"I have to say, I think this is incredibly sad. Fully grown men (I presume) banging heads and trying to score points rather than co-operating over trying to establish the truth of the matter - and to all of us who have an IMC, and are current, this matters - a lot."
I am so glad at least someone is prepared to take a sensible stance! Thank you.
I don’t suppose I will get the PM from DFC anyway.
However it would seem that DFC has received in writing contradictory advice from the CAA.
I have therefore written to them again asking them how the reply they sent to me can be promulgated. I shall let everyone know what reply I receive.
"Why ? The CAA are the undisputed fount of UK aviation knowledge in most people's eyes. Hauled into a court, I would unhesitatingly argue that the "test of the reasonable man" would confirm this, and that basing my interpretation of a very badly worded sentence on an authorised and verified source within the CAA would seem an extremely sensible thing to do !"
Actually FF I do agree with you. As I think I said previously in the event of proceedings on any matter, not just this, I suspect the judge would find a letter from the CAA as pretty persuasive - moreover, you cant quite imagine the CAA mounting a prosecution against a position they had outlined.
So far as the reminder concerning the design of the IMCR is concerned this is all pretty dull - I made this point pages ago and we all know the CAAs stance on this one. I agree with their stance and have always said so. That however is not the issue.
Some other examples that might be equally justified:
The PPL is not designed from a six hour cross country trip through Europe,
The driving license is not designed for the just qualified driver to do six hours on European motorways,
and most importantly,
The IR is not designed for a pilot who is not current to undertake the same flight as a pilot with an IMCR who is very current.
What really must not be forgotten in all this is that the IMCR was originally introduced by some very wise people who realised that in this country a private pilot is safer if he can undertake training ro enable him to fly in marginal weather. I think we all agree the training is not as comprehensive as for a pilot with an IR. We may even agree there is a big disparity between the training for an FAA and our IR in so far as the private pilot is concerned.
However training can mean very little in terms of developing skills, and I think the CAA rightly recognised this in drafting the legislation and supplying the interpretation they have and are able to see past the vested interest of some instructors and the training industry.
Why.
Find me a doctor, a lawyer, a dentist, or a Corgi gas fitter who is not better at his job than when he passed his exams. Yes I know there are a few that are worse! However in the vast majority of cases they are far better because their skills and practical application has improved with use and currency just as is the case for an IMCR holder who uses the qualification regularly. In fact be in no doubt they are significantly better than some IR holders I have flown with who are not current!
I recall well when a pilot with 600 hours to his credit (I think it was 600 hours) enjoyed some significant exemptions with regards IR training. It was in my opinion a retrograde step when that was changed.
Not only do I not agree with DFC proposed changes but I have a few of my own.
Firstly the legislation works perfectly well as it stands. In my experience instructors are very good at emphasising the need for caution to IMCR pilots. Secondly when pilots end up flying hard IFR sectors it is for one of two reasons - they have misinterpreted the weather or feel they are sufficiently current to undertake the flight. I don’t have proof, but how many IMCR holders who are current do you hear getting into trouble and how many accidents can you point to? (And I do read all the published accident reports every month). For those that have misinterpreted the weather, unfortunately that is always going to happen - it is the biggest reason pilots get into trouble and has nothing to do with whether or not they have a current IMCR or a lapsed IMCR.
My own proposals are that a pilot who has an IMCR and 600 hours total time of which at least 100 hours are instrument time, and of which 30 hours are instrument time in the last twelve months should on test by an approved examiner be entitled to be granted an IR restricted to private use. Students would be recommended to undertake a minimum of 10 hours further instrument training before the test but with an absolute minimum of 5 hours further training. If they did not undertake the further recommended training but past the test they should still get the rating!