Saving the IMC. Did we do enough? Can we do more?

[Level Attitude]

Given AOPA's latest statement, of 20th March, on the IMC ( Welcome to AOPA UK (http://www.aopa.co.uk/) )
it seems all hopes of saving it for the future is based on amending FCL.600
to allow for National differences to continue.

I understand that "high level" "behind the scenes" discussions have been,
and remain, on-going - but National differences do seem anathema to EASA.

Just to ensure nothing is overlooked, and given that all the important bodies
(CAA, AOPA, etc) follow PPRuNe avidly, perhaps we should all contribute our
ideas of what should have, and more importantly, what could still be done to
help ensure the IMC or IR(R) continues to be available to pilots in the future.

Some to start off:

In all meetings with EASA the CAA could not demonstrate how important
the IMC rating was to the UK as it had no idea how many current IMC holders
there were.
From 2008 onwards the CAA should have required that it was informed
of all IMC renewals (just like other Ratings) and, in my opinion, it should
still instigate this asap.

To "help" our European colleagues, the CAA could have changed the
IMC Rating to a more recognisable format:
ie: Valid for 24 months from date of Test.
Renewal, or Revalidation, by Test.
If Revalidated in the last 3 months of validity then valid for 24 months
from date of expiry of previous Rating.

IMC is not valid for IFR in Class A airspace. Change that to not valid for
IFR in Airways. Even combined with the proposed EIR that should not
(especially with clever wording) give full IR privileges (which is what
EASA don't seem to like).

Change the Restriction from UK Airspace only to Airspace of EASA
members who accept it (not quite getting rid of National differences
but wording can be important)

Maybe nothing should be done until the Single European Sky has been
implemented for a while.
So that what classes of airspace are in use, for what purpose, and hence
what privileges are required, is fully understood.
In this case could a temporary change to FCL.600 be requested?

[stickandrudderman]

It seems to me that nobody had addressed the point that the "S" in "EASA" stands for "Safety" and their first fallback position should be just that. If it improves safety, which it demonstrably does, then they simply shouldn't have the power to remove it let alone make us plead to keep it.

[Johnm]

EASA has an objective to achieve a high uniform level of safety across the EU. Unfortunately it is staffed largely by bureaucrats who know little of aviation or by ex engineering QA folks from the airlines.

They believe that as long as the paperwork is uniform and consistent their goal will automatically be achieved.

Yes you know that's nonsense and I know that's nonsense but anyone who has met a ISO 9000 or health and safety consultant will have seen the syndrome and Cologne is staffed almost entirely by such folks as far as I can make out.

[soaringhigh650]

The IMC rating is just an IR with 15 hours of the training.

[RedKnight]

Does the AOPA statement effectively suggest that the IMCR will be unavailable after April 2014 to new/unrated pilots? And that anyone who wants to obtain an IMCR for all practical purposes (i.e. such that it is valid on EASA aircraft and for EASA licensees) needs to obtain the rating before that date?

[S-Works]

At this moment in time yes.

So anyone wanting this valuable privilege needs to get cracking and trained. I am taking bookings.... ;)

[Whopity]

it seems all hopes of saving it for the future is based on amending FCL.600
to allow for National differences to continue.This is by far the simplest way of dealing with the bureaucracy and only requires the addition of one line of text into the regulation. It was there in JAR-FCL 1 so could easily have been copied.
EASA has an objective to achieve a high uniform level of safety across the EU.Think about it - "Uniform" determines the Lowest Common Denominator - the bottom line, not a high standard!

the "S" in "EASA" stands for "Safety" Looking through the English dictionary the word "Shyster" (http://oxforddictionaries.com/definition/english/shyster) seems more applicable in the EASA context

[Sillert,V.I.]

The IMC rating is just an IR with 15 hours of the training.

The way I see it, an IMC rating gives you enough training & experience to fly under IFR without killing yourself; an IR rating gives you enough training & experience to fly in Class A without inconveniencing other users of that airspace.

IMO there should be a way for experienced IMC holders to obtain some credit for experience gained flying in real-world instrument weather towards a full IR rating, providing of course their instrument flying is of a sufficiently high standard to pass the requisite flight test.

[Whopity]

IMO there should be a way for experienced IMC holders to obtain some credit for experience gained flying in real-world instrument weather towards a full IR rating,This is included in the NPA covering the Competence based IR which is likely to go ahead.

[BEagle]

The so-called 'AOPA statement' was in fact cut and pasted from an e-mail I sent to a fellow director - without my knowledge.

However, since it simply summarises the current situation, I'm not particularly bothered.

The reason I first drafted the FCL.600(b) amendment proposal is that it would not be UK-specific. It would also enable other Member States to meet their national needs - for example, why should a Frenchman flying a French aircraft from one small French aerodrome to another be required to communicate in ICAO Level 6 English when flying IFR? Curiously, the EIR doesn't include such a requirement... Also, it would mean that gliderists could develop suitable ratings which would allow them to be towed up to cloudbase at high elevation aerodromes without the tug pilot needing to hold an IR or the glider pilot a SCR.

But it would also secure post-Apr 2014 initial issues of the IR(R) for those who have never held IMCR privileges, of course....;)

[Jonty]

Having done a PPL with IMC rating many years ago, I personally feel that the IMC rating should be replaced with a full instrument rating.

However, I also feel that the PPL should contain more instrument flying in the syllabus.

[Sillert,V.I.]

Having done a PPL with IMC rating many years ago, I personally feel that the IMC rating should be replaced with a full instrument rating.

However, I also feel that the PPL should contain more instrument flying in the syllabus.

I'd agree that PPL's would likely be safer if they had better instrument flying skills, but without the opportunity to practice, it's not so easy to keep those skills current. The IMCr gives you enough training to be able to safely practice solo instrument flying and to build confidence in your own time. Without the ability to (legally) fly in real IMC, any skills learnt during ab-initio training will fade with time & that all-important confidence needed to maintain control after losing visual reference will be lost.

There are still too many accidents resulting from loss of control after inadvertent entry into cloud - most could have been prevented if the pilots concerned had just kept flying the aeroplane, but when the crunch came, they lacked either the skill or the confidence to do so.

The step from PPL to full IR is just too big for the majority of recreational pilots.

[CaptainChairborne]

However, I also feel that the PPL should contain more instrument flying in the syllabus.
The price of avgas has gone through the roof, airspace in the UK gets more and more complicated, the number of exams has gone from six to seven and will soon be nine, the minimum time to get a PPL used to be forty hours, now it is forty five. There is a correlation between these disincentives and the falling number of people getting and keeping a PPL. GA is in big trouble, making it even more onerous is not going to help

Reducing the number of accidents by making it harder to fly isn't really an answer. China and Japan have very low numbers of GA accidents, mainly because they have no GA


There are still too many accidents resulting from loss of control after inadvertent entry into cloud - most could have been prevented if the pilots concerned had just kept flying the aeroplane, but when the crunch came, they lacked either the skill or the confidence to do so.
I agree, but all those pilots had passed the Human Factors/Flight Safety Exam. They had done a minimal amount of instrument flying during their PPL course and had demonstrated to an examiner that they could do a rate one turn to get out of cloud. You can only go so far in protecting people from themselves

[tmmorris]

The step from PPL to full IR is just too big for the majority of recreational pilots.

Do you mean the step in skills, or the step in training time and costs?

