En-route instrument rating - how's it supposed to work? [Archive]

Fuji Abound

30th Nov 2009, 13:13

I think the way it is intended to work is something like this:

You must depart in VMC on a VFR flight plan. You may not enter cloud until having reached whatever height is specified in the rating. If for example this ends up as being lets say 1,500 feet you will proceed outbound from the airport on a VFR clearance and if lets say the cloudbase is between 1,300 and 1,700 feet in the vicinity you will arrange you route with the controllers so that you can find an area where you can climb to your en route height without entering cloud until you are at least at 1,500 feet.

You will presumably have declared in your flight plan the point at which you expect your flight to become IFR and also the point at which you would like to join a lower airway. If you have been displaced by the cloud base during the climb presumably you will now ask to join somewhere else on the route or will head back to your planned join point and tell the controller that due to the cloudbase unfortunately you will be joining at a later time than planned.

The Controller may or may not now give you the clearance you requested. If he doesnt you will continue in solid IMC rather than achieving the expected VMC on top and generally increase both your work load and cause a satisfying amount of chaos in the system generally as you seek to renegotiate your join. Your departure planning will have long since gone out of the window and you will be working hard potentially in IMC repositioning the aircraft and replanning the flight.

If you are lucky you might eventually secure a join, if you are not, its enroute for you remaining outside of CAS negotiating every clearance and if you are very unlucky IMC the whole way. Enjoy.

Of course when you arrive you will have to explain to the Controller that you need to negotiate a VFR arrival and will need a descent somewhere suitable in order to achieve this. Its down into the soup again for you. Where? Where indeed, who knows, because the Controller sure doesnt want you making up a descent in his backyard. Down you go somewhere, but as long as it is not in my patch. Of course you dont really know when, or should I say, if you are going to become visual within the limits of your rating. I can hear you curse as you dodge between clouds and gliders that someone should have told the clouds they must form up into a uniform base. If you are very unlucky the base will have changed since your departure three hours ago from the South of France - someone should have told those pesky clouds that they really should read and abide by the forecast. I know you are an astute pilot so you got the forecast before crossing the channel so you would be ready to divert into northern France - what a shame the base is a few hundred feet lower over the north of France - so its a diversion for you my boy. Of course you are getting pretty good at this replanning lark now, so its out with the map, on with the radio and some fun and games with the Contollers getting them doing some work to find the weather at your alternates - ah well they havent got anything better to do have they?

Easy stuff this IR flying I remember the days I flew on an EIR - now that was hard work. :}

bookworm

30th Nov 2009, 13:57

If you can't make an approach at the end, what does a typical flight using the EIR look like?

You'll have to wait for FCL.008's report and NPA for a definitive answer, but my impression is that the flight would be an IFR flight like any other, with a requirement that planning minima are met at the destination or alternate -- just like a current IFR flight but with higher minima to enable a visual approach from MSA.

As far as I can recall, my last 10 or so IFR legs would have been perfectly flyable under such requirements -- I would have thought that 80-90% of flights would be.

mm_flynn

30th Nov 2009, 14:11

A slightly more optimistic example could be, for instance, today - you decide today to go to Prague and look at the weather

METAR for EGLC 9.4NM from EGTF
EGLC 301420Z AUTO 35012KT 9999 SCT020/// 07/03 Q1001
EGLC 301350Z AUTO 35010KT 310V030 9999 BKN022/// BKN040/// 07/03 Q1001
EGLC 301320Z AUTO 35012KT 320V030 9999 SCT018/// BKN024/// BKN030/// 07/03 Q1000
TAF AMD TAF AMD EGLC 301213Z 3012/3021 36014KT 9999 SCT015 TEMPO 3012/3015 36015G28KT 7000 RA BKN012

And see you can get a VFR departure in and can safely climb to 1300 feet above EGTF (so you can be enroute IFR compliant before entering clouds)

METAR for LKPR
LKPR 301400Z 33006KT CAVOK 07/05 Q0995 NOSIG RMK REG QNH 0991
LKPR 301300Z 34006KT CAVOK 07/06 Q0995 NOSIG RMK REG QNH 0991
LKPR 301200Z 36005KT CAVOK 08/05 Q0995 NOSIG RMK REG QNH 0991
TAF LKPR 301100Z 3012/0118 04004KT 9999 SCT036 BECMG 3013/3016 18010KT BECMG 3022/0101 31010KT 9000 -RA SCT014 BKN020 TEMPO 0101/0118 4500 RA BR BKN014 PROB30 TEMPO 0101/0108 2500 RA BR BKN009

And see that as long as you plan to get to Prague before 01Z tomorrow you are OK (using the FAA rules for determining 'guaranteed VFR')

You then file

(FPL-DFLT-ZG
-BE36/L-SGRY/S
-EGTF1000
-N0182VFR GWC/N0360F100 IFR DCT SFD R803 DVR L9 KONAN L607 RUDUS L984 SULUS/n0175f060 Z650 TONSU Z35 LOMKI VFR
-LKPR0319
-DOF/091201
)

On departure you are handed to Farnborough, they co-ordinate your airways join and you sail smoothly across the channel, France and most of Germany above a range of scattered to broken clouds, at SULUS you duck under these clouds to avoid the OVC from about 6000-12000 all below 0 (assuming you are not deiced) and are vectored onto a visual approach.

No need for a bouncy windy channel crossing and dodging/blagging transits for various pieces of controlled airspace.

No need to try and maintain proper VMC.

If the forecast is totally blown, ATC know by the VFR transition there is going to be a problem and you either coordinate a diversion to your alternate (which can happen to anyone) or as often happens when you are on top you can see a hole off route and descend, or in the worst case you are in the same boat as a PPL from any country in the world other than the UK who has been caught on top and you need to declare an emergency - however, you have quite a lot of practice in attitude control and keeping the needles centred in IMC, have done a number of 'emergency ILSs' in training so it is a bit of extra work for ATC but not particularly life threatening.

It is totally different from an IMCr, may not be what the European community wants or needs from a sub-ICAO Instrument Qualification but does offer considerable safety and utility beyond a basic PPL.

