IR vs IMC training

[Pace]

Hot N High

That maybe correct but it would be impossible to prove a cloudbase in a court unless you admit it. Even with overcast at 200 feet no one can prove that there was not a hole and tunnel in the clouds leading to the numbers and touchdown point. This appears to be unenforceable law in the above format.

RVR is a different matter and you will get the book thrown at you breaking an RVR minima.

Pace

[Fuji Abound]

HotNHigh

English proficiency for you, me thinks.

The sentence simply says adding the extra height and imposing an absolute minima are RECOMMENDED, read the whole of the section after recommended as just that - a complete section. I recommend you dont get too close to the edge, and I (recommend) you absolutely should not stand on the edge on one leg. If you like the recomendation that you impose a minima is a stronger recommendation by the addition of the word absolute.

That is the CAAs interpretation as outlined in writing on numerous occasions and one with which I would agree. You may not agree, but there it is.

[Hot 'n' High]

Pace

Even with overcast at 200 feet no one can prove that there was not a hole and tunnel in the clouds leading to the numbers and touchdown point. This appears to be unenforceable law in the above format.

Very true! I guess we have all seen people landing in abysmal conditions having "found a hole". The "Law" is unenforceable for "real" DH/MDH's as well. Even I have landed where I and ATC were surprised I made it in but, a couple of minutes later, as we taxy to stand, we could not even see the next aircraft as it executed a GA. And the converse has happened to me - off we trot to the Diversion!!!!

All I would observe is that the question raised here is what the legal minima are for an IMCr pilot, not the enforceability of said legal minima. Personally, I Instruct to the 500/600ft minima and flew to my interpretation of the minima on my IMCR. I'm not suggesting that anyone here is doing otherwise as the issue here is clearly "interpretation" of what the law is.

Shunter, Fuji

Always delighted to be corrected, is it possible to have a copy of any letter from the CAA as that would be really useful? I have learned over the last 30 years, some correspondence is best held on file – just in case. My logic for my current position is that, if there was an "and" rather than a "but" between the two sections, I would agree that the recommendation applies to both. That's my take on it given my knowledge of English but if the CAA view both as recommendations then, hey, it's their Rules!!!!!

The sad part about this, why don't they just amend the section to read:- Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, and are advised to use absolute minima of 500 ft for all precision approaches and 600 ft for all non-precision approaches for additional safety. Job done!

Cheers, H ‘n’ H

[IO540]

you know you want to deep deep down and then do the JAA IR in an aztec with no autopilot or FMS or head up display or whatever else you have FAA STC'd in your aircraft

Sorry to inform you but my TB20 is identical to its previous G-reg equipment level, and everything I have installed was on the DGAC Type Certificate

[Fuji Abound]

Hot N High

If you consider the sentence I think you may find the use of and or but doesnt make any difference to the meaning of the sentence, the key is the sentence starts with the use of "recommended". If the draftsman wanted to impose the recommended minima as a legal minima he would have started a new sentence. I would agree it is a good example where the wording requires carefully reading to avoid any confusion.

I also have written confirmation from the CAA. Such correspondence will usually be qualified with "This e-mail, and any files transmitted with it, are confidential." so it would be inappropriate to engage in their wider distribution.

However, particularly if you are an instructor, you should write and can expect a rapid response. I dont know whether David Cockburn is still editor of GASIL but I know it was suggested he might include clarrification in GASIL - whether or not he did, I am uncertain. If Cpt Pat Lander is still in PL he might also be another good port of call.

Why not just take 6 months off and do the JAA exams - you know you want to deep deep down and then do the JAA IR in an aztec with no autopilot or FMS or head up display or whatever else you have FAA STC'd in your aircraft

Just a thought.....hang on.....dont tell me you couldn't afford the pay cut....yada yada yada

and your point from the corner is?

[Hot 'n' High]

Fuji (and Shunter), I quite understand re the e-mails and I will drop David a line or even ping him when I next see him at a CAA Safety Evening.

If it's any consolation, I can almost read the para as you say - but my alternative interpretation is so long-standing and deep-rooted ......

Anyway, cheers for that. Just goes to show how one can be mistaken for so long!!!

Cheers, H 'n' H

[IO540]

I agree with Fuji. That famously often quoted piece of text is so poorly worded it would have never been drafted by a lawyer. The non-legal writing emanating from the CAA is often like that, but thankfully it is not the law.

[Hot 'n' High]

That famously often quoted piece of text is so poorly worded it would have never been drafted by a lawyer.

LOL! The cynic in me thought it had been deliberately worded vaguely so that any Court Cases arising would run and run arguing the toss, thereby ensuring both the Prosecution and Defence would make a tidy sum!!!!

Cheers, H ‘n’ H


Disclaimer:- No offence is meant by the comments made by H 'n' H in this Post to any member of the Legal Profession!!!!! H 'n' H is only kidding!!! Honest!!!!!

[mm_flynn]

I believe the CAA employ special purpose writers to take simple concepts and document them in as complex a manner as possible.

