Avoiding VFR into IMC accidents

[no_one]

Hi all,

It seems that every few weeks there is another GA accident in Australia where the likely cause is a planned VFR flight into either night conditions or IMC. I don't have the data analysis to support this but I suspect that the accident rate is getting worse. It seems to me that the concept of "dont fly in IMC as a VFR pilot" is about as effective as the abstinence method of birth control among teenagers. Is there something better that can be done to prevent this type of accident?

With each of these incidents I reflect on what I would have done differently if I were in the same situation. The danger in this thinking is to lump it all into the term "pilot error". It is too easy to dismiss the accident as happening because of some shortcoming in the pilot that crashed. If you find yourself thinking "well I would never do that" then you are probably underestimating the risk. Many of the pilots who crashed were experienced pilots and its not like the pilots that have crashed took off with the intention of crashing on that flight.

I have some thoughts on what we can do to prevent this sort of accident but before I post them it would be good to get some feedback from others on the forum.

It might help to break the thoughts into 3 groups,

1: In the years before up to the crash. eg training, equipment, ...?
2: In the hours before up to the crash. eg planning, weather,
3. In the minutes before... eg pilot actions, ATC help/intervention.

What are your thoughts?

[Runaway Gun]

Students should learn to fly in tough and marginal conditions so that they can be exposed as to what is suitable for operating in, and what diversion weather looks like. Flying in CAVOK only gives them a false sense of security.

[Petropavlovsk]

Wow! every few weeks huh?
I did not know the 'accident' rate was so high!
You have NO data analysis for reference,

What are you doing here???

[thorn bird]

VFR pilots getting themselves trapped in IMC conditions has been a problem since the Wright brothers.
There are many causes, such as press on itis, blatant disregard of rules, or simply unintentionally getting caught out.
Considering the dwindling number of GA pilots in Australia there seems a disproportionate number of these incidents
compared with the massive industry in the USA and our weather conditions are far more benign than theirs.
Our aviation police endeavour to tackle the issue with convoluted draconian regulation and penalties.
In the USA the FAA approach is education and mentoring.
There is also the fact that almost 80% of private pilots in the USA hold instrument certificates.
They do so because sensible regulations make it relatively cheap to obtain a certificate and maintain it,
they are not burdened with the same regulatory cost burden that apply here making aircraft far cheaper to operate thus
increasing participation and therefore recency.
Unlike Australia committing aviation is encouraged in the USA, Inane security requirements just don't exist in the home of 9/11.
Airports are not locked up by local owners with silly restrictions and burdensome costs.
All this aids and encourages participation. A practiced pilot is far safer than an out of practice one.

[Lead Balloon]

There should be a law prohibiting a VFR flight continuing into IMC. Oh wait...

The penalty for breaching a law prohibiting a VFR flight continuing into IMC should be the death penalty. Oh wait....

The price paid for the regulatory ‘reform’ program would have paid for IFR ratings for every Australian pilot. Lucky the money was instead spent on the oh-so-successful regulatory ‘reform’ program.

It should not be so hard to get an IFR rating in Australia. Not only is it made hard by the unnecessarily complex rules imposed by a regulator that overreacts to most perceived risks, the number and location of organisations that have the approvals to deliver the training are slowly dwindling.

CASA’s education program is manifestly inadequate. That’s not a criticism of individuals involved in the program (except for the ones who think it’s a medium for them to promote their pet theories). It’s a criticism of CASA’s abject failure to understand the practical importance of and accordingly properly resource effective education programs.

[Falcon99]

Back in the 1960's I wrote to the then Department, and suggested that at the completion of the Private Pilot Licence flight test the applicant be placed under the hood and be required to make a 180 degree turn without losing altitude. After entering the probable spiral dive the hood could be removed when the examiner considered control had been lost and any continuation would result in an accident. The examiner could reinforce the lesson to be learned after the flight and the new Private Pilot would have seen first hand the results of flight into IMC.

This suggestion was obviously not considered to be very helpful as I never heard of it being implemented and I never had a response from the Department.

I agree a simpler and cheaper IFR rating would help.

[Squawk7700]

USA pilots also get a night rating with their PPL. That might help stop pilots dying from entering NVFR and black holes. Wouldn’t that be nice to have here!

[lucille]

Back in the 1960's I wrote to the then Department, and suggested that at the completion of the Private Pilot Licence flight test the applicant be placed under the hood and be required to make a 180 degree turn without losing altitude. After entering the probable spiral dive the hood could be removed when the examiner considered control had been lost and any continuation would result in an accident. The examiner could reinforce the lesson to be learned after the flight and the new Private Pilot would have seen first hand the results of flight into IMC.

This suggestion was obviously not considered to be very helpful as I never heard of it being implemented and I never had a response from the Department.

I agree a simpler and cheaper IFR rating would help.

Unless, of course if your shiny new PPL were to get lucky and perform the 180 perfectly with no loss of control or altitude then all you have done is reinforce to him/her that they can cheerfully fly into IMC because they’ve mastered the 180 under the hood.

IFR flying for PPLs work in the USA works because of near universal radar coverage, a particularly helpful ATC and good weather reporting and forecasting. None of which is found here.

[machtuk]

Another consideration here is that today's modern LSA and VH reg kit planes have more fancy gear by way of flight instruments than most basic older Airliners, that alone would entice hapless VFR pilots into non VMC at the drop of a hat! We are fortunate that our WX is generally far more benign than the States where freezing rain/snow etc is a big factor in VFR flight for many accidents! An IFR rating is one thing, having the plane to deal with such WX and remaining proficient is another!
There will always be accidents attributed to poor pilot judgment WX related or not, just a fact of life in the bottom end of the aviation sector!

[Squawk7700]

Dick Smith and I wrote a compelling letter to the director of CASA around 10 years ago about the USA concept of the PPL having a NVFR rating built in. We got a very nice reply from the caretaker director saying that it will be actioned by the new incoming director.

Crickets since then... nada. Tried to follow-up and it fell on deaf ears despite their promise of a reply under their SLA’s.

[Sunfish]

CASA couldn’t give a toss about private pilots killing themselves at all. They are only concerned about the noisier members of the general public giving the Minister a hard time. Witness their treatment of Angel Fight.


As for training????? CASA cheerfully let SOAR remain in operation, so the idea that CASA has any consideration for the well being or safety of pilots is completely alien.

I have yet to witness the slightest concern of CASA for the safety of anyone but the Minister and it’s own staff.

