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EIR, IMC rating and Jim Thorpe

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Old 9th Nov 2009, 16:01
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Actually DP, I was just reflecting on how those behaving maliciously often get caught out out in there keenness to share tit bits with others. That was an extract from a personal message written about me that the recipient forwarded to me as well as the mods in disgust.

Assuming that the enemy of your enemy is your friend is often a dangerous one to make.........
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Old 9th Nov 2009, 16:13
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Sorry Bose.

As that wasn't an extract from a pm you received, I'll delete the post and hereby apologise to you

We don't always agree on stuff, but that doesn't make you my enemy Enough of people say nice stuff about you, so I assume you're actually a nice bloke

dp
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Old 9th Nov 2009, 17:29
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For one moment let’s examine the evidence, and forget what may or may not be commercially or politically desirable – it isn’t a bad place to start.

Before the IMC rating pilots flew in cloud – there was no cloud rating. However it became clear some training was required in order to enable pilots to fly safely in cloud – the IMC rating was born.

Fact: In over forty years there have been almost no accidents involving pilots with an IMC rating in IMC. That would suggest, in what ever way pilots are using the rating, they are doing a remarkably good job of managing the risks.

Fact: There have been far more accidents in the last five years in the UK and Europe involving private pilots with an IR than those with an IMC rating. That would suggest that however you cut it IMCr holders do a much better job of managing the risks than pilots with an IR.

The very best test we have in aviation of almost anything is the test of time. Theilert engines were happily certified by EASA – time proved they were rubbish.

The IMC rating has stood the test of time.

Some say the training is inadequate to enable pilots to safely fly approaches in IMC. Some say IMC holders rarely fly approaches in IMC.

Fact: There has never been an accident involving a pilot flying an approach in IMC. That would suggest either IMC holders never fly approaches in IMC – which I know not to be true if only because I have over 100 approaches in my log book in IMC of which a reasonable number were to minima, or that as a population they manage the risk better than pilots with an IR.

Fact. Since the introduction of the IMC rating the training of pilots has improved significantly, aircraft have become more reliable and better equipped. That would suggest it is easier to do a good job in IMC these days than it was say twenty years ago.

So let’s see – we have developed over time a rating that has proved to be VERY safe, popular and clearly that meets the requirements of most private pilots in the UK, given that those who want to fly airways have always had the option of an IR.

There is another long standing life rule: if it isn’t broken, don’t fix it. The only reason we are fixing the IMC rating is political. There IS no evidence it is UNSAFE. More importantly, of the various proposals that have been discussed there is no evidence that ANY of these proposals are safe. Where are the studies? Where are the regulatory impact assessments?

What may or may not be politically acceptable is one thing – but don’t kid yourself there is anything “wrong” with the IMC rating it has stood the best test we have. Be in no doubt none of the proposals on the table have been tested – in fact I am not aware there has been any quantitative study of any of the alternatives in European air space.
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Old 9th Nov 2009, 17:38
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The big two problems with this issue are that;

a) Many supporters of the UK IMC rating are ignoring the fact that if other countries thought it was a good idea or that it would make operations safer then they would have established a similar national rating a long time ago.

b) Very few people seem to have read and understood the proposal.
the proposal is not for a rating that will enable the pilot to climb through IMC to operate VFR on top. The purpose of the rating is to permit legal IFR flight enroute. i.e. VFR departure, IFR IMC enroute and VFR arrival.
The pilot with the EIR can be IFR IMC for hours on end - enroute.

Let me provide a little quote from the German AIP ENR 1.1

VFR Flights Above Cloud Layers

VFR flights above cloud layers are only permitted if

1. the flight is conducted at a height of at least 300 m (1000 ft)
above ground or water and flight visibility as well as distance
from clouds (§ 28 para 1) according to the values for Airspace
Class E (Attachment 5) are maintained;

2. the pilot is able to adhere to the intended route;

3. the approach to the destination aerodrome and the landing in
flight conditions in which VFR flights are permitted are guaranteed;

4. the pilot is licensed to conduct air-ground communication.
This is a well established procedure and it is entirely reasonable that a flight that will be counducted enroute in or above IMC would have the same requirements with regard the destination weather.

