IMC: 'Hung out to dry by our own side'
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Could you post the whole route please? I am quite interested.
EGPH. TLA SID then Direct to TRN then P600 to BLACA then the Standard routing via MAGEE to the approach procedure for EGAC.
-(FPL-GABCD-IG -C182/L -S/S -EGPH1200 -N0120F080 TLA DCT TRN P600 BLACA DCT MAGEE -EGAC0100 EGAA -OPR/PRIVATE)
Now how many people in the European regulatory system thinks that it is a good idea for a pilot with as little as 12 hours sole reference to instrument time to depart Edinburgh in a twin (having only doen the 12 hours training in a single) climb into the teeth of the Edinburgh and Glasgow arrivals to say FL160 and then route down the P600 to take up the hold at MAGEE - a procedure they have never been checked as being able to do and hold for 20 minutes because the weather at EGAC is below minima and then route back up the P600 to Glasgow.
Even taking the fact that a pilot can get an IMC rating in a single and then legally use it in a twin causes even the most ardent supporter some "concern".
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Brendan,
Maybe just nit picking here but.........
You suggest that an IMC rating can be achieved with less than 15 hours actual IMC or simulated IMC. This was certainly not the case when I gained the rating. A MINIMUM of 10 minutes of time per flight was discounted for takeoff, landing plus any rest time.
When I obtained my multi rating the IMC renewal had to be done in a twin if I wished to use the privileges of multi IMC.
DO.
Maybe just nit picking here but.........
You suggest that an IMC rating can be achieved with less than 15 hours actual IMC or simulated IMC. This was certainly not the case when I gained the rating. A MINIMUM of 10 minutes of time per flight was discounted for takeoff, landing plus any rest time.
When I obtained my multi rating the IMC renewal had to be done in a twin if I wished to use the privileges of multi IMC.
DO.
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I've only known personally three people who have died in light aircraft as recreational flyers since I started flying as a PPL in 1987. Each one of them was an IMC holder, in weather that they should never have been flying in, plus in one case, in an aircraft where the equipment let them down. Regardless, the one common factor is that without the rating they would have been on the ground.
The justification given above of using a rating to fly into what are basically icing conditions in a single-engine aircraft, shooting an ILS at the end to have coffee with friends is quite frankly ludicrous. As, to an extent, is the argument of using the rating as a get-out-of jail card if the weather deteriorates whilst in flight.
Perhaps the answer is a simple one, albeit in two parts. First part; raise the bar of the basic PPL to provide enhanced instrument flying skills to enable safe exit from IMC conditions, and re-test such skills annually. Second; a realisation that if you are not being paid to make the flight, which by definition you are not under the privileges of the PPL (and neither will it be for any defined business purpose of course,) then you have no right to place yourself or more importantly your passengers in any enhanced jeopardy.
Regardless of the fine-print differences between nations and tail-numbers, any rating that allows someone not fully trained to fly in instrument conditions in an aircraft not fully equipped for such is something that should be anathema. A basic skill-set to save your ass is fine, but allowing planning in such marginal weather for what is basically recreational flying is something that cannot withstand scrutiny.
Perhaps bringing the full IR within more peoples grasp would be a better goal? I am somewhat out of the Private Flying loop these days, but I still feel I would know 3 people still alive and enjoying their flying and their families today had their confidence not been artificially boosted above their competence.
Sorry if that sounds a bit arrogant coming from an airline pilot; it's not, it's a hard-earned viewpoint. Also, one I have espoused for many years now.
Squid
The justification given above of using a rating to fly into what are basically icing conditions in a single-engine aircraft, shooting an ILS at the end to have coffee with friends is quite frankly ludicrous. As, to an extent, is the argument of using the rating as a get-out-of jail card if the weather deteriorates whilst in flight.
Perhaps the answer is a simple one, albeit in two parts. First part; raise the bar of the basic PPL to provide enhanced instrument flying skills to enable safe exit from IMC conditions, and re-test such skills annually. Second; a realisation that if you are not being paid to make the flight, which by definition you are not under the privileges of the PPL (and neither will it be for any defined business purpose of course,) then you have no right to place yourself or more importantly your passengers in any enhanced jeopardy.
Regardless of the fine-print differences between nations and tail-numbers, any rating that allows someone not fully trained to fly in instrument conditions in an aircraft not fully equipped for such is something that should be anathema. A basic skill-set to save your ass is fine, but allowing planning in such marginal weather for what is basically recreational flying is something that cannot withstand scrutiny.
Perhaps bringing the full IR within more peoples grasp would be a better goal? I am somewhat out of the Private Flying loop these days, but I still feel I would know 3 people still alive and enjoying their flying and their families today had their confidence not been artificially boosted above their competence.
Sorry if that sounds a bit arrogant coming from an airline pilot; it's not, it's a hard-earned viewpoint. Also, one I have espoused for many years now.
Squid
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Now how many people in the European regulatory system thinks that it is a good idea for a pilot with as little as 12 hours sole reference to instrument time to depart Edinburgh in a twin (having only doen the 12 hours training in a single) climb into the teeth of the Edinburgh and Glasgow arrivals to say FL160 and then route down the P600 to take up the hold at MAGEE - a procedure they have never been checked as being able to do and hold for 20 minutes because the weather at EGAC is below minima and then route back up the P600 to Glasgow.
