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Old 17th Oct 2008, 07:50
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I agree, if you must, declare an emergency, but you would need to have a good reason for not going to an alternate (such as the weather conditions were no better).

The case you mention is interesting. I would have guessed with a good barrister the prosecution would not have been successful.

However, the law makes it illegal to even start the approach if the RVR is inadequate. Clearly this pilot not only started, but concluded, the approach knowing that. Perhaps if he had asked, and AT had confirmed that the RVR was well above minima in the first half of the runway, and he had declared he would commence his approach on this basis with the intention of landing only if he could stop within the first half, he would have escaped prosecution.

I have been in almost that exact situation. The airport (or should I say grass strip I was going to) was exactly on the edge of the Ha when I arrived. One side of the line of sea fog it was CAVOK, 3,000m the other side it was probably 00. As it turned out I was lucky. I hung around for about 20 minutes as I had plenty of fuel and landed when the strip was clear. As I landed the Ha was settled on the forest line at the far end which could barely be seen. Of course an hour later it had all burnt off. The go around, had it been required, would have been on instruments. I have to admit an engine failure on the go around would have been interesting but as you can imagine I had very little intention of going around . I also recall another occasion in Alderney arriving back as the bank of fog started to roll in form the sea. The runway was just starting to go into the fog as I started the departure roll (but he RVR was above minima), climbing out through the fog bank on insturments into crystal blue skys and CAVOK both above and below across the channel. I was the last flight out that day, and the next.
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Old 17th Oct 2008, 09:07
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Thank you all for the healthy discussion on this. I'm really trying to concentrate on the law and numbers (after all, flying is a numbers game).

Pace is quite correct, cloudbase is a subjective thing and what the man in the tower sees is not the same as the pilot sees (at 285 feet, even the tower at Heathrow is higher than their Cat 1 minima). I have flown many times in conditions of low cloudbase where the base is not uniform so it could quite easily be possible for the tower to report 200 feet but it being higher over the approach and numbers. Once you are clear of cloud and can continue the approach with continuous reference to the surface, it matters not if the cloud was angled at 4 degrees and was only 100' over the centre of the runway. So, tower reported cloud is not a legally binding reason to throw away an approach.

On the subject of visibility, this is defined as "flight visibility". The ANO says Flight visibility means the visibility forward from the flight deck of an aircraft in flight, however, the ANO does then comment "For the purposes of an aircraft taking off from or approaching to land at an aerodrome within Class B, Class C, or Class D airspace, the visibility, if any, communicated to the commander of the aircraft by the appropriate air traffic control unit shall be taken to be the flight visibility for the time being."

Some refer to RVR but this is measured by 3 transmissometers alongside the runway (touchdown, midpoint and stop end). RVR's are not reported when the vis is above 1,500m so if the tower are reporting all RVR's below 1500m then the IMCR is subject to an approach ban and can't descend below 1,000' above the airfield/past the FAF etc.

If the reports were, say, >1500/1200/900m (TD/MID/STOP) then the pilot could use his assessment of the visibility at decision height, then continue the approach and land. There is no law against taxiing in low visibility, so the mid point and stop end are not important for a light aeroplane that can be demonstrated to stop in the first third of the runway (pedantic I know). The ANO refers to the RVR being above minima for the relevant RVR. The stop end RVR is not usually relevant for a light aircraft on landing. (Assuming that RVR transmissometers are usually installed at airports with runways >2,000m). You could therefore argue the midpoint isn't overriding either.

IO540 says the AIP is not the law but I would not fancy my chances in court against the CAA if it could be shown I breached something that was even a "recommendation" in the AIP, which are after all guidelines and information published by NATS. You mention the autopilot and there are higher limits for single crew ops unless an autopilot is installed but these won't apply to SEP pilots because of the more restrictive SEP limits (when under public transport). Again, if you fly below PT limits on a private flight, you're opening yourself up to potential problems if something went wrong. Better than the IMCR advice of "add a bit if you're not current", the public transport rules add better clarity to what limits should be used.

