Where are we really going with the IMC rating?

[Fuji Abound]

I thought, since I started it here I should post here to keep the IMC rating in the headlights and make it clear that we need everyones continuing support with our campaign.

It is very easy to think the battle has been won, when so far there has only been a minor skirmish.

On the positive side, it would seem EASA will protect the IMC rating during a transition period of up to four years, from 2008.

On the negative side, the survival of the IMC rating will ultimately depend on the degree of support for the rating here and in the rest of Europe.

Unfortunately, it is far from clear what position each of the UK representative organisations take on this matter. Sadly, their web sites contain very little information on which we might form a view. They have represented us during the early committee stages but a veil of secrecy has been drawn over those meetings. Many people have asked for copies of the minutes, or at least a summary, but nothing has been forthcoming.

You might expect to a man they would support the European wide retention of the IMC rating, given the view of the vast majority of British pilots. However, if they do, they certainly have not been very quick to nail their colours to the mast. This, in my opinion, is a great shame. We would all be better served if we could co-operate on such a key matter.

Whatever happened to open representation?

There is a growing suspicion that some of the representative organisations are selling out the IMC rating in the belief that a more acceptable IR is achievable.

Unfortunately this presupposes that most pilots want to commit time and money to an IR, when the IMC rating already provides everything they need.

Moreover, the evidence is that any “concessions” in the IR syllabus will comprise little more than tinkering with the theory content, and would in any event presumably result in a two tier system divided between the "commercial IR" and the “private IR”.

There is a growing suspicion that the representative organisations think they know what is good for us, but forgot to ask us along the way.

Now I fully appreciate it will appear that I am running them down and ignoring all the work they do for us.

That would be wrong.

I am concerned that in this process none of us make any assumptions. It would be a great shame to believe our representative bodies support our own view on this issue when they hold another.

It seems not unreasonable that we should know how we are being represented, so that we can make intelligent choices about whether we agree with the way we are being represented.

My concern extends to the rest of Europe as well.

It is widely reported the French are opposed to the IMC rating.

It is widely reported the European Commercial Pilots Association is opposed to the IMC rating.

Why is the average French pilot opposed? I don’t know the answer. I am not even certain anyone has asked them. Are they opposed because no one has bothered to explain the rating to them?

The CAA say that there is no evidence what so ever of problems associated with IMC rating pilots mixing with commercial traffic. Does the European Commercial Pilots Association know better? In fact I have written to their secretary on three occasions to ask them to set out their position. I have yet to receive the courtesy of an acknowledgment of my correspondence, never mind an informative reply. Does this mean that they are above the democratic process? Does this mean if their own members write to them they will also not be given the privilege of a reply? Perhaps some one on here who is a serving commercial pilots might like to try? Who in fact do they actually represent?

Why would you pay good money for someone to represent you and not have a clue whether they are representing your views or their own? BALPA say they support the IMC rating - good news indeed. Are they really a lone voice in the rest of Europe's commercial world? Is the commercial world so blinkered as to not examine over forty years of evidence gathered in the UK or has no one bothered to provide them with the evidence?

Lots of questions unanswered.

So far as our campaign is concerned, we are going to try an get some answers. We are going to try and honestly engage anyone and everyone.

Very shortly we will be “rolling out” our new web site, which will be carried in a number of other languages. We are going to work hard on continuing to drum up support here and in Europe. We have one or two other initiatives that we think will be helpful.

For the time being please continue to register with the campaign at www.ukimc.org

I apologise for the long post.

However, there is a very real danger we each and everyone don’t support the campaign through lack of time or because we fell we can leave it to others. If you believe in preserving the IMC rating which is all that we stand for, we need your support. If you are clear on the position of any of the representative organisations to which you may belong by all means give them your support as well and ask how you may demonstrate your support.

You can support our campaign by simply registering on our web site. We will suggest to you when it is a good time to contibute further as matters progress through the consultation phase.

For the avoidance of any doubt our campaign is solely concerned with preserving the IMC rating in the UK and for its wider adoption by EASA. We are not in the business of compromise - and the loss of the IMC to be replaced with some other form of IR is not on our agenda.

Finally, I am aware there has been some criticism of “our” No 10 petition. The petition has demonstrated the extent of the support. I believe this was needed. I accept there is a danger that those who have signed don’t now support the campaign. That is one further reason for my asking now for you to register to with us.

[BroomstickPilot]

Hi Fuji,

Let me say at the outset that I am in favour of the IMCR and want to see it retained.

However, within recent days we have all read the posts by a French ATCO who had personally handled a number of instances where IMC holders had quite illegally entered French airspace in serious IMC and had then become a serious problem for French air traffic control staff by reason of lack of skill, currency or judgement. She was adamant that she wished to see the IMCR scrapped, and as soon as possible.

Unfortunately, although French ATCOs do report the actions of these people to the French authorities, somehow this has not resulted in contact between DGAC and CAA with a view to prosecution, so the misbehaviour has continued.

Under these circumstances, it is surely no surprise that the French at least are against the IMCR. We have no way of knowing how these same people behave in other countries of the JAA participating countries. Perhaps these people are doing the same thing in Spain, Belgium, the Netherlands and elsewhere. So no wonder other countries are against the IMCR.

If we want to get other countries to support the IMCR, then this needs to be the first thing we attend to, as even the best of campaigns such as your own are going to fail if our own people are, in effect, 'shooting us in the foot'.

If the IMCR is to achieve support from other countries, then the holders of the rating have got to secure a reputation for being both competent and responsible.

Broomstick.

[IO540]

Broomstick - I can assure you that anything serious notified to the DGAC does get pursued back to the UK. A few years ago I busted a TRA in France (in the days when the French IGN charts did not yet show their nuclear power station TRAs, and the ais.org.uk notam system did not yet carry the info either). I was under radar contact with a special squawk issued; French ATC said nothing at the time but asked me for the pilot name, his inside leg measurement, etc. 6 months later I heard from the CAA who were asked to prosecute on behalf of the DGAC. The radar trace (which I got a copy of) proved the special squawk and made everybody wonder why ATC did not tell me about it at the time but that is another story...

So I think if we did see the alleged huge numbers of Brit pilots flying illegally in France, there would be a lot of cases heard of over here of people getting done. The GA rumour mill would make absolutely sure of it. Yet, nothing, zero, zilch has been heard. I reckon that if some cases were suspected there was no proof and no action was taken.

It takes only a few cases of French police pick on an N-reg pilot and turn his plane over checking his VAT certificate and the words "instrument pilot" on his plastic card, for the word to get right around.

[englishal]

Would the French still be against an IMC rating (to keep it's old name) even if it were valid in France? Surely this would eliminate supposed problems of people illegally using an IMCr in France. I wonder how may incidents out Irish neighbours get?

Despite what some short sighted people think, the no. 10 petition does one thing really well.....acts as a key indicator to everyone what level of support the IMCr has. I don't really care if Gordon B writes back a standard "of course we will review this..." letter, becuse it lets us know what the PEOPLE think.

Of course if the "people" can't be arsed with the IMCr then that is another matter. I suspect also that no one has really asked the other European pilots if they want an IMCr...My mate is German and did the JAA PPL (UK) so he COULD add and IMCr to it.

[IO540]

A sub-IR IMC privilege would work well in France.

Put a limit of FL110 on it, that keeps it below the major Class D base but would allow transit of the Class D airport zones.

Presently, VFR traffic is completely routinely allowed to pass through all this airspace which is for the most part devoid of traffic.

There are just a few mountainous areas where FL110 would not be enough, but not many.

And FL110 is a reasonable level for which (or below which) one could file meaningful IFR flight plans.

Mode S would be mandatory of course, together with BRNAV above FL095.

[A and C]

There is nothing that a goverment department likes more that an industry that speaks with more than one voice, they use this as an excuse to do nothing by saying that they are getting mixed messages from the industry.

So what ever happens if the IMCr is to be saved then ALL of UK GA must speak with one voice on the subject.

Personaly I think that the IMC is doomed because a "not invented here" attitude seems to persist in EASAland but as a tool to get a Europe wide class two IR the current campaign is in the forefront of putting pressure on EASA to act on this issue that they want to leave on the back burner.

The work that is being done to save the IMCr has my full support and I will be writing to my MEP but the thrust of my letter will be to in effect extend the IMCr to the whole of Europe, on safety grounds alone this is a good idea but I know that to sell it to the other states in Europe the name will have to change.

What I do find baffeling is the attitude of the European commercial pilots association, the safety issues are clear but still they stick to an intreched position dispite the evidence, unfortunatly this attitude is not suprizing to me at the moment in the UK motorcycle groups are campaigning to use bus lanes on safety grounds, reseach has shown a dramatic drop in accidents (45% drop in motorcycle /pedelcycle accidents) and yet it is the pedel cycle groups that are strongest opponents of motorcycles using bus lanes.

The only way to deal with groups with intrenched veiws is to keep using good reseach data and eventualy there position will become untenable.

[BEagle]

"A sub-IR IMC privilege would work well in France.

Put a limit of FL110 on it, that keeps it below the major Class D base but would allow transit of the Class D airport zones"

Precisely why I advocate referring to 'permitted' airspace for individual states to decide, rather than an universal one-size-fits-all decision imposed upon them!

We had this for military low level flying - the rules were different for Belgium, Holland and Germany. I once had a low level flypast to do in Belgium, but we had to approach from the east close to 'Dreilandenpunkt'. So 3 different sets of rules to adhere to in the space of 5 minutes! Not hard, just took careful preparation.

[englishal]

ALL of UK GA must speak with one voice on the subject.
That is the problem...The reason Fuji started his campaign in the first place was because it was clear that GA was not talking with one voice.

I suspect some people in other organisations are not really interested in the IMCr as it may undermine their "available IR" campaign, and so don't want to become involved. The flying helmet and goggles brigade don't really care, and no one has asked our foreign neighbours their opinion...

The only way to speak with one voice as far as I can work out is to sign up to www.ukimc.org. It must be getting some weight behind it, when the CAA on asking some advice, advise you to visit this website for the answer!!!!

[skydriller]

It is widely reported the French are opposed to the IMC rating.
It is widely reported the European Commercial Pilots Association is opposed to the IMC rating.
Why is the average French pilot opposed? I don’t know the answer. I am not even certain anyone has asked them. Are they opposed because no one has bothered to explain the rating to them?


You have answered your own question there Fuji. About half the French pilots at my club here have heard of the IMCR, mostly because there is a Brit (me) who has spoken about it at their club!! When I have asked the active pilots who like to fly places (ie not the brevet de base type) most wish they could have one here in France as a Full IR is unatainable now.

So, to sum up : Alot of French PPLs probably havent heard about the IMCR and Im sure no-one has asked the French PPLs if they think its a good idea. I recall someone posting that UK-AOPA has been in contact with French AOPA, but I dont know anyone at our club thats heard of AOPA either - The FFA is the organisation representing PPLs here in France because all Club PPLs are members of the FFA in order to fly at aeroclubs!!

Regards, SD..

[Fuji Abound]

Skydriller

Did you get my email in response to yours of a week or so ago?

[Fuji Abound]

Some excellent points.

If we want to get other countries to support the IMCR, then this needs to be the first thing we attend to, as even the best of campaigns such as your own are going to fail if our own people are, in effect, 'shooting us in the foot'.

I agree.

However, I think equally we should be cautious of accepting the anecdotal comments of a single contributor. As IO540 comments it seems hard to believe if there are this many bad eggs DGAC and the CAA would not have taken more action. I can only reiterate IO540s comments that a friend of mine (it really was him not me!) infringed a military zone in France and he received his letter from the CAA within the week!

What I do find baffeling is the attitude of the European commercial pilots association,

I also agree.

However, their only members that are probably even remotely familiar with the IMC rating is BALPA. I suspect the real issue is that no one has bothered to properly put across the case to each of their members for the IMC rating. If we can get the grass roots support of GA in the main member states behind the rating they will in turn persuade their representative organisations of the wisdom of this campaign.

This is as much about education as anything else, something which I dont think any of our representative organisations have even considered.

It is all very well to have a 5 minute say at some committee meeting but as Skydriller comments if no one is a member of AOPA in France you might just as well stand on the end of Dover pier and shout, hoping that you might be heard the other side of the Channel. :D

Precisely why I advocate referring to 'permitted' airspace for individual states to decide, rather than an universal one-size-fits-all decision imposed upon them!

I am not convinced.

EASA want harmonisation - and rightly so!

We dont fly across America having to worry about the regulations changing just becasue we cross a line drawn in the sand. No more should we in Europe otherwise EASA is a waste of space.

I would forget all the old ideas - I think EASA fully intend to sweep that all aside from my idscussions with them and rightly so as long as they have the support of pilots who know what they want and can prove the safety case.

IMC rating access to all classes, except class A, and anythong below FL110 is simple to understand and ensures the minimium of interaction between CAT and GA. Moreover, with cross border radar services and hand offs in many parts of Europe I cant believe it helps the zone services either.

[poss]

It is beyond me as to why some pilots would deny themselves access to a poor mans instrument rating that has clearly been of great aid to private pilots that have this rating. It rises situational awareness and gives you a special get out of trouble card. The skills taught in the IMC rating are definitely very valuable and I know a couple of pilots that have used this rating to its full to act appropriate and safely in fast weather changing conditions. I know from a recent airfield meeting that the rating is safe for pilots that already have it for another 4 years, in which they will be allowed to practise the privileges of the rating but past that is deemed uncertain (information from the CAA). My flying club will still offer the IMC course after this point, even if it isn't a recognised rating, as they feel it is a great assest to a pilots skills/knowledge.
Perhaps people in these other countries, as someone has previously said, just don't understand what the IMC rating is nor what it can do for safe flying. Clearly EASA have safety in mind if they wish to bring in that French basic PPL were students can take passengers up at 20hours!! (where is the logic in this I ask you!?)
I've signed the petition and have forwarded it onto everyone I know.
:ok:

[skydriller]

Fuji,

You have mail, Delayed due to work!!

