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

[Fuji Abound]

see the wood for the trees

Clearly a man who has spent the day watching the golf news.

[Pace]

Fuji

No sitting in a hotel in Berlin just about to go out for some food with my co pilot. Back to the UK tomorrow in a Citation So IFR filed FL360 on an FAA ATP. Strange how we use the same airspace but dont accept each others licences

Pace

[Fuji Abound]

Pace

Have a good one, your co-pilot clearly cant be very attractive as you have been looking at the screen a fair bit.

Here is a thought that might keep you happy.

Leaving aside what may or may not happen in the UK, I think we all understand that the IMC rating sits uncomfortably in a system where there is no IFR in open FIR.

Where ever you place the IR pole, the IMC rating sits below the IR pole and yet if the IMC rating entitled the holder to operate in airways there is little to distinguish an IMC rating from an IR. If there is so little distinction between the two ratings then once must fail. Clearly it cannot be the IR because of the two that is the only rating that achieves ICAO status. The UK of course found a peculiarity of its airspace structure which enabled the IMC rating holder to be prohibited from flight in class A. Thus, there was a clear distinction between the privileges of CAA IR and CAA IMC rating holders in UK airspace.

The EIR attempts the same trick in a way compatible with European airspace (including the UK for those who think we shouldn’t be part of Europe) by distinguishing between IR holders with approach privileges and EIR holders without approach privileges (if the rumours are creditable). Unfortunately this is a very poorly executed trick because there is nothing more ridiculous than allowing a pilot to climb through cloud and then ask him to write his own ending.

So if there is to be a pan European sub ICAO IR a solution must be found which is based on exactly the same slight of hand that the UK found worked so well.

Mr Thorpe was right; you must permit the holder access to class A airspace or at least the lower airways whatever letter of the alphabet you assign to that airspace. However, we pilots are not good story writers, so rather than write his own end every time a way must be found of allowing the pilot to follow the script. In our hearts we all know that is the safer option which is why we all get so excited about made up cloud breaks on a hope and see basis. Moreover, the system is not constructed for us to do so – for that reason the EIR would make mavericks of pilots using the EIR in any meaningful way.

Aside form there being a philosophical need to distinguish between the privileges of an IR holder and an EIR holder there is I believe a safety case. In reality so far as instrument flying is concerned more accidents occur on the approach than during any other phase of instrument flight. It is of course the one and only time we are intentionally closing with matter not compatible with flight or our health. Moreover the closer we get, the smaller the margin for error. As some narrators have pointed out the UK also sits peculiarly in terrain in which we haven’t built airports in mountainous areas. That enables the draftsmen to write approaches which have much more margin for lateral separation than some approaches in Europe.

There has been much debate over whether the recommended minima for IMC rating holders are more than recommendations; whatever the original intent the draftsmen was either having a bad day or had his mind on something else. When I passed my IMC rating a long time ago I thought the higher minima were mandatory and operated to those minima. The higher minima suited me; it took me a long time to feel completely comfortable with popping out at even 400 feet, never mind lower.

I fly for business and pleasure. There are days I really need to fly, but never days I have to fly. In fact since most of my business is in the UK although I kid myself it is faster by aircraft than car when I add up the whole journey there is rarely much in it unless I am going to the I of W (or the CIs) but in the case of the former I don’t have the luxury of an instrument approach in any event. I guess there are a few GA pilots who have to fly, but I would equally bet there aren’t many. Moreover even with an IR and an aircraft that is de-iced there are still 10 days out of every 100 I wouldn’t choose to fly.

For me this means that I rarely see minima’s; and when I do they are not by choice unless I feel a desperate need to fly one, and often it will be with a mate of mine who is a training captain with BA. Checking my log book I have flown to minima’s three times in the last year of which one required a diversion. Am I unusual – I don’t think so?

Where is this going?

