difference in IR and IMC rating
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You are all very good at quoting rules and regulations 
Why not? The usual rules apply, if the needle is out by the specified amount of deflection (personal limit / ½ / full scale), you execute a missed approach. I'm sure there are IMCR holders out there capable of flying an ILS down to 20', and IR holders who are not even capable of getting to minimums (because they are out of practice, or can't afford to remain current ).
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.
).
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Originally Posted by englishal
You are all very good at quoting rules and regulations
It's the interpretation that is causing the fun and games.
I'm sure there are IMCR holders out there capable of flying an ILS down to 20'
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I note the word 'capable', but even the FAA won't let you do that
Most nice aeroplanes I fly have an autopilot. Fly the ILS on the AP, when the G1000 reads 20', chop the throttle and George (...sorry, the AP) will keep pitching up and you may even make a perfect landing. If not, at least you may only break the aeroplane......
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Originally Posted by englishal
Fly the ILS on the AP, when the G1000 reads 20', chop the throttle and George (...sorry, the AP) will keep pitching up and you may even make a perfect landing. If not, at least you may only break the aeroplane......
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All depends on the situation and how likely you are to die doing something else
George doesn't know the height, but as you chop the throttle, George will have to keep pitching up to try to keep on the GS, but as there is no power he will eventually induce a stall.....hopefully by which time you'll be within 1" of the runway, so in otherwords he has just flared for you.
The nice thing about the G1000 is you can read off the "numbers" very accurately. Of course not being a Rad alt, you may find that 20' is actually -10' but assuming you have current pressure and you set it accurately, you may get away with it.
I can't try this in the UK as George lives in America
George doesn't know the height, but as you chop the throttle, George will have to keep pitching up to try to keep on the GS, but as there is no power he will eventually induce a stall.....hopefully by which time you'll be within 1" of the runway, so in otherwords he has just flared for you.
The nice thing about the G1000 is you can read off the "numbers" very accurately. Of course not being a Rad alt, you may find that 20' is actually -10' but assuming you have current pressure and you set it accurately, you may get away with it.
I can't try this in the UK as George lives in America
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Lets leave aside the issues associated with using an autopilot below its authorised minimum height (If we're talking N-reg for the moment, that is published in the flight manual supplement)
As you fly down the ILS, the sensitivity of both localiser and glideslope increase significantly. As you fly down to the runway below the ordinary Cat I DA, that sensitivity will rapidly increase to the point where is defeats the ability of GA autopilots to make the necessary adjustments with appropriate timeliness.
An altogether better plan, would be to fly the aircraft manually, with the FD displaying in approach mode. That way, you can decide if you want to continue all the way to the ground.
2D
As you fly down the ILS, the sensitivity of both localiser and glideslope increase significantly. As you fly down to the runway below the ordinary Cat I DA, that sensitivity will rapidly increase to the point where is defeats the ability of GA autopilots to make the necessary adjustments with appropriate timeliness.
An altogether better plan, would be to fly the aircraft manually, with the FD displaying in approach mode. That way, you can decide if you want to continue all the way to the ground.
2D
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DFC and others
I can now confirm that the CAAs official interpretation of the "IMC minima" is that the whole sentence is advisory, including after the "but". I have their interpretation in writing and I am satisfied their interpretation is specific and clear.
I am not prepared to quote the name of the person giving the interpretation or to reproduce their letter here because I have not asked their permission to do so.
I can now confirm that the CAAs official interpretation of the "IMC minima" is that the whole sentence is advisory, including after the "but". I have their interpretation in writing and I am satisfied their interpretation is specific and clear.
I am not prepared to quote the name of the person giving the interpretation or to reproduce their letter here because I have not asked their permission to do so.
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Funny old world eh! Did I not state exactly the same several pages ago?
But then of course it would of denied the barrack rooom lawyers the opportunity to spout off and impress us with there knowledge or lack of.....
