PDA

View Full Version : Future of IMC rating?


DBisDogOne
30th Aug 2007, 19:07
I've read and heard various things about the future of the UK IMC rating in the last year or so. I've seen this on various threads but didn't want to hijack them so I'm posting this. My question is 'Is it worth doing an IMC or is it going to be ditched sooner or later?'

By 'ditched' I mean replaced with an IR rating of some description. I know a few of you (notably bose-x) are involved with AOPA(?) steering this in the right direction so I'd like some clarification as to what the situation would be for the holders of an IMC in the new system, ie:Grandfather rights (no new IMCs issued but keep what you've got) or a shed load of expensive training required for all IMCR holders.

The reason I ask is that I'm considering doing one (I already have a night rating) but, while no training is ever pointless, I don't want to spend a couple of grand on a rating that's going to be invalid or invalid without more money spent, in a year or two. I don't bother flying when the wx is possibly going to turn crap, I don't push my luck, so don't want to go the whole hog on an IR but appeciate that for safety, an IMC would be nice.

Any comments from the great and the good (in fact, anyone!) with more definative info than the magazines (contradictory) can give would be welcome.

Blue skies to all
Be seeing you...
dB
:)

Three Yellows
30th Aug 2007, 20:05
I don't have any info about the future of the IMC or the new "IR Lite". But my advice would be to go and do the IMC and then use it regularly.

There seems to be two schools of thought on the IMC, one is to keep it up your sleeve and "it will get you out of trouble", the other is that it regularly enables you to fly in poorer conditions. I'm afraid that not using it regulalry WILL get you into trouble. I use my IMC as much as possible. You have to keep current otherwise in twelve months time when it turns a bit horrible, if you are not crisp, that's when the trouble starts.

Secondly, take Cardiff for example, it has numerous VFR routes in and out. Strangley they aim you straight at some very large TV masts but they expect you to be as low as possible. Going to new airfields for the first time, its not always easy to locate all these VFR reporting points. Programming them all into your GPS is an option, but takes a long time. Why not get the IMC and ask for radar vectors to the ILS? This is all done at a very safe height and once under radar control, they line you up with the runway, couldn't be simpler.

Go and do it, you wont regret it.

gcolyer
30th Aug 2007, 20:54
I think the point in the original question is will the IMC rating still be valid when the "IR lite" comes in to play. What a waste of a few grand if you have to bin the IMC and start again.

Fuji Abound
30th Aug 2007, 20:55
1. As we all know the IMCR is a UK national rating. It is difficult to see how EASA could "withdraw" the rating for those who have obtained the rating but I suppose given the current "proposals" regarding the life long CAA license anything is possible.

2. If they do, the "carrot" maybe to give some credit against the PPLIR, and indeed it has been suggested this will be so.

3. In any event the time would be well spent. In my experience the training given for the IMCR is around 50% of what is required for an IR. I know pilots with an IMCR used regularly which has enabled them to achieve the standard of an IR.

Aside, if IMCR privileges are withdrawn from those who already hold the rating it would be scandalous. We should jump up and down and write to AOPA (who wont do anything) and generally create. Exactly the same is true of those who hold a life CAA license. I have already written in this regard to the CAA and will be writing to my MP if I do not receive a satisfactory reply.

IO540
30th Aug 2007, 21:19
EASA will have the power to stop national licenses and ratings. This is what the UK signed up for, and if you don't like it, it's too late.

Whether they will use this is debatable. IMV there is no chance of them blocking it until there is a similarly accessible replacement. To do so would look terrible on the safety front - forcing a few thousand UK pilots to scud run and to do dodgy VFR approaches.

As to when a replacement will come, that's been done to death here recently. I think it's fair to say nobody really knows.

But I reckon that when it does come, previous instrument training will count towards any minimum flying time requirement.

If I was after IFR capability now, I would absolutely definitely not hang around waiting for some "new IR". I would just get on with it. Any kind of instrument rating is seriously hard work, and having say 50-100 hours under under the IMCR privileges is going to make it far easier than doing it from scratch as a pure VFR pilot. The IMCR is really useful for getting about the UK. The full IR is really for European IFR touring (it's great for that) but to do that you need to have an aircraft access deal suitable for taking it away for decent periods, etc.

If you want to fly IFR for real, instrument training will never be wasted. The only thing which is a bit wasteful is training in a plane that's very different from the one you will eventually be flying. Training in a really crappy C152 with crap avionics is not going to be helpful for flying IFR in something modern. Currency on type is what matters.

Fuji Abound
30th Aug 2007, 21:29
EASA will have the power to stop national licenses and ratings.

I suspect you are correct.

However, I have read comment that whilst they will certainly be able to withdraw recognition outside the UK, it may be more difficult within the UK. Mind you I dont know the basis of this comment and I suppose it may turn on whether the CAA retain any authority over the sovereignty of our airspace (whcih you might expect they would). Whilst this is not a lot of help to CAA lifetime licenses (unless you never intend to fly outside the UK) the IMCR was always a national rating and therefore this element of the restriction would remain unchanged.

BillieBob
31st Aug 2007, 07:04
I suppose it may turn on whether the CAA retain any authority over the sovereignty of our airspace This is the whole point - the CAA will not retain any authority 'over the sovereignty of our airspace' or any other part of flight operations or licensing. Once competency is assumed by EASA, whatever they decide becomes EU law, which supersedes UK law, and is equally binding on all memeber states. Should EASA decide that the IMC rating is to go or that all instructors will be required to hold 'European' licences then that is what will happen, no matter what you, I or the CAA may think about it.

BEagle
31st Aug 2007, 07:41
Watch this space!

I hear that the CAA has just informed the unelected public servants of EASA that it won't take their intention of scrapping National Licences and Ratings lying down. Abolishing 'Grandfather Rights' for the mere administrative convenience of EASA would undoubtedly face legal challenges - and, should EASA then be overruled, they would have a hefty legal bill to face.

IO540
31st Aug 2007, 09:18
There is no mileage for EASA to abolish national licenses. It would achieve exactly nothing and would create an uproar. There are enough hot potatoes for them.

On the same argument there is no mileage in abolishing the N-reg scene.

I guess all this will happen one day but only in the context of a much bigger change, involving a major airspace redesign throughout Europe. At the moment, airspace is a mess.

Fuji Abound
31st Aug 2007, 09:40
the CAA will not retain any authority 'over the sovereignty of our airspace

That is the theory .. .. ..

.. .. .. but wait and see.

sternone
31st Aug 2007, 09:47
Is it worth doing an IMC or is it going to be ditched sooner or later?

I do not see any reason why you shouldn't go for the IR now except money.

You have to many question marks at this moment about a LIR (light instrument rating ?) or MIR (minimum istrument rating?) :)

If you will need to study or train to hard now, i guess you will be happy when your in the coulds sweating your pants off in unexpected bad weather and surviving it due to your intense training.

I myself will immediatly as soon as possible after my PPL go into IR because of the reasons IO540 wrote. Just go for it!

dublinpilot
31st Aug 2007, 10:17
I can't see how EASA could remove the IMC privlidiges for those who already hold the rating, without there being a riot! Has such a thing ever happened wihtout those being affected, being given grandfather rights to something else?

I would say that the three most likely senarios are

1) Those who already old an IMC rating keep the privlidges within UK airspace, but noone new can get the rating, or

2) EASA introduce it's own IMC rating, and UK IMC holders are given a free EASA IMC rating in return for their UK one, or

3) All those with an IMC rating loose the IMC rating and are given a free IR, but with the conditions that it can't be used in class A airspace, can't be used outside the UK and whatever other conditions are required to ensure that it's basically the same as the existing IMC rating.

I think there is plenty of precidents for any of these options, but none for the complete withdrawal of privlidges without any replacement.

If an IMC rating was available to me, I'd do it straight away, and wouldn't be worried about what might happen with EASA. I'd do this because

a) I agree that it would be a good stepping stone to a full IR, and
b) there is a very good chance I'd benefit in some way in the conversion process, and
c) It's an extremely useful rating to have now.

dp

MikeJ
31st Aug 2007, 12:51
In the thread on pilot drop out, IO540 put links to CAA pilot licence and rating statistics. I was staggered to find that until the JAR PPL training requirements came in in 2000, that new IMC rating issues were running steadily at 1000 per year, about 1/3rd of new PPL issues. This compares with an average of just about 40 pa for PPL/IR. As IO said, everything has gone downhill since then.

Doing a bit more reasearch, I have been told that the CAA have issued about 17,000 IMC ratings. There will always be a significant drop out rate in licences and ratings, but I would expect those going the extra mile for the IMCR will be better 'stayers' than basic PPL holders. This could mean that of the 20,000 PPL(A) with current medical, perhaps 50% hold the IMCR, which is a simar figure to the proportion of US PPLs with IR. Certainly every one of my PPL acquaintences at my home base has an IMCR or IR

All of this shows the IMCR to have been an absolute stunning success.
Other threads have commented that 'see and be seen' just does not work well enough. Since 1990 there has been an average of one mid air every two years involving a Group A aircraft, but all are in VMC. Over the last 30 years (I didn't go back further) there has NEVER been a mid air in IMC in uncontrolled airspace involving a light aircraft .
Statistics show that there are 10 times as many airproxs between 0 and 3000ft, as compared with a similar height band 4000 to 7000 ft, where the quadrantals and LARS reign. But even in clear weather, you should have an IMCR or IR to go up there because of the unpredictable British weather at your destination.
The sheer delight of flying on top in silky smooth 'see forever' conditions, compared with grotty bumpy scud running below, just adds to the benefit of it being much, much safer. Despite the very large numbers of holders, there is no record in all the years I have been reading the CAA qrtly Occurrance Reports of anything unsatisfactory in the IMCR. Just as there is no poor record of FAA PPL/IR flying N reg. We just a lot of what IO540 calls 'slagging off' with absolutely no history to justify it.