[Arm out the window]

I find there are are generally two schools of thought when this comes up:
1. Don't teach VFR pilots how to fly on instruments because it will lead to a false sense of security and cause them to push on in worse weather than they otherwise would, or
2. Give everyone some basic instrument training so if they happen to be in an aircraft that at least has an AI or AH of some kind, they might have a fighting chance of maintaining control when visual reference is lost.

I believe 2 is best, and am very thankful for my instrument training, the more so because it was old school and covered limited panel (i.e. no attitude instrument) UA recoveries. Make it compulsory, I reckon, particularly as noted above by machtuk that many more modern machines, or old ones with a TV screen added, have a decent AI and compass built in.

And don't only teach how to maintain control on instruments, and climb and turn, but hammer home some scenarios about how to avoid losing visual reference in the first place, but if you do, extending the thought process into 'now how am I going to safely get visual again'.

[Checklist Charlie]

Take 'education' away from CAsA because it only confuses them. Let them stick to all that they are, a regulator, nothing more, nothing less.

My into country (TPNG) brief from Ron Green of DCA was, "stay out of cloud" and "don't make me come looking for you and have to pick up some bits to send home to your Mum". He also mentioned one back door is not enough, 4 or 5 would be good.
Those 3 bits of advice have stuck with me for over 50 years and they seem to work.

The current regulator is far too confused by their own regulations to actually see things as clearly and succinctly.

CC

[Frontal Lobotomy]

Another vote for NVFR training. Saved my bacon after a few poor decisions.

[Ascend Charlie]

Flying schools generally don't take a student out into marginal weather. The flight would be cut short, the operator would not be paid for a completed lesson, and the paid-per-hour instructor would not take much home that week.

Hopeless. I used to try to take students on nav trips where they would HAVE to make a diversion around Cadbury clouds, but the boss didn't like "DNCO" (Duty Not Carried Out) flights. So, Bloggs only ever flew on CAVOK days and the decision-making process wasn't well developed.

[Stickshift3000]

Flying schools generally don't take a student out into marginal weather.

Totally depends on the instructor (& student to an extent). When I recently completed my PPL, if it was VMC, we flew. That wasn’t always pleasant but I didn’t want to be the sucker caught out after only flying in ‘nice’ weather.

[ShyTorque]

I've never seen a 180 turn in IMC as a safe way of regaining VMC, especially so for an inexperienced pilot. As someone wrote earlier, it is likely to end in disorientation and a spiral dive, which will probably end in tears, even if VMC is then regained. I say that after experience of first obtaining an IR for fixed wing in 1978 and rotary wing a year later. These days I regularly operate RW from field locations, flying VFR to an IFR transit (and usually back to VFR).

I've stuck my heretic neck out before in saying that it's often safer to reduce power and descend straight ahead to regain VMC below cloud then to carry out the 180 turn. Obviously, this won't help if the pilot has flown up a blind alley in the hills, but then neither would getting into a spiral dive because if your first visual reference on breaking cloud is the steep side of a valley, you might well find it impossible to quickly re-orientate yourself.

One good example which sticks in my mind: About twenty years ago I was required to operate by night, flying an unstabilised police helicopter at a site with very little helipad lighting (less than that required for public transport) and no cloudbase measuring equipment. For that job, we were not required to hold an IR and we therefore received no recurrent instrument training, so I was mainly out of practice, although to hover at night one does need to scan the flight instruments. One night the met forecaster got it very wrong and an occluded front brought the cloudbase right down to 200 feet agl, rather than the expected 800 to 1,000 feet. We had flown earlier that night before the weather front arrived and the forecast at that time had seemed reasonably accurate. We launched again later to a vehicle pursuit but we hit cloud almost immediately on departure. I descended straight ahead to VMC, carried out a VERY low level circuit and landed safely back at the helipad and went for a cup of tea and informed operations we were offline due to weather (while we recovered our composure). Less than two hours later, the same front caught out another police pilot from an adjacent county force. He also entered very low cloud, but he descended in the turn, became disorientated and hit trees adjacent to the helipad, One occupant was killed in the crash and both others were badly injured.

[Runaway Gun]

I took a buddy up in his aircraft, after he recently gained his Night VFR rating, and he wanted to try some 'under the hood training' for a possible upcoming IF course.

Within 30 minutes of some basic coordination exercises and a few Unusual Attitude recoveries, he called 'Time Out' and we landed.

He commented that he thought it might be easier, given his NVFR rating, but that he didn't appreciate just how demanding Instrument Flying was - and at that time he had no thinking about approaches to do, merely learning to correctly interpret the AI and other instruments in his scan.

End result - he's determined to get his Instrument Rating ASAP. The NVFR can provide overconfidence...

[Sunfish]

As a very inexperienced pilot but one who is experienced in risk management in other pursuits, I believe training is necessary, not necessarily positive “I can do IFR” training but a series of structured “oh s##t!” encounters with flying VFR into IMC with a suitably qualified instructor to recover you. You CANNOT do this artificially with Foggles! You have to cop it full force so to speak.

’The purpose of such training is to:

’(a) recognize the warning signs that you are about to encounter IMC.

(b) respond appropriately to the threat of entering IMC, AND/or recover into VFR.

You cannot do (b) if you are startled, fearful and have never experienced IMC before.

There are a multitude of ways IMC can sneak up on you, just ask me. Luckily for me I once had an instructor who let it happen and we calmly discussed what was happening and what the available options were best.

If all you’ve been taught is “don’t enter IMC’ and don’t know what it feels like, your chances of recovering are not as good. it can sneak up on you and if you don’t know the signs then you are asking for trouble.

While everyone has war stories, some might include:

- gradually deteriorating afternoon light with smoke, fog and haze (even in the circuit at YMMB!).

- gradually decreasing ceiling perhaps with drizzle limiting visibility and surrounding hills - makes navigation very hard.

- “That’s not really a cloud!”

- “ My autopilot will get us through that!”

- “I know the ceilings low but it will get higher as we go north/south/east/west.

etc. etc. I’m sure there are plenty more that I don’t know.


Three escape doors are my minimum, cup of tea and a wait is the best.

[Frontal Lobotomy]

I would suggest if you inadvertently enter IMC in controlled flight the additional training from NVFR may assist you in a positive outcome. If you don’t learn from your misadventure and continue to push the envelope it is probably going to end badly at some stage.