I think the latter is more of a problem than the former; but the biggest issue is currency. For many pilots it is expensive/impractical to maintain even FAA IR levels of currency (one IAP per month). I am in the lucky situation of being based at an airfield with an ILS and even I struggle to fit in the one approach per month (which I aim for as an IMCR holder as this seems a sensible approach - with a personal minimum of 500ft precision/600ft non-precision but on the understanding this is voluntary and not mandatory - an argument for another time :-) )

Tim

[Sillert,V.I.]

Do you mean the step in skills, or the step in training time and costs?

Training time and costs. Skills can be built with experience.

I'd agree with your comment about lack of opportunity to practice IAP's in the UK - but there are usually plenty of opportunities to fly in real weather enroute, and keeping your IMC handling skills current will go a long way to keeping you safe when you really need to use them in anger.

[Fuji Abound]

I have found concern when people belittle the IMC rating.

It is true that in the past the standard to which it has been taught has been variable. However it is equally true that there are many IMC holders that fly to every bit as a high or higher standard than IR holders.

In reality there are very few GA pilots that want to operate into and out of airports used by commercial traffic - if for no other reason than the cost. When it comes to en route flying very very few have the capability to operate in anything other than the very base of the airways. In consequence there is very little interaction between CAT and GA, and no evidence that the IMC rating is more generally unsafe. As it is it gives access to class D and, in my experience at least, I see just as many private IR holders struggling in class D as IMCr holders, and fortunately not many of either rating.

In many ways it is an IR without the overhead of irrelevant exams and a bloated training regime, moreover, proof, if any were required, that most of the theoretical training involved with an IR is an exercise in funding the training industry and little else. I know, I hear you say proof, if any more proof were required that a FAA IR fits the bill for private pilots.

Whatever will happen will happen. In a theoretical world I would add another 10 hours to the practical component of the IMCr, leave the current restrictions in place on runway visibility, and restrict the privileges such that they could only be exercised in aircraft falling below en route charges. I would then call the rating an EIR.

I think you would find that approach would save many more lives that outlawing the IMCr and replacing it with the EIR or IR, neither of which will enjoy any greater up take than has historically proved to be the case.

At the moment we seem to be planning to increase deaths, not reduce them.

[Whopity]

However, I also feel that the PPL should contain more instrument flying in the syllabus.The UK PPL did include 4 hours which was reduced to a single lesson under the JAA. One of the problems associated with doing more IF is that it can instill a false sense of confidence in some pilots and instead of getting out of IMC conditions will actually carry on. A little knowledge can be a dangerous thing.

[Level Attitude]

why should a Frenchman flying a French aircraft from one small French aerodrome to
another be required to communicate in ICAO Level 6 English when flying IFR?
Just for flying IFR in VMC I would agree, but in IMC talking to an ATC Service I would
prefer a common language is used.

Curiously, the EIR doesn't include such a requirement...
Not so curious:
The EIR specifically excludes Instrument Approaches (except in an emergency).
IAs require comms with ATC - hence everyone listening on the same frequency should
(in my opinion) be able to understand what everyone else says.

[Level Attitude]

The IMC rating is just an IR with 15 hours of the training.
I believe it is statements such as this that got EASA all worked up
over the IMC in the first place - and it is not correct.

One specific example: The IMC is restricted to UK airspace whose
Airways are all (I think) Class A and an IMC Rating does not give the
privilege of IFR flight in Class A - therefore the IMC Rating does not allow
flight in Airways.

[bookworm]

The step from PPL [in training time and costs] to full IR is just too big for the majority of recreational pilots.

Is that not the issue to address then? I don't hear US pilots clamouring for an IMC rating (though I believe that AOPA is considering a no-privileges version of the IMC rating training course as a ‘VFR into IMC’ course). The difference seems to be that while you can do your IMC rating at a local flying club, the IR requires school that is usually focused on commercial pilot training (£££), and a set of exams at Gatwick.

The CBM-IR proposed by FCL.008 goes some way towards addressing that, but not far enough. We need to keep the pressure up on EASA to make sure the requirements for training organisations (including those that train for the IR) are proportionate and suitable for schools that serve the needs of GA pilots, not just airline-pilot factories. While the IR might need more hours than the IMC rating, the key to its take-up is to make it as easy to go to a school and say "I want to do an IR" as it now is to go to a school and say "I want to do an IMC rating".

[Fuji Abound]

Bookie - exactly.

Without meaning to be pedantic I would only quibble with the word "easy". I know what you mean but it may send the wrong message.

The key is exactly as you write - easy to do from the standpoint of schooling being supplied at a point convenient to the average PPL who has a day job and four weeks holiday a year. Inevitably a PPL IR is not "easy" and it shouldn't be - but the training should be totally relevant with as much emphasis as possible on practical training and much less emphasis on unnecessary and bloated theory the majority of which is simply irrelevant to the needs of a PPL IR holder.

[Pace]

I agree with Bookworm. The FAA IR is every bit as good as a JAA IR But if you offered the IMCR as a sub FAA IR to the Americans no body would bother with it.
Why because the FAA IR is designed to achieve a standard which is sensible, cost effective and does not require months of study.
This is what I hope EASA are doing and will continue to do up until the real date of 2016 not 2014.
By september november they should have completed their study of the FAA system and JAA system to complete their ideas on PPL FCL before moving onto a similar study on commercial licences but the driving force is to simplify not complicate.

Pace

[Fuji Abound]

The more I think about it the more I wonder whether we need a more clearly defined separation between private and commercial pilots? The training world (beyond the PPL) is controlled by relatively few commercial operators who doubtless exercise considerable influence throughout Europe. They clearly have vested interests and the last thing they want is a "simpler" IR. However the number of private pilots they tutor is miniscule. We all know how few private pilots in Europe have an EASA IR. They would not be bothered to loose the few private pilots that past through the system each year

We accept a PRIVATE pilots license and we dont restrict how a pilot with a PPL shall operate - VFR into the largest hubs is entirely acceptable. Flying IFR is no more difficult with the correct tuition, and it seems logical that an IR attached to a PRIVATE license should be a PRIVATE IR. With that distinction it would enable the rating to be far better designed around the needs of the private pilot without compromising safety.

It is not on the road map, and its not going to happen, but fun to muse.

[peterh337]

I wonder whether we need a more clearly defined separation between private and commercial pilots?

The risk with that, which I believe is real in Europe's highly politicised aviation regulation / ATC union / airline pilot union dominated climate, is that that would result in "private IR" holders being excluded from a lot of airspace or airports.

They are already excluded (by pricing) from many airports which are not busy, just for the manager's laugh, and airspace issues would be a disaster.

If it wasn't for ICAO, GA would be dead in nearly all of the world including most of the "civilised" world, except a few countries which have a long history of private flying (USA, UK, Germany, France basically). We must stick to ICAO licenses and ratings, or face extinction of GA and especially IFR GA.

[Fuji Abound]

I am not convinced for the reasons given.

I see no reason why the private IR couldn't be an ICAO license - after all the FA IR is ICAO compliant without the bloated theory content.

Moreover as I said earlier the PPL is ICAO compliant BUT is a private license without commercial privileges.

If airports want to exclude private flights they will do so anyway - either using pricing or as we are seeing in Belgium - other means. Realistically how many private light singles or twins go into Gatwick at the moment and for how long has this been the case?

No, I don't think yours is a reason for not developing a private rating, but, as I said earlier, this is all dream world, its not about to happen so what I think is irrelevant in the big scheme of things.

[FlyingOfficerKite]

The problem might/will be 'who is qualified to teach', as debated in other Threads by the flying instructors and examiners?

Even if the proposals you suggest were viable, the provision of instructors to teach the IR are not it seems.