But let's look at this
climb into the teeth of the Edinburgh and Glasgow arrivals
Also there is no way anybody is going to be competent in 12 hours. The average IMCR time is over 20. Mine was about 25.
to say FL160
a procedure they have never been checked as being able to do and hold for 20 minutes
You are assuming a mix of absolutely minimal experience, maximum mission complexity, worst case weather, most complex aircraft, flying into probably very expensive places. You just don't find this combination in the same place.
You could equally argue that a C150 could fly into Gatwick - which it absolutely can do, both VFR or IFR. That is a lot busier than anything in Scotland. So why don't they? Because it costs £500 to land there, and it would be too much bother even if it was free.
SS, I'm very sorry you have lost friends in this way. I understand that there have been very few accidents involving IMCR pilots in IMC, so I think you are unfortunate (to put it mildly) to know of three.
I agree, given you said "into what are basically icing conditions". Not a good idea.
I don't have the knowledge to dispute what you say, but presumably the CAA think the IMCR training is sufficient? As I say, I understood that the accident record is pretty good. As a proportion of PPLs, IMCRs are said (I don't have the source) to have a lower rate of accidents in IMC than non-IMCR rated PPLs.
The justification given above of using a rating to fly into what are basically icing conditions in a single-engine aircraft, shooting an ILS at the end to have coffee with friends is quite frankly ludicrous.
...any rating that allows someone not fully trained to fly in instrument conditions in an aircraft not fully equipped for such is something that should be anathema...
SS
I would characterise your contribution as patronising rather than arrogant.Nowhere do I see in the post you refer to any indication that the poster was suggesting flying into icing conditions but rather climbing through cloud to vmc on top a situation allowed in many parts of the world on a basic PPL but interestingly not in the UK where to do so you require an IMCR!You seem to also hold the view that with the acquisition of an IMCR somehow basic airmanship is put to one side and common sense thrown out of the window.Whilst I am sorry you lost two friends apparently in situations that were beyond their capabilities in the situation they found themselves in maybe had they exercised good judgement and common sense they might be here today.That is not necessarily anything to do with holding an IMCR but rather a particular approach to flying.
SF
I would characterise your contribution as patronising rather than arrogant.Nowhere do I see in the post you refer to any indication that the poster was suggesting flying into icing conditions but rather climbing through cloud to vmc on top a situation allowed in many parts of the world on a basic PPL but interestingly not in the UK where to do so you require an IMCR!You seem to also hold the view that with the acquisition of an IMCR somehow basic airmanship is put to one side and common sense thrown out of the window.Whilst I am sorry you lost two friends apparently in situations that were beyond their capabilities in the situation they found themselves in maybe had they exercised good judgement and common sense they might be here today.That is not necessarily anything to do with holding an IMCR but rather a particular approach to flying.
SF
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******* alias BoseX seeks to demonstrate that many IMCr trips could equally be done with an EIR. No one appears to know how you would descend through cloud between say 3,000 and 1,500 for a VFR approach other than via a made up let down with a hope and see cloud break. When the details of the EIR are eventually revealed we might know.
In the mean time the hypocrisy of Jim Thorpe should not be lost in going public with his “personal view” of the EIR in which he hints at the promise of a simplified IR, argues the EIR is a realistic replacement for the IMCr without providing any detail of how it will actually work and espouses the EIR as a stepping stone to a new IR of which he is silent on the detail.
It will come as no surprise to me when in due course a simplified IR does not emerge, the IMCr is abolished and the EIR proves to be a solution to a problem that never existed when Mr Thorpe and others point out that these were only his personal views.
Politicians, judges and many others learnt a very long time ago that when you hold an office you cannot afford to have personal views. In answer to your question Bookworm that is why I am so critical of Mr Thorpe’s article – I don’t need to know him, and can only judge by what I read. He has crossed a line that he should not have crossed. Moreover, we have been told here and elsewhere on many occasions that members of FCL008 sign a ND; either this was never true, Mr Thorpe has breached the ND or his article is with the consent of FCL008. In which ever event, unless I have missed an alternative, he is on very dangerous ground.
******* you were very clearly in favour of the IMCr and said so publically. I can refer you to your post if you wish. For the avoidance of doubt please would you now either confirm you stand by your earlier position or you have changed your position and if so please will you set out why? This is fundamental to your credibility.
You also refer to the IMCr survey. I assume when the results are announced you will also set out how and by who the questions were planned, how the results have been independently audited, and who has been asked to determine the statistical validity of the results. I made this point many months ago so you were clearly warned. I have to tell you that without this information the results will be meaningless and pointless; in a court of law they would not even be admissible evidence. I admire you for attempting a survey but hope you have not wasted your time and more to the point don’t damage the debate with data that is dreadfully misleading to suite your own agenda – whatever that might be?
Moreover AOPA have sadly not come out of this saga smelling of roses so far – I should remind everyone that the survey was conducted on behalf of AOPA and if and when the results are published it will be AOPA publishing the results (not ******* ) if I am not mistaken. I hope AOPA think very carefully about allowing these results to be published given my earlier comments unless they are absolutely certain they will stand critical scrutiny. If they are not certain AOPA will be damned for publishing whereas given the considerable delay that has already occurred at least they will not be damned for not publishing!
