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IMC: 'Hung out to dry by our own side'

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IMC: 'Hung out to dry by our own side'

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Old 4th Dec 2009, 16:41
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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. One might argue polar opposites.

Here is the "missing" line. Note that Mr Thorpe says I can find no credible evidence to support this. A statement of apparent fact. He doesnt go on to say "I could equally argue the polar opposite" but vaguely acknowledges there might be other arguments, by the use of "one might". I dont see on any basis that is a reasonable and unbiased account of the position, it is a clear statement by Mr Thorpe that he has considered all the evidence and he cant find anything to support the IMCr as having any credible safety benefit based on what he then acknolwedges as inadequate data. I would love him to be in Court as an alledged export witness being cross examined on the position he has adopted.

So Mr Thorpe you have considered the data, which you acknowledge is inadequate and you have concluded based on this inadequate data that there is no credible evidence to support the IMCr, rather than concluding there is no adequate data to deteremine whether the IMCr is of benefit to safety or not.

This is what I would have said.

I have considered the studies that have been conducted into whether or not the IMC rating enhances pilot safety and I have reviewed the data on the number of hours flown and the ratings held by pilots involved in accidents. In my opinion the studies and data are inadequate to reach a safe conclusion as to whether or not the rating enhances pilot safety.

I would add that I dont subscribe to that view point based on the data and evidence, but that is another matter, at least that would be a reasonable opinion to express by our self proclaimed expert.

On which point given that Mr Thorpe is just such an expert it would be interesting to know what research and studies he has personally been involved with?

On the stand I can hear the barrister asking Mr Thorpe to set out his creditials. He owuld of ocurse real off that he holds an IR, CPL and doubtless a few other qualifications. So Mr Thorpe to set yourself apart from your everyday peers doubtless you will tell the court your special areas of expertise, the studies you have conducted, the papers you have written, by who they have been peer reviewed etc. I wonder what his answer would be.

Often they have little chance to stay current and are subject to less frequent renewal checks than holders of the IR.

What do you not understand about renewal checks?

I didnt use that term Mr Thorpe did! He could have said that IMCr pilots are not subject to the same renewal checks AND currency requirements of other IRated pilots BUT he didnt.

You might think I am being picky. You would be wrong. This should be a carefully crafted "write up" by an expert either giving his personal views or representing the views of FCL008. There can be no room for a document as poorly drafted as this with such potential to mislead. If a forumite had posted the same nonesense on here it would have been torn to shreds by people like Bookworm - you know it, and I know it, and he knows it, please dont make excuses.

421C

What I dont get is other people just keep telling you, you are wrong. I could understand if they kept telling me I was wrong - I would have to review my position - but they dont.

You will find if you give it a chance the critique of Mr Thorpe's write up will come thick and fast - so even if you think it is well drafted most people have formed quite the opposite impression.
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Old 4th Dec 2009, 16:55
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bose-x, Fuji Abound,

Play the ball, not the man.

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Old 4th Dec 2009, 16:56
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bose-x, your post is frankly very insulting.

I have seen no slander of Thorpe on here. Any and all allegations that I have seen are borne out by the man's own words.

It is clear that the majority here do not support Thorpe's proposal or position. Fuji, BEagle and others have put a very good case for retaining the IMCr. It is a case with which I agree.

Are you going to call me stupid as well?
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Old 4th Dec 2009, 19:49
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Saab / Bose

Sorry if I got drawn into making anything personal, that was not my intention. You are quite correct that should have nothing to do wth the debate.

It is clear that I fundamentally disagree with Mr Thorpe's views and the way he has "professionally" conducted himself. I dont know Mr Thorpe from Adam; I am sure he is a perfect gentleman. However anyone who sets themselves up in the role he has must be subject to scrutiny - that is part of our democratic process, of which I would expect no more and no less. However I have had the courtesy to set out exactly why I disagree with his statements and views - it would be unforgiveable if I attacked Bose or Jim without explainng why which I have always sort to do.
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Old 4th Dec 2009, 20:10
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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 agree, but it is again not what Jim said. He could have said exactly that, but he preferred to say "whose own experience is quite limited". What does that mean and who has assessed whether their expereince is limited. My IMCr instructor all those years ago I can guarantee you had more experience of IF than Mr Thorpe and most pilots with an IR even though he did not hold an IR.

I imagine the irony is lost on you.
The irony of mentioning in a "technical write up" that some nuter made such insulting remarks that were totally irrelevant to the matter in hand. Sadly I dont think the intention was irony but a feeble attempt to tarnishing the protagonists with the same brush. However, which ever way you read it, it would as ridiculous as Mr Brown talking about climate changing and bereating the nuter that poored custard over Madelson.