SD..

[DFC]

All this talk of educating the pilot population outside the UK who do not seem to know what the IMC rating actually does is a total waste of time.

The only people who you have to convince are the national aviation authorities and their representatives at EASA level plus a few pilot organisations. Convincing a pilot from Bordeaux will make no difference but if you can convince the French licensing officer then it is unlikely that French pilots are going to object.

Unfortunately, those people know what the IMC rating is and remember the JAR-FCL negotiations and why the IMC rating go it's special paragraph in JAR-FCL. One has to agree that any national aviation authority would have grave concerns with letting pilots having as little as 5 hours IMC flight training in the aircraft loose in their IFR system.

The CAA privately also can not see a way forward for the IMC with the future european airspace and IFR operation that is comming to the UK.

Statements saying that the IMC is a poor mans IR make the position worse.

The best way forward is to accept that the IMC rating is gone. Far better to work on a PPL-IR (a qualification suitable for flying IFR anywhere) and more importantly, credit for the IMC rating holders towards obtaining that IR.

Regards,

DFC

[BEagle]

There are 2 distinct camps developing:

1. Those who wish to keep the 15 hr UK IMCR, albeit called something else, and work to get it accepted by the rest of the EU.

2. Those who wish to kill off the UK IMCR and make the 50 hr IR somehow 'easier' to attain.

Well, sorry but I cannot fall in with the second camp. Who seem to be the well-off types of the PPL/IR world, in the main. The only real way forward with Europeans is to use their own rules back at them. Such as 'proportionality' of requirements....

IMCR/Class2IR and IR should have the same core IF skill requirements. Nothing to do with navaids or airways, I mean the basic stick and rudder skills to fly in IMC following ATC`instruction as required.

However, the rest of the training must be 'proportionate' to the needs of the end-user. So, for example, an FI, who just wants the IMCR privileges to climb up to VMC on top in order to teach basic lessons, does NOT need the same en-route training as the dedicated long distance IFR cruiser.

As for holders of other ICAO IRs? They should be accepted for direct conversion to EASA IRs with no formal requirements beyond issue fee and ICAO level 4 English.

[Fuji Abound]

The only people who you have to convince are the national aviation authorities and their representatives at EASA level plus a few pilot organisations. Convincing a pilot from Bordeaux will make no difference but if you can convince the French licensing officer then it is unlikely that French pilots are going to object.

Unfortunately you are wrong.

In the UK there is hardly a pilot who would not like to see the IMC rating retained.

Most thought AOPA UK, PPL IR and the other rep. organisation would back them to the hilt.

We were all wrong on that count.

In fact the UK pilots have so far been backed by the UK IMC campaign (www.ukimc.org), the CAA and EASA - how is that for a turn up for the books.

EASA have fully taken on board the ground swell of support in the UK thanks to our campaign, all credit to them and the CAA for doing so.

In Europe the European Pilots Association didnt back the IMC. Why? Who knows, they dont reply to correspondence. BALPA support the IMC rating but they are only one member.

French pilots I feel want the IMC rating - they certainly do once they understand it.

So, Europe is a bit like here, the pilots will want the IMC rating once they know what it is about. Fortunatley many of the European pilots association will also want the IMC rating. They arent the problem. The issue is people like the EPA but if they dont even have the courtesy to reply to correspondence it will ultimately be us, the pilots, that let EASA know the IMC rating is a very good thing for Europe.

[S-Works]

I am currently working on an IMC use survey on behalf of AOPA. I will publish links to it here as soon as it goes live and would appreciate a link on the IMC campaign site.

No personal data is being collected. It will look the IP address to ensure there are no duplicate entries but otherwise will be looking at the type of flying, currency and status of IMC holders. This will enable us to build a proper case on the use and value of the IMC.

I would appreciate if this can be propagated in due course to the widest audience possible to facilitate accurate data collection.

I will post the official AOPA position on the situation shortly once I have had the wording approved.

[Fuji Abound]

Bose

As per my post on Flyer we have already put together a survey which will also be concerned with the views of pilots in Europe - it is multi langauge and will come out with our new Euro web site.

You might like to share the data rather than asking everyone to complete two surveys - it would be far more productive.

We also have a really first rate web designer on the team.

www.ukimc.org

[S-Works]

I am more than happy to share data. We will still carry out our own survey as an AOPA initiative but cross validation will be beneficial.

[Fuji Abound]

Bose

OK

Not looking to score points, but it is hardly an AOPA initiative, but as long as we achieve what we are seeking, who cares.

Given all the discussion on the AOPA forum

www.joinaopa.com/forum/viewtopic.php?t=263&postdays=&postorder=asc&start=0

has AOPA actually decided what it is they are supporting?

[ThePirateKing]

However, within recent days we have all read the posts by a French ATCO who had personally handled a number of instances where IMC holders had quite illegally entered French airspace in serious IMC and had then become a serious problem for French air traffic control staff by reason of lack of skill, currency or judgement. She was adamant that she wished to see the IMCR scrapped, and as soon as possible.

What a ridiculous position to take. I'm sure we all know people who "quite illegally" drive their cars too fast. Let's just ban driving for everyone shall we?

:yuk:

[poss]

Now whilst I understand that there is a want for standisation over europe, why should our country have to lose a perfectly safe rating that many have because a few countries don't want it. Personally I feel if it was to be implimented for the rest of Europe. the pilots in those countries been free to get it if they want, they would finally understand it's use, get one and it would be the greatest rating ever then.
Most, if not all of the private pilot community in the UK is screaming out for this rating to be saved, surely we shouldn't have to fight to keep it as there is nothing to fight about. It's been around a long time and the facts speak for themselves. It's clear that someone doesn't want to do an extra bit of paper work and are using other countries rejections as the grounds upon that. Perhaps the only way to save the IMC rating is to elect our own IMC board to deal with the issuing of IMC ratings?

[S-Works]

Posted on Flyer. This will be my last post on here on this. For more information visit flyer or the AOPA forums.

AOPA have always been clear on their position on the IMCR rating. They have worked tirelessly for this for over a year. This may not have been communicated clearly enough for some unfortunately.

AOPA fully support retention of the IMC rating in the UK. We believe that the work that AOPA, the CAA and PPLIR have been undertaking to bring the rating up to date should continue. AOPA will continue to lobby the appropriate people within government and EASA towards this aim. This will include trying to convince the Europeans that the IMC has great benefit to pilot safety. The AOPA philosophy is to 'keep our powder dry' when it comes to letter writing campaigns and involvement of MP's. There will be an election before all of this comes to a head and as such we prefer to continue to work existing channels.

We will continue to work with the regulator towards a more accessible IR.

We will not be trying to convert the IMC to a mini IR or try to get adopted as a European wide rating. We will continue to make representations towards having full and justifiable credit given to IMC holders towards an accessible IR.

I am not getting into a debate with you on this. I have offered an olive branch and am prepared to work with you. If you just want to continue to dig at AOPA you do yourself and your cause no justice.

[BEagle]

"We will continue to work with the regulator towards a more accessible IR."

"We will not be trying to convert the IMC to a mini IR or try to get adopted as a European wide rating. We will continue to make representations towards having full and justifiable credit given to IMC holders towards an accessible IR."

Actually 'we' will rule nothing out. And yes, 'we' will indeed work with CAA/EASA to ensure that a pan-EU IMC level rating is available.

[S-Works]

I am not getting into a fight with you either Beagle.

Martin was asked to clarify the position at the MWG meeting at White Waltham yesterday. I have repeated his response. His view did not contain the statement that a Pan European IMC rating was the priority. If it came about as a result of the representations to save the rating then all well and good.

Feel free to take it up with him. But then perhaps you should have paid more attention.

[Fuji Abound]

We will not be trying to convert the IMC to a mini IR or try to get adopted as a European wide rating.

Is that AOPA's official position?

Lets be clear - no Euro wide IMC equivalent rating?

If the UK is not granted a national "exception" - that is the end of the IMC rating, so far as AOPA is concerned.

Is that what AOPA asked EASA for?

[BEagle]

As usual, you have to throw in a stupid final remark, bose-x.

You really aren't helping the cause with your attitude, I'm afraid.

[S-Works]

Beagle. I am sorry but your constant know it all digs do your cause no good either. I made a statement that was the AOPA position as outlined to me and minuted in the MWG minutes. Ask Mandy for a copy or better still come to the MWG meetings. I will be coming to the Instructor group meetings staring 9th April.

You chose to try and make some sort of a point by attacking me as usual. You choose to dig endlessly. If you are so close to AOPA policy then why not out your self? I know who you are, perhaps you will do others credit.

Fuji. AOPA asked EASA for nothing. They presented a case and they will continue to do so. Who knows what the future will hold.

I have refrained from making comment about your campaign as I said I would, you clearly have an issue with AOPA for whatever reason. Chipping away to try and score points does you no credit.

AOPA do not think that the IMC in it's CURRENT format will be accepted by the Europeans. However if in the course of convincing them there is a case to allow it to stay for the UK others choose to adopt it then all the better.

[Fuji Abound]

I have refrained from making comment about your campaign as I said I would, you clearly have an issue with AOPA for whatever reason.

Bose

You are a good fella, but you are deluding yourself by constantly suggesting I have an issue with AOPA as such.

I cannot support any representative organisation that had ample opportunity before Christmas to ask pilots what they thought about the loss of the IMC rating but failed to do so. I cant support any representative organisation who allowed this to go to the wire. I cant support any representative organisations on whom it has suddenly dawned that a survey of their members and the wider audience might all of a sudden be a good idea when that should have been done many many months ago.

Do you honestly believe it was AOPA that achieved a four year moratorium on the rating at the joint EASA / CAA briefing - or might it have been because, 2,000 odd pilots, all the GA mags, and a couple of Euro MPs took time out to point out what we were about to lose?

[S-Works]

We are done on this subject. All I hear is another anti AOPA rant.

Good luck.

[derekf]

Fuji,

I have posted this here as well as Flyer forums as we seem to have threads going on in both places and you've been cross posting so I felt I'd better do the same for this specific post as I think it's fairly key.

Please take this as a constructive post as I have been giving this some thought.

I do see you having an anti-AOPA position from all your posts questioning the work that has been done. This may well not be the case, but this is the way it comes across - rightly ot wrongly.

I do support your aims to keep the IMCR, but can I please suggest that if you really are serious about doing this then you should look to get all the heavyweight backing you can to get financial assistance and also access to the appropriate people in EASA.

I would suggest, in my simplistic view of the world, that you take up Bose's 'olive branch' and get together and meet AOPA.

There's no reason why you and the rest of the ukimc.org team cannot continue working together, but why not do it with/under the auspices of AOPA.

You would be able to get their financial backing and access via IAOPA to the appropriate meetings / people in EASA.

You may believe that AOPA have not done enough, but surely if you were to get together with them and discuss this then you could find a way of moving forward with the passion you obviously have but under a large body already recognised by EASA and the NAAs

Whatever you may think of the AOPA efforts to date I believe you would be doing yourself, ukaopa.org, and all of the pilots you claim to represent if you didn't take up this opportunity and have a round table discussion as opposed to trying to do this in this forum or over on PPRUNE. I feel you need all the help you can get and as a number of other posters have put it, to get a single voice coming across would add weight to the campaign - and if it was AOPA (and IAOPA) then that's got to be good.

So please, for the sake of the IMCR, get together with AOPA, sit down, discuss your joint aims and what you've done and what you plan to do, and see if you can't do something together.

Derek...

[Fuji Abound]

Copy of my cross post reply


Please take this as a constructive post as I have been giving this some thought.


I take every post as constructive, unless past experience is inclined to make me wary. Yours are always constructive.


I do see you having an anti-AOPA position from all your posts questioning the work that has been done.

It depends what you mean by anti AOPA.

Yes I am anti AOPA on this issue because I dont agree with what has taken place - that is why I started this campaign. Before Christmas so far as the pilot community were concerned AOPA had been almost silent on this issue. If AOPA represents you and me I believe they have a responsibility to clearly tell us what they were proposing and why. I also believe they had a responsibility to conduct their surveys then. They attended the joint EASA CAA briefing as we did. So far as I am aware this is the very first meeting concerned with this issue on which they have written a detailed report. Sadly their report is as far removed from being an accurate account of what took place as to make one wonder if they were really at the same meeting.

I cant escape the evidence that it all appears to be too little too late at best.

I had a decision to make. Did I feel I trusted AOPA to represent me on this. It would have been a great deal simpler to say actually I dont care, but it seemed sufficiently important that I believe totally in our campaign and I believe another way had to be found.

So, your observation in isolation is accurate, but is it so wrong to point out that sometimes our representative bodies may have got it horribly wrong not for reasons of a silly vendetta but in the belief that if you do nothing the rating will be lost and we will all be the worse for that.

I know what I am told by AOPA members and others in emails. I know what has been written on AOPAs own forums by well respected members of our community such as Irv Lee.

The people involved in the UKIMC.org all have plenty better to do - I guarantee you, and they dont get paid, they dont get expenses, so you can guess we all feel some one needed to do something about protecting the IMC rating.

