En-route instrument rating - how's it supposed to work?

[IO540]

A "visual approach" (which is an approach flown under IFR) commences much closer to the airport.

However, it is not clear whether this is the EIR intention, or whether they were planning to require a Y (IFR to VFR) flight plan to be filed. The latter would indeed imply a DIY letdown somewhere further back, but that letdown is supposed to be in VMC

[B2N2]

OMG, what a tragedy and a travesty.....
Because (unlike the USA) they don't want you to get an Instrument rating at a decent price and they killed the IMC they come up with this rubbish?
There is something seriously wrong with this picture.
They need to be strung up.

I'll get my coat and my tin foil hat so they can't mess with MY mind.

[BEagle]

Yes, anyone descending in IMC outside CAS without a radar service of some sort is courting disaster, I agree.

Unusually in nuLabor's surveillance society, radar service outside CAS is pretty poor in the UK, particularly at weekends. So how safe would the stupid 'EIR' be on such occasions? Currently an IMC rating holder would only need 1800m / 600 ft at destination, but with the 'EIR', all bets are off.

Apart from a very small minority of the 'PPL/IR Europe' group, everyone in the UK is opposed to the 'EIR'. We will be making this point to EASA officially later this week, so that they are under no mis-apprehension that FCL.008's UK members speak for UK GA.

[IO540]

Yes, anyone descending in IMC outside CAS without a radar service of some sort is courting disaster, I agree.

I take it that statement is tongue in cheek

[Fuji Abound]

However, it is not clear whether this is the EIR intention, or whether they were planning to require a Y (IFR to VFR) flight plan to be filed. The latter would indeed imply a DIY letdown somewhere further back, but that letdown is supposed to be in VMC

IO540

I still dont quite follow your point.

Please take my example of a pilot returning from the CIs to Bournemouth. There is a solid overcast from mid channel to the south coast and over southern UK between 2,000 and 3,000 feet - or if you like 1,500 feet and 3,000 feet. Conditions are VMC above and below. It is a situation I am sure you have seen many many times.

Now as I understand the position the pilot could not call for vectors onto the ILS either because he would be commencing / entering IMC during the approach or because he would not become visual before his rating minimium.

Therefore in order to become visual below the base (which would enable him to continue to Bournemouth and request a visual arrival) he would need to inform the Controller he wished to leave the airway at say St Catherine's Point.

The pilot would then descend through 1,000 or 1,500 feet of cloud over the IofW outside CAS and potentially without a service. At some point he would become visual and would continue inbound to Bournemouth on what has now become a VFR flight plan or a continuation of his IFR flight plan but in VM conditions.

Is that how we see it?

I use these conditions because I think most would agree they are the type of benign conditions in which many pilots would be flying be it below the base in VMC or on top with their IMC rating followed by vectors for the ILS. This isnt hard IFR it is typical British summer weather. Those of you who like mentioning holes in the undercast - forget the holes, there arent any - I can assure you this is quite common.

If this is the way it works as I mentioned earlier doesnt this simply encourage a load of pilots to perform made up descents outside CAS and amoung other things make the big sky more than a little bit smaller!

[Utfart]

"If that's true it seems to be just as much of a loophole as the good old FAA IR, except it's sub ICAO."

Sorry, I didn't word this well at all. What I really wanted to say is that I perceive the
IMCR to be a loophole the same way many in the UK perceive the FAA IR to be a
loophole. On further thought, I'm glad I don't fly in the UK and share the sky with
people with a legal right to fly in IMC but very little training. If the idea was to give a
pilot the skills to survive an inadvertant encounter, why the rating? why not simply
expand the requirment on a PPL? I'm sure there are some IMCR holders that are
very proficient at instrument flight, but I don't want to meet the others. Unfortunately
there don't seem to be any reliable statistics to support or refute my position, and
that's something that needs to be seriously addressed.

I don't know what will happen in the future, and I guess whatever it is will take a
long time. I can say that as a pilot flying in Europe, me, and the others I have spoken
to, have no interest in an IMC rating, but we are very much looking forward to a
European IR with an easier to attain theory component.

[Fuji Abound]

Unfortunately
there don't seem to be any reliable statistics to support or refute my position, and
that's something that needs to be seriously addressed.

