difference in IR and IMC rating
Join Date: May 2003
Location: Gt. Yarmouth, Norfolk
Age: 68
Posts: 799
Likes: 0
Received 0 Likes
on
0 Posts
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.
State.
The AIP does not itself lay down a mandatory minimum restriction on descent below a certain altitude - this is defined in the legislation which is the ANO, which prohibiting descent below the published minima. The AIP is where those published minima are to be found. Had there been a separate (different) restriction on IMC holders then the place to find it would be the ANO, not the AIP.
Taking the point a stage further, the penalty for a breaching the requirement in the ANO is a fine. The only offence created is breaching Article 49, which refers only to descent below the published minima for the particular airfield and approach. There are no separate published minima which apply to IMC holders and therefore no sanction for any breach of the DA + 200' etc.
Join Date: Jun 2003
Location: EuroGA.org
Posts: 13,787
Likes: 0
Received 0 Likes
on
0 Posts
SS
We were discussing two separate issues:
1) Does 91.175 prohibit descent below the MSA other than on a published IAP, in any airspace including uncontrolled
2) Are the IMCR minima mandatory or advisory
I posted the view from an FAA examiner relating to 1) above. I think that he (and this one was a particularly senior one) would know more about it than I would know just reading the FAR/AIM. I agree with you that 91.175 sounds like there is a blanket ban, but I reported an informed view in the USA that in Class G you can do what you like (out there). The other point is that you can fly IFR/IMC down to the MSA (in Class G, without ATC clearance, both in the USA and in the UK) and if you are visual then you can make a visual approach; do you disagree with that?
As for 2) well this one will run and run. I am with Justiciar; having been in business for best part of 30 years I have seen more legalese than I've had Kentucky Fried Chickens and that para was written by an amateur who doesn't even have a decent grip on English grammar. It was not written by a lawyer. That doesn't mean it isn't law, in which case why is it not in the ANO? Everything else IMCR-specific (the 1800m, the no Clall A bit) is in the ANO. Justiciar provides the answer to this.
In general, UK instructors are a very poor place indeed to ask regarding any legal details. I could write for far longer than I have time for, listing the complete and utter bo110cks I have had from them. One instructor told me I could train for the initial IMCR in a particular plane which was on a Private CofA, so long as I owned more than 1/4 of it. Much later I discovered he was involved with the other owners, doing training for them charged as "ground school". Very very hard indeed to know who one can trust in this business. Most instructors live in their own little world, training Joe Public day after day, in between thumbing through airline job adverts. This stuff is way above most of them.
The CAA doesn't make this any easier, with all the advisory stuff they put out which is made to look like it is mandatory. I think a lot of it is written in a kneejerk reaction to some event somewhere...
Finally, to be practical about this, it is unenforceable because nobody can tell when you, the pilot, actually got visual. Unless you have a CAA official sitting in the aircraft. So this isn't a real issue, unless you want to create more traffic on the server. The important thing is to do it safely.
We were discussing two separate issues:
1) Does 91.175 prohibit descent below the MSA other than on a published IAP, in any airspace including uncontrolled
2) Are the IMCR minima mandatory or advisory
I posted the view from an FAA examiner relating to 1) above. I think that he (and this one was a particularly senior one) would know more about it than I would know just reading the FAR/AIM. I agree with you that 91.175 sounds like there is a blanket ban, but I reported an informed view in the USA that in Class G you can do what you like (out there). The other point is that you can fly IFR/IMC down to the MSA (in Class G, without ATC clearance, both in the USA and in the UK) and if you are visual then you can make a visual approach; do you disagree with that?
As for 2) well this one will run and run. I am with Justiciar; having been in business for best part of 30 years I have seen more legalese than I've had Kentucky Fried Chickens and that para was written by an amateur who doesn't even have a decent grip on English grammar. It was not written by a lawyer. That doesn't mean it isn't law, in which case why is it not in the ANO? Everything else IMCR-specific (the 1800m, the no Clall A bit) is in the ANO. Justiciar provides the answer to this.
In general, UK instructors are a very poor place indeed to ask regarding any legal details. I could write for far longer than I have time for, listing the complete and utter bo110cks I have had from them. One instructor told me I could train for the initial IMCR in a particular plane which was on a Private CofA, so long as I owned more than 1/4 of it. Much later I discovered he was involved with the other owners, doing training for them charged as "ground school". Very very hard indeed to know who one can trust in this business. Most instructors live in their own little world, training Joe Public day after day, in between thumbing through airline job adverts. This stuff is way above most of them.
The CAA doesn't make this any easier, with all the advisory stuff they put out which is made to look like it is mandatory. I think a lot of it is written in a kneejerk reaction to some event somewhere...
Finally, to be practical about this, it is unenforceable because nobody can tell when you, the pilot, actually got visual. Unless you have a CAA official sitting in the aircraft. So this isn't a real issue, unless you want to create more traffic on the server. The important thing is to do it safely.
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
IO540 and SS
I feel you come from different view points. SS maybe that of an instructor and IO540 the instructed.
There are some excellent instructors - I have come across a few who have a very good understanding of aviation law, never mind the experience to instructor at a very high standard. Sad to say that is not my general experience nor the experience I find of most other pilots.