Finally I still don’t understand why some of you will not listen to the message that comes over loud and clear from this thread. It seems to be on the whole it is the private IR holder who will not do the listening. Pilots with IMCrs don’t want to fly on the whole in hard IFR conditions! Do you simply not understand that if the wind is 20 gusting 30 across the runway while that has nothing to do with whether or not they can see out of the window they don’t want to land in conditions which by definition are reasonably challenging. Have you never been to a typical GA airport on days such as this with good VFR and see how many people are flying – or should I say not. They don’t want on the whole to fly to minima and they don’t want to fly with oxygen in the airways. Do you not understand that for many short sectors an airway routing all other issues aside are a right pain in the arse? Do you not understand that they don’t want to breathe oxygen for hours on end and they don’t want to fly 10 times a week to the CIs to help maintain their income as a FI – they don’t need to, they have other jobs.
I think some of you are playing a very dangerous game judging what people want by what you want. The biggest mistake EASA made was in the composition of FCL008 – in their own terms of reference they state they are briefed with considering the IMCr and yet they don’t have a single representative on the committee with an IMCr. Surely IAOPA or Jim Thorpe’s lot could have managed between them to find someone with an IMCr?
(Also posted on the darker side but I feel worth posting here as well as the debates are similiar)
[Name removed - mods]
In the mean time the hypocrisy of Jim Thorpe should not be lost in going public with his “personal view” of the EIR in which he hints at the promise of a simplified IR, argues the EIR is a realistic replacement for the IMCr without providing any detail of how it will actually work and espouses the EIR as a stepping stone to a new IR of which he is silent on the detail.
It will come as no surprise to me when in due course a simplified IR does not emerge, the IMCr is abolished and the EIR proves to be a solution to a problem that never existed when Mr Thorpe and others point out that these were only his personal views.
Politicians, judges and many others learnt a very long time ago that when you hold an office you cannot afford to have personal views. In answer to your question Bookworm that is why I am so critical of Mr Thorpe’s article – I don’t need to know him, and can only judge by what I read. He has crossed a line that he should not have crossed. Moreover, we have been told here and elsewhere on many occasions that members of FCL008 sign a ND; either this was never true, Mr Thorpe has breached the ND or his article is with the consent of FCL008. In which ever event, unless I have missed an alternative, he is on very dangerous ground.
******* you were very clearly in favour of the IMCr and said so publically. I can refer you to your post if you wish. For the avoidance of doubt please would you now either confirm you stand by your earlier position or you have changed your position and if so please will you set out why? This is fundamental to your credibility.
You also refer to the IMCr survey. I assume when the results are announced you will also set out how and by who the questions were planned, how the results have been independently audited, and who has been asked to determine the statistical validity of the results. I made this point many months ago so you were clearly warned. I have to tell you that without this information the results will be meaningless and pointless; in a court of law they would not even be admissible evidence. I admire you for attempting a survey but hope you have not wasted your time and more to the point don’t damage the debate with data that is dreadfully misleading to suite your own agenda – whatever that might be?
Moreover AOPA have sadly not come out of this saga smelling of roses so far – I should remind everyone that the survey was conducted on behalf of AOPA and if and when the results are published it will be AOPA publishing the results (not ******* ) if I am not mistaken. I hope AOPA think very carefully about allowing these results to be published given my earlier comments unless they are absolutely certain they will stand critical scrutiny. If they are not certain AOPA will be damned for publishing whereas given the considerable delay that has already occurred at least they will not be damned for not publishing!
Finally I still don’t understand why some of you will not listen to the message that comes over loud and clear from this thread. It seems to be on the whole it is the private IR holder who will not do the listening. Pilots with IMCrs don’t want to fly on the whole in hard IFR conditions! Do you simply not understand that if the wind is 20 gusting 30 across the runway while that has nothing to do with whether or not they can see out of the window they don’t want to land in conditions which by definition are reasonably challenging. Have you never been to a typical GA airport on days such as this with good VFR and see how many people are flying – or should I say not. They don’t want on the whole to fly to minima and they don’t want to fly with oxygen in the airways. Do you not understand that for many short sectors an airway routing all other issues aside are a right pain in the arse? Do you not understand that they don’t want to breathe oxygen for hours on end and they don’t want to fly 10 times a week to the CIs to help maintain their income as a FI – they don’t need to, they have other jobs.
I think some of you are playing a very dangerous game judging what people want by what you want. The biggest mistake EASA made was in the composition of FCL008 – in their own terms of reference they state they are briefed with considering the IMCr and yet they don’t have a single representative on the committee with an IMCr. Surely IAOPA or Jim Thorpe’s lot could have managed between them to find someone with an IMCr?
(Also posted on the darker side but I feel worth posting here as well as the debates are similiar)
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Patronising? Fair enough, if you see it like that, but I think the two disciplines of visual flying and instrument flying should be completely and irrevocably separated, bar the the inclusion of a set of basic skills that are re-tested to allow a basically visual flyer to escape unforseen incursion into instrument conditions. I don't think it's patronising to have such an opinion otherwise I wouldn't have posted. I don't do patronising.
I feel that the allowing of planning into what are marginal conditions is way too much of a grey area, one that we in the UK have become accustomed to by the offering of such a rating, and perhaps it is time to realise that two completely different disciplines exist; that of Visual Flying in the associated Met conditions, and that of Instrument Flying in full IMC/Controlled Airspace in suitably equipped aircraft. As I implied above, would that all of the authorities around the World saw likewise, many do not at the moment.