As bookworm says - we need to wait for the NPR before this is anything more than speculation at the detail level - but you can see a version that is quite practical or the potential for a dog's breakfast - depending on the detail.

More relevant in the short run - Is this capability at all interesting to the tens of thousands of European pilots, who to date, have chosen not to advance beyond PPL level? (It may even be of interest to IMCr holders - but as I said earlier is a very different mix of privileges)

bookworm

30th Nov 2009, 14:18

GWC/N0360F100

I want that BE36! Do you park it beside the G4? ;)

Cows getting bigger

30th Nov 2009, 14:20

You beat me to it BW!!!

Fuji Abound

30th Nov 2009, 14:27

You'll have to wait for FCL.008's report and NPA for a definitive answer, but my impression is that the flight would be an IFR flight like any other

Bookworm

Seriously my flippant earlier post aside how do you think that will work?

As you suggest you file IFR in France. Presumably the Contoller may still give you a SID and presumably you may enter cloud on the SID at a lower altitude to which you are entitled. Does that mean that you ensure the cloudbase for the whole of the SID is above the minimium cloud base and if it isnt stay put on the gorund? Alternatively do you build in a degree of common sense and accept you may enter IMC at a lower altitude and if so how much common sense do you build in? What do you do if you are in an out of cloud on the SID because the cloud is broken with elements below your minimium IMC altitude? Do you base your go dont go decision on the base of the very lowest cloud anywhere in the area of the airport from which you are departing?

I fully accept that on most occasiosn the cloud will either simply be too low or too high to be of concern. However is there a danger with limits such as these that the rules simply get bent when it suites in which case why have the rules in the first place. Moreover on marginal days does it encourage pilots to go because they know / think the base will lift en route and therefore they set off VFR with the intention of staying below the base in the hope of a pop up clearance en route.

mm_flynn

30th Nov 2009, 14:40

I want that BE36! Do you park it beside the G4? ;)
Yes I do!! I must get the turbofan STCed!

Oops

IO540

30th Nov 2009, 15:12

As stated, the detail proposals have not been published (and won't be for a long time) but there are lots of different scenarios here.

1) UK departures OCAS
You "just fly". Nobody cares if you enter IMC almost immediately.

2) UK departures INCAS
Each airport has its own VFR minima; typically ~ 1500ft cloudbase. Below this, you won't be going. Above this, you are good to go.

3) Foreign departures OCAS - countries which allow IFR to be filed to any airport
You file IFR and just fly, probably.

4) Foreign departures OCAS - countries which don't allow IFR onto to IFR airports
You probably file a Z flight plan, and just go.

5) Foreign departures INCAS
Each airport has its own VFR minima; typically ~ 1500ft cloudbase. Below this, you won't be going. Above this, you are good to go.

So much for departures. Presumably the rules will require a minimum cloudbase/vis for a departure, as a baseline, for any airport.

For arrivals, the pilot will have to request a visual approach, but he can't do that until he is in VMC, obviously. This will obviously be fine if the weather is good.

What concerns me is what happens if the wx is not so good. The final resort (a mayday and flying the IAP) is not realistic because if any significant # of people do it, it will give IFR GA a really lousy reputation and cause the privilege to be terminated (or worse).

So this bit has to be worked out carefully.

The other way to handle arrivals is to always file a Y flight plan. That will almost always work in the regulatory sense, but it leaves the pilot to do his own cloudbreak - just like VFR pilots flying VMC on top have been doing. There are various hacks for this, which are safe with coastal airports but not so great where there is terrain. I've done plenty of this stuff and it is OK if you have perfect situational/terrain awareness...

One could also handle departures by always filing a Z flight plan. This might get you in trouble if the departure leg is OCAS and you are spotted entering IMC, in a country where IMC (IFR) OCAS is not allowed, or requires an IFR clearance.

One might expect the regulatory planning minima for this privilege to require the forecast cloudbase to be above the platform altitude for any approach at the destination airport, otherwise obviously the pilot will be flying the IAP (which he is not allowed to) before he gets visual....

A comparison with VFR pilots is not applicable here because a VFR pilot has no clearance and the approach controller can tell him to s*d off at any time, leaving him high and dry. That is how VFR works!! That is why VFR/sports flying does not face significant challenges on deregulation - because ATC always have the "remain OCAS" magic words at their disposal. Whereas on an IFR flight, you have filed a Eurocontrol flight plan and you have an implied clearance all the way, and they have to handle you.

Anyway, one could speculate endlessly, and it will be pointless to do so.

The great bonus of this rating would obviously be the enroute section, which would be flyable at any level and on any Eurocontrol acceptable routing, limited only by aircraft performance, and without having to beg for transits which a lot of the time are denied. Much better than hacking along under "VFR".

The downside will be the need to file a Eurocontrol flight plan, and this means having to be able to fly at high altitudes. Anywhere near London this is FL100 plus, anywhere in Europe it is FL070, and realistic levels for the routings are FL100-FL180. So this is really a full IR in terms of aircraft capability, and pilot knowledge and equipment (oxygen, etc). It involves planning to deal with icing (which I do by flying VMC on top enroute, up to FL200 if necessary) etc. Only in the UK, and a very few (none?) other places, will the EIR be usable at low levels like the IMCR is.

As I've said before, I think the IMCR will remain because the CAA knows full well everybody with it will continue to fly in IMC. They just won't be able to overtly fly an IAP, so they will be doing DIY letdowns, in close proximity to the IAP-equipped airfields...

For European pilots, who currently have zilch, the EIR will be a totally added bonus, so that's a good thing.

However, IMHO, any new IR will be a marketing failure unless one can do it at one's local school. Having to do it at a professional pilot FTO means that the flight training will be a residential project for most people.

bookworm

30th Nov 2009, 16:24

Seriously my flippant earlier post aside how do you think that will work?

Well how does it work at the majority of GA airfields where there are no IAPs available? There you don't have a choice, whether you have an IR, IMC rating or an EIR. For an IFR flight you need to make a transition from visual flight to instrument flight on departure, and vice versa on arrival. Yet pilots make such flights every day, in the UK, in the US and in continental Europe.

