IMC - what's the latest ?
421C,
Perhaps we agree on facts, but we differ on the priority we attach to them.
I consider an en route only rating to be substantially inferior (less useful and less safe) than the IMC Rating and not a satisfactory compromise. Dare I say it: I'll bet my view is the majority one among UK PPLs.
I'm appalled at the thought that UK representatives might consider en route IMCR acceptable as an alternative, and I hope this is not the case. To have an en-route IMC rating in addition is great, if other countries agree. But it should be clear that preserving the IMCR in the UK is a precondition for the UK. If other countries can have national ratings (e.g. altiport) then the UK can.
Perhaps we agree on facts, but we differ on the priority we attach to them.
I consider an en route only rating to be substantially inferior (less useful and less safe) than the IMC Rating and not a satisfactory compromise. Dare I say it: I'll bet my view is the majority one among UK PPLs.
I'm appalled at the thought that UK representatives might consider en route IMCR acceptable as an alternative, and I hope this is not the case. To have an en-route IMC rating in addition is great, if other countries agree. But it should be clear that preserving the IMCR in the UK is a precondition for the UK. If other countries can have national ratings (e.g. altiport) then the UK can.
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I consider an en route only rating to be substantially inferior (less useful and less safe) than the IMC Rating and not a satisfactory compromise. Dare I say it: I'll bet my view is the majority one among UK PPLs.
I'm appalled at the thought that UK representatives might consider en route IMCR acceptable as an alternative, and I hope this is not the case.
preserving the IMCR in the UK is a precondition for the UK
If other countries can have national ratings (e.g. altiport) then the UK can.
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421C, there is nothing to stop the UK filing differences with EASA. However, there are other fish to fry. One is actually having the IMCr recognised in other EASA states if possible.
I'll rise to your bait - your suggestion that an EIR is preferable to nothing between the PPL and the IR. I disagree. I think it will encourage people to fly in conditions for which they are neither qualified nor trained and lead to a false sense of security. I can't remember ever being flying in a spamcan over the sort of distances they fly when the weather has been VFR for departure, down to less than 2000' enroute and "virtually certain" VFR at destination (or alternate).
And with no approach privileges, how are people supposed to let down? Just descend through the murk and hope?
The "virtual certainty" of VFR weather at destination will (possibly) occur on a maximum of two days per annum in the UK. The rest of the time, "virtual certainty" in the accuracy of TAFs and their timing is a falsehood that will sucker in far too many people. I can just hear the barristers discussing "virtual certainty" and the likelihood of weather forecasters getting it right to that extent in the courtroom wherein is held the Subsequent Inquiry.
Sorry - but not only is it a chocolate teapot, it's a thoroughly dangerous one. I speak as someone whose first training after PPL was an IMCr, holds an IR with rather a lot of hours in elephant's backside conditions (=grey and ****ty) and now also instructs people in how to hold it all together when things go pear-shaped. As a fairly new PPL/IMCr, I also managed to fly inadvertently into IMC Wx - and was bloody glad of the training I had received that got me out of it without turning inverted and throwing a rather nice Arrow at the ground at a higher-than-usual rate of descent. An EIR would not have achieved that.
I'll rise to your bait - your suggestion that an EIR is preferable to nothing between the PPL and the IR. I disagree. I think it will encourage people to fly in conditions for which they are neither qualified nor trained and lead to a false sense of security. I can't remember ever being flying in a spamcan over the sort of distances they fly when the weather has been VFR for departure, down to less than 2000' enroute and "virtually certain" VFR at destination (or alternate).
And with no approach privileges, how are people supposed to let down? Just descend through the murk and hope?
The "virtual certainty" of VFR weather at destination will (possibly) occur on a maximum of two days per annum in the UK. The rest of the time, "virtual certainty" in the accuracy of TAFs and their timing is a falsehood that will sucker in far too many people. I can just hear the barristers discussing "virtual certainty" and the likelihood of weather forecasters getting it right to that extent in the courtroom wherein is held the Subsequent Inquiry.
Sorry - but not only is it a chocolate teapot, it's a thoroughly dangerous one. I speak as someone whose first training after PPL was an IMCr, holds an IR with rather a lot of hours in elephant's backside conditions (=grey and ****ty) and now also instructs people in how to hold it all together when things go pear-shaped. As a fairly new PPL/IMCr, I also managed to fly inadvertently into IMC Wx - and was bloody glad of the training I had received that got me out of it without turning inverted and throwing a rather nice Arrow at the ground at a higher-than-usual rate of descent. An EIR would not have achieved that.
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The Mountain rating is not a national rating - it is an EASA-wide rating. I don't know of any national ratings.
My understanding is that FCL008 were asked to review sub-IR quals to apply to all EASA countries, and since none of them accepted the IMCr
A "precondition" for what? Not leaving the EU in a huff? EASA's jurisdiction is already European law.
Anyway, debate as you will, nothing is about to happen just yet. The gauntlet has been laid at EASA's feet, it remains to wait and see how they respond. It could be a very long while before very much changes.
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nothing to stop the UK filing differences with EASA
I'll rise to your bait
However, given we are where we are, EASA at least have a working group trying to find an intermediate qualification, and I think it's worth more consideration than the experts in this thread have given it.
I can't remember ever being flying in a spamcan over the sort of distances they fly when the weather has been VFR for departure, down to less than 2000' enroute and "virtually certain" VFR at destination (or alternate).
