IR vs IMC training

[Hot 'n' High]

IO540,

Thank you. Sadly, I stand corrected - not because it weakens the argument much - just that any accident is sad. Pity we can't look at when it has helped.

Confession time! Years ago, I was flying cross-country and Met conditions got worse and worse, but I thought it would be easier to stay VFR underneath - even though I had an IMCR. Don't recall being particularly current in IF at the time and the forecast certainly had been way out - the vis was right down and cloud was forming off some high ground. To begin with, I could not face changing my "planned" VFR flight to an "unplanned" IFR flight particularly as, at the time, I was not particularly IF current. However, once I made the psychological decision to call it IFR and climb, all of a sudden my world got a whole lot easier and a lot safer. Yes, the flying was harder .... but I did not have the stress of peering out wondering how much worse things were going to get! Got the first VOR tuned in and I was up and running - with a friendly Radar service to back me up too if I became "unsure of my position". I felt sorry for the PA-28 ahead of me who was left grubbing along VFR as it was really not nice at all. I like to think the only reason I stayed VFR for so long was "because the guy ahead was managing OK"! At least, that way, I can blame my stupidy on the "macho-factor"!!! Hopefully, I've learned a bit over the years ... and long may I continue to learn!!

H 'n' H

[Fuji Abound]

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

Pace

There is, perhaps if only because I may have a better memory than you.

Airbus Girl has rolled out the same arguments before and was corrected last time. I think for the reasons I said her comments were very far off the mark.

I dont mind anyone putting forward a reasoned argument, but I do object when the argument is neither reasoned nor has the evidence previously presented been either refuted or accepted.

There are a great many people who would wish to see the end of the IMCr for reasons other than safety. If the IMCr is lost, and there is no comparable alternative, a great deal of the damage will have been done through either ignorance or maliciouness.

Neither should be tolerated by us.

[Pace]

10540

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.

There was a fatal in Ireland earlier this year descending into high terrain another over the channel. As Posted in an Earlier debate one of my best friends was killed in a mooney flying IMC with an IMCR.

Having said that both IMCR and IR pilots have fatals and the French accident stats are not a good advert for pure VFR no IMC flights. Without doubt the IMCR is a strong addition to flight safety but the Europeans for their own reasons dont want to see that.

Pace

[IO540]

the Europeans for their own reasons dont want to see that.

I don't think that is true, Pace.

In the few cases where the subject has been discussed among European pilots, AFAIK, half said that everybody will kill themselves without a proper gold plated IR, while the other half would have given both arms for what we have here in the UK.

About the same as here then

Anyway, give it a few years. There might be some interesting developments.

[Sciolistes]

Fuji, Hot and High,

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 interpret that the same way as High and High, that the absolute minima is 500/600' and that the recommendation applies to adding 200' to achieve an optionally higher DH/MDH.

However, some time ago I emailed the CAA and asked for clarification and was told that anything above standard IR privileges is recommended. But if you chose to ignore the advice and have an incident then the CAA would probably use that against you. When I asked if I could quote the email on pprune, they said they rather I didn't. I viewed the refusal as ominous and that they didn't really have much confidence in their own interpretation.

Regardless of what the CAA thinks (or that chap at the CAA thinks), I wouldn't trust the such ad hoc opinions from individual employees. My interpretation of the offending sentence is as stated and, personally speaking, if I were to use the IMC again in the future that is how I would treat it.

[IO540]

But if you chose to ignore the advice and have an incident then the CAA would probably use that against you

I wonder what view their lawyer would take of that

Especially as the history of prosecutions in this area (where only the pilot can say when he became visual) is exactly nil.

Regardless of what the CAA thinks (or that chap at the CAA thinks), I wouldn't trust the such ad hoc opinions from individual employees

For yourself, such an opinion, coming as it does from an apparent authority, would make a prosecution impossible. That's how things work, and if they didn't work that way, any opinion on anything whatsoever from any official body whatever, would be totally worthless, because the enquirer has a reasonable expectation of receiving the correct advice from an official.

However, and I got this from a lawyer, such an opinion does not change the law itself, and this makes it difficult for other people to rely on it too. It appears, however, that if you posted that opinion openly on some website, and for ages the CAA did nothing to correct it, then it would hold up for the others too. This, I suspect, is why the CAA doesn't like their letters reproduced verbatim with the headers... and this is widely suspected to be the reason why the FAA withdrew their website FAQ in 2004; they didn't want their Chief Counsel opinions to be undermined.