IO540

30th Nov 2009, 17:00

Bookworm - your input above suggests that the regulatory requirement for the EIR will be to always file a Z or Y flight plan.

IOW, the departure and arrival will always be formally and overtly VFR.

Is this right?

Otherwise, I can't see how it will fit in with ATC procedures. Coming off a Eurocontrol flight plan, ATC expects you to drop off the enroute section (as directed), and fly the approach (as directed). And a departure will be on a SID (as directed), etc...

bookworm

30th Nov 2009, 18:37

Otherwise, I can't see how it will fit in with ATC procedures. Coming off a Eurocontrol flight plan, ATC expects you to drop off the enroute section (as directed), and fly the approach (as directed).

"As directed" is almost always radar vectors for the ILS or visual approach, isn't it? I don't see why it has to involve VFR, though it might. A European version of the contact approach would be helpful.

IO540

30th Nov 2009, 19:08

If not arriving on a Y flight plan:

When about to commence the approach, the pilot would have to ask for a Visual Approach (if visual at/above the platform altitude) or declare a Mayday and in the same breath ask to fly the approach which ATC expected him to fly anyway (if not).

That's why I think arrivals would need to be on a Y FP.

What also puzzles me is that one is not allowed to fly an instrument approach under any conditions, including CAVOK, and instead fly the published VFR circuit.

While (it appears) one would be expected to fly a SID as published.

If however the arrival and departure were under Y and Z flight plans, then it makes sense.

bookworm

30th Nov 2009, 19:28

You're right IO540. It makes much more sense to allow the EIR holder to fly the IAP in visual conditions. The hard bit is not following a profile in visual conditions, but flying it in cloud or low vis. Looking out of the window and seeing the obstacles is the safety net.

That would avoid the necessity for a visual approach. I wouldn't use "VMC" though -- the flight remains separated from other aircraft by ATC, hence issues like cloud separation are not relevant.

mm_flynn

30th Nov 2009, 19:30

You can swap back and forth between VFR and IFR several times. I think Y means you depart IFR planning to switch to VFR (and possibly back and forth several times), Z means you departed VFR and are going to switch to IFR(possibly having switched back and forth several times).

leaving a German VFR only field and then arriving in Lido (Italian VFR arrival required) with an IFR enroute seems to need to be filed as Z (and CFMU doesn't choke on this).

IO540

30th Nov 2009, 20:43

This is digressing, but is such switching really possible, mm_flynn?

There are many cases in airways routings where being able to fly a VFR section within an IFR route would be a useful way to do a shortcut - where there are no airway routes for example. The gotcha is that upon completion of the VFR segment one would have to get a fresh IFR clearance from ATC, also hoping that they have not in the meantime binned the IFR flight plan.

One can understand going VFR - IFR - VFR (on a Z FP) because ATC don't have to do anything special; all they see is the contiguous IFR section which is all that enroute ATC care about.

Fuji Abound

30th Nov 2009, 20:51

It does seem odd that dear old Jim didnt think of having an expert from ATC on FCL008 to thrash out what issues this may cause them.

I suppose this has always been one of my huge misgivings with the EIR. If Jim gets his way effectively a new way of flying will be introduced into a very wide and diverse system which has not been tested and it would seem without almost any proper study whilst a very well tested and proven mechanism will be abolished.

I hope Jim will accept responsibility if it fails to work and if more than a few pilots get themselves into difficulty.

Utfart

30th Nov 2009, 21:00

IO540 - if you're at a towered airport in CAVOK conditions, can't you
simply ask for clearance on the approach of your choice, and fly it once cleared?

Excuse me if this is incorrect as I live outside the UK, but my impression is that
many pilots use their IMC rating as an everyday tool for navigating through
IMC, and not as the "lifesaver" it is advertised to be. If that's true it seems to be
just as much of a loophole as the good old FAA IR, except it's sub ICAO.

IO540

30th Nov 2009, 21:30

IO540 - if you're at a towered airport in CAVOK conditions, can't you
simply ask for clearance on the approach of your choice, and fly it once cleared?Yes, within reason (e.g. a busy airport will be operating a specific runway and that narrows the choice of approaches). Also, while most airports publish a number of instrument approaches, most bigger places use radar vectoring onto the ILS and ATC there will not be terribly interested in somebody wanting to fly the procedural NDB/DME approach when they have half a dozen ILS inbounds :) So at a busy place the choice would tend to be either the primary instrument approach (usually vectored) or a visual approach to the same runway.

However, the EIR will not allow instrument approaches of any kind - other than in an emergency.

Excuse me if this is incorrect as I live outside the UK, but my impression is that
many pilots use their IMC rating as an everyday tool for navigating through
IMC, and not as the "lifesaver" it is advertised to be. Yes. If you look at the IMCR privileges, they are identical to a full IR except

- no Class A airspace
- min vis 1800m for arrivals and departures
- IFR allowed in UK airspace only

If that's true it seems to be just as much of a loophole as the good old FAA IR, except it's sub ICAO.It's not a "loophole" and neither is the FAA IR !! Both are 100% legal privileges. If you have a legal privilege to fly with your trousers down, then you are 100% legal to fly with your trousers down :)

Whereas for example flying in IMC on a VFR flight is illegal (although practically everybody has done it at some stage).

Fuji Abound

30th Nov 2009, 21:45

So at a busy place the choice would tend to be either the primary instrument approach (usually vectored) or a visual approach to the same runway.

So the EIR holder inbound to Bournemouth who cant call for vectors onto the ILS will come off airways somewhere south of the IofW (inbound from the CIs) and let down over the sea or the IofW until visual. I hope there is no VFR traffic pottering around below.

Personally I hate let downs outside an ATZ - it seems to me it is bl**dy dangerous and irresponsible to other users of the airspace - is this exactly what the EIR will encourage?

IO540

30th Nov 2009, 22:01

A "visual approach" (which is an approach flown under IFR) commences much closer to the airport.