I have great admiration for people like DFC who spend a great deal of time and effort trying to convice us there intrepetation is correct! Personally if I have a question regarding the rules I just write to the CAA who have always answered in a timelly manner with what I assume is the correct information (I base the assumption on the fact that it would be the CAA prosecuting me for an violation) so if I have the answer from them it could provide some sort of defence!!!
High Wing if you really want to see it in writing for yourself, you could do what the rest of us did and email them, answer came back in 48hrs. [email protected]
But then of course it would of denied the barrack rooom lawyers the opportunity to spout off and impress us with there knowledge or lack of.....
I have great admiration for people like DFC who spend a great deal of time and effort trying to convice us there intrepetation is correct! Personally if I have a question regarding the rules I just write to the CAA who have always answered in a timelly manner with what I assume is the correct information (I base the assumption on the fact that it would be the CAA prosecuting me for an violation) so if I have the answer from them it could provide some sort of defence!!!
High Wing if you really want to see it in writing for yourself, you could do what the rest of us did and email them, answer came back in 48hrs. [email protected]
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bose x.
It's hangar talk, all a bit of a laugh, that's all. And who is worse. Somebody who crafts and posts an argument which is proven wrong by a regulator as they will always be right, or somebody who comes along and says 'I told you so' ?
Well Fuji, seems like I was wrong. No, not about the interpretation, wrong when I said DFC worked for a regulator. I thought he had the inside track, still think his argument makes more sense than any I've seen, need to see yours before I can comment So he doesn't work for the CAA, from his 'prop deice' answer he obviously doesn't work for the FAA, I guess he must be an airline pilot!!
It's hangar talk, all a bit of a laugh, that's all. And who is worse. Somebody who crafts and posts an argument which is proven wrong by a regulator as they will always be right, or somebody who comes along and says 'I told you so' ?
Well Fuji, seems like I was wrong. No, not about the interpretation, wrong when I said DFC worked for a regulator
. I thought he had the inside track, still think his argument makes more sense than any I've seen, need to see yours before I can comment So he doesn't work for the CAA, from his 'prop deice' answer he obviously doesn't work for the FAA, I guess he must be an airline pilot!!
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To change the subject slightly, could anyone advise on how I stand flying in IMC with an IMCR (or JAA IR come to that) in an N-reg a/c in the UK? I heard today off of a very knowledgable FAA instructor that wherever in the world you are, you must have an FAA IR to fly an N-reg in instrument conditions. This is contrary to what I have been led to believe up until now 
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IO540,
Leave "in curent practice" in and define it. How would one define it? Having made that type of approach in IMC/under the hood/FNPT2 in the last 28 days as a starter?.....if not then add another 300ft and 1000m to the minima?
-------
look at the situation like this;
1. The rules say no lower than 500ft DH for an IMC rating holder.
As a result of this, the training sylabus requires that pilots are trained to fly a precision approach to a minimum DH of 500ft; and
The Skill Test to obtain the rating involves being tested on the ability to fly a precision approach to a minimum DH of 500ft.
If you go over the 15 hours in training because you are having problems with flying the ILS below 500ft then you could be in a position to claim your money back because that is not a required part of the sylabus. ( Think of it like taking 100 hours to get your basic PPL because it took 40 hours dual for you to master instrument approaches! - you would ask for a lot of money back since they are not a required part of the sylabus.)
If you fail your Test because you were unable to fly the ILS below 500ft then you can complain about the conduct of the test.
and finally but probably more important to this discussion;
If you have an accident while flying below 500ft in IMC on a precision approach with an IMC rating - you can not claim that you were not properly trained because it is not in the sylabus, you can not claim that the CAA should have chekced your ability because it is not required. That leaves you with no one for you, or the insurance company to blame but yourself.
However, if the permitted minima were less than 500ft, you could claim that you did not receive the required training - but they are not and you can not............or atleast you can but you will win the lotto before you win that one against anyone who can put a good argument to the Judge about training, demonstrated ability, safety, attitude and rules! Perhaps you should look up the original proposal documents and the initial idea that was the birth of the IMC rating - ask AOPA for more info!
