IMC rating in theUK?

[Check Airman]

What's this IMC rating they're talking about on the Flight International (http://www.flightglobal.com/articles/2008/01/25/221113/uk-battles-to-save-imc-rating-for-ga-pilots.html) website? How is different from an IFR rating?

I've posted the article below:

UK battles to save IMC rating for GA pilots
By Kate Sarsfield ([email protected])
http://adserver.adtech.de/adserv|3.0|289|1061237|0|277|ADTECH;loc=300;key=key1+key2+ke y3+key4;grp=[group] (http://adserver.adtech.de/adlink|3.0|289|1061237|0|277|ADTECH;loc=300;key=key1+key2+ke y3+key4;grp=[group])

The UK general aviation (GA) community is bracing itself for a bitter and protracted battle with 27 European Union member states whose widespread opposition to the instrument meteorological conditions (IMC) rating for pilots has forced its exclusion from the European Aviation Safety Agency (http://www.easa.eu.int/home/index.html) draft regulation for flight crew licences (FCL).
The agency is developing a set of common standards across 31 EASA member states which will be enforceable by European law.
The IMC rating is unique to the UK due to the country's notoriously unpredictable weather and has been in existence in its various forms since 1970. The UK Civil Aviation Authority (http://www.caa.co.uk/), the only national aviation authority to voice its support for the rating, says it is designed to train pilots to rescue themselves from inadvertent entry into deteriorating weather conditions.
The authority has issued around 25,000 IMC ratings to holders of air transport, commercial and private pilots licences, of which 2,300 are still current. "The IMC rating has been a safety boon," says the CAA. "There have been eight air proxes in seven years involving commercial aircraft in IMC conditions, but none of these involves a GA pilot with an IMC rating."
"A lot of people have spent time their time and money on a rating that will allow them to operate safely in bad weather and save their lives and others. EASA doesn't have a right to take this away," says a GA pilot.
The CAA and GA supporters have done a substantial amount of lobbying at European level to convince EU member states and stakeholders of the need to protect the rating.
However the opposition is widespread with countries including France, Germany, Italy and Poland appearing resolute.
"Apart from the UK nobody has come out in support of the rating. A number of states are saying nothing at all," says EASA deputy head of flight standards Eric Sivel. Opponents, which also include commercial operators, argue that rather than improve safety, the IMC rating encourages pilots to take unnecessary risks.
"Our opponents argue that if pilots choose to fly in IMC conditions they should get a proper instrument rating, but these are very time-consuming, costly and unnecessary as most of the time they are flying under visual flight rules and in visual metrological conditions," says the CAA.
The draft FCL regulation is scheduled for publication by March and should be adopted early next year following consultation, comment and review periods. EU and EASA member states then have a three-year transition period to implement the changes. EASA says it "supports the preservation of some sort of IMC flying in Europe" and is keen to find a solution.
"Although the IMC rating has not been included in the draft, pilots can continue flying with the rating until the end of the transition period in 2012. But over the next four years work we will work to build support for IMC flying throughout the EU member states," it says.

[Three Yellows]

In brief, it allows me as a PPL holder to fly in cloud in all classes of airspace except class A. So here in the UK I can fly from my home base, near London and fly to any of the major airfields around the UK (except London Heathrow) and fly in cloud to get there and fly an IAP when I get there.

It does not allow flight in IMC in the airways. However it is possible to get around the UK outside class A.

Its fantastic and allows me to get all over the UK with a degree of certainty. I use it as a pseudo IR. i don't go along with the "to get you out of trouble" school of thought as you have to be current. I fly an IAP at least once a week so I feel current.

[Contacttower]

There is loads on the IMC rating in the Private Flying Forum.

A brief description...

15hrs flying training, with a minimum of that 10hrs on instruments alone covering basic instrument flying skills, unusual attitudes and usually ILS, VOR and NDB tracking/approaches as well.

Clears the pilot to fly IFR in the open FIR as well as class D airspace with a reduction in SVFR minims to 3km in flight vis for class A airspace (up from 10km and in sight of the surface). Approaches to airports in class D airspace may also be made.

The differences between the IMC rating and the IR in terms of privileges are:

Minimum 1800m vis for take off and landing.

A recommended minimum DH of 500ft for precision approaches and 600ft (or published MDA+200ft whichever is higher) MDA for non-precision approaches.

No IFR airways flight.

Valid only in the UK.




The rating is used mostly by PPLs in the UK, but also by ATPLs who have let their single pilot IRs lapse.

I see though Three Yellows has beaten me to it....;)

[Zorst]

It's a cheap and nasty licence to have a go at instrument flying.

(now, I'll bet a lot of money that the mods have this one away quickly... They don't like the truth, you see...)

[Contacttower]

Zorst I take it you are joking...

[machinehead]

Sounds like another infexible, costly and unecessary decision which affects the safety of pilots and their passengers as well as preventing the training of pilots on how to recover from flying IMC when it's vitally important. Unfortunately, the crew of a PA28 lost their lives approaching Blackpool Airport last year when encountering IMC conditions. Surely this will make the licencing expensive and out of reach of many GA pilots and ultimately lead to further incidents. :ugh:

[av8boy]

As a US ATC who also ran into this concept online, I asked about it here almost a year ago. Some excellent explanations in this thread: http://www.pprune.org/forums/showthread.php?t=266308

:ok:

Dave

[Three Yellows]

Zorst,

Interesting attitude. May I ask are you a UK PPL/pilot etc or non UK? Are you a pilot?

Just curious.

[Zorst]

the crew of a PA28 lost their lives approaching Blackpool Airport last year when encountering IMC conditions

In the circumstances, that is in horribly, shockingly, bad taste.

They didn't 'encounter' those conditions, they flew into them knowingly.

Read the report! The mother of one of those involved posts here, by the way.

In my honest opinion, that post is utterly typical of the dim-witted, thick-skulled, UK PPL community: always justifying their petty little ways with twisted interpretations of the real world.

[Zorst]

Three yellows,

Yes, very much so. UK ATPL holder, lots of hours, many classes and types, including rotary and fixed wing, medium and heavy transport aircraft (both seats), training background...

...and the ability to see beyond the end of my nose to the bigger picture...

[Three Yellows]

Zorst,

You seem quite excited about this!

I'll be honest and say that the level of IMC training I received was very poor indeed. I learnt more from my mate (100hr PPL) than I did from my instructor. I was lucky I did my IMC with a great deal of real world aviation under my (not inconsiderable) belt. The bits my mate didn't teach me, I taught myself - not ideal.

If the IMC is to survive then I believe that the quality of instruction needs to be improved.

For the flying I do, I need an IR, but I don't have the time to do the JAR IR so I'm doing the FAA IR and putting the plane on the N reg, despite all of the fears about EASA and N reg planes.

Could you take a deep breath and tell us what troubles you so much.

[Shunter]

Zorst - sounds like elitest bull**** to me. IMC holders with good currency are more than capable of hand flying substantial sectors to IAP minima. Can the average button-pushing ATPL say the same? The rating, and the skills taught are what you make of them; use them or lose them. That said, the safety case for the IMC rating in the UK is statistically overwhelming. Ask the CAA...

[Zorst]

Well, in your case, it's that you're going to ask the Feds to regulate your safety, yet you're going to keep your aeroplane well out of their reach.

Now, what did I say about justifying petty little ways?

QED

[Zorst]

IMC holders with good currency are more than capable of hand flying substantial sectors to IAP minima. Can the average button-pushing ATPL say the same?


Shunter, it's not hand-flying ability that confers absolute safety (though it's significant); it's things like proper briefings, good training, TCAS, EGPWS, and the like. In my time, I have flown with many IMC rating holders. One of them impressed me with his ability.

Referring to your jibe at airline pilots... Glancing through my log book, about a third of my recent medium jet approaches were hand flown on raw data. I can't answer for my colleagues.

Nothing elite here, just very peed off at some totally inappropriate remarks trying to justify retention of a one-off dodgy qualification by relating it to a very sad and completely avoidable fatal accident.

[Three Yellows]

Zorst,

I don't know why you are being so offensive when you haven't met me or flown with me.

I suspect that you are not British as Brits don't call the government (any goverment) "the Feds".

You haven't actually said anything sensible at all. What's petty about putting an aeroplane on the N reg and having further IR training to go with it?

Please say something sensible or go back to hand flying your 747 around the world...... what version of MS flight Sim are you using?

[Shunter]

I'm well into my IR, and thus far haven't learnt anything which has improved my flying skills (not an ego-trip, simply an observation). I took a current B744-rated friend up in my aircraft in solid IMC and without the AP he was in a right mess, found the workload overwhelming. He's a great pilot, but was simply out of touch with instrument flight at a rudimentary level. That doesn't make him a bad ATPL, just a fish out of water.

Like I said, it's what you make of it; 15hrs is nothing, but an experienced, capable, practiced IMC-rated pilot is more than capable of flying with superb accuracy. By the same token, an IMC holder who lives in VMC for 2 years then tries to fly a procedural ILS to minima is probably toast and an idiot for getting airborne in the first place.

[VeriLocation]

As a high hours PPL and (h) pilot operating a modern light aircraft for business and pleasure at all times of the year and travelling to and from the UK & Switzerland I have find the whole IMC or not debate rather irksome, and as a long term "observer" rather than contributor to PPrune this particular subject has prompted me to put the old keyboard into action. The way I see it, is that ANY form of training over an above the PPL can only be a good thing. I seem to detect that the IR stakeholders who have invested considerable time and effort in gaining their status seem a little peeved that Joe Public can mix it with them in the clouds rather than applying common sense and equiping normal social pilots with key skills that seems from the stats to prove that we can control an aircraft quite safely in marginal weather which has a nasty habit of producing accidents on non-IMC holders where they inadvertently enter rain/cloud/mist/fog. But more than anything the rating for me gives me a sense that on a regular bi-annual basis I am assessed for my competence not just in instrument flying but also ILS , NDB navigation which is a large part of my weekly flying and this produces one net result - CONFIDENCE. I have seen so many friends / fellow pilots make bad decisions and lose their confidence in marginal weather just when they needed it. It may only be a rating but it allows me personally to keep safe when the conditions change and not panic. I would never chose to fly IMC on a long business related trip but sometimes terrain , weather conditions may not make it a choice but a forced reality and like all good training in any walk of life, it equips you with the ability to cope when it matters. So please EASA get off your high horse and think about raising the bar - not lowering it or at least change the IR into a sensible rating for people like me who will never fly commercially. Anyway I must get back to my IR course, currently having to learn how to use polar jet airways........need I say more.

[IO540]

Regarding "Zorst", best thing is to not feed the trolls.

[Contacttower]

Regarding "Zorst", best thing is to not feed the trolls.


You are so right IO540, I was about to launch into a real rant...but I've thought better of it.

But even so I wouldn't be suprised if he recieved a broadside 'a la PPRuNe' anyway...

[BALLSOUT]

contacttower

"The rating is used mostly by PPLs in the UK, but also by ATPLs who have let their single pilot IRs lapse."

I think you will find that anyone who has switched from a UK/CAA CPL/ATPL to a JAA, they no longer have this privelage.

[Contacttower]

I think you will find that anyone who has switched from a UK/CAA CPL/ATPL to a JAA, they no longer have this privelage.

Are you sure about that? Not that I know for certain...although the impression I got from all the discussion we've had on here about EASA/IMC/etc etc was that yes, current JAA ATPLs could hold an IMC rating (In fact I'm pretty sure that's the arrangement my instructor had...ATPL+Multi crew IR+IMC rating for the single pilot stuff).

My PPL is JAA...with an IMC rating. Why should it be any different for ATPLs?

They do have to take the IMC rating test though...which is something the old CAA ATPL I think allowed you to bypass.

[dublinpilot]

Come on guys....Zorst registered just a couple of days ago, and his few posts have been rants that could only come from someone with either little or no knowledge of the issues, or someone looking to create an argument with a hidden agenda.

As IO says...he's a troll. Don't fall for it.

dp

The question is who's behind the troll.......:}

[dublinpilot]

CT,

I think Ballsout thought you were implying that a JAA ATPL automatically got an IMCr, ingrained as part of the licence without having to apply for it or keep it current. That I think applied to old CAA issued licences.

You are of course correct in that there is nothing to stop a JAA ATPL holder adding an IMCr to their licence.

dp

[DX Wombat]

If the IMC is to survive then I believe that the quality of instruction needs to be improved
Surely that depends on where you are doing it and who is teaching you? In some ways the same could be said of the PPL itself. There will always be good FTOs and poor FTOs and the same with instructors, don't lump them all together. I am doing my IMC at the moment and my instructor is very experienced and very thorough. I certainly can't get away with anything and we don't move on to the next part until he is satisfied that I have a good grasp of what I am supposed to be doing.

[BEagle]

"I think you will find that anyone who has switched from a UK/CAA CPL/ATPL to a JAA, they no longer have this privilege."

That is correct.

However, the CAA decided a year or so ago that JAR-FCL IR multi-pilot rated pilots would no longer have automatic UK IMCR privileges on single-pilot aeroplanes.

They did this without any consultation or Regulatory Impact Assessment...

Whereas at least EASA is determined to find an acceptable European solution.

The JAR-FCL IR (single-pilot aeroplanes) is a gold plated solution which is out of the reach of most GA pilots. The FAA IR is much more accessible; however, the UK IMCR provides elements of IMC flying which are all most people actually need. It is a proportionate solution to a requirement - and has proved to be a very good safety investment for many pilots.

Flight's report is a bit of a disappointment; the last thing the UK wants is a '4 year battle'. Rather, we seek to elicit the concerns from those who have yet to be convinced of the value of te UK IMCR and to address those concerns.

In the UK, IMC flight outside CAS is permitted; in other EU states it is not. Hence the solution must be a Rating with the following objective:

To enable pilots of light aeroplanes to cope safely with non-VMC weather in EU airspace without the requirement to hold a full IR.

Such a Rating would provide the pilot with the following privileges:

To fly IMC/IFR in permitted airspace other than Class A.
To navigate the aircraft by sole reference to instruments under circumstances which require mandatory compliance with defined routes.
To fly instrument approaches for which they have logbook endorsements to IAM +200 ft for precision approaches and +250 ft for non-precision approaches.It is also a given that any pilot with such a pan-EU IMC-level Rating would need to have ICAO Level 4 English and, to enjoy such privileges, to fly a suitably equipped aeroplane with Mode C or Mode S. So we are not talking about some mumbling incompetent flying a piece of old junk in proximity to people-tubes stuffed with the Great Unwashed!

[echobeach]

I joined pprune at the time the IMC debate began and I have been disappointed with criticism levelled by some on this and other posts .
It is often quoted that this is only 15 hours training (the required minimum) but as with PPL training I am sure that many do more to satisfy their own requirement for competence rather than just the minima for exams.

I was taught by an IR holder and I requested that I was trained to the standards that I would need if I go on to the IR. I chose to do 40 hours training so that I thought I could fly myself safely in IMC and an ILS in IMC. I keep current in IMC and fly IAPs whenever available at destination. I fly 3 hours a week most of the time and I don’t believe that those who have trained for the IMCr and continue to keep current have the easy option was out referred to here. I suspect I will do the IR but I feel this was a good place to start.

The improvement this makes in safe flight in VMC as well cannot be forgotten.

I know this has been debated fully in recent posts but I felt I could not let the comment above pass with no response.

[mm_flynn]

...
Such a Rating would provide the pilot with the following privileges:
[LIST]
To fly IMC/IFR in permitted airspace other than Class A.
...
This specific point is very UK centric.

In the UK 'Class A' could be considered a euphemism for, 'enroute airspace in which passenger transport operates'. Which is why we have low level Class A out to the CI for the altitude impaired Islanders.

Almost nowhere else in Europe (Italy excepted) creates this Iron Wall between totally controlled and totally uncontrolled airspace. If there is any chance of explaining the IMCr concept to our colleagues in Europe, we need a more general description of the airspace in which this rating would be valid.

It is also worth remembering that European transport aircraft fly with VFR traffic separated only by 500 feet in and across the airways. As well, unfortunate experience shows that Jet Transport are not really capable of 'seeing and avoiding' in VMC, so you could argue that having more aircraft IFR in the 5 to 15k foot range would reduce collision risk (which is what I am assuming is the concern in Airline and Regulator world).

[BEagle]

As there is no general EU harmonisation of airspace and associated regulation, it must be for individual states to define the airspace in which the EU Class 2 IR may be used in IMC or under IFR.

Perhaps the first privilege should thus be re-stated as:

To fly IMC/IFR in permitted airspace.

[dublinpilot]

Perhaps the first privilege should thus be re-stated as:
To fly IMC/IFR in permitted airspace.


I think that would be much more acceptable in a European context.

It would allow individual countries to not classify any airspace as permitted if they didn't want to.

It might also allow sceptical countries to start off with just class G being permitted, and they may get more used to the idea as time goes on and start adding other classes.

dp

[IO540]

Echobeach

You are absolutely right, and there are many pilots who like you use the IMCR seriously. I was doing ~ 150hrs/year when I had just the PPL and IMCR.

One problem is that there is always somebody who thinks such and such privilege is not adequately gold plated, and this is demonstrated here by the troll "zorst".

The other problem is that a lot of people cannot get it into their heads that ultimately it is up to the pilot to realise what he can and cannot do. There is no legislation (nor IMHO should there be, although curiously a lot of regs could be made far better if there was) saying that to fly in IMC one needs a £200k IFR spaceship, but obviously if you do have a £200k IFR spaceship then all of IFR becomes a relative piece of cake. But if somebody tried serious IFR in a 1970 C150 with its single VOR receiver about to fall out of the panel, the pilot workload would be, shall we say, rather high. Not everything can be regulated and some people cannot accept that.

For a change (for a regulator), EASA is taking a sensible view on this stuff.

[englishal]

But if somebody tried serious IFR in a 1970 C150 with its single VOR receiver about to fall out of the panel, the pilot workload would be, shall we say, rather high. Not everything can be regulated and some people cannot accept that.
But to be fair, in the USA many people fly old C150's IFR in airways, shooting NPA's all the time and they don't make a big deal out of it....because really it is not a big deal....I've flown some dodgey old wrecks IFR with MEAs up to 11000 and never once had to tell ATC I couldn't make it. Sure it is more work than direct-enter-enter but once you get used to doing it, it is "fun" in a strange sort of way :O

In Euroland we like to make it a big deal, which is why the JAA IR has become so sufficiently gold plated that no normal PPL can justify doing one. Equipment is another issue. In USALand, you can fly your experimental IFR (Equv. of UK permit aeroplane more or less). You can fly your ex-mil jet IFR, and even shoot a GPS approach in it with suitable kit. In Euroland they like to gold plate the kit you need too, which doesn't encourage private IFR (E.g. my aeroplane has a VOR, NDB etc....but I can't fly IFR because my radio is not FM immune.....and my GPS is not IFR certified and I have no DME).....In the states I'd be perfectly legal to fly IFR, shoot a VOR, LOC, ILS or Back Course approach......

[Zorst]

Ahem , no troll here. I don't stand under bridges.

(I don't often stand under T67s on spinning exercises or R22s regardless of phase of flight, either).

If you find the truth painful, move on.

Echobeach, why don't you just get an IR, if you're so sharp? (I know it's out of fashion, and a trifle uncool).

[stray10level]

I happen to be a UK PPL holder and take extreme offence at some jumped up jerk calling me this:- "In my honest opinion, that post is utterly typical of the dim-witted, thick-skulled, UK PPL community: always justifying their petty little ways with twisted interpretations of the real world".
It usually takes a reasonable amount of SPARE cash to learn to fly and to then move on to further training etc. Agreed you may find some born wealthy types. But most of the pilots i know are business men etc. Hardly fitting of the dim-witted thick skulls title are they? So please explain how, when sitting in your ivory tower watching your EFIS screens and playing with the FMS etc, you will avoid an aircraft who has strayed into your path who has no T/P? Rendering your TCAS readout ineffective
Also if your training, briefing, CRM etc are so much better than a "cheap and nasty rating", how come you need EGPWS? Why on earth would your flight profile be anywhere near ground you weren't expecting? Only conclusion one could draw from that is the higher powers that be, expect your type(ATPL's) to make mistakes and so give you the tools to do the job safely. Lastly, if the IMCR is so "cheap and nasty" then why are there not hundreds of files at AAIB into all the accidents were having?
Sorry to other ppruners, but i cant stand people making assumptions of thousands of PPL holders from an experience of a few!
Sir you are a :mad: and i would love to meet you for a beer one day:ok:

[S-Works]

Well at least I tried to bring some balance...... :O

[Contacttower]

Well at least I tried to bring some balance...... :O


I'm confused :confused:. Do you mean to say you are Zorst bose?

[julian_storey]

I'm not sure that it's reasonable to suggest that IMC training is poor or of a low standard.

Generally, I think that the standard of instruction for the IMC rating is very high and perfectly designed to equip IMC rating holders to exercise those priviliges which the rating affords.

My only concern about the IMC rating is currency. I wouldn't mind seeing some kind of rolling currency brought in, as is currently the case with the FAA IR. Then again, this doesn't seem to be a source of accidents - so if it aint broke - don't fix it?

[S-Works]

Quote:
Well at least I tried to bring some balance......
I'm confused . Do you mean to say you are Zorst bose?

Don't be stupid.

[mostlytossas]

It may interest you to know that here in OZ we have introduced a ppl imc rating a couple of years ago following years of lobbying the powers that be. While it does not allow instument approaches as it is an enroute instument rating it sounds simular to the UK one. I can only say it was a long time coming here and thankfully it has finally become possible to legally fly in cloud enroute and save many anxious moments trying to stay visual in marginal conditions and therefore must be safer.

[Contacttower]

Don't be stupid.


My apologies bose, I don't know what I was thinking. :ugh:

[dublinpilot]

Mostly,

Can you explain how that works? If a pilot departs, and climbs into cloud, and is allowed to fly there or above enroute, how do they get back down, if not flying an appraoch? Does it mean that the cloud base must be fairly high to start with, to facilitate an enroute letdown (which will be above MSA)?

If that was the case, what's the need for the imc enroute?

I'm just curious to understand how it works ;)

dp

[Zorst]

Also if your training, briefing, CRM etc are so much better than a "cheap and nasty rating", how come you need EGPWS?



dim-witted, thick-skulled, UK PPL community: always justifying their petty little ways with twisted interpretations of the real world


and some characters to make the daft software happy.

[S-Works]

I am curious Zorst (I have no axe to grind as I find your posts humorous) but have you ever held a PPL or did you jump direct to ATPL?

[Zorst]

Nope, PPL, CPL, ATPL, with various ratings and other licences on the way, thank you for asking.

[frog_ATC]

Maybe Zorst is a bit rude... in fact very rude, that's true :-)
He could maybe have expressed himself in another way.

But I must admit that I do not appreciate that UK IMC at all, and I hope they will stop it as soon as possible.


I know most of you will scream!!!! when they will read those lines, but that's my feeling.


Let's introduce myself first : my first job is Air Traffic Controller, radar and non-radar approach qualifications, ATC instructor and examiner in France.

I'm also a pilot, and an instructor (JAR instructor and examiner, and FAA instrument instructor).

