difference in IR and IMC rating
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I would like to clarrify my position one final time.
The reason I have decided to do so is that I agree with BRL - this thread has degraded into personal snipes - I think that is to be regretted.
There has been some very interesting and constructive debate on this thread about whether or not the recommended landing minima for an IMCR are the same as an IR holder with a recommendation that higher minima are used, or whether the higher minima are compulsory.
I admit that I had also understood it was the former. Others disagreed.
It seemed to me this was an important issue that we could all benefit from being clarified and so I telephoned the CAA.
In my view the response from the CAA was first class. Firstly they consulted internally and I believe at a very senior level. They then wrote to me officially setting out precisely and clearly the question I had asked and informed me that the whole sentence - before and after the “but” dealing with IMCR minima were advisory. I then asked my insurance company whether cover would be endangered by operating to IR landing minima where the pilot has an IMCR and not an IR as is the case for some of my group members - they confirmed that cover would not be endangered.
I have been asked to publish the letter I received form the CAA. I am not prepared to do so. Firstly, the correspondence between us was personal. I feel it would be an abuse of that understanding to publish their reply. Secondly, the correspondence from them asks that the reply is not copied to any other person - a tag I had not noticed in the first instance. Some have suggested “publish and be dammed” others have said I am quite entitled to publish not with standing the views I have expressed. I respect but do not agree with your views, please respect mine.
Some have suggested that IMCR holders should not rely on my post. I would agree. Given these are anonymous forums I could be making the whole thing up or I may have misinterpreted what the CAA have to say. Some also say the final test is the courts.
In the first instance you will have to make your own minds up. You may wish to take into account that a number of other contributors on this thread have reported they have received the same interpretation from the CAA. You may also wish to take into account that I have set out clearly the basis of the exchange of correspondence and the reasons why I am not prepared to publish their reply. Most importantly, I and a number of others have made it clear that you only need to write to the CAA yourself and doubtless you will receive the same reply. Should you decide to do so and feel it would also be inappropriate to publish their reply you might like to report your conclusions here.
For those who say whatever the CAA’s interpretation the Courts are the final arbiter, I would also agree - of course they must be. However, I think the Courts would find a letter from the CAA setting out their interpretation of the legislation pretty persuasive.
Finally, and this is not intended as a snipe, just a statement of my opinion, I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others. You are of course quite entitled to doubt their integrity but I believe before expressing those doubts here it would be as well for them to write to the regulator themselves to establish whether their doubts are justified or if they cant be bothered to do so, keep their doubts to themselves!
The reason I have decided to do so is that I agree with BRL - this thread has degraded into personal snipes - I think that is to be regretted.
There has been some very interesting and constructive debate on this thread about whether or not the recommended landing minima for an IMCR are the same as an IR holder with a recommendation that higher minima are used, or whether the higher minima are compulsory.
I admit that I had also understood it was the former. Others disagreed.
It seemed to me this was an important issue that we could all benefit from being clarified and so I telephoned the CAA.
In my view the response from the CAA was first class. Firstly they consulted internally and I believe at a very senior level. They then wrote to me officially setting out precisely and clearly the question I had asked and informed me that the whole sentence - before and after the “but” dealing with IMCR minima were advisory. I then asked my insurance company whether cover would be endangered by operating to IR landing minima where the pilot has an IMCR and not an IR as is the case for some of my group members - they confirmed that cover would not be endangered.
I have been asked to publish the letter I received form the CAA. I am not prepared to do so. Firstly, the correspondence between us was personal. I feel it would be an abuse of that understanding to publish their reply. Secondly, the correspondence from them asks that the reply is not copied to any other person - a tag I had not noticed in the first instance. Some have suggested “publish and be dammed” others have said I am quite entitled to publish not with standing the views I have expressed. I respect but do not agree with your views, please respect mine.
Some have suggested that IMCR holders should not rely on my post. I would agree. Given these are anonymous forums I could be making the whole thing up or I may have misinterpreted what the CAA have to say. Some also say the final test is the courts.
In the first instance you will have to make your own minds up. You may wish to take into account that a number of other contributors on this thread have reported they have received the same interpretation from the CAA. You may also wish to take into account that I have set out clearly the basis of the exchange of correspondence and the reasons why I am not prepared to publish their reply. Most importantly, I and a number of others have made it clear that you only need to write to the CAA yourself and doubtless you will receive the same reply. Should you decide to do so and feel it would also be inappropriate to publish their reply you might like to report your conclusions here.