For example our expert web designer has spent all week end working on our new web site.


There's no reason why you and the rest of the ukimc.org team cannot continue working together, but why not do it with/under the auspices of AOPA.


I could not agree more.

I wrote to both Bose and AOPA expressing my wish that we co-operate.

I am afraid they (and I mean AOPA not necessarily Bose) saw things differently.

[DFC]

If the UK is not granted a national "exception" - that is the end of the IMC rating, so far as AOPA is concerned.

Is that what AOPA asked EASA for?

I hope not because it would be rather stupid to set out on a programme to properly harmonise pilot ratings and licensing requirements across the EU and get rid of the major flaw with JAR-FCL - local interpretations and local differences only to insist on establishing local differences.

Everyone has to remember that national aviation authorities are not swayed by the number of pilots wanting to do something.........they will dig their heals in and not budge until they can be assured that safety and thus their credibility as a regulator is not going to be comprimised.

AOPA and others should have plenty of experience of that position - there are thousands of pilots in the UK with the same ideas on GPS as IO540. If the popular position was what regulators went with then we would have had mandatory GPS and GPS approaches in the UK years back.

That is an example of where sheer numbers of pilots requiresting something does nothing to speed change. The same thing applies with the IMC rating. Other national aviation authorities are going to look at what would happen if they had IMC rating holders active in their airspace and more importantly the posibility of something happening and their public / government minister turning round and saying that the introduction of the rating was a bad idea while beating them round the ears with ICAO Annex 1, the FARs or whatever comes to hand.

The proposal has to be European wide and has to be a rating that will ensure safe enroute IFR flight in all classes of airspace. The idea that the flying instructor getting on top to teach a lesson needs only limited IFR training is not a credible position because they can find that when they wish to descend the weather is below minima and they have to divert.........and they may have to divert to a major international airport in Class A airspace.

First question from a foreign NAA regarding the IMC rating is........if it is so safe why do you not permit IFR flight on the airways and at a major international airport?........What happens when Heathrow is the best available IFR alternate?..........If the Airways are there for enroute IFR flight why are enroute IFR flights excluded and even discouraged from flying along the alignment but just below the base?

One also has to overcome the simple position that most NAA's (including the FAA) as well as the ICAO standard position is that an IR is the minimum qualification for IFR IMC flight. That is the wall that is going to have to be broken down. Claiming that the safety benifits of the trainng will not work because the training can be provided to anyone without them having to be given some poor man's IR - they simply get the safety benefits. How do they then keep current? - ask the majority of IMC rating holders and the answer is they don't.

It is unfortunate that this is on the table at the same time as a growing case for the rethinking of the IMC training element of the PPL course. I remember the arguments across Europe when it was implemented and the agruments that it would give the basic PPL too much confidence in IMC flight and that the simple - enter cloud and you'r dead message will be lost are still ringing in my ears. The heli guys have gone down the road of removing the IMC training element and chances are that the fixed wing position will change slightly.

Now if pilots and NAA's across Europe are starting to push for the 180 deg turn in cloud requirement to be removed from PPL trainig then how can you expect that the safety benifits of the IMC rating will sit with their thinking?

Regards,

DFC

[Fuji Abound]

Everyone has to remember that national aviation authorities are not swayed by the number of pilots wanting to do something.........they will dig their heals in and not budge until they can be assured that safety and thus their credibility as a regulator is not going to be comprimised.

25,000 IMC ratings issued,

40 years experience,

No evidence of issues with problems with commercial traffic,

One case of CFIT in 40 years.

I think that is a pretty solid case. Of course we and they could ignore the evidence. Fortunately they have not.

[englishal]

Unfortunately, I believe that unless we can get a Eurowide "mini IR" (Call it eIMCr or IWR) then the IMCr is gone.

My feeling is that we stand virtually no chance of getting an exemption to allow it to be used in the UK only, so it has got to be expanded to the rest of Europe in some form or another, with European support. And unfortunately it appears AOPA and PPL/IR do not support a Eurowide rating because they believe (or at least some in their executive committees) that it will undermine their attempts at an "easily obtainable" IR. They will of course support retaining the UK rating, if they didn't they couldn't justify taking our money in subs....but I suspect they know full well that there is not much hope.

Cutting a bit of ground school does not make the IR obtainable, especially with Euro training prices (cost is the real issue). The only REAL way to get an obtainable IR is to cut costs, which means having a 2 stage process with reduced hours for the first stage, upgradeable when required.

I'm not sure why AOPA are running and "IMC usage" survey? Why do they need to do that, why not just look at the statistics and see how many were issued?

[FullyFlapped]

Bose,

Since the start of this debate, I have wanted a clear understanding of the AOPA position. You say :-

AOPA fully support retention of the IMC rating in the UK. We believe that the work that AOPA, the CAA and PPLIR have been undertaking to bring the rating up to date should continue. AOPA will continue to lobby the appropriate people within government and EASA towards this aim. This will include trying to convince the Europeans that the IMC has great benefit to pilot safety. The AOPA philosophy is to 'keep our powder dry' when it comes to letter writing campaigns and involvement of MP's. There will be an election before all of this comes to a head and as such we prefer to continue to work existing channels.

We will continue to work with the regulator towards a more accessible IR.

We will not be trying to convert the IMC to a mini IR or try to get adopted as a European wide rating. We will continue to make representations towards having full and justifiable credit given to IMC holders towards an accessible IR.


So thanks for that. Now, will you please tell me how this position was arrived at ? Was it via a vote of members ? Because (as a member) I don't recall being asked about any of this ?

Apologies if you've covered this elsewhere !

[S-Works]

FF. AOPA is not parliament. It is a company that provides a service to a membership just like a Gym for example. It is not a members owned organisation like leicester aero club for example or others.

It has a number of working groups that are made up of members, the MWG, the Instructor Committee, the schools etc. All AOPA members and with few exceptions all VOLUNTEERS.

Discussion and solution planning are worked on by committee and subject to vote. Martin then acts on this on our behalf, with the support of the various working groups. He is not some lone cannon deciding what he is going to do unilaterally. He sets great stock on what we the members have to say.

If anyone is unhappy that a committee of members is acting on there behalf then they are welcome to volunteer at any stage to participate. We are actively seeking volunteers to act as airfield reps. This role is to be a focal point for the AOPA membership feeding views and opinions back into the organisation. So if you want to be asked about something personally rather than be represented by your peers then please feel free to volunteer your services. We would be delighted to have you onboard. 1 volunteer being better than 10 pressed men and all that.

I hope this helps.

AL, the reason we are running a survey is to gain real statistics on what is a very emotive subject. There have been 25,000 IMC issued. 10,000 of those to PPL. But we do not know how many are current and the CAA can't get the information. It is all well and good saying that there are 25,000 issued of which 23,000 have medicals but how many are actually valid and in current use. 1 or 1,000 or 10,000? Carrying out the survey allows us to put REAL statistics across about the number of current IMC's, the type of flying they are being used for. This will help create a case that can be put across at European level based on fact not emotion.

[Fuji Abound]

It is not a members owned organisation like leicester aero club for example or others.

Who owns AOPA?

If anyone is unhappy that a committee of members is acting on there behalf then they are welcome to volunteer at any stage to participate.

Who decides who is put forward to the commmittee, and who elects the committee?

[rustle]

AL, the reason we are running a survey is to gain real statistics on what is a very emotive subject. There have been 25,000 IMC issued. 10,000 of those to PPL. But we do not know how many are current and the CAA can't get the information. It is all well and good saying that there are 25,000 issued of which 23,000 have medicals but how many are actually valid and in current use. 1 or 1,000 or 10,000? Carrying out the survey allows us to put REAL statistics across about the number of current IMC's, the type of flying they are being used for. This will help create a case that can be put across at European level based on fact not emotion.

Good post bose.

If you need any assistance collecting or collating this data give me a shout: I'm always happy to assist a worthwhile initiative, not so keen on helping folk on their ego trips ;)

[S-Works]

Quote:
It is not a members owned organisation like leicester aero club for example or others.
Who owns AOPA?

Quote:
If anyone is unhappy that a committee of members is acting on there behalf then they are welcome to volunteer at any stage to participate.
Who decides who is put forward to the commmittee, and who elects the committee?

AOPA is a Limited Company.

All current issues that are facing aviation where known are put towards the relevant committees and discussed. Members write to AOPA with issues, government and regulators interact continuously with the organisation. AOPA have been operating in this way for many decades.

The 'committee' is not elected. Any member may volunteer and sit on any of the working groups if they have relevant skills to offer. The membership of the working groups is fluid as members commitments change.

If anyone wishes to become involved with the MWG please contact me. It is an open forum and new members are welcome.

[FullyFlapped]

Bose,

Thanks for the detail. My initial reaction was to be a little unhappy that a bunch of unelected people who I have never even met can claim to represent my views as a member (actually, that should be 'customer' really, since 'member' implies share ownership if AOPA is a Ltd company). However, if making sure your voice is heard on something you feel deeply about is as easy as volunteering, then I guess it's down to each of us to either get stuck in or "get off the pot" by ceasing to pay subs. Fair enough. I still don't understand this apparent lack of transparency or unwillingness to publish working group ... err, "workings" ... but perhaps that's something else that could be changed from the inside.

Rustle,

Good post bose.

If you need any assistance collecting or collating this data give me a shout: I'm always happy to assist a worthwhile initiative, not so keen on helping folk on their ego trips You know matey, if you keep this up, your nose is going to stay that colour permanently ... :ooh:

[Mixed Up]

Bose says


AOPA is not parliament. It is a company that provides a service to a membership just like a Gym for example. It is not a members owned organisation like leicester aero club for example or others.


AOPA UK's web site says


The Association is a not for Commercial Gain organisation, owned and operated by its members.


I'm mixed up.:confused:

[S-Works]

There is no secrecy in AOPA working group activities. Everything we do is open to discussion and review.

I think you are confusing the regulator working groups that AOPA members volunteer to sit on. These are are government, regulator etc and there are rules applied to them that we have to agree to. This often means that we are not permitted to disseminate directly the content of the meetings. As with all working groups doing things over a period of time things change, views change etc, and so often it is better to get to the end of the process and 'keep your powder dry' before making announcements of the process.

Generally speaking we try to speak publicly where possible about the goings on but where restricted there is nothing we can do. As a citizen I am sure you could make appropriate requests under the FIA or whatever the Europe equivalent is for the EASA meetings but really at the end of the process it all comes out into the public domain anyway.

So please understand there is no veil of secrecy around any of the AOPA activities.

[FullyFlapped]

Mixed Up,

I haven't pulled their accounts for a look yet, but it's perfectly possible for a company to be intentionally non-profit making. As to being "run by its members", well, that's probably true, if a couple of its shareholders also sit in executive positions on its board - although I'd agree the wording might be a little misleading, as it implies some form of group concensus management by its paying subscribers ! Still, I think the way it works has been covered well enough above.

[Fuji Abound]

The 'committee' is not elected. Any member may volunteer and sit on any of the working groups if they have relevant skills to offer. The membership of the working groups is fluid as members commitments change.

I rather thought AOPA was a limited company, limited by guarantee since it has no shareholders and no shareholding.

I also thought its constituition was determined by its Memorandumn and Articles of Association which determines how directors may be appointed and replaced.

I wonder how many of its members know how this process works?

Why is this relevant?

In order to make a decision whether you are happy with the representation you are receiving you should base your decision on the facts.

If you and other shareholders dont like what your directors are doing and if the company is controlled by its shareholders you can sack the lot of them, if you dont like what your club is doing you can stand for election to the governing committee once a year.

[S-Works]

FF is completely correct and is how AOPA operates. That is the reason so much work is done by volunteers.

Anyone is free to volunteer and AOPA welcomes all offers. Through the hard work and efforts of these volunteers GA has benefited significantly for decades.

The accounts of the organisation are freely available to members. Any profit made on merchandising etc is poured straight into the organisation. There are no leaches taking money out of the organisation. What goes in is used to represent you the member. I go through the accounts every year and am satisfied with the transparency and use of the funds that I contribute as a member.

There is nothing cloak and dagger about the organisation

[S-Works]

Yet again Fuji, I don't see your point all I see is noise from you AOPA bashing and stirring up.

The board of AOPA is made up off a line of distinguished and experienced aviation experts. If any member feels they are better qualified than the constitution allows for them to stand for election to the board.

I have already explained how the working groups operate.

I am a member, AOPA will continue to receive funding from me as I am satisfied with the operation.

Not a lot more to say really other than to say that at least AOPA is a transparent organisation with named individuals who do not hind behind anonymity. Neither do they engage in questioning the constitution or financing of other 'representative' groups.

[Fuji Abound]

Bose

I have no idea why whenever questions are asked about how AOPA operate you resort to these accusations.

I rather thought this was a discussion forum.

Personally, I think there is an interesting discussion to be had about how AOPA operate particularly as they are the lead representative organisation for GA in this country.

I wonder how many people on these forums can explain AOPAs constituition to us?

I wonder how many AOPA members see their accounts each year?

[S-Works]

Everything that you need or want to know about the constitution and operation of AOPA is available from AOPA. When I became a member all of that information was supplied to me.

The accounts of the organisation are freely available to any member at any time and for a non member if they choose to apply for them from the relevant authorities.

I see no further benefit in discussion on these forums.

[FullyFlapped]

Fuji,

The difference here is that we are NOT shareholders of this limited company, and so we have no powers to sack anyone. We either choose to continue to buy its product or not, and at least it seems that there is the option of volunteering to help to define the "product".