The question might not be 'I want to do an IR', but 'do you have any instructors to teach an IR'?

KR

FOK :)

[bookworm]

The more I think about it the more I wonder whether we need a more clearly defined separation between private and commercial pilots? The training world (beyond the PPL) is controlled by relatively few commercial operators who doubtless exercise considerable influence throughout Europe. They clearly have vested interests and the last thing they want is a "simpler" IR.

You might envisage that. However, it doesn't tally with the fact that FCL.008 was chaired by the IAAPS (http://en.wikipedia.org/wiki/IAAPS) nominee, and that the training industry has been extremely supportive of the CBM-IR. Thus I suggest we cross that particular bridge when we come to it.

[Silvaire1]

The FAA IR is every bit as good as a JAA IR But if you offered the IMCR as a sub FAA IR to the Americans no body would bother with it.Yes. All that's needed is to make the existing European IR suited to its purpose, private or commercial. Obviously at the moment its too complicated and has a great deal of content that's irrelevant for both. Then air transport pilots get (oddly enough ;)) an ATP. There is no logical linkage for licensing between meteorological conditions during the flight and whether the pilot is being paid or not.

Some guys in the hangar next to mine share a 182 and are all getting their FAA instrument ratings. Their instructor is an AA check pilot and its great for me too - I get a smattering of free ground instruction from being in the hangar next door!

[Pace]

The more I think about it the more I wonder whether we need a more clearly defined separation between private and commercial pilots? The training world (beyond the PPL) is controlled by relatively few commercial operators who doubtless exercise considerable influence throughout Europe. They clearly have vested interests and the last thing they want is a "simpler" IR.

Why not? Surely if there was a simpler IR and I presume we are talking about the extensive ground exams then there would be a much higher demand for training rather than the few sponsored by mum and dad into a career in aviation!
Making the process more streamlined and as you put it "simpler" while achieving the same end result will mean that the training industry will have far higher influx of students both commercial and private into the training industry.

There was an extensive study carried out between FAA trained ATPs and JAA trained ATPs the conclusion was while both took different routes to the qualification they both achieved the same quality of pilot at the end of the process.
Complex does not mean better nor does it mean more trade for the training industry! I would suggest the opposite is the case.

Hence the present study of the two systems to see where there is common ground and where simplification can be achieved without loss of safety.

Pace

[Fuji Abound]

Bookworm

I dont understand your point.

I know you will be aware of the proposed CBM-IR fees - why wouldn't the training industry lap up these proposals. I know you will also know the cost of the FAA IR theory. There is no proven case that the theoretical content for private pilots is necessary or justified and the bloated costs add insult to injury. It is unjustified day light robbery. I wouldnt mind if it could be justified on safety grounds.

[Silvaire1]

There is no proven case that the theoretical content for private pilots is necessary or justified and the bloated costs add insult to injury. It is unjustified day light robbery. I wouldnt mind if it could be justified on safety grounds. It is equally unjustified daylight robbery for any pilot, no? The relatively simple, attainable-for-all FAA instrument rating does not distinguish between private and commercial pilots for instrument rating... because the distinction makes no sense.

Yet another stratification of the irrational and over-complex does not seem like any kind of solution - it actually reinforces the problem.

[Level Attitude]

I do not care whether the IMC survives, or not, in it's exact current form.
But I do want a Rating that gives essentially the same privileges, for about
the same amount of training and will be valid for longer than 1 year.

Responses to my original Post started with knocking EASA (understandable,
but not helpful) and seem to have moved on to a discussion on how to make
an IR easier to obtain (discussions which, unlike for the IMC, are not time critical).

If we end up losing the IMC then, at least, I would like to ensure that
all ideas/avenues/approaches had been tried.

We should never assume that "the great and the good" have already
thought of everything. I note that BEagle states he is a director of AOPA,
so any ideas, that might just tip the balance, would be seen if posted here.

So far only Fuji (Post 16) has suggested anything, unfortunately his suggestion
is very much like the idea for an "Instrument Weather Rating" of a couple of
years ago - rejected because it gave full IR privileges on a sub-ICAO IR.

People must have some other ideas, suggestions.................

[Fuji Abound]

So far only Fuji (Post 16) has suggested anything, unfortunately his suggestion
is very much like the idea for an "Instrument Weather Rating" of a couple of
years ago - rejected because it gave full IR privileges on a sub-ICAO IR.

Thank you - but I don't support the idea of a sub ICAO IR, nor did I say otherwise.

That said even ICAO is not quite what it seems - have a look at the various ICAO licenses for which exemptions have been filed - they are ICAO licenses, well to all intense purposes, or are they?

The variation I proposes was to distinguish between a commercial rating and a private rating in much the same way the distinction exists between a private pilot's license and a commercial pilot's license - both ICAO licenses. The private IR would, as Bookworm suggests, create a license designed to meet the training needs of a pilot unable to fund the cost of a commercial license or the additional time to learn a deal of theory that is irrelevant to private operations. The license would never the less be ICAO compliant.

Lest we forget over 50% of private pilots in the US have an IR, less than 5% of EASA private pilots have an IR. The goal should be to achieve at least the same percentage of IR rated pilots in Europe because we know it makes for safer pilots. There is nothing in the current proposals likely to achieve this. If the IMCr is lost in the UK it will only make matters worse.

If I had just one wish, it would be that the bureaucrats learn the lessons of history; if the IR embodies bloated theoretical content that is both costly and impractically difficult to access and if the training is not widely available then the up take will be almost zero.

[Pace]

If I had just one wish, it would be that the bureaucrats learn the lessons of history; if the IR embodies bloated theoretical content that is both costly and impractically difficult to access and if the training is not widely available then the up take will be almost zero

Hence why the training industry should welcome simplification to encourage more students commercial or private through their doors.
It is not just Private pilots who are scarce taking up full IRs but also would be commercial pilots who unless funded by wealthy parents struggle to raise the £60K plus needed!
a few years ago in these forums I was against trying to preserve the IMCR and for putting all our efforts into Getting EASA to create an FAA like IR rating.
I really hope that the information being bled to me is accurate that EASA are indeed looking at both FAA and JAA and trying to find common ground with the idea of simplification and unification of FAA and EASA where safety allows and this is not yet another trick of hand for a more sinister motive.

Pace

[Fuji Abound]

Pace - yes but a few training organisations have a strangle hold on the IR at the moment, and guess what, as Bookworm indicated earlier, those few are far more influential than your and my local FBO.

Commercially the last thing that is wanted is a cheaper IR or for that matter any form of cheaper commercial license training. That is fair enough - it may be wrong, but it is not an issue for this forum, which after all is concerned with private pilots.

As I said earlier, in my theoretical world there would have been a chance of distinguishing between commercial and private licenses because, I suspect, the commercial organisations wouldn't see the loss of the private punters a significant enough issue.

It is the art of the possible, and I feel their were opportunities, but they haven't been taken.

[Pace]

Fuji

But these larger training organisations already subcontract out to the USA for a large portion of the flight training because its a lot cheaper there than here!
Second does it make more business sense to sell a lot at a cheaper price or a little at a large price?
Any supermarket will give the answer to that
Looking at 50% of PPLs with IRs in the USA compared to 5% in Europe gives a huge potential market for selling simpler IRs to European pilots to these training organisations.
I would think that any training organisations with half a brain would encourage a simpler cheaper option???

Pace

[abgd]

And any craftsman or self-employed instructor will give a very different answer from the supermarkets.