The "virtual certainty" of VFR weather at destination will (possibly) occur on a maximum of two days per annum in the UK. The rest of the time, "virtual certainty" in the accuracy of TAFs and their timing is a falsehood that will sucker in far too many people. I can just hear the barristers discussing "virtual certainty" and the likelihood of weather forecasters getting it right to that extent in the courtroom wherein is held the Subsequent Inquiry.
And with no approach privileges, how are people supposed to let down? Just descend through the murk and hope?
a thoroughly dangerous one
You think people can be safely taught to fly instrument approaches to IR minima in a 15hr IMCr course and to fly enroute IMC OCAS safely and yet an unspecified course, which might well have as much approach training as the IMCr (not difficult, I remember doing a few ILSs and a few SRAs on mine) but only enroute privileges is bound to be "thoroughly dangerous".
brgds
421C
Fuji
It is?
Unfortunately, they do object to the IMCr.
The CAA say they support the IMCr and so does AOPA UK so I wonder who is not telling the truth
I wonder why we should be suspcious of committee behind closed doors - open govenrment, hmm.
You think people can be safely taught to fly instrument approaches to IR minima in a 15hr IMCr course
I held IRs on various aircraft for about 30 years. Rarely did I ever need to fly to 'IR minima' - on most occasions the IMCR would have been sufficient.
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even a well trained monkey could fly an ILS..
but this is not the challenge here. The absolutely fundamental challenge on the entire "how to make the IR more accessible" proposal, going back over the few years that I have been watching the GA scene, is nothing to do with matching training to the actual mission requirements. It is nearly wholly political/emotional: the European regulators have nailed the "professional pilot" flag to the "IR" mast and this is why the IR has never been made significantly more accessible. In the USA, the "professional pilot" flag is nailed to the "ATP" mast which is where it belongs, and anybody can get an IR as a natural step after doing their PPL.The GA IR community's interests happen to not be all that divergent however, from the professional pilot unions etc. One gotcha is that if you "water down" the ICAO IR then the regulators could then use this as an excuse to water down the privileges, reducing them from the present totally unquestionable full IFR-anywhere, to something lower - but anybody with an IR knows that any privilege reduction would render the full IR pretty useless. The whole point of an IR is to get the free IFR flight procedure, with ATC working for you, etc.
this potential scenario exists today with the vast majority of the world's PPLs who have VFR-on-top privileges. They are equally vulnerable to destination forecasts changes and just as untrained to fly IAPs.
IMHO the vast majority of pilots who in theory can fly VMC on top don't do it because this requires totally competent radio navigation, which is not AFAIK taught properly anywhere.
A plain PPL cannot climb legally through IMC, and this fairly drastically cuts down the # of people who will end up trying to do a hard VFR letdown at the far end.
My talks with some French pilots suggest that very very few of them actually use their VMC on top legal right. Not a lot of long distance touring goes on in France anyway...
Finally, some pilots who might fly VMC on top under "VFR" are instrument competent but have not got the IR and they fly "VFR" in IMC as necessary. In the UK this is pretty common. These are going to do DIY letdowns where nobody will catch them (hopefully).
So I do think that this proposed EIR needs an SRA which after all is no more than flying a heading and altitude as directed by ATC - in IMC and a plain PPL ought to be able to do this anyway.
BTW some googling suggests that the Australian IFR Rating is here.
I wonder why we should be suspcious of committee behind closed doors - open govenrment, hmm.
Perhaps we should be less quick to jump to the conspiracy theory....re my prior answer
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Perhaps we should be less quick to jump to the conspiracy theory....re my prior answer
Yes it is.
My "none of them" meant EASA countries, not FCL008 members. I understood that in FCL001 the IMCr was rejected by all the participants except the UK ones.
I've turned back on many trips when the enroute murk was such I couldn't continue, where my destination was forecast VFR.
Another aircraft was returning to my destination after a local VFR flight. He remained below the base and the flight was legal if, perhaps, not prudent for some.
The EIR as proposed by you is not based on a sound safety case (if it is please set out the case for us all) but on political expediency. If EASA legislates for reasons of political expediency and not safety we are all doomed and the process is broken.
I reiterate if you want to engage in debate then please set out the safety case for the EIR. Time has already set out the case for the IMCr - I know of no better judge.
Would you also like to set out your credentials. You appear to be soliciting opinion and formulating a defence of the EIR - what is your interest?
My interest is already on record.
Last edited by Fuji Abound; 6th Sep 2009 at 21:14.
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In my opinion, the critical point that has been missed is a robust analysis of the actual use of the IMC and motivations / intentions of the people who get and hold it. Without any decent data of this ilk, everyone is largely talking from opinion and we can only rely on a feeling that the original IMC 'requirement' remains valid and is satisfied by the current IMCR. The AOPA survey was a brilliant opportunity to tackle this, but with no results out I fear it could be too late to influence the debate and I struggle to understand what 'requirement' the FCL008 committee are working towards satisfying.
Again in my opinion as an FI, I reckon 80-90% of the people who get the IMCR want it for the skills to go flying in poorer vis [than they would fly in with a vanilla PPL], to get up on top of broken cloud layers and for the confidence that they can get down safely if they end up in IMC. It is my third point that has really attracted every IMCR holder I have ever known. Indeed, on many PPL [non IMC holding] checkouts and currency checks I get people asking to try an SRA or ILS for the experience.
I bet if we lose the IMCR and end up with the EIR, people will not bother with the EIR and we will see unofficial IMC 'courses' spring up where people can experience some IAP tuition with an FI for emergency use only.
