difference in IR and IMC rating
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That's correct bpilatus, IO540 is incorrect. The majority of FAA PP/CP with IR's who want to remain current legally will head out every six months to do their holds and approaches under the hood in one flight. I would say most PP/CP IR in the states don't fly in clouds very often, and at the small plane level are used to get through cloud decks more than anything else, not shooting approaches to minima. This does happen of course. Once you have the rating you are expected to use your own common sense in deciding how to use it. You have to remember that getting an IR in the States is often just rating collection, another goal to keep you interested in flying.
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"Once you have the rating you are expected to use your own common sense in deciding how to use it."
That is such an important statement.
As we all know the aviation industry is probably the most regulated of any.
Doctors, dentists, lawyers, accountants and a host of other professionals are not tested at interval. I appreciate if they have any sense they will undertake ongoing professional training and in some case are required to demonstrate they have done so to their regulatory authority. I also understand that in some cases there is an effective ongoing peer review.
As has been commented in the States no revalidation of an IR is required if you meet the currency requirments. In the UK revalidation is required every 12months. The States have always had a biannual review, for years we have not. Is there evidence that revalidation improves safety, is there evidence revalidation should be every 25 months, every year, every six months, every .. .. .. Where do you draw the line if a line should be drawn, and do you draw that line on some arbitary whim - once a year sounds good, and will go down well with the examiners!!
I have a pretty high regard for peoples common sense particularly if they have shown the ability to become a pilot and go on to get an IRing. On the whole if people are not current and have in the first place been properly trained to understand the risks of not being current they will go and get some training and certainly will not be shooting approaches to minima. Of course there will always be bold pilots and I suspect with all the currency checks in the world there will still be bold pilots who are prepared to exceed their own currency abilities.
That is such an important statement.
As we all know the aviation industry is probably the most regulated of any.
Doctors, dentists, lawyers, accountants and a host of other professionals are not tested at interval. I appreciate if they have any sense they will undertake ongoing professional training and in some case are required to demonstrate they have done so to their regulatory authority. I also understand that in some cases there is an effective ongoing peer review.
As has been commented in the States no revalidation of an IR is required if you meet the currency requirments. In the UK revalidation is required every 12months. The States have always had a biannual review, for years we have not. Is there evidence that revalidation improves safety, is there evidence revalidation should be every 25 months, every year, every six months, every .. .. .. Where do you draw the line if a line should be drawn, and do you draw that line on some arbitary whim - once a year sounds good, and will go down well with the examiners!!
I have a pretty high regard for peoples common sense particularly if they have shown the ability to become a pilot and go on to get an IRing. On the whole if people are not current and have in the first place been properly trained to understand the risks of not being current they will go and get some training and certainly will not be shooting approaches to minima. Of course there will always be bold pilots and I suspect with all the currency checks in the world there will still be bold pilots who are prepared to exceed their own currency abilities.
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"getting an IR in the States is often just rating collection"
I suggest you go and do an FAA IR before posting such generalised drivel.
On the currency, it's true that one can knock off the 6 IAPs under the hood with a safety pilot, but few aircraft owners who fly for real to real places need to do that. And those that don't don't need to, so there isn't a safety issue. Just like with PPL training; most people never get to use it, so the fact that the training is mostly cr*p (relative to the legal privileges of a PPL) doesn't cause any problems.
If every PPL went off and flew to privileges, ATC would collapse (under the infringements), and the training establishment would get shut down pending a complete review of the syllabus.
If every JAA IR went off and got into the plane they can (some rented spamcan, no good for IFR and probably illegal for IFR in CAS) and flew it to his privileges, the result would be similar; perhaps slightly less bad.
As I've said, currency is the key and unfortunately aircraft ownership is the key to currency.
This is the real problem which most IMCR holders struggle with. It's not a problem for IR holders because.... there are so few of them it doesn't matter.
I suggest you go and do an FAA IR before posting such generalised drivel.
On the currency, it's true that one can knock off the 6 IAPs under the hood with a safety pilot, but few aircraft owners who fly for real to real places need to do that. And those that don't don't need to, so there isn't a safety issue. Just like with PPL training; most people never get to use it, so the fact that the training is mostly cr*p (relative to the legal privileges of a PPL) doesn't cause any problems.
