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Campaign for a proper instrument rating

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Old 20th Nov 2002, 10:48
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Arrow Campaign for a proper instrument rating

Campaign Private Pilot IR!
The lack of an available instrument rating for the private pilot has been a common theme on this forum.

It would seem most agree that the JAA IR does not provide a wholly relevant theoretical framework for the private pilot. Moreover, the renewal requirements would seem unnecessarily onerous for the private pilot.

The IMC rating provides a reasonable alternative, but its national status and restriction to national territorial boundaries would seem contrary to a pan European licensing system. Moreover the holder is unable to operate in the lower airways.

In consequence many have chosen to hold the FAA IR and re register their aircraft on the N reg., arguably demonstrating that it is safe to operate a privately owned single with lower airways capability on a license that is realistically obtainable and maintainable by a private pilot.

It seems to me that the GA fraternity should be a powerful lobby both in the UK and through out Europe. Moreover in one way or another we pay for much of the airspace infrastructure. Surely if the GA community want and can justify a European IR aimed at the private pilot with a sufficiently vigorous campaign it may be achievable, or are we as a group just too disorganised or lacking in a sufficiently representative body?


.........

I have added this edit because it would be interesting to see what we would wish changed in the PPL IR. My own views at this stage would be:

1. A single examination using the multiple choice approach for which the study could be entirely undertaken at home. Why? The rating we need is a private rating not a professional rating like the current IR. The theoretical training therefore should be concerned with assessing whether the applicant has the technical knowledge to operate a light piston aircraft within European airspace in an IFR enviroment. The CAA believes that is achievable with the present IMC rating theory test within the UK . What would change is access to the lower airways and European airspace in IMC so deal with the theoretical knowledge required for this access in the same way,
2. I see know reason to change the in flight training required. Around 40 hours seems not unreasonable, possibly with some exemption for existing IMC holders,
3. Instructors able to provide IR training are few and far between. Instructors presently qualified to provide IMC training and testing should be permitted to provide PPL IR training and testing,
4. The curreny requirements should be based on the FAA model.

Last edited by Fuji Abound; 20th Nov 2002 at 12:41.
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Old 20th Nov 2002, 12:19
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Fuji Abound

Yes, we probably are too disorganised at the moment - but we shouldn't let that be an excuse. Let's get organised and start lobbying.

In a few years from now, if GPS approaches are accepted, it will become increasingly practical to use private aircraft for business travel between small airports with limited infrastructure. So pilots are not the only interested parties in this debate - it's in the interest of aircraft and avionics manufacturers, airfields and training organisations, among many others. If we have a coherent message, it should be possible to get a lot of support. (I'm having an optimistic day today! )

If we campaign, we'd need to be clear on what we are campaigning for. Is it a JAA version of the IMC rating, designed to be accessible to private pilots while keeping them nicely separated from most commercial traffic, or a "full blown" IR? My vote would be for the latter - accepting that it would still be hard to obtain (and retain) and cost many thousands of pounds.
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Old 20th Nov 2002, 12:54
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May I suggest a poll just to see how many here would be interested in a PPL IR, and maybe how much they would be willing to pay?

I for one agree we should have a JAA PPL IR, or be able to use an FAA IR with G reg. A/C

Regards,
LF

editied 'cos the G Reg said N Reg ..... fool

Last edited by long final; 20th Nov 2002 at 15:24.
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Old 20th Nov 2002, 12:58
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LF:
I for one agree we should have a JAA PPL IR, or be able to use an FAA IR with N reg. A/C
ZAP!!

Both your wishes are granted Long Final.

There is a PPL IR available under JAA

AND

You CAN use an FAA IR with an N reg. A/C

How's that for starters
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Old 20th Nov 2002, 12:59
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Damned good idea.

At present the IR is clearly designed to allow a huge range of aircraft to be operated, in virtually any conditions.

Strikes me that in the same way JAA have effectively made PPL/CPL/ATPL modular, the same might be the way ahead for an IR.

For the sake of argument, lets say there were three levels, which I'll term IR1, IR2 and IR3. One could perhaps peg them:-

IR1 - non air transport use, not above FL100 / 140kn, 500 ft local cloudbase during let-downs.
IR2 - commercial use, not above FL249, 250ft local cloudbase during let-downs. P2 to an IR3 holder.
IR3 - unrestricted instrument flying, subject to limitations of the aircraft.

Peg the experience, training and exams against each, level, and set it up so that it's possible for the holder of each level to simply do the next chunk of work for the higher rating if required.

I'd have thought in general, IR1 would probably correspond to an IMC but include lower airways, IR2 to an FAA IR, and IR3 to a JAA IR.

