EASA? What a joke! [Archive]

Fuji Abound

7th Dec 2007, 22:16

stellair

.. .. .. are you sure your other pseudoym is not Rustle?

I'll be sure to tell my chief pilot that all the company pilots who renew their IR's only do so to "better" their chances with his aeroplanes

That was a pointless comment. Why did you make it?

Please don't confuse an IMC with being qualified or able to fly PROPERLY on instruments

Have a word with the CAA old chap - they have thought otherwise for the last 40 years. Be in no doubt with an IMCr you are qualified to fly on instruments.

The reason IR's are expensive are due to the complexity and depth of the course, quality costs!

You raised the issue of cost, no one else.

FAA IR's are well and good albeit not as indepth as JAA

If you really had both I doubt you would make that comment.

Why should EASA or the French recognise the IMC qualification?

The evidence of 40 years experience tends to speak volumes that it does what it says on the box.

The CAA does not agree with anything you have said in your post. It doesnt mean they are right, but you will have to do a great deal more (in terms of solid evidence rather than unsubstantiated opinion) to persuade us they are wrong.

stellair

7th Dec 2007, 23:21

FUJI.....

That was a pointless comment. Why did you make it?

To highlight the stupidity of your comment.

Have a word with the CAA old chap - they have thought otherwise for the last 40 years. Be in no doubt with an IMCr you are qualified to fly on instruments

It's no where near as comprehesive as an IR no matter how you look at it otherwise why do we have 2 seperate ratings :ugh:...period.

You raised the issue of cost, no one else Wrong... You said:40 years service with excellent safety record in an enviroment in which the CAA / JAA IR have proved practically unobtainable by most private pilots If you refering to an average PPL's ability not budget to pass an IR then you have answered for me.

If you really had both I doubt you would make that comment Don't insult me, it's certainly clear you don't have either!....Just two of many........Ask any American IR instructor how many times they fly a proc. NDB, then ask any UK IR instructor to fly an ILS backcourse. :rolleyes:

Look......... I hope you enjoy safe flying in the UK and VFR abroad but I don't need to present you with any proof! It is NOT a recognised qualification outside the UK, get over it.......GET AN IR if you want IR privilages! There is a huge difference between them, sorry old chap!

IO540

8th Dec 2007, 06:54

The reason IR's are expensive are due to the complexity and depth of the course, quality costs! If you can't afford it then......:confused:..FAA IR's are well and good albeit not as indepth as JAA but some of the procedues often used in the UK aren't even touched in the American IR and vice versa, I know I have both!

That "quality" argument is utter elitish bo110cks. You are presumably a JAA IR instructor or better still a CAA IR examiner.

The trouble is that one reads so much of this crap on pilot forums there is a limit to how much effort one can put into posting corrections all the time. Which is why this trash propagates so easily. Most of it goes unchallenged because the people who actually fly for real can't be bothered to argue anymore, and those with all the bits of gold plated paper but who rarely fly anywhere have all the keyboard time.

The reality is that neither a fresh FAA IR nor a fresh JAA IR is capable of planning an IFR flight from A to B in European airways. There are loads of procedural issues that are not covered. The JAA IR is intended to prepare the person for an airliner RHS and the ops man hands him the whole plan when he step on, and the LHS keen an eye on him. The FAA IR prepares you to fly real IFR yourself, and the rest (how to work out Eurocontrol routings, which website you get the weather from in Europe, etc) you can pick up.

However the biggest b011ocks is the continual slagging off of the IMC Rating. Before the IR, I was flying European airways on the IMCR (with an IR in the RHS to make it legal) at oxygen altitudes and never had the slightest problem. It's FAR easier than hacking around under VFR, begging variously helpful (or not) ATCOs for a transit of "their" private airspace. The RHS was a graduate of the JAA school machine between Bournemouth and Cranfield etc so he knew nothing about IFR/airways flight planning or enroute strategy. I did all the planning and all the flying. On the skills from the IMCR. The only essential bits which didn't get covered by the IMCR training were SIDs and STARs and those are just like approach plates (you have to read dem and do wot it sez on dem).

The biggest enemy of the IMCR is poor pilot currency, not the training. It's been marketed as just another sausage to sell from the PPL sausage machine, and most holders don't use it. An expired IMCR holder will however be no worse a pilot than an expired IR holder and there are plenty of the latter. In fact most instructors who once held an IR have let it lapse.

The other enemy is poor access to suitable IFR aircraft and of course an IR holder has exactly the same problem. Most JAA IR holders are would-be ATPLs and most of them are skint and don't fly because they can't afford to but they have time, which is how they were able to do the frozen ATPL in the first place.

Both IRs are every bit as good as each other for the core skills of instrument flight.

None of this cuts any ice with the old guardians of purity who regard the European IR as the minimum gold standard for sharing airspace with the so-called professionals. The fact that airways flight is actually a piece of cake and a lot easier than hacking around the UK at 2400ft is conveniently forgotten. If somebody was tasked TODAY with developing a syllabus for the essential skills to fly Euro IFR, the result would make all the old puritans revolve in their graves at 2400rpm.

Contacttower

8th Dec 2007, 07:31

FAA IR's are well and good albeit not as indepth as JAA

I can't believe that after all that has been said on this forum about instrument training people still believe this...it is quite absurd...try telling that to the American Airlines pilot at Heathrow! stellair you say you have both, can I ask you, did you really mean that?

And by the way there has never been a fatal accident in the UK attributed to an IMC rating holder exercising his legal priviledges.

IanSeager

8th Dec 2007, 07:49

Ask any American IR instructor how many times they fly a proc. NDB

I wish my instructor hadn't been so keen on these, I had to fly at least one on every flight during the second half of the course. I also got to fly one during my flight test.

Ian

TheOddOne

8th Dec 2007, 08:44

And by the way there has never been a fatal accident in the UK attributed to an IMC rating holder exercising his legal priviledges.

I've held the IMCR for over 20 years now and I've recently become a FI. I wouldn't have dreamed of trying to get an IR for this purpose, the IMCR does evrything I need to instruct.

As a new PPL many years ago I had a few 'dodgy moments' that encouraged me to do the IMCR. I think it taught me far more about avoiding unsuitable SEP weather than encouraging me to fly by sole reference to instruments in bad weather. I think that this is the beauty of the course and perhaps why IMCR holders have such an excellent safety record.

Personally I'd far rather cross the Pennines or cruise up the Western Isles at FL65 even if conditions are VMC rather than try and grub about under the cloudbase; depends upon what you want from the flight. Incidentally, the Isles look just as beautiful from that level, maybe even more so, as you get the breath of vision from up there. It's just that with the IMCR, it really doesn't matter to you if you DO encounter cloud. I probably wouldn't go, though, if I thought it was going to be cloud all the way.

I can appreciate that there are those who feel the need for an IR to give them access to the airways system and other Class 'A' airspace but I do agree that largely the IR is all about getting a RHS airline job, not taking a PA28 to Geneva or Nice.

TheOddOne

Fuji Abound

8th Dec 2007, 09:05

What well spoken comments from those who know what they are talking about.

I don't need to present you with any proof!

That is hallmark of the really dangerous.

Those that are so arrogant that they have no interest in the eivdence, only to blindingly repeat biased opinions that are derived not from fact but from commercial bias or unfounded elitism.

drambuster

8th Dec 2007, 09:30

Please don't confuse an IMC with being qualified or able to fly PROPERLY on instruments, you are NOT. THAT'S exactly how people KILL themselves!

Stellair ... ... your job security with 'Top Notch Airways' is not under threat from hoards of cheap labour IMCrs so please don't get too carried away with your superior qualifications.

You have spent so long at high altitude that you have forgotten (if you ever knew) what the IMCr is all about. It is not for the occasional 'rabbit out of the bag' to get you home safely. If you fly IMC that infrequently then that is where the risk comes from (whether IR or IMCr).

I fly (with PPL/IMC) routinely in IMC without autopilot - so far around 20 hours this year. So long as the minimums are OK at each end then, as far as I am concerned, I am not gambling with the lives on board. IMHO I can fly "PROPERLY" on instruments and certainly, I suspect, as well as you.

Safe flying :ok:

FlyingForFun

8th Dec 2007, 09:35

IO540, what an excellent post.

With one exception, though:That "quality" argument is utter elitish bo110cks. You are presumably a JAA IR instructor or better still a CAA IR examinerI'm a JAA IR instructor, but I most certainly do not go along with this idea that the IMCR is a rating not to be used!

Before I had an IR, I had an IMC rating, which I used to use as often as I could, even if it meant wearing foglges and taking a safety pilot. (The fact that the aircraft I owned at the time was day-VFR only meant that I had to go out of my way to hire an appropriate aircraft, but as an IMC rating holder, I understood that I had to keep current at instrument flying if I was to stay safe.)

Before I was an IR instructor, I was an IMC instructor. My IMC students, by the end of their course, were just as capable of doing everything on the IMC syllabus (and more) as my IR students now are of doing everything on the IR syllabus (and more).

So I'm with you 100%, it would be a real shame if the IMC rating were lost to Eurocrats, but please don't assume that IR instructors don't value the IMC rating!!!

FFF
-------------

DFC

8th Dec 2007, 09:38

Whoever says that pilots with licences issued after few hours training should bin their licence must have a very big bin. Of course, since many pilots do not even need a licence to fly in UK airspace (or much of Europe) and now there is the option to fly a fixed wing aircraft that is totally uncertified and untested, one must wonder how big their bin is!

As for the IMC Rating, the postings of many here just show how little understanding many holders of the IMC rating have about IFR IMC operation.

We have IO540, admitting to illegal flying - he knew nothing about IFR/airways flight planning or enroute strategy. I did all the planning and all the flying (you can not say that and at the same time claim that the PIC satisfied themselves pre-flight that the flight could be completed safely and legally there is also the fact that a smart insurance lawyer would easily show that the other pilot was simply a passenger based on what you said.) and others failing to remember or simply forgetting the often transmitted statement from the CAA that the IMC is not designed for prolonged flight IFR in IMC and the reminders that the IMC rating is not an instrument rating.

The UK aviation industry has complained that costs increased because of JAR. There is no evidence to back that up and I can tell you that for many including me (and it should be no different for any other training provider), the costs have substantially reduced...............many of the UK resident pilot population believed what they were being told and happily paid more for the same training failing to recognise that for example RTFs are issued free of charge and simply made the training providers pockets bulge further.

Then there was the CAA paper completed which showed that there was no change in safety caused by JAR-FCL. Why on earth should harmonisation of licensing make things more (or less) safe......it was a harmonisation project not a safety initiative.

The UK has similar weather to Ireland and other parts of the world have worse weather at times. The UK is unique in providing VFR pilots the legal ability to depart VFR when the weather is less than VMC contrary to the VFR rules and the international standards. They can then later abandon the VFR flight to fly in IMC and never be required to report the poor pre-flight planning that caused them to abandon the VFR flight they departed on.

The rules are clear - if you plan to fly A to B VFR then the combination of actual and forecast weather must indicate that the flight can be safely completed in VMC. If not then the options are stay on the ground or plan and execute an IFR flight.

How much safety reporting data is lost in the UK simply because unexpected or rather expected but ignored IMC enroute on VFR flights is simply un-reported.

In other countries, VFR flights going IFR or VFR flights unable to maintain VMC are taken very seriously by ATS and the authorities.......why is the UK so lax?

There are advertisers in the current UK pilot mags providing JAA-IRs for about £6000. That is good value for what you are getting but you will not get it in the UK.....because people there prefer to pay £12,000 or moan.

Regards,

DFC

englishal

8th Dec 2007, 09:45

Stellair is typical of many of the bunch of pilots that we breed over here...
All gob. Although his profile reads that he is all ATPL'd to the hilt, I don't believe it as a) he has not one ounce of professionalism, or b) has a ****e attitude - not worthy of an airline captain. Maybe he is not then? Maybe he is just DFC reading from a different book?

What you find is the REAL PROFESSIONAL PILOTS have either a very reasonable attitude, or don't comment at all.

S-Works

8th Dec 2007, 10:17

Ha! I knew it would come down to a my IR is better than yours, even IO in trying to stop people doing it sunk to it himself in his last post.

Neither IR is particularly good at preparing you for the Practicality of flight planning across Europe. The JAA IR not gold plated either and is common with many other IR's around the world. The different regulators have choses different areas to focus on outside of the core skills. In the US more emphasis on partial panel and non precision approaches, little in the way of NDB as they have had the good sense to get rid of them. GPS approaches are the way forward and FAA focus on those. In Europe we are still heavily reliant on the NDB and so a large focus is made on getting IR pilots flying them very accurately. Part of the reason the course is longer is the extra focus on the NDB work.

What both IR's do is teach the pilot the most fundamental part of Instrument flying, as the name suggests actually flying on the clocks and that is the same the world over. The JAA IR is not designed for the RHS wannabes it is designed just the same as the FAA IR to get the pilot into Single Pilot IFR OPs safely. Flying the same routes with the sam instrument group of approaches to polish the test is as dull as hell, but is the only way the wannabes can afford the training. Many places will quite happily allow you to choose your schedule and routing. When I did my JAA IR I went on tour across Europe with my Instructor in the Twin, visiting places like Annecy in the mountains.

As IO points out neither course teaches you the really important stuff like getting routes into the system, how to arrange fuel in way out places etc. That is all learnt after the IR. Imagine trying to cover all that on top of what has to be learnt........... Flying is about a lifetime of learning.

Finally if anyone actually bothered to look at the academics they would discover that what is ACTUALLY required as learning material sits neatly in a slim A4 binder which is thinner than the Jepp FAA Instrument Manual. I have such an example sat on the desk in front of me. The questions in the exam bank have been slimmed down considerably as well.

But back to the IMCR.

I am a great supported of the IMCR but have many reservations as well. I believe that the general standard of teaching is very low. Howls of protest will follow about how great everyones Instructor was, how do you know this when you had no prior experience to compare it against.......

The core reason for this in my opinion is that those teaching it have gained the rating from others at the same level and over the years the standards have declined without anyone noticing.

I think that many people treat it as a get out of jail free card and only practice what were poorly taught skills in the first place every couple of years for renewals.

My view is that the IMCR should only be taught by an IRI with a current IR with proven experience on the clocks. Probably around the 150hrs of sole flight by instruments plus the usual CRI/FI requirements.

I think that IMCR holders should be required to maintain a rolling currency in the same was as the FAA IR along with 25 month revalidation.

We did some work earlier this year to tweak the IMCR and if you take a look in LASORS for 2008 you will see they are pretty good enhancements to move towards improving the standards. This work was also put towards the EASA as a recommendation for retaining the IMCR. Our group was a combined industry and CAA group.

The IMCR is a rating created by the late Ron Campbell in the mid 70's for AOPA. So it has not been around the 40 and 50 years people are spouting off on here. How can you be taken seriously at representing this when you have not even done your research on the background of the rating?????

His wife still represents IAOPA at EASA on flight crew licensing.

As Fuji points out holding an IMCR does indeed qualify you to fly on instruments. HOWEVER the CAA's view is that it qualifies you for limited exposure time on instruments NOT the lengthy times that an IR holder trains for. There are some IMCR holders who will go out and continuously train after the IMCR to reach the standards required for extended IMCR flight (an IR by DIY means?) but the average IMCR holder will do not further training after the initial rating. Most IMCR holders keep them as the bragging card in the club house to be able to claim they are an 'instrument' pilot'.

Whilst we can argue that there is a great safety case for the IMCR as has been pointed out there has never been an accident involving a CURRENT IMCR holder, there have been quite a few involving EXPIRED IMCR holders though. Playing devils advocate we can turn it around and ask what all of the people who don't hold IMCR's do? Perhaps we could argue that either the IMCR allows/encourages people to go flying in more marginal conditions or that actually it is a 'badge' and is not used by as many as who actually claim?

I have flown this morning, 8000m FEW1200ft, BKN1900 170/14kts RAIN a perfect flying day for those with an IMCR yet I heard no one else airborne. This is the same pretty much on every other crappy day that I go flying(and there are rather a lot of them).

So I am curious, lets have a few postings of those flights that poster on here with an IMCR (IO540 you are banned from response!) have actually used there IMCR for in 'battle' over the last 6 months and what they have done to retain currency. I am interested only in IMCR holders not FAA pilots with an IMCR on the back of a proper IR.

englishal

8th Dec 2007, 10:36

or that actually it is a 'badge' and is not used by as many as who actually claim?
While this may well be true, it is a badge worth having, just as some swimming "personal survival" badge is...you have it, but hope you never need it to some ;)

Actually, when I did the IR back in 2002, I rememebr thinking that after 15 hours I felt that there was NO WAY I'd venture into the clag on my own. After 45 or so I felt reasonably confident but still pretty nervous. The day after my mate got his IR we flew to stay with my brother-in-law in San Diego. The next day my mate had a date with the "fuel girl" up in LA and in typical fashion the weather was ****e. Down to minimums, frontal weather,rain, wind, you name it. He went and I bottled out :O He made it alive, and the fuel girl stood him up :} Still, it showed that his training prepared him for the flight, but he didn't mind admitting that he was shi++ing himself at times, and you can imagine that had something gone wrong it could be a receipie for disaster.

However, 5 years on it is a different matter. We know when NOT to fly, and when it is safe to do so. Our envelopes have also opened up so we WILL fly in worse weather but only if it is safe.

The same can be said of the IMCr. After 15 hours, no one is competent to fly "IFR" as in the airways, on a long cross country IMHO. However, these same IMCr pilots after XX hours "actual" are probably as safe as many IR pilots and probably safer than many, they just don't have the paperwork.

That is my view of the IMCr....a worthwhile rating which if used as a get out of jail free card, may just save your bacon. If used as a "mini" IR then this is ok so long as the experience is there to back up the lack of paperwork....if you get my drift.

Johnm

8th Dec 2007, 10:42

Bose-X

I think you hit the nail on the head in that the IMCR is used by some as a get out of jail free card and by others to make it more parctical to use the aircraft for transport while unable to find the commitment to do a full IR. I see nothing wrong with either attitude and they both add to safety in my view. One can survive getting caught out, the other can go in less friendly conditions than he could otherwise.

I see IMCR as to some degree a stepping stone to IR (rightly or wrongly) and was taught by a very professional lady (now a captain for Flybe) and examined by a training captain from a well known airline. I'm revalidated by an FAA/JAA IR examiner who is pretty stern.

I can fly approaches with confidence and fly in solid IMC under IFR outside controlled airspace fairly regularly.

I now have (I hope) the time to pursue an IR and I am going to sign up for groundschool at CATS I will then use it in anger whenever I can in my lowly Archer2 and maybe sell the Archer and buy a share in something a bit beefier.

IO540

8th Dec 2007, 10:45

So I am curious, lets have a few postings of those flights that poster on here with an IMCR (IO540 you are banned from response!) have actually used there IMCR for in 'battle' over the last 6 months and what they have done to retain currency. I am interested only in IMCR holders not FAA pilots with an IMCR on the back of a proper IR.

This kind of survey (attempted by so many) unfortunately means nothing, without looking into what people fly (aircraft/equipment) and what kind of access arrangements they have, and of course time/money budgets. THAT is the biggest limiting factor in pilot currency, not what kind of piece of paper they collected yonks ago.

I don't recall learning anything of relevance to actual instrument flight in the IR. But that could be because I had ~ 600hrs and about 100hrs IMC time (no AP) by the time I did it. Everything needed to fly Euro airways could easily be contained in a slightly modified IMCR syllabus. More than 15hrs would be needed but that's true for the IMCR in practice too.

The challenge would be finding instructors who can teach it out of personal experience (basically, no ATPL hour builders) and the punters would need to be wealthier too because once you starting doing real instrument flight from A to B it will get much more fun but rather expensive.

BTW there is no such thing as accurate flying of an NDB approach. Well, you could fly it accurately as far as the ADF instrument indication is concerned, but where the plane will actually be is another matter ;)

I rarely file Eurocontrol over the UK and just fly on what might be the privileges of the IMCR, Class G. Keeping current is not a problem - one just has to get out there when one can. In this weather it's very hard unless one is unemployed or doesn't have to work for some other reason, yet can still afford to fly. Yesterday was a perfect flying day but that was a rare break.

S-Works

8th Dec 2007, 10:55

I am not holding a survey IO, I am asking for real recent experience of people actually using the IMCR not just comments about how all good they are at it. Real flights like this week I flew to south end in a XXX the weather was xxx the approach was XXX and I flew XXX time on the clocks.
I am interested in the responses nothing more sinister than that. So come on all give me real flights and the reasons for them.
I am the only one who flew from our place this morning, the tea shack full of people with IMCR drinking coffee and talking about flying but not actually doing any.
And:
There is such a thing as an accurately flown NDB, how do you think all of us got through our IR's? +-5 degrees from the centerline as well as accurate NDB holds. It is not difficult just takes a fair bit of practice.
Your comment about finding nothing difficult on the iR just proves what I was saying!!
I don't recall learning anything of relevance to actual instrument flight in the IR. But that could be because I had ~ 600hrs and about 100hrs IMC time (no AP) by the time I did it.
I fly airways in the UK whenever possible. I am below 2 ton and I have an IR so why not?

