelical zeal.

You will have to wait and see whether AOPA UK's efforts to change FCL.008's thinking on the IMCR situation will bear fruit - but work is ongoing as I write....

[421C]

AOPA UK is not directly represented on FCL.008; representation is made through the IAOPA representative.


Fine. So tell us what AOPA UK's indirect representation on FCL008 has been for the year (?) FCL008 has been running.

[BEagle]

421C - are you an AOPA member?

If so, e-mail the Chief Executive and ask him.

[421C]

Why won't you post an answer to this simple question? You are hardly shy about posting on this subject, and it seems to me a fair and reasonable question. Either you don't know what AOPA UK has been doing, which seems odd given your intensity on the topic, or you do know and can't or won't say.

BTW I am a member of AOPA UK.

[vanHorck]

Beagle

I am not a member of the UK AOPA (being Dutch) but I do have an IMC.

What has AOPA UK indirectly done in the lobby in this last year on the subject?

You write:
...you may rest assured that strenuous efforts are NOW (my capitals) being made....

What do you mean by NOW ? Was AOPA UK too late off the starting blocks?

[S-Works]

Pam Campbell has represented AOPA indirectly at FCL008 after AOPA UK did not get a place on the group which I always found a bit strange as it is a UK rating after all.

Beagle you clearly have an axe to grind over this issue as both your emails and forum postings have been aggressive and downright rude about Jim Thorpe. Whatever your opinion of the situation and FCL008 as a group that is uncalled for.

Regardless of how you butter up the situation, it has been made clear that the EASA and the European NAA's have no stomach for the IMC and in order to try and get something through Jim Thorpe put forward a solution that was not torpedoed by the group. Whilst it was not an ideal solution it was one that had a potential.

We all know that the simple solution would be for it to be accepted European wide using the 'where allowed' clause that you trumpet regularly about. However if it was that simple why has it not been adopted?

[Johnm]

We all know that the simple solution would be for it to be accepted European wide using the 'where allowed' clause that you trumpet regularly about. However if it was that simple why has it not been adopted?

This is a committee set up by a bureaucracy, simple is not a word in the vocabulary in use.

[BEagle]

Beagle you clearly have an axe to grind over this issue as both your emails and forum postings have been aggressive and downright rude about Jim Thorpe. Whatever your opinion of the situation and FCL008 as a group that is uncalled for.

bose-x, yet again you appear unable to differentiate between criticism of an individual and criticism of his policies or proposals.

I'm sure Jim Thorpe is a perfectly charming person; however, the damage wrought by his 'EIR' proposal deserves every criticism.

In this context, it is interesting to note the difference between the original PIRR proposal and the version ulitmately delivered. And, of course, there was an opportunity for everyone in Australia to respond to the Notice of Proposed Rule Making published in 1998.....

[vanHorck]

Beagle,

Any chance of an answer re. my questions?

I ted to agree with Bose X here. I took felt there was a harsh undertone towards Mr Thorpe in your criticism.

Let's cool down a little and accept we all try to find solutions, and we may not always agree with other people s attempts.

Trying to work towards a solution seems better to me than doing nothing about the problem at hand

[S-Works]

bose-x, yet again you appear unable to differentiate between criticism of an individual and criticism of his policies or proposals.

I can indeed differentiate which was the very reason I made comment. As VanHorck says, cool down a little and reflect on what you write. This is clearly an emotive subject to you, but personal abuse is not called for and will not change anything.

If you wish to take issue with me directly then I suggest you save it for me in person for the 5th December. We can discuss directly my ability to understand the nuances of human interaction.

[englishal]

I seem to have lost the plot with regards to this whole business....

I'd actually like to see a EIR which is aimed at the PPL, grandfathing previous instrument time, distance learning, using flying clubs.....I'd actually find it more useful than an IMCr as France is on my doorstep so to speak.

I'd hate to see a national rating disappear though and I don't see why it should just vanish with no alternative.

[dublinpilot]

I'd actually like to see a EIR which is aimed at the PPL, grandfathing previous instrument time, distance learning, using flying clubs.....I'd actually find it more useful than an IMCr as France is on my doorstep so to speak.

Are you aware that it would not allow you to fly an instrument approach?

[mm_flynn]

Are you aware that it would not allow you to fly an instrument approach?
Remember, quite a lot of people are flying from fields that don't have instrument approaches anyhow. I don't do a lot of flights that need an approach below the local MSA, but I do an awful lot of flying where remaining legally VFR is a pain (and sometimes would be unsafe). In addition, the whole enroute process is so much easier on an IFR flight plan at FL100 than trogging through the dirt, dog legging around CAS or getting a series of ad hoc transits. In the context of the reduced requirements proposed for an IR, the EIR seems to have a point as a stepping stone, and addresses the concern a number of UK FI raised that they frequently need to 'pop through a layer'

I agree it is not a replacement for the IMCr, and AOPA UK are leading the charge on a method to retain that ... but it is virtually inconceivable the rest of Europe will agree to an IMCr (unless you count agreeing to the principle ... but not in their airspace! - which may well be an approach to retaining the UK IMCr).

You only need ask yourself, 'Why are IMC holders so comfortable about not having access to the airways, and why does the UK not allow an IMCr in the airways?" and then think about how the answers would apply (or more accurately not apply) in most of the rest of Europe to understand why an IMCr has little chance of being implemented outside the UK.

[englishal]

Are you aware that it would not allow you to fly an instrument approach?
Well that is the really stupid bit. The rating should at least incorporate a precision approach.

'Why are IMC holders so comfortable about not having access to the airways
Are they? Give me access to airways any day.

I wonder why they couldn't just come up with a proper IR "for private privileges or training purposes only", with an upgrade course necessary for anyone wanting to fly 747's using it?

Would seem eminently sensible to me, allow distance study, one private IR exam based upon the FAA one (as in computer based, easy to book etc...), only 15 hrs of *required* tuition or a foreign IR/IMC in lieu of.....training at a small flying club etc etc....Then there would be no problems with ATC issuing clearances one cannot comply with, and those wanting to go on to fly CAT could do so with a bit of extra training....Surely this this would even please the Eurocrats?

[BackPacker]

I'd be very interested in such an IR. And I would not even mind if they would limit such an IR to below certain airspeeds, or below certain altitudes. For instance the oxygen level (FL100 or thereabouts) or the RVSM level. Or non-FIKI only.

You want higher, faster, bigger, FIKI, get the big boys IR.

But I see no value in an EIR if you cannot depart or arrive in instrument conditions. Particularly the non-instrument arrival will lead to a lot of situations where people misjudged the situation and get "boxed in" by their license privileges.

[englishal]

I'm not sure you could place airspace limits really unless it was say 18000', otherwise ATC might issue clearances that one cannot comply with. Plus I'd like to cruise in the high teens for best TAS and to be clear of the weather and many private aeroplanes can cruise at 20,000.

But they could limit it to "for use not above 250 kts, not authorised for Turbojet aircraft" or something if there was a need. The IR upgrade could then form part of a type rating which most aeroplanes of this nature would require.

But I think a limit of "not authorised for public transport operations" would be good enough to differentiate between a Public and Private IR.

[BackPacker]

That's why I would not choose the altitude limit arbitrarily, but connect it to something that, in practice, is a limit already. Without oxygen/pressurization you cannot fly above a certain altitude (except for a short while in FAA-land) and without RVSM capability in the plane the upper flight levels are forbidden anyway. So those would make natural limits for an IR-light, since you don't have to explain a lot more to the controller if you get such a clearance.

I'm just looking at my club environment where we have a bunch of stock standard PA28s, 172s and a DA-40. Most of them IFR equipped and certified. That's the kind of airplane that a lot of PPLs would want to do their IR-light in. And that's probably what they're using for their IMC today in the UK in any case. They rent, not buy. And as a result of which, even if the airplane has the capability to cruise above the oxygen level, there's no club which rents oxygen cylinders, masks, regulators and stuff along with the plane.

We are primarily looking at a pan-European replacement for the IMC so I think you've got to look at what the types of airplanes are, and the experience levels of the pilots who use the IMC.

And as I said, if you want more capability, get the full IR.

[S-Works]

An IR that is limited by speed or altitude etc is a full IR just crippled..... You still need the theory of the system and the skill flying the approaches so what is the point?

The enroute IR makes sense to me as it allows most people to do what they already claim they do with the IMC which is cruise VFR on top but with the advantage they can fly the lower airways system. If you want approaches then you convert your enroute IR to a full IR and get the approaches. It actually struck me as a logical route.

What we have as usual is people trying to turn the IMC into an IR by the back door. Wake up and smell the coffee, it aint going to happen.....

[englishal]

An IR that is limited by speed or altitude etc is a full IR just crippled..... You still need the theory of the system and the skill flying the approaches so what is the point?
To appease the Eurocrat doubters?

An EIR without IAP capability is a load of crap, one could do most of it now anyway "VFR on top", and without IAP capability then it is step backwards - unless the UK files a difference and allows it in UK airspace which I doubt.

Flying airways is a piece of cake as you know. Flying an ILS is a piece of cake. But there are always going to be the noobs who say that "ooohhh noooo you can't have someone in the airway with such limited experience". Balls, airways in many other countries are not controlled and allow a mix of VFR and IFR traffic and so that argument doesn't stand. As I understand it, the EIR would allow "access to all classes of airspace" and so again the argument doesn't hold. The only change then is the lack of the IAP.

It seems to me that to get a PPL/IR then there has to be sacrefices made to make it "more achievable" and the best way to do this is to reduce training requirements and place limits on it. The "not for public transport use" is a sensible limit, it would not affect most of us that fly for fun and would mean that commercial pilots still have a "gold plated IR". It would be self regulating, most EIR holders would not choose to fly in really ****e weather, something which often can't be avoided in CAT operations.

It needs to have at a minimum a precision approach capability.

[S-Works]

It needs to have at a minimum a precision approach capability.

In which case it then becomes an IR...........

All we actually need is an IR that is fit for purpose. But that would require a massive shake up of the training industry and there are way to many vested interests for that ever to happen.

[dublinpilot]

Jim Thorpe's idea wouldn't be bad, if it allowed you to add approaches with further training like the Aussie's do (which it is based on).

Those approaches could even have higher minimum decision heights than an IR, and still be useful.

But without it, it's useless, other than to facilitate those trying to progress to a gold plated IR.

It's certainly no replacement for an IMC, and will result in much lost business to the UK training industry. I can't see many people training for it, which will eventually lead to the same situation as in Ireland. ...... few interested in training for IFR flight, so aircraft aren't maintained to IFR standard. As fewer aircraft are maintained to IFR standard, there are fewer people with access for IFR aircraft, which means fewer people will bother to train......a classic spiral descent.

If you don't think that will happen, you just have to look at the rest of Europe. The UK is an oasis in the middle of a desert of non commercial IFR flight. It's because of that desert that the UK is a lone voice....private IFR pilots in Europe are almost extinct.

[S-Works]

If you don't think that will happen, you just have to look at the rest of Europe. The UK is an oasis in the middle of a desert of non commercial IFR flight. It's because of that desert that the UK is a lone voice....private IFR pilots in Europe are almost extinct.