If every PPL went off and flew to privileges, ATC would collapse (under the infringements), and the training establishment would get shut down pending a complete review of the syllabus.
If every JAA IR went off and got into the plane they can (some rented spamcan, no good for IFR and probably illegal for IFR in CAS) and flew it to his privileges, the result would be similar; perhaps slightly less bad.
As I've said, currency is the key and unfortunately aircraft ownership is the key to currency.
This is the real problem which most IMCR holders struggle with. It's not a problem for IR holders because.... there are so few of them it doesn't matter.
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Slim, you may be correct about the objectives of American pilots, I have never flown in the States so I am unable to comment.
As a matter of fact if a FAA/IR pilot converts his rating here he gets an IMC, provided he has not obtained one previously. A JAR/IR holder however gets a FAA/IR in the States subject to a small test. This may be something for Pilotho to bear in mind.
As a matter of fact if a FAA/IR pilot converts his rating here he gets an IMC, provided he has not obtained one previously. A JAR/IR holder however gets a FAA/IR in the States subject to a small test. This may be something for Pilotho to bear in mind.
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DFC,
MSA is 1000' above within 5nm of the aircraft, not 10nm as you state. Generally agree with most other comments you make, although you seem to have gone quiet on this one since FFF's comments.
MSA is 1000' above within 5nm of the aircraft, not 10nm as you state. Generally agree with most other comments you make, although you seem to have gone quiet on this one since FFF's comments.
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Justicar, good to see some actual citations of documents to back up your argument. May I ask a question or two?
You quoted Article 49 (5)(a) and (5)(b) and concentrated on "notified instrument approach procedure", but not the 'specified... height'.
Specified is defined in (7) as
There is the word 'notified' which DFC mentioned.
In 155 (Interpretation) is says
Ah, there is the reference to the AIP, so the minima specified in the ANO are to be found in NOTAMS or the AIP. Surely that gives the AIP more than an advisory document status, sounds like it is where the ANO tells you to find the minima for an instrument letfown. Doesn't that make it law?
Now, getting to the AIP again
There is the 'but', which I think makes 500/600 absolute. Therefore, as it's referenced by the ANO as being where you find these numbers, that makes it mandatory to add 600/600ft to a published approach.
I think that's what DFC said, and it's hard to see why he is wrong. Why do you think he is?
Another question.
49 (7) has two parts. The first is
I am assuming this is when there is a published IAP.
it goes on to say.
I assume this is when there is no published IAP, one of these DIY approaches we hear about.
So if is this is the case, where is the "notified method for calculating aerodrome operating minima" to be found? Wouldn't this determine the MDH for somebody performing a DIY instrument letdown in class G. If this is not to be found, or the calculation hasn't been made using that notified method, then is an instrument letdown below MSA actually allowed? DFC made reference to this too, that DIY letdowns below MSA are illegal.
So, my other question is, what authority does anybody have to descend below MSA if they only have an IMCR (or IR) if there is no published (notified) approach?
You quoted Article 49 (5)(a) and (5)(b) and concentrated on "notified instrument approach procedure", but not the 'specified... height'.
Specified is defined in (7) as
(7) In this article “specified” in relation to aerodrome operating minima means such particulars of aerodrome operating minima as have been notified in respect of the aerodrome or if the relevant minima have not been notified such minima as are ascertainable by reference to the notified method for calculating aerodrome operating minima.
In 155 (Interpretation) is says
Notified’ means set out with the authority of the CAA in a document published by or under an arrangement entered into with the CAA and entitled ‘United Kingdom Notam’ or ‘Air Pilot’ and for the time being in force
Now, getting to the AIP again
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.
I think that's what DFC said, and it's hard to see why he is wrong. Why do you think he is?
Another question.
49 (7) has two parts. The first is
In this article “specified” in relation to aerodrome operating minima means such particulars of aerodrome operating minima as have been notified in respect of the aerodrome
it goes on to say.
or if the relevant minima have not been notified such minima as are ascertainable by reference to the notified method for calculating aerodrome operating minima.