Just two very quick comments:

The two best stats. available:

1. No (or maybe 1 depending who you believe) accidents involving IMC rated pilots in IMC in more than 40 years - there have been a lot more in the same size population of IR pilots,

2. No collisions in IMC involving an IMC rated pilot ever.

Sounds pretty safe to me.

[Utfart]

a reliable statistic, to me, would be something published that can be referenced.

[TWR]

It doesn't mean anything.

More important are the incident reports (which are potential accidents).
But it is impossible to get decent data on these since IMCr is outside CA.

From an ATC point-of-view, the EIR is complete nonsense.
IFR is only cancelled on pilot's request. What if he doesn't do this ?
We put him in a holding ? We vector him in the sequence for an ILS ?

[IO540]

Fuji - I understand what you saying but we don't know the details of how the EIR will be expected to work.

If the pilot will be required to file a VFR arrival then he would have to descend some way before the airport, and yes in your example he would become illegal on the way down.

If the pilot is able to fly all the way to the instrument approach, and then hopes to be visual before actually commencing it and request+fly a visual approach, or if not visual declare a mayday and fly the instrument approach, things get pretty tacky and I don't get how this would work... It would drive ATC nuts, to have somebody flying all the way to the ILS platform and then (presumably not being allowed to fly an approach he is equally not allowed to fly a missed approach) ask for some kind of ad hoc diversion to his alternate.

A more workable assumption is that he will get the ATIS and if the cloudbase is below the IAP platform he will divert immediately.

I suspect the intention is that the preflight TAF requirements will be such that the probability of this (the diversion) happening will be very low. This can certainly be achieved; I used to fly VFR around Europe and while I was in IMC enroute on most flights (for a little bit maybe) I was always able to arrive properly VFR. One just has to be really careful in the weather planning.

Utfart - you fall into the same old trap of believing that instrument competence requires X hours of training, where X was determined by Jesus in 30 BC (and then JAA came and decided Jesus was wrong and stuck another 10 hours on top) I don't know if you are a pilot but most IFR pilots know that the degree of competence actually required for IFR flight is way below what is trained if one assumes an aircraft appropriate to that type of flight. I was flying European airways (700nm legs) on my IMCR training, with an IR instructor to make it legal. I learnt nothing of significance doing the IR, which was basically an exercise to prove I could keep 10 balls in the air at the same time. The difficulty of the IR training is primarily because it is taught on the assumption that the pilot will be flying a piece of wreckage with half the equipment malfunctioning, but not tell anything to ATC and just pretend all is well.

[bookworm]

Now as I understand the position the pilot could not call for vectors onto the ILS either because he would be commencing / entering IMC during the approach or because he would not become visual before his rating minimium.

Then he diverts somewhere else, just like any other instrument-qualified pilot who finds that, despite his intended destination meeting planning minima, the actual weather does not.

And if he finds this reduced level of operational utility frustrates him, he goes and gets an IR like everyone else in the world who doesn't want to be limited to making approaches in visual conditions. In order to do so, all he has to do is those extra few hours of training that take his dual IF total up to 25, and pass a test of his competence to fly IFR, including instrument approaches.

[mm_flynn]

Originally Posted by Fuji Abound

Just two very quick comments:

The two best stats. available:

1. No (or maybe 1 depending who you believe) accidents involving IMC rated pilots in IMC in more than 40 years - there have been a lot more in the same size population of IR pilots,

2. No collisions in IMC involving an IMC rated pilot ever.

Sounds pretty safe to me.

Fuji, you damage your cause with bogus statistics. 1 is clearly untrue from the CAA's own publications (I accept it is a low number) and collisions in IMC are almost unheard of globally (regardless of the qualifications) so you wouldn't expect the relatively small IMCr population to appear.

I am in no way saying the IMCr is unsafe - just the ongoing pushing of demonstrably false statistics makes the job of the IMCr attackers that much easier.

With regard to your Bournemouth question. I would expect the EIR pilot to be vectored to the MVA on the extended centre line and if visual continue, if not divert. However, that is just my expectation.

Given the apparent total objections to the EIR from the population, it is unlikely anyone will bother to work up the details and we will be left with some bodge for the UK to continue to allow IMCr operations (if we are lucky) and an IR (which, if it is more sensible may be good enough for GA in the rest of Europe).