The actual stunning success of the IMCR should be blasted about as loudly as possible to counter the 'slaggers'.

Reading a report on the PPL/IR Europe website, the work that Bose X and others have been doing so assidously doesn't seem as if it will produce that much improvement to the PPL/IR syllabus, unless Bose knows more. Nowhere near the FAA one. I even heard the other day from someone 'high up' that there is pressure within EASA to abandon the PPL/IR altogether, and make everyone get a CPL/IR to fly in airways.

IO540
31st Aug 2007, 13:46
20,000 PPL(A) with current medical

I don't doubt this, but where did you get this, Mike? It's not on the CAA website, AFAIK.

I agree the IMCR has been a super success. However, a lot of "traditionally minded" gold plated IR holders don't like the fact that the IMCR gives you essentially the same privileges as the full IR, except Class A.

I even heard the other day from someone 'high up' that there is pressure within EASA to abandon the PPL/IR altogether, and make everyone get a CPL/IR to fly in airways.

This is a standard comment, among many similar ones, coming out of the elitist aviation regulatory establishment which (all around Europe) is stuffed with superior ex air force and superior ex national flag carrier airline types. Most of these people have never flown "IFR GA" and haven't got a clue about it.

A requirement for a CPL for airways flight is utter stupidity. You sit there, FL100-150 or whatever, in a great void with no traffic, and you'd be lucky to spot another plane over a 700nm flight.

Last year I went to an event at the West Drayton ATC centre. Interesting it was, but the usual bundle of prejudices came out. According to them, the CAA will ban all single pilot jets. Clearly they thought that there will be 10,000 VLJs flying out of Luton. The good news is that these are just ATCOs who went to some CAA or NATS presentation, and none of the people involved are the real policymakers. Recently, Germany proposed to require an ATPL for any jet - they would have fun squaring that with ICAO. If however one took all this stuff at face value, one would just push one's plane off Beachy Head and take up knitting.

The Americans call this "FUD" - fear, uncertainty, doubt. It takes only one old ex ATP codger somewhere "high up" to start off a rumour like this.

I wouldn't worry about it :)

MikeJ
31st Aug 2007, 14:10
IO,
At end 2005 the number was 20458.
Try http://www.caa.co.uk/docs/175/2005%20Aircrew%20Age%20%20Sex%20Profile%20(Med%20Cert%20Hold ers%20Only)p2.pdf

Fuji Abound
31st Aug 2007, 14:17
I do not see any reason why you shouldn't go for the IR now except money.

I think you may have missed the past discussions.

I suspect for many the money is actually a long way down the list.

At the top of the list would be the huge amount of pointless theory and the essentially class room based strategy to the theory element. Most PPLs (who are really PPLs and not commercial aspirants) neither have the time nor inclination.

i guess you will be happy when your in the coulds sweating your pants off in unexpected bad weather and surviving it due to your intense training.

I am not sure if the inference you intend is the pilot with the IMCR will be the one sweating. I dont think there is any evidence at all for this assertion, if that is what you intend. the safety record of those with IMCRs is very good in the UK amoung a group of pilots who I suspect use their priviliges to varying degrees.

Perhaps to go out on a limb flying light aircraft on instruments is a very practical art. All the theory in the world will only help so far. The IMCR holder is only less well equipted because he has less hours in IMC and the standards required of his flying are to a lower tolerance. The fact that he has to understand this is the case is no different than the PPL who has just qualifed and would be at risk if he flew in conditions with which he could only cope when he had a few hundred hours more to his credit.

I have said it before, but I will say it again, if the IMCR is abolished on the back of an IR light that is little removed in achievability from the existing IR avaition safety in this country will have suffered its greatest below yet. The authorities will be culpable, we should all write to our MPs and hopefully AOPA will finally wake up and actually do something about it.

IO540
31st Aug 2007, 15:05
i guess you will be happy when your in the coulds sweating your pants off in unexpected bad weather and surviving it due to your intense training

Hardly. One is only as good as one's recent currency on type.

Training which one got some years ago is almost irrelevant.

On the Spot
31st Aug 2007, 15:21
Why not go the commonly used FAA IR route and get your IMC on the back of that. The FAA IR seems to be fairly stable, reasonable to achieve in both cost and requirements plus it gives you an additional avenue of use if you so choose

gcolyer
31st Aug 2007, 15:31
Why not go the commonly used FAA IR route and get your IMC on the back of that. The FAA IR seems to be fairly stable, reasonable to achieve in both cost and requirements plus it gives you an additional avenue of use if you so choose


So you mean to say If I add an FAA IR to my FAA piggy backed license I can then get a UK IMC based on my FAA IR :bored:

If thats the case sounds good to me.

Then my next question would be how easy would it be to transfer an FAA IR from my piggy backed FAA PPL to and FAA CPL when I get it?

On the Spot
31st Aug 2007, 16:25
That is exactlly what I intend to do at the appropriate point in time that I decide to shell out for a JAA medical and revalidate my CAA PPL. For the moment I am happy and able to move around solely on my FAA PPL and $50 medicals.

Assuming you got it attached to your PPL SEL I believe you would have to retest, rather than retrain, the IR anyway for class of aeroplane you are flying (ME for instance) and Licence to which it is added i.e. CPL when you get to that point. Retest if reqd is simple as it requires 3 hours instrument instruction in the preceeding 90 days and an FAA instructors endorsement to sit the test.

The training for the initial IR is more than the IMC :- 40 hours instrument or simulated instrument time, inc 15 hours instruction and 3 of those in the last 90 days. But at US prices I don't think the difference is significant.

IO540
31st Aug 2007, 16:43
Why not go the commonly used FAA IR route and get your IMC on the back of that. The FAA IR seems to be fairly stable, reasonable to achieve in both cost and requirements plus it gives you an additional avenue of use if you so choose

Indeed; the only issue is that for the IMCR you need a valid UK PPL (plus the CAA medical, etc).

You also need an FAA IR IPC in the past 2 years; the CAA reportedly does not issue the IMCR on the basis of the rolling FAA IR currency.

Another thing is that the FAA IR is a reasonable stepping stone to a JAA IR. You "just" have to sit the PPL subset of the JAA ATPL ground exams (about 10 of the 14) and do the checkride. The UK CAA also requires 15hrs of flight training in this case but some/most other JAA states don't.

If you have a FAA PPL/IR and get the FAA CPL, then you immediately have an FAA CPL/IR. This is what I did. There is no IR re-test. The FAA CPL is a VFR-only thing. There would be an IR re-test for ME, of course.

It's only the ATPL which has additional and tighter instrument requirements but that's not too hard to do either - just one written exam. The catch with an ATPL is that you need 1500hrs and this has to include ~ 100hrs at night, etc.

However, there is no practically relevant context in which an FAA CPL/ATPL is of any use in European airspace. Every European country has protectionist legislation banning commercial ops on foreign licenses (or foreign reg aircraft). AFAIK the only use of an FAA CPL in UK airspace is that you can be a paid company pilot, contractually required to fly the company's plane on company business.

Gertrude the Wombat
31st Aug 2007, 18:50
But at US prices I don't think the difference is significant.
In coming to that conclusion, how much are you reckoning for lost income due to spending weekdays in the USA and therefore not earning (compared to zero lost income doing the IMCR in the UK at weekends)?

IO540
31st Aug 2007, 21:05
My inclination, having done the IR in the USA, is to treat the US option as a device for completing the "IR project" and not as some open ended adventure where you learn to fly on instruments.

For a VFR-only pilot, instrument flight is usually quite hard to start with. A monkey can learn to fly straight and level in IMC, but doing other stuff at the same time quickly reaches the brain capacity. I would recommend getting through this stage in the UK first and not going to the USA until one more or less knows what one should be doing. The US is not the place to be doing ground school type of stuff. Then the 2-3wks spent there is mostly a "consolidation" thing, but, trust me, it won't be a walkover.

BillieBob
31st Aug 2007, 22:16
I hear that the CAA has just informed the unelected public servants of EASA that it won't take their intention of scrapping National Licences and Ratings lying down.That may be so but, in the brave new world of EASA, the UK is but one voice among 27, and is the only one that has national licences. Whilst it would be comforting to believe that we have a significant influence in the affairs of the United States of Europe, the fact is that our influence is about as significant as Rhode Island's (or maybe Vermont's) in the affairs of the USA.

By all means, as Fuji Abound suggests, 'wait and see' but, of course, by then it will be too late.

IO540
1st Sep 2007, 05:03
and is the only one that has national licences

I know for a fact (from a friend who has one) that Switzerland is still running a pre-JAA national license. And there are going to be others too.

The UK (CAA) is a powerful player in EASA. France and Germany are others. Most of the rest of the EU barely participates. The UK will have a big say - this is a good thing in this case; it is a bad thing in others because it will hold back modernisation on things like the proposed EU-wide PPL with a possible IR which is scaring the national CAAs to death.

tmmorris
1st Sep 2007, 08:40
gcolyer,

You need to convert your piggy-back FAA PPL to a standalone first. The piggy-back one will only contain ratings held on your JAR/CAA one at the time of issue, and no further ratings can be added.

Tim

dublinpilot
1st Sep 2007, 09:15
Tim,

That's totally incorrect. A piggy back PPL is a real licence, and you can add FAA ratings to it, just like any other FAA PPL.

dp

tmmorris
1st Sep 2007, 10:30
You are right, and I sit corrected. Though I am sure I read that somewhere when I got my piggyback FAA licence.