For those who say whatever the CAA’s interpretation the Courts are the final arbiter, I would also agree - of course they must be. However, I think the Courts would find a letter from the CAA setting out their interpretation of the legislation pretty persuasive.
Finally, and this is not intended as a snipe, just a statement of my opinion, I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others. You are of course quite entitled to doubt their integrity but I believe before expressing those doubts here it would be as well for them to write to the regulator themselves to establish whether their doubts are justified or if they cant be bothered to do so, keep their doubts to themselves!
Last edited by Fuji Abound; 14th Mar 2006 at 15:52.
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Originally Posted by Fuji Abound
.........I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others. You are of course quite entitled to doubt their integrity but I believe before expressing those doubts here it would be as well for them to write to the regulator themselves to establish whether their doubts are justified
I accept your appology.
Regards,
DFC
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I think it is sad that some contributors feel it appropriate to call into doubt the integrity of others.
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OK - I take the wind ups in good spirit and will not pass comment 
.
I think pretty much everything reported on PPRuNe is an expression of opinion or interpretation.
As we have seen on this thread even the legislation is a matter of interpretation.
I still find it staggering that there is an interest in arguing a case when there is a clear suggestion that those arguing may be wrong. I would have thought it just obvious that if you have any interest at all you ask the regulator for their interpretation for yourself. You may disagree with their interpretation and that would be an interesting debate. You may believe that a contributor has misrepresented the position for any of the reasons suggested but wouldn’t you just want to make sure? In that way the whole discussion is moved on rather than becoming a pretty pointless argument of "I am right, I don’t care what any one else says, and I will go one telling every one I am right even if that results in more new pilots also believing something for the wrong reasons".
I suppose one of the reasons I feel so passionate about this is I always remember one of my instructors telling me something that was fundamentally and worryingly wrong. As many might I never the less believed he was right for a very long time. It was only through PPRune and doubts raised by a contributor that I finally wrote to the CAA for clarification. I would reiterate that I accept they are not the ultimate authority but I am far more comfortable if I have a letter from the CAA which sets out to me clearly their interpretation of the position particularly when it seems to me there is obviously some doubt.
Finally I think it is helpful to serious debate if a quote is to be made that it is in context. My point I thought was quite clearly put - it is pointless to the debate that we say a contributor might just be misleading everyone, surely far better to either set out why we disagree (and I appreciate this has been done on this thread in terms of the interpretation of the legislation) or in so far as the case in point goes report that we have written to the regulator and a contrary opinion has been received. Simply to say I don’t believe what a contributor reports would seem pretty pointless unless you just enjoy a good wind up!
High Wing Drifter has "popped the question" and I think it will be far more interesting to learn what he has to tell us when he gets a reply.
.I think pretty much everything reported on PPRuNe is an expression of opinion or interpretation.
As we have seen on this thread even the legislation is a matter of interpretation.
I still find it staggering that there is an interest in arguing a case when there is a clear suggestion that those arguing may be wrong. I would have thought it just obvious that if you have any interest at all you ask the regulator for their interpretation for yourself. You may disagree with their interpretation and that would be an interesting debate. You may believe that a contributor has misrepresented the position for any of the reasons suggested but wouldn’t you just want to make sure? In that way the whole discussion is moved on rather than becoming a pretty pointless argument of "I am right, I don’t care what any one else says, and I will go one telling every one I am right even if that results in more new pilots also believing something for the wrong reasons".
I suppose one of the reasons I feel so passionate about this is I always remember one of my instructors telling me something that was fundamentally and worryingly wrong. As many might I never the less believed he was right for a very long time. It was only through PPRune and doubts raised by a contributor that I finally wrote to the CAA for clarification. I would reiterate that I accept they are not the ultimate authority but I am far more comfortable if I have a letter from the CAA which sets out to me clearly their interpretation of the position particularly when it seems to me there is obviously some doubt.
Finally I think it is helpful to serious debate if a quote is to be made that it is in context. My point I thought was quite clearly put - it is pointless to the debate that we say a contributor might just be misleading everyone, surely far better to either set out why we disagree (and I appreciate this has been done on this thread in terms of the interpretation of the legislation) or in so far as the case in point goes report that we have written to the regulator and a contrary opinion has been received. Simply to say I don’t believe what a contributor reports would seem pretty pointless unless you just enjoy a good wind up!
