IMC rating recommended minima?

[Shunter]

I got my PPL just over 2 years ago, and my IMC rating shortly afterwards. I now have several hundred hours and exercise the privileges of the rating almost every flight. Sometimes it's simply being out of sight of the surface, sometimes to punch through cloud for a relaxed cruise on top, sometimes for the reduced SVFR minima in Class D, but fairly regularly it's to land back at my home base (LBA) when the weather is rather less than perfect. If I'm current (which I do my best to remain), I have no problem with flying to 300ft on the ILS. If not current I tend to impose 500ft on myself.

I've trotted this out a few times, but it's a great example of how an IMC can be used... Collect aircraft from annual at Derby, viz about 2000m cloudbase 800ft, take off and enter cloud before I've even cleaned up. IFR transit through East Mids, breaking into sunshine at about FL050. Fly back to Leeds via GAM (to skirt round the Class A) in the sunshine, then slide down the ILS, breaking cloud at about 400ft or so. No drama whatsoever.

There are 2 key factors to bending an IMC rating to its full extent, one being currency, the other being an autopilot. Instrument flying gets very rusty, very quickly if you don't do it regularly. Even a basic autopilot capable of keeping you straight and level is an enormous workload reducer and is damn near essential for flying in IMC for extended periods.

[Fuji Abound]

Pace

I really wish you wouldnt put words into my mouth.

This discussion was not about using an IMC as a back door IR. More importantly I did not imply it was a back door IR. I said that a pilot who was CURRENT and had the required experience with an IMCr was legally entitled to fly an IAP to below the recommended minima in the ANO - end of, nothing more, nothing less. A debate does not make good progress if we invent what we think the other said. I stand by my comment.

In so far as light aircraft are concerned I am not sure how many people fly and travel in serious IMC conditions as you put it.

Firstly, what do you mean. I dont choose to ever travel in serious IMC. My objective is to climb on top as soon as I can. I might hump through it in an Aztec if I have to (and have done so) but at my level I most certainly dont choose to. I think that is what most people do with an IR.

Secondly, I suspect that 4% of the sample, if that is statistically sound, is more than the number of IR SEP GA pilots. I therefore find that population of pilots has no greater inherent risk of an accident, and perhaps the risk level is less because they are more conservative.

Thirdly, I have absolutely no idea where you got the idea from of IMC rated pilots flying to 200 feet. I have repeatedly said they should fly to their personal minima. That may be more or less that the CAA's recommended minima - strangely that is why, for what it is worth, the CAA use this word.

Fourthly, I would not be happy flying hard IFR in most of the GA fleet - a point on which we do agree. By definition that limits the amount of hard IFR flying pilots undertake whether or not they have an IR.

Finally the CAA were not referring to the accident rate in one year, but since the rating was introduced. Either your earlier allegations about the accident rate is wrong or the CAA are wrong.

I am happy to debate the issues, but please can we avoid read things that were not said, and not being prepared to support our own contentions whilst challenging others in the debate to support theirs.

[IO540]

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.

That's one person's assertion, not backed up by anything. Yawn. You may as well start quoting GASIL or GASCO or some other rag. Anyway, what relevance is there is what somebody intended back in the 1960s? The full IR was a piece of cake back then, too, with various grandfather / self improver routes.

I personally know of several IMCR IMC fatal accidents and there are scores more.

I went to a CAA/EASA presentation Feb 2008 and they reported that they are aware of just one fatality of an IMC Rated pilot while exercising the privileges of the IMC Rating. This is since the introduction of the Rating c. 1969.

[Pace]

I went to a CAA/EASA presentation Feb 2008 and they reported that they are aware of just one fatality of an IMC Rated pilot while exercising the privileges of the IMC Rating. This is since the introduction of the Rating c. 1969.

10540

Can you pick up the details of that one accident since the accident which killed my friend was in this aircraft

8 January 1994. Mooney M20J G-BSKJ. Aircraft flew into the Eye of the Needle on n the summit of the Wrekin Hill.

If the CAA one accident since the IMC rating was introduced was not this one then frankly the CAA are talking a load of rubbish because I know better, FACT!!! If not the CAA are as I stated talking rubbish or cooking the data to make a point.

Pace

NB I had 200 hrs in that plane and know the accident details to the letter and it was an IMCR pilot in IMC

[S-Works]

That's one person's assertion, not backed up by anything. Yawn. You may as well start quoting GASIL or GASCO or some other rag. Anyway, what relevance is there is what somebody intended back in the 1960s?