[Pace]

And any craftsman or self-employed instructor will give a very different answer from the supermarkets.

Hence why craftsmen are a dying breed working niche markets and instructors do not make money.
Went into a furniture store beautiful oak all made by machine and computers for the mass market but very passable.

Pace

[Fuji Abound]

Pace

There arent a lot of trainee pilots to go around. Super markets sell a lot cheap because we cant control either ourselves or our stomachs so we produce more people with ever larger stomachs and the supermarkets are happy.

The airlines control the supply and demand for pilots. There are a roughly fixed numbers of commercial students each year. Making it cheaper / easier will only create more unemployed pilots. There is nothing in your model for commercial fly training setups so they neither want to make "their" product cheaper or easier. In fact more expensive would suite them.

Of course i dont dispute the airlines would like cheap pilots, but the beaucrats arent about to slow down the gravy train because they have their own vested interest.

No but the chink in the armour is the private pilot. Lets face it other than the fbos everyone sees them as a bit of a nuisance, the sort that dont fit the model. Too be fair they dont fit the model and that is why their needs should be provided for in another way.

[Pace]

Fuji

We could go into a long political discussion on why the USA has always been pro GA while Europe NOT!

The USA because there was often hundreds of miles between cities and GA offered a cost effective means of travel.

Europe is fairly new! a mix of individual countries many from left wing backgrounds with little or no GA preferring to keep their citizens in people carriers!

All air travel confined to state controlled carriers and not to individuals with money to buy such aircraft or move freely in our skies.
Hopefully GA will increasingly be seen as a viable business tool

Pace

[abgd]

If you're selling a commodity it makes sense to sell a lot with very low margins. This means big organisations with a highly paid CEO and lowly paid minions.

A set of oak bookshelves is a commodity, and in the days of CNC that's true even for a made-to-measure set. There are still things that aren't though.

I don't quite know where flying instructors are on the scale of things, but mine (in a busy school) seemed to do quite well - certainly better than the average supermarket employee.

[Silvaire1]

Flight Training 'Organisations' are an unnecessary government creation, forced into existence because they can pay licensing taxes without making it obvious to the student that he's actually paying them (indirectly). They should have zero influence on regulators... but their tax revenue buys them a vote which works against the interests of the flight student and aircraft owner. I assume they also collect VAT from the student (at no charge) which obviously no two individuals doing business between themselves would do. So they become an entrenched part of the tax machine.

Its illegal for the FAA to charge licensing taxes of that nature, and there is no sales tax on labor in any state. So economics being what they are, few of the 100s of private pilots I know were instructed through commercial and ("full") IR by anybody other than a part time instructor with a 'real' job doing something else. That's what the real market supports, that plus European students doing their 45 day zero to hero stuff in local schools that nobody local actually uses. At least they keep the aircraft movement count up.

Much of the local US instruction (especially instrument ratings) is done in the students own aircraft, which I think must be the best way to do it.

[Mickey Kaye]

"Flight Training 'Organisations' are an unnecessary government creation"

Yes I've often thought that. I can't see why if the instructor is appropriately qualified and the aircraft is suitably equipped why they simply can't teach a student? As at the end of the day they all have to demonstrate the appropriate standard to the CAA approved examiner.

And as for information that is required to get FTO approval such as the number of rooms, the size of the CFI office and the number of toilets. Well for the life on my I can't see what relevance it has.

An example of this is I split my time between a FTO and a rf. During the week I could be offering CPL training and at the weekend I could be instructing at the rf in exactly the same aircraft from exactly the same airfield using exactly the same briefing room.

Yet at the weekend I'm not allowed to offer CPL or BIFM training.

The only difference I can see is one organisation hasn't paid the CAA a wodge of cash and produced a load of utterly irrelevant manuals.

And as far as I am aware I don't deliver a lower standard of instruction at the weekends. There is one difference however. The added cost of all the manuals, audits, visits etc adds an extra 62 quid per hour onto the hire cost for the FTO.

[dobbin1]

I don't quite know where flying instructors are on the scale of things, but mine (in a busy school) seemed to do quite well - certainly better than the average supermarket employee.

I'm only a part timer(4 days per week), but my net income last tax year was -£400. Yes, that is a minus. I doubt many supermarket employees pay to go to work:)

Perhaps at a very busy school in a good weather year an instructor might be able to scrape out a meagre living, but they would almost certainly do better at ASDA.

[Fuji Abound]

Yes, forget about instructors making a mint. They don't. In fact given their skill, expertise and the time taken to gain the qualifications they are substantially under paid. However it reinforces my earlier point - most private pilots cant and wont pay a reasonable commercial rate, just as most people have to run their hobbies on a shoe string. After all for most it is a hobby. That is why I put forward my argument that the sooner private flying is separated from commercial ops. the better - no compromise on safety - just a different way of going about things. In fact get the majority of private pilots instrument rated and you will improve the record enormously, you will increase the revenue contribution from GA (because more flights will take place) and their will be less "unpleasant" interaction between GA and commercial ops. because pilots will be much less likely to infringe.

Simple really.

Are we getting good at missing the obvious?

[Pace]

Fuji

Not sure what you mean by seperating private flying from commercial ?
Joe Bloggs flying his Cirrus in the airway or on an approach is mixing it with Mr EasyJet and has to be trusted to fly with accuracy!
An instrument rating can only be one standard and tha standard should be more akin to the American system instead of being a major hurdle for the working man with family commitments to achieve.
There has been study after study and both FAA and JAA IRs are equal so the rest in the JAA rating has to be needless junk!
I really do hope that EASA will grab the opportunity and make courageous steps in freeing up the industry from all the overloading and strangulation which is suffocating it!
Maybe elaborate on what you mean ?

Pace

[007helicopter]

Joe Bloggs flying his Cirrus in the airway or on an approach is mixing it with Mr EasyJet and has to be trusted to fly with accuracy

That's easy just pop on the autopilot, and away you go !!

[007helicopter]

On a more serious note the FAA IR and the IMCR are poles apart in my opinion in terms of both effort to achieve and practical use, if only we had a world IR rating similar to the FAA IR that would surely serve all purposes.

[abgd]

How do you make a £400 loss? I know people who have to pay for some twin time to keep their MEIR valid and other costs, but I have seen people make a reasonable living in a busy school.

I agree about the ATOs.

[Fuji Abound]

Fuji

Not sure what you mean by separating private flying from commercial ?
Joe Bloggs flying his Cirrus in the airway or on an approach is mixing it with Mr EasyJet and has to be trusted to fly with accuracy!

Perhaps I am getting old but seriously Pace do tell me what the EASA theory exams compared with the FAA multiple guess exams have to do with flying an approach in a Cirrus. I don't believe for one moment the EASA theory exams make the commander of a Cirrus a better pilot. So unless you haven't had time to keep up with my posts (and I don't blame you if you haven't) I am not for one moment suggesting the practical skills of the Cirrus pilot relevant to flying a SEP be any less than the Easyjet pilot flying a multi jet. I am suggesting that if EASA want to gold plate commercial ratings then who am I to care, but leave private pilots to devise a relevant ICAO qualifying standard that suites the needs of private pilots without compromising standards.

In short leave us to do our own thing because I don't think we need to put private pilots through the same needless treadmill suffered by our commercial brethren.

[Pace]

Fuji

I am not fighting you on that as I agree with what you are saying ;) but I also do not agree with commercial pilots being put through anymore of a treadmill than say an FAA ATP.
The quality of both is the same proved time and time again so why 14 exams for a JAA ATP.
I do not think this has anything to do with separating Commercial and private but in looking at all training and slimming down the whole process from junk food to something more akin to the FAA system on private or ATP level.