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Fuji,
I am not prepared to quote the name of the person giving the interpretation or to reproduce their letter here because I have not asked their permission to do so.
Go on. Ask them. I can guarantee that they will give their permission.
The reason why I ask is that training providers would be very interested in this new development and would be taking time to consider the implications in terms of training standards, sylabus and potential advertisement , not to mention revision of course notes and from the Examiner's position, revision of the written exam and skill test standards.
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3FallinFlyer,
I will have to check again but my understanding is that you must hold an IR to fly an N reg aircraft IFR. The FARs say so. To my understanding that means an FAA IR or an IR issued by the country where the aircraft is operating.
Regards,
DFC
Leave "in curent practice" in and define it. How would one define it? Having made that type of approach in IMC/under the hood/FNPT2 in the last 28 days as a starter?.....if not then add another 300ft and 1000m to the minima?
-------
Originally Posted by englishal
You are all very good at quoting rules and regulations
Why not? The usual rules apply, if the needle is out by the specified amount of deflection (personal limit / ½ / full scale), you execute a missed approach. I'm sure there are IMCR holders out there capable of flying an ILS down to 20', and IR holders who are not even capable of getting to minimums (because they are out of practice, or can't afford to remain current ).
Why not? The usual rules apply, if the needle is out by the specified amount of deflection (personal limit / ½ / full scale), you execute a missed approach. I'm sure there are IMCR holders out there capable of flying an ILS down to 20', and IR holders who are not even capable of getting to minimums (because they are out of practice, or can't afford to remain current
).1. The rules say no lower than 500ft DH for an IMC rating holder.
As a result of this, the training sylabus requires that pilots are trained to fly a precision approach to a minimum DH of 500ft; and
The Skill Test to obtain the rating involves being tested on the ability to fly a precision approach to a minimum DH of 500ft.
If you go over the 15 hours in training because you are having problems with flying the ILS below 500ft then you could be in a position to claim your money back because that is not a required part of the sylabus. ( Think of it like taking 100 hours to get your basic PPL because it took 40 hours dual for you to master instrument approaches! - you would ask for a lot of money back since they are not a required part of the sylabus.)
If you fail your Test because you were unable to fly the ILS below 500ft then you can complain about the conduct of the test.
and finally but probably more important to this discussion;
If you have an accident while flying below 500ft in IMC on a precision approach with an IMC rating - you can not claim that you were not properly trained because it is not in the sylabus, you can not claim that the CAA should have chekced your ability because it is not required. That leaves you with no one for you, or the insurance company to blame but yourself.
However, if the permitted minima were less than 500ft, you could claim that you did not receive the required training - but they are not and you can not............or atleast you can but you will win the lotto before you win that one against anyone who can put a good argument to the Judge about training, demonstrated ability, safety, attitude and rules! Perhaps you should look up the original proposal documents and the initial idea that was the birth of the IMC rating - ask AOPA for more info!
---------
Fuji,
I am not prepared to quote the name of the person giving the interpretation or to reproduce their letter here because I have not asked their permission to do so.
Go on. Ask them. I can guarantee that they will give their permission.
The reason why I ask is that training providers would be very interested in this new development and would be taking time to consider the implications in terms of training standards, sylabus and potential advertisement
, not to mention revision of course notes and from the Examiner's position, revision of the written exam and skill test standards.---------
3FallinFlyer,
I will have to check again but my understanding is that you must hold an IR to fly an N reg aircraft IFR. The FARs say so. To my understanding that means an FAA IR or an IR issued by the country where the aircraft is operating.
Regards,
DFC
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I wonder if the CAA intended to make the 500/600ft limits mandatory, but actually the wording of the ANO 2000 failed to do so? Thus they are in the position where they wish it was mandatory, they intended it to be so, they would like us to believe so, but when you put them on the spot they have to admit that it's not?