Again in my opinion as an FI, I reckon 80-90% of the people who get the IMCR want it for the skills to go flying in poorer vis [than they would fly in with a vanilla PPL], to get up on top of broken cloud layers and for the confidence that they can get down safely if they end up in IMC. It is my third point that has really attracted every IMCR holder I have ever known. Indeed, on many PPL [non IMC holding] checkouts and currency checks I get people asking to try an SRA or ILS for the experience.
I bet if we lose the IMCR and end up with the EIR, people will not bother with the EIR and we will see unofficial IMC 'courses' spring up where people can experience some IAP tuition with an FI for emergency use only.
Fuji,
I find your example of changing TAFs quite common. A few weeks ago I went to Shoreham. The TAFs showed something like BKN012 but BECMG SCT020 before I got there, and continuing to improve all day. It was similar all over the S East, and I had no reason to doubt the TAFs. When I got there (less than 2 hours later) it was OVC007. According to the plate, the MSA for the 25nm circle round Shoreham is 2100.
Nuff said?
I find your example of changing TAFs quite common. A few weeks ago I went to Shoreham. The TAFs showed something like BKN012 but BECMG SCT020 before I got there, and continuing to improve all day. It was similar all over the S East, and I had no reason to doubt the TAFs. When I got there (less than 2 hours later) it was OVC007. According to the plate, the MSA for the 25nm circle round Shoreham is 2100.
Nuff said?
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You still don't seem to have grasped the point that IMCR holders neither expect to fly to 'IR minima', nor wish to. The training for the IMCR to fly to IMCR minima is entirely proportionate, as 40 years of practical experience has conclusively proved
Fuji,
In another thread in another place I gave an example of a flight of less than an hour
The EIR as proposed by you is not based on a sound safety case (if it is please set out the case for us all)
The person who dreamed up this lunatic idea considers that there should be 'almost certain' VFR conditions for take-off and landing (whatever that means), so the EIR holder can then go and play airliners without being concerned about going IMC in the cruise.
AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR and has asked IAOPA to tell the FCL.008 group that the UK advocate of this EIR does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.
AOPA does not consider this Chocolate Teapot Rating to be in any way a suitable alternative to the UK IMCR and has asked IAOPA to tell the FCL.008 group that the UK advocate of this EIR does not have the support of the UK GA fraternity - he speaks for himself and for no-one else.
When and if the EIR is proposed by EASA I guess we'll all have a basis to judge whether its safe or dangerous or useful or useless. Of course, apart from those who've already made their minds up before anything detailed or final has been published.
Would you also like to set out your credentials. You appear to be soliciting opinion and formulating a defence of the EIR - what is your interest?
brgds
421C
I have shown you, 421C, that a UK member of FCL.008 admitted guilt for having proposed this Chocolate Teapot Rating nonsense - and no-one else who has posted on this thread has supported it.
You were trying to defend the indefensible. Quite why, I do not know, since the EIR proposal has been supported by no-one apart from this one FCL.008 member - whose opinion must be considered his and his alone and not the consensus view of the wider UK GA fraternity.
You were trying to defend the indefensible. Quite why, I do not know, since the EIR proposal has been supported by no-one apart from this one FCL.008 member - whose opinion must be considered his and his alone and not the consensus view of the wider UK GA fraternity.
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Pilots can get caught out by weather worse than forecast.
It demonstrates that instrument rated pilots very rarely get caught out by the weather going below minima but they would get caught out by this type of artificial minima.
In my experience IMC rated pilots, and indeed the majority of IR rated pilots, when flying GA type aircraft do not "push" the minima. I cant think of a single occasion when I have arrived and the ILS has been below minima. Indeed it is rare to find these conditions on days (note days) on which GA pilots typically fly.
I also cant think of a single accident involving an IMC rated pilot during the approach segement of a flight but I can think of many involving pilots with an IR. Whatever IMC rated pilots are doing they seem to have developed a pretty good means of flying approaches to the same minima as pilots with an instrument rating. Given the population of GA IMC rated pilots in the UK is more than 10 times the size of those pilots with an instrument rating they would seem to be doing a pretty good job.
What evidence do you have they are not?
I am sorry to keep referring to evidence, but it seems to me this is the crux of the issue. Those seeking change HAVE NO EVIDENCE to support the changes they seek. I am happy to accept change if there is good reason, but change for change sake is a very bad idea.
I wouldn't.
Moreover for all we know you might be "representing" one of those arguing for the adoption of the EIR? If you are you should have the courage to nail your colours to the mast.
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The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.
Most of the posts here do not reflect the actual situation and so we have the argument revolving about the ability of a chocolate tea pot to hold ice cold tea.
"Saving" the IMC Rating is a very bad point to pitch. The idea that it is essential to private GA operations in the UK and even if EASA does not agree, the UK should be able to keep it just for UK pilots gets countered by the fact that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence. Is it an essential safety requirement or not? Make up your mind. Don't ask people to accept something that you won't do yourself.
The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc
Someone said that the IMC rating was essentail because it made it safer for the pilot who accidently enters IMC. They claimed that the enroute proposal would kill them. How? Can't they both complete a 180 degree turn and fly back to VMC? Why would the holder of an enroute rating be less likely to retain control in IMC compared to an IMC rating holder?
More and more, people arguing in favour of the IMC rating are assisting those that do not like the idea. They are doing this through lack of knowledge of how other countries approach safe VFR flying.
In many other countries Marginal VFR is cloud between 1000 and 3000ft and visibility between 5K and 8K. For most people in the UK they will say that in that case they fly in marginal VFR for most of the year. However, when looking at the proposal look at what other countries call good VFR conditions - 3000ft and 8K+.