However, it is not clear whether this is the EIR intention, or whether they were planning to require a Y (IFR to VFR) flight plan to be filed. The latter would indeed imply a DIY letdown somewhere further back, but that letdown is supposed to be in VMC :)

B2N2

30th Nov 2009, 23:08

OMG, what a tragedy and a travesty.....:yuk:
Because (unlike the USA) they don't want you to get an Instrument rating at a decent price and they killed the IMC they come up with this rubbish?
There is something seriously wrong with this picture.
They need to be strung up.

I'll get my coat and my tin foil hat so they can't mess with MY mind.

BEagle

1st Dec 2009, 05:51

Yes, anyone descending in IMC outside CAS without a radar service of some sort is courting disaster, I agree.

Unusually in nuLabor's surveillance society, radar service outside CAS is pretty poor in the UK, particularly at weekends. So how safe would the stupid 'EIR' be on such occasions? Currently an IMC rating holder would only need 1800m / 600 ft at destination, but with the 'EIR', all bets are off.

Apart from a very small minority of the 'PPL/IR Europe' group, everyone in the UK is opposed to the 'EIR'. We will be making this point to EASA officially later this week, so that they are under no mis-apprehension that FCL.008's UK members speak for UK GA.

IO540

1st Dec 2009, 06:42

Yes, anyone descending in IMC outside CAS without a radar service of some sort is courting disaster, I agree.

I take it that statement is tongue in cheek ;)

Fuji Abound

1st Dec 2009, 07:57

However, it is not clear whether this is the EIR intention, or whether they were planning to require a Y (IFR to VFR) flight plan to be filed. The latter would indeed imply a DIY letdown somewhere further back, but that letdown is supposed to be in VMC

IO540

I still dont quite follow your point.

Please take my example of a pilot returning from the CIs to Bournemouth. There is a solid overcast from mid channel to the south coast and over southern UK between 2,000 and 3,000 feet - or if you like 1,500 feet and 3,000 feet. Conditions are VMC above and below. It is a situation I am sure you have seen many many times.

Now as I understand the position the pilot could not call for vectors onto the ILS either because he would be commencing / entering IMC during the approach or because he would not become visual before his rating minimium.

Therefore in order to become visual below the base (which would enable him to continue to Bournemouth and request a visual arrival) he would need to inform the Controller he wished to leave the airway at say St Catherine's Point.

The pilot would then descend through 1,000 or 1,500 feet of cloud over the IofW outside CAS and potentially without a service. At some point he would become visual and would continue inbound to Bournemouth on what has now become a VFR flight plan or a continuation of his IFR flight plan but in VM conditions.

Is that how we see it?

I use these conditions because I think most would agree they are the type of benign conditions in which many pilots would be flying be it below the base in VMC or on top with their IMC rating followed by vectors for the ILS. This isnt hard IFR it is typical British summer weather. Those of you who like mentioning holes in the undercast - forget the holes, there arent any - I can assure you this is quite common.

If this is the way it works as I mentioned earlier doesnt this simply encourage a load of pilots to perform made up descents outside CAS and amoung other things make the big sky more than a little bit smaller!

Utfart

1st Dec 2009, 08:06

"If that's true it seems to be just as much of a loophole as the good old FAA IR, except it's sub ICAO."

Sorry, I didn't word this well at all. What I really wanted to say is that I perceive the
IMCR to be a loophole the same way many in the UK perceive the FAA IR to be a
loophole. On further thought, I'm glad I don't fly in the UK and share the sky with
people with a legal right to fly in IMC but very little training. If the idea was to give a
pilot the skills to survive an inadvertant encounter, why the rating? why not simply
expand the requirment on a PPL? I'm sure there are some IMCR holders that are
very proficient at instrument flight, but I don't want to meet the others. Unfortunately
there don't seem to be any reliable statistics to support or refute my position, and
that's something that needs to be seriously addressed.

I don't know what will happen in the future, and I guess whatever it is will take a
long time. I can say that as a pilot flying in Europe, me, and the others I have spoken
to, have no interest in an IMC rating, but we are very much looking forward to a
European IR with an easier to attain theory component.

Fuji Abound

1st Dec 2009, 08:13

Unfortunately
there don't seem to be any reliable statistics to support or refute my position, and
that's something that needs to be seriously addressed.

Just two very quick comments:

The two best stats. available:

1. No (or maybe 1 depending who you believe) accidents involving IMC rated pilots in IMC in more than 40 years - there have been a lot more in the same size population of IR pilots,

2. No collisions in IMC involving an IMC rated pilot ever.

Sounds pretty safe to me. :)

Utfart

1st Dec 2009, 08:18

a reliable statistic, to me, would be something published that can be referenced.

TWR

1st Dec 2009, 08:18

It doesn't mean anything.

More important are the incident reports (which are potential accidents).
But it is impossible to get decent data on these since IMCr is outside CA.

From an ATC point-of-view, the EIR is complete nonsense.
IFR is only cancelled on pilot's request. What if he doesn't do this ?
We put him in a holding ? We vector him in the sequence for an ILS ?

IO540

1st Dec 2009, 08:24

Fuji - I understand what you saying but we don't know the details of how the EIR will be expected to work.

If the pilot will be required to file a VFR arrival then he would have to descend some way before the airport, and yes in your example he would become illegal on the way down.

If the pilot is able to fly all the way to the instrument approach, and then hopes to be visual before actually commencing it and request+fly a visual approach, or if not visual declare a mayday and fly the instrument approach, things get pretty tacky and I don't get how this would work... It would drive ATC nuts, to have somebody flying all the way to the ILS platform and then (presumably not being allowed to fly an approach he is equally not allowed to fly a missed approach) ask for some kind of ad hoc diversion to his alternate.

A more workable assumption is that he will get the ATIS and if the cloudbase is below the IAP platform he will divert immediately.

I suspect the intention is that the preflight TAF requirements will be such that the probability of this (the diversion) happening will be very low. This can certainly be achieved; I used to fly VFR around Europe and while I was in IMC enroute on most flights (for a little bit maybe) I was always able to arrive properly VFR. One just has to be really careful in the weather planning.