Re overconfidence from the extra training, that is probably an individual personality trait. I like to think additional training/ratings makes me a little safer and hopefully smarter.

[The name is Porter]

So, Bloggs only ever flew on CAVOK days

That's a bit harsh, pretty sure he gets into IMC every now and again.

[PerPurumTonantes]

... a series of structured “oh s##t!” encounters with flying VFR into IMC with a suitably qualified instructor to recover you. You CANNOT do this artificially with Foggles! You have to cop it full force so to speak..

Agreed. The best prevention is sheer terror. Also, never underestimate the detrimental effect of an attractive lady on your decision making.

Having abandoned a sightseeing trip because of weather, I was stuck at the airfield with said disappointed lady. Clouds BKN020, OK let's just go up for a quick circuit instead.

In between taxi and climbout, cloudbase dropped to 600-900ft. Leaving us up in the soup unable to see the ground, at an airfield with no ILS, no diversion planned, sandwiched between Heathrow and Luton airspace, and somewhere underneath us is a 600ft radio transmission tower.

Luckily my FAA PPL training included some real IMC sessions, so my eyes went straight to instruments without thinking. 700ft circuit dipping in and out of the cloudbase. However, lady has declined to fly with me ever again. Quite right.

Lessons:
1) All PPLs must have some real IMC thrown in. Weather is too unpredictable, at some point you're going to be in it.
2) The terror of that event made me revise my planning and minimums. There's no such thing as a simple circuit if there are clouds anywhere near.
3) It doesn't matter how hot your lady friend is. She'll respect you more for saying "no" than for scaring her witless.

[Centaurus]

Most flying schools have a simulator of sorts. They are flight training devices. Before a student's first flight in a real aeroplane he/she/they/should be given several "simulator" sessions in the clear so that when the big day arrives for their first dual flight in the real thing, the student is entirely familiar with terminology and positions and operation of all applicable bits and pieces that form the cockpit. Saves money in taxiing time and holding point time.

Fast forward to their first dual navex. Before that occurs it is back to the FTD and undertake several hours of simulated instrument flight including unusual attitude recovery. No need for a full flight expensive simulator as all you need to learn is instrument flying skill and a standard no motion FTD is good enough. All this unencumbered by an instrument flying hood as the instructor simply selects IMC on the instructor panel.

By the time the student is ready for his first solo cross-country navex he will have at least the rudimentary skills to handle inadvertent flight into IMC safely.
Flight under the hood or using foggles in a Cessna or Warrior is really a waste of time as it is all to easy to peep outside from under the hood. FTD are a relatively cost effective of learning to fly on instruments and can be flown dual or solo. What is needed though are instrument capable instructors who may not necessarily hold an instrument rating but who have the ability to teach instrument flying in a FTD. All grade 3 instructors should have that skill.

It follows that instructor course syllabus must include at least ten hours in a FTD and the demonstrated ability to teach instrument flying in an FTD. With all that basic grounding on instrument flying hopefully it would translate into losing less aircraft accidents due to VMC into IMC flight.

[421dog]

VFR pilots getting themselves trapped in IMC conditions has been a problem since the Wright brothers.
There are many causes, such as press on itis, blatant disregard of rules, or simply unintentionally getting caught out.
Considering the dwindling number of GA pilots in Australia there seems a disproportionate number of these incidents
compared with the massive industry in the USA and our weather conditions are far more benign than theirs.
Our aviation police endeavour to tackle the issue with convoluted draconian regulation and penalties.
In the USA the FAA approach is education and mentoring.
There is also the fact that almost 80% of private pilots in the USA hold instrument certificates.
They do so because sensible regulations make it relatively cheap to obtain a certificate and maintain it,
they are not burdened with the same regulatory cost burden that apply here making aircraft far cheaper to operate thus
increasing participation and therefore recency.
Unlike Australia committing aviation is encouraged in the USA, Inane security requirements just don't exist in the home of 9/11.
Airports are not locked up by local owners with silly restrictions and burdensome costs.
All this aids and encourages participation. A practiced pilot is far safer than an out of practice one.


Would that this were were the case.

There were 163,695 estimated private pilots in the US as of 12/31/18, and, according to the FAA, 47.961 had instrument ratings.

https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/media/2018-civil-airmen-stats.xlsx

[jmmoric]

Some sort of basic IFR training is always good.

Other than that, trust the instruments.... use wing leveler or auto pilots if available.... and take your feet of the pedals. Call ATC if within range, and get their help navigating in the right direction.

But the best is to stay out of it.

[old,not bold]

From my personal experience the biggest single factor in flying in IMC when not trained, qualified or experienced in doing that is huge and unjustified over-confidence in one's own ability. This applies to people under about 40 years old.

Paradoxically, the IMC Rating, in my day, and I guess the IR(R) today, had/have the dual effect of improving PPLs' ability to fly safely in IMC, while increasing their unjustified belief that they can do it perfectly, even when things go slightly wrong.

(In my case, "things going slightly wrong" was an engine failure (of the only engine) while climbing through cloud to "VFR on top" over hills, which was a challenge I felt quite unprepared for, even though I had an IMC Rating.

[Flyingbadge]

I completed my U.K. PPL a few years ago and during training we did a fair bit of 180 turns (2 minute turn?) under foggles and also a full hour of unusual attitude recovery. I was also flown into a cloud to try it out for real.

[ShyTorque]

and take your feet of the pedals.

Don't try that if you are flying a helicopter. Keep the ball in the middle!

[visibility3miles]

Do the fires and extreme levels of smoke have anything to do with this?

I know from personal experience as a VFR PPL that smoke can reduce the visibility well below what is reported just when you'd like to know exactly where you are.

[visibility3miles]

As to flying VFR at night...

(My training included several hours of IFR training under the hood.)

[Edited to add that I've had actual IFR instruction, including flying through clouds, but not enough to try it solo.]

Everywhere I've flown under VFR conditions at night in the USA, there are so many lights on the ground that there's no chance I could confuse which side is up, at least under conditions I'd risk flying.

I can easily imagine that most of Australia is far darker on the ground once you get away from coastal regions, hence far harder to discern a horizon.

https://en.wikipedia.org/wiki/John_F._Kennedy_Jr._plane_crash

July 16, 1999, John F. Kennedy Jr. (https://en.wikipedia.org/wiki/John_F._Kennedy_Jr.), son of US president John F. Kennedy (https://en.wikipedia.org/wiki/John_F._Kennedy), died when the light aircraft he was flying crashed into the Atlantic Ocean (https://en.wikipedia.org/wiki/Atlantic_Ocean) off Martha's Vineyard (https://en.wikipedia.org/wiki/Martha%27s_Vineyard), Massachusetts (https://en.wikipedia.org/wiki/Massachusetts)....