Well, we need to find a distinction between the privileges of an EIR holder and an IR holder. We have talked our selves into believing an EIR holder needs more protection than an IR holder and we have acknowledged that the most dangerous part of an IF is the approach. I think we might also all agree the danger increases the lower we get OR in circumstances where the approach is less protected from surrounding terrain. I don’t suppose any of us would argue that vectors to a cloud break on the localiser at minima plus 500 feet should unduly tax an instrument trained pilot. I know, what about the approach in Geneva – and I have flown it! We all check the plates before we launch don’t we? After all it is a legal requirement. The airport authority in conjunction with the national regulatory authority (will that become EASA?) writes the AP for every airport. Perhaps where the IAP falls within certain parameters there might be a caveat under the minima box – NAEIR – not available for EIR holders.

I wonder.

And perhaps the UK would nearly keep its IMC rating privileges at most of its airports by one means or another.

Wouldn’t that be a clever trick?

[Sick Squid]

I don't think classifying instrument flying as easy is either relevant, valid or realistic. In my experience, some of the hardest challenges I have faced have been fully on instruments. Then again, a night visual into some black-hole Island is also challenging.

Perhaps the reason someone would think it was easy is because they have never been loaded up under those conditions? Throw in a couple of failures and a requirement to nail your minima, and the "ease" of flying on instruments might not appear quite so apparent, even without the "masonic"handshakes. After all, if it was that easy, why do professional pilots require a retest every six months, and a revalidation every year? Put someone behind you marking you on that particular venture, and suddenly the ease seems to disappear, does it not? Particularly when your licence is on the line.

Instrument flying is a skill, but it is not like riding a bicycle. If you do not practice it regularly and honestly it will fade. No amount of secret "IR handshakes" will save you then. You might gather I feel that part of the post above was rather frivolous and mistaken.... no-one ever gave me a handshake, and at least once a week I take everything out and practice instrument flying, because I have to. To keep safe, current and relevant. And yes, if I don't do it, I do notice a difference.

So no, IO540. Instrument flying is not easy. It is a skill that has to be practiced. If you find it easy, then bully for you; I don't, never will, and should the day arise I do then perhaps that is the day I will should flying.

{edit} On Reflection, that comment seems to me even more wrong. I'm thinking about flying ATP into the Scottish Islands, at night, in turbulence with no autopilot available, and having to absolutely nail it. I'm also thinking about an approach I did into an African destination with the ITCZ right over the top having to gash a localizer-only approach from 15 miles out as the glideslope had just become u/s and the marker crossing height was 1200" above the field, and that was where the approach started from, and we were coming in at 3000". Where to descend? When to descend? How to calculate that point of descent bearing in mind you can't dive-and-drive an airliner? And what to then do when the right-seat pilot (training Captain) is telling you you are 500" too high.... a quick glance right showed his clock was out from mine as it was all timing based and I'd checked mine on the overhead. But easy? Some secret handshake? No, I think not.

Or the VOR I screwed up into the Bahamas a few months back, not flying it accurately enough so we had to go-around and only got in on a "Highlands Visual" ie "I can see the coast, I know how to get to final from there, you happy? If you are tell them visual and we'll go for it."

So no. Not easy. Never has been, never will be and can bite you in a moment. I would not be happy flying behind anyone who feels IFR flying is easy, and part of some "Masonic" conspiracy. Sorry.

Squid

[IO540]

SS - you are taking my comment out of context. Yes, airline pilots have a line check every so often but they do it on a representative cockpit, not in some GA spamcan in which few people would fly IFR for real, partial panel and with the moving map GPS switched off for the very bits where you want the best situational awareness... Airline pilots also have to fly (subj. to wx above company minima) else they get the sack; a private pilot will generally pick another day. I take my flying pretty seriously but cannot help reflecting on how irrelevant the training practices are to reality.

in turbulence with no autopilot available,

A private pilot would not depart IFR with no AP. One can do the flight but the cockpit workload is high, so why go? I've flown to Greece and back manually (due to AP failure on the way) but would not depart with a duff AP. I know the Trislander crews were/are flying manually - hard work.