As with any exam based instructor qualification of course they have achieved a minimium standard but equally that does not mean they have the same in depth knowledge of many of the contributors on this forum.
The debate about the IMCR minima is a case in point where even we cannot agree on the correct interpretation (although I am in no doubt they are recommended minima).
The fact of the matter is that there is a whole bunch of instructors who are far less experienced than many on this forum - IO540 is quite correct.
I feel you come from different view points. SS maybe that of an instructor and IO540 the instructed.
There are some excellent instructors - I have come across a few who have a very good understanding of aviation law, never mind the experience to instructor at a very high standard. Sad to say that is not my general experience nor the experience I find of most other pilots.
As with any exam based instructor qualification of course they have achieved a minimium standard but equally that does not mean they have the same in depth knowledge of many of the contributors on this forum.
The debate about the IMCR minima is a case in point where even we cannot agree on the correct interpretation (although I am in no doubt they are recommended minima).
The fact of the matter is that there is a whole bunch of instructors who are far less experienced than many on this forum - IO540 is quite correct.
Join Date: Jan 2001
Location: He's on the limb to nowhere
Posts: 1,981
Likes: 0
Received 0 Likes
on
0 Posts
Fuji,
There are a lot of instructors on both side of the Atlantic who are just bumps on logs building time. But I was not crticising instructors. What I was criticising was the attitude that
a) I am right, and I found an instructor that agrees with me, so I am right
b) I am right, and I found an instuctor that disagrees with me, so the instructor is wrong.
IO54O,
The only interpretation of the FAR's that matter comes out of the FAA General Counsel's office, or the judge who is going to hear your case for violating a FAR (probably 91.13). What I attempt to do is provide interpretations citing from and quoting the FARs, I don't cite unnamed instructors/examiners or emails from unknown FAA staff. I also try not to redefine words like 'turning' to mean 'cleared to land'. I encourage people to read the FARs themselves, as in general they are very clear, for legal stuff anyway. You should know anyway this if you have an FAA IR.
It doesn't sound like a blanket ban because there are exceptions. The exceptions do not include class G airspace. 3FallinFlyer asked a question, I warned him that if he wants to move over to an FAA IR then he should be aware that he cannot descend below the MEA in IMC in class g unless there is a published IAP and it appears he found my answer (citing the FAR, not some unknown individual) useful. If you want to stop these threads from repeating ad nauseam then don't jump in and post nonsense and I will not be forced to point out to people like 3FallingFlyer that you are wrong.
OK?
You cannot do what you like in class G airspace. This is a major and fundamental misunderstanding of the FARs. If in weather below VFR minimums, you can fly IFR if rated but you do not need to file a flight plan, and you do not need an ATC clearance (FAR 91.173), that's about it. Minimum altitude rules certainly apply (91.177). You need an IR. Your plane needs to be equipped (91.205). Hardly you can do what you want.
I agree with that. I disagree with your claim that this is 1000 AGL, it will be higher than that. If you are using an FAA IR you can descend to the relevant MEA in cloud, but not below. Below the MEA, unless on a published IAP, you mustfly VFR, minimums are prescribed in 91.155.
I agree that you will probably get away with it but that was not the point of my answering 3fallingflyer's initial question. If you just said "I'm busting the rules and don't care", then that is fine but you didn't. You tried to justify your breaking the rules by misinterpreting them.
If you really understood the FARs and wanted a discussion relevant to 3fallingflyers actual question you should cite 91.703 (a) (3) and not some unnamed instructor/examiner. Even then, you would still be wrong
There are a lot of instructors on both side of the Atlantic who are just bumps on logs building time. But I was not crticising instructors. What I was criticising was the attitude that
a) I am right, and I found an instructor that agrees with me, so I am right
b) I am right, and I found an instuctor that disagrees with me, so the instructor is wrong.
IO54O,
The only interpretation of the FAR's that matter comes out of the FAA General Counsel's office, or the judge who is going to hear your case for violating a FAR (probably 91.13). What I attempt to do is provide interpretations citing from and quoting the FARs, I don't cite unnamed instructors/examiners or emails from unknown FAA staff. I also try not to redefine words like 'turning' to mean 'cleared to land'. I encourage people to read the FARs themselves, as in general they are very clear, for legal stuff anyway. You should know anyway this if you have an FAA IR.
Originally Posted by IO540
SS
We were discussing two separate issues:
1) Does 91.175 prohibit descent below the MSA other than on a published IAP, in any airspace including uncontrolled.
.......
I agree with you that 91.175 sounds like there is a blanket ban, but I reported an informed view in the USA that in Class G you can do what you like (out there).
We were discussing two separate issues:
1) Does 91.175 prohibit descent below the MSA other than on a published IAP, in any airspace including uncontrolled.
.......
I agree with you that 91.175 sounds like there is a blanket ban, but I reported an informed view in the USA that in Class G you can do what you like (out there).
OK?
You cannot do what you like in class G airspace. This is a major and fundamental misunderstanding of the FARs. If in weather below VFR minimums, you can fly IFR if rated but you do not need to file a flight plan, and you do not need an ATC clearance (FAR 91.173), that's about it. Minimum altitude rules certainly apply (91.177). You need an IR. Your plane needs to be equipped (91.205). Hardly you can do what you want.