I have to admit that DFC's case is coherent - the training syllabus, the test standards, the written exams all hang together - but there is the undeniable fact that the CAA have told people the limits are advisory.
Tim
I have to admit that DFC's case is coherent - the training syllabus, the test standards, the written exams all hang together - but there is the undeniable fact that the CAA have told people the limits are advisory.
Tim
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If the cloud base was 50ft below the MDA or DA how else could one get down and who is measuring anyway. Surely this activity (instrument approaches) can only be subject to to advisory heights.
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DFC
You are wrong.
You have quite clearly set out your case and why you consider there to be an absolute minima.
The regulators interpretation of the legislation is contrary and clear - the minima is a recommended minima. It so happens that a number of us have always agreed with their interpretation.
As an aside it is noteworthy that with regards the departure minima the ANO uses the words “shall not fly .. .. ..”. It seems to me if the draftsmen was capable of using such clear and unambiguous English where the IMCR holder is to be restricted to certain minima he was equally capable of saying and distinguishing between an advisory statement and a mandatory requirement!
There are many areas of law in which the regulatory authority will set out their understanding of legislation where there may be doubt. Tax law is full of examples. That does not absolutely mean the courts would have reached the same view, however as others have said it does mean if you adopt the interpretation of the regulatory authority you will not be criticised or prosecuted for a breach of the regulations. I happen to believe the courts would reach precisely the same interpretation.
It is my personal view the regulatory authority has it absolutely correct and the legislation is sound. I would be very concerned should it ever change. I am personally happy applying the IR minima and will continue to do so.
As I think Bose also commented, I was very impressed how quickly and clearly the CAA replied to my correspondence (and I might add that has consistently been my experience on issues such as this). If you don’t accept that I have correctly represented their reply you should write to them yourself.
I can now also add that I have since discussed the matter with my insurers and they have confirmed they accept the minima as recommended and that there is no “breach” of the conditions of my policy where a pilot with an IMCR operates below the recommended minima. Again, in my case you are wrong.
I do not accept your contentions regarding the training industries “take” on this issue. As I posted previously my instructor took the trouble some time ago to obtain clarification from the CAA although in fact both before and after his view had always been the minima were advisory. Whether or not others have done so is wholly academic. The schools teach a syllabus, and the regulatory authority deems that syllabus appropriate to determine on test whether a candidate should be granted the rating.
Finally your arguments about the IMCR syllabus are for me bizarre and so are the conclusions you reach. Moreover this is the second time in this thread you have “trotted out” the same argument. An exam is designed to test certain prescribed abilities of the examined. It provides no guarantee that the successful candidate will be capable of doing everything the qualification permits - the only guarantee it provides is that the candidate has met a certain standard. As I mentioned earlier, and to take a very simple example, when you pass a driving test you are not tested on your ability to drive on a motorway and indeed you are unlikely to have demonstrated you can drive the car above 50 mph. The day after the test you can of course go and kill yourself and half a dozen others on the motorway (God forbid).
It is very well understood by examiners and pilots that the IMCR initially sets a less rigorous standard than an IR. That is why there are these recommended minima, and that is why the CAA has always recommended that a newly qualified IMCR holder should consider the rating as a “get you home” or “get you out of trouble” license. However, the regulators in their wisdom also (fortunately) had the sense to realise that there are some private pilots who will use the rating in earnest and will achieve a standard of flying that is better than many IR holders.
So in short you are wrong DFC. The only reason I have repeated that you are wrong is because you have raised an important issue and we have all had an good debate on this matter. Rightly I believe the matter has been clarified and I think it is important that interested pilots are aware. However much as you disagree I do not believe you should go on setting out a position that is simply wrong because some people might actually believe you!