[Sick Squid]

I don't agree with you that it's out of context. It actually strikes right to the heart of the argument I would espouse that there should be two completely separate disciplines in flying, vis. instrument and visual with no middle area in between where only certain instrument skills are taught and allowed to apply to lowered minima. It is that lowering of minima for planning purposes, and perhaps also the relevant increase in "perception" of skill that I feel should not be part of regulation. The fact that it was in the UK is, again in my opinion, unfortunate.

Practice is the relevant verb here, and yes, from your post above I see you agree on that. What I would argue is that is practice and checking of skills is perhaps more relevant than most people realise. In an ideal World I'd see an increase in basic IF flying taught in training, and checked every year as part of licence revalidation as a "get my ass out of the ****" skill. As for full IFR flying, then that again should be checked separately, and with failures thrown in. All just my opinion, and I do realise there would be a financial cost with that, but so be it, I feel it is that significant an issue.

The ATP reference to no autopilot was simply that it was not available in turbulence. We could, and did often depart with the whole thing u/s, but again we were a multi-crew environment. IFR single-pilot is a call that would always require a second thought, and respect to those that choose to do such.

Regards,

Squid

[englishal]

Flying IFR is easy under normal circumstances IMHO. It is even easier for airline pilots - for example I flew from London to LA on a B747 recently and the amount of time spent in IMC was oooohhh....Nil. I've flown my fair share of light singles and multis without AP and basic instrumentation and enjoy it. I wouldn't do it for 600 miles though, but a hop from Jersey to Bournemouth---no problem.

I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too.

Requirements for the "commercial" IR should be a formal course and exams OR a Private IR already held and some other stuff.

It really is so easy so I just don't know why this won't happen. I suppose it is a function of being in europe , with too many people who will never agree.

[mm_flynn]

Originally Posted by englishal

I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too.

To a very real extent that is true in FAA land and if the FCL.008 proposals on the more sensible IR come to pass it will be true here as well. (In the sense that the commercial stuff is included in the commercial licences and in the US the ATPL ride and type ratings have significantly tighter IMC tolerances than the IR).

I have disagreed with a lot of what Fuji has said, but his most recent post seems like a very sensible strategy to go forward with.

[Fuji Abound]

I have disagreed with a lot of what Fuji has said, but his most recent post seems like a very sensible strategy to go forward with.

Thank you.

[IO540]

SS

Perhaps my choice of the word "easy" was irreverent but that is just my writing style

IFR is a highly structured discipline which has enabled tens of thousands or more pilots from all over the world, with all kinds of education backgrounds, to fly worldwide. And lots of them are landing at LHR as I write this Sitting there, twiddling the heading bug according to ATC directions, until getting LOC intercept...

IFR facilitates very easy flight across Europe and its diverse airspaces and its sometimes "diverse-attitude" ATC.

If IFR was hard, few private pilots would aspire to it. Most I know agree with me that the greatest secret of IFR is that once you have passed the checkrides and collected the papers, the actual flying is nothing like as hard.

There are other major differences between commercial IFR and private IFR:

- few private IR pilots would choose to fly the Trilander type ops, occassionally scud running at 400ft above the sea because of hugely limited capability to get above weather

- most private IR pilots have substantially capable planes, in both navigation and altitude

- most private IR pilots don't have to fly; even on a business flight visiting a customer (the hardest kind of "business flying") one can choose alternative transport

- private IFR is done in an empty airspace void; FL100-FL200 in which there is close to zero commercial traffic, and one doesn't get routings through terminal areas where the two might be closer

I can see where you are coming from but I think it illustrates why for years there has been close to zero progress on making the private PPL/IR more meaningful in Europe - while the Americans are laughing all the way to the ILS (or I should say the precision GPS approach.........)

For avoidance of doubt: I think an IFR pilot should be trained to fly every type of instrument approach, and holds, and should be examined on these. It is the theory and the mandatory nonsense (industry protectionism like having to do stuff via a professional FTO, and 50/55hrs min dual which is not relevant to demonstrated competence) which needs overhauling.