Under ICAO and most other country's requirements one can not commence a VFR flight unless it is VMC all the way to destination. Would all those that jump up at this point and say "that would ground us on most days and what is wrong with a look see" think for a moment what that attitude says to other countries - countries you are relying on to get this qualification.
The whole argument about the French requirement for a Mountain Rating disdplays what is wrong with those putting forward arguments to "save the rating". Everyone needs to understand the vast difference between a country having a requirement for pilots to hold a rating to do something compared to a national rating. The requirment to hold a mountain rating is a national issue - France may require it while Italy may not. However, the ability to add a mountain rating to any EASA licence is not a national issue and there should be nothing stopping an appropriately qualified German instructor teaching a Spanish pilot for the rating and having it included on a licence issued in the UK so that the pilot can use it in France (where it is required).
As for the proposed conpromise. Most commentators here do not seem to understand the principles involved.
Most non-UK countries permit VFR flight out of sight of the surface without any extra requirements. Some palces have VFR over the top ratings.
However, the proposed rating is not designed to enable VFR on top or replace that ability. Pilots without the rating will still be able to operate VFR on top. The rating entitles the pilot to fly continuously in IMC while enroute. There is no requirement for a "hole in the cloud" at the start or at the end. The cloud can be solid from 3000ft to 30,000ft. The overriding principle is that VFR conditions must exist at departure and destination. Everyone here talking of the problems with a TAF showing cloud at the MSA and the pilot arriving at MSA only to find that they are still IMC, have not taken into account the fact that according to many countries cloud below 3000ft is marginal VMC and cloud below 1000ft is IMC.
In the UK one is never far from an aerdrome included on the Volmet. Using that element of the FIS on it's own provides the pilots the ability to ensure that weather conditions are not vastly different from what they expected. The Shoreham example again plays into the hands of those opposed to the IMC rating. An aerodrome close to the sea and someone is surprised that the cliund could be low and visibility poor? Even the Frenach post warnings for Le Touquet etc about such happenings and pilots select alternate aerodromes well inland.
The discipline in the instrument pilot revolves to a large expent around the ability to set minima and adhere to them. If they are 300ft or 3000ft, it makes no difference. If they are 1800m or 8000m makes no difference. One adheres to the minima or stays on the ground. The cround that jumps up at this point and says that would ground us for most of the year have to be asked would it? Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?
As I see it the proposals are very simnple;
PPL - VFR - limited to VFR conditions at all times. Can fly VFR on top.
PPL with Enroute IMC - Limited to VFR arrival and departure. Can file and fly IFR (IMC) enroute regardless of airspace.
IR - Can fly IFR departure to arrival.
The argument that having to operate with minima of 3000ft and 8K would do nothing for most pilots who fly at 2000 to 2500ft ignores the fact that the UK system where VFR pilots rarely climb above 3000ft is at odds with many other country's desired method of operation.
The UK airspace limits VFR operations in the FL60 to FL115 band. However, everyone needs to be aware of what the future holds for European Airspace before being able to put up a convincing argument.
Should the UK retain the IMC rating - as an addition to an NPPL - what happens a few years later when European airspace proposals sound the end for non-IR qualified pilots in controlled airspace?
Serious proposals for an "IMC"-like rating have to take into account who the holders of such ratings are going to be and just as importantly (but forgotten by many) what type of equipment will they be using.
Let's have EASA grant an IMC rating to all. Then require a flight plan for all IFR flights and all IFR flights to have mode S and BRNAV. So suddenly the rating issue has gone - the equipment issue is nothing new - but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.
Is that what you really want?
Bren.
Most of the posts here do not reflect the actual situation and so we have the argument revolving about the ability of a chocolate tea pot to hold ice cold tea.
"Saving" the IMC Rating is a very bad point to pitch. The idea that it is essential to private GA operations in the UK and even if EASA does not agree, the UK should be able to keep it just for UK pilots gets countered by the fact that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence. Is it an essential safety requirement or not? Make up your mind. Don't ask people to accept something that you won't do yourself.
The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc
Someone said that the IMC rating was essentail because it made it safer for the pilot who accidently enters IMC. They claimed that the enroute proposal would kill them. How? Can't they both complete a 180 degree turn and fly back to VMC? Why would the holder of an enroute rating be less likely to retain control in IMC compared to an IMC rating holder?
More and more, people arguing in favour of the IMC rating are assisting those that do not like the idea. They are doing this through lack of knowledge of how other countries approach safe VFR flying.
In many other countries Marginal VFR is cloud between 1000 and 3000ft and visibility between 5K and 8K. For most people in the UK they will say that in that case they fly in marginal VFR for most of the year. However, when looking at the proposal look at what other countries call good VFR conditions - 3000ft and 8K+.
Under ICAO and most other country's requirements one can not commence a VFR flight unless it is VMC all the way to destination. Would all those that jump up at this point and say "that would ground us on most days and what is wrong with a look see" think for a moment what that attitude says to other countries - countries you are relying on to get this qualification.
The whole argument about the French requirement for a Mountain Rating disdplays what is wrong with those putting forward arguments to "save the rating". Everyone needs to understand the vast difference between a country having a requirement for pilots to hold a rating to do something compared to a national rating. The requirment to hold a mountain rating is a national issue - France may require it while Italy may not. However, the ability to add a mountain rating to any EASA licence is not a national issue and there should be nothing stopping an appropriately qualified German instructor teaching a Spanish pilot for the rating and having it included on a licence issued in the UK so that the pilot can use it in France (where it is required).
