Where are we really going with the IMC rating?

[S-Works]

Bose: "Contacting the examiners may be one way but it one hell of an exercise to reconcile the examiners records with the CAA records and one could ask if there is motivation on the part of the CAA to that sort of exercise."

Why would you or the CAA need to do any reconciliation? It would be a very simple matter for either the CAA or AOPA to contact the relatively small number (guess: around 150?) of FEs and get accurate info about IMC tests; a voluntary survey will take longer and is unlikely to produce accurate data.
Presumably all you need to know is the date and CAA reference number for all IMC tests performed over the last 2-3 years.
The only thing an FE survey wouldn't catch are the people using UK CPL privileges, but your proposed survey is unlikely to catch them either.

HFD

A possible solution but still only going to give me renewed numbers which is not much use in isolation.

DFC makes sense over the long term of logging more data during the renewal but that means it will take me at least 2 years to get any data to work with that is representative. Good for the long term as it would allow me to cross check what we gather now.

What I am looking for are those numbers and the actual usage of the IMCR, hours flown etc. We could have a thousand pilots who are renewed but only ever use the rating at renewal. This will skew the results. To build a genuine safety case I want to be able to say for example that there are 2000 IMC holders who are currently renewed, of this number x% use it for xhrs per year flying x number of approaches. The primary uses of the IMCr are x. Tied with the safety record this would provide compelling proof that the rating gives clear benefits to UK flyers. This data could then be compared to data collected as suggested by DFC and give us a quality check.

[hugh flung_dung]

It looks like you need to take a multi-faceted approach:

• Get the CAA to ask FEs to send a form back when doing IMC tests (DFC's suggestion). Recorded details could include CAA ref number and date, plus approaches and IMC hours flown since last test (I think for most people you'll find a very small number of approaches).
• Contact examiners and ask for their historical test data. If you were prepared to wait you could even get this data at the 3-yearly FE renewals.
• Instigate a pilot survey (although I'm dubious that this will yield data that could be regarded as authoritative)

You then need to try and capture all the times when someone had the ability to be VMC on top between holes when otherwise they would have been scud-running, when they were prepared to fly an approach but didn't needed to, and all the UK CPLs.

Personally I would get as much hard data as you can (first 2 bullets) and then use the rest just as unmeasurable safety benefits.
HTH Good luck!

HFD

[DFC]

Don't mention VMC on top.

VMC on top is something that every JAR-PPL holder (except UK) can do. EASA harmonisation will dispense with the UK restriction in this regard and thus VMC on top has nothing to do with instrument flying it is simple VFR flying.

Having an IMC rating means having the legal ability to complete IFR IMC flights and every thing about it must concentrate on the privileges of the rating - IFR IMC flight.

The fact that IMC rating holders like the IR holders prefer to cruise in the sunshine has nothing to do with the rating. Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.

I would caution gathering too many statistics that will be used as a good example of why the IMC rating can not be continued with. Do you really want to prove that the majority of holders do not use the rating or that those that do are not current in the strict meaning of current?

Gathering data can help and at the same time hinder your objectives.

Regards,

DFC

[dublinpilot]

Originally Posted by DFC

Ask Dublin Pilot what happens to AOPA when they get involved in stupid legal battles.

For the sake of clarity, in case anyone takes that as a slur on myself, what DFC is refering to is a case of infighting in AOPA-Ireland which eventually ended up in the courts, and basically brought AOPA-Ireland to an end.

I have never had any involvement nor connection with AOPA-Ireland.

dp

[englishal]

Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.

What are you talking about DFC, are you trying to say that a flight would only count if in actual IMC for the entire duration? Or are you saying that the flight only counts if it has been planned as an IFR flight,even though you could be in the sunshine on top?

The problem is that 99% of airline flights for 99% of the time fall into this later catagory. I have flown IFR on gin clear days, and VFR on 3 mile vis days. I plan all my long distance VFR flight with respect to IFR, so IF I can't continue VFR, I can carry on IFR. I do this in America too, the only difference there is you need to get a clearance to carry on IFR. Anyway the alternate can also be your starting destination can it not?