While this may well be true, it is a badge worth having, just as some swimming "personal survival" badge is...you have it, but hope you never need it to some

All badges are worth having otherwise there would be no point in them.......;)

Johnm

8th Dec 2007, 11:10

I'll try and satisfy a little of Bose X curiosity.
Two relatively recent examples from me:
Kemble Fowlmere:
Routine VFR flight until the fog rolled up from the South, Fowlmere not accessible. Cambridge ATIS pretty marginal nonetheless upgraded to IFR and flew the Cambridge ILS down to 500ft AGL with no sign of runway lights(my personal view is that I'll take the recommended advice notwithstanding my level of practice or the legalities). Considered another go but the fog was still heading North so I decided to divert to Conington while I still could.
Alderney Kemble
Forecast at destination 6000 broken at 1200 which is above circuit height. Origin broken at 1500 9999
So I fly SVFR to 50N, IFR in class G to Kemble with services from Bournemouth Boscombe and Brize/Lyneham (thank you one and all v professional as always).
Arrive over head in weather rather worse than planned. Cloud base reported below 1000 in heavy rain, but ground visible through broken cloud. Options available divert to Filton/Bristol and take ILS approach or have a go into Kemble.
In the event I got more or less clear of cloud into pretty good visibility overhead the field at my decision height (900 ft agl ) flew a 600 ft bad weather circuit and landed without drama.
I also fly regular routine flights through Brize class d at 3000ft IFR in IMC to keep above their heavies en route Kemble and elsewhere and they merrily vector me all over the place if they need to, but always apologise afterwards:ok:.

I should have added that I've also flown practice ILS into Cambridge and Cranfield in living memory with safety pilot.

DFC

8th Dec 2007, 11:11

Just to point out a small point;

The amount of NDB training completed in the UK for the IR is not done because of a requirement to complete such extended NDB training. It is done because there is a requirement to practice NDB tracking and there is also a requirement to complete training in use of the single pointer i.e. the RMI or RBI.

Much of the single pointer training with the RMI and indeed the elements of the test that require such flying can be completed by using a VOR and the RMI pointer.

Problem is that the UK has far more NDBs at airfields than VORs.

Regards,

DFC

Fuji Abound

8th Dec 2007, 11:15

Bose

The IMCR is a rating created by the late Ron Campbell in the mid 70's for AOPA. So it has not been around the 40 and 50 years people are spouting off on here.

http://www.pprune.org/forums/showthread.php?t=263216

Interesting. Perhaps Mr Pilcher has it wrong then? Any one know any more?

I am the only one who flew from our place this morning, the tea shack full of people with IMCR drinking coffee and talking about flying but not actually doing any.

Well, at least that has answered one question that has been really worrying me. I am compelled to say you have no understading of the intention behind the IMCr do you?

drambuster

8th Dec 2007, 11:55

lets have a few postings of those flights that poster on here with an IMCR and have actually used there IMCR for in 'battle' over the last 6 months and what they have done to retain currency

Bose-X happy to oblige, but please don't quote me on any illegal bits ! :eek:

Nov Trip to Le Touquet , overnight then on to Rouen, and return to base on day 3. At least two hours of this was in IMC (zero viz), and the same again VFR on top. (all IMC in UK FIR only :}). Planned arrival at LFAT was with cloud break over sea and then final leg at low level.

Nov Bristol Filton from London area base. ILS arrival at Filton. NDB cloud break on return to base day 2. 80% of both legs were solid IMC. Interestingly on return flight from Bristol after signing off with Benson we free-called Farnborough who were so busy providing a single SRA that there was no capacity to provide any service to us ! Incidentally we always try to get a radar service in clag and squawk Mode S at all times.

Oct Overnight to private strip in Norfolk. Great weather up there but cloud from 800' up to 8000' around London. Luton provided a terrific service all the way around London TMA at 2400' (from Maidenhead area). Shot out of cloud just north east of Stansted.

Oct Business trip to Guernsey. Again 800' base. IMC over Farnborough, climbed on top by Isle of Wight at 6000'. Descended into Jersey Zone breaking out at 3000' in time for SVFR, but carried on with ILS for practice.

I won't bore everyone with more detail but other destinations have been Hungary (Gyor) stopping half way in Germany (Speyer). Western Isles (Islay, , Oban, Plockton, Glenforsa . . strongly recommend the Glenforsa log cabin hotel on the grass strip with pilot owner, Brendan Walsh!), Scilly Isles, Bodmin, Exeter, Roserrow, Jersey, Deauville, St Malo (Dinard), Friedrichshafen for the Aero (but that was April). What all these trips have in common is a high percentage of IMC. Without the IMC rating then all of these would not have been possible unless I had zero time constraints (which I don't).

Our aircraft is well equipped with mode S, Garmin 530 with terrain, Stormscope, RadAlt, ADF, VOR, DME, HSI, twin horizons, handheld Garmin 496. There is no autopilot, and this suits me fine as every trip counts as 'real' training. We fly GPS as primary and cross check to VORs/NDBs. We never fly above 12,000' so airways and IFR routing is not a realistic option for us (even if we were to obtain IRs)

We have registered the aircraft with several RAF stations so regularly practice ILSs and PARs with them (in fact if the entire panel went blank then I would feel comfortable flying on the 496 as sole navigation and 'instrument panel' and doing a PAR into Benson on the iCom handheld!).

One personal preference I have adopted is to avoid single pilot IMC without autopilot. I have done a fair amount of it but find the workload is too high to have 'fun' (which is what it's all about for me). Trying to note down and change the transponder code in reasonably strong turbulence , along with everything else, certainly does get my full attention.:ooh:

So for us (there is one other similar minded guy in the group) the loss of the IMC rating would be a disaster. No doubt we would have to get IRs but, and I may be wrong about this, I see so much of that syllabus as being irrelevant to our typical flying profile.

Bose-X . . . . I look forward to meeting you up there some time on a suitably horrible claggy day ! :) I'm relying on you to have the TCAS kit :}

julian_storey

8th Dec 2007, 12:26

I think that IMCR holders should be required to maintain a rolling currency in the same was as the FAA IR along with 25 month revalidation.

It is rare that I find myself agreeing with BOSE on this forum, but he has made an excellent point.

Whilst unlike BOSE I think that the IMC rating is an excellent qualification and whilst I would dispute BOSE's claim that training for the rating is sub standard; the ability to fly on instruments, just like any other skill, degrades if it isn't practiced regularly.

The FAA IR has a rolling currency requirement. For those unfamiliar, the FAA require you to have logged six instrument approaches which include a hold, an intercept and VOR tracking within the preceeding six months in order for you to exercise instrument privilliges. A change to the IMC rating incorporating something like this, probably wouldn't be such a bad idea.

Fuji Abound

8th Dec 2007, 12:41

It is rare that I find myself agreeing with BOSE on this forum, but he has made an excellent point.

Rare indeed, but I agree.

stellair

8th Dec 2007, 12:43

drambuster

8th Dec 2007, 12:48

That is my view of the IMCr....a worthwhile rating which if used as a get out of jail free card, may just save your bacon

Englishal I agree with most of your points . . . . but not the one above ! Pilots who hold the 'badge' but don't maintain currency are best to avoid IMC at all costs. I may be a particularly poor example, but I find my instrument skills decay at an alarming rate. Just six weeks is enough to go off the boil. If I left it three months, say, then I would no longer regard myself as 'rated' and would do at least an hours sortie with a current mate to get back in the saddle.

This view is supported by Bose's comment (I think it was) that there are a fair number of accidents involving expired IMCrs. This is the worst of all worlds - you think you can do it but the reality is different.

I therefore guess I am agreeing with Bose and Julian Storey that the best way around this is to adopt the rolling currency solution. However, I prefer the self imposed method rather than a statutory licensing requirement !

Out of interest, what is everyones' view on the number of IMC rated pilots who are, in a practical sense, current? i.e regular IMC, or at least 4 hours a year and one flight in the last three months (which must be about as minimal as you could get to be current, wouldn't you say?) My guess is that only about 25% maintain it while the rest see it as a badge. I may be over optimistic in this assessment !

julian_storey

8th Dec 2007, 12:48

IO540, you are correct, I agree 100%..... I'm not questioning the IMC rating, as I said, it should be mandatory for a PPL issue in my opinion, great rating and as many have been quick to point out very safe. Let's not forget the title of this thread! It's not about IR vs IMC although I got sidetracked, it's about people venting anger that the french won't let them fly instruments in their airspace with an IMC.....WHY SHOULD THEY?? IT'S NOT AN IR, IT'S A UK ONLY QUALIFICATION!!!

I agree completely.

There is absolutely no reason at all why the French should allow people with a non ICAO, UK IMC qualification fly on instruments in THEIR airspace.

What I find objectionable, is that the folk at EASA would seek to prevent people with a perfectly adequate, UK issued IMC rating from flying on instruments in UK airspace.

Fuji Abound

8th Dec 2007, 12:56

There is absolutely no reason at all why the French should allow people with a non ICAO, UK IMC qualification fly on instruments in THEIR airspace.

I wouldnt bang on about that too much.

They dont allow people to fly in their airspace even with an ICAO rating - it has to be of the correct grade as well.

IanSeager

8th Dec 2007, 12:56

it's about people venting anger that the french won't let them fly instruments in their airspace with an IMC
AAAAArrrrgggghhhhh......who said it was the French? they may not have voted for it (not even sure they were at that particular meeting), but if it had been only the French then it would have passed.
The FCL.001 committee is made up of the following*

Ole Boysen Lynggaard – CAA Denmark
Matthieu Burgers – CAA Netherlands
Francisco Frontera – European Cockpit Association
Dr Annette Ruge – LBA (Germany)
Mike Dobson – UK CAA
Peter Moxham – BBGA
Zuzana Kapustova – CAA Czech Republic
Hervé Jammayrac – Eurocopter
Rudi Schuegraf – Europe Air Sports
Phillippe Tossan – AEA
Pam Campbell (AOPA)
Thomas Leoff (EAAPS)

*Thanks to Dave Roberts for the information from this (http://forums.flyer.co.uk/viewtopic.php?t=38946&postdays=0&postorder=asc&start=0) thread.

Ian

Fuji Abound

8th Dec 2007, 12:58

Ian

Yes, thank you for reminding us.

Are you able to provide some background on each of the members as I suspect everyone would find that very informative?

IanSeager

8th Dec 2007, 13:10

Are you able to provide some background on each of the members as I suspect everyone would find that very informative?

I'm afraid that I don't have that information at the moment. Like most I'm an observer with a vested interest.

EASA will bring major changes with winners and losers. We need a debate, but that debate should be informed (which hasn't always been the case in many of the threads)

Ian

Islander2

8th Dec 2007, 13:39

bose-x said:

The IMCR is a rating created by the late Ron Campbell in the mid 70's for AOPA. So it has not been around the 40 and 50 years people are spouting off on here. How can you be taken seriously at representing this when you have not even done your research on the background of the rating?????Good advice, bose-x; advice that perhaps you too should heed!

The IMC Rating was originally introduced in 1970. The syllabus at that time (10 hours) was biased towards basic instrument flying, with VDF its only let-down procedure. Prior to its introduction, a UK PPL could legally fly IMC OCAS without any instrument qualification. The syllabus was subsequently extended into a 15-hour course at the behest of Ron Campbell and AOPA in March 1981.

TheOddOne

8th Dec 2007, 13:42

I'd have thought at least 3 if not 4 from that list would have voted in favour, unless there was some horsetrading to allow something else to get through ('you vote my way on this issue and I'll vote your way on yours'). Lots of stuff gets changed that way, not seen as particularly immoral by politicians and I'm not saying that it necessarily happened in this case.

It's just that from the outside it can seem terribly unfair.

TheOddOne

The Flying Pram

8th Dec 2007, 13:51

You already do share the UK airspace with lots of them......have a look at the minimum requirements for the restricted microlight licence and how few dual hours are required in microlight training.

With a grand total of 15 hours a person could obtain a restricted microlight licence bring that up to a total of 25 hours a microlight pilot could be unrestricted and fly round the world.I cannot comment on the IMC vs IR ratings that this thread seems to have migrated to, but I do take issue with DFC's words above. The Restricted Microlight licence doesn't require navigation training, but limits flight to a maximum of 8nm from the take off point, in a surface wind of not more than 15kts, and a minimum vis and cloudbase of 5nm & 1000ft. You also cannot carry passengers until completing 25hrs total / 10hrs PIC time. It was conceived back in the days when actually flying 8nm without an engine failure was considered an achievement! Very few pilots fly with with this limitation now.

To get the Unrestricted licence requires navigation training the same as you. The 25hrs needed is simply a reflection of how simple and easy to fly most microlights are. I am well aware that the new breed of "Plastic Fantastic" machines are a different kettle of fish, but I doubt that any instructor is going to send a student solo in a £40k+ aircraft unless he/she is pretty sure it will come back in one piece.

I think that "digital.poets" idea has some merit. I remember finding it quite a jump going from circuits at a familiar airfield, to launching out over unfamiliar territory. A few flights with a local pilot to help out would have been most welcome.

S-Works

8th Dec 2007, 15:13

Good advice, bose-x; advice that perhaps you too should heed!
The IMC Rating was originally introduced in 1970. The syllabus at that time (10 hours) was biased towards basic instrument flying, with VDF its only let-down procedure. Prior to its introduction, a UK PPL could legally fly IMC OCAS without any instrument qualification. The syllabus was subsequently extended into a 15-hour course at the behest of Ron Campbell and AOPA in March 1981.

You know full well that I was referring to the IMCR in it's CURRENT form which is what all of these discussions revolve around saving. I was also making the point that the rating has not been around for 50 years.

Guess who was the AOPA Chairman in this period....

The IMC rating has been in existence in the UK for over 30 years. According to those involved in the original IMC rating Working Group, it was designed to provide private pilots with enhanced skills and greater confidence when faced with deteriorating weather conditions, by increasing a pilot’s instrument flying knowledge and radio navigation skills, when compared to the limited instrument flying instruction provided under the PPL syllabus.
The rating was originally lobbied for by industry representatives, most notably AOPA, who wanted to see a stepping-stone between the one-hour instrument navigation training provided under the PPL curriculum and the full-blown commercial Instrument rating, used by commercial pilots operating in Class A airspace.

The 15-hour IMC rating course finally settled upon, allows a private pilot to climb through cloud and operate ‘VFR on-top’ before letting down again through cloud at their destination airport on either an Instrument Landing System (ILS) approach or non-precision let down. The privileges are more limited than those afforded to holders of an Instrument rating, but are nonetheless said to enhance safety and prevent pilots "hedge-hopping" at low-level to remain in sight of the ground. Fundamentally, the IMC rating provides pilots with the skills to get themselves out of trouble when faced with deteriorating weather conditions, and was never designed as a ‘cheap’ Instrument rating. IMC rated pilots, for example, are not allowed access to airways, or Class A airspace and for flights within Class D airspace, which includes the airspace around many of the UK’s airports, Minimum Descent Heights (MDHs) allowed for instrument approaches as well as minimum horizontal visibility distances are much more restricted than they are for IR qualified pilots.

Nonetheless, renowned UK aviator, display pilot and ex CAA employee, Barry Tempest, who was involved in the original IMC consultations back in the 1970s, told us that the rating originally came up against heavy criticism from the professional pilot unions, who saw it as little more than a budget Instrument rating which could compromise the safety of their operations. And according to those present at the recent JAA FCL 001 group meeting in Cologne, the same negative reaction by professional pilot unions would appear to have occurred again, albeit this time by unions outside of the UK.

IO540

8th Dec 2007, 16:22

not allowed access to airways, or Class A airspace and for flights within Class D airspace

?

rustle

8th Dec 2007, 16:26

..., which includes the airspace around many of the UK’s airports, Minimum Descent Heights (MDHs) allowed for instrument approaches as well as minimum horizontal visibility distances are much more restricted than they are for IR qualified pilots.

At least quote the whole thing IO - it makes sense if you read it aloud.

englishal

8th Dec 2007, 19:03

But MDH's are not increased? (recommendation only)

rustle

8th Dec 2007, 20:43

But MDH's are not increased? (recommendation only)

Depends whether the AIP forms part of the requirements and/or law or is just something to read to while-away the time I guess :8

Perhaps we can have another IMC-minima thread when all the current hoo-hah has died down...

I'll start the thread on Wednesday ;)

Fuji Abound

8th Dec 2007, 21:18

But MDH's are not increased? (recommendation only)

You are correct.

I have it in writing from the CAA - no doubt what so ever.

S-Works

8th Dec 2007, 21:56

Semantics.

The quotations refer to the CAA recommendations for more restrictive MDA(H) rather than the law.

rustle

8th Dec 2007, 22:15

The quotations refer to the CAA recommendations for more restrictive MDA(H) rather than the law.

You sure about that bosey? ;)

Justiciar

8th Dec 2007, 22:21

Finally if anyone actually bothered to look at the academics they would discover that what is ACTUALLY required as learning material sits neatly in a slim A4 binder which is thinner than the Jepp FAA Instrument Manual. I have such an example sat on the desk in front of me. The questions in the exam bank have been slimmed down considerably as well.

It doesn't look as though you can any longer get copies of the regulation son the JAA website. So when are these changes coming in in the UK?

stellair

9th Dec 2007, 17:17

Drambuster

You have spent so long at high altitude that you have forgotten (if you ever knew) what the IMCr is all about. It is not for the occasional 'rabbit out of the bag' to get you home safely. If you fly IMC that infrequently then that is where the risk comes from (whether IR or IMCr).

I fly (with PPL/IMC) routinely in IMC without autopilot - so far around 20 hours this year. So long as the minimums are OK at each end then, as far as I am concerned, I am not gambling with the lives on board. IMHO I can fly "PROPERLY" on instruments and certainly, I suspect, as well as you.

20 Hours this year you say!
Good luck to everyone with their plight.:ok:

Contacttower

9th Dec 2007, 17:54

20 Hours this year you say! oh jeezzus hahaha I'm sorry, I think I walked into the wrong clubhouse!

Good luck to everyone with their plight.:ok:

Alright for some. :rolleyes:

S-Works

9th Dec 2007, 18:09

How anyone can claim they are current as an Instrument pilot on 20hrs in a YEAR is beyond me.............

Instrument skills are rapidly lost without practice. What becomes critical is the time it takes you to settle down on the clocks. An experience and current IR pilot can do it in an instant because they have been trained for it. The IMCR for the basic user just does not give this.

The safe IMCR pilots are the guys that go out and practice, practice, practice and 20hrs a year is not practice.
:rolleyes::rolleyes:

Contacttower

9th Dec 2007, 18:15

The safe IMCR pilots are the guys that go out and practice, practice, practice and 20hrs a year is not practice.

I quite agree bose...forgive me stellair but your post sounded just a little condescending.

Fuji Abound

9th Dec 2007, 18:16

settle down on the clocks

You are not still on that old kit are you Bosey.

Its all glass these days - not a clock in site - other than the one on your wrist. Tapes are what you need to be looking for.

Its all changing you need to get up yourself up to date. :) :) :)

Shunter

9th Dec 2007, 18:20

Please don't confuse an IMC with being qualified or able to fly PROPERLY on instruments

You sir, are a cock (and probably just some idiotic troll who doesn't have either an IMC or an IR). Please don't confuse the requirements and test standards of the IMC rating with the capabilities of an IMC holder who has practised and refined his skills to a level where he CAN fly accurately on instruments and CAN fly approaches perfectly safely to the same minima as an IR.

There are good and bad IMC's, just as there are good and bad IR's. I'm sure an IMC who's sharp and current would give any half-arsed IR a damn good run for his money!

stellair

9th Dec 2007, 18:44

Don't you love people that have the balls to call others a cock over the internet :ok:

S-Works

9th Dec 2007, 18:48

To be fair shunter, he has a point the basic IMCR is not designed for extended flight in IMC it is a pop up and down.

You have shafted your own argument by pointing out that someone who has honed his skills can be a safe and competent IFR pilot. There are a few ways to do this, go out and fly a lot and practice practice practice or go out and do an Ir where you will fly a lot and practice practice practice. The end result is the ability to fly on instruments but one gets to do it an all classes of airspace the other is VERY limited.

I would be very interested to hear about your experience with current IR rated pilots though, please share.

And I would suggest that you don't confuse the very simple test standards of the IMCR with those of the IR. Including the fact that no IMCR examiner will test to IFR minima only to the CAA recommended DA/DH. Therefore no IMCR pilot can claim they have been tested to the same standards as an IR pilot. They may with practice be able to fly to minima, although it would be interesting to see how many IMCR pilots have actually flown an approach ti IR minima in reality (rather than just claiming it), when I had an IMCR I flew a thousand hours on it using it as a mini IR and can count the number of MINIMA approaches I did on 1 finger..........

Contacttower

9th Dec 2007, 18:53

They may with practice be able to fly to minima, although it would be interesting to see how many IMCR pilots have actually flown an approach ti IR minima in reality (rather than just claiming it), when I had an IMCR I flew a thousand hours on it using it as a mini IR and can count the number of MINIMA approaches I did on 1 finger..........

I suspect bose that very, very few IMC rating pilots have flown an ILS all the way down to 200ft...most (and I include myself in this) would not be going flying at all with such a low base because firstly we probably took off from an airfield in the open FIR with no IAP anyway and since we rarely rent aircraft overnight the prospects of getting back again to our 'field' would be almost zero.

DFC

9th Dec 2007, 19:20

Indeed IR holders only very seldom operate to the absolute minima (for an IR holder).

--------

Flying Pram,

I think that you will find that I mentioned "Dual" Training and there is no dual training requirement or test in navigation to de-restrict a microlight rating.

Regards,

DFC

S-Works

9th Dec 2007, 19:22

I guess that was kind of my point. Looking at my logbook for November I flew 4 approaches to minima and another for to less than 400ft. The rest were all flown to what would have been acceptable for an IMC holder.

The fact is that the holder of an IR generally has one because the have a need to travel when the weather is crap and they have an aircraft capable of doing so.

The average IMCR holder is a club flyer, operating from VFR airfields in ill equipped aircraft. So to try and compare an IMCR holder to an IR holder is not smart.

I flew yesterday, no one else at my airfield did they sat and ate chips and talked flying as the weather was 'crap'........ Most of them IMCR holders.

Fuji Abound

9th Dec 2007, 19:53

I flew yesterday, no one else at my airfield did they sat and ate chips and talked flying as the weather was 'crap'........ Most of them IMCR holders.