Actually it was exactly the intention of Ron Campbell and was always clearly stated. His widow is still very actively involved in AOPA and in fact is part of team working on the fight to save the rating her late husband came up with.

[Fuji Abound]

Bose, a good point.

I recall this posting form many years back:

The IMC rating was introduced a few years before I learned to fly in 1970. Before that time, a PPL was entitled to fly IMC outside controlled airspace, despite there being no provision for any sort of instrument flight training in the PPL syllabus at all. Concientious PPL's who wanted to improve their I.F. skills would do some dual with an instructor in simulated IMC (under the hood) and even practice instrument approaches which were VDF letdowns (if anybody remembers them!).
The powers that be decided, shortly before I learned to fly that this was not a good idea! There had probably been some accident statistics where pilots had gone IMC without any form of instrument training and suffered for it, so, at a stroke the IMC priveleges of all PPL's were removed. To get them back, an IMC rating had to be obtained and the training to do this was based on the fact that, apart from a set of "blind flying instruments" the aircraft concerned was equipped with only a VHF radio transceiver.
10 hours flying by sole reference to instruments was required including full and limited panel manoeuvres. A candidate also had to have carried out an appropriate pilot interpreted let down. (usually a VDF one) to the satisfaction of a QFI and I think experience in carring out a surveillance radar approach was required as well. As loads of pilots were expected to acquire an IMC rating to regain their lost IFR priveleges, all QFIs were empowered to carry out the test which included a written part. Here there was no formal exam paper, the candidate had to prove to his instructor that he could prepare an IFR flight outside controlled airspace.
As few aircraft in those days were equipped with anything other than a VHF radio (and maybe one VOR receiver), the training requirements were designed with this in mind. This means that over the years, us pilots who obtained our IMC ratings in those days have subsequently had to learn how to carry out ILS and ADF approaches, holds and all the other contents of the I.R. syllabus!
Oh - one other thing: you couldn't qualify for an IMC rating unless you had a total flying experience in excess of 100 hours.

It demonstrates not only how much flying has "evolved", but also how the IMC rating has "evolved" in that time - the point I think IO is making.

[Pace]

Bose

If you look at the American statistics then VFR into worsening weather figures highly and the numbers are in the hundreds.

I have NOT questioned the validity of the IMCR but am STUNNED that the claims to being only one fatality in ten years. If that is the case then something has to be wrong because the IR fatal accident statistics dont come anywhere near that.

The IMCR is a good safety tool in the fact that it is an insurance policy against a VFR pilot flying into cloud or bad weather.

The french VFR accident statistics where there is no IMCR backs up the benefits of the IMCR as there VFR into weather crashes far exceed ours.

But one crash in ten years either indicates that Pilots with IMCR do only use it as a insurance policy ie hardly at all or those statistics are amazing and maybe we should scrap the IR so we can all benefit from flying with the safety of an IMCR.

The Gist of this thread appeared to me to be promoting the IMCR as means of travel rather than an insurance policy. We had discussions on whether pilots should go down to 200 feet on an ILS OK Yes if pilot X flying VFR inadvertantly charges into weather and there is no where else with higher bases for him to land. That is almost an emergency and what the rating was designed for.

But to promote it as a mini IR is encouraging minimally trained pilots to use it as a daily tool and that is my point.

As a safety tool there is an arguement to incorporate it into the PPL syllabus as that would improve safety for those that dont get the IMCR but the extra cost and time would make that deter would be pilots from getting their licences.

The problem with Europe is how the IMCR is regarded. It falls short of the IR and is not being promoted as a safety insurance tool but as one for pilots to fly IFR and even IFR in controlled airspace.

This is way off its original conception.

If it is being promoted for IFR use then it has to be regarded as an IR ? That then brings up the question of building a new European IR which is reasonably achievable by the working man who cannot spend months or years passing a mass of unneeded exams.

That is how I see the way the Europeans regard it as a mini IR unique to the uk which does not meet the standards they require rather than a safety tool for inadvertant flight into adverse weather.

So we have two options to promote it to the Europeans in its original concept as purely a safety tool which I find it hard to see them arguing against or push for a new IR with restrictions for PPLs.

My inclination would be to scrap the IMCR, build more instrument training into the PPL and go for a European PPL IR with certain restrictions which is easy to achieve and acknowledged Europe wise

Pace

[jxk]

""""My inclination would be to scrap the IMCR, build more instrument training into the PPL and go for a European PPL IR with certain restrictions which is easy to achieve and acknowledged Europe wise."""""

I'm intrigued by the European PPL IR concept, WHY not a Worldwide IR rating - what qualifies Europe as the authority for the rest of the Planet? Wouldn't it be nice for our ratings to be accepted where ever we choose to fly??