The other point is that you can fly IFR/IMC down to the MSA (in Class G, without ATC clearance, both in the USA and in the UK) and if you are visual then you can make a visual approach; do you disagree with that?
I agree that you will probably get away with it but that was not the point of my answering 3fallingflyer's initial question. If you just said "I'm busting the rules and don't care", then that is fine but you didn't. You tried to justify your breaking the rules by misinterpreting them.
If you really understood the FARs and wanted a discussion relevant to 3fallingflyers actual question you should cite 91.703 (a) (3) and not some unnamed instructor/examiner. Even then, you would still be wrong
Last edited by slim_slag; 7th Mar 2006 at 09:10.
Join Date: Mar 2002
Location: Euroland
Posts: 2,814
Likes: 0
Received 0 Likes
on
0 Posts
To the person who asked who I got to explain the meaning of the excerpt from the AIP and who said that the word "but" was important - the answer is a person with an english language degree and absolutely no flying experience and hence no pre-conceptions.
Feel free to forward the paragraph to the plain english society and ask them.
--------
Justicar,
You said;
Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to a recomended minimum of 500 for a precision approach etc.
Should that not have said;
Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to an absolute minimum of 500 for a precision approach etc.
The fact that you had to change the wording in order to make the paragraph read like it is all a recomendation only goes to support the point of view that the 500ft DH and 600ft MDH are absolute minima and since they are minima and notified in the AIP, they are covered by Article 49.
but is not a qualifier, it is a conjunction!
------
What everyone seems to miss in the argument is that it is often the case that an MDH of 600ft is less than 200ft above the IR MDH. The minima for the IR pilot permit an approach in IMC to be continued to MDH. The IMC holder can use 600ft as long as it is not less than the IR minima.
--------
Whatever anyone agrues what has to be agreed is that;
1. The IMC rating holder is not trained according to the sylabus to fly a precision approach below 500ft. DH or a non-precision approach below 600ft MDH.
2. The majority of holders of the IMC rating are in the situation where the AIP recomends that they do not attempt to make an approach and of the remainder a high proportion of those would have to make additions to the IMC minima to allow for not being totally current with the type of approach procedure.
That makes the idea of an IMC rating holder who flies the average number of PPL hours per year doing an ILS in IMC down to 200ft and expecting to be in a position to safely land as remote.
If one wants to operate as if one holds an IR regardless of airspace then there is only one answer - get an IR.
--------
There is no such thing as a home made Instrument Approach! There are quite a few cloud break procedures and those of us that use them have CAA permission to do so. Anyone else is illegal for a number of reasons but the most important one from my point of view is that you could hit us!
The only people who should be in IMC below MSA are;
1. Pilots on special VFR flights (in a zone of course!)
2. Pilots making an approved public or private descent.
Everyone else is endangering their aircraft.
IO540 is correct to say that there is nothing wrong with descending to MSA and being visual there, (Note that I said visual and not VFR) continue descent visually. Of course the MSA is usually 1000ft above the highest obstacle within 10nm of the indicated position of the aircraft.
------
I note that everyone is very reluctant to name these CAA officials and FAA officials who say certain things. However, if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAA and post their reply here for us all to see.
-----
What about the pilots who get the IMC on a single and then use it on a twin. Now there is an accident waiting to happen!
Regards,
DFC
Feel free to forward the paragraph to the plain english society and ask them.
--------
Justicar,
You said;
Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to a recomended minimum of 500 for a precision approach etc.
Should that not have said;
Speaking with a lawyer's hat (or should it be wig?) on, I don't believe this is laying down mandatory minima. The entire paragraph reads as an advisory statement. The use of "but" links the second part of the sentence to the first by qualifying the general statement that IMC holders are recommended to add 200 feet etc, but they should always work to an absolute minimum of 500 for a precision approach etc.
The fact that you had to change the wording in order to make the paragraph read like it is all a recomendation only goes to support the point of view that the 500ft DH and 600ft MDH are absolute minima and since they are minima and notified in the AIP, they are covered by Article 49.
but is not a qualifier, it is a conjunction!
------
What everyone seems to miss in the argument is that it is often the case that an MDH of 600ft is less than 200ft above the IR MDH. The minima for the IR pilot permit an approach in IMC to be continued to MDH. The IMC holder can use 600ft as long as it is not less than the IR minima.
--------
Whatever anyone agrues what has to be agreed is that;
1. The IMC rating holder is not trained according to the sylabus to fly a precision approach below 500ft. DH or a non-precision approach below 600ft MDH.
2. The majority of holders of the IMC rating are in the situation where the AIP recomends that they do not attempt to make an approach and of the remainder a high proportion of those would have to make additions to the IMC minima to allow for not being totally current with the type of approach procedure.
That makes the idea of an IMC rating holder who flies the average number of PPL hours per year doing an ILS in IMC down to 200ft and expecting to be in a position to safely land as remote.
If one wants to operate as if one holds an IR regardless of airspace then there is only one answer - get an IR.
--------
There is no such thing as a home made Instrument Approach! There are quite a few cloud break procedures and those of us that use them have CAA permission to do so. Anyone else is illegal for a number of reasons but the most important one from my point of view is that you could hit us!