As an ATC, I very often have these G-Reg IMC ratings in my controlled area, 100% IMC, VFR status. I've been ATC on 2 different airports, and this was always the same problem : these damned G-Reg IMC ratings, playing the "IR pilot", without qualification, but also, without the status, without the flight plan, and... without the skills.

Yes, outside UK.
Yes, very often.

One of these foggy and cloudy days, a G-reg VFR crossing through my (controlled!) TMA, and I wondered how this was possible with that awful weather, but I already knew deep inside.
So after a while I asked :

- G-XXXX, say conditions ?
- G-XXXX, we are IMC.
- G-XXXX, confirm you are VFR ?
- G-XXXX affirm.
- G-XXXX confirm you are VFR and IMC ??
- G-XXXX affirm.

... Pilots behaving that way have absolutely no respect, either for the ATC, either for the country they are flying through and its regulation. What a great image of UK !

Sometimes they tell you they are IMC, sometimes they don't.
Not only are they outlaw, but this is something completely impossible to handle in a normal traffic for the ATC.

When you tell them they should maintain VMC, they answer "I'm IMC rated".
I do not care your IMC rating, dummy, you are in France and I want you to maintain VMC !!

My second activity, quite time consuming I must say, is flight instructor, and more especially, FAA Instrument instructor.

I sometimes have some IMC rated asking me "I hold an IMC rating, I'm nearly ready for the FAA IR checkride". And they want to fly the minimum as minimum as minimum.

I'm sure there are some talented IMC rated pilots, but I must say that some of those I evaluated had a very poor level of basic IMC flying.

And it took time to train some of them because they thought they "already knew" ! They may have some very bad habits we have to erase to make them safe.
Their flying method is often not structured enough and they try to "reinvent" everything, or consider many things as "details" which are not important... but every detail is important when you are in the soup.

Flying IMC is not only entering clouds and shaking controls, it is more than that, it is a pilot attitude, decision making, understanding of what's happening with the ATC, the traffic, the airplane, the weather.


And as a pilot, I had some unhappy experiences when flying in the same sky...

So did my husband, that "met" one of these "half-VFR half-IFR" two months ago crossing a beacon completely illegaly, while he was same position same altitude, shooting an IFR approach...

When you have seen, in a fraction of second, another airplane passing by below your wheels in complete IMC soup, so nearby that you could see the head of the pilot (this was a cirrus, with one onboard), I can tell you that you really nearly collided and there would have been nothing you could do against that.
Only by chance, you did not "kiss" over that beacon.

They were three onboard, and I remember that 15 minutes after landing the students were still shaking. (of course => AIRPROX)


So, in the name of all ATC outside UK, and in the name of myself as a pilot, I hope they will stop this damned IMC rating, that makes some pilots think they are what they are not.


You cannot be "half trained". Even with the best weather briefing in the world, you can be trapped in clouds more deeply than expected, trapped in weather you did not expected that way. Then you will need a full experience, a full qualification, to sort this out.


Then we are back to the problem: the European Instrument Rating was designed only for airline pilots.
It is too complicated, too expensive, the ground school is completely useless for a private pilot.

THAT IS TRUE.

And that's the main problem.

We need a european Instrument rating in the same spirit as the FAA one. That would be great...

What is the difference between a JAA and a FAA IR, once you are rated ?
None !
You'll fly in the same sky, same conditions, same everything, and you will need the same skills.
Only the way to get it which is different... You learn only what you need.

Despite I had some JAA IR flight experience, I stopped waiting for that marvelous "improved JAA IR" and switched to the FAA one, and I really appreciate now the FAA system with those safety seminars, the fact that they insist on decision making and human factors...
But I still hope they will create a similar IR in Europe, that would be great for the GA safety.

Fly safe,

The ATC frog

PS : sorry, English is not my native langage

[Contacttower]

... Pilots behaving that way have absolutely no respect, either for the ATC, either for the country they are flying through and its regulation. What a great image of UK !


I'm sorry ATC frog, that must drive you absolutely mad! :eek:

I promise though the pilots that do this are very much in the minority and that actually taking away the IMC rating would do nothing to stop people who knowingly break the rules anyway.

The IMC rating has a very good safety record, in fact according to AOPA there has never been an accident involving a current IMC rating holder exercising his privileges legally. Most people on this forum would agree that it has saved lives and is a good thing.

[S-Works]

At the risk of being controversial as usual..

I am not sure you are quite right there about the minority. You only have to be at LFAT on murky day to see one or two rules being bent.

[frog_ATC]

Thanks Contacttower,

First for your kind message, and secondly for flying those pretty taildraggers !

You are right, human behavior is always the key problem.

But I keep thinking that a more accessible IFR (not a "simplified" one, but a more pragmatic one) would be such a better solution than this terrible "IMC thing".

Croa-Croa from the tower

[Fuji Abound]

Frog ATC

Welcome to PPRuNe - how nice to have your first post on here.

I am worried about your English as I suspect some of the content may have been lost in translation.

I am fluent in French - French aunt, brought up with her, so I telll you what, please could you post your last in French as well and I can let everyone else know if anything was lost in the translation.

Thank you.

[frog_ATC]

Thanks Fuji that's very nice !

As I wrote it directly in English, I have no French version of it !
But that's true that I sometimes made some cut because I could not find a specific word ! :)

Mais ce n'est pas très grave, ça me fait du bien aussi d'écrire en anglais de temps en temps, ça fait travailler un peu !

Fly safe,

Towered Frog

[S-Works]

With all due respect, french is not my first language in fact I speak very little but her posting was very clear to me and I can understand exactly the point she was getting across.

It is a scenario that I have heard many times crossing France.

As contact tower states a bad example but not quite the minority he thinks. But I think that anyone who is prepared to behave like that is going to do it regardless of whether we have the IMC or not.

[Contacttower]

But I keep thinking that a more accessible IFR (not a "simplified" one, but a more pragmatic one) would be such a better solution than this terrible "IMC thing".



Indeed, the IMC rating was never meant to be a 'solution' in the sense of a replacement for doing an Instrument rating...and if a 'good' IR was thought up for Europe wide then that would be better.


First for your kind message, and secondly for flying those pretty taildraggers !



Well thank you, I do enjoy the Super Cub :).

[Fuji Abound]

With all due respect, french is not my first language in fact I speak very little but her posting was very clear to me and I can understand exactly the point she was getting across.

Take it from me French is a very subtle language and I am sure our friend will not mind repeating her post in her native tongue.

Makes me chuckle though - there I was accepting vectors into Southampton recently when this chap pipes up, wanting vectors on to the localiser.

He gets told slow traffic ahead, I will position you behind.

That wasn’t good enough, but despite pushing he was vectored further out.

Then he wanted another vector for weather.

At this pointed the frustrated controller asked if he was instrument rated.

I have an IR he said.

In that case you are probably aware you are about to leave CAS, what are your intentions, came the sarcastic reply.

The three of us chuckled.

A very long pause.

Vectors were renegotiated.

Then another weather avoidance was requested.

As we landed he was positioned back on the localiser.

A by now exasperated controller mentioned that you appear to have gone through the localiser, what are your intentions.

We were rolling around by now.

The moral of the story - I am not sure there is one really.

The following week en route to Jersey, and I am not going to name the company, spXXXXXXX :), FL45, ORTAC etc. Sir you are not in the airway, what are your intentions. Requesting 20 degrees right. Sir, that will take you further outside the airway, what are your intentions then!!

Chuckles all round.

.. .. .. and the moral, ask the French.

There maybe a difference between these various tales. I can give you the date and time from my log, you might even pull the tapes .. .. ..

[Zorst]

if a 'good' IR was thought up for Europe wide then that would be better


Errr, what's wrong with the one that's there already? Yes, of course, I forgot, you have to be up to scratch. Oh well...

And to think, I've been called 'very rude' by a frog! Praise indeed!!!! :)

[IO540]

FrogATC

When you tell them they should maintain VMC, they answer "I'm IMC rated".
I do not care your IMC rating, dummy, you are in France and I want you to maintain VMC !!


I think that what you are proving is only that it is possible to be stupid (really stupid) and get a PPL at the same time :)

Only a really stupid pilot will not know the IMC Rating is valid (for IFR) UK only.

And only an extremely stupid pilot will fly VFR in IMC and tell ATC they are in IMC (illegally).

A French pilot will do what VFR-qualified pilots do all over the world: fly VFR in VMC or IMC, and if ATC ask "confirm you are VMC" the reply is "Affirm".

I suspect you are seeing a small minority of really stupid people. Not just Brits but also French and Spanish pilots - a lot of people fly illegal VFR. That is the price we pay for having had a very hard IR for so many years. The smarter pilots fly illegal VFR enroute only - it gets a bit obvious if one ends up "VFR" overhead some French airport which is OVC005 :)

Don't worry, there is no prospect of an exact copy of the UK IMCR coming to France. But a new EASA IR could well be a modular qualification, with some privileges being attained before one reaches the full ICAO IR. This is what Australia has had for some time and it works well. The principle is sound.

[Fuji Abound]

Zorst

Well that is quite amusing in view of my earlier post, which I posted before yours.

Tell you what you should do, spend a bit of time listening to AT.

It is quite fun listening to some of the aircraft arriving into Luton.

Hmmm there was me thinking you had to be up to scratch as well, ah well that is another myth blown.

We are running out of myths this week, I must have a word with the myth creators to see if we can rustle up a few more - now there is a thought :D.

[frog_ATC]

Here is a very big mistake.

Being a VFR in IMC is one thing.
You may be trapped by weather, or whatever.
You are non legal, that's a point.

But being a VFR in IMC, and telling the ATC that you are VMC, that is the most stupid thing I've ever seen (quite often, unfortunately).

Acting that way if being a killer, there is no other word for that. Those liars in VFR are the most dangerous thing I could meet when flying IFR, or when working at the tower.

I'm always anxious about them, especially since I met some of some "more nearby than needed". And the problem becomes bigger now that they have great GPS, TCAS and beautiful Cirrus with autopilot : those VFRs really think they are Kings in the Sky, like this stupid guy that nearly killed my husband in his SR22.


I prefer the pilot that tells me he's IMC. On the example given below, the point that makes me angry is that the guy answered very calmly, like if it was something absolutely natural "Yes I'm VFR and IMC, by the way, do you want a cup of tea ?".


But some of them lie, yes, most of the time.
With a 500ft ceiling, top of clouds 6000 ft, my airliners and IFR all in the soup at all levels, this stupid VFR at 3000 feet will tell me "oh yes, we are VMC".
One of them told me one day "Oh no, not IMC, just in and out of clouds".
!!!


If one day you're VFR and IMC when you did not expect to, and moreover, in controlled airspace, but even in uncontrolled airspace, the first thing you should do is TELL THE ATC.

This is the only way we can handle the situation, by knowing what's happening.


But this should be an exception, a very rare situation when you are trapped by weather, not happen to you every two days when you fly VFR !

Because if you are not able to check weather before your flight without being trapped in clouds each time they build, and without being able to evaluate in flight that things are going the wrong way when it becomes obvious, then stop flying... there are other funny activities for you !

The angry Frog


PS : You think that VFR pilots all over the World fly IMC without telling anybody. Not me. I've been flying 12 years before getting my instrument rating, and during these 12 years with more than 100 h/year average,, summer and winter, I never entered IMC. Maybe one day I'll be trapped, but I'll my best not to be trapped, and I trained all my students to do so... and I also told them, if one day they are trapped, how to handle that, and how to query ATC immediately.

[Fuji Abound]

Frog

So lets see, the Brits are in and out the cloud, sort of IMC a bit of the time and the French are in the clouds all the time but VMC all of the time of course.

Vive la Difference!

Still we have had a bit of fun this evening, not sure whether it is deserving of quite such a serious subject but happy to keep chipping in with a few other stories if it amuses us.

[Contacttower]

Errr, what's wrong with the one that's there already? Yes, of course, I forgot, you have to be up to scratch. Oh well...



Goodness you know how to wind people up.

You Zorst (I take it at least) are surrounded by luxuries at work, your plane has multiple redundancies, it has all those safety features like GPW like you mentioned earlier, it can fly itself if you want it to and with super accurate GPS backed INS systems it makes IFR flight safe and easy. It is a spaceship in comparison to most GA hacks. You may have paid for your instrument rating initially but your airline takes care of most recurrent training and state of the art simulators ensure practice is complete and thorough. Because of all this and an excellent CAA the airlines in this country have a safety record to be proud of.

Now lets look at GA; most people in it are not doing it for a living, they are doing it in their spare time because they enjoy it. Although the CAA has regulatory oversight in the single pilot world safety has to rely on individuals observing good practice at all times. Coupled with the fact that most light aircraft in this country are over 20 years old and falling to bits with poor equipment levels it is not suprising that GA does not share the safety record of the airlines.

What would you do? Ban us because of it?

Or maybe take practical steps like the IMC rating to try and help improve the safety situation.

The point about the IR is a simple one. The FAA IR has much less ground school than the JAA one. A lot of the JAA ground school content is irrelevant to the PPL/IR holder and puts people off, I mean how ridiculous is it that people have to go to Gatwick to take tests that are only held once in a blue moon whereas in the States it can all be done in four weeks or so?

I promise you Zorst it isn't about being thick skulled, or having petty ends, it's simply about having safe flying from limited time and money.

[Islander2]

Maybe one day I'll be trapped, but I'll my best not to be trapped, and I trained all my students to do so... and I also told them, if one day they are trapped, how to handle that, and how to query ATC immediately.Undoubtedly one's first priority in those circumstances, n'est-ce pas? :D:D:D:D

[Fuji Abound]

Guys

I would be really careful having a debate with posters who have no history here.

Personally I think it is in danger of devaluing a really important debate, and a bit of fun aside, I think it devalues the debate.

Just my opinion of course and carry on as you see fit, but it is one I am going to bow out of, other than the occasional gentle reminder that it may also devalue this excellent forum.

[frog_ATC]

Of course it is a priority (as soon as the airplane is recovered and flown, which basic IMC flying is part of the PPL training).

Because when you have no eyes anymore, and you are struggling to fly that airplane with no references, which requires most of your capacities, the ATC becomes your eyes, and your assistance !

And other pilots in IMC would be happy to know that someone can help them avoid you (which is also something interesting for you, by the way...).

I'm getting used to providing assistance to those VFR in trouble because of the weather, but I'll NEVER get used to those liars in VFR-IMC, and I'll do my best to fight these dangerous comportments.


French Frog, now completely convinced thanks to that thread that this IMC rating should be banned !

[eltonioni]

Frog ATC, an interesting and alarming tale that no sensible peson would condone or excuse.

But looking at it from another point of view, if France had the IMC rating those pilots (both UK and French) could be legal and France might not need to accept 80 GA deaths each year.

You do know that (from memory) the UK IMC accident rate is zero don't you?

[Contacttower]

Just my opinion of course and carry on as you see fit, but it is one I am going to bow out of, other than the occasional gentle reminder that it may also devalue this excellent forum.

You are absolutely right Fuji.

[Contacttower]

Do you have an opinion on the 'brevet de base' (I think that's how you spell it) frog ATC?

I'm just curious because from the UK perspective it does sound rather dangerous (just as you think the IMC rating is dangerous) and is possibly contribute to the considerably higher accident rate the French have compared to the British.

[frog_ATC]

Despite this IMC Rating, the statistics in UK are not better than those in France.

So where is the improvement ?
There's none !

And I'm convinced that this is maybe even worse than nothing, by pushing those pilots to go in situations they would not have entered without that "rating".

But it seems like my opinion has no value, according to Fuji, because I have "no history on that forum". :D

I just have many years of flying, instructing, and controlling quite a lot of your G-reg airplanes, dear Fuji, in both JAR and FAA system.


Frog_ATC

[Fuji Abound]

.. .. .. you still seem to have lost your mother tongue.

Dont be shy.

[frog_ATC]

I think the "Brevet de Base" is a real good thing, because it is a step in your training, where you can only fly solo, local flight at small distance from your airfield, and back to your airfield.

I participated to brainstorming about "how to improve the PPL" in France, and one very bad point is that pilots are not trained to handle there passengers.

You fly your PPL checkride, and boom !
The day after you can fly with your wife or friend onboard.

But, if flying requires a lot of your energy, handling your passengers requires even more than that, and most pilots are not able to achieve both together just after their PPL when things go wrong.

This is the main reason why I think the Brevet de Base is a good thing, when integrated in a PPL cursus.
Moreover, the accident rate at the Brevet de Base level is very low.

There are some points that could be improved on that Brevet, but the principle is not a bad thing.

For example, I always required that my students are able to divert to another airfield in order to get there Brevet de Base, and most of them have nearly a PPL level when getting that Brevet.
I also prefer my students being rated by another instructor, and myself I endorsed that Brevet to other's instructors' students.

Last point : I do not know why you say there are really more accidents per flight hour in France than in UK, that does not seem to be the case according to the statistics I've read.

But I do not trust fully statistics most of the time, so this one may be wrong... as well as the one about your "zero accident rate" on the IMC rating, which I hardly believe !


regards

soon-sleeping Frog

[Contacttower]

But it seems like my opinion has no value, according to Fuji, because I have "no history on that forum". :D



Of course your opinion has value...no matter how new to PPRuNe one is. :ok:

If you read the 'sticky' thread (fourth from the top on the Private Flying index) someone posted this a little while ago, and it explains partly why we in Britain want to keep the IMC rating (although of course believing that a more accessible IR would be better) and why also we believe that in the UK we do have a better accident rate than France.

(Sorry it's a little out of context, that explains why it sounds a little strange at some points.)


Apologies for a similar posting in other fora, but I think the "French Lesson" is of vital evidence to us, literally a matter of life-and-death. It needs to be distributed as widely as possible.

The IMC rating in the UK, like the Instrument Rating in the USA, has democratised the life-saving skill of being able to fly and land on instruments safely.

There is evidence from France which suggests that our fatal accident rate COULD DOUBLE with the loss of the IMC rating.

This report was commissioned by the french ministry of transport, and was published in April:
http://lesrapports.ladocumentationfr...00415/0000.pdf (http://lesrapports.ladocumentationfrancaise.fr/BRP/074000415/0000.pdf)

It shows that GA in France has twice the number of fatalities than either the UK, or the US (4.2 fatalities per 100,000 hours, versus 2.0 in the UK, and a similar level in the US)

Why?

Part of the reason is because both we and our American cousins have a large proportion of private pilots trained to fly on instruments, while the French PPL is almost strictly a visual flyer with no training or access to the safety of IFR when the weather turns bad.

So they have a far higher proportion of VMC to IMC related accidents: both loss of control and "classic" CFIT.

The sort of accidents which led to the introduction of the IMC rating in the UK by wise people, and there are plenty amongst the pilot population and their passengers (no doubt some reading this forum) who owe their lives to the IMC rating.

The report makes several recommendations, amongst which, relevant to this discussion, are the need for an accessible IR for private pilots in France; an IMC rating if you will.

Amongst interesting points in the report, is the fact that 80% of Accidents are due to "Human Factors". Furthermore when human factors were studied in depth, an analysis of 60 such accidents in france found that:

"The great majority (43 out of 60, with 98 fatalities) took place in unfavourable weather, underlining the problems with lack of training, over-confidence, poor decision-making and pre-flight preparation.

All areas which are dealt-with by the IMC rating.

It would be worth one of our representative bodies going to the expense of formally translating the "French Lesson".


edit: sorry I realise that I copied that twice :ugh:. Must be my bed time too..

[Fuji Abound]

Nite, nite Froggy.

Bonne Nuit a Tous.

(PS just going to check the fridge for some garlic, might be frying some time soon.)

[englishal]

I have some sympathy with Frog_ATC (and my Aunt is French too, she claims to come from the "oily" part of europe :})......

I have seen some very poor decision making being done in the skies over France and the sourthern UK, though I don't think you can claim it is only IMCr holders. I have known "partial pass" JAA IR wannabes (JAA FI's would you believe) fly IFR into France on a VFR flight plan. I have seen VFR pilots take off into OC010 at L2K and I have seen JAA IR holders too scared to file IFR so they cross the channel at 400' :rolleyes: I have also known FAA IR holders shoot approaches into French airports in a G reg. I don't consider this last one a dangerous flouting of the law though....more of a flouting of adminsitration seeing as if you are a non EU resident the DGAC will give you a JAA IR based upon the FAA IR anyway......(N or G it is the same). Of course I'd never do this or condone it. I believe all these bad decisions could be avoided with an achievable instrument qualification valid Eurowide.

My ideal would be an "enhanced" IMC valid in Europe with slightly stricter restrictions applied, but with greater privileges. By that I mean you need an IFR clearance to enter some sort of "controlled airspace" with it and more controlled airspace available to IMCr holders (e.g. Charlie / Delta airways to FL100)....

The problem with the JAA IR is that unless you have £10,000 to spare and 3-6 months of study, and perfect hearing, it is not achievable. My wife would rather we had a new car than I had a JAA IR......It'd be much better to have an IMCr euro-wide which can then lead on to a full JAA IR with credit being given for experience later on and hence a modular IR achievable by those that need it......

[frog_ATC]

Thanks for that, it is really interesting.

As I said above, I hardly 100% trust statistics.
Why ? Because they only have the value they have, but numbers can be torned in all directions to make them say what you want them to say.

Your documents says that UK and US have approximately the same rate of accidents per hours, and France twice.

We studied some statistics 6 months ago to compare France and USA, which were very different, and all based on official sources (NTSB + BEA).

It appeared that the rate between France and USA was not 2... it was even worse!!!!!


Here are our results :

Commercial flights

- USA : 0.4 accidents for 1000 000 flight hours
- Europe : 0.7 accidents for 1000 000 flight hours
- Africa : 13 accidents for 1000 000 flight hours ...


General Aviation

USA : 600 000 pilots, 1.31 deaths / 100 000 flight hours (source NTSB)
Switzerland : 19 000 pilots, 4.63 deaths / 100 000 flight hours (source OFAC)
France : 7.67 deaths / 100 000 flight hours (source BEA + DGAC)


These statistics were done with the help of the BEA.
And they depict a real big difference with the numbers given in the other article.

I have to check the exact result we had for UK, because it was not the subject we were studying during that brainstorming (but I'll go and find it), but I remember we did not find the same as the US, absolutely not... it was more like France !

So you understand now why I do appreciate statistics, but always keep a kind of distance with them.

Whatever, one thing is sure : the more you limit the "sophistication" of the learning of piloting available to pilots, the more you increase your accidents rate.
Developping the IFR for private pilots is one of the keys, and I work actively on that.

But also, did you compare the accident rate of IFR-rated pilots with the one of VFR-only pilots ?
The IFR-rated have more accidents than VFR-only...

Does this mean that it is safer not to get an instrument rating ?
Of course not !!

But this means that the more you learn to fly in bad conditions, the more you fly in bad conditions.
So the more risks you take.

And if you take those risks, you have better be trained correctly and fully.

For me, entering in bad weather conditions SHOULD BE with a real IFR qualification, and with a real IFR equipped airplane !
You cannot be "half pregnant" : you need a real full IFR to fly in IMC !