As I also implied above, the opinion I give here is based upon a negative experience, and that in no way implies that everyone who holds such a rating will be going flying willy-nilly in marginal weather. But to someone who flies professionally, it seems an anachronism to have a middle-ground between the basic recreational licence and the full IFR licence and, importantly, to allow planning within the remit of that middle-ground rating.
It is indeed possible to climb on top through cloud avoiding the icing layer. Not always. Neither, in my experience, has the forecast top of the cloud layer regularly appeared as predicted, indeed yesterday it was 5000' out, which we had a laugh about as we were being bumped around waiting for clearance to climb from what should have been a clear level.
Sorry again if you feel it's patronising, it's just a heart-felt opinion based on my years and experience, one that as a Moderator (albeit not named on this part of the site) I thought several times before posting.
Squid
I feel that the allowing of planning into what are marginal conditions is way too much of a grey area, one that we in the UK have become accustomed to by the offering of such a rating, and perhaps it is time to realise that two completely different disciplines exist; that of Visual Flying in the associated Met conditions, and that of Instrument Flying in full IMC/Controlled Airspace in suitably equipped aircraft. As I implied above, would that all of the authorities around the World saw likewise, many do not at the moment.
As I also implied above, the opinion I give here is based upon a negative experience, and that in no way implies that everyone who holds such a rating will be going flying willy-nilly in marginal weather. But to someone who flies professionally, it seems an anachronism to have a middle-ground between the basic recreational licence and the full IFR licence and, importantly, to allow planning within the remit of that middle-ground rating.
It is indeed possible to climb on top through cloud avoiding the icing layer. Not always. Neither, in my experience, has the forecast top of the cloud layer regularly appeared as predicted, indeed yesterday it was 5000' out, which we had a laugh about as we were being bumped around waiting for clearance to climb from what should have been a clear level.
Sorry again if you feel it's patronising, it's just a heart-felt opinion based on my years and experience, one that as a Moderator (albeit not named on this part of the site) I thought several times before posting.
Squid
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HOWEVER, nowhere allows a PPL to climb through a cloud layer (i.e. operate in less than full VMC) without an IR, except the UK - which allows an IMCr to do this as well as an IR.
Additionally, unlike everywhere else, the UK allows a basic PPL to operate IFR in sub-VMC met conditions, in some airspaces - but not in 'proper' IMC.
SS
Fair enough-I think we will just have to agree to disagreeiI just think its potentially aretrograde step to throw the baby out with the bath water.After all the proposed "solution" looks far worse to me in the context of PPL safety.
SS
Fair enough-I think we will just have to agree to disagreeiI just think its potentially aretrograde step to throw the baby out with the bath water.After all the proposed "solution" looks far worse to me in the context of PPL safety.
SS
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I feel that the allowing of planning into what are marginal conditions is way too much of a grey area, one that we in the UK have become accustomed to by the offering of such a rating
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According to the documents available from EASA, dated October 3rd 2008, the objectives of the FCL.008 group are as follows:
"3. Objectives:
Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules. This evaluation shall take into account the ICAO Annex 1 SARPs for the issue of an IR
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
Review the existing national requirements for cloud flying with sailplanes and assess the need for an additional European rating for sailplane pilots to fly in IMC
Take into account Air Traffic Control (ATC) requirements regarding Instrument Flight Rules (IFR) flights
Amend the proposed requirements for the instrument rating if necessary"
where does it say they are tasked with saving the UK IMCR? I don't care because I don't fly in the UK, but when I read this it says they will review the existing requirements to consider the development of a rating separate from the IR....period. I've never met Jim Thorpe either, but it seems silly to get the facts wrong while being so vicious.
"3. Objectives:
Review the existing JAR-FCL requirements for the Instrument Rating with a view to evaluate the possibility of reducing these requirements for private pilots flying under Instrument Flight Rules. This evaluation shall take into account the ICAO Annex 1 SARPs for the issue of an IR
Review the requirements of the UK IMC rating and other national qualifications for flying in IMC and consider whether there is a need to develop an additional European rating to fly in IMC with less training but also with limited privileges
Review the existing national requirements for cloud flying with sailplanes and assess the need for an additional European rating for sailplane pilots to fly in IMC
Take into account Air Traffic Control (ATC) requirements regarding Instrument Flight Rules (IFR) flights
Amend the proposed requirements for the instrument rating if necessary"
where does it say they are tasked with saving the UK IMCR? I don't care because I don't fly in the UK, but when I read this it says they will review the existing requirements to consider the development of a rating separate from the IR....period. I've never met Jim Thorpe either, but it seems silly to get the facts wrong while being so vicious.
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Utfart
I fair point but here are some comments relevant to getting your facts straight:
I do not wish to disparage the efforts of many well meaning folk over this extended period. In a time of great change they did their best to adapt but the reality was that what emerged was not a finely crafted product carefully aligned to the needs and skills of pilots. In that great British tradition we ‘made do’ and lived with the least bad compromise.
