IMC rating in theUK?

[IO540]

Some random comments:

I hoped they would modify the JAR IR, but they did not.
So now I believe the FAA IR is the key solution for JAR pilots, until they do something for us with a JAA IR.
Just listen to frequencies : more and more N-reg.

Very true.

This is the proof that EASA has completely failed.

No, EASA has not even got authorisation to take over JAA FCL (flight crew licensing). They are about to. They will be running FCL later in 2008.

It is JAA who has failed. The airline pilots, their unions, and the ex airline and ex air force people in the regulatory bodies tend to be very elitist and they made sure that within JAA everything got stuffed like a duck - to the tightest common denominator.

EASA's attitude to private IFR is refreshingly different. They want a sub-IR private IMC privilege throughout Europe. Of course it won't be the UK IMC Rating, but something designed in a modular manner should work. But EASA needs to get consensus too - just not the absolute tightest common denominator which made JAA block all progress.

Don't you want a real IR, more accessible, instead of this half-IMC thing ?
That's what you should fight for, with us, not for an IMC rating !

Why? Basic flight in IMC is no rocket science. UK's 35 year "experiment" proves it.

And we should also fight to improve the PPL training, and add more IMC stuff in it, to improve safety.

I would agree, but all those pilots who did a PPL just to fly basic types, or aerobatics, would not. They want the simplest possible VFR-only license. They make up the great majority of PPLs. And they jolly well make sure this "we don't want any instrument stuff" desire is transmitted through votes of their representative bodies at every committee vote.

And I am quite sure many of these "VFR-only" pilots do fly unofficial IFR anyway, all over Europe - just go to any GA aircraft show and look at the IFR equipped planes that are not certified for IFR. The equipment is clearly what the buyers want. If you are happy to fly illegal VFR then you have nothing to lose in the European GA-political scene (except maybe getting yourself killed, but with good equipment that is a lot less likely these days).

France and the rest of Europe likes to turn a blind eye to this kind of flying (of which only a small fraction will be done by Englishmen - the vast majority of GA pilots rarely if ever fly abroad, so most of it is done domestically by pilots with local knowledge) and this is also helping to keep the full IR very hard because everybody pretends that illegal VFR doesn't exist so there is no need to train people to fly in IMC.

The UK IMCR came about because in the 1960s it was legal for PPLs to fly in IMC, and some got killed, so the mandatory training was introduced. The IMCR recognises that some pilots would do this anyway and that it is better to give them a very accessible kind of basic but adequate instrument training.

Incidentally, there is some possibility of the "EASA IR" ground school being substantially reduced in the next year or two.

The IMCr does need revision to take into account the modern world (it was previously based primarily on ADF and VDF procedures) and nowadays it should be reasonably based on a wider 30 hour syllabus.

The IMCR usually takes 25hrs to do. The key issue however is that training should be competence based. The FAA IR "needs" just 15hrs dual training! Yet the checkride is just as hard as the JAA one. There is no way to do the FAA IR in less than about 40-50hrs total instrument time - whether with an instructor or just one's own experience under IFR.

[mm_flynn]

Originally Posted by frog_ATC

mmflynn:
Thanks for answer.
Please note that in France (as in most European countries), VMC conditions in class G are not the same as in UK.

Below 3000 ft AMSL (or 1000 AGL, the highest) : Vis 1500 m or 30sec flight, and out of clouds.
Above 3000 ft (or 1000 AGL, the highest) : Vis 5km (8km above FL100), distance from clouds 1000ft vertically, 1500m horizontally.

The UK rules for VMC are the same as the French ones above, if a pilot does not comply with these rules then he CAN NOT BE VFR!. HOWEVER, the ONLY rule in the UK Instrument Flight Rules that is relevant in Class G, In the UK, above 3000 feet is the REQUIREMENT to fly quadrantals (vs the Recommendation to do in VFR). So to a pilot IFR = VFR there is the subtle change from quadrantal levels being required vs recommend and that is it!!! No requirement for ATC services, radio contact, a change in squawk (The UK has no VFR squawk code).