I have visited 3 flying schools in the UK who offer IMC Rating courses. In all 3 cases the aircraft were not certified for IFR flight. The answer was "we do the whole course VFR in VMC and thus avoid the requirement for FM immune radios". Most of the work they do is outside controlled airspace.

Most pilots completing the course do so to obtain the normal JAR-FCL PPL privileges i.e. VFR flight out of sight of the surface etc.

The opinion of the IR as being "Gold Plated" is a mindset unique to the UK.
Could the reasons for this be partly in the perception that it is for commercial pilots or that it is a weeding out of pilots going the commercial route or that it can't be done part time?
The CAA has a lot to answer for in this regard and has only managed to get away thus far with such absurd restrictions because of the availability of the IMC rating.

Don't forget that EASA will remove the unique UK system of handing out a PPL and then limiting the privileges. Thus much of the IMC training business will be removed because it is no oonger required.

I also visited some UK FTO's offering training for the IR. They were not interested in part time training. Some even incorrectly told me that it was not possible. All they are interested in is running a full time course because a) people are willing to do it and b) it makes it easier for the school.

The ability to do the PPL exams with your local club which is different to every other country puts PPLs in the mindset that having to adhere to an exam timetable and go to a central examination centre is operessive.
Who said that that UK system will survive EASA?

Elsewhere in Europe, part time IR training is very common. If one can take the time to do 60 odd hours VFR to get a PPL in one's spare time then having to do 40 hours in a sim (any weather any time) and 15 hours in an aircraft - not limited to VMC would be an easier prospect would it not?

Then the exams - Two pilots want to fly IFR from Amsterdam to Madrid. Are those pilots not entitled to expect that the other pilot they share the system with will have both the knowldge and skill to not just safely operate in the system but also to - as the German AIP puts it -

Each participant in air traffic shall act to guarantee that the
safety and order of air traffic are guaranteed and no other person is
endangered, injured or hampered, or bothered more than necessary
according to the circumstances.

Finally can those that want to keep the IMC as a national "opt out" please remember why JAR-FCL has not worked in terms of harmonisation and why the EU asked EASA to sort it out - i.e. properly harmonise. EASA may have tried to re-invent the wheel and has laterly decided that the timescale was ambitious but the programme remains the same with the exception that JAR-FCL will be the initial text until that is later changed into what has been proposed.

How can it be a " common market" is part of the market is not available to the majority of producers?

So forget trying to save a rating that the majority of the citizens don't want. Work to get the most out of a new rating that will increase the privileges of the majority of the citizens.

It would be quite ironic if the UK got to keep their IMC rating and the rest of Europe went the EIR way. French pilots happily cruising accross the top of Heathrow in the Airway at FL100 lapping up the sunshine while their UK friends scramble round at 2400ft in the weeds with all those "I may be in a cloud but I am VFR" pilots!!!!!
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Old 9th Nov 2009, 18:01
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You make some good points, Brendan Navigator, but a number I disagree with.

if other countries thought it was a good idea or that it would make operations safer then they would have established a similar national rating a long time ago.
That doesn't follow. If you flew "GA" around Europe a bit (as I have done) then you would quickly see that there is a lot of GA in the UK, Germany, France (though very little "touring") and then it gets very thin, with most of Europe having virtually no GA other than a very low microlight type of "sports" activity. By the time you get down to Greece (which, due to geography, would benefit hugely from GA) you are looking at 100-200 planes in the whole country.

So most European CAAs have close to zero interest in doing anything for their GA population. Many here accuse the UK CAA of not understanding GA (a view I don't think is correct) but the officials I've met from some foreign CAAs are on a different planet completely.

Germany would seem to be an exception but Germans are a conformist people and if you need an IR for something then a German will go and do it because the Govt says so. Well, to the extent that it remains practical, which is why the IR takeup over there is pretty small too.