I love that statement. I do not mean to disparage.. .. .. but as is usually the case when someone says something like this – watch I, I am just about to. I think it is very disparaging to criticise something that has evolved with and stood the test of time. I know of no better test, and you can bet it is a far better test than a bunch of hypocrites inventing something which they haven’t tested at all.
Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited
Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.
Often they have little chance to stay current and are subject to less frequent renewal checks than holders of the IR.
Let’s ignore the largest population if ICAO IR holders in the world which are subject to far less frequent renewals than IMCr holders.
It is not hard to see that this seems rather irrational if you live anywhere else in the world since no other country has seen a requirement for an IMC like rating.
Canada was just about the only country that saw the need for adequate liquidity control of their banking sector – what a fatuitous statement to make, in a world in which the largest population of GA pilots has solved the problem in a different and very effective way as has the third largest continental GA population and the majority of the rest of the world hardly has any GA or any GA that needs to fly in IMC.
It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents.
Extraordinary. I can find no data, but rather than concluding I can find nothing to support the safety case one way or another, I will conclude the rating is unsafe.
On the basis of the only two surveys of IMC holders of which I am aware
Which two, conducted by who and when?
It is true that training and testing standards are far more variable in the US than the UK and while I have come across no evidence of outright corruption, it is almost certainly possible to get an ‘easy’ IR.
Why would you pass this observation? As “easy” as an IR in Poland?
It is greatly to EASA’s credit that in spite of their enormous workload they accommodated UK minority concerns even though they were often expressed in unhelpful ways. In a public meeting I attended, a well known GA figure suggested that we needed an IMC because England stood alone against the Nazi hordes in the Second World War
Oh I am so sorry you had to manage minority concerns. I am also sorry that one nuter is the only thing you can remember of a very valuable meeting. One would have hoped for a little more maturity.
I could go on, but frankly I am bored.
It is just complete dribble.
I fair point but here are some comments relevant to getting your facts straight:
I do not wish to disparage the efforts of many well meaning folk over this extended period. In a time of great change they did their best to adapt but the reality was that what emerged was not a finely crafted product carefully aligned to the needs and skills of pilots. In that great British tradition we ‘made do’ and lived with the least bad compromise.
I love that statement. I do not mean to disparage.. .. .. but as is usually the case when someone says something like this – watch I, I am just about to. I think it is very disparaging to criticise something that has evolved with and stood the test of time. I know of no better test, and you can bet it is a far better test than a bunch of hypocrites inventing something which they haven’t tested at all.
Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited
Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.
Often they have little chance to stay current and are subject to less frequent renewal checks than holders of the IR.
Let’s ignore the largest population if ICAO IR holders in the world which are subject to far less frequent renewals than IMCr holders.
It is not hard to see that this seems rather irrational if you live anywhere else in the world since no other country has seen a requirement for an IMC like rating.
Canada was just about the only country that saw the need for adequate liquidity control of their banking sector – what a fatuitous statement to make, in a world in which the largest population of GA pilots has solved the problem in a different and very effective way as has the third largest continental GA population and the majority of the rest of the world hardly has any GA or any GA that needs to fly in IMC.
It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents.
Extraordinary. I can find no data, but rather than concluding I can find nothing to support the safety case one way or another, I will conclude the rating is unsafe.
On the basis of the only two surveys of IMC holders of which I am aware
Which two, conducted by who and when?
It is true that training and testing standards are far more variable in the US than the UK and while I have come across no evidence of outright corruption, it is almost certainly possible to get an ‘easy’ IR.
Why would you pass this observation? As “easy” as an IR in Poland?
It is greatly to EASA’s credit that in spite of their enormous workload they accommodated UK minority concerns even though they were often expressed in unhelpful ways. In a public meeting I attended, a well known GA figure suggested that we needed an IMC because England stood alone against the Nazi hordes in the Second World War
Oh I am so sorry you had to manage minority concerns. I am also sorry that one nuter is the only thing you can remember of a very valuable meeting. One would have hoped for a little more maturity.
I could go on, but frankly I am bored.
It is just complete dribble.
Quite right Utfart, it doesn't say (in the FCL.008 ToR) that it will save the UK IMCR. Nor does it say it will do anything else, except "review" and "consider".
It says "...consider whether there is a need for a European rating to fly in IMC... [with sub-IR training and privileges]" and it says "...evaluate the possiblity of reducing the requirements [for IR training]".
Your reading of the ToR is correct only if they recommend a separate rating which meets the needs of a sub-IR. Those of us in the UK that use the IMCR are strongly of the opinion that the talked-of EIR rating is pointless and nowhere nearly meets the need for a sub-IR. The reason for the vitriol aimed at Jim Thorpe is that the EIR looks like an excuse to say "we've considered a sub-IR rating" without actually doing anything useful. I'm more charitable towards Jim's motives, but I consider his judgement rather flawed in this respect.
It says "...consider whether there is a need for a European rating to fly in IMC... [with sub-IR training and privileges]" and it says "...evaluate the possiblity of reducing the requirements [for IR training]".
Your reading of the ToR is correct only if they recommend a separate rating which meets the needs of a sub-IR. Those of us in the UK that use the IMCR are strongly of the opinion that the talked-of EIR rating is pointless and nowhere nearly meets the need for a sub-IR. The reason for the vitriol aimed at Jim Thorpe is that the EIR looks like an excuse to say "we've considered a sub-IR rating" without actually doing anything useful. I'm more charitable towards Jim's motives, but I consider his judgement rather flawed in this respect.