You are right that the UK airspace, ATC system, approach to Class G and muddling of IFR/VFR/night/IMC/VMC and licence privileges is unique.


Yes, I do know there are some areas where terrain goes above 2000 ft in the UK, but not very many, and I am ignoring those for simplicity.


With regard to your US Class G point, you are correct, it is not technically required to have an IFR flight Plan and be in radio contact enroute in G (and there is little enroute G other than the middle of nowhere! However, I believe there is case law that confirms the FAA view that not availing oneself of these services is Careless and Reckless operation of an aircraft and hence illegal.

[dublinpilot]

Which means Dublin considers an IMC rated pilot as qualified as an IR one.
That's exactly the problem, thanks Dublin to show us that : those IMC rated do think they have the skills, even without the same training...

Frog,

It does not mean that I think an IMC rated pilot is as qualified as an IR rated one. It means that I think an IMC rated pilot is trained and examined, and suitably qualified for the additional privlidges that are granted to them. (Privlidges that are less than those of an IR qualified pilot).

What I am struggling to understand is this.
You say

So now I believe the FAA IR is the key solution for JAR pilots, until they do something for us with a JAA IR.

Just listen to frequencies : more and more N-reg.
This is the proof that EASA has completely failed.

I agree with you on this...the JAA IR is broken.

You haven't said why it's broken, but I think that we would probably be able to agree that it's because the training isn't suited to private IFR flight, and contains too much stuff only needed at commerical level.

So if we can agree that that JAA IR is broken, why can't we agree to introduce something more suited to private IFR flight?

What if we forgot about the IMCr and decided to leave the Instrument Rating alone, and instead brought in a second type of IR, called a "Private-IR"? Would that be more acceptable? This would be much more achievable I think than trying to change the current IR.

Then of course the question arrises what should be in a "Private IR" sylabus? I would suggest that we'd have a more suitable sylabus if we started with the IMCr and tried to agree what was necessary to be added on to the sylabus (or privlidges curtailed), than if we started with the current IR and tried to take out what wasn't necessary

dp

[rustle]

Originally Posted by frog_ATC

Thanks Rustle, I do appreciate, and you're also welcome on my airport with broomstick, to take coffee at the tower if you fly through the channel !

Very kind, thank you

I would be interested in your views about the likelihood of EASA pushing through an EU-wide (or EASA-wide) IMC rating...

I'd also be interested in your views about the likelihood of EASA pushing through an EU-wide (or EASA-wide) reduced-training IR...

I ask because you have already mentioned the "pushback" from French commercial pilots in relation to "private IFR" etc. Do you also know (or have any indication of) what the other continental ATC/Pilot fraternity might be thinking?

Thanks - a refreshing change from the usual suspects

PS and BTW: this subject also gets quite a lot of airtime at another place too

[frog_ATC]

I've been thinking about that quite a long time.

Yes, a "private-IR" would be fine.
But I'm afraid that our dear authorities apply restrictions to those IR : no class A, no major airports, etc.

I do not agree with that.

Private pilots with the required training and recurrent training should be given a full IR with all privileges.

My dream would be that they modify the JAR IR and throw away that extra useless stuff, not only for private, but also for commercial pilots.
This extra stuff can be done in the ATP or CPL cursus !
When you add it to the IR, that means you imply that IR is ONLY for CPL-ATP.

But my dream will probably never be true in Europe :-)


ATC_croa-croa


Note 1 : The FAA IR requires 40 hours IMC, with 15 dual minimum. The checkride is as difficult as the JAA one, and maybe even harder because you have to perform a non-gyro non-precision approach which you do not have on the JAA one.

Note 2 : This note is a quizz. In your opinion, which is the harder : flying IFR as a private, or as a commercial ? Answer coming next !