France, as I said, does very little European touring. The reason I've been given by French and other pilots who don't have English as their 1st language, is that they are reluctant to leave their own country due to language issues. And indeed the touring pilots I have met while abroad have been mostly from countries which are either the UK or ones where English is spoken well (Germany, Belgium, Netherlands, Sweden, etc but not the more southern ones).

So the pressure is not there for any action. Hence the lack of support among most European CAAs which are packed with elitist ex ATP and ex military people.

3. the approach to the destination aerodrome and the landing in
flight conditions in which VFR flights are permitted are guaranteed;
Obviously this is a prerequisite for any VFR flight above an overcast (for a non-instrument licensed pilot) but I would like to know how [even] the Germans can guarantee the weather
Most pilots completing the course do so to obtain the normal JAR-FCL PPL privileges i.e. VFR flight out of sight of the surface etc.
I'd like to see the case study data which found the above. IMHO, most IMCR holders don't even know that it enables them to do that - hence the interminable forum threads on this very topic, over the years.

I think most people who do the IMCR do it genuinely for flying in IMC if necessary, and to fly approaches, etc, but they don't know (at the time) that the product is effectively being mis-sold: most being renters, they are unable to get their hands on a suitably equipped plane. But an awful lot of "products" are being mis-sold; I'd argue the whole PPL is being "mis-sold" because if you were totally up front about the utility of a standard PPL, most punters would walk away.

It would be quite ironic if the UK got to keep their IMC rating and the rest of Europe went the EIR way. French pilots happily cruising accross the top of Heathrow in the Airway at FL100 lapping up the sunshine while their UK friends scramble round at 2400ft in the weeds with all those "I may be in a cloud but I am VFR" pilots!!!!!
That would be hilarious. But I don't think it will quite work that way, to/from the UK, given a lot of UK weather.
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Old 9th Nov 2009, 18:44
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Originally Posted by Fuji Abound
For one moment let’s examine the evidence, and forget what may or may not be commercially or politically desirable – it isn’t a bad place to start.
Fact: In over forty years there have been almost no accidents involving pilots with an IMC rating in IMC. That would suggest, in what ever way pilots are using the rating, they are doing a remarkably good job of managing the risks.
There are at least 2 in the last 10 years in the UK, which is not dissimilar to IR holders (but with no information available on exposure)


Originally Posted by Fuji Abound
Fact: There have been far more accidents in the last five years in the UK and Europe involving private pilots with an IR than those with an IMC rating. That would suggest that however you cut it IMCr holders do a much better job of managing the risks than pilots with an IR.
This is false for the UK.

One would hope there are no accidents involving IMCr pilots flying in IMC outside the UK!

However, there is definitely an issue with instrument flight outside the UK. A number of incidents CFIT in mountainous areas have involved IR rated pilots based in the UK (and also the low countries).

The whole approach to IMCr flying in England benefits hugely from the country being flat and is another reason its applicability to much of Europe is limited.
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Old 9th Nov 2009, 18:59
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The whole approach to IMCr flying in England benefits hugely from the country being flat and is another reason its applicability to much of Europe is limited.
Not only that but it fits well with the lack of IFR enroute service outside Class A, which in turn fits well with the privatised ATC

In most of Europe, an "IMCR" would be equivalent to a full IR. For example in France one could fly up to FL200 or so, nearly everywhere. The only place with a lot of Class A is Italy.
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Old 9th Nov 2009, 19:15
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There are at least 2 in the last 10 years in the UK, which is not dissimilar to IR holders
Not according to the CAA - maybe they got it wrong! I have heard just this suggestion but have yet to have anyone point me in the direction of the accident report. Again fact or fiction? However, whether it is noen, one or two a remarkable safety record.

This is false for the UK.
Which is why I did not say for the UK.

It is also worth considering how many pilots have an IMC rating in the UK and how many PPLs have an IR. Now there is an interesting statistic particularly for those who want to debate the relative safety record of each population.

The whole approach to IMCr flying in England benefits hugely from the country being flat
You got to be joking! Are you sure that really is a rational point.