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It is argued that there is a safety benefit but I can find no credible evidence to support this. The data is pretty inadequate with no record of hours flown and often no record of the licence held by pilots involved in accidents or incidents.
Please go ahead and post the next sentence in the letter and explain to us why you chose to exclude it. The fact is he has allowed that the opposite point of view could be true and there there is a lack of data to support either case!
Let’s ignore the largest population if ICAO IR holders in the world which are subject to far less frequent renewals than IMCr holders.
In fact, the largest population of IR holders have to pass a biennial flight review (that's every 24 months), but you have conveniently missed the currency requirements that must be met to legally fly in IMC as pilot in command. They are; 6 approaches to landing within the last 6 months, as well as intercepting and tracking a course through the use of navigation systems, and holding. Are there currency requirements for the IMCR?
Your logic and arguments remind me of my opposition in the old union busting days in Canada. Reliance on half truths and ignorance. THAT is boring.
FREDAcheck. I'm afraid your reasoning doesn't explain all the vitriol aimed at Jim Thorpe. We must look elsewhere for that and find it in ignorance, misunderstanding, and perhaps guilt. Yes, guilt by those who have been caught unaware by their lack of attention and diligence. I'm not in the aviation business and pretty busy with my work and family, and yet have not been surprised by much of what I read the last few weeks at all. How can that be? Glad I'm not in the AOPA UK. I respect what you have said, and maybe Mr. Thorpes' judgement can be debated. I am very grateful for his decision to share insight and comments on the process he took part in though, else we would have no news whatsoever.
Please go ahead and post the next sentence in the letter and explain to us why you chose to exclude it. The fact is he has allowed that the opposite point of view could be true and there there is a lack of data to support either case!
Let’s ignore the largest population if ICAO IR holders in the world which are subject to far less frequent renewals than IMCr holders.
In fact, the largest population of IR holders have to pass a biennial flight review (that's every 24 months), but you have conveniently missed the currency requirements that must be met to legally fly in IMC as pilot in command. They are; 6 approaches to landing within the last 6 months, as well as intercepting and tracking a course through the use of navigation systems, and holding. Are there currency requirements for the IMCR?
Your logic and arguments remind me of my opposition in the old union busting days in Canada. Reliance on half truths and ignorance. THAT is boring.
FREDAcheck. I'm afraid your reasoning doesn't explain all the vitriol aimed at Jim Thorpe. We must look elsewhere for that and find it in ignorance, misunderstanding, and perhaps guilt. Yes, guilt by those who have been caught unaware by their lack of attention and diligence. I'm not in the aviation business and pretty busy with my work and family, and yet have not been surprised by much of what I read the last few weeks at all. How can that be? Glad I'm not in the AOPA UK. I respect what you have said, and maybe Mr. Thorpes' judgement can be debated. I am very grateful for his decision to share insight and comments on the process he took part in though, else we would have no news whatsoever.
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Utfart,
Thank you for bringing some objectivity and a fresh pair of eyes to this discussion.
I didn't have time to dissect Fuji's post, but now you have started, I'll continue
You can't deconstruct an uncertainty into a certainty by saying it was "hidden", or suggest something untoward by the use of possibly. Possibly alien life forms have visited Earth. Is that "a statement hiding behind a possibly"? No. It is what it says.
More importantly, there is the factual point that an IMCr may be taught by an instructor who does not have an IR. Personally, I have no problem with that - I think flight instruction is more about motivation and teaching skills and currency in teaching than it is about other experience. Also, I think the IF course is the same as the IRI and a very good course. Nevertheless, the point is factually true an IMCr holder may flying IFR departures, enroute, arrivals and approaches having had their entire instruction conducted by someone who wasn't an ICAO IR holder themselves. I am not making a judgement either way. I am stating a fact. That fact may not concern you or me, but there are stakeholders in the UK and Europe, I suspect, who don't think it's acceptable.
He is making a point that balance and maturity are not exactly hallmarks of some of the IMCr campaigning and that this, at times, may be counter-productive. I imagine the irony is lost on you.
You don't get it, do you. The European system has evolved 2 features
- standardisation through the JAA and, now, EASA
- a "standards paradigm" (I hate the word but can't think of a better one) which is distinct and very firm in the European regulatory mindset.
In respect of training, that standards paradigm involves
- long, structured courses of Theory and Flight training
- written exams conducted by NAAs
- flight courses conducted by FTOs with all the approvals paraphenalia
From the EASA point of view, it doesn't matter that the IMCr has "stood the test of time". EASA's goal is about raising safety standards to a common level in Europe, as defined in the thousands of pages of JAA and, now, EASA documentation. Your inability to grasp this point is why you will be typing the same stuff post after post after post. It doesn't matter. Whatever the strenght of your claims about the record for the IMCr (most of which I agree with), it doesn't fit the "standards" of EASA.
I can't think of a single new European/JAA regulation or restriction that didn't replace something that previously had "stood the test of time" equally well. What happened to the old self-improver route to the IR? What happened with smaller schools teaching commercial stuff? What happened to independent engineers? What happened to engines running more than 12 years? The list is endless.