Rubbish. melodramatic claptrap dreamt up by those justifying the IMC. The figures do not support the romantic notion that the UK is some sort of IFR oasis. The figures show that with the exception of a tiny minority the IMC is used as a get you home rating with few people ever flying approaches between the renewals. One of the key things that people use the IMC for is to remove the stupid restrictions on the basic PPL to fly out of sight of the surface and reduced viz requirements. So in this sense an enroute IR is a direct replacement and an enhancement as it counts fully towards the full IR.

As IO540 will be along in a minute to point out, the UK rental scene is full off non IFR legal clapped out old crap. Those that own IFR equipped aircraft are (with the exception of the minority mentioned earlier in my post) IR holders, FAA or JAA.

The figures also show that the move is massively towards permit aircraft with the lower costs of operation and the greater access to wizzy gadgets.

Jim Thorpe's idea wouldn't be bad, if it allowed you to add approaches with further training like the Aussie's do (which it is based on).

It does, it is called doing the full IR........

[BEagle]

dublinpilot, you're quite correct there.

I researched all this over the last couple of days for reasons which may soon become evident. Yes, the original 1999 Australian 'EIR' proposal bore a remarkable similarity to Jim's idea.

But the CASA 'EIR' became the 'PIFR' with, as you rightly state, the ability to add Flight Procedure Authorisations for other items such as instrument approaches. See Appendix 2 to Civil Aviation Order Part 40 section 40.2.3.

Jim's EIR doesn't include the FPA concept and it would be interesting to know why the Australians modified their original EIR to include it. Perhaps they recognised the folly of the original EIR concept? I don't know - the comment responses seem to have been removed from the web.

Using an old UK military analogy, you can think of the 'full' IR as a Procedural Green Rating. Whereas the UK IMCR is more equivalent to a non-Procedural White Rating - an IR with proportionate theoretical knowledge requirements but with a mandatory 200ft addition to MDA/DA and no 'airways' privileges. Which worked fine.

[englishal]

In which case it then becomes an IR...........
"For private purposes only".

[dublinpilot]

The figures do not support the romantic notion that the UK is some sort of IFR oasis. The figures show that with the exception of a tiny minority the IMC is used as a get you home rating

Everything is relative. You have lots of pilots being made safer, by being trained in IFR flight. You have some pilots using it regularly, and some using it simply to 'get home'.

That IS an oasis, compared to the rest of Europe. There is zilch IFR training going on outside the UK, other than for those going commerical.

The UK might not be the USA for IFR flight, but it's certainly a lot more active than the rest of Europe.


As IO540 will be along in a minute to point out, the UK rental scene is full off non IFR legal clapped out old crap

Probably true, but none the less, when I speak to UK pilots, a lot of them seem to have done the IMC rating, and many have access to IFR capable aircraft. They might not be that many that are well equipped, but there are some.

Have a look here.....during our recent boom, everyone could afford the nice luxury cars, and multiple holidays.....but no one bothered with IFR training....because there were no aircraft to fly IFR once they qualified.

The UK is far from where we are.

[S-Works]

Probably true, but none the less, when I speak to UK pilots, a lot of them seem to have done the IMC rating, and many have access to IFR capable aircraft.

Thats because the sausage machine flying clubs are always 'encouraging' people to collect more badges that they don't use. The night qualification is another example. Look how many people who have one and then say they will never fly at night in a single etc.

The term IFR capable has very different meanings to many people.

IFR to me is a full BRNAV airways capable machine. To a flying school it is enough to teach the course and generally not legal in terms of FM immunity etc.

[BEagle]

Personally I consider that flying clubs actually teach IMCR courses for the clearly associated safety benefits, rather than for 'badge collecting' reasons. Particularly given the reduction in instrument flying requirements for the PPL(A) introduced under JAR-FCL.

'IFR capability' and 'FM immunity' are two topics widely misunderstood, I agree. Again, many of us consider 'FM immunity' to have been an expensive irrelevance - is it mandatory in the US with its larger number of aerodromes and FM broadcast stations and greater 'risk' of FM-interference?

However, the old distinction between 'airways capable' and 'suitably equipped to fly/navigate in IMC outside CAS' was reasonably clear.

If full B-RNAV (and airways) capability would be needed to use the 'EIR', then teaching it would probably have little appeal to any flying club's business plan as they probably won't have aircraft equipped to such standards generally available. Even if they did, they'd probably be very expensive to rent.

[englishal]

Probably true, but none the less, when I speak to UK pilots, a lot of them seem to have done the IMC rating, and many have access to IFR capable aircraft.
And many PPLs PLAN to do the IMC after the PPL+a few years flying. More than PLAN to do the IR.

So what if some people train and then never use it? Does it matter? The fact that have done all their training makes them a better pilot anyway, and surely doesn't inconvienience you in your *BRNAV* airways machine....what difference does it make to you? Just because you have already collected your badges, I don't see why other people shouldn't have their chance too.

[S-Works]

It is not inconveniencing ME.

I am trying to bring balance and explain how people ending up doing the IMCr. When people do the PPL, they go out fly for a bit, get bored look for a new challenge, do the night qual, fly a bit more, get bored, look for new challenge and then do the IMC. Same goes for tailwheel training, bigger faster hotships etc. Then equally they don't do anything with that either and with the IMC never use it in earnest, keep it current for a few years out of guilt for the money spent and then it lapses.

Then are the people who really get into and then want an IFR hotship, then realise it is really restrictive flying around the few truly available IFR airfields in the UK and move onto full IR's. What most people do with the IMC is fly between non IFR airfields on top. Something an enroute IR gives them and the bonus of being able to do it in the airways.

So lets leave the personal attacks out of the discussion please.

[bookworm]

If you don't think that will happen, you just have to look at the rest of Europe. The UK is an oasis in the middle of a desert of non commercial IFR flight. It's because of that desert that the UK is a lone voice....private IFR pilots in Europe are almost extinct.

And surely that makes it all the more important to establish a pan-European instrument rating that revitalises private IFR in Europe, rather than creating a historical anachronism that serves the interests of a group who appear to think that the air stops at an FIR boundary.

But without it, it's useless, other than to facilitate those trying to progress to a gold plated IR.

The main objective of FCL.008 is to remove all that gold plate and create a European IR with requirements that are fit for purpose and appropriate for its privileges. The Enroute IR has been proposed as nothing more than a facilitator for that.

[englishal]

So lets leave the personal attacks out of the discussion please.
Sorry you thought that mentioning BRNAV was a personal attack?

I thought one of the main objections to reduced training (put forward in earlier arguments) was that CAT didn't want to mix with the PPLs in the airways. Well the EIR doesn't address this (not that there is anything to address), so why limit approaches? Why not just limit it to "private privileges only" and if people want to let it lapse, so what? People will use it when they want or need to.

[mm_flynn]

Further to BWs comment, the full context of the EIR also included a substantial revision to the IR - specifically a dramatic reduction in TK content (c. 50% ) and training to a competency level not a number of hours. In this environment adding the extra training for approaches to the EIR (as the Aussies do) seems a bit of a waste as with about the same expenditure you could upgrade to the full IR.

The heat in this whole issue is the fact the IMC ball was dropped several years ago and there is a scramble to pick it up. 'Saving the IMC' is a UK specific issue, which AOPA UK is ideally positioned to champion.

Revitalising European touring and light business aviation by having sensible licencing and sensible requirements for an IR is what FCL.008 seems focused on.

Creating a EuroIMCr (other than the previously mentioned wheeze of creating it and than not allowing it anywhere other then the UK as part of a 'save the IMCr' strategy) is pretty much of a no hoper.

[englishal]

seems a bit of a waste as with about the same expenditure you could upgrade to the full IR.
I disagree. If you had the EIR with Precision approach capability, then TK requirements would be dramatically less, and training would be dramatically reduced. It takes about 15 hours (IMHE) to become competent in basic attitude instrument flying, so add a further 5 hours for the ILS....with training as required for current IMC/ICAO pilots. TK could focus on weather, enroute and the ILS rather than include all other types of approach.

[IO540]

Anybody trying to put words in my mouth is going to end up on a seriously losing wicket, as they should know by now :) Especially makes me smile to see BRNAV mentioned :) :) :) :) Well, at least I don't have to strip down most of my Photobucket site in a mega hurry after writing some web article.

The proposed EIR would be a useful privilege for European pilots who currently have nothing, zero, zilch, beyond plan VFR, right up to the full JAA IR. Most of my long "VFR" trips would have been very nicely doable with such a rating.

I think there may be an issue with ATC acceptance of flights which will be fully "normal IFR" when enroute, and when arriving (STAR or vectors), but which will then have to refuse the IAP and request a visual approach instead - having somehow first managed to get themselves low enough to be VMC before getting formally cleared for the approach. Merely vectoring to the MVA won't do because the MVA is often way higher than the MSA. And often one will be cleared for the approach long before becoming VMC (fairly obviously). Some ATC "training" will thus be required. Bear in mind that a fair chunk of European ATC is only just managing to hang in there when it comes to English Proficiency. And ATC unions are among the most powerful players on this whole aviation-political landscape. These are just my immediate thoughts; it could well be that these issues have been worked out with some scheme e.g. having to ensure, before departure, that the forecast cloudbase (like the FAA 1/2/3 rule for alternates) is above the platform altitude for any approach for that airport. Of course, the pilot could also make it all work by using the highly desirable IFR clearance for the whole enroute bit and cancelling IFR say 30 miles before the destination, departing CAS, finding his own hole in the clouds OCAS, and then popping up on the radio at low level, VFR (this is safe at coastal airports...).

For the UK, I suspect the IMCR will remain, as a last-minute face saving compromise solution accepted by an overworked EASA buried up to its neck in controversy and with top level political flak incoming from all directions. Stripping thousands of pilots of existing privileges is simply unknown in aviation history, AFAIK, especially a safety-critical privilege like IFR.

[S-Works]

especially a safety-critical privilege like IFR.

If the IMCR is such a safety CRITICAL privilege how come all of the day VFR only pilots are not dropping dead through lack of it?



Words in your mouth........ :=

But PLEASE do not post these publicly or reveal how you found out.

[Captain Stable]

how come all of the day VFR only pilots are not dropping deadI recently attended a CAA Safety Evening. It highlighted (among other things) that quite a lot of fatal accidents are caused by untrained pilots getting in over their heads weather-wise.

So, actually, some are dropping dead through lack of it.

[dublinpilot]

[deleted] and a few more more as the post is too short

[S-Works]

Actually DP, I was just reflecting on how those behaving maliciously often get caught out out in there keenness to share tit bits with others. That was an extract from a personal message written about me that the recipient forwarded to me as well as the mods in disgust.

Assuming that the enemy of your enemy is your friend is often a dangerous one to make.........

[dublinpilot]

Sorry Bose.

As that wasn't an extract from a pm you received, I'll delete the post and hereby apologise to you ;)

We don't always agree on stuff, but that doesn't make you my enemy :ok: Enough of people say nice stuff about you, so I assume you're actually a nice bloke :)

dp

[Fuji Abound]

For one moment let’s examine the evidence, and forget what may or may not be commercially or politically desirable – it isn’t a bad place to start.

Before the IMC rating pilots flew in cloud – there was no cloud rating. However it became clear some training was required in order to enable pilots to fly safely in cloud – the IMC rating was born.