I don't have my KAP150 or a/c POH to hand. What is the minimum height for your autopilot engagement on take off/landing? I too have watched one fly down to 200 feet in VMC but found it a bit agricultural in coping with even light crosswinds in the latter stages of the approach (ie <500'). If it was mist/fog I'd trust it with close monitoring, if it was a gusty night in heavy rain, I'd go somewhere else.

I agree that setting personal limits is vital, but it's important that every pilot knows what the absolute legal minima is. With your help, I've found the info, thanks!

Edited to add: IO540 says since almost nothing (short of total fog) stops CAT going to a destination.

In fact forecast arrival fog rarely stops (long haul) Cat 3 equipped (ie most) commercial flights departing, they just carry appropriate fuel. What does stop them departing on more occasions are strong wind forecasts (eg typhoons in Hong Kong). In a short haul environment, fog over Europe can often be widespread and wipe out both departure and destination or cause such long ATC delays whilst LVP's (low vis procedures) are in effect that flights are scrubbed. It's not the low visibility that gets them for they can operate quite happily, but the economics of potentially holding at OCK for 80 minutes on a 30 minute sector.

Last edited by Fright Level; 17th Oct 2008 at 09:26.
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Old 17th Oct 2008, 09:44
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Some refer to RVR but this is measured by 3 transmissometers alongside the runway (touchdown, midpoint and stop end). RVR's are not reported when the vis is above 1,500m so if the tower are reporting all RVR's below 1500m then the IMCR is subject to an approach ban and can't descend below 1,000' above the airfield/past the FAF etc.
FrightLevel

For a prosecution to be successful there has to be an accurate way of determining the visibility. ie with a IMCR you are illegal at 1799 metres but legal at 1800 metres?

An estimated visibility without the pilot admitting the infringement would be like a policeman estimating your speed as 65 mph in a 50 mph zone. Unless you admitted to driving at 65mph the prosecution would be hard pushed to make a successful prosecution against you.

But if you went through a speed trap at 65 mph they have evidence of your speed to take to court.

RVR is simular to the speed trap as the CAA would have evidence to take to court.

Cloudbase is not evidence as even with a solid overcast no one could prove that a hole didnt open giving you the lights and runway numbers.

If an IMCR pilot took an approach and landed and then had his licence checked with a runway RVR of 1000 metres then the prosecution would have a good case against the IMCR pilot.

You are correct on RVR variations on each end of the runway. It is the RVR on the touchdown point which is relevant.

I have made approaches where the RVR was below minima on one end but above on the other end. ATC will normally offer you the above minima end approach even if there is a slight tailwind on that end.

Landing RVR maybe 550 metres but takeoff RVR minima could be 200 metres allowing takeoffs but not landings.

As Fuji stated the pilot who landed on the 100 metres sticking out of the fog could have argued the fact that he landed in VFR and then used the takeoff /taxi minima for the roll out. He could have questioned the RVR equiptment as the readings were obviosly not correct on the touchdown.
I believe he was advised to admit guilt and took the £2000 fine

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Old 17th Oct 2008, 09:49
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Pace, completely agree. There is clearly a murky area (excuse pun) between 1501m when RVR's are no longer reported and 1799m, the IMCR's "below limits".

Now, what about factored visibility ...
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Old 17th Oct 2008, 10:17
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Fright Level

An interesting debate. I dont mean to be cynical but your subsequent posts imply considerably more experience than your first. Just curious as to why you asked the question in the first place?
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Old 17th Oct 2008, 10:27
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As Fuji stated the pilot who landed on the 100 metres sticking out of the fog could have argued the fact that he landed in VFR and then used the takeoff /taxi minima for the roll out. He could have questioned the RVR equiptment as the readings were obviosly not correct on the touchdown.
I believe he was advised to admit guilt and took the £2000 fine
Correction to my statement above he could not have avoided the prosecution because he accepted an approach and Ils when the RVR was quoted at below minima. That acceptance itself was an infringement.