High Wing Drifter has "popped the question" and I think it will be far more interesting to learn what he has to tell us when he gets a reply.
Last edited by Fuji Abound; 15th Mar 2006 at 12:08.
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Originally Posted by Fuji Abound
I then asked my insurance company whether cover would be endangered by operating to IR landing minima where the pilot has an IMCR and not an IR as is the case for some of my group members - they confirmed that cover would not be endangered.
If your insurer actually said/wrote what you wrote above, where do they differentiate the min 1800m viz requirement for an IMC holder as opposed to the min 800m viz for IR-SPA?
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It is quite easy to get a response to support ones preconceived notion/s. Surely though it's all a bit academic. Private pilots shouldn't be pushing their luck nor should they be endangering the lives of their passengers with such irresponsible behaviour.
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That's a good comment, Rustle
Unfortunately for the person asking, it is possible to obtain all kinds of replies from regulatory bodies, if you ask the right (I mean wrong, of course) question.
(It's a bit like the patent office - you can get a patent granted on just about anything so long as it is reasonably specialised. The examiner will probably not spot that there are a dozen cases of prior art, all known to anybody actually working in the business.....)
Unfortunately for the person answering, the answer could get them into serious trouble if the person asking uses it in his defence one day. And he can certainly do that.
That's why, when I ask questions on something like this, I always go to a lot of trouble to very clearly state the regulatory background and why I want to know the answer. Then, when the answer comes, you are much better able to rely on it, should you need to one day.
I have thus obtained affirmative written answers on:
CAA: The IMC Rating is not limited to any aircraft reg (and is thus valid in an N-reg if the FAA doesn't mind)
CAA: The removal of the "sight of surface" requirement, which you get when you get an IMCR, is valid worldwide, even though the IFR privileges of the IMCR are limited to the UK
FAA: The IMC Rating [within its own limited privileges, and in an N-reg] is equivalent to the FAA IR
plus some other very interesting stuff...
Looking at the way Fuji writes I am pretty sure he did write his questions in a non-misleading manner.
The practical bottom line is that approach minima are unenforceable, because nobody can prove when the pilot got visual. It is in other more readily visible areas where the CAA might wish to go back on a previous written reply saying it is "OK". I believe they have done this, or rather the DfT did it for them, in a particular situation last year in connection with the old Article 115, but I won't say....
Unfortunately for the person asking, it is possible to obtain all kinds of replies from regulatory bodies, if you ask the right (I mean wrong, of course) question.
(It's a bit like the patent office - you can get a patent granted on just about anything so long as it is reasonably specialised. The examiner will probably not spot that there are a dozen cases of prior art, all known to anybody actually working in the business.....)
Unfortunately for the person answering, the answer could get them into serious trouble if the person asking uses it in his defence one day. And he can certainly do that.
That's why, when I ask questions on something like this, I always go to a lot of trouble to very clearly state the regulatory background and why I want to know the answer. Then, when the answer comes, you are much better able to rely on it, should you need to one day.
I have thus obtained affirmative written answers on:
CAA: The IMC Rating is not limited to any aircraft reg (and is thus valid in an N-reg if the FAA doesn't mind)
CAA: The removal of the "sight of surface" requirement, which you get when you get an IMCR, is valid worldwide, even though the IFR privileges of the IMCR are limited to the UK
FAA: The IMC Rating [within its own limited privileges, and in an N-reg] is equivalent to the FAA IR
plus some other very interesting stuff...
Looking at the way Fuji writes I am pretty sure he did write his questions in a non-misleading manner.
The practical bottom line is that approach minima are unenforceable, because nobody can prove when the pilot got visual. It is in other more readily visible areas where the CAA might wish to go back on a previous written reply saying it is "OK". I believe they have done this, or rather the DfT did it for them, in a particular situation last year in connection with the old Article 115, but I won't say....
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Originally Posted by IO540
The practical bottom line is that approach minima are unenforceable, because nobody can prove when the pilot got visual.
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OK Fuji, I have it in writing that the CAA's position on this matter is the same as my position.
End of debate.
Regards,
DFC
PS: IO540, did you hold an IMC rating when you started training for the FAA IR? If you did then why did you need any training as you already had an equivalent rating. You should have saved yourself a lot of money and just asked for the paperwork to be issued on the basis of the equivalent rating.