And this IMC rating just make some pilots (not all of them I assume, I believe there are some serious.... but too many in my opinion and experience) think they are what they are not, without telling the other what's happening, just cow-boys through the clouds...

They just forget the sky does not belong only to them, and maybe the other do not want to get killed by them, especially in other countries were they do not expect to meet them, especially in controlled areas.

So at least, keep your IMC rating for your own country, fly VMC abroad, thanks !


Frog go to sleep


Remarks : About the one above telling that when you enter IMC in VFR you should lie to the ATC, he has better not having me as ATC next time he does that "joke" in France...

[frog_ATC]

Hello Englishal

Thanks for your examples.
I've seen them also... all of them, and even worse.
I could tell stories all night long (don't worry, I won't :-) ).

About the FAA-rated IR in a JAA-reg airplane, yes it is not "dangerous", but in case of problem... No insurance !

Frog-dodo

[englishal]

I have no idea if it works the "other way" for example a French plane taking off into IMC to travel back to France though...Maybe they don't visit the UK because the food is not as nice ;)

I know for one I'd never dare to fly IFR in the USA without a clearance unless it was an emergency. This is the only trouble in the UK, the grey area between IFR and VFR. Without formality anyone can be IFR, nope VFR, nope IFR etc., which is not a good thing in my opinion. This probably also leads to people "pretending" to be VMC when in fact they are IMC - (not that it appears to have caused any accidents yet). Likewise this pseudo IFR does not help the pilot - I'd rather file a route, and have all airspace controllers on the route informed of it before I got there, so zone transits can be easily and quickly accomplished.

IMCr holders who use the rating must be pretty good though as it is the toughest sort of IFR flying in the world. You are resposible for flying and navigating in IMC, you are responsible for negotiating airspace transits and re-routing if nescessary, you are responsible for avioding all class A airspace, you are single pilot. By contrast flying airways is easy, join the airway, sit there, tune the radio, eat your sarnies.......:)

Regarding the stats, I can't remember where I saw them but yes, the UK is far worse than the USA re: fatality per 1000,000 flight hours but roughly half of where France is.........I'll see if I can find them.

[IO540]

I would be really careful having a debate with posters who have no history here.

A very good point I think. One presumes the mods can see the IPs and will be having a laugh, if what we suspect is true ;)

Frog-ATC

You are blaming IMC Rated Brits for a problem which some pilots are guilty of worldwide.

The difference, whether you like it or not, is that the IMCR holder will be much safer doing it.

A while ago I was sitting at a certain southern French airport, and a load of French pilots departed for another French airport. In the conditions it was obvious they were going to be IMC enroute, and do a home-made letdown at the other end.

We could swap stories for ages, and it would lead nowhere.

The only answer is training. Not a legal prohibition. Training which is accessible to a broad spectrum of pilots. The IR isn't and never will be very accessible. If as you claim you hold an IR you will know how hard it was.

France already allows its PPLs to fly above a solid overcast. How do you handle those pilots who arrive at the destination, and find themselves still above a solid overcast?

[BroomstickPilot]

Hi frog ATC,

First of all, let me say how delighted I am to see posts from an ATCO on the other side of the Channel, who has experience of handling Brit private flyers in French airspace. I've often wondered how we are seen by people over there. (I wonder if you could be tempted to write an article for one of the UK private flying magazines: now that would be good).

On Pprune, we tend to see a fair number of very interesting posts from other English speaking countries, (US, Aussie, Canada, etc), but few from our immediate non English speaking neighbours in whose airspace we do a fair amount of flying.

I have understood the points you have made perfectly. (Your English is splendid, don't let anybody here tell you otherwise).

I think the only point I would make by way of reply would be to say that in any field of human endeavour standards of both training and of personal conduct are going to be variable. Flying is no different.

We recently read an account of a JAA qualified commercial pilot who didn't know that wind direction is expressed in terms of the direction the wind comes from, not the direction in which it is travelling! He was apparently sent for 'retraining'.

An instructor told me of an IMC holder on a revalidation checkride who, on being asked to pick up a particular radial from a VOR beacon, failed to find the radial and just continued round in a complete circle looking for it!

But to infer from encounters with a minority of under-performers that the qualification they have should be abolished is like throwing out the baby with the bath water. Perhaps what we need is better means of reporting these irresponsible people and getting them prosecuted and their IMC ratings removed.

I do hope more people from 'over there', ATCOs and others, will be encouraged to talk to us on Pprune, not only from France, but Belgium, the Netherlands, Germany, etc. Do please stay with us.

Regards,

BroomstickPilot.

[Nek7]

Hello every one.

I`d like to say that this is my first post.
I'm IMC student and i need 4 more Hours hopefully to complete the rating.I`d like to say that already IMC save my life ones, doing a night flight, wen suddenly lost visual with ground.The 180 turn from my JAR PPL training didn't work but the DTY VOR work fine...The ATC informed of course! I sag-est to every PPL holder in UK even if they stop the IMC R in the future to go for it.


(PS Sorry for my English but I`m Greek :))

Thx for Listening:ok:

[S-Works]

A very good point I think. One presumes the mods can see the IPs and will be having a laugh, if what we suspect is true

Oooh! conspiracy theory, just like the cold war days. Go on share! Who do you think is masquerading as who!

[frog_ATC]

(unhappy tone)

IO540 :
If you think that your IMC rating makes you "safer" when IMC...
Maybe it helps you handle the airplane without getting upside down, which is a good thing (but I think all PPLs should be trained to do that), but please remember that NO RATING in your pocket will never protect you from another airplane in IMC in front of you !
No piece of paper will build a wall arround your airplane !
So play with your own life if you want, be non legal if you want, that's your own business, but stop flying wild IMC in controlled airspace outside UK, and telling the ATC you are VMC !!!
Trying to convince anyone that this is a "good attitude" is just foolish, and proves you have a very poor idea of the ATC's job and environment.

(change of tone...)



Hello Broomstick,


All you say is really interesting and makes sense, thanks very much, that raises a lot of ideas.

You are right : one main problem is that procedures against pilots that commit violations abroad hardly fly over national boundaries, unless a real crash occurs.
Europe is only a dream and a paperwork nightmare, but those important things have still room for improvment.

To tell you how often this happens, there is now a common joke between ATCs when the weather is very very bad and one ATC has a VFR in radio contact.

- What ? You have a VFR today ?? Must be a Brit !

Sometimes we write a report, sometimes we don't, for I'm not convinced these violations reports will "fly" through the Channel and their authors be punished as they should.
I'll have a look at that next time.

The real worst thing is when they lie about their conditions. At least when they say the truth, we can handle that (more or less).


And do you know we even have some commercial G-reg airplanes (light twins), carrying passengers for hire, that fly through the channel VFR (in order not to pay the IFR Eurocontrol fee) in a solid IMC, sometimes even intensive IMC ?

When it is "too obvious" (I mean, 200ft ceiling and 1000 meters vis) they sometimes request an IFR clearance on arrival... but spent 99% of the flight in solid IMC.


Now we try to treat them as IFR for safety purpose, and apply IFR separation rules with other IFRs, when we "can recognize" them (we had this "VFR airline" from Southampton for a while), but we had some fears at first when applying VFR/IFR separation rules...


I think there is a big problem with attitude, not only with Brits of course.

We also have other problems, that you probably have too : airspace violations, flights with no contact, very low altitude flights, poor preflight briefing, poor decision making, human factors, poor self-training, poor english abroad, etc.

There are many reasons for these violations, and it's quite a hard work to try to improve attitudes and provide safe and useful information to all.

That's also the reason why we'll organize some Safety Seminars (first one should be in June) on different topics.

I would be happy to write an article for any UK magazines (Flyer?), if someone can correct my non-native English :-).


Most pilots think that being a Pilot is just shaking controls of an airplane...
Which is completely false.
Being a Pilot is taking good decision (which often means cancel flight, land as soon as practicable, turn back home, divert, or go around).

Being a Pilot, is more in your head than in you hands !

(Copyright ATC_Frog :p )


And thanks very much Broomstick to welcome me.

I must admit that if you have few French on PPRUNE, it's mainly because we (French people) usually do not speak English very well...

That's a real problem !


Frog_ATC



PS1 : For my own information : can you carry passengers for hire in UK, in IMC conditions, without IFR flight plan ? (with IMC rating)
I would say no, according to international rules, but I'm not sure.

PS2 : Second question for my own information : what legal equipement for the airplane is required to fly it under IMC rating ?

[frog_ATC]

Nek7, I'm very happy that you could handle that, and double-happy that you told the ATC. Congratulations !

That proves that basic IMC flying should be taught to all pilots !
And especially for night flying... When I train a student for a night VFR rating, I give them some IMC training, and even ILS training...

But I know there is another problem for you in UK : the incredibly high fees you have to pay for any IFR approach your perform, even for training. :{
And those damned slots...

It does not help, for sure.

Froggy

[FullyFlapped]

Frog,

Which TMA do you control ?

[Mariner9]

That proves that basic IMC flying should be taught to all pilots

What a great idea Froggy, EASA should adopt that and call it the IMC rating :E

[rustle]

frog_ATC may I join BroomstickPilot in welcoming you to PPRuNe.

I would caution that some posters here will try and devalue your comments on the basis you haven't been posting on PPRuNe very long: But most won't. :)

[frog_ATC]

No, what I suggest is NOT your IMC rating.

There should be no legal flight in IMC for non Instrument Rated pilot, only some training to make you able to save your life in case of problem, and of course recurrent dual training to maintain your skills at top level.

If you want to fly IMC intentionnaly, you should get a full IR.
You can't be half pregnant ! There is no "half IMC".

But everything was already said above.
Quoting a single phrase without really discussing things is useless.
And whatever, what will happen to the IMC rating won't depend on me !
This is just a "poor small French ATCo opinion".

For my TMA, should not be hard to guess, a French TMA which local radar approach, ILS, soon GPS approach, and plenty of G-Reg !
But this could have been asked a more polite way.

ATC-Frog

[frog_ATC]

Thanks Rustle, I do appreciate, and you're also welcome on my airport with broomstick, to take coffee at the tower if you fly through the channel !

(if you do, tel details via private mail)

The foggy-froggy

[stray10level]

Frog, whilst you had your UNHAPPY TONE on to admonish IO540, you managed to avoid a point he raised which i wanted to raise too! Namely, how does a French VFR pilot flying LEGALLY VFR ON TOP usally on airways too, infering more than a local bimble hence various weather systems to consider!(Note:- VFR ON TOP/AIRWAYS Not Legal in UK) make a safe approach to land when the destination is clagged in? You have already stated the IMC could lead pilots in to weather that wasnt forcast, so you cant use the explanation that they had a good briefing before departure! Don't you think it is a little ironic that the French hate the IMCR but allow VFR ontop, whereas the British have the IMCR and dont allow VFR on top?
Also, to try to move this debate along, what do you think needs to added to the IMC training cyllabus to make it an acceptable IFR licence for the GA pilot?
RSVP Mademoiselle.

[Contacttower]

Re the IMC rating's safety record,

It's an AOPA 'fact' that no one has had an accident while legally exercising the privileges so in order to verify that you'd have to contact AOPA. There have been accidents involving lapsed IMC rating holders, but then there have also been accidents involving people deliberately flying in IMC having never held an IMC rating. I think with all the discussion we've had here over the last few months we would have uncovered an accident involving a legal IMC holder that was related to being in IMC at the time of the crash if one existed.

What pilots go across to France and do sometimes is very naughty :=, but it isn't an argument against the IMC rating itself, simply for better enforcement of the rules and training.

[homeguard]

It's got to be good that ATC people from France are debating. France is listed as one of the few countries against the IMCr. However;

Frog_ATC

I absolutely agree that breaking the law is wrong! But, f the law is unreasonable it simply will not work and everyday you prove that truth, in France, with your death rate. In other less hazardous spheres the french are notorious for ignoring patritional laws - thank God!

However the UK CAA, not always known for broad and pragmatic thinking, should be congratulated, together with AOPA, for conceiving the IMC rating. Prior to the IMC rating the deaths from lack of control and CFIT were as they are NOW in France. The decision to bring into place the IMC rating was pragmatic and has been a tremendous success. Not a single fatality since! In the UK BALPA and the ATC system are supportive of the rating. I have never heard of any move against the IMCr from ATC. Indeed the rules with regard to flight into controlled airspace by IMCr pilots was relaxed some years ago without any objection from ATC. Why - because it works.

How do you balance the UK IMCr weather related ZERO deaths with the current death rate in France. Face up to the evidence?

[frog_ATC]

Dear Straight10,


Thanks for your questions, I'm happy to think about it right now, and try to answer in my froggy english (pfiou good english training for me today !).

Your vision "from abroad" on our system may help us improve it, so I appreciate your opinion. And we all know it needs improvement, and as some other I work actively on that goal since years.


What could be added on the IMC rating syllabus to make it a IR acceptable one ?
It is not something that should be added, it is the whole spirit of the thing that does not cope with the requirements.

1) Flying IMC intentionaly should require an IR, which means a full IR training and understanding (only the ground school part should be improved : a lot of questions are completely useless).
So the whole IR syllabus should be the one you are taught before flying IMC intentionnaly.
If you think an IMC rating is enough to handle IMC, so that means you think that the IR is completely useless.
Having flown and taught quite a lot of IFR now, I do not think so !

2) Being able to handle an unintentional IMC situation should be taught to all pilots.
And your IMC rating syllabus could be added for the basic PPL VFR. This would not allow any VFR to enter IMC conditions intentionaly, but help them recover "in case of".

In fact, the main problem is the pilot's attitude.

You know that in the PPL cursus, there is a 180° in simulated IMC conditions. That's not enough, but that's a good start.
Why not more IMC training ?

Mainly because they thought that if they trained pilots to handle IMC, that would incitate them to enter IMC. So, they applied the rule : "I do not teach you what I do not want you to do".

That's completely stupid, but that's it.

In my opinion, VFR pilots should be taught more IMC stuff, but be aware that they mustn't enter IMC intentionnaly, and that these skills are only for non-intentional situations.

And if they do enter intentionaly without any care of the regulation => big punishment, license removed for a while, etc.

But NO punishment for those who have an unintentional bad situation that makes us enter IMC (except if they do it quite often, then => mandatory training, because a pilot should being able to make a decision according to the weather briefing + weather situation in flight)

This is what we already apply most of the time. On my airport, we have bad conditions most of the time. I never wrote a report against a pilot that entered IMC unintentionaly and required my assistance.
But I did for those who took off despite I advised them of very bad conditions on departure, and had to fly back IMC because of these conditions, or for those who obviously entered IMC "nearly intentionaly", just thinking they are "good enough" to handle that and "it's not a big deal".

And if any pilot cheats me by telling he's VMC when he's IMC, I'll do my best to have his license removed. So with those pilots that switch "stand by" when they violate a controlled airpace, or those IFR who declare a false "short petrol" just to get a direct clearance through other IFR and number 1 on approach.
My report will be rude enough to make them have big troubles.

No one is perfect, we all can be trapped by the situation.
But the main difference is our attitude, and this attitude makes a good/bad pilot.



Now, considering the on-top VFR.

You cannot say "We can keep our IMC rating, because you keep something which is at least as dangerous".
This is not an argument :-)
Each of these have to be discussed individually, there is no link between them.


First, let's make a difference between the US VFR-on-top and the French one.

In the US, VFR-on-top is an IFR clearance, that is given to an IFR airplane, whereas in France it is not a clearance, and it applies to a VFR flight.
In the US, flying VFR on-top is called "VFR over the top".

There is a regulation considering On-Top VFR :

- Day only
- You need a VHF two-way on board
- You need a VOR or an approved class A GPS on board
- You must fly above the S surface (3000 AMSL / 1000 ASFC)
- You must respect cloud clearance requirements (1000ft / 1500m etc)
- You must be able to climb and descend, maintaining VMC
- You must have done a minutious weather preflight briefing, which confirms the condition on arrival can allow your VMC descent to your airfield
- You must have prepared all alternatives possible for the flight
- You must update along the route your weather information to make sure the flight can be completed as planned


Which means this requires a lot of preparation for the flight, and a very attentive and consciencious pilot.
You cannot just climb above the layer during a flight and lose visual contact with the ground.

But sometimes some pilots with a bad attitude do so.
And once they get trapped by weather, if the forecast was obviously not adapted to an on-top flight that day, they get in trouble with the authorities.
I personaly know a pilot that acted a bit stupidely. He could land VMC without entering IMC, but needed assistance because he had not planned his flight correctly.
He had a 2-months suspension and had to fly some hours with an instructor.

But I do agree with you that the on-top VFR could be discussed, and that's interesting that you raise that point.

I'm also interested in your opinion about the Brevet de Base that seems not to be appreciated in UK (please feel free to write an email to me about that), that could raise ideas for our next brainstormings, and maybe we could make proposals to improve it.


VFR in airways

I'm not sure to understand : are VFR forbidden in airways in UK, or on-top VFR only ?

Whatever, only the airspace class is taken into account here.

First, a VFR cannot fly IMC, so he has to apply distance from clouds and visibility requirements at any time to maintain VMC.

Most VFR pilots forget that those requirements were set to allow distance+time for collision avoidance.
Which means that flying out of clouds just below a cloud layer (above 3000ft) is considered as IMC.

Just remember that if you do so during a PPL checkride, you fail.
That's a very dangerous attitude.
I always have a bit of tense during IFR flights when I just pop out of the clouds, because I'm always afraid to discover a VFR airplane in front of me and not have time to avoid him.

So, anywhere, VFR should apply distance from clouds and visibility requirements, and query ATC if they cannot apply those requirements because of deteriorating weather.

In IMC, IFR cannot meet a VFR (except some stupid non-legal G-reg...).
In VMC, IFR pilots should look out, as VFR do, for traffic avoidance (whatever the class of the airpace).
I do agree with you that most IFR pilots tend to forget that, and think they do not need to scan out for traffic avoidance when they fly under IFR rules... they are completely wrong.

As airways are usually E airspace, or D-C-B-A airspace, but not G, most of the time you will be in radio contact with the ATC.
In E airspace, that contact is not mandatory as long as you maintain VMC. If you cannot maintain VMC, you have to get a clearance to enter E airspace, and to establish radio contact.

In France Special VFR clearances are given only in CTRs.
We used to have a lot of class E CTRs, but this created a lot of problems, because VFRs were crossing through without radio contact, whatever their weather conditions, and we had a lot of AIRPROX and complains from Pilots, Companies and ATCs.
That's why all these CTR became Class-D quite recently, so that VFR cannot cross without radio contact...


I hope I answered your question.
I may not have time today to answer more (because even frogs need to go to work/shops/etc sometimes) but if ou have more feel free to write me an email.

If you want a good IFR syllabus, just check the FAA one, it is nearly perfect. (nearly, because nothing is perfect!)

Some people say the FAA one is "not serious", "too easy", etc.
Depends on your school.
I've seen some verybad JAR IR schools, believe me.
Moreover, if you learn in the US, you'll need some training back here because systems are different (and a JAA IR pilot in the US will also need some training to get used to the US system).

And it depends on you also.
What means "getting an Instrument Rating" ?
It only means that the day of your checkride, you could do more or less what is required.
But then, it will be your own responsibility to develop and maintain your skills at top level.


But I'm sure we could make something great, if only our politics and administrations could listen to us.

Regards,

Frozen_frog

[IO540]

There are quite a lot of prejudices here, but this one

What could be added on the IMC rating syllabus to make it a IR acceptable one ?
It is not something that should be added, it is the whole spirit of the thing that does not cope with the requirements.

1) Flying IMC intentionaly should require an IR, which means a full IR training and understanding (only the ground school part should be improved : a lot of questions are completely useless).
So the whole IR syllabus should be the one you are taught before flying IMC intentionnaly.
If you think an IMC rating is enough to handle IMC, so that means you think that the IR is completely useless.

is the real problem.

All the time there is the total complete attachment to the full IR for any flight in IMC, little progress is likely to be made in Europe, because of the army of people who want to keep the IR just like the old days. Actually "old days" is not a good description because the Euro IR was much easier in the old days; easier on flying and far easier on the ground school.

[Contacttower]

I'm also interested in your opinion about the Brevet de Base that seems not to be appreciated in UK (please feel free to write an email to me about that), that could raise ideas for our next brainstormings, and maybe we could make proposals to improve it.



I asked about it because 'on the face of it' it sounded quite dangerous, but actually when you explained it didn't sound too bad...in fact the idea behind it (PPLs learning to deal with passengers) is excellent. I think it's good that we can discuss ideas like this.


Re the airways: in the UK airways are class A so no VFR flight at all (I think occasionally parachute droppers are allowed to enter but I'm not quite sure about the rules). In general no one goes into the airways without an IFR clearance. CTRs are class D and all traffic has to ask permission to enter and maintain contact with ATC at all times.

[dublinpilot]

Frog,

I find it hard to reconcile your argument Flying IMC intentionaly should require an IR, with the fact that you are teaching an FAA IR in France :confused:

I don't agree that "Flying IMC intentionaly should require an IR", but if I did, then I imagine that I would think that it must be a JAA IR for a French person.

In any case your main issue seems to be with IMC trained pilots flying in IMC but declaring that they are VFR. This does indeed seem stupid, but none the less, the problem would be eliminated overnight if the rating was made Eu wide...the problem will just disappear, as there would be no reason to do that.

dp

(From a country also without an IMCr ;) )

[mm_flynn]

Frog_ATC a couple of responses to your questions.

1 - A UK PPL is not allowed to fly VFR over the top (it is a restriction on his licence)

2 - When a UK pilot talks about 'Airways' they normally mean the UK airway system which is almost universally Class A (hence only available to full IR holders)

3 - Most of the volume of UK airspace is Class G, where as I would guess most of France is Class E. Within the UK there is no real facility to get an IFR clearance for Class G and any radar separation service needs to be negotiated with each radar unit (if available at all!).

4 - Interestingly a UK PPL (without IR or IMCr) is allowed to fly IFR in Class G (most of the airspace he would use) and is EVEN allowed to fly in some types of IMC. Specifically, does not need to observe the cloud separation minima of VFR.

The combination of all of these is a UK view that hitting someone else in the open FIR in IMC is a vanishingly small possibility. The US, where I learned, has a view you have a high possibility of Crashing and Burning if you are IMC not on an IFR flight plan (similar to the view you have expressed).

Interestingly, the British don't seem to have hit another plane in Class G in IMC since around WWII, yet have the same depressing regularity of aircraft hitting each other on fine VMC days.

Finally, this hazy combination of IFR/VFR rules (which in many cases have no material difference), licence privileges (which are not straight VFR only or VFR + IFR), and the rigid separation of Class A airways vs. the rest results in much more casual (confused) views like - 'I am VFR (i.e. not on an IFR flight plan) but IMC' a non sequitur but you can understand why the pilot says in (because a well planned Class G VFR flight in the UK is going to be equally valid as an IFR flight - with NO CHANGE AT ALL on the pilots part)

[BroomstickPilot]

frog_ATC,

Check your personal messages (PMs).

Broomstick.

[homeguard]

There is a pathological need amongst some pilots to, when thinking of flight to also think of death as if it is a qualifying requirement to fly.