[421C]

I just don't know why there can't be a "PRIVATE" and "COMMERCIAL" IR (or my preferred wording "not authorised for public transport ops". For the Private there should be training as required to pass the flight test, one exam, and credit for previous instrument time (for example then the IMC time would count). The flight test could be to the same standards too

Englishal,

There is today exactly the Private IR you describe. It is the JAA IR. You can't use it for public transport ops unless you have considerable additional training and qualifications
- in a light piston aircraft; CPL writtens, a CPL and all the line/base training and checks required under the operator's approvals
- in a larger aircraft, all the above, plus a Type Rating passed to higher (ATPL) standards and an MCC and the ATPL writtens
and there is nothing in the current flight training and testing which is specific to public transport. The written exams have a few remnants in airlaw which might be considered as such, but let's remember the JAA IR syllabus is already signficantly slimmer than the present one in the UK. It's simply that the UK CAA have not chosen to implement the JAR-FCL amendment and the new question bank that have been available for a year or two.

I wrote a post earlier with a bit about the "privilege limitation fallacy". I don't mean for 'fallacy' to sound derogatory - perhaps 'problem' or 'conundrum' would have been better, but the earlier discussion was a bit more heated...

Let me repost it adding your restriction to the list in underline.

......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.
- can't be used for public transport ops
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

What FCL008 is proposing is
- a further reduction in the IR TK syllabus to eliminate items not relevant to the privileges granted. These are not 'commerical' items, they have already been elminated. They are irrelevant depth in the private items.
- a training method more flexible than the current ones, which were primarily designed for the purpose of turning zero-hour cadets into 190hr junior FOs for the RHS of transport jets
But, the irony is that, although the JAA IR training structure was designed to fit the Integrated/Modular routes to a frozen ATPL, the actual content is wholly focused on low-level IFR in small piston aircraft, with no meaningful 'commercial' elements.

EASA has already decided the standards needed to operate a light aircraft under the priviliges of a 'private' IR. They are those of the current JAA IR. All the extra stuff (from Commercial/PT to operating a 3 engine pressurised aircraft with more than 6 seats in RVSM/Oceanic airspace) needs a bunch of extra training in addition to that of the current JAA IR.

No 'privilege limitation trick' is going to change this. If the current JAA IR immediately qualified a PPL to fly commercial or jet stuff, then privilege limitation would work. But it doesn't, because it qualifies you for nothing more, as a PPL holder, than to operate a light aircraft privately under IFR in all phases of flight. Which is exactly what we want in a 'private' IR and exactly what the IMCr does outside Class A. But see above my points on the "Class A limitation".

We may all agree that the FAA methods, lock stock and barrel, are as safe and a lot more flexible and efficient than the European ones. But until someone has a masterplan to overthrow the entire regulatory model in Europe, I think our best bet is to support the FCL008 outcome within the EASA model. Outside of the EASA model, of course, the UK can try and save/exempt/grandfather the IMCr and good luck to those efforts.

[Fuji Abound]

But until someone has a masterplan to overthrow the entire regulatory model in Europe, I think our best bet is to support the FCL008 outcome

That very much depends on which bits you pick:

1. The EIR as rumoured is unsupportable. In fact I think it is dangerous,
2. The lack of grandfather rights (if that is the case) for IMCr holders into the EIR (or at least a realistic conversion) is unsupportable,
3. Since we dont know as usual what the IR concessions will be, there is nothing to support at the moment.

Unfortunately in so far as private pilots are concerned that doesnt leave a lot.

EASA should consider my solution to the EIR problem, but then I would say that.

[drambuster]

This has been an interesting thread kicked off by AOPA's article in December's GA magazine which I read with mounting dismay last Sunday.