I disagree with Fuji on one point, I think that exams should be properly supervised, otherwise the risk of abuse and consequent loss of credibility is too high. But, no reason that the necessary exam(s) can't be administered in the flying school.

G

Rustle's point is all very well but:-

(1) Not everybody wants to have to run a foreign registered aeroplane, particularly when French customs will keep trying to charge import duty on it.

(2) Whilst JAA permits a PPL/IR, it's the full IR and even holding an FAA IR gets you no credit at-all unless you've got at-least 1500 hrs P1.

G
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Old 20th Nov 2002, 13:21
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I'm definitely all for this.

However, it would need to be, at the very least, JAA-wide, if not ICAO-wide. The UK CAA can introduce as many ratings as it likes, but unless other authorities recognise these ratings they're no use outside the UK.

Is there an international lobby who could push for something like this?

Out of interest, does anyone know why the CAA make it so hard to get a PPL/IR? I assume the reason is a combination of a) our crap weather meaning everyone wants to fly IFR, and b) being a small country with a dense population limits the amount of airspace. Combine these two together, and if the PPL/IR were as easy to get as the FAA PPL/IR, I suspect the TMAs would be too crowded for the airliners to get up into the airways. Does anyone know better? Or can anyone confirm if there's any truth to my theory?

FFF
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Old 20th Nov 2002, 13:31
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Rustle - one point I would like to clear up so it does not detract form the thread is this - whilst you are correct, the point is the existing PPL IR under JAA is to all intensive purpose inaccessible to the private pilot. Why - you still have to complete an onerous and in part college based theoretical course, which includes study material relevant to commercial IR operations in aircraft other than light singles. I may be wrong but the average private pilot simply does not have time in a busy career to devote to this. Now let their be no misunderstanding, I am not proposing a new rating should be easier just so we can achieve the rating and go and kill ourselves or worse, someone else. I am proposing the theoretical training should be relevant AND manageable. After all even the old CAA PPL IR enabled you to complete the study material entirely at home. Secondly, the rating must be renewed annually at a cost of around £400 combined with the problems of finding and booking an examiner with which to do the renewal. Yep - flying is not cheap and nor is safety, but is there a shred of evidence that the American model for the PPL IR results in a less safety pilot.

And finally - yep we can of course do an FAA IR and reregister our aircraft on the N reg. My point is why! Why be put to the cost, why endorse the FAA system when we are English / British / European, and all to do something which in fact with different paperwork (an FAA IR and an N reg aircraft) we could legally do with an FAA IR in European airspace.
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Old 20th Nov 2002, 13:33
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GtE,

"(2) Whilst JAA permits a PPL/IR, it's the full IR and even holding an FAA IR gets you no credit at-all unless you've got at-least 1500 hrs P1. "

WRT your point 2 copied above, please have a read of this:

http://www.caa.co.uk/docs/175/srg_fcl_gid15.pdf

See page 8 in particular, where there is a really neat chart showing the requirements under various circumstances.



The other day someone on this forum said they couldn't find this on the CAA website.

It took about 10 nano-seconds for the search engine, provided by CAA, to find exactly the right document
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Old 20th Nov 2002, 13:34
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Genghis

Isn't the difference between non commercial and commercial use adequately catered for by attaching the IR to either a PPL or CPL?

In my opinion, if PPL/IR holders are to fly in controlled airspace in instrument conditions, they need the same level of instrument flying proficiency as CPL/IR holders.

Your IR1 proposal is quite similar to a UK IMC rating, but without the UK's over-restrictive use of class A airspace. In France, most airways are class E up to the flight level where you are realistically likely to encounter commercial traffic.

If the JAA could combine French airspace definitions with a UK IMC rating, we would achieve the desired result. That would involve fighting a battle on two fronts, though (airspace and licensing) and is not likely to happen.

I think the issue is less to do with the privileges of an IR, but more the accessibility of it.
  • The technical exams need to cover what is relevant and required.
  • It should be possible to get IR flight training at a sensible cost (although it would probably cost a fair bit more than PPL training), and at more than the current handful of training establishments.
  • An IR examiner probably doesn't need to be a CAA employee....
  • Etc.

Something like the old "non-approved" training, but with a minimum number of hours training, and without the 700hrs total time entry requirement.
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Old 20th Nov 2002, 13:36
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Gengis

What a complicated and beaurocratic mess There is a perfectly decent, safe and proven model for all this, where to fly in clouds you need an ICAO IR, and that's about it. Unfortunately it's 'over there' so in the eyes of many must be inferior.