[frog_ATC]

Dear Rustle,

About an EASA IMC rating, I do not love that idea.

About an EASA reduced-training IR... why not, but only the ground school should be reduced (most of it is useless), not the flight school.

The only limitation I would accept would be : no flights for hire.
But there should be all privileges included (major airports, class A, airways, etc).

ATC_frog

PS : coffee is soon ready !

[dublinpilot]

About an EASA IMC rating, I do not love that idea.

About an EASA reduced-training IR... why not, but only the ground school should be reduced (most of it is useless), not the flight school.

Frog....this is where I can't follow you. You are ok with an reduced training IR, but not with an EASA IMC rating (which may involve additional over and above what the UK IMC does). ....what's the difference? Nothing more than a name as far as I can see.

You also say that you'd be happy for the ground studies to be reduced, but not the flight training. But the reality is that we all learn at different rates. The test shouldn't be how many hours you've done, but instead should be about what standard of flying that you have reached. The test should be able to distinguish those who have reached the required standard from those that haven't, irrespective of the number of hours. Pilot A, might be very quick and be able to reach the standard after 25 hours, and pilot B might never be able to reach the required standard.

dp

ps. no test....IMC test nor IR test, will be able to stop pilots flying outside their privlidges after getting their rating.

[Islander2]

I ask because you have already mentioned the "pushback" from French commercial pilots in relation to "private IFR" etc. Do you also know (or have any indication of) what the other continental ATC/Pilot fraternity might be thinking?

rustle, Frog_ATC seems to have missed your cue on that one. You may need to give him a prompt!

[frog_ATC]

Dublin, you're unbelievable :-)

As far as I know, the IMC rating is not a full instrument rating, am I wrong ?
The flight training is not the same, it is reduced, am I wrong ?
If it was, that would be named "instrument rating", and you would have no restrictions when flying IFR with it, am I wrong ?

So could you explain to me why you do not see any difference between an IR and an IMC rating ?

Or are you just pulling my leg ?

To finish with that, then I'll let everybody try to answer my quizz above, flying IFR is not a complicated thing, I do think it is quite simple : it requires only enough practice by a calm and attentive pilot with a good IR instructor.
How to fly IFR correctly ? Just apply what you learnt, be calm, use checklists, do not do more than what you learnt, think before you act, make you decision with calm, listen to the ATC, do not do silly things. Not a big deal in fact.

But it has to be learnt, and requires a flight training that should not be reduced.
But the knowledge test should be modified to make it more accessible.

Let's quizz!


Frog


Added PS for Islander : about "what the other think"... hard to say :-)
ATCs do not like small airplanes in most countries, especially in major airports. They hate VFRs in IMC (so do I, as you know, especially if they lie :-) ). Most of them do not know what is your IMC rating, except those who love piloting, but there are not so many.
Pilots... some dream about your IMC rating, but they can hardly say what it is. In fact most French pilots don't know it, or just know the name "IMC rating" without understanding it.
Even me, despite I tried to get informed because I had some IMC-rated students for an IR, I do not know the exact regulation linked to it, except that it is limited to UK.
Most French pilots do not fly IFR at all, and have a great veneration for those who are rated. Which is stupid, because flying IFR is not such a complicated thing, once you have learned, it just requires method and structured actions.

[dublinpilot]

As far as I know, the IMC rating is not a full instrument rating, am I wrong ?
The flight training is not the same, it is reduced, am I wrong ?
If it was, that would be named "instrument rating", and you would have no restrictions when flying IFR with it, am I wrong ?

The point I was trying to make is that neither the content of a EASA IMCr (which you dont' find acceptable) nor the content of a private-IR (which you do find acceptable) is defined. They could very well be the EXACT same content! Same training, same instructors, same theory, same flight test! There doesn't seem to be any possibility of getting an EASA Private IR, so why not work towards an EASA IMCr which has the content that you'd like to see in a private IR? It would be just an private-IR with a differnt name!