FAR 61.75 (c) states

(c) Aircraft ratings issued. Aircraft ratings listed on a person's foreign pilot license, in addition to any issued after testing under the provisions of this part, may be placed on that person's U.S. pilot certificate.

(my italics)

which does indeed indicate that you can have an IR added to a piggyback license.

Tim

DBisDogOne
3rd Sep 2007, 13:48
Thanks for all the info chaps, it's pretty much as I'd suspected though, the usual political balls-up/vested interests etc. taking priority. Still I think I'll do my IMC anyway and hope for the best in the future. Also, agree completely with the point a couple of you made about staying current, an instructor friend commented that any IR was very much 'Use it or lose it'.

Continuing VMC to all.
Be seeing you...
dB

ThePirateKing
3rd Sep 2007, 21:35
There is one difference between the IMCR and anything based too heavily on a full ICAO IR (and this also covers the oft-touted FAA IR route too)...

The IR requires good colour vision and the IMCR does not.

It would be a shame if the Eurocrats decide to swap one for the other believing the training to be substantively the same (as if they'd actually care about that) only to discover that some Colour Vision Defective (CVD) pilots are suddenly excluded.

...but I have no doubt that's exactly what will happen.

S-Works
3rd Sep 2007, 21:53
There will never be an IR "Lite" as long as controlled airspace is the home of CAT. The airlines would ensure that any attempt to allow lesser qualified individuals to inhabit the rarefied air is quashed.

I have no doubt that EASA will attempt to get rid of the IMCR along with other national ratings. This was made clear to us last year and sparked a whole round of debate on here and flyer when I suggested it. However our CAA are committed to keeping the national ratings and will not go down easily so there is still hope.

What we have tried to do and are continuing to work on is a more accessible IR. One that has theory that is valid for flight under IFR in CAS without all of the extra stuff that is type rating specific. To this end a reduction on TK requirements, easier exam access, fewer exams and no compulsory ground school have been recommended. We have proposed a modular training programme for the IR with easier access to testing rather than CAA office hours only and use of the BIF 10hr module to count towards the IMCR and vice versa.

There are other proposals being made around the IMCR that we will be able to discuss in due course.

I do have great sympathy for those with hearing and colour problems, but they are truly in the minority and it is difficult to build changes around such minority needs. Harsh but true.

Whichever way we look at it there are going to be significant changes in the next few years, some good and some bad. Now is the time for us in GA to try and influence our own future.

Fuji Abound
4th Sep 2007, 07:33
There will never be an IR "Lite" as long as controlled airspace is the home of CAT. The airlines would ensure that any attempt to allow lesser qualified individuals to inhabit the rarefied air is quashed.

I have never understood this. If an IR(light) were anything like an IMCR, an IMCR already enables pilots to operate in class D in IMC to the same landing minima as an IR holder. They are as we know excluded from class A.

Were they to be permitted to operate in class A, their operations would all be in the lower airways, which in Europe is rather like marching through a desert, you will not see another sole for hundreds of miles.

So in reality the only points of conflict between CAT and GA would be in the TCA were the traffic is joining class D. For those with just an IMCR the traffic is already there and with a great proven safety record.

If CAT were really that bothered the IR(light) rather than being restricted to airspace class, would be restricted to altitude.

Whether Euro control wants GA causing more delays within the system may be another element.

The fact of the matter is the existing system is seriously flawed. It also seriously degrades the safety of the system for all users. If you are involved with the regulatory policy making, you know it, shame on you for not doing something about it.

S-Works
4th Sep 2007, 07:58
Fuji, I could not agree with you more. I merely stated the facts. I know the lower airways are empty, I spend a significant amount of my time in them.

You are not looking beyond the end of your nose I am afraid. You are right the IMCR does allow access to Class D airspace under IFR. However this is in the UK only and in reality that is actually not many places. The vast majority of IMCR flight is outside of CAS.

You may think that the IMCR traffic and the CAT traffic are sharing the same space but in reality this is not the case. There are actually few IMCR pilots who are really doing true IR type Instrument flight and thats because there are so few properly equipped aircraft. The controllers are careful to keep this limited volume of traffic separate and the performance of modern CAT is such that they are out of the Terminal area and into the lower airways very quickly. Following that they are then fed into the jet routes and are gone. If you increase the number of people who can leave a terminal and enter the lower airways you are increasing the risk and this is where the standards have to be kept.

I am looking at the bigger picture and opening up Europe to "IR Lite" pilots is a major concern to the airlines and naturally if they are going to share airspace then everyone has to be trained to the same minimum standard. So what we have tried to do with the working group is ensure that the minimum standards are met to the satisfaction of all, remove the superfluous TK and put it where it belongs in type ratings and make the training more accessible for the full IR. This ensures the airlines have nothing to complain about.

I am involved with the regulatory policy making in representing YOU the private pilot not the airlines or CAA. But I would be a very poor representative if I did not look at all the arguments. The fact is that the average IMCR flies to a pretty shocking standard and is not current. By current I mean has flown approaches with the last couple of weeks to a high standard. I also find that the average IMCR holder is unable to sustain accurate flight on Instruments for long periods or time or is reliant on an AP. When you enter the airways system you are committed to Instrument flight for the entire duration. Further to that the average spam can is just not equipped for airways flight. You need a full WORKING compliment of steam gauges and GNSS capability so a panel mount GPS with current database. I don't see many flying club hacks or even syndicate aircraft to this standard. It is mostly private owners who are serious about IFR flight and they are the ones who go out and get an IR.

What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.

Fuji Abound
4th Sep 2007, 08:40
You are not looking beyond the end of your nose I am afraid.

You are correct. The IMCR is a unique rating not understood in Europe. I was not intentionally falling into this trap, merely seeking to demonstrate what many years of experience with the IMCR has shown. If the regulators, airlines or those involved promoting change ignore the evidence they do themselves and those they represent a disservice.

There are actually few IMCR pilots who are really doing true IR type Instrument flight and thats because there are so few properly equipped aircraft.

Yes, but that is the point. If the aircraft is not equipped to fly in CAS then it doesn’t matter what rating the pilot has, the aircraft cannot be flown in CAS. Indeed some of the aircraft I fly whilst in theory they could operate in the lower airways don’t have the performance that would make me feel comfortable doing so. On the other hand, with a twin fitted with a G1000 arguably I am better equipped than some CAT, if a bit light on performance!

If you increase the number of people who can leave a terminal and enter the lower airways you are increasing the risk and this is where the standards have to be kept.

Sorry, I don’t follow this argument. Firstly, as you have already alluded most GA operates outside of CAS. Their typical missions will continue to between small airports, which if they have any commercial traffic at all will be limited in number. Airway joins would more often than not be well below the operating height of CAS as would their release from CAS.

I appreciate there would be some users who would operate to or from the larger commercial airports. I have spent a reasonable amount of time being vectored around CAS - arguably more demanding on the pilot that arriving off a STAR. AT has no idea whether the pilot has an IR or an IMCR, although they might be able to guess in a few cases by the standard of their RT. In that time I have seen little evidence of the performance of those pilots within CAS in IMC falling below acceptable standards. Of course, the vast majority of that traffic in the UK will have an IMCR.

I recall many years ago a barrister telling me only three things matter in assembling your case - evidence, evidence, evidence.

You ignore the evidence at your peril because in doing so it is easy for those who have other agendas to convince you that what you propose is unsafe.

On the Spot
4th Sep 2007, 09:05
As a colour vision defective pilot, at least in the UK, I find that flying VFR in the US my colour vision is much more important in reading charts and spotting beacons than it is in the UK.
Pirateking states that good colour vision is required for an IR. But in my experience flying instruments in the US is that it mattered far less, charts are easier to read, beacons are of less importance etc. Maybe that is why the FAA take a slightly more reasonable view on CVD.

IO540 suggests not doing the ground school in the US and Gertrude suggests that the cost in US does not factor in lost earnings. Both are down to personal circumstances.
I did my PPL and IR in the US and find that the total immersion route is best for me, doing the PPL in 2.5wks and the IR in two weeks from almost zero start. The ground school fills in the gaps as you go along, putting everything into context very easily. Of course any reading you can do is bound to help and if you can get to a level to take the written before you go it is one less stress while you are there. Sportys.com and mywritten.com have good online practice written exams for free.

As for loss of earnings again that is for the individual situation but in my case was effectively zero. Aircraft hire is in any case higher than my hourly rate when I am contracted and so I prefer to extract the maximum value from that by maximising progress and concentrating the learning. May not suit everyone but it works well for me. A further factor might also be the flight test costs $500 inthe US and possibly £700 in the UK. Well that covers the airfare.

As for IR lite - well I think I already have that based upon the fact that I do not have sufficient real world IFR experience to take off into a heavy IFR environment safely and with confidence just as it was for the first few flights after getting my PPL.
Perhaps that is a route to seperate the traffic streams and keep everyone happy with use of controlled airspace and jet airways etc. being based upon experience and currency in IFR. A high level of both being able to open the gates to the other world where presumably both will be at home together. Meanwhile us less fortunate souls still get to pootle around in the murk as needs and experience permit, building confidence and experience but doing so as safely as we able.

I will possibly follow IO540's suggestion and see if I can add the CAA/EASA IR at a later date and with the benefit of some more experience. However I guess that the CVD will prevent that and which will be a shame.

stevieb1
4th Sep 2007, 09:33
As a recently qualified PPL, already working on the IMC, I've been following this thread with some interest.

Unfortunately I'm colour deficient, suffering from a moderate deuteranomaly, and have failed the lantern tests at Gatwick and therefore been diagnosed CP4.