Pace

[Fuji Abound]

Pace - yes you are right and I agree with you. Your and my opinion has little sway and it is not going to happen. I was just lamenting that there was more chance it happening were private and commercial licensing segregated because the Eurocrats will never give up their hold on the commercial training industry but might give up their hold on a private wing because there is neither enough money nor sufficient vested interest at work - cynical - yep, guilty.

[Pace]

Fuji

My contact in the EASA negotiating team says otherwise! A major study of both FAA and JAA working on PPL FCL to be concluded by Sept/Nov this year, then moving to the same on commercial licences! An acceptance that nothing will happen in 2014 so a delay to 2016.
Another BASA this june.
The principal is to bring FAA and JAA (to be EASA regs) closer together with a simplification of cross licencing.
Lets wait and see genuine efforts and thinking or a big con exercise to leave us all with eggs on our face!

I will still takes bets on nothing major happening in 2014 to anyone who wants a bet :E

[Pace]

F900EX

A simple conversion route between licences was achieved between the USA and Canada!

There is no sensible reason why the same cannot be achieved between the FAA and EASA.

More so with ATPs who hold current type ratings and more than 1500 hrs.
That category are of little interest to the training world other than through type renewals or initials.

Neither would ATPs be used as a back door to achieving easy EASA commercial licences for the same reason

Pace

[Fuji Abound]

F900 EX

You cant really take part in a discussion if you have followed the discussion, can you?

I have said countless times it is not going to happen, we all know we are on a different track, we were debating what could have been.

As to "getting around the system" that is the last thing the debate is about. The system is ridiculous, because it has totally failed in its prime objective to promote safety, but that is a different matter.

Finally, I dont know who you have flown with but I guarantee you I have flown with pilots with an IMCrating that I would far rather be with than some pilots I have flown with who have an IR. The practical component of the IMCr is less than an IR and the training standard more variable. By definition a student will not complete the IMCr as well trained. However with a good instructor and an additional 20 hours the obtained standard is every bit as high.

[mad_jock]

Until the FAA IR is done by check instead of rolling experence requirements to keep it current there will be no crossover.

Apart from that there is still the problem that alot of the tolerances are tighter for the european IR.

I think heading is +-10 FAA EU its 5deg
They are aloud 3/4 scale deflection we are half scale.
And speed they are 10kts and EU is 5knts.

Then there is the theory requirements.

Which is why it was only ever acredited IMC rating.

Where as the European IR is the same what ever flavour of license you hold.

[Pace]

f900EX.

I was never even two years ago keen on the idea of saving the IMC rating preferring every effort was put into getting a more achievable IR
50% of FAA private pilots hold FAA IR s
5% of European private pilots hold IRs
the French have an atrocious VFR safety record we have a much better record put down to our IMCR which demonstrates that some instrument training and approach capability is a big plus to the private VFR pilot.
Many studies have been carried out comparing FAA IR safety records compared to JAA IR safety records !
conclusion ? There is no difference
the only difference is the ease of achieving one against the other
Private pilots tend to be working people with family commitments who do not have the time or inclination to spend months studying exams.
Hence a IR based on the FAA system would encourage pilots into proper IRs which in turn would lead to better safety levels in Europe.
this would also lead more students to the doors of the hard hit training organisations so win win all round.
My problems with an FAA ATP and type ratings are different if the requirement for dual licensing came into force without a sensible conversion route for me!
But that is a different problem to this thread

Pace

[mad_jock]

I believe one of the problems with the French VFR record is the fact they are currently allowed to go VFR on top and use it to boot.

Which the IMC training very sensibly got you to a level which you could still get down safely if the cunning plan turned into a what the hell do I do now plan.

And to be honest it doesn't matter how you have been trained until you have go a shed load of experence under your belt you are a danger to yourself with any form of instrument rating. The training could be 100 hours and it still wouldn't make any difference.

[soaringhigh650]

The IMC rating is just an IR with 15 hours of the training.

The way I see it, an IMC rating gives you enough training & experience to fly under IFR without killing yourself; an IR rating gives you enough training & experience to fly in Class A without inconveniencing other users of that airspace.

I understand that in the UK Class A airspace mainly comprises of airways. This is typically the easiest part of an IFR flight. You learn to fly straight and level before doing more complex maneuvers.

Therefore it's absurd to have an IMCR that is essentially an easy-IR with approach privileges and just 15 hours of training; and then an overkill IR with 50 hours training and crazy reading material which just gives you the additional ability to fly in such airways.

IMHO the IMC rating shouldn't have given pilots ANY privileges when it was created. It remains a good course though. The invaluable skills taught by the course should be used by VFR pilots in an emergency to get them safely back down to the ground.

What's good news is the FCL008-IR coming soon. It should have been there some 30+ years ago.

[topoverhaul]

The IMC rating previously was just a get out of trouble rating, a good grounding in Applied Instument Flying. However as it gave no ability to fly IFR in Special Rules Areas B which comprised the major airports which had radar and an ILS, it was of no value in planning to fly cross country IFR unless there was a reasonable chance of a visual approach at the other end. I think the only ILS which was available in IMC was at Stornoway.
The change came when IFR was permitted in the Class D airspace into which the SRZs had changed. Thus it was now possible to fly across the country IFR and make approaches, all with no Flight Plan and no fuss, as long as one remained clear of Class A. I appreciate the continuing informality of UK cross country IFR but I also think that the real answer is an easier to achieve and maintain IR and await the next text from FCL 008 with interest.

[Pace]

Agreed, but as Mad_Jock stated it is the renewal process of the FAA IR that concerns EASA, there is no annual recurrent testing unless you are going for a type rating recurrent course, it is self certification.

I fly as a Captain on Citations N reg so renew the type every year but mine is on an ATP.
For a PPL IR It would be sensible to have an annual check ride and that is something that could be added to a more FAA (lLike) EASA iR.
I never indicated it should be a carbon copy :ok:
There is little difference in the flight training infact some reckon the FAA flight side is more difficult while the study side a lot easier and less time consuming

Pace

[mad_jock]

I suspect that is correct pace I have heard that the IR is alot more partial panel and the oral is alot more in depth. But if you wait and transfer across to ATP in the sim on a type its easier than a EU LPC. The oral work on the FAR's is the challange.

The EASA theory isn't as bad as you think.

The question banks are allowing people to get 99% averages.

Even when I did them when JAR first came in and there was some 1000 questions on photo copied paper knocking around they wern't that bad.

[BEagle]

A lot of ill-informed nonsense here about the UK IMCR....

No, it is not just a 'get out of trouble' rating. That's the first myth to dispel. It is a rating which, in 40 years of experience, has proved to provide privileges entirely commensurate with the experience, training and testing requirements associated with the rating. Unlike the FAA IR which is rarely, if ever, retested, the UK IMCR requires a comprehensive retest of IF skills (including limited panel unusual attitude recoveries) every 2 years.

The approach privileges have a minimum decision height of 500ft and a minimum descent height of 600 ft. These are currently only 'recommended' values; if EASA accepts the FCL.600(b) proposal, we intend to ask the CAA to make these 'mandatory' values.

If there's any 'overkill', it stems from the ridiculous CAA attitude that the IR should be a 'last chance check' of suitability for airline employment, rather than a check of IF skills.

The UK IMCR / IR(R) is an entirely adequate rating, which is both proportionate and safe and which must be retained.