What do you think the FAA would say if some person in the CAA said you could fly an N reg PA28 with a microlight licence? I think that they would be asking who gave the CAA authority to decide who can fly US registered aircraft and also asking when the FAA can start saying who can fly G registered aircraft.
End of debate.
Regards,
DFC
PS: IO540, did you hold an IMC rating when you started training for the FAA IR? If you did then why did you need any training as you already had an equivalent rating. You should have saved yourself a lot of money and just asked for the paperwork to be issued on the basis of the equivalent rating.
What do you think the FAA would say if some person in the CAA said you could fly an N reg PA28 with a microlight licence? I think that they would be asking who gave the CAA authority to decide who can fly US registered aircraft and also asking when the FAA can start saying who can fly G registered aircraft.
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OK DFC that is very helpful to know.
Just so we are all clear you are saying that you have written to the CAA and they have replied to you in writing that the landing minima for a pilot with an IMCR is 500 feet for a precision approach and 600 feet for a non precision approach. In other words these are legal minima and not recommended minima.
Perhaps you would confirm I have understood correctly that this is what you are saying the CAA have confirmed they are in agreement with?
Maybe you would also like to PM me and let me know who replied to your letter and I will PM you who replied to mine. Doubtless we can then jointly take up the matter with the CAA together with Bose-X and establish why their interpretations conflict.
Just so we are all clear you are saying that you have written to the CAA and they have replied to you in writing that the landing minima for a pilot with an IMCR is 500 feet for a precision approach and 600 feet for a non precision approach. In other words these are legal minima and not recommended minima.
Perhaps you would confirm I have understood correctly that this is what you are saying the CAA have confirmed they are in agreement with?
Maybe you would also like to PM me and let me know who replied to your letter and I will PM you who replied to mine. Doubtless we can then jointly take up the matter with the CAA together with Bose-X and establish why their interpretations conflict.
Last edited by Fuji Abound; 15th Mar 2006 at 22:22.
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Originally Posted by IO540
(It's a bit like the patent office - you can get a patent granted on just about anything so long as it is reasonably specialised. The examiner will probably not spot that there are a dozen cases of prior art, all known to anybody actually working in the business.....)
That's why, when I ask questions on something like this, I always go to a lot of trouble to very clearly state the regulatory background and why I want to know the answer. Then, when the answer comes, you are much better able to rely on it, should you need to one day.
That's why, when I ask questions on something like this, I always go to a lot of trouble to very clearly state the regulatory background and why I want to know the answer. Then, when the answer comes, you are much better able to rely on it, should you need to one day.
Secondly, have you ever had to rely on any of this 'aviation' knowledge which you are gathering? Indeed has anyone writing on here ever had to quote chapter and verse in their defence? Presumably things change and interpretation alter over time, with change in policy and case law which suggests that it is a moving target.
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All very sad ....
I have to say, I think this is incredibly sad. Fully grown men (I presume) banging heads and trying to score points rather than co-operating over trying to establish the truth of the matter - and to all of us who have an IMC, and are current, this matters - a lot. I sincerely hope DFC does what Fuji has asked and shares names - but to be honest, I'm not holding my breath.
For what it's worth, I disagree with DFC's position on the "magic sentence" : the lawyer in me believes that the sentence reads that the additional heights are advisory - but DFC would say that I have an IMC, so I'm therefore biased.
I also disagree (bear with me) with Fuji's statement that :-
Why ? The CAA are the undisputed fount of UK aviation knowledge in most people's eyes. Hauled into a court, I would unhesitatingly argue that the "test of the reasonable man" would confirm this, and that basing my interpretation of a very badly worded sentence on an authorised and verified source within the CAA would seem an extremely sensible thing to do !
Anyway, I continue to watch this thread in the hope that there is an outbreak of common sense before long. I'm afraid, however, that with the stances adopted by some of the contributors, this is looking increasingly unlikely ...
FF
For what it's worth, I disagree with DFC's position on the "magic sentence" : the lawyer in me believes that the sentence reads that the additional heights are advisory - but DFC would say that I have an IMC, so I'm therefore biased.
I also disagree (bear with me) with Fuji's statement that :-
I finally wrote to the CAA for clarification. I would reiterate that I accept they are not the ultimate authority
Anyway, I continue to watch this thread in the hope that there is an outbreak of common sense before long. I'm afraid, however, that with the stances adopted by some of the contributors, this is looking increasingly unlikely ...