The official investigation by the National Transportation Safety Board (https://en.wikipedia.org/wiki/National_Transportation_Safety_Board) (NTSB) concluded that Kennedy fell victim to spatial disorientation (https://en.wikipedia.org/wiki/Spatial_disorientation) while he was descending over water at night and consequently lost control of his plane. Kennedy did not hold an instrument rating (https://en.wikipedia.org/wiki/Instrument_rating) and therefore he was only certified to fly under visual flight rules (https://en.wikipedia.org/wiki/Visual_flight_rules). At the time of the crash, the weather and light conditions were such that all basic landmarks were obscured, making visual flight challenging, although legally still permissible...

[jonkster]

my 2c, as others have said, VFR into IMC has been a problem forever. I do not know if it is more prevalent now, suspect it is not but do not have evidence to categorically say.

I seem to remember an article in one of the old Aviation Safety Digests lamenting how regularly they reported the same VFR->IFR story over and over again and seem to recall(?) the writer asking whether reporting the stories in ASD really made any difference because it kept happening.

The idea students should have instrument training so they can simply do a 180 on instruments and get clear of IMC seems a bit trite to me. I suspect a lot of VFR into IMC happens more gradually and people get suckered into IFR like the frog in boiling water. By the time they go on instruments a 180 turn into the clear is not going to be available.

Sometimes I worry students get over confident about their ability to handle the aircraft on instruments if they have a high natural aptitude and their PPL BIF training goes well. Doesn't mean we should abandon that training but it is not a cure and sometimes can give people a false sense of their ability. Do not abandon that but it is not a cure, it just helps mitigate bad outcomes in some cases.

I worry that the proliferation of GPS solutions and EFBs and panel GPS's means people are more confident about pushing on because they feel confident of navigating where in the 'old' days the fear of losing contact with the ground or having limited vis meant they were more reluctant to press on. It may save the day as well but also may cause situations to occur that didn't in the past.

Ultimately I see it is a human factors issue. Teaching human factors (in the sense of teaching people to not be human!) is I believe one of the hardest tasks of instructors and one I feel we do not really have a good grasp on how best to do it yet.

No simple answers.

[Squawk7700]

Perhaps an instructor can answer.... how long does it usually take a student to get used to flying off the AH in IMC by hand?

Surely it’s not that hard for a student to learn to climb and descend under the hood in order to simply immediately climb (if the aircraft is equipped) and to be able to descend into a known safe area by gps.

How much hood time is genuinely being taught these days, is it realistically 2 hours? Are the students ok with this at the time and then forgetting how to soon after? Are instructors doing AFR’s covering off under the hood to reinforce those skills? I know my AFR’s haven’t except for one of them which include recovering from unusual attitudes.

I guess this doesn’t help the guy who is scud running above a mountain range who runs out of options and can’t turn around as the mountains head up into the clouds. I’ve been there before myself. Committing to a climb through cloud in that situation feels as bad legally as blasting off from your local and heading through a few thousand feet of cloud. Human factors indeed...

[wheels_down]

Perhaps a government subsidy for those wishing to self fund a IF rating?

Not only could it save your arse, a CPL with a IF rating, and not many have that combo, obviously stands out more than the others to prospective employers for the first few jobs.

What’s the ratio of PPL pilots with a IF rating? 5%?

[Frontal Lobotomy]

Jonkster I think it is the centre page of ASD #82 from November 1972 to which you are referring:

"What More Can We Say

WITH one exception, every Aviation Safety Digest produced in the past two years, this one included, has dealt at length with the unhappy results of attempted visual operations in "Below VMC" weather. The one exception is more than offset by the fact that last year's March issue was given wholly to a detailed study of accidents in this category. In addition, nearly all these issues have included editorial and technical comment on the attitudes of mind and the operational circumstances that combine to produce accidents of this type. In this two year period, 17 accidents of this type have been studied in the Digest. All but three of these were fatal and, in total, they cost a staggering 52 lives.

Eight years ago, a similar "Below VMC" accident trend, though on a much smaller scale, developed during the winter months of 1964. Some very forceful Departmental publicity followed, including a personal letter to all general aviation pilots from the Director-General, as well as a detailed analysis of each of the accidents in the Aviation Safety Digest. It was subsequently most encouraging to find that, despite the steady growth in general aviation activity that followed this time, there was only one further fatal accident of this type in Australia for almost five years. Unfortunately as it turned out, this proved to be only the calm before the storm, for in the latter part of 1969 and throughout 1970, there was a veritable spate of accidents, most of them fatal, in the same category. It was these that prompted the very emphatic treatment of the subject in our March issue last year.

To judge from our 1964 experience and what followed, it seemed reasonable to suppose that this further publicity in the Digest might prove similarly efficacious in averting future potential accidents of this type. Regrettably, the issues that have followed tell quite a different story and any such pious hopes have been well and truly shattered.Now, having examined all these further accidents at length, and having considered and discussed in depth the reactions and motives that combined to bring them about, we must confess to having almost scraped the bottom of the safety education barrel on the subject. So what more can we say about this seemingly elementary problem which yet continues to be responsible for such a high proportion of our general aviation fatalities?

Much of the trouble associated with unforeseen disasters of this type seems to be that their symptoms are so very subtle; Flying is such an enjoyable and effortless way of getting from A to B; To a qualified pilot, even if not greatly experienced, a modern, comfortable and speedy light aeroplane is so easy and satisfying to handle; On the other hand, it can be so very frustrating when unexpected cloud or poor visibility dictates that this desirable means of transport should be turned back and landed at some "alternate" aerodrome to wait hours, or even overnight, for some improvement in the weather.Indeed, it is the very performance of our machine itself, that makes it all the more frustrating, for we know that we could be through that "little area of dirty weather" in only a few minutes. And our aircraft seems so safe, solid and reliable - surely it is worth "giving it a go". After all, we can still turn back if we find the going too tough, so where's the problem?

