IMC rating in theUK?

[S-Works]

that there is no such thing for a fully qualified UK Flight Instructor to have an IR Instructor rating as a seperate attachment.

Nice wordsmithing but I think you mean that there is no requirement for an FI with the applied Instrument restriction lifted to have an IRI as a separate attachment but that there is in fact an IRI rating.

I am curious about one thing, does training with an Instructor who has the no Instrument restriction lifted but who does not have an IR count towards the 15hrs of applied instrument flight?

[IO540]

The holder of an IMCr will by holding the IMC rating be able to demonstrate that they meet the requirement of 15 hours dual instrument training.

That, Homeguard, is exactly how the FAA requirement for "authorised instructor" is met. If the instructor was not "authorised" for the training, you would not have got the IMC Rating in the first place

IMHO, the FAA "authorised instructor" requirement is intended to prevent instrument instruction by people not authorised to do it... fairly obvious I suppose.

[frog_ATC]

Do whatever you want Homeguard, I'm sure you are instructor-something-somewhat-somewhere so you know things better than me.

But I'll keep doing things by the rules.
And when I'm not sure of the rules, I just write to the authorities to make things clear, and I do not try to invent or interpret them.

That's the way it works for stupid frogs like me !

Discussion over for me, useless I think... I wasted too much time !
Good luck !

Single-neurone frog

[homeguard]

Rules of thumb....it seems

Frog

That is just the problem. Rules, laws whatever are made by those charged to do it. But, when it comes to the crunch where are they. We are left to work it out for ourserves.

I don't know what the french authority is like but try ringing the CAA. At best you will get interpretation from whoever, who adds the caveat "but don't take my word for it" or they simply read out to you the LASORS passage that you have in front of you.

It all really started with the JAA. Each countries authority becoming a processing organisation but with no one body in charge at the centre, will no doubt get worse.

Come back please Elizabeth Cullen-Hayes we need you desperately! We need decisions to be made and a tiny bit of common sense would be very nice.

[englishal]

I am inclined to agree with Mme Frog......At least I'd advise anyone who was thinking of doing an IMC with a view to getting an FAA IR to use an IRI to cover their arse. But still, only 15 hrs is required with an instructor anyway which in terms of money equates to about $500 in the USA........You could do it in the sim in 3 days.......

I don't know which is 100% right, but as the FAA have this "CFII" rating - Intrument Instructor, authorised to teach for an ICAO IR it'd be reasonable to assume that you need to have previous training done my an instructor authorised to teach for an ICAO IR......

Just my view of course, though if you ask the FAA it probably won't make it any clearerer

[421C]

It is simple : the non-FAA training has to be endorsed by an authorized IR instructor to be acceptable.

An IMC instructor is not an authorized IR instructor, as well as the IMC rating privileges do not apply outside UK.

This is obvious, and was confirmed by the IFO New York.

Regards,

Frog

It's not as obvious as that because you have inserted the capitals "IR" in the text above. 14CFR only referes to "instrument training" and "authorised instructors". IMC Rating instructors are authorised to give instrument training. This is obvious, to use your own words, and it is all that 14CFR specifies for the 15 hrs. No-where does is say what you claim, that the 15hrs have to be "endorsed by an authorized IR instructor to be acceptable"

Like many regulators, the FAA is a large organisation managing a complex environment in which individuals have to apply policy judgements. However, only the FAA's General Counsel office is authorised to make legal interpretations. It is perfectly possible to get different interpretations from different people at different times within the FAA on obscure topics. I believe you that someone in the New York IFO told you what you report. You should believe others who tell you that FSDOs and DPEs have systematically accepted IMCr training, fully aware of its nature as a UK-specific sub-ICAO instrument qualification, for many years. Of course, ultimately, anyone depending on this needs to check with the FAA Instructor completing their training check and with the DPE who will perform their IR check ride.

rgds
421C

[englishal]

14CFR only referes to "instrument training" and "authorised instructors".

Probably though because the FAA has no concept of non IR'd or non "IRI" instructors teaching for an instrument "rating" (there is also no concept of an non instrument, instrument type rating under the FAA).

It is a very complicated issue and it is better to be safe than sorry. I "failed" my IR test before we even got in the air because I was missing 3 hours of night flying.

You could claim to an FAA DPE that Compton Abbas to Henstridge was a cross courntry flight and he'd probably believe you....technically under the FARs it is not, and later on I guess it could come back to haunt you (very unlikely of course)......