There is no evidence either in fact or circumstantial to substantiate the believe that safety following the IR is greater than that achieved amongst IMCr pilots. It cannot be safer if one accepts the zero figure from the IMCr statistics. If anything the IR in its current form is perhaps 'over the top'. With the introduction of the JARs the IR course went up to 55 hours. Why, for it had been claimed, though nievely, that the UK IR was the finest in the world at a couple of hours over 40hrs minus 10 hours off if you had an IMC rating.

Frog_ATC you seem to have had the fear of God bread into your flying. Why frog do you believe that a Shark is maybe lurking just below cloud, just waiting to get you. To be honest I know what you mean, I find life is much safer in IMC - if one believes that the only encounters will be from those talking to RADAR and therefore be known as it is within the UK owing to the IMCr. It appears to be more that two aircraft collide in VMC as mm_Flyn reminds us and as continues to be experienced outside of the UK. According to FROG they would all be english if she had her way! Her husbands near miss during a procedure, of course, had to be an englishman for the french non IR pilot would have lost control well before the beacon, no doubt.

Frog, you acknowledge yourself, the old chauvinistic thinking that; if you do not want someone to do something keep it a secret from them, as if you can. In fact education generally and the IMCr specifically proves the opposite. Many in the UK who undertake the IMC course also learn their personal limitations and later work within that limitation. Ignorance and fear are the greatest killers. The IMCr course removes the fear and eradicates ignorance and teaches respect. I have never witnessed arrogance evolving out of the IMCr training only humility. To the doubters, hasn't that got to be a good thing?

[frog_ATC]

Thanks mmflynn for your answers.

Just one question :
"4 - Interestingly a UK PPL (without IR or IMCr) is allowed to fly IFR in Class G (most of the airspace he would use) and is EVEN allowed to fly in some types of IMC. Specifically, does not need to observe the cloud separation minima of VFR."

Are you sure of that ? (maybe I do not understand)
You mean in UK a PPL can fly IMC in class G ?
I'm sorry but this is non-ICAO and I'm very surprised of that.
VMC conditions definition is different in class G, but "in clouds" it is certainly not allowed. Only "out of clouds" in very low levels, but you always have to keep your 1500m/30s vis distance ahead (not easy to evaluate in flight !).
Could you confirm ?


Wow homeguard, how fine you are ! :-)
I feel better now after your fine analyze of my psychology !
:D:D:D
I'm probably afraid of flying and scared before and after any flight, you're right ! :ok:


I fly and teach tailwheels very often, vintage airplanes, aerobatics, mountain flying, gliders, I teach ultralight as well as actual IMC to beginners (which requires a lot of concentration), so I think I'm not "afraid" of flying.
Just attentive and cautious, as any pilot should be, because I know I'm just human and can make mistakes (and I did sometimes), and the other can too.
Don't think I'm arrogant, I'm not a good pilot. Not the finest, not the best at all. I just do my best to make more good decisions than silly actions, and this is not always easy, as you all know.


About arrogance and humility, I did not speak about that because I did not want to embarrass some IMC-rated pilots here which are probably very fine and humble, but I'm sorry to say that those I met, requesting a "quick IR training", were most of the time arrogant and not as skilled as they believed they were...

Dublinpilot : there is no contradiction in what I say. I flew JAA IR as well as FAA IR, and you know what ?
The airplane flies the same !
Same lift, same air, same clearances, you see no difference once you are rated. And in both cases, you are responsible for maintaining your skills by recurrent training.

I do not change my point of view, and for me, intentional IMC flight implies Instrument Rating, whatever FAA or JAA I do not care.
IMC basic flying (what you call IMC rating) should be taught to all pilots, on safety purpose, but not allow them to enter IMC intentionaly.

This is only my own humble position.

I hoped they would modify the JAR IR, but they did not.
So now I believe the FAA IR is the key solution for JAR pilots, until they do something for us with a JAA IR.

Just listen to frequencies : more and more N-reg.
This is the proof that EASA has completely failed.

Don't you want a real IR, more accessible, instead of this half-IMC thing ?
That's what you should fight for, with us, not for an IMC rating !

And we should also fight to improve the PPL training, and add more IMC stuff in it, to improve safety.

Frog, in and out of internet

[TheOddOne]

Why not more IMC training ?

Mainly because they thought that if they trained pilots to handle IMC, that would incitate them to enter IMC. So, they applied the rule : "I do not teach you what I do not want you to do".

That's completely stupid, but that's it.

Frog,

When I got my UK PPL many years ago, there was 4 hours 'sole reference to instruments' training, after which I thought I'd got quite good at it. Then I took some friends for a ride and entered IMC unexpectedly and thought 'this is BAD'. I contacted ATC (Heathrow radar actually!) and they were very helpful in ensuring that my 180 turn back into VMC was conducted without harm to other aircraft. Lesson learned. I then did the IMC course, which principally taught me how to plan better and have a better understanding of the weather forecast to avoid flight in IMC, but if I did enter IMC, not to panic and how to get safely home or divert. Thus, all my long trips in the UK have been planned for VMC, but convert to IMC without having to change anything (except upgrade the Radar service to Radar Advisory Service). This is better and safer than running along at 500' under the cloud and meeting the ground ahead rising up to meet you. The 4-hour requirement was removed from the syllabus because too many pilots were like me and thought that they could do IMC. There is now only 1 hour, all about making a safe 180 turn back to VMC. Now I'm just starting as an instructor in the UK and I'm teaching this to other people.

In 20 years of flying since getting the rating, I can count on one hand the times I've really had to make use of the skills, though I do practice 'under the hood' with a safety pilot. i'm fully aware that the rating stops being valid at the FIR boundary. In any case, when I go for a day out, I want the weather to be nice. Just becasue I CAN fly in clouds, doesn't mean to say that I WANT to - I might as well fly a sim if that's what I want.

Now, the peculiar law about IFR in the UK. IFR here means flight 1,000' above any obstruction within 5 NM of track except when landing and taking off and a recommendation to follow the quadrantal rule above 3,000'. That's it. NOTHING about 'sole reference to instruments' or flying inside the soup (lovely expression, thank you!) I took a student on a cross-country flight today which was planned and flown entirely by this UK IFR rule, but it was a beautiful sunny day and the whole flight was flown completely by external references, except for the watch, compass and altimeter (and of course the engine guages etc). There's a LOT of confusion around that equates UK IFR with some sort of indication that you can't see out. If EASA could only do one thing, they could get a re-definition of VFR, IFR, VMC and IMC.

By the way, I'm sure we're all understanding your meaning perfectly from your excellent English. The style is very distinctive and refreshingly different from our usual 'stiff upper lip' prose. Thank you once again for your views, we much needed some opinion from outside our own group. I'm sure something from you in our magazines would go down a storm!

Cheers,
TheOddOne

[mm_flynn]

With regard to Point 4.

A plain UK PPL is allowed to fly IMC in Class G so long as two conditions are true
1- they are in sight of the surface
2 - they have 3 km viz

So you are right, they can not be 'in cloud', however, they are not required to comply with the cloud clearance or in flight visibility requirements for VFR operation in Class G above 3000ft or above 10000ft (so long as they follow the IFRs - which at that altitude are only to fly quadrantals), nor are they limited to 140 kts for the low level clear of cloud restriction of VMC because high speed low level flight clear of clouds with at least 800m viz is legal UK IFR and so long as the viz is 3km is legal for a basic PPL.

[dublinpilot]

Dublinpilot : there is no contradiction in what I say. I flew JAA IR as well as FAA IR, and you know what ?
The airplane flies the same !
Same lift, same air, same clearances, you see no difference once you are rated. And in both cases, you are responsible for maintaining your skills by recurrent training.


I'm sure an IMC rated and trainned pilot would say the same thing ;) The airplane flys the same when an IMCr pilot is flying it, as when an FAA or JAR IR rated pilot is flying it ;)

Don't you want a real IR, more accessible, instead of this half-IMC thing ?
That's what you should fight for, with us, not for an IMC rating !


In many ways I agree with you here. But I'm afraid that I don't believe EASA will sort that one out. I think getting an Euro wide IMCr is the closes that we can get.

intentional IMC flight implies Instrument Rating
I don't understand your hang up with Instrument ratings. "Instrument Rating" is nothing more than the name given to some training and an exam. By your own admission, EASA have made a mess of their IR. Why can't you argue for some training and exam, that is appropriate to private instrument flight? There is no reason why it has to be an IR if that training (and exam as proof) is sufficient, no matter what it's called. Call it an IMC rating....call it a IFR rating, or perhaps a non-VFR flight rating....what does it matter if it's called IR or not? The name should matter not one little bit. Now if you can agree with me on that, then surely it's only a matter of deciding what you don't like about the IMCr training, and how it could be improved so that it would be acceptable in France? (or Ireland for that matter;) )

That would be a much more reasonable argument than IR=Ok, no IR=not ok ;)

dp

[homeguard]

Frog, I value your contribution. A big question for us all is; what are those outside of the UK actually thinking with regard to the IMCr.

But I'm left still with a feeling that the opposition is immotive. Your posts are clear and honest and helpful and I respect that.

However if I may illustrate my earlier comments by making a comparison. A good friend and brilliant ex RAF Engineer couldn't understand how anyone could get airborne with anything less than four engines. He'd flown for some thirty years. I asked him how many engines he'd had fail. He had to think hard but could only remember shutting one down on only two occasions. So why four was neccessary for safety he couldn't answer but it was how he felt. In a single engined aeroplane he was always very nervous and couldn't bring himself therefore to do his PPL. He always forsaw doom when behind one engine. Many twin pilots are similar, illogical but understandable, albeit the safety record for twins is no better than singles.

My comments were not to offend but to make the point that for some, if all they have known is the IR, it can be inconceivable that anything less will do. But that is far from the truth. Should the IMCr syllabus be strengthened? YES. Without doubt.

Prior to the JAA UK Flying Instructors were required to hold at a minimum an IMCr. All UK PPLs had to do a minimum of 4 hours instrument training and were tested for their PPL in all aspects of actual instrument flight including Partial/Limited panel and also recovery from unusual attitudes. The 15 hours minimum IMCr training took account of that. Further, in my twenty years of instructing and examining I know that most IMCr candidates would do at least 20-25 hours of IMCr training, some more. A norm then would be in the region of 25-30 hours of instrument flight but without the additional airways training included within the IR.

The IMCr does need revision to take into account the modern world (it was previously based primarily on ADF and VDF procedures) and nowadays it should be reasonably based on a wider 30 hour syllabus.

The JAA agreement abolished minimum hours of instrument training for the PPL and I find that appalling.

Whilst the revision of the IR along the lines of the FAA IR would be progressive it is unlikely that the passion of the european beaurocracy would keep it that simple. By the time they had finished any improvement to access would be blurred and still awkward to obtain. We in the UK would go back 40 years and begin to experience the appaulling level of marginal weather safety seen in most of northern europe. The ICAO/JAA 1500m is VMC by name but in practice requires instrument skills and IFR navigation but is undertaken on mainland Europe without any training for it. The UK PPL is restricted to 3K without an IMCr. The IMCr holder requires 1nm while taking off and also to land.

Anyway keep your arguments coming and I for one would like to hear more from non UK pilots and controllers to build a better picture of what the actual european fears are amongst some.

[frog_ATC]

I'm happy to see that my English is mainly understood :-)
That's quite interesting to read your points of view (even if I do not agree with all of you :p )


mmflynn:
Thanks for answer.
Please note that in France (as in most European countries), VMC conditions in class G are not the same as in UK.

Below 3000 ft AMSL (or 1000 AGL, the highest) : Vis 1500 m or 30sec flight, and out of clouds.
Above 3000 ft (or 1000 AGL, the highest) : Vis 5km (8km above FL100), distance from clouds 1000ft vertically, 1500m horizontally.

Which means that above 3000ft, "out of clouds" is not enough to be legal.
Why ? Because we have IFR flights in class G, so that is required for traffic avoidance purpose.

So maybe now you wont fly IMC in France without notice :)

In the US it is more or less the same, only values and units change a little bit.
One specific point in the US that I dislike : you can fly IFR without contact and without FPL, in class G.
But there is nearly no class G in the US, mostly E :-) so i've never seen that happening.


TheOddOne says :
Just becasue I CAN fly in clouds, doesn't mean to say that I WANT to - I might as well fly a sim if that's what I want.


Hello TheOddOne,

I'm fully 100% percent OK with your vision of your IMC rating, and I wish all pilots could behave like you ! That is - in my humble opinion- the best attitude.

I agree with all you say !



Dublin Pilot says :
I'm sure an IMC rated and trainned pilot would say the same thing ;) The airplane flys the same when an IMCr pilot is flying it, as when an FAA or JAR IR rated pilot is flying it ;)

Which means Dublin considers an IMC rated pilot as qualified as an IR one.
That's exactly the problem, thanks Dublin to show us that : those IMC rated do think they have the skills, even without the same training...

And sometimes, trained by non-IR instructors !

The problem is skills.
And believe me, when things go wrong, you are happy to be current and recently trained, even with your IR.
So if you could improve the IMC rating training to allow you to have the same skills as an Instrument Rating, why not having a real IR, without any of those restrictions that will undoubtly be imposed to IMC-rated pilots, and without having to fly illegaly sometimes ?


About making it acceptable in France : I think never.
At least for me :-) but also with our airlines, they dislike private IR, they dislike special VFRs, so they will hate IMC ratings.

I forgot another problem : UK airspaces are not managed the same way than airspace anywhere else in the World (I mean, anywhere else I experienced flying, at least... approx 40 countries, which is not the whole World, that's true).

For example, we do not have your joining clearances. I've never seen that anywhere else than in UK.

I've never seen your Radar service, or Radar Advisory Service, or traffic information service, blablabla... anywhere else than in UK.

As I flew in UK, I know that you use that and why, but must of my colleagues are surprised when a G-reg requests "traffic information service please".

In UK you have different level of service you can request in one single airspace.
In most other countries, there is one service per area, which depends mainly on the equipment of the ATC and the class of the airspace.

So you cannot "switch" from one service to another, it is something completely unusual abroad.

In fact, I must say that the more I fly in UK (and the more I talk with UK pilots), the more I see that you have a different system with really specific features, maybe not compatible with abroad systems.

regards

Frog

[IO540]

Some random comments:

I hoped they would modify the JAR IR, but they did not.
So now I believe the FAA IR is the key solution for JAR pilots, until they do something for us with a JAA IR.
Just listen to frequencies : more and more N-reg.Very true.

This is the proof that EASA has completely failed.No, EASA has not even got authorisation to take over JAA FCL (flight crew licensing). They are about to. They will be running FCL later in 2008.

It is JAA who has failed. The airline pilots, their unions, and the ex airline and ex air force people in the regulatory bodies tend to be very elitist and they made sure that within JAA everything got stuffed like a duck - to the tightest common denominator.

EASA's attitude to private IFR is refreshingly different. They want a sub-IR private IMC privilege throughout Europe. Of course it won't be the UK IMC Rating, but something designed in a modular manner should work. But EASA needs to get consensus too - just not the absolute tightest common denominator which made JAA block all progress.

Don't you want a real IR, more accessible, instead of this half-IMC thing ?
That's what you should fight for, with us, not for an IMC rating !Why? Basic flight in IMC is no rocket science. UK's 35 year "experiment" proves it.

And we should also fight to improve the PPL training, and add more IMC stuff in it, to improve safety.I would agree, but all those pilots who did a PPL just to fly basic types, or aerobatics, would not. They want the simplest possible VFR-only license. They make up the great majority of PPLs. And they jolly well make sure this "we don't want any instrument stuff" desire is transmitted through votes of their representative bodies at every committee vote.

And I am quite sure many of these "VFR-only" pilots do fly unofficial IFR anyway, all over Europe - just go to any GA aircraft show and look at the IFR equipped planes that are not certified for IFR. The equipment is clearly what the buyers want. If you are happy to fly illegal VFR then you have nothing to lose in the European GA-political scene (except maybe getting yourself killed, but with good equipment that is a lot less likely these days).

France and the rest of Europe likes to turn a blind eye to this kind of flying (of which only a small fraction will be done by Englishmen - the vast majority of GA pilots rarely if ever fly abroad, so most of it is done domestically by pilots with local knowledge) and this is also helping to keep the full IR very hard because everybody pretends that illegal VFR doesn't exist so there is no need to train people to fly in IMC.

The UK IMCR came about because in the 1960s it was legal for PPLs to fly in IMC, and some got killed, so the mandatory training was introduced. The IMCR recognises that some pilots would do this anyway and that it is better to give them a very accessible kind of basic but adequate instrument training.

Incidentally, there is some possibility of the "EASA IR" ground school being substantially reduced in the next year or two.

The IMCr does need revision to take into account the modern world (it was previously based primarily on ADF and VDF procedures) and nowadays it should be reasonably based on a wider 30 hour syllabus.The IMCR usually takes 25hrs to do. The key issue however is that training should be competence based. The FAA IR "needs" just 15hrs dual training! Yet the checkride is just as hard as the JAA one. There is no way to do the FAA IR in less than about 40-50hrs total instrument time - whether with an instructor or just one's own experience under IFR.

[mm_flynn]

mmflynn:
Thanks for answer.
Please note that in France (as in most European countries), VMC conditions in class G are not the same as in UK.

Below 3000 ft AMSL (or 1000 AGL, the highest) : Vis 1500 m or 30sec flight, and out of clouds.
Above 3000 ft (or 1000 AGL, the highest) : Vis 5km (8km above FL100), distance from clouds 1000ft vertically, 1500m horizontally.

The UK rules for VMC are the same as the French ones above, if a pilot does not comply with these rules then he CAN NOT BE VFR!. HOWEVER, the ONLY rule in the UK Instrument Flight Rules that is relevant in Class G, In the UK, above 3000 feet is the REQUIREMENT to fly quadrantals (vs the Recommendation to do in VFR). So to a pilot IFR = VFR there is the subtle change from quadrantal levels being required vs recommend and that is it!!! No requirement for ATC services, radio contact, a change in squawk (The UK has no VFR squawk code).

You are right that the UK airspace, ATC system, approach to Class G and muddling of IFR/VFR/night/IMC/VMC and licence privileges is unique.


Yes, I do know there are some areas where terrain goes above 2000 ft in the UK, but not very many, and I am ignoring those for simplicity.


With regard to your US Class G point, you are correct, it is not technically required to have an IFR flight Plan and be in radio contact enroute in G (and there is little enroute G other than the middle of nowhere! However, I believe there is case law that confirms the FAA view that not availing oneself of these services is Careless and Reckless operation of an aircraft and hence illegal.

[dublinpilot]

Which means Dublin considers an IMC rated pilot as qualified as an IR one.
That's exactly the problem, thanks Dublin to show us that : those IMC rated do think they have the skills, even without the same training...


Frog,

It does not mean that I think an IMC rated pilot is as qualified as an IR rated one. It means that I think an IMC rated pilot is trained and examined, and suitably qualified for the additional privlidges that are granted to them. (Privlidges that are less than those of an IR qualified pilot).

What I am struggling to understand is this.
You say
So now I believe the FAA IR is the key solution for JAR pilots, until they do something for us with a JAA IR.

Just listen to frequencies : more and more N-reg.
This is the proof that EASA has completely failed.

I agree with you on this...the JAA IR is broken.

You haven't said why it's broken, but I think that we would probably be able to agree that it's because the training isn't suited to private IFR flight, and contains too much stuff only needed at commerical level.

So if we can agree that that JAA IR is broken, why can't we agree to introduce something more suited to private IFR flight?

What if we forgot about the IMCr and decided to leave the Instrument Rating alone, and instead brought in a second type of IR, called a "Private-IR"? Would that be more acceptable? This would be much more achievable I think than trying to change the current IR.

Then of course the question arrises what should be in a "Private IR" sylabus? I would suggest that we'd have a more suitable sylabus if we started with the IMCr and tried to agree what was necessary to be added on to the sylabus (or privlidges curtailed), than if we started with the current IR and tried to take out what wasn't necessary ;)

dp

[rustle]

Thanks Rustle, I do appreciate, and you're also welcome on my airport with broomstick, to take coffee at the tower if you fly through the channel !

Very kind, thank you :ok:

I would be interested in your views about the likelihood of EASA pushing through an EU-wide (or EASA-wide) IMC rating...

I'd also be interested in your views about the likelihood of EASA pushing through an EU-wide (or EASA-wide) reduced-training IR...

I ask because you have already mentioned the "pushback" from French commercial pilots in relation to "private IFR" etc. Do you also know (or have any indication of) what the other continental ATC/Pilot fraternity might be thinking?

Thanks - a refreshing change from the usual suspects ;)

PS and BTW: this subject also gets quite a lot of airtime at another place too (http://forums.flyer.co.uk)

[frog_ATC]

I've been thinking about that quite a long time.

Yes, a "private-IR" would be fine.
But I'm afraid that our dear authorities apply restrictions to those IR : no class A, no major airports, etc.

I do not agree with that.

Private pilots with the required training and recurrent training should be given a full IR with all privileges.

My dream would be that they modify the JAR IR and throw away that extra useless stuff, not only for private, but also for commercial pilots.
This extra stuff can be done in the ATP or CPL cursus !
When you add it to the IR, that means you imply that IR is ONLY for CPL-ATP.

But my dream will probably never be true in Europe :-)


ATC_croa-croa


Note 1 : The FAA IR requires 40 hours IMC, with 15 dual minimum. The checkride is as difficult as the JAA one, and maybe even harder because you have to perform a non-gyro non-precision approach which you do not have on the JAA one.

Note 2 : This note is a quizz. In your opinion, which is the harder : flying IFR as a private, or as a commercial ? Answer coming next !

[frog_ATC]

Dear Rustle,

About an EASA IMC rating, I do not love that idea.

About an EASA reduced-training IR... why not, but only the ground school should be reduced (most of it is useless), not the flight school.

The only limitation I would accept would be : no flights for hire.
But there should be all privileges included (major airports, class A, airways, etc).

ATC_frog

PS : coffee is soon ready !

[dublinpilot]

About an EASA IMC rating, I do not love that idea.

About an EASA reduced-training IR... why not, but only the ground school should be reduced (most of it is useless), not the flight school.


Frog....this is where I can't follow you. You are ok with an reduced training IR, but not with an EASA IMC rating (which may involve additional over and above what the UK IMC does). ....what's the difference? :confused: Nothing more than a name as far as I can see. ;)

You also say that you'd be happy for the ground studies to be reduced, but not the flight training. But the reality is that we all learn at different rates. The test shouldn't be how many hours you've done, but instead should be about what standard of flying that you have reached. The test should be able to distinguish those who have reached the required standard from those that haven't, irrespective of the number of hours. Pilot A, might be very quick and be able to reach the standard after 25 hours, and pilot B might never be able to reach the required standard.

dp

ps. no test....IMC test nor IR test, will be able to stop pilots flying outside their privlidges after getting their rating.

[Islander2]

I ask because you have already mentioned the "pushback" from French commercial pilots in relation to "private IFR" etc. Do you also know (or have any indication of) what the other continental ATC/Pilot fraternity might be thinking?rustle, Frog_ATC seems to have missed your cue on that one. You may need to give him a prompt! ;)

[frog_ATC]

Dublin, you're unbelievable :-)

As far as I know, the IMC rating is not a full instrument rating, am I wrong ?
The flight training is not the same, it is reduced, am I wrong ?
If it was, that would be named "instrument rating", and you would have no restrictions when flying IFR with it, am I wrong ?