FF
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Surely though it's all a bit academic. Private pilots shouldn't be pushing their luck nor should they be endangering the lives of their passengers with such irresponsible behaviour.
Comments like this represent elitist nonsense which in turn helps only to stifle General Aviation in the UK.
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What I did not do was send an email that turned into a phone call that resulted in a letter that included an email confidentiality clause. 
The students will continue to be taught the same correct safe information that they have been taught since the IMC rating came into being.
They will also be reminded as I have just been that the CAA's written position clearly says that the IMC rating is not designed for prolonged IMC flights planned to be terminated with an approach at an aerodrome where the weather is at minima. The IMC rating provides training in a basic skill designed to get a pilot out of troubble and is not a substitute for an IR.
Not (quite) a quote of course.....would not do that now would we.....but it is what the CAA have put in writing!
Why have the privileges in the ANO in that case? Now that is a question I also ask!
---------------
To get back to more important matters,
What does everyone think of a proposal to make the following the legal and clearly expressed minima for IMC rating holders in current practice;
1. DA(H) to be not lower than IR published DA(H) plus 300ft
2. MDA(H) to be not lower than IR published DA(H) plus 300ft
3. Visibility/RVR to be published IR minima + 1000m
4. Take-off minima to be ceiling = IMC approach DH+100ft and Vis / RVR 1800m or the approach Vis/RVR if higher
5. Requirement to teach and in practice to comply with the increased planning minima for alternates.
6. IMC rating limited to Single engine unless test done in Multi engine.
As an example, the result of the above at Blackpool runway 28 would be;
ILS DME = DA528, DH 500, RVR 1800 / 2000m ALS out
LOC DME = MDA 700, MDH 672, RVR 2200m / 2500m ALS out
Circle to land south of 10/28 = MDA 740, MDH 706, Vis 2500m
Circle to land = MDA 880, MDH 846, Vis 2500m
Take-off minima ceiling 600ft and Vis/RVR 1800 with the ILS available.
Take-off minima ceiling 800 and RVR 2200m if the GS is U/S. etc
Very easy to work out from the charts. Easy to apply.
More importantly, it links departure minima to that required to return if something fails eg alternator failure. This is something that very few IMC rated pilots seem to take into account or understand. It also allows some margin for efato in a single.
I know that some would not be happy with the higher minima but the safety case would easily show that such an easily applied system would be more safe and thus an improvement on the current system while any regulatory impact study / industry consultation would show that based on current teaching and CAA advice, there would be no adverse effect on safe operators.
Regards,
DFC
The students will continue to be taught the same correct safe information that they have been taught since the IMC rating came into being.
They will also be reminded as I have just been that the CAA's written position clearly says that the IMC rating is not designed for prolonged IMC flights planned to be terminated with an approach at an aerodrome where the weather is at minima. The IMC rating provides training in a basic skill designed to get a pilot out of troubble and is not a substitute for an IR.
Not (quite) a quote of course.....would not do that now would we.....but it is what the CAA have put in writing!
Why have the privileges in the ANO in that case? Now that is a question I also ask!
---------------
To get back to more important matters,
What does everyone think of a proposal to make the following the legal and clearly expressed minima for IMC rating holders in current practice;
1. DA(H) to be not lower than IR published DA(H) plus 300ft
2. MDA(H) to be not lower than IR published DA(H) plus 300ft
3. Visibility/RVR to be published IR minima + 1000m
4. Take-off minima to be ceiling = IMC approach DH+100ft and Vis / RVR 1800m or the approach Vis/RVR if higher
5. Requirement to teach and in practice to comply with the increased planning minima for alternates.
6. IMC rating limited to Single engine unless test done in Multi engine.
As an example, the result of the above at Blackpool runway 28 would be;
ILS DME = DA528, DH 500, RVR 1800 / 2000m ALS out
LOC DME = MDA 700, MDH 672, RVR 2200m / 2500m ALS out
Circle to land south of 10/28 = MDA 740, MDH 706, Vis 2500m
Circle to land = MDA 880, MDH 846, Vis 2500m
Take-off minima ceiling 600ft and Vis/RVR 1800 with the ILS available.
Take-off minima ceiling 800 and RVR 2200m if the GS is U/S. etc
Very easy to work out from the charts. Easy to apply.
More importantly, it links departure minima to that required to return if something fails eg alternator failure. This is something that very few IMC rated pilots seem to take into account or understand. It also allows some margin for efato in a single.