I also have it on good authority the CAA receive a pay for click commission for each new post on the Internet debating their arcane wording. These funds are used to support the 100 year plan for implementation of an NDB replacement strategy.

My personal favorite in the UK is

'... may not fly in Class D under circumstances which require compliance with the instrument flight rules'

actually means

'may not fly IFR in Class D' - under ANY circumstances

[IO540]

LOL! The cynic in me thought it had been deliberately worded vaguely so that any Court Cases arising would run and run arguing the toss, thereby ensuring both the Prosecution and Defence would make a tidy sum!!!!

I know you are leg pulling, but seriously I don't think there is ANY point behind such allegedly deliberately crap wording because there is no evidence the CAA have ever prosecuted this. You can find recent prosecution details on their website.

Any minima is according to whether the runway etc is seen by the pilot and in a single crew scenario this cannot ever be enforced anyway.

'... may not fly in Class D under circumstances which require compliance with the instrument flight rules'

actually means

'may not fly IFR in Class D' - under ANY circumstances

What about VFR in Class D?

[Hot 'n' High]

IO540

I don't think there is ANY point behind such allegedly deliberately crap wording

I agree, given it would be difficult to prove a breach as you and Pace rightly say. Even sadder, looking at the "amendment bar" adjacent to the current 3.3.2.1, it looks like it has recently been changed! And, still,
H 'n' H is confused! Not much hope for me really!

Anyway, I've learned something today! Think, for my own peace of mind, as Pace said, I'll just get it in writing. Not that I don't trust the CAA/NATS - soon, you'll be thinking H 'n' H is permanently paranoid!!!

Cheers guys! Off out now and I'm now suitably enlightened!

H 'n' H

[mm_flynn]

Originally Posted by IO540

What about VFR in Class D?

It is from the PPL section and more fully means - in (Class D) VFR (in VMC of course) is OK, IFR in VMC is forbidden, IFR in IMC is forbidden.


The logic of why the CAA phrasing means IFR in VMC is forbidden (to a PPL in class D) is ---

Although you are not 'in circumstances requiring compliance with the IFRs', once you say you are IFR, you will receive and accept an IFR clearance, putting you in a 'circumstance requiring compliance with the IFRs' (which in this particular case are almost certainly operationally identical to the VFRs).

This is almost a verbatim response I received from the CAA.

[421dog]

From a "this side of the pond" perspective, an ATP is really just the "commercial instrument" rating. The standards are those that are required for any type-rating, so anyone who's got 1500 hrs and is taking his Citation 500 or whatever checkride actually has to perform to the standard, so he might as well get the rating. The hard part is all of the part 121, 125, and 131 garbage you have to regurgitate on the written.

The instrument rating over here has been best described as a "license to kill yourself, but not the rest of us". Part 91 operations are nearly entirely permissive, in that there are no specific minima for attempting an operation (other than airport limitations) so some 200 hr pilot with his newly minted instrument rating and absolutely no actual instrument time is totally free to kill himself on an ILS to a 0/0 field.

[Airbus Girl]

I think these posts just prove the point that in all kinds of flying, it is the pilots attitude that is the most important thing. Personally I don't like the IMC rating because the majority of IMC holders tend to not be current on real instrument flying and the only practice they tend to do is to fly the occasional ILS approach. I think most of the posters on here who have IMC ratings are the kind of pilots who keep their ratings valid, and are in regular practice with their instrument flying, and keen to add to their knowledge. The problem IMC rating holders are the ones who do the rating and then don't keep actively current, and then one day they have a trip planned to France with friends and rather than lose face and cancel it, they go ahead, knowing that they have an IMC rating, regardless of the fact they are not in current practice. They are the ones we read about in the accident pages.

I guess its like learning a language - I did German 'O' level at school but haven't really used it since. I have the piece of paper but would be pretty rubbish at speaking German. Yet if I was living in Germany I would be very proficient and my knowledge would probably mean I was on a par with an A level or Degree holder even though I didn't have that piece of paper.

[421C]

They are the ones we read about in the accident pages

No we don't. IFR accidents involvng IMCr holders are almost non-existant in the accident record. I've read zillions of web postings conjecturing the dangers of the IMCr and never seen any evidence for it. It's been around a long time and enough people have held it that there would be an accident record to support the "inadequately trained, don't stay current, blunder on regardless" hypothesis if it were true IMHO.

I'm not saying the IMCR danger hypothesis is impossible. But every Licence, Rating, Privilege etc has a potential danger scenario of being used to its legal max limit with legal min currency (or illegally in your French example). There's no evidence that such a danger is any higher with the IMCr than with any other qualification. It seems to me the training, privileges and how pilots use those privileges all line up very nicely.

brgds
421C

[Fuji Abound]

Personally I don't like the IMC rating because the majority of IMC holders tend to not be current on real instrument flying and the only practice they tend to do is to fly the occasional ILS approach.

Which only goes to show you have absolutely no understanding of the rating, and very little understanding of IMC ops in light aircraft.

and then one day they have a trip planned to France with friends and rather than lose face and cancel it, they go ahead, knowing that they have an IMC rating, regardless of the fact they are not in current practice.