The only people who should be in IMC below MSA are;
1. Pilots on special VFR flights (in a zone of course!)
2. Pilots making an approved public or private descent.
Everyone else is endangering their aircraft.
IO540 is correct to say that there is nothing wrong with descending to MSA and being visual there, (Note that I said visual and not VFR) continue descent visually. Of course the MSA is usually 1000ft above the highest obstacle within 10nm of the indicated position of the aircraft.
------
I note that everyone is very reluctant to name these CAA officials and FAA officials who say certain things. However, if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAA and post their reply here for us all to see.
-----
What about the pilots who get the IMC on a single and then use it on a twin. Now there is an accident waiting to happen!
Regards,
DFC
Join Date: Oct 2002
Location: England
Posts: 0
Likes: 0
Received 0 Likes
on
0 Posts
Originally Posted by pilotho
hey guys,
about to get my PPL if the uk weather permits!
anyway, after the training i would like to get more ratings, although i dont really get the difference with IR and IMC rating.
if i have an IR rating would that mean i could fly in IMC anyway and wont need to do IMC training? or do i need IMC before i can actually start IR training?
about to get my PPL if the uk weather permits!
anyway, after the training i would like to get more ratings, although i dont really get the difference with IR and IMC rating.
if i have an IR rating would that mean i could fly in IMC anyway and wont need to do IMC training? or do i need IMC before i can actually start IR training?
With an IR you can fly a G reg ship anywhere in the world in controlled airspace in any weather. You don't need an IMC to do a IR but it would be helpfull, for practical purposes . Expect to take 12 months to obtain an JAR/IR. As some folk have mentioned perhaps a practical option is the FAA version. This will restrict you to an N reg ship, but will allow you the same privileges as mentioned above. With an IMC you may be able to do the entire thing (FAA rating) in the States in a couple of weeks at a fraction of the cost.
An IMC is a UK rating. It doesn't allow flight into class A but is a very useful rating for the PPL, perhaps I should qualify that and say a 'current' PPL with regular IMC practice.
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
DFC
A number of contributors on this forum, including at least one solicitor interpret the legislation as advisory, a number, including yourself as mandatory.
However strongly you may hold to your view it is quite apparent that the legislation is ambiguous at best and a worst appallingly drafted. I suspect if you had asked the plain English society to look at the drafting they would have come up with a number of better ways of saying the minima were either mandatory or advisory depending what was in the mind of the legislator. Ultimately if push came to shove the courts would be guided by the CAAs "official" line which, as much as you might wish otherwise, would clearly seem to be the minima are advisory BUT the judge would have to be satisfied in his mind that the intention of the legislation was clear. It seems to me that would be a difficult count on which to be satisfied. I doubt the judge would have the slightest interest in consulting the plain English society!
This issue had been rumbling on for years now (I seem to remember that it was certainly discussed as many as five years ago on this forum). One would suspect that if the CAA's view was not as many have expressed the CAA might have found ample opportunity to carnify their interpretation of the legislation.
Your argument that IMCR pilots are not trained to the same minima standard as an IR pilot really does not wash as justification that they should not be permited to operate to the same minima as a pilot with an IR, however much that might seem common sense. The fact of the matter is I do not honestly believe anyone could successfully argue an IMCR pilot is trained to fly a hard IFR sector, with a departure and arrival to minima. Yet subject to the debate about whether or not the IMCR minima is "higher" there is no doubt the qualification legally entitles you to do just this.
"If one wants to operate as if one holds an IR regardless of airspace then there is only one answer - get an IR"
Of course as you know full well this is nonsense. The IMCR is an instrument rating - or if it is not then all that time spent flying on instruments is pretty pointless. It does not cover instrument skills in the same depth as the IR, but other than this debate about the minima, it legally enables the pilot to operate in UK airspace in exactly the same way as an IR holder with the exclusion of class A. In my view excluding the pilot from class A is a complete nonsense. If the pilot is judged safe to operate in class D with other commercial traffic one suspects there is less risk with their operating in class A given the aircraft is up to the job. One suspects the class A exclusion has far more to do with commercial considerations that safety. Even more bizarre is the fact that an FAA IR holder has no rights in UK airspace unless operating on the N reg or unless he has been granted an IMCR but in which event the IMCR restrictions remain.
Practically you should see the standard of some newly qualified IR holders particularly when the approach does not go to plan. Ask commercial training captains on how many occasions they have had to “save the day”. Both ratings, are a license to learn, the IMCR a license to learn more, perhaps!
What one can say is this issue is just the tip of an iceberg of poorly thought out legalisation which was creditable in its intention when enacted but has become hopelessly corrupted by the vested interests and commercial pressures of the regulators who have long forgotten that the principle concern should be the safety of pilots and of the public.
Many regards
Fuji abound!
A number of contributors on this forum, including at least one solicitor interpret the legislation as advisory, a number, including yourself as mandatory.
However strongly you may hold to your view it is quite apparent that the legislation is ambiguous at best and a worst appallingly drafted. I suspect if you had asked the plain English society to look at the drafting they would have come up with a number of better ways of saying the minima were either mandatory or advisory depending what was in the mind of the legislator. Ultimately if push came to shove the courts would be guided by the CAAs "official" line which, as much as you might wish otherwise, would clearly seem to be the minima are advisory BUT the judge would have to be satisfied in his mind that the intention of the legislation was clear. It seems to me that would be a difficult count on which to be satisfied. I doubt the judge would have the slightest interest in consulting the plain English society!