As for the proposed conpromise. Most commentators here do not seem to understand the principles involved.
Most non-UK countries permit VFR flight out of sight of the surface without any extra requirements. Some palces have VFR over the top ratings.
However, the proposed rating is not designed to enable VFR on top or replace that ability. Pilots without the rating will still be able to operate VFR on top. The rating entitles the pilot to fly continuously in IMC while enroute. There is no requirement for a "hole in the cloud" at the start or at the end. The cloud can be solid from 3000ft to 30,000ft. The overriding principle is that VFR conditions must exist at departure and destination. Everyone here talking of the problems with a TAF showing cloud at the MSA and the pilot arriving at MSA only to find that they are still IMC, have not taken into account the fact that according to many countries cloud below 3000ft is marginal VMC and cloud below 1000ft is IMC.
In the UK one is never far from an aerdrome included on the Volmet. Using that element of the FIS on it's own provides the pilots the ability to ensure that weather conditions are not vastly different from what they expected. The Shoreham example again plays into the hands of those opposed to the IMC rating. An aerodrome close to the sea and someone is surprised that the cliund could be low and visibility poor? Even the Frenach post warnings for Le Touquet etc about such happenings and pilots select alternate aerodromes well inland.
The discipline in the instrument pilot revolves to a large expent around the ability to set minima and adhere to them. If they are 300ft or 3000ft, it makes no difference. If they are 1800m or 8000m makes no difference. One adheres to the minima or stays on the ground. The cround that jumps up at this point and says that would ground us for most of the year have to be asked would it? Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?
As I see it the proposals are very simnple;
PPL - VFR - limited to VFR conditions at all times. Can fly VFR on top.
PPL with Enroute IMC - Limited to VFR arrival and departure. Can file and fly IFR (IMC) enroute regardless of airspace.
IR - Can fly IFR departure to arrival.
The argument that having to operate with minima of 3000ft and 8K would do nothing for most pilots who fly at 2000 to 2500ft ignores the fact that the UK system where VFR pilots rarely climb above 3000ft is at odds with many other country's desired method of operation.
The UK airspace limits VFR operations in the FL60 to FL115 band. However, everyone needs to be aware of what the future holds for European Airspace before being able to put up a convincing argument.
Should the UK retain the IMC rating - as an addition to an NPPL - what happens a few years later when European airspace proposals sound the end for non-IR qualified pilots in controlled airspace?
Serious proposals for an "IMC"-like rating have to take into account who the holders of such ratings are going to be and just as importantly (but forgotten by many) what type of equipment will they be using.
Let's have EASA grant an IMC rating to all. Then require a flight plan for all IFR flights and all IFR flights to have mode S and BRNAV. So suddenly the rating issue has gone - the equipment issue is nothing new - but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.
Is that what you really want?
Bren.
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Beagle
If this is true, then why on earth are you worried about it? It will never get through FCL008 or any other rulemaking. End of story.
Fuji,
In which case your point is not relevant to what I was saying. I wasn't saying that instrument rated pilots often get caught out by weather minima. I was saying exactly what you are saying - that both VFR and IFR pilots are able operate safely despite the inherent uncertainty in weather forecasts.
It's not an "artificial minima". It's the same kind of planning every non-UK PPL is exposed to every time they venture VFR on top, out of sight of the surface. The forecast weather has to indicate that they will be able to get back down again in VMC.
Show me the studies and evidence of PPLs with VMC-on-top privileges "caught out" by not being able to descend to land VMC. There are hundreds of thousands of them in the USA. If it is so utterly fraught with risk and danger, there must be evidence in the US. If it is anything like as risky and dangerous as you say, there must be articles, advisory circulars, NTSB reports all supporting the dangers you are so convinced of.
I am not saying that IMCr pilots are not doing a good job. In fact I am agreeing with you that they do a good job. My point is that if they can be trained to do such a good job on IFR approaches in the IMCr, then why couldn't EIR holders be trained to safely handle an IFR approach in the event of the emergency situation created by weather being systematically worse than forecast.
That's my only point on this, in reply to the specific argument that the EIR must be 'thoroghly dangerous' because EIR holders might end up caught out by unexpectedly worse weather.
I am happy for whatever points I make to be judged, ignored, disagreed with, or whatever, on their own merits or lack of. If you want a forum where people should declare their quals before they venture an opinion, then my impression is that PPRUNE isn't the one. If those are your rules for engaging in a discussion, then I will understand why you won't want to continue this one.
Well, I'm not. I am doing what I think this forum is intended for. I read it and I have an opinion. I post that. We exchange replies.
I am happy to be guided by the moderators if there is some special rule about replying to you, or posting on this particular topic. Or for that matter, if I should stop posting because I am outnumbered by posters with opinions different from my own.
The crux of what issue? I am sorry, but I am confused by some of your replies. I sense you are writing in reply to points you want someone to have made, so you can wheel out your reply. But the problem is no-one is making those points.
What is the change "they" are seeking and have no evidence for? If it is the "abolition of the IMCr" then no-one is seeking a change; unless it is a change that has already happened when a) the EU gave EASA powers over FCL and b) EASA published the FCL NPA without an IMCr in it.