As for the FCL.008 C-b M IR coming to this theatre soon, I wouldn't bet on that. If a vote has to be taken on all of FCL.008 rather than just parts of it, you can rest assured that at least one Member State will oppose it - because they have grave concerns about the proposed EIR. That's not the UK, incidentally.....

[Fuji Abound]

Thank fully the current system seems to keep people like you with your attitude out the airspace I am flying in, long may it continue :D

Oooooow.

Actually I am happily flying in all the same airspace as you although with oxygen only perhaps not as high!

Actually I think you will find even the humble PPL will be operating in the same class D airspace as you albeit not in IMC.

As Beagle rightly points out there is so much utter nonsense spouted it is not surprising we are where we are. The real problem is that in a way you are culpable when pilots kill themselves and that is why I am still passionate about this one - dont forget it. All the time you realistically deny private pilots the training they need you are culpable.

It is not about tolerances, it is not about the FAA rating is better or worse, it is about whether the EVIDENCE is that the rating is safe - that is all that matters. There is no evidence the FAA IR with it multiple guess exams and practical approach to training is ANY less safe - in fact there is evidence it is SAFER. There is so much evidence that private pilots with an IR are safer pilots that if you are not aware of the evidence and have any interest at all in this subject take a little time to do some research.

Thinking about it none of this really matters and I dont know why I still feel so passionate about it because I have heard the same arguments for as long as I can remember and doubtless it is part of the reason we are set on the course we are. Personally I dont care.

It is worth thinking about though the next time a private pilot kills themselves for the most common reason pilots kill themselves whether you have helped perpetuate some of these myths and just how proud you feel of supporting a system that has resulted in less than 5% of European pilots having an instrument rating and but thank God for our IMC rating a record in the UK which would be a as poor as Frances were in not for the IMC rating.

Personally I think you have nothing to be proud of.

[Pace]

As for the FCL.008 C-b M IR coming to this theatre soon, I wouldn't bet on that. If a vote has to be taken on all of FCL.008 rather than just parts of it, you can rest assured that at least one Member State will oppose it - because they have grave concerns about the proposed EIR. That's not the UK, incidentally.....

Beagle

I know you are a great supporter of the IMCR!

I never was not because of the IMCR or its quality or what it has achieved but because we were looking at a rating which would be universally accepted Europe wide.

I saw fighting for the IMCR as a distraction away from what we should have put 100% into fighting for which was an FAA style IR! A full IR with departure and approach as well as enroute.

The EIR is a flawed part way house with a number of safety threats to the holder who could be forced to land half way along his route with 200 foot cloudbases below his blissful in the sun cruise above cloud.

No ability or experience to get down.

I have flown into Barcelona numerous times CAVOK over the airport while thick dense cloud over the mountains where Tommy EIR rated has to be visual and leave the airway a recipe for disaster

Pace

[soaringhigh650]

It is a rating which, in 40 years of experience, has proved to provide privileges entirely commensurate with the experience, training and testing requirements associated with the rating.

If this is really is the case then nobody has properly explained why it was rejected and thrown out the window by EASA.

If there's any 'overkill', it stems from the ridiculous CAA attitude that the IR should be a 'last chance check' of suitability for airline employment, rather than a check of IF skills.

:ugh: That is what the ATPL checkride is for!!

[mad_jock]

The ATPL check for years was a paperwork exercise in the UK.

And for a long period when JAR came in it continued to be a tick box intially just taken as your normal LPC after getting the aquired hours and then as box to be ticked.

Some European Countries its a bit more involved requiring a state examinor not a company one and also the test is seperate and done from the LHS seat with LOFT exercises.

The SPA-ME-IR was the only real test when the examinor was independent and salaried allocated by a central office with nothing dependent on a pass or fail.

[BEagle]

If this is really is the case then nobody has properly explained why it was rejected and thrown out the window by EASA.

In my opinion, it was very poorly explained and offered as a 'throughout Europe' option, which put the noses of certain people firmly out of joint.

It will be difficult to plan and execute a flight using the EIR at times. Explaining to an unfamiliar controller than you can accept vectors, but not a STAR and that you may only fly under VFR in the terminal area isn't going to be easy. But if you can, then why not?

Area forecasts are rarely very specific regarding minimum cloudbase. However, one EIR advocate maintained that only TAFs and METARs were necessary to use the rating safely. So we turned the question over to EASA and asked them to state whether they considered that the current ICAO en-route forecasting criteria were sufficient..... Needless to say, they stated that they were sure that these criteria were entirely adequate. To (mis)-quote Mandy Rice-Davies, "Well they would, wouldn't they?".

[Fuji Abound]

If this is really is the case then nobody has properly explained why it was rejected and thrown out the window by EASA.

It is really the case.

In previous debates we always liked to point out not a single pilot has ever been killed whilst exercising the privileges of an IMC rating. Even the CAA said so!

After a huge amount of research doubtless by the most ardent detractors someone came up with one possible and highly debatable example! I cant even recall the circumstances and it was really clutching at straws.

By any definition that is a remarkable standard, especially compared with the number of pilots killing themselves every year in instrument conditions with ICAO IRs.

The explanation is actually quite simple. EASA was intended to unify standards. The IMCr was a unique British rating and didnt fit well into this model. National pride was a huge factor - the German's had no interest in adopting a peculiarly British rating, that they didnt understand anyway. Then there was the problem of it being sub ICAO - EASA doesnt really understand anything that is sub ICAO. Then there was the problem of our airspace structure being very different from the rest of Europe. Only we define all our airways (well almost all) as class A. The there was the problem that this thread illustrates so well of those pontificating on matters about which at best they knew nothing, and at worst had very different motives. I could go on.

Are these proper reasons - in some cases yes, in some cases certainly not. The missed opportunity was to find a formula that took the best of the IMCr and integrated this into the best of EASA - the EIR was not that formula, abolishing the IMCr was not it, and the proposed IR is not it.

[Pace]

one EIR advocate maintained that only TAFs and METARs were necessary to use the rating safely.

Oh well when little Tommy gets the all clear for Barcelona weather and then is expected to leave the airway before the STAR and happens to descend over the mountains bathed in thick cloud what use will his TAFS and Metars for Barcelona be to him :ugh:
again little Tommy is struggling along on Top of solid! Departure weather great destination great! Enroute not so great! Infact the airports below are all reporting Overcast 200! Little Tommy has a problem! " oh dear I need to divert what do I do ? ".
Oh well

Pace

[Fuji Abound]

Pace - I think you will find EASA has banned en route emergencies. ;)

No, as I understand it, the theory is you stay on top (in IMC or not as the case might be) and ONLY descend at your destination if they have stayed visual as predicted by the TAFs. If not, you divert to your alternate, assuming that has stayed visual, and if not you divert to somewhere that is, and if not you declare an emergency.

If you have a problem en route you divert to where ever is visual and if there is no where visual you declare an emergency.

The theory is emergencies will almost never happen, and if they do there will be somewhere to go visual, and the TAFs are almost never wrong but if they are your alternate will be good.

To be fair the theory probably stands up most of the time - it is rare for the destination and two alternates to both predict a visual approach and all three to fall below visual. The theory doesnt of course take into account an en route emergency but given most EIR holders will be flying singles I guess the most likely emergency will be an engine failure in which event you are coming down whatever (and would be just with a PPL with on top rights) - just better hope you have a chute. ;)

In your case EASA would probably say you chose your alternates unwisely!