The CAA is IME pretty good in the accuracy of their replies. I know of just two which are misleading or totally wrong. One told somebody he cannot fly a G-reg on an FAA license (which is really basic utter bollox), and the other told somebody he can fly a G-reg, worldwide IFR, on an FAA IR (which is true but they forgot to mention it works only in Class F or G which makes it effectively useless especially outside the UK).

[Hot 'n' High]

Pace,

I’m really sorry to hear that. Have you got the details of the Accident Report? I’d like to see what teaching points the Recommendations have.

Sciolistes

I interpret that the same way as High and High

and, notwithstanding what I now know thanks to IO540, Fuji, Shunter and your good self, I think I will still emphasise, and instruct to, the higher limits – explaining to the student why I am doing so. The reasons I will do this are as follows:-

1. Personally, I feel that, in the main, the pilots I take on to the IMCR will use it purely as a “recreational” licence. Usually, there is no need to fly “recreationally” in weather to the absolute IR minima. If the weather is that bad, most PPL IMCR’s would not bother anyway – most of those I know, and especially their pax, enjoy the view too much!

2. The newly qualified IMCR pilot will not be subject to the sort of early post-qualification supervision that we find in the Commercial world (OPC/LPC etc) followed, in the main, by two-crew Ops with an experienced Captain. While the upper-air section is fine, it’s the decision/transition phase as the ILS becomes more and more sensitive which is key.

3. And, finally, and not wishing to open another can of worms – my personal view this, flying SEP (which most IMCR PPLs do) with an overcast at 200ft leaves no margin for error in the engine failure case. If it’s 200ft at the field it’s probably on the deck on the hills surrounding the field! I know, statistically, it is very unlikely for all holes to line up for that one but ….. well, call me a woossie!

If someone asked me to Instruct them to the absolute limits, I would now do so (what choice have I got?!!) - but only having re-iterated (on a regular basis) the above cautions. I would even make a note to that effect in their Training Records! After all, we not only Instruct the practical mechanics for safe flight, but the decision-making skills which also ensure that the flight is safe. That way, hopefully Airbus Girl will see IMCR pilots making sensible choices, as I believe the vast majority do already - flying within their personal limits, be that the IR limits or the recommended IMCR limits.

Anyway, that’s my tack on this now, FWIW!

Cheers, H ‘n’ H

PS As a matter of fact, I have always made sure I take IMCR students down to the IR ILS minima once - to emphasise to them how much difference those last few hundred feet make!

[mm_flynn]

Hot N High, the accident in question is here AAIB.

A more complete analysis of the accidents in the CAA's latest 10year fatal accident summary shows twoweather related accidents for IMC rated pilots

There is one CFIT for an IMC pilot (An IMC pilot and instructor on an IMC re-validation)
There is one loss of control accident (the above referenced Mooney engine failure in IMC).

In the same period of time there were
1 CPL/IR CFIT
1 ATPL loss of control in IMC
1 CPL/IR Loss of control in IMC
9 PPL CFIT in IMC
2 PPL Loss of control in IMC

There is no data to suggest the relative exposure of PPL, PPL/IMC,CPL/IR, ATPL to IMC conditions in GA operations.

Interestingly there were also 6 accidents in the CAAs analysis that ocurred outside the UK and look like weather accidents (eg. 'crashed into mountainous terrain in deteriorating weather') for which inadequate information is available to be analysed.

Recently there have been a number if 'foreign' weather related accidents involving UK based pilots. As these are investigated by agencies other than the AAIB or the NTSB, the reports take ages to come into the public domain (and even the AAIB can take well over a year).

[belowradar]

Regarding training minima

I train to the minima on the approach plate and fly all ILS to the minima. This gets the pilot used to flying the full approach.

I explain what the CAA guidance is regarding adding a safety factor for IMC and emphasise that it is best practice HOWEVER don't worry about flying to the minima if you need to as long as you are current, just don't plan to do that !!!

[Hot 'n' High]

Pace,

Thanks for the link. And I’ll also dig out the latest “10 year” summary as well. Not looked at that for a while I must admit.