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 find that a sad inditement of the whole process. You seem to be saying it doesnt matter to EASA whether or not there is a proven safety case, we are far more concerned with a common standard. EASA is mandated to safety by way of common standard.
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Old 4th Dec 2009, 20:27
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I have stayed out of this little spat until now as I have no interest in the IMC Rating but there is one statement that I cannot let pass without comment.
EASA's goal is about raising safety standards to a common level in Europe
This is simply not true. The fact is that EASA's goal is about achieving a common level of safety standards in Europe that will involve some countries (mainly in the south) raising their standards and others (mainly in the north) lowering them. As with everything EU, it's all about 'one size fits all' which, of course, it never does.
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Old 4th Dec 2009, 20:38
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I think it is far from certain that the IMCR is going to get killed off.

When the EU started going on about animal rights, they got the chief on TV and asked him about bullfighting in Spain... his reply, with a smile, was along the lines of: politics is the art of the possible

What I think people are most worried about is that the IMCR will get negotiated away, while the promised replacement will never come. The "more accessible IR" has a history longer than the 10 years I have been flying, with loads of failed promises, with proposals frustrated at each stage by very well practiced commercial / job protection / elitist interests, and plain inertia.

Maybe EASA has a better chance of doing something on this front but to date there is no evidence to support that belief - unless one assumes that since EASA is a bigger fatter kid than any previous ones, it has a better chance.

I also think that their aggressive stance to do with banning foreign licensed pilots flying in Europe if they are EU residents is going to hit the buffers; obviously I hope it does. This proposal was IMHO a piece of stupidity because there is no realistic fallback / face-saving climbdown position. They bet the whole shop on the USA climbing down and signing a reciprocal treaty with that pompous little hole called Europe. But because this is lumped in with all the other year-2012 stuff, the whole lot might get sunk together. And then if the IMCR is lost as well............. ?? The only accessible IFR option will be the FAA IR, which nowadays means a significant residence at an American motel
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Old 4th Dec 2009, 22:03
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EASA's goal is about raising safety standards to a common level in Europe
This is simply not true. The fact is that EASA's goal is about achieving a common level of safety standards in Europe that will involve some countries (mainly in the south) raising their standards and others (mainly in the north) lowering them. As with everything EU, it's all about 'one size fits all' which, of course, it never does.
Not quite true

I was at a meeting where it was made abundantly clear that

1) Despite its name, there is actually no part of EASA concerned with Safety.

2) EASA is a political organisation where most of the rules are constructed by lawyers working to a brief to bring standardisation (and nothing else) to the EU members.

These are the lawyers who insisted that for 'neatness' balloons would need to carry serviceable ASIs!

The default position is that when constructing rules, national exceptions are anathema, but they start from the premise that what the French do is the baseline. Only in exceptional circumstances will there be opt-outs.

The French get their Brevet de Base and Mountain Rating because they play it cleverly.

We don't get involved in the game and can't get even the simplest opt-out.

Once our leaders (whoever they may be) start to understand this and work with each other, we might start to get somewhere.

The way to guarantee failure is to sound off about how the UK does it better and safer than everyone else in Europe. Oh, and to send out our reps with no defined position helps to really screw things up.
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Old 5th Dec 2009, 08:11
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Not quite true....Despite its name, there is actually no part of EASA concerned with Safety.
Whilst it is true that there is no one department within EASA whose function directly and specifically includes 'safety', one of the first statements one comes across on the EASA website is
Our mission is to promote the highest common standards of safety and environmental protection in civil aviation.
Therefore, it is a little disingenuous to imply that EASA is concerned only with standardisation and not specifically safety standards.

The important point is that, having made such a mission statement, to accept anything less than the very highest safety standards is to immediately fail in that mission. It is thus clear that, by its very nature and composition, EASA is bound to fail - some (many) would say that it already has.
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Old 5th Dec 2009, 08:21
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The way to guarantee failure is to sound off about how the UK does it better and safer than everyone else in Europe. Oh, and to send out our reps with no defined position helps to really screw things up.
Robin

There is a huge arguement made about the IMCR and safety benefits!
That implies as a IMC flying rating it has safety benefits which it does not,
To do that you would need to compare the IMCR to other IMC flying ratings ie the full IR.

THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land,

The easy answer to that is to have the enroute privalages suggested with approach privalages only in an emergency and with a special call.
This would mean you were treated as an emergency and vectored onto an ILS by ATC: Argue the safety angle and thats all you may get on safety grounds with no furher safety arguement.

Hence why I plead to put all efforts towards an easier not less quality IR.
I know the above is not what IMCR holders want. They want the IMCR to be a mini IR in the UK and Europe.