[bookworm]

Are these proper reasons - in some cases yes, in some cases certainly not. The missed opportunity was to find a formula that took the best of the IMCr and integrated this into the best of EASA - the EIR was not that formula, abolishing the IMCr was not it, and the proposed IR is not it.

How does the proposed IR (i.e. the CBM IR) differ from "it"?

[Fuji Abound]

Bookworm

I wasnt aware the CBM IR will address the "problems" identified in this thread as to a mechanism for EASA IR holders to obtain the rating without the overhead of the theory exams and the existing limited access to training organisations?

I appreciate the "applicant" could complete the FAA IR and then convert without these problems and only an oral examination with regards the theory, but that seems to rather defeat the object for new pilots.

I am probably missing a lot?

[bookworm]

I wasnt aware the CBM IR will address the "problems" identified in this thread as to a mechanism for EASA IR holders to obtain the rating without the overhead of the theory exams and the existing limited access to training organisations?

My question was an open one, and you've answered it. The "difference" is in the theory and the ATO requirements.

On the former, at the risk of being labelled an IMC rating detractor (which I am not), I do worry a bit that the IMC rating theory is both light and outdated. Unless I've missed an update of the syllabus, QGH procedures, VDF and ADF are unlikely to take the pilot far in the 2016+ world of IFR operation, where every instrument runway end is supposed to have APV and NDBs will have disappeared. The proposed CBM-IR has halved the theory syllabus. Nevertheless, there's lots of scope to improve on the examination administration, and I'd like to see it be as easy to take the IR TK exam as it is in the FAA world.

On the latter, organisational requirements should be at the top of the hitlist of EASA disproportionate rulemaking to be rectified in the wake of the GA Safety Strategy. Again, we need to make the European IR as accessible as the FAA IR. If the IMC rating had by some sleight of hand been made into a European rating, the ATO requirements would be no less burdensome than they are for the CBM-IR. It was simply the (misguided) European way to assume that everything to do with aviation needs an approval certificate, even if it is just an exercise in box-ticking.

On balance, I remain a supporter of the retention of the IMC rating in the UK, just as I know BEagle supports, on balance, the adoption of the FCL.008 package of CBM-IR, EIR and sailplane cloud flying rating.

[Pace]

Bookworm :ok:

The route we should be taking lets hope that is the way things go

F900EX

I very quickly realized the limitations of the IMC rating

I think it was MadJock who talked about experience with either the IMCR or the IR!
I always remember the IMCR as being a get out of jail for free card for the VFR pilot who got into minimal conditions more than a mini IR.

Having said that I knew quite a few very experienced PPLs who used it with anger and shot approaches in pretty bad weather often making life hard for themselves beating around OCAS avoiding bit of airspace to the sides and above and stuck down in the worst of weather but they were relying on hard earned experience over many years.

The majority never used it in anger and frankly a lot were not capable of using the privalages in anger.

Pace

[mad_jock]

There have always been two types of IMC holder.

One hard core that used it more than most IR holders outside commercial ops.

And the ones that did the rating had an occassional approach for ****s and giggles and that was about it. They might have renewed it once or twice but that was about it.

The main thing for me have been the number of expired IMC holders that have found themselves where they really didn't want to be and got themselves back on the ground safely if not in exactly text book or pretty manner.

Then there are those of us that fly multicrew IR and want some form of instrument rating for flying singles without going for the full wack. I suspect 50% of us since converting to JAR haven't bothered to be honest keeping it current. And more than likely wouldn't hesitate either banging up into the cloud if we thought it was the safest thing to do.

In the UK IMC works because of the airspace structure. They are kept away from class A airways but still have access to the majority of instrument approaches. And landing fees take care of the rest.

There will I suspect be a huge part of the problems with certain parties is the fact they don't want a load of 80-130knt spam cans cluttering up their airways and them having to provide ATS for the increase in traffic load. And not get payed for it to boot.

It doesn't bother the UK because they can't get access to any of the enroute center services they have to sort themselves out bodging between local services and they don't screw with the flow figures.

[Whiskey Bravo]

I think that the IMCr as it stands answers what the majority of 'spam can' GA pilots want, which is the ability to climb on top of cloud, get somewhere and make an approach safely if required. Being excluded from airways and class A is probably not a big deal and I suspect there are very few IMCr holders who would plan a flight wholly in IMC conditions as it is basically unpleasant and not really what a private pilot is indulging in their hobby for.

I know this doesn't suit the even smaller group of GA, private pilots that fly more fancy equipment at higher levels and over further distances, but it is probably reasonable that if you want to mix it with the 'big boys' then you have to accept that the airspace your playing with is fundamentally their train set, so you play by 'their' rules.

An EIR appears to me to be useless... The important bit is not getting up there, or staying up there, it is getting down in one piece! An approach IR would seem to make more sense in that case.

My IMCr has saved my bacon once and I know others who wouldn't have got themselves in such a pickle for the sake of 15 hours training, so any replacement should be as accessible as it is currently. Currency is definitely key and perhaps this needs to be tightened up a little for the purposes of establishing a rating that can be used more widely.

[BEagle]

To me the IMC rating never made any sense as a useful rating it was more a rating to get yourself in to trouble with.

I can only assume that your training was somewhat lacking....

For my purposes when I was an ATPL holding UK/FE(PPL), the IMCR was precisely what I needed. I neither wanted nor needed to fly down to 200ft a.a.l. in a spamcan, but the ability to fly in cloudbases of 600 ft was ideal. Finish a training exercise above 8/8, then a quick cloudbreak to visual was perfect. Playing airliners in a light aeroplane was emphatically for others - they were welcome to it! It was boring enough in my 'day job'.

Re. the EIR, I don't think it will be 'useless' if accepted. But I do think that it will probably have little appeal / practicality.....

[Pace]

Beagle

I fail to understand why you fight so hard for the IMCR rather than an FAA lookalike full IR?
Never sell it to Euroland but you could sell an FAA lookalike IR
In my eyes it has served a purpose but is past its sell by date and is clouding the waters in focusing on an achievable IR for Europe as well as distracting from that goal.


Pace

[Fuji Abound]

F900EX

Thanks for a reasoned post. You say you are not a rich boy but fly jets. Presumably you fly for someone else. Presumably you decided you needed a professional rating at some point and that is why you funded an IR - rightly, and necessarily so. Most PPLs are not in that position nor do they want to be. They dont have any commercial aspirations. Therefore they fund an IR or IMCr themselves and most arent "rich". Moreover they cant afford weeks off work to attend residential courses 100 miles away. That doesnt mean they want an easier rating because it doesnt need to be that way. What they want, indeed need, is rating stripped of unnecessary theory, with a practical point of supply and a means of delivery that fits in with having to work. The FAA IR has always done that very well which is why the uptake is so high - every version of European IR has failed on every one of those counts.

In some ways the IMCr makes life harder and the need for a standard higher. As Pace explains there isnt much harder operating OCAS in IMC single pilot single engine - take note all you multi engine multi crew pilots. Worse still you might well not have an A/P and pretty basic instruments. Its tough. It makes the safety record even more compelling.

Yes, many IMCr holders dont use the rating in earnest. Good. They have learned to operate within their abilities, just like any pilot. There is plenty of evidence to suggest some IR holders could have learned an important lesson when they are less than current but think because they have an IR they can blast off into any conditions.

Yes, the content of the IMCr is outdated, that is hardly a surprise having regard to the last time it was properly overhauled - that isnt the fault of the rating and it could have been overhauled had their been a will to do so.

[mad_jock]

Then there will be the issue of if there are any instructors to teach it.