I know that some would not be happy with the higher minima but the safety case would easily show that such an easily applied system would be more safe and thus an improvement on the current system while any regulatory impact study / industry consultation would show that based on current teaching and CAA advice, there would be no adverse effect on safe operators.
Regards,
DFC
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"I have to say, I think this is incredibly sad. Fully grown men (I presume) banging heads and trying to score points rather than co-operating over trying to establish the truth of the matter - and to all of us who have an IMC, and are current, this matters - a lot."
I am so glad at least someone is prepared to take a sensible stance! Thank you.
I don’t suppose I will get the PM from DFC anyway.
However it would seem that DFC has received in writing contradictory advice from the CAA.
I have therefore written to them again asking them how the reply they sent to me can be promulgated. I shall let everyone know what reply I receive.
"Why ? The CAA are the undisputed fount of UK aviation knowledge in most people's eyes. Hauled into a court, I would unhesitatingly argue that the "test of the reasonable man" would confirm this, and that basing my interpretation of a very badly worded sentence on an authorised and verified source within the CAA would seem an extremely sensible thing to do !"
Actually FF I do agree with you. As I think I said previously in the event of proceedings on any matter, not just this, I suspect the judge would find a letter from the CAA as pretty persuasive - moreover, you cant quite imagine the CAA mounting a prosecution against a position they had outlined.
So far as the reminder concerning the design of the IMCR is concerned this is all pretty dull - I made this point pages ago and we all know the CAAs stance on this one. I agree with their stance and have always said so. That however is not the issue.
Some other examples that might be equally justified:
The PPL is not designed from a six hour cross country trip through Europe,
The driving license is not designed for the just qualified driver to do six hours on European motorways,
and most importantly,
The IR is not designed for a pilot who is not current to undertake the same flight as a pilot with an IMCR who is very current.
What really must not be forgotten in all this is that the IMCR was originally introduced by some very wise people who realised that in this country a private pilot is safer if he can undertake training ro enable him to fly in marginal weather. I think we all agree the training is not as comprehensive as for a pilot with an IR. We may even agree there is a big disparity between the training for an FAA and our IR in so far as the private pilot is concerned.
However training can mean very little in terms of developing skills, and I think the CAA rightly recognised this in drafting the legislation and supplying the interpretation they have and are able to see past the vested interest of some instructors and the training industry.
Why.
Find me a doctor, a lawyer, a dentist, or a Corgi gas fitter who is not better at his job than when he passed his exams. Yes I know there are a few that are worse! However in the vast majority of cases they are far better because their skills and practical application has improved with use and currency just as is the case for an IMCR holder who uses the qualification regularly. In fact be in no doubt they are significantly better than some IR holders I have flown with who are not current!
I recall well when a pilot with 600 hours to his credit (I think it was 600 hours) enjoyed some significant exemptions with regards IR training. It was in my opinion a retrograde step when that was changed.
Not only do I not agree with DFC proposed changes but I have a few of my own.
Firstly the legislation works perfectly well as it stands. In my experience instructors are very good at emphasising the need for caution to IMCR pilots. Secondly when pilots end up flying hard IFR sectors it is for one of two reasons - they have misinterpreted the weather or feel they are sufficiently current to undertake the flight. I don’t have proof, but how many IMCR holders who are current do you hear getting into trouble and how many accidents can you point to? (And I do read all the published accident reports every month). For those that have misinterpreted the weather, unfortunately that is always going to happen - it is the biggest reason pilots get into trouble and has nothing to do with whether or not they have a current IMCR or a lapsed IMCR.
My own proposals are that a pilot who has an IMCR and 600 hours total time of which at least 100 hours are instrument time, and of which 30 hours are instrument time in the last twelve months should on test by an approved examiner be entitled to be granted an IR restricted to private use. Students would be recommended to undertake a minimum of 10 hours further instrument training before the test but with an absolute minimum of 5 hours further training. If they did not undertake the further recommended training but past the test they should still get the rating!
I am so glad at least someone is prepared to take a sensible stance! Thank you.
I don’t suppose I will get the PM from DFC anyway.
However it would seem that DFC has received in writing contradictory advice from the CAA.
I have therefore written to them again asking them how the reply they sent to me can be promulgated. I shall let everyone know what reply I receive.