Still an ICAO grade 4 English speaker..

[S-Works]

It demonstrates not only how much flying has "evolved", but also how the IMC rating has "evolved" in that time - the point I think IO is making.

It has only evolved in a limited manner officially. That is vastly different from people like IO going out and equipping an aircraft to IR levels and self teaching.

This is the real crux of the issue and why standards are so variable.

There will no doubt be an ardent few who will claim that the IMC is enough to be a mini IR and there will be those that don't agree.

What is clear so far from the survey is that most people who hold an IMC do so in the spirit it was intended as an aid to safety rather than as some sort of IR. This I think gives compelling evidence of how people see and use the rating and should serve to be a real kick up the bum to the Eurocrats trying to get rid off it.

The fact is very simple, the IMC is a great aid to safety and a major improver of pilot performance.

I will leave others to argue about what minima etc. it is intended for.

[Pace]

The fact is very simple, the IMC is a great aid to safety and a major improver of pilot performance.

I will leave others to argue about what minima etc. it is intended for.

Bose

I agree with what you are saying but on a safety ground any published minima is a nonsense as it either promotes the IMCR as a mini IR promoted as such by the CAA or is meaningless in the event of a situation that the rating was intended for. Example

Pilot X Takes off VFR to make a VFR destination airport before a front moves in from the west. He travels south to North with a line of hills to the east.
Enroute he notes scud clouds below the plane and tries to maintain ground contact.Eventually it all closes in on him. The front has moved in ahead and behind him and to the west. He cannot even turn east.

He climbs to the SSA and in solid IMC he calls a radar unit who give him the weather at two airports in his range which is not great and which are equipt with ILS.

Both airports are reporting 300 overcast with RVRs of 800 metres in drizzle
Ok this is a semi emergency situation Looking at the CAA minima does he say " sorry cant take that as I need 1800 metres and 600 feet" ?

As a insurance safety policy it is almost pointless in the CAA stipulating a minima because that encourages another pilot to takeoff in IMC into a cloudbase of 600 feet fly solid IMC to a destination and land off an ils with a cloudbase of 600 feet and 1800 metre vis.

This is my point you either promote it as a get you out of trouble rating or set limits and encourage its use as a mini IR.

For those who defend its use in that way I would say would you take the current measly 15 hr training and structure of the IMCR to Europe to promote as the new PPL IR? You wont get far and justifiably so.

I'm intrigued by the European PPL IR concept, WHY not a Worldwide IR rating - what qualifies Europe as the authority for the rest of the Planet? Wouldn't it be nice for our ratings to be accepted where ever we choose to fly??

jxk

I echo your sentiments as it is an absurdity and more to do with terratorialism and job protection.
Pace

[Fuji Abound]

So we have two options to promote it to the Europeans in its original concept as purely a safety tool which I find it hard to see them arguing against or push for a new IR with restrictions for PPLs.

I dont think so. Europe has no interest in a mini IR. Bose has put a huge amount of effort into reducing the workload involved in the IR for the private pilots and his efforts have come to very little (sadly). It is still the case that almost everyone goes the FAA route.

The IMCr should be promoted as a safety tool. A small percentage will use the rating as they do now for intentional flights into IMC.

EASA are concerned with safety. If they do not recognise ICAO IRs, and if they end up abolishing the IMCr and / or do not introduce an IR within the reach of PP (and by that a dont mean sub standard, but based more closely on the FAA model) IMO they will have failed in their primary responsibility to those they regulate.

The IMCr is safe for four years - and AOPA say they have taken up the campaign to retain the rating - I trust they will keep us properly informed on what they are doing and how pilots need to contribute in a timely fashion so proper and comprehensive representation can be made when and as required. The campaign to preserve the IMC rating attracted as much attention as I have seen in GA in a very long time - huge numbers signed the No 10 petition. I personally know the CAA and EASA took the matter very seriously as a result of the response we achieved and ultimately lead to the meeting in London attended by our own IO540 representing the IMC campaign. A great deal more needs to be done to ensure the rest of Europe understands the value of the rating. I hope AOPA have this well in hand. Sadly there are a few that have other agenda. They would rather see the IMC rating abolished. They will make promises of an IR lite. In fact they really wish to see only pilots with a EASA IR operating in European air space. It is they that are the biggest threat to our safety. We should be on our guard.