Had he cancelled IFR and requested to proceed VFR to the runway for a look that may have been a way out?

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Old 17th Oct 2008, 10:55
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Fuji

I dont mean to be cynical but your subsequent posts imply considerably more experience than your first

I never mentioned or implied my own experience. I asked if a pilot has an IMC rating?. I have an ATPL with current MPA IR (practised to Cat 3B with no DH) and SPA IR ratings and about 12,000 hours. I'm pretty current and fly both SEP and heavy jets several times a month ;-)

Just curious as to why you asked the question in the first place?

A couple of PPL/IMC holders have asked me to act as safety pilot for them. I know my limits, I just wanted to (definitively) know theirs.


So to confirm the answers to my own questions:

Does one of you kind instructors have the reference for minima to be used if a pilot has an IMC rating? I've found the 1800m (3,000m in CTZ) in the ANO but I can't find the suggested minima or increment for an ILS and other types of approach.

Visibility - 1800m for take off and landing. (ref ANO CAP393 Ratings)

Cloudbase:

IMCR in practise - recommended to add 200' to published minima with absolute minima of 500' (precision) and 600' (non precision) (ref AIP AD 1.1.2 - para 3.3.2)

IMCR out of practise - advised to add another 100' with further increments depending on familiarity with airport/type. (ref AIP AD 1.1.2 - para 3.3.3)

With an IR, one should add 50' to the minima to allow for altimeter errors unless that error is shown as a figure in the POH. Do you add this to the IMC limits as well?

Yes, suggested by AIP 1.1.2 - para 3.1.1.

Last edited by Fright Level; 17th Oct 2008 at 11:08.
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Old 17th Oct 2008, 11:12
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I never mentioned or implied my own experience.
I didnt mean your flying experience, more that you seem to have more than enough experience of knowing where to look in the legislation. I appreciate that you just missed the appropriate reference.

both SEP and heavy jets several times a month
I take it that was said a bit tongue in cheek.

I know my limits, I just wanted to (definitively) know theirs.
I think we have discussed their legal limits. I wonder how you or they will establish their operational limits?

Although the AIP says these are recommended figures, only a brave pilot would fly to limits below those recommended for his IMC rating.
I am still struggling with your observation. The recommended limits for an IMC holder I think it would have to be said are very conservative. If applied the DH is very similiar on an ILS to an NDB / DME IAP. If your friends are current and have flown a number of approaches with you down to minima, and you are satisfied with their performance, I still find it surprising that you would consider it brave for them to subsequently fly an approach to below the recommended minima for an IMC holder in the ANO. I initially did all my instrument flying on an IMC. I was flying around 200 hours a year and was compfortable using the rating to IR minima from straight out of the course. In hind sight I probably should not have been until I had another six months or so under my belt - because whilst my flying was OK I didnt have the experience to cope with every situation be it weather or aircraft related or the training on which to have fallen back - mind you I still dont have enough experience
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Old 17th Oct 2008, 11:28
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more than enough experience of knowing where to look in the legislation. I appreciate that you just missed the appropriate reference.

Yes, because we're spoiled at work by having the legislation transferred into our operations manuals so we don't need to fly to CAA rules, but company rules as these are generally more restrictive. As vis and cloudbase is split between the ANO and AIP, that's why I was struggling to find the info I needed!

both SEP and heavy jets several times a month. I take it that was said a bit tongue in cheek.

Nope, just checked my logbook, 9 flights in a SEP and 8 sectors in a 747 in the last 30 days.

I wonder how you or they will establish their operational limits?

Great discussion point now we established the bottom lines. In reality other aspects of the weather will deter the typical PPL/IMCR pilot flying rather than vis or cloud being right on limits inc embedded TCU or CB's, icing, engine failure terrain options etc etc. I'm not in a position to establish their limits, only pass on experience.

