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

[FREDAcheck]

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.

That makes sense, and another mistake for less experienced pilots is probably "wrongly set QNH". But restrictions on minima would be enough in some cases, I would have thought. For those requiring accuracy for obstacle clearance, or busy ones where volume of traffic would make wrong turns more than usually hazardous, they could simply make the procedure "no EIR".

[bookworm]

My proposals are commensurate with the needs of private pilots who do not wish to hold an IR,

Sounds to me like that's exactly what they do wish to hold...

[IO540]

Sorry to disagree, but: Yes, I would. I often do. It hones the handling skills.

As often, I don't write an essay on each point

It depends on the flight.

If I was flying from say Goodwood to Southend, OVC008 at each end, and done mostly at 2400ft as one does in that area, I would not be worried. In fact I would probably not use the AP, because when flying "real IFR" one spends so much time in VMC that one doesn't get enough hand IMC practice. On my last big trip (Turkey LTBH via LDSB, and back via LGMT, LDSP) I logged about 30hrs I think and barely a few minutes "instrument flight", which is not unusual for high altitude IFR with an appropriate icing strategy.

I think that when flying IFR/airways one should aim for the most professional conduct, which means flying accurately and generally being on top of things w.r.t. ATC etc. This means making best use of cockpit automation. The place to practice hand flying stuff like NDB holds is in Class G, at 5000ft where few in UK GA have ever ventured, out of the way, in real cloud, and one can do them over and over without anybody else caring. I do that about once a week on little local flights. That is also the place (with the 0C level being no lower than 2000ft) to see how much one's IAS drops versus the thickness of the ice picked up

But a flight from Goodwood to Prague, IFR, with a duff AP? I would not go. I would get the AP fixed. I would not accept the reduced safety of the increased workload. I would go with a co-pilot (and indeed I have done more or less exactly such a flight with a co-pilot a year ago, when a replacement for a failed pitch servo had not yet turned up from the USA).

Another reason I would not generally fly for real with an INOP AP is that unless the fault is positively diagnosed, one cannot be sure there isn't a latent defect in the electrical system which is actually not limited to the autopilot system. This is a much wider safety policy issue and is why I don't like flying the old GA training scene wreckage which is often covered in INOP stickers. Is such and such item INOP because the specific piece of kit is duff, or because a wiring harness is slowly getting cut through / shorted out against a bulkhead? A lot of defects are left undiagnosed due to working under the cost pressure of a typical FTO owner. Unless somebody chased down the defect, you just don't know, and "not knowing" is a no-go for me.

[Fuji Abound]

Bookworm

Sounds to me like that's exactly what they do wish to hold...

That seems a very strange remark for you to make?

What would you propose and why?

[bookworm]

What would you propose and why?

I would propose:

* that those who wish to fly IFR should get an instrument rating

* that the training requirements for the IR should be proportionate to the real needs of instrument flying (as apparently proposed by FCL.008) rather than being needlessly costly and time-consuming

* that the standards for IFR flying should remain single tier and universal

* that any sub-ICAO instrument qualification is considered not as an end in itself but as a stepping stone to an IR, in the same way that student solo flight is considered a stepping stone to a PPL (or CPL/ATPL).

On the last point, I remain encouraged that such a stepping stone is possible, but I don't feel too attached to the idea that it has to be the Enroute IR that FCL.008 has discussed. I have not, however, seen a proposal that convincingly balances privileges and training of any such sub-ICAO rating.

[421C]

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.

I think (with respect) you've misunderstood the differences between the two. The JAA IR is not the JAA world's equivalent of the FAA ATP checkride. The equivalent is the Type Rating in a Multipilot Aircraft (MPA TR) you need to get, after an MCC, in order to qualify for a JAA ATPL. It's pretty similar to the FAA system, where every Type Rating is done to ATP standards, but under the JAA there is no ATP checkride you can do in a light piston aircraft, but you can do your final ATP checkride (the MPA TR) before you qualify for the hours.

Our 200hrs C152 man has to pass a type rating on a 747 (amongst other things) before he can command one! The private and commercial routes diverge after the JAA IR, not before it.

This way we wouldn't have to have a gold plated JAA IR as the only option.

As tempting as it is to assume the JAA IR is the "ATPL gatekeeper" it simply isn't. The ATPL writtens, the 1500hrs and 500 multicrew and the MPA TR are the 'gatekeepers'.

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.