This issue had been rumbling on for years now (I seem to remember that it was certainly discussed as many as five years ago on this forum). One would suspect that if the CAA's view was not as many have expressed the CAA might have found ample opportunity to carnify their interpretation of the legislation.
Your argument that IMCR pilots are not trained to the same minima standard as an IR pilot really does not wash as justification that they should not be permited to operate to the same minima as a pilot with an IR, however much that might seem common sense. The fact of the matter is I do not honestly believe anyone could successfully argue an IMCR pilot is trained to fly a hard IFR sector, with a departure and arrival to minima. Yet subject to the debate about whether or not the IMCR minima is "higher" there is no doubt the qualification legally entitles you to do just this.
"If one wants to operate as if one holds an IR regardless of airspace then there is only one answer - get an IR"
Of course as you know full well this is nonsense. The IMCR is an instrument rating - or if it is not then all that time spent flying on instruments is pretty pointless. It does not cover instrument skills in the same depth as the IR, but other than this debate about the minima, it legally enables the pilot to operate in UK airspace in exactly the same way as an IR holder with the exclusion of class A. In my view excluding the pilot from class A is a complete nonsense. If the pilot is judged safe to operate in class D with other commercial traffic one suspects there is less risk with their operating in class A given the aircraft is up to the job. One suspects the class A exclusion has far more to do with commercial considerations that safety. Even more bizarre is the fact that an FAA IR holder has no rights in UK airspace unless operating on the N reg or unless he has been granted an IMCR but in which event the IMCR restrictions remain.
Practically you should see the standard of some newly qualified IR holders particularly when the approach does not go to plan. Ask commercial training captains on how many occasions they have had to “save the day”. Both ratings, are a license to learn, the IMCR a license to learn more, perhaps!
What one can say is this issue is just the tip of an iceberg of poorly thought out legalisation which was creditable in its intention when enacted but has become hopelessly corrupted by the vested interests and commercial pressures of the regulators who have long forgotten that the principle concern should be the safety of pilots and of the public.
Many regards
Fuji abound!
Join Date: Jan 2001
Location: He's on the limb to nowhere
Posts: 1,981
Likes: 0
Received 0 Likes
on
0 Posts
I don't think I'm really qualified to say too much about the CAA side of things, but for me DFC has by far the most persuasive argument on what you can legally do with an IMCR. At least he has provided an argument (with references) which gives the relevant part of the AIP the legal force of the ANO. His argument that the 'but' is key is very persuasive. I still reckon he works for a regulator Fuji is quite correct though, it's all very badly written.
Fuji is quite correct though, it's all very badly written.
Join Date: May 2003
Location: Yorkshire
Posts: 664
Likes: 0
Received 0 Likes
on
0 Posts
I note that everyone is very reluctant to name these CAA officials and FAA officials who say certain things. However, if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAA and post their reply here for us all to see.
I am an IMC holder who - brace yourself - doesn't any longer believe that I know the answer to the minimums question. I have had my head filled with "absolute knowledge" available from the instruction/flying school/pundit crowd, and I have had so many varying opinions that I have come to the conclusion that I'd be no worse off raising the question on this forum - i.e., I'm not likely to find a definitive on here either !
Let's face it, you ask an what should be a simple enough question of aviation law, and receive a clutch of opinions regarding sentence construction. You ask for subject literacy, and receive (probably dodgy) answers relating to linguistic literacy.
Good fun this may be, but those who sign up to this forum should be made very, very aware that there are as many duff opinions as facts to be found here ... which may of course include the one I've just expressed !
For what it's worth, I tend to keep to the 500/600 mantra unless I'm bloody sure of what I'm doing and where I am ... Wrong ? Possibly. But I'll wait for the for the proof. And for what it's worth, that won't be provided by someone with a 3rd in English language ....
FF
Join Date: May 2003
Location: Gt. Yarmouth, Norfolk
Age: 68
Posts: 799
Likes: 0
Received 0 Likes
on
0 Posts
they should always work to an absolute minimum of 500 for a precision approach etc.
The point is this: what happens to a pilot with an IMC who descends below the DA/MDA before acquiring visual reference? What is the sanction? The answer is nothing happens to him, because the ANO does not prescribe any separate penalty or sanction for breaching the 500/600' minima. The AIP cannot create any separate sanction for breaching this "limit" because it is not legislation and cannot lay down penalties or sanctions as the ANO does. It is merely descriptive of the aerodrome limits. There is no separate and distinct limit for IMC rated pilots.
since they are minima and notified in the AIP, they are covered by Article 49.
"an aircraft to which this article applies when making a descent to a runway in respect of which there is a notified instrument approach procedure shall not—
(a) continue an approach to landing on such a runway by flying below the relevant specified decision height; or
(b) descend below the relevant specified minimum descent height;"
So, the restrictions are defined by the "notified instrument approach procedure". There is nothing within the "notified instrument approach procedure" which distinguishes between the IR and IMC rated pilot. The "notified instrument approach procedure" is defined by reference to the design and layout of the aerodrome and its terrain. It is specified by the AIP for different types of approach and Article 49 is then applied by reference to that published procedure.