The whole trouble with this reasoning is that, by the time the pilot has learnt to his horror that there is indeed a problem, it is already too late - more often than not the aeroplane is completely out of control in a screaming spiral dive! It's not good enough to say "it won't happen to me!" Pilots who are not instrument trained but who insist on pressing their luck in marginal weather, even "cautiously'', will sooner or later find this out for themselves. And what of those pilots who have the ability to fly on instruments,but who yet, in their own wisdom, choose to compromise the very terrain clearance standards that hard-won experience has consistently shown to be vital to safe flight in Instrument Meteorological Conditions? when their moment of truth comes, they probably won't have enough time to reason why!

Sceptical readers need not take our word for these claims - intelligent study of all material referred to will establish the facts clearly enough. Perhaps the greatest tragedy of it all is that some of the victims caught in these situations are not the swashbuckling, press-on-regardless, accident-going-somewhere-to-happen types we might expect. They are quite often ordinary, normally careful and responsible private pilots, who simply don't recognise their limitations.

All that needs to be said about the mechanics of these accidents has been repeated ad nauseam in the Digest over the past two years. We make no apology for having continued to cover this subject - the need for repetition is not of our making and, in fact, we would like to be able to devote space to other air safety problems. We therefore earnestly suggest that you re-read what has been said on the subject in the Digest over the past two years - it could literally mean the difference between life and death - YOURS! ...,."

[jonkster]

Jonkster I think it is the centre page of ASD #82 from November 1972 to which you are referring:

"What More Can We Say

WITH one exception, every Aviation Safety Digest produced in the past two years, this one included, has dealt at length with the unhappy results of attempted visual operations in "Below VMC" weather
...
[snipped/]
...
Regrettably, the issues that have followed tell quite a different story and any such pious hopes have been well and truly shattered.
Now, having examined all these further accidents at length, and having considered and discussed in depth the reactions and motives that combined to bring them about, we must confess to having almost scraped the bottom of the safety education barrel on the subject. So what more can we say about this seemingly elementary problem which yet continues to be responsible for such a high proportion of our general aviation fatalities?
...
[snipped/]
"

yep, pretty sure that is the one, thanks FL
:(

[Lead Balloon]

Would that this were were the case.

There were 163,695 estimated private pilots in the US as of 12/31/18, and, according to the FAA, 47.961 had instrument ratings.

https://www.faa.gov/data_research/aviation_data_statistics/civil_airmen_statistics/media/2018-civil-airmen-stats.xlsx

You seem to be misreading the tables. Table 11 says that (as at the 2018 period) 68% of US pilots have instrument ratings. Sensibly and appropriately, that table ignores holders of licences that authorise operations only in VMC.

It is true that thorny’s ‘nearly 80%’ is an exaggeration of the actual 68%, but so is your implied suggestion that the percentage is only around 30%.

[421dog]

Nope. Table 10, I believe, enumerates the number of Ppls who have instrument ratings. It doesn’t make any sense to look at all pilots, because more than half are cpl/atp types, who overwhelmingly are instrument rated.

my numbers are, I believe, correct, and extracted from the data supplied.

an instrument rating over here involves essentially as much training (hour wise) as a ppl. The vast majority of private pilots are not so rated.

[poteroo]

Is Prevention better than Cure?

If education and recurrent awareness and training is what 'prevention' offers - then Yes!

It is very helpful to students if the instructor is able to introduce them to deteriorating conditions of both forward visibility, and lowering cloud ceiling. Until a student can actually see for themselves what we are all talking about, and they can match the published VMC minima to what's in front of them - as instructors we are not helping to minimise this all too common way of becoming a statistic.

Forward visibility estimation is only possible where the distance between certain landmarks is already known, eg, 3nm, 5nm etc. GPS distance from a 'going to' location also helps with becoming familiar with what visibility is actually being seen. With cloud ceiling, it also helps if you actually have a good GPS with a reasonably accurate database to help with height above ground estimates, but this can also be done safely by simply using the altimeter and flying over a location of known height amsl in VMC.

The above only 'works' when you have a good VMC fallback position for 180 degrees of horizon, which allows for skirting of poor weather with clear cut escape direction. But, I have found it useful.

For what it's worth......

[Lead Balloon]

Nope. Table 10, I believe, enumerates the number of Ppls who have instrument ratings. It doesn’t make any sense to look at all pilots, because more than half are cpl/atp types, who overwhelmingly are instrument rated.

my numbers are, I believe, correct, and extracted from the data supplied.

an instrument rating over here involves essentially as much training (hour wise) as a ppl. The vast majority of private pilots are not so rated.
I see the point you are making, but I still disagree with your conclusion.

You will see from the notes that the categorisation is by reference to the ‘highest’ qualification held, and therefore the holder of both commercial and private pilot certificates is counted in the statistics only as a commercial certificate holder. Those persons can (and do) still engage in private flying.

[GAGuy]

When I was earning my instrument rating and after I had become pretty cocky on my ability to fly the gauges, my instructor took me up into a layer of thick stratus. I'm hooded, climbing out and before we hit the clouds, my instructor said to take the hood off and look around. I did. Nice view. Then suddenly we're in a bowl of cotton candy. Old crappy trainer, the air vents start leaking water. My heart rate went up times two. I'll never forget that day and how true IMC felt the first time.

This October past I earned my CFI. It's not in the syllabus, but I would love to give my students a flight into real IMC. Of course they wouldn't pay for it.

[421dog]

Yes (we) do, and I would posit that VFR into IMC is not a big problem for most of us who are in that category.

Upon receiving a new certificate in FAA-land, the airman surrenders his previous one. Thus, when you pass your commercial check ride, you cease to be a private pilot forever more, even if you only maintain a 3rd class medical and never shoot another approach or submit to another IPC.

[Lead Balloon]

That may be true, but so far as the stats you are quoting are concerned it means that the private pilot certificate holders who obtained their IFR rating before becoming commercial or ‘higher’ certificate holders are ‘lost’ to the stats once they get that ‘higher’ certificate.

Tell me where in the stats it shows how many commercial or ‘higher’ certificate holders obtained their IFR rating as private pilots before becoming a commercial certificate holder. Your previous assertion as to the numbers assumes that no pilot who moved from being a private certificate holder to a ‘higher’ certificate holder in the US obtained an IFR rating before doing so. That’s a rather brave assumption.

[Old Akro]

I'm with Thornbird.

CASA's approach to IFR ratings costs lives.