Whilst posting I take on board the comment that were the intention of the legislator different? I don’t believe this to be the case at all. I think if you look at the history of the IMCR it is quite clear what the legislator had in mind and it is quite clear why an 1,800 departure minima should apply. In fact whilst I don’t agree with the class A restriction it is also clear why at the time this restriction should also have been applied. Whilst I know there are many examples of appallingly drafted legalisation I do think this is not one of those cases.
You are wrong.
You have quite clearly set out your case and why you consider there to be an absolute minima.
The regulators interpretation of the legislation is contrary and clear - the minima is a recommended minima. It so happens that a number of us have always agreed with their interpretation.
As an aside it is noteworthy that with regards the departure minima the ANO uses the words “shall not fly .. .. ..”. It seems to me if the draftsmen was capable of using such clear and unambiguous English where the IMCR holder is to be restricted to certain minima he was equally capable of saying and distinguishing between an advisory statement and a mandatory requirement!
There are many areas of law in which the regulatory authority will set out their understanding of legislation where there may be doubt. Tax law is full of examples. That does not absolutely mean the courts would have reached the same view, however as others have said it does mean if you adopt the interpretation of the regulatory authority you will not be criticised or prosecuted for a breach of the regulations. I happen to believe the courts would reach precisely the same interpretation.
It is my personal view the regulatory authority has it absolutely correct and the legislation is sound. I would be very concerned should it ever change. I am personally happy applying the IR minima and will continue to do so.
As I think Bose also commented, I was very impressed how quickly and clearly the CAA replied to my correspondence (and I might add that has consistently been my experience on issues such as this). If you don’t accept that I have correctly represented their reply you should write to them yourself.
I can now also add that I have since discussed the matter with my insurers and they have confirmed they accept the minima as recommended and that there is no “breach” of the conditions of my policy where a pilot with an IMCR operates below the recommended minima. Again, in my case you are wrong.
I do not accept your contentions regarding the training industries “take” on this issue. As I posted previously my instructor took the trouble some time ago to obtain clarification from the CAA although in fact both before and after his view had always been the minima were advisory. Whether or not others have done so is wholly academic. The schools teach a syllabus, and the regulatory authority deems that syllabus appropriate to determine on test whether a candidate should be granted the rating.
Finally your arguments about the IMCR syllabus are for me bizarre and so are the conclusions you reach. Moreover this is the second time in this thread you have “trotted out” the same argument. An exam is designed to test certain prescribed abilities of the examined. It provides no guarantee that the successful candidate will be capable of doing everything the qualification permits - the only guarantee it provides is that the candidate has met a certain standard. As I mentioned earlier, and to take a very simple example, when you pass a driving test you are not tested on your ability to drive on a motorway and indeed you are unlikely to have demonstrated you can drive the car above 50 mph. The day after the test you can of course go and kill yourself and half a dozen others on the motorway (God forbid).
It is very well understood by examiners and pilots that the IMCR initially sets a less rigorous standard than an IR. That is why there are these recommended minima, and that is why the CAA has always recommended that a newly qualified IMCR holder should consider the rating as a “get you home” or “get you out of trouble” license. However, the regulators in their wisdom also (fortunately) had the sense to realise that there are some private pilots who will use the rating in earnest and will achieve a standard of flying that is better than many IR holders.
So in short you are wrong DFC. The only reason I have repeated that you are wrong is because you have raised an important issue and we have all had an good debate on this matter. Rightly I believe the matter has been clarified and I think it is important that interested pilots are aware. However much as you disagree I do not believe you should go on setting out a position that is simply wrong because some people might actually believe you!
Whilst posting I take on board the comment that were the intention of the legislator different? I don’t believe this to be the case at all. I think if you look at the history of the IMCR it is quite clear what the legislator had in mind and it is quite clear why an 1,800 departure minima should apply. In fact whilst I don’t agree with the class A restriction it is also clear why at the time this restriction should also have been applied. Whilst I know there are many examples of appallingly drafted legalisation I do think this is not one of those cases.
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I do like that term "DFC you are WRONG" it warms my heart.