[Utfart]

I certainly don't believe in the X-hours = IR formula. I am a firm believer in proficiency and recent experience on type creating safe IR pilots. While mastering actual aircraft handling in IMC may not have required a lot of training time, I think that learning to deal with failures, recovering from unusal attitudes, and functioning safely inside the IR system can easily fill the 15 hours dual instruction required to finish an FAA IR. I never bothered to learn what the dual training requirements are for the Euro IR, as I will never have time for the theory study. I have managed to learn many new things doing the IR training, and I know it has made me safer.

I haven't encountered anyone assuming that we will be training on junk aircraft so far, probably because there are alternatives if one looks, but I'll keep my eyes peeled.

[Fuji Abound]

Then he diverts somewhere else, just like any other instrument-qualified pilot who finds that, despite his intended destination meeting planning minima, the actual weather does not.

Bookie

I am not sure if you follow my point (which is perhaps badly made).

An overcast of between 2,000 and 3,000 feet is not exactly demanding instrument conditions but is quite common.

As we understand matters the pilot cannot accept vesctors for the ILS because more than likely the vectors would capture the GS in IMC and in any event part of the approach would be in IMC.

I dont see it is a question of whether or not the forecast meets planning minima. If the pilot is above a base (any base) unless the base is higher than 3,000 feet it is inconceivable the pilot could accept vectors or fly ANY approach for the reasons I have explained.

He therefore can only descend outside CAS on a get down and hope basis.

Now if we are saying the weather minima for an EIR holder at destination must at worst be scattered so far as cloud is concerned at anything between 0 and 3,000 feet I would agree with you, but if that really is the case the rating will be even more worthless than I previously thought. Of course to be pedantic the EIR holder would not even be entitled to go through a bit of scattered at 1,800 feet.

I know the details have not been published but either there is to be an aprroach ban in IMC or there isnt. If there is I just cant see how it can be made to work other than in the circumstances I have outlined in the previous paragraph.

I dont see this can in any way be compared with an IR pilot flying an approach to minima, not becoming visual and diverting. The diversion is because it would be unsafe to continue, whereas to not fly an approach through 1,000 feet of stratus between 3,000 feet and 2,000 feet but in the alternative to legally descend through the same cloud outside CAS on a get down and hope basis would seem just silly.

Fuji, you damage your cause with bogus statistics

The claim is frequently made that the IMC rating is unsafe. Ultimately what do we base our asessment of safety on? Accidents and incidents? The accident record speaks for itself so is worth repeating. The incident record is not known so we cant report on the record. How else would you prefer to confront the accusation that the rating is unsafe?

For those that claim it is unsafe - in what way is it unsafe? Clearly IMC pilots are not crashing all over the country side. They may be busting clearances, they may be losing control but recovering, they may be failing to accurately follow controllers instructions and each of these events would be potentially serious. However, it would be reasonable to believe if these were regular occurences the CAA would be well aware, unless you are suggesting the CAA has been negligent in dealing with the reports made to them by ATCOs.

Moreover the average IMCr holder is flying single pilot ops. Whilst I hate making a comparison with CAT and commercial IR holders you need only read the incident reports or fly (at all) to realise that their are plenty of incidents amoung this fraternity. I was at Southampton only last week and we had two CA one of which asked for vectors that would take him outside CAS and clearly had no idea that was the effect of his request and another than descended below his cleared altitude.

I accept that IMCr holders avoid the worst of the weather; infact I think they do a pretty good job of self regulation and that is why as a population they do a damn good job of managing the risk. To constantly argue as some do that they are unsafe and they shouldnt be in the same airspace as CAT or even GA holders of an IR should be addressed because if it were such an issue I would have expected there to be some evidence that it was.

[bookworm]

As we understand matters the pilot cannot accept vesctors for the ILS because more than likely the vectors would capture the GS in IMC and in any event part of the approach would be in IMC.
...
I know the details have not been published but either there is to be an aprroach ban in IMC or there isnt. If there is I just cant see how it can be made to work other than in the circumstances I have outlined in the previous paragraph.

I think all of us need to wait for the proposals from FCL.008. You're making a number of assumptions ("approach ban in IMC", "cannot accept vectors for the ILS") as to how this might work.