I very much doubt you will find much evidence of the implied hords of IMCr pilots doing this and ending up in trouble in the air.

They are the ones we read about in the accident pages.

In which case, doubtless you would like to point us to the accident pages in question.

Airbus Girl - I am afraid your post is the usual dribble, which sounds all very alarming until you try and find any evidence to support the dribble.

The real problem is the intention behind your post was presumably to caution people either from obtaining an IMCr (in favour of a proper IR) or just a general slating of the IMCr on the basis, if it was well intentioned at all, of keeping these pilots out of harms way.

The reality is your post has the potential to achieve exactly the opposite effect - the abolition of the IMCr all together. As matters stand, all that will then happen is pilots will engage in IMC for what ever reason without any training at all - and will kill themselves.

I think you will find that pilots with either and IMCr or an IR in the vast majority of cases know their limits. It matters not the colour of your rating, as you rightly say, what does matter is whether or not you are current. For those pilots who are willing to push their PLs I can guarantee you it doesnt matter what rating they have, they will still find ways of killing themselves

You would do well to not be judgemental unless you can assure us you have reviewed the evidence.

[Pace]

Fuji

There is no reason to get heavy handed with Airbus Girl as a lot of what she says is not far off the Mark.

The IMCR is a minimal instrument training and nav package with high innacuracy tolerances for instrument flying. It is NOT an IR.

Many pilots do use it as an insurance policy, a get out of trouble rating only and are not current or experienced in instrument flight but like the enhanced safety the rating offers.

A few pilots use it for HARD IMC flying like a mini IR but it is their experience and currency which allows them to do so not the rating training itself.

Where AirbusGirl is wrong is in the fact that it cannot be used for day trips into France because it is not accepted there.

Pace

[IO540]

What I am not happy about with

I think these posts just prove the point that in all kinds of flying, it is the pilots attitude that is the most important thing. Personally I don't like the IMC rating because the majority of IMC holders tend to not be current on real instrument flying and the only practice they tend to do is to fly the occasional ILS approach. I think most of the posters on here who have IMC ratings are the kind of pilots who keep their ratings valid, and are in regular practice with their instrument flying, and keen to add to their knowledge. The problem IMC rating holders are the ones who do the rating and then don't keep actively current, and then one day they have a trip planned to France with friends and rather than lose face and cancel it, they go ahead, knowing that they have an IMC rating, regardless of the fact they are not in current practice. They are the ones we read about in the accident pages.

is that it implies that these pilots would be safer without the IMCR being an option at all.

Outside the UK, there is very little private IFR activity because the pilots there have been pushed into the VFR-only ghetto where they stay, occassionally doing some illegal and (more importantly) untrained IMC flight.

I was once parked at San Sebastian. There were a bunch of French pilots, all VFR ones, flying plastic homebuilts. All departed into ~ OVC007 to go back to their French destinations.

Here is some data on private IR issuance in the UK. Pretty unimpressive, against the 20,000 or so IMC Ratings (reference: CAA presentation Feb 2008) issued since its start.

An IR holder with a poor currency will be as useless as an IMCR holder with poor currency.

[Hot 'n' High]

An IR holder with a poor currency will be as useless as an IMCR holder with poor currency.

Could not have put it better IO540!

The Thread title is “IR [training] vs IMCR training”. I think we all agree that there is more time on the IR course to practice things for the Test. But I would suggest that the “training experience advantage” rapidly diminishes after the Test leaving a PPL IR and a PPL IMCR in exactly the same boat within a couple of months of the IR, and less after renewals! And the differences in “tolerances” is a real red herring when it comes to basic safety. Where it really matters (ILS or similar) it’s the same. Upper air, the IMCR has a bit more latitude, but that is not where rocks and trees are found. A far more logical and productive discussion is to look at recurrency periodicity. But even that is moot as you can’t logically reduce the IMCR validity to less than that of the IR. Finally, as far as I’m aware, there have been absolutely no IMCR-related accidents ever - IMCR pilots have had accidents, but these have not been related to use of the Rating.

As Airbus Girl says

I think these posts just prove the point that in all kinds of flying, it is the pilots attitude that is the most important thing.

You said it – for a PPL IR or a PPL IMCR, it matters not.

[IO540]

Finally, as far as I’m aware, there have been absolutely no IMCR-related accidents ever - IMCR pilots have had accidents, but these have not been related to use of the Rating.

In that presentation, the CAA head of licensing said they know of just one fatal accident where the pilot was exercising his IMCR privileges at the time.

This suprised a lot of people, because it goes against a certain widespread common "wisdom" but I would suppose that if this was easy to challenge, he would not have said it.

As 421C says, the IMCR training and usage tend to line up well and this is no doubt why there isn't wreckage everywhere (though there is a lot more wreckage in France, resulting from French pilots doing VFR into IMC etc). This is fairly obvious IMHO, because if you have the time and money to fly in a more advanced way (both equipment and mission profile) you will eventually find the time for the IR, not least because the IMCR is no good for IFR abroad. An FAA one it will be in most cases but that's another story.