difference in IR and IMC rating
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Of course Fuji and I could now be accused of being in collusion as we have both bothered to ask the question of the regulator.
Go on DFC try asking them directly yourself, you never know you might even enjoy being corrected......
Go on DFC try asking them directly yourself, you never know you might even enjoy being corrected......
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I'm not at liberty to post the individuals name without his permission (and the CAA rules tend to say "No direct information on Pprune"), but...
I used to do many, many IMC rating skill tests and always used the mandatory figures of 500 and 600 as per DFC's argument.
When I moved to the USA - and kept doing those tests - I ended up flying aproaches to runway 05 at lakeland Linder Regional Airport, here in Florida.
As per the mandatory figures of 500 and 600 we ended up doing the go around at just short of two miles from the threshold.
Tampa approach (119.9) went ballistic, every time, as we were screwing up their plans for the guys ahead of and behind us.
During one of the annual school inspections, I asked the man from the CAA for his advice on how to deal with the mandatory figures of 500/600 for IMC rated pilots without screwing up ATC.
His reply was simple, "They aren't mandatory figures - they are only advisory.. The LIMITS for an IMC rated pilot is the same DA, published directly on the chart, as for an instrument rated pilot".
Advisory! (Bluddy good idea - but advisory).
I used to do many, many IMC rating skill tests and always used the mandatory figures of 500 and 600 as per DFC's argument.
When I moved to the USA - and kept doing those tests - I ended up flying aproaches to runway 05 at lakeland Linder Regional Airport, here in Florida.
As per the mandatory figures of 500 and 600 we ended up doing the go around at just short of two miles from the threshold.
Tampa approach (119.9) went ballistic, every time, as we were screwing up their plans for the guys ahead of and behind us.
During one of the annual school inspections, I asked the man from the CAA for his advice on how to deal with the mandatory figures of 500/600 for IMC rated pilots without screwing up ATC.
His reply was simple, "They aren't mandatory figures - they are only advisory.. The LIMITS for an IMC rated pilot is the same DA, published directly on the chart, as for an instrument rated pilot".
Advisory! (Bluddy good idea - but advisory).
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"the CAA rules tend to say "No direct information on Pprune"
I wonder what the thinking behind that is (seriously).
A related subject is why so few manufacturers participate in internet newsgroups (or other types of forum) dedicated to a particular hardware or software product. I am an electronics hardware/software engineer, and have seen such forums fill up with the same questions over and over and over, often degenerating into long debates full of completely useless speculation - yet a single post from the horse's mouth would have settled the matter.
There are a few forums where the manufacturer does participate and they work extremely well, to everybody's benefit.
Obviously the principal in question needs to assign an employee to the task, and the employee needs to have slightly more than 2 braincells, otherwise the participation will do more harm than good. These days, many companies in technology (especially the main players in consumer IT) seem to have problems with placing a single person with >2 braincells into any customer-facing position, but I would not think the CAA would have this problem.
I wonder what the thinking behind that is (seriously).
A related subject is why so few manufacturers participate in internet newsgroups (or other types of forum) dedicated to a particular hardware or software product. I am an electronics hardware/software engineer, and have seen such forums fill up with the same questions over and over and over, often degenerating into long debates full of completely useless speculation - yet a single post from the horse's mouth would have settled the matter.
There are a few forums where the manufacturer does participate and they work extremely well, to everybody's benefit.
Obviously the principal in question needs to assign an employee to the task, and the employee needs to have slightly more than 2 braincells, otherwise the participation will do more harm than good. These days, many companies in technology (especially the main players in consumer IT) seem to have problems with placing a single person with >2 braincells into any customer-facing position, but I would not think the CAA would have this problem.
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Originally Posted by IO540
Obviously the principal in question needs to assign an employee to the task, and the employee needs to have slightly more than 2 braincells, otherwise the participation will do more harm than good. These days, many companies in technology (especially the main players in consumer IT) seem to have problems with placing a single person with >2 braincells into any customer-facing position, but I would not think the CAA would have this problem.