Neither. The "dead reckon" to ORTAC is just being practical if RNAV is not used. It's quicker than intercepting the radial from the GUR. The fact RNAV isn't used is more down to the schools than the CAA; many do not teach the use of GPS because it would add more workload to the course. The use of GPS and Autopilot are already perfectly acceptable in the JAA IR; it's just that single needle tracking of radio aids and hand flying also have to be demonstrated. So schools focus on the parts likely to catch students out, not the relatively easy parts.

My understanding is that from Jan 2010, there will be a change in policy from the CAA IR Examiners, to permit GPS approaches as the NPA on the IR and to reduce the single needle enroute and approach work. I saw a letter in an FTO and don't remember the details.

There is very little difference in content between the JAA and FAA IRs. There's a lot of difference in training processes and structure.

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 doubt if anything is going to get materially more accessible than the already pretty reasonable FAA to JAA IR conversion. You don't need a formal course of ground training, you just sit the written exams for the costs you describe. Then its 10 Sim Hrs and 5 Aircraft hrs (or all in your own aircraft if you prefer) plus the exmaniner fee. What really hikes the cost is the 50hr initial course for people who don't have an ICAO IR; the relatively small number of FTOs around can also be very inconvenient. Under EASA, the RF vs FTO distinction will disappear - they all become ATOs. The written exams will probably get cheaper and dragged into the late 20th century in terms of computer testing at independent test centres. All IREs, rather than just CAA ones, will be able to conduct initial IRs.

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

The problem is that you see it as an "EIR with precision approaches" and EASA will see it as an "IR without non-precision approaches" and conclude that course needs to be pretty much like the current IR with a few bits trimmed. They are not going to say "good lord, without NPAs we can make it a totally different training model". And if you are going to do all the exams and training and take the test, why not include the one NPA flown on the test and get a full IR?

[Fuji Abound]

Bookworm

You should be very careful what you wish for.

If you are not careful you will get the promise of a more relevant IR, period.

That would be the worst thing that has ever happened to GA in this country - and I refer intentionaly to this country because as much as I support the EC people on this thread are concerned about what happens in their backyard.

At least even FCL008 realises there is a need for an intermediary IF rating and are in step with "modern" thinking. Modern because the Australians are the only country in recent times to have overhauled FCL and they effectively went exactly that route.

Clearly we are much further apart than I thought, sadly.

[Fuji Abound]

and if a simplified IR were really come to pass, in the end few would bother with the IMC rating or EIR so what does it matter if you introduce these during the transition? I bet if you introduced and EIR or IMC rating in FAA land no one would bother with it, BUT they have a realsitic IR.

The trouble is you will be promised one and get neither. Go figure.

[FREDAcheck]

bookworm, I'm afraid I have to disagree with you.

* that any sub-ICAO instrument qualification is considered not as an end in itself but as a stepping stone to an IR, in the same way that student solo flight is considered a stepping stone to a PPL (or CPL/ATPL).

That really isn't what most IMCR holders are looking for. For them IMCR isn't a stepping stone to anything except exercising the privileges of IMCR.

Saying that IMCR holders fall into two groups: those that really want IR, and those who want to cope with accidental IMC, simply isn't true. Sorry to be so blunt, but it's a mistake to try to wish away any requirement for IMCR by imagining people really want something else (or would do if only their eyes were opened).

I'm well aware of the hostility to IMCR or any sub-ICAO instrument qualification, but really: the IMCR is what is wanted to fill a substantial need among PPLs.

It absolutely won't meet the need to have an accessible IR and quietly trash the IMCR.

[Keef]

Things are getting awfully "black and white", and inappropriately so in my view.

I'm a defender of the IMCR, and will be exceeding miffed if it disappears with no replacement. However, if EASA came out with a "halfway house" IR that was very like the IMCR (but different) - I wouldn't be yelling "NO WAY". I'd be wanting to know more about the details.

The EIR as defined - with no IAPs - doesn't cut it, I think we agree. Not even as a "stepping stone to the real IR". I think that message has been communicated. I hope it's been understood.

Anyone who can pass the IMCR written can, with a bit of application, pass the FAA IR written. Take that as the "benchmark". EASA say they will simplify the IR written: I'd like to know more about what that means before I reject it out of hand. If it's just "tinkering at the edges", they know what the reaction will be. If it's something very like the FAA IR (ie totally relevant), the reaction should be positive.

I remember when I did my FAA IR asking the instructor "is this the same IR that the ATPL flying a 747 has?" His answer was "Question is irrelevant." He explained that it's the same IR "on paper", but that the ATPL checkride tests IFR capability all over again, and the test standards are higher. If you have an FAA ATPL, he said, effectively you don't "need" an IR because the IR is included - and to those higher standards.