But plead the safety angle and thats all you will or should get on that arguement.

Pace
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Old 5th Dec 2009, 08:38
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The easy answer to that is to have the enroute privalages suggested with approach privalages only in an emergency and with a special call.
This would mean you were treated as an emergency and vectored onto an ILS by ATC:
Without automatic IAP privileges attached to an EIR the pilot is not going to be in current practice or carrying, or familiar with, any particular ILS plate/procedure. In a true emergency any pilot is going to opt for the lowest work load option, ie a vectored SRA approach.

When I did my PPL 27 years ago, this scenario was precisely what the instrument training and SRA part of the syllabus (applicable in those days )was intended to address.
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Old 5th Dec 2009, 08:51
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THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land,
Pace, not only do I think that incorrect, but the CAA would appear to as well. Your statement is not consistent with the privileges of the IMCR.
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Old 5th Dec 2009, 09:39
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Pace

My point was not that making a safety case was invalid, it is that the EU generally get upset by arguing on a national basis.

The IMCr is being seen as the UK solving a problem that does not exist elsewhere in Europe (whether that is true or not, that is how it is seen) and the other members don't take kindly to the UK trying to railroad them into taking a different line, based on national interests.

All other countries engage in a lot of behind the scenes negotiations and horse-trading. I don't think the UK reps at political level, where it counts, do that well enough.
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Old 5th Dec 2009, 09:55
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Freda

THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land,
Please explain which part of my statement above is incorrect? I know what it is used for but that is not the safety benefits of the rating,

I hope you are not trying to say that the IMCR has safety benefits above other IMC flying ratings if so which? I repeat the safety benefits are to VFR pilots who get into non VFR conditions.

To the other poster how many PPLs with IMCR could be classified as current on instrument approaches? very few have the money or regular IFR flights and approaches to be so.

Pace
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Old 5th Dec 2009, 10:18
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Pace,

Perhaps I did not understand the intention of your post?

I inferred from your remarks that you consider the IMCR rating is intended for VFR pilots who plan only VFR flights, to help them if they accidently encounter IMC. I disagree with that. The rating also allows for planned IFR flights into IMC, including planned, intentional instrument approaches.

However, if you are saying the safety benefits accrue only to VFR pilots who fly in IMC – well, that’s sort of self evident, and non-VFR pilots already have a rating to fly IMC, that is IR.

But your wording ("THE SAFETY BENFITS ARE TO VFR FLYING: Ie get in a mess and you have some skills to cloud fly and even to take a down graded IAP to land") suggests the former, with which I do not agree. The IMCR is also for intentional IFR flights.

I think I must have missed your point.
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Old 5th Dec 2009, 10:29
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Pace

how many PPLs with IMCR could be classified as current on instrument approaches? very few have the money or regular IFR flights and approaches to be so.
What would you say is preferred :

1) An IMCR holder who is less than current but who is legal to land on an ILS

2) An IR holder whose IR lapsed a long time ago (because he can't afford his own plane) who dabbles in IFR here and there (because he can't do it overtly) and whose ability to fly the ILS is probably the same as the above IMCR holder

??

I got the IMCR in 2002 and got the IR in 2006, having been flying airways in Europe since 2005 with an instructor.

I don't see the difference in the end product - once the memory of the checkride (my FAA IR one was incredibly hard) fades away.

Basically, a pilot will be only as good as his currency, which in turn depends on

- funding
- a keen interest in aviation and going places
- funding
- spare time to fly
- funding
- spare time to fly (most people with the funding don't have a lot of spare time)
- a keen interest in aviation and going places
- aircraft ownership (more or less mandatory for going places)
- aircraft equipment and his comprehension of it
- his ability to make optimal use of cockpit automation (i.e. none of this "I have an autopilot but don't need it so I fly by hand" crap)

I have a CPL/IR but apart from chandelles and lazy eights (which were great fun), the IFR lost comms procedure, and one or two other snippets, I learnt nothing in the CPL or the IR that is relevant to real flying - over and above what I knew before doing them. Nearly all of the knowledge I use on real flights was learnt elsewhere - probably from other pilots, probably via the internet. I knew more about IFR, high altitude flight, oxygen, airways route planning, etc in 2005 than my IR instructor, and this was fairly evident...

I think that IFR is actually really easy. You have to know about strategy relative to aircraft mission capability and weather / icing etc. Somebody really dumb can learn to fly but they will fail in these more advanced areas. But IFR was hard, the whole earth would be covered in wreckage, which it isn't.

What you have to do is read the plates and fly them. If you fly them wrong, you will probably die. Nothing new there. If you drive on the wrong side of the road the same will probably happen.