One flight I did recently started out VFR and I became IFR when the cloudbase got in my opinion dangerously low. So I climbed up to 4500 and continued IFR in IMC to the destination and shot the ILS. Does this count according to your rules or not?

It is getting too complicated. Just see how many IMCr's are within their two year validity date at the time of the survey, that should be enough to provide reasonable stats of how many people "care" about the IMCr.

Perhaps we should poll flying clubs too and find out how the lack of IMCr training may affect them? Surely that is of interest too...

[DFC]

Sorry, let me repeat what I said with emphasis;

Any IFR flight must be operated on the basis that from entering IMC it may not exit IMC until reaching minima at the alternate.

In otherwords do not gow down the road of a VFR over the top rating and confuse what IMC IFR flying involves.

If you depart on an IFR flight and enter IMC at 600ft then you must allow for the posibility that you may not be visual again until at your minima at the alternate.

Remember that one argument for retaining an IMC level rating is the expanse of poor weather that frequents the UK. You can not use the poor weather as a reason for having an IMC rating but then turn round and say that the weather is not so bad really because you can opo up through the cloud to VFR on top and then before landing at an aerodrome with no instrument approach, break cloud at the MEA. You can not claim that flying at the MEA is skud running!

To convince Europe's Authorities and Experts one has to show that the rating is not simply a good idea but that the idea is sound from an operational IFR point of view.....i.e. you depart you enter IMC you remain IMC and find that the destination is below limits, you then perhaps shoot a second approach followerd by a diversion to the alternate where you hold and shoot a third approach (gettting tired by now) to a safe landing.

The CAA are the ones who for years warned that the IMC rating does not equip pilots for sustained enroute IFR flight. They spent years reminding pilots that the purpose of the IMC was a get you out of trouble rating and so on. With the CAA not retracting any of those statements, it is not easy to convince their counterparts in other NAAs that the IMC rating is worth more than an insurnace discount for some training.

You made the point earlier that the IMC rating is lost and that a pan European rating is required. I agree. That rating will have to be better than the current IMC to get past the regulators.

Regards,

DFC

[FullyFlapped]

Simple question, DFC : would you like to see the IMCr continued in its present form ?

It's just that on the one hand you say it's a better idea to forget the IMCr and concentrate on some form of "PPL/IR", and in the next post you're giving advice on what not to use as evidence in order to win the battle to keep the status quo ... ?

So where do you stand ?

[S-Works]

It is not a case of abandoning the IMC it is a case of having a pragmatic approach. The IMCR should be preserved and if it is to be proper safety case must be presented.

At the same time proper access to the IR by PPL's needs to be worked on. I genuinely believe that if the IR is made fully accessible and performance based rather than the current prescriptive hours based training that the uptake of it would be significantly higher and probably negate the need for an IMC.

The argument about having an IMC and not doing the IR revolves around the high cost and poor access, remove these barriers and the IR becomes more attractive.

And with all due respect, don't you think it is a bit childish demanding that people take a 'stand' either way?

[FullyFlapped]

Bose, firstly, note that my question was directed at DFC, not you.

Secondly, it's not childish at all to ask someone to clarify their position.

In an earlier post, DFC states :-

The best way forward is to accept that the IMC rating is gone. Far better to work on a PPL-IR (a qualification suitable for flying IFR anywhere

Then a short while after :-

I would caution gathering too many statistics that will be used as a good example of why the IMC rating can not be continued with.

I am simply trying to reconcile the two statements.

My own position is simple : (1) retain the IMC in its present form in the UK. (2) Immediately begin work on a more accessible PPL/IR acceptable to EASA. (3) When (2) is complete, mandate a reasonable period for IMC holders to upgrade or lose their privileges.

And by the way, you still haven't told us whether DFC is right about the AOPA member's guarantee being unlimited ?

[S-Works]

FF. I was just trying to bring balance. Even though I regularly disagree with DFC his post struck a chord and seems quite a balanced view rather than trying to be polarised.