I guess you are saying an IR3 (airline pilot) is better than an IR1 (warrior pilot). Do you think that a 737 pilot who never flies a PA-28 is going to be better/safer at flying a PA-28 to 200ft DH than an IR1 who does that every other day? It's not so! Type ratings are the way to introduce this IR1, IR2, IR3 complexity. Insurance companies are also effective at mandating training for the IR2 type of plane, as would be actual testing of IR skills on a multi engine plane before you could fly it.
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Old 20th Nov 2002, 14:00
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Interesting thread...

FFF,

your theory is shocking. For starters, the TMA's are already full, as are the airways feeding them - hence slot times and height capping.

Don't you read your NOTAMs?


Fuji Abound,

The "old" CAA PPL/IR theory course was able to be done by distance learning (aka home study) but there was a mandatory classroom element. Surprise, surprise, the exact same rules apply to the JAA version. (FTR, this also applies to JAA ATPL theory, but the classroom elements are longer)

Yes, you are required to fly an IR-renewal annually. Good! I do mine with my MEP annual renewal - hardly onerous...

My comment about the FAA IR use in N reg was purely an answer to LF's request - tongue-in-cheek
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Old 20th Nov 2002, 14:32
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Couple more comments

Airways conjestion - The airways are conjested however lets me honest, effectively preventing the private pilot from using the airways may well be a sound political expedient but I am not sure any more valid from preventing some road users using the motor way because they arent rated to do so. Moreover I suspect few private pilots will be operating above FL120 much of which may become deregulated anyway under the new European airspace proposals.

Renewals - doubtless there are a multitude of opinion on what is required to remain safe on instruments and for that matter in VMC. However surely what matters is the evidence. Consider the American model for the FAA IR and their renewal proceudure and then consider their safety record in terminal airspace at least as conjested as ours.

Moreover you can fly an approach in IMC in every terminal control zone in the UK other than Heathrow with an IMC rating - it works. and it has worked for a very long time.

Finally, and I think this the most significant point, there are many FAA PPL IRs operating in Europe. They hold a valid ICAO license that most countries accept, they fly the same aircraft as the rest of us - the only difference is they have painted an N on their aircraft. Are they less safe - I doubt it. I for one would however prefer to be regulated by our good old national authority and not by the States (as much as I like Americans!)
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Old 20th Nov 2002, 15:10
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You get my vote Fuji...

EA
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Old 20th Nov 2002, 15:20
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rustle

For starters, the TMA's are already full, as are the airways feeding them - hence slot times and height capping.

Are the airways and TMA's in the UK really full? According to 2001 movement figures, LHR is the 15th busiest TMA in the world. ORD, ATL, DFW, LAX, PHX, DTW, MSP, LAS, DEN, STL, MIA, IAH and PHL are all busier and allow PPL IFR traffic in as a matter of routine. Maybe the TMAs are not full, but the supporting infrastructure is slightly over-stretched.

As I said, there is a model out there which proves what is possible. It's attitude which prevents it happening.

Fuji

I for one would however prefer to be regulated by our good old national authority and not by the States (as much as I like Americans!)

Very nice, but a bit old fashioned Like it or not, the UK has handed it's ultimate sovereignty to Brussels by treaty. So the relevant question now is whether you would rather be regulated by the EU or the US?

Well, as far as aviation matters goes, IMHO the UK would be better taking the FARs, photocopying them and renaming them the ANO, and then becoming an FAA region. Of course you would also have to persuade the UK government that tax on Avgas is to be ring fenced and used for the direct use of the person paying the tax, sort of how the US looks at it. That would require a governmental culture shift which will not happen.

In another thread ATC people are saying that BA pays for radar services so GA should shut up. You see it's all about attitude, GA needs the clout to point out that AvGas taxes are for the benefit of GA, and ATC should be lucky they have VFR traffic to control A bit too much like the attitiude 'over there' I'm afraid. But at least I have a high quality and safe IR which was cheap to get, cheap to maintain, and respected by even the superb controllers at the busiest TMAs in the world.
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Old 20th Nov 2002, 15:20
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Reading the previous posts with interest, it appears the most desirable outcome to any campaign would be the reintroduction of the non aproved route to an IR, as suggested by Aerobatic Flyer.

However the biggest obstacle to the UK achieving this is that it would have to be part of the non JAA licence as far as I can see, so there would remain the difficulty of getting legal recognition of the rating in other countries.

The worse outcome would be to lose the IMC rating in any review of the licencing regulations.

Ghengis's shot at describing alternatives is interesting, but fraught with detail problems. For instance his IR1 speed would be too slow for a lot of light twins, his height is lower than France allows VFR airways, etc,etc.