1, people would complain about their money being wasted employing someone to sit on the internet all day;
2, no matter who it was, the topics would still rage forever as people thought of more and more bizarre ways the law could be interpreted.
The only test is in the Courts, and then the only real test is in the highest Court that can/will hear it.
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I wonder what the thinking behind that is (seriously).
Other snag would be how do you know - on a board like this - that whoever is posting as the CAA actually IS the CAA?
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Rustle, that's the first sound advice I think I have read on this forum. Please get more involved. There are too many people shooting from the hip and putting a hole in another pair of slippers.
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Fuji and Bose,
Ok I get the idea.
On Tuesday I make a posting saying that the CAA have agreed with my position but I can't post the reply or name the person who provided the answer.
Do you honestly think that would change your position?
No?.....why not?
Again I say that I have no problem changing my position based on the CAA's change in position. You say you have the evidence - I call your bluff is one way of putting it, and put up or shut up is another
----
IO540,
The rules do indeed say - no direct information on PPrune.
Employees of the CAA are not permitted to post on internet forums in their official capacity even in response to situations such as these.
Even if the question was posted in "The Times", a response would have to be sanctioned by management and approved by press officer before being sent for publication.
However, to explain this situation, if you ask me a question and I give you a reply. You then post the answer on PPrune and name me, that is no problem because I would not have provided any direct information on PPrune - you could have been totally unrelated to any debate and I would have no way of linking you to a debate unless you told me you were IO540.
That would not apply however if the information I gave to you was covered by a security marking or confidentiality marking eg "Medical in Confidence", "Commercial in Confidence" etc.
Imagine you as a member of a club ask a question of the CAA and they send you a response with no security / confidentiality marking. Do you not think that you would share that response with other members of your club, perhaps even post it on a notice board. - No problem it is all about improving understanding and safety.
However, it is nice to ask so that the person who provides the answer so that they can be sure they have the authority to make such a statement or pass you onto someone who has or even retract their statement.
Regards,
DFC
Ok I get the idea.
On Tuesday I make a posting saying that the CAA have agreed with my position but I can't post the reply or name the person who provided the answer.
Do you honestly think that would change your position?
No?.....why not?
Again I say that I have no problem changing my position based on the CAA's change in position. You say you have the evidence - I call your bluff is one way of putting it, and put up or shut up is another
----
IO540,
The rules do indeed say - no direct information on PPrune.
Employees of the CAA are not permitted to post on internet forums in their official capacity even in response to situations such as these.
Even if the question was posted in "The Times", a response would have to be sanctioned by management and approved by press officer before being sent for publication.
However, to explain this situation, if you ask me a question and I give you a reply. You then post the answer on PPrune and name me, that is no problem because I would not have provided any direct information on PPrune - you could have been totally unrelated to any debate and I would have no way of linking you to a debate unless you told me you were IO540.
That would not apply however if the information I gave to you was covered by a security marking or confidentiality marking eg "Medical in Confidence", "Commercial in Confidence" etc.
Imagine you as a member of a club ask a question of the CAA and they send you a response with no security / confidentiality marking. Do you not think that you would share that response with other members of your club, perhaps even post it on a notice board. - No problem it is all about improving understanding and safety.
However, it is nice to ask so that the person who provides the answer so that they can be sure they have the authority to make such a statement or pass you onto someone who has or even retract their statement.
Regards,
DFC
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DFC
Let me be clear.
I am not prepared to publish the letter I received from the CAA because it was addressed to me, in response to a question I asked. It has nothing to do with whether or not I am entitled to “pin it up”, simply that I consider it discourteous to pin up a personal letter - forget the old text book legal hooey.