My understanding is that this only precludes night flying however, and has nothing to do with IFR versus VFR. Both the CPL and IR syllabi both include an element of night flying, and the CAA have already told me that in the case of the CPL that can be done during the day.

I've argued with them that that same precedent should be applied to the iR, and they're wrestling with that right now. In the meantime, I personally know two pilots who have day only restricted IRs.

Am I missing something here?

S-Works
4th Sep 2007, 10:19
Sorry, I don’t follow this argument. Firstly, as you have already alluded most GA operates outside of CAS. Their typical missions will continue to between small airports, which if they have any commercial traffic at all will be limited in number.

Fuji, You need to make your mind up, either you want access to the airways or you don't..... If you don't then the IMCR remains a viable option and we have to look at what needs to be done to improve the standard and give fair credit to those who want to go on and do the full IR.

SteveiB1, the problem with trying to restrict an IR to day only is that you start to become a liability to ATC if you hit weather, wind or ATC delays and end up arriving after dark. A good example, last week I flew IFR to Cannes, hit much stronger winds than forecast and as a result ended up nearly an hour later than I expected well into dark. I had to divert to Nice on a procedural arrival followed by vectors to the ILS that took another 40mins. What would I have done if I had a Day only IR? I flew in over the ALPS at FL150 so any diversion would still have seen me arriving well after dark. Sometimes we just have to resign ourselves that we have limitations rather than trying to change the rules. I would love to have been an Olympic sprinter.........

stevieb1
4th Sep 2007, 10:38
Bottom line is Bose, although I caught the bug fairly late in life (I'm 30), I love to fly. Why should I accept logic like that just 'cause them's the rules?

Useful VFR flight in northern europe is not a realistic proposition (ie going away for the w/e and stading a fair chance of being able to get home when you want).

You would have to trust me not to put myself in a situation where my arrival before nightfall is borderline, the same way my green (brown?!) PPL licence allows me to take several other people's lives in my hands and fly them off somewhere VFR; and not stray into cloud and kill everyone...

A simple answer would be a stipulation that on a day only IR min fuel endurance = at least the time left before dusk. That way, running out of daylight would be the least of my worries!

dublinpilot
4th Sep 2007, 10:48
last week I flew IFR to Cannes, hit much stronger winds than forecast and as a result ended up nearly an hour later than I expected well into dark. I had to divert to Nice on a procedural arrival followed by vectors to the ILS that took another 40mins. What would I have done if I had a Day only IR?

Not knowing much about IFR flight, I would have thought you'd do the same thing as a VFR day only pilot? Divert as soon as it became apparent that you wouldn't make it in time?

Fuji Abound
4th Sep 2007, 16:33
Bose

Fuji, You need to make your mind up, either you want access to the airways or you don't..... If you don't then the IMCR remains a viable option and we have to look at what needs to be done to improve the standard and give fair credit to those who want to go on and do the full IR.

Forgive me but I follow your argument even less.

My comments had absolutely nothing to do with who should or shouldn’t have access to class A.
I was making the observation that taking the UK model, IMCR holders have access to class D in IMC and operate to the same minima as CAT. (Reduced minima operations and departure excluded).

To suggest that AT treat those pilots in anyway different to IR holders is rubbish. AT have no idea whether the pilot has an IR or IMCR (although I accept in few cases they may have a clue from the initial call up, but equally the call ups I have heard from some CAT pilots have been so poor that I wonder how they ever got their IR.)

In my opinion given your experience of airways operation I do not understand how you can go along with the suggestion that the most difficult segment for an IMCR holder is the STAR. I doubt there is any evidence what so ever to support this hypotheses. From my own experience, and also taking into account what happens in the States where there are large numbers of PPL IRs with varying degrees of proficiency, the vast majority of problems occur during the approach.

With respect, and I really do mean this with the greatest of respect because you have my admiration for taking on the task you have, I think you and many others have been taken in by the whole host of unproven arguments why certain things should not be.

You may well argue you have not, but are engaging the art of the possible not the desirable. Whilst I would accept the rational in that argument there is a real danger that all that results is a whitewash that achieves absolutely nothing other than effectively maintaining the status quo. Sadly you will have wasted your time.

What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.

Personally I feel you could not be more wrong.

Why? Well the reality is hardly anyone does a PPL IR in Europe whereas the MAJORITY of pilots in the US have an IR. Moreover those pilots that do have an IR in Europe are likely to have an FAA IR. Do you honestly believe that among the fraternity of European FAA IR holders they would not have undertaken a European IR unless there was a very good reason for their not doing so? Evidence, evidence, evidence as my friend told me.

In short I am seriously concerned that AOPA has no understanding of the needs of GA or of the way in which GA pilots would use an IR.

Why oh why is everyone so intent on rewriting the rule book when there is already a tried and tested model in the form of the FAA IR that works and meets the needs of the private pilot.

You will end up with something so watered down as to be utterly pointless and all the serious pilots will continue to run N reg aircraft on the back of their FAA IR. What a shame.

S-Works
4th Sep 2007, 17:12
Dublin pilot, I don't know how many times you have crossed the alps over the top, but trust me there are not many places to divert to!!!

SteveiB, So what happens in the winter when the days are very short? Do you not fly IFR? What happens to currency? The point of an IR is basically an all weather day or night rating.

Fuji. I think you and I are never going to agree on this as I am not sure we have a common terms of reference. I am not talking about SID's and STAR's with reference to IMCR pilots being able to fly them. I am reflecting on the fact that traffic departing on them is kept well clear from traffic attempting a zone transit. I am also making the point that there are actually very few pilots doing real IFR and by real IFR I mean actually going any distance truly IFR with a let down at either end. It is mostly VFR pilots having chance encounters with cloud and carrying on. Trust me when I tell you on an average days flying for me under IFR the radio is very quiet.

AOPA and PPL/IR understand perfectly well the needs of pilots, those of use who volunteer our time to do the stuff are real pilots just like yourself and I actually find your view that we do not understand the needs offensive. We have not been take in by anything, we have sat down and listened to very balanced arguments and counteracted them with our own. All of this type of work is a matter of balance. In fact if you feel you can represent GA better please feel free to replace me.

But I will issue a challenge to you. Come on an airways flight with me, you can fly the entire trip under IFR including the SID's and STAR's (I am an IRI) and we can review hoe adequately you feel your IMCR prepared you for the task. It will cost you nothing other than a lunch and some genuine feedback.

Three Yellows
4th Sep 2007, 18:03
Bose-X

When I used the term "IR Lite" what I meant was a cut down version of the IR, like the FAA IR without all the uneccessary theory that I as a PPL/IR wouldn't need.

I am lucky, I have a DA42, full IFR airways capable. In the UK I use my IMCR like an IR (as much as the law will allow) to actually go places. To be clear for your working group, I don't want to put my DA42 onto the N reg (too much grief) what I want is an accessible IR, like the FAA IR. I haven't got a problem with the 55 hours flight training, I just don't want to learn about how a jet engine works, as interesting as that may be. What I want more than anything is to be able to fly in near Europe and do an instrument approach in IMC if required.

However, I suspect that I am in the minority of being a PPL with a serious IFR aeroplane.

Interestingly, some airports in the UK do ask me to fly a SID. Not something that is taught in the IMC. The book says that IMC rated pilots "would not normally be expected to fly a SID". "Not normally" doesn't mean 'never'.

I hope this all turns out to everybodies satisfaction. However with the JAA experience behind us, I suspect that yet again we will snatch defeat from the jaws of victory. Sorry, no disrespect to your efforts on the W/G, I've just got this terrible sense of foreboding over getting 27 (?) countries to agree on something whilst I still have my health.

High Wing Drifter
4th Sep 2007, 18:14
However, I suspect that I am in the minority of being a PPL with a serious IFR aeroplane.
I suggest there is a flip side to this problem. I am a CPL/IR without a serious aeroplane. I'm finding it very difficult to locate a decent and legal aircraft for European travel to hire. Either the A/P is U/S, or some critical aspect of the the de-icing equipment is duff or it doesn't have Mode S or even the basic avionics are missing that oh so crucial device, the ADF or some other malady. It seems to me that the only people who are really able to access a decent and sufficiently equipped aircraft are sole owners - that is out of my price range by quite a long way. Even with the pieces of paper, getting airborne legally and safely will probably remain one of the major hurdles.

dublinpilot
4th Sep 2007, 18:23
Dublin pilot, I don't know how many times you have crossed the alps over the top, but trust me there are not many places to divert to!!!


Bose-x,

I may not have made my point very clear. What I was trying to say is that we presently trust day-VFR only pilots to be able to make a decision based on the fact that they can't fly at night. If they can't be assured of landing before the end of VFR, then they divert. If there are no options for diversion, then they don't take off in the first place.

We turst them to make that decision at present, and we don't seem to have any problems from this.

If we can trust day VFR pilots to make those decisions, why wouldn't we trust them to make the same decision after they have earned an IR?

dp

stevieb1
4th Sep 2007, 19:13
Bose, with apologies to others on here whom I'm sure are not in the least interested in issues of colour vision; I'm bothering to respond to you because you appear to be involved in some way in shaping the future of GA in Europe. Something that for selfish reasons I care passionately about.

Why can I not be trusted to exercise my IR during the day only, winter or not? I have little interest in flying a SEP at night anyway.

You will agree that the problem with this industry is that, at regulatory level at least, it appears to operate a policy of exclusion rather than inclusion. Why not learn form the Americans, and find a way to make things work rather than finding reasons why they cannot?

If you're happy with blindly accepting the status quo, why are you bothering to try to change things more widely on the IR fornt?