Yes non approved, training as necessary to reach the standard, theory by distance learning, accessable annual examiners all good ideas, but perhaps the phrase non approved needs a rethink.
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Old 20th Nov 2002, 15:35
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slim_slag, you do me an injustice - I would have thought my comment about TMAs being "full" was clearly tongue in cheek, in the same manner as FFF's original question surely was.

Maybe my irony, like my CAA PPL/IR, doesn't travel across the pond

As for BA paying and GA not - two points about that old chestnut which I have discussed in 'ATC Issues' previously.

In the UK - fly an aircraft over 2 tonnes, you pay if you file IFR;
In the UK - fly an aircraft over two tonnes AT NIGHT, you pay. (because night = IFR)

Based on that discussion it's very clear most people don't actually know who pays for what
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Old 20th Nov 2002, 15:50
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Continuing the discussion (and emphasising that all I was doing was throwing an idea in the pot for people to play with):-

- The CAA/JAA IR is ICAO compliant. So is the FAA one. Should we instead find out what the minimum ICAO standard is and campaign for that.

- I proposed 140/100 because that lines up with the switch in the VMC/IMC definition and the switch to pressurised aircraft. Opinions on that? Can somebody who can afford a 200kn twin also afford a bit more training?

- Type ratings, makes a lot of sense to me. Lets say you were to have a minimum ICAO compliant IR/SEP, then type ratings for IR/MEP, IR/type etc. Similar currency requirements to the main license, and cost and complexity will automatically follow the cost and complexity of the aircraft type.

G


(N.B. Most aircrew licensing is a beaurocratic mess, you wouldn't wish me to be inconsistent would you Slim_Slag ? )
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Old 20th Nov 2002, 15:56
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Rustle,

No, my question wasn't tongue in cheeck actually!

LHR may only be the 15th busiest airport in the world, but none of the others mentioned share their TMA with Gatwick, Luton, Standstead and City! Although I don't know for sure, it wouldn't surprise me if the airspace really was close to being full.

I don't think there's an issue with the actual airways. As others have pointed out, the average PPL going for a £100 hamburger in his PA28 will not be at the same leves as PA28s. But arriving and departing heavy jets on SIDs/STARs will be at the same level as the average PA28, and I'd guess that trying to vector all us guys around the heavies, in IMC, in a TMA which already serves 5 international airports, would be a complete nightmare. And our weather means that pilots will invariably be in IMC more often than they would be at many of the airports slim_slag has listed.

I may be completely off the mark here, I don't know. But it was a genuine question

FFF
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Old 20th Nov 2002, 16:31
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rustle

No injustice meant, I was just being matter of fact, apologies if I came over badly. Irony is not well transmitted via these new fangled methods. I just hear a lot of people say London is the busiest place in the world (and I am sure it is if you define busiest narrowly enough) and we cannot fit more planes in. I don't think that is true.

fff

Again just being matter of fact here, I have no axe to grind, just throwing out food for thought. LGW is a "mere" class D and doesn't even rank in any 'busiest airport in the world' list I can find. I am using movements not passengers as I think that is more relevant for looking at traffic flow and airspace usage.

I took the figures for the primary airports in the TMA. Look at the airports within the TMA of any of the US airports I cited. You will find plenty of Class D airports and even plenty of class C, and even the occasional class B. The London TMA is nothing compared with NY Approach, Chicago Approach, SOCAL Approach, Bay Approach, Atlanta Approach....... In all these TMAs you will find PPL IRs mixing it with the big boys, to a greater or lesser degree. I'm not saying you will not be vectored around a bit if heading for a reliever airport, or even have to hold a bit if you are foolish enough to want to land at the primary airport, but these TMAs handle a lot more big and small IFR traffic than London.

As for weather, America is a big place and it's not all desert. There is pretty extreme weather to be found where people put airports.

Gengis

Indeed, the beaurocracy might even be desirable to some regulatory authorities . I think you are correct in asking what is the minimum requirement for an ICAO IR and just use that. Unfortunately ICAO Annex 1 is only available if you cough up the dough. If a US IR fits, then that should be good enough. Unfortunately we now have to ask the French whether it's OK to have a CAA ICAO IR.
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Old 20th Nov 2002, 17:24
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Surely the point is that if you and your aeroplane are both ICAO compliant, and registered in the same state, you can fly freely in any ICAO state?

Equally, surely somebody in here has access to a copy of Annex 1 and can enlighten us all as to what the minima are?

Incidentally I just did a search on this, and at http://www.iaopa-eur.org/jipolctd.htm IAOPA have a policy that "States should use only the requirements for issuance of an instrument rating listed in ICAO Annex 1 in an effort to promote universal acceptance of instrument ratings and pilot certificates by all contracting States" Which sound awfully like what we all just said !

G
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