Belowradar,

Having pondered things a bit more, I think the thing for me to do is to chat to the CFI and see what "company policy" is on this, and clarify this wherever I happen to be Instructing. Had not even considered instructing IMCR to IR limits until yesterday so still a bit of a novel idea for me!

Anyway, my thanks to all. A very useful/enlightning Topic.

H ‘n’ H

[Pace]

These stats are between 1985 and 1994 where there were 29 fatal accidents in IMC.
Three quarters were to pilots who had NO IR or IMCR. That leaves approx 7 pilots killed with an IMCR in IMC in that period.

Only one of the accidents involved a pilot with a full IR.

Appendix 5 Loss of Control in IMC (LOC IMC)
1 Definition of a Fatal LOC IMC
¨ This is defined as a fatal accident where a pilot lost control of the aircraft in
Instrument Meteorological Conditions.
2 Pilot Characteristics in LOC IMC Accidents
¨ Pilots involved in fatal LOC IMC accidents appear to be close to average age.
The mean values for Total Hours and Hours on Type appear slightly lower than
for other accident types but the difference is not statistically significant.
Although recency data was too sparse to analyse, the averages do not suggest
that this type of accident is particularly associated with being out of practice.
¨ All were flying in IMC yet more than three quarters had no Instrument Rating
(IR) or IMC rating. (Only one pilot in this group had an IR.)

So much for the CAA guy who stated there had never been a fatal accident to a holder of an IMCR in IMC which is argued in these threads.
My Friend killed in the mooney was in this period.

Pace

[-GQ-]

I'm close to doing the PPL skills test and plan to do IMC training straight after (I understand the 25 hour rule).

Given the common view, albeit not universal, in this thread that IMCr allows full IFR flight (except no class A and 1800m horizontal take off and landing minima), why does a respected training institution like Multiflight say on their website "The IMC rating allows you to pilot your aircraft in slightly worse weather conditions than the basic PPL. However it must be stressed that this licence is designed to allow you to depart into better weather or land should the weather change enroute and is more of a 'get out of jail card'. It is not a licence to takeoff, cruise and land is [sic] poor weather."?

Is this just to illustrate that they are a conservative and responsible organisation?

My question not rhetorical or aimed at slating any FTO, but a genuine enquiry, as I plan to use the rating as regularly as I can - I don't want to become a fairweather local bambler and if I want to go on to CPL/IR/ME and beyond, I want to be as prepared as possible.

So would your average club allow you to take off in a rented aircraft in genuine IMC minima?

I would appreciate the views of pilots who use their IMCr regularly.

Thanks

[Fuji Abound]

Pace

So much for the CAA guy who stated there had never been a fatal accident to a holder of an IMCR in IMC which is argued in these threads.

Where are you getting your information from? Do you have a link to the reports and stats. for the period to which you refer?

But if you chose to ignore the advice and have an incident then the CAA would probably use that against you.

Rubbish

I think I will still emphasise, and instruct to, the higher limits – explaining to the student why I am doing so.

I wouldnt, if I were you.

The best way to ensure the average pilot knows he shouldnt being flying to minima is to require him to do just that. How many of us think we can do things, until we try. It is in the trying that we come to appreciate the skills required. Emphasise time and again the dangers of doing so unless you are current, point out how tough you found it when you were current during your training and accompanied by an instructor - you have far more chance to get the message home. Moreover if they get really unlucky and the forecasts are horribly wrong at least they have an idea what it is about.

[Brendan Navigator]

I just love how this debate goes on and on. Polarised views colouring the views from both sides of the fence.

Considder this;

When driving pass a school it is recomended that your speed is less than 20 mph but with an absolute limit of 30 mph.

or

When driving past a school it is recomended that your speed is less than 20 mph and with an absolute limit of 30 mph.

I believe that both of the above sentences say the same.

They both recomend that you drive at less than 20 mph

They both say that while driving at 25mph you are not following the recomendation but are within the overall limit

They both say that driving at 35 mph in the above case is not OK because it is outside the absolute limit of speed allowed.

BN

[Pace]

https://www.caa.co.uk/docs/33/CAP667.PDF

Fuji

This is the Link to the CAA accident stats for that period. They are for aircraft flying IMC not ones flying IMC that decided to try going underneith or for IMCR pilots flying VFR in minImal conditions.