Is that wrong Don't get too hung on on the name of the qualification

dp

[frog_ATC]

For me, the flight training of the private-IR should be exactly the same as the one of the IR.
Only the ground school part should be reduced.
(by the way, does someone could send me the syllabus of the IMC rating?)

And I would like it to be called "IR" also, just because I do not want our dear authorities to try to add restrictions on its use !

Private pilot are just as able as those commercial, they just do not want to learn things during the ground school they do not need, and lose time and money because of that written.

So why don't you answer my quizz ? ;-)

Frog

QUIZZ :

In your opinion, which is the harder :
flying IFR as a private, or as a commercial ?
Answer coming next !

[dublinpilot]

Well I'm not really qualified to answer your question....I've no IR, and as I'm Irish qualified, the IMCr is not an option to me

But I'm sure that the answer is, that in the same aircraft, with the same instrumentation, on the same route, in the same weather, the licence that you hold (PPL/CPL/IR/IMC) makes no difference to how easy it is.

If you mean PPL/IR in C172 with minimium IFR fit vs ATPL in EFIS B777 with another pilot sitting beside you, then I imagine that the ATPL has an easier time.

Now, to continue the debate

As I understand you, you would be willing to accept an EASA IMCr which had similar flight training requirements to a JAA IR, but with significantly reduced ground school (it's already sounding like your FAA IR)

Now one significant requirement of a JAA IR is 50 hours training (SEP). Lets take that one for a minute. The FAA one has a lower number of hours....IO540 says it's only 15 hours dual training.

How about saying, to get an EASA IMCr (which is an EASA Private IR in all but name....we could even agree to call it an EASA Private IR if it would make you more agreeable ) you don't need any dual training....you just need to be able to fly to the standard required for the test. The examiner can, and should, throw everything and anything at you during the test to make sure that your flying is up to the benchmark.

Doesn't that make sense....after all, why should holder of a foreign IR who has thousands of hours flying IFR in IMC who could pass the flight test without any further training, have do do 50 hours training before taking the test? The test should be the standard, not the number of hours training.

Can we agree that much?

dp

[Fuji Abound]

Well Frog for what it is worth you are wrong.

The IMC rating is a FULL instrument rating.

It qualifies the pilot to fly on instruments.

Of course, instrument conditions here are rather the same as instrument conditions any where else, unless the laws of physics are different in Europe.

Put simply you are either qualified to fly when you cant see out of the window or you are not.

You may care to look up the two things it does not enable a pilot to do in the UK so far as instrument flying is concerned. Unfortunately there are some maverick instrument pilots here who do one of those two things in single engine aircraft - which says rather less for their professionalism.

IR and IMCr are names, terms we use to define a rating.

There is no such thing as a FULL instrument rating.

If you wish, the IMCr is not an ICAO instrument rating, but then neither is the FAA or JAR IR, both of which include differences. So the IMCr is not an ICAO rating, the JAR and FAA IRs are ICAO instrument ratings but with differences filed.

In the UK more private pilots hold an IMCr than there are private IR holders in the whole of Europe.

There has been one accident involving a pilot with an IMC rating in the last thirty years.

There have been far more accidents involving pilots with instrument ratings.

In fact, all other factors aside, instrument rated pilots in Europe are far more likely to kill themselves than IMC rated pilots.

If you were a responsible controller you would file on the pilots you have referred to in your posts that abuse the law. I am not aware of these reports on which the CAA would have been obliged to act. You do no one any favours by your failure to do so in the circumstances you describe.

You would benefit from grasping how the rating is used in the UK by the vast majority of instrument pilots. You would find it informative to look at the statistics because historical evidence is the best way of judging whether the system is safe.

The ultimate safety solution is to react to evidence that suggests something is unsafe, be it because the same accident keeps occurring or the same group of pilots keep killing themselves.

There is evidence that pilots in France kill themselves because they do not have an IMC rating. You ignore this evidence at your peril and their peril.