Your point that the EIR must be compatible with ATC procedures and practices is a fair one, but your own proposed alternative of a rating that permits approaches but not IFR flight in certain classes of airspace suffers from the same inconsistencies, even in the UK. Doesn't pushing a whole class of competent instrument pilots below a particular class of airspace for arbitrary reasons "simply encourage a load of pilots to perform made up descents outside CAS and among other things make the big sky more than a little bit smaller"?

Now if we are saying the weather minima for an EIR holder at destination must at worst be scattered so far as cloud is concerned at anything between 0 and 3,000 feet I would agree with you, but if that really is the case the rating will be even more worthless than I previously thought.

You seem to be concerned about the utility of this rating, and to be forgetting that it's proposed as a stepping stone to an achievable IR. I've still not fathomed what causes you to be so vehemently opposed to creation of an IR that can be achieved by a similar proportion of pilots as currently hold the IMC rating, but offers privileges that permit them to maintain the sort of currency that permits safe instrument flight.

[Utfart]

Sorry, but the UK CAA's accident statistics do not speak for themselves outside the UK. If you are trying to convince European pilots of the safety and importance of an IMC rating, it may be good if someone refers to specific, documented numbers.

I have been told on the one hand that IMCR holders are using their ratings on a daily basis in a much broader way that it was originally intended. On the other hand, I am asked to believe that the safety record of IMCR holders is better than that of all pilots with instrument ratings. Something doesn't add up for me. Either the statistics (never referred to) are false/misunderstood, or IMCR holders are not actually flying in IMC very much. Sorry if you think this is off topic a bit, but I thought it was relevant.

[Fuji Abound]

You seem to be concerned about the utility of this rating, and to be forgetting that it's proposed as a stepping stone to an achievable IR. I've still not fathomed what causes you to be so vehemently opposed to creation of an IR that can be achieved by a similar proportion of pilots as currently hold the IMC rating, but offers privileges that permit them to maintain the sort of currency that permits safe instrument flight.

If it is an effective stepping stone then my opposition will diminish. Do we know that it will be?

If existing IMCr holders that have invested time and money achieving the rating are protected in terms of their existing priviliges my opposition will diminish. Stripping pilots of existing priviliges sits very uncomfortably for me as much as any retrospective changes in the law.

or IMCR holders are not actually flying in IMC very much.

I think IMCr holders fly in IMC to the extent that befits their experience which means, as I indicated earlier, they do a very good job of self regulation. Perhaps we would agree that self regulation is the key. An IR holder however much better trained might be equally foolish to fly an approach to minima if he is not current. In the same way an IMCr holder will doubtless apply the recommended higher approach minima unless he is satisfied he is current and has accumulated the experience to enable him to do so safely.

Doesn't pushing a whole class of competent instrument pilots below a particular class of airspace for arbitrary reasons "simply encourage a load of pilots to perform made up descents outside CAS and among other things make the big sky more than a little bit smaller"?

Yes, a very sound point. I agree.

However, as you know the IMCr was formulated around UK airspace and to meet the needs of UK pilots to fly what are usually relatively short sectors between smaller airports. As we all know climbing into CAS and following pre-defined routes often confers no advantage in these circumstances.

In other words the IMCr was and is an effective solution to a problem whereas the EIR may be a solution looking for a problem.

[Brendan Navigator]

TAF LKPR 301100Z 3012/0118 04004KT 9999 SCT036 BECMG 3013/3016 18010KT BECMG 3022/0101 31010KT 9000 -RA SCT014 BKN020 TEMPO 0101/0118 4500 RA BR BKN014 PROB30 TEMPO 0101/0108 2500 RA BR BKN009


And see that as long as you plan to get to Prague before 01Z tomorrow you are OK (using the FAA rules for determining 'guaranteed VFR')

I think that this debate and especially the above statement shows that quite a lot of training is going to be required before anyone is let loose with an EIR.

I can not see how arriving at "01z tomorrow" based the above TAF would in any way permit VFR in a class D zone plus or minus 1 hour. If one is being relatively conservative one would say that the general deteoriation in the weather starts at 2200z and thus one would have to plan to be there by 2100z.

As I understand the proposal it is for VFR departure, IFR enroute and VFR approach and landing phases. Therefore, at departure, destination and alternates the visibility will have to be above the minima for VFR and