You said that yesterday and I let it go.

Do you think flying on instruments is like one of your contests in the playground?

Good for you that you flew yesterday. Actually when you claimed you flew yesterday both the TAFs and METARs were fine. The weather was always forecast to detiorate later in the day - and, guess what, it did, and you were back on the ground.

So what if you p^&ssed around the local cabbage patch in a bit of cloud and wind!

I suspect those sitting in the club house had a bit more sense. No where to go on such a miserable day and no good reason to go - unless you happen to work at the weekend.

.. .. .. but if that is what turns you on .. .. ..

Whether you have an IR or IMCr is not some sort of competition in who has got the most gold plate.

You really need to understand that each has its own use, and each in turn is potentially as good, or bad, as the pilot using it.

I think you will find that those with 10,000 hours in light aircraft usually are not so inclined to boast when they have a job to do and go fly in weather when they would far rather have their feet up in front of the fire.

When you go fly in your single in crap weather with the base on the deck it doesnt matter if you have an IR or not when the donkey stops you are going to kill yourself.

drambuster

9th Dec 2007, 20:04

Bose & Stellair

The safe IMCR pilots are the guys that go out and practice, practice, practice and 20hrs a year is not practice

As I have pointed out earlier in this thread, all my flying is without the assistance of an autopilot. As a typical PPL doing about 100 total hours per annum, I would suggest that 20 hours of that flying manually in IMC is more than sufficient to maintain currency. I certainly don't need to 'settle down' as I have over 200 hrs total time on instruments and find the whole experience thoroughly enjoyable as well as being intellectually challenging.

It is not my objective to fly in conditions that require ILSs down to 200'. I am happy to stick with 500' or thereabouts as that ensures I can complete 95% of my planned business and leisure trips. If I wanted to improve on that then I would not hesitate to up the game and get an IR.

You both extol the virtues of the 'real' IR rating versus the limited IMCr. However, in my experience the 'paltry' 20 hours a year manual IMC flying exceeds that of many jet jockey chums of mine who point out that their company policy is to conduct the entire commercial flight on autopilot . . . especially if the conditions are bad. So although the two of you have creased up with laughter, I actually think my instrument skills compare quite favorably with many of my IR friends.

. . . .. and Stellair - I am gutted that you won't be joining our club. What a loss :yuk:

S-Works

9th Dec 2007, 20:08

I am sorry what part of my post prompted you make yet another personal attack on me?

You really need to understand that each has its own use, and each in turn is potentially as good, or bad, as the pilot using it.

Exactly my point I was merely pointing out the difference in use between the IMCR and the IR holder.

You said that yesterday and I let it go.

You really are a cocky ****. I also gave the METAR and pointed out it was a perfectly OK day for an IMCR holder, yet no one wanted to go flying.

I don't fly around the 'cabbage patch' I have better things to do with my time. I went flying because I had a meeting and I am curious to know what allows you to judge what aircraft I flew as I have a multi engine IR......

stellair

9th Dec 2007, 20:09

Once again I would ask the question as to how this became an IR vs IMC slag match when the thread started by asking about EASA and IMC tickets?

IO and BoseX have made some sensible comments.

Islander2

9th Dec 2007, 20:11

You know full well that I was referring to the IMCR in it's CURRENT form which is what all of these discussions revolve around saving. I was also making the point that the rating has not been around for 50 years.Bose-x, I've no desire to get into a spat with you, and the topic is way too important for this kind of bickering.

As a matter of fact, however, I didn't know that you/AOPA would argue the safety case based only on the more recent introduction of the 15-hour IMCR course that extended IMCR priviliges to include (limited) IMC access to controlled airspace. Nor would I consider that to be a sensible stance.

If that is considered to be the relevant time frame, however, I would point out that AOPA's own submission to EASA is consequently in error. The IMCR in its current form has been around since March 1981, which is 26 years not the >30 quoted by AOPA. Overall though, including in its previous guise, the IMCR has been enhancing PPL safety in the UK for 38 years.

stellair

9th Dec 2007, 20:17

drambuster,
Don't worry mate, no loss here either.

S-Works

9th Dec 2007, 20:30

Islander, it seems you are indeed looking for a spat dragging up a comment from several pages ago that has been discussed to death.

The AOPA submission is correct. It gives the correct number of years. It does not get dragged down in idle irrelevant history nor try to claim that the rating has been around since the wright brothers..... 38 years is not 50 years is it?

I do not see the relevance of your comment. The IMCR as it stands NOW is what needs to be preserved or are you suggesting we take it back to 10 hrs?

Anyway as I have said several posts ago, I am done arguing AOPA's case on here.

drambuster

9th Dec 2007, 20:31

Stellair

Don't assume how people operate, you'd be suprised,

My point exactly . . . so your conjecture throughout this thread that IMCr is not for 'real' pilots (but simply for getting stupid PPL mutts out of sticky situations) is also wide of the mark.

Sure you guys at Air Atlantique do some impressive hands-on IR work - probably more than most - but that doesn't make the IMCr a waste of space. The rating is absolutely fine for my business and private use and, unless it gets binned, I have no need to upgrade to an IR. Horses for courses :)

stellair

9th Dec 2007, 20:39

Drambuster, again go back and read my posts! I think it is vital for all PPLs to have an IMC, and what a superb rating to have available.

For once you have said something sensible....horses for courses. Absolutely.....

I originally felt the need to post on this thread to address a comment about the nasty old French and EASA that was incorrect. Somehow it turned into a battle about IR vs IMC..........Stupid .:rolleyes:

IO540

9th Dec 2007, 20:45

There is no practical difference between the IMCR and the IR, a few years down the road, within the limits of their respective privileges.

It all comes down to currency on type, currency on type, currency on type, and whether the man has the fund$ to get his hands on a decent plane. And you are only ever as good as your last flight.

The two training products are aimed at different markets and this is what results in one having often ropey currency - lack of time/money to fly and lack of access to a decent IFR plane.

Whereas somebody with an IR will either be using it on their own substantial flying budget, will be getting someone else to pay for it all, or will let it lapse.

Almost nobody will do an IR to fly rented spamcans. Most are illegal for IFR in CAS anyway.

Incidentally 20hrs/year instrument flight is plenty and is far more than the vast majority of IRs get. Most IFR flight is in VMC anyway, and most is on autopilot. If I was flying 500hrs/year (which is at the limit of what is possible while having any kind of life) and all of it on airways flights, I would not be logging as much as 20hrs/year instrument flight. Not HONESTLY.

The more clever you are in the weather/route planning, and/or the more powerful plane you fly, the less instrument time you will log.

Hilariously, the pilots who log the most instrument time are

a) pilots of unpressurised public transports (Trilanders and such) who fly at ~ FL100 max, and in bad weather they either fly in IMC (plenty of sick bags get used then) or they scud run the knackered old dogs over the sea at 700ft, all nice cosy CAA authorised stuff which is exactly what private IFR pilots try damn hard to avoid doing by flying VMC on top on oxygen in sunshine

b) pilots of > 1999kg piston twins who fly "VFR" ;) to avoid IFR charges - one often can't get to VMC on top while VFR because one can't get the clearance into CAS, so this kind of flying is often sitting in the muck the whole way

Pot and kettle come to mind when I read ostensibly professional pilots knocking somebody here.

drambuster

9th Dec 2007, 20:48

Stellair

Somehow it turned into a battle about IR vs IMC..........Stupid, but hey I took the bait with others.

All forgiven . . . . you can join us at Waltham any time :)

englishal

9th Dec 2007, 20:56

How anyone can claim they are current as an Instrument pilot on 20hrs in a YEAR is beyond me.............
I think 20 hrs per year Actual is quite reasonable???? Probably more than ANY airline pilot who is correctly logging gets that is for sure...

stellair

9th Dec 2007, 20:57

I love a happy ending :E

Fuji Abound

9th Dec 2007, 20:57

The average IMCR holder is a club flyer, operating from VFR airfields in ill equipped aircraft. So to try and compare an IMCR holder to an IR holder is not smart.

I flew yesterday, no one else at my airfield did they sat and ate chips and talked flying as the weather was 'crap'........ Most of them IMCR holders.

Bosey, so sorry if I have offended you. I was just being forthright.
I just cant get too grips with the inconsistancy.

It was you who just said the weather was crap. Now the weather is either crap or it is not. Perhaps if you have an IMCr it is a bit more crap than if you have an IR?

.. .. .. then there is the average IMCr holder. I dont think the rating has much to do with what aircraft the pilot owns or rents. I suspect that has a lot more to do with how deep his pockets are, so how that runs on into comparing someone with an IMCr and an IR I dont know?

Even if there was the casue and effect you suggest, firstly it would be meaningless because the population of owner operator IRated pilots is so small and secondly if they can afford the cost of the IR they can afford the cost of a more expensive aircraft.

.. .. .. in your contest a friend of mine flew today in a 152. The weather really was crap. He was also the only person flying. He doesnt have an IR. So what does that make him - an IMCr holder with bar or an idiot?

I get the impression that you dont understand the flying the average pilot does - that is all - and for that reason although I know you suggest otherwise I dont think you really understand the importance of the IMCr.

I have read most of your posts. I am sorry if you see it differently, but I can only tell you that candidly that is how I feel.

S-Works

9th Dec 2007, 21:05

As you want mate, I don't give a damn!

You twist everything I say to your own end. Even your last post.

I have flown this morning, 8000m FEW1200ft, BKN1900 170/14kts RAIN a perfect flying day for those with an IMCR yet I heard no one else airborne. This is the same pretty much on every other crappy day that I go flying(and there are rather a lot of them).

I quite clearly gave the metar. the weather was crap, but thats what an IMCR is for.......

Fee free to twist the above to your own needs.

At the end of the day, I no longer care, you know why? Because I can go where I want and do what I want. It's you thats losing because you can't concentrate on the job in hand rather to busy trying to stick the knife into me.
:D

You are quite right, things are changing..........

You are not still on that old kit are you Bosey.

Its all glass these days - not a clock in site - other than the one on your wrist. Tapes are what you need to be looking for.

Its all changing you need to get up yourself up to date.

rustle

9th Dec 2007, 21:07

Ignore her, bose mate: She ain't worth it. :D:D

Contacttower

9th Dec 2007, 21:26

Oh dear is all I can say....

I started this thread attacking EASA...who are kind of enemy number one at the moment...and yet despite this the thread still manages to descend like all the other threads on this topic.

It wouldn't suprise me if some EASA people were reading this...and laughing...a lot.

Fuji Abound

9th Dec 2007, 21:26

Well I am not going to give up, so for those who dont like it, get out the fire.

I would sign up if it was not factually incorrect.

If you want to get support for something you need to state the facts correctly......

So there you go, you have got the whole post this time.

Let me sum up what I am trying to get over.

The IMCr is really important. It is worth fighting for because I really believe it makes for a safer pilot. I dont care if you have an IR and IMCr or neither it is worth fighting for. In my view sign the petition because you believe in what it seeks to achieve. Who really cares if the IMCr is 50, 40 or 30 years old.

I am really glad to see a lot already have. Is everyone who has signed - wrong? Should we have preferred to see no names on it because of a single inconsequential error?

and on the AOPA issue, I personally think AOPA have done a bad job on this issue. The reason I go on saying so is because I think it is important to examine the evidence and decide whether we should leave this to AOPA. I honestly believe I and many others have set out the evidence.

To repeat myself if many of your members are raising the said same issues on your own bulleting board I personally think their comments should be taken serioulsy. I would expect to see evidence of that, and I havent - sorry again, but that is the way I feel. Show me the evidence and I will change my tune - happily I might add!

You may disagree. It makes me no less of a friend of yours because you do.

S-Works

9th Dec 2007, 21:32

you ain't my friend thats a fact.:ugh:

you are truly as mad as a hatter..... :sad::sad::sad::sad::sad::sad::sad::sad::sad:

Fuji Abound

9th Dec 2007, 21:39

As I said on the other thread -

clearly we disagree, so I am going to leave it at that.

:)

The Flying Pram

9th Dec 2007, 22:00

Flying Pram,

I think that you will find that I mentioned "Dual" Training and there is no dual training requirement or test in navigation to de-restrict a microlight rating.

DFC, From the "Microlight Pilot's Handbook" (the U.K. "bible" for microlight students):

Types of Group D Licence

Restricted - A minimum of 15 hrs flying instruction of which 7 hrs must be solo. The solo hours must be completed within the 9 month period prior to applying for the licence.

Unrestricted - In addition obtain a further 10 hrs flying time of which at least 5 hrs must be navigation training under instructor supervision.
Complete 2 solo X country flights of at least 40nm over different routes.
During each flight an out landing must be made at least 15nm from the take off point.

wsmempson

9th Dec 2007, 22:03

I haven't read all of this, but it looks like a bloody good punch-up; Has Sternone been posting again???:D

Contacttower

9th Dec 2007, 22:05

Has Sternone been posting again???:D

No, these guys make sternone look like an angel.:ouch:

DFC

9th Dec 2007, 22:29

Flying Pram,

Long time since I heard anyone talking of the group D licence.

Thanks for confirming that there is absolutely no dual training required to remove the restriction. A few hours solo with a few short hops to and from nearby fields get the ticket.

I am not saying that there is anything wrong with it, but others should not complain that they will have to share the sky with pilots who have very few hours training before obtaining a licence.

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

Getting back to the EASA situation.

The UK industry has so many holes in it's foot thatit is about to fall off.

Isn't the UK industry the one and same one who said that no one wanted a JAR-PPL and everyone who was not going to fly professionally would only want an NPPL....to which you can not add an IMC rating or Night qualification.

If the IMC is so essential for safety among the UK pilot population then why has the UK industry with the backing of AOPA decided that not only does the NPPL not need an IMC rating they should not be allowed to get one.

Is the UK weather different in some way when NPPL holders are flying?

The biggest growth area in the UK recreational pilot flying is microlight flying which of course is limited by both the NPPL and the aircraft certification to Day VFR.............is the weather diferent when flying a microlight along at 120 to 140 Knots?

AOPA UK have in this case to deal with people who do not recognise the old boy's squadron tie brigade and who know a thing or 20 about flying. try telling someone from Ireland that the UK has worse weather or someone from Switzerland, Norway, Sweeden, Iceland etc etc etc.

Regards,

DFC

Crash one

9th Dec 2007, 22:52

Do forum members have to buy arse kicking boots or can they be rented like ice skates?

Edit:
DFC
I agree with that, It is also not possible to get a seaplane rating on a NPPL (A) but is allowed on a NPPL (Microlight)

Fuji Abound

9th Dec 2007, 22:56

AOPA UK have in this case to deal with people who do not recognise the old boy's squadron tie brigade and who know a thing or 20 about flying.

I am not certain of the point you make?

try telling someone from Ireland that the UK has worse weather or someone from Switzerland, Norway, Sweeden, Iceland etc etc

I am not sure whether you intend this as a critcism of the UK seeking to maintain the IMCr? I do know that there are many pilots in Europe who are envious of the IMCr. I also know of some pilots who do not understand its purposes. When they do they join the ranks of the envious.

Surely better to have a rating pilots can obtain than to use France as a better example where the number of pilots with an IR is equally small but those with out fly in IMC regardless?

In a perfect world perhaps anyone ever wanting to fly in cloud would have an IR, would fly a minimium of 50 hours a year, and would be ramp checked every month. We live in an imperfect world. It is knowing where to draw the line. The fact that the safety record of the IMCr is so good, would suggest it is a pretty good place to draw the line.

Why is it in this debate so few people turn to the evidence? So much is based on those who would say it is inherently unsafe. Why? My gut tells me so, or if I spend £X on an IR then it must be unsafe. Demonstrate that it is unsafe by reference to the evidence accumulated over the last 40 years - in short put up or shut up.

On your issue of the weather I dont think the weather has anything to do with it.

I think the IMCr has a lot more to do with the foresight of those that recognised the need for the rating and its value. It just happens to be lucky that it was our CAA who decided to adopt the IMCr.

The biggest growth area in the UK recreational pilot flying is microlight flying which of course is limited by both the NPPL and the aircraft certification to Day VFR.............is the weather diferent when flying a microlight along at 120 to 140 Knots?

No but it would seem to be contrary to the whole concept of a microlight that you would fit it with IFR kit costing the best part of £40,000.

If the IMC is so essential for safety among the UK pilot population then why has the UK industry with the backing of AOPA decided that not only does the NPPL not need an IMC rating they should not be allowed to get one.

That's a good question. The NPPL is perhaps ideally not seen as an end in itself. If you want an IMCr or an IR why not remove the restriction by converting to a PPL?

Is the IMCr so essentail to the safety of UK pilots?

Probably not - but, safety from weather is assured if you are selective about the conditions in which you fly, but if you are this hugely restricts the days on which you can fly. Weather forecasting by definition is not an exact science and nor is pilot judgement. Fly on days when the forecast is CAVOK and hopefully the weather will never be an issue. Fly on days when the weather is broken at 2,000 and it might be.

Pilots that comlete an IMCr course should be able to safetly demonstrate to the examiner that they meet the requirements of issue.

Much is made that the standard of training and examination is poor. If that is so dont use that to attack the rating, rather deal with the poor standard amoung professional pilots.

Contacttower

9th Dec 2007, 23:00

AOPA UK have in this case to deal with people who do not recognise the old boy's squadron tie brigade and who know a thing or 20 about flying. try telling someone from Ireland that the UK has worse weather or someone from Switzerland, Norway, Sweeden, Iceland etc etc etc.

Ah well, I suppose you are sort of right DFC, but that doesn't stop me hating the whole EASA project. The CAA in this country, despite how much we complain, is a good organisation which while hasn't done a great job as far as promoting GA is concerned is thoroughly fit for purpose as far as maintaining standards in safety...I don't believe EASA are...hence why I started the thread.

http://i226.photobucket.com/albums/dd195/edbellamy/DSCN0017.jpg

It was good while it lasted....:{:{:{

Islander2

10th Dec 2007, 08:53

Bose-x said:
I do not see the relevance of your comment. The IMCR as it stands NOW is what needs to be preserved or are you suggesting we take it back to 10 hrs?I was merely observing that the IMCR safety case is primarily one of reducing CFIT and loss of control accidents, and in that respect the entire 38 years history of the rating is relevant.

But you raise an interesting question.

Amongst the people actively involved with the authorities on this subject, you are by no means alone in appearing to believe it's already a lost cause. It seems likely, from what's been 'reported', that 1) the airline pilot lobby will prevail in preventing an EASA-wide IMCR (which is presumably a controlled-airspace issue, first and foremost); and 2) the objectives of the 'European Project' will prevail to prevent any national variations.

If the IMCR is otherwise to be lost, do you know if consideration been given to a fall-back position corresponding to the 1970-1981 IMCR, whereby the holder of the rating gets IMC privileges OCAS and special VFR privileges in controlled airspace? Maybe that's something the airline-pilot lobby would be more likely to accept, and could form the basis of a European-wide rating? Not ideal, from a UK perspective, but nothing like as disastrous to UK GA as the loss of the rating in its entirety. Does this have any merit?

DFC

10th Dec 2007, 17:48

Fuji,

Surely better to have a rating pilots can obtain than to use France as a better example where the number of pilots with an IR is equally small but those with out fly in IMC regardless?
............

in short put up or shut up

Go on then..........tell us that there are French VFR pilots flying IFR in IMC. :)

With microlights, it is more a case of we can fly on as many days as we want to as recreational pilots and we would rather have the fuel making up the max weight.

Have a look at these $3500 units - http://www.bluemountainavionics.com/products.html#eflite

Even the UK CAA was going to be having a long look at the IMC rating but EASA maye have helped it save face. Do you think that the CAA were going to keep the IMC rating while the Daventry CTA was made class D and much of the current class A was designated D or even E?

Have a vote among the UK recreational pilot population........would you prefer to retain the IMC rating and have large expansion in Class A airspace or would you prefer to have lower controlled enroute airspace mainly class D and E?

I can see what all the glider pilots, the NPPL holders, the hang glider pilots, the powered parachute pilots, and so on who make up the vast majority would vote for.

Not knocking AOPA but one must remember that they represent only a very small portion of UK recreational pilots.

I also struggle to reconcile "recreational pilot" with "I use my PPL for business and the IMCr helps when the weather is poor". Perhaps in the UK business is the new recreation?

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

ContactTower,

If "Safety is no accident" then are incidents just bad luck ? :}

Regards,

DFC

Contacttower

10th Dec 2007, 19:12

If "Safety is no accident" then are incidents just bad luck ? :}

Perhaps you should ask the CAA?

Fuji Abound

10th Dec 2007, 19:52

Have a look at these $3500 units

They are not approved.

Even the UK CAA was going to be having a long look at the IMC rating but EASA maye have helped it save face. Do you think that the CAA were going to keep the IMC rating while the Daventry CTA was made class D and much of the current class A was designated D or even E?

Yes

I also struggle to reconcile "recreational pilot" with "I use my PPL for business and the IMCr helps when the weather is poor". Perhaps in the UK business is the new recreation?

I dont know where the term recreational has come from - PPL are not recreational pilots they are private pilots.

Some interesting points, but I dont think they stack up.

S-Works

10th Dec 2007, 20:06

Explain why you don't think they stack up then?

DFC

10th Dec 2007, 21:29

They are not approved.
Do you believe that the majority of aircraft used for IMC training and by those that use their IMC ratings are fully IFR approved according the the full EASA requirements?
I can say that most schools in the UK use non-FM immune aircraft to train for IMC ratings and most pilots exercising the privileges of the IMC do not fly FM immune aircraft. Never mind that, there will be many flying round in cloud with no mode S long after it is required.
You might also like to look up the requirements for equipment on home-built or microlight aircraft to be approved...........none.
I may have been round for a long time but at the end of the day I am simply a pilot and do not have the argumentative skills and the backing of serious research and legal teams such as the NAAs do but I can fairly well rubbish much of the pro-imc rating arguments and plant plenty of doubt about the benifits of having it. If I can do that, what hope is there in using those arguments...........better arguments are required if there is to be any hope of success.
Regards,
DFC

Fuji Abound

10th Dec 2007, 21:51

Do you believe that the majority of aircraft used for IMC training and by those that use their IMC ratings are fully IFR approved according the the full EASA requirements?