So if is this is the case, where is the "notified method for calculating aerodrome operating minima" to be found? Wouldn't this determine the MDH for somebody performing a DIY instrument letdown in class G. If this is not to be found, or the calculation hasn't been made using that notified method, then is an instrument letdown below MSA actually allowed? DFC made reference to this too, that DIY letdowns below MSA are illegal.
So, my other question is, what authority does anybody have to descend below MSA if they only have an IMCR (or IR) if there is no published (notified) approach?
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Slim, an interesting submission but I have to confess at feeling slightly punch drunk. Personally I prefer to adopt a practical approach but I recognise that these matters should be aired if for no other reason to demonstrate just how confusing it all is. In answer to your last question I give myself authority in the interest of self preservation.
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Ah, bpilatus, emergency authority of pilot in command, you can do almost what you want then, but I think you have to tell the authorities about it and they may come asking annoying questions 
It sure is a tortuous route to the conclusions, and I don't know a vast amount about the UK system, but nobody has yet said where it goes wrong. All the people who come up with folklore about what you can do with the IMCR have gone quite This subject will come up again so I'll bring it up then.
So having thought about it even more, I now think the CAA rules are basically the same as the FAA rules for flight in class G, and that's no instrument descent below MEA/MSA in class G unless you are on an approved letdown. On published instrument approaches, the IMCR minima are higher by the amounst prescribed in the AIP, and these are legally binding minima. Unless somebody can demonstrate otherwise using an argument with cites regulations
It sure is a tortuous route to the conclusions, and I don't know a vast amount about the UK system, but nobody has yet said where it goes wrong. All the people who come up with folklore about what you can do with the IMCR have gone quite
This subject will come up again so I'll bring it up then. So having thought about it even more, I now think the CAA rules are basically the same as the FAA rules for flight in class G, and that's no instrument descent below MEA/MSA in class G unless you are on an approved letdown. On published instrument approaches, the IMCR minima are higher by the amounst prescribed in the AIP, and these are legally binding minima. Unless somebody can demonstrate otherwise using an argument with cites regulations
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I now think the CAA rules are basically the same as the FAA rules for flight in class G, and that's no instrument descent below MEA/MSA in class G unless you are on an approved letdown.
There is currently no such requirement under the CAA regime. IFR flights outside controlled airspace are simply required to comply with the "Rules of the Air". For IFR flights, these waive the "no flight below MSA" rule when the aircraft is engaged in take-off or landing - with no requirement for the landing to be accomplished using a published procedure.
Should the CAA wish to bother a pilot in the UK for such an action, they would need to think in terms of something more generic - Endangering an Aircraft or its Occupants, for example.
2D
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Thanks 2donkeys,
I am guessing you are basing your argument on the following..
If you are using this to say you can do what you want if you are taking off or landing, then can you descend to 100ft AGL in cloud? Is there actually a MDH if there is no published approach?
I am guessing you are basing your argument on the following..
Minimum height
29. Without prejudice to the provisions of rule 5, in order to comply with the Instrument Flight Rules an aircraft shall not fly at a height of less than 1000 feet above the highest obstacle within a distance of 5 nautical miles of the aircraft unless:
(a) it is necessary for the aircraft to do so in order to take off or land;
29. Without prejudice to the provisions of rule 5, in order to comply with the Instrument Flight Rules an aircraft shall not fly at a height of less than 1000 feet above the highest obstacle within a distance of 5 nautical miles of the aircraft unless:
(a) it is necessary for the aircraft to do so in order to take off or land;
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That is in essence what I am saying.
The simplest case is a private airfield with no ATC and no published approaches. There is no rule to restrict a GPS-based home-made instrument approach down to such a field. Minima apply to published approaches.
Note, that I am not attempting to cloud the issue with the specific privileges of the IMC rating, where as we know, landing or taking off in less than 1800m is not permitted.
By focusing on the simplest case of a private field, I am also removing some of the other confusing practical issues, such as the Management of an Airfield denying authority for an aircraft to land below certain weather minima.
If the argument is focused on this simplest case, I think you'll find that there is nothing in legislation to prevent such an approach. This is not to suggest that it is sensible or safe.