Many supporters of the UK IMC rating are ignoring the fact that if other countries thought it was a good idea or that it would make operations safer then they would have established a similar national rating a long time ago.
In the US well over half the private pilot population have an IR -an IR that is relevant to private operations. There is an excelelnt safety case for their approach and yet not a single European country has adopted a US style IR. Perhaps that best demonstrates the folly in your argument.

The opinion of the IR as being "Gold Plated" is a mindset unique to the UK.
Sorry, utter rubbish. Why do you think nearly everyone in Europe is flying on the N reg?

Two pilots want to fly IFR from Amsterdam to Madrid. Are those pilots not entitled to expect that the other pilot they share the system with will have both the knowldge and skill to not just safely operate in the system but also to - as the German AIP puts it -
Again this is just scare mungering. There is no evidence that IMCr holders have not operated safely in the same enviroment as IR holders. More to the point you had better mention this to the French with their Brevet de Bas - taken to your logical conclusion do I want to operate in the same air space as pilots who dont even have a PPL, or do I want to fly in the same airspace as NPPLs. If you take your argument there is no difference - they each have a lesser qualification in your eyes. Next you will be saying you dont want to be in the same enviroment as FAA IRs because their theoretical exams are less "gold plated" you had better let AA know.

So forget trying to save a rating that the majority of the citizens don't want
.. .. .. and your evidence for that spectacular assertion?
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Old 9th Nov 2009, 19:43
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This argument will be solved in a few years I am sure, but from my own point of view this is what I would like.....

If the ONLY choice was an IMC or EIR then I'd opt for the EIR - it'd give me access to the airways into Europe & UK, even on gin clear days.

A slightly better option would be for the EIR to be adopted and the UK to have a difference allowing current IMC privileges in the UK (i.e approaches into Class D)...though this is unlikely and probably unworkable as this would be the same privileges as the full IR in UK airspace.

Ideally the EIR would include a precision approach capability - that would suit me perfectly, I'm not too worried about shooting NPA's in bad weather, I'd either file to an ILS or "guarantee" the weather is VFR at destination.

I can see a whole host of problems with the EIR though - not least ATC responsibilities. How does one "guarantee" VFR conditions at destination, and what happens if it is not? How does this fit in with EuroATC and what is their responsibilities in this situation?

The UK has a lot of experience with PPL's flying IFR - much more than the rest of Euroland. One thing that both the US and UK realised a long time ago was that keeping private pilots away from Instruments had a detremental effect to air safety - part of the reason the FAA removed many of the IR training requirements many years ago and the CAA introduced the IMCr.

It does pi55 me off that there are two very good systems (CAA/FAA) which have been around many years yet Eurocrats just don't seem to want to listen to the advice and experience of these bodies, and insist yet again of re-inventing the wheel to a Eurostandard.

we shall see what happens....
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Old 9th Nov 2009, 19:52
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Englishal

Sanguine and sound as usual.

We shall indeed see - but we must be prepared for a "fight" if necessary.

It is all too easy to give away hard won priviliges, by simply doing nothing.
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Old 9th Nov 2009, 20:17
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Wait and see what hits the fan c. 2012 when the IMCR "gets" abolished.

Currently, the issue is not really hot. A lot of pilot forum bandwidth but maybe 2/10. In 2012 (or delayed as EASA FCL is likely to be, on current trends) it will be 10/10.

Abolition of the IMCR will be unworkable anyway, because everybody flying IFR in Class G will carry on doing so, with the only difference being that they won't be able to openly ask for an IAP so they will be arriving "VFR". Or maybe not even that, because the IMCR has been around for so long, and intra-UK flights have been done at sub-Eurocontrol levels by IRs/IMCRs for so long, that UK approach controllers have decades ago stopped wondering whether the pilot is IR or IMCR, and somebody asking for the IAP will just be assumed to be an IR. And it gets better: since a plain PPL can fly IFR in VMC, and since his actual flight conditions will be known only to him, provided he is visual by the time anybody can spot him (usually the case) no action will be possible.
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Old 9th Nov 2009, 20:32
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IFR to me is a full BRNAV airways capable machine.
Bose

What is your definition of fully BRNAV capable?
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Old 10th Nov 2009, 07:55
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we must be prepared for a "fight" if necessary.
I agree.