What has that got to do with the IMC rating?

I can say that most schools in the UK use non-FM immune aircraft to train for IMC ratings and most pilots exercising the privileges of the IMC do not fly FM immune aircraft. Never mind that, there will be many flying round in cloud with no mode S long after it is required.

Again, what has that got to do with the IMC rating?

I can fairly well rubbish much of the pro-imc rating arguments and plant plenty of doubt about the benefits of having it.

Well I don’t believe you have presented any arguments that fit that requirement.

I am never the less interested to see if you can, because if there are any effective arguments these need to be addressed.

As you know the IMCr is an instrument rating. In itself it has nothing to do with the aircraft. An entirely separate issue is whether or not the aircraft complies with the legislation for IFR operations. I know of a number of pilots with IRs who operate Cirius - the aircraft concerned are not fitted with either a DME or NDB receiver. The rating does not secure any more or any less a commitment from the pilot to operate aircraft that are EASA IFR certified.

The key question is whether the training is adequate to enable pilots with an IMCr to use the rating safely within the constraints of the privileges. The best evidence for this is the safety record of pilot's with a current IMCr.

Contacttower

10th Dec 2007, 22:08

DFC forgive me if this is a stupid question...or if I've missed the answer to this but what is your personal view on the IMC rating?

DFC

10th Dec 2007, 22:58

My pesonal view is that the idea is sound but the practical application is flawed in many ways.

There are so many flaws but as an example I would much rather see pilots having the training to as many put it get themselves out of trouble but still have the legal obligation to report the fact they they got into trouble in the first place.

Does one really have to fly in IMC to practice instrument flying or instrument approaches - NO.....Thus having completed the required training there is absolutely no further requirement to fly in cloud again in order to maintain the basic skill set that is then used to save a foolish unplanned excursion into IMC.

Also why does the CAA permit IFR passenger flight without IFR planning or IFR fuel reserves?

Why does the CAA allow an IMC rating holder to plan IFR flights wih no alternates?

Why does the CAA allow IMC rating holders to fly to plan lower minima than IR holders?

As i said.........flawed application of a good idea.

Regards,

DFC

IO540

11th Dec 2007, 06:29

Does one really have to fly in IMC to practice instrument flying or instrument approaches - NO.....Thus having completed the required training there is absolutely no further requirement to fly in cloud again in order to maintain the basic skill set that is then used to save a foolish unplanned excursion into IMC.

Same for the IR

Also why does the CAA permit IFR passenger flight without IFR planning or IFR fuel reserves?

You are confusing the requirements for public transport of paying passengers (under an AOC), with private flight in which the State has no business to interfere other than to minimise 3rd party risk, and 3rd party risk in GA is utterly negligible. GA passengers, assuming a nonzero IQ, are assumed to be aware they are not getting the same level of safety as on a 747.

Why does the CAA allow an IMC rating holder to plan IFR flights wih no alternates?

As above.

Why does the CAA allow IMC rating holders to fly to plan lower minima than IR holders?

As above.

Get real, DFC. You speak like a long retired ex CAA IR examiner. Most of the old guard of the great IR gate in heaven see the IMCR as a back door IR and slag it off accordingly. Any instrument privilege is only as good as pilot currency on type, etc.

Fuji Abound

11th Dec 2007, 07:46

DFC

I agree.

Again I dont believe you have flagged up defects with the IMCr - rather addressed endemic licensing issues that are equally as relevant to the IR holder and the PPL.

Moreover it is important to distinguish good practice from the law.

For example flying over ground fog in a SEP with an IR is perfectly legal, but the same flight with paying passengers is not, even with a PT6 up front. Is the former unsafe, is it bad practice or is it acceptable risk taking. Of course if the departure and arrival airports were clear of fog the IMCr holder could make this flight - but is he more or less likely to do so than the IR holder? If you believe Bosey with his clubhouse full of IMCr holders on a marginal weather day it is the IR holder who is far more willing to fly in "poor" weather. When the engine quits I dont suppose the IR holder will do any better than the IMC holder.

S-Works

11th Dec 2007, 08:34

I have a simple solution to your when an engine quits suggestion, make any Instrument flight a multi engine only exercise.........

What is the purpose of the IMCR then Fuji if not for flying on a marginal weather day, bragging rights in the bar that you are an 'instrument pilot' but never actually going anywhere near marginal conditions in case the engine quits?

You also did not answer my question about why you don't think other posters comments stack up.

You can't just dismiss things that you don't agree with without an explanation.

None of your points in the last dozen or so posts actually give a reason to save the IMCR they are just you constantly battering us with your opinion.
You are on a blind mission to shoot anyone down who does not agree with you.

I think DFC's posts about the type of aircraft being used and the skills are relevant ones. Not least because those are exactly the type of arguments being used to get rid of the rating. So rather than just repeating yourself by saying not relevant, not relevant please come up with a logical counter argument to fixing the situation that will convince those that are so anti. It's no good just keep putting others down when they come up with reasonable arguments its about countering them.

We would like you to lay out clearly your case for saving the IMCR without plagiarism from other sources and a clear plan to what you think we should do to save it.

I realise it will be a struggle for you without resorting to being rude but go on try it, you my even get taken seriously.

Contacttower

11th Dec 2007, 08:42

Moving on from the flaws of the IMC rating does anyone have any idea what sort of basis a legal challenge to EASA would be formed on?

S-Works

11th Dec 2007, 08:47

Moving on from the flaws of the IMC rating does anyone have any idea what sort of basis a legal challenge to EASA would be formed on?

You are kidding? Try asking a solicitor familiar with European law and aviation law in particular.

There are a couple of possible areas that have been identified but they are not high win chances and would be very expensive to pursue.

You get what you pay for when it comes to legal advice.......

Justiciar

11th Dec 2007, 10:20

Is the present issue about EASA's powers, which are defined by legislation from the European Parliament, or have we moved beyond this? If we have, then it a case of ensuring that their powers are exercised in accordance with the legislaqtion; otherwise it would be about influencing the form of the legisdlation and any power to allow national differences, which i suspect there would not be. However it begs the question why the French may be allowed to restrict access to altiports by way of a requirement for differences training whilst the UK may not be allowed, for example, to permit the flying of an ILS in IMC without an IR or permit let downs through cloud from VFR on top. Being devil's advocate, the difference in this example is that let downs through cloud are flights under IFR (as defined by ICAO) and EASA is unlikely to wish to file a difference with ICAO allowing this to be done.

What still concerns me is that the new "sports licence" being proposed is itself going to be a sub ICAO licence, thereby severely restricting the ability of pilots to convert or validate their licences in non EASA countries. This seems to be as important an issue as the six pages of mud slinging we have hade here over the IMCR :{

S-Works

11th Dec 2007, 10:40

Justicair, you have to look at it the other way round. There will still be a fully ICAO compliant PPL in the form of the EASA PPL just as with the JAA PPL. You will be able to add any ICAO compliant ratings to it that you want, ME, IR, SET etc etc etc.

The LAPL is going to be a European wide NPPL. So those that have an NPPL actually gain. It is also aimed at the permit type flyer who is really only interested in the local bimble or day vfr only travel. So for the permit tourer a licence that is cheap and easy to maintain like the NPPL but allows them to go into Europe is a benefit and keeps in with the low cost theme of their aviation.

I would be interested to see how many of those types who would go onto the LAPL would actually go an fly outside of Europe.

For the more adventurous the route of an ICAO PPL is still there and so they can go off an fly around the world and add lots more exotic ratings. The bridge between the two still has to be finalised but just as with an NPPL now you can convert to a JAA PPL you will be able to convert an LAPL to an EASA PPL.

For those that already hold a JAA PPL it is just a paperwork exercise.

The IMCR would have been a natural addition to the LAPL but it was shot out of the water when certain parties insisted the LAPL was to be a day VFR only licence. So the actual licensing structure makes sense largely, it is just things like the IMCR that have become orphaned as a result.

bookworm

11th Dec 2007, 10:40

Also why does the CAA permit IFR passenger flight without IFR planning or IFR fuel reserves?

Why does the CAA allow an IMC rating holder to plan IFR flights wih no alternates?

Why does the CAA allow IMC rating holders to fly to plan lower minima than IR holders?

Care to expand on these, particularly the last?

Surely the first two of these issues are related to Aircraft Operations, not Personnel Licensing. And they are addressed in the ANO, but with much less specific regulation than JAR-OPS 1, a difference that seems reasonable for the needs of private flying.

wsmempson

11th Dec 2007, 11:47

Stellair,how does what you have just posted on the IMC verses IR thread square with your comments on this thread?
QUOTE:
"mark,
Get that IMC . It's a great introduction to Instruments, unique to the UK, cheaper and is a priceless rating should you ever need to use it in anger for clearing bad weather or getting into an airfield in less than perfect VMC during your hour building to C.P.L.
When I did mine I had a very experienced instructor and he made me fly to IR limits which gave me a great leg up for things to come."
UNQUOTE:

S-Works

11th Dec 2007, 11:50

Are there we go again, nobody can resist the personal attacks can they.......

DFC

11th Dec 2007, 12:21

The rules are clear........you can not depart on a VFR flight unless the weather (reported and forecast) indicate that the flight can be made safely VFR.

IFR flights are required to carry suficent fuel for destination and alternate (or 2 alternates if limited met reporting etc etc for first alternate) and having reached the furthest alternate be able to hold for 45 minutes in the case of propeller aircraft.

IO540 - the comander is legally required to check pre-flight that they have the required fuel, oil and coolant.

Unfortunately, many IMC rating holders fly IFR without ever having considdered the fuel requirements, the alternates and so on and thus they have not acted legally if pre-flight they planned to fly IFR for any part of the flight. Of course if they are forced to abandon IFR enroute due to unforecasted IMC then they do not have the oportunity to plan in advance but they should report the circumstances so that the incident can be investigated.

Many IMCr holders will depart VFR knowing that they are going to have to fly IFR at some stage enroute. Thus there is a requirement to plann for an alternate should the weather not be as planned (VFR at destination).

We have had the debates here on PPRuNE. Many IMC rating holders fly as if they had an IR and use minima not appropriate to their rating.

Specifically, bookworm, there is no requirement for an IMC rating holder to apply higher minima at the alternate aerodrome when planning the flight (if they have even bothered to plan one) than at the destination i.e. the IMC rating holder can plan to a destination with an NDB approach and have an alternate with an ILS and use the 500ft DH and 1800m as minima where an IR holder will be obliged to apply non-precision minima at the alternate which could be higher than the IMC rating 500ft limit for a precision approach.

Overall if you were a citizen of another European country would you be happy with your government through the NAA permitting the IMC rating in that country with all the confusion that still surounds it so many years after it was started?

Don't forget that any NAA agreeing to an IMC rating will have their government minister thinking more about what the voters think that PPLs not being able to fly VFR into IFR IMC without submitting a safety report.

This is very much a political issue and one must wonder if so many foreign pilots wished their NAA had a similar rating, they never asked for on in their home country........and as far as I am aware, no UK IMC rating holder has ever applied to a foreign NAA for permission to exercise the ratying in their airspace.

Finally, one confusing issue in the UK is the fact that when you get your PPL, you are not permitted to fly to the limits of VFR.........you have to get an IMC rating to be able to do that. Getting rid of the IMC and getting rid of that very confusing licensing restriction unique to the UK will go hand in hand.

The altiport issue is a non-starter..........many airports have requirements that pilots must meet before flying in to them. For example, to fly into London City requires approval, simulator tests and so-on. They are justified on safety grounds in the UK just as elsewhere.

Regards,

DFC

Justiciar

11th Dec 2007, 13:14

The LAPL is going to be a European wide NPPL. So those that have an NPPL actually gain. It is also aimed at the permit type flyer who is really only interested in the local bimble or day vfr only travel. So for the permit tourer a licence that is cheap and easy to maintain like the NPPL but allows them to go into Europe is a benefit and keeps in with the low cost theme of their aviation.

That begs a few questions:

Will the EASA version of an ICAO PPL be any more difficult than it is at present? We would not want to see it made more difficult on the basis that it is only gained by people as a stage on the commercial route
If the LAPL is Europe wide, will we also see a pan Europen Permit system removing the need there currently is for Permit aircraft to get permission from some countries and not others?

A and C

11th Dec 2007, 13:45

I have that agree that the we need the IMCR or an EASA equivalent but all this thread seems to be focusing on is pilot licence issues, EASA is bigger than that!

Part M maintenance will be comming to an aircraft near you very shortly, the rules are changing by the day and reams of paperwork are having to be re-writen by engineering company's resulting in licenced engineers stuck in the office and not working in the hangar.

Who is going to pay for all of this pen-pushing?....................... the customer of course. There is little doubt that this part M will be pushing up the cost of maintenance and with supervising engineers having to spend so much time with the paperwork inspection standards will start fall due to time pressure.

S-Works

11th Dec 2007, 13:45

As I understand it there will be no changes to the existing PPL when it transfers to EASA. I don't actually think the EASA PPL is viewed as the commercial route, I think in the future it will see the prospective commercial guys going direct into the MPL without ever touching a light aircraft. One good thing to come out of is the end of the hours builders, which will hopefully drive the career instructor market and make it attractive enough for people to want to do it as a career.

I don't know about the Pan European permit thing, one of our PFA types might know more on that.

Fuji Abound

11th Dec 2007, 14:24

Bosey

Let me set out the position for you.

This is an internet forum. It is full of people a) with nothing better to do with their time, b) who think they know it all, c) want to keep up to date and learn from others, d) enjoy a bit of banter.

You and I have had a bit of banter over the IMCr. To the extent it is taken seriously there are some issues on which you and I clearly disagree. There is however a danger that the tone of the debate detracts from the forum. I don’t want to go down that road any further. It is you who dont want to be my friend and think I am totally mad which is fine by me.

However, the subject matter I believe is really important for two reasons:

a) I don’t think enough exposure has been given to the impact of the loss of the IMCr and for that matter other changes that will come from EASA,

b) and judging by all the emails I have received already and from the number of people that have already signed the petition I think there is widespread support for retaining the IMCr.

Stirring the pot in the way we have has produced a deal of interest. The threads, unlike in the past, have not been quick to die. There have been some excellent contributions. I think this is a significant step forward.

Now I know you want to goad me by the use of some well chosen terms - “plagiarism” comes to mind as but one example. However let me explain this:

I do not have the answers to all or even some of the questions - I am not an expert. I am not on any of the representative bodies. I certainly do not have the head start doubtless you and some others have.

What I do have is a belief that the abolition of the IMCr is a retrograde step. I also believe is that the vast majority of pilots share my view. I intend to ensure as many as possible are aware of what is taking place.

I believe that changes in legislation are not readily introduced if the regulators meet with significant resistance. I also believe that the IMCr is fundamentally a safe rating for a pilot to add to their license. I intend to gather as much evidence as I can to ensure that conclusion is sound. Inevitably, and as anyone would expect, that will rely on the work of others.

So, to conclude, I am glad we have raised the profile of the issue at least on PPRuNe anyway.

I know you don’t agree with me, or with my approach. I understand you think the battle is already lost. I know you think AOPA have done / are doing all they should. It so happens I think you are wrong. Fall out with me over that, tell me I am mad, or whatever, it doesn’t matter. Persuade me that all the people that have signed the petition are wrong or that the IMCr is fundamentally unsafe based on the evidence over the last forty years and I will sit up and take note.

DFC

Where is the evidence that all these pilots are doing what you suggest? I have started to go through every reported accident and incident and I have yet to find one involving an IMCr pilot in the circumstances or anything like the circumstances you outline.

There are many things a pilot is not specifically prevented form doing by law. In that respect the legislation can never be totally prescriptive. It recognises that a degree of responsibility comes with the license. More importantly there are clear recommendations regarding the limitations of the IMCr imparted both by the instructors and the CAA.

In answer to Bosey’s question about SEP flights personally I don’t think a pilot should depart with the cloud on the deck in a single piston whereas I do in a turbine. Clearly there are many IR pilots who would disagree but at least there aren’t any IMCr pilots who could disagree. Bosey exercises his judgement which he is entitled to do - some would argue he should not have that entitlement in these circumstances.

In exactly the same way there has been a lively discussion about whether a VFR pilot should depart if the forecast suggests he cannot maintain a given seperation from the ground. Yet another example is whether an IRated pilot should fly if there is a risk of icing (and the aircraft does not have certified de-icing). The law recognises for the private pilot these are calls of judgment. My own opinion is that it is best left that way.

If you are so bothered about all these IMCr pilots setting out in aircraft that are not certified for flight in IMC / IFR and departing with the destination at minima and no alternate apply the same standards to both IR and IMCr pilots in this regard so far as the legislation currently stands and enforce those standards for both. I suspect you might well end up prosecuting more IR holders than IMCr holders.

Contacttower

11th Dec 2007, 14:27

You are kidding? Try asking a solicitor familiar with European law and aviation law in particular.

It was more an attempt to steer things away from the arguements about the IMC rating....I don't know any aviation lawyers...but my dad was a European court judge for seven years.

S-Works

11th Dec 2007, 14:56

I know you don’t agree with me, or with my approach. I understand you think the battle is already lost. I know you think AOPA have done / are doing all they should. It so happens I think you are wrong. Fall out with me over that, tell me I am mad, or whatever, it doesn’t matter.

See there you go again, you are like a dog with a bone. I ask you quite reasonably to actually state your case and you go off attacking AOPA and me again.

You see every exchange as some opportunity to pour out your anti AOPA bile.

So lets go back to my original question, lets see if you can actually state your case in a calculated manner without resorting to attacks about what you see OTHERS having failed to do. YOU are trying to gain support, I am interested in hearing your case. So far you have failed to state one.

As for your petition, 200 (including Laura Croft and Basil Brush) out of 18,000 is failing to get me excited in the same way as it is you.

julian_storey

11th Dec 2007, 14:59

As for your petition, 200 (including Laura Croft and Basil Brush) out of 18,000 is failing to get me excited in the same way as it is you.

It is though a pretty good step in the right direction.

bookworm

11th Dec 2007, 15:39

DFC

I think I see what you're driving at but I don't agree with your statements:

IFR flights are required to carry suficent fuel for destination and alternate (or 2 alternates if limited met reporting etc etc for first alternate) and having reached the furthest alternate be able to hold for 45 minutes in the case of propeller aircraft.

You're quoting JAR-OPS 1. The ANO does not distinguish between VFR and IFR flights, though it does single out public transport in a way that is likely to require JAR-OPS fuel planning.

Art 52(e) in the case of a flying machine or airship, that sufficient fuel, oil and engine
coolant (if required) are carried for the intended flight, and that a safe margin has
been allowed for contingencies, and, in the case of a flight for the purpose of
public transport, that the instructions in the operations manual relating to fuel, oil
and engine coolant have been complied with;

Specifically, bookworm, there is no requirement for an IMC rating holder to apply higher minima at the alternate aerodrome when planning the flight (if they have even bothered to plan one) than at the destination i.e. the IMC rating holder can plan to a destination with an NDB approach and have an alternate with an ILS and use the 500ft DH and 1800m as minima where an IR holder will be obliged to apply non-precision minima at the alternate which could be higher than the IMC rating 500ft limit for a precision approach.

Again you're quoting JAR OPS 1. The law does not distinguish on the basis of rating held. For non-public transport flights, planning minima are simplistic:

49(6) If, according to the information available, an aircraft would as regards any flight be
required by the Rules of the Air Regulations 1996(a) to be flown in accordance with
the Instrument Flight Rules at the aerodrome of intended landing, the commander of
the aircraft shall select prior to take-off an alternate aerodrome unless no aerodrome
suitable for that purpose is available.
...
(6B) A flight shall not be continued towards the aerodrome of intended landing unless the
latest available information indicates that conditions at that aerodrome, or at least one
alternate aerodrome, will, at the estimated time of arrival, be at or above the specified
aerodrome operating minima.

If you were to say that, often, insufficient emphasis is placed on sensible fuel and alternate planning in IMC rating training, I might agree.

S-Works

11th Dec 2007, 15:40

It is though a pretty good step in the right direction.

And what is the right direction? As I have asked several times, I am interested to know exactly what the battle plan is?

Contacttower

11th Dec 2007, 15:46

I am interested to know exactly what the battle plan is?

bose why don't you tell us what the battle plan should be?

You're the expert after all.....

S-Works

11th Dec 2007, 15:51

I already gave my view on that and it was deemed as wrong, you obviously missed it in all the AOPA bashing.

I am genuinely interested in what your plan is. At the moment I see a lot of shouting and no clear direction.

What is so difficult about my question? As pilots we are being asked to sign up and support something. I am just not clear EXACTLY what we are supporting and why and so am asking a genuine question.

Kirstey

11th Dec 2007, 16:13

As pilots we are being asked to sign up and support something. I am just not clear EXACTLY what we are supporting
So you agree with my thoughts on AOPA then Bose ;)

soay

11th Dec 2007, 16:14

I already gave my view on that and it was deemed as wrong, you obviously missed it in all the AOPA bashing.
Would this (http://www.pprune.org/forums/showpost.php?p=3757496&postcount=26) be what you are referring to?

S-Works

11th Dec 2007, 16:15

Yeah whatever.

So back to my question, is someone going to state EXACTLY what we are signing up to support?