[IO540]

I am inclined to agree with Mme Frog......At least I'd advise anyone who was thinking of doing an IMC with a view to getting an FAA IR to use an IRI to cover their arse

I would agree, on the precautionary principle. However (and I am making a rod for my own back saying this) there are not many UK instructors on the PPL scene with valid IRs. The ATPL hour builders usually had an IR initially but they cannot afford to renew it so they let it lapse until it starts to look like they might get an airline job offer, then they renew it. But they can teach the IMC Rating in the meantime. This situation is a legacy of the historically hard CAA/JAA IR, which has resulted in very tiny numbers of private pilots doing the European IR, and these few people have always managed to get it done at the commercial/ATPL schools. Almost nobody is doing IR training on the normal PPL scene. Of course most people do the FAA IR now anyway.

I "failed" my IR test before we even got in the air because I was missing 3 hours of night flying.

Well, yes, but you would not have got a standalone FAA PPL either, if you didn't have the night stuff. The IR doesn't need anything beyond that, IIRC (could be wrong).

I've been around this block far more times than I want to remember. These things highlight the absolute need to get in direct contact with the FAA examiner and get him to confirm that your logbook (send him a copy of it, with explanatory notes on eligible flights for Part 61) is acceptable.

Generally, the FAA instructor signing you off as ready for the checkride will do all these checks, but there are grey areas which the examiner alone must decide on - for example whether the 250nm cross country flights (IR and CPL have these) with 3 different landings all need to be done on the same day. The FARs are silent on this; John Lynch's FAA FAQ said it doesn't need to be on the same day, but the DPEs are split maybe 50/50. And if the examiner says "jump" you say "HOW HIGH SIR"

[421C]

Probably though because the FAA has no concept of non IR'd or non "IRI" instructors teaching for an instrument "rating" (there is also no concept of an non instrument, instrument type rating under the FAA).

I don't think so. The FAA is well aware that all sorts of things go on in the rest of the world, and they make it clear what can be done by an authorised instructor (the very general definition) vs what needs an FAA Instructor. For example (and I don't know anything about military flying) but an ex-military pilot could have instrument training that wasn't by an ICAO IR qualified instructor but counted as instrument training by an authorised instructor. Probably a fairly common case.

You could claim to an FAA DPE that Compton Abbas to Henstridge was a cross courntry flight and he'd probably believe you....technically under the FARs it is not

This analogy is wrong, because you'd be making a claim that contradicts the explicit 14CFR definition of cross-country flight as >50nm. The whole point is that "instrument training" by an "authorised instructor" does not specify "ICAO IR qualified", it permits the more general case of instrument training (eg. my military example). A better analogy is whether the 40hrs of total instrument flight time is met by an IMC-r holder who has done solo hours in IMC after the training. Of course does - it is "instrument flight time" as per the 14CFR definition, because they don't define it as "exercised by the holder of a valid ICAO IR". And, again, it's not a UK IMCr loophole - the same can apply to military flight time, or a holder of Australia's PIFR qualification etc.

better to be safe than sorry

You're right of course. I agree with IO540 that the best way to be safe is to check with the DPE. I'm not debating what's a good idea or what is good practice - just the question of whether IMC-r training meets the definition of what's needed for the FAA 15hr instrument training minimum.

[homeguard]

IRritating

It is established that the actual Instructing qualifications for the teaching of applied instruments are the same for the IR or IMCr instructor and they need only to have completed the same course. This fact is specifically stated within LASORS (see earlier quote from LASORS). Additionally, a long standing principle is that you do not teach on a course for anything for which you do not have the qualification. Holding an IR to be able to teach on an IR course satisfies that principle.

Some argue that the training given by an IMCr Instructor is sub ICAO and shouldn't count toward an an ICAO recognised IR. I should remind everyone that until the establishment of JAA the UK gave credit for 10 hours IMCr training toward the fully recognised ICAO UK IR.

What is it that some think is actually different between the two instructors, when teaching the IMCr as far as it goes, and therefore believe the training should not be credited toward an ICAO IR?

[Cusco]

I've enjoyed your postings, Frog:

What a pity you didn't take the trouble to look at the IMC rating syllabus until now:

It might have added more gravitas to your railing about what IMHO is an excellent rating.

When I did my IMC rating a few years ago now, in a residential course, I was told that the previous week three French pilots had come over to do the training: Even in the full knowledge that they were unable actually to be granted the rating, they felt they would benefit.

RIP Jim Hilton............

Cusco (CAA/PPL(A) IMC FAAPPL FAA/IR )

[rustle]

frog_ATC, I have cross posted one of your posts onto the FLYER website I hope that is okay (your post about French training etc.)

[Check Airman]

Wow! I had no idea my question would spark 11 pages worth of discussion. Now all I have to do is sit and read them all. Thanks guys!