[IO540]

My inclination would be to scrap the IMCR, build more instrument training into the PPL and go for a European PPL IR with certain restrictions which is easy to achieve and acknowledged Europe wise

The problem with that kind of superficially attractive sentiment (disagreeing with which is as unreasonable as telling Bob Geldof to stop running pop concerts to stop poverty) is that in practice the Euro IR has got harder and harder at every step. Despite the effort of a fair few people over the years, and despite wild claims all over the pilot forums of a "new and more accessible IR" being "just around the corner", "here by next summer", "here by next year", "with the CAA for the final rubber stamp", etc etc etc etc etc. Somebody with the will to search some pilot forums would have a field day digging out all the wild promises.

The political reality is that the IR is a qualification which carries a massive emotional weight and has the backing of the most powerful bodies in aviation regulation (airline pilot unions) which makes it really hard to make it "easier".

This is a consequence of Europe's "one and only IR for everybody" policy which has been in existence for as long as anybody I know can remember. This ties the IR with the concept of "professional pilot status" and that prevents any progress on a more appropriate private IR.

The USA has the FAA IR which, at its basic level, is directly applicable to private pilots. It doesn't teach you any jet type rating crap. You can use it with a PPL, to fly IFR around the place, and it is more than adequate (I know, I've got one and done enough European airways flying).

Then, if you want to fly a jet, you get a jet type rating and in that TR you learn the stuff you need to know to fly the jet. In practice, an FAA jet TR is comparable to an ATPL. This is how it should be.

But Europe never split things up in that way - for various vested-interest reasons.

There is a slightly reduced (about 25%) IR ground syllabus which is scheduled to arrive (according to some CAA release I read recently) in late 2009. That is ALL that is coming. There is nothing else.

Well, not until EASA do something, and the time scales for that are looking like 2012 and beyond. There is NO "private IR" proposal in the making right now. There was going to be an IFR add-on on the EASA LPL but this got clobbered by the LPL/LAPL committee which was loaded with VFR-only interests and which correctly understood that limiting the new EASA PPL to VFR only will ease its passage through the committees which are loaded with professional pilots, ATC and their union interests.

So be grateful that you have the IMCR in the UK. There isn't anything just around the corner to replace it.

It is indeed true that flying has moved on. 30 years ago, even an airline pilot has only a vague idea of where he was - until he got localiser established and intercepted the glideslope. Today, any pilot seriously going places has navigation accurate to a few yards. Yesterday I flew 150nm one way and 150nm back, and the two GPS tracks are on top of each other - within a yard or two. And within maybe 10ft vertically as well. I can fly a GPS approach, on autopilot, and if I flew it all the way to the runway I would end up in the middle of the runway. This is without WAAS/EGNOS, too. The world has changed. Maybe the regulators will wake up 30 years from now. In the meantime, the IMCR is a fantastic privilege which every serious pilot should get and which gives him similar rights to the full IR - except no Class A, min 1800m vis, IFR in UK only.

[Pace]

fuji and 10540

Thanks for the input both beautifully written. We are really saying the same things from different angles but with the same goal.

I cannot say I disagree with anything either of you have said in the last postings

Pace

[S-Works]

In the meantime, the IMCR is a fantastic privilege which every serious pilot should get and which gives him similar rights to the full IR - except no Class A, min 1800m vis, IFR in UK only.

Similar rights but in the vast majority of cases not similar training or experience and that is where the problem lies in the eyes of our regulators.

As I said before in my opinion the correct way to go around this is to separate the IMC and the IR, stop making inferences that apart from Class A they are interchangeable and drive home the fact that the IMC is a safety and skill enhancer for the private pilot.

Leave the politics of changing the IR to follow it's natural course, which is something that some of us have been working on for a number of years now and know better than IO's guess about the way the wheels are turning. It is a slow process but one that is happening.

[IO540]

Pace - curious why you have blocked PMs. Has somebody been harrassing you?

[Fuji Abound]

Leave the politics of changing the IR to follow it's natural course, which is something that some of us have been working on for a number of years now and know better than IO's guess about the way the wheels are turning. It is a slow process but one that is happening.

Bose, sorry but I am going to have a tiny moan.

I hate this business where the politicians tell us "dont worry, we have some plans up our sleeve, something just around the corner". It is patronising, and I am not convinced it goes down well.

Far better to keep everyone informed of whats taking place (unless there is good reason for it to be confidential, in which event dont refer to something you cant disclose in the first place), otherwise poeple tend to judge on past performance. I can understand IO's stance - as long as I have been flying, which is a very long time everyone has talked about an "easier" IR - the reverse has happened, so the the history aint good, and as long as I can recall someone or other was saying ah well, its all about to change.

Who was it that called wolf too many times (silly piggies) and in the end no body believed them.