You have got the entire debate the wrong way around. You think EASA or someone is killing the IMCr because they have a case that it is unsafe. You write thousands of words opposing that. Most of them I agree with. You've used a legal analogy before and one is useful now. You are in an empty courtroom defending the IMCr against charges no-one has brought.
EASA are in a different courtroom. The EU has legally empowered and directed them (it's the EU Basic Regulation laws, not EASA's discretion) to
1. develop a set of high common standards for aviation regulation in Europe
2. standardise those across the region without national exceptions
It doesn't matter that the IMCr is safe and has met the test of time. A million non-EASA or non-JAA practices and methods meet the same criteria (eg. the entire FAA system). Europe has chosen a different model. You can either choose to do your best within the model we are in, or you can write endless posts which are irrelevant. Good luck in overturning the entire European regulatory paradigm in your "campaign". I think this is an ambitous goal. Achieving it may need a brief respite from your main activity of slagging off Jim Thorpe.
I absolutely understand the apparent contradiction between the proven IMCr and the unproven EIR.
At its heart is a misunderstanding some people may have; let me call it the "Privilege Limitation Fallacy".
The IMCr is a rating which permits a pilot to fly under IFR in IMC in every phase of flight. From the point of view of knowledge, training and skills, there is no meaningful difference between the IR and the IMCr, if, as EASA does, you took the current IR as the baseline and said "how can the training be reduced if we removed Class A privileges and recommended higher minima"; what would the answer be?
- a tiny bit of air law relating to Class A and airways
- the dog-leg join of an airway you do on IR test routes (one of the easiest bits)
- the ~40s on each ILS it takes to descend from 500' to 200'
Teaching a non-precision approach would be identical, except there'd be a different number on the altimeter at MDA.
Therefore, from the perspective of the EASA IR, the reduction in IMCr privileges simply does not correspond to the reduction in training and "approval" standards for training.
Let's take the example of all the other ideas for "limited privileges" I've seen on various threads.
- can't be used in RVSM airspace
- can't be used in pressurised aircraft
- can't be used in Type Rated aircraft
- can't be used in Oceanic routes
- can't be used in aircraft with more than 6 seats.
It's all clap trap. The JAA/EASA IR is conducted in a light piston aircraft at low level. What could you eliminate from the flight training as a result of all these "restrictions"?
- err, nothing
The reason FCL008's output is the best achievable for GA is that EASA's current "baseline", the IR, is simply not up for debate. Jim's success on behalf of GA has been to
- push for a more flexible, competency based training method towards the IR
- push for the IR TK to be more relevant to the privileges granted.
The EIR is perhaps achievable for the very reason its privileges are meaningfully limited. Approaches and departures are the hardest part of IFR training and flight. If a safe model for the EIR and its privileges can be defined (and I agree it's a new concept, so far from certain), then it is probably the best "sub IR" that can be achieved at a standardised, EASA level. The problem with all the "sub IR lite" proposals is that they openly tweak the privileges and then implicitly flip the training paradigm from the "EASA high standards" one to a more informal IMCR/PPL/FAA traning model. EASA won't accept that. You can tweak privileges and training in a consistent manner within the EASA training model (as the EIR tries to do), but something outside that model (as the IMCr is) will not be accepted in Europe.
brgds
421C
As a final thought, if his article was so weak and dribbly, why not try writing an article or paper of your own? Let us hold your writing and analysis to the same scrutiny you apply. It would be illuminating.
Thank you for bringing some objectivity and a fresh pair of eyes to this discussion.
I didn't have time to dissect Fuji's post, but now you have started, I'll continue
Thus pilots with 15 hours training, possibly from an instructor whose own experience is quite limited
Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.
Instructors with limited instrument experience teaching an IMCr .. .. .. Now there is a brave statement made without reference to a single fact and hidden behind a “possibly”.
More importantly, there is the factual point that an IMCr may be taught by an instructor who does not have an IR. Personally, I have no problem with that - I think flight instruction is more about motivation and teaching skills and currency in teaching than it is about other experience. Also, I think the IF course is the same as the IRI and a very good course. Nevertheless, the point is factually true an IMCr holder may flying IFR departures, enroute, arrivals and approaches having had their entire instruction conducted by someone who wasn't an ICAO IR holder themselves. I am not making a judgement either way. I am stating a fact. That fact may not concern you or me, but there are stakeholders in the UK and Europe, I suspect, who don't think it's acceptable.
Oh I am so sorry you had to manage minority concerns. I am also sorry that one nuter is the only thing you can remember of a very valuable meeting. One would have hoped for a little more maturity.
I think it is very disparaging to criticise something that has evolved with and stood the test of time. I know of no better test, and you can bet it is a far better test than a bunch of hypocrites inventing something which they haven’t tested at all
- standardisation through the JAA and, now, EASA
- a "standards paradigm" (I hate the word but can't think of a better one) which is distinct and very firm in the European regulatory mindset.
In respect of training, that standards paradigm involves
- long, structured courses of Theory and Flight training
- written exams conducted by NAAs
- flight courses conducted by FTOs with all the approvals paraphenalia
From the EASA point of view, it doesn't matter that the IMCr has "stood the test of time". EASA's goal is about raising safety standards to a common level in Europe, as defined in the thousands of pages of JAA and, now, EASA documentation. Your inability to grasp this point is why you will be typing the same stuff post after post after post. It doesn't matter. Whatever the strenght of your claims about the record for the IMCr (most of which I agree with), it doesn't fit the "standards" of EASA.