When I used to fly around with a new PPL/IMCR I don't think I'd ever had the benefit of flying with someone that actually had operational experience in real or limiting IMC conditions which is probably why these people have asked me to sit with them. At least I have my facts re actual limits now, thanks!

brave

You've taken the wrong context for my use of this term. I mean brave as in operating the wrong side of the AIP recommendation and not brave meaning he was inexperienced, sweating and white knuckled being at 500' on an ILS. Personally I think hand flying an ILS to 200' is great practise, it's below 500' where all the work starts (hence the need for IR levels of skill?).
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Old 17th Oct 2008, 11:54
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Great discussion point now we established the bottom lines.
I agree - let the discussion begin!

and on a similiar note:

You've taken the wrong context for my use of this term. I mean brave as in operating the wrong side of the AIP recommendation and not brave meaning he was inexperienced, sweating and white knuckled being at 500' on an ILS. Personally I think hand flying an ILS to 200' is great practise, it's below 500' where all the work starts (hence the need for IR levels of skill?).
I dont think I have (taken the wrong context). I dont see that it is brave operating on the wrong side of the recommendations for the reasons I gave earlier. I did a flight recently with a pilot with an IMC who flew regularly. The sector back was in VMC above a shallow cloudbase - which had hung around in the south east for a couple of weeks. The descent was through a couple of thousand feet of IMC becoming visual on the ILS a little below the IMC recommended limits. The approach was flown perfectly. I didnt think the pilot was brave - he was operating well within his personal limits and and quite entitled to have flown the approach. There was no indication with an IR whether or not something had gone wrong during the approach he would have performed any differently.
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Old 17th Oct 2008, 13:02
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I dont think I have (taken the wrong context). I dont see that it is brave operating on the wrong side of the recommendations for the reasons I gave earlier. I did a flight recently with a pilot with an IMC who flew regularly. The sector back was in VMC above a shallow cloudbase - which had hung around in the south east for a couple of weeks. The descent was through a couple of thousand feet of IMC becoming visual on the ILS a little below the IMC recommended limits. The approach was flown perfectly. I didnt think the pilot was brave - he was operating well within his personal limits and and quite entitled to have flown the approach. There was no indication with an IR whether or not something had gone wrong during the approach he would have performed any differently.
Fuji

You have to consider the advisability of flying the regular club spam can single in serious IMC regardless of the pilots ability.

Too often a 600 foot cloud base becomes 200 feet, 1800 metre vis becomes 800 metre vis at the drop of a hat.

The question should be whether an IMCR pilot in the usual spam can should be flying in that sort of weather. The answer has to be NO!

he is then faced with a missed approach and diversion and all the stress that will add to a minimally trained pilot with a poorly although legally IFR equipt aircraft or busting recommended limits and flying to levels that he is not properly trained to do.

May I also add the IMCR student having also been examined for an IMCR by pilots whos standards and expectations vary are not qualified to examine to IR standards and expectations.

While I appreciate there are pilots who have flown for donkeys years in capable aircraft on an IMCR and who have a lot of experience I think it is dangerous to Promote in general the IMCR as some sort of instrument rating which it is not and was not intended to be.

There is the added danger of perception that lesser experienced pilots will see the IMCR as a fly in most conditions rating and that could put them into a real mess situation. Weather is very fickle and changeable.

The rest of the JAA states do not acknowlege the IMCR and the training is NOT to the standards of an IR or the tolerances required for an IR.

Whether there should be a JAA approved mini IR for PPL holders which is more easely achievable could bring up another thread as I feel that would be a good move forward but the IMCR is not that and was never intended to be an IR in disguise. It was designed to be a get you out of trouble rating for inadvertant entry into IMC conditions.