If the "change" is the introduction of the EIR, then my understanding is that this is a concept or early stage proposal - in fact, if Beagle is right, it is nothing at all except the workings of a lone person unsupported by any other stakeholder or FCL008 member. Nevertheless, the concept can be discussed in principle, which is what we are doing.
brgds
421C
the EIR proposal has been supported by no-one apart from this one FCL.008 member - whose opinion must be considered his and his alone
Fuji,
That is not the point it demonstrates.
It demonstrates that instrument rated pilots very rarely get caught out by the weather going below minima but they would get caught out by this type of artificial minima
It demonstrates that instrument rated pilots very rarely get caught out by the weather going below minima but they would get caught out by this type of artificial minima
they would get caught out by this type of artificial minima.
Show me the studies and evidence of PPLs with VMC-on-top privileges "caught out" by not being able to descend to land VMC. There are hundreds of thousands of them in the USA. If it is so utterly fraught with risk and danger, there must be evidence in the US. If it is anything like as risky and dangerous as you say, there must be articles, advisory circulars, NTSB reports all supporting the dangers you are so convinced of.
In my experience IMC rated pilots, and indeed the majority of IR rated pilots, when flying GA type aircraft do not "push" the minima. I cant think of a single occasion when I have arrived and the ILS has been below minima. Indeed it is rare to find these conditions on days (note days) on which GA pilots typically fly.
I also cant think of a single accident involving an IMC rated pilot during the approach segement of a flight but I can think of many involving pilots with an IR. Whatever IMC rated pilots are doing they seem to have developed a pretty good means of flying approaches to the same minima as pilots with an instrument rating. Given the population of GA IMC rated pilots in the UK is more than 10 times the size of those pilots with an instrument rating they would seem to be doing a pretty good job.
What evidence do you have they are not?
I also cant think of a single accident involving an IMC rated pilot during the approach segement of a flight but I can think of many involving pilots with an IR. Whatever IMC rated pilots are doing they seem to have developed a pretty good means of flying approaches to the same minima as pilots with an instrument rating. Given the population of GA IMC rated pilots in the UK is more than 10 times the size of those pilots with an instrument rating they would seem to be doing a pretty good job.
What evidence do you have they are not?
That's my only point on this, in reply to the specific argument that the EIR must be 'thoroghly dangerous' because EIR holders might end up caught out by unexpectedly worse weather.
That is a problem. Your argument has little creditability without
Moreover for all we know you might be "representing" one of those arguing for the adoption of the EIR? If you are you should have the courage to nail your colours to the mast.
I am happy to be guided by the moderators if there is some special rule about replying to you, or posting on this particular topic. Or for that matter, if I should stop posting because I am outnumbered by posters with opinions different from my own.
I am sorry to keep referring to evidence, but it seems to me this is the crux of the issue. Those seeking change HAVE NO EVIDENCE to support the changes they seek. I am happy to accept change if there is good reason, but change for change sake is a very bad idea.
What is the change "they" are seeking and have no evidence for? If it is the "abolition of the IMCr" then no-one is seeking a change; unless it is a change that has already happened when a) the EU gave EASA powers over FCL and b) EASA published the FCL NPA without an IMCr in it.
If the "change" is the introduction of the EIR, then my understanding is that this is a concept or early stage proposal - in fact, if Beagle is right, it is nothing at all except the workings of a lone person unsupported by any other stakeholder or FCL008 member. Nevertheless, the concept can be discussed in principle, which is what we are doing.
brgds
421C
Last edited by 421C; 7th Sep 2009 at 12:52.
Brendan,
I think I understand all the words you are using, but it's the sentences that are giving me trouble. Much of what you say doesn't make much sense to me, and what I do understand I disagree with.
This is what gives the UK Independence Party growing support in Britain. I used to be an enthusiastic European supporter, but it's this grinding down to the lowest common denominator. Europe should be about enabling, but it's actually constricting. What should be a liberal ideal is an illiberal bureaucracy.
Why?
No one is saying it's essential. It's just a very good idea, and increases safety.
As I say, this is a misrepresentation of what people are saying, so this point doesn't follow.
Not relevant. The point is that most of the time you can't rely on cloud base above MSA, so you need the safety net of the ability to divert to a field with an instrument approach, and the ability to use it.
No, not essential but a useful aid to safety
That point is valid, but doesn't alter the main points made on this thread.
I really don't follow this. We're not trying for force other countries to do anything - it's other people trying to force us to do something (get rid of the IMC Rating) that we're upset about.
What people do or do not do in VFR is very interesting, but I don't see the relevance to an IMC Rating.
You'll have to forgive me, I don't understand the bureaucratic implications of what you are saying. I sounds gobbledygook to me. We should be starting with what we want to achieve, and writing rules around that. It sounds as though we're doing the other way round. "You can't do it because of the rules." Well, if the rules don't allow it, change the rules. This is the tail wagging the dog.
Sorry, can't see the relevance.
Have you flown in the UK? That simply isn't true.
Perhaps you missed my point, or are you saying that no one should ever assume VMC at a coastal airport? The point I am trying to make is that flying with an en-route IMC qualification but no ability to fly an instrument approach if necessary would very severely limit the occasions on which one can safely fly IMC in the UK.
This is true, but misses the point. Of course all sensible pilots fly within sensible limits. This is about extending those (safe and sensible) limits by a considerable degree.
As I see it the proposals are very simnple;
PPL - VFR - limited to VFR conditions at all times. Can fly VFR on top.
PPL with Enroute IMC - Limited to VFR arrival and departure. Can file and fly IFR (IMC) enroute regardless of airspace.
IR - Can fly IFR departure to arrival.