More importantly, your testimony is based on anecdotal evidence regarding pilots that are acting illegally - if that was the basis for any study then clearly we should ban alcohol because some drivers drink and drive whilst ignoring the vast majority that do not.

I am sorry Frog but I don’t find merit in your posts and I don’t believe that if you were an ATC you would post in the way that you have. I am in correspondence with a French ATC and you and his views are so far apart that I find it very difficult to believe you are who you purport to be.

[frog_ATC]

Ok ok ok, Fuji, I think you should have a break, take a glass of water, maybe eat something or just listen to music and relax !


(and if someone could send me the IMC rating syllabus, that would be nice !)

[Contacttower]

Well she likes the Twin Comanche, so she must be pretty cool whatever her views on the IMC rating.

[frog_ATC]

Thanks

(I also looooove pipercubs & supercubs...! )

[Fuji Abound]

I am, the garlic is frying, the fat is hot, and I am looking forward to enjoying one of my favorite delicacies.

Mind you I have really enjoyed your posts.

They are really entertaining and have added to that which is PPRuNe.

You have however missed a very good opportunity to move the debate forward in a sensible but humerous way and that is a shame.

It would have been better if people took your posts seriously as well as being entertaining.

[frog_ATC]

Fuji, I think they did, according to those very interesting private emails I received ! So this was maybe not only entertainment, let's hope !

By the way, could you please send me the IMC rating syllabus, so that I can tell you whether it can be compared to an IR cursus or not ?

Because those IMC-rated guys I flew with had a very poor IMC flying !

(no one else to answer my quizz?)

Frog, not ashamed...

PS : Fuji, you are probably more "openminded" than expected if you eat frogs :-) Let's try snails now !
If you come to my tower, I will propose you a glass of fine sparkling water, or red wine if you do not fly after, because I think you are too nervous for a cup of coffee !

[Contacttower]

Re the IMC rating syllabus, it can be found in LASORS (the UK version of FAR/AIM) Section E:

http://www.caa.co.uk/docs/175/SECTION%20E.pdf

The description of the rating starts on page 12 and appendices A and B which describe the ground training requirements and flight test standards start on pages 20 and 22 respectively.



I would guess private IFR is harder (than the airlines at least). Single pilot IFR in light twins is about as hardcore as it gets I'd have thought.

The issue with IMC rating holders having poor skills is probably about currency more than anything else...with most airfields lacking an IAP people only go flying when the weather is good anyway and have little opportunity to practice approaches (or don't have access to FM immune equipped aircraft).

[frog_ATC]

Thanks ContactTower that's exactly what I was looking for !

The IMC Rating syllabus and flight test syllabus are excellent.
It covers a good part of the IR program, and the tolerances for the test are the same (100 feet, 0/+50 feet, 10 degrees, etc).


Why not improve it and make it a real IR, with full privileges ?

I think it is the only way to have it accepted by Europe, because the IMC rating is not compatible with airspaces abroad (other countries do not have your different levels of services in the same areas, such as "request radar information service" blablabla... That would be complicated to explain, but incorporating your IMC ratings airplanes in a controlled airspace abroad would require heavy changes in the regulation, and I think you will never get that, whereas incorporating an IFR airplane is easy to handle).


Only the 25 months validity is really too long, with no mandatory practice in between.
That's maybe the reason why those IMC-rated lose skills.
The US system is better for that : 6 months validity, and renewed automatically as long as you keep on flying regularly.

Another problem you have in UK is your horrible IFR fees and these slots you need to negociate. It's so hard to train in UK !
And practice is really important to maintain your skills.

By the way, they say :

Details of rating privileges can be found in Schedule 8
of the Air Navigation Order (please also refer to Section
A, Appendix F)

Do you have this also ?


I think your IMC rating is a good step to try to get a real european IR, with no restriction of use.

Answer to the quizz pretty soon... :-)

Frog