Again, I think its website is a little misleading, but at the end of the day, I joined not because of the IMC, but because I understand that AOPA does good work in other areas.

I don't like monopolies, but if AOPA was the only game in town for the regulators to talk to "GA", it's hardly surprising that they've acquired this quasi-official "voice of GA" status. There is always a danger in these circumstances that organisations in their position actually start to believe that they alone have the authority to speak for whoever they claim to represent, whether the punters want this or not. I'm not saying this is so in the case of AOPA, because I don't know, but this is where campaigns such as your IMC one often bring immense value outside of their stated aim by reminding every one that there are other views which must be considered, and other voices which must be heard.

This, aside from the fact that I agree with its aims completely, is why I wholeheartedly support the IMC campaign.

[soay]

Who owns AOPA?
That's an interesting question, which prompted me to try to find out. According to the AOPA web site (http://www.aopa.co.uk/scripts/background.php):
The Association is a not for Commercial Gain organisation, owned and operated by its members.
and
AOPA ensure the view of pilots and aircraft owners are heard in all the appropriate places both locally and Internationally.
As a member, I feel that any representation is in a patrician style, whereby unelected representatives decide what's best, and only communicate with their membership retrospectively.

I think AOPA's inability to use their website to keep their members abreast of the issues they are tackling, and to post surveys to obtain feedback on the positions they should adopt does them no favours. You've only got to look at the AOPA US website to see how it should be done. An indication that AOPA US understand the most fundamental aspect of all is the following statement that they make here (http://www.aopa.org/info/history.html):
In times of change it would have been easy to adopt a wait-and-see approach to setting organizational goals, but AOPA elected not to stagnate. Instead, because the association understands that there is strength in numbers, it decided to strive for membership growth.
I don't suppose it went about achieving that aim by alienating current and possible future members.

[Mixed Up]

FF: Thanks. I am aware of various forms of 'not for profit' organizations, but in this case Bose says it is not owneed by members and AOPA UK's web site says it is.

The posts are coming in faster than I can accommodate them, but I've just noticed that Bose says it is a limited company. This morning I checked and this is not the case. The following organizations are "not trading" and I can find no reference in Companies House to any other legal entities relating to AOPA UK:

AOPA Ltd
AOPA (UK) Ltd
Aircraft Owners & Pilots Association Ltd

I don't suggest there's anything cloak & dagger about this but Bose' comments don't sqare with the other facts and it leaves me mixed up. But this has been nothing but passing curiosity for me, so I'm not going to get into a ding-dong about it. I'm confident AOPA UK is not a corrupt organization.

[S-Works]

FF: Thanks. I am aware of various forms of 'not for profit' organizations, but in this case Bose says it is not owneed by members and AOPA UK's web site says it is.

No I said it is not owned in the way that a club like Leicester is. Before misquoting me read what I wrote. To join Leicester Aero Club, you have to be proposed and seconded and go before the committee. You become jointly liable for the debts of the club to a set limit and if you want to leave the club you must formally resign. The club is run by a council of management that is elected formally every year by a majority vote of the membership.

The way AOPA is constituted you can join and leave at your discretion etc.

The AOPA Company is:

British Light Aviation Centre Limited.
Registered in London No. 874355
Registed Address: 50a Cambridge Street,
London
SW1V 4QQ

[Fuji Abound]

Mixed Up

I think you will find AOPA trades as the "British Light Aviation Centre Limited"

The company is limited by guarantee - a very diffeent animal from the vast majority of limited companies which are limited by share capital.

As the company does not have any members the company is controlled by its M and As.

I am sure Bose can tell us how its Board of directors is appointed.

[S-Works]

Actually its the British Light Aviation Centre Limited trading as AOPA.

If any AOPA member wishes to discuss further the constitution or any other AOPA question then they are welcome to discuss them on the AOPA forums. Open to all AOPA members.

http://www.joinaopa.com/forum/viewforum.php?f=2

We also have a specific AOPA discussion area on the flyer forums.

None of this discussion around AOPA has anything to do with the IMC rating so I think this subject is now done.

[421C]

I have no idea why whenever questions are asked about how AOPA operate you resort to these accusations.

I rather thought this was a discussion forum


Fuji,

As an ordinary member of AOPA my observation is that you seem to post an awful lot of direct accusations and various insinuating questions about AOPA - and then act surprised when people "discuss" those pretty vigorously. I rather think Bose is being very restrained (!).

You seem full of accusations that AOPA didn't publish stuff and didn't consult its members.

As I understand it, and as Bose has pointed out, none of the deliberations of the Industry Working Groups were open for discussion or consultation. This happens after they publish their results some time this year. AOPA has been working hard to my entire satisfaction as a member on these.

Now, since you have been happy to critique their approach, please tell me what yours would have been, presumably either
A. to refuse to participate in any Working Group (and therefore be shut out of the whole process)
B. to agree to participate but then breach the agreement your participation was conditional on, and disclose/publish/consult on confidential work-in-progress?..and deservedly be thrown off the Working Group

Which one? A or B? Tell us how this would have achieved more? What has been achieved to date I credit to the good intentions of EASA, the CAA and AOPA in working on this.

AOPA was doing good work when I learned to fly as a teenager 25years ago. In those last 25 years, 90% of UK PPLs have never bothered to join. AOPA has done good work that helped all of them. If more people had joined and fewer had the "I don't like X about it" (where X is any one of a myriad of personal bees-in-bonnet about AOPA) perhaps GA would be in a stronger position than it is now. I think AOPA will be around in 25 years time, but the next couple of years are critical to the EASA process. It needs the most support it can get. It will never be everyone's perfect representative - that would take as many organisations as there are members. It will never have the resources to satisfy the internet era's appetite for communication. But neither do I see any other EASA accredited "industry representative" for mainstream private GA working for us (as opposed to EAS work for Sport/Recreational GA).

I'd prefer to see campaigns working in parallel and wish them all well. I thought your petition couldn't do any harm and perhaps help raise awareness. It could potentially do a lot of good by the very fact that it is "outside the system" and therefore is free to do stuff which would compromise the credibility and good relations of someone like AOPA who depend on mutual respect with the regulators. However, your input into saving the IMC-R seems recently to consist of posting a lot, bickering about other representative organisations and trumpeting your own. Since you are not shy about giving feedback to representative organisations, I am sure you will appreciate this feedback.

[dublinpilot]

Fuji,

You're getting distracted again from your good work, with this AOPA bashing! You were doing so well in avoiding it!

Bose has set out AOPA's position fairly clearly. They are campaigning for a retension of the IMCr in the UK only. (I was sure I read elsewhere, perhaps Flyer, that they were campaigning for it's expension across the EU, but Bose has set us straight on that.)

Now a member of AOPA can sit happily and pay their subs if that's what they support, or they can make their views known to AOPA if they don't agree with that aim. They can even get involved directly and try to change it from within if they wish. That is their choice. Those of us who aren't AOPA members have no right to tell a private members organisation what their aims should be.

Let's leave them alone and not do any more AOPA bashing, and concentrate on our own aims ;)

I understand that AOPA offered to meet to try to work together, but your aims and theirs weren't compatable. So be it.....lets get on with building the IMCr campaign, and leave AOPA to theirs. You have done amazing work todate, with some spectacular results.....let's not get distracted now ;)

dp

[Fuji Abound]

Now, since you have been happy to critique their approach, please tell me what yours would have been, presumably either
A. to refuse to participate in any Working Group (and therefore be shut out of the whole process)
B. to agree to participate but then breach the agreement your participation was conditional on, and disclose/publish/consult on confidential work-in-progress?..and deservedly be thrown off the Working Group

FCL001 are committee proceedings of EASA. A number of people have asked what stance AOPA took at these meetings, including such respected commentators as Irv Lee (see the thread on AOPA's own web site). Disclosing the minutes of a meeting is quite different from reporting to your members the essence of what took place and where you stood. If I had been involved and EASA had forbidden me from doing this much then I would have called foul. Of course that is not EASAs position.

Actually I hate disseminating AOPA's involvement in this matter but I do think it is important that we all understand where they stand because otherwise we may think they are supporting our position when they are not - is that so unreasonable?

Dublinpilot

Very sound comment. I agree and I have tried to stick to that line but see above.

Personally I also object to some of the information handed down that paints a biased picture.

Actually we offered to work with AOPA. There was no attempt on their part to see how we might work together. The fact that our ultimate aims might be different I don’t think is relevant to the wisdom in co-operating.

Bose has been good enough respond to our request we co-operate and he has my respect for doing so. However, so far as I am aware Bose is not on the executive committee. It would be inappropriate to work with Bose unless AOPA’s executive committee gave their blessing.

Anyway, I agree back to the task in hand. The discussion has however been useful because thanks to Bose we all have a better understanding of exactly where AOPA sit on this issue.

[S-Works]

The executive committee may not be prepared to deal with you directly, however I am and will take whatever needs to be fed into them for decision. Unless of course you ego does not allow you to interact with a mere underling?

However as we do not understand your ultimate aims you are probably right cooperation may not work but the offer has been made.

You have not answered 421C's question, you have just side stepped the question. He explained clearly the process and asked you what you would have done. My reading of your answer is that you would have taken option B.

The reason that AOPA as an organisation have the trust of these people is that AOPA are prepared to play by the rules.

[Fuji Abound]

The executive committee may not be prepared to deal with you directly, however I am and will take whatever needs to be fed into them for decision. Unless of course you ego does not allow you to interact with a mere underling?

Come on Bose, you cant have it both ways, on the one hand you praise AOPA for playing by the rules (and rightly so) and on the other want you and I to play by different rules. I dont do that.

You have not answered 421C's question, you have just side stepped the question.

You know I havent. The question is hypothetical as I havent seen the agreement AOPA signed. Therefore I dont know their terms of reference.

Do you?

If the agreement says AOPA is prevented from summarising the issues discussed and the stance that AOPA took, then I would have refused to sign the agreement on the basis that it was unreasonable. If on the other hand the agreement said AOPA was not entitled to publish the minutes of the meeting (but inter alia could summarise the issues discussed etc) then I would have signed the agreement and played by the rules.

[S-Works]

Of course I know the terms of reference, I was present. The terms are simple, as any working group is a living process that the output is not made public until it has been reviewed and all parties sign off the content. This no different from any working group in my day job.

You can't change the terms of reference to suit your self, they are stated at the start, if you don't want to participate you loose your place at the table. It's not complicated.

The question asked by 421C was not theoretical it was an accurate reflection of the situation and based on fact. So answer the question.

Offering to assist you is nothing to do with not playing by the rules. I am perfectly within my remit to communicate with you and take that communication back into Martin for decisions. If you think that I am not high enough up the chain then fair enough but there are no rules being broken. It is perfectly clear to me that you are looking for excuses not deal with AOPA but rather concentrate on rubbishing them. Notwithstanding I will leave the offer open.

[derekf]

Fuji,

Please please please, for the sake of the IMCR, swallow your pride and see if you can't get somewhere by having a meeting with Bose (and/or whoever else at AOPA) to see if you can't get this working.

It really does look like schoolground "my gang is better than yours" which does all sides no good whatsoever.

If you really care about saving the IMCR then put personal feelings behind you and sit down and talk (and I do mean sit down as opposed to any online discussion initially where things can be taken out of context).

PLEASE !

[Fuji Abound]

Of course I know the terms of reference, I was present.

At EASA FCL001?

until it has been reviewed and all parties sign off the content.

Which is when?

I am perfectly within my remit to communicate with you and take that communication back into Martin for decisions.

I never said you were not. What I tried to politely imply is I have no idea what authority you have in AOPA or not. If AOPA want to work with us then I would expect to agree the formula with a member of their executive committee so that there was no misunderstanding. I appreciate you might be happy to go about things a different way but we are not. If you beleive that is an excuse that is up to you.

[Fuji Abound]

Derekf

I really do care.

If a member of AOPA's committee wish to 'phone me, or they wish me to phone them they only have to say so. Martin has my email address and we have already exchanged correspondence.

[derekf]

Fuji,

If that's the case why don't you take up Steve's offer of talking about this to allow him to feed back to AOPA as a way of getting to them?

Surely it's got to be worth a go if you really do want to use (or try to use) all possible resources in your campaign.

What have you got to lose?

[rustle]

Fuji,

What have you got to lose?

All credibility?

Oops, too late. :D

[Fuji Abound]

derekf

If that's the case why don't you take up Steve's offer of talking about this to allow him to feed back to AOPA as a way of getting to them?

I have. I have not yet received a reply.

I have said on many occasions I would welcome working with any other organisation. Inevitably each needs to establish where they stand. I think we have been quite clear. This debate had been useful in trying to establish where AOPA stand. However they are a large organisation.

As Bose has quite properly said on a number of occasions he is entitled to express his own personal views on this forum - and he very much is, as well as AOPA policy. Which is which, is sometimes not clear.

AOPA are reported here to not be pursueing the wider adoption of the IMC rating in Europe. However, elsewhere it is reported that their CEO has "asked
that the rating be retained and expanded throughout the European community". Now both cannot be true.

AOPA policy may well have changed over the last few months, but if you support the former, but it is not longer the case as we are now told, is it not unreasonable that you should be aware that AOPA do not support expansion of the IMC rating throughout Europe?

We are campaigning for its wider adoption throughout Europe.

[derekf]

Fuji,

I'm glad you've said you will meet with Bose and look forward to him replying to you and setting that up.

We are campaigning for its wider adoption throughout Europe

This does appear slightly different to your original ideas (or what I thought htey were) and the header on your website "The Campaign to Save the UK IMC Rating".