I can still go and get an FAA IR, probably without even the night restriction as there are further more practical tests available in the States, and fly N reg in Europe. As someone who's new to the game, none of this makes any sense.

S-Works
4th Sep 2007, 20:07
I am not prepared to accept the status quo which is why I volunteer my time to to try and make change. But neither am I naive enough to think that we can wave a magic wand to change decades of bureaucracy. Like all things in politics we have to change a little at a time to achieve our long term goal.

DP, I am sorry but IFR is a very different beast to VFR. Once you embark on an IFR flight you are committed to the resolution. The pilot does not have the same choices as a VFR pilot. You climb into the airway, it gets dark you look for an alternate, the alternate is below minima, the next alternate is 80 miles away, you are committed and if it gets dark you can't just expect to descend and land. It is not a question of trusting people to make decisions, IFR really is a totally different world and as much I try to find empathy for StevieB's situation I find myself in support of the rules. I have been there and found myself in the situation described above and in European weather it is a very real scenario.

stevieb1
4th Sep 2007, 20:19
It's clearly pointless my trying to reason with you Bose, and yet I find myself biting.

I've read enough of your posts to see that you regard yourself as some sort of master aviator. This may well be the case.

But even if you are a genuine guru, you are still limited by your fuel endurance and the Newtonian laws. If you cannot reliably plan an IFR flight to be over by a certain time, how do you stop your aircraft from falling from the sky?

In fairness to you, your struggle for a more accesible IR does you credit, whether your motives are alturistic or not. But your views on this subject are bo**ocks my friend.

Fuji Abound
4th Sep 2007, 20:26
I think you and I are never going to agree on this

May be not - interesting debate though.

I am reflecting on the fact that traffic departing on them is kept well clear from traffic attempting a zone transit.

The vast majority of light traffic in class D in IMC are pilots with an IMCR or FAA IR. Whether that traffic is transiting the zone, coming off a STAR or making an approach, the controllers do not separate the CAT traffic to any greater or lesser extent. Moreover, there is plenty enough light aircraft traffic in class D in IMC.

AOPA and PPL/IR understand perfectly well the needs of pilots, those of use who volunteer our time to do the stuff are real pilots just like yourself and I actually find your view that we do not understand the needs offensive.

I hope my criticism of AOPA in the past has been constructive. At least I have taken the trouble to justify my criticism.

I pointed out their web site was hopeless. They have made some improvements.

However:

Look at their main page http://www.aopa.co.uk/

They tell me they have 400,000 members in 50 countries.

AOPA America tell me they have 413,000 pilots in America or two thirds of all pilots in America. (http://www.aopa.org/info/) I guess that means the rest of the world has -13,000 pilots.

Cheap comments aside, I really don’t want to know how many pilots AOPA have worldwide. If I am visiting AOPA UK I want to know how many pilots AOPA UK has, and how many thirds of the UK pilot community they represent - or are they too embarrassed to let on?

I really don’t want to know what’s happening in IAOPA or about tougher carbon targets.

I don’t want cheesy photos.

Compare and contrast with AOPA America. Their front page is full of issues relevant to GA.

.. .. .. And then lets take a look at the news section. There must be something in there about a subject as important enough as proposals to make the IR more accessible .. .. .. Oh dear, still not a mention.

Come on guys this is part of the image you present to every pilot in the UK who might think about joining. It is a disaster. Do you give me the impression you represent me and are doing something about the host of threats to GA - I don’t think so.

What I do see a lot off is people who think they could do an IR but don't really want to hiding behind what they see as onerous requirements. In fact the IR is not difficult to do at all, even in it's current format. There are too many old wives tales and myths spread about around it.

Representing the views of pilots means listening to what they have to say and do.

Take the afore comment.

As I said before I don’t think this is the view of most pilots. If that were the case tell me why it is that there are more than 100 FAA private instrument rated pilots in Europe for every 1 European IR holder.

It is those pilots who usually own their own aircraft and are highly motivated and intelligent people that should be offended when each one of them has assessed the pros and cons of gaining an FAA IR compared with a European IR and in spite of the extra costs of having to operate their aircraft on the N reg never the less feel compelled to take that route.

Old wives tales and myths - I doubt it very much.

No - if AOPA believe they understand the views of GA and yet believe pilots take the FAA IR route becasue of myths and old wives tales and think they have it horribly wrong.

But I will issue a challenge to you. Come on an airways flight with me, you can fly the entire trip under IFR including the SID's and STAR's (I am an IRI) and we can review hoe adequately you feel your IMCR prepared you for the task. It will cost you nothing other than a lunch and some genuine feedback.

If I relied on my IMCR I would happily take you up on that challenge. Thank you though. My friend and I on the other hand (with his IMCR) has just done a 500 mile round trip, both sectors in IMC all the way, but outside CAS other than the class D component with a localiser at one end and no autopilot - that is as demanding as it gets - you should give it a try some time. :)

Sadly, I dont think anything of substance will change - but I really hope I am wrong.

However, I am a huge supporter of the IMCR and for that reason if it is axed I shall do something about it.

S-Works
4th Sep 2007, 20:44
StevieB. I do not consider myself a guru at anything, I am however prepared to practice to get things right and as a result have put a lot of practice in. When you have equalled my practice then feel free to call what I say bollox. Just because I am not saying what you want to hear does not make it any less a statement of the situation as it stands. To answer your question on fuel endurance etc which is obviously based on a total lack of understanding of IFR rules. You can quite easily find yourself still airborne at night and still have more than enough fuel if you are following IFR rules. Get an IR and then accuse me of talking bollox.

Fuji. I suggest you start now because the IMCR IS under threat. Join AOPA and come and assist me on the next round of talks because when the IMCR goes you will be able to do NOTHING after the fact......

stevieb1
4th Sep 2007, 21:18
I'm of course willing to accept that I know next to nothing about the IFRs at this stage of my experience.

I'm still not sure you understood what I was saying though. If the IFRs, whatever they may say, state that I must have, say, 4 hours fuel endurance, and I take off four hours before night; then I'm going to arrive before nightfall. One way or the other.

It seems to work fine in the States. As a (self appointed?) representative of GA, I would have thought you would at least be interested in my perspective. On the other hand, if I didn't have colour problems I probably wouldn't give a toss either!

In less than a month I should have an IMC, and therefore be legal and trustworthy IFR in IMC within UK airspace. With respect, your argument is nonsense. More to the point, you should really be trying to find ways of including people, IMHO.

S-Works
5th Sep 2007, 07:25
I am not going to get into a fight with you over this SteveiB. I am not a self appointed representative of GA. I was asked to do it. Go out get yourself some real experience of flying and the regulation that surround it then volunteer your services we always need more volunteers. I am prepared to discuss but not be abused by someone who knows squat all about the real world that drives aviation.

And I am sorry that you have a what is fairly unique condition and I take on board your desires to do more. However I would be lying if I told you we could do anything about it. The mountain will not move just because your view of it is not good enough.

AOPA and PPL/IR (both organizations you should be joining if you want to fly and be an Instrument pilot) try to represent the interests of the majority and through a team of volunteers work tirelessly towards this. There are always going to be a minority that are not going to get there way.

Your view of flight planning is way to simplistic and if that is what you are being taught in your IMC then it just reinforces what I have been saying about the poor standard of the average IMCR.

Right I am off to fly to Rosserow and play golf...

Fuji Abound
5th Sep 2007, 07:46
Right I am off to fly to Rosserow and play golf...

Was thinking of a trip to Perranporth today but it has ended up being the East coast.

I have had a look at the Rosserow web site - it looks lovelly.

Do they have a strip?

PS Whilst we may not agree on some issues, once again I take my hat off to you for your efforts. At times you must wonder if it is worth the hassle but I think the fact that pilots take such an interest in what you are trying to achieve proves it is very worth while.

Bandit650
5th Sep 2007, 09:30
I first got an IMC rating 10 years ago and renewed it only once since.

Although I regret feeling this way, I really do, I can see some sense in the rating being retired...certainly given my experience anyway.

I really enjoyed doing the training and it definately does sharpen your skills, but I never really felt sufficient safe to fly IMC solo despite being technically able to do so. I did some ILS approaches in cloud after getting the rating, but I never felt sufficiently equipped to undertake regular IMC trips in bad weather. The risk/benefit balance was never positive. In addition I was told numerous times in conversations with experienced aviators that the rating is nothing more that a "get out of trouble" rating and is seen as such by the CAA.

In addition, the flying schools I went to, although excellent in training, left me cold and dry in terms of encouraging/helping me to become a regular IMC aviator. In fact, PPL IMC trips were discretely discouraged in their hire fleet.

Having started the ATPL theory and becoming increasingly aware of how difficult the full IR is, it does leave me wondering just maybe the IMC could be guilty of tempting insufficiently trained/safe inexeperienced pilots into very difficult situations. If I remember correctly (pls correct me otherwise), a newly qualified PPL can go straight into an IMC rating and being flying around in marginal conditions with less than 60hrs under their belt. That does seem worrying.

Its an expensive rating to acquire and to maintain. If you're that commited to instrument flight, and can afford to maintain the skill, surely a full IR is a more appropriate?

Ultimately, I do harbour a degree of dissapointment at the state of the UK private flying scene, which does feed this particular perspective, so I do apologise if I seem negative. It's a shame there isn't a stronger GA club scene here as there is in France/US for example (and less congested airspace too!).

I'm not saying PPL holders should not fly on instruments, I am just of the view that the existing rating probably does need refining in some way. As a training course in its own right it's a great thing...but it is tempting to subscribe to the view that all pilots flying in IMC should be trained to the same level regardless of the number of people sitting inside their aeroplane.