From memory, the checkride standard was for example "maximum of half scale on the localiser/glideslope" for the IR, and "quarter scale" for the ATPL. Those may be wrong, but that was the principle.

I took and passed the FAA IR after self-study and the "recent training hours with an FAA CFII". The other hours required by the FAA were obtained from the IMCR course I did all those years ago, and the hours I'd built up flying around the UK using the IMCR. It was a logical, challenging but achievable process.

Had I had a CAA IR, the requirements to get an FAA one would have been minimal. Sadly, the UK CAA regards (or regarded, I dunno) the FAA IR as being sub-ICAO in some way and won't return the compliment to the FAA. They required me to do the whole academic bit, more training, and then the full flight test. Fair enough on the flight test, maybe on the training, but rhubarb on the study. So I didn't do a CAA or a JAA IR.

My hope is that EASA will recognise and deal sensibly with the safety need for an achievable IFR qualification for PPLs and other non-ATPL types (as the FAA did) and disregard the vested interests that want to preserve the present jumbo mumbo-jumbo. I don't think many on here disagree with that. Or I hope that's so.

[flybymike]

Can I suggest you urgently engage an aviation lawyer (the Flying Lawyer aka Tudor perhaps?)

I believe Tudor is a Circuit Judge these days, and don't imagine he could become involved even if inclined.

[bookworm]

Saying that IMCR holders fall into two groups: those that really want IR, and those who want to cope with accidental IMC, simply isn't true.

You're right, FREDAcheck. There's also a group who want to exercise the privileges of an IR but are not prepared to demonstrate their competence to do so by going through a training and testing process that is proportionate to the privileges of the rating. They claim that they "don't need an IR" by striking off privileges that they mistakenly believe differentiates what they do from what instrument rated pilots do. But, probably since most of them have not held IRs, they actually expect to be allowed to perform most of the hardest flying tasks expected of an instrument rated pilot and still be exempted from the training and testing framework that will be put in place for FCL. And I fear they will be disappointed.

[IO540]

One thing which needs to be appreciated is that to fly around Europe in controlled airspace under IFR, one needs more than an "IR".

One also needs an appropriately powered and equipped plane. The minimum altitudes at which one can file Eurocontrol routings are about FL070. However in many areas FL070 results in a terribly roundabout routing and FL100 is where it starts to be viable. FL120 is required in many places to avoid big doglegs. FL140 is pretty good, and is the minimum to cross the Pyrenees. FL160 is required to cross the Alps. There is a lot of detail I am leaving out here (like minimum LTMA overflight levels being about FL100 plus) but basically that is the picture. The routes cannot generally be worked out from an airway chart; one has to use special routing tools to develop them.

So you need a capable plane, very preferably with oxygen, etc.

Above FL095 (and airways routings don't work well below that in many places) the only legal means of navigation (in GA context) is an IFR BRNAV approved GPS installation.

Mode S of course, everywhere.

I don't think many people have access to this level of equipment. In general you will be an owner, or in a reasonably upmarket syndicate. Then there are the Cirrus "zero equity" rental groups, etc. but they are far from cheap.

There is also a significant amount of technical/operational knowledge, much of which isn't taught anywhere. But that's another story.

The IMCR, with its restrictions, suits an awful lot of casual flyers/ renters very well.

The IMCR training is also generally used towards the FAA IR, although last time I wrote about this I got hit with a filthy libellious and widely circulated email alleging flying on a fake IR etc. In practice this is usually moot as almost everybody reaching the FAA checkride standard will have done the whole FAA 15hrs dual time in the USA with an FAA instructor - myself included

I think most FAA IR holders started life as IMCR holders and this enabled them to do an awful lot of instrument practice on their own, which is much more relaxed as well as cheaper than flying with an instructor as one would for 50-55hrs for the JAA IR. So even if they did not strictly speaking use their IMCR training time towards the FAA IR's 15hrs requirement, they still saved a big pile of money. By the time I went for the FAA IR, I had a bigger part of 100 instrument hours already.

[mm_flynn]

Originally Posted by IO540

One thing which needs to be appreciated is that to fly around Europe in controlled airspace under IFR, one needs more than an "IR". ....

IO,

I think you are painting an overly complex picture of IFR in Europe. Certainly over the Alps and Pyrenees you need to be able to reach O2 levels to be safe. However, there is a reasonable amount of 'Near Europe' that is nearly as benign as the UK from a terrain perspective. Some of those countries have a similarly relaxed attitude towards DCT routings as the UK - and even better, have not designed their airways around turbine routes! In these countries any reasonable aircraft can be an IFR platform.