I also like to think the by posting on Pprune the strength of feeling gets across to the CAA as I believe that they do monitor these discussion boards. (so best not incriminate oneself or post videos of yourself flying under the Forth Road Bridge )

Hello CAA
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Old 10th Nov 2009, 09:53
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I cannot escape the feeling that in a few years this will be looked back on as being something of a non issue for UK pilots. There seems zero chance of the IMCR surviving into the brave new world of EASA FCL as other countries in Europe simply will not accept it. On the other hand, the up side may be en route IFR privileges and increased (for the UK) PPL minima.

GA is changing, probably 40 years too late, but it is changing. As the old C150/PA28 fleet is finally dumped by FTOs their replacement is in most cases likely to be new generation aircraft either fully certified or, more likely, certified to LSA/VLA standards, which will have a (slightly) more relaxed maintenance regime and will allow for PPL training but which will not be equipped for full IFR. Many more people post PPL will I believe go for Permit aircraft (there is a lot of evidence of this happening already). In this new world there is likely to be very little scope or demand for the fully certified IFR equipped aircraft.

None of this of course needs to prevent post PPL training for IMC flying as training aimed at enhancing pilot skills and safety. In fact, this could be insurance driven and perhaps the likes of the LAA or IOPA should give consideration to an suitable training syllabus and certificate rather like the AOPA aerobatics certificate (an aerial version of pass plus!) which could reduce the insurance premium. It does seem too much of the debate focuses on loss of privileges (used to their full extent by a minority, I suspect) and not enough of the inherent value in undergoing this sort of training.

Last edited by Justiciar; 10th Nov 2009 at 10:28.
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Old 10th Nov 2009, 10:13
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I would accept the principle of the EIR if, and only if, there was the option to add on subratings for different types of approach - PIR (either SRA or PAR). ILS, NDB, or even GPS. But the requirement for "virtually certain" VMC for the destination is ridiculous.

The extra training for an IMC is, IMHO, excellent discipline for the PPL who wants to improve his abilities, whether or not he actually uses the privileges associated with the rating. The UK IR is out of reach of most PPL holders and is really only of use (indeed, effectively essential) to a holder of a commercial licence (CPL or ATPL).
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Old 10th Nov 2009, 10:25
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In this new world their is likely to be very little scope or demand for the fully certified IFR equipped aircraft.
Although it is not inconceivable that "Permit" aeroplanes may be allowed to fly IFR in the relaively near future...something that they do in the USA now.
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Old 10th Nov 2009, 10:30
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Although it is not inconceivable that "Permit" aeroplanes may be allowed to fly IFR in the relaively near future
The words "snowflake" and "hell" come to mind

Is anyone aware of any such proposal in Europe?
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Old 10th Nov 2009, 10:34
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I've heard rumours of it from people who know more about it than me.....Someone suggested that within the next 3-4 years it may be a real possibility. But that is all, just rumours.
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Old 10th Nov 2009, 10:46
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Justicair, subject to having the proper/required equipment installed & operational, and FM immunization as required, why would a Permit aircraft be less suitable for IFR operations than a CofA aircraft?

Arguably a lot of modern Permit aircraft (homebuilts with glass cockpits, dual nav/com, GPS and slaved autopilot for instance) are easier to fly IFR, including airways, than a lot of CofA/IFR certified 1960s spamcans.

Something else. Is anyone aware of any proposal/solution to the problem that if the IMC really goes away, that it is possible to lift the PPL "in sight surface" restriction without gaining an IR? Would be nice if that restriction could be lifted after suitable instruction & and endorsement from an instructor for instance.
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Old 10th Nov 2009, 10:48
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Anything is possible if you go sub-ICAO. But IFR certification still requires technical compliance e.g. the ability to deal with static, and to withstand lightning strikes, and most "plastic planes" can't.
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