However, my mind is still open on this and would be very interested in continuing to read other perspectives.

bigfoot01
5th Sep 2007, 12:49
...I have to say I disagree. I have just completed my IMC Training - 90 hrs. I have yet to do the skills test. My view is that the IMC is a cracking qualification. I would suggest it needs a mandatory dual cross country and a solo cross country navigating by instruments, but not necessariy in IMC (I have done this with an instructor and it was good experience).

Hopefully I will pass my test, but I won't feel like flying off and flying around the UK down to minimas, but it is a rating I think I will use and build up my experience with. When I started flying after my ppl, I didn't feel like doing vast cross countires close to CTA, but it is something I have built up to.

I also think we need to recognise that things are getting easier for GA. I now have access to a plane with auto pilot; twin gns430's. Most of the airfields I am likely to want to fly to have Survelance Radar, or there is an alternative nearby suitably equiped.

So I guess I am suggesting I would like to see the IMC Saved/Kept.

Slopey
5th Sep 2007, 13:04
I'm seriously considering doing the IMC, as based in (non) sunny Aberdeen, we're constantly beset by fog/haze and a layer of low cloud on otherwise fine flying days which makes VFR flight infrequent (at least this summer anyway). Being able to push above it and actually *get* somewhere would be wonderful - I've had many oppertunites to go to Dundee/Inverness/Perth which I've had to cancel as the weather hasn't been VMC and I end up driving instead - the Inverness road in particular is a nightmare - 2.5/3 hours to do 105 miles compared with a 40 min flight in a 172.

So I'd like to use it to actually go places rather than a "get out of trouble" rating.

As previously intimated, if you don't keep it pretty current, it'll go from a "get out of" to a "get into" trouble rating when you try an approach in cloud having not done one for 6 months. I intend using it very regularly.

That said - the IMC or the IR??

I have a young son, I managed to get my PPL completed before the nipper arrived but the thought of me heading off for X weeks to do the full IR (55hrs I believe) would put the wife in a bad mood. Add to that the exam requirements - I don't really have the time or the inclination to sit 7 exams, and I'm not going to go ATPL in the future.

I'm also not going to be flying into any Class A/B airspace unless I'm SLF (or I'm *really* confused about where I am!!!), and based in Aberdeen - I need to fly about 4/5 hours south before I can go to a foreign country, which makes me popping over to Euroland IFR virtually non-existant.

So - the IMC looks like a better fit for what I want to do with it.

25 hours training will be much more wallet friendly (especially in Aberdeen!) given (iirc) that I can't use my group aircraft to train for the inital grant of a licence.

1 exam also sits better with me. Do the IR exams reflect airline/commercial flying rather than GA? The 7 vs 1 seems like quite a difference, but if most IRs are ATPL exam passers anyway, that probably explains it.

So, on balance, the IR exam and hourly requirements seem untenable to someone in my position.
Would I love to have an IR? Absolutely.
Can I afford it? No.
Would I be divorced afterwards? Possibly (unless I planned to go commercial - but that would be financially undesirable for me)

So the IMC -
can I afford it - yes.
Will it let me do what I'd like to? Looks like it.


Now the only sticky wicket is if the IMC is withdrawn in the next few years. However, by that time I'd assume that any future PPL/IR would be easier, on the wallet and theory, to obtain and hopefully there would be a credit from an existing IMCR.

So - I'll go for the IMC in the near future.

Until someone has a timescale for the 'new' IR, with concrete requirements and costs - I can't afford to do the IR anyway... :hmm:

DFC
5th Sep 2007, 19:35
[QUOTE=bose-x]Get an IR and then accuse me of talking bollox.
[/QYOTE]

You are talking bo11ox.

There have not been any significant unforecasted enroute winds in Europe recently.

If flying any form of crosscountry flight even the student pilot with 32 hours on their skill test are required to provide reasonable accurate eta's and update them if an error is found.

Even if there was an unforecasted wind, a 1 hour late ata should have been obvious from a long way back along the route so even if you were transiting the alps from Austria through Switzerland and onto Nice, you could easily have diverted to a non-alpine aerodrome.

Can you circle to land at Cannes after dark? If not would that not have been something to consider at the planning stage and suitable enroute alternates found?

Why did you fly an ILS at Nice, is the preferred Riviera and other noise abatement arrivals not to your liking?

What were your plans for an engine failure at about the half way stage?

-------------

The problem with AOPA is that they never have people who know enough about what they are dealing with to be able to press the regulator if required.

-----------

Dublin Pilot and stevieb1,

The IR does of course give night flying privileges just like the CPL and thus one needs nornal colour vision. Yes one could have a CPL limited to Day VFR and get round the vision requirements.

However, with the IR, which of course is not type limited. there is another problem.

Imagine an IR holder restricted to day only breaks out at minima from a ILS with just the bare visual requirments over a full CAT 3 approach lighting and runway lighting system.

Undershoot area lights are red, threshold lights are green and touchdown zone lights are white. You are at 200ft descending with only about 300m visibility you have fractions of a second to differentiate the light colours and decide where the threshold and touchdown zone is..........can a colour-blind person make the difference between the red and green lights?

Put it another way....as a Doctor, are you going to sign a piece of paper that they will?

Regards,

DFC

S-Works
5th Sep 2007, 19:46
You know DFC you are so full of **** at times I should not even bother replying to you. But just for the hell of it...............

Un-forecast wind is one that showed on the forecast as being 15kts and ended up being nearer 30kts. 15kts over a near 5hr flight is enough to put you behind schedule. Nice was my diversion and as the weather required an ILS, and ILS was flown after a short delay in the hold. I was not the only aircraft to miss Cannes.

My plans for an engine failure are the same at every stage. Land. My risk acceptance for SEP over hostile terrain is my choice.

How about going flying instead of spewing your endless opinionated ****e.

Shunter
5th Sep 2007, 20:02
Not sure "unforecasted" is even a word...

Just for the record, I flew a SID, and an NDB hold on my IMC test. I was trained for both and am glad to have the experience.

DFC - you clearly know absolutely jack f'cking sh!t about colour vision. Trust me, I know plenty. The VAST majority of people who have VCL restrictions are PERFECTLY capable of seeing PAPI lights etc.. The testing employed be JAA is utterly irrelevant, in complete breach of the testing medium manufacturers instructions, and wide-open to a crushing legal challenge (watch this space).

S-Works
5th Sep 2007, 20:14
He knows jack **** about anything but is always quick to come over as an authority figure. Highly annoying to those of us who do know everything... :p :p :p:ok:

stevieb1
5th Sep 2007, 20:21
DFC - at the end of the day, if I won't be allowed to take the JAA IR as it stands; I'll accept it far more readily armed with logic and reason as to why it's not possible. It's good of you to chip in with what appears to me as dispassionate, and frankly un-opinated reason.

As shunter says, in reality the whole colour vision thing is bulls*t; but that is another argument for another day. For now, I just wondered whther I could get around the existing rules.

Bose, I took the liberty of having a look through your previous posts. You're not a veteran at all are you, having had your IR for what, a year? Where do you get off on dispensing advice and narrow, parochial proclamations on a bulletin board?

The guy who did your IR is a good mate of mine. Just because you've piqued my interest, I'll ask him if he remembers you; and whether you're as much of a bellend as you appear to be.

Shunter
5th Sep 2007, 20:27
There is NOTHING to prevent you from doing a JAA IR even with a CP4 colour unsafe medical restriction. This has been done to death on the medical forums. I have an unrestricted class 1 FAA medical by the way...

You do the night rating, all dual. You do the CPL, you do the IR. Yet you still can't fly at night. Fly in zero viz, just not when it's dark. How pathetic. If it was such a big deal, all those FAA ATPL's wouldn't be able to fly 747's in and out of the UK on a daily basis now would they...

dublinpilot
5th Sep 2007, 20:34
Bose,

I'm not going to argue with you over the diversions. I do find it very strange that a pilot with an IR would find it difficult to perform a diversion during their flight. I also find it very strange that they can't be trusted to not to get themselves into a position where they may need to divert, but have no options for the diversion.

Howver, you are correct that I know next to nothing about IFR flight, and if you that that is the case, then so be it.

But I must pull you up on one thing. You say to StevieB

And I am sorry that you have a what is fairly unique condition

As I understand it colour blindness affects one in every ten males. It would seem as if Stevies condition is far from unique, and must be quite common among the male dominated pilot population. Perhaps it's not part of your struggle to make the IR more accessable (which I do very much appreciate, and hope to be able to benefit from) but it does seem as if this will be an issue for quite a lot of pilots wanting to do the IR.

Whether it can be justified or not on safety grounds, I'm not qualified to say, but it would seem like it's going to be an issue for a lot of people. Stevie I suspect it just the tip of the iceburg.

Then there is the hearing issue too......

dp

Shunter
5th Sep 2007, 20:37
No, it can't be justified - not with the present testing regime.

http://www.city.ac.uk/avrc/members/j.l.barbur/JAR_colour_study.pdf

As pointed out, substantial numbers of people with PERFECT colour vision fail the bull**** tests JAA employ. The key word is RELEVANCE. The FAA employ RELEVANT means testing, and how many accidents involving FAA pilots who would have failed JAA tests are related to colour vision? NONE.

stevieb1
5th Sep 2007, 20:39
Apolgies for the thread drift.

Shunter, I spoke to the CAA a fortnight or so ago. They said I could do the CPL by taking the mandatory night flying section during the day. Fair enough.