Fact: In over forty years there have been almost no accidents involving pilots with an IMC rating in IMC. That would suggest, in what ever way pilots are using the rating, they are doing a remarkably good job of managing the risks.

Fact: There have been far more accidents in the last five years in the UK and Europe involving private pilots with an IR than those with an IMC rating. That would suggest that however you cut it IMCr holders do a much better job of managing the risks than pilots with an IR.

The very best test we have in aviation of almost anything is the test of time. Theilert engines were happily certified by EASA – time proved they were rubbish.

The IMC rating has stood the test of time.

Some say the training is inadequate to enable pilots to safely fly approaches in IMC. Some say IMC holders rarely fly approaches in IMC.

Fact: There has never been an accident involving a pilot flying an approach in IMC. That would suggest either IMC holders never fly approaches in IMC – which I know not to be true if only because I have over 100 approaches in my log book in IMC of which a reasonable number were to minima, or that as a population they manage the risk better than pilots with an IR.

Fact. Since the introduction of the IMC rating the training of pilots has improved significantly, aircraft have become more reliable and better equipped. That would suggest it is easier to do a good job in IMC these days than it was say twenty years ago.

So let’s see – we have developed over time a rating that has proved to be VERY safe, popular and clearly that meets the requirements of most private pilots in the UK, given that those who want to fly airways have always had the option of an IR.

There is another long standing life rule: if it isn’t broken, don’t fix it. The only reason we are fixing the IMC rating is political. There IS no evidence it is UNSAFE. More importantly, of the various proposals that have been discussed there is no evidence that ANY of these proposals are safe. Where are the studies? Where are the regulatory impact assessments?

What may or may not be politically acceptable is one thing – but don’t kid yourself there is anything “wrong” with the IMC rating it has stood the best test we have. Be in no doubt none of the proposals on the table have been tested – in fact I am not aware there has been any quantitative study of any of the alternatives in European air space.

[Brendan Navigator]

The big two problems with this issue are that;

a) Many supporters of the UK IMC rating are ignoring the fact that if other countries thought it was a good idea or that it would make operations safer then they would have established a similar national rating a long time ago.

b) Very few people seem to have read and understood the proposal.
the proposal is not for a rating that will enable the pilot to climb through IMC to operate VFR on top. The purpose of the rating is to permit legal IFR flight enroute. i.e. VFR departure, IFR IMC enroute and VFR arrival.
The pilot with the EIR can be IFR IMC for hours on end - enroute.

Let me provide a little quote from the German AIP ENR 1.1

VFR Flights Above Cloud Layers

VFR flights above cloud layers are only permitted if

1. the flight is conducted at a height of at least 300 m (1000 ft)
above ground or water and flight visibility as well as distance
from clouds (§ 28 para 1) according to the values for Airspace
Class E (Attachment 5) are maintained;

2. the pilot is able to adhere to the intended route;

3. the approach to the destination aerodrome and the landing in
flight conditions in which VFR flights are permitted are guaranteed;

4. the pilot is licensed to conduct air-ground communication.
This is a well established procedure and it is entirely reasonable that a flight that will be counducted enroute in or above IMC would have the same requirements with regard the destination weather.

I have visited 3 flying schools in the UK who offer IMC Rating courses. In all 3 cases the aircraft were not certified for IFR flight. The answer was "we do the whole course VFR in VMC and thus avoid the requirement for FM immune radios". Most of the work they do is outside controlled airspace.

Most pilots completing the course do so to obtain the normal JAR-FCL PPL privileges i.e. VFR flight out of sight of the surface etc.

The opinion of the IR as being "Gold Plated" is a mindset unique to the UK.
Could the reasons for this be partly in the perception that it is for commercial pilots or that it is a weeding out of pilots going the commercial route or that it can't be done part time?
The CAA has a lot to answer for in this regard and has only managed to get away thus far with such absurd restrictions because of the availability of the IMC rating.

Don't forget that EASA will remove the unique UK system of handing out a PPL and then limiting the privileges. Thus much of the IMC training business will be removed because it is no oonger required.

I also visited some UK FTO's offering training for the IR. They were not interested in part time training. Some even incorrectly told me that it was not possible. All they are interested in is running a full time course because a) people are willing to do it and b) it makes it easier for the school.

The ability to do the PPL exams with your local club which is different to every other country puts PPLs in the mindset that having to adhere to an exam timetable and go to a central examination centre is operessive.
Who said that that UK system will survive EASA?

Elsewhere in Europe, part time IR training is very common. If one can take the time to do 60 odd hours VFR to get a PPL in one's spare time then having to do 40 hours in a sim (any weather any time) and 15 hours in an aircraft - not limited to VMC would be an easier prospect would it not?

Then the exams - Two pilots want to fly IFR from Amsterdam to Madrid. Are those pilots not entitled to expect that the other pilot they share the system with will have both the knowldge and skill to not just safely operate in the system but also to - as the German AIP puts it -

Each participant in air traffic shall act to guarantee that the
safety and order of air traffic are guaranteed and no other person is
endangered, injured or hampered, or bothered more than necessary
according to the circumstances.

Finally can those that want to keep the IMC as a national "opt out" please remember why JAR-FCL has not worked in terms of harmonisation and why the EU asked EASA to sort it out - i.e. properly harmonise. EASA may have tried to re-invent the wheel and has laterly decided that the timescale was ambitious but the programme remains the same with the exception that JAR-FCL will be the initial text until that is later changed into what has been proposed.

How can it be a " common market" is part of the market is not available to the majority of producers?

So forget trying to save a rating that the majority of the citizens don't want. Work to get the most out of a new rating that will increase the privileges of the majority of the citizens.

It would be quite ironic if the UK got to keep their IMC rating and the rest of Europe went the EIR way. French pilots happily cruising accross the top of Heathrow in the Airway at FL100 lapping up the sunshine while their UK friends scramble round at 2400ft in the weeds with all those "I may be in a cloud but I am VFR" pilots!!!!!

[IO540]

You make some good points, Brendan Navigator, but a number I disagree with.

if other countries thought it was a good idea or that it would make operations safer then they would have established a similar national rating a long time ago.That doesn't follow. If you flew "GA" around Europe a bit (as I have done) then you would quickly see that there is a lot of GA in the UK, Germany, France (though very little "touring") and then it gets very thin, with most of Europe having virtually no GA other than a very low microlight type of "sports" activity. By the time you get down to Greece (which, due to geography, would benefit hugely from GA) you are looking at 100-200 planes in the whole country.

So most European CAAs have close to zero interest in doing anything for their GA population. Many here accuse the UK CAA of not understanding GA (a view I don't think is correct) but the officials I've met from some foreign CAAs are on a different planet completely.

Germany would seem to be an exception but Germans are a conformist people and if you need an IR for something then a German will go and do it because the Govt says so. Well, to the extent that it remains practical, which is why the IR takeup over there is pretty small too.

France, as I said, does very little European touring. The reason I've been given by French and other pilots who don't have English as their 1st language, is that they are reluctant to leave their own country due to language issues. And indeed the touring pilots I have met while abroad have been mostly from countries which are either the UK or ones where English is spoken well (Germany, Belgium, Netherlands, Sweden, etc but not the more southern ones).

So the pressure is not there for any action. Hence the lack of support among most European CAAs which are packed with elitist ex ATP and ex military people.

3. the approach to the destination aerodrome and the landing in
flight conditions in which VFR flights are permitted are guaranteed;Obviously this is a prerequisite for any VFR flight above an overcast (for a non-instrument licensed pilot) but I would like to know how [even] the Germans can guarantee the weather :)
Most pilots completing the course do so to obtain the normal JAR-FCL PPL privileges i.e. VFR flight out of sight of the surface etc.I'd like to see the case study data which found the above. IMHO, most IMCR holders don't even know that it enables them to do that - hence the interminable forum threads on this very topic, over the years.

I think most people who do the IMCR do it genuinely for flying in IMC if necessary, and to fly approaches, etc, but they don't know (at the time) that the product is effectively being mis-sold: most being renters, they are unable to get their hands on a suitably equipped plane. But an awful lot of "products" are being mis-sold; I'd argue the whole PPL is being "mis-sold" because if you were totally up front about the utility of a standard PPL, most punters would walk away.

It would be quite ironic if the UK got to keep their IMC rating and the rest of Europe went the EIR way. French pilots happily cruising accross the top of Heathrow in the Airway at FL100 lapping up the sunshine while their UK friends scramble round at 2400ft in the weeds with all those "I may be in a cloud but I am VFR" pilots!!!!!

That would be hilarious. But I don't think it will quite work that way, to/from the UK, given a lot of UK weather.

[mm_flynn]

For one moment let’s examine the evidence, and forget what may or may not be commercially or politically desirable – it isn’t a bad place to start.
Fact: In over forty years there have been almost no accidents involving pilots with an IMC rating in IMC. That would suggest, in what ever way pilots are using the rating, they are doing a remarkably good job of managing the risks.
There are at least 2 in the last 10 years in the UK, which is not dissimilar to IR holders (but with no information available on exposure)



Fact: There have been far more accidents in the last five years in the UK and Europe involving private pilots with an IR than those with an IMC rating. That would suggest that however you cut it IMCr holders do a much better job of managing the risks than pilots with an IR.

This is false for the UK.

One would hope there are no accidents involving IMCr pilots flying in IMC outside the UK!

However, there is definitely an issue with instrument flight outside the UK. A number of incidents CFIT in mountainous areas have involved IR rated pilots based in the UK (and also the low countries).

The whole approach to IMCr flying in England benefits hugely from the country being flat and is another reason its applicability to much of Europe is limited.

[IO540]

The whole approach to IMCr flying in England benefits hugely from the country being flat and is another reason its applicability to much of Europe is limited.

Not only that but it fits well with the lack of IFR enroute service outside Class A, which in turn fits well with the privatised ATC :)

In most of Europe, an "IMCR" would be equivalent to a full IR. For example in France one could fly up to FL200 or so, nearly everywhere. The only place with a lot of Class A is Italy.

[Fuji Abound]

There are at least 2 in the last 10 years in the UK, which is not dissimilar to IR holders


Not according to the CAA - maybe they got it wrong! I have heard just this suggestion but have yet to have anyone point me in the direction of the accident report. Again fact or fiction? However, whether it is noen, one or two a remarkable safety record.


This is false for the UK.


Which is why I did not say for the UK.

It is also worth considering how many pilots have an IMC rating in the UK and how many PPLs have an IR. Now there is an interesting statistic particularly for those who want to debate the relative safety record of each population.


The whole approach to IMCr flying in England benefits hugely from the country being flat


You got to be joking! Are you sure that really is a rational point.


Many supporters of the UK IMC rating are ignoring the fact that if other countries thought it was a good idea or that it would make operations safer then they would have established a similar national rating a long time ago.



In the US well over half the private pilot population have an IR -an IR that is relevant to private operations. There is an excelelnt safety case for their approach and yet not a single European country has adopted a US style IR. Perhaps that best demonstrates the folly in your argument.


The opinion of the IR as being "Gold Plated" is a mindset unique to the UK.



Sorry, utter rubbish. Why do you think nearly everyone in Europe is flying on the N reg?