So could you explain to me why you do not see any difference between an IR and an IMC rating ?

Or are you just pulling my leg ?

To finish with that, then I'll let everybody try to answer my quizz above, flying IFR is not a complicated thing, I do think it is quite simple : it requires only enough practice by a calm and attentive pilot with a good IR instructor.
How to fly IFR correctly ? Just apply what you learnt, be calm, use checklists, do not do more than what you learnt, think before you act, make you decision with calm, listen to the ATC, do not do silly things. Not a big deal in fact.

But it has to be learnt, and requires a flight training that should not be reduced.
But the knowledge test should be modified to make it more accessible.

Let's quizz!


Frog


Added PS for Islander : about "what the other think"... hard to say :-)
ATCs do not like small airplanes in most countries, especially in major airports. They hate VFRs in IMC (so do I, as you know, especially if they lie :-) ). Most of them do not know what is your IMC rating, except those who love piloting, but there are not so many.
Pilots... some dream about your IMC rating, but they can hardly say what it is. In fact most French pilots don't know it, or just know the name "IMC rating" without understanding it.
Even me, despite I tried to get informed because I had some IMC-rated students for an IR, I do not know the exact regulation linked to it, except that it is limited to UK.
Most French pilots do not fly IFR at all, and have a great veneration for those who are rated. Which is stupid, because flying IFR is not such a complicated thing, once you have learned, it just requires method and structured actions.

[dublinpilot]

As far as I know, the IMC rating is not a full instrument rating, am I wrong ?
The flight training is not the same, it is reduced, am I wrong ?
If it was, that would be named "instrument rating", and you would have no restrictions when flying IFR with it, am I wrong ?


The point I was trying to make is that neither the content of a EASA IMCr (which you dont' find acceptable) nor the content of a private-IR (which you do find acceptable) is defined. They could very well be the EXACT same content! Same training, same instructors, same theory, same flight test! There doesn't seem to be any possibility of getting an EASA Private IR, so why not work towards an EASA IMCr which has the content that you'd like to see in a private IR? It would be just an private-IR with a differnt name!

Is that wrong ;) Don't get too hung on on the name of the qualification ;)

dp

[frog_ATC]

For me, the flight training of the private-IR should be exactly the same as the one of the IR.
Only the ground school part should be reduced.
(by the way, does someone could send me the syllabus of the IMC rating?)

And I would like it to be called "IR" also, just because I do not want our dear authorities to try to add restrictions on its use ! :)

Private pilot are just as able as those commercial, they just do not want to learn things during the ground school they do not need, and lose time and money because of that written.

So why don't you answer my quizz ? ;-)

Frog

http://cache02.stormap.sapo.pt/fotostore02/fotos//7f/32/9a/5084_00035s6w.jpg

QUIZZ :

In your opinion, which is the harder :
flying IFR as a private, or as a commercial ?
Answer coming next !

[dublinpilot]

Well I'm not really qualified to answer your question....I've no IR, and as I'm Irish qualified, the IMCr is not an option to me :bored:

But I'm sure that the answer is, that in the same aircraft, with the same instrumentation, on the same route, in the same weather, the licence that you hold (PPL/CPL/IR/IMC) makes no difference to how easy it is.

If you mean PPL/IR in C172 with minimium IFR fit vs ATPL in EFIS B777 with another pilot sitting beside you, then I imagine that the ATPL has an easier time.

Now, to continue the debate ;)

As I understand you, you would be willing to accept an EASA IMCr which had similar flight training requirements to a JAA IR, but with significantly reduced ground school (it's already sounding like your FAA IR) ;)

Now one significant requirement of a JAA IR is 50 hours training (SEP). Lets take that one for a minute. The FAA one has a lower number of hours....IO540 says it's only 15 hours dual training.

How about saying, to get an EASA IMCr (which is an EASA Private IR in all but name....we could even agree to call it an EASA Private IR if it would make you more agreeable ;) ) you don't need any dual training....you just need to be able to fly to the standard required for the test. The examiner can, and should, throw everything and anything at you during the test to make sure that your flying is up to the benchmark.

Doesn't that make sense....after all, why should holder of a foreign IR who has thousands of hours flying IFR in IMC who could pass the flight test without any further training, have do do 50 hours training before taking the test? The test should be the standard, not the number of hours training.

Can we agree that much? :)

dp

[Fuji Abound]

Well Frog for what it is worth you are wrong.

The IMC rating is a FULL instrument rating.

It qualifies the pilot to fly on instruments.

Of course, instrument conditions here are rather the same as instrument conditions any where else, unless the laws of physics are different in Europe.

Put simply you are either qualified to fly when you cant see out of the window or you are not.

You may care to look up the two things it does not enable a pilot to do in the UK so far as instrument flying is concerned. Unfortunately there are some maverick instrument pilots here who do one of those two things in single engine aircraft - which says rather less for their professionalism.

IR and IMCr are names, terms we use to define a rating.

There is no such thing as a FULL instrument rating.

If you wish, the IMCr is not an ICAO instrument rating, but then neither is the FAA or JAR IR, both of which include differences. So the IMCr is not an ICAO rating, the JAR and FAA IRs are ICAO instrument ratings but with differences filed.

In the UK more private pilots hold an IMCr than there are private IR holders in the whole of Europe.

There has been one accident involving a pilot with an IMC rating in the last thirty years.

There have been far more accidents involving pilots with instrument ratings.

In fact, all other factors aside, instrument rated pilots in Europe are far more likely to kill themselves than IMC rated pilots.

If you were a responsible controller you would file on the pilots you have referred to in your posts that abuse the law. I am not aware of these reports on which the CAA would have been obliged to act. You do no one any favours by your failure to do so in the circumstances you describe.

You would benefit from grasping how the rating is used in the UK by the vast majority of instrument pilots. You would find it informative to look at the statistics because historical evidence is the best way of judging whether the system is safe.

The ultimate safety solution is to react to evidence that suggests something is unsafe, be it because the same accident keeps occurring or the same group of pilots keep killing themselves.

There is evidence that pilots in France kill themselves because they do not have an IMC rating. You ignore this evidence at your peril and their peril.

More importantly, your testimony is based on anecdotal evidence regarding pilots that are acting illegally - if that was the basis for any study then clearly we should ban alcohol because some drivers drink and drive whilst ignoring the vast majority that do not.

I am sorry Frog but I don’t find merit in your posts and I don’t believe that if you were an ATC you would post in the way that you have. I am in correspondence with a French ATC and you and his views are so far apart that I find it very difficult to believe you are who you purport to be.

[frog_ATC]

Ok ok ok, Fuji, I think you should have a break, take a glass of water, maybe eat something or just listen to music and relax ! :p


(and if someone could send me the IMC rating syllabus, that would be nice !)

[Contacttower]

Well she likes the Twin Comanche, so she must be pretty cool whatever her views on the IMC rating. :D:D

[frog_ATC]

Thanks :O

(I also looooove pipercubs & supercubs...! )

[Fuji Abound]

I am, the garlic is frying, the fat is hot, and I am looking forward to enjoying one of my favorite delicacies.

Mind you I have really enjoyed your posts.

They are really entertaining and have added to that which is PPRuNe.

You have however missed a very good opportunity to move the debate forward in a sensible but humerous way and that is a shame.

It would have been better if people took your posts seriously as well as being entertaining. :D

[frog_ATC]

Fuji, I think they did, according to those very interesting private emails I received ! So this was maybe not only entertainment, let's hope !

By the way, could you please send me the IMC rating syllabus, so that I can tell you whether it can be compared to an IR cursus or not ?

Because those IMC-rated guys I flew with had a very poor IMC flying !

(no one else to answer my quizz?)

Frog, not ashamed...

PS : Fuji, you are probably more "openminded" than expected if you eat frogs :-) Let's try snails now !
If you come to my tower, I will propose you a glass of fine sparkling water, or red wine if you do not fly after, because I think you are too nervous for a cup of coffee !

[Contacttower]

Re the IMC rating syllabus, it can be found in LASORS (the UK version of FAR/AIM) Section E:

http://www.caa.co.uk/docs/175/SECTION%20E.pdf

The description of the rating starts on page 12 and appendices A and B which describe the ground training requirements and flight test standards start on pages 20 and 22 respectively.



I would guess private IFR is harder (than the airlines at least). Single pilot IFR in light twins is about as hardcore as it gets I'd have thought.

The issue with IMC rating holders having poor skills is probably about currency more than anything else...with most airfields lacking an IAP people only go flying when the weather is good anyway and have little opportunity to practice approaches (or don't have access to FM immune equipped aircraft).

[frog_ATC]

Thanks ContactTower that's exactly what I was looking for !

The IMC Rating syllabus and flight test syllabus are excellent.
It covers a good part of the IR program, and the tolerances for the test are the same (100 feet, 0/+50 feet, 10 degrees, etc).


Why not improve it and make it a real IR, with full privileges ?

I think it is the only way to have it accepted by Europe, because the IMC rating is not compatible with airspaces abroad (other countries do not have your different levels of services in the same areas, such as "request radar information service" blablabla... That would be complicated to explain, but incorporating your IMC ratings airplanes in a controlled airspace abroad would require heavy changes in the regulation, and I think you will never get that, whereas incorporating an IFR airplane is easy to handle).


Only the 25 months validity is really too long, with no mandatory practice in between.
That's maybe the reason why those IMC-rated lose skills.
The US system is better for that : 6 months validity, and renewed automatically as long as you keep on flying regularly.

Another problem you have in UK is your horrible IFR fees and these slots you need to negociate. It's so hard to train in UK !
And practice is really important to maintain your skills.

By the way, they say :
Details of rating privileges can be found in Schedule 8
of the Air Navigation Order (please also refer to Section
A, Appendix F)
Do you have this also ?


I think your IMC rating is a good step to try to get a real european IR, with no restriction of use.

Answer to the quizz pretty soon... :-)

Frog

[frog_ATC]

Let's compare "Pro" (professionnal pilots) and "Priv" (privates on light airplanes).


When you pass your IR...
- as a Pro you are seated in the right seat of a big plane, with an experienced guy on the left seat that you call "captain"
- as a Priv you are alone the day after your rating, and have to experience everything by yourself

When you encounter icing conditions...
- as a Pro, you airplane is well equipped to fight that ice, and powered enough to climb above these icing conditions
- as a Priv, you are probably not deiced, or poorly deiced (light to moderate icing, not severe), and that TKS is so expensive...

When you fly enroute...
- as a Pro your airplane climbs at high levels where the sun is always shining, ABOVE the bad weather, and you are given great direct routes
- as a Priv your airplane is limited to low levels (because engine, pressurization, non-RVSM...) and you are most of the time IN the bad weather, with icing, turbulence, poor vis... and those damned ATC at Paris Control make your travel longer with a big deviation around Paris !

When your autopilot fails...
- As a Pro you have probably two autopilots, or a copilot
- As a Priv you'll have to control the airplane + read the chart + talk to the ATC + manage the flight (greaaat in turbulences !)

When the ATC calls you...
- As a Pro, your copilot will answer while you are busy
- As a Priv, damn it's always at the bad moment, while you're busy turning outbound, intercepting, preparing your route in the GPS, levelling the plane...

What about your currency requirements...
- As a Pro, you do not care, you do not pay for approach fees, landing fees, airplane annual or whatever... you get paid for flying ! and checked out quite often.
- As a Priv, you try to find an airport where the fee will be low enough to let you enough money to pay for your coffee... Hard to train sometimes, expensive !

What about your documentation...
- As a Pro you are given everything by your ops : approach charts, GPS update, weight and balance... you just check dates & co to make sure it's alright
- As a Priv you pay for that horribly expensive Jeppesen update, you download it on your computer or skybone, upload it in your GPS in the airplane... **** you have two GPS, no discount... And those paper charts to classify each week, drives you mad

What about weather briefing...
- As a Pro : Captain, the ops gave it to me !
- As a Priv : do it yourself, where is the ISO 0° ? How is that front ? What is the forecast? What could be my alternate ?

What about your equipement...
- As a Pro, FMS, glasscockpits, numerous radios and avionics... better than disney channel
- As a Priv, maybe you have a G1000 or an Avidyne, or maybe you have a conventional directional (no HSI), and some good old fashioned avionics...

What about flying across the Alps:
- As a Pro : and so what ?
- As a Priv : where are my canulas ? damned the Oxygen bottle is empty... I'll have to refill.

Etc. etc. etc.....


So yes, flying IFR as a private is really HARDER than commercial, in my opinion, considering only the aeronautical aspect of the thing (the commercial part, handling passengers etc. is something else).

So you can be proud when flying IFR in a small Piper, Cessna or even Malibu, because managing the flight is not so easy.


Frog

[IO540]

When you pass your IR...
- as a Pro you are seated in the right seat of a big plane, with an experienced guy on the left seat that you call "captain"
- as a Priv you are alone the day after your rating, and have to experience everything by yourselfSo? Same with a PPL. So, ban the PPL, shall we?

When you encounter icing conditions...
- as a Pro, you airplane is well equipped to fight that ice, and powered enough to climb above these icing conditions
- as a Priv, you are probably not deiced, or poorly deiced (light to moderate icing, not severe), and that TKS is so expensive...Having the money to spend on a $500k plane is nothing to do with pilot privileges. You could have a debate on legislating for a minimum standard of aircraft, but I think most would strongly disagree.

When you fly enroute...
- as a Pro your airplane climbs at high levels where the sun is always shining, ABOVE the bad weather, and you are given great direct routes
- as a Priv your airplane is limited to low levels (because engine, pressurization, non-RVSM...) and you are most of the time IN the bad weather, with icing, turbulence, poor vis... and those damned ATC at Paris Control make your travel longer with a big deviation around Paris !Having the money to spend on a $500k plane is nothing to do with pilot privileges. You could have a debate on legislating for a minimum standard of aircraft, but I think most would strongly disagree.

Also I don't think you have ever flown in a decent IFR tourer, like the French made TB20/TB21 which (the 21) can get to FL250 - above nearly all weather except CBs. I fly a TB20 and FL190 is not a problem.

RVSM applies only above FL290. Hardly "GA" territory, short of a TBM850.

The "deviation around Paris" is taken care of with the Eurocontrol routing. Again, I don't think you have thus flown in Europe, otherwise you would know how this works. The routings accepted by the computer take you well away from the busy terminal areas. On a typical long flight across Europe, say 800nm, you may just about get visual with some heavy jets in the far distance.

When your autopilot fails...
- As a Pro you have probably two autopilots, or a copilot
- As a Priv you'll have to control the airplane + read the chart + talk to the ATC + manage the flight (greaaat in turbulences !)The workload goes up. Not a problem. Read the chart???????? Do you really fly IFR????? You have an IFR GPS - mandatory for FL095+ in Europe (look up BRNAV requirements).

When the ATC calls you...
- As a Pro, your copilot will answer while you are busy
- As a Priv, damn it's always at the bad moment, while you're busy turning outbound, intercepting, preparing your route in the GPS, levelling the plane...The radio workload in airways is generally low.

What about your currency requirements...
- As a Pro, you do not care, you do not pay for approach fees, landing fees, airplane annual or whatever... you get paid for flying ! and checked out quite often.
- As a Priv, you try to find an airport where the fee will be low enough to let you enough money to pay for your coffee... Hard to train sometimes, expensive !Comment as above re legislating for pilot budget.

What about your documentation...
- As a Pro you are given everything by your ops : approach charts, GPS update, weight and balance... you just check dates & co to make sure it's alright
- As a Priv you pay for that horribly expensive Jeppesen update, you download it on your computer or skybone, upload it in your GPS in the airplane... **** you have two GPS, no discount... And those paper charts to classify each week, drives you madComment as above. You can get free plates for most of Europe from Eurocontrol. Most weather is free on the internet. File flight plans online via Homebriefing for Euro 37/year. No big deal. And most IFR pilots have a friend (often an airline pilot) who has Jeppview and can get them all the approach plates in the world.

No real IFR pilot buys paper plates anymore. It takes hours to put the new ones in. Use Jeppview and print off those you need.

What about weather briefing...
- As a Pro : Captain, the ops gave it to me !
- As a Priv : do it yourself, where is the ISO 0° ? How is that front ? What is the forecast? What could be my alternate ?See above.

What about your equipement...
- As a Pro, FMS, glasscockpits, numerous radios and avionics... better than disney channel
- As a Priv, maybe you have a G1000 or an Avidyne, or maybe you have a conventional directional (no HSI), and some good old fashioned avionics...You have more kit than a 747 would have had 20 years ago, and better than most 3rd world jets landing at Heathrow (or Paris) this morning.

What about flying across the Alps:
- As a Pro : and so what ?
- As a Priv : where are my canulas ? damned the Oxygen bottle is empty... I'll have to refill.You think people that fly like that (as I do, over the Alps, on oxygen, and with a big bottle in my garage to refill from) are STUPID?????????????

Etc. etc. etc.....Indeed. You need to make your points more rationally.

So yes, flying IFR as a private is really HARDER than commercial, in my opinion, considering only the aeronautical aspect of the thing (the commercial part, handling passengers etc. is something else).True. But relevant to exactly what? Only 2-pilot jets should be allowed to fly IFR??

So you can be proud when flying IFR in a small Piper, Cessna or even Malibu, because managing the flight is not so easy.

True. It's called FREEDOM. Even the French should understand that word ;)

[Fuji Abound]

Frog

Fun and games aside you do us all a great dis-service.

You insult the French by pretending to be French and by parodying them in a style reminiscent of Hello Hello,

and you trivialise an important debate.

It is no surprise that EASA and the CAA think most of the GA organisations are a bunch of amateurs that cannot be taken serioulsy.

Shame on you!

You have a few, very few posters who reply. It is not a debate, it is engaging the few of us that care and are unhappy that you should represent the professional guys involved in ATC in this way.

If you existed you had a professional forum only last week at which to present your views and which you could have readily attended.

Please give it a rest now!!

[frog_ATC]

The explanation above was done only to explain that flying IFR as a private is harder than as a Pro, and my conclusion is that Private Pilots do not to have feel ashamed or less competent than professionnals.

My opinon is that we have the right to fly in the same sky as them, whatever they may think.

Have you only read what I write ?
Are you only able to understand it ?

Some other pilots did, and I hope I'll meet them quite soon as we planned.

I've spent more than one hour yesterday reading the IMC rating syllabus, which appears excellent to me, as I said.

But it seems like you are completely unable to understand what I say, and are really aggressive while I'm not.

So... Shame on you !

You should be more openminded and able to discuss ideas without this non-respect that seems to be quite common for you, and have respect for someone else ' s opinion and experience.
May I remember you I'm a professional in Aviation, as Pilot as well as ATC.

I suppose you are not instrument rated, Fuji, and I hope you won't try to because your violence does not cope with the required attitude in a cockpit.

I think you should apologize for your attitude, both IO and Fuji, and your bad comments on the fact that I am French, but I am not sure you are able to do so !

You won't help the IMC rating, nor any fight, with such a comportment.

Frog

[Fuji Abound]

Froggy

We have an organisation here called AOPA, if you were French you would be familiar with AOPA in France.

Martin Robinson who is in charge of AOPA in the UK wants the IMC rating expanded throughout Europe and has told EASA this is AOPA UKs policy.

So far as AOPA are concerned the IMC rating is coming to Europe.

You might like to write to him as I am sure he will be very interested in your views.

[frog_ATC]

I'm already in both AOPA France and US, and I explained above my opinion on how to improve the IMC rating (after having read the IMC syllabus) in order to create a European Private IR.

But you are too agressive to be able to understand what I say !

Frog

[Fuji Abound]

Aggressive - no, just rather disappointed.

One of my best friends is a Professor of English. He spent many years at the Sorbonne researching the teaching of French - English. He is French - or at least his Mum is English and his Dad French.

Years of experience enable you to identify someone who is not what they pretend to be - and you are not what you pretend to be.

Moreover in spite of your poor English, there are many give aways in your posts that you are not involved with AT.

So I think you are at best just as mad as a box of frogs. :D :D :D

Thats my lot on this thread my friend.

The only further contributions from me will to be remind everyone that you are not what you would wish us to think and it is that which makes it impossible to have a debate with you. :=

(I am off to the Rugby now, France sadly just missed out on the Ellis cup :D, but it is England and Wales today)

[frog_ATC]

My poor Fuji...

I am what I "pretend" to be, I do not need to pretend anything else than what I am, and Broomstick will soon have a confirmation of that.
+ anybody can contact me via private mail to have confirmation.

Whatever, I think your "instinct" needs improvement, and your behaviour also, dear "Sherlock Holmes"....

What's your telephone number, Sherlock ?
Do you want to hear the frequency direct from the tower, to prove you that you need maybe some psychological help ?

Or maybe that's the only way you find to destroy what I say, which proves you have very poor arguments !

Frog

[Fuji Abound]

OK, OK you are what you are.

The end.

[Contacttower]

I'm already in both AOPA France and US, and I explained above my opinion on how to improve the IMC rating (after having read the IMC syllabus) in order to create a European Private IR.



Fuij I think you are being rather unfair on frog...no one on this forum has to "prove" who they are and actually considering we are trying to convince the rest of Europe over the IMC rating she deserves a fair hearing (OK you think she is a fake...but I hadn't picked up on that and I don't think we should judge like that).

I posted the link to LASORS and actually despite what she said before frog had the good grace to read it and actually seems to have changed her tune a bit on this...


I've spent more than one hour yesterday reading the IMC rating syllabus, which appears excellent to me, as I said.

[BEagle]

There are a number of issues with instrument flying. Here are some of them:

1. The ability to fly the aeroplane without external references.
2. The ability to navigate and communicate whilst flying without external references.
3. The ability to comply with specific routes and approach procedures.

The first issue is the most essential and often the difficult to assimilate. Which is why this core skill must be attained before any navigation or communication is attempted.

The specific requirements in issue 2 vary for pilots who simply need to fly up through cloud to VMC-on-top and those who need to fly long enroute sectors without the luxury of choice between IMC or VMC. Hence 'proportional' (that much used eurocratic term) levels of training are appropriate.

Pilots who need to fly SIDs, IFR routes and STARs, culminating in CATIII approaches require more training than those who only need radar vectors to an approach with a 4-600 ft DH/MDH. Hence proportional training is again appropriate.

When I learned to fly, I was required to hold a 'Basic Instrument Flying Grading' with about 30 hours total time on the aeroplane - a single engined jet. Then to fly radio navigation exercises (single pilot, no autopilot) with only DF and a very primitive short range DME system with which to navigate. A month later came the 'Advanced Instrument Flying Grading' which included the privilege of flying to lower approach criteria.

This utter drivel about needing 2 pilots, a whole number of autopilots and lots of toys to fly under IFR is rubbish. Just think - the military teach youngsters to fly in formation in IMC. And if the wingman loses sight of the leader, he/she has to follow the lost leader procedure and immediately transfer to instrument flying. With no co-piglet or autopilot to help.