Since GPS and the ability to "follow the magenta line" IFR ratings should be materially easier. There's no need for NDB, VOR or DME approaches. ILS is not really needed (we hardly have any that are accessible to GA). The theory should be a shadow of what IREX was. The only reason I can see for the gap between the proportion of pilots with instrument ratings in the US compared with Australia is bloody minded bureaucracy. And we should call out that it costs lives.

[knackered IV]

All very good talking about IMC training for new pilots but unless you're going to have some sort of recurrent training mandated, it will all be for nought. Many of these accidents involve pilots who have had their licences for years. As you know, unless you regularly fly IMC, or have been doing it so long it's become second nature, you need regular refreshers.

[421dog]

That may be true, but so far as the stats you are quoting are concerned it means that the private pilot certificate holders who obtained their IFR rating before becoming commercial or ‘higher’ certificate holders are ‘lost’ to the stats once they get that ‘higher’ certificate.

Tell me where in the stats it shows how many commercial or ‘higher’ certificate holders obtained their IFR rating as private pilots before becoming a commercial certificate holder. Your previous assertion as to the numbers assumes that no pilot who moved from being a private certificate holder to a ‘higher’ certificate holder in the US obtained an IFR rating before doing so. That’s a rather brave assumption.


An instrument rating, in the US, is not a certificate, per se. If, as is the case with me, one held a PPL with an instrument rating before receiving a commercial certificate, the instrument rating “follows” one to any subsequent certificate.
There are, in fact, quite a few commercial certificate holders who do not hold an instrument rating (mostly Ag pilots), so I think that the denominator would hold true for them as well when it comes to NIR into IMC crashes.
What I am getting at, is that really, a minority of private pilots (nowhere near the 68% you posit) have an instrument rating.

[Lead Balloon]

Your argument reinforces my point.

I got the 68% figure from Table 11.

You said, in effect, that the 68% figure isn’t a reliable indicator of how many private certificate holder have IFR ratings because the 68% covers a whole bunch of commercial certificate holders as well. I said that a whole bunch of those commercial certificate holders may have obtained IFR ratings before they obtained their commercial certificates.

Now you’re saying that a bunch of commercial certificate holders don’t hold IFR ratings. If that is correct, it would inexorably follow that the 68% covers a correspondingly greater number of private certificate holders.

Until that 68% figure is ‘sliced and diced’ in a way that can identify the ‘certificate history’ of the holders of IFR ratings, I do not think it’s reasonable to use phrases like “the vast majority” of private pilots don’t have instrument ratings (although I note that you’ve moderated your language to a “minority” do).

[421dog]

I’m sorry, but I have no more time for this inanity. You are wrong, as you well know.
The vast majority of PPLs don’t have instrument rratings, and essentially no CPLs die as the result of the transgressions in question.

Enjoy your weather down there.

I just flew my first trip today (IMC from 10 min after takeoff until 20 mi before landing) in the last 16 that didn’t end ind in an instrument approach.

no drama, nobody died, I am a current, instrument-rated pilot, and just happen to currently posses a third class medical, so I can only exercise private privledges.

[ZAZ]

Back in the 1960's I wrote to the then Department, and suggested that at the completion of the Private Pilot Licence flight test the applicant be placed under the hood and be required to make a 180 degree turn without losing altitude. After entering the probable spiral dive the hood could be removed when the examiner considered control had been lost and any continuation would result in an accident. The examiner could reinforce the lesson to be learned after the flight and the new Private Pilot would have seen first hand the results of flight into IMC.

This suggestion was obviously not considered to be very helpful as I never heard of it being implemented and I never had a response from the Department.

I agree a simpler and cheaper IFR rating would help.

The PIFR is about as cheap as it gets.
As a CIRSEA holder since 1987 I dropped back to PIFR in 2010 and have done biennial renewals/reviews at SHT on the MNG VOR and SHT NDB with the flight school and biennial cost was under $500
Providing you practice your recency faithfully there is no issue in staying current.
As for VFR into IFR imo its the guys who tell you IFR is crap who are the ones who always push the elements.
And they always make a point they think we ifr guys are arrogant idiots always pushing them out if the way.
Wierd attitude.
Getting to IFR from VFR in view of a recent local quote I got fir a bfr review of $1000 is probably going to die a death like the hapless souls who fly controlled into high terrain probably on their gos dead in track.

[ZAZ]

I’m sorry, but I have no more time for this inanity. You are wrong, as you well know.
The vast majority of PPLs don’t have instrument rratings, and essentially no CPLs die as the result of the transgressions in question.

Enjoy your weather down there.

I just flew my first trip today (IMC from 10 min after takeoff until 20 mi before landing) in the last 16 that didn’t end ind in an instrument approach.

no drama, nobody died, I am a current, instrument-rated pilot, and just happen to currently posses a third class medical, so I can only exercise private privledges.

Did you check your tolerance on flight radar and your track keeping or was it autopilot flying the plane.
What a foolish admission to make on social media!
Officer I have a porsche and I drive it at 100 in a 65
Do your passengers kniw you are flying illegally
.

[ZAZ]

When I was earning my instrument rating and after I had become pretty cocky on my ability to fly the gauges, my instructor took me up into a layer of thick stratus. I'm hooded, climbing out and before we hit the clouds, my instructor said to take the hood off and look around. I did. Nice view. Then suddenly we're in a bowl of cotton candy. Old crappy trainer, the air vents start leaking water. My heart rate went up times two. I'll never forget that day and how true IMC felt the first time.

This October past I earned my CFI. It's not in the syllabus, but I would love to give my students a flight into real IMC. Of course they wouldn't pay for it.

Never went into imc?
I guess Sth Cal is sunny all the time, but what about the highbterrain to the east?
no clouds?
Where I live in sw vic back in 1987 trying to get out vfr was a mugs game.
Did the I follow railway lines crap and then upgraded with casa to class 1 stayed that way until 2010 for 5000 hours in single engined cessnas.
Then went to our new pifr which was the ONLY concession afforded to ifr guys in three decades.
And now its a two year review and you have to ge honest with yourself in both recency and currency, though I now see under new licencing the pifr has been tightened up.
Its now 2020 have done about 30 ifr flight tests and would not swap with vfr guys for a million bucks.
IMO its always the vfr guys protesting the degree of difficulty in upgrading not the IFR guys maintaining their profficiency.
And now with flight radar everyone knows how well ifr guys are at track keeping and maintaining tolerances lol!

[421dog]

Did you check your tolerance on flight radar and your track keeping or was it autopilot flying the plane.
What a foolish admission to make on social media!
Officer I have a porsche and I drive it at 100 in a 65
Do your passengers kniw you are flying illegally
.