Two pilots want to fly IFR from Amsterdam to Madrid. Are those pilots not entitled to expect that the other pilot they share the system with will have both the knowldge and skill to not just safely operate in the system but also to - as the German AIP puts it -



Again this is just scare mungering. There is no evidence that IMCr holders have not operated safely in the same enviroment as IR holders. More to the point you had better mention this to the French with their Brevet de Bas - taken to your logical conclusion do I want to operate in the same air space as pilots who dont even have a PPL, or do I want to fly in the same airspace as NPPLs. If you take your argument there is no difference - they each have a lesser qualification in your eyes. Next you will be saying you dont want to be in the same enviroment as FAA IRs because their theoretical exams are less "gold plated" you had better let AA know.

So forget trying to save a rating that the majority of the citizens don't want

.. .. .. and your evidence for that spectacular assertion?

[englishal]

This argument will be solved in a few years I am sure, but from my own point of view this is what I would like.....

If the ONLY choice was an IMC or EIR then I'd opt for the EIR - it'd give me access to the airways into Europe & UK, even on gin clear days.

A slightly better option would be for the EIR to be adopted and the UK to have a difference allowing current IMC privileges in the UK (i.e approaches into Class D)...though this is unlikely and probably unworkable as this would be the same privileges as the full IR in UK airspace.

Ideally the EIR would include a precision approach capability - that would suit me perfectly, I'm not too worried about shooting NPA's in bad weather, I'd either file to an ILS or "guarantee" the weather is VFR at destination.

I can see a whole host of problems with the EIR though - not least ATC responsibilities. How does one "guarantee" VFR conditions at destination, and what happens if it is not? How does this fit in with EuroATC and what is their responsibilities in this situation?

The UK has a lot of experience with PPL's flying IFR - much more than the rest of Euroland. One thing that both the US and UK realised a long time ago was that keeping private pilots away from Instruments had a detremental effect to air safety - part of the reason the FAA removed many of the IR training requirements many years ago and the CAA introduced the IMCr.

It does pi55 me off that there are two very good systems (CAA/FAA) which have been around many years yet Eurocrats just don't seem to want to listen to the advice and experience of these bodies, and insist yet again of re-inventing the wheel to a Eurostandard.

we shall see what happens....

[Fuji Abound]

Englishal

Sanguine and sound as usual.

We shall indeed see - but we must be prepared for a "fight" if necessary.

It is all too easy to give away hard won priviliges, by simply doing nothing. :)

[IO540]

Wait and see what hits the fan c. 2012 when the IMCR "gets" abolished.

Currently, the issue is not really hot. A lot of pilot forum bandwidth but maybe 2/10. In 2012 (or delayed as EASA FCL is likely to be, on current trends) it will be 10/10.

Abolition of the IMCR will be unworkable anyway, because everybody flying IFR in Class G will carry on doing so, with the only difference being that they won't be able to openly ask for an IAP so they will be arriving "VFR". Or maybe not even that, because the IMCR has been around for so long, and intra-UK flights have been done at sub-Eurocontrol levels by IRs/IMCRs for so long, that UK approach controllers have decades ago stopped wondering whether the pilot is IR or IMCR, and somebody asking for the IAP will just be assumed to be an IR. And it gets better: since a plain PPL can fly IFR in VMC, and since his actual flight conditions will be known only to him, provided he is visual by the time anybody can spot him (usually the case) no action will be possible.

[Fuji Abound]

IFR to me is a full BRNAV airways capable machine.


Bose

What is your definition of fully BRNAV capable?

[englishal]

we must be prepared for a "fight" if necessary.
I agree.

I also like to think the by posting on Pprune the strength of feeling gets across to the CAA as I believe that they do monitor these discussion boards. (so best not incriminate oneself or post videos of yourself flying under the Forth Road Bridge ;))

Hello CAA :ok:

[Justiciar]

I cannot escape the feeling that in a few years this will be looked back on as being something of a non issue for UK pilots. There seems zero chance of the IMCR surviving into the brave new world of EASA FCL as other countries in Europe simply will not accept it. On the other hand, the up side may be en route IFR privileges and increased (for the UK) PPL minima.

GA is changing, probably 40 years too late, but it is changing. As the old C150/PA28 fleet is finally dumped by FTOs their replacement is in most cases likely to be new generation aircraft either fully certified or, more likely, certified to LSA/VLA standards, which will have a (slightly) more relaxed maintenance regime and will allow for PPL training but which will not be equipped for full IFR. Many more people post PPL will I believe go for Permit aircraft (there is a lot of evidence of this happening already). In this new world there is likely to be very little scope or demand for the fully certified IFR equipped aircraft.

None of this of course needs to prevent post PPL training for IMC flying as training aimed at enhancing pilot skills and safety. In fact, this could be insurance driven and perhaps the likes of the LAA or IOPA should give consideration to an suitable training syllabus and certificate rather like the AOPA aerobatics certificate (an aerial version of pass plus!) which could reduce the insurance premium. It does seem too much of the debate focuses on loss of privileges (used to their full extent by a minority, I suspect) and not enough of the inherent value in undergoing this sort of training.

[Captain Stable]

I would accept the principle of the EIR if, and only if, there was the option to add on subratings for different types of approach - PIR (either SRA or PAR). ILS, NDB, or even GPS. But the requirement for "virtually certain" VMC for the destination is ridiculous.

The extra training for an IMC is, IMHO, excellent discipline for the PPL who wants to improve his abilities, whether or not he actually uses the privileges associated with the rating. The UK IR is out of reach of most PPL holders and is really only of use (indeed, effectively essential) to a holder of a commercial licence (CPL or ATPL).

[englishal]

In this new world their is likely to be very little scope or demand for the fully certified IFR equipped aircraft.
Although it is not inconceivable that "Permit" aeroplanes may be allowed to fly IFR in the relaively near future...something that they do in the USA now.

[Justiciar]

Although it is not inconceivable that "Permit" aeroplanes may be allowed to fly IFR in the relaively near future

The words "snowflake" and "hell" come to mind :hmm:

Is anyone aware of any such proposal in Europe?

[englishal]

I've heard rumours of it from people who know more about it than me.....Someone suggested that within the next 3-4 years it may be a real possibility. But that is all, just rumours.

[BackPacker]

Justicair, subject to having the proper/required equipment installed & operational, and FM immunization as required, why would a Permit aircraft be less suitable for IFR operations than a CofA aircraft?

Arguably a lot of modern Permit aircraft (homebuilts with glass cockpits, dual nav/com, GPS and slaved autopilot for instance) are easier to fly IFR, including airways, than a lot of CofA/IFR certified 1960s spamcans.

Something else. Is anyone aware of any proposal/solution to the problem that if the IMC really goes away, that it is possible to lift the PPL "in sight surface" restriction without gaining an IR? Would be nice if that restriction could be lifted after suitable instruction & and endorsement from an instructor for instance.

[IO540]

Anything is possible if you go sub-ICAO. But IFR certification still requires technical compliance e.g. the ability to deal with static, and to withstand lightning strikes, and most "plastic planes" can't.

[BackPacker]

and to withstand lightning strikes, and most "plastic planes" can't.

Well, if Cirrus and Diamond can get their plastic aircraft certified for IFR, why not Europa and a few others?

Furthermore, not all Permit aircraft are plastic. Vans, Glasair and a few others all use traditional riveted aluminium.

[dublinpilot]

I would accept the principle of the EIR if, and only if, there was the option to add on subratings for different types of approach - PIR (either SRA or PAR). ILS, NDB, or even GPS. But the requirement for "virtually certain" VMC for the destination is ridiculous.


I agree. The "Virtually certain" VMC is a serious problem for someone not qualifed and trained to fly an approach in IMC. What happens if you're flying along in IMC (or above it for that matter), and see a falling oil pressure, and increasing temperature? You desent to MSA and are still in IMC. Do you 'have a go' an a proceedure that you're not trained for and not qualifed to do, or do you continue to your destination, knowing that the weather is ok there, but not sure if you're engine will survive that long?

Things happen, and you need an escape route when they do. Without the ability to fly an approach, you don't have an escape route with an EIR as proposed.

[IO540]

There's the answer then :)

It can be done but perhaps not in 600kg MTOW and for 10 quid? An SR22 costs, how much?

There is no technical reason why a metal plane cannot be IFR certified - once you have driven a coach and horses through the ICAO requirements, like TSOd avionics, etc. We live in a very old regulatory climate, worked out decades ago, and while things are changing, nobody can guess just how much of the old stuff is going to get discarded.

My guess is that, looking at how utterly anally retentive EASA is over certification (e.g. disregarding FAA AML STCs), that this is not going to happen, ever - unless EASA gets shut down totally.

You know and I know that it is perfectly possible to fly IFR/airways with a Garmin 496 handheld. It's just illegal. There is a vast raft of regs concerning equipment carriage, equipment certification, airframe certification, you name it, and all of this would have to be set aside. Yet some kind of framework would have to remain in place, otherwise why should anybody else bother?

The USA manages to combine the two, but AIUI they prevent any CofA plane to go Experimental - a bit like the CAA prevents a CofA plane to go on a Permit (generally). And this keeps the non-CofA scene restricted.

EASA is a fantastic gravy train for all kinds of old farts (many ex UK) who just love paperwork, and organisations like that have the greatest staying power, defeating all attempts at reform from above.

So, I have no idea which way it's going to go but would not hold my breadth for any interesting developments.

As regards being stripped of privileges, I think most people feel strongly about it because they have worked so hard for what they have. I have a CPL/IR (FAA) which took me ages to fit into my life, and while in theory every place I've been to could be reached on a VFR flight, I would hate to have to do all the dodgy VFR stuff again, flying above the Alps at FL129 because the Swiss won't allow me into their Class C (Class C being perfect for VFR, according to ICAO) whose base is FL130, with the terrain being about FL115... despite this airspace being devoid of any traffic.

The IMCR is a fantastic privilege. The other day I flew to Southend and back, 3400ft, solid IMC both ways, down the ILS, NDB/DME, etc.

[BEagle]

IO540, out of curiosity, what were the forecast and actual cloudbases on the day you flew to Sahf'en?

I see that Garmin have just brought out the 'aera' touch-screen portable GPS which is only slightly larger than their well-known 'nuvi' car systems. In fact it is a dual-mode automotive / aviation system. But it's 'VFR only'.....

The regulators will have to accept that people will use such systems in IMC outside CAS as they cost about 10% of the price needed to buy a panel mounted GPS/COM such as the 430 - and for the latter there are all the 'approval fees' and installation costs to include.

[Fuji Abound]

To be fair there is a good reason for tighter regulation of airways traffic.

As reliable as a Garmin 496 may be having some dodgy CPL on a foreign licence operating in the airways relying on kit that may run out of battery power at any moment is clearly not fair on the other users of the air space or the ATCs trying to regulate orderly conduct.

I recall being low level returning from Germany with my trusty Garmin 195 that had never let me down. Well it was just the moment when the LCD decided to pack up (nothing wrong with the rest of the unit, but not a lot of good when you can hardly read the display). I had little interest in navigating from one VOR to the next and any way the weather was cr**. The controllers were wonderfully helpful in assisting me staying on track but I was well aware I was taking up their time. I don’t think it mattered as I was outside CAS and the airspace was very quite but something we could all do without in CAS.