If you have expanded your ideas I personally feel that's the wrong thing and that you should focus on the UK rating, however that's up to you to decide.

But, your top priority must be to save the UK IMCR and any expansion ideas should be secondary IMHO

[eltonioni]

In the words of that famous telegram...

PLEASE PLEASE PLEASE STOP

It seems to me that a few heads need knocking together, and a few ego's deflating - no names no pack drill. Squabbling between people who are trying to achieve the same thing is a simple yet pointless waste of energy so can I try to move it on a bit?


Bose, does the CAA really have no way of knowing how many new IMC's or revalidation's it has issued in the last 25 months?

[hugh flung_dung]

eltonioni, they will know the number of new issues but not the number of revals or renewals - but if they REALLY wanted to know they could always ask the examiners because we are required to keep records.

HFD

[eltonioni]

I'm genuinely flabbergasted that they don't require FI's / examiners to inform them. I assume therefore that they have no idea how many active (or at least potentially active) pilots there are in the UK?

Does no portion of the revalidation fee go to the CAA?

[hugh flung_dung]

They presumably get the info about active pilots from medicals and the type/rating/class form - it's just the IMC renewals that they don't get notified about.
(And I'm sure you didn't mean to suggest that the CAA should start charging for processing renewals and revals:eek:)

HFD

[S-Works]

eltonioni, there is no revalidation fee for an IMC. Any money you pay over is for the examiner. No records are sent to the CAA for a revalidation.

Contacting the examiners may be one way but it one hell of an exercise to reconcile the examiners records with the CAA records and one could ask if there is motivation on the part of the CAA to that sort of exercise.

The AOPA survey is probably going to be the best route for this data gathering.

[FullyFlapped]

Rustle :

All credibility?

Oops, too late.
Pot to kettle, over .... :ugh::ugh::ugh::ugh::ugh:

[S-Works]

AOPA had hoped that they could convince the rest of Europe to not only allow the IMCR to exist but to even expand it to other European users. This is unlikely to happen so AOPA are concentrating on the preservation of the IMC rating for British pilots and a fully accessible IR for all.

I am now aware of the communication that Fuji has had with the CEO and it has been agreed that he will contact Fuji and ask him to coordinate with me as the official representative. I am fully prepared to do so as I have stated.

As I am now going to be handling this in a representative capacity it will be wise for me to no longer enter into debate with Peter over the activities of AOPA or debate my personal view on the issue. I would therefore request that if he genuinely wishes to work in a collaborative manner he refrains from further AOPA trashing.

AOPA represents it's membership, if that matches the needs of non members then they are getting something for free, if it does not then so be it. If the membership wish to makes changes to policy they just have to contact the CEO, any member of the executive or a member of the working groups and the matter will be reviewed.

I would like to thank everyone for there patience in staying with frequently has amounted to garbage but can assure that AOPA are acting with the best interests of the AOPA membership at heart.

[DFC]

Contacting the examiners may be one way but it one hell of an exercise to reconcile the examiners records with the CAA records and one could ask if there is motivation on the part of the CAA to that sort of exercise.

Not very hard at all. Very simple actually.

Every examminer who tests for the IMC can check their logbook for the previous 25 months and list the IMC renewals they did which were passed.

Add to that list the initials they passed and there is the total IMC population.

Ask those holders for deatails from their logbooks of IMC flights and imstrument approaches in the past 4 or 8 weeks and you have the list of current IMC rating holders.

-----------

As many people as possible should join AOPA. That ensures that if there is an expensive legal challenge to the end of the IMC rating taken all the way to the European courts where it fails, the more members there are that can share the financial guarantee that every member is liable for the better.

How much of your savings are you betting on the IMC rating? AOPA may be betting more than you would like if you are a member.

Ask Dublin Pilot what happens to AOPA when they get involved in stupid legal battles.

Regards,

DFC

[Lima Juliet]

Fuji

I wish to contest the following...

One case of CFIT in 40 years

Surely, CFIT indicates a navigation or spatial-awareness error rather than a lack of skill to fly in IMC? I propose that there have been very few IMC holders that have lost control of their aircraft whilst flying IMC - I count 1 accident over the past 30 years excluding a couple of accidents involving pilots operating "illegally" on the continent. I propose that this illustrates the safety benefits better.

By the way, both you and Bose-X need to stop bickering as you're playing into the hands of the "jumbled message" brigade! ;)

LJ

[FullyFlapped]

Bose,

DFC is suggesting that AOPA members are subject to an unlimited financial guarantee in respect of AOPA actions.

Is this correct ?

[hugh flung_dung]

Bose: "Contacting the examiners may be one way but it one hell of an exercise to reconcile the examiners records with the CAA records and one could ask if there is motivation on the part of the CAA to that sort of exercise."

Why would you or the CAA need to do any reconciliation? It would be a very simple matter for either the CAA or AOPA to contact the relatively small number (guess: around 150?) of FEs and get accurate info about IMC tests; a voluntary survey will take longer and is unlikely to produce accurate data.
Presumably all you need to know is the date and CAA reference number for all IMC tests performed over the last 2-3 years.
The only thing an FE survey wouldn't catch are the people using UK CPL privileges, but your proposed survey is unlikely to catch them either.

HFD

[DFC]

A problem with asking pilots is that an unknown percentage are going to lie.

A fact of aviation life unfortunately. Ask a pilot if they hold a current IMC rating and they will answer Yes. Check their logbook and in many cases you will find that the last proper IMC flight was their renewal test.

Getting the data from the examiners is the only 100% credible answer.

If this is going to take years to come to a head then the CAA can bring in a paperwork requirement for renewals which will track holders of the rating and record the amount of IMC time, instrument approaches etc logged since previous renewal. Can't see any examiners objecting if they actually support the IMC rating idea.

---------

Spoke with a French pilot this morning. His opinion was that if the UK made all the lower enroute airspace class E and D thus allowing the IMC rating holders access it or removed the airspace class restrictions from the rating it would look better in places like France where those are the lower airspace classes. Otherwise it is seen as a "we want you to take on our rating that we don't let people use in our system."

Regards,

DFC

[S-Works]

Bose: "Contacting the examiners may be one way but it one hell of an exercise to reconcile the examiners records with the CAA records and one could ask if there is motivation on the part of the CAA to that sort of exercise."

Why would you or the CAA need to do any reconciliation? It would be a very simple matter for either the CAA or AOPA to contact the relatively small number (guess: around 150?) of FEs and get accurate info about IMC tests; a voluntary survey will take longer and is unlikely to produce accurate data.
Presumably all you need to know is the date and CAA reference number for all IMC tests performed over the last 2-3 years.
The only thing an FE survey wouldn't catch are the people using UK CPL privileges, but your proposed survey is unlikely to catch them either.

HFD

A possible solution but still only going to give me renewed numbers which is not much use in isolation.

DFC makes sense over the long term of logging more data during the renewal but that means it will take me at least 2 years to get any data to work with that is representative. Good for the long term as it would allow me to cross check what we gather now.

What I am looking for are those numbers and the actual usage of the IMCR, hours flown etc. We could have a thousand pilots who are renewed but only ever use the rating at renewal. This will skew the results. To build a genuine safety case I want to be able to say for example that there are 2000 IMC holders who are currently renewed, of this number x% use it for xhrs per year flying x number of approaches. The primary uses of the IMCr are x. Tied with the safety record this would provide compelling proof that the rating gives clear benefits to UK flyers. This data could then be compared to data collected as suggested by DFC and give us a quality check.

[hugh flung_dung]

It looks like you need to take a multi-faceted approach:

Get the CAA to ask FEs to send a form back when doing IMC tests (DFC's suggestion). Recorded details could include CAA ref number and date, plus approaches and IMC hours flown since last test (I think for most people you'll find a very small number of approaches).
Contact examiners and ask for their historical test data. If you were prepared to wait you could even get this data at the 3-yearly FE renewals.
Instigate a pilot survey (although I'm dubious that this will yield data that could be regarded as authoritative)

You then need to try and capture all the times when someone had the ability to be VMC on top between holes when otherwise they would have been scud-running, when they were prepared to fly an approach but didn't needed to, and all the UK CPLs.

Personally I would get as much hard data as you can (first 2 bullets) and then use the rest just as unmeasurable safety benefits.
HTH Good luck!

HFD

[DFC]

Don't mention VMC on top.

VMC on top is something that every JAR-PPL holder (except UK) can do. EASA harmonisation will dispense with the UK restriction in this regard and thus VMC on top has nothing to do with instrument flying it is simple VFR flying.

Having an IMC rating means having the legal ability to complete IFR IMC flights and every thing about it must concentrate on the privileges of the rating - IFR IMC flight.

The fact that IMC rating holders like the IR holders prefer to cruise in the sunshine has nothing to do with the rating. Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.

I would caution gathering too many statistics that will be used as a good example of why the IMC rating can not be continued with. Do you really want to prove that the majority of holders do not use the rating or that those that do are not current in the strict meaning of current?

Gathering data can help and at the same time hinder your objectives.

Regards,

DFC

[dublinpilot]

Ask Dublin Pilot what happens to AOPA when they get involved in stupid legal battles.


For the sake of clarity, in case anyone takes that as a slur on myself, what DFC is refering to is a case of infighting in AOPA-Ireland which eventually ended up in the courts, and basically brought AOPA-Ireland to an end.

I have never had any involvement nor connection with AOPA-Ireland.

dp

[englishal]

Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.
What are you talking about DFC, are you trying to say that a flight would only count if in actual IMC for the entire duration? Or are you saying that the flight only counts if it has been planned as an IFR flight,even though you could be in the sunshine on top?

The problem is that 99% of airline flights for 99% of the time fall into this later catagory. I have flown IFR on gin clear days, and VFR on 3 mile vis days. I plan all my long distance VFR flight with respect to IFR, so IF I can't continue VFR, I can carry on IFR. I do this in America too, the only difference there is you need to get a clearance to carry on IFR. Anyway the alternate can also be your starting destination can it not?

One flight I did recently started out VFR and I became IFR when the cloudbase got in my opinion dangerously low. So I climbed up to 4500 and continued IFR in IMC to the destination and shot the ILS. Does this count according to your rules or not?

It is getting too complicated. Just see how many IMCr's are within their two year validity date at the time of the survey, that should be enough to provide reasonable stats of how many people "care" about the IMCr.

Perhaps we should poll flying clubs too and find out how the lack of IMCr training may affect them? Surely that is of interest too...

[DFC]

Sorry, let me repeat what I said with emphasis;

Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.

In otherwords do not gow down the road of a VFR over the top rating and confuse what IMC IFR flying involves.

If you depart on an IFR flight and enter IMC at 600ft then you must allow for the posibility that you may not be visual again until at your minima at the alternate.

Remember that one argument for retaining an IMC level rating is the expanse of poor weather that frequents the UK. You can not use the poor weather as a reason for having an IMC rating but then turn round and say that the weather is not so bad really because you can opo up through the cloud to VFR on top and then before landing at an aerodrome with no instrument approach, break cloud at the MEA. You can not claim that flying at the MEA is skud running!

To convince Europe's Authorities and Experts one has to show that the rating is not simply a good idea but that the idea is sound from an operational IFR point of view.....i.e. you depart you enter IMC you remain IMC and find that the destination is below limits, you then perhaps shoot a second approach followerd by a diversion to the alternate where you hold and shoot a third approach (gettting tired by now) to a safe landing.

The CAA are the ones who for years warned that the IMC rating does not equip pilots for sustained enroute IFR flight. They spent years reminding pilots that the purpose of the IMC was a get you out of trouble rating and so on. With the CAA not retracting any of those statements, it is not easy to convince their counterparts in other NAAs that the IMC rating is worth more than an insurnace discount for some training.

You made the point earlier that the IMC rating is lost and that a pan European rating is required. I agree. That rating will have to be better than the current IMC to get past the regulators.

Regards,

DFC

[FullyFlapped]

Simple question, DFC : would you like to see the IMCr continued in its present form ?

It's just that on the one hand you say it's a better idea to forget the IMCr and concentrate on some form of "PPL/IR", and in the next post you're giving advice on what not to use as evidence in order to win the battle to keep the status quo ... ?

So where do you stand ?

[S-Works]

It is not a case of abandoning the IMC it is a case of having a pragmatic approach. The IMCR should be preserved and if it is to be proper safety case must be presented.

At the same time proper access to the IR by PPL's needs to be worked on. I genuinely believe that if the IR is made fully accessible and performance based rather than the current prescriptive hours based training that the uptake of it would be significantly higher and probably negate the need for an IMC.

The argument about having an IMC and not doing the IR revolves around the high cost and poor access, remove these barriers and the IR becomes more attractive.

And with all due respect, don't you think it is a bit childish demanding that people take a 'stand' either way?

[FullyFlapped]

Bose, firstly, note that my question was directed at DFC, not you.

Secondly, it's not childish at all to ask someone to clarify their position.

In an earlier post, DFC states :-

The best way forward is to accept that the IMC rating is gone. Far better to work on a PPL-IR (a qualification suitable for flying IFR anywhere

Then a short while after :-

I would caution gathering too many statistics that will be used as a good example of why the IMC rating can not be continued with.
I am simply trying to reconcile the two statements.

My own position is simple : (1) retain the IMC in its present form in the UK. (2) Immediately begin work on a more accessible PPL/IR acceptable to EASA. (3) When (2) is complete, mandate a reasonable period for IMC holders to upgrade or lose their privileges.

And by the way, you still haven't told us whether DFC is right about the AOPA member's guarantee being unlimited ?