Utfart - you fall into the same old trap of believing that instrument competence requires X hours of training, where X was determined by Jesus in 30 BC (and then JAA came and decided Jesus was wrong and stuck another 10 hours on top) :) I don't know if you are a pilot but most IFR pilots know that the degree of competence actually required for IFR flight is way below what is trained if one assumes an aircraft appropriate to that type of flight. I was flying European airways (700nm legs) on my IMCR training, with an IR instructor to make it legal. I learnt nothing of significance doing the IR, which was basically an exercise to prove I could keep 10 balls in the air at the same time. The difficulty of the IR training is primarily because it is taught on the assumption that the pilot will be flying a piece of wreckage with half the equipment malfunctioning, but not tell anything to ATC and just pretend all is well.

bookworm

1st Dec 2009, 08:24

Now as I understand the position the pilot could not call for vectors onto the ILS either because he would be commencing / entering IMC during the approach or because he would not become visual before his rating minimium.

Then he diverts somewhere else, just like any other instrument-qualified pilot who finds that, despite his intended destination meeting planning minima, the actual weather does not.

And if he finds this reduced level of operational utility frustrates him, he goes and gets an IR like everyone else in the world who doesn't want to be limited to making approaches in visual conditions. In order to do so, all he has to do is those extra few hours of training that take his dual IF total up to 25, and pass a test of his competence to fly IFR, including instrument approaches.

mm_flynn

1st Dec 2009, 09:24

Just two very quick comments:

The two best stats. available:

1. No (or maybe 1 depending who you believe) accidents involving IMC rated pilots in IMC in more than 40 years - there have been a lot more in the same size population of IR pilots,

2. No collisions in IMC involving an IMC rated pilot ever.

Sounds pretty safe to me. :)

Fuji, you damage your cause with bogus statistics. 1 is clearly untrue from the CAA's own publications (I accept it is a low number) and collisions in IMC are almost unheard of globally (regardless of the qualifications) so you wouldn't expect the relatively small IMCr population to appear.

I am in no way saying the IMCr is unsafe - just the ongoing pushing of demonstrably false statistics makes the job of the IMCr attackers that much easier.

With regard to your Bournemouth question. I would expect the EIR pilot to be vectored to the MVA on the extended centre line and if visual continue, if not divert. However, that is just my expectation.

Given the apparent total objections to the EIR from the population, it is unlikely anyone will bother to work up the details and we will be left with some bodge for the UK to continue to allow IMCr operations (if we are lucky) and an IR (which, if it is more sensible may be good enough for GA in the rest of Europe).

Utfart

1st Dec 2009, 09:49

I certainly don't believe in the X-hours = IR formula. I am a firm believer in proficiency and recent experience on type creating safe IR pilots. While mastering actual aircraft handling in IMC may not have required a lot of training time, I think that learning to deal with failures, recovering from unusal attitudes, and functioning safely inside the IR system can easily fill the 15 hours dual instruction required to finish an FAA IR. I never bothered to learn what the dual training requirements are for the Euro IR, as I will never have time for the theory study. I have managed to learn many new things doing the IR training, and I know it has made me safer.

I haven't encountered anyone assuming that we will be training on junk aircraft so far, probably because there are alternatives if one looks, but I'll keep my eyes peeled. :8

Fuji Abound

1st Dec 2009, 10:24

Then he diverts somewhere else, just like any other instrument-qualified pilot who finds that, despite his intended destination meeting planning minima, the actual weather does not.

Bookie

I am not sure if you follow my point (which is perhaps badly made).

An overcast of between 2,000 and 3,000 feet is not exactly demanding instrument conditions but is quite common.

As we understand matters the pilot cannot accept vesctors for the ILS because more than likely the vectors would capture the GS in IMC and in any event part of the approach would be in IMC.

I dont see it is a question of whether or not the forecast meets planning minima. If the pilot is above a base (any base) unless the base is higher than 3,000 feet it is inconceivable the pilot could accept vectors or fly ANY approach for the reasons I have explained.

He therefore can only descend outside CAS on a get down and hope basis.

Now if we are saying the weather minima for an EIR holder at destination must at worst be scattered so far as cloud is concerned at anything between 0 and 3,000 feet I would agree with you, but if that really is the case the rating will be even more worthless than I previously thought. Of course to be pedantic the EIR holder would not even be entitled to go through a bit of scattered at 1,800 feet.

I know the details have not been published but either there is to be an aprroach ban in IMC or there isnt. If there is I just cant see how it can be made to work other than in the circumstances I have outlined in the previous paragraph.

I dont see this can in any way be compared with an IR pilot flying an approach to minima, not becoming visual and diverting. The diversion is because it would be unsafe to continue, whereas to not fly an approach through 1,000 feet of stratus between 3,000 feet and 2,000 feet but in the alternative to legally descend through the same cloud outside CAS on a get down and hope basis would seem just silly. :)

Fuji, you damage your cause with bogus statistics

The claim is frequently made that the IMC rating is unsafe. Ultimately what do we base our asessment of safety on? Accidents and incidents? The accident record speaks for itself so is worth repeating. The incident record is not known so we cant report on the record. How else would you prefer to confront the accusation that the rating is unsafe?

For those that claim it is unsafe - in what way is it unsafe? Clearly IMC pilots are not crashing all over the country side. They may be busting clearances, they may be losing control but recovering, they may be failing to accurately follow controllers instructions and each of these events would be potentially serious. However, it would be reasonable to believe if these were regular occurences the CAA would be well aware, unless you are suggesting the CAA has been negligent in dealing with the reports made to them by ATCOs.

Moreover the average IMCr holder is flying single pilot ops. Whilst I hate making a comparison with CAT and commercial IR holders you need only read the incident reports or fly (at all) to realise that their are plenty of incidents amoung this fraternity. I was at Southampton only last week and we had two CA one of which asked for vectors that would take him outside CAS and clearly had no idea that was the effect of his request and another than descended below his cleared altitude.