The UK is unique in its approach to IFR (in that about the only rule in IFR is 1000 ft above the ground, if you can't see it, unless you are trying to land (there are others but they either exist implicitly in the V rules or are recommended but not obligatory for Visual flight), as such it does help create this view of pilots than 'I am VFR but am in IMC' and that IFR is what people do up high on Eurocontrol routes.

It is actually quite enjoyable to be able to duck through clouds without the overhead of an ATC clearance/routing, but it is a concept totally out of synch with the rest of the world.

[IO540]

Yes, I agree but I was referring to the airway MEAs rather than terrain. Most European airway MEAs are set by ATC rules / airspace classification and bear no relation to obstacle clearance, and this is especially so in the UK.

[Fuji Abound]

There's also a group who want to exercise the privileges of an IR but are not prepared to demonstrate their competence to do so by going through a training and testing process that is proportionate to the privileges of the rating.

and you base that spectacular assertion on what evidence?

It is most unlike you Bookworm to be carried along by emotion, you should stick to the facts.

I think whatever Europe does it is quite insulting to IMC rating holders who have taken and passed a series of tests laid down by the legally appointed regulatory authority and then imply that they have not demonstrated their competence.

THEY have!

You may not like it, you may disagree with the IMC rating, but doubtles there are more than a few who would disagree that the IR standard is proportionate. Simply because you believe one standard is more proportionate than another has little to do with reality unless you can base your assertion on evidence rather than getting carried away by your emotions.

I might just as well say I think your IR is worthless because the test and training is hopelessly out of step with whats needed to fly in controlled airspace in Europe in a light sinlge.

Anyway we shall just have to see. There is a democratic process to be followed. You can bet we havent heard the last of this. You can also bet that a lot of pilots will not simply roll over and accept the outcome unless it is proportionate.

I am done for the time being because we are just going around in ever decreasing circles without any ambition by many to address the real issues.

[bookworm]

I think whatever Europe does it is quite insulting to IMC rating holders who have taken and passed a series of tests laid down by the legally appointed regulatory authority and then imply that they have not demonstrated their competence.

And I've done nothing of the sort. I've repeatedly said that I believe that group of IMC-rating holders, who use their ratings to plan and execute IFR flights which would require IRs in any other country, are perfectly capable of demonstrating their competence to do so by taking and passing an IR skills test. What puzzles me is why they are so adamant that they shouldn't have to.

[Fuji Abound]

I did say that was my lot but reluctantly:

Come on Bookworm you know exactly why they would say that, you are just being mischevious.

I wonder how many IR holders could pass an initial IR check ride - and indeed why they would want to. I know I probably couldnt if I turned up tomorrow claiming I was a first time student and wanted to take the test.

Moreover, you know full well the check ride for the IMC rating is different to the check ride for an IR and presumably the check ride for an EIR would be different again. The check ride for an FAA IR is different from a JAA IR, and doubtless different from an ICAO IR check ride in outer Mongolia.

I recall many years ago I turned up for an IMCr renewal with a different instructor. The fella had an IR. He asked to see my PLOG and expected to see all the freezing levels calculated, W and B, and half a dozen other matters which were complete nonesense. (It was August and we couldnt have reached the freezing level if we spent all day trying). I went round the corner as they say to a chap who didnt have an IR but had 100 times the experience of our latter day saint.

[Katamarino]

I think a big reason that many IMC holders would not wish to go ahead and 'demonstrate their skills' to get an IR currently, is the sheer amount of unecessary money to be sent to the numpties at Gatwick for doing...pretty much nothing. 700 pounds for the privelige of taking a short examination? The CAA certainly monopolise their way to impressive hourly rates for sitting on their arses and trying to stop us from flying!

What do they even do nowadays? All the recent times I have sent them questions, I've received the reply 'we don't know, ask EASA'.

[IO540]

I may be missing something obvious here but I don't understand why UK IMCR holders should be required to pass an IR checkride to continue exercising their IFR privileges in the UK.

If they wanted to exercise them in say Germany then it would make sense. In Germany you play by German rules, etc.

Anyway, the vast majority of UK flight on IMCR privileges is going to be OCAS and thus falling outside of the remit of any regulatory authority to dictate the individual's attitute to risk.

I don't know if I would pass a JAA IR checkride today; probably not... depends on how much raw data single-nav-instrument stuff is involved.