I can't think of a single new European/JAA regulation or restriction that didn't replace something that previously had "stood the test of time" equally well. What happened to the old self-improver route to the IR? What happened with smaller schools teaching commercial stuff? What happened to independent engineers? What happened to engines running more than 12 years? The list is endless.
You have got the entire debate the wrong way around. You think EASA or someone is killing the IMCr because they have a case that it is unsafe. You write thousands of words opposing that. Most of them I agree with. You've used a legal analogy before and one is useful now. You are in an empty courtroom defending the IMCr against charges no-one has brought.
EASA are in a different courtroom. The EU has legally empowered and directed them (it's the EU Basic Regulation laws, not EASA's discretion) to
1. develop a set of high common standards for aviation regulation in Europe
2. standardise those across the region without national exceptions
It doesn't matter that the IMCr is safe and has met the test of time. A million non-EASA or non-JAA practices and methods meet the same criteria (eg. the entire FAA system). Europe has chosen a different model. You can either choose to do your best within the model we are in, or you can write endless posts which are irrelevant. Good luck in overturning the entire European regulatory paradigm in your "campaign". I think this is an ambitous goal. Achieving it may need a brief respite from your main activity of slagging off Jim Thorpe.
I absolutely understand the apparent contradiction between the proven IMCr and the unproven EIR.
At its heart is a misunderstanding some people may have; let me call it the "Privilege Limitation Fallacy".
The IMCr is a rating which permits a pilot to fly under IFR in IMC in every phase of flight. From the point of view of knowledge, training and skills, there is no meaningful difference between the IR and the IMCr, if, as EASA does, you took the current IR as the baseline and said "how can the training be reduced if we removed Class A privileges and recommended higher minima"; what would the answer be?
- a tiny bit of air law relating to Class A and airways
- the dog-leg join of an airway you do on IR test routes (one of the easiest bits)
- the ~40s on each ILS it takes to descend from 500' to 200'
Teaching a non-precision approach would be identical, except there'd be a different number on the altimeter at MDA.
Therefore, from the perspective of the EASA IR, the reduction in IMCr privileges simply does not correspond to the reduction in training and "approval" standards for training.
Let's take the example of all the other ideas for "limited privileges" I've seen on various threads.
- can't be used in RVSM airspace
- can't be used in pressurised aircraft
- can't be used in Type Rated aircraft
- can't be used in Oceanic routes
- can't be used in aircraft with more than 6 seats.
It's all clap trap. The JAA/EASA IR is conducted in a light piston aircraft at low level. What could you eliminate from the flight training as a result of all these "restrictions"?
- err, nothing
The reason FCL008's output is the best achievable for GA is that EASA's current "baseline", the IR, is simply not up for debate. Jim's success on behalf of GA has been to
- push for a more flexible, competency based training method towards the IR
- push for the IR TK to be more relevant to the privileges granted.
The EIR is perhaps achievable for the very reason its privileges are meaningfully limited. Approaches and departures are the hardest part of IFR training and flight. If a safe model for the EIR and its privileges can be defined (and I agree it's a new concept, so far from certain), then it is probably the best "sub IR" that can be achieved at a standardised, EASA level. The problem with all the "sub IR lite" proposals is that they openly tweak the privileges and then implicitly flip the training paradigm from the "EASA high standards" one to a more informal IMCR/PPL/FAA traning model. EASA won't accept that. You can tweak privileges and training in a consistent manner within the EASA training model (as the EIR tries to do), but something outside that model (as the IMCr is) will not be accepted in Europe.
brgds
421C
As a final thought, if his article was so weak and dribbly, why not try writing an article or paper of your own? Let us hold your writing and analysis to the same scrutiny you apply. It would be illuminating.
Last edited by 421C; 4th Dec 2009 at 16:54.
FREDAcheck. I'm afraid your reasoning doesn't explain all the vitriol aimed at Jim Thorpe. We must look elsewhere for that and find it in ignorance, misunderstanding, and perhaps guilt. Yes, guilt by those who have been caught unaware by their lack of attention and diligence. I'm not in the aviation business and pretty busy with my work and family, and yet have not been surprised by much of what I read the last few weeks at all. How can that be? Glad I'm not in the AOPA UK. I respect what you have said, and maybe Mr. Thorpes' judgement can be debated. I am very grateful for his decision to share insight and comments on the process he took part in though, else we would have no news whatsoever.
This has been a constant theme: those opposing IMCR use terms like ignorance, guilt, lack of diligence... and on other threads: "die-hards", "stubbornly defending", or referring them as too lazy or too stupid to get a "proper" IR.
Why are people so threatened by the IMCR? You may not think it has any chance of being agreed by EASA, in which case, just smile quietly and ignore people pressing for it. I don't think anyone is trying to impose IMCR on other countries (though I think it might be a good idea). No one is trying to make anyone else do anything they don't want to. We're just trying to persuade people to let the UK continue with a rating that is wanted and serves a useful purpose. I think there's evidence that it improves safety, but there's certainly no evidence that it causes harm.
So what's the problem?
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I don't know about other schools, but the one where I have been known to cause studes a load of misery has four people qualified to instruct the IMCr.
All of us hold IR's.
All of us hold IR's.