[Johnm]

I am one of those who used an IMCR extensively and regularly and upgraded to a IR to get access to class A. In my experience the issue is not the level of qualification, it's the currency and the confidence that brings.

I could have done all the things I do with my IR with my IMCR because I do it a lot, so my flight planning, RT and aircraft operation are all reasonably confident.

The big secret in long distance light aircraft travel is that VFR is hard, difficult and complicated and IFR isn't.

Whatever debate takes place on this the fundamental issue is this. In a climate where the weather is not all that predictable an accessible and affordable proper IMC qualification that permits travel under IFR in IMC and includes the ability to use approach procedures to get back safely to the ground is a safety essential not an optional extra.

Knowing how to use the OBS facility on a GPS is a critical requirement too.

[tmmorris]

Knowing how to use the OBS facility on a GPS is a critical requirement too.

As indeed is having an OBS facility. As an IMCR holder who flies less often than he would like to, but almost always includes an IAP on every flight to remain current (even if it's only an ILS into home base) I use the OBS hold mode a lot to 'monitor' NDB approaches. Skydemon don't offer an OBS hold mode and that feature alone pushed me back to Garmin for my new GPS last year.

Tim

[Pace]

TMMorris

When the IMCR is used in anger by very experienced PPLs it can be far more demanding than flying IFR following a nice SID then a cruise then a nice star or more likely to be pulled off and vectored onto a nice ILS.
The hardcore IMCR pilot often took off into equally low cloudbases, never got on top battling in the cloud and turbulence low level and to top it often had a home made approach often to quite low limits based on GPS with hopefull conventional navaids as a back up.
Of course never me :E

Pace

[mad_jock]

About to say that sounds like a normal day at work for me Pace but with out the home made approach. But it is multi crew which makes a huge difference.

[tmmorris]

Pace,

Quite right. My airline pilot friends think I'm mad doing NDB approaches at all. (NDB 20 at Shoreham, anyone?)

Tim

[Bigglesthefrog]

If you look around the flying clubs in the Cambridge area of the UK you will find a group of PPLs who make up "The IMC Club"
It was my good fortune to be invited to join them on one of their fly outs last year. Although I gained an IMC rating in the early 1990s it was hardly used and had long expired, so I flew the legs that were VFR. I thoroughly enjoyed the whole fly out and experienced real and well flown IMC on a number of occasions and soon realised just how much enthusiasm was going on here.
It didn't take me long after this to decide to re validate my own IMCr and I received my "new" rating from the CAA a few days ago.
It is a well known fact that many PPLs give up soon after gaining their license and I think this is because they feel the challenge is finished, but the IMC course is not easy and constitutes a further exiting challenge. Then by joining a group who actually fly IMC on purpose, a pilot can enjoy a new and exciting aspect of aviating that at the same time hones the skills of instrument flying, which when actually needed in earnest will then be a perfectly safe procedure. So whilst the IMCr was designed to be a "get out of jail free" card for PPLs, it can make private flying a lot more fun too!

[BEagle]

So whilst the IMCr was designed to be a "get out of jail free" card for PPLs, it can make private flying a lot more fun too!

That was NOT the purpose of the IMCr and is an incorrect statement peddled around the bazaars by those who should know better. The IMCr adds proportionate instrument flying privileges commensurate with the experience, training and testing requirements associated with the rating as defined under UK law.

Rest assured that the CAA continues to press the stubborn €urocrats and will leave no avenue unexplored in order to achieve the continuance of IMCr availability for pilots of the future.

[wsmempson]

A total divergence from the topic, for a moment, but I can't help but notice that if Beagle makes ONE more post, that will make a round total of 20,000 posts.

And I also agree - the IMCR is NOT a get out of jail card to be played only in extremis, it is a rating that can (and should) be used in anger; like any other skill-set, the more you use it, the better you will become.

[thing]

Some interesting arguments. If I'm flying across more than my local zone I always go IFR, in my experience limited though it is I've found I'm more liable to get a zone crossing flying IFR. I use my IMC privileges regularly because

a. with the weather we've had in the past year or so there wouldn't have been much flying otherwise.

b. There's not much point in having it if you don't keep on top of it.

c. Odd though it may seem I like instrument flying in a single engine spammy with no autopilot, it's a different challenge and mentally stimulating. At no time have I ever felt that I wasn't in control of the situation; put that down to excellent instruction in the first place.

[Bigglesthefrog]

OK BEagle, I admit that "Get out of Jail Free" is just a figure of speech loaned to all those words you said it was meant to be and I will take 100 lines. But who cares, what it was really meant for was to enable the training of PPLs to get the aircraft down when in a difficult situation due to weather. I think we've all been there at some time and it was one scare like this that prompted me to get it in the first place years ago. I'm sure that it has saved many lives and as such is, and has been a huge success.
I will also go as far as to say that even if EASA do not sanction anything like the IMCr in the future, then regardless of this, instructors should still teach the syllabus here in the UK. Because if it ended up being a choice of dying or breaking the law, I know what I would choose!

So there BEagle, I invite you to comment on my reply, but not necessarily for you to take issue with my post, but certainly so I can be the one to take you to 20,000 posts!!!;)

[englishal]

The differences between FAA and JAA IRs are irrelevant. The FAA have lower tolerances in some areas, and higher tolerances in other areas - partial panel for example. The format of the FAA IR is "on the fly" - as soon as I took off, the examiner slapped a post-it note over the AI and DI and most of the test was partial panel.

Anyway, I'd advise anyone to do the IMCr now as it will be issued as an IR(R) on your EASA license. I am sure there will be an interesting conversion route to the EIR too, meaning that you could pretty well end up with FULL IR privileges in the UK (Fly IFR in class A and shoot approaches - due to the EIR and IR(R) ) as well as enroute IFR throughout the world.

This is cool, and as much as most people need. It'd make an interesting court case, someone with an FAA IR in an N reg plane with EIR and IR(R) shooting an approach in Euroland....I wonder how that would pan out.....!

[mad_jock]

UK wouldn't touch it with a barge pole unless they thought you were going to pled guilty. I suspect the number of instrument approaches flown without a valid ticket is relatively high in the UK amongst the multicrew IR fraternity. If nothing happens nobody cares.

I know if the wx got a bit ****ty I wouldn't hesitate in going IMC if I thought it was the safer option. Not likely to happen though as if I am in a spam can I wouldn't be trying to fly in marginal wx these days. If its un-forecast there is not a lot they can do about it.

France you would be in the slammer and in front of the sheriff the next day. A wacking great fine would be imposed and you plane impounded until you pay it. And it would takes years and years of appeals and you more than likely wouldn't get the fine back and it would cost more than the fine anyway.

[englishal]

How could you be bunged in the slammer? You are legal in all respects to operate the machine IAW IFR world wide, unless you happen to be a European living in Europe. They'd have to prove your residency - next to impossible in the space of a few hours. And then the "residency" test would have to be tried in court - is the operator resident in EU land or not?!

What would happen to a Norwegian who did this?

[mad_jock]

Bunged in the slammer is the solution to all things paper work related in France if they find an issue. They know fine you will be off sharpish and won't return. So they hold you until its sorted.

Then they stick you in the local sheriffs court PDQ. And then fine is delivered. You can bitch and complain as much as you like but you won't get the aircraft back until you pay it or complete the legal appeals process which takes years. Once you pay it to get the aircraft back you can kiss good bye to the money. I think there is an option to take it to a higher court but the aircraft stays where it is and you are open to a larger fine so take your choice.

It doesn't really matter what nationality you are apart from French.