[BackPacker]

I agree about the "UK old farts" although I think that part of their attitude is legit - they represent, to a part, the massive interests of the commercial aviation scene - not an insignificant part of the GNP of your average country. So anything that's being proposed on the PPL/IR front, including possible IFR "certification" of Permit aircraft, should be acceptable to them. Which in practice is going to mean: is going to guarantee not to impact their commercial operations.

As for FCL, I think that to make an "IR-light" acceptable to those interests, means getting guarantees that we're not sharing the same airspace, as far as possible, as CAT. If that means putting an altitude restriction in an IR-light so that we're guaranteed to be clear of most CAT in cruising altitudes, fine. As far as I'm concerned, FL100 or thereabouts would do the trick but if we're to satisfy the very few PPL/IR-light holders that have oxygen/pressurization, maybe FL210 would work too. That would guarantee the Boeing and Airbus drivers that we would not be bothering them during the cruise. And a sensible altitude limit (maybe coupled with a speed limit) to an IR-light would also mean less theory requirements - high altitude cruise, coffin corner, mach effects, RVSM, oxygen/pressurization systems, high-altitude weather to name a few. Heck, if you limit an IR-light to SEP/MEP only you can also forget about turbine engines and a few other things. And I even would not mind that IR to be limited to PPL privileges only (private flight), to protect the present commercial training industry.

As for aircraft certification, well, we currently have a whole "Permit" structure which allows basically uncertified aircraft to fly (VFR) and their safety record is impressive. Despite this, they're limited to non-commercial ops. If those aircraft would be allowed to fly IFR (assuming certain equipment is in place), they would still be restricted to non-commercial ops, so the airline industry would not see this as competition.

Oh, well, one can only dream...:zzz:

[IO540]

what were the forecast and actual cloudbases on the day you flew to Sahf'en?About BKN/OVC007, IIRC. At both ends of the trip, it was not doable VFR except as an all-out scud run, probably busting the 500ft rule.

The regulators will have to accept that people will use such systems in IMC outside CAS They don't have to "accept" anything because such flight is pretty well unregulated. In the UK, IFR without an IFR clearance it is actually legal :) In fact, IFR in Glass G is not capable of receiving a clearance; IIRC the FAA has busted pilots doing that not for not having a clearance but for not having filed an IFR flight plan.

I have always thought that the pilots of the "IFR-equipped" "sports" planes probably do fly in IMC quite readily. I certainly would too. But not if the thing was unsafe, not e.g. having static precautions.

I think that part of their attitude is legit - they represent, to a part, the massive interests of the commercial aviation sceneThe interests of the avionics shops, I think... EASA acceptance of FAA certification would wipe out a whole load of business.

If that means putting an altitude restriction in an IR-light so that we're guaranteed to be clear of most CAT in cruising altitudes, fine. As far as I'm concerned, FL100 or thereabouts would do the trick but if we're to satisfy the very few PPL/IR-light holders that have oxygen/pressurization, maybe FL210 would work too. That would guarantee the Boeing and Airbus drivers that we would not be bothering them during the cruise. And a sensible altitude limit (maybe coupled with a speed limit) to an IR-light would also mean less theory requirements - high altitude cruise, coffin corner, mach effects, RVSM, oxygen/pressurization systems, high-altitude weather to name a few. Heck, if you limit an IR-light to SEP/MEP only you can also forget about turbine engines and a few other things. And I even would not mind that IR to be limited to PPL privileges only (private flight), to protect the present commercial training industry.

I'd be careful what you wish for. An IR limited to FL100 was actually proposed, allegedly by IAOPA or something like that, and caused a bit of an uproar. It would be as useful as a chocolate teapot, when one looks at not only European terrain (airway MEAs) but also Eurocontrol routings, and then where the clouds lie... A FL100 ceiling would put me in IMC, below 0C, on most flights.

A FL250 ceiling would be more reasonable, because that represents the bottom of where commercial traffic actually flies enroute. Anyway, RVSM comes in about FL270/290 or so and that introduces a huge cost barrier anyway.

Oxygen can be bought for a few hundred quid for a portable kit, so that is a non-issue.

[Justiciar]

Justicair, subject to having the proper/required equipment installed & operational, and FM immunization as required, why would a Permit aircraft be less suitable for IFR operations than a CofA aircraft?

Arguably a lot of modern Permit aircraft (homebuilts with glass cockpits, dual nav/com, GPS and slaved autopilot for instance) are easier to fly IFR, including airways, than a lot of CofA/IFR certified 1960s spamcans.

I wouldn't disagree with any of this, but as IO points out, we have a regulatory system in Europe which derives from ICAO and which in turn is a reflection of the standards of 50 years ago, when equipment was much more basic and more unreliable than it is today. Modern electronics and engineering designs and tolerences make for my more reliable aircraft and the kit that goes in them. However, we are stuck with the present regulations and attitudes for the forseeable future, which in the case of the UK mandates things like DME and ADF in a certified as opposed to Permit aircraft in order to legally fly IFR. This equates currently to expensive but outdated equipment with a paper trail.

The issue here is not that modenr equipment can do the job, it is whether legally it is allowed to.

Something else. Is anyone aware of any proposal/solution to the problem that if the IMC really goes away, that it is possible to lift the PPL "in sight surface" restriction without gaining an IR? Would be nice if that restriction could be lifted after suitable instruction & and endorsement from an instructor for instance.

This goes to VFR minima, and out of sight of the surface above 3000' is exactly what an IMCR allows currently(in class G), in effect VFR on top. My understanding is that the EASA privileges of the proposed EASA PPL will allow this (but I cannot remember where I read this!). The minima for VFR are set by the country whose air space you are flying through (subject to any greater restriction on the licence held) which is why French PPLs can fly VFR on top but a Uk pilot in Frence air space cannot, because his privileges are restricted by the ANO. EASA will do away with this restriction for VFR as I understand it. The EIR suggests allowing en route IFR flying. I am not clear what the real benefit of this will be as few people would want to fly IMC for extended periods en route so en route IFR is not much better than VFR on top. Does any of this make sense :confused:

[Fuji Abound]

I think in EASA land it is their very concept that national license differences will no longer exist - so whatever does or doesnt happen with the EIR or IMCr PPLs will be entitled to fly out of sight of the surface but clear of cloud just as they can do on pretty much any ICAO PPL any where in the world.

RVSM is FL290 I think which if you were going to place such a restriction on a PPL IRLite is as good as any.

[IO540]

I am not clear what the real benefit of this will be as few people would want to fly IMC for extended periods en route so en route IFR is not much better than VFR on topEnroute IFR means you could fly IFR enroute :) which means

- you can fly above the weather (in Europe, stratus cloud tops are rarely above FL160, so a decent IFR tourer can stay in VMC on the whole route)

- you have an implicit clearance all the way (under VFR, because of controlled airspace, through which one often does not get a transit, this cannot usually be done)

- ease of route planning (basically you can forget all about airspace classes - except at the ends which is a different thing....)

But one could make the earth shattering observation that if every country operated its airspace according to ICAO classifications (meaning VFR is allowed everywhere except Class A) then the "enroute IFR" would indeed be very close to VFR !!!

This really shows up the utter anal retentivity in this business. Two pilots, flying the same route (composed wholly of IFR waypoints), same altitudes, in the same plane, with the same equipment. One flying IFR, and ATC eases his passage (so to speak) all the way. The other flying VFR (because he hasn't got the magic piece of "IR" paper certifying he passed through the school separating the men from the mountain goats), and he has to ask for ATC clearance at every piece of CAS, and this can be denied at any time, without giving a reason.

[englishal]

The issue here is not that modenr equipment can do the job, it is whether legally it is allowed to.
Ah that is the crux. But again there is a wealth of data available from the USA where "experiemental" aircraft have been IFR certified for years. ou could buy an RV9 with all singing all dancing G530W and fly GPS approaches until the cows come home if you want. So I don't see really why euro regulators in their sweeping changes of Euroland don't phone the FAA and have a quick word with them, then change the rules to allow anyone with a funky homebuilt with suitable avionics to fly IFR - after all an experiemental aeroplane (or permit in our land) is just that - "at your own risk".

I'm sure there must be some stats out there saying how many have suffered in flight breakups due to being struck by lightning (or not).
I'd personally feel pretty happy flying an RV with 430/530 combo, backup AI, and glass screen to my villa in Spain for the weekend in IFR conditions....

(assuming I had a Villa and an RV of course ;))

[mm_flynn]

This goes to VFR minima, and out of sight of the surface above 3000' is exactly what an IMCR allows currently(in class G), in effect VFR on top. My understanding is that the EASA privileges of the proposed EASA PPL will allow this (but I cannot remember where I read this!). The minima for VFR are set by the country whose air space you are flying through (subject to any greater restriction on the licence held) which is why French PPLs can fly VFR on top but a Uk pilot in French air space cannot, because his privileges are restricted by the ANO. EASA will do away with this restriction for VFR as I understand it. The EIR suggests allowing en route IFR flying. I am not clear what the real benefit of this will be as few people would want to fly IMC for extended periods en route so en route IFR is not much better than VFR on top. Does any of this make sense :confused:
PPLs in most of the world do not have the 'out of sight of surface restriction' so all of the worries about what does an EIR pilot do in an emergency are quite similar to what a PPL does who is flying above an undercast.

My understanding of the EASA licencing is that PPLs who were originally certified by the CAA will just have this restriction lifted (because they are transferring to an EASA licence) so that is an upside. (It also should address the OTT limitation on SVFR for UK PPLs)

The major advantages of an EIR vs VFR on top, are
1 - It is legal to move up/down through a layer (which is a reasonably common situation)
2 - You are IFR and able to be in controlled airspace (remember E is controlled for IFR) so no longer neeed visibility and cloud separation minima (which UK pilots don't seem to recognise as part of the requirements to be VMC above 3000 ft). Once again it is very common to be in a situation where flying is quite easy from an orrientation and navigation perspective but maintaining 1000 ft vertical and 1500 meters horizontal (i.e. clouds 3 kms apart) is a pain.
3 - Most people are not going to fly enroute IMC for an extended period by hand, but the EIR, like the IR would allow you to couple the autopilot to the gps, receive a radar control service and make a long IMC enroute transit throughout Europe in a much lower stress environment than operating under a 1500 ft overcast over a long distance.


I of course recognise that not having an approach capability is a limitation and may well be a sufficient reason for the European pilot population to reject the rating in favour of retaining their current binary world of PPL only or PPL/IR. Without some approach capability it is also not a replacement for the IMCr, but I don't think it was ever supposed to be such a replacement.

[BEagle]

Q. What were the forecast and actual cloudbases on the day you flew to Sahf'en?

A. About BKN/OVC007, IIRC. At both ends of the trip, it was not doable VFR except as an all-out scud run, probably busting the 500ft rule.

And that's EXACTLY what the UK IMCR is all about. Preventing unnecessary scud-running whilst allowing you to make an approach to reasonable limits - albeit more restrictive than those applicable to IR holders with their far greater theoretical knowledge, training and testing requirements.

A sound British compromise!