There have been some convincing posts for the retention of the IMCr by Fuji and others. I am a firm supporter and can attest that at my own flying club the most proficient pilots at combining GA jollys with demanding clag flying (often manually) with IAPs at the conclusion tend to be IMCr holders. Of course they are no different as individuals from the IR lot - but this is all about 'currency' - and the IRs tend to be commercial crew who do it all week (on triple autopilot, auto throttles, full instrument landings etc etc) and by the weekend they are just looking for a different kind of fun - and the prospect of bouncing around in cloud in a spam can doesn't seem to tick their boxes ! (but don't get me wrong - they are top pilots who could do it if they felt the urge)

Sadly I think the current situation was best summed up by mm_flynn:

Blathering on forums, Number 10 petitions, writing to FCL.008, dark threats, etc. are going to wind up with the IMCr holders being left behind. Only realistic lobbying of the key decision makers is going to achieve the objective of retaining all of the current privileges of the IMCr.

PS - no one is 'holding their noses' up at IMCr holders - but the IMCr holders need to fight their battle not hope some Euro committee will save them!!

Until this weekend I thought AOPA UK were leading that battle - based on the magazine article they appear to have been leading from an armchair.

This was reinforced by this morning's review of the latest Loop magazine:

"IMC saved my life" - You respond in droves to campaign to keep UK's IMC rating:
"The campaign to HELP THE MEN FIGHTING TO KEEP THE IMC RATING ALIVE and legal for UK pilots has been overwhelmed by your support . . . etc"

They go on to say:

"Many thanks for all your submissions to AOPA to add your support. Email your testimonials to LOOP . . . . . [and] we will forward them to AOPA's Martin Robinson"

As Cows getting bigger so eloquently put it (post 11):

"at the risk of sounding flippant, WTF is going on ? . . . "

My thoughts exactly Who precisely are all these 'MEN FIGHTING' to keep the IMCr? I am an AOPA member and in general I support all that they do . . . . .. but I have to say Martin Robinson now needs to explain exactly what he is up to as the 'campaigning' seems to be getting absolutely nowhere. I have an overwhelming sense that we are losing the battle to keep the IMCr (whether as a UK 'one-off' or some form of PPL-IR) through inept handling of the necessary politics.

How come AOPA UK failed to get a seat at the meeting? How come the IAOPA representative failed to push our case when it must have been obvious to those 'in the know' that Thorpe and his mates would love to see the rating eradicated? Frankly this shows how poor we Brits are at getting our way in Europe - we just don't know how to do it. Very sad as the potential consequences will be absolutely dire . . . .

Mr Robinson would you please post a statement on the AOPA website explaining how you are going to turn this situation around? Can I suggest you urgently engage an aviation lawyer (the Flying Lawyer aka Tudor perhaps?) to advise on how best to improve our lobbying? We only have one chance so please don't blow it.

. . . .. and maybe you should hire a French or German national to front our campaign as at least we won't then miss every trick in the book

Finally, under the 'news' section of your website there does not seem to be any reference to the IMC Campaign at all - why not? What happened to the 'urgent meeting' you were having with Mr Eric Sivel? Surely your website news section should be updated every week on matters such as this?

Yours,

(one well and truly dismayed)
Drambuster

cc LOOP and AOPA by email

[bookworm]

Mr Thorpe was right; you must permit the holder access to class A airspace or at least the lower airways whatever letter of the alphabet you assign to that airspace.

Aside form there being a philosophical need to distinguish between the privileges of an IR holder and an EIR holder there is I believe a safety case. In reality so far as instrument flying is concerned more accidents occur on the approach than during any other phase of instrument flight. It is of course the one and only time we are intentionally closing with matter not compatible with flight or our health.

OK. So you seem to agree that we cannot have a meaningful pan-European instrument qualification with privileges restricted by airspace class, and that flying IAPs safely is the most demanding aspect of IF. You want to propose a sub-ICAO pan-European IR based on reducing the amount of training required and applying a restriction to the privileges which is appropriate to that reduction in training. On that basis, I don't think there's any difference between what you, Jim Thorpe, and FCL.008 want to achieve.