Early RNAV such as the KNS80 made creating your own 'airway' routes relatively simple if you knew how to use it. Early non-IFR GPS did the same, but with much greater accuracy. Modern integrated GPS makes flying anywhere in a light single very much easier.

Ironically, it has not been unknown for airline captains with years of multi-pilot time to fail the IMC Rating Test! The skill sets required to fly limited panel unusual attitude recoveries and to cope with a steam-driven DI on an NDB approach are different to those needed to watch a people-tube flying itself down the approach.

Those who dismiss the IMCR through ignorance of the training and privileges conferred by the Rating are not worthy of debate. However, if the naysayers can make clear what their precise concerns are, those can be reasonably addressed by the EASA group working towards the EU solution. As we have seen, when people such as notre amie la Grenouillette actually take the time to read the IMC training syllabus requirements - and the contents of the Skill Test - some of the more illogical prejudices can disappear.

Of course it goes without saying that anyone flying throughout Europe under IFR will need at least ICAO 4 level English..... I was once waiting for an IR-holding German GA pilot to fly into a UK airport in IMC and was listening out on an airband radio so that I could advise my colleagues when he was due to arrive. He was barely able to communicate with ATC, let alone follow their vectors to the localiser. So I think if there's anything which is going to reduce the number of problems in EU airspace, it's the requirement to hold at least ICAO Level 4 English.

So, the people-tube drivers with their autopilots, TCAS and superior instrumentation will not only be able to see any possible conflict, thanks to Mode C and eventually Mode S, but know that the 'amateur' flying his light aeroplane has been trained and tested properly- and can make himself understood to ATC!

Interestingly, I find the 'playstation generation' are quite good at flying procedural approaches, but when it comes to maintaining situational awareness and air picture with a diverse approach (such as radar vectors to the localiser), they find things more difficult. Whereas those brought up on radar to SRA/GCA approaches can often maintain better situational awareness even without any radio navigation aids!

Vive le RosbIF IMCR!!

[rustle]

Wise words, Contacttower.

Many posters would be surprised at the attitude shown on this thread by FA and it exposes an interesting HF element.

frog_ATC thank you for taking the time and trouble to read LASORS (not the most user-friendly document with its myriad references to other documents) and I hope it has allowed you to understand our IMC rating a little better. :ok:

[homeguard]

I also regret the Fuji outburst onto Frog. She gave her honest opinion very succinctly. She has a right to her view and appears to be open to reason.

So Fuji please let us debate the IMC vs IR issue and we should all keep away from personal attacks.

Beagle has summed up very clearly in his last post. Further posts should now encourage a much better debate.

[Fuji Abound]

Fuij I think you are being rather unfair on frog...no one on this forum has to "prove" who they are and actually considering we are trying to convince the rest of Europe over the IMC rating she deserves a fair hearing (OK you think she is a fake...but I hadn't picked up on that and I don't think we should judge like that).

Perhaps.

However, having a debate with someone who is not representative of the view of air traffic controllers in France, is disingenuous to these very professional people.

There are very few people on here who are not what they are. I know a few of them. I know the qualifications they claim to have or the positions they claim to hold and I also know they are not telling the truth. I know that one of the regular contributors on here posts under a least two pseudonyms and you would think they are different people.

You must make your own judgement.

However, you will note the link to Frogs aircraft that was for sale has quickly been removed, and you will note that he has not answered any of the questions about what he does and where he is based.

I am suspicious of anyone professional who feels it necessary to go about their business in this way. If they had official blessing for what they have to say then there would be no reason for secrecy and if they do not then they are probably a maverick at best, and certainly not representative of the majority view.

This business is about finding a consensus. There will always be a few who have another agenda.

Personally, I have no issue with anyone who is opposed to the IMC rating IF they are transparent.

If Froggy cares to be transparent then lets debate.

Look at the history of this issue. Look at the rumors that have been spread and are wrong. Consider for a moment what certain people have said on here - and they were wrong.

[frog_ATC]

I just wait for your telephone number, "Sherlock Holmes".

Anyone has the right not to widespread personal life online, especially when you know that in France, ATCs are governemental agents, which means they are not free to give there opinion in public without agreement of their superior (whereas your ATC in UK are part of private companies).

But I already answered by email to several persons, and hope to meet them soon. Some already know me, I recognized one or two UK pilots I know on other topics.

But I think it is useless to debate with you, you'll always find a way to justify yourself, and keep that agressive attitude.

Frog

[dublinpilot]

Frog,

I answered your question....how about answering mine? ;)

Now, to continue the debate

As I understand you, you would be willing to accept an EASA IMCr which had similar flight training requirements to a JAA IR, but with significantly reduced ground school (it's already sounding like your FAA IR)

Now one significant requirement of a JAA IR is 50 hours training (SEP). Lets take that one for a minute. The FAA one has a lower number of hours....IO540 says it's only 15 hours dual training.

How about saying, to get an EASA IMCr (which is an EASA Private IR in all but name....we could even agree to call it an EASA Private IR if it would make you more agreeable ) you don't need any dual training....you just need to be able to fly to the standard required for the test. The examiner can, and should, throw everything and anything at you during the test to make sure that your flying is up to the benchmark.

Doesn't that make sense....after all, why should holder of a foreign IR who has thousands of hours flying IFR in IMC who could pass the flight test without any further training, have do do 50 hours training before taking the test? The test should be the standard, not the number of hours training.

Can we agree that much?

Also can you clarify the position with French residents being able to fly in France on a FAA IR? I read here sometime ago, that the Franch authorities has banned the use of an FAA IR by French residents in French airspace. Is that true?

dp

[Fuji Abound]

Anyone has the right not to widespread personal life online, especially when you know that in France, ATCs are governemental agents, which means they are not free to give there opinion in public without agreement of their superior (whereas your ATC in UK are part of private companies).

Hmm, well you see there is another issue.

You represent yourself as an ATC in France and express an opinion to which you seek to give credibility by virtue of your profession BUT you go behind the backs of your professional colleagues.

Of course a true professional, if he had the concerns you have, would have gone about matters another way.

Moreover, if you are not free to give the views you are, but you have told certain people you are who you are, then there would seem a rather glaring contradiction.

Anyone on top of everything else I am bored with this now.

[frog_ATC]

No that's wrong, you can fly FAA IFR in France.
It's funny because I had read that the Brit had done so in class A :)
(which is also wrong apparently)

About your question : which question ?

Frog

PS : my poor Fuji....

[dublinpilot]

The one I repeated above.....

[llanfairpg]

Reading the above, its frightening to think some of you are representing the interests of UK pilots.

[frog_ATC]

OK !

Training required for FAA IR is 40 hours IMC, including at least 15 dual, and max 10/20 ground trainer, and a cross country 250NM (check FAR Part 61).
For JAA IR, it is now 50 for single, check JAR FCL :

FLYING TRAINING
9 A single-engine IR(A) course shall comprise at least 50 hours instrument time under instruction of which up to 20 hours may be instrument ground time in a FNPT I, or up to 35 hours in a flight simulator or FNPT II With the agreement of the approving Authority not more than 10 hours of FNPT II or flight simulator instrument ground time may be conducted in a FNPT I.
10 A multi-engine IR(A) course shall comprise at least 55 hours instrument time under instruction of which up to 25 hours may be instrument ground time in a FNPT I, or up to 40 hours in a flight simulator or FNPT II. With the agreement of the approving Authority not more than 10 hours of FNPT II or flight simulator instrument ground time may be conducted in a FNPT I. The remaining instrument flight instruction shall include at least 15 hours in multi-engine aeroplanes.

But whatever your logbook, you'll be endorsed for the checkride only when ready, we all agree about that.
And the number of hours is not the only parameter : the duration of the training (intensive or not), the efficiency of the instructor, the complexity of the airplane, the training environment, the student him/herself....

I do not make rules, I just apply them.
Whatever, I think 40 IMC is more or less a good guess, some pilots require less, some more.


Frog

[dublinpilot]

But why have any minimum number of hours? Isn't the test what's needed to check if someone has reached the standard, and not the number of hours flown?

[IO540]

Indeed; it should be competence based. I actually don't think this is the #1 political issue, anyway.

The FAA IR has 15hrs min dual training, which is as close to "competence based" as one will get, since it is absolutely impossible to reach the checkride standard in that time.

This is good because there is implicit acceptance of previous instrument training.

So, e.g. a UK IMCR holder who is good and current and has a lot of his own IFR time, can go to the USA and finish the FAA IR with say another 20hrs' flight training. Very efficient.

I think a new EASA IR will also have something along these lines, but the latest I know is that it is 1-2 years away.

In the meantime, the best "upgrade route" is the FAA IR and then come back to Europe, go to Switzerland, and do the JAA IR which in Switzerland requires zero flight training if you already hold an ICAO IR. In the UK you have to do 15hrs which isn't bad either - a week's flying and a chance to suss out what the examiner will be looking for, from the instructor who knows him ;)

[BEagle]

15 hours at £150 per hour is well out of reach of the average UK IMCR holder who does not have any need for full IR privileges.

By the time you add travel and subsistence, plus a test with a CAA Staff Examiner, I can't see there being any change out of £3000.....

When I did my first military Preliminary Instrument Flying Grading, I had all of 12 hours TOTAL IF time. The test involved full and partial panel flying, plus an 'ACR7' surveillance radar approach into RAF Andover in a Chipmunk with a floor mounted compass!

Why this CAA/JAA/EASA obsession with total training time?

Even when I flew the Gnat, I only did 6 hours IF in it before taking the IRT (which was VERY demanding! I was utterly amazed that I'd passed). I had to do a navigation exercise to Pershore at around 350KIAS, a TAC/ILS approach then back to Valley for a QGH to GCA, touch and go then a short pattern GCA to land. Total 1:10, of which 1:05 was IF - with all of 6 hrs IF time on the aeroplane plus another hour in the primitive simulator.

I can say from a background of IF in everything from that Chipmunk to being a VC10 IRE, with IRs on various military fighter, trainer, bomber and transport aircraft as well as being a strong advocate of the UK IMCR that the UK IMCR most certainly gives the average GA/PPL holder (except for those who wish to fly long distances on airways) everything he/she really needs for safe IMC flight. Fortunately, many of the more senior people in the CAA agree with me.

[IO540]

15 hours at £150 per hour is well out of reach of the average UK IMCR holder who does not have any need for full IR privileges.

In that context, I agree. It would be totally daft to expect any significant % of UK IMCR holders to do anything resembling the full IR. Most of them non-owners just want basic privileges for a rental spamcan.

[englishal]

Reading the above, its frightening to think some of you are representing the interests of UK pilots.
What is really frightening is that some people on here are supposedly commercial pilots and ATC;)

I'm with Fuji, I think I was suckered in. One thing I have learned about Pprune is often not everything is as it appears. I know for a fact that some regular contributors who like to stir things, don't even fly any more, or certainly rarely!.....I call that sh*t stiring. Anyway, it doesn't bother me, we know who they are......;)

[dublinpilot]

I'm with Fuji, I think I was suckered in.

I agree too.....but if Frog is who I'm guessing they actually are, then they are in a far more constructive mood in their Frog persona than their regular one, and I planned to use that ;)

[frog_ATC]

IO540 will now confirm that I am what I said I am, he had a special ATIS recorded only for him.

But I'm disappointed to see the attitude of some of you.
You should be ashamed of that, and no one should have to justify to be what he is.

And you, who are you ?
Do you think that posting thousands of messages proves anything about you ?
I've seen liars that lasted for years, even in airclubs, fake CFI etc.

Sherlock Holmes probably knows thousands of ATCs, to be able to recognize a fake one just with some online messages. Great job boy !
But maybe some lessons about respect could be good for you.

If you do not want other people's advice, do what you want !
I do not care your IMC rating, I'm IR so I do not need it. :-)

The only thing that is important for me, is safety for all pilots, and freedom for general aviation.

And I know that your "IMC rating" as it is today is not compatible with most european countries' airspaces, so if you are not able to discuss it to find a solution you will just lose it.

Bad luck !


Frog

[rustle]

IO540 will now confirm that I am what I said I am, he had a special ATIS recorded only for him.

But I'm disappointed to see the attitude of some of you.
You should be ashamed of that, and no one should have to justify to be what he is.

As no-one else from this side of the channel will bother, please accept our apologies for their rudeness: Not all English people are as rude as some are demonstrating in this thread. :ugh:

For the record it is good to know that people on your side (of the radio and the channel) are interested in this issue as well ;)

[frog_ATC]

Thanks Rustle that's very nice, I do appreciate.

Frog

[homeguard]

Keep participating Frog.

Unfortunately some can't help but be rude when anonymous. It is the desease of the ignorant to be offensive and make claims that the opposition are frauds. Usually the same wouldn't have the balls to say the same to ones face.

To qoute Bernard Shaw. "the last act of the scoundrel when losing an argument is to fall back on their respectability".

Anyway, back to the IMC vs IR .................!

[IFollowRailways]

How much easier it is to be critical than to be correct.
- Benjamin Disraeli (http://www.quotationspage.com/quote/33255.html)

[Contacttower]

Frog why don't you just tell us which airport/zone you control?...It would stop some of the rudeness and convince others that you are who you say you are (not that I need convincing :)).

BTW I was slightly disappointed that you didn't take up Fuji's offer to post in French, I used to be quite good at French (lived in Luxembourg for 5 years a while ago) and it would be interesting for me to see how much I could understand still.


The points about the IMC rating you raised, the 25 month validity period and the problem with airspace in Europe are things that would have to change for it to be Europe wide (I think 25 months is too long, although I suppose the thinking is that much less would discourage people from doing it in the first place) and the airspace...well is for people like you to think about...

[frog_ATC]

Chèr(e) Contacttower,

Je t'ai écrit tout celà par email privé, comme je l'ai fait pour tout ceux qui me l'ont demandé.

Et quoi qu'il en soit, je ne suis pas convaincue que le fait de prouver qui je suis changera quoi que ce soit à la stupidité de ceux qui n'ont que l'insulte comme argument.

Alors laissons-les dans leur bêtise !

La grenouille à micro

[englishal]

As no-one else from this side of the channel will bother, please accept our apologies for their rudeness: Not all English people are as rude as some are demonstrating in this thread.

For the record it is good to know that people on your side (of the radio and the channel) are interested in this issue as well

:}:}:ok:

I humbly apologise if I was in any way rude. I just have much experience of Pprune and some of the morons who post here - lying about what they get up to yet preach to you..etc......you know what I mean. I respect you though Mme grenouille as you stand up for the FAA of which I am a great supporter.

Thank you Madame grenouille ;)

[Contacttower]

Merci beaucoup frog_ATC. :ok:

Bonne chance pour le ATPL!

[dublinpilot]

Frog,

Why do you keep ignoring my question about minimum hours? I answerd your question :)

[frog_ATC]

But I did answer your question ?

If I did not, maybe you can rephrase it so that I understand it better.

Frog

PS : Merci Contacttower :-)

[IO540]

I am sure frog_ATC is a real person, even if I didn't spot anything unusual about the ATIS (could not make it out too clearly on the phone connection).

Let's keep this debate totally rational, shall we?

[englishal]

I agree.....:ok:

[mm_flynn]

I would suggest that re-reading the thread (ignoring the sniping) gives some indication on how the IMCr is emotionally perceived (Frog's first post) and how after explaining to someone who actually wants to listen (with a surprising amount of patience and tolerance on Frog's part) they can see the merit at least to the extent of saying the syllabus is a pretty good basis for a more rational IR.

A couple of views I have formed from the debate
1 - It will be impossible to have an IR that does not have some minimum amount of training - every other rating has a minimum number. However, 15-20 hours minimum training for a PPL seeking to add instrument capability seems reasonable (they have no real chance of requiring less)

2 - A big part of the UK IR problem is that there are very few places to be taught and I suspect they have to pay big fees to the CAA. If the same organisations that can do PPL, night, IMCr, multi, etc. could do IR this would be a big step in accessibility and cost containment.

3 - The exam process (once every couple of months, at Gatwick, with mandatory classroom training) is a problem. Along with the size of the pile of information required to be stuffed into your head.

4 - The IMCr as it stands (note I have never done the course just got mine off my FAA/IR) don't cover the full scope of flying needed for international and TMA flying - so there probably would need to be a transition training module (but pretty limited in mandatory time as the bits that are missing are not rocket science)

5 - If there is going to be a modular approach we need some real clear thinking (that I have not yet seen articulated) on what specific privileges the IR module 1 holder (i.e. current UK IMCr type of rating).

A structure like
Module 1 -
Privileges - IMCr landing viz and the recommended minima being obligatory, no access to air carrier airports under IFR, limited to 5000 AGL.

Requirements - basically the IMCr syllabus, 15 hours minimum training, maybe an IFR MET, basic nav, IFR human factors, IFR airlaw knowledge requirement with an FAA style computerised test system (i.e. cheap, reliable and convenient)

The objective of this is to allow basic capabilities of a stepping stone for popping through a layer and hacking about low level (ie. like many people use the IMCr for)

Module 2 -
Privileges - non-commercial IFR, world wide, all airspace, all airports (i.e. and IR).

Requirements - Module 1 + 5 hours minimum adding in SIDS/STARS, more emergency procedures, filing and planning international and RNAV routes, a long distance airways flight, maybe an expanded IFR MET, IFR systems, expanded IFR airlaw knowledge requirement with an FAA style computerised test system (i.e. cheap, reliable and convenient)

The objective of this is to allow people who have achieved module 1 to easily move on to a full IR. Logically there would be an integrated version where you did it all at once as well.


This could give a basis to convince our European colleagues that the IMCr (IR module 1) is safe and a solid knowledge base, provide a grandfathering position (which some of us will not like because it is a step back from the IMCr, but a step forward in its international scope) and a sensible and cost effective migration to a full and appropriate IR.

[BEagle]

This is my proposal - it would require 20 hrs training plus the Skill Test:

EASA CLASS 2 INSTRUMENT RATING PROPOSAL

EASA Class 2 IR to enable pilots of light aeroplanes to cope safely with non-VMC weather in EU airspace without the requirement to hold a full IR.

Privileges:

1.0 To fly IMC/IFR in permitted EU airspace.

1.1 To navigate the aircraft by sole reference to instruments under circumstances which require mandatory compliance with defined routes.

1.2 To fly instrument approach procedures for which they have logbook endorsements to instrument approach minima +200ft for precision approach and +250ft for non-precision approach.

Specific Exclusions:

2.1 No multi-pilot Class 2 IR – multi-pilot ratings must include a full IR by default, as is current JAA practice.

2.2 No CAT II/IIIa/IIIb/IIIc approaches permitted.

Training:

3.1 At least 10 hours Basic Instrument Flight Module, common to the modular IR training.

3.2 At least 10 hours procedural instrument flight training, to consist of:

Module 1: 4 hours training in take-off, departure, en-route navigation and holding.

3.3 Any 2 of the following 4 modules (Modules 2-5):

Module 2: 3 hours training in precision approaches with pilot-interpreted guidance.

Module 3: 3 hours training in non-precision approaches with pilot-interpreted guidance in azimuth only.

Module 4: 3 hours training in precision or non-precision radar approaches, with guidance provided by an external controller.

Module 5: 3 hours training in approved RNAV/GNSS approaches.

3.4 All instrument approach flight training modules shall include:

3.4.1 Missed approach and go-around training.

3.4.2 Visual circuit flying under simulated conditions of low cloud and reduced visibility (600 ft cloudbase and 1800m horizontal in-flight visibility).

3.5 Additional training will be required if the test is to be undertaken in a multi-engine aircraft:

Module 6: 4 hours training in one-engine inoperative procedures relevant to all phases of flight (take-off, departure, en-route, approach and missed approach).

3.6 Training to be conducted:

3.6.1. By either:

3.6.1.1. A FI authorised under JAR-FCL or EASA-FCL whose privileges include instruction in applied instrument flying; or

3.6.1.2 An IRI authorised under JAR-FCL or EASA-FCL

3.6.2. At an RF or FTO

3.6.3 In suitably equipped aeroplanes or, as specified in para 3.7., an FNPT2 or FFS.

3.7. Of the required hours procedural instrument flight training, the following synthetic training may be conducted in FNPT 2 or FFS:

3.7.1. 2 of the 4 hours of Module 1; and

3.7.2. 2 of the 6 hours of Modules 2-5

Skill Test:

4.1 Skill Test shall be conducted by a FE or IRE authorised under JAR-FCL or EASA-FCL to include:

4.1.1. Full Panel Instrument Flying.

4.1.2. Limited (or Partial) Panel Instrument Flying.

4.1.3. Use of radio navigation aids for position fixing and en-route navigation.

4.1.4. Let down and approach procedures, to include one precision and one non-precision approach, of which at least one shall be pilot-interpreted and of which at least one shall be concluded by a missed approach and go-around.

4.1.5. Bad weather circuit.

4.1.6. Flight with asymmetric thrust (multi-engined aircraft only).


Language Proficiency:

5.1 Applicants for the EASA Class 2 IR shall hold at least ICAO Level 4 English Language proficiency.


UK IMCR holders would migrate to this scheme by passing the Skill Test and an oral examination at their next revalidation.

[Contacttower]

And how long should it be valid for BEagle?

[IO540]

mm_flynn

A couple of views I have formed from the debate 1 - It will be impossible to have an IR that does not have some minimum amount of training - every other rating has a minimum number.

Agreed - this is also politically unavoidable. I would pick the FAA's 15hrs - this is sure to get gold plated to 20-25hrs using the absolutely inevitable "European process" but that is still OK for an ab initio IR.

A big part of the UK IR problem is that there are very few places to be taught and I suspect they have to pay big fees to the CAA. If the same organisations that can do PPL, night, IMCr, multi, etc. could do IR this would be a big step in accessibility and cost containment.

This, and the other stuff you list, has been more eloquently described by others as "death by a thousand cuts". It's certainly true that historically the huge size of the JAA ground school has driven a lot of the usual private IR candidates (older pilots; usually in their 50s+) to the US route, and also things like the JAA audiogram, but it is probably the collective effect of these various smaller factors that has been the killer. Also, the latest indications are that by the time EASA gets stuck into FCL, say 2010, the private IR ground school will be much reduced.

Beagle

Your proposal is good IMHO but "1.0 To fly IMC/IFR in permitted EU airspace" is the gotcha whose detail will make the difference between the "Europeans" accepting it on one hand, and going totally berserk on the other. This bit needs to be worked out. I am doing a little airspace study. Never received your email BTW.

[BEagle]

Contacttower: 24 months - same as for SEP Class Rating so that both could be conveniently revalidated during the same LPC.

Revalidation by Test only.

IO540 - the problem is that different EU nations have different airspace regulations. What is lawful in one may not be so in another. I suspect some of the rules are left over from the Cold War - so that intercepting, identifying and reporting off-airways aircraft would less difficult, perhaps? So it'd have to be up to the individual authorities to decide in which airspace a Class 2 IR would be 'permitted'.

I don't know why you didn't receive my e-mails - they went to the addresses you gave me!