[Justiciar]

you can fly above the weather (in Europe, stratus cloud tops are rarely above FL160, so a decent IFR tourer can stay in VMC on the whole route)

We are back to the aircraft and equipment issue. What you describe is Ok for someone holding a full IR, but this debate really centres on the more limited privileges of the yet to be confirmed EIR or IR light (call it what you will). Even if EASA licensed Permit aircraft tomorrow for IFR the reduced payload of most such aircraft coupled with limited equipment (no de ice, oxygen etc) severely limits the possibility of extended IFR flight, whether in IMC or VMC.

couple the autopilot to the gps

Again - any gps to any autopilot? Or, a certified installed GPS to a certified installed autopilot in a certified aircraft?? This is a real issue for most pilots who might want to fly IFR. Of course, to use an IMCR (or an IR for that matter) in anger often requires a suitable instrument approach at destination. Given the cost of using any airfield big enough to have an ILS or even an NDB approach (most of these airfields now seem to have "international" in their names :ugh:) in terms of landing fees and mandatory handling the options are further limited.

Simply in terms of numbers flying relaxing the VFR minima for PPLs will overall have a far more beneficial effect on aviation as a whole than an EIR which in practice I suspect will be used by fewer and fewer people.

[IO540]

De-ice and oxygen are not an issue. Many IR holders fly IFR without de-ice (I have only prop de-ice myself), and portable oxygen kits are very cheap and easy to use (it's what I have).

The major IFR technical capability issues that I see are

- operating ceiling (FL160 is really handy; FL180 significantly better, and a big increment on that doesn't come easily) - otherwise you'd better have some good de-ice kit :)

- navigation (an IFR GPS with a reasonably current database is a must, because IFR airspace is treated by ATC as totally-RNAV) with a reasonably rapid selection of DCT etc waypoints, and a moving map for situational awareness

- the ability to fly any instrument procedure (approaches and holds)

- the ability to climb and descend at least 500fpm within terminal areas, say to FL080

- obviously, the ability to fly in IMC, with all radio equipment fully working - this means efficient dissipation of static charge from all parts of the airframe

- the ability to read (so one can read the approach plates etc :) )

- an autopilot, while not a must, reduces cockpit workload by perhaps 90%, so go figure...

[mm_flynn]

...this debate really centres on the more limited privileges of the yet to be confirmed EIR or IR light (call it what you will).
The debate originally centred on the contention that the EIR was a chocolate tea pot concept of no use to man nor beast and that it was not a suitable replacement for the UK IMCr.


I don't believe it was ever intended as a replacement for the IMCr
It would be of some value to some IMCr holders as a backstop if the AOPA UK effort to carve out a life for the IMCr in the UK fails
It was never intended to address the question of IFR in permit aircraft or IFR privileges for sub-ICAO licences
It seeks to provide a stepping stone to a full IR (one of the many arguments put forward in support of the IMCr)
It tries to upgrade the utility of GA outside the UK and to make legal some of the typical Continental flying of UK pilots (and others)
It is designed to be of benefit to European pilots, not just focused on UK pilots flying in the UK.
It was put forward in the context of a rational IR (competency based with relevant and proportionate theoretical knowledge requirements)

It tries to achieve these objectives while,

recognising a desired principle that licences shouldn't have airspace limitations.
not opening a 'Professional'/'Hobby' divide on flying privileges
not creating opportunities to limit the utility of a full IR in light aircraft/single crew operations through artificial speed, altitude, gross weight, etc. limitations

[englishal]

I think people get too hung up on what is capable of IFR flight or not. I have flown a fair share of ropey old SEP's IFR - one VOR'd/GS olds C172s nogps for example. Not something I'd choose to do for 500 miles mind, but for an hour, no problem.

But if the EIR had the ability to fly a precision IAP then it would open up huge opportunities. For example one could go to Jersey for the weekend and not worry (so much) about coming back on Sunday. Even though we don't have an IAP at home, I could file to say Exeter or Bournemouth, and I can always get home from there by car- of from there I'd be prepared to nip home at 1000' - not something I'd choose to do across the channel. One could almost do this now with an IMCr but you may be limited in altitude, not be under positive control, and may have to scud run to Ortac.

So I can definitely see the benefits of the EIR but just wish it included at least a precision approach capability.

[Pace]

Reading all this I sometimes wonder whether we are not all loosing the big picture amongst all the detail and that includes the people putting the whole thing together.

There are many very competant IMCR holders and equally many who are not.

Instead of saying that a pilot has to follow a set course to an IR why not give the holders of a current IMCR two options?
They can either work through a stipulated IR course if they dont feel they are up to scratch or alternatively? If the pilot feels he is mustard the right to present themselves to a training establishment for a test.

If in the opinion of the school the pilot is up to the standard to pass a proper IR flight test they can be signed off to take that test.

The point of this is either a IMCR pilot is up to a standard to pass or not.
The proof of the pudding being in the eating and if passed for an IR by an IR examiner then the IMCR pilot should be issued with an PPL/IR

As to the exams a very cut down version directed at PPL requirements should do.

If the pilot then wants to in the future he can simply add the other ground exams to get a full IR directed at commercial use.

Pace

[Fuji Abound]

I don't believe it was ever intended as a replacement for the IMCr


I dont know how you reach that conclusion. If you believe Europe has always been happy with the IR and VFR on top priviliges why would they want an EIR. Moreover the protagonist of the EIR is Jim Thorpe - he is from the UK school and presumably he thought the EIR was a way of placating his brethern. I know he claims otherwise, but I take that with a pinch of salt.

Why this obsession with believing the EIR will be more acceptable in Europe - after all it is releasing "amateurs" into the same airspace as that used by CAT but with the implied protection of the amateurs having to be visual before they commence their final approach. The fact of the matter is few private pilots want to go into airports out of which CAT is operating to any great degree and, in any event, what evidence is there that with "only" an EIR rating they are more likely to suffer an accident during the approach phase.

It is all very well to dream up these ideas on the back of an envelope but where is the evidence? In banning approaches, but permitting en route IMC, who are you protecting from who?

Pace

Its a good idea. When I used my IMCr all I wanted was the "right" to take the IR test and not to have to sweat through the exams which I didnt see as relevant given the amount of IFR flying I had already accomplished. As usual were it that simple - but yours is a good idea.

[IO540]

I vaguely recall that a "modular IR" (like the Australian one) which eventually leads to a full ICAO IR, was proposed at one stage inside EASA, and then UK IMCR holders could be logically grandfathered into one of the stages in that, but for some reason it didn't go anywhere. I guess the reason is subtly political but I haven't got a clue what it might be...

If you had an "EIR" but with approaches, it would be a full IR in all but name. Which takes us back to the problem of the political/emotional attachment to the IR, which will always ensure (through airline pilot union veto) that it goes nowhere, if the ground school side of it appears too watered-down.

And if you had an "EIR" but with just precision approaches, you would be looking at almost the same ATC training issues which the EIR will present - because the pilot would be OK with an ILS but would have to divert if the ILS was INOP, etc.

I think a reasonable division would be a full IR but limited say to FL250. That would sidestep any objections to enroute conflicts. Almost anybody above FL250 is flying a turboprop or a jet, which tend to involve type ratings (or equivalent insurance-mandated training if N-reg) so that would take care of objections there.

[Pace]

Its a good idea. When I used my IMCr all I wanted was the "right" to take the IR test and not to have to sweat through the exams which I didnt see as relevant given the amount of IFR flying I had already accomplished. As usual were it that simple - but yours is a good idea.

Fuji

I agree with you to be forced to wade through an expensive training programme is hard to take.

Frankly either you are good enough or your not and a test would soon weed out those who are not especially to IR standard.

If your not you need the training or part of, if you are then why can you not just sit the test after a mock test with a flight school to give you the green light for the real thing.

I always felt we should look at an achievable European PPL /IR rather than a European IMCR but one which allows approaches. For me this IFR on top is a nonsence and one which is courting disaster for a number of reasons.

If they could address the ground exams and make those far easier to get and more practically orientated and then to just give existing IMCR holders the option to bypass the flight training by doing a pre test flight test then that is all we should need, ask for or expect.

The end result a proper European PPL/IR with all the approach privalages and a few shortcuts competant IMCR holders can take.

Pace

[SkyCamMK]

Perhaps by the time the next recession arrives we will lobbying and really trying to rationalise and harmonise standards across the whole world given that we all use the same air and in many cases the same aircraft for the same purposes on the same or similar routes.

If there is one safe standard for IFR lets meet it and if ATPs need to go higher faster and more complicated then add to an IR qual with endorsemnets based on competency testing.

Whatever happens now it will eventually change - let's just hope it evolves in a useful way.

I know, pie in the sky....

[Justiciar]

What is interesting about the debate here is that almost every contributor has their individual ideas as to what any new EIR should allow and what its training requirements should be. It is not difficult to see how any European agency is having such a problem arriving at a consensus! That is besides those who think that it should be business as usual with no change to the IMCR.

Personally, I do not see why a national rating should be incompatible with the new EASA regime, but I get the feeling it is largely a done deal.

[IO540]

A status quo is not unattractive, because it would preserve the FAA / N-reg option on which so much IFR GA (including much high-end GA) runs.

Looking at the political options, a status quo is far from impossible, IMHO.

[Fuji Abound]

Hence my comment earlier that if you have something which works, which has a proven track record and an exceptional safety record you are on very dangerous ground fundamentally changing the parameters particularly when you have no safety case for doing so and, more importantly, not a single study whcih demonstrates the new proposals are better than those they replace.

In any other arena you would be wide open to some very substantial civil claims.

If anything comes of the EIR I shall be very interested to see the RIAs and how the changes are railroaded through unless UK IMCr holders are offered a very attractive carrot.

[Brendan Navigator]

Everyone has to stop thinking in UK terms and start thinking from the perspective of a European licence holder who has never held an IMC rating.

Some points to pick up on;

Dublin pilot - Engine failure in IMC enroute for someone with an EIR or an IR or an IMC rating present exactly the exact same issues. It is an emergency and thus the pilot can legally do whatever they think is necessary. However, should a PPL or an EIR or an IR or an IMC rated pilot be flying in VMC over an extensive fog bank and the single engine fails then they are all faced with having to complete a forced landing in IMC with insturments that are in the process of running down due to lack of suction and limited battery life for the turn coordinator and pitot heat etc

So do you think that a basic PPL flying VFR on top or an EIR holder who at the same place and the same level has the engine problem you describe - which will be better equipped to descend through cloud and track a VOR/NDB and/or follow ATC vectors?

I do not know how people have a problem with the requirement to "guarantee VMC" at the destination.

Perhaps it is a poor choice of words?

However every VFR pilot flies on the basis that they guarantee that they will fly and land in VMC. Is the UK somehow different in this basic safety issue?

People need to have a serious look at what the UK restricts and what is permitted outside the UK (as well as what is permitted both in and outside the UK) before they comment.

For example, someone asked how I would like to share the airspace with "Brevet de Base" pilots from France. Anyone in the UK has a good opportunity of sharing class D E F and G airspace with pilots who are the UK's version of the same i.e. 15 hours limited to a radius from departure etc etc. So different? how?

What about places where to fly IFR you have to hold an IR regardless of weather conditions? Or places where you have to fly IFR at night regardless of conditions?

People must not think of the proposed rating in isolation. Operating rules (Rules of the Air) and other related licensing rules have to be taken into account.

As for "permit to fly aircraft not being certified". That is not quite true. They are certified to a certain standard - CS-VLA, Section S etc but for various reasons are not eligible for the issue of an ICAO C of A. This is often simply down to paperwork, quality assurance and records standards.