I accept that IMCr holders avoid the worst of the weather; infact I think they do a pretty good job of self regulation and that is why as a population they do a damn good job of managing the risk. To constantly argue as some do that they are unsafe and they shouldnt be in the same airspace as CAT or even GA holders of an IR should be addressed because if it were such an issue I would have expected there to be some evidence that it was.

bookworm

1st Dec 2009, 11:10

As we understand matters the pilot cannot accept vesctors for the ILS because more than likely the vectors would capture the GS in IMC and in any event part of the approach would be in IMC.
...
I know the details have not been published but either there is to be an aprroach ban in IMC or there isnt. If there is I just cant see how it can be made to work other than in the circumstances I have outlined in the previous paragraph.

I think all of us need to wait for the proposals from FCL.008. You're making a number of assumptions ("approach ban in IMC", "cannot accept vectors for the ILS") as to how this might work.

Your point that the EIR must be compatible with ATC procedures and practices is a fair one, but your own proposed alternative of a rating that permits approaches but not IFR flight in certain classes of airspace suffers from the same inconsistencies, even in the UK. Doesn't pushing a whole class of competent instrument pilots below a particular class of airspace for arbitrary reasons "simply encourage a load of pilots to perform made up descents outside CAS and among other things make the big sky more than a little bit smaller"?

Now if we are saying the weather minima for an EIR holder at destination must at worst be scattered so far as cloud is concerned at anything between 0 and 3,000 feet I would agree with you, but if that really is the case the rating will be even more worthless than I previously thought.

You seem to be concerned about the utility of this rating, and to be forgetting that it's proposed as a stepping stone to an achievable IR. I've still not fathomed what causes you to be so vehemently opposed to creation of an IR that can be achieved by a similar proportion of pilots as currently hold the IMC rating, but offers privileges that permit them to maintain the sort of currency that permits safe instrument flight.

Utfart

1st Dec 2009, 11:12

Sorry, but the UK CAA's accident statistics do not speak for themselves outside the UK. If you are trying to convince European pilots of the safety and importance of an IMC rating, it may be good if someone refers to specific, documented numbers.

I have been told on the one hand that IMCR holders are using their ratings on a daily basis in a much broader way that it was originally intended. On the other hand, I am asked to believe that the safety record of IMCR holders is better than that of all pilots with instrument ratings. Something doesn't add up for me. Either the statistics (never referred to) are false/misunderstood, or IMCR holders are not actually flying in IMC very much. Sorry if you think this is off topic a bit, but I thought it was relevant.

Fuji Abound

1st Dec 2009, 11:39

You seem to be concerned about the utility of this rating, and to be forgetting that it's proposed as a stepping stone to an achievable IR. I've still not fathomed what causes you to be so vehemently opposed to creation of an IR that can be achieved by a similar proportion of pilots as currently hold the IMC rating, but offers privileges that permit them to maintain the sort of currency that permits safe instrument flight.

If it is an effective stepping stone then my opposition will diminish. Do we know that it will be?

If existing IMCr holders that have invested time and money achieving the rating are protected in terms of their existing priviliges my opposition will diminish. Stripping pilots of existing priviliges sits very uncomfortably for me as much as any retrospective changes in the law.

or IMCR holders are not actually flying in IMC very much.

I think IMCr holders fly in IMC to the extent that befits their experience which means, as I indicated earlier, they do a very good job of self regulation. Perhaps we would agree that self regulation is the key. An IR holder however much better trained might be equally foolish to fly an approach to minima if he is not current. In the same way an IMCr holder will doubtless apply the recommended higher approach minima unless he is satisfied he is current and has accumulated the experience to enable him to do so safely.

Doesn't pushing a whole class of competent instrument pilots below a particular class of airspace for arbitrary reasons "simply encourage a load of pilots to perform made up descents outside CAS and among other things make the big sky more than a little bit smaller"?

Yes, a very sound point. I agree.

However, as you know the IMCr was formulated around UK airspace and to meet the needs of UK pilots to fly what are usually relatively short sectors between smaller airports. As we all know climbing into CAS and following pre-defined routes often confers no advantage in these circumstances.

In other words the IMCr was and is an effective solution to a problem whereas the EIR may be a solution looking for a problem.

Brendan Navigator

1st Dec 2009, 12:02

TAF LKPR 301100Z 3012/0118 04004KT 9999 SCT036 BECMG 3013/3016 18010KT BECMG 3022/0101 31010KT 9000 -RA SCT014 BKN020 TEMPO 0101/0118 4500 RA BR BKN014 PROB30 TEMPO 0101/0108 2500 RA BR BKN009

And see that as long as you plan to get to Prague before 01Z tomorrow you are OK (using the FAA rules for determining 'guaranteed VFR')

I think that this debate and especially the above statement shows that quite a lot of training is going to be required before anyone is let loose with an EIR.

I can not see how arriving at "01z tomorrow" based the above TAF would in any way permit VFR in a class D zone plus or minus 1 hour. If one is being relatively conservative one would say that the general deteoriation in the weather starts at 2200z and thus one would have to plan to be there by 2100z.

As I understand the proposal it is for VFR departure, IFR enroute and VFR approach and landing phases. Therefore, at departure, destination and alternates the visibility will have to be above the minima for VFR and the ceiling above the minimum enroute IFR level.

Therefore, the idea is based on our friend inbound to Bournemouth using what is common elsewhere in Europe -

GABCD request descent to 3000ft.

GABCD is VMC request cancel IFR.

GABCD IFR canceled at 1230 report Hengistbury Head VFR for joining instructions.

As I understand the EIR it is simply permitting those pilots that currently fly VFR on top to be able to fly IFR in the middle part if they choose / if weather / airspace dictates. Therefore, I believe that the minima required +/- 1 hour of ETA will be 5Km and ceiling above minimum IFR altitude or perhaps a blanket 3000ft AAL.

What has not been spoken of yet is what equipment would be required for enroute IFR flight. The nav equipment required for IFR flight today is mostly made up of landing aids and as far as enroute is concerned, a Garmin 430 would be suficient for most if not all enroute flying.

Thus a typical UK flight would be depart Compton Abbas, climb to 2300ft (min IFR level) + in VMC VFR. Then request IFR Airways join at SAM FL60 (by this time VMC on top) and route Airways to the CI CTR entry where at an appropriate time the aircraft can descend IFR to the minimum level and when VMC cancel IFR and proceed (in this case) Special VFR to the appropriate VRP.

