Where are we really going with the IMC rating?

[FullyFlapped]

Quote:
I don't think it has anything to do with height.....

It does if by descending along the approach you are getting closer to the LOC and GS antenna's

Regards,

DFC

So on that basis, the needles more sensitive at 900' than at 1000', more at 800' than at 900' etc (all properly on slope) ... so how does this help your "stop at 500'" argument ? Why not stop at 600' ? Or 400' ?

[DFC]

Because on the IMC flight test the pilot is expected to be capable of flying an ILS down to a DH of 500ft (unless the published minima are higher).

If an examiner permits use of the ILS below this height then they leave themselves open to appeal doe to how the test was conducted.

It could well be that when presented for the test they have never flown an ILS below that height.

In fact one has to remember that the IMC rating training and testing is very limited. There is no requirement to train in all the approach aids available - only two approach aids are required and only one needs to be pilot interpreted. The ability to perform a hold is not part of the test.

Only 10 of the 15 hours needs to be by sole reference to instruments. Of that 10, some can be in a ground trainer.

It could be argued that as soon as the IMC rating test is passed the pilot is firmly in the non-current and should avoid flight in IMC category.

The IMC rating has so many holes in it that making swiss cheese is impossible.

A new way is required. A rating with appropriate clearly understood limits, better sylabus and better training and testing.

Some are going to argue that it already exists in the IR but are you going to leave it at that?

Regards,

DFC

[Julian]

I agree with Beagle here, the wording of the relevant clause is ambigous and could , I think, be argued pretty well by a clever lawyer.

3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.

The way it reads to me is that it recommends that you add 200', this is only a recommendation and therefore you do not have to adhere to it. However the 'but' followed by 'absolute minima' suggests to me that 500'/600' must be adhered to.

Any legal eagles on here can clarify?

the ILS is more sensitive below 500ft and thus requires a bit more ability to fly accurately.

When you are this far down the ILS its that sensitive I doubt you would really notice the difference. If you are current and flying the ILS with small inputs you should be holding the needles without too much variance anyway, if they swinging wildly - suggest you get an instructor.

[rustle]

Originally Posted by Julian

When you are this far down the ILS its that sensitive I doubt you would really notice the difference. If you are current and flying the ILS with small inputs you should be holding the needles without too much variance anyway, if they swinging wildly - suggest you get an instructor.

I don't believe DFC was suggesting they would be "swinging wildly", however basic trigonometry tells us that due to funnelling, being several feet out (in GS) at 500' DH (say range approx. 1.75 nm) is not going to be half-scale deflection, whereas it could easily be > 1/2 scale deflection (and therefore a fail) at 200' DH (say range approx. 3/4 nm).

[bookworm]

The way it reads to me is that it recommends that you add 200', this is only a recommendation and therefore you do not have to adhere to it. However the 'but' followed by 'absolute minima' suggests to me that 500'/600' must be adhered to.

Any legal eagles on here can clarify?

You don't need a "legal eagle", merely a dictionary. Absolute means "not relative" [to the published DH/MDH]. There is no case for treating the word absolute as synonymous with mandatory.

[FullyFlapped]

The way it reads to me is that it recommends that you add 200', this is only a recommendation and therefore you do not have to adhere to it. However the 'but' followed by 'absolute minima' suggests to me that 500'/600' must be adhered to.

I see your point, but I would suggest that the entire construction after "recommended" is governed by that word.

It's an old argument, as we all know, and it really matters not a jot what opinions turn up on this board: a courtroom argument would be interesting, though.

There is also another argument which I suspect might get an airing ...

This phrase has been in existence in this text for a long time, and has been the subject of considerable debate and provable communication with the CAA. If, as has been suggested by that well-known close friend of Irish ATCOs , the CAA meant for it to dictate minimums of 500/600' for IMC holders, why have they simply not revised the text to make this plain ? Is it perhaps that there is no such intention ?

[Julian]

Aha, but looking in a dictionary I get :

Not to be doubted or questioned; positive: absolute proof.

All suggesting it should be adhered to, i.e. mandatory, hence the asking for clarification.

[IO540]

No lawyer would use this terminology. Like most of the recommendations going around, that text was written by some CAA employee who was doing his best at being a bar-room lawyer.

The CAA have never prosecuted any of this and are never likely to. They would lose, because the ANO overrides the AICs.

[Islander2]

They would lose, because the ANO overrides the AICs.

IO540, I agree that the 'IMC DH/MDH minima' paragraph in the AIP (not AIC!) is ambiguous and that there's a very persuasive case for arguing that none of it is mandatory.

But that is not because the ANO overrides the AIP. AD 1.1.2 (which includes the paragraph in dispute) of the AIP provides the notified method of calculating minima as specified by Articles 48 and 49 of the ANO, and as such is mandated by the ANO.