What the heck are you implying? I am in no way flying illegally. I am simply saying that, as I obtained my 2nd class medical more than a year ago, it has “degraded” to a 3rd. I am flying myself under part 91 for business, and not operating for hire, so I’m perfectly legal to operate with private privileges.


I was just pointing out (well, kvetching really) that even one operating only as a private pilot can be very current (about 300 hrs a year for the past 5) and very competent in the clag (as above).
Weather here sucks, lots of ice and clouds. Even the ducks would rather be in Florida...

be nice...

[Rarife]

Guys, you really say that there are PPL pilots out there who can not fly rate one turn under hood just with instruments? I understand they can not fly departures, arrivals, approaches and all that serious IFR things but simple turn?

[jonkster]

I am sure most could do it under the hood. They would have demonstrated that umpteen years earlier when getting their licence.

Problem is when it happens for real some time down the track and they do a rate one turn and find themselves still in the clag and in real life with no one to help. And they are at low level because they have tried to get under deteriorating conditions that looked sort of OK until a few minutes ago. And now do not know where they are in relation to the terrain. And seeing little bits of ground appearing when they do not expect it and it appears to be at an angle they do not expect while turning they get the leans. And having only ever done instrument flying under the hood, not for real, always with an instructor next to them and even then rarely and under no real pressure, they start to panic and turn to wherever they thought was better but it doesn't get better.

I still think the idea that exiting IMC by a simple 180 turn is probably not actually an option available when this situation claims VFR pilots. By the time they are onto instruments they have already dug themselves way past that. The situations that are resolved by a 180 turn I suspect never make the accident reports.

[Frontal Lobotomy]

A very stressed VFR pilot who has just entered IMC needs to get their act together quickly. Maybe turn away from rising terrain, if possible without entering a spiral dive, and set the aircraft up in a climb (500 fpm) on a fixed heading whilst you calm down.

Sure you may still hit solid clouds or encounter icing conditions but at least you are in control of the aircraft. I am just stating what worked for me many years ago. 15 minutes later I popped into bright sunshine at 8500’.

[machtuk]

The myth: one second it's VFR next second it's IMC. Upon entering none VMC you go on the dials, exicute a basic 180deg turn back in to clear sky.

Reality: It's turbulent, you've been getting further and further beyond yr limits visually and getting lower and lower to stay visual, at times not far above the ground, the rain is now a factor, you are sweating getting very tense with viz slowing deteriorating to conditions you've never experienced before. You have family onboard the wife is firing off questions beyond what you can answer with any certainty. The kids are starting to get upset due turbulence and the rain now pelting the aluminium can you are all in. You know you have really stuffed up and attempt to squint further into the muck, it doesn't feel right, noises are getting louder, the dials are all over the place, yr GPS ground speed has increased a lot, you are shaking, the wife is now screaming louder than the wind noise, the G forces are nasty & combined with the bad turbulence you are totally confused, you emerge from the bottom of the cloud and instantly see the ground at a 90+ deg angle, you pull back hard but the trees rush up rapidly.......lights out!!

YOU are the ultimate protection!

[Centaurus]

and also a full hour of unusual attitude recovery. I was also flown into a cloud to try it out for real.

Do I detect just a wee bit of embellishment with that statement?

[Repos]

OK , I though it was relevent but I've deleted it now.

[Rarife]

I did not mean that 180 turn will save you. I though the problem was that they can not even fly basic things without looking out of the window. Sure you just can't turn back. When you realise what is going on it is too late.

But even the idea to push close to ground so you can see is really bad. I understand that VFR pilot wants to see but they should know. Just keep it straight, maybe turn back and call for help if you can't navigate yourself out of it.

We had accident like that few years ago. She got into VMC (PPL, maybe 70-80 hours total), called ATC for help and ended up in a hill. She was so scared and lost that I could not finish whole communication recording.

[ZAZ]

Guys, you really say that there are PPL pilots out there who can not fly rate one turn under hood just with instruments? I understand they can not fly departures, arrivals, approaches and all that serious IFR things but simple turn?
t
Its not that simple!
U turn to safety is fine in theory
other factors such as turbulence emotional adrenelin kick in
and the way back thru the sucker hole may have closed off

I remember in more recent tests drifting off into uncommanded turns will fiddling with the comms panel
scanning takes practice practice practice
and now it is mandatory to demonstrate low and slow down low
for obvious reasons

IFR is a skill that you quickly lose if you dont regularly practice or exercise in flight
its why recency is a legal requirement in all classes of IFR
and a highly reccomended activity if we arecall being honest with ourselves

By the way after all that is said here
i profess to have chickened out of IFR flying after seeing errors develope in my flying that all the training in the world did not correct all there to see on flight radar

everyone stalks flight radar now as you saw with the crash of the c130
it was on tv within the hour

altitude heading speed and rate of descent

take a look at your last flight type in tail number its all there to see especially the crashes

Angel Flight vfr into imc Mt Gambier for one
Angel Flight near Warracknabeal results shown to us in a CASA safety seminar was sobering evience to see
nothing excuses that sort of pilot behavior
nothing

[Squawk7700]

A very stressed VFR pilot who has just entered IMC needs to get their act together quickly. Maybe turn away from rising terrain, if possible without entering a spiral dive, and set the aircraft up in a climb (500 fpm) on a fixed heading whilst you calm down.

Sure you may still hit solid clouds or encounter icing conditions but at least you are in control of the aircraft. I am just stating what worked for me many years ago. 15 minutes later I popped into bright sunshine at 8500’.

This has worked for many a pilot. The worse similar scenario though is when it doesn’t clear up at 8,500ft. Then you have the added complexity of calling up ATC and trying to work out with them where to come down again. You could be stuck in the cloud for a long while when this occurs. Plenty have done that successfully also. It’s much easier and less embarrassing to scud run whilst dodging mountains though, especially if you can make it through. It all depends on how desperately you want to get there.

Years ago I needed to always get there. Nowadays, I don’t.

The most dangerous thing on my aircraft..... is a schedule.

[sudden twang]

Didn’t EASA run a seminar for exactly this situation a year or so ago?
It involved a sim session and debrief with the aim of prevention in the future.

[jmmoric]

Don't try that if you are flying a helicopter. Keep the ball in the middle!

Thanks, that one made my day :)

It’s much easier and less embarrassing to scud run whilst dodging mountains though, especially if you can make it through..