If you actually read his last post it has gone from being "illegal" to "the training does not support minimum approaches". I look forward to the next line he trots out to support his argument.
<Go on. Ask them. I can guarantee that they will give their permission. >
It would be much easier for DFC to actually ask the CAA himself instead of pontificating or is he scared getting the answer from the horses mouth will sink his arguments?
Personally my original IMCR training was actually done by the same guy who is doing most of my current JAR IR training and he believed strongly in the IMCR as a proper tool and trained me and all of his students to minima. In the 1400hrs between doing the IMCR and deciding to do the full IR (to give me access to the airways as my plane is equipped) I have flown over 200hrs by sole reference to instruments and carried out many approaches to minima. But in real terms it is rare to have to fly to minima as the weather is not that bad, however when I take off I am happy that I can get back down at the other end.
If you actually read his last post it has gone from being "illegal" to "the training does not support minimum approaches". I look forward to the next line he trots out to support his argument.
<Go on. Ask them. I can guarantee that they will give their permission. >
It would be much easier for DFC to actually ask the CAA himself instead of pontificating or is he scared getting the answer from the horses mouth will sink his arguments?
Personally my original IMCR training was actually done by the same guy who is doing most of my current JAR IR training and he believed strongly in the IMCR as a proper tool and trained me and all of his students to minima. In the 1400hrs between doing the IMCR and deciding to do the full IR (to give me access to the airways as my plane is equipped) I have flown over 200hrs by sole reference to instruments and carried out many approaches to minima. But in real terms it is rare to have to fly to minima as the weather is not that bad, however when I take off I am happy that I can get back down at the other end.
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Good stuff...
It's debatable whether one should make the privileges of the IMCR dependent on currency.
While this is a plausible safety argument (and always remember that "safety" can be used to force just about anything through; a bit like "do you agree that convicted child molesters should be able to work as PE teachers") it would remove IMC privileges from the great majority of PPL/IMCR holders. Most UK PPLs are already struggling to clock up something like 20-30hrs/year, VFR.
It would amount to a back door abolition of the IMCR.
One needs to decide whether to support the IMCR, or kill it off. If you want to kill it off (on "safety" grounds) then you ought to kill the basic PPL too, on the same patently obvious grounds that the usual training falls way short of its privileges. In reality one has to assume that pilots have the sense to not do something that's dangerous.
I would support a currency requirement for the IMCR if one got Class A privileges, but there is no way that would happen. The IR training industry would vigorously campaign against any such proposal; the fact that almost no UK PPL is doing a JAA IR being beside the point.
To change the subject slightly, could anyone advise on how I stand flying in IMC with an IMCR (or JAA IR come to that) in an N-reg a/c in the UK? I heard today off of a very knowledgable FAA instructor that wherever in the world you are, you must have an FAA IR to fly an N-reg in instrument conditions.
A year or so ago I wrote to the CAA with exactly this question. Their reply was that it is up to the FAA to decide which (if any) of the IMCR privileges work in an N-reg. So I wrote to the FAA and their reply was they they regard the IMCR as "equivalent" to the FAA IR. For those that are going to jump at me over the last sentence, DFC no doubt et al, let me remind them of the obvious caveat that the IMCR privileges are themselves limited by the ANO to be well below those of the FAA IR (i.e. no Class A, 1800min vis) but it does mean the IMCR appears fully valid in an N-reg. One cannot really go any further than this is clarifying this old chestnut.
Tied up with this is the other old chestnut whether an FAA PPL holder (an FAA PPL has automatic night privileges, normally) can fly in the UK at night (whether in N or G) given that UK night is normally IFR. I have never seen this one answered, and now that I have the IR it doesn't concern me anymore.
On a related tack, the supporting case for flying an N-reg with a UK PPL with the night qual/rating is
FAR $61.3 (a) (1) says: "when operated within a foreign country, a current pilot license issues by the country in which the aircraft is operated may be used"
and of course that provides a supporting case for the IMCR privileges in an N-reg, too, unless one goes for the anally retentive argument that a "license" is not the same as a "rating" in the above context.