[S-Works]

FF. I was just trying to bring balance. Even though I regularly disagree with DFC his post struck a chord and seems quite a balanced view rather than trying to be polarised.

If you wish to find out details of the AOPA constitution then please contact the AOPA office. Full details are available to all members and prospective members. As I pointed out a few posts ago I will no longer enter into discussion on these matters on this thread.

[Fuji Abound]

DFC

To convince Europe's Authorities and Experts one has to show that the rating is not simply a good idea but that the idea is sound from an operational IFR point of view.....i.e. you depart you enter IMC you remain IMC and find that the destination is below limits, you then perhaps shoot a second approach followerd by a diversion to the alternate where you hold and shoot a third approach (gettting tired by now) to a safe landing.

Good point, but shouldnt some responsibility remain with the pilot?

Do we have to regulate for every scenario?

A PPL grants you rights to fly aircraft you would be very unwise to fly without further instruction.

An IR grants you rights to fly to published minima, but should you do so if you are rusty?

An IMC rating grants you the rights you set out, but at the same time during training significant emphais is placed on the need for currency and development of skills.

I think because these aspects are emphasised the vast majority of IMC rating holders operate to their limitations. That is why the safety record of holders is so good.

On the other hand because some IR holders believe they are qualified to fly hard IFR in very poor weather they will be inclined to do so, when perhaps they should not.

[FullyFlapped]

Bose,

WRT AOPA, apologies, I missed your post on not discussing AOPA regs on these forums, but that's fine, I'll contact them directly.

I think this one needs nailing and putting to bed, so when I get the answer, I'll post a summary so that we all understand the position.

[IO540]

As I have said many times, it is purely elitist to argue against the IMCR on the basis of alleged poor pilot currency.

This is because while safety does derive from currency, it derives even more from automation resulting in a low cockpit workload.

The airline industry learned this decades ago. It is a FACT.

Today, most pilots flying serious IFR (particularly airways) are doing it in planes equipped as well as a BA 747 was 20 years ago, or equipped as well as many cargo 747s landing at Heathrow right now.

Should Europe regulate for minimum aircraft standard? They already regulate heavily for minimum equipment carriage. That, together with BRNAV (an IFR GPS with a current database) being mandatory for all practical Eurocontrol routes, means that there are virtually no "spamcans" flying serious IFR.

There are a lot of IMCR holders who fly these very capable planes and they use the Rating fully. Most of them are probably working towards an IR (usually the FAA one).

The IMCR holders with only spamcan access are intelligent enough to know they can't do a lot with it. Only a total idiot will be flying a spamcan with a radio hanging out of the panel by 1 screw, and with a knackered VOR receiver will dive into a cloud hoping to find a runway at the bottom of it.

That's why the IMCR safety record is so good. No regulation is needed - pilots aren't stupid.

So fly keep flogging this dead horse?

Often, on these forums, allegations are posted which are misleading, so somebody dives in to set things straight. But I don't think there is much point in debating this point anymore, with the same individuals.

[DFC]

Fully Flapped,

The two statements need no reconciliation because they are two separate and unrelated statements.

The first delas with the reality of the situation with regard to the IMC rating in it's current form.

The second is simply pointing out that gatering statistics can sometimes give more ammunition to the opposition.

-----------

My thoughts on the IMC rating is that it only works because the vast majority of holders either do not use the rating at all or simply use it in class G airspace.

As I said previously, the UK CAA are on record as having described the IMC rating as something to be used as a get you out of trouble rating and also stating that the IMC rating did not equip pilots for intentional enroute extended IFR flight.

I believe that the CAA know that the IMC rating is gone. The future UK airspace structure will not support it. They have lots of items that they need GA on side for - Part M (UK style), Mode S, one sky, enroute VFR charges, enroute IFR charges, euro GNSS etc etc and want to be seen as GA's friend as long as possible. They are also on record as saying they object to EASA and the way EASA is going to do things. Of course the comission going down the legislative route has put paid to Roy's ramblings regarding EASA.

Perhaps everyone needs to look at the Microlight world as an example. Totally unregulated for years, brought into regulation and has negotiated and pushed forward both the regulatory boundaries and the popularity / usefullness of the sport to such an extent that they have managed through well planned well thought out and well negotiated actions to go full circle with the introduction of the single seat deregulation.

Had they insisted on retaining the situation as was in the 80's then I can guarantee that it would not be such a healthy sport today.

Any claims regarding the safety benefit can be dismissed because a training course completed yearly (in a sim perhaps) would have a similar safety benefit and if combined with an insurance discount would assist both safety and reduce the cost. That would only leave those who use the IMC rating as a poor man's IR. That is not what Campbell et al invisiged and it was not what the CAA planned for either ( hence the various "get out of trouble rating" and similar statements over the years). However, give a pilot the legal ability to do something and they will do just that.

Here is where many European Authorities ind their first problem. The privileges it gives - IR privileges for enroute an terminal area operations - are above what the designers, the enabliung authority and the sylabus envisaged.

It's the old - you got caught out and we are not sheep.

Best way forward is to imagine that there was no IMC rating.

We know that the CAA would not accept the proposals for the IMC if it were put to them today - try suggesting making it possible to add an IMC rating to the NPPL and wait for the ah but's. If the UK will not add a national rating to it's national licence then what message does that give out.

So starting with a clean sheet a proposal must be out forward for a rating that will permit recreational pilots access to the IFR system.

Remember that such a rating will have to include night flying privileges. After all, no European Aviation authority is going to leave it's IFR system open to the C172 at the top of the stack demanding an immediate approach....not because of some emergency but because nightfall is near and while they are entitled to fly IFR, all flying, holding and diverting they do must cease at nightfall.

Ladies and Gentlem, unfortunately your flight to Paris is being delayed because priority has to be given to some pilots who are operating in the IFR system but can not fly at night!!!

So if the microlight industry can negotiate it's way to deregulated single seat, one now waits to see if the JAR-23 industry has the ability to do something similar in terms of recreational pilots gaining acess to the IFR system.

Regards,

DFC

[Fuji Abound]

DFC

Some useful comment, but I am left wondering why 50 pilots a day are signing a petition to retain the IMC rating.

It is actually quite hard getting people to support a campaign, so the level of support would suggest there are other factors at work.

EASA granting a moratorium on the IMC rating would also suggest that they are at least interested to see how the campaign pans out.

Someone emailed me a while back.

This is the jist of what he said.

I am an ex military pilot. I held a military instrument qualification for many years. I now fly and enjoy aerobatics at competition level.

I want to safely operate above a broken cloud base rather than below, knowing that I can enter cloud on the way down if I need to. I dont need a civil IR.

The IMC rating means I can do this legally and safely.

For me, a regulators responsibility is to enhance my safety and the safety of every other user of the system. The IMC rating means I can do what I do more safely.

[IO540]

Best way forward is to imagine that there was no IMC rating.
We know that the CAA would not accept the proposals for the IMC if it were put to them today

IF IF IF IF .... so many IFs.

IF the ICAO treaty was not there, where would GA be today?

Outside the USA, it would be banned, almost certainly - except for purely low level sporting activites, very tightly controlled. Forget foreign trips.

The whole aviation world which means so much to so many pilots relies on a treaty signed around 1944, when regulation was run by real "can-do" men who had a real vision of the future and were able to properly size up the risks.

[DFC]

I am left wondering why 50 pilots a day are signing a petition to retain the IMC rating

The general Anti-Europe UK position would account for a large proportion

Many others would simply fear the loss of a rating with no replacement.

Only a small percentage would be active current fully competent IMC Rating users.

Your example works against your aims - a professionally trained former instrument rating holder using the IMC to avoid IR currency requirements while flying an aircraft probably not fully IFR equipped and operating in class G IFR probably with no ATS.................all red flags to many Europeans.

Furthermore, their reason for using the IMC seems to suggest that they need an IMC rating to operate simple VFR flights...........in other words having the IMC rating has no impact on their ability to do what they want to do..............thus one could say that not having an IMC rating would have no adverse impact on their flying.

Again I say you must be very carefull about what information you collect but 10 times more carefull about the information you use.

Regards,

DFC

[englishal]

Many others would simply fear the loss of a rating with no replacement.

Only a small percentage would be active current fully competent IMC Rating users.
I don't think you give the PPL enough credit DFC. What catagory are you, are you an MIR'd ATPL, IR'd CPL, an IR'd PPL, an IMCrd' PPL, a FSX Master or x-RAF (not flying) what? Just curious so that I know what catagory of pilot (or not) we need to convince. Or are you like someone else on here who just likes to stir?

As you obviously think the IMCr is a load of crap, prehaps it would be better if you leave us to our discussion.....thanks.

[DFC]

Just curious so that I know what catagory of pilot (or not) we need to convince.

You can convince every pilot in the world. That is not going to make any difference. You have to convince the regulators and the national Governments plus the European comission. Pilots especially just the purely recreational and sport kind i.e. PPL represent very few votes. Think of the airfield closures. How many pilots vote and campaign against those.

I don't feel the need to thump my chest and proclaim my experience to justify the opinions I express.

As you obviously think the IMCr is a load of crap, prehaps it would be better if you leave us to our discussion.....thanks.

The idea is sound but the training, the legislation and the practical application are flawed - The UK CAA said that - ban them from any IMC discussions also. Here is an oportunity to change that and broaden the appeal.

Seems that anyone not in the keep the IMC Rating as it is sheep flock is not wanted because only those that agree are permitted to have a say.

Fine...take your discussions into some secret place and we can sit back and enjoy our flying related debates.

Regards,

DFC

[Fuji Abound]

You can convince every pilot in the world. That is not going to make any difference.

Is the purpose of a regulator to be so removed from those they regulate as to take no account of their wishes?

If the Government says a new drug is to expensive, and yet the doctors tell the government the new drug will save many peoples' life to whom do we listen?

The idea is sound but the training, the legislation and the practical application are flawed - The UK CAA said that

When, where, who?

Your example works against your aims - a professionally trained former instrument rating holder using the IMC to avoid IR currency requirements while flying an aircraft probably not fully IFR equipped and operating in class G IFR probably with no ATS

We should not jump to conclusions. You dont know what avionics the aircraft had. I fly an aircraft that is fully IFR compliant and is also certified +6, -4. The pilot is fully IR current because he holds a valid IMC rating. He can do everything a IR holder can do with only two exceptions. In fact he is almost certainly more current and has a deal more experience than many pilots with an IR.

Furthermore, their reason for using the IMC seems to suggest that they need an IMC rating to operate simple VFR flights

I dont understand your statement?

I also dont understand the use of the world "simple".

The vast majoity of IFR flights I do in IMC are no more, nor any less simple than VFR flights - I try and prepare for each as methodically. I consider "simple" a relative term.

The IMC rating was dead and buried before Christmas.

It is alive and kicking for at least the next four years.

EASA would not grant a moratorium for that length during which NEW IMC ratings will be issued and then abolish the rating, at least not without an equivalent alternative (grand fathered or otherwise).

To do so would be a clear breach of natural justice on their part. If the IMC was going, it would have gone now and would never have been recognised by EASA.

Fortunately there are a lot of very experienced people in EASA who recognise a good thing when they see one and know the precedent they have set by adopting the rating for at least the next four years.

I would encourage anyone of thinking about doing an IMC rating that now is a better time than ever! :) :)

Readers should be quite clear that AOPA are clearly on record as fully supporting the expansion of the IMC rating through out Europe for which I congratulate them.

It has been suggested on here (by Bose) that AOPAs stance has very recently changed but I find no evidence that is so and no such admission by AOPA. I don’t believe, in spite of some criticisms expressed by me in the past, such a well respected organisation would change their policy without notification.

This is what their CEO says:

AOPA-U.K. Managing Director Martin Robinson has made this view known to EASA, asking that the rating be retained and expanded throughout the
European community. [my emphasis]

Good news indeed. :)

[englishal]

You can convince every pilot in the world. That is not going to make any difference. You have to convince the regulators and the national Governments plus the European comission. Pilots especially just the purely recreational and sport kind i.e. PPL represent very few votes. Think of the airfield closures. How many pilots vote and campaign against those.

I don't feel the need to thump my chest and proclaim my experience to justify the opinions I express.
Unfortunately many of the "regulator" are made up of pilots or ex pilots (who know better).

Anyway, I'd rather have this discussion with someone who I know actually flies, and hence is arguing for a reason. Some of the other contributors who like to stir the pot I know don't fly, or fly very rarely and their contributions are designed to stir, cause arguments and not be productive. Even trying to sabotage efforts you could say....

[TheOddOne]

If the Government says a new drug is to expensive, and yet the doctors tell the government the new drug will save many peoples' life to whom do we listen?


Fuji,

Sorry to hijack the thread for a moment.

Actually it's a body called the National Insitiute for Health and Clinical Excellence (NICE). This is a panel of doctors and NHS professionals (accountants etc) whose job it is to balance out health benefits with cost to the NHS. There are always howls of anguish when they say a drug is not cost-effective, but unfortunately mostly these screams have the drug companies egging people on from the back (in my view).

Maybe there's a parallel here?

TheOddOne

[Fuji Abound]

I know.

The parallel being that on those occasions there is popular demand for a drug to be available the "regulator" takes notice of demand.

In fact if every regulator and government ignored every campaign I guess we would still have the poll tax and the red arrows would not be gracing our Olympic games.

The point is campaigns can be very productive.

Englishal

I agree.

I can think of a few on here since I have been doing this who are kown by others and it turns out they dont fly at all, or hardly at all. Their posts imply other wise.