If those were brought in the picture I am sure there would be far worse picture especially amongst IMCR pilots who are not current or experienced but do use it to fly in minimal VMC.

Fuji we had a long thread on this before and one where numerous times the arguement was made that there had been NO fataliies in the whole history of the IMCR which is rubbish.

There are NOT two brigades the pro IMCr and anti IMCR.
I have my own views that by promoting an IMCR in Europe will lead to a new IMCR watered down to almost nothing as I cannot see the Europeans accepting an IMCR in the way we use it in the UK.

A case of passing the ball and shooting an own goal.

I could see the Europeans seeing an IMCR as a way out of issuing a Proper achievable FAA style PPL IR and creating a VFR IMCR tacked on for VFR pilots who get into trouble only.

IMO It is better to fight for a PPL IR Than cloud the issue but then what do I know?

Lastly small point when you place highlighted extracts please make sure who they refer to as you open your post with PACE as if the extracts are from my writing which apart from the first they are NOT.

Pace

[Gertrude the Wombat]

So would your average club allow you to take off in a rented aircraft in genuine IMC minima?

Mine doesn't, nowhere near.

But it's their train set, they can set whatever rules they see fit, if I don't like it I can go elsewhere.

[mm_flynn]

Pace, Cap667 is more than a decade old (and I think your friend's Mooney accident happened in 1999 and is therefore not included in Cap667 but is included in Cap780 (rather than the late 80's M20K at Southampton). The data I based my analysis on is Cap780. In addition, I have only included fixed wing aircraft, whereas a number of the IMC accidents in Cap667 involve helicopters.

Much the same as in Cap780, a number of the IMC fixed wing IMC accidents happened outside the UK.

[Pace]

mm flynn

The big words were " never in the history of the IMCR there has never been a fatality etc.

All used as arguemnt in the previous thread. But hey statistics can read what you want them too. I could take one month, say there have been no accidents to pilots as there were none in that month and then portray the no accident result from statistics.

There have been three fatal accidents alone this year due to non VFR weather and conditions in fixed wing and am pretty sure all 3 held IMC ratings.

But this is point scoring as No one me included is trying to say that pilots trained in instrument flying are more dangerous than their pure VFR brothers.
Infact the reverse is true they are far safer.

But things have changed.
We are now more and more under the power of Europe who dont really care much about GA and whether Joe Blogs can take his girlfriend for a weekend in france flying IFR in airways on his PPL .
Yes they will give sympathetic noises, big smiles and tea and biscuits but thats about all and for us charging around Europe in cloud on an IMCR to an ILS forget it it wont happen other than in an emergency only situation.


Pace

[IO540]

The CAA said there was one known fatality of a pilot while exercising the privileges of the IMC Rating.

That's not the same as counting all pilots who got killed and who happened to have the IMCR. There will be more of those, obviously. One reportedly got killed flying an ILS into Le Touquet, I gather, but that one obviously doesn't count because it was illegal anyway.

[Pace]

The CAA said there was one known fatality of a pilot while exercising the privileges of the IMC Rating.

10540

How can that be when the IMC fatalities for that period contained 7 IMCR pilots in IMC. Being in IMC with IMCR ratings must mean that they were exercising their privalages to be there?

I can remember flying a C150 with very basic instrumentation and no NAV. I started VFR following a river line to avoid high ground at 700 agl in poor vis and rain. When I was down at 200 feet with wisps of cloud below I elected to climb IMC and get a PAR to a landing at a military base back then I had an IMCR. Luckely for me I flew out of the front into good VFR 20 miles from the base. I was exercising the privileges of the IMC Rating having been forced up.

My big concern with saving the IMCR is that we will loose the bigger picture of an achievable PPL IR. We will hand EASA a way out of ever making a European PPL IR a la FAA. I can see it now.

The new European IMCR has been approved in the name of safety. The new IMCR will allow VFR pilots to fly in lower VFR limits. Should such a pilot EIMCR rated be unable to continue his/her trip because of weather they may climb to the SSA into IMC. They must then squawk an emergency special code and state their situation. They will then be guided to a nearby airport by radar with an instrument approach and with weather in certain limits and will land.

Is that what we want? becuase my fear is something like that is what we will get.

Pace