That is why the disclaimer says "Not Certified to ICAO Standards" rather than "Not Certified".

Happy flying.

Brendan

[Cows getting bigger]

I must admit I don't have intimate knowledge of FCL.008. However, I have some reservations about part training pilots for IMC flight. If someone is trained to fly en-route IFR (ergo IMC) then there will be occasions where they will need an instrument approach having failed to 'guarantee' VFR (VMC) at destination. Assuming that is the case, I would speculate that any EIR would have to include an element of instrument approach training as part of the syllabus. Either that or there would have to be some pretty outrageous, public transport-type, destination and planned alternate airfield weather requirements defined in relevant legislation. I could not see any regulator signing-off a safety assessment on the understanding that pilots will never go IMC unless they can guarantee VMC at destination.

[IO540]

every VFR pilot flies on the basis that they guarantee that they will fly and land in VMC.Not quite...

A VFR pilot flies without any clearance whatsoever - except a little bit he can pick up from the unit he happens to be talking to. (And if that piece of CAS joins onto another one, then he has a reasonable expectation that he will get a transit through that piece too - except maybe in Italy :) ).

If for whatever reason he cannot proceed (which could be due to weather, but ATC is also totally entitled to wash their hands of him) then he must divert, turn back, or (great stuff, this) do what they call a "precautionary landing".

An IFR pilot, flying a Eurocontrol route (and there is no other way, outside the UK), has an IFR clearance all the way to destination. The "system" cannot just drop him like a hot VFR potato ("remain outside controlled airspace") at any stage. Not in Europe, anyway.

This of course is what makes IFR flight so nice and stress free. ATC works with you (well most of the time :) ) and they have no option; that is their job.

Obviously the regs would specify destination forecasts to be above certain limits, but the ultimate backstop is a mayday followed by an instrument approach - because a landing is not optional.

The only debate I see possible around this area is how often the mayday would occur. In much of southern Europe, not very often.

[Pace]

I do not know how people have a problem with the requirement to "guarantee VMC" at the destination.

Brendon

I flew to France IFR in a twin. Beautiful weather and landed at Pontoise.
My owner businessman went off for a meeting then rang to say he had to fly to Le Havre.

The forecast was good with a front expected moving in from the southwest but later in the early evening.

Pontoise was bathed in glorious sunshine, deep blue sky and endless vis.
I filed VFR for the short hop over to Le havre.

All went well until halfway there when the vis dropped, upper cloud obscured the blue sky and bits of scud floated past beneith.

That soon changed to flying on top of solid with an actual at le Havre of overcast 400 vis 2 k in drizzle.

I requested a change to IFR and landed off an ILS approach.
It does happen take my word for it!

We should push for a European full PPL /IR.

We should push for a far more esely achievable ground exams designed for a PPL /IR and we should push for allowances towards the flight section with even the option to fly a pre flight test exam and if passed a Full IFR flight test.

Pace

[englishal]

If you had an "EIR" but with approaches, it would be a full IR in all but name.
Ah but you could limit it to "non public transport operations". This way the "full IR" skygods could be kept happy as they have done the full IR to fly people around - and rightly these fare paying passengers should have well qualified pilots up front.

You could also limit it to a single approach for example "limited to precision approaches or visual approaches only".

It would certainly give us mere mortals a chance at flying airways / "proper" IFR without the time and expense of a full IR, and achive an IR that many of us would use.

Even better, there could then be upgrade courses to the full IR, upgrade exams, previous instrument time taken into consideration etc.. It would boost UK and Euro flight training a heck of a lot I reckon.

[IO540]

Ah but you could limit it to "non public transport operations".

It's a fair proposal, but there is a very respected school of thought that one must not do anything which the "guardians of the professional IR" could use to push private IR holders into a ghetto.

Once you give them one excuse for saying that the private pilot's competence is any lower than the professional pilot's, the wedge is cast and it could lead to all kinds of undesirable outcomes.

So, the private IR pilot has a strong interest in not making the demonstrated competence any lower.

Which in turn leads to the perpetual difficulty in making the Euro IR more accessible...

[Fuji Abound]

Pace

You have it - I just cant help feeling some of those who contribute to these threads have little or no real word experience. Not long ago I flew from Oxford to the south coast - less than an hour. I "filed" VFR and both the TAFs and METARs indicated VFR would be possible the whole way. Now I am happy as it happens to run scud with the best of them but not only was my destination out of bounds VFR so was Oxford by the time I was half way into the flight. In fact by the time I arrived it was hard IFR and I only just got in. Moreover my climb was limited to remain below CAS because there was little hope of a pop up clearance so the rest of the route was IMC with the fluid running.

Coming back from Ireland last year tops were forecast at FL55 and with a base of broken 1,500 a VFR arrival seemed on the cards. Over the Bristol Channel I managed to just clear the tops at FL95 accumulating light ice in the last 1,000. On arrival the base proved to be overcast at around 850 feet.

I cant think of anything more dangerous than creating a rating that encourages pilots to get themselves stuck on top, or for that matter ever struggling to find the tops followed by a descent to a predicted VFR arrival but in fact having to divert or "bend the rules" in order to get home.

Like it or not much of Europe is dominated by Oceanic weather - it is not Australia and its not Spain, Italy or Germany.

For me those that propose ratings of this type have no real world experience or if they do it is long forgotten and that is one of the reasons I am so bitterly opposed to rule making to pander to those with a very different agenda form the safety of the pilots they serve.

For those reasons Brendan Europe might want to pretend that we should stop thinking about what happens when the weather changes en route from Ireland, and so might you for that matter, but I am far more comfortable in the real world and a great deal more comfortable knowing that when I set off I can safely make an approach without having to be concerned about a set of rules which are of no concern to Mother Nature.

For those that think otherwise talk to the guys that fly the milk run to the CIs for a living, ask them about the weather, and when you have done that come back and let us know whether you still hold to the same view - here is the problem, you can bet thats something none of the committee members have bothered to do.

[Pace]

So, the private IR pilot has a strong interest in not making the demonstrated competence any lower.

10540

I like the suggestion here of a modulated IR with a Basic PPL/IR which can then be upgraded to cover the whole CPL to ATPL.

the flight test would be No different the only difference would be in the ground exams. There would be a specific exam/ set of exams designed for the PPL who is not flying commercially, who will be using LAS and has no aspirations to be a heavy jet pilot flying at FL390.

The flight test and standards would be the same but with generous allowances given to PPL IMCR pilots. The litmus test is the test itself. Either you are good enough to handle all the IR test requirements or your not.

So the only quality difference between the two would in reality be the exams you have covered but even there you could always upgrade as and when you need to be a commercial /ATP pilot.

The powers that be may actually like the idea of the building block scenario of what they already have rather than a mickey mouse stand apart IR for private pilots.

Pace

[BackPacker]

The flight test and standards would be the same

Would that be absolutely necessary? The test standards for CPL are already more strict than for the PPL and we don't find that a problem do we?

I admit I do not possess an IR (otherwise I wouldn't bother mingling in this thread anyway) but if you allow slightly less strict standards for a PPL/IR than for a CPL/IR, and compensate for that by having, say, slightly higher departure/approach minima (published minima + 200' for instance), would that significantly impact the utility of a PPL/IR? Or maybe some system where you need to apply slightly higher minima for the first x "for real" IMC approaches?

PPL/IMC holders have long lived with the "advice" of the CAA to apply such a factor to their approach minima, haven't they? Was that an unreasonable advice, making things unworkable?

[englishal]

This is an interesting discussion.

Regarding level of training, the practical test standards should be the same.

So how does one make the EIR more achievable than the "full" IR for someone on a limited time/budget? Cost is going to be a big factor (main factor for most) in a private "sunday" pilots decision. For others it is time.

One way is the EIR with precision approach capability. This would mean that a) The ground exams could be a very cut down version, concentrating on IFR rules and procedures and weather only, b) The flight training could be cut down as one doesn't need to demonstrate NPA's and c) make allowances for previous time.

In theory then a current IMCr / ICAO IR holder could then self study for the exam, pay the exam fee (£100?) and take the test, do some brush up training with your local flying school and then take the test with an examiner - a relatively simple, time efficient and cost effective solution. Current IMCr holders wouldn't feel agrieved at losing a rating, as their rating counts towards the required time. IR holders shouldn't feel agreived because the practical test standards are the same as for them.

For new candidates, flying an ILS is the simplest procedure to learn and not particularly difficult. By cutting out NPA's the EIR could probably be condensed into 20-25 hours - which is realistically what the IMCr is now. The enroute stuff is easy, the ILS is easy. The hardest bit is the basic attitude instrument flying and partial panel.

Forget 170A's and JAA Class 1 Audiograms and keep it in the realm of the "private" pilot, not A380 captain.

If this was what the EIR evolved into, then I'd be quite happy, and I guess many of those who put their planes onto the N reg would also reconsider.

[IO540]

The JAA IR test is the same for the PPL as for the CPL.

In FAA land there is a tighter IR checkride incorporated in the ATPL checkride.

I agree with Pace, but there is some political obstacle to a straight modular IR.

[Pace]

BackPacker

I admit I do not possess an IR (otherwise I wouldn't bother mingling in this thread anyway) but if you allow slightly less strict standards for a PPL/IR than for a CPL/IR, and compensate for that by having, say, slightly higher departure/approach minima (published minima + 200' for instance), would that significantly impact the utility of a PPL/IR? Or maybe some system where you need to apply slightly higher minima for the first x "for real" IMC approaches?

You are realistically asking the Europeans to accept the IMCR? whats the difference?


The problem that concerns me is selling something acceptable to the Europeans. I agree with 10540 that if its seen as a lesser rating mixing in with the big boys the Europeans wont buy it.

If its seen as a stepping stone rating with the same flying standards they may?

The biggest hurdles are the cost of flight training which could be partially covered by IMCR allowances and the option if you think you are good enough to put yourself up for a pre flight exam exam and secondly the exams.

The exams can take months of hard dedicated graft learning a lot of stuff you dont really need to know.

The FAA exams can be done really quickly with no safety differences between the two. That beggers the question of are months of study really needed for a PPL/IR?

The business man /working man with a family often cannot find the time or level of commitment needed to study those blast+d exams.
So IMO keep the flying standards the same with allowances but make the study work a whole lot easier and more relevant.

They will never buy a European IMCR they may buy a stepping stone PPL/IR where the flying standards are the same but the study work can be added later as required.

Thats my opinion for what its worth.

One way is the EIR with precision approach capability. This would mean that a) The ground exams could be a very cut down version, concentrating on IFR rules and procedures and weather only, b) The flight training could be cut down as one doesn't need to demonstrate NPA's and c) make allowances for previous time.

Englishall

What you are asking for is for the Europeans to accept the British good old tried and tested IMCR. Trust me it will never happen go that route and we are dead meat.

Pace

[vanHorck]

It seems to me the horse is behind the cart here. We are looking at what can be made easier for the sake of being easier.


I see two issues:

the FAA IR is easier but then I understand their IFR flying is easier too because the FAA has been more dynamic than our European counterparts. The question is, are their lower standards also less safe? If not why not simply adopt the american FAA IR and/or allow it here for non commercial use on European aircraft?