That is an improvement over what the current IMC holder has to do - remain below the airway and be special VFR from the zone boundary.

Fuji Abound

1st Dec 2009, 12:20

Thus a typical UK flight would be depart Compton Abbas, climb to 2300ft (min IFR level) + in VMC VFR. Then request IFR Airways join at SAM FL60 (by this time VMC on top) and route Airways to the CI CTR entry where at an appropriate time the aircraft can descend IFR to the minimum level and when VMC cancel IFR and proceed (in this case) Special VFR to the appropriate VRP.

Hence my point - pilots descending outside of CAS and probably with no radar cover to break cloud at some height of which they have no certainty (the best they can do is assume the base will be the same as the nearest METAR or ATIS) unless of course they only fly when their departure and arrival are CAVOK - not many of those days around these parts I am afraid, but it should be OK UK to the South of France. I am looking forward to the hords of pilots doing that trip. :) Sorry, but it is not going to happen, hence my earlier comment - simply a solution looking for a problem that doesnt exist! :) :)

The real problem is pilots want to fly form Lydd to Bournemeouth (well maybe not Bournemouth but since it was part of our earlier discussion) for a bacon buttie or to meet up with their mates - they want to fly when there is cloud between 1,500 and 3,000 and they want a nice an easy approach at each end with a cloud break a comfortable way above the deck. They dont mind too much if there is no formal approach in the ATZ as long as they can tell all and sundry they are overhead and descending through IMC for a visual circuit, but they would prefer some sort of IAP. They know it is not for now, but they think the Authorities will be looking to the future becasue they have heard of GPS and even EGNOS, to the day when every grass patch can have its own GPS letdown that will safely guide them to 800 feet for a visual approach. Ideally they want to cruise along in the sunshine above a messy cloud layer that so often characterises these shores but is otherwise pleasantly benign and not the sort of stuff you really want to be beneath. I reckon there are a few pilots who want the same thing in Northern France - but who knows, that is another story. It is not rocket science. If they get that in some form which doesnt involve them spending three weeks at Oxford learning stuff they already know or dont need to know then I guess they will be happy.

Some of them have been doing this stuff for years. They arent going to be too happy when they are suddenly told they cant - well they cant without spending a significant sum of money. Some, maybe a lot, will just keep on doing it with descents outside CAS or the ATZ. Some, maybe quite a few, will give up. I suspect a few, a very few will toddle off to Oxford. It saddens me we encourage people into illegality, or to give up, or to do something unsafe because it is the only option, or to spend more money to do somehting they are already doing safely - that is the only reason I write about it. 5 of my mates all have IMC, they all use the IMC as I have described, none of them want to do an IR, not least becasue they really havent the time or inclination. Are these 5 the exception or do we all know a pilot or two in this baot?

Seems to me that is definitely not what they will get with the EIR.

IO540

1st Dec 2009, 13:45

Worth mentioning that the claim of there having been just one fatal accident involving a pilot exercising the privileges of the IMCR came from the then head of licensing of the CAA, at a CAA/EASA conference c. 1/2008 where I was present and was taking detailed notes.

The claim did suprise a lot of people but nobody I came across was able to categorically refute it.

The CAA man said they went through the accident records back to the start of CAA records. I don't recall how far back it was.

I suppose one could arrive at different figures according to the criteria used. For example a fatal crash of an IMCR holder flying VFR would not count. Similarly for an IMCR holder flying an unpublished approach. Similarly for an IMCR holder flying an ILS in France. Similarly if the IMCR was lapsed. The only thing that would count would be a valid IMCR holder flying a published IAP in UK airspace, overtly under IFR.

A part of the lack of official data on the accident rate of the IMCR (safety = no accidents = no data!! :) ) is that once you get the IMCR, you renew it every 25 months with an instructor but he just signs your logbook; no paper is returned to the CAA. So the CAA has no good data on how many valid IMCR holders there are. They do know that something over 20,000 (the figure was mentioned at the conference) were issued in total since c. 1969.

My guess, from speaking to pilots at random and knowing (also from the CAA) that about 20,000 UK pilots have valid medicals and presumably are doing some flying) is that a few thousand are currently valid.

Every year, loads of VFR pilots kill themselves doing all kinds of stuff, some in IMC. But it is very very rare to hear of a PPL+IMCR killing himself by bodging an IAP, or in a CFIT.

It doesn't matter how you look at it or what assumptions you make; the accident rate of IMCR holders (once you exclude irrelevances like somebody killing themselves flying illegal IFR outside the UK, which frankly is done by plenty of VFR pilots too) does appear to be very very good.

One could argue, and I would agree, that the good safety record of the IMCR is due to much of the UK being relatively flat i.e. not Switzerland, or Nepal :)

But it is just possible that the stats are actually telling us that the level of flying competence required to deal with IFR is much lower than the regulators keep pretending ;) And I would be the first to agree with that. My son could fly an ILS on the sim at 12 and has flown a number of them on the bigger CPL training sims at flying exhibitions. And any monkey can fly headings and levels in IMC - assuming a level of cockpit automation appropriate to real-world IFR flight.

mm_flynn

1st Dec 2009, 19:00

Worth mentioning that the claim of there having been just one fatal accident involving a pilot exercising the privileges of the IMCR came from the then head of licensing of the CAA, at a CAA/EASA conference c. 1/2008 where I was present and was taking detailed notes.

Fuji, you damage your cause with bogus statistics
The claim is frequently made that the IMC rating is unsafe. Ultimately what do we base our asessment of safety on? Accidents and incidents? The accident record speaks for itself so is worth repeating. The incident record is not known so we cant report on the record. How else would you prefer to confront the accusation that the rating is unsafe?

Given IO's comment I understand why you keep repeating the statement. HOWEVER, check some facts as the CAA man was wrong - the accident record does not speak for itself - an assertion devoid of fact is being made.