If you wish to find out details of the AOPA constitution then please contact the AOPA office. Full details are available to all members and prospective members. As I pointed out a few posts ago I will no longer enter into discussion on these matters on this thread.

[Fuji Abound]

DFC

To convince Europe's Authorities and Experts one has to show that the rating is not simply a good idea but that the idea is sound from an operational IFR point of view.....i.e. you depart you enter IMC you remain IMC and find that the destination is below limits, you then perhaps shoot a second approach followerd by a diversion to the alternate where you hold and shoot a third approach (gettting tired by now) to a safe landing.

Good point, but shouldnt some responsibility remain with the pilot?

Do we have to regulate for every scenario?

A PPL grants you rights to fly aircraft you would be very unwise to fly without further instruction.

An IR grants you rights to fly to published minima, but should you do so if you are rusty?

An IMC rating grants you the rights you set out, but at the same time during training significant emphais is placed on the need for currency and development of skills.

I think because these aspects are emphasised the vast majority of IMC rating holders operate to their limitations. That is why the safety record of holders is so good.

On the other hand because some IR holders believe they are qualified to fly hard IFR in very poor weather they will be inclined to do so, when perhaps they should not.

[FullyFlapped]

Bose,

WRT AOPA, apologies, I missed your post on not discussing AOPA regs on these forums, but that's fine, I'll contact them directly.

I think this one needs nailing and putting to bed, so when I get the answer, I'll post a summary so that we all understand the position.

[IO540]

As I have said many times, it is purely elitist to argue against the IMCR on the basis of alleged poor pilot currency.

This is because while safety does derive from currency, it derives even more from automation resulting in a low cockpit workload.

The airline industry learned this decades ago. It is a FACT.

Today, most pilots flying serious IFR (particularly airways) are doing it in planes equipped as well as a BA 747 was 20 years ago, or equipped as well as many cargo 747s landing at Heathrow right now.

Should Europe regulate for minimum aircraft standard? They already regulate heavily for minimum equipment carriage. That, together with BRNAV (an IFR GPS with a current database) being mandatory for all practical Eurocontrol routes, means that there are virtually no "spamcans" flying serious IFR.

There are a lot of IMCR holders who fly these very capable planes and they use the Rating fully. Most of them are probably working towards an IR (usually the FAA one).

The IMCR holders with only spamcan access are intelligent enough to know they can't do a lot with it. Only a total idiot will be flying a spamcan with a radio hanging out of the panel by 1 screw, and with a knackered VOR receiver will dive into a cloud hoping to find a runway at the bottom of it.

That's why the IMCR safety record is so good. No regulation is needed - pilots aren't stupid.

So fly keep flogging this dead horse?

Often, on these forums, allegations are posted which are misleading, so somebody dives in to set things straight. But I don't think there is much point in debating this point anymore, with the same individuals.

[DFC]

Fully Flapped,

The two statements need no reconciliation because they are two separate and unrelated statements.

The first delas with the reality of the situation with regard to the IMC rating in it's current form.

The second is simply pointing out that gatering statistics can sometimes give more ammunition to the opposition.

-----------

My thoughts on the IMC rating is that it only works because the vast majority of holders either do not use the rating at all or simply use it in class G airspace.

As I said previously, the UK CAA are on record as having described the IMC rating as something to be used as a get you out of trouble rating and also stating that the IMC rating did not equip pilots for intentional enroute extended IFR flight.

I believe that the CAA know that the IMC rating is gone. The future UK airspace structure will not support it. They have lots of items that they need GA on side for - Part M (UK style), Mode S, one sky, enroute VFR charges, enroute IFR charges, euro GNSS etc etc and want to be seen as GA's friend as long as possible. They are also on record as saying they object to EASA and the way EASA is going to do things. Of course the comission going down the legislative route has put paid to Roy's ramblings regarding EASA.