I'd rather be embarrassed than deceased? And there's nothing embarrasing in admitting a bad decision.

From an air traffic controllers point of view, we will do our outmost to help if you get into trouble, noone is gonna yell at you on the frequency. We do understand that everyone makes a bad jugdement from time to time, and there's no need to kill the guys over that.

Even the authorities will normally go easy on folks now a days, they won't say "good job" or pad your back, but they will not fine or jail you either.

[pa28warrior]

This was over 36 years ago during flight training. Me and my CFI checked the weather teletype (I told you it was a long time ago) and he "signed off" on my flight from a tower-controlled airport inside a radar-service area (I am not current and only fly as a passenger, so I don't know the current alphabet soup).

Climbed out and started encountering the cloud layer. My first reaction was "no big deal" because I had flown commercial out of that same airport and staring out from a window seat, crossing the cloud layer and coming out on top was such a conditioned experience. My next reaction was, "not cool -- I am not legally allowed to do this." My third reaction was, don't make your trouble worse, level off and key the microphone. "Departure, Warrior Thirty-Echo, it's kind of cloudy up here, I would like to turn around. Student pilot." I learned that last phrase from just having attended an FAA Safety Seminar.

The controller was exceedingly kind, gentle and non-scolding. I was vectored around until I get sight of the runway, where I was cleared to land. When I tied down the airplane, the guy behind me was the eye-in-the-sky traffic police officer. His weather info sent him up, too, but it was not a day to catch speeding motorists from the air.

Thanks ATC!

[Mr Approach]

2 things:
1. I met an FAA instructor once who had flown out of Long Beach where he said IFR flight into VMC was commonplace (apparently instructors must have IFR licence) or they could not find any VMC to reach VFR! He did not like the Australian rules to instructors which apparently forbid such a practice, hence removing from students the experience of getting used to being in cloud and the difficulties they could encounter. He thought that was more value than teaching how to get out of trouble. This also assumes his flying school aircraft were equipped for IFR flight which also might be different in Australia. (Disclaimer: long ago conversation so details might not be accurate)
2. In conjuction with this post, a note about requesting special VFR clearance. According to ICAO PANS/ATM Doc. 4444 Para.7-14, this can only be issued by ATC to allow a VFR pilot to transit non-VMC conditions for the purposes of arriving, departing or transitting a Control Zone. Australian regulations modify ICAO in Part 172 Manual of Standards para 12.1.3 to allow Special VFR in Control Area, and not for transit purposes.

I recently heard Channel 9 news state that ATC had "allowed" the Kobe Bryant helicopter pilot to fly in non-VMC conditions, this is apparently (subject to NTSB Interin Report) true, but Ch. 9 is ignorant of the purpose of a Special VFR clearance. The only reason a controller should refuse a Special VFR clearance is if he/she cannot separate the aircraft from IFR or other Special VFR aircraft in the Class C or D control zone. Normally VFR flights in Class C or D can simply have traffic information on other VFR flights, but not under Special VFR. The controller is not required to make an assessment of whether Special VFR conditions exist, that is the pilots job, however controllers do have a duty of care to pass on relevant information such as a recent IFR pilots estimate of the visibility, and confirm the pilot still wishes to proceed Special VFR.
So VFR pilots, do not assume that a Special VFR clearance contains a clearance to operate in less than the Special VFR minima for your type of aircraft, that is your job - it simply means that there are no other aircraft in your way.

[Squawk7700]

Special VFR is very grey and always has been. They let potentially low time inexperienced VFR pilots into sub-optimal situations with very poor visibility.

My first intro to Special VFR was a very long time ago into Moorabbin. ATC told me it was IFR only, however I could request special VFR if I wanted to and continue as normal. So I did.... let’s just say I was very surprised anyone could fly VFR at the time and it felt like an accident waiting to happen.

If you didn’t know the rules you’d assume special VFR required an IFR rated pilot and IFR equipped aircraft, but without the requirement to follow full IFR procedures. It feels like that’s the way it should be.

[ve3id]

In Canada we have a VFR-Over-the-top rating, which I picked up along the way to the CPL. It has a lot more instrument training than the night rating, seemingly to help if you get to dest and the forecast VMC is not there, as well as keeping level between layers.

Even before that, my night rating was enough to get me out of a bone-shaking foray into severe mechanical chop with IMC at night, while in the Toronto Terminal zone You know it's serious when the controller's voice is replaced by an older, more experienced-sounding one!.

The secret is practice. My instructors would never have made a living if they only flew in CAVU - the area around the Caledon Hills North of YYZ is notoriously unstable. Transiting to the practice area was often under the hood just to make sure I could keep the plane level.

[Mr Approach]

Squawk7700,
In my opinion ATC should not have "offered" Special VFR.
It is the pilot's prerogative and if the pilot does not know about it then that is a good reason not to mention it!
Special VFR requires the pilot to be able to navigate visually:
By day, when VMC do not exist, the ATC unit responsible for a control zone may issue, at pilot request, a special VFR clearance for flight in the CTR, or in controlled airspace next to the CTR for the purpose of entering or leaving the CTR, providing
(AIP ENR 1.2):

the special VFR flight will not unduly delay an IFR flight
the flight can be conducted clear of cloud
the visibility is not less than

1600 m for aeroplanes
800 m for helicopters
for balloons, not less than 100 m below 500 ft AGL and 3000 m at and above 500 ft AGL

a helicopter is operated at such a speed that the pilot has adequate opportunity to observe any obstructions or other traffic in sufficient time to avoid collisions and
the flight can be conducted in accordance with the requirements of CAR 157 regarding low flying (see page 1.28 (https://vfrg.casa.gov.au/general/pilot-responsibilities/in-flight/) ).

[jmmoric]

There are cases where the conditions for VFR in a control zone applies, but depending on where the VFR flight is, he may opt to request Special VFR.

For instance, the weather is fine, but the aircraft has to cross a ridge, which will bring him closer to clouds than the prescribed VFR minima for the CTR, the only option would be to ask for special VFR (or fly around).

Noone does that though..... eventhough they remove the safety built into the class D airspace where "see and avoid" applies between IFR and VFR by removing the 1000 ft separation from the clouds where IFR flights will be dumping out.

I don't think 4444 mention that you are not allowed not to offer special VFR? Just never even mention the word "VFR" to an IFR flight... or even think about it (they'll come during the night and drag you off).