[englishal]

I think the IR should be split into a "private" IR and "commercial" IR....and my suggestion would be:

Private IR

Cannot be used for public transport operations but exemptions given for Airwork and Instructors.
Can be used in all airspace as per current IR


25 hours of IMC experience including a minimum of 10 hrs training with a Instructor
A 200nm cross country route by air traffic control directed routings (i.e. airways)
One exam paper covering MET, Navigation and Procedures
A flight test with similar tolerances to the FAA IR


Commerical IR

Can be used for private, comemrical or Public Transport ops
Can be used in all airspace


45 hours IMC experience including a minimum of 15 hours with an Instructor
A 200nm cross country route by air traffic control directed routings (i.e. airways)

Two exam papers, one covering IFR procedures and Navigation and one covering Met for public transport operations
A flight test with similar tolerances to the JAA IR


OR


The holder already holds a Private IR
45 hours total instrument time including a minimum of 5 hours dual
cross country not required
One exam paper - Met for PT ops
Flight test with similar tolerances to JAA IR


Also to add ME privileges to either:


The initial test may be carried out in a ME aeroplane
A further reduced test may be carried out in a ME aeroplane (shorter nav elements for example)
A ME IR automatically confers SE privileges


24 month currency period as long as say a certain number of approaches are shot in the first 12 months, after which an IPC is required by an IRI (not: not examiner). If the certain number of approaches are not met, a revalidation test can be done with an examiner (every 12 months if wished).

[mm_flynn]

The reason my module 1 was fairly limited is that I perceive there are a large group of UK IMCr pilots who don't actually want or need a 'real' IR but would like something to make modest IMC legal and safe (situations where there is a thin layer at 1000-2500 and being on top would be a lot safer and easier than slogging underneath. I tried to spec the restrictions so that they would make reasonable sense in any of the European airspace systems (in that they are similar to the practical restrictions on the current IMCr). This group seems to have a view they want the basic limited IMCr and don't want to have to do anything else (or would not have been inspired to do even EnglishAl's private IR).

If this is a significant constituency, then it would be ideal that any future IR has a module which is similar to this and current IMCr holders can be grandfathered into. I struggle to believe we will get any traction in an IMCr converting to even a private IR (but that is just my view)

[homeguard]

The IMCr has no need to be a 'poor mans' IR.

BEagle has outlined a very clear syllabus and standard for the EU IMCr. I see no need to water down an IR or treat the IMCr as a module. For those who can go back prior to 1999 (the onset of JAA) the UK credited 10 hours, for those who held a valid IMCr, towards the IR.

Again to qoute BEagle with regard to those wishing to hold an IMCr, they do so to satisfy their personal needs as far as it goes. They are able to do the course 7 days a week at their club at times that they can. Not easy to find an approved course operating ar weekends. They can also sit the exam and be tested at their club, allowing flexibility.

The IR requires many elements not required by a vast number of PPLs and this accounts for much of the additional hours within the IR syllabus and the testing content. The IMCr should/does satisfy civil concerns for the specific privileges it confers. The safety statistics over 35 years establishes that fact.

Whilst the particular EU bodies who are reticent to accept the IR need to be brought round by persuasive argument we must just the same hold a firm line and believe in what we have. Should those against an EU IMCr not be persuaded of the need, then they must understand that the UK will not just roll over. Persuasion must be the best way but you don't win a difficult argument going at it half-cock.

An increasing number of the Fleet Managers, Training Captains and flight crews within the UK are self improvers (the airlines train very few pilots nowadays). They likely held an IMCr in the past and understand it. Many will still instruct at club level and be very much up to speed on current club flying. Strong support from BALPA and the airline associations will help our cause a lot should they be so minded. The advanced skills and knowledge of IMCr PPLs is in their interest.

With regard to airspace. The UK has had a long tradition of preserving airspace for all. Generally the Controlled airspace in the UK must be fully justified. It would appear that within much of the EU controlled airspace is given willy nilly. Too often it is established for the odd commuter flight which maybe departs in the morning and returns late afternoon. The idea that an IMCr holder cannot use their privileges at an airport used by an airline, with respect, is daft. Where an airport is busy with heavies the landing fees and the availibilty of slots normally do the trick. The whole point of the IMCr is not only to make the pilot and their passengers safer but also all those around them, including airliners.

We are a country of 60 million with the most congested airspace in the world. Things work here with little or no objection to the IMCr, who then can have an excuse to resist the IMCr. The IMCr exists and the onus must be on those who oppose it to justify themselves. No one in a free world should be allowed to take something away without good evidential reasoning. I've yet to hear any opposition that is supported by fact.

EASA/EU, if all cannot be persuaded, should approve an IMCr but allow each state freedom to adopt it or not

[ThePirateKing]

BEagle,

Great idea.

Would you mind if I proposed one addition:

1.3 The above priviledges can be exercised by holders of an ICAO Class II medical

(It's the colour vision thing again, you see...)

TPK:ok:

[mm_flynn]

BEagle has outlined a very clear syllabus and standard for the EU IMCr. I see no need to water down an IR or treat the IMCr as a module. ... The IR requires many elements not required by a vast number of PPLs and this accounts for much of the additional hours within the IR syllabus and the testing content. The IMCr should/does satisfy civil concerns for the specific privileges it confers. The safety statistics over 35 years establishes that fact.
The syllabus is reasonable, it is the privliges and scope which need working on in a European context. The IR doesn't have that much more technical content than the IMCr and leaving aside the gold plating of the JAA IR, the knowledge and flying requirements of an IR seem reasonable for planning airways routed IFR - which is all that will ever be available in the rest of the world.

There is a fundamental problem that the IR is currently gold plated. A more appropriate IR is critical for a whole range or reasons. This is not the same as a watered down IR.

Whilst the particular EU bodies who are reticent to accept the IR need to be brought round by persuasive argument we must just the same hold a firm line and believe in what we have. Should those against an EU IMCr not be persuaded of the need, then they must understand that the UK will not just roll over. Persuasion must be the best way but you don't win a difficult argument going at it half-cock.

There are four strategies we can pursue

Fight to keep a separate IMCr just like it is today with no chance of extending it to Europe (i.e. a status quo opt out)
Try for a more sensible IR (which is unlikely to have lower requirements than the FAA IR)(but still pursuing the other strategies)
Try to morph the IMCr into something which could work in the rest of Europe
Create a two tier IR with a tier similar to the current IMCr and a sensible set of requirements for the full IR

Just rolling over and loosing the IMCr is, I agree, not an option which should be considered.

At the moment, I believe we need people pursuing all of these strategies, and developing proposals in each of these areas (my previous one was clearly targeted to the last option). However, option 1 probably needs to be maintained till the end to cover for failure of any of the other three.
With regard to airspace. The UK has had a long tradition of preserving airspace for all. Generally the Controlled airspace in the UK must be fully justified. It would appear that within much of the EU controlled airspace is given willy nilly. ... The idea that an IMCr holder cannot use their privileges at an airport used by an airline, with respect, is daft.

Only in remote areas of the world (other than the UK) is the concept of uncontrolled IFR flight allowed. Notwithstanding the fact that the big sky theory works, everywhere else in the world puts controlled airspace in that generally allows pretty free VFR access but requires clearance for IFR. Bizarrely, the UK sees fit to have uncontrolled IFR allowed to run through ILS's and operate 100 feet below the London TMA, but for virtually all commercial enroute bans VFR traffic from sharing the same airspace. Other than Italy, the UK seems to be the only EU country with this ultra protective view of the enroute airspace.

Until recently (I would guess the last decade) the IMCr was only allowed in some Class D airspace (which broadly would be described as not air carrier airports), for people using the IMCr for personal satisfaction and basic safety they probably aren't using these airports. For people who are, they are probably using the IMCr as a 'poor man's IR' and I believe sustaining this is only viable in my first strategy.


We are a country of 60 million with the most congested airspace in the world. Things work here with little or no objection to the IMCr, who then can have an excuse to resist the IMCr.
While 60 m population is true, most congested airspace in the world is not. The UK is just like many other countries, with some busy airports and a lot of empty space (particularly true below FL195).

EASA/EU, if all cannot be persuaded, should approve an IMCr but allow each state freedom to adopt it or notI think the only way this is likely to happen is through some kind of UK opt out.

[homeguard]

mm_flynn

The IMCr holder has always been able to use their privileges fully in all Class D airspace within the UK as they were in the previous Special Rules Airspace.

Surely you can't be argueing that airports such as; Birmingham, Bristol, Edinburgh, East Midlands, Glasgow, Liverpool, Manchester, Newcastle, Southampton, Leeds Bradford to name a few, are not air carrier airports! The london airports such as Heathrow, Gatwick, Luton and Stanstead as a group are far too expensive and slots at a premium. For light aircraft there are alternatives in the region around London with instrument approaches available to the IMCr holder at an acceptable cost. There are many regional airports with precision approaches that do not have controlled airspace. Lydd, Manston, Southend, Blackpool, Cranfield, Cambridge, Coventry, Norwich, Doncaster, Humberside etc, etc. Most of these have regular heavy aircraft flying short and medium haul and RADAR is available with the exception of Cranfield. In my experience all these airports would be in controlled airspace elsewhere in Europe. Southend had, but lost its controlled airspace some years ago. The DAP will remove controlled airspace if not justified. All of these airports and others within and outside controlled airspace are used by IMCr holders exercising their privileges on a regular basis and they will be an important source of income for some.

Le Touquet, Deauville, Calais, Ostend, Renne, Le Man, Tours etc would not be able to retain controlled airspace subject to the UK rules.

[BEagle]

The IMCr holder has always been able to use their privileges fully in all Class D airspace within the UK as they were in the previous Special Rules Airspace.

Not so. I disticntly recall when there used to be a list in Pooley's of those Class D CTRs in which one was not permitted to use the UK IMCR in IMC. One such was Cardiff; one week a colleague went down and had to scrape around under the scud to get in; a week later he could have taken radar to ILS in IMC when the rules changed!

Did extending the IMCR to all Class D cause problems? No. An important point and one I made at the recent CAA/EASA Press Brief - the UK IMCR privileges have been developed since 1970-ish as experience has been gained. And of course, as air transport movements into regional airports has expanded hugely.

[mm_flynn]

Just to be clear, I am not saying there is any safety case re: air carrier airports (which I was thinking of as say 50000+ transport category movements), just that with the very strong resistance from our continental airline cousins, it is a possible way the 'permitted airspace' would be defined. With the demonstrated safety record of the IMCr operating into all Class Ds it is difficult to see any logic reason why it isn't permitted in Class A as well, but no one is arguing for that change.

Re homeguard on LFAT etc having controlled airspace - that's the way it works everywhere else in the world, IFR airports are in controlled airspace (but not operated like the UK's where Class D sometimes feels like Class B!). On the plus side, if the French followed UK rules then all of their airways would be Class A, they seem to have a much more relaxed view of their enroute airspace than the UK.

[homeguard]

Well, perhaps what is being unearthed is that pilot qualifications are being influenced as much by restrictive practice as it is safety. But that of course is not without precedent within the UK. Class A airspace is a rare beast within the UK but is established where 'heavy' traffic is intense. Legislation is often designed with the circumstances of the time in mind.

Not that many years ago when much current legislation was conceived a VOR installed in a C172 was a point of interest. Anything more and private pilots would oogle through the window for hours on end. Many transport aircraft such as the F27 and others had nothing more than dual VOR, ADF, DME and manual trim. Climb rates on others were poor when loaded to max and not much better than many private GA types in that condition. The old RADAR needed a very high specialist skill with a high degree of interpolation by experienced controllers. I've spent hours, some twenty years ago, sat next to RADAR controllers trying to see pointed out aircraft amongst cloud returns and most of the time never did. Restrictive practices were to an extent understandable.

Nowadays it is unusual for modern Watchman RADAR, at least, not to be available at most airports with precision approaches. All public transport aircraft must be equiped with TACAS. Light aircraft are equiped to be an envy of many commercial operations and will usually have Mode C and increasingly Mode S as a minimum. Most light aircraft however complex they may appear are well within the requirements for single pilot operation.

We do have to understand the difficulties that exist for controllers with too great a variation in performance of aircraft. A Heavy will reduce speed to 200-250kts below 10,000ft which is still much greater than a great many light singles that will impress at 150kts full chat. I was held at the hold at Glasgow some time back for over 30 minutes. This was because of the elapsed time we required to T/O after a landing heavy. The following heavies to land didn't need the spacing and continued to land and others taxied past us to T/O putting our departure continously back. The Tower controller was 1st class and continued to apologise for the delay. He didn't need to apologise for we understood but its an indication of the difficulties in mixing aircraft of a different class in a busy environment.

Not that many airports are that busy of course and that is true throughout Europe also. Aircraft performance can be a major restrictor but when the IMCr is not.

[englishal]

Looking at it from a different persective....

How come the anks can feed in VFR Cessna 172's in LAX or JFK, how can 152's fly IFR in the airways above LAX (many do), how can 90 Kt warriors be allowed to fly IFR?

Easy because there really isn't a problem. We love to imagine a problem in Europe and look at "worst case", but in reality there isn't a problem....

....we just winge a lot I suppose...:}

[frog_ATC]

mm_flynn & BEagle (& other) made an interesting "first try" on what a private IR could be, thanks for the brainstorming.

One thing : I said the IMC syllabus is excellent, and I do confirm.
But a syllabus may be excellent, if it is not applied correctly, it is useless.

Those IMC rated pilots I flew with had a poor level, and I hardly believe they were trained in respect with the IMC syllabus.
Maybe I understand better now that I discovered that the IMC rating is valid for 25 months, that's a too long period.


What I would suggest in addition to mmflynn brainstorming :

- 24 or 25 months is a too long period for validity of an IR.
Even the FAA "6 calendar months" is short for someone who does not practice regularly. I would not feel comfortable in IFR if I flew only one approach per month...
I would suggest the same as the FAA rule, which means : you keep on flying legally as long as you have performed 6 approaches within the last 6 calendar months (let's forget about the holdings and tracking stuff, as approaches imply tracking and patterns).
If you did not performed that, check with instructor.
And why not a mandatory check every 24 months if you want.

- training implying 15 hours with certified IR instructor (no IMC instructor, this is a non-icao thing and will make it too complicated for a private IR if he wants to upgrade to the commercial IR, and use his previous private IR training for that). The remaining part of the training can be simulated IMC or ground trainer.

- 25 total is short I think. Flying IFR is not only flying an airplane in IMC.
Any child can become a great IMC pilot just by playing some hours on flight simulator, dealing with needles is not more complicated than a computer game and just requires to "play" often.
When the IMC stuff is learnt, flying IFR is more a matter of attitude and decision making.
Somebody said above in this thread that "adverse weather conditions" is the main factor for accidents. This is wrong, the main factor is human factor, and adverse weather condition is only a parameter which is linked to it.
I think that flight hours are also necessary to understand the environment, the ATC, the main concerns, the traffic, the weather from "inside", etc.
That's also a reason why this training should be at least partly in real IFR condition & environment (flight plan, congested airspace, etc) and not only simulated IMC in G airspace.



I feel tired now, because I understand that despite I spent hours writing long messages here (in a language that is not my native one), but some readers were so persuaded that I was somebody else that they did not even try to understand what I was writing.

My Priv/Pro comparison had only one goal : to explain that flying IR as a private on a GA airplane is not an easy thing, which means that those private IR have to be proud, and not ashamed when compared to commercial pilots.
But IO540 thought I was trying to explain that private pilots are stupid !!!

And my bad english was not the matter I think.
When you read someone with a false opinion of who this person is, you just do not read at all.

Happy landings.

Frog

[rustle]

...And my bad english was not the matter I think.
When you read someone with a false opinion of who this person is, you just do not read at all.

Frog

I think plenty of people have read what you had to say and made their own minds up about its validity. :ok:

Now it is time to move on from some of the "personalities" (!) on this BB and concentrate on the issue at hand, and both BEagle, mm_flynn and yourself have listed some quite interesting ideas in that regard.

[homeguard]

Well Frog, I do not think your a fraud or stupid. You put your arguments clearly and from an experienced footing albeit I don't agree with some of what you say.

There is a desease within much of aviation and amongst some instructors that the student is stupid. I have a friend who is a engineer specialising in concrete structures. I some times go to work with him. We have a deal. In the aeroplane he listens to me and does as I say. On construction sites I listen him and do as I'm told. Horses for courses. In the aeroplane he is not stupid for he is still the man he is. One should not confuse expertise with superioty of character.

Many of those who can afford to fly are already accomplished people in difficult and pressured jobs and they are quite capable of making serious decisions given the training but from a greater experience of the world than perhaps the instructor has in their gift. BEagle has already made the point that the IMCr allows people to train for their particular needs. They are clearly carrying out there responsibilties safely. The pilots needs are not always the same as those devised by an institution. Sadly in the UK and, I also suspect elsewhere in Europe, I don't witness much evidence to say decision making is any more of the IR course than it is for the IMCr. Too much of the IR is rehearsing pre-determined routes and other elements very likely to be undertaken for their test with its pre-determined format. The IR course is so often undertaken in much the way an actor rehearses for a performance. At the peak of training they must be at a high level of precision but it dosn't follow that this will be maintained.

I'm getting a lot of reports from airline recruiters that a large number of recruits are being chopped because their IR skills are so rusty. This has been happening for many years. A Captain friend recently told me of a 1st officer who lost it during an NDB approach. His excuse was that he has never been good at them. Presumbly he passed his IR from repitition of known procedures. I know of one airline so concerned that they now use a local IR school to vet applicants for currency/ability before they are interviewed. Give a dog a bad name ......... I don't think so. Please don't judge a few poor IMCr performances with the all.

With regard to examiners. You must understand that in the UK Examiners are now required to attend a course of training and pass an assessment in order to be appointed. Clearly from the statistics with regard to the IMCr they are carrying out their responsibilties effectively.

IR training is as likely to be undertaken in simulated conditions as the IMCr. Very few clubs will have an FNPT trainer therefore it will be normal to do all training in flight. Within the UK it will be very unique indeed not to encounter full IMC conditions for much of the training.

I would have no problem with an annual review of IMC skills although BEagle has suggested it should remain at 24/25 months as now and he gives his reasons.

The UK requires an Instructor to undertake a formal 30 hours approved course of training and pass an entry examination of knowledge or at the minimum have passed the CPL examinations. Should an instructor wish to teach applied IMC flight they must attend an addition course and again be tested. That adds up to a higher requirement than ICAO.

[frog_ATC]

Hello Homeguard

I do agree on most of your remarks, and confronting positions is interesting.

No, you are right, students are not stupid. And I would even say : qualified pilots are often more stupid than students :-)
Why ? Because gaining confidence and habits have bad "secondary effects" on you, on me, on everybody.

And I do agree with you, "decision making" should be more emphasized in the IR training as well. We slowly improve on that field, but there is still room for improvement.

I said I flew with some poor-skilled IMC rated pilots, but I'm sure they are some talented, do not worry.
And they are also some poor-skilled IR pilots, I flew with some of them, whatever FAA or JAA rated.

The quality of the training does not depend on the rule or on the syllabus, but mainly on the school and the serious of the student.
And once you're rated, it depends only on you.

Rules are a guideline, but the final result do not depend only on them.


Why applying flight hours minimum instead of just competency ?

Hard to say. Even in the US they have difficulty to make a decision on that. Right now you renew your IR just by flying a minimum number of approaches every 6 months + holdings + tracking/intercepting stuff, but they think about requesting also a minimum of flight hours maybe.

As I said, I do not make rules, I just apply them.

But if I had to make them, I would not be comfortable in that role, because it is really not an easy one.
No rule is perfect, that's the reason why they are modified, and improved, as time goes by, and they try to take into consideration all different human behaviors and all possibilities.

A rule is a kind of "compromise" between what is expected, experienced, known statistics, and a kind of "guess" about the future.

We recently had a student, CAA IR rated, for an FAA IR.
He flew the airplane pretty well, no problem with his IMC flying, he was very sharp.

But...

=> He came without clearing the customs, and without even knowing he needed to between UK and France.
=> His approach plates were completely outdated (year 2002) and he tried to convince me that those differences since then were "not really important".
=> He had no IR flight time endorsed in the logbook by any instructor (it is the second time we have that problem with a UK pilot... Why instructors do not endorse logbooks in UK? Is that normal on your side of the Channel ?)
=> His answers to basic oral preparation questions were false (about regulation, ATC, what would you do in case of radio failure, use of GPS in IFR, etc).


On the other hand, we teach a young UK girl for a multiengine IR.
She has just a PPL, not more, not even an IMC, but she is really sharp, she studies, she listens carefully, she understands everything, she makes good decisions, so she will be ready in a very short period of time.


Someone above proposed that approach minimums would be raised for private IR pilots (+200 on a precision, +250 on a non-precision, if I remember well).
I do not agree with that.

If your minima are raised, then you will probably more often go for a missed-approach, and performing several approaches is more dangerous than only one, because you get tired, nervous, etc.
Moreover, diverting is a really more hazardous thing than performing the approach to the legal minimums.

I know some pilots who self-raised their minimums when they feel they did not train enough recently, and of course I respect that decision they make.
But I think that should not be a legal thing, only a personal decision.

Over ;)

Frog

[IO540]

=> He came without clearing the customs, and without even knowing he needed to between UK and France.

He has probably not been outside the UK very much. Or he saw wrong airport data - easy to do.

=> His approach plates were completely outdated (year 2002) and he tried to convince me that those differences since then were "not really important".

This highlights lack of IFR (airways) experience. Very few pilots who are not aircraft owners fly airways, due to the difficulty in renting a suitable aircraft. And if you don't fly airways often, it is hard to justify getting Jeppview; European coverage is about Euro 1500. OK, one can get free plates from Eurocontrol or Olivia but not many people like those because they use some strange notation and are hard to read if printed on A5.

Plus a lot of training is done with old approach plates, because the schools won't pay for current ones. Before I got electronic data, I used to give away my old approach plates to schools; they used them for training.

=> He had no IR flight time endorsed in the logbook by any instructor (it is the second time we have that problem with a UK pilot... Why instructors do not endorse logbooks in UK? Is that normal on your side of the Channel ?)

This is normal. Instructors rarely sign individual lessons. When I started on my FAA PPL/IR/CPL route I went back to the old instructors and got them to sign everything possible.

Someone above proposed that approach minimums would be raised for private IR pilots (+200 on a precision, +250 on a non-precision, if I remember well).
I do not agree with that.
If your minima are raised, then you will probably more often go for a missed-approach, and performing several approaches is more dangerous than only one, because you get tired, nervous, etc.
Moreover, diverting is a really more hazardous thing than performing the approach to the legal minimums.

I agree. One should always fly to published minima. It is the safest thing. Unless the approach has gone badly wrong...

[homeguard]

Frog

To clarify further.

The CAA require that a seperate detailed Training Record is maintained by the FTO/RTF to an acceptable format. This explains why UK instructors do not normally enter detail into the pilots logbook. Further, Revalidation Flight Test passes and routine validations are entered into the Rating Validation page of the pilots licence by the examiner. The first entry on the issue of a licence or rating is always entered by the CAA themselves. You need to see the actual licence for validity. The log book will only indicate currency as entered by the pilot themselves.

For UK flight, up-to-date Approach Plates, Airspace and Aerodrome data is always available from the ais.org.uk website for free or by subscription it is supplied on CD or in paper format. There is no excuse to have out of date data for flight within the UK. 1050 makes his points with regard to the eurocontrol/Sylvia stuff.