"Why ? The CAA are the undisputed fount of UK aviation knowledge in most people's eyes. Hauled into a court, I would unhesitatingly argue that the "test of the reasonable man" would confirm this, and that basing my interpretation of a very badly worded sentence on an authorised and verified source within the CAA would seem an extremely sensible thing to do !"
Actually FF I do agree with you. As I think I said previously in the event of proceedings on any matter, not just this, I suspect the judge would find a letter from the CAA as pretty persuasive - moreover, you cant quite imagine the CAA mounting a prosecution against a position they had outlined.
So far as the reminder concerning the design of the IMCR is concerned this is all pretty dull - I made this point pages ago and we all know the CAAs stance on this one. I agree with their stance and have always said so. That however is not the issue.
Some other examples that might be equally justified:
The PPL is not designed from a six hour cross country trip through Europe,
The driving license is not designed for the just qualified driver to do six hours on European motorways,
and most importantly,
The IR is not designed for a pilot who is not current to undertake the same flight as a pilot with an IMCR who is very current.
What really must not be forgotten in all this is that the IMCR was originally introduced by some very wise people who realised that in this country a private pilot is safer if he can undertake training ro enable him to fly in marginal weather. I think we all agree the training is not as comprehensive as for a pilot with an IR. We may even agree there is a big disparity between the training for an FAA and our IR in so far as the private pilot is concerned.
However training can mean very little in terms of developing skills, and I think the CAA rightly recognised this in drafting the legislation and supplying the interpretation they have and are able to see past the vested interest of some instructors and the training industry.
Why.
Find me a doctor, a lawyer, a dentist, or a Corgi gas fitter who is not better at his job than when he passed his exams. Yes I know there are a few that are worse! However in the vast majority of cases they are far better because their skills and practical application has improved with use and currency just as is the case for an IMCR holder who uses the qualification regularly. In fact be in no doubt they are significantly better than some IR holders I have flown with who are not current!
I recall well when a pilot with 600 hours to his credit (I think it was 600 hours) enjoyed some significant exemptions with regards IR training. It was in my opinion a retrograde step when that was changed.
Not only do I not agree with DFC proposed changes but I have a few of my own.
Firstly the legislation works perfectly well as it stands. In my experience instructors are very good at emphasising the need for caution to IMCR pilots. Secondly when pilots end up flying hard IFR sectors it is for one of two reasons - they have misinterpreted the weather or feel they are sufficiently current to undertake the flight. I don’t have proof, but how many IMCR holders who are current do you hear getting into trouble and how many accidents can you point to? (And I do read all the published accident reports every month). For those that have misinterpreted the weather, unfortunately that is always going to happen - it is the biggest reason pilots get into trouble and has nothing to do with whether or not they have a current IMCR or a lapsed IMCR.
My own proposals are that a pilot who has an IMCR and 600 hours total time of which at least 100 hours are instrument time, and of which 30 hours are instrument time in the last twelve months should on test by an approved examiner be entitled to be granted an IR restricted to private use. Students would be recommended to undertake a minimum of 10 hours further instrument training before the test but with an absolute minimum of 5 hours further training. If they did not undertake the further recommended training but past the test they should still get the rating!
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Excellent proposal, but would never get past JAA. And an IR which doesn't get past JAA is going to be worthless.
There is a JAA committee working on a "private IR"; they are still debating whether to cut down the ATPL ground school by 10% or 20%... a complete waste of time.
The IMCR would never come into existence today, either. It dates from another age altogether.
There is a JAA committee working on a "private IR"; they are still debating whether to cut down the ATPL ground school by 10% or 20%... a complete waste of time.
The IMCR would never come into existence today, either. It dates from another age altogether.
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"Students would be recommended to undertake a minimum of 10 hours further instrument training before the test but with an absolute minimum of 5 hours further training"
Would that be a recommended absolute minimum or a mandatory absolute minimum:
Would that be a recommended absolute minimum or a mandatory absolute minimum:
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There is a JAA committee working on a "private IR"; they are still debating whether to cut down the ATPL ground school by 10% or 20%... a complete waste of time.
They should scrap the ATPL exams with respect to obtaining an IR as they are a complete waste of time.
Introduce a single exam specifically testing the pilots knowledge of operating under IR conditions and not how many fire extinguishers you need on a 747!!!
Julian.
They should scrap the ATPL exams with respect to obtaining an IR as they are a complete waste of time.
Introduce a single exam specifically testing the pilots knowledge of operating under IR conditions and not how many fire extinguishers you need on a 747!!!
Julian.