Where you differ is on the magnitude/nature of the reduction in requirements and the appropriate restriction of privileges. You want the restriction to be based on higher minima. So the question becomes "what is included in the proposed IR that you not need to know, and that you do not need to be trained to do competently in order to fly approaches to higher minima?" There would seem to be three options for reduction:

1) The theoretical knowledge.
2) The dual training hours required.
3) The total hours of IF required.

FCL.008 came up with the EIR. Same TK. 15 hours of dual instead of 25, reflecting 10 hours less training on IAPs (note, no one has said "no training on IAPs"), and a removal of the 40 hours minimum IF (which is there to comply with ICAO standards). The restriction is yet to be detailed, but I think we can deduce from what has been written that it would involve some measure of avoidance of IAPs in IMC. One could argue that these are increased minima of a particular magnitude.

What's your proposal, and, more importantly, how is it appropriate to the higher minima restriction that you suggest?

[englishal]

and there is nothing in the current flight training and testing which is specific to public transport.

Right - that is the problem.

People like to harp on about the FAA ATP flight test, well the FAA ATP is required to fly certain transport aircraft / ops - namely scheduled airline type stuff as commander.

In JARland we expect our 200 hr C152 and 50 hr SIM pilots to be capable of commanding a 747 as captain under instrument conditions? That is nuts, which is where the FAA 1500 hr ATP minimum and test (and as was the Norwegian system and I believe the UK system too in the old days) makes complete sense. Why not revert the EASA ATP back to that and get rid of this "frozen" ATPL nonsense.

This way we wouldn't have to have a gold plated JAA IR as the only option. Incidentally is it gold plated or not or just anal? On his test / 170A my mate had to "dead reckon" his way to ORTAC on some departure from Gurnsey despite having a fully functional G430 in the aeroplane. That is just plain stupid.

I calculated yesterday that for me to convert to the IR it would cost me £1000 for the ground school, and then abut £500 for the exams, plus the examiners fee of £700 - and that is before one bit of flying. Unless this changes then an IR will be no more accessible than it is now.

I still think the EIR is a sensible step forward, but ONLY if it includes a precision approach capability.

[Captain Stable]

Flying IFR is easy under normal circumstances IMHO. It is even easier for airline pilots - for example I flew from London to LA on a B747 recently and the amount of time spent in IMC was oooohhh....Nil.

That the flight might not have been in IMC doesn't mean that it is any easier.

Please do NOT confuse IMC with IFR. We've already had that discussion.

FLying some of the more complicated IFR approaches is pretty damn difficult, in VMC or IMC - it makes no difference. The tolerances remain the same, the possibility of misreading hte plate or the DME is the same, the possibility of busting an intermediate altitude is the same.

If you think being in IMC makes a difference, you know a grand total of ZIP about flying IFR.

Where there is a big difference for a relatively inexperienced private pilot is that, unless practising, he will be flying an approach for real, with few of the toys that Sick Squid has at his disposal, and the pressure will be on. He may be disorientated, worried and distracted by even a small equipment failure. Add in night and poor weather, slight traces of icing... We owe it to him to ensure he is trained to do it. If his training is less than that of an IR, then to higher minima.

Conversely, I accept that a daytime descent through a slight layer of stratus with base at 2000' AGL in +15 degC with a decent 3-axis autopilot switched into the HSI and a serviceable aircraft is not terribly taxing.

But there is little difference in conditions between those two scenarios that is allowable in a rating. One is not nice even for a professional pilot in good practice. The other is a doddle even for an 80-hour PPL.

[FREDAcheck]

I still think the EIR is a sensible step forward, but ONLY if it includes a precision approach capability.

And preferably non-precision, with suitable minima. Why not? Some of the smaller airfields with instrument procedures - the sort that IMCR holders might fly to - don't have ILS. I'd much rather fly an NP procedure to break through a cloudbase of 800-1000 feet than risk it DIY - when the MSA might well be 2000 feet. (We can have a separate debate about what the minima should be - whether the existing recommended 500/600 feet AAL are suitable.)