The question of whether IMC rated pilots are actually trained to descend below that altitude is completely separate. Nothing discussed here should be seen as an endorsement of ignoring the AIP. But the question was whether the 500/600' figure was mandatory or advisory. My view is that it advisory. That is not to say I would ignore the recommendations.
Join Date: Oct 2002
Location: England
Posts: 0
Likes: 0
Received 0 Likes
on
0 Posts
There is of course a practical consideration, one can hardly expect a pilot to remain aloft because he can not satisfy the MDH. It is important that s/he can descend safely, regardless of cloud base and visibility.
Having said that from my casual observations I suspect that the vast majority of PPL/IMC holders are not current and don't fly in IMC or if they do depend on the autopilot (there is nothing wrong with using the autopilot provided the pilot can also fly hands on). The IR is a package it concerns more than simply flying. Weather (and its effect on the flight and aeroplane) is studied in some detail, far in excess of what an IMC pilot studies. A pilot having to use his rating below the minimums (whether IR or IMC) has probably not prepared adequately and may not know how to.
There is a tendency that the IMC rating will become a get out of jail card. Too often an IMC instructor renewing a PPL's rating is keen to demonstrate how to perform procedural approaches.
For what it's worth I am also a believer in the 500/600ft min for an IMC and perhaps equally controversially that it should only be used in the UK airspace. There are some that believe it can be used abroad to fly above cloud.
Having said that from my casual observations I suspect that the vast majority of PPL/IMC holders are not current and don't fly in IMC or if they do depend on the autopilot (there is nothing wrong with using the autopilot provided the pilot can also fly hands on). The IR is a package it concerns more than simply flying. Weather (and its effect on the flight and aeroplane) is studied in some detail, far in excess of what an IMC pilot studies. A pilot having to use his rating below the minimums (whether IR or IMC) has probably not prepared adequately and may not know how to.
There is a tendency that the IMC rating will become a get out of jail card. Too often an IMC instructor renewing a PPL's rating is keen to demonstrate how to perform procedural approaches.
For what it's worth I am also a believer in the 500/600ft min for an IMC and perhaps equally controversially that it should only be used in the UK airspace. There are some that believe it can be used abroad to fly above cloud.
Last edited by bpilatus; 8th Mar 2006 at 06:41.
Join Date: Jun 2003
Location: EuroGA.org
Posts: 13,787
Likes: 0
Received 0 Likes
on
0 Posts
"There is a tendency that the IMC rating will become a get out of jail card"
Not that one again, please
A pilot with an IMCR who has not flown for a year is going to be as useless as a pilot with an IR who has not flown for a year.
3 things that matter:
currency on type
currency on type
currency on type
Now, how many of each sort are there hanging around airfields?
Most PPLs don't fly anywhere really (most chuck it in pretty fast). I therefore suspect most IMCRs are well out of currency, too. One big reason is that one cannot at all easily rent a plane that's legal for IFR in CAS, never mind one that someone with a brain would want to fly in IMC.
The vast majority of IRs are also either lapsed or their currency is zero. Most are in the hands of ATPL hour builder instructors who did the IR by banging a Seneca around for a while, plus sim sessions, passed the ATPL exams and, when they are not thumbing through airline job ads, are trying to hour build by flying in perfect VFR between the four creases in their chart next to a student.
There is a tiny group of noncommercial IRs flying around Europe. Practically all of them are owners, and they will generally be current (most owners are current especially those who can fly IFR).
There is a much bigger group of G-reg owners who don't have an IR but have the IMCR. Most owners of something reasonable will have a job/business and cannot possibly do the JAA IR.
I reckon if you picked 100 pilots who have just arrived on some IAP, and stripped out the commercial ones, you would find the good IMCR pilots vastly outnumber the good IR pilots.
An IMCR pilot who had a half decent instructor can fly everything in the IR flying syllabus, except SIDs and STARs and those are easy. The reality of Class A is nearly all RNAV i.e. a BRNAV GPS.
Not that one again, please
A pilot with an IMCR who has not flown for a year is going to be as useless as a pilot with an IR who has not flown for a year.
3 things that matter:
currency on type
currency on type
currency on type
Now, how many of each sort are there hanging around airfields?
Most PPLs don't fly anywhere really (most chuck it in pretty fast). I therefore suspect most IMCRs are well out of currency, too. One big reason is that one cannot at all easily rent a plane that's legal for IFR in CAS, never mind one that someone with a brain would want to fly in IMC.
The vast majority of IRs are also either lapsed or their currency is zero. Most are in the hands of ATPL hour builder instructors who did the IR by banging a Seneca around for a while, plus sim sessions, passed the ATPL exams and, when they are not thumbing through airline job ads, are trying to hour build by flying in perfect VFR between the four creases in their chart next to a student.
There is a tiny group of noncommercial IRs flying around Europe. Practically all of them are owners, and they will generally be current (most owners are current especially those who can fly IFR).
There is a much bigger group of G-reg owners who don't have an IR but have the IMCR. Most owners of something reasonable will have a job/business and cannot possibly do the JAA IR.