[421C]

Sorry, let me repeat what I said with emphasis;

Quote:
Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.


I don't agree. A flight must be operated on the basis of the forecast and actual weather conditions. You could operate on the basis of enroute IMC and the weather being VFR at your destination if that is what's forecast, of course being prudent about any marginal conditions that might deteriorate.

In otherwords do not gow down the road of a VFR over the top rating and confuse what IMC IFR flying involves.

Australia has a modular "PIFR" which starts with permitting only enroute IFR/IMC conditions.

[DFC]

I don't agree. A flight must be operated on the basis of the forecast and actual weather conditions

and also on the basis that things may not turn out quite as planned. I.E. having al alternative course of action.

-----------

The pilot is fully IR current because he holds a valid IMC rating

Statements like that and the previous statements from some that IMC holders can operate to IR minima do not put the IMCrating in a good light.

The IMC is not an instrument rating. The holders are not instrument rated. If you want to push forward the idea you need to ensure that such is made clear.

EASA have not "granted a moratorium" and they are not adopting the rating for at least the next four years.

To think such is simply dreaming.

EASA simply pointed out that the whole process is going to have such a timeframe.

People should decide personally if they want to pay for a rating that may not exist in 4 years time and one could argue that shcools sdhould make them aware.

Natural Justice?

It costs me a fortune to drive a 4x4 round inner London (more than the cost of an IMC rating each year. I was able to do it for free. Can I not pay and claim my rights to Natural Justice in infringed?

If Authorities listed to the popular position then GPS would be mandatory fro VFR flights.

If I wanted to strii things, I would make 2 posts - The IMC rating is dead............and in 4 years time - I told you so.

However, if I simply point out what I believe are errors in the way people are going about this then they can have a think about what I say. They may agree or they may not that is up to them.

Regards,

DFC

[Fuji Abound]

The IMC is not an instrument rating. The holders are not instrument rated.

It entitles the holder to fly on instruments.

It costs me a fortune to drive a 4x4 round inner London (more than the cost of an IMC rating each year. I was able to do it for free. Can I not pay and claim my rights to Natural Justice in infringed?

No, because you have no good reason to do so. You cause an unacceptable level of pollution and you dont need 4 wheel drive in London. I would ban them completelly.

[englishal]

The holders are not instrument rated
I am.......................

[DFC]

It entitles the holder to fly on instruments.

A basic PPL can fly on instruments. No rating required. You really need to read what the IMC rating entitles a pilot to do.

No, because you have no good reason to do so. You cause an unacceptable level of pollution and you dont need 4 wheel drive in London. I would ban them completelly.

and your reason for flying a 6+ litre engine fueled by petrol with extra lead added round is?.............are ther not airline flights and public ground transport not to mention the fact that the average car provides less polution?................

People would have a field day if you compared a recreation / sport activity to day to day essential business.

Regards,

DFC

[DFC]

englishal,

Good point - there are pilots who hold both an instrument rating and an IMC rating........but do they exercise the privileges of the IMC rating when flying IFR or the IR?

Regards,

DFC

[englishal]

but do they exercise the privileges of the IMC rating when flying IFR or the IR?
From a legal perspective I exercise the privileges for the IMCr in UK airspace as my IR is issued by the FAA. But that is not to say that I won't come down to minimums should it be required..

[FullyFlapped]

I have removed this post intentionally.

Hoodie's post below was made before I removed this post, which is why the sequence of events seem strange (entirely my fault, not his). Thus I offer the following explanation.

The post concerned my feelings regarding DFC and his opinions, which he often represents as fact without ever offering any evidence, claiming some "inside track". I presented my reasons for believing him to be a seriously unhelpful fantasist at some length, and challenged him to prove his credentials (which I know well he will not do).

However, on reflection, I considered that by attacking him, my post simply served to add credibility to his position, and so I removed it.

FF

[hoodie]

FF, thank you. :D

For anyone else looking for the source of...

And yet, my favourite post of yours over the years was the one in which you claimed that should you ever enter cloud unexpectedly on a VFR flight you would immediately put down in the nearest field, and consider yourself a failure for having to do so ...

...then check out DFC's contributions to this thread (http://www.pprune.org/forums/showthread.php?t=176783&highlight=unexpected&page=2). They're an eye-opener.

(FF, I assume that's what you meant, unless there are other examples - not that I'd be surprised. :bored:)

[DFC]

EnglishAl,

Are you saying that when using the IMC rating and have not declared an emergency, you will operate to IR minima?

-----------

Hoodie

I never said "in which you claimed that should you ever enter cloud unexpectedly on a VFR flight you would immediately put down in the nearest field, and consider yourself a failure for having to do so ..."

I stand by the posts I made in the thred you use as an example and I still say that faced with an unplanned excursion into IMC the precautionary landing will often be a safer option.

Had some pilots followed that then the population of Blackpool pilots would be 2 greather than it is today and also there would not have been the IMC CFIT in North Wales that killed one and ruined the life of another.

Regards,

DFC

[englishal]

DFC,

Yes with regards to DA MDA....

DA and MDA are the same for IMCr or IR holders as we all know very well. I would feel comfortable taking the aeroplane down to minimums if I had too, as it is withing my personal experience envelope...

Had some pilots followed that then the population of Blackpool pilots would be 2 greather than it is today and also there would not have been the IMC CFIT in North Wales that killed one and ruined the life of another.
You could also say that perhaps they should have climbed higher into IMC and continued on instruments had they been able to?

[IO540]

Scoring points off a particular fatal accident is never a good strategy. DFC should know that.

There are books and books and books packed with airliner accidents where two gold-standard trained ATPs piled their jet into terrain and killed some 3 digit # of passengers. If they can do it (and tens of thousands of passengers have died in these accidents) anybody can do it.

[DFC]

Bose,

If you have nothing further to debate then why attack a person?

This is typical of the bully boy attitude often found here - can't argue the point any further so then start describing other posters as "a fool, a liar and cheat".

Unfortunately those comments simply say notihing about Fuji and more about you.

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

IO540,

You are 100% correct. Was not trying to score a point but was pointing out that I held those views prior to certain accidents such as those described which could have turned out differently if some unfortunates had followed my position on such situations.

---------

EnglishAl,

I was afraid you were going to say that.

The AIP as a legal text is clear with regard to notifications regarding the absolute lowest DA(H) and MDA(H) to be used by IMCrating holders as well as recomended additions.

Do you think that a German regulator will look at such use of IR minima by non-IR holders and say that is a good idea or even say that those pilots are not simply using the rating in an unintended manner and use that as a reason for giving German pilots such a rating.

IMC rating holders need to be on their best behaviour while the debate rages and nothing could be more damaging than giving the detractors some indication that the rating encourages pilots to operate beyond the uses for which the rating is provided.

Regards,

DFC

[421C]

Do you think that a German regulator will look at such use of IR minima by non-IR holders and say that is a good idea or even say that those pilots are not simply using the rating in an unintended manner and use that as a reason for giving German pilots such a rating.

Yes, I think they could look at the long history of the IMCR, and conclude that it has been successfully used as per its legal privileges by the IMCR-holding community, and that the discretion to apply or not apply the recommended additions to published descent minima has also been wisely used by those IMCR holders.

All pilot licenses and ratings carry priviliges which could be dangerous if used without any consideration for how trained, current and skilled a particular pilot is. Air law can not legislate for every scenario and occassion, and makes pilots accountable for using their judgement. Using judgement and being accountable for one's own actions is probably the reason many of us enjoy flying.

The IMC-R is a special case. It has clear and unambiguous privileges that a holder can exercise, just as the holder of any other qualification can exercise its privileges in full. However, IFR is particularly difficult and unforgiving, and the CAA, recognising that some IMCR holders may lack currency and/or experience, very sensibly make all sorts of recommendations about caution in how the rating is used.

Why this is such a catalyst for a zillion forum-pontificators to say "it must only be used as a get-out-of-trouble rating", "you should always apply the recommended minima addition" etc etc is beyond me. I imagine there is some enjoyment people get from prescribing and pontificating about exctly how pilots should make decisions they have discretion over.

IMC rating holders need to be on their best behaviour while the debate rages and nothing could be more damaging than giving the detractors some indication that the rating encourages pilots to operate beyond the uses for which the rating is provided.

What an odd thing to say. IMC holders need to be on their "best behaviour" because IFR is challenging and they are responsible for their own safety. I actually think it is helpful to the IMC-R case that the descent minima are the same as for IR holders, and that some IMC-R pilots apply those minima. It shows that it is safe, since I am not aware of any IMC-R holder accidents where the application of IR minima has been a factor.

Think of the counterfactual situation, in which the recommended additions had been legally required. That situation would be utterly irreversible. Posters like DFC would claim, I'm sure, that death and mayhem would result from IMCR holders flying to IR minima. However, we are not in that counterfactual world, but one in which some do fly to those minima, and the safety record is a good one.

The legal privileges of a qualification are the final arbiter of what a rating was "intended" for. Everything else is pilot judgement. Why does that concept frighten people?

[Keef]

Thank you, 421C. A little common sense among much noise.

It makes me very sad to see folks throwing rocks at each other when they should be working together.

[englishal]

I was afraid you were going to say that.

The AIP as a legal text is clear with regard to notifications regarding the absolute lowest DA(H) and MDA(H) to be used by IMCrating holders as well as recomended additions
Can you please point me in the direction of this legal text please, I'm feeling a bit stupid this morning......

[FullyFlapped]

Quote:
IMC rating holders need to be on their best behaviour while the debate rages and nothing could be more damaging than giving the detractors some indication that the rating encourages pilots to operate beyond the uses for which the rating is provided.

What an odd thing to say. IMC holders need to be on their "best behaviour" because IFR is challenging and they are responsible for their own safety. I actually think it is helpful to the IMC-R case that the descent minima are the same as for IR holders, and that some IMC-R pilots apply those minima. It shows that it is safe, since I am not aware of any IMC-R holder accidents where the application of IR minima has been a factor.

No. And neither is DFC. And you are quite right about the minima.

And as for throwing rocks, Keef, I am sorry - truly - that there is discord. However, the guy at my airfield who said to me yesterday that - despite being a perfect candidate for it, in terms of usage and profile - he wouldn't be taking up an IMC because someone he knew had seen on PPruNe that it was definitely a dead duck - makes me angry, and those who propagate this crap deserve all they get ...

[goodworker]

DFC, Your not really one to take the high ground on personal attacks, having recently had posts deleted by the moderator on a different thread, for very clearly identifying an Irish ATCO, and slandering his professionalism.

Yes DFC, there may be some posters who describe others as 'fools, liars or cheats', but you go the whole hog and just describe them in all their personal detail; occupation, ratings, address, hair colour (I kid you not)

[IO540]

And as for throwing rocks, Keef, I am sorry - truly - that there is discord. However, the guy at my airfield who said to me yesterday that - despite being a perfect candidate for it, in terms of usage and profile - he wouldn't be taking up an IMC because someone he knew had seen on PPruNe that it was definitely a dead duck - makes me angry, and those who propagate this crap deserve all they get ...

I agree. I think this is why a good number of us are still on here banging on about these issues: to try to counter the constant flow of disinformation, in case some "outsider" casually drops in and manages to read it.

The value of the debate between most of the people on here has fallen to zero long ago.

Countering disinformation is alone a worthwhile cause. I know a man who was told (by somebody in the UK CAA, no less) that he could fly a G-reg on an FAA PPL only in the UK; he sold the plane on the basis of that advice.....

[BEagle]

The relevant section of the UK AIP states:

3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.

This is a somewhat ambiguous statement. As I read it, it is a mere recommendation and is sufficiently vague for any lawyer to successfully defend anyone using lower limits routinely. For example, it seems to state that it recommends that, where a published DH is 260 ft, the recommendation is not for 460 ft (DH+200) but 500 ft.

This is why my recommendation for the Class 2 IR uses mandatory additions to DA/H and MDA/H rather than the slackly worded statements above.Regarding industry 'best practice', most people I know use the simple figures published in Pooley's Guide as their everyday minima.

Thus industry has found a sound, commonsense solution which is easier to understand than the AIP! This could work to our advantage as it shows that the UK routinely provides sensible recommendations for 'amateur' pilots to follow - who would perhaps otherwise be confused by the AIP.

[DFC]

BEagle,

You and I both know that if an candidate doing their initial IMCrating test use a DH of 250ft for the ILS then they will fail the element regarding appropriate minima.

That i why the schools teach the 500ft / 600ft and the examiners require it to be displayed on the test.

I agree with you that the proposals should be for a simple mandatory addition of x and y amount to the IR minima in terms of DA(H) / MDA(H) and also the visibility element.

However, the point I am still trying to get across is that whatever may be done in practice by some pilots, with the IMC rating under the microscope anything that even remotely adds to the posibility of not having a PPL level European IR - eg

"not a good idea because pilots will simply fly as if they had the full IR therefore the safest thing to do is make sure they do have the full IR" - a quote from a European member of the pannel who will decide what happens

The IMCrating holders are not in any way different from IR holders in regard to busting appropriate minima etc etc.........the problem is that there is no fight to retain the IR or to have the IR expanded across Europe.

Regards,

DFC

[BEagle]

A pilot who holds a multi-pilot (or a military) IR on much faster aircraft is in a better position to consider the 'recommendations' for IMC Rating minima than a pilot who does not.

This serves to complicate the appropriate consideration of the 'recommendation'.

You can fly your Hawk to 200 ft with a Green IR, but should you fly your much slower spamcan to 200 ft with your IMC rating? Perhaps not. But why not?