Perhaps everyone needs to look at the Microlight world as an example. Totally unregulated for years, brought into regulation and has negotiated and pushed forward both the regulatory boundaries and the popularity / usefullness of the sport to such an extent that they have managed through well planned well thought out and well negotiated actions to go full circle with the introduction of the single seat deregulation.

Had they insisted on retaining the situation as was in the 80's then I can guarantee that it would not be such a healthy sport today.

Any claims regarding the safety benefit can be dismissed because a training course completed yearly (in a sim perhaps) would have a similar safety benefit and if combined with an insurance discount would assist both safety and reduce the cost. That would only leave those who use the IMC rating as a poor man's IR. That is not what Campbell et al invisiged and it was not what the CAA planned for either ( hence the various "get out of trouble rating" and similar statements over the years). However, give a pilot the legal ability to do something and they will do just that.

Here is where many European Authorities ind their first problem. The privileges it gives - IR privileges for enroute an terminal area operations - are above what the designers, the enabliung authority and the sylabus envisaged.

It's the old - you got caught out and we are not sheep.

Best way forward is to imagine that there was no IMC rating.

We know that the CAA would not accept the proposals for the IMC if it were put to them today - try suggesting making it possible to add an IMC rating to the NPPL and wait for the ah but's. If the UK will not add a national rating to it's national licence then what message does that give out.

So starting with a clean sheet a proposal must be out forward for a rating that will permit recreational pilots access to the IFR system.

Remember that such a rating will have to include night flying privileges. After all, no European Aviation authority is going to leave it's IFR system open to the C172 at the top of the stack demanding an immediate approach....not because of some emergency but because nightfall is near and while they are entitled to fly IFR, all flying, holding and diverting they do must cease at nightfall.

Ladies and Gentlem, unfortunately your flight to Paris is being delayed because priority has to be given to some pilots who are operating in the IFR system but can not fly at night!!!

So if the microlight industry can negotiate it's way to deregulated single seat, one now waits to see if the JAR-23 industry has the ability to do something similar in terms of recreational pilots gaining acess to the IFR system.

Regards,

DFC

[Fuji Abound]

DFC

Some useful comment, but I am left wondering why 50 pilots a day are signing a petition to retain the IMC rating.

It is actually quite hard getting people to support a campaign, so the level of support would suggest there are other factors at work.

EASA granting a moratorium on the IMC rating would also suggest that they are at least interested to see how the campaign pans out.

Someone emailed me a while back.

This is the jist of what he said.

I am an ex military pilot. I held a military instrument qualification for many years. I now fly and enjoy aerobatics at competition level.

I want to safely operate above a broken cloud base rather than below, knowing that I can enter cloud on the way down if I need to. I dont need a civil IR.

The IMC rating means I can do this legally and safely.

For me, a regulators responsibility is to enhance my safety and the safety of every other user of the system. The IMC rating means I can do what I do more safely.

[IO540]

Best way forward is to imagine that there was no IMC rating.
We know that the CAA would not accept the proposals for the IMC if it were put to them today

IF IF IF IF .... so many IFs.

IF the ICAO treaty was not there, where would GA be today?

Outside the USA, it would be banned, almost certainly - except for purely low level sporting activites, very tightly controlled. Forget foreign trips.

The whole aviation world which means so much to so many pilots relies on a treaty signed around 1944, when regulation was run by real "can-do" men who had a real vision of the future and were able to properly size up the risks.

[DFC]

I am left wondering why 50 pilots a day are signing a petition to retain the IMC rating

The general Anti-Europe UK position would account for a large proportion

Many others would simply fear the loss of a rating with no replacement.

Only a small percentage would be active current fully competent IMC Rating users.

Your example works against your aims - a professionally trained former instrument rating holder using the IMC to avoid IR currency requirements while flying an aircraft probably not fully IFR equipped and operating in class G IFR probably with no ATS.................all red flags to many Europeans.

Furthermore, their reason for using the IMC seems to suggest that they need an IMC rating to operate simple VFR flights...........in other words having the IMC rating has no impact on their ability to do what they want to do..............thus one could say that not having an IMC rating would have no adverse impact on their flying.