You appear to believe I have an interest in who is “right” or “wrong”. The fact of the matter is that I was curious to know the “correct” position. We all enjoy a good debate, and there is a fair bit “tongue in cheek” but I think as professional pilots we also value our credibility - I am sorry that line has been crossed.
For those who are interested and to be absolutely clear I am completely satisfied on the basis of a written reply to my correspondence with the CAA a pilot with an IMCR can legally operate to the same landing minima as a pilot with an IR. If anyone wants to so satisfy themselves as I have said before write to the CAA - flight ops - you will know it is the same person - his surname made me smile anyway. Of course should you get a contrary reply, as DFC suggests, you can always PM me.
.. .. .. And to end on a lighter note - DFC, on this one you were wrong yesterday, you are wrong today, and because the legislation will not get changed tomorrow, you will still be wrong in the morning, but curiously I suspect you will be happier thinking you are right, so it is best left that way!
Let me be clear.
I am not prepared to publish the letter I received from the CAA because it was addressed to me, in response to a question I asked. It has nothing to do with whether or not I am entitled to “pin it up”, simply that I consider it discourteous to pin up a personal letter - forget the old text book legal hooey.
You appear to believe I have an interest in who is “right” or “wrong”. The fact of the matter is that I was curious to know the “correct” position. We all enjoy a good debate, and there is a fair bit “tongue in cheek” but I think as professional pilots we also value our credibility - I am sorry that line has been crossed.
For those who are interested and to be absolutely clear I am completely satisfied on the basis of a written reply to my correspondence with the CAA a pilot with an IMCR can legally operate to the same landing minima as a pilot with an IR. If anyone wants to so satisfy themselves as I have said before write to the CAA - flight ops - you will know it is the same person - his surname made me smile anyway. Of course should you get a contrary reply, as DFC suggests, you can always PM me.
.. .. .. And to end on a lighter note - DFC, on this one you were wrong yesterday, you are wrong today, and because the legislation will not get changed tomorrow, you will still be wrong in the morning, but curiously I suspect you will be happier thinking you are right, so it is best left that way!
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"The only test is in the Courts"
I agree; however the possibility of somebody getting taken to a Court for descending below the 500/600ft "minima" (IF they were law) is nil. This stuff is completely unenforceable because nobody can prove when you got visual.
A plain PPL could fly in solid IMC all the way across Europe, answering "maintain VMC" to every ATC instruction to do so, and provided he kept OCAS, descend down to say 800ft over the sea at some coastal airport and then call them up for a normal VFR approach. Plenty of people around Europe (where there is no IMCR and the JAA IR is the only option) do this, especially those with modern "permit" type aircraft which can be technically very advanced. You need a good understanding of weather so you don't get caught, and due to the need to do a DIY descent into VMC non-radio and do it safely, it works only for some destinations. And again there is no chance of getting done for it because nobody can prove there wasn't a hole in the cloud.....
Back to the subject of IMCR minima - the CAA has no difficulty publishing a flyer which interprets the ANO in readable language (the well known "public transport summary" one) for the purpose of PPL Cost Sharing etc. This subject is evidently close to the heart of the CAA, as they really go after anybody encroaching on the (more closely regulated and much more CAA-fee-producing) AOC territory. For some bizzare reason they have chosen to leave a lot of other stuff unclarified. I suppose it suits them; more options if prosecuting somebody for other stuff. But I still don't get it; unless the pilot is thick and admits to having flown in cloud or whatever, he cannot possibly get done for it. The 1800m minima for the IMCR is something else of course; very clearly recorded at any towered airfield.
Personally I would not publish personal correspondence either; it's bad manners unless names are deleted. Also, of course, even ifnames are deleted, the man at the CAA will discover the identity of the person who posted it here
Which will in turn restrict one's ability to speak one's mind on here.
I agree; however the possibility of somebody getting taken to a Court for descending below the 500/600ft "minima" (IF they were law) is nil. This stuff is completely unenforceable because nobody can prove when you got visual.