I think the emotion about the IR being something "special" is the result of a deep realisation that IFR is really easy and almost anybody with a half decent brain and the ability to read a plate, who can fly headings and levels, and who can operate the aircraft technically, can do it and provided they don't make a c0ckup, they will be safe and correct. But if this knowledge was to get out of the IFR pilots' Masonic lodge, their professional status would collapse.

A lot of IMCR training is crap, but a great deal of PPL training is also crap. And don't I know it - I could tell a few stories myself about mad instructors. The initial IR test in the UK is done by CAA employees, but that isn't the case in the rest of the known universe so there is no evidence that this consistency in the very early stage has any long term safety benefit. The UK IR test is a very narrow airways flight exercise which AIUI any monkey who trained on those routes (which they all do of course) can fly. After a while, none of this means very much.

I have met crazy lapsed IR holders and crazy IMCR holders, and crazy PPLs. Some crazy CPLs too. After some passage of time, all these bits of paper mean sod-all. If I could pick up a JAA ATPL by finding that Mongolia will convert my FAA CPL/IR into a Mongolian ATPL and then Mongolia joins the EU and becomes JAR-FCL compliant, and it charged me Euro 3000 for it, I would do it right away. In the longer term, the pilot is only as good as his attitude, intelligence, and funding. The bit of paper just sets the privileges.

What I do think is a shame is the lack of operational detail training. The PPL is claimed to be a preparation for all kinds of flying but actually it leaves the graduate unable to really go anywhere. The IR is similar - it doesn't teach the operational details of flying especially in the European IFR system. But no training syllabus is going to ever address these things. After all, over here, they are only just getting their hands around GPS - 10+ years after it became the de facto sole nav method for IFR.
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Old 5th Dec 2009, 10:41
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Utfart, please don't assume false and insulting motives by others. I'm not doing that about you, even if I think your comments wrong.

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?
I don't feel I've made any wrong assumptions about people's motives, there are clearly two camps in the argument. Maybe I've been misunderstood by my lack of position on the issue. Allow me to clarify, I don't care about the IMCR as I don't fly in the U.K., if it remains in place 10 years from now, or even becomes available in Europe, it won't have any impact on my life whatsoever.

I have not meant to use the terms ignorance, and lack of diligence, to a attack defenders of the IMCR. It was intended to point out that those whom many have trusted (and paid) to represent their interest, seem to have done an extremely poor job. Regardless of our opinions on the work of Jim Thorpe within the FCL.008 committe, he was the EAS delegate. Why no attack on the AOPA rep on the commitee? Why no attack on the organizers of AOPA UK who didn't manage to get a rep on the commitee? Mr. Thorpe has chosen to publish some information and I'm sure he knew there would be dialogue. I don't feel sorry for him and I'm grateful for the information, but the news he told us wasn't really a surprise, and nothing different than one with knowledge of the mandate should have expected.

I'm in favour of any additional training undertaken by pilots, it can only be a good thing. I was motivated to comment by my perception of a lack of focus in the debate. No personal insult was intended.
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Old 5th Dec 2009, 11:03
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Utfart, thanks for the clarification. I certainly mean no insult to you either.
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Old 5th Dec 2009, 11:33
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If EASA doesn't encompass safety, what's the S for? Also, have a look at this link ECAST

I think the level playing field objective comes from the old EEC where the removal of barriers to free trade within Europe was a main column in the the Treaty of Rome.

For the regulation of aviation EASA have already signaled that rules should be proportionate to the operation being regulated. They also have adopted AMC's to permit states to come up with ways of meeting Implementing Rules.

Lowest Common Denominator (LCD) will be the eventual result.

But wait, the IMCR is a national scheme just like the NPPL, the CAA will continue as an NAA doing EASA's work in the UK. Some aspects of UK aviation will fall outside the scope of EASA rulemaking and hence the CAA will have to devise ways regulating these 'left overs'.

Why not propose to the Captain of the Belgrano that we do things the French way? Sign up to the EASA IR but carry on as before with our UK IMCR. It could just work - couldn't it?

Sir George Cayley
 
Old 5th Dec 2009, 16:03
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Freda Check

Firstly let me make it clear I am not anti the IMCR or its benefits. The only point in its defence Europe wise is that it does add to the safety of VFR pilots.

I do not see any danger that UK pilots with IMCR will suddenly find they can no longer fly in cloud. Equally I do not see any chance of the IMCR being accepted in Europe.

There is a small chance that there is a window of opportunity to get a more attainable IR but on focusing on saving the IMCR (which wont be lost anyway!) we will loose the real prize of a more achievable IR.

So lets all shoot ourselves in the foot by chasing a Red Herring and not being able to see the wood for the trees

Pace
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