Fuji Abound

11th Dec 2007, 17:06

Bosey

Come on, you of all people know it is a closely guarded secret, it couldnt possibly be revealed on a anonymous forum such as this. If it was then someone would have to shoot themselves - and we would not want that, would we.

S-Works

11th Dec 2007, 17:53

So what you are in fact full of hot air and not worth supporting.

Fair enough.

Bus429

11th Dec 2007, 18:05

Haven't read all the threads but some factions of EASA are only concerned with complying with the Implementing Rule etc (although AMCs are not mandatory), rather than operating or maintaining safely.

Part M Subpart I sums up the confusion that reigns; there are a variety opinions as to the "privilege".

soay

11th Dec 2007, 19:36

Are there we go again, nobody can resist the personal attacks can they.......
I wonder who said (http://www.pprune.org/forums/showpost.php?p=3764047&postcount=112) that. Could it be the same person who said (http://www.pprune.org/forums/showpost.php?p=3764851&postcount=129):
So what you are in fact full of hot air and not worth supporting.
I wish the Internet didn't bring out the worst in people. :ugh:

Sleepybhudda

11th Dec 2007, 19:48

A Little background on me. Previous PPL/IMC (let IMC lapse) then trained JAA CPL/IR now FO on Jetstream 32 (no autopilot) Still flying privately on SEP/IR PA28 for Pleasure.

When I trained for both IMC and later the IR I can say that the JAA IR was Hard and more comprehensive than the IMC (was on a twin but still was 50hrs versus 15hrs for my IMC) Big differences on Hours.

Plus theory for IMC versus IR theory. Also big difference and harder for IR.

My opinion is that an IMC holder could use the rating as a mini IR if he remained very current. I've had bad days in IMC to IR minima (with a valid IR rating) in a PA28 and I am very glad I had the extra training. It was not a fun place to be.

Now that I have an IR im aware just how restrictive the IMC was because the IFR enviroment is geared towards IR rated pilots and I kept having to check what I was and was not allowed to be doing with just an IMC.

EASA is I believe a step forward for commercial aviation. I will admit its affect on GA at the moment are negative (Part M's yearly C of A and sign of by a different engineer an example).

Only hope for the EASA future?

Two IR's, one attached to the MPL another a Private IR. Easier to obtain than the JAA IR. More hours than the UK IMC (maybe 25-30 hrs).

With the exception of Single Pilot Multi engine Public transport the gap between the commercial world of IR (full EFIS, autopilot, Flight OPS department flight planning) and that of PPL/IR is seperating in my opinion.

englishal

11th Dec 2007, 20:23

The IR and IMC are both stepping stones...like degrees and HNDs.

10 years on, whatever bit of paper you have is irrelevant - it is you practical experience which counts.

Fuji Abound

11th Dec 2007, 21:11

Here are some observations to think about:

Controlled flight into terrain (CFIT) accounted for 30% of all fatalities between 1995 and 2004. There were 3,000 fatalities in consequence. (Source: CAA SRG 2006). In a similar length of time (1985 to 1994) CFIT and loss of control in IMC involving aircraft with a MTOW of 5,700 kg or less accounted for 28.5% of all accidents. (Source CAP 887 CAA Safety Regulation Group).

The SRG noted as follows:

“Typically, the CFIT accident involved the more mature and experienced pilot who, despite his experience, seemed to be oblivious to the dangers of continuing the flight into deteriorating weather conditions.”

The reports observes

“Usually, training for the Private Pilot’s Licence (PPL) takes place in good weather and with the advent of more candidates training for the PPL overseas, this trend is likely to increase”

and concludes

“It was considered that PPL training should be subjected to a greater level of CAA oversight to ensure that the best information is made available to candidates particularly in the areas of weather appreciation, calculation of safety altitude, flight planning and diversion techniques.”

The IMCr training syllabus incorporates all of the components of the SRG’s conclusion.

Loss of control in IMC was identified as the fourth most common accident type in the same report. The report states

"Three quarters of the pilots involved were attempting to fly in IMC when not qualified to do so."

IMCr training would have enabled the majoity of these pilots to avoid these accidents.

DFC

11th Dec 2007, 21:14

Bookworm,

No, I use ICAO annex 6 part 2 - the standard that the UK CAA says UK aircraft operate to with the exceptions noted. There is no exception for fuel planning requirements or to the fact that a VFR flight can not depart for anything other than a local flight unless the weather is VMC all the way to destination.

I also use the UK AIP.

I can't remember how long the debate on IMCr minima was..........but it certainly told the world that here was a rating that the holders were very confused about exactly what it entitled them to do.

If you lived in a European country where the IR was not as costly to obtain as in the UK would you want this hassle?

Don't forget that if EASA expands the IMC rating to all of Europe, France, Ireland etc are going to have UK IMCr holders flying IFR in their airspace while their own pilots do not have the option and if they wanted that they would have permitted the IMCr's use in their countries before now.

A and C tells us about all the extra paperwork that engineers are having to do and how he is going to have to charge more for maintenance. God help us, he must have picked that line from the training providers who claimed all this paperwork of JAR-FCL is going to push up costs...........Can any ATPL, CPL, PPL or Instructor point me to all the extra paperwork?

A and C should indeed help the rest of Europe maintenance providers and push up his prices. Perhaps UK pilots will see sense and take their business elsewhere in what is now at long last becomming a "common market" in aircraft maintenance.

Regards,

DFC

Fuji Abound

11th Dec 2007, 21:35

Don't forget that if EASA expands the IMC rating to all of Europe, France, Ireland etc are going to have UK IMCr holders flying IFR in their airspace while their own pilots do not have the option and if they wanted that they would have permitted the IMCr's use in their countries before now.

That depends on whether the IMCr can be permitted as a national exception or on whether it is adopted through out Europe. I dont think your proposal is viable.

I can't remember how long the debate on IMCr minima was..........but it certainly told the world that here was a rating that the holders were very confused about exactly what it entitled them to do.

I cant agee. I think it told the world that there were a very very few posters who did not understand the law and would not accept the "official" interpretation of the law which I might add has since become widly accepted.

I can see a similiar debate might well evolve between two IRed pilots, your goodself and Bookworm where you each disagree on the interpretation of the legilsation.

If that debate were to run to more than a few pages would we have told the world that here was a rating (the IRing) for which the holders were also confused about exactly what it entitled them to do? I dont think so.

Pot and kettle comes to mind.

stickandrudderman

11th Dec 2007, 21:37

I'm sure if I read every single post on here I'd learn something, but it's difficult to seperate the worthwhile content from all the mud-slinging and handbag swinging.
Could someone please PM me when it's stopped?

(Legal holder of an IMC but definately not current).

Fuji Abound

11th Dec 2007, 21:43

Stickandrudderman

I posted this on the other thread and I think it is worthwhile repeating because it may explain why the mud slinging has occurred and was perhaps always difficult to avoid.

Unfortunately if you feel as many you have to read past that and form your own view based on the evidence. That might not be supportive but for some of the reasons below I hope it is.

"Sunday Driver

It is indeed a shame and I regret the way this thread has deteriorated. I am sorry. However you should not under estimate the strenght of support.

Firsly, in case you did not follow the thread you should visit the petition and note the number of pilots already signed up. This has occured with no publicity other than that which has taken place on PPRuNe.

Secondly, there are people who have a different agenda, or one that is less than clear. It is in the nature of debates of this sort that they will vent their views. This forms an important part of the debate. By definition they are likely to be as vociferous as those in favour. However, I can assure you by the number of emails and posts I have had that there are many, who although they have not posted, have closely followed and support this campaign.

Thirdly, there are already a few of us who are working together to increase the profile of this issue. There will very shortly be a dedicated web site. There is already a petition. There will be far wider representation.

Forthly, consider this as a starter for ten posted else where.

"Here are some observations to think about:

Controlled flight into terrain (CFIT) accounted for 30% of all fatalities between 1995 and 2004. There were 3,000 fatalities in consequence. (Source: CAA SRG 2006). In a similar length of time (1985 to 1994) CFIT and loss of control in IMC involving aircraft with a MTOW of 5,700 kg or less accounted for 28.5% of all accidents. (Source CAP 887 CAA Safety Regulation Group).

The SRG noted as follows:

“Typically, the CFIT accident involved the more mature and experienced pilot who, despite his experience, seemed to be oblivious to the dangers of continuing the flight into deteriorating weather conditions.”

The reports observes

“Usually, training for the Private Pilot’s Licence (PPL) takes place in good weather and with the advent of more candidates training for the PPL overseas, this trend is likely to increase”

and concludes

“It was considered that PPL training should be subjected to a greater level of CAA oversight to ensure that the best information is made available to candidates particularly in the areas of weather appreciation, calculation of safety altitude, flight planning and diversion techniques.”

The IMCr training syllabus incorporates all of the components of the SRG’s conclusion.

Loss of control in IMC was identified as the fourth most common accident type in the same report. The report states

"Three quarters of the pilots involved were attempting to fly in IMC when not qualified to do so."

IMCr training would have enabled the majoity of these pilots to avoid these accidents."

This is just part of the reason why preserving the IMCr is so important.

As has been pointed out on here on numerous occasions the JAA IR is not a viable alternative for most private pilots. The FAA IR is an attractive alternative but the concerns about its use in Europe continue unabated.

Moreover an IR extends the priviliges of an IMCr beyond that which many private pilots require.

If you believe in flight safety and take on board the statistics and findings above I think we have a duty to support this initiative.

I commend it to you.

Please let us know your views?"

David Roberts

11th Dec 2007, 21:57

Have just been watching the (live) broadcast this evening from Strasbourg of the European Parliament reading / debate on the extension of EASA’s scope to Licensing, Operations and Third Country (i.e. non EU) Aircraft.
Several MEPs made reference to the importance of light aviation and the SME sector, the impact of EASA of costs particularly on maintenance (with a UK example quoted of a 60% increase). But most significant was UK MEP Philip Bradbourne’s speech which criticised EASA for its inefficiencies and failings, and the burden of red tape. “Not yet fit for purpose” he said, opposing the extension of EASA’s scope.
UK MEP Timothy Kirkhope (he is a private pilot) said EASA is incompetent, with delays in procedures and other difficulties and not yet fit for purpose. He said the UK costs were already high because of the CAA’s requirement to recover full cost. He referred particularly to the impact of EASA on private pilots and in particular the threat to UK pilots of possible withdrawal of the IMCR. He quoted Flyer Magazine, then referred to the UK weather which required the use of the IMCR . “Scrapping the ICR would be disastrous.” He asked the Commissioner (Jaques Barrot) to take a close look at this.
Barrot responded that he would be “at Mr Kirkhope’s disposal” to look at this.
The full Parliament vote on the 2nd reading is tomorrow.
I think the session was recorded and should be available at:
http://www.europarl.europa.eu/wps-europarl-internet/faces/vod/

Fuji Abound

11th Dec 2007, 22:07

David

It was a very interesting debate. The thread is well worth following. I have taken the libery of adding it to the sticky thread.

sunday driver

11th Dec 2007, 22:15

Fuji

The more recent posts, focussing on facts and statistics, raise the credibility of the debate, and of the participants.

Let's keep it up - it's the only way to inform and influence others who may be watching.

SD

PS The IMCr dramatically raised my respect for the demands of flying IMC and has enabled me to extract myself from IMC without drama. IMHO it should be a part of every PPL's kit, along with instruction in basic aerobatics.

Fuji Abound

11th Dec 2007, 22:20

Thank you - I hope that approach can be maintained.

bookworm

12th Dec 2007, 07:58

No, I use ICAO annex 6 part 2 - the standard that the UK CAA says UK aircraft operate to with the exceptions noted.

Annex 6 part 2 is for international air navigation. It would be perfectly reasonable to expect UK aircraft engaged in international air navigation to comply with it, and carry a 45 minute final reserve. Within the UK, the fuel planning requirements are simply as I have previously quoted from the ANO. I'd be very happy to see IMC rated pilots taught that a 45-minute final reserve is good, standard practice. But it would be a bit daft to emphasise to applicants for a national rating adherence to international regulations, wouldn't it? There is no difference between fuel planning requirements for an IMC rated pilor and an instrument rated pilot.

There is no exception for fuel planning requirements

That is a matter between ICAO, the CAA and the UK legislature. As you well know, many amendments were made to the ANO for conformity with ICAO Annex 6 part 2. Why this was not one of them I don't know.

or to the fact that a VFR flight can not depart for anything other than a local flight unless the weather is VMC all the way to destination.

As usual you're twisting regulation by placing your interpretation on it. The ANO says:

Art 52 ... (a) that the flight can safely be made, taking into account the latest information
available as to the route and aerodrome to be used, the weather reports and
forecasts available and any alternative course of action which can be adopted in
case the flight cannot be completed as planned;

That's all. No requirement for VMC to destination to depart VFR.

DFC

12th Dec 2007, 10:00

Controlled flight into terrain (CFIT) accounted for 30% of all fatalities between 1995 and 2004. There were 3,000 fatalities in consequence. (Source: CAA SRG 2006). In a similar length of time (1985 to 1994) CFIT and loss of control in IMC involving aircraft with a MTOW of 5,700 kg or less accounted for 28.5% of all accidents. (Source CAP 887 CAA Safety Regulation Group).

Please do not use stats that work against your argument for having the IMC rating!

You are saying that despite having the IMC rating available, a large proportion of accidents involved loss of control in IMC. Unless you expect EASA to require every pilot to hold an IMC rating, you are only proving that having it as an optional addition to the PPL does not improve safety.

Please also remember that many CFIT accidents are in VMC and were never near any IMC.

----------
Bookworm,

I think that you are misguided if you think that you are safe flying IFR without as a minimum complying with Annex 6.

Your argument about only applying to international navigation does not wash because if I am holding at a UK aerodrome I am on an international flight and the UK Government assures me through Annex 6 and the differences filed that I will not have my hold time extended by a sequence of local pilots having to jump ahead of me in the sequence because they do not bother to carry reserves or diversion fuel.

I am aware that some local pilot may jump ahead because they hold this IMC rating thing that permits them to file IFR but not be in a position to enter class A (where the hold is) or even to fly a hold. Annex 1 explains that to those who read it properly.

Regards,

DFC

dublinpilot

12th Dec 2007, 10:18

I think that you are misguided if you think that you are safe flying IFR without as a minimum complying with Annex 6.

Bookwork made no claim was to what was safe. He simply said that you were incorrect to claim that IMC holders and IR holders had different legal requirements regarding fuel. He's made that point pretty clear. IMC holder and IR holder have the same requirements, for domestic flight. IMC holders can't make international flights.

Your argument about only applying to international navigation does not wash because if I am holding at a UK aerodrome I am on an international flight and the UK Government assures me through Annex 6 and the differences filed that I will not have my hold time extended by a sequence of local pilots having to jump ahead of me in the sequence because they do not bother to carry reserves or diversion fuel.

On the contrary. It's your argument that does not wash, becuase that person in the hold could just as easily be an IR holder. The IR holder on a domestic flight, is operating to the same rules as the IMC holder on a domestic flight.

dp

Fuji Abound

12th Dec 2007, 11:22

You are saying that despite having the IMC rating available, a large proportion of accidents involved loss of control in IMC. Unless you expect EASA to require every pilot to hold an IMC rating, you are only proving that having it as an optional addition to the PPL does not improve safety

The fact that the majority of pilots involved had neither an IMCr or IR is significiant. It would sugest if you hold either you are much less likely to be involved in either. It is also interesting that of those pilots with an IR or IMCr more had an IR than IMCr out of a much smaller population or IR holders.

Please also remember that many CFIT accidents are in VMC and were never near any IMC.

Not so.

There were very few CFIT in good VMC. Marginal VMC or cases were the visibility could not be established accounted for the vast majoirty.

Bookwork made no claim was to what was safe.

You are correct.

I think you need to distinguish between what the law permitts, and what may or may not be safe. If you are going to suggest that the procedures followed by IMCr pilots which go beyond what the law requires are unsafe then you are also going to need to provide evidence to support that contention rather than anecdotal account simply because you feel it must be so from a possible perception that private pilots generally are a bunch of cowboys unitl they have a professional rating (which some perceive is the case of an IR)

There are many reasons why pilots not qualified to do so unintentionally enter cloud. Some very interesting studies have been undertaken at Cranfield and elsewhere. However not surprisingly the the process also starts from a perception that TAFs are more accurate than they are.

rustle

12th Dec 2007, 11:50

Firsly, in case you did not follow the thread you should visit the petition and note the number of pilots already signed up. This has occured with no publicity other than that which has taken place on PPRuNe.

Demonstrably not true.

FLYER forum
PPL/IR forum
AOPA forum

Don't know about PFA or UKGA but wouldn't be surprised to see it there too.

Stick to facts, or at least if you're going to lie about stuff don't be quite so obvious - credibility is everything in these discussions, and is currently nothing.:hmm:

Fuji Abound

12th Dec 2007, 12:01

Rustle

Lie = the intent of being untruthful

I had no idea that there are links to the petition on these forums.

Perhaps you would identify them as that would be most helpful.

Thank you to those who have posted these links presumably following the original post on PPRuNe - at least PPRuNe can still hopefully say "you read it here first" :ok:

Hopefully there is so much interest in this the word will spread very quickly.

criditability .. .. .. is currently nothing

Naturally, I am sorry that you believe that to be so.

EDITED to add:

Just had a quick look on AOPA. Do you mean this one:

http://www.joinaopa.com/forum/viewtopic.php?t=263

which seems to have had the link added on the same day I made the comment, so I suppose unless people were very qucik to sign up, at leat so far as the AOPA bulletin board is concerned by comment stands.

Fuji Abound

12th Dec 2007, 12:29

I thought this was an interesting comment from elsewhere worth repeating from a very well respected and very experienced avaition journalist:

It's disgraceful/shameful that the IMC rating was allowed to be led quietly and meekly to slaughter through a process not fit for purpose for these types of ratings. If the reps spotted this problem with the process, why weren't they alerting everyone to it months ago and objecting to it? Are they under self-agreed gagging orders or didn't they notice ?

2) Some of the other reps in the meeting 'deciding our IMC future' use VERY different classifications for their airspace, and their 'picture' of what really happens when pilots are let loose mixing it with commercials in IMC is not something you can break down that easily. I'd love to see the content of the UK pitch and perhaps even more interesting how long they had to get the message across. I suspect I will be shocked if I ever find out!

S-Works

12th Dec 2007, 12:29

You better have a word with your 'campaign manager' Julian Story then as he cross posted it all over the world. And it seems reading the response on a number of his cross postings that I am not the only one with reservations.
If you can't even get your supporters in line how are you going to deal with the regulators.......

A lie or an omission?

You still have not answered the question of how you plan to pitch this. It is all well and good screaming to save the rating which I am all for but how exactly are you going to save it?
Which licence do you intend on attaching it to and how do you plan on achieving that?

And I think if you are going to quote Irv Lee you could include all his comments and acknowledge him.

David Roberts

12th Dec 2007, 12:41

I have just posted the following on another thread re Norway and EASA:
I am just leaving for a meeting of the MDM.032 core group in Cologne, and there will be further discussion on the content of the LAPL (which was formulated in a sub group with separate people).
There is still two further chances to influence the process - (1) responding to the CRD - Comment Response Document - and (2) when the NPA is published, probably March 08
I suggest everyone looks at the CRD explanatory note which is in the third box down at:
http://www.easa.europa.eu/home/r_crd.html
You will see from this that the question of an IMCR / IFR rating was not the primary concern of respondents, but then the responses came from all over Europe including many at the very light end of GA (microlights).
The other related documents are there too.
It took an age for all the 8054 comments in late 2006 to be assimilated by EASA - a major task - hence the delay in publication.

DFC

12th Dec 2007, 12:54

Dublin Pilot, etc,

Unfortunately, it is a misconception (that even I held for a while) that what is legal and what is safe are two different things.

If you believe that it is unsafe to fly IFR without a proper alternate and proper quantities of fuel for diversion hold etc then even if the law in one part says to fly you only need enough fuel to take-off and land you can not use that as an excuse for unsafe operation which is the other part of the law that you will be breaking and your insurers will use to avoid their bill.

Remember that the CAA will prossicute everyone who runs out of fuel. They will not prossicute under the ANO article regarding pre-flight planning and amount of fuel to be carried they will use Reckless endangerment or similar.

Thus if the vast majority of the world use destination , alternate and holding fuel as a minimum and it is the international standard you would find it hard to convice a court they they are wrong and you are right in terms of safety and thus hard to disprove an unsafe operation.

--------

The difference is not between IR and IMC holders.........it is in the way that the rating is for the most part used. Far too many IMC holders will depart on VFR flights with VFR planning and VFR fuel knowing that they will at some stage convert (even for a short while) to an IFR flight. The training, the CAA guidance and as per your post, peer pressure does not enforce the knowledge that such flying is illegal and can result in an accident or at a minimum unnesessarily disrupt normal properly planned and conducted IFR flights.

I am simply trying to get the message across that the vast majority of the flying world look at the IMC rating in part as legalised corner cutting i.e. cut the corner on training,cut the corner on testing, cut the corner on revalidation and cut the corner on operational requirements and you have cut so many corners of the cheese that all that is left is several holes.

--------

Marginal VMC or cases were the visibility could not be established accounted for the vast majoirty.

Thanks for confirming that there is no evidence of IMC flying in the majority of cases.

Regards,

DFC

Fuji Abound

12th Dec 2007, 13:06

Bosey

There you go.

It certainly would be a disgrace. If you have a room of European 'peers' judging your proposal (to keep an IMC rating), you have to remember some basics :

1- Some of them have entirely different ways of using 'airspace' and unless detailed work was done with explanations they could well be anti IMC rating as they would try and visualise it in their country, and not see the same picture. ie: we can be talking 'apples', they can be sitting their visualising 'pears'.

