IMCR - The Petition - Please give your support

[julian_storey]

For example if it is taken in a single...it shouldn't be valid in a multi.

That actually is a very valid point.

An asymetric go around in a light twin with a critical engine is substantially more demanding than anything you might have encountered if you'd done your IMC training and test in a Cessna 152!

[BEagle]

'My' proposal is modified from a concept initiated by others. However, I have made certain significant chnages, including a subtle amendment to the Skill Test.

You will also note that 4 hours could be completed in a FNPT 2 or in a FFS.

I would particularly welcome opinion from Irish and mainland European pilots.

[dublinpilot]

I would particularly welcome opinion from Irish and mainland European pilots.

BEagle,

As an Irish pilot, all I can say is that it would be most welcome! I asked the IAA about bringing in an IMC type rating here about two years ago, and was told they were not interested.

I would certainly love it if your proposal was extended across EASA land. Irish weather is probably even less suitable to VFR than much of the UK, as we get hit with the fronts from across the Atlantic before you guys. We take the bashing, and pass on what's left of the front to you guys

The biggest problem I would see with it being introduced here (apart from the IAA) is the lack of organisations with suitably equipped aircraft and instructors. There is very little instrument training going on here...only IR for those thinking of going commerical.

dp

[FREDAcheck]

BEagle's list seems about right, if more than I need. To keep the cost down, I'd add:

• Class 2 medical only (no audiogram)
• Written test at local flying school supervised by instructor (like IMCR test)
• Substantial credit for existing IMCR holders, eg written/skills tests only plus training required by examiner

[BEagle]

My proposal for existing IMCR holders is that they should 'upgrade' at the next renewal point by including two approaches, of which at least one shall be pilot-interpreted and of which at least one shall be concluded by a missed approach and go-around.

I was 'brought up' on PAR and SRA approaches (and DF!), hence found all this procedural stuff rather novel. But the playstation generation seem happier with following a laid down procedure rather than coping with random ATC instructions and maintaining situational awareness when not flying the 'approach plate' procedure. Hence nowadays on IMC revalidation tests I get people to do a radar-vectored ILS, rather than a published NDB/ILS.

Fair point about the medical!

Re. the written exam, my opinion is that this should be conducted exactly as the currrent UK IMCR exam is. There may be cause to review the syllabus, mainly to ensure that privilegesof use and subdivision of EU airspace is properly addressed.

[Irv]

Re: the Beagle proposal:
Personally I could live with with it all being limited to Class F/G plus controlled airspace allowed but limited to Class D/E CTA/CTRs for arrival or departure.
Whether others could is another matter. All I really want to do myself is nip up through a cloud layer to do lessons in the clear air 'on top' in our Class G, and nip down again, and very occasionally if necessary, use the approaches at nearby class D under tight radar / procedural sequencing there. (At the moment, the IMC-R only gives extra IFR privileges in Class D/E, not 'all except "A"')
I think some countries who use Class E en-mass where we use Class G will never be happy with PPLs mixing it with commercials in IMC en-route without a real I/R. However, limit it as I described, and would they have an argument, as it would only 'work' where there are masses of class G (eg: UK), but not 'in their country'?
Its bad enough finding the weather to do lessons anyway, but to cut off the option to do the upper air work stuff in the clear air 'on top' of a layer is wrong

[BEagle]

Well, I wrote 'permitted' airspace.

Limiting Class D/E for arrivals/departures only would rule out simple procedures such as IMC crossings of the Brize and Lyneham CTRs. That would be a reduction of current privileges - something I would not support.

I would also propose that any flight in IMC must be in receipt of either a radar service ('traffic' or 'deconfliction' as they may become), or under procedural control. 'Big sky separation' has had its day! I can quite understand the anxiety of commercial airliner drivers flying in IMC in Class G under a RAS ('deconfliction') at the thought of uncontrolled IMC pilots wandering around nearby.

[bookworm]

I would also propose that any flight in IMC must be in receipt of either a radar service ('traffic' or 'deconfliction' as they may become), or under procedural control. 'Big sky separation' has had its day! I can quite understand the anxiety of commercial airliner drivers flying in IMC in Class G under a RAS ('deconfliction') at the thought of uncontrolled IMC pilots wandering around nearby.

Then you've made the airspace class E, in which all IFR flights must be in receipt of an air traffic control service. There's no justification for this -- the "commercial airline drivers" are not bothered as to whether the uncontrolled pilots are wandering around in IMC or VMC. The anxiety is that they won't be seen in time to avoid -- by the time they're close enough to sight in VMC they'll be setting of TCAS RAs anyway.