In short if you know better how the wheels are turning then tell everyone, and if you cant, then say nothing - better to hold Pandora's box to yourself, rather than tell everyone that only you know what is inside, cse cynically if they never get a look they aint going to like you, and if they do get a look, but dont like what they see, they are going to like you even less.

[IO540]

It is currently known that EASA is planning to revisit the subject of the "private use IR" over the coming years.

Nothing else is actually happening on the IR front.

Sadly, confidentiality is vital in all these things, whether one likes it or not. Otherwise, overt and covert lobbying (by industry or whatever the stakeholders are) would scupper any work you are trying to do - because practically every change is not going to be liked by somebody. The committee members are generally known and pressure would be applied to them directly, to affect their voting.

The official pretence (at EASA and everywhere else) that direct lobbying of the legislative bodies is ineffective and that due process must be followed. Obviously this is nonsense because the whole process is wrapped up in politics, but they at least try to protect the low level committees so they can prepare proposals of some sort.

Another, less charitable, reason for confidentiality is that if a certain representative body fails to achieve anything whatsoever (or even votes in the complete opposite way, because they traded votes with somebody else in exchange for support on some other issue) no blame can be attached for the "failure". Vote trading does go on on these committees - just like in Planning Committees

[Pace]

No I have not blocked the PMs cannot get the thing to work took me ages to find out how to highlight quotes

Will give it another go after weekend as am away in the clouds this weekend

Pace

[Pace]

10540

I am going to stick my kneck out here and say that I feel trying to defend the IMCR my be counterproductive.
Really what everyone appears to want is an achievable PPL IR Simular to the FAA variety.

Both the IMCR and the impractability of getting an IR for Joe Blogs in the street could be challenged in the European courts on the grounds of being denied safety in an unreasonable way.

There was a major study carried out on the comparisons between FAA and JAA licening.
The result was that there was NO difference in safety between JAA trained pilot right up to ATP and the FAA trained pilots.

Trying to defend the IMCR might get a result on grounds of safety as there is plenty of evidence showing the french high accident statistics with pure VFR only compared to the UK IMCR protected pilots.

But following safety lines might mean you end up getting an IMCR to be used only for inadvertant entry into IMC and with the declaration of a mayday.
Not what I think we want to achieve.

Better to go for an FAA type PPL IR with a direct challenge on the grounds of safety to the European Courts claiming the present system is not achievable in a practical way for working people and endahgering their lives by not having it.
As stated there are plenty of studies showing that FAA and JAA achieve the same standards albeit by different routes and in safety too.

It might be cleverer to abandon the IMCR and concentrate on an FAA like PPL IR. dont shoot yourselves in the foot.
Finally abandon the reason way through normal channels and go to court to force it through.

Pace

[Fuji Abound]

Finally abandon the reason way through normal channels and go to court to force it through.

In some respects not an unreasonable proposition BUT who is going to pay?

Not wishing to get me back on an old hobby horse, but in spite of the much improved efforts of AOPA, unless they can increase their membership significantly, they neither have the financial resources nor the ground swell of support to make a difference in an arena where as IO says, there are so many vested interested. In America AOPA count amoung their membership over 50% of the pilot population, here it is less than 5%. AOPA dont seem to have a good record of working with the other players, and even if they did, it is difficult to find another player who for various reasons wants a more accessable IR. Then there is Europe. AOPA have a few organisations scattered around Europe but for example, in France, a significant cradle of GA, they are far less representative than AOPA UK. This means within the world of EASA there is no cohesive force behind GA that can even come close to claiming it represents the wishes of the majority of GA pilots. We have ourselves of course to blame.

This was one of the reason I started the campaign to preserve the IMC rating with a few others. With a huge committment of time and lot of generousity of others it was refreshing the huge support we gained - some 4,000 pilots in a pretty short period of time. The GA community is prepared to fight their corner. I have good reason to believe there are many in Europe prepared to fight the same corner. However, sadly, I am not convinced we have anyone or body prepared or able to take on the other vested interests - who will in consequence ride rough shod over us all. It is a shame.

IO

As I commented I accept the needs for confidentiality at times, and I do understand why that shoud be so. My point stands, if it is confidential then it is best to say nothing. Just my opinion you understand.

Edited to add.

Think about this thread. There are three of us debating this. No one else chips in with a view, other than Shunter , who tells us he uses his IMC in earnest. Thank you Shunter for contributing. I wonder why? What it does demonstrate is that it takes effort to get people to understand the changes that are taking place - I think there are a lot who care, but as Bose (I think) memorably said, wake up, cse it is already nearly too late.