For example, take Spain vs UK just for one of many. UK has enormous volumes of Class G, Spain doesn't, it uses Class E where we would expect G. We use our IMC ratings mainly in our enormous Class G volume, with 'mixing with commercials' happening (if at all) under strictly controlled conditions under radar for arrival. If you then consider Spain, with Class E as the 'main' airspace and commercials routing through it all the time, their commercials are not going to be too happy about a brand NEW concept to them (explained in a few minutes) of PPLs mixing it with them in IMC conditions after 15 hours training - of course they are not going to be keen because they are visualising what is happening differently!

2- Some of the people 'in the room' have totally different attitudes to 'safety' - for example France have between 60 and 80 fatalities a year in aviation and seem perfectly happy with that. Their attitude seems to be 'it's a dangerous sport, like mountain climbing, etc, so if they fly, don't be surprised if some of them die'. When you look at hours flown or aircraft numbers and deaths, fatalities in Italy are even more common, and 'who cares'? And these people actually have votes over whether we keep our IMC rating which we consider a huge safety benefit!

I'd love to see the 'pitch to keep the IMC' to see what arguments were put across in what way with what emphasis - and how long it lasted, given some of the attitudes listening.

If we'd come out of the meeting with a positive thumbs up, then basically we would be on a train, only having to make sure we didn't fall off it. As it is, we seem to have missed the train, which means enormous effort to chase it and try and board it, and that may or may not be possible, but it's certainly harder work!

The actual concept of presenting such a rating to other countries in a brief 'pitch' and asking them to understand it fully is flawed.

Irv Lee

You better have a word with your 'campaign manager' Julian Story then as he cross posted it all over the world. And it seems reading the response on a number of his cross postings that I am not the only one with reservations.

If you can't even get your supporters in line how are you going to deal with the regulators.......

My main objective was always to put this issue in front of as many pilots as possible. I am really glad to see the amount of debate that is taking place.

DFC

The difference is not between IR and IMC holders.........it is in the way that the rating is for the most part used. Far too many IMC holders will depart on VFR flights with VFR planning and VFR fuel knowing that they will at some stage convert (even for a short while) to an IFR flight. The training, the CAA guidance and as per your post, peer pressure does not enforce the knowledge that such flying is illegal and can result in an accident or at a minimum unnesessarily disrupt normal properly planned and conducted IFR flights.

Please would you let us know on what evidence you are relying for that assetion - or is it just anecdotal?

Euro MP

I am pleased to say that I have now heard directly from one of our Euro MPs. He has confirmed to me that the reports of the impact his submission had were very positive and a meeting will now ensue at which he intends to set out the views of so many UK private pilots. I was really pleased to receive this news because it would seem this issue is now at the fore front of the debate.

Fuji Abound

12th Dec 2007, 13:32

Bosey

Oh, I meant to ask, would you like to give us an update as to how AOPA are progressing with this issue at the moment please? Obvioulsy anxious that we all work together if we can.

dublinpilot

12th Dec 2007, 14:05

If you believe that it is unsafe to fly IFR without a proper alternate and proper quantities of fuel for diversion hold etc then even if the law in one part says to fly you only need enough fuel to take-off and land you can not use that as an excuse for unsafe operation which is the other part of the law that you will be breaking and your insurers will use to avoid their bill.

DFC,

I think you are in your own little world, trying to argue with things that weren't said. What I said was "Bookwork made no claim was to what was safe." That's all I said about that. Nowhere did I or Bookwork say that it was either safe or unsafe to plan in such events.

The difference is not between IR and IMC holders
That is all the Bookwork was trying to get across to you.

dublinpilot

12th Dec 2007, 14:07

Bose & Fuji.

Will the two of you please call a truce, or take your bickering to pm? It helps noone, and brings both of your campaings into disrepute.:hmm:

The important stuff is stuff is getting lost in pages of "AOPA didn't do x", followed by "You ought to get your facts right". :rolleyes:

dp

S-Works

12th Dec 2007, 14:33

No bickering on my prt DP, I merely asked questions which Fuji has yet to answer. He takes every post as an opportunity to attack me or AOPA or both.

So I will ask again, now you have this campaign in front of a full 250 of the 18,000 pilots in the UK, what are your proposals for the future of the IMCR?

It is obvious that it can't stay as it is because there will be no licence to attach it to. So what is your proposal? I am sure your Euro MP will ask the same question in due course.

Fuji Abound

12th Dec 2007, 14:39

Dublinpilot

Yeah - I would love too.

Genuinely with out wishing to pursue it in swift order there was a pathetic post about getting my facts right because I commented that the link to the petition was here, then clever remarks abouts lies or omissions and complaints about not quoting the whole of a post (most of us quote the bit we think relevant).

Quite honestly I think it is pathetic but there seems very little I can do about it. I am happy to ignore it except it worries me that some take these remarks seriously and that there is a concerted effort to side track a worth while campaign. I dont want that to happen.

What do you suggest?

"If you have one enemy you have one problem, if you have no enemies you dont have any problems" - well I think I have two enemies and there is not much I can do about it.

Edited to add:

Well Bosey has crossed with me on the usual theme.

For the last time - yes there are only 250 names on the petition, I know. Yes, we might be wasting our time. Yes, you have made a whole load of very valid comments - and no, I dont have all the answers.

In the interests of harmony I am not going to reply to another of your posts.

There are others I am sure who are better able than me.

I am just going to leave it at that and let you have a free hand in addressing whatever I say as you wish.

and no it is not personal - I just dont agree with the spirit or substance of some of your comments.

dublinpilot

12th Dec 2007, 14:43

Bose, it may not seem like bickering to you. But to the rest of us, it's obvious that both yourself and Fuji are carefully disguising your bickering as seemingly reasonable comments. But we can all see that each of you is just offering a red flag to the other bull. You are each as guilty as the other.

Call a truce or take it to pm. ;)

dp

dublinpilot

12th Dec 2007, 14:48

What do you suggest?

Me? I suggest that you stop attacking AOPA (and for the sake of pease refrain from any mention of AOPA for awhile..good or bad), and Bose stops provoking you and asking you pointed questions, and simply waits and sees where your campaign goes.

No appologies, no climb downs, no need to agree with this post or comment on it......just ignore one another on this particular issue for a few days until everyone calms down. We'll all be better off, and we all might get a little closer to our common aim...retention of IMC rights for the masses in some shape or form. :D

dp

Fuji Abound

12th Dec 2007, 15:02

So, as to good reasons for keeping the IMCr -

I think it is fair to say it is an often leveled criticism that it is a corner cutting IR.

In other words if the IR sets a reasonable standard, is the standard of the IMCr to low, is the IR setting a standard for a different purpose, is the IR in respects a too high a standard, or is it simply that there can be a safe but different standard?

Thoughts on the back of a post card?

S-Works

12th Dec 2007, 15:06

I am sorry but all I wanted was an answer on a single thread without the constant attacks on AOPA, the cross posting and the general abuse.

The self congratulation for getting a full 250 people including basil brush and penelope pitstop to sign up to a petition that is flawed.

Fudji might not have all the answers but he could have the courtesy of answering my simple question about how he plans to retain the rating. I am sure that I am not the only one wondering what licence he plans to attach this to and how. I am not clear what he is drumming up support for other than trotting out the same line time and time again between AOPA attacks.

The JAA licence is going, that leaves two options for the future, I want to understand what his pitch is going to be.

If he can answer clearly and intelligently without insults or digs then he will win himself credibility and I will back down.

Give me an answer and I will drop it.

englishal

12th Dec 2007, 15:11

It is obvious that it can't stay as it is because there will be no licence to attach it to
Oh I don't know. My mate held a JAA IR briefly this summer (matter of weeks) but didn't have a JAA licence. He did the IR before the CPL, using his American licence.....

S-Works

12th Dec 2007, 15:21

Oh come on Al, don't be daft, you know as well as I do that he may have passed the IR but without a licence he had nothing until the bit of paper was in his hand and there is no way of issuing a JAA IR with nothing to attach it to.

In fact just the same way as the IMCR will need to be attached to something in the future.

IO540

12th Dec 2007, 16:02

One thing I am curious about is what will happen to instrument training in the UK.

It's obvious almost nobody will do the "EASA IR" and anyway the vast majority of PPL schools cannot train the IR.

Presumably it will be possible to legally teach instrument flight but why would anybody bother if they don't get any privileges? It's like the various AOPA add-on module proposals from years ago - they fell flat because it was obvious nobody would do them in the absence of real benefits. Few PPLs train for the sake of it.

And if you can't log the lessons towards something, there is no benefit in going with an instructor. It will be just as good, in fact probably a lot better, to go up with an experienced private pilot and drill holes in clouds around some VOR etc. Lot cheaper too.

On the practical side, anybody instrument capable will still be able to fly in IMC under VFR, as people do all over the world. But, only with an OCAS departure, or only enroute. No instrument approaches in actual IMC, short of a mayday.

If all this comes about, things will get interesting...

Incidentally, Bose, the reason I did not believe the IMCR would end is because I never thought the VFR-only lobby would be able to "arrange" the committee votes to strip the LAPL of the IFR option, against EASA's express previous wishes. But they did it - a very clever move probably organised beforehand.

S-Works

12th Dec 2007, 16:35

Thanks, IO your apology is accepted........ :O

A and C

12th Dec 2007, 16:40

DFC please tell me how in your dream world do you not think that EASA part M will make maintenance more expensive?

All the maintenance companys are having to write new company manuals for part M, this requires engineers to sit in the office pushing a pen when they should be fixing aircraft or getting a contractor in.

Both cost money and so the cost will evantualy get passed on to the customer.

Some of the new maintenance regulations are more restrictive, this will lead to extra cost (more of that later!).

The CAA is making new charges for the maintenance approvals....... more cost.

A new EASA 66 licence is required by all licenced engineers by September 2008, cost £215.

All this extra expence is before the engineering companys make one extra penny.

DFC if you are dreaming of cheap eastern european maintenance you will find that it will turn into a nightmare when your aircraft goes "tech" and has to be fixed in the UK and you find that you have taken it outside the EASA part M "controlled enviroment" or you have to pay your eastern europeans to come over to the UK to fix it to keep it inside the "controlled enviroment".

Good luck with your common market theory but I can tell you now the only winners from this are sitting in an office in Cologne.

IO540

12th Dec 2007, 17:39

when your aircraft goes "tech" and has to be fixed in the UK and you find that you have taken it outside the EASA part M "controlled enviroment" or you have to pay your eastern europeans to come over to the UK to fix it to keep it inside the "controlled enviroment".

You will do what people have been doing since the beginning of regulated aviation. Do the work and not log it.

Most parts don't have serial numbers, and those that do can have the old sticker transferred to the new part. OK, that may be really crooked but unlogged maintenance is common. I am 100.0% certain there isn't a single plane flying, from a Tiger Moth to a 747, which does not contain substantial or legally significant unlogged maintenance.

So EASA will just shoot itself in the foot by making things too tight.

Having to stick with the same maintenance company is also great for companies doing bad work, because ditching a company is usually the only thing one can do if somebody has done a bad job. After a while, you build up a small band of trusted people, and you use different ones for different jobs. That (alongside brown-nosing and dealing with airfield politics) is probably the KEY learning curve in ownership.

Contacttower

12th Dec 2007, 17:46

from a Tiger Moth to a 747, which does not contain substantial or legally significant unlogged maintenance.

Apparently after a very heavy landing at Brize (something in the order of 3000fpm) which left daylight between the wing and fuselage of a Tristar inspection revealed previous repairs from another heavy landing and there was nothing in the logs about it.

Fuji Abound

12th Dec 2007, 17:54

IO540

The provision of instrument training is as you say a significant issue.

There are very few schools that are able to offer IR flight training. Approval is costly to obtain and in consequence the school has no alternative than to gear its operation to the commercial market. One consequence for example is that it would not be possible to offer commercial training without the school having access to at least two twin aircraft.

That is yet another reason for the poor uptake of the IR in Europe. Moreover it is even less likely to change in the UK with the demise of the IMCr which will result in many FBOs losing an important stream of income.

This is well worth a read.

http://www.easa.europa.eu/doc/Rulemaking/CRD-14-2006%20Explanatory%20Note.pdf

Please note

The stakeholders’ position concerning this question about the future licensing is summarised as follows:
The vast majority of stakeholders highly supported the envisaged new concept for a European Pilot Licence. Most of them mentioned all types of General Aviation aircraft categories. A slight majority of stakeholders considered that the future European Private Pilot Licence should be introduced for aircraft with a MTOM up to 5700 kg. However a considerable number of stakeholders proposed to develop requirements for such a licence for “non-complex” aircrafts only up to 2000 kg MTOW.
Concerning ratings, the vast majority of stakeholders considered that all the existing types of ratings should be introduced for the future European PPL. A significant minority however proposed to create a basic licence and additional ratings for the different aircraft categories.
Concerning medical assessments, the majority of stakeholders considered that medical assessments carried out by a general practitioner accompanied by some form of self declaration would be the right solution for this new European Licence. Many of them mentioned that an approved standard of aviation medicine knowledge for the General
CRD to A- NPA 14-2006
Page 9 of 10
Practitioners must be ensured. Amongst these only a few recommended an initial check by an AME7 or AMC8 with a subsequent procedure involving general practitioners based on
self declaration. Finally a small number of stakeholders expressed their disagreement with the proposal to introduce a system based on general practitioners.28.

and

Firstly, it would appear that despite the efforts made by the Agency to address the issue of better regulation in general aviation, the members of the microlight community continue to fear overregulation by the European community and have therefore applied strong pressure during this consultation process to leave Annex II unchanged. Secondly a certain portion of aircraft manufacturers have a clear commercial interest in maintaining and extending an un-level playing field that has allowed them to gain a very large portion of the market of very small aircraft. According to Article 2 of the Basic Regulation one of the Agency’s key objectives is to prevent such situations from occurring. It is therefore impossible for the Agency to take the proposal made to extend Annex II to heavier aircraft into account. Finally, considering the divided views on a possible reduction of Annex II, the Agency will analyse, taking into account the new situation that will be created by the new regulations stemming from this activity, the opportunity for any change to Annex II.

You can have your say:

The feedback is at the end of box 3:

http://www.easa.europa.eu/home/r_crd.html

The process last time resulted in 8,500 submissions and caused the proposals to grind to a hault!

DFC

12th Dec 2007, 17:57

Dublin Pilot,

The difference is most certainly between IR and IMC holders.

IR holders will have completed quite a lot of graound training and testing and can not calim to be uaware of the requirements for pre-flight planning in respect of any flight which at any stage will be IFR and also of the fuel planning requirements for the various scenarios not to mention point of no return, critical point etc etc.

The IMC rating training falls far short of covering even the basics especially when you consider that a UK PPL can obtain the IMC rating in a Cherokee 140 and fly IFR in a PA34 out of Gatwick after picking up their rating at the CAA.

Does any other country want an instrument qualification where pilots trained on single enine aircraft can exercise the privileges on multi engine aircraft?

----------

A and C,

If you have to work hard to catch up with the rest of Europe then does that not say something in itself. If on the other hand eceryone else in Europe is in the same boat then why are they not putting up their prices also?

You forget that managed maintenance does not restrict one to a single provider one can have maintenance completed at several approved organisations provided that it is correctly managed and controlled.

Some countries have had full maintenance engineer licensing for decades and issued type ratings to engineers. You could not certify a PA28 if you only hels approval for Cessna 100 series. In some countries there was always a visit from the NAA inspector at C of A renewal time.

The problem with leveling the field is that one end goes up and the other goes down.......unfortunately, you seem to be on the up end but that will not stop me going to the other end for maintenance if your prices rise.

Regards,

DFC

Contacttower

12th Dec 2007, 18:06

rustle

12th Dec 2007, 18:38

Small point DFC...surely an IMC rating taken in a single is not valid in a twin?

Yep. It is not type specific. :hmm:

Glad you boys know all these points you're arguing about :p

dublinpilot

12th Dec 2007, 18:52

The difference is not between IR and IMC holders.........it is in the way that the rating is for the most part used.

The difference is most certainly between IR and IMC holders.

:rolleyes:

DFC,

You are in your own little world.

You stated
Specifically, bookworm, there is no requirement for an IMC rating holder to apply higher minima at the alternate aerodrome when planning the flight (if they have even bothered to plan one) than at the destination i.e. the IMC rating holder can plan to a destination with an NDB approach and have an alternate with an ILS and use the 500ft DH and 1800m as minima where an IR holder will be obliged to apply non-precision minima at the alternate which could be higher than the IMC rating 500ft limit for a precision approach.

Bookworm clearly showed that you were mistaken. Neither he nor I made any comment on the safety of operating in such a way, just pointed out that your comment was incorrect. Why you have attempted to argue that you are correct because to operate in a particular way is unsafe, or because in your view IMC holder are or are not different to IR holders I don't know. Neither Bookworm nor I are talking about that. You are talking to yourself when you talk about that!

Our comments were simply pointing out that your above statement was incorrect. Nothing more, nothing less.

dp

Contacttower

12th Dec 2007, 19:01

Yep. It is not type specific. :hmm:

Then how come if you take the test in a PA34 you have to do engine out flying?

A and C

12th Dec 2007, 19:03

This is not just a British problem and we are not playing catch up, this thing is new for the whole of europe.

I expect the prices to go up across Europe, the big diference is that some european states provide the NAA free and in the UK the CAA charge for there services.

Level playing field ?................... Like hell it is!

Fuji Abound

12th Dec 2007, 19:10

The IMC rating training falls far short of covering even the basics especially when you consider that a UK PPL can obtain the IMC rating in a Cherokee 140 and fly IFR in a PA34 out of Gatwick after picking up their rating at the CAA.

DFC

You are correct this is an important issue. However it can easlily be clouded in emotive comment and subjective judgement.

I have asked this before.

Please can you provide us with evidence that the IMCr holder is unsafe or more accident prone. Please can you provide us with evidence that because these basics are not being covered in their training this is sufficiently significant as to result in incidents or accidents involving IMCr holders.

After all the rating has been around for a very long time. Please also take into account that the population of IMCr holders in the UK outnumbers private IR holders by a scale of at least ten and almost certainly more.

Glad you boys know all these points you're arguing about

Love it, keep it up.

rustle

12th Dec 2007, 20:46

Then how come if you take the test in a PA34 you have to do engine out flying?

Any MEP renewal (PPL/IMC/IR) done in a MEP will involve some assymetric (assuming a conventional MEP ;))

However legally, which is where I think DFC is, an IMC rating doesn't have to be renewed in a MEP or even gained in a MEP. Infact the first time a MEP/IMC pilot might do an assymetric go-around (from whatever IFR minima they choose to believe) might be for real.

Assuming (for sake of argument) the "same DH for IMC and IR holders" applies, that could legally mean a MEP pilot at 250 AAL engine-out in the go-around for the first time in their life.

Untested, unpractised, untrained, legal.

Sell that to the Europeans :oh:

Fuji Abound

12th Dec 2007, 21:12

Assuming (for sake of argument) the "same DH for IMC and IR holders" applies, that could legally mean a MEP pilot at 250 AAL engine-out in the go-around for the first time in their life.

Do tell us the last time you did an asy approach with go around at 250?

S-Works

12th Dec 2007, 21:25

My last IR renewal. 200ft actually.

Fuji Abound

12th Dec 2007, 21:33

.. .. .. and at what height were you visual?

S-Works

12th Dec 2007, 21:35

I wasn't. IR Renewal. Go figure.

Fuji Abound

12th Dec 2007, 21:48

So lets see not visual at DH lets say 250, sys asy, go around initiated, IMCr, with ME simulated asy not visual on a NDB DME with go around intiated at 750and the difference is?

Actually I withdraw that - I agreed not to get into this debate and I know where it is going.

I agree the IR sets a different standard.

Lets leave it at that.

rustle

12th Dec 2007, 21:56

So lets see not visual at DH lets say 250, sys asy, go around initiated, IMCr, with ME simulated asy not visual on a NDB DME with go around intiated at 750and the difference is?

Deciphering that the best I can, the answer is 500 feet and over a minute assuming a standard ROD.

IR renewal to answer your previous question: No "visual" as it was screens up, not some silly "foggles" - does that help?

Fuji Abound

12th Dec 2007, 22:08

Oh goodness - why.

What the hell just this once. I promise it really is the last.

.. .. .. and the FAA IR who does 6 approaches in six months.

Oh I know, that is a part 38 sub ICAO IR so it doesnt count, but the 25 month compulsory renewal with an asy go around is a sub sub not even ICAO rating so it counts even less. :}.

So lets see, one does it to 200 feet (without silly foggels I have noted), one doesnt do it at all perhaps for years, and one does it every 25 months (with sill foggles I have noted) 500 feet higher.

So the examiner passes the first, never meets the second, and even though the third nearly kills him, also gives him a pass.

Yep, I have got it now.

rustle

12th Dec 2007, 22:30

Some simple concepts about minima and what is legal.

An IMC is not type specific, and can be obtained in a non-complex SEP.

It can also be renewed in a non-complex SEP once every 25 months irrespective of whether it is used in a MEP/SEP/SET whatever.

Notwithstanding that, you could legally fly a complex MEP (if you are so rated) in IMC to the same IMC-rated minima - which on any other day you would argue is the same minima as an IR holder (albeit with 1800m met viz in lieu 800m RVR)

There is no requirement to ever learn, practise or be tested on assymetric IMC flight as an IMC holder: Not once every 25 months, not ever.

That ain't right and won't ever be accepted by EASA - deal with it. :8

Now if you want to start discussing why a (non-ATP) FAA IR is worth an IMC rating and not an IR that's another thread for another day. :D:p

Fuji Abound

12th Dec 2007, 22:36

I think you have just totally missed the point. Go figure.

