UK IMC Rating + JAA PPL

[Charley]

Hello all,

Sorry to intrude but am I after some instructor's viewpoints on how useful an IMC rating is to a JAA PPL holder.

I am currently training on my IMC Rating. A few weeks ago, whilst studying the Air Law aspects of the rating, I opened up CAP393 to check on the privileges afforded to the holder. To my horror I read that the benefits of an IMC Rating for a JAA PPL holder are much reduced as opposed to for the holder of a CAA PPL. What I have not yet concluded is whether this is a result of an oversight in the documentation, an error in my interpretation of the rules or a deliberate attempt to make the IMC Rating less relevant to JAA licence holders.

If anybody wants the full SP then I can post the relevant extracts, word-for-word; I wanted to avoid it in this first post so that this didn't become an endless, tiresome post.

Fire away!
Charley

[Aussie Andy]

As someone who just got their JAR-PPL and is planning to embark on IMC course as soon as possible, I too find this alarming! Where do I get CAP393? Is it on the AIS ro CAA websites?

Andy

[Cahlibahn]

I'm intrigued. A quick glance at schedule 8 of the ANO provides:-

CAA
(c) He shall not, unless his licence includes an instrument rating (aeroplane) or an instrument meteorological conditions rating (aeroplanes), fly as pilot in command of such an aeroplane:

(i) on a flight outside controlled airspace when the flight visibility is less than 3km;

(ii) on a special VFR flight in a control zone in a flight visibility of less than 10 km except on a route or in an aerodrome traffic zone notified for the purpose of this sub-paragraph; or

(iii) out of sight of the surface.

(f) He shall not, unless his licence includes an instrument rating (aeroplane) or an instrument meteorological conditions rating (aeroplanes), fly as pilot in command or co-pilot of such an aeroplane flying in Class D or E airspace in circumstances which require compliance with the Instrument Flight Rules.


JAA
b) subject to paragraph (c), entitle the holder of a JAR-FCL Private Pilot Licence (Aeroplane) to fly as pilot in command of an aeroplane in Class D or E airspace in circumstances which require compliance with the Instrument Flight Rules.

(c) the holder shall not fly:

(i) on a special VFR flight in a control zone in a flight visibility of less than 3 km;

(ii) when the aeroplane is taking off or landing at any place if the flight visibility below cloud is less than 1800 metres.


I can't see the difficulty, but I am notoriously stupid :confused: so please explain further, Charley

[ 09 July 2001: Message edited by: Cahlibahn ]

[Charley]

Okay, I'll try to explain my confusion.

It one part of CAP393 it seems to say that a JAA-licenced PPL/IMC can do near-enough the same as a CAA PPL holder. This is the part of Schedule 8 the describes the various licences. However, further into Schedule 8 where it describes the ratings it paints a different picture.

I'm really sorry if this gets tedious, which it might, but here are all the relevant extracts from CAP393.

Firstly,

{CAP 393 / Section 1 (The Air Navigation Order 2000) / Schedule 8 (Flight crew of aircraft - licences and ratings) comprising Articles 22 through 26 inclusive / Part A - Licences / Section 1 - United Kingdom Licences / pages ANO Sect 1/171 & 1/172 (both Aug 2000)}

From Private Pilot's Licences (Aeroplanes);

Privileges:

{...}

2(c) He shall not, unless his licence includes an instrument rating (aeroplane) or an instrument meteorological conditions rating (aeroplane), fly as pilot in command of such an aeroplane:

2(c)(i) on a flight outside controlled airspace when the flight visibility is less than 3 km;

2(c)(ii) on a special VFR flight in a control zone in a flight visibility of less than 10km except on a route or in an aerodrome traffic zone notified for the purpose of this sub-paragraph; or

2(c)(iii) out of sight of the surface

2(d) He shall not fly as pilot in command of such an aeroplane at night unless his licence includes a night rating (aeroplanes) i.e. the CAA rating or a night qualification (aeroplane). i.e the JAA 'rating'

2(e) He shall not, unless his licence includes an instrument rating (aeroplane), fly as pilot in command or co-pilot of such an aeroplane flying in Class A, B or C airspace in circumstances which require compliance with the Instrument Flight Rules.

2(f) He shall not, unless his licence includes an instrument rating (Aeroplane) or an instrument meteorological conditions rating (aeroplanes), fly as pilot in command or co-pilot of such an aeroplane flying in Class D or E airspace in circumstances which require compliance with the Instrument Flight Rules.

{...}

This covers the CAA licence. Further on, the JAA licence is covered fairly similarly.

{CAP 393 / Section 1 (The Air Navigation Order 2000) / Schedule 8 (Flight crew of aircraft - licences and ratings) comprising Articles 22 through 26 inclusive / Part A - Licences / Section 2 - JAR-FCL Licences / pages ANO Sect 1/181 & 1/182 (both Aug 2000)}

From Private Pilot Licence (Aeroplanes);

{...}

2(a) The licence is subject to the conditions and restrictions specified in paragraph 1.175 of JAR-FCL 1.