There's also insufficient ATC resource to provide this service with enough certainty to make IFR flight practical. What do I do when I've taken off on an IFR flight, called the local LARS unit and been told "FIS only due controller workload"?

I like the syllabus, BTW. The problem is with the privileges. They're not appropriate to airspace in mainland Europe where class A is rarely used. Your EuroIMC-rated pilots will be flying ILSs into Frankfurt Main, Brussels and Madrid.

[Contacttower]

Then you've made the airspace class E, in which all IFR flights must be in receipt of an air traffic control service.

If one suggests on PPRuNe that it is safe to go IMC in the open FIR without a radar service then you will be shouted down by all. Most people ask for a radar service while in IMC...what is wrong with formalising that?

[Irv]

I never seem to have a problem getting a radar service just to nip up or down through a layer because I say I only need it for that short duration. It's getting a word in sometimes being the problem, rather than getting what I want!

[dublinpilot]

Personally I could live with with it all being limited to Class F/G plus controlled airspace allowed but limited to Class D/E CTA/CTRs for arrival or departure.

I read recently on the EADS website that EASA still wanted to rationalise the number of airspace classifications used. I wouldn't be surprised to see class D being phased out in a few years, and for us to be left with something like Class C (which EASA is already looking for above FL195), Class E and Class G.

The privlidges must take account of this in one form or another if it's to be accepted.

dp

[dublinpilot]

Actually it was the Eurocontrol website.

The second strategic step is to harmonise and simplify the airspace classifications FL 195 and below. This resulted in an agreement that the airspace classifications to be applied should be ICAO classes C, D, E and G, with a caveat that where justified, for higher density, higher complexity TMA and other CTA, a higher classification may be used. The implementation date for this stage was 13 April 2006. As of 30 April 2007, 33 states are in compliance.

The third strategic step, to reduce the number of airspace categories to only three is currently under development.

With C being Eurocontrols favourite above FL195, and one having to go to make 3, it's seems quite likely that D will be the one to go.

dp

[bookworm]

If one suggests on PPRuNe that it is safe to go IMC in the open FIR without a radar service then you will be shouted down by all.

By all? No I don't think so. Not by those who have looked at the real risks involved.

Most people ask for a radar service while in IMC...what is wrong with formalising that?

I could equally say "Most people who fly in IMC have an instrument rating. What is wrong with formalising that?"

Risk management may dictate that a short period of flying in IMC without a radar service avoids scud running below a cloud deck in an area of much higher traffic density. Class F/G airspace allows that, as it should. Just because something is good practice much of the time doesn't justify making it mandatory.

[rustle]

Originally Posted by dublinpilot

With C being Eurocontrols favourite above FL195, and one having to go to make 3, it's seems quite likely that D will be the one to go.

dp

Don't confuse N/K/U (the three they want) with existing classes A-G.

Different kettle of fish all together AFAICT with no real direct comparison except perhaps G and U (and maybe A and N at a stretch)

[dublinpilot]

Rustle,

Recent reports seem to suggest that they have given up on the the idea of N/K/U and reverted back to ICAO classifications.

dp

[rustle]

I thought that was only recent reports here in this forum, rather than news from Brussels...

Maybe DFC is right

[Fuji Abound]

I think 20 hours is spot on.

For example if it is taken in a single...it shouldn't be valid in a multi.

I agree.

If it were taken on a multi should it be valid in a single?

What is the view on whether an Europe wide IMCr might be accepted?

I have heard widely conflicting opinions.

I have also been told today from a well placed source that "retiring" the IMCr is now recognised as becoming a hot potatoe as is for that matter revoking the CAA life time licenses. Interesting developments. A solution is being sought other tan simply "abolishing" both.

[BEagle]

Given that FCL001 are currently meeting in Cologne and that this issue has now attracted the political interest of the EU Commissioner, that is hardly surprising...

My firm recommendation would be to maintain all National privileges 'until an equivalent European qualification is available'.

[llanfairpg]

BEagle, I take a different view to llanfairpg - 20 hours certainly isn't too much. If candidates can't afford to obtain a usable skillset at a suitable standard, then then that's unfortunate. 20 hours is generally achievable, that's the main thing.

Usable skillset !!! But where are these IMC rated pilots going to fly these approaches legally.

[Fuji Abound]

But where are these IMC rated pilots going to fly these approaches legally.

Please would you expand a little.