From the latest 10 year safety analysis published by the CAA.
AAIB Bulletin No: 4/2002 Ref: EW/C2001/2/5 Category: 1.3
Aircraft Type and Registration: Rockwell Commander 114, G-LIMA
current IMC rated pilot in the UK, the aircraft was seen diving out of the bottom of a snow cloud, pulled up and its wing fell off

AAIB Bulletin No: 1/2000 Ref: EW/C99/4/3 Category: 1.3
Aircraft Type and Registration: Mooney M20J, G-BIWP
Current IMC rated pilot in the UK. After suffering an engine failure enroute, the aircraft lost control and spun out of the bottom of the clouds.

AAIB Bulletin No: 9/99 Ref: EW/C99/2/3 Category: 1.3
Aircraft Type and Cessna 172M, G-BXLJ
The pilot IMC current (not flown in 4 weeks so flying with CPL AFI - no IR), CFIT in IMC conditions in the UK.

So there are three fatal accidents in the last 10 years with IMCr pilots, in the UK, with the rating current, reasonably in IMC conditions - 2 of these are basic accidents - 1 of had the engine failure contribute (which in detail appears to have resulted in a slow decay in airspeed, the trim running to hold altitude until the aircraft spun in)

So the recent fatal rate is either 2 or 3 /10 years. Which is 8-12x Higher than you are claiming Fuji.

You are just giving the anti- IMCr argument on opportunity to discredit your safety argument by showing you are grossly wrong on the fact (1 in 40 years is clearly not true).

A much stronger argument is - there are no approach accidents involving IMCr holders (there is only one approach accident in the entire 10 year period within the UK -that was a CPL/IR continuing descent into the water ).

An even more relevant argument is there are lots of CFIT/LOC accidents that kill people who only have a standard PPLs after inadvertent encounters with IMC and the IMCr seems to make this rate much lower in the UK than the rest of Europe. I am not against the IMCr (I think it is a sensible answer for the UK), just don't build an argument on demonstrably false numbers.

Fuji Abound

1st Dec 2009, 20:46

MM_Flynn

Your argument is sound and your observation about accidents during an approach is very relevant.

G-BIWP

The aircraft had climbed through the cloud and was in VMC above a cloud layer.

G-BXLJ

The pilot who hired the aircraft had not flown since 28 November 1998; consequently the AFI accompanied him in order to satisfy the operator's 4 week currency requirement. The AFI not surprisingly was recorded as the Commander and he also held a CPL. It is not known whether the aircraft was above the tops or not.

G-LIMA

I understand this is the accident referred to by the CAA.

Italics = quote from the AAIB report.

I am not sure your assessment of these accidents is quite as sound for the above reasons. Unless there are any more of which you are aware perhaps the CAA are correct.

IO540

1st Dec 2009, 21:09

I too think some of those accidents should not be counted, but really one is splitting hairs trying to dig up a few deaths incurred during IMCR-privilege flights, against the vastly greater number of deaths incurred during "VFR" ;) ;) flights, many of which ended with some "IMC event" leading to less than controlled flight to somewhere below the ground level.

It is also pointless to argue this because Europe is not going to accept the IMCR, no matter what. France possibly might be OK (their extensive low level Class E is perfect for it) but nobody else.

The real argument is whether the requirements of the IR can be set much lower than they are.

There is no doubt they can be...

Unfortunately that line is a total loser for private IFR because any competency differentiation between the 'professional IR' and a 'private IR' would most likely lead to a ban on private IFR in a lot of places. The greatest weapon private IFR has against the gold plating elitists is "we passed the same IR checkride as the ATPL flying your 737".

Never forget that much of Europe has virtually zero GA (not counting people with lawn mowers strapped to their back, and the microlight scene) and its regulators couldn't care less for GA. They are, almost to a man, ex military (remember that most of the world is run by military dictators, actually or de facto), or ex ATC and these are highly elitist and rule-based professions.

Yet we want to be able to fly there, and overfly it.

So the only options for making the IR more accessible (like the FAA one is in the USA) are

- reduce the theory content (this is reportedly happening in the EASA IR)

- reduce the minimum dual training time i.e. go for demonstrated competence; ICAO is a friend here with its 10hrs min requirement (this is also reportedly happening in the EASA IR)

- take the IR flight training out of the professional school arena which is currently mandatory (I am not sure any progress has been made on this, due to FTO industry protectionism)

- take the IR theory training out of the professional school arena which is currently mandatory-attendance (this I believe will be in the EASA IR i.e. self study permitted)

- take out the Class 1 audiogram and go for Demonstrated Ability which is what you get anyway on all medicals after the Initial one :ugh: (this is not going to happen because medical departments in the CAAs rule more or less absolutely)

Give it a few years and then see.

In the meantime, get the FAA PPL/IR, buy an N-reg plane and enjoy at least a number of years of freedom :) That's what I have been doing, along with a few thousand European pilots.

mm_flynn

1st Dec 2009, 21:27

G-BIWP

The aircraft had climbed through the cloud and was in VMC above a cloud layer.

The fact the aircraft was likely just above a cloud layer at the time and the fact that managing a power reduction sometimes causes people to loose control even in VMC is the reason I was equivocal on this one.

G-BXLJ

The pilot who hired the aircraft had not flown since 28 November 1998; consequently the AFI accompanied him in order to satisfy the operator's 4 week currency requirement. The AFI not surprisingly was recorded as the Commander and he also held a CPL. It is not known whether the aircraft was above the tops or not.
It was bloody careless to hit the top of a mountain shrouded in fog if they were above the tops. My understanding is a British CPL w/o an IR effectively has an IMC - so two IMCr pilots are in this aircraft - one of them was flying.

My point is not to debate the details of exactly what should or should not count - more to provide some facts for others to judge the 'only 1 accident in 40 years claim'. I find it surprising that the only accident the CAA are aware of happened in the most recent 10 year analysis - particularly as contributor Pace says his IMC rated friend died in IMC in the previous 10 year analysis. I have not analysed accidents in the period 10-40 years ago.

I do overall agree the IMCr in the UK is not dangerous, is overall a benefit to pilots and the European training requirements for an IR are excessive.