It's debatable whether one should make the privileges of the IMCR dependent on currency.
While this is a plausible safety argument (and always remember that "safety" can be used to force just about anything through; a bit like "do you agree that convicted child molesters should be able to work as PE teachers") it would remove IMC privileges from the great majority of PPL/IMCR holders. Most UK PPLs are already struggling to clock up something like 20-30hrs/year, VFR.
It would amount to a back door abolition of the IMCR.
One needs to decide whether to support the IMCR, or kill it off. If you want to kill it off (on "safety" grounds) then you ought to kill the basic PPL too, on the same patently obvious grounds that the usual training falls way short of its privileges. In reality one has to assume that pilots have the sense to not do something that's dangerous.
I would support a currency requirement for the IMCR if one got Class A privileges, but there is no way that would happen. The IR training industry would vigorously campaign against any such proposal; the fact that almost no UK PPL is doing a JAA IR being beside the point.
To change the subject slightly, could anyone advise on how I stand flying in IMC with an IMCR (or JAA IR come to that) in an N-reg a/c in the UK? I heard today off of a very knowledgable FAA instructor that wherever in the world you are, you must have an FAA IR to fly an N-reg in instrument conditions.
A year or so ago I wrote to the CAA with exactly this question. Their reply was that it is up to the FAA to decide which (if any) of the IMCR privileges work in an N-reg. So I wrote to the FAA and their reply was they they regard the IMCR as "equivalent" to the FAA IR. For those that are going to jump at me over the last sentence, DFC no doubt et al, let me remind them of the obvious caveat that the IMCR privileges are themselves limited by the ANO to be well below those of the FAA IR (i.e. no Class A, 1800min vis) but it does mean the IMCR appears fully valid in an N-reg. One cannot really go any further than this is clarifying this old chestnut.
Tied up with this is the other old chestnut whether an FAA PPL holder (an FAA PPL has automatic night privileges, normally) can fly in the UK at night (whether in N or G) given that UK night is normally IFR. I have never seen this one answered, and now that I have the IR it doesn't concern me anymore.
On a related tack, the supporting case for flying an N-reg with a UK PPL with the night qual/rating is
FAR $61.3 (a) (1) says: "when operated within a foreign country, a current pilot license issues by the country in which the aircraft is operated may be used"
and of course that provides a supporting case for the IMCR privileges in an N-reg, too, unless one goes for the anally retentive argument that a "license" is not the same as a "rating" in the above context.
Last edited by IO540; 11th Mar 2006 at 10:18.
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Fuji,
I am quite contented with my position and have clearly demonstrated tangible evidence to support the case.
The CAA says "seeing is believing" and we are waiting to see your communication or identification of the CAA member of Licensing Staff that replied to you as you (and BOSE) say.
Until then we have the tangible evidence on one side of the debate and hearsay on the other.
Nice to know that your insurer is available to provide a considered response so early on a Saturday morning.
As for telling other people - I have been doing that for decades - as have many others in the training industry. Until the CAA change the position, we will continue to do as before. We also expect students being told such information to take heed and use the information provided. Otherwise instructors are wasting their time. If the CAA change the position, the training industry will change the information included in lessons.
From a potential liability point of view, I would be far happier to incorrectly advise pilots to use minima which are more on the safe side of any legal limit than have the posibility that I was advocating or promoting using minima that are less than the established ones.
-----
bpilatus,
If the cloud base was 50ft below the MDA or DA how else could one get down and who is measuring anyway. Surely this activity (instrument approaches) can only be subject to to advisory heights.
You can not depart for a destination where the minima are below what is required unless you have planned for two available alternates where the weather (actual and forecast) is going to be above minima within a good time period round the ETA.