[bookworm]

FLying some of the more complicated IFR approaches is pretty damn difficult, in VMC or IMC - it makes no difference.

Your point is a good one, but I think you exaggerate. Flying IFR in VMC can indeed be "pretty damn difficult" in some circumstance, but handflying a light aircraft in IMC undoubtedly adds to the workload, otherwise we wouldn't bother with those pesky screens and hoods for practice. IMC also takes away the safety net of seeing the obstacle before you hit it.

Where there is a big difference for a relatively inexperienced private pilot is that, unless practising, he will be flying an approach for real, with few of the toys that Sick Squid has at his disposal, and the pressure will be on. He may be disorientated, worried and distracted by even a small equipment failure. Add in night and poor weather, slight traces of icing... We owe it to him to ensure he is trained to do it. If his training is less than that of an IR, then to higher minima.

I think one of the points IO540 is making is that to force the pilot to fly at low level and deprive him of an air traffic control service because the airspace above him has the wrong letter attached is hardly going to make his job any easier. Yet the difficulty of flying IFR for IMC-rated pilots tends to be increased by the airspace class restrictions. To fly IFR with an IR is usually considerably easier than what they have to deal with, as we have more levels available and more ATS help. That is yet another reason why a reduced-privilege instrument qualification must not be arbitrarily restricted by airspace class.

And I have reservations about any restriction being based on IAP minima. A couple of hundred feet vertical buffer sounds as if it's a concession to inexperience, but is unlikely to save the poor overloaded pilot who turned the wrong way at the fix, misread the platform altitude from the plate by 1000 ft, selected the wrong VOR (these days I guess it's "flew towards ABAMO rather than ABUMO"), or misheard the ATC clearance and failed to check the MSA. The vertical tolerance with which one flies a profile has a lot more to do with currency and experience than the amount of training one received 10 years ago at an approved organisation.

[Keef]

Originally Posted by IO540

A private pilot would not depart IFR with no AP.

Sorry to disagree, but: Yes, I would. I often do. It hones the handling skills.
It also tests how well I've prepared the stuff I can prepare, and how well I cope with the unexpected.

Whether or not I shouldis a different question. My IMCR instructor, many many years ago, taught me to use all the equipment available, but to fly with whatever's there - as long as it meets the minimum IFR requirements.

So I do. I flew the FAA IR checkride, at night, in an Archer with no A/P. It was a long session, too, as that checkride is.

[Fuji Abound]

A couple of hundred feet vertical buffer sounds as if it's a concession to inexperience, but is unlikely to save the poor overloaded pilot who turned the wrong way at the fix, misread the platform altitude from the plate by 1000 ft, selected the wrong VOR (these days I guess it's "flew towards ABAMO rather than ABUMO"), or misheard the ATC clearance and failed to check the MSA.

There is a choice to be made between Mr Thorpe's idea of pilots climbing through an overcast (hopefully, but not necessarily, into VMC) followed by a descent before their destination in the hope that they will safely achieve a cloudbreak and achieving VMC on an IAP but with a greater buffer minima than IR holders.

That choice will have to be made unless Mr Thorpe proposes that an EIR holder may only depart if his destination is VMC. If that becomes his proposal then we may as well all give up on this one.

I accept there are some airports were there is less margin for error because of either the complexity of the IAP or the terrain. That is why I proposed the airports have the authority to make certain approaches or certain airports unavailable to pilots with an EIR.

It should be remembered a great many airports with IAPs have radar which inevitably provides a degree of protection from pilots making turns in the wrong direction.

My proposals are commensurate with the needs of private pilots who do not wish to hold an IR, whilst providing the EIR holder with additional protection during the most dangerous phase of IF, whilst keeping the pilot on the same hymn sheet as everyone else in the system rather than making up his own procedures - I commend these proposals to you.