Recommendations are fine whn considered correctly. But all too often they will be taken advantage of by people without the background to understand the error of their ways.

[dublinpilot]

To all on this thread, beware, dublinpilot had a close enough call.

What are you on about? Close enough to having one of my posts deleted? Which one are you refering to?

Looking at your own profile, it seems you have registered on pprune mainly to post on this thread (http://www.pprune.org/forums/showthread.php?t=310303)
I haven't made any contribution to that thread, so am at a loss for what you are talking about :confused:

dp

[goodworker]

Dublinpilot, I was referring to posts made by DFC about you and AOPA, which resulted in you having to defend your reputation. The 'close call' I referred to was of having your reputation slurred, I did not mean to imply that you had posts pulled. DFC is very keen on personal slurs and I just wanted others posters to be wary.

However, through my own poor prose, I have succeeded to decend to this level of offensive posting.

My post is obviously not clear and will be edited accordingly.

I apologise for the misunderstanding and/or offence.

I leave your thread in peace

Yours

Goodworker

[dublinpilot]

Ah no problem :) Now I understand what you mean :)

In all fairness I don't think DFC intended to imply that I had any involvement with AOPA Ireland.....he just phrased it badly so that it looked like that was what he was saying ;)

It is very easy with an online forum for the meaning to get totally lost ;)

Have a good day :)

dp

[DFC]

In all fairness I don't think DFC intended to imply that I had any involvement with AOPA Ireland.....he just phrased it badly so that it looked like that was what he was saying

I do not think that saying the only poster who is an Ireland based pilot will be able confirm the situation with regard to AOPA Ireland (as was) is in any way reflecting on that pilot's anything.

Perhaps everyone should read my statement that DP can confirm that something happened........how on earth does that implicate DP in anything?

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

BEagle,

I think that you are mudying the waters. The IMC rating has nothing to do with military fliers. I do think however that the RAF system of grading the instrument ratings is a well proven model that can be taken forward.

Can you confirm that a candidate you are testing for an IMC initial test will fail if they use a DH of 250ft for an ILS - published minima 200ft (adding 50ft for PEC) and they they will pass if they use 550ft?

Regards,

DFC

[BEagle]

Any military Green IR (aeroplane) holder can apply for an IMC Rating without any need for exam or test. This is because the 'old' UK CPL/ATPL IMC privileges, lost by the CAA through their own cock-up when JAR-FCL came along, still apply to military pilots.

I will not make any statement on IMCR pass/fail criteria on a public website as to do so would be inappropriate.

[DFC]

I will not make any statement on IMCR pass/fail criteria on a public website as to do so would be inappropriate.

No problem have found the reference now.

Here is the appropriate section from CAA Standards Document 25

3.4.3 Applicants will be expected to comply with the IMC rating weather minima published in the UK AIP. Consideration must also be given to the weather conditions at any nominated alternate airfield if the actual weather at the planned destination is marginal.

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

While checking the CAA requirements in regard to this, I also stumbled across something else that is more significant and which I was not aware of ;

UK ATPL and CPL licence holders do not have an IMC rating included in their licence. The actual situation is that in the case of UK national CPL/ATPL licenses maintaining a current Single Pilot Aeroplane Type/Class rating give the holder similar instrument flying privileges to those of an IMC rated pilot but that these privileges do not require revalidation

That means that such pilot do not hold an IMC rating. They by virtue of their holding a UK National CPL/ATPL and a Current Single Pilot Aeroplane Type/Class rating have certain instrument privileges which just happen to be similar to the IMC rating.

That means that any removal of the IMC rating would have no effect on those pilots and the privileges their National Licenses provide.

Or looking at it another way - If the IMC rating was retained - or a Pan European PPL-IR was brought into effect replacing the IMC rating, unless those National Licenses remained in force also, they could loose their embeded single pilot instrument privileges.

In terms of support - are pilots who are not geing to benifit in any way - or for that matter those who loose nothing - going to be easy to convince when it comes to giving support to the issue?

Regards,

DFC

[DFC]

Any military Green IR (aeroplane) holder can apply for an IMC Rating without any need for exam or test. This is because the 'old' UK CPL/ATPL IMC privileges, lost by the CAA through their own cock-up when JAR-FCL came along, still apply to military pilots.

BEagle,

No matter how they obtain the rating, it is attached to a licence and no matter who they are in the Military world, when exercising the privileges of that licence and the ratings therein, they are no different from you and me in terms of the legal requirements to operate to in the case of IMC ratings to the appropriate minima.

If I am flying a CAT 2 certified aircraft to a CAT 2 certified runway, I can not simply decide to dispense with the 200ft DH and 550m RVR requirement for CAT 1 because I think that I am capable of getting to the CAT 2 minima safely........I can only do so when I hold an appropriate authority to do so. Anything else would be reckless endangerment of the aircraft...........or if in my other job, I have CAT 2 approval that would not make it OK either.

---------

The CAA may have messed up but it had nothing to do with JAR-FCL. As it has been pointed out to me, the CAA can still give a free IMC rating to every new CPL issued in the UK.By giving new JAR-CPL's a free IMC rating would counteract the loss of the embeded instrument privileges of the UK-CPL.

All it needs is some typing in the National Ratings section.

Regards,

DFC

[BEagle]

Have you really only just found out about the legacy UK CPL(A) and ATPL(A) privileges, DFC? It's a pretty fundamental part of the whole sorry saga.

The excuse for the CAA cock-up was that the JAR-FCL CPL(A) training 'was not the same' as it was in the days of CAP54. It must have taken them quite a while to research that piece of nonsense.

Nor will they pay for the adminstrative effort required to issue a 'free' IMCR to JAR-FCL CPL(A) or ATPL(A) holders unless it is requested at the time of IR(A) initial issue.

Your example of the Cat 2 minima is nihil ad rem. You cannot compare a 'recommendation' for the IMCR with an absolute regulatory requirement for Cat 2 operations.

Also, the excerpt you quote from Standards Document 25 does not state that applicants must adhere to the IMC weather minima quoted in the AIP, merely that they are 'expected to'....

The impact of the loss of legacy IMCR privileges if EASA requires all UK CPL(A) and ATPL(A) holders to convert to EASA part-FCL licences has already been made plain to the CAA on many occasions.

[DFC]

There is that word absolute again.

Are you not going to apply it in the same way in the case of the IMC rating also?

Regards,

DFC

[BEagle]

The only absolute weather minima applicable to the UK IMCR are:

3 km in-flight visibility under SVFR in a CTR
1800m in-flight visibility below cloud for take-off and landing
Aerodrome Operating Minima

The 3.3.2.1 recommendations in the UK AIP are just that. Recommendations.

[DFC]

BEagle,

You know my position with regard to the IMC minima and it is not going to change until the CAA change the paragraph in the AIP and the guidance so may as well leave that there.

However, I must point out to prospective candidates that to avoid confusion, you will fail any questions that may be on the CAA written test for the IMC if you fail to apply the absolute minima of 500 / 600ft as appropriate.

You will also fail the flight test if you fail to apply the same rationalle to the minima you use.

So despite BEagles hedging regarding what will happen - don't risk having a punt with a 200ft DH on your initial test.

On the up side of course the chosen minima are covered in the briefing and if you choose a DH of 200ft, you will be "strongly persuaded" to apply more appropriate minima before going flying.

Regards,

DFC

[IO540]

Regarding the IMCR checkride, I would ask the examiner what his expectations are. Quite a few IMCR instructors (the better ones) will train down to IR minima. Also on the IMCR (not being JAA) you can have the same person as the instructor and the examiner.

I can confirm that the IMCR written exam (the one I did in 2002) the questions are written as per the recommendations i.e. 500/600ft or whatever so you have to just give them the answers they expect. This is poor form but who is to argue? It's just an exam.

[DFC]

BEagle,

The CAA position I was told today is actually that you can use IR minima. But only where they are specified as 500ft or above in the case of a DH and 600ft or above in the case of an MDH i.e. the +200ft is optional.

Give 01 a ring and check.

--------

IO540,

If you find an examminer to agree to the use of IR minima on an IMC rating test then you have good grounds to appeal a failure because you can complain about the conduct of the test was not appropriate.

You are only expected to be trained and to be capable of flying an ILS to a DH of 500ft. You are required to keep the ILS within half scale at all times - to go outside is basically a fail..........the ILS is more sensitive below 500ft and thus requires a bit more ability to fly accurately.

Many people confuse the common practice of terminating the test / exercise at 500ft but permitting the candidate to have a go at flying the ILS below that height with some approval for doing such in real flying.

Regards,

DFC

[englishal]

the ILS is more sensitive below 500ft and thus requires a bit more ability to fly accurately.
I don't think it has anything to do with height.....

Seems to be a massive confusion, I have yet to see EVIDENCE that you cannot use the IR minima. The CAA say a lot of stuff, only to retract it in writing later on.

[DFC]

I don't think it has anything to do with height.....

It does if by descending along the approach you are getting closer to the LOC and GS antenna's

Regards,

DFC

[FullyFlapped]

Quote:
I don't think it has anything to do with height.....

It does if by descending along the approach you are getting closer to the LOC and GS antenna's

Regards,

DFC
So on that basis, the needles more sensitive at 900' than at 1000', more at 800' than at 900' etc (all properly on slope) ... so how does this help your "stop at 500'" argument ? Why not stop at 600' ? Or 400' ?

[DFC]

Because on the IMC flight test the pilot is expected to be capable of flying an ILS down to a DH of 500ft (unless the published minima are higher).

If an examiner permits use of the ILS below this height then they leave themselves open to appeal doe to how the test was conducted.

It could well be that when presented for the test they have never flown an ILS below that height.

In fact one has to remember that the IMC rating training and testing is very limited. There is no requirement to train in all the approach aids available - only two approach aids are required and only one needs to be pilot interpreted. The ability to perform a hold is not part of the test.

Only 10 of the 15 hours needs to be by sole reference to instruments. Of that 10, some can be in a ground trainer.

It could be argued that as soon as the IMC rating test is passed the pilot is firmly in the non-current and should avoid flight in IMC category.

The IMC rating has so many holes in it that making swiss cheese is impossible.

A new way is required. A rating with appropriate clearly understood limits, better sylabus and better training and testing.

Some are going to argue that it already exists in the IR but are you going to leave it at that?

Regards,

DFC

[Julian]

I agree with Beagle here, the wording of the relevant clause is ambigous and could , I think, be argued pretty well by a clever lawyer.

3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.

The way it reads to me is that it recommends that you add 200', this is only a recommendation and therefore you do not have to adhere to it. However the 'but' followed by 'absolute minima' suggests to me that 500'/600' must be adhered to.

Any legal eagles on here can clarify?

the ILS is more sensitive below 500ft and thus requires a bit more ability to fly accurately.


When you are this far down the ILS its that sensitive I doubt you would really notice the difference. If you are current and flying the ILS with small inputs you should be holding the needles without too much variance anyway, if they swinging wildly - suggest you get an instructor.

[rustle]

When you are this far down the ILS its that sensitive I doubt you would really notice the difference. If you are current and flying the ILS with small inputs you should be holding the needles without too much variance anyway, if they swinging wildly - suggest you get an instructor.

I don't believe DFC was suggesting they would be "swinging wildly", however basic trigonometry tells us that due to funnelling, being several feet out (in GS) at 500' DH (say range approx. 1.75 nm) is not going to be half-scale deflection, whereas it could easily be > 1/2 scale deflection (and therefore a fail) at 200' DH (say range approx. 3/4 nm).

[bookworm]

The way it reads to me is that it recommends that you add 200', this is only a recommendation and therefore you do not have to adhere to it. However the 'but' followed by 'absolute minima' suggests to me that 500'/600' must be adhered to.

Any legal eagles on here can clarify?

You don't need a "legal eagle", merely a dictionary. Absolute means "not relative" [to the published DH/MDH]. There is no case for treating the word absolute as synonymous with mandatory.

[FullyFlapped]

The way it reads to me is that it recommends that you add 200', this is only a recommendation and therefore you do not have to adhere to it. However the 'but' followed by 'absolute minima' suggests to me that 500'/600' must be adhered to.

I see your point, but I would suggest that the entire construction after "recommended" is governed by that word.

It's an old argument, as we all know, and it really matters not a jot what opinions turn up on this board: a courtroom argument would be interesting, though.

There is also another argument which I suspect might get an airing ...

This phrase has been in existence in this text for a long time, and has been the subject of considerable debate and provable communication with the CAA. If, as has been suggested by that well-known close friend of Irish ATCOs :ugh:, the CAA meant for it to dictate minimums of 500/600' for IMC holders, why have they simply not revised the text to make this plain ? Is it perhaps that there is no such intention ?

[Julian]

Aha, but looking in a dictionary I get :

Not to be doubted or questioned; positive: absolute proof.


All suggesting it should be adhered to, i.e. mandatory, hence the asking for clarification.

[IO540]

No lawyer would use this terminology. Like most of the recommendations going around, that text was written by some CAA employee who was doing his best at being a bar-room lawyer.

The CAA have never prosecuted any of this and are never likely to. They would lose, because the ANO overrides the AICs.

[Islander2]

They would lose, because the ANO overrides the AICs.IO540, I agree that the 'IMC DH/MDH minima' paragraph in the AIP (not AIC!) is ambiguous and that there's a very persuasive case for arguing that none of it is mandatory.

But that is not because the ANO overrides the AIP. AD 1.1.2 (which includes the paragraph in dispute) of the AIP provides the notified method of calculating minima as specified by Articles 48 and 49 of the ANO, and as such is mandated by the ANO.