The argument that having to operate with minima of 3000ft and 8K would do nothing for most pilots who fly at 2000 to 2500ft ignores the fact that the UK system where VFR pilots rarely climb above 3000ft is at odds with many other country's desired method of operation.
The UK airspace limits VFR operations in the FL60 to FL115 band. However, everyone needs to be aware of what the future holds for European Airspace before being able to put up a convincing argument.
Should the UK retain the IMC rating - as an addition to an NPPL - what happens a few years later when European airspace proposals sound the end for non-IR qualified pilots in controlled airspace?
Serious proposals for an "IMC"-like rating have to take into account who the holders of such ratings are going to be and just as importantly (but forgotten by many) what type of equipment will they be using.
Let's have EASA grant an IMC rating to all. Then require a flight plan for all IFR flights and all IFR flights to have mode S and BRNAV. So suddenly the rating issue has gone - the equipment issue is nothing new - but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.
Is that what you really want?
Bren.
I'm sorry if you feel insulted by my comments, and I don't mean it personally, but as you can tell I feel quite angry about this. We feel let down. We have a perfectly workable rating in the UK that increases the ability of PPLs to fly, enhances safety and increases skill.
What we see is a lot of bureaucratic nonsense and intolerant people telling us we can't do it, just because other people in other countries don't want it. So what? Why should that stop us doing it? Don't tell me, I know the answer.
I think I understand all the words you are using, but it's the sentences that are giving me trouble. Much of what you say doesn't make much sense to me, and what I do understand I disagree with.
The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.
"Saving" the IMC Rating is a very bad point to pitch.
The idea that it is essential to private GA operations in the UK and even if EASA does not agree...
...the UK should be able to keep it just for UK pilots gets countered by the fact that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence. Is it an essential safety requirement or not? Make up your mind. Don't ask people to accept something that you won't do yourself.
The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc
Someone said that the IMC rating was essentail...
...because it made it safer for the pilot who accidently enters IMC. They claimed that the enroute proposal would kill them. How? Can't they both complete a 180 degree turn and fly back to VMC? Why would the holder of an enroute rating be less likely to retain control in IMC compared to an IMC rating holder?
More and more, people arguing in favour of the IMC rating are assisting those that do not like the idea. They are doing this through lack of knowledge of how other countries approach safe VFR flying.
In many other countries Marginal VFR is cloud between 1000 and 3000ft and visibility between 5K and 8K. For most people in the UK they will say that in that case they fly in marginal VFR for most of the year. However, when looking at the proposal look at what other countries call good VFR conditions - 3000ft and 8K+.
Under ICAO and most other country's requirements one can not commence a VFR flight unless it is VMC all the way to destination. Would all those that jump up at this point and say "that would ground us on most days and what is wrong with a look see" think for a moment what that attitude says to other countries - countries you are relying on to get this qualification.
Under ICAO and most other country's requirements one can not commence a VFR flight unless it is VMC all the way to destination. Would all those that jump up at this point and say "that would ground us on most days and what is wrong with a look see" think for a moment what that attitude says to other countries - countries you are relying on to get this qualification.
The whole argument about the French requirement for a Mountain Rating disdplays what is wrong with those putting forward arguments to "save the rating". Everyone needs to understand the vast difference between a country having a requirement for pilots to hold a rating to do something compared to a national rating. The requirment to hold a mountain rating is a national issue - France may require it while Italy may not. However, the ability to add a mountain rating to any EASA licence is not a national issue and there should be nothing stopping an appropriately qualified German instructor teaching a Spanish pilot for the rating and having it included on a licence issued in the UK so that the pilot can use it in France (where it is required).
As for the proposed conpromise. Most commentators here do not seem to understand the principles involved.
Most non-UK countries permit VFR flight out of sight of the surface without any extra requirements. Some palces have VFR over the top ratings.
However, the proposed rating is not designed to enable VFR on top or replace that ability. Pilots without the rating will still be able to operate VFR on top. The rating entitles the pilot to fly continuously in IMC while enroute. There is no requirement for a "hole in the cloud" at the start or at the end. The cloud can be solid from 3000ft to 30,000ft. The overriding principle is that VFR conditions must exist at departure and destination. Everyone here talking of the problems with a TAF showing cloud at the MSA and the pilot arriving at MSA only to find that they are still IMC, have not taken into account the fact that according to many countries cloud below 3000ft is marginal VMC and cloud below 1000ft is IMC.
Most non-UK countries permit VFR flight out of sight of the surface without any extra requirements. Some palces have VFR over the top ratings.
However, the proposed rating is not designed to enable VFR on top or replace that ability. Pilots without the rating will still be able to operate VFR on top. The rating entitles the pilot to fly continuously in IMC while enroute. There is no requirement for a "hole in the cloud" at the start or at the end. The cloud can be solid from 3000ft to 30,000ft. The overriding principle is that VFR conditions must exist at departure and destination. Everyone here talking of the problems with a TAF showing cloud at the MSA and the pilot arriving at MSA only to find that they are still IMC, have not taken into account the fact that according to many countries cloud below 3000ft is marginal VMC and cloud below 1000ft is IMC.
In the UK one is never far from an aerdrome included on the Volmet. Using that element of the FIS on it's own provides the pilots the ability to ensure that weather conditions are not vastly different from what they expected.
The Shoreham example again plays into the hands of those opposed to the IMC rating. An aerodrome close to the sea and someone is surprised that the cliund could be low and visibility poor? Even the Frenach post warnings for Le Touquet etc about such happenings and pilots select alternate aerodromes well inland.