Contacttower

12th Dec 2007, 22:57

The concept of what is legal and what is safe diverging is not something new in aviation and is certainly not confined to the IMC rating. Debate about the legality of twins in IMC etc does not make the concept of the rating flawed and need not form part of what we are trying to 'sell' to Europe.

All this talk about what idiots in planes could do seems slightly pointless considering that no one seems to have ever had an accident trying to do them. OK someone might do something stupid in future....but that is will be because he displayed poor judgement and not because the IMC rating is wrong.

rustle

12th Dec 2007, 23:01

All this talk about what idiots in planes could do seems slightly pointless considering that no one seems to have ever had an accident trying to do them.

Is that a researched fact or a "Fuji fact"?

I believe you are wrong, and no: I am not doing all your homework for you :8

Contacttower

12th Dec 2007, 23:13

Is that a researched fact or a "Fuji fact"?

No, I read in Pilot:

'there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record'

So it would appear that even though there is scope within the IMC rating for foolish yet legal behaviour thankfully no one has yet come to grief exploring it.

S-Works

13th Dec 2007, 06:51

Ah so you read it in a magazine so it must be true? Go and have a look at the AIB reports and then come back to us with an assessment. Maybe even have a look for some famous cases?

.. .. .. and the FAA IR who does 6 approaches in six months.

And the point is?

Islander2

13th Dec 2007, 07:07

rustle said:
Is that a researched fact or a "Fuji fact"?Actually, it's an "AOPA fact"... see pages 4 and 6 of the December 07 issue of General Aviation!

Any prospect that the juvenile point scoring can cease? Nah, I thought not! This really has turned into a "size of willy" debate.

Pity.

Fuji Abound

13th Dec 2007, 07:52

Any prospect that the juvenile point scoring can cease? Nah, I thought not! This really has turned into a "size of willy" debate.

Yes it really has.

However you are correct in your assessment of the issue I was trying to get at.

The point I was trying to make is that any rating is about drawing lines in the sand.

I might happen to think that an EASA IR who does not fly a single approach in 9 months and then go to minima is a very dangerous pilot. For that reason I might happen to think that an FAA IR holder who regulalry does an approach to self certify currency is a far safer pilot.

I might think that to fly an twin IR then the minima requirment should be a sim check every six months.

I might think that a compulsory revalidation every 25 months for instruments skills and annual revalidation for ME skills and the knowledge that my instrument rating should not be used to fly to anything like minima unless I am very current makes for a safer pilot.

As has been demonstrated you might think because you fly an asy approach to minima behind the screens once a year that must be part of a definitive standard.

The danger is because you have worked so hard to achieve a particular standard you think that is the only standard that should exist and the only way of ever doing it. After you have been doing the job for ten years your thinking often changes.

One point to take away from all of this is that in a number of studies there is good evidence to suggest that the most significant factor in accident occurence is not a pilots motor skills but their over confidence. In an intersting recent study it was consistantly the IRated pilots who were slower to react because they wrongly felt their skills should get them through the problem.

EASA of course has also to draw lines in the sand.

However, I am not aware of ANY evidence to indicate the IMCr is an inherently unsafe rating. Fortunatley whether you are signed up to it or not most agency appreciate they have a responsibility to assess regulatory impact.

EASA may kill of the IMCr as an administrative convenience but that would be a travesity for an agency who has as their primary objective - safety.

rustle

13th Dec 2007, 07:59

This really has turned into a "size of willy" debate.

Not really, imho.

On countless threads here and elsewhere people have argued that an IMC rating holder is not bound by higher DA/MDA limits than an IR holder.

I have highlighted one thing about an IMC rating that someone from EASA might think is a bit "iffy": That there is no legal requirement for arguably one of the most demanding missed-approach procedures to have been taught, practised or tested.

For my efforts I'm told by FA that I have totally missed the point. :rolleyes:

That isn't "willy waving" on my part.

Bose has asked a few times what, exactly, is being asked for. i.e. which licence do people actually want to attach this "retained IMC-R" onto.

Not had an answer yet, and that isn't "willy waving" on bose's part either.

Are posters really so stupid as to think that myself and/or bose are the only people in Europe who might actually ask any questions and expect something better as an answer than "you have totally missed the point"?

EASA committees will be wetting themselves with laughter if that's the best argument winner put forward.

[In a whiny 12 year old girlie voice] "You have totally missed the point. Go figure." :D

Brilliant.

Fuji Abound

13th Dec 2007, 08:10

EASA will probably create two "private" pilots licenses - so the IMCr will have to be attached to one or the other.

I am convinced EASA will take a long hard look at the safety record.

As Islander2 has so well pointed out:

"there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record" (Source AOPA)

I am convinced AOPA will take note of the views expressed by UK pilots and by our Euro MP's - in particular Mr Kirkbride who has already got the Commissioner's attention.

Contacttower

13th Dec 2007, 08:46

'there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record'

Actually, it's an "AOPA fact"... see pages 4 and 6 of the December 07 issue of General Aviation!

Ah so you read it in a magazine so it must be true? Go and have a look at the AIB reports and then come back to us with an assessment. Maybe even have a look for some famous cases?

So AOPA are wrong then bose? That's funny.....:E

Justiciar

13th Dec 2007, 09:06

I try and keep a sense of proportion in all this but it is very difficult. There is clearly a matter of basic principle at work here. There are those (many?) in Europe who see VFR sports flying as essentially incompatible with any formalised IMC qualification below that of an IR. The attitude appears to be that an IR is a professional qualification and amateurs have no business trying to fly IFR under any circumstances – or at least unless they have a £0.5m aircraft which can keep up with the heavy stuff. Hence the reluctance to reduce the theoretical knowledge requirements, for example, so that the IR can be more suited to the private pilot.

On the other hand we now hear a lot about regulatory impact assessment and devolving power down. This latter was a key theme in recent consultations. There appears to be no evidence that the IMCR contributes anything significant in the way of safety concerns. Indeed, you might argue that France, with no IMCR or equivalent has a substantially higher fatality rate because of the lack of any formalised IFR flying that the IMCR provides for; likewise, the US is on a par with the UK (where I believe about 50% of pilots hold the FAA IR, which though not “easier” to obtain in the flying sense is more practical and has a training regime much more accommodating to and less costly for the private pilot who has work and other commitments).

There are huge advantages to the IMCR which have become submerged in theoretical arguments about what the IMCR holder can do as compared to the IR holder. There is no evidence that these concerns have any basis in actual evidence of the way the IMCR operates in practice. Among the benefits are:

Hugely improved skill at flying in IMC, which I have certainly found of benefit if only during inadvertent flight into IMC;
The ability to descend through cloud from VMC on top or to gain VMC by ascent through cloud;
The ability to fly precision and non precision approaches if required if weather at destination is IMC
Improved VMC minimaThese are all definite benefits which contribute to safety. Yes, it might encourage pilots to fly in whether which is too marginal from the start, but there is again no evidence that this happens more frequently with holders of an IMCR than it does with basic PPLs (or NPPLs). In fact the better appreciation of flying in IMC might reduce rather than increase the chances of this happening. Too often the professional “we know best” brigade stamp on proposals which bring genuine safety benefits without any evidence to support their arguments. We see this time and again in aviation. This is a British and European disease. The existence of the IMCR is a beacon in a generally unimaginative regulatory environment.

Going further, the proposal to restrict the rights attaching to foreign based aircraft will strip away the rights of those owners holding an FAA IR to exercise the privileges of that rating by requiring them to place their aircraft on the EASA register. Again, there is no evidence that N registered aircraft in Europe are a safety issue, either because of their maintenance safety record or because of the quality of the IFR flying performed by their pilots.

So, in neither case has any convincing argument been made out, either for excluding an IR from the LASL or for excluding foreign based aircraft. These issues are now (as I under stand it from the recent European Parliament debate) in the political arena and may remain so for some time. They are not a done deal and the carve-up which has already happened behind the scenes and which has resulted in exclusion of any IFR rating from the LASL need not happen. There is a lot of hand wringing on these threads with an “I told you so” approach coupled with the attitude that it is now all a done deal. As far as I can see it is not. If the petition and these threads do any good it will be to on the one hand alert the politicians and on the other to make those in the representative organisations aware that the flying public may not be happy at what is being said, done and agreed to in their name. Certainly, the current perception is that the committees have a cosy agreement to carve it all up and then feed it to the politicians to rubber stamp. It will do none of us any harm if the politicians flex their muscles for a change and show them that they are not just a push over.

radicalrabit

13th Dec 2007, 09:28

Excuse me for a simplistic view but isnt the desired outcome supposed to be that ALL pilots ONLY do what is safe and for the legislators to make sure that what isn't safe is no longer legal?:confused:
And to that end there is an increase in quality of training and a decrease in ambiguity? If that were the case would not the (rest of the ) Europeans increase their levels of training to ours and not for us to lower our STANDARDS to theirs?

TRACK RECORD OF EEC initiatives / policies?

The "European" shambles (read EEC) created the common agricultural policy and common fisheries policy that have disasterous effects financially and environmentally but if they do that with Aviation the end result will cost lives.:ugh:

Justiciar

13th Dec 2007, 09:39

And to that end there is an increase in quality of training and a decrease in ambiguity? If that were the case would not the (rest of the ) Europeans increase their levels of training to ours and not for us to lower our STANDARDS to theirs?

The problem here is that the rest of Europe seems to be arguing that the IMCR is not conducive to safety - though there is no evidence of this other than to say that applying it to different European airspace structures would reduce safety.

Always be wary of the "safety" argument. Almost any daft bit of regulation can be dressed up as being necessary for "safety" without any evidence that it produces a measurable benefit in exchange for the inevitable increase in costs and the burden or regulation. Witness the JAR, which as compared to the old regulations have produced no measurable increase in safety of flying.

IO540

13th Dec 2007, 10:11

Justiciar, I think your post above of 10:06 is the best summary anybody could manage of the situation.

It isn't a done deal and a lot can still be done at the political level - despite the various vested interests that are trying to screw things from both the sports-VFR and the CAT ends of the flying spectrum.

DFC

13th Dec 2007, 10:16

In order to demonstrate an effective counter argument in this case, I do not need to quote stats or facts. All I need to do is simply plant seeds of doubt and hit on a few fundamental areas that will not be seen as reasonable by those who will sign the dotted line. Those people will be thinking of the impact on their pilot population or more importantly it's impact on their career if an IMC rating holder has an accident in their home country.

If you feel that the only way to press the case in favour of having an IMC rating is to quote stats and statements about the IMC rating then thank God you were not part of the team trying to establish the IMC rating in the first place because there was not much experience of how the IMC rating would work back then..............just like there is not much experience in the rest of Europe now.

I love the quote - "there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record" (Source AOPA)

Well I would not call an aircraft without full IFR instrumentation and radio equipment serviceable for IFR flight and more importantly...........a multi engine aircraft with one engine failed is most definitely not serviceable.

Similarly, I would not say that unsing less than the IMC notified minima is legal.

That AOPA statement is worth just as much as saying pilots who don't fly never have accidents.

-----------

All this talk of the IR being a professional rating is utter tosh. The IR is the qualifiecation for a PPL to fly IFR. It is not a professional qualification and confers nothing more than the ability to fly when VFR (or special VFR) is not possible.

The fact that if a PPL holds an IR that get a credit for the training they have completed if they apply for a CPL simply makes sense...............or would you prefer that applicants for the CPL who hold an IR must sit the exams to demonstrate the knowledge they demonstrated previously.

Again - the IR is a PPL level qualification that you get credit for should you apply for a CPL.

Regards,

DFC

Fuji Abound

13th Dec 2007, 11:36

Again - the IR is a PPL level qualification that you get credit for should you apply for a CPL.

I agree.

All I need to do is simply plant seeds of doubt and hit on a few fundamental areas that will not be seen as reasonable by those who will sign the dotted line.

I also agree.

An effective campaign must eventually focus on the facts.

Of course if ultimately the decision makers are not prepared to determine the issue on the facts then we are all lost!

Equally, I would not want to be one of those who had put forward a load of spurious nonesense purely for sake of destroying a worthwhile initiative.

Keef

13th Dec 2007, 12:00

Justiciar: thank you for some sensible words in an otherwise very noisy bar room. I hope the EASA and NAA folks aren't reading this lot.

There's too much argument about what individuals think, or see as potential risks, without facts to support. There are far too many teddy bears littering the floor round the prams. If the fighting tigers are really supposed to be representing someone, I despair about the process that "appointed" them.

Those who don't want to hold an IMCR aren't forced to. Those who do hold an IMCR haven't been driving into terrain with monotonous regularity - on the contrary. So it seems to work in the UK.

I have an FAA IR, but unless the aircraft has the magic letter N painted on the side, I can't use it in Europe. How sensible is that? In the UK, I can fly in IMC in my G-reg aircraft, but once I reach mid-Channel I suddenly become incapable of IMC flight. How sensible is that?

I never did get the hang of politics.

S-Works

13th Dec 2007, 12:02

EASA will probably create two "private" pilots licenses - so the IMCr will have to be attached to one or the other.

So to ask the question yet again..... Which of these is your campaign planning to attach the IMCR to?

rustle

13th Dec 2007, 12:08

...I would not want to be one of those who had put forward a load of spurious nonesense purely for sake of destroying a worthwhile initiative.

So which bits are spurious nonsense then?

Also, could you please link to these reports you keep mentioning and quoting from - if they are authoritative I'd like to read the whole thing rather than just snippets. Thanks.

Fuji Abound

13th Dec 2007, 12:20

So to ask the question yet again..... Which of these is your campaign planning to attach the IMCR to?

Please appreciate that I personally have come to this very late in the day.

As I have said on numerous occasions, you and others did warn us that if we did nothing we would only have ourselves to blame - so I decided to try and do something. Foolhardy - perhaps, misdirected - maybe, but I am trying and it is taking a great deal of time (and I dont mean the posts on PPRuNe - there is a fair amount going on that is not yet evident).

Without mentioning any other parties I did feel not enough was being done by any of the representative bodies. If I had, I would have left it to them.

So that was the conundrum. The atmosphere appeared to be one of - the battle has already been lost, so coming in behind with the cavalry was no bad thing.

I appreciate your questions, but you must understand I dont have all the answers yet for the reasons I have said. However I am in discussion with those who I think can answer some of the questions and understand far better that I what is possible and technically the best way of achieving this. I am sure you are well aware of some of what is taking place and the discusions that are already underway.

Rightly or wrongly, I beleive the key at the moment is for there to be a full, sensible and mature debate about the issues, which sadly has not taken place before, an assessment of the support for retaining the rating, whilst developing alongside the best way of bringing to fruition what the majority of pilots believe is an important initiative.

I would hope we can all work together constructively, even if some may believe there are good reasons for not retaining the IMCr.

Does that answer your questions?

S-Works

13th Dec 2007, 12:31

No it does not. However you would have made a fine politician with your ability to evade answering a direct question.

Without fighting with you I am asking for a very simple statement from you as to what your pitch is.

What form will you want to IMCR to take in the future an what licence do you see it being attached to.

Please state clearly what your safety case is, how you see the IMCR being taught and maintained.

If you can answer those simple questions you campaign will hold more credibility. At the moment you are making a lot of noise and evading direct questions. It strikes me that every time the subject gets to hot you go and attack others to divert attention.

So please just answer the question.

rustle

13th Dec 2007, 13:07

Fuji, can you update us with what the Popular Flying Association aka Light Aircraft Association are doing to assist in the "save the IMC" cause?

We've heard lots about AOPA, so what are the PFA/LAA doing about it? (There must be pilots within PFA/LAA who also fly IFR capable aircraft)

Thanks in advance.

BEagle

13th Dec 2007, 13:09

1. EASA will not permit the CAA to issue any EASA licences or ratings with further 'UK airspace only' restrictions on them.

The reason I asked for information on this was that I saw a possibility of the CAA issuing (on behalf of EASA) EASA-FCL IRs restricted to existing IMCR privileges only and in UK airspace only. A simple way out of the currently looming mess - but not permitted under EASA regulations....:rolleyes:

2. The only way to retain the IMCR is to convince the other EU states of its value. Otherwise it will be swept away.

I have seen a draft RIA (EASA, of course) which seems to think that the only way forward is to let UK IMCR holders 'convert' their IMCRs into EASA FCL IRs by an additional 5 hours training and testing and a 'theoretical examination'. However, this so-called Regulatory Impact Assessment has not given any cost estimates for this process, neither has it assessed the loss of business for those RFs currently teaching for the IMCR. It is a totally flawed draft RIA in every respect and is the product not of any GA organisations.

Personally I consider EASA fundamentally unfit for purpose - its whole rationale must be questioned by MEPs and this whole lunacy delayed.

When the NPA comes out, you must comment. But do NOT cut and paste the comments of others. Every single comment must be answered individually, so the more comments the better as this will slow everything down considerably...;)

Justiciar

13th Dec 2007, 13:37

So please just answer the question.

I will answer it. There are two scenarios:

The European Parliament does not vote in that part of the amendment designed to give EASA exclusive competence in Flight Crew Licensing = national authorities retaining competence; or
They do but do not rubber stamp the draft regulations put before them, arrived at by what sounds increasingly like a cosy stitch-up, and instead provide a power for a for IFR ratings to be added to the euro sports licence (which I believe is what EASA originally envisaged).In the first scenario the IMCR is retained; in the second a euro version will emerge. That may not be for some years, but the power will exist.

Of course the phasing of any EASA take over of licensing is an aspect we haven't really considered. It is possible that any amended Regulation will have a longer transition time that is envisaged.

If you feel that the only way to press the case in favour of having an IMC rating is to quote stats and statements about the IMC rating then thank God you were not part of the team trying to establish the IMC rating in the first place because there was not much experience of how the IMC rating would work back then..............just like there is not much experience in the rest of Europe now.

No: you rely upon the evidence which is available at any particular point. Forget figures for a moment and tell us what anecdotal evidence there is thet pilots exercising the priviliges of the IMCR are causing a danger. I am unaware of any such evidence. The difference as regards Europe is that whilst they may not have experience themselves there is substantial evidence from the UK of how such a rating works in practice. Europe should therefore be in a better position to judge than the UK was when the rating was introduced. Of course it may not be desireable to transfer the concept wholesale. There are airspace differences, for example, and there may be valid issues on the degree of training. The may be a case for splitting the privileges into a number of different qualifications or sign offs, as I believe they do with approaches in Australia.

What we seem to have from Europe is a knee jerk reaction which fails to consider how such a rating would work in practice, how it works in the UK and whether it may be desirable as a means of increasing safety by enhancing pilot skills.

All this talk of the IR being a professional rating is utter tosh. The IR is the qualifiecation for a PPL to fly IFR. It is not a professional qualification and confers nothing more than the ability to fly when VFR (or special VFR) is not possible.

So why do the theoretical knowledge requirements contain so much which is wholy irrelevant to PPLs? Why is there no credit for instrument flying already done, as is allowed by Annex 1 of ICAO (and is recognised in the FAA IR training)? I believe that recent proposals for modifying the knowledge requirements are on hold and may not see the light of day for some time, if at all.

The fact that if a PPL holds an IR that get a credit for the training they have completed if they apply for a CPL simply makes sense...............or would you prefer that applicants for the CPL who hold an IR must sit the exams to demonstrate the knowledge they demonstrated previously.

Am I alone in not understanding the relevance this comment in relation to the issues:confused: Credit across the various aspects of the training is to be welcomed. However the existing system is cumbersome: for example, anyone initially getting a CPL or an IR and who later wants to go the ATPL route has to redo exams by sitting the full set of ATPLs. Why we do not have a progressive system of training and exams like the US is beyond me.

Contacttower

13th Dec 2007, 15:27

In the first scenario the IMCR is retained; in the second a euro version will emerge. That may not be for some years, but the power will exist.

All those attacking Fuji are being slightly unfair I think, we don't know exactly what we are fighting yet...so a set in stone battle plan is perhaps not such a good idea...we need to be careful and react with common sense.

rustle

13th Dec 2007, 15:55

...we need to be careful and react with common sense.

A bit friggen late for that, don't you think? :ugh:

Contacttower

13th Dec 2007, 15:56

A bit friggen late for that, don't you think? :ugh:

And do you have a better idea?

rustle

13th Dec 2007, 16:16

Well one better idea would be to agree what it is you want.

Justiciar's post, whilst interesting, missed option 3 (at least) which is a straightforward rubber stamping of everything EASA wants, including the abolition of national licenses and ratings: On that happening you really need to get your ducks in a row before launching petitions (what are you asking the PM to do) and having several threads running in the public domain which, in and of themselves, are so full of disinformation as to be next to useless and lacking credibility.

Another better idea would be to have a full understanding of both current and proposed privileges of a rating - even the bits that don't fit your argument as nicely as others.

Another better idea might be knowing how to answer questions without going on the defensive immediately, nor telling people they have missed the point.

Maybe, as a fourth idea, these several threads should be allowed to die until some or all of my other better ideas can be accommodated ;)

Justiciar

13th Dec 2007, 16:32

missed option 3 (at least)

This was not an option for preserving some form of IMCR - hence is not an option at all though it is a distinctly possible outcome.:{

S-Works

13th Dec 2007, 17:03

All those attacking Fuji are being slightly unfair I think, we don't know exactly what we are fighting yet...so a set in stone battle plan is perhaps not such a good idea...we need to be careful and react with common sense.

Oh for Gods sake, we know exactly what we are fighting and so would Fuji if he had bothered to do any actual research on the situation.

As we have know what we are fighting for a long time it would be rather helpful if he made a statement of exactly what he is saving and why and how he would like to see it moved forward. It does not have to be set in stone but at the moment it is not even in quick sand.

We are also still waiting on his comments on the PFA efforts that rustle asked for several posts ago.

I realise that it may seem that I am being provocative, bit all I really want is him to demonstrate he has a real grasp of the situation and a plan to move forward with a resolution. At the moment all I see is hot air and abuse.