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Old 17th Oct 2008, 13:38
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I agree, but by the same token an approach TAF'ed as being within an IMC holders recommended limits in just the same way often goes below the recommended limits (but by a couple of hundred feet). The pilot is flying the approach and doesnt become visual at the recommended limit but is capable and competant to continue to a lower personal limit. So what does he do. Break off the approach because the CAA recommend he should do so? He is now faced with the "stress" of another approach, perhaps another missed, and then continuing en route to a diversion where the approach is above recommended limits. You see IMHO that is the problem with recommended limits that are meaningless. Setting a blanket recommendation that is in theory applicable to all approaches in all weathers might even be considered dangerous. Of course our man with his IMC could elect to not even fly in the first place unless the base was TAF'ed to be 300 feet above the recommended limits in case it went lower - where do you stop?

Of course, I never said the training was to the standard of an IR. Whether or not other EASA member states accept the rating is irrelevant. The fact of the matter is they dont accept an FAA IR in a member states aircraft which tells us a great deal about the rationality of some aspects of law making in this business.

I also was not promoting IMC holders as a matter of course flying to minima - in fact quite the opposite - I have repeatedly said they should fly to their own personal limits. So far as I am concerned personal limits include a number of factors not just limited to how low the base is forecast to be, but has a lot to do with en route weather and alternates.

The fact of the matter is there has never been an accident involving an IMC rated pilot flying in IMC conditions. That says a great deal about the rating and the standard of instruction - which should not be under estimated - and it all very well to say that IMC rated pilots do not use the rating in earnest - that is simply not true I can assure you - there are many who do.
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Old 17th Oct 2008, 13:51
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The fact of the matter is there has never been an accident involving an IMC rated pilot flying in IMC conditions. That says a great deal about the rating and the standard of instruction - which should not be under estimated - and it all very well to say that IMC rated pilots do not use the rating in earnest - that is simply not true I can assure you - there are many who do.
Fuji wherever did you get that from? sadly there have been loads of IMCR pilots killed in IMC flying.
One was one of my best friends killed flying IMC 15 years ago. I should know as I went through the accident report in detail and was a pallbearer at his funeral Sadly it was a lack of adequate training and experience which contributed to it.

and it all very well to say that IMC rated pilots do not use the rating in earnest - that is simply not true I can assure you - there are many who do

I also stated above that there are very experienced pilots who have flown with an IMCR for years in capable aircraft so I do appreciate that! but it is their experience and the fact that they have survived to gain that experience which makes them capable not an out of the box IMCR

But I am not sure what you are trying to argue here? Is it that the IMCR is as good as an IR and as such holders of the IMCR should fly to the same limits?
In which case great abolish the IR and have the training to IMCR standards and we can all save a lot of money and time.

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Old 17th Oct 2008, 14:08
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Pace

Fuji wherever did you get that from? sadly there have been loads of IMCR pilots killed in IMC flying.
I am sorry to hear that. It would be interesting to have a reference to the AAIB if you are willing.

As you may or may not know I started the campaign to retain the IMC rating after EASA sought to abolish it. This statement came directly from the CAA and has been quoted publically by then on numerous occasions.
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Old 17th Oct 2008, 14:19
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I am sorry to hear that. It would be interesting to have a reference to the AAIB if you are willing.

As you may or may not know I started the campaign to retain the IMC rating after EASA sought to abolish it. This statement came directly from the CAA and has been quoted publically by then on numerous occasions.
I would like to see that reference as I personally know of several IMCR IMC fatal accidents and there are scores more.
If that was the case and the CAA quoted that there have been NO fatal accidents with IMCR pilots flying IMC then that would be a far better record than IR pilots flying IMC So following that there must be something seriously wrong and dangerous in IR training which is not a factor in IMCR training?

I would fully go with you on an achievable Mini IR across Europe as the present system is full of needless junk for a PPL/IR and does not encourage the working man to achieve a level of IR flying which can only increase safety especially in our poor climate in the uk.
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Old 17th Oct 2008, 16:07
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Pace

UKIMC.ORG News

and follow the news link and the slides.