The discipline in the instrument pilot revolves to a large expent around the ability to set minima and adhere to them. If they are 300ft or 3000ft, it makes no difference. If they are 1800m or 8000m makes no difference. One adheres to the minima or stays on the ground. The cround that jumps up at this point and says that would ground us for most of the year have to be asked would it? Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?
As I see it the proposals are very simnple;
PPL - VFR - limited to VFR conditions at all times. Can fly VFR on top.
PPL with Enroute IMC - Limited to VFR arrival and departure. Can file and fly IFR (IMC) enroute regardless of airspace.
IR - Can fly IFR departure to arrival.
The argument that having to operate with minima of 3000ft and 8K would do nothing for most pilots who fly at 2000 to 2500ft ignores the fact that the UK system where VFR pilots rarely climb above 3000ft is at odds with many other country's desired method of operation.
The UK airspace limits VFR operations in the FL60 to FL115 band. However, everyone needs to be aware of what the future holds for European Airspace before being able to put up a convincing argument.
Should the UK retain the IMC rating - as an addition to an NPPL - what happens a few years later when European airspace proposals sound the end for non-IR qualified pilots in controlled airspace?
Serious proposals for an "IMC"-like rating have to take into account who the holders of such ratings are going to be and just as importantly (but forgotten by many) what type of equipment will they be using.
Let's have EASA grant an IMC rating to all. Then require a flight plan for all IFR flights and all IFR flights to have mode S and BRNAV. So suddenly the rating issue has gone - the equipment issue is nothing new - but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.
Is that what you really want?
Bren.
What we see is a lot of bureaucratic nonsense and intolerant people telling us we can't do it, just because other people in other countries don't want it. So what? Why should that stop us doing it? Don't tell me, I know the answer.
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The problem is that any reasonable argument for retaining the IMC rating has to take into account the position of the people who make up that majority. Unfortunately, like it or not, the UK is a minority part of EASA and consequently for any proposal to suceed it needs support from other members.
EASA are considering a sub ICAO IR – call it what you will. The IMCr is just that. The proposed EIR is also just that. Since a sub ICAO IR is on the cards the issue is not whether the member states agree to adopt one, but the form it will take. How has that form been reached? By all means let’s have a discussion about the evidence on which the Commission has relied. Doubtless proper studies have been commissioned? Presumably the Commission has evidence that demonstrates there is a higher accident rate among IMCr pilots whilst flying the approach. Why is it every time the discussion turns to hard evidence most advocates go very quite?
that pilots of SSEA aircraft holding a UK NPPL can not add an IMC rating to that licence.
They can’t add an IR either. It might just be something to do with the reduced medical – do you think?
The UK data shows that the majority of GA operators fly from VFR aerodromes. How many diversions to aerodromes where an Instrument Approach procedure was required were made by IMCrating holders from say.....Popham or Blackbushe or Rochester or White Waltham etc
Nonsense. The majority of IR holders do exactly the same. Consider for just one minute how much time the average IR holders spends on instruments and how much they spend flying visually.
Is the method of deriving the safe minima based on being able to get airborne or to ensure a safe operation - for all?
Please point us to the evidence that indicates the existing minima for IMCr holders is unsafe. Unless you have evidence its just words – you can set whatever minima you like and of course everyone can adhere to those minima, but they mean nothing. Minima exist to protect the pilot because the EVIDENCE shows that for a pilot that is current descending below the minima is unsafe. If the pilot is not current he should revise his minima – it matters not what name appears on his rating.
but the ability of the Club pilot from Popham to pop up through a layer and do some aeros on top before descending back down again is gone.
And do you imagine that is not exactly what they already do, rating or not, or what they will continue to do. After all I wonder if EASA is about to stop gliders flying in or near cloud.
En route IFR is a serious business. I see nothing wrong in ensuring those that do it are adequately equipped – that seems to me a far more reasonable safety concern.
As a barrister told me there are only three things that should count in determining a case:
EVIDENCE, EVIDENCE, EVIDENCE.
So lets see it - otherwise it is all hot air.
EASA can do what they like for all the wrong reasons, if they do they are not fit for purpose, it will not stop them - I know that, but it is no less lamentable.
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Two comments sum the entire thing up for me.
As has been pointed out, EASA WANT a sub-IR rating. No other country in EASA has had one up to now AFAIK.
We have one. It works very well. It is good training for PPL pilots, and is a good second step after PPL issue. WTF is wrong with EASA using the same spec? Why do we have to ditch a perfectly good rating and substitute an EIR which (in the opinion of at least a significant minority, if not a majority) is not fit for purpose, does not achieve what is wanted, and will possibly erode safety? Let's face it - the IMCr has proven very useful, very safe. If it ain't broke, don't fix it. And don't substitute it for something that might well break very quickly.
We have a perfectly workable rating in the UK that increases the ability of PPLs to fly, enhances safety and increases skill.
EASA are considering a sub ICAO IR – call it what you will. The IMCr is just that. The proposed EIR is also just that. Since a sub ICAO IR is on the cards the issue is not whether the member states agree to adopt one, but the form it will take.
We have one. It works very well. It is good training for PPL pilots, and is a good second step after PPL issue. WTF is wrong with EASA using the same spec? Why do we have to ditch a perfectly good rating and substitute an EIR which (in the opinion of at least a significant minority, if not a majority) is not fit for purpose, does not achieve what is wanted, and will possibly erode safety? Let's face it - the IMCr has proven very useful, very safe. If it ain't broke, don't fix it. And don't substitute it for something that might well break very quickly.