2D
The simplest case is a private airfield with no ATC and no published approaches. There is no rule to restrict a GPS-based home-made instrument approach down to such a field. Minima apply to published approaches.
Note, that I am not attempting to cloud the issue with the specific privileges of the IMC rating, where as we know, landing or taking off in less than 1800m is not permitted.
By focusing on the simplest case of a private field, I am also removing some of the other confusing practical issues, such as the Management of an Airfield denying authority for an aircraft to land below certain weather minima.
If the argument is focused on this simplest case, I think you'll find that there is nothing in legislation to prevent such an approach. This is not to suggest that it is sensible or safe.
2D
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Thanks again 2D.
What about Article 49 (7)
My italics.
The relevant minima have not been notified as there is no published approach. So minima have to be calculated "by reference to the notified method for calculating aerodrome operating minima"
I'm guessing that is PANS-OPS. So sure you can do an instrument letdown in class g where no published IAP exists, but it has to be designed to the standards set out in PANS-OPS. Does anybody do this?
Originally Posted by 2Donkeys
If the argument is focused on this simplest case, I think you'll find that there is nothing in legislation to prevent such an approach
(7) In this article “specified” in relation to aerodrome operating minima means such particulars of aerodrome operating minima as have been notified in respect of the aerodrome or if the relevant minima have not been notified such minima as are ascertainable by reference to the notified method for calculating aerodrome operating minima.
The relevant minima have not been notified as there is no published approach. So minima have to be calculated "by reference to the notified method for calculating aerodrome operating minima"
I'm guessing that is PANS-OPS. So sure you can do an instrument letdown in class g where no published IAP exists, but it has to be designed to the standards set out in PANS-OPS. Does anybody do this?
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Slim_Slag
You make a good case however, the purpose of 49 (7) is to define the use of the word "specified" in that particular Article.
"Specified" in the context of this article, is used uniquely in relation to aerodromes having published approaches. It is covering the case in which an aircraft must fly a published approach into an aerodrome which does not calculate/promulgate approach minima. This would be relevant in particular if descending into a foreign airport for example.
2D
You make a good case however, the purpose of 49 (7) is to define the use of the word "specified" in that particular Article.
"Specified" in the context of this article, is used uniquely in relation to aerodromes having published approaches. It is covering the case in which an aircraft must fly a published approach into an aerodrome which does not calculate/promulgate approach minima. This would be relevant in particular if descending into a foreign airport for example.
2D
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2D,
A published approach without any minima? That would be a strange animal, never seen one of those, but that could just mean I haven't flown in most places. I don't see anything thet says 49(7) is only for aerodromes having published approaches, but if that is the basis for saying you can fly a 0/0 approach to a class G then fair enough. Very peculiar for a regulator like the CAA, who are generally far more strict than the FAA on supposed safety matters, to let that one get past
Cheers
A published approach without any minima? That would be a strange animal, never seen one of those, but that could just mean I haven't flown in most places. I don't see anything thet says 49(7) is only for aerodromes having published approaches, but if that is the basis for saying you can fly a 0/0 approach to a class G then fair enough. Very peculiar for a regulator like the CAA, who are generally far more strict than the FAA on supposed safety matters, to let that one get past
Cheers
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It's not easy is it Slim_Slag?
49(7), as you quoted it starts by saying:
So, the purpose of what follows is to define what they mean by the term "specified", throughout this Article. Nothing more or less.
So the next question is, when do they use the word "specified" in Article 49?
And here is the answer:
My bolds. You'll note that specified only applies in this instance to a runway with a notified instrument approach procedure.
And here it is again:
Once again, my bolds. Once again, "specified" only applies to a runway with a notified procedure. And that's it. Two "specifieds" to which 49(7) applies, neither of which relate to making unpublished approaches.
I hope that clears it up.
So far as published approaches with un-notified minima are concerned, this is not nearly as rare as you might imagine. You won't find minima as such in the UK AIP charts. You get OCHs and OCAs from which you are required to apply maths to determine your minima. Jepp and Aerad do this for you (to a point). Some other countries take a similar stance, by publishing the constraints, leaving it for the aircraft operator to determine the minima which apply to his flight.
So far though, still nothing to convince me that you have found a law prohibiting descent below MSA other than on a published approach, but I am open to offers.