A plain PPL could fly in solid IMC all the way across Europe, answering "maintain VMC" to every ATC instruction to do so, and provided he kept OCAS, descend down to say 800ft over the sea at some coastal airport and then call them up for a normal VFR approach. Plenty of people around Europe (where there is no IMCR and the JAA IR is the only option) do this, especially those with modern "permit" type aircraft which can be technically very advanced. You need a good understanding of weather so you don't get caught, and due to the need to do a DIY descent into VMC non-radio and do it safely, it works only for some destinations. And again there is no chance of getting done for it because nobody can prove there wasn't a hole in the cloud.....
Back to the subject of IMCR minima - the CAA has no difficulty publishing a flyer which interprets the ANO in readable language (the well known "public transport summary" one) for the purpose of PPL Cost Sharing etc. This subject is evidently close to the heart of the CAA, as they really go after anybody encroaching on the (more closely regulated and much more CAA-fee-producing) AOC territory. For some bizzare reason they have chosen to leave a lot of other stuff unclarified. I suppose it suits them; more options if prosecuting somebody for other stuff. But I still don't get it; unless the pilot is thick and admits to having flown in cloud or whatever, he cannot possibly get done for it. The 1800m minima for the IMCR is something else of course; very clearly recorded at any towered airfield.
Personally I would not publish personal correspondence either; it's bad manners unless names are deleted. Also, of course, even ifnames are deleted, the man at the CAA will discover the identity of the person who posted it here
Which will in turn restrict one's ability to speak one's mind on here.
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There are no bad manners involved. Unless the correspondence says private and personal (which I doubt) there is no reason why the contents can not be made public. It seems unlikely the CAA would not want public information made er.. public, particularly if it means one letter will answer another dozen.
It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not.
It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not.
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"There are no bad manners involved. Unless the correspondence says private and personal (which I doubt) there is no reason why the contents can not be made public. It seems unlikely the CAA would not want public information made er.. public, particularly if it means one letter will answer another dozen."
As I have said before if you are really interested write to them, and obviously you and DFC will be very happy to post their reply here. It took me three days to get a reply - it really is not that difficult.
I cant quite believe there are certain contributors prepared to comment who presumably have some interest in the matter who cant be bothered to write. One can only guess for some reason they dont want the reply that will be given or they just enjoy a pretty pointless debate.
"It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not."
The legislation was specifically quoted in the reply. Ultimately it is of course their interpretation of the legislation but with an IMCR I would be very happy flying to IR landing minima with the letter from the CAA in my flying bag.
As I have said before if you are really interested write to them, and obviously you and DFC will be very happy to post their reply here. It took me three days to get a reply - it really is not that difficult.
I cant quite believe there are certain contributors prepared to comment who presumably have some interest in the matter who cant be bothered to write. One can only guess for some reason they dont want the reply that will be given or they just enjoy a pretty pointless debate.
"It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not."
The legislation was specifically quoted in the reply. Ultimately it is of course their interpretation of the legislation but with an IMCR I would be very happy flying to IR landing minima with the letter from the CAA in my flying bag.
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"It is another question whether a letter from a CAA employee binds the CAA to a particular view. In connection with matters of opinion, as opposed to quoting legislation or case law, I suspect it does not."
Very difficult to get done for it if you have such a letter.
Unless the writer made an obvious mistake, but here we are talking about legislation so ambiguous and difficult to comprehend that even insurance underwriters' lawyers refuse to give a view on it (yes I have tried that one a number of times, with all the usual subjects plus others).
Very difficult to get done for it if you have such a letter.
Unless the writer made an obvious mistake, but here we are talking about legislation so ambiguous and difficult to comprehend that even insurance underwriters' lawyers refuse to give a view on it (yes I have tried that one a number of times, with all the usual subjects plus others).
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Originally Posted by Fuji Abound
Let me be clear.