2(b) The holder shall not, unless his licence includes an instrument rating (aeroplane) or an instrument meteorological conditions rating (aeroplanes), fly as pilot in command of such an aeroplane:

2(b)(i) on a flight outside controlled airspace when the flight visibility is less than 3 km;

2(b)(ii) on a special VFR flight in a control zone in a flight visibility of less than 10 km except on a route or in an aerodrome traffic zone notified for the purpose of this sub-paragraph; or

2(b)(iii) out of sight of the surface.

2(c) The holder shall not, unless his licence includes and instrument meteorological conditions rating (aeroplanes), fly as pilot in command or co-pilot of such an aeroplane flying in Class D or E airspace in circumstances which require compliance with the Instrument Flight Rules.

2(d) The holder shall not fly as pilot in command of such an aeroplane at night unless his licence includes a night rating (aeroplanes) or a night qualification (aeroplane).

{...}

The preceeding definition describes the JAR-FCL licence. Notice also, aside from my IMC gripe which I will come to, that this seems to prohibit PPL/IR holders from flying in Class A (airways) or B (upper airspace) due to the exclusion of a clause similar to that of (e) in the CAA bit........

Anyway, I digress. This gives you the full, legal definition of the privileges for the CAA and JAR-FCL PPLs respectively. Onwards now to the Ratings section.

{CAP 393 / Section 1 (The Air Navigation Order 2000) / Schedule 8 (Flight crew of aircraft - licences and ratings) comprising Articles 22 through 26 inclusive / Part B - Ratings / page ANO Sect 1/187 (August 2000)}

Instrument meterological conditions rating (aeroplanes) shall within the United Kingdom:

(a) subject to paragraph (c), entitle the holder of a United Kingdom Private Pilot's Licence (Aeroplanes) or a United Kingdom Basic Commercial Pilot's Licence (Aeroplanes) to fly as pilot in command of an aeroplane without being subject to the restrictions contained respectively in paragraphs (2)(c) and (f) of the privileges of the United Kingdom Private Pilot's Licence (Aeroplanes) or (2)(b)(vii) or (xi) of the privileges of the United Kingdom Basic Commercial Pilot's Licence (Aeroplanes).

(b) subject to paragraph (c), entitle the holder of a JAR-FCL Private Pilot Licence (Aeroplanes) to fly as pilot in command of an aeroplane in Class D or E airspace in circumstances which require compliance with the Instrument Flight Rules.

(c) the holder shall not fly:

(c)(i) on a special VFR flight in a control zone in a flight visibility of less than 3 km;

(c)(ii) when the aeroplane is taking off or landing at any place if the flight visbility below cloud is less than 1800 metres.

Here lies the crux of my problem. The definition of the rating itself does, for the CAA holder, specifically say that he can fly without the restrictions specified in paragraphs (2)(c) and (2)(f) of the licence definition. The definition of the rating for the JAA holder does not make a similar exemption.

I guess it's all down to perception. Perhaps the CAA meant for the IMC Rating to be as valid for the JAA PPL as for the CAA PPL and just messed up the wording; after all, the definition of the JAA licence does say 'unless the holder has an IMC' (sic).

Alternatively, perhaps there is supposed to be a clear gap in the privileges of the IMC Rating when applied to either rating. Clearly there is some inconsistency between the way the licence definition for the JAA PPL references the IMC Rating and the way the the definition of the IMC Rating references the JAA licence.

I'm more than willing (and indeed I hope) to be proved wrong on this one. ;)

[Noggin]

There is an error in the ANO which is waiting amendment. The IMC privileges are exactly the same, irrespecive of whether you have a JAA or a CAA PPL.

The ANO appears to give the JAA licensee IFR privileges in D and E airspace only, F and G have been omitted.

As for an instrument rating: Instrument Rating (aeroplane) shall entitle the holder of the licence to act as PIC or co-pilot of an aeroplane flying in controlled airspace in circumstances which require compliance with the IFR. That means all Classes of Airspace.

The big difference between the CAA and JAA licences is that with a JAA licence you may only fly VFR whereas with a CAA licence you may fly IFR without any instrument qualification provided you fly within the limitations of the licence.

[Charley]

Thanks for the feedback. I'm very glad to hear that I'll still be able to use my IMC effectively when I get it.

Aussie Andy, for info, you can get your hands on CAP393 in the Breifing Office at most larger airfields. Or you can buy a copy from Westward Documedia for about £60, and it's about £30 every year thereafter for the subscription (if I remember correctly).

[Cahlibahn]

Of course rather than fork out £60 you could simply browse your way to http://www.hmso.gov.uk/si/si2000/20001562.htm