2D
49(7), as you quoted it starts by saying:
"In this article “specified” in relation to aerodrome operating minima means"
So the next question is, when do they use the word "specified" in Article 49?
And here is the answer:
an aircraft to which this article applies when
making a descent at an aerodrome to a runway in respect of which there is a notified instrument approach procedure shall not descend from a height of 1000 feet or more above the aerodrome to a height less than 1000 feet above the aerodrome if the relevant runway visual range for that runway is at the time less than the specified minimum for landing.
making a descent at an aerodrome to a runway in respect of which there is a notified instrument approach procedure shall not descend from a height of 1000 feet or more above the aerodrome to a height less than 1000 feet above the aerodrome if the relevant runway visual range for that runway is at the time less than the specified minimum for landing.
And here it is again:
...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;
unless in either case from such height the specified visual reference for landing is
established and is maintained.
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;
unless in either case from such height the specified visual reference for landing is
established and is maintained.
I hope that clears it up.
So far as published approaches with un-notified minima are concerned, this is not nearly as rare as you might imagine. You won't find minima as such in the UK AIP charts. You get OCHs and OCAs from which you are required to apply maths to determine your minima. Jepp and Aerad do this for you (to a point). Some other countries take a similar stance, by publishing the constraints, leaving it for the aircraft operator to determine the minima which apply to his flight.
So far though, still nothing to convince me that you have found a law prohibiting descent below MSA other than on a published approach, but I am open to offers.
2D
Last edited by 2Donkeys; 10th Mar 2006 at 10:07.
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Originally Posted by Dr Eckener
DFC,
MSA is 1000' above within 5nm of the aircraft, not 10nm as you state. Generally agree with most other comments you make, although you seem to have gone quiet on this one since FFF's comments.
MSA is 1000' above within 5nm of the aircraft, not 10nm as you state. Generally agree with most other comments you make, although you seem to have gone quiet on this one since FFF's comments.
If you simply measure 5nm each side of track and check for obstacles then there is the posibility that you will be less than 5nm for the edge of the area checked because of system errors and you not flying to the exact mm on the chosen centerline. Thus 10nm allows for a maximum RNP5 enroute error.
Of course you could sit down with PANS-OPS and accurately calculate the errors and use the exact figures to reduce the area to be considdered.
As for FFF's comments - Annex 10 provided a clear black and white written statement that was at odds with what the Examminer said and at the time I said that it would be odd for an examminer to fail someone for using the BPL outside of the DOC while permitting / advocating using the LOC outside of the DOC. I am still waiting for those that claimed to have CAA advice regarding IMC minima being advisory to name names (as FFF did) or publish written evidence.
---------
What everyone regardless of position agrees on is that the whole thing is confusing. Thus I propose that it be re-written to a very simple statement;
"IMC rating holders in current practice shall add 300ft and 1000m to the applicable IR minima".
That would make the ILS (IR single pilot 200ft / 800m) a 500ft / 1800m IMC minima and the lowest possible. Everything else requiring higher DH / MDH and higher Visibility / RVR.
Any comments regarding that?
Regards,
DFC
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2D,
I accept your interpretation than 49 does not apply to airports with DIY approaches. I still think the minima for an IMCR holder when shooting a published approach (as found in the AIP) are not recommended but mandatory.
I still don't feel beat up
Let me think about that one
I accept your interpretation than 49 does not apply to airports with DIY approaches.
I still think the minima for an IMCR holder when shooting a published approach (as found in the AIP) are not recommended but mandatory.I still don't feel beat up
So far though, still nothing to convince me that you have found a law prohibiting descent below MSA other than on a published approach, but I am open to offers.
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I still think the minima for an IMCR holder when shooting a published approach (as found in the AIP) are not recommended but mandatory.
The IMC rating and its conditions of use are in effect, rather than by design, scattered around a number of places (two parts of the ANO and AIP) each of which uses language which fails in small degrees to interlock fully. It is this lack of interlock which gives rise to the testosterone-filled debates that Pprune is so famous for.
I've always believed the vertical minima to be advisory, but I am happy to hear the arguments on both sides - they are certainly well rehearsed now.
2D