Again I say you must be very carefull about what information you collect but 10 times more carefull about the information you use.

Regards,

DFC

[englishal]

Many others would simply fear the loss of a rating with no replacement.

Only a small percentage would be active current fully competent IMC Rating users.

I don't think you give the PPL enough credit DFC. What catagory are you, are you an MIR'd ATPL, IR'd CPL, an IR'd PPL, an IMCrd' PPL, a FSX Master or x-RAF (not flying) what? Just curious so that I know what catagory of pilot (or not) we need to convince. Or are you like someone else on here who just likes to stir?

As you obviously think the IMCr is a load of crap, prehaps it would be better if you leave us to our discussion.....thanks.

[DFC]

Just curious so that I know what catagory of pilot (or not) we need to convince.

You can convince every pilot in the world. That is not going to make any difference. You have to convince the regulators and the national Governments plus the European comission. Pilots especially just the purely recreational and sport kind i.e. PPL represent very few votes. Think of the airfield closures. How many pilots vote and campaign against those.

I don't feel the need to thump my chest and proclaim my experience to justify the opinions I express.

As you obviously think the IMCr is a load of crap, prehaps it would be better if you leave us to our discussion.....thanks.

The idea is sound but the training, the legislation and the practical application are flawed - The UK CAA said that - ban them from any IMC discussions also. Here is an oportunity to change that and broaden the appeal.

Seems that anyone not in the keep the IMC Rating as it is sheep flock is not wanted because only those that agree are permitted to have a say.

Fine...take your discussions into some secret place and we can sit back and enjoy our flying related debates.

Regards,

DFC

[Fuji Abound]

You can convince every pilot in the world. That is not going to make any difference.

Is the purpose of a regulator to be so removed from those they regulate as to take no account of their wishes?

If the Government says a new drug is to expensive, and yet the doctors tell the government the new drug will save many peoples' life to whom do we listen?

The idea is sound but the training, the legislation and the practical application are flawed - The UK CAA said that

When, where, who?

Your example works against your aims - a professionally trained former instrument rating holder using the IMC to avoid IR currency requirements while flying an aircraft probably not fully IFR equipped and operating in class G IFR probably with no ATS

We should not jump to conclusions. You dont know what avionics the aircraft had. I fly an aircraft that is fully IFR compliant and is also certified +6, -4. The pilot is fully IR current because he holds a valid IMC rating. He can do everything a IR holder can do with only two exceptions. In fact he is almost certainly more current and has a deal more experience than many pilots with an IR.

Furthermore, their reason for using the IMC seems to suggest that they need an IMC rating to operate simple VFR flights

I dont understand your statement?

I also dont understand the use of the world "simple".

The vast majoity of IFR flights I do in IMC are no more, nor any less simple than VFR flights - I try and prepare for each as methodically. I consider "simple" a relative term.

The IMC rating was dead and buried before Christmas.

It is alive and kicking for at least the next four years.

EASA would not grant a moratorium for that length during which NEW IMC ratings will be issued and then abolish the rating, at least not without an equivalent alternative (grand fathered or otherwise).

To do so would be a clear breach of natural justice on their part. If the IMC was going, it would have gone now and would never have been recognised by EASA.

Fortunately there are a lot of very experienced people in EASA who recognise a good thing when they see one and know the precedent they have set by adopting the rating for at least the next four years.

I would encourage anyone of thinking about doing an IMC rating that now is a better time than ever!

Readers should be quite clear that AOPA are clearly on record as fully supporting the expansion of the IMC rating through out Europe for which I congratulate them.

It has been suggested on here (by Bose) that AOPAs stance has very recently changed but I find no evidence that is so and no such admission by AOPA. I don’t believe, in spite of some criticisms expressed by me in the past, such a well respected organisation would change their policy without notification.

This is what their CEO says:

AOPA-U.K. Managing Director Martin Robinson has made this view known to EASA, asking that the rating be retained and expanded throughout the
European community. [my emphasis]

Good news indeed.