However, their stance on the IR was that I couldn't do it because I couldn't get the night rating. I suggested what you just said, attaining the night qualification dual, but they said that they would not put a rating on my licence that I'm medically unable to exercise.

That at least was their scripted response. My request is now with their specialist FCL person, who's away on leave. Who know's, maybe I'll get an answer this month!:ok:

Dublin, you're correct and it is I believe 1 in 10 males. I know people who've got round the CAA, so there is a precedent of some sort for me.

Again, thanks for your input guys.

S-Works
5th Sep 2007, 20:44
Wow SteveiB you really do seem to have taken issue with me!!!! Sinking to insulting me just makes you the bellend as you subtly put it.

I am flattered that you have the time to talk to all of my IR Instructors. but please say Hi to them for me. I have never claimed to be a veteran at anything however in the last couple of years I have done one or two hours under IFR..............

Like I said just because you don't like what I say about the rules surrounding your condition does not make it any more likely they will get changed and abusing me won't make it any different. However if it makes you feel better or you get off on it, then who am I to deny you a bit of dirty pleasure... :p :O

The airlines have a major voice when it comes to the rule making and they do not want to see anyone they view as sub standard sharing the airspace. For the record I think it is wrong but is the way it is. So if you feel so strongly about it put all that hostility you are aiming at me to use and actually try and make some changes yourself. If nothing else it will give you an appreciation of what we are dealing with.

Shunter
5th Sep 2007, 20:52
stevie - I suggest you read the colour vision threads on the medical forum. It's perfectly acceptable to do a JAA CPL/IR with a CP4 medical restriction. Many people already have.

You do the night flying at night, just with the solo stuff as P1/S. So you've got the night rating, you just can't exercise it as PIC. Once you get the CPL/IR you are restricted to day only, and no public transport. I've spoken to a number of barristers who specialise in discrimination cases, and 2 of them even offered to take the case on a pro-bono basis!! That's how weak the JAA case is!

There are LOADS of people in the same boat, including a very experienced CFI I know. He's a JAA CPL/IR examiner, with thousands of hours. Whoever told you that is full of ****. If you want the fact, speak to Adrian Chorley at Gatwick, he knows the rules. It's a shame whoever you spoke to doesn't.

stevieb1
5th Sep 2007, 21:05
Shunter - I've read them all. Before I commit a lot of money to training, clearly I need something rock solid from the CAA. Hopefully I'll get that soon.

Bose - nice comeback sweetcheeks. And it's not hostility, you have actually entertained me. I hope you allowed yourself a little chuckle when I was insulting you. No hard feelings eh big guy? :ok:

Keep up the good work.

stevieb1
5th Sep 2007, 21:08
Shunter - I think I mis-read your post... Thanks for the tip, I'll have a word with Mr Chorley at CAA Towers!

Fuji Abound
5th Sep 2007, 21:12
If nothing else it will give you an appreciation of what we are dealing with.

The only way to deal with anything effectively is as I said before:

Evidence, evidence, evidence.

I know very little about colour blindness, but if there is sufficient evidence it should not be an excluding condition present the evidence,

the airline representative may argue the IMC is a sub standard qualification - lets see the evidence to support or counter their argument. If it is poorly taught, embarrassingly it befalls the CAA to enforce standards - if they have failed to do so they are complicit.

DFC makes a sound point.

The biggest problem is that AOPA is ineffective. They do not represent the majority of pilots in the UK or in Europe and in consequence they are unable to "employ" representatives with the experience or quality to take on the establishment.

I appreciate it is a catch twenty in that if pilots don’t join AOPA the situation is not going to change. Equally if AOAP continue to do such a poor job of representing what they are about (see my earlier post) is it surprising so few pilots join?

Anyone interested should compare and contrast AOPA this side of the pond with their counter part in America. So far as I am aware AOPA US have not lost a single issue they have pursued. They are considered to be a powerful and effective lobbying body of whom the politicians take considerable heed.

On this issue, as but one example, if AOPA brought a legal challenge against EASA that they were acting illegally by not accrediting pilots with an FAA IR with instrument privileges then I suspect they would win.

S-Works
5th Sep 2007, 21:35
Fuji, You are wrong, but I think the only way you are going to ever understand is to volunteer. We always have space on the working group and in fact we need a volunteer to assist with the mentoring scheme. How about giving up some time and energy to become involved.

ThePirateKing
6th Sep 2007, 08:20
All, I did not intent to turn this thread into a colour blindness thread, but I'm glad that a frank and open debate has ensued.
I know very little about colour blindness, but if there is sufficient evidence it should not be an excluding condition present the evidence,
I recently went to City University to have the colour vision testing done and to take part in their CAA sponsored study into the possibility of changing the colour vision requirements.
Interestingly, I was a total mess at all the "CAA/FAA/JAA approved tests", but when they gave me the practical tests, I was much much better. In fact, the head of department came to speak to me and asked me to describe some magazine covers selected at random from his book shelf. He then claimed that, given the clinical results, he was amazed how well I had done with the magazines and said I was "remarkably well adjusted" to coping with my condition. Apparently, I (and other CVDs) use other clues/cues to discern colours (such as intensity, common sense, etc.)
Anyway... the point was that they then administered a new test which I believe to be in some way linked with the possible proposal to change the CAA testing procedure. This test used just red and white lights (or maybe red and green... it's the white/green difference I struggle with), and I did perfectly well on it.
Plus, I've never jumped a traffic light in my life. (Well, not due to misinterpretting them, anyway! :E)
I'm very interested to hear this discussion of doing CPL/IR courses that are restricted to day only. But having said that, I have no interest in flying in class A airspace or in Europe, so for me the IMC is perfect. It would be a shame to have it taken away and replaced with an IR (of any form) which is more onerous to acquire (than the IMC) but which offers me no personal benefit for the kind of flying I do. It would be even more annoying if that left me with no choices because of the draconian colour vision requirements.
Tell me this... how many nav lights am I expected to spot when I'm bimbling around inside a cloud? And how much of my cockpit to I completely fail to understand because of my colour vision?

On the Spot
6th Sep 2007, 08:44
As in the previous posts I hope that sense prevails on CVD and night flying with an IR. I too have problems between white and green when doing a lantern test and hence have the daytime only restriction on my CAA PPL.
There is no restriction on my FAA PPL which includes a night rating and IR because in the testing it has not been found to be relevant. However I know from experience that, for me, it is difficult to spot an airfield at distance by the green flashing beacon, when it is located amongst thousands of other lights in or near a city.
The only reason I can see that affecting an instrument flight is if the pilot should choose, or maybe be forced by equipment failure, to change during the flight from IFR to VFR. Making a visual approach under IFR is only done when the airfield is in sight anyway.
I would not want to invest time and money in an IR with a daytime restriction either.

DFC
6th Sep 2007, 12:33
An IRI who can't update eta's enroute, and then has to divert to the alternate they have where unexpectidely (despite being in the air for 5 hours) the weather is below the required minima........and to top it all off, does not have any enroute alternates!

Perhaps BoseX, this highlights that any IMC/IR changes are also going to have to be part of a full review of how little experience or practical ability some people have when the CAA gives them the ability to teach applied instruments.

------

They said I could do the CPL by taking the mandatory night flying section during the day.

I have never laughed to much. Did you talk to them on April 1st.

Cant believe that you did not question them about the requirement to wear sunglasses to make it darker :D

------------

Shunter,

I did specifically not mention PAPI or VASI. Read the later comments regarding coping mechanisms and contrast. You do remember from which side the PAPIs start going from white to red don't you?

What I spoke about was red green and white lights in close proximity with little contrast and no way of easily deciding which is which based on position (like one does with traffic lights) with high workload, and poor visibility.

Any restricted IR would require agreement from the other JAA states - not likely and would also have a weather minima restriction similar to the IMC as well as day only. Being sub-ICAO it would probably be restricted to UK airspace only.

Now let me think.....instrument flying privileges with a requirement for 1800m visibility at take-off and landing, higher minima factors, limited to day only and the UK only........

Do you want to pay for a full IR course just so that you can fly IFR in class A airways during the day in the UK?

Regards,

DFC

poorwanderingwun
6th Sep 2007, 17:25
just happened to drift into the Private threads out of curiosity.. Was disappointed to note that the IMC rating was in danger of being scrapped...

I found the extra freedom that it allowed me together with the boost in confidence that came as I became more familiar with (gentle) IMC was invaluable... not everyone would feel justified in lashing out the funds necessary for the full IR.. especially those who are limited to non ice protected a/c... and in my case I know that those hours climbing to get 'on-top' and safely back down again were real value for money when the time came to do the IR ... even for those not planning to lose sight of the ground it can prove a very useful tool... I remember just how suprised I was on those early cross-channel trips on fine days to find that the sea haze had blended the blue sky and blue sea together so effectively that my AH/VSI and Alt had suddenly become my dearest friends.. Obviously one can practise these skills with an instructor without any requirement to sit an exam but the proceedure regularises the training and the standards. It's a fine balance between confidence and overconfidence... I always felt that the IMC rating was a well placed stepping stone.

S-Works
6th Sep 2007, 18:04
DFC, Of course you are right, I stand corrected in the light of your infinite wisdom. As is proven time and time again on here you are never wrong.............. :ugh:

Now that I have the benefit of your wisdom I shall at once observe your guidance. How frequent do you think my enroute alternates should be, every 10 miles to be on the safe side or something more frequent? Shall I have a ferry tank fitted just to make sure I have appropriate reserves.

In fact if you don't mind a little bit of online IR training would clearly benefit me. I realise that being an active IR flyer yourself I will benefit from a mountain of wisdom. ;):ok:

DFC
6th Sep 2007, 18:50
BoseX,

You are in Europe, flying with a 30Kt headwind component on an IFR flight with appropriate reserves and destination aternate fuel.