I am not prepared to publish the letter I received from the CAA .............
For those who are interested and to be absolutely clear I am completely satisfied on the basis of a written reply to my correspondence with the CAA a pilot with an IMCR can legally operate to the same landing minima as a pilot with an IR. If anyone wants to so satisfy themselves as I have said before write to the CAA - flight ops - you will know it is the same person - his surname made me smile anyway. Of course should you get a contrary reply, as DFC suggests, you can always PM me.
I am not prepared to publish the letter I received from the CAA .............
For those who are interested and to be absolutely clear I am completely satisfied on the basis of a written reply to my correspondence with the CAA a pilot with an IMCR can legally operate to the same landing minima as a pilot with an IR. If anyone wants to so satisfy themselves as I have said before write to the CAA - flight ops - you will know it is the same person - his surname made me smile anyway. Of course should you get a contrary reply, as DFC suggests, you can always PM me.
As these are anonymous forums the origins of the contributions may be opposite to what may be apparent. In fact the press may use it, or the unscrupulous, to elicit certain reactions.
Originally Posted by Fuji Abound
You appear to believe I have an interest in who is “right” or “wrong”. The fact of the matter is that I was curious to know the “correct” position
I have stated many times that I am willing to change my position but that decision will be based on evidence of a CAA statement. As a person who has held an IR for a very long time, I can indeed honestly say that I have no interest in which answer happens to be the final one.
Until then.
Regards,
DFC
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bosex, It's not a letter from your mistress, it's a letter from the bleeding government quango regulator. Publish it or shut up If you don't then I shall go back to arguing my case, and the board will not thank you for that..
If you don't then I shall go back to arguing my case, and the board will not thank you for that..
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Wow!
Lost count of the number of posts that have disapeared.
Someone must have posted something untrue or something they should not have not.
You'll have to say that all again Fuji.
Regards,
DFC
Lost count of the number of posts that have disapeared.
Someone must have posted something untrue or something they should not have not.
You'll have to say that all again Fuji.
Regards,
DFC
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Someone must have posted something untrue or something they should not have not.
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Well, not sure if any of mine went AWOL or not, forgot what I said anyway. Not wanting to ingratiate myself, but I think BRL does a great job moderating this forum.
bose-x did throw down a challenge, but I cannot be bothered.
So would we agree that the order of importance is
1) Case Law as written by judges
2) Letter of the Law as written by the legislative branch (i.e ANO/CFR 14)
3) Written interpretation from the authorised representative of the regulator (FAA General counsel/don't know CAA equivalent)
4) Advisory document published by regulator (AIM/AIP)
and at about
999,999,999) I've got a special email/phone call from somebody who claims to work for a regulator but I'm keeping it secret but I promise you it overrules everything in 1-4 above.
Even so, does a special phone call really count for much anyway? A CAA official was recently reported to say that you should use the localiser when outside it's guaranteed reception volume, so do we care what the regulator says in personal emails? And even usually persuasive people in the 'prop icing' thread claimed (4) trumped (1).
I still like the 'but'
Originally Posted by BRL
This doesn't look like it is heading anywhere at the moment, I will give it a day or so to see where it heads off to.
So would we agree that the order of importance is
1) Case Law as written by judges
2) Letter of the Law as written by the legislative branch (i.e ANO/CFR 14)
3) Written interpretation from the authorised representative of the regulator (FAA General counsel/don't know CAA equivalent)
4) Advisory document published by regulator (AIM/AIP)
and at about
999,999,999) I've got a special email/phone call from somebody who claims to work for a regulator but I'm keeping it secret but I promise you it overrules everything in 1-4 above.
Even so, does a special phone call really count for much anyway? A CAA official was recently reported to say that you should use the localiser when outside it's guaranteed reception volume, so do we care what the regulator says in personal emails? And even usually persuasive people in the 'prop icing' thread claimed (4) trumped (1).
I still like the 'but'