Even if the weather at destination is above minima, you still need to have an available alternate with appropriate weather that you can divert to should you not be able to land at the destination.
To use a destination with no alternate theweather has to be very good - something like VMC from MSA to the airfield.
One can not start an approach or continue below 1000ft AAL if the weather is below minima.
All those issues are deigned to prevent ducking under, multiple approaches going lower and lower and such like which in the past have contributed to accidents.
As for those "who is measuring?" - 6' X 6' X 3' is not a measurment you want to encounter too soon - which you will if you reguluarly duck under.
Regards,
DFC
I am quite contented with my position and have clearly demonstrated tangible evidence to support the case.
The CAA says "seeing is believing" and we are waiting to see your communication or identification of the CAA member of Licensing Staff that replied to you as you (and BOSE) say.
Until then we have the tangible evidence on one side of the debate and hearsay on the other.
Nice to know that your insurer is available to provide a considered response so early on a Saturday morning.
As for telling other people - I have been doing that for decades - as have many others in the training industry. Until the CAA change the position, we will continue to do as before. We also expect students being told such information to take heed and use the information provided. Otherwise instructors are wasting their time. If the CAA change the position, the training industry will change the information included in lessons.
From a potential liability point of view, I would be far happier to incorrectly advise pilots to use minima which are more on the safe side of any legal limit than have the posibility that I was advocating or promoting using minima that are less than the established ones.
-----
bpilatus,
If the cloud base was 50ft below the MDA or DA how else could one get down and who is measuring anyway. Surely this activity (instrument approaches) can only be subject to to advisory heights.
You can not depart for a destination where the minima are below what is required unless you have planned for two available alternates where the weather (actual and forecast) is going to be above minima within a good time period round the ETA.
Even if the weather at destination is above minima, you still need to have an available alternate with appropriate weather that you can divert to should you not be able to land at the destination.
To use a destination with no alternate theweather has to be very good - something like VMC from MSA to the airfield.
One can not start an approach or continue below 1000ft AAL if the weather is below minima.
All those issues are deigned to prevent ducking under, multiple approaches going lower and lower and such like which in the past have contributed to accidents.
As for those "who is measuring?" - 6' X 6' X 3' is not a measurment you want to encounter too soon - which you will if you reguluarly duck under.
Regards,
DFC
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DFC - ah well, I give up
You obviously believe you are correct so I doubt anyone will persuade you otherwise.
For me what is really worrying is that a pilot can be so dogmatic in his opinion without recourse to the legal regulator.
What you should do is 'phone or write to the CAA - but you are obviously not going to.
Anyone else who is interested just write or phone the CAA and talk to Flight Ops - GA. I guess you will get the same answer as I - the whole sentence is a recommendation and for guidance. More to the point the answer I got was not glibly given - leaving you wondering whether the person was sure of their position but came after consultation at the most senior level and was in writing. In my view beyond any doubt.
Oh and insureres work on Friday.
My own view is if I am not sure of the position and there has been sensible debate that makes one question ones earlier understanding go get the answer - thats the responsible stance to take - and if I had been wrong I would have been equally as happy to say so. I have been wrong plently of the times in the past .
You obviously believe you are correct so I doubt anyone will persuade you otherwise.
For me what is really worrying is that a pilot can be so dogmatic in his opinion without recourse to the legal regulator.
What you should do is 'phone or write to the CAA - but you are obviously not going to.
Anyone else who is interested just write or phone the CAA and talk to Flight Ops - GA. I guess you will get the same answer as I - the whole sentence is a recommendation and for guidance. More to the point the answer I got was not glibly given - leaving you wondering whether the person was sure of their position but came after consultation at the most senior level and was in writing. In my view beyond any doubt.
Oh and insureres work on Friday.
My own view is if I am not sure of the position and there has been sensible debate that makes one question ones earlier understanding go get the answer - thats the responsible stance to take - and if I had been wrong I would have been equally as happy to say so. I have been wrong plently of the times in the past
.