The statement was made by the Head of Personal Licensing and Safety Regulation albiet the specific reference was to CFIT involving an IMC rated pilot. There are no known cases of loss of control in IMC leading to fatality amoung IMCr pilots within 25 months check - unless you know better than the CAA.

Not withstanding, the safety record is exceptional, given that in the UK the number of pilots with a SEP IMC far exceeds the number of pilots with a SEP IR involved solely in GA.

Moreover, I would be interested if you have any evidence that there are more accidents involving IMC rated pilots flying an approach than instrument rated pilots?

I am not saying you are wrong, and am very sorry to learn of your friend, but I have severe reservations when accusations are put forward that IMC rated pilots are unsafe unless there can be shown to be reliance on specific evidence and a proper analytical comparison between IMC holders and IR holders. You can probably tell I am on one of my hobby horses, the foundations of which are based on a real feeling that the abolition of the IMC rating will result in more, not less, fatalities. To suggest there are "scores more" is either displays an element of hysteria on your part not charactereistic of your usually well informed psots or the CAA have their statistics horribly wrong min which case I owe you an apology. Notwithstanding, I have prepared my own anaylsis of every AAIB report involving a fatal accident where there was a suggestion of IMC being involved and not come to the conclusion you do.
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Old 17th Oct 2008, 17:37
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The advent of the GPS is probably the reason for the significant drop-off over
the past 10 years in IMC ratings issued as a proportion of PPLs – rather worrying as a GPS is
not a lot of help if you fly into cloud inadvertently and become disorientated.
Fuji i found a link but have lost it now which showed statistically that the vast majority of IMCR holders use it as an insurance policy to get out of IMC conditions rather than what you are implying as a sort of IR for serious IFR and IMC flight.

In that situation the IMCR is being used in the manner that it was designed for which was to improve safety by giving PPLs a way out in inadvertant entry to clouds or poor vis.

That is very different to what you are stating that IMCR pilots fly to 200 feet on ILSs and use it as a go anywhere rating in bad weather.

In that light the proportion of PPL IMCR pilots who fly serious IMC on purpose must be tiny and those who do probably have a lot of experience over years.

I also note that the accident stated was in one year only. To support your arguement the VFR french pilot has a far worse accident rate compared to UK pilot who holds an IMCR when flying VFR with inadvertant flight into weather.
But that is what I would expect as any instrument training is going to improve your chances of surviving running into bad weather when flying VFR in VMC.

But that is very different from promoting the rating as a modus operendae for travel in serious IMC conditions as some mini IR. From a basic VFR PPL you can have an IMCR with a bare 15 hrs flight hardly an IR allowing you to fly solid IMC to a 200 foot cloudbase, handle a missed approach and a diversion?

Statistics show what people want to see from them and I am sure they do not support your view of an IMCR but more as pilots using it as an insurance policy.

I would support a PPL IR with the same level of flight training to the JAA IR requirements and tests but with practical ground exams far reduced from what is required now.

May I also add that no new qualification whether it be a PPL , IMCR or Even an IR is a licence/rating to dive in at the deep end but a licence/rating to start learning and that means step by step.It is hard fought experience coupled with the ratings which counts for hard IFR IMC whether the PPL holds a IMCR or IR. IE I would rather travel with an IMCR pilot with 2000 hrs a multi and bags of experience than a PPL IR with 300 hrs total who has just achieved an IR

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Old 17th Oct 2008, 17:46
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I can tell you that statistically so far 80.7% of IMC holders who have responded to the AOPA survey use the rating as a get you home when the weather turns bad and those who use it for IFR touring is less than 4%.

Which to my mind proves that the IMC rating is doing exactly what it was created for and enhancing safety.
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Old 17th Oct 2008, 18:00
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I'd vote for a ICAO PPL/IR limited to say 4/6 seat aircraft.
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Old 17th Oct 2008, 18:01
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Bose

Thanks for that as it reflected the link I found and then lost and reflects what I imagine would be the case that the IMCR enhances safety if used as it was intended and not as a back door IR.

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