On another issue. What is the training and qualification process/procedure to be a Flight Instructor in France? Is there a formal course for instructors similar to the UK? Incidentally the UK Instructor course also includes 120 hours of groundschool made up of lectures/briefings and student practice. It is in this way that the UK have always complied with ICAO knowledge and skill requirements but the Instructor is not required to hold a CPL except to be paid, which is only since JAA.

[frog_ATC]

Thanks Homeguard, it helps me understand better.


///////// quick note...

So just a note for those who want their IFR experience to be valid in an FAA IR cursus : ask your instructors (or chase them, for previous flights!) to endorse each line of your logbook they flew with you.
It is the only way to make your experience valid.

Moreover, your IMC rating training maybe taken into account, as long as the instructor was an IR instructor, not an IMC instructor.
You'll have to prove that to the DPE.
Some of them do not check that point because they do not even know that IMC instructors exist, some other are touchy about that because they had bad experiences about training taken into account which was not "legal" on the FAA point of view.
So if you have a written proof (copy of license, etc) that the instructor was a legal IR instructor at the time of the training, perfect.

/////// end of note !


For info, French charts are available for free online also :
http://www.sia.aviation-civile.gouv.fr/aip/enligne/FR/IACProduitPartieframeset.htm

But I prefer using Jeppview, and print charts before departure.
Jeppview has also a great option which allow you to select a list of favourite airports, and then make an "print update" : Jeppview will print only those that changed since your last print.
Useful !

I always have a printed version of my approach plate, even on airplanes equipped with Cmax, screens and Disney Chanel TVs, even on airfields where I know the approach "by heart".

I think it's more easy to concentrate on a sheet of paper, and safer.


For the Flight Instructor cursus in France, we have 2 possibilities :

- "Commercial" FI (normal JAR one)
- "Airclub" FI (maybe we'll lose this specificity)


The second one (airclub) is exactly the same as the first one, but you have a simplified written test, whereas the first one requires the JAR CPL written test.
The "airclub" CFI also has a mandatory 1-week refresher ground course.
The flight preparation and examination are exactly the same (evaluation, 5 weeks training in FTO, Checkride).

The limitations for the "airclub" instructor are :

- no compensation for instruction
- instruction only in France

Maybe the same in UK ?

Frog

[IO540]

So just a note for those who want their IFR experience to be valid in an FAA IR cursus : ask your instructors (or chase them, for previous flights!) to endorse each line of your logbook they flew with you.
It is the only way to make your experience valid.

The FAA IR needs 15hrs dual and I would agree that that time ought to be signed off. It's wise but not a requirement. However the remainder of the 40hrs is solo instrument flight which nobody else is in a position to sign off.

Moreover, your IMC rating training maybe taken into account, as long as the instructor was an IR instructor, not an IMC instructor.
You'll have to prove that to the DPE.

Do you have the FAR reference for that, Frog-ATC? That is absolutely not the practice in all FAA training I have seen, UK or USA. The FAR wording is "authorised instructor".

There are particular individuals, no names mentioned but they have been well known, outside the USA, with a history of certain practices, indeed... especially when working in association with a training establishment :) It isn't right. Instrument training by an IMCR instructor is fine and acceptable. Anyway, the pilot has to pass the checkride.

The scenario where an IMCR holder turns up in the USA for the FAA IR is very common. Most of them turn up with a large # of dual instrument hours - obviously more than the 15hrs min. But practically all of them need at least another 15hrs to reach the FAA IR checkride standard, which makes the original IMCR training logbook entries irrelevant because they get the 15hrs all over again.

I have totally lost count of the number of people I know who followed this route.

Re UK instructors, I don't believe they are limited to instructing in the UK. Cross channel fly-outs are common, and the school tries to maximise revenue by placing a student in the LH seat and an instructor in the RH seat. That way they get the aircraft rental plus instructor rate, and they set it up so this happens on every leg flown. The time is logged by the student as instructional flight. So I don't think there is a ban on foreign instruction here.

[frog_ATC]

It is simple : the non-FAA training has to be endorsed by an authorized IR instructor to be acceptable.

An IMC instructor is not an authorized IR instructor, as well as the IMC rating privileges do not apply outside UK.

This is obvious, and was confirmed by the IFO New York.

Regards,

Frog

[S-Works]

You might need to differentiate here on what exactly an IMC Instructor is. A good number of Instructors teaching the IMC are actually IRI and those with a modern FI rating will have done the equivalent of the IRI to get the no Instrument Instruction restriction lifted.

It is perfectly within reason for me to teach an IMC rating using the IRI rating and that time is time with an ICAO approved Instrument Instructor.

The discussion should not be around the Instructor but rather around the Sub ICAO nature of the IMC rating.

You will find that most IRI's will be teaching Instrument flight to the same standard whether IR or IMC. It is just with the IMC there is a lot less of it.

[youngskywalker]

I can also confirm that all my IMC training hours were approved by the school and the DPE when conducting my Instrument rating in San Diego, no question at all. As long as those hours were signed off by the instructor with his licence number and expiry date. very comon practice.

[homeguard]

There is no such thing in the UK as an IR Instructor. No course nor no rating. The Applied Instruments Restriction initialy entered into the Instructor Page has to be removed following an FIC Applied Instruments Course and a succesful test with an FI Examiner. Same to teach the IMC or IR.

An Instructor when teaching on a IR course needs to hold an IR and be entered into the FTO Approval following Standardisation training. I could be out of date, correct me if I'm wrong (silly to think someone wouldn't!).

[frog_ATC]

Please read again what I wrote above : I do confirm that the IMC training can count for an FAA IR.

But only if the instructor that provides the training is also an IR instructor, which means someone which can legally train for the IR.
If he is only an IMC instructor (which seems to exist in UK) then the flight hours cannot count.

Frog

[S-Works]

homeguard, can I respectfully suggest that you go away and do some research before making such a categorical statement?

H2.1 INSTRUMENT RATING INSTRUCTOR
(AEROPLANE) (IRI(A))
Privileges
The privileges of the holder of an IRI(A) rating are
limited to conduct flight instruction for:
a. The issue of an IR(A) single-engine aeroplanes;
b. The issue of an IR(A) multi-engine aeroplanes,
provided that the instructor meets the
requirements of JAR-FCL 1.380(a).
Requirements
a. The applicant for an IRI(A) shall hold a valid
IR(A).
b. Have completed at least 800 hours of flight time
under IFR of which at least 400 shall be in
aeroplanes. Where pilots have recorded flight by
sole reference to instruments and not under IFR,
then 1 hour sole reference to instruments may be
counted as 4 hours flight by IFR.
c. Successfully completed at an approved FTO and
approved course (see Appendix 1 to JAR-FCL
1.395 and AMC FCL 1.395) comprising
theoretical knowledge instruction and at least ten
hours of flight instruction on an aeroplane, flight
simulator or FNPT II; and.
d. Pass the relevant elements of a FI Skill Test in a
single pilot aeroplane with a suitably qualified
FIE(A).
e. IRI(A)’s who wish to conduct training for a ME IR
are also required to have met the qualifications
for a ME CRI. Where both courses are conducted
together, the teaching and learning element is
common to both CRI and IRI courses.
Candidates qualifying for the teaching and
learning exemption in accordance with Appendix
1 to JAR-FCL 1.395(2) who combine both ME
CRI and IRI qualifications on one course will be
required to complete a minimum of 15 hours
theoretical training before attempting the ME CRI
and IRI Skill Tests. The IRI(A) rating is designed
to train instructors to teach for the JAA IR within
an approved FTO. In the UK, the same (IRI)
qualification course is also used to qualify
instructors to teach for the UK National IMC
rating. The entry requirements for the IRI course
to teach solely for the UK IMC rating are detailed
in Section H1.4 (Removal of No Applied
Instrument Restriction). The theoretical ground
training requirements shall be the same as those
required for the IRI qualification.

[IO540]

OK guys we can digress down this road... but there is AFAIK no known case of instrument training done outside the USA (in a European reg plane) being disallowed for the award of an FAA IR, by the FAA examiner, on the basis that the instructor had an IMCR and not the full valid IR.

Well........... except as part of a blatent revenue generating scheme as run by certain UK based FAA flight training establishments in years gone by, but the FAA DPE was not involved in the refusal. I did my FAA PPL in the UK, and then spent much of 2004 trying to do the FAA IR in the UK too, in my own plane, only to find that not only was nobody able to guarantee the availability of the FAA (visiting) examiner, but also some of the merchants came out with utter tosh like "all training towards an FAA IR must be done by an FAA CFII" which "everybody" would recognise as utter crap but it was a case of quietly saying "sod it", getting one's credit card out, and doing 15hrs of flying. In the end, the examiner availability problems (which resulted in legal action by some candidates to get checkride deposits refunded) were enough and I went to the USA.

I have it in writing from the FAA that they regard the UK IMCR as equivalent to the FAA IR - within the respective legal privileges of the two ratings obviously.

My own experience is that various FAA CFII instructors hold the UK IMCR in high regard.

[homeguard]

Bose-X

I did invite responses should I be out of date. I need some assistance in interpreting your extract, presumably from LASORS.

I qoute the following from your extract;

In the UK, the same (IRI)
qualification course is also used to qualify
instructors to teach for the UK National IMC
rating. The entry requirements for the IRI course
to teach solely for the UK IMC rating are detailed
in Section H1.4 (Removal of No Applied
Instrument Restriction). The theoretical ground
training requirements shall be the same as those
required for the IRI qualification.

I'm presuming that the long pre-amble which precedes the above bit outlines the requirements for a CRI i.e. for someone who is not a fully qualified Flight Instructor with the No Applied Instruments endorsement removed but who wishes to instruct on an approved IR course.

I've not gone away, I thought I'd let you help me through this jungle.

[S-Works]

It is my understanding that under JAA to teach for the IR the holder must have a current IR and have an IRI rating. The IRI rating can be added to an FI or a CRI. An ME IRI has to be added to the ME CRI rating. An FI who wishes to be an ME Instructor has to do a ME CRI which is what the LASORS entry refers to.

For an FI to teach for the IMC they are required to have the no Instrument flight restriction lifted. It is my understanding that lifting this restriction only allows them to teach for the IMC. An IRI may teach for the IR if they hold a current IR and the IMC. If they do not hold an IR then they may only teach for the IMC.

That is my understanding. I too stand to be corrected.

But the purpose of my post was to point out that there is such a thing an IRI rating, with a course and a test.

[aztec25]

Not quite the case.
It is my understanding that the removal of the applied instrument restriction allows an FI to instruct for both the IR or the IMC provided of course he/she has that rating themselves.

[frog_ATC]

IO : "but there is AFAIK no known case of instrument training done outside the USA (in a European reg plane) being disallowed for the award of an FAA IR, by the FAA examiner, on the basis that the instructor had an IMCR and not the full valid IR."


Of course there are known cases.

But IO does not seem to be very good at respecting the rules, as I remembered above on this thread that he claimed that a VFR pilot entering IMC should tell the ATC that he is VMC...

Great job boy ! :bored::bored::bored::bored::bored:

[S-Works]

I have it in writing from the FAA that they regard the UK IMCR as equivalent to the FAA IR - within the respective legal privileges of the two ratings obviously.

Then why won't the issue a foreign instrument pilot rating after passing the theory to IMCR holders?

[S-Works]

Both sides of the story!


Removal of No Applied Instrument
Restriction
a. Hold either a valid single pilot, Instrument Rating
(IR(A)) or Instrument Meteorological Conditions
(IMC) Rating.
b. Hold a valid FI(A) with Supervisory Restriction
removed.
c. Have flown at least 200 hours flight time in
accordance with Instrument Flight Rules (IFR), of
which up to 50 hours may be instrument ground
time in an approved flight simulator or FNPT II.
Where pilots have recorded flight by sole
reference to instruments and not under IFR then
1 hour of flight by sole reference to instruments
may be counted as 4 hours flight by IFR. Where
pilots wish solely to instruct for the IMC Rating a
reduced experience level of 10 hours flight time
by sole reference to instruments is applicable
and;
d. Complete an approved course comprising at
least 5 hours dual flight training on instruments in
an aeroplane, flight simulator or FNPT 2 and 10
hours of theoretical training. All training to be
conducted by FIC Instructor qualified to conduct
instrument training at an approved FIC FTO.
e. Pass the relevant elements of a FI Skill Test in a
single pilot aeroplane with a suitably qualified
FIE(A).
In addition, for the issue of an IR(A) multi-engine
aeroplanes the instructor shall meet the
requirements of JAR-FCL 1.380(a) (see Section
H3.3)

[IO540]

But IO does not seem to be very good at respecting the rules, as I remembered above on this thread that he claimed that a VFR pilot entering IMC should tell the ATC that he is VMC...

I didn't say he "should". That would be illegal ;)

"Then why won't the issue a foreign instrument pilot rating after passing the theory to IMCR holders?"

Because the IMCR is non-ICAO, could be one reason.

[S-Works]

Therefore to use your method of surmising the FAA IR and the IMCR are in fact not equivalents? The IMCR is a sub ICAO licence with significantly less training than an FAA IR.

They may be close cousins but they are not equivalents.

[BEagle]

The IRI is a standalone Rating for a non-FI.

The 'Removal of no Applied IF' as an additional qualification for an FI.

Either may teach for the IMCR or IR, but must hold the IR to teach for it. There are also greater 'IFR' hours requirements for the standalone IRI.

[homeguard]

Frog

You are allowing yourself to be dragged into a downward spiral going nowhere, some thrive on it. You have until now kept above bickering, keep it that way. Human Factors, remember..........!

From the recent interlude, perhaps, your able now to agree that there is no such thing for a fully qualified UK Flight Instructor to have an IR Instructor rating as a seperate attachment. Only an Instructor Rating with the 'no applied Instrument training endorsement removed exists, at least within the UK.

For the purposes of the USA I presume an Instructor with the UK Flight Instructor 'no applied .........' endorsement removed, having validated a pilots logbook, satisfies their requirement. The holder of an IMCr will by holding the IMC rating be able to demonstrate that they meet the requirement of 15 hours dual instrument training.

I can quite see that it will not be so simple for those outside of the UK to demonstrate the same without logbook endorsements, which may have lead you to your believe.

[S-Works]

that there is no such thing for a fully qualified UK Flight Instructor to have an IR Instructor rating as a seperate attachment.

Nice wordsmithing but I think you mean that there is no requirement for an FI with the applied Instrument restriction lifted to have an IRI as a separate attachment but that there is in fact an IRI rating.

I am curious about one thing, does training with an Instructor who has the no Instrument restriction lifted but who does not have an IR count towards the 15hrs of applied instrument flight?

[IO540]

The holder of an IMCr will by holding the IMC rating be able to demonstrate that they meet the requirement of 15 hours dual instrument training.

That, Homeguard, is exactly how the FAA requirement for "authorised instructor" is met. If the instructor was not "authorised" for the training, you would not have got the IMC Rating in the first place :)

IMHO, the FAA "authorised instructor" requirement is intended to prevent instrument instruction by people not authorised to do it... fairly obvious I suppose.

[frog_ATC]

Do whatever you want Homeguard, I'm sure you are instructor-something-somewhat-somewhere so you know things better than me.

But I'll keep doing things by the rules.
And when I'm not sure of the rules, I just write to the authorities to make things clear, and I do not try to invent or interpret them.

That's the way it works for stupid frogs like me !

Discussion over for me, useless I think... I wasted too much time !
Good luck !

Single-neurone frog

[homeguard]

Frog

That is just the problem. Rules, laws whatever are made by those charged to do it. But, when it comes to the crunch where are they. We are left to work it out for ourserves.

I don't know what the french authority is like but try ringing the CAA. At best you will get interpretation from whoever, who adds the caveat "but don't take my word for it" or they simply read out to you the LASORS passage that you have in front of you.

It all really started with the JAA. Each countries authority becoming a processing organisation but with no one body in charge at the centre, will no doubt get worse.

Come back please Elizabeth Cullen-Hayes we need you desperately! We need decisions to be made and a tiny bit of common sense would be very nice.

[englishal]

I am inclined to agree with Mme Frog......At least I'd advise anyone who was thinking of doing an IMC with a view to getting an FAA IR to use an IRI to cover their arse. But still, only 15 hrs is required with an instructor anyway which in terms of money equates to about $500 in the USA........You could do it in the sim in 3 days.......

I don't know which is 100% right, but as the FAA have this "CFII" rating - Intrument Instructor, authorised to teach for an ICAO IR it'd be reasonable to assume that you need to have previous training done my an instructor authorised to teach for an ICAO IR......

Just my view of course, though if you ask the FAA it probably won't make it any clearerer:O

[421C]

It is simple : the non-FAA training has to be endorsed by an authorized IR instructor to be acceptable.

An IMC instructor is not an authorized IR instructor, as well as the IMC rating privileges do not apply outside UK.

This is obvious, and was confirmed by the IFO New York.

Regards,

Frog


It's not as obvious as that because you have inserted the capitals "IR" in the text above. 14CFR only referes to "instrument training" and "authorised instructors". IMC Rating instructors are authorised to give instrument training. This is obvious, to use your own words, and it is all that 14CFR specifies for the 15 hrs. No-where does is say what you claim, that the 15hrs have to be "endorsed by an authorized IR instructor to be acceptable"

Like many regulators, the FAA is a large organisation managing a complex environment in which individuals have to apply policy judgements. However, only the FAA's General Counsel office is authorised to make legal interpretations. It is perfectly possible to get different interpretations from different people at different times within the FAA on obscure topics. I believe you that someone in the New York IFO told you what you report. You should believe others who tell you that FSDOs and DPEs have systematically accepted IMCr training, fully aware of its nature as a UK-specific sub-ICAO instrument qualification, for many years. Of course, ultimately, anyone depending on this needs to check with the FAA Instructor completing their training check and with the DPE who will perform their IR check ride.

rgds
421C

[englishal]

14CFR only referes to "instrument training" and "authorised instructors".
Probably though because the FAA has no concept of non IR'd or non "IRI" instructors teaching for an instrument "rating" (there is also no concept of an non instrument, instrument type rating under the FAA).

It is a very complicated issue and it is better to be safe than sorry. I "failed" my IR test before we even got in the air because I was missing 3 hours of night flying.

You could claim to an FAA DPE that Compton Abbas to Henstridge was a cross courntry flight and he'd probably believe you....technically under the FARs it is not, and later on I guess it could come back to haunt you (very unlikely of course)......

[IO540]

I am inclined to agree with Mme Frog......At least I'd advise anyone who was thinking of doing an IMC with a view to getting an FAA IR to use an IRI to cover their arse

I would agree, on the precautionary principle. However (and I am making a rod for my own back saying this) there are not many UK instructors on the PPL scene with valid IRs. The ATPL hour builders usually had an IR initially but they cannot afford to renew it so they let it lapse until it starts to look like they might get an airline job offer, then they renew it. But they can teach the IMC Rating in the meantime. This situation is a legacy of the historically hard CAA/JAA IR, which has resulted in very tiny numbers of private pilots doing the European IR, and these few people have always managed to get it done at the commercial/ATPL schools. Almost nobody is doing IR training on the normal PPL scene. Of course most people do the FAA IR now anyway.

I "failed" my IR test before we even got in the air because I was missing 3 hours of night flying.

Well, yes, but you would not have got a standalone FAA PPL either, if you didn't have the night stuff. The IR doesn't need anything beyond that, IIRC (could be wrong).

I've been around this block far more times than I want to remember. These things highlight the absolute need to get in direct contact with the FAA examiner and get him to confirm that your logbook (send him a copy of it, with explanatory notes on eligible flights for Part 61) is acceptable.

Generally, the FAA instructor signing you off as ready for the checkride will do all these checks, but there are grey areas which the examiner alone must decide on - for example whether the 250nm cross country flights (IR and CPL have these) with 3 different landings all need to be done on the same day. The FARs are silent on this; John Lynch's FAA FAQ said it doesn't need to be on the same day, but the DPEs are split maybe 50/50. And if the examiner says "jump" you say "HOW HIGH SIR" :)

[421C]

Probably though because the FAA has no concept of non IR'd or non "IRI" instructors teaching for an instrument "rating" (there is also no concept of an non instrument, instrument type rating under the FAA).


I don't think so. The FAA is well aware that all sorts of things go on in the rest of the world, and they make it clear what can be done by an authorised instructor (the very general definition) vs what needs an FAA Instructor. For example (and I don't know anything about military flying) but an ex-military pilot could have instrument training that wasn't by an ICAO IR qualified instructor but counted as instrument training by an authorised instructor. Probably a fairly common case.


You could claim to an FAA DPE that Compton Abbas to Henstridge was a cross courntry flight and he'd probably believe you....technically under the FARs it is not

This analogy is wrong, because you'd be making a claim that contradicts the explicit 14CFR definition of cross-country flight as >50nm. The whole point is that "instrument training" by an "authorised instructor" does not specify "ICAO IR qualified", it permits the more general case of instrument training (eg. my military example). A better analogy is whether the 40hrs of total instrument flight time is met by an IMC-r holder who has done solo hours in IMC after the training. Of course does - it is "instrument flight time" as per the 14CFR definition, because they don't define it as "exercised by the holder of a valid ICAO IR". And, again, it's not a UK IMCr loophole - the same can apply to military flight time, or a holder of Australia's PIFR qualification etc.


better to be safe than sorry


You're right of course. I agree with IO540 that the best way to be safe is to check with the DPE. I'm not debating what's a good idea or what is good practice - just the question of whether IMC-r training meets the definition of what's needed for the FAA 15hr instrument training minimum.

[homeguard]

It is established that the actual Instructing qualifications for the teaching of applied instruments are the same for the IR or IMCr instructor and they need only to have completed the same course. This fact is specifically stated within LASORS (see earlier quote from LASORS). Additionally, a long standing principle is that you do not teach on a course for anything for which you do not have the qualification. Holding an IR to be able to teach on an IR course satisfies that principle.

Some argue that the training given by an IMCr Instructor is sub ICAO and shouldn't count toward an an ICAO recognised IR. I should remind everyone that until the establishment of JAA the UK gave credit for 10 hours IMCr training toward the fully recognised ICAO UK IR.

What is it that some think is actually different between the two instructors, when teaching the IMCr as far as it goes, and therefore believe the training should not be credited toward an ICAO IR?

[Cusco]

I've enjoyed your postings, Frog:

What a pity you didn't take the trouble to look at the IMC rating syllabus until now:

It might have added more gravitas to your railing about what IMHO is an excellent rating.

When I did my IMC rating a few years ago now, in a residential course, I was told that the previous week three French pilots had come over to do the training: Even in the full knowledge that they were unable actually to be granted the rating, they felt they would benefit.

RIP Jim Hilton............

Cusco (CAA/PPL(A) IMC FAAPPL FAA/IR )

[rustle]

frog_ATC, I have cross posted one of your posts onto the FLYER website I hope that is okay (your post about French training etc.)

[Check Airman]

Wow! I had no idea my question would spark 11 pages worth of discussion. Now all I have to do is sit and read them all. Thanks guys!