Contacttower

13th Dec 2007, 18:24

Oh for Gods sake, we know exactly what we are fighting and so would Fuji if he had bothered to do any actual research on the situation.

Well yes and no...I know you have been quite rightly highlighting this for a long time but at the same time as Justiciar posted there is still more than one possible outcome to what EASA may decide.

Perhaps we should let this thread die now....sorry for starting it in the first place. :bored:

Fuji Abound

13th Dec 2007, 18:57

ContactTower.

The worst thing would be to let this go away.

The debate has to develop. The approach and views will solidify.

There are always going to be different agendas at work - that is usually a good thing and from all the emails I have had (over 20 just today) every one has been hugely supportive.

The petition now has 350 names on it including for example

Al Walker - CFI RAF Halton Aero Club

Thank you Mr Walker.

Those in support need to stay with it for the long haul.

I have been told today that this very campaign has been very positively noticed - so those that would tell you otherwise are simply wrong.

Brilliant.

S-Works

13th Dec 2007, 18:59

I have had more than 40 emails today asking if you are ever going to stop blowing hot air and self congratulating and actually set out your campaign.

Brilliant.

S-Works

13th Dec 2007, 19:04

Wow, huge......

Just another 10 or 12 thousand to go for majority support. Keep up the good work.

Not to mention the fact that the petition is clearly fraudulent with a significant number of names having been added to it fraudulently or falsely including my own.

How do you expect to be treat seriously......
:ugh::ugh::ugh::ugh::ugh::ugh::ugh::ugh::ugh:

Contacttower

13th Dec 2007, 20:10

The worst thing would be to let this go away.

Sorry Fuji that's not what I meant...at all!

What I should have said is that this particular thread is not getting far, has exhausted its original title and people who have something serious and relevant to say should contribute on your sticky.

Justiciar

14th Dec 2007, 08:55

Trying to be neutral and not commenting on individuals' positions here is quite difficult.

Bose-x: I do get the feeling that you have lost sight of the process, as perhaps have we all. There is a political dimension here. Whatever the machinations of the committees and the manoevering to produce a desired result it is the politicians, the MEPs, who now have their say. Yes, they may well rubber stamp what you guys have put forward from committee as a "good idea", but they may not. We are now in the arena of good old fashioned lobbying, and this is where petitions, letters to MEPs and the general raising of public awareness can have a benefit.

When this thread started I was under the impression that the changes to EASA's remit were a done deal; in fact that was the impression you and others conveyed, to me at least. That is far from the case. There is an increasing dissatisfaction with the way Europe does things and imposes cost and regulation on individual groups and countries. The worm is beginning to turn.:D

S-Works

14th Dec 2007, 09:39

I am all for lobbying and letting the people have their say. After all government is supposed to represent us.

To lobby their must be a clear mission with accurate facts and an achievable goal. I have not seen any of that so far in the emotive ramblings here.

As far as things being a done deal, I have just said that it is my opinion that we are not going to change anything but the time for response is when the RIA comes out following a PROPERLY guided campaign.

The way it should work is that someone should state clearly the objectives, what it is we are retaining and why we are retaining it. How it is going to be implemented if it is retained. Is it going to going in the LAPL which is a sub ICAO licencem, the ideal place for a sub ICAO rating or are you going to attempt to get all of the European states to agree to a variation for a sub ICOA rating on the EASA PPL? None of that has been clearly stated to this point in time.

Once you have formed your battle plan and have the MP's etc on your side with a clear logical campaign when the RIA comes out you will be able to respond clearly with what you want.

As far as the politics are concerned it has been demonstrated time and time again that the politicians get what the want. Take a look at the constitution, snuck in via the back door, galileo being paid for from farming money (when our farmers are suffering), the list goes on.........

Justiciar

14th Dec 2007, 10:04

time and time again that the politicians get what the want

Collectively that is true. However, we have a duty to try and tell them what it is they actually do want :}

I don't think it is necessarily reasonable to expect those on the outside to present a full and detailed bueprint for an entire regulatory framework. We start however from a certain position, namely that we have rating which has existed for at least thirty years, that works, increases skills levels in pilots, that is affordable and which contributes to safety. From this position we have to educate the politicians to the idea that any changes which remove the IMCR and reduce to almost zero the money and training people have put in to getting and maintaining the rating are a bad thing; that this should not happen until a way is found either to allow the existing rating to continue in place along side any new licensing regime or to ensure that something equally effective is put in its place.

Such an approach accords with the concept of proportionality; it allows for the particular conditions of weather and airspace to be accorded proper place and allows for a rating to continue to be used in a country where it is well suited and designed to be used, without impinging in any way on the right of other European countries to reject the IMCR as a concent if they choose to do so (which they have).

I don't see anything wrong in this approach - anyone who ever campaigns for a change in the law in any area approaches it in a similar way; they do not produce a detailed legal framework, which is a matter to be determined by the government or parliament concerned. It is the basic principle which need to be established, not the fine detail.

S-Works

14th Dec 2007, 10:45

It is the basic principle which need to be established, not the fine detail.

Agreed. At the moment that has not happened and is what I keep asking for. I outlined in my post above what the basic principles were and we still do not have a direction.

Yes lets keep the IMCR, what ar you going to attach it to, a cornflake packet or a licence? Which licence? To make this work a general direction has to be chosen.

My personal view would be that the avenue with the any likelihood off success would be to overturn the DAY/VFR aspect of the LAPL and have the rating added to that. Sub ICAO licence, sub ICAO rating. This was the view that EASA had in the first place.

Might upset the EAS guys a little but hey they are supposed to be representing all of GA.

pulse1

14th Dec 2007, 10:58

May I interject on this debate to suggest that the principle should be that EASA should accept the lowest standard of regulation which has a PROVEN safety record in ANY DEVELOPED part of the Western world.

This would probably mean that the IMCR AND the FAA IR could be accepted as European standards. We could also sort out all the anomalies on light aircraft weights and noise regulations.

They would probably also have to introduce new legislation to allow pigs to fly.

BEagle

14th Dec 2007, 11:05

Forget any idea of IMC flight using a LAPL. It will be a Day VFR (cf the NPPL) licence and will also include the 'restricted version' in order to allow the French to continue killing themselves with their 'Brevet de Basse'.

The IMCR needs to be promoted as a pan-ESA Rating, with the following objectives and privileges:

Objective:

To enable pilots to cope safely with non-VMC weather in EU airspace.

Privileges:

To fly IMC/IFR in airspace other than Class A without the inclusion of an Instrument Rating on the licence.

To navigate the aircraft by sole reference to instruments under circumstances which require mandatory compliance with defined routes.

To fly instrument approach procedures for which they have logbook endorsements to instrument approach minima +200 ft for precision approaches and +250 ft for non-precision approaches.

The IMCR should be available to PPL(A), CPL(A) and ATPL(A) holders.

S-Works

14th Dec 2007, 11:22

Makes sense Beagle.

Maybe a look at the Canadian system of a 2 class IR for Inspiration. This would allow IMCR holders to upgrade to a Class 1 IR.

dublinpilot

14th Dec 2007, 12:28

BEagle,

I'm not sure I understand why you say forget attaching it to the LAPL? To me this would seem to be the one where it would stand the best chance of success.

Personally, I don't see the reason not to argue for allowing it to be attached to either licence.

In any case, I think that that is just details, which is what I think Justiciar was saying. (Please correct me if I'm wrong Justiciar). Argue for the retension of the rating, and the the politicans and EASA work out how best to retain it, once they realise there will be a big revolt if they don't.

dp

IO540

14th Dec 2007, 13:52

My personal view would be that the avenue with the any likelihood off success would be to overturn the DAY/VFR aspect of the LAPL and have the rating added to that. Sub ICAO licence, sub ICAO rating. This was the view that EASA had in the first place.

Might upset the EAS guys a little but hey they are supposed to be representing all of GA.

I couldn't agree more.

I don't think that what is today known as the UK IMC Rating (that is, IFR in Class D-G, with no ATS service and no implicit enroute clearance, and non-radio if OCAS for good measure) has ever had the slightest chance of being adopted Europe-wide.

There are political reasons (the NAAs i.e. old airline Captains and their unions would fight like hell) but also on the practical front some countries have a lot of Class C/A and not much Class E/G.

However, if the IFR option was not excluded totally, then one could work on a modular IFR scheme similar to Australia for example, which would then offer a grandfather route from the IMCR, so an IMCR holder would enter the scheme at the appropriate point.

I can see why the IFR option was scuppered - it was done to usurp any opposition from the old Captains to the LAPL, with its GP medical and the general deregulated "sporting" nature.

I suppose one could add an IFR option later on to the LAPL but this screws UK IMCR holders who will be left without IFR privileges until somebody gets around to pushing this through EASA. And the opposition from the gold plating commercial IFR lobby will not be any easier then.

DFC

14th Dec 2007, 20:45

The IMCR should be available to PPL(A), CPL(A) and ATPL(A) holders.

Putting that forward will not get very far because as everyone knows, one needs an IR a long time before one meets the requirements to obtain an ATPL.

Nonsensical suggestions are only going to drag the whole idea down.

The proposals show a distinct lack of knowledge of future airspace proposals. Is Eurocontrol going to have to restart it's one sky and future airspace plans just so that thre UK IMC rating can be imposed on the rest of Europe?

As I said many posts ago, the UK CAA was going to have to revisit the IMC rating in the future with the revised classes of the lower airspace and the reduction in the use of Class A and expansion of classes D and E in the enroute environment.

Regards,

DFC

dublinpilot

14th Dec 2007, 20:56

I can see why the IFR option was scuppered - it was done to usurp any opposition from the old Captains to the LAPL, with its GP medical and the general deregulated "sporting" nature.

IO,

That maybe what happened, but it shouldn't be such a difficult problem to overcome.

There's no reason not to have a basic GP medical for the basic LAPL, but require a more stringent (class 2 equivalent?) medical if someone wishes to exercise the privileges of an IFR rating which they added to the LAPL. In fact this is very similar to the current JAR PPL/IR. Someone wishing to exercise the privileges of their JAR IR is required to "upgrade" their class 2 medical to include an audiogram.

It should be an easy enough situation to sort without upsetting those that want a generally deregulated type of licence.

DFC, people sometimes let ratings lapse, because they no longer need their privileges ;)

dp

DFC

14th Dec 2007, 21:48

DFC, people sometimes let ratings lapse, because they no longer need their privileges

I don't get your point.

Regards,

DFC

Contacttower

14th Dec 2007, 21:56

DFC, people sometimes let ratings lapse, because they no longer need their privileges

DFC I may have missed something but surely the point of allowing ATPL holders to hold an IMC rating is so that having flown for years with a multi-crew IR they don't have to go through the single pilot IR again (which would have lapsed soon after they started airline flying). Now I don't know the ins and outs of this but I know some ATPL holders do fly around in IMC single pilot on the IMC rating...not the IR, which is what I assumed BEagle had in mind when he made the suggestion.

DFC

14th Dec 2007, 22:08

You may be confusing the UK pilots who obtained an ATPL having flown nothing more than a C150 for 1500 hours of which 100 was at night and JAR-FCL qualified ATPLs who are a totally different breed.

The only way to obtain an ATPL now is as follows;

Hold a CPL and a single pilot IR
Have completed an MCC course

Obtain a multi crew type rating and a multi crew IR

Amass a minimum total of 1500 hours with a minimum 100 hours night with 500 hours multi pilot and pass the required test.

If having at any stage one decides to do single pilot IFR flying privately, for the same price of doing the IMC renewal, one can do the single pilot IR test.

If the multi pilot IR is allowed to lapse then the pilot can not exercise the privileges of the ATPL or the multi pilot type rating included therein. They effectively become a CPL as far as privileges are concerned (assuming they have a valid Class 1 medical). If they only have a class 2 medical then they only have PPL privileges.

I don't know anyone who would spend the time and money to pass an IMC test when for the same time and money they could pass the single pilot IR test and not be restricted as per the IMC rating.

Regards,

DFC

englishal

14th Dec 2007, 22:13

Perhaps they want a rating to be valid for 2 years...
Perhaps they don't want to fly in the airways, but want to get back to their farm strip in ****e weather.
Perhaps you should put the book down DFC.

DFC

14th Dec 2007, 22:14

Forgot to say that of course one needs the ATPL exams also to get an ATPL!

Remember that one of the biggest arguments for the IMC rating is that those who may benefit from it can not get an IR. Those with an IR (even if it is only a multi-pilot one) don't have that problem and any proposal to attach the IMC rating to professional pilot licenses would come up against much in the way of claims about drumming down and reduction of safety in public transport.

Of course remember that one can if one chooses hold a PPL and a CPL and an ATPL at the same time. Few pilot can be bothered to pay the 5 yearly fee 3 times over though.

Many do however, hold both PPL and CPL or both PPL and ATPL. The fact that they hold an ATPL does not affect in any way the rights and responsibilities and limitations of operating using the PPL. i.e. the ATPL is simply dead weight in the pocket while flying a microlight.

Regards,

DFC

Fuji Abound

14th Dec 2007, 22:16

DFC

What about the "old" CAA ATPL holders now in their fifties, 10,000 or more hours to their credit, did the exams etc etc, but now find themselves about to be stripped of their ATPLs.

What about the "old" CAA BCPLs, the true career instructors who have no other careers to turn to, never had any intention or desire to move on to a commercial career and are the true main stay of many a fly club / school who are about to be stripped of their ability to earn a living. These are also the guys with 10, 20,000 hours, seen it all, done it all so far as teaching is concerned.

How does that work?

englishal

14th Dec 2007, 22:24

I forgot to say...

The IMC is given away free for anyone:

Who has passed an IR check flight in the past 2 years

So another reason for a MC IR holder to use one....it is FREE...no test required.

DFC

14th Dec 2007, 22:25

Perhaps they don't want to fly in the airways, but want to get back to their farm strip in ****e weather.

Hopefully, they would not risk their career flying in such cases.

Remember that current JAR-ATPLs are going to be earning a reasonable wage. I don't think that doing a quick IR renewal test each year is going to break the bank.

I spend less doing single pilot IR renewals each year than many IMC holders I know spend renewing their IMC rating. Mostly because I simply expeditiously complete the test and get the signature rather than the old....ah you need a brush-up flight....and another one....before doing a test that takes longer than the IR renewal.

For that I also get the multi-engine piston signed off which of course is extra for the IMC rating holder.

The only thing we both get is the exemption from having to do the 1 hour with an instructor for the SEP renewal.

Keeping the sep going means that one can fly microlights without having to pay for a microlight rating or having to complete any minimum hours in the past 13 months etc etc not to mention that as a JAR-FCL instructor, one can teach SEP, MEP, IR, IMC Night and Microlight.

You really do get a lot for your money!

Regards,

DFC

Contacttower

14th Dec 2007, 22:31

Just as an aside I remember reading on some thread ages ago about a BA captain who failed an IMC rating test...apparently he had forgotten how the basic DI worked. :=

DFC

14th Dec 2007, 22:39

Fuji,

What does anyone need an ATPL for if they are not going to use it.

Is it a "I've got an ATPL so I look down on him", I'got a CPL so I look up to him but I look down on him" .......

If they have 10,000 hours then they have 10,000 hours. They may be a great pilot, they may be reckless idiots but PPLs, CPLs and ATPLs are simply bits of paper that entitle pilots to perform certain functions.

I know many PPLs who are far more experienced and far more capable than me. It is the experience, knowledge and capability I respect, not the piece of paper in their hand.

----------

If I was earning my living from doing something I would want to excell in that field and if the way ahead was to complete some simple exams after a bit of study the I would and I would not expect someone to feel sorry for me over a dacade after I ignored the oportunity to do just that simply because my past failure to act is now coming home to roost.

Microlight instructors earn more than JAR-PPL instructors. I would have been teaching microlights with a PPL and reaping the rewards that many have tapped into over the last 20+ years rather than moaning that someone should help me out because I did not help myself when the time was right.

20,000 hour pilots should not have a problem with a few exams and a test.

Two pilots were in the bar talking.

I bet I can make that crusty old CFI laugh and cry within a minute said one.

Go on said the other.

The first walked over to the CFI and shouted into his ear "I've got more hours than you"................to which the CFI burst into laughter.

They then opened their logbook and showed it to the CFI........

One mans vast experience is anothers learning to walk phase.

Regards,

DFC

dublinpilot

14th Dec 2007, 22:46

Hopefully, they would not risk their career flying in such cases.

The point I was trying to make is that their career maybe over. They may have flown the airlines all their lives, but now are retiring, and wanting nothing more than to be able to enjoy flying around for their own pleasure. They'd have no need for airways, and be happy with the limited privlidges of the IMC rating to simply allow them to get home when the weather turned.

dp

DFC

14th Dec 2007, 23:05

When I am working, I have to cope with all those hassles.

When I fly for pleasure, the last thing I want to do is fly IFR. If I make a serious mistake and the weather turns (as you put it), I will remain VFR and if really stuck land close to a nice pub where I can weather the storm.

Most retired ATPLs I know prefer the piper cub, luscombe, microlight type of simple sunny afternoon wafting along flying.

WE do enough racing round at 500Kt and flying in weather with approaches to minima at work. That is not recreational flying.

Recreational flying is setting off when the weather is good enough to ensure a pleasurable relaxing flight not a working office job in a more cramped environment.

Since I need minimum 1000ft ceiling above everything within 10nm of the destination when IFR and no published approach........is there any way that I can arrive there IFR if I can't arrive there VFR?

Regards,

DFC

David Roberts

14th Dec 2007, 23:56

Just back from Cologne after two days of MDM.032 meeting.
There is a lot of factual information re FCL, FAA, LAPL, IFR, IMCR etc debate I need to provide updated information on but it is quite late….
I’ll construct an accurate and measured response to this thread this weekend (after another meeting Sat a.m. and Xmas shopping, domestic brownie points etc).
Some commentators on this thread over the last week, especially Justiciar, are closer to the truth than most. Politics are playing a close hand as is the dominance of ex JAA interests including airlines and the associated unions on FCL group, which outnumber the GA experts who have done their damndest (? spelling) for our (UK) interests. There are many trade offs-involved between an ICAO complaint FCL/PPL and the LAPL. Airspace access in the EU context is a major factor to take into account and EASA’s objective (I believe), as well as that of ‘industry’ as we are called, is to have licences that prima facie are not limited to particular classes of (EU) airspace.
Remember one thing though – the EU agenda (which EASA as an agency of the Commission is obliged to implement) is standardisation, not harmonisation.
And before we all sound off about EASA and the FAA on future licence issues, bear in mind that a bi-lateral is required between the EU and the US Govt. Not there yet and guess where (who) the problem is? Not where you might immediately think if you are “EASA-bashing”.
Some of us are trying to find a satisfactory outcome through this whole situation as we go along, but it ain’t easy.

IO540

15th Dec 2007, 06:06

David,

Thank you for the feedback here; very useful.

And before we all sound off about EASA and the FAA on future licence issues, bear in mind that a bi-lateral is required between the EU and the US Govt.

I don't quite get this. Can you be specific as to the area where there is a problem?

Currently, the FAA accepts FAR (no pun intended) more JAA stuff than JAA accepts FAA stuff.

For example, you can convert a JAA IR to an FAA one with just a written exam. Or a JAA ATPL to an FAA ATPL with just a written exam. The FAA accepts all JAA (or any ICAO for that matter) flight training towards any of its licenses/ratings.

OTOH, JAA accepts none of the above from the FAA. No credit for flight training, no credit for exam passing. A 10,000 hour FAA ATP pilot with 9,000 hours on a C172 would have to do a JAA PPL from scratch as if he had never sat in a plane at all. Exams, 45hrs training, the lot. In a C172 if you like.

The FAA accepts any ICAO license for an N-reg, automatically, so long as it is issued by the country owning the airspace you are flying in. With the exception of the UK CAA, an FAA license is worthless in an EASA-reg; some countries do paper validation, but grudgingly e.g. France does it only for non-French pilots - a blatent restrictive/protectionist practice. And JAA itself limits member states to 1 year max for the validation of any foreign (which obviously means FAA) IR - another blatent restrictive practice.

Then we get onto certification. This is less clear but the vast majority of "avionics stuff" is US made and comes with US certification anyway. The vast majority of non-US-made stuff comes with US certification - because the USA is the major market. It is EASA that is hard on this, not accepting FAA STCs. It was joining JAA that killed the CAA-FAA mutual STC recognition treaty which I remember reading myself a few years ago. And now we have a stupid situation where you can have a product with an FAA STC but EASA won't even look at it unless the application for the EASA STC comes from either the manufacturer (who already did the work for the FAA!) or a design authority (4 digits+).

I'd like to know what EASA is complaining about? Is it FAA's refusal to implement some EASA ADs? There is a recently kicked off EASA-FAA AD harmonisation process anyway; I have the reference for it.

421C

15th Dec 2007, 06:56

I'd like to know what EASA is complaining about?

I completely agree with your post above. EASA have chosen to couple all the crew licensing issues that affect us with various other politics that don't. My vague understanding is that the area the FAA are being tough in is to do with Maintenance organisations in Europe and oversight. This is a guess and may be wrong, but I think an example might be of European maintenance organisations that might work on a US airliner whilst it is positioned here (eg. develops a fault) and what direct oversight the FAA requires of such an organisation.

It is a purely political decision, the EASA stance to say "well we can't possibly have mutual recognition of crew licensing and STCs unless we have a bilateral treaty on X,Y,Z". Interestingly, I think relations with Canada and Australia are better, and don't have this barrier. We may more readily have total mutual recognition with those more easily. So it may be a roundabout route whereby an FAA STC becomes a Canadian STC which then can be recognised under EASA. And any FCL regime has to be better than JAR-FCL.

All the above based on scraps of info, I am sure someone who knows more will post soon. Caveat again, I may have got this wrong.