The second issue is that PPL IR's will not encounter all the things ATPL's do. I am thinking of the coffin corner up very high, the risks in flying well above FL250, perhaps the pressures of having to fly in all conditions, surely things like auto land.

I would like to hear the opinions of IR rated PPL's here such as IO on these matters:
From a practical standpoint why would the FAA IR not suffice?
From a practical standpoint, what ATPL IR part of the syllabus should not be required for PPL IR's and how much time on theory and practical training would that save?

[Pace]

Van

The FAA IR Pilots have the same safety levels as the European IR pilots.
There was a massive study comparing both up to ATP level probably so EASA could use that study to force through changes on a safety angle.
No difference could be found.

In a sensible world yes an FAA IR CPL ATP should be easely changed for a European variety and visa versa, but its not a sensible world.

If it was a sensible world the Europeans would accept the UK IMCR as a an addition to VFR safety but they wont!

Its all about quangos, burocrats, protectionsism, politics, state control and above all NON SENSE. Thats what we are up against.

Pace

[IO540]

From a practical standpoint why would the FAA IR not suffice?It would but European regulators just say "we are Europeans, not Americans, and we must have European solutions". End of debate.

From a practical standpoint, what ATPL IR part of the syllabus should not be required for PPL IR's and how much time on theory and practical training would that save?Quite a lot, but a lot of it has already happened in the ground school. The PPL/IR has 7 exams, whereas the CPL/IR (in JAA-land the ATPL is a given once you reach the #hours etc) is 14 exams. Moreover, should you be doing the PPL/IR exams and encounter a question on 737 FMS etc, and you have just failed by 1 point, you can AIUI appeal the result. So, the early 2000s situation where a European PPL/IR had to do all the CPL crap (about the time I started on the US route) was fixed a few years ago.

What has not changed, and these differences are vital to getting US levels of IR penetration in the population, are

1 - the need to learn a lot of stuff (still)

2 - the need to do 50/55hrs (with zero credit for previous experience, regardless of competence)

3 - the need to do all flight training via a professional FTO (a blatent business protection measure, and most pilots don't have one at their local airfield, so are looking at a "residential" scenario to some degree)

4 - the Class 1 medical audiogram (affects some older pilots, though there are very roundabout solutions).

The EASA full IR, which is being worked on now, will address 1. to a degree (no idea how much), 2. to a large degree (I gather there would be a large element of "demonstrated competence"), but not 3. at all. 4. likewise; medical stuff is seemingly out of reach in Europe.

So things are happening, slowly. I think not solving 3. (if true) will be a major damper on progress. A large part of the success of the IMCR is that one can do it at one's local school.

The problem I see is more basic: EASA has tabled such aggressive FCL proposals on the foreign license side of things (undoubtedly, this was naively done to drag the FAA to the table, to get them to agree to a bilateral treaty on a pile of stuff which assumed that Europe is as relevant as the USA) that the resulting s**t is going to hit the fan in such quantity that all the wheels might come off in one go. In which case we will probably end up with a status quo...

[mm_flynn]

Van,

I hold the FAA/IR but have a number of friends who hold the JAA flavour and a few who have JAA and or FAA ATPLs. There is a fundamental philosophical difference between America and Europe on the knowledge side. In Europe, there is a view these things should be structured qualifications at professional schools. In the US it is that you need to know and demonstrate the application of the knowledge in the real world and they don't really care how you got the knowledge. In Europe, there is an element of knowledge requirements to make it more time consuming.

However, and many people seem to ignore it, I am confident the key objective of FCL.008 was not to save the IMCr but to make access to the IFR system more attainable while not reaching so far as to create something that could not be sold across Europe (which like it or not is what happens when your government agrees to regulate aviation on a pan-European basis).

The flying tolerance are broadly similar with a couple of areas where the JAA/IR is tighter than the FAA/IR, however, the FAA then make type rated pilots (i.e. everyone in a large or turbojet aircraft) fly to higher tolerances in the ATPL exam (and these are slightly tighter than the JAA tolerances). However, anyone who is doing real IFR approaches should be flying to this tolerance anyhow. As several people have pointed out, the weather can always go down hill and an EIR pilot may not be able to do a cloud break and have to land off an emergency ILS, and IR pilot may have what he thought was going to be 600 and 1 mile go down to 200 and RVR700 - and you want to be able to hold it together when that close to the ground.

Many of the comments that have been made seem to be reflect aspect of what I believe is being created in terms of making the IR more accessible. However, there was a view, which by the comments on this thread seems to have been misguided that a stepping stone rating between the PPL and a streamlined competency based PPL/IR was necessary for PPL's to feel they can approach the instrument flying learning curve and backstop the save the IR plan. If there is no interest across Europe in this stepping stone, I would imagine it would simplify FCL.008s work to drop it and focus on a streamline IR and hope AOPA UK comes up with the goods for a UK opt out to keep the IMCr.

[FREDAcheck]

Everyone has to stop thinking in UK terms and start thinking from the perspective of a European licence holder who has never held an IMC rating.Why?

An IMCR in the UK does not infringe on the rights of other European fliers, nor does it cause them any harm. We know it enhances safety (and enjoyment) in the UK. If other countries want ratings for which there is a demand in those countries: good luck to them.

I really don't understand this mind-numbing dullness of thought that regards harmonisation as a desirable end in itself. There's a feeling that the UK is trying to "get away with something" in the IMCR, as though the rest of Europe must clamp down on an evil plot by the fiendish Brits.

We're getting wall-to-wall coverage at the moment of the events in 1989 when we really thought we were entering a new age of freedom, not a illiberal grinding down to a lowest common denominator. The vision of Europe should be about enabling, not preventing. People should stop thinking "why" and start thinking "why not".

[FREDAcheck]

mm_flynn wrote:
However, and many people seem to ignore it, I am confident the key objective of FCL.008 was not to save the IMCr but to make access to the IFR system more attainable while not reaching so far as to create something that could not be sold across Europe (which like it or not is what happens when your government agrees to regulate aviation on a pan-European basis).
I'm sure you know more about FCL.008 than I do, but the ToR of the group make two specific references to the UK IMCR in a short document.

The Problem Statement includes:
Additionally some of the group experts were in favor to develop a similar rating as the UK national IMC rating with lesser requirements than the current requirements for the Instrument Rating (IR) which allows the pilot to fly in circumstances that require compliance with the Instrument Flight Rules (IFR) but in certain airspace categories only.
and the objectives include both:
Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules. This evaluation shall take into account the ICAO Annex 1 SARPs for the issue of an IR
and
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
In other words: BOTH consider a more accessible IR for PPLs AND consider an IMC-like rating.

I suppose Jim Thorpe considers that the en-route rating meets the latter objective. I don't agree, but such a rating could also allow national opt-outs like the Altiport rating. Much fuss was made in previous threads about the Altiport rating restricts a license, rather than adding to it. This apparently makes it OK whereas the IMCR is bad, as it adds to capabilities of a licence. So the European IMC rating could allow restricted (higher minima than an IR) approaches, but allow individual countries to impose further restrictions, such as "no approaches".

I can't see anything in the Terms of Reference of FCL.008 that would rule out what UK pilots want - except perhaps the composition of FCL.008.

[dublinpilot]

Dublin pilot - Engine failure in IMC enroute for someone with an EIR or an IR or an IMC rating present exactly the exact same issues. It is an emergency and thus the pilot can legally do whatever they think is necessary. However, should a PPL or an EIR or an IR or an IMC rated pilot be flying in VMC over an extensive fog bank and the single engine fails then they are all faced with having to complete a forced landing in IMC with insturments that are in the process of running down due to lack of suction and limited battery life for the turn coordinator and pitot heat etc

So do you think that a basic PPL flying VFR on top or an EIR holder who at the same place and the same level has the engine problem you describe - which will be better equipped to descend through cloud and track a VOR/NDB and/or follow ATC vectors?


The circumstance I described was a developing situation, not an engine failure that had happened.

As for how an IR/IMC holder would deal with it vs a VFR on top/EIR pilot, well it's pretty simply.

An IR/IMC holder would divert to somewhere close by and perform an instrument arrival.

Neither a VFR on top pilot or EIR pilot would be trained to do such an arrival...hence why I don't see it as a good idea.

Speaking as someone who can legally fly VFR on top, I don't think very many people do, unless they have some instrument qualification. The dangers associated with being stuck on top, and your only way out being an instrument arrival that you are not trained for, are too serious.

I suppose an EIR course could include some instrument arrival training to cover this, but if it was enough to allow it to be done safely, then why not examine the student in it, and give them the privlidige?

[IO540]

I can't see anything in the Terms of Reference of FCL.008 that would rule out what UK pilots want

That bit is called the "European Union" :)

Standardisation.

[englishal]

What you are asking for is for the Europeans to accept the British good old tried and tested IMCR. Trust me it will never happen go that route and we are dead meat.
Not really. All I'm asking for is that previous instrument time is taken into consideration. Anyone in Europe could do the EIR, but if you happen to already be experienced on Instruments then it is going to be easier. This could be a french person holding FAA IR for that matter.

I hold an IMCr by virtue of of my FAA IR - The CAA exempted me from the ground exams and also the flight test due to my IR. That would be very nice in the case of an EIR but being Europe I can't see this happening. But as such I'd be happy to do 1 theoretical knowledge exam which I can self study for (plus I already have a pretty good grounding in FAA IFR ops having been IR'd since 2002), and brush up / flight test. This seems a very sensible route.

FAA tolerances are easier in some respects (needle deflection on an ILS for example) and harder in other areas (partial panel for example) so it is not "easier" by any means.

The problem with Europe is the high training costs so to make it cheaper (and hence more achievable for the majority) then these have to drop. By reducing the hours required, and consequently cutting some of the course and privileges, this seems a sensible compromise.

I would probably have already converted to JAA via the "15 hr" route, had it not been for the £1000 exam course, the year of study with mandatory residential course, and the silly "170A" . Test fees alone probably amount to £1000, so one has spent at least £2000 and a 6months to a year of study for no extra privileges that I could already enjoy in an N reg.

[IO540]

The FAA IR -> JAA IR conversion eliminates the need for ground school residence. I have the fairly obscure reference for that somewhere.

What it doesn't do is eliminate the need (for most people) for flight training residence - because one has to do it all via an FTO.

And not just any IR FTO is convenient. Where I am based, there is an FTO which does an IR but of the people I know who started with them, all moved on fast and started living out of hotels about 70nm away. This was because the JAA examiners expect you to be doing a specific route, and this route is what is trained, and if the airport you are at is not on that route, you are for ever flying to the airport that is, and it is a big waste of time and money.

[englishal]

No doubt someone will say this is not always the case....But one of my friends did the IR conversion from FAA. He had to live at Bournemouth for a month, didn't fly for the first week so spent the time hanging around, then they didn't fly at weekends, then they did one hour per day in the aeroplane / or sim. Grand total of a bit over 15 hours + test+170A, 28 days B&B, and £000's., not to mention loss of income as he was self employed. He already had the ATPL's and JAA CPL.

[Stapleford 2007]

Apologies as I am a newbee to this netwrok.
Can anyone recommend a school offering a fasttrack IMC course over a week or less in the UK? Time constraints & other committments mean that completing this rating on the usual once a week at the weekend basis is going to take too long to complete. However, I can take a few days off on holiday, concentrate on the course and get it done.

Many thanks