I reckon if you picked 100 pilots who have just arrived on some IAP, and stripped out the commercial ones, you would find the good IMCR pilots vastly outnumber the good IR pilots.
An IMCR pilot who had a half decent instructor can fly everything in the IR flying syllabus, except SIDs and STARs and those are easy. The reality of Class A is nearly all RNAV i.e. a BRNAV GPS.
Join Date: Oct 2002
Location: England
Posts: 0
Likes: 0
Received 0 Likes
on
0 Posts
IO540, if the IMC is to be a serious rating then instructors should place more emphasis on assessing a pilots competence. Demonstrating, once every 25 months, how the ILS should be flown is probably not doing the pilot a favour.
I think you need some factual information to back up your other points, these appear to be personal thoughts.
I think you need some factual information to back up your other points, these appear to be personal thoughts.
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
bpilatus
Unfortunately the ANO does not use the word should.
With regards evidence, the FAA IR does not require renewal as long as you are able to self certify currency.
I know some don’t like the comparison between us and the States. However the fact remains there are hugely more private pilots in the States flying in all sorts of conditions. You mention evidence - well look at the evidence from the States regarding the use of the IR by private pilots and also consider the accident statistics. For me it is a pretty persuasive model that their system works - and works very well.
In Europe there a a significant number of pilots operating N reg. I cant remember the last time I saw an N reg accident here in IMC conditions. Moreover I also cant remember a significant number of accidents involving pilots with an IMCR in IMC.
DFC writes about the IMCR not being with us much longer. Perhas it will not be but I wonder if anyone will bother to do a regulatory impact anaylsis if the rating is withdrawn and if they do I wonder whether anyone will consider what the safety implications are?
Unfortunately the ANO does not use the word should.
With regards evidence, the FAA IR does not require renewal as long as you are able to self certify currency.
I know some don’t like the comparison between us and the States. However the fact remains there are hugely more private pilots in the States flying in all sorts of conditions. You mention evidence - well look at the evidence from the States regarding the use of the IR by private pilots and also consider the accident statistics. For me it is a pretty persuasive model that their system works - and works very well.
In Europe there a a significant number of pilots operating N reg. I cant remember the last time I saw an N reg accident here in IMC conditions. Moreover I also cant remember a significant number of accidents involving pilots with an IMCR in IMC.
DFC writes about the IMCR not being with us much longer. Perhas it will not be but I wonder if anyone will bother to do a regulatory impact anaylsis if the rating is withdrawn and if they do I wonder whether anyone will consider what the safety implications are?
Join Date: Oct 2002
Location: England
Posts: 0
Likes: 0
Received 0 Likes
on
0 Posts
Fugi, at the risk of being controversial I'm inclined to say that you are merely supporting 540 with more personal opinions. If you want to make a valid point please do so from an authorised source. I have no problem with the FAA/IR, as you say it is possible to self certify. Un/fortunately this isn't the case with the JAR/IR. Which is best is another issue, perhaps we can let the reader decide as opposed to trying to persuade.
Why do it if it's not fun?
Join Date: Jul 2001
Location: Bournemouth
Posts: 4,779
Likes: 0
Received 0 Likes
on
0 Posts
DFC,
A couple of quotes from your last post which I think need some further comments:
That is probably true. But exactly the same is true of an IR holder doing an average number of PPL hours per year.
On the other hand, there are plenty of IMC-rating holders who do far more than the average number of hours. They might even have had training in flying an ILS down to 200'. (I am certainly happy to give this kind of training to my IMC students, although it is not on the syllabus and will not be tested, and when I do so I of course point out the relevant recommendations and the requirement for currency.)
The rating (IMC or IR) a pilot holds does not necessarily reflect on the currency or ability of the pilot.
On an unrelated note:
In a recent thread, I was asking about the possibility of using the localiser for guidance on the outbound leg of an ILS procedure with a procedure turn. My colleague had already asked Steve Oddy for his opinion, and his opinion was that it was allowable. I then asked PPRuNe for further opinions - and someone posted a very detailed reply describing why Steve Oddy was wrong, because the localiser coverage does not extend to the height required to fly the leg. I just went back to that thread and checked who it was that posted this information, which I'm sure is correct but which was in direct conflict with advice from a CAA staff examiner. It was you.....
FFF
--------------
A couple of quotes from your last post which I think need some further comments:
That makes the idea of an IMC rating holder who flies the average number of PPL hours per year doing an ILS in IMC down to 200ft and expecting to be in a position to safely land as remote
On the other hand, there are plenty of IMC-rating holders who do far more than the average number of hours. They might even have had training in flying an ILS down to 200'. (I am certainly happy to give this kind of training to my IMC students, although it is not on the syllabus and will not be tested, and when I do so I of course point out the relevant recommendations and the requirement for currency.)
The rating (IMC or IR) a pilot holds does not necessarily reflect on the currency or ability of the pilot.