Do you really believe that with 2 or 3 hours to go to the destination, you can not find an enroute alternate where the weather is suitable.

With all that endurance on board why would you need any more.

Please take some time to think about what you are saying and imagine what you would say to a student who said the same!

:rolleyes:

Regards,

DFC

S-Works
6th Sep 2007, 19:03
keep the advice coming DFC. I am learning all the time........... ;)

IO540
7th Sep 2007, 08:43
I am on holes so won't comment much - just a few things.

The colour vision requirement is an old thing, passed down from generation to generation of grey haired aviation regulators, without anybody really questioning it. Then Pape (http://www.aopa.com.au/infocentre/topicdocuments/colourvision.pdf)came along and more or less demolished it. It's largely bogus.

The hearing (audiogram) requirement for the JAA IR is even more bogus. It isn't an ICAO requirement (no FAA ATP has got one, for example) and while the locals here like to pretend their hands were tied by ICAO, this is a disgraceful misrepresentation. ICAO merely recommends that an IR holder meets the same hearing requirements as a commercial pilot, but does not state what those should be. The morally and intellectually superior Europeans gold plated the ATP hearing requirements with the audiogram and then then pretended that ICAO forced them to do the same for the IR. This one is completely bogus.

The stupidity of these requirements is underlined by the fact that on renewal medicals, JAA offers a demonstrated capability route. This is of course necessary to prevent thousands of old and highly experienced ATPs losing their jobs - something which would be politically unacceptable. Many of these are too deaf to hold a social conversation (without a hearing aid) but are fine when flying.

Anybody allowing standard X on a renewal but requiring standard Y on initial is standing on totally bogus ground. Airline pilos are all flying on renewals :) :ugh:

These requirements DO stop many private pilots acquiring the IR - because most pilots with the funds to fly IFR/airways are not 21 year old unemployed ATPL candidates. Most are older professional/business people and as one gets older one's hearing doesn't get better. It's easy to fail the audiogram yet have a perfect hearing while flying.

It's also easy to fail the CV test yet see all the colours required in flying. Lots of ATP candidates have been doing their initial medicals in places like Hungary...

Bose-x would be right if he said that ramming reduced medical requirements down the throats of the present regulators is politically very hard. But to say it is right to leave them as they are is just maintaining the present elitist approach, designed to separate men from sheep for no particular purpose.

DFC
7th Sep 2007, 12:40
IO540,

Re hearing requirements you describe as bogus;

ICAO Annex 1;

2.6 Instrument rating — Aeroplane

2.6.1.5.1 Applicants who hold a private pilot licence shall
have established their hearing acuity on the basis of compliance
with the hearing requirements for the issue of a Class 1
Medical Assessment.

6.2.5.2 Applicants for Class 1 Medical Assessments shall
be tested by pure-tone audiometry at first issue of the
Assessment, not less than once every five years up to the age
of 40 years, and thereafter not less than once every two years.

6.3.4 Hearing requirements
6.3.4.1 The applicant, when tested on a pure-tone
audiometer, shall not have a hearing loss, in either ear
separately, of more than 35 dB at any of the frequencies 500,
1 000 or 2 000 Hz, or more than 50 dB at 3 000 Hz.

Seems quite clear to me.

If you insist that just because the USA permits pilots to fly when they do not meet the ICAO requirements everyone should do so then please search further afield and you will find a country where there is no licensing requirements at all and then you can insist that EASA use that as a model.

Regards,

DFC

IO540
7th Sep 2007, 16:59
DFC, where does it say (in ICAO) that a PPL/IR needs a Class 1 ?

DFC
7th Sep 2007, 17:29
It does not say anywhere that a PPL must obtain a Class 1 medical to get an IR.

What ICAO does say, as I clearly quoted on my previous post is that unless a PPL holds a class 1 medical they have to comply with the class 1 hearing requirements.

Please re-read my previous post which is quite clear in this respect.

Regards,

DFC

MungoP
8th Sep 2007, 09:26
Are you sure that it is ICAO stating that ? FAA is an ICAO licence and has no hearing test that I know of... at least I've never undergone one for my FAA ATPL... although I do undergo one for my UK License every 2 years it's not with the same medico.

S-Works
8th Sep 2007, 16:32
I too am unable to locate an ICAO requirement for a Class I hearing test but have found a JAA reference.

rustle
8th Sep 2007, 16:45
The ICAO reference DFC quoted can be found IN THIS DOCUMENT (http://dcaa.slv.dk:8000/icaodocs/Annex%20I%20-%20Personnel%20Licensing/Personnel%20Licensing%20-%2010th%20ed%20-%20July%202006.pdf), but note that it is a 2006 edition and that Instrument Rating section is 2.7 and not 2.6 as per DFC quote.

UL730
8th Sep 2007, 19:05
I find the audiogram a baffling experience. I sit there like a complete plonker pressing the button at the slightest rustle of the headset - hear a few almost completely inaudible tones and still manage to pass.
This is useful (http://www.phys.unsw.edu.au/jw/hearing.html) but not definitive.

IO540
9th Sep 2007, 13:28
I am miles away and unable to check out the references right now, but I simply cannot believe that the FAA Class 1, which I have myself, and which I know does not include an audiogram, is sub ICAO, that the USA has filed a difference with ICAO (as it must in such a case), and therefore all US air carriers flying the world over are doing it on non ICAO compliant licenses :ugh:

There has to be more to this.

The audiogram is indeed JAA, and it is under JAA that the "demonstrated ability" option is available (which makes a mockery of having the requirement in the first place ;) ), but the audiogram was also required for the pre-JAA CAA IR.

About a year ago, the CAA published a change (I have the URL but not with me) relaxing the initial requirements to the renewal levels. I never did check whether this was in JAA too but I guess it must be. Or maybe other JAA member states never did have the more onerous initial limits.

Any medical requirement that exists for initial but does not exist on renewal is patently bogus and one has to question the thought processes of the people that drew up the requirements.

There is a general problem with medical requirements, in that the medical department of the UK CAA, and I believe similarly with other CAAs, is quite powerful and is probably the biggest stumbling block to any changes to make the requirements more appropriate to private flight.

DFC
13th Sep 2007, 16:18
2.6.1.5.1 Hearing requirements are identical for Class 1 and Class 3 Certificates. However, they are not in
compliance with the ICAO Standards for Class 1 hearing requirements.

The above is the difference filed by the US regarding the requirement for Class 1 hearing.

There is also a difference filed that US ATPL holders do not meet ICAO medical standards.

Regards,

DFC

IO540
14th Sep 2007, 10:17
2.6.1.5.1 Hearing requirements are identical for Class 1 and Class 3 Certificates. However, they are not in
compliance with the ICAO Standards for Class 1 hearing requirements.

The above is the difference filed by the US regarding the requirement for Class 1 hearing.

There is also a difference filed that US ATPL holders do not meet ICAO medical standards.

If the above is true, and is current (I can't find the URL for it, and IIRC never did find online the bit of ICAO listing the differences filed by various nations) then it means that ICAO did something which the world's biggest (by far) aviation user, the USA, regarded as pointless, ignored it, and the rest of the world has had to accept that.

It doesn't really affect anybody at present but it's bad news for any improvement in Europe, because anybody wishing to get anally retentive about this can just say they have to stick to ICAO. This is going to hold back progress in important areas, and will restrict any European IR just like the present one.

S-Works
14th Sep 2007, 10:45
Perhaps DFC would care to amaze us with correct facts for a change and actually post the URL or whole document rather than snippets that are meaningless.

Not saying he is wrong but I am unable to find anything that relates to this as a filed difference.

DFC
14th Sep 2007, 11:01
BoseX,

ICAO Annex 1 and the supplement is quite a big document to post here when a simple quote will do.

Why not read the post from rustle and follow the link to the document.

On the same webspace you will find the supplement which details the differences.

Regards,

DFC

S-Works
14th Sep 2007, 11:07
I found the document, I was trying to find reference to the filed differences for FAA pilots.

421C
15th Sep 2007, 10:42
Rustle's link is to Annex 1, the same site (Danish CAA which helpfully has all the ICAO docs) also has the Supplement (http://dcaa.slv.dk:8000/icaodocs/Annex%20I%20-%20Personnel%20Licensing/an01_sup162.pdf)to Annex 1, which is where all the states' differences are filed. The US differences start on page 99. Australia also has a lot of differences.

DFC's quotes are accurate but shouldn't be interpreted as anything sensational. An international aviation lawyer should explain this properly but AFAIK:

An ICAO contracting state can comply with ICAO by either incorporating Annex 1 Standards in its national legislation or by filing differences with ICAO. The filing of differences makes it compliant, under the principle that the difference is published and available for other states to see, and judge, if they wish, whether to restrict the priviliges of another state's licensees on the basis of differences filed.

Many licenses and medicals are compliant on the basis of differences - see the document. This is mainly a technicality. One meaningful impact I think this has had in recent years was that the FAA were forced to issue a SIC Type Rating because Europe threatend to stop 2 crew aircraft flying without both pilots holding a TR.

Either way, it doesn't matter for the question IO540 raises on PPL/IR audio requirements. It is an ICAO standard that these meet Class 1 Medical level; however, ICAO compliance with Class 1 Audio does not require the Audiometry test - a practical hearing test suffices for initial and renewal Class 1 medicals, see Rustle's link page 6-7.

BTW a license complying with ICAO on the basis of filed differences is not "sub-ICAO". A "sub-ICAO" license would be one that did not comply on either basis and would have a statement about it not being ICAO compliant printed on it.