On an unrelated note:
if one wants confirmation that 500ftDH and 600ft MDH are the absolute minima for an IMC holder - mandatory and that is what we teach and test please ask the chief examminer at the CAA
FFF
--------------
Guest
Posts: n/a
FFF,
Agreed with the caveat that it is a matter of degrees. As you know the IR training is much more rigourous with much greater demands for accuracy and arming the pilot with many more techniques to maintain accuracy and situational awareness. I suspect, that an IR pilot would be considerably safer than an IMC pilot with only the same amount of VFR only time since IR/IMC training, the longer the gap, the more so. That doesn't mean to say the IMC pilot would unsafe, but I wouldn't feel comfortable comparing the two ratings in such a way.
That is probably true. But exactly the same is true of an IR holder doing an average number of PPL hours per year.
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
bpilatus
- nothing like a bit of controversy
"Which is best is another issue, perhaps we can let the reader decide as opposed to trying to persuade."
I wasnt aware that I was passing any opinion on which is best? I was simply making an observation on one very limited aspect in response to your point that there was some magic in requiring and IR pilot to renew every year. My point was it doesnt happen in the States. I am not aware of any evidence that by renewing an IR every year the pilot is "safer" - are you, or is this another personal opinion?
I am also struggling to see what other personal opinions I have given - although of course thats part of what PPRuNe is about anyway. I read the US and UK AAIB reports every month, I also follow the stats published in American Flying and other sources. My perception is as I set out in my post - a personal opinion, well maybe, because I have not referred to a statistical study, but the reports are there for all to read. If you have reached a different conclusion maybe you would like to share that.
- nothing like a bit of controversy
"Which is best is another issue, perhaps we can let the reader decide as opposed to trying to persuade."
I wasnt aware that I was passing any opinion on which is best? I was simply making an observation on one very limited aspect in response to your point that there was some magic in requiring and IR pilot to renew every year. My point was it doesnt happen in the States. I am not aware of any evidence that by renewing an IR every year the pilot is "safer" - are you, or is this another personal opinion?
I am also struggling to see what other personal opinions I have given - although of course thats part of what PPRuNe is about anyway. I read the US and UK AAIB reports every month, I also follow the stats published in American Flying and other sources. My perception is as I set out in my post - a personal opinion, well maybe, because I have not referred to a statistical study, but the reports are there for all to read. If you have reached a different conclusion maybe you would like to share that.
Join Date: Jun 2003
Location: EuroGA.org
Posts: 13,787
Likes: 0
Received 0 Likes
on
0 Posts
Just some random thoughts.
There won't be any "official" data on this - who is doing currency surveys in this business? It's just pretty obvious looking around. There is however plenty of data on the CAA website showing that each year about 100x more people get an IMCR than an IR (NON commercial).
The CAA have really good data on licence/rating lapsing but they don't publish it. If I was them, I wouldn't publish it either.
An FAA IR needs to have done 6 approaches in the past 6 months, to fly under IFR. That means you have to be doing more than that, of course, otherwise the oldest approach you did will be just about to "drop off the end". You've got to be doing something IFR every fortnight, more or less.
A JAA IR has to sit a checkride every year, but he may not have flown for a whole year before that. Is that better? We could argue about that but I don't think it is better. We all know the examiner won't fail you unless you do something pretty bad.
The biggest enemy of all this is lack of currency... currency costs serious money, and decent planes cost even more money, and money is in a very short supply in this business. Just look around your local airfield.
If the IMCR is abolished, we will still have every "instrument capable" pilot flying in cloud en-route, just like they do abroad at present. One just can't do an IAP and one can't depart from a towered field if it's sub-VFR. A very poor case for safety! I am 100% certain that nobody would have the ba11s today to introduce the IMCR (the IR training business would be up in arms about it, wouldn't they, Slim-Slag?) but equally I don't believe it will be abolished. Not until there is an accessible "IR" and probably a comprehensive airspace review to something like the US model.
There won't be any "official" data on this - who is doing currency surveys in this business? It's just pretty obvious looking around. There is however plenty of data on the CAA website showing that each year about 100x more people get an IMCR than an IR (NON commercial).
The CAA have really good data on licence/rating lapsing but they don't publish it. If I was them, I wouldn't publish it either.
An FAA IR needs to have done 6 approaches in the past 6 months, to fly under IFR. That means you have to be doing more than that, of course, otherwise the oldest approach you did will be just about to "drop off the end". You've got to be doing something IFR every fortnight, more or less.
A JAA IR has to sit a checkride every year, but he may not have flown for a whole year before that. Is that better? We could argue about that but I don't think it is better. We all know the examiner won't fail you unless you do something pretty bad.
The biggest enemy of all this is lack of currency... currency costs serious money, and decent planes cost even more money, and money is in a very short supply in this business. Just look around your local airfield.
If the IMCR is abolished, we will still have every "instrument capable" pilot flying in cloud en-route, just like they do abroad at present. One just can't do an IAP and one can't depart from a towered field if it's sub-VFR. A very poor case for safety! I am 100% certain that nobody would have the ba11s today to introduce the IMCR (the IR training business would be up in arms about it, wouldn't they, Slim-Slag?) but equally I don't believe it will be abolished. Not until there is an accessible "IR" and probably a comprehensive airspace review to something like the US model.
Join Date: Oct 2002
Location: England
Posts: 0
Likes: 0
Received 0 Likes
on
0 Posts
Originally Posted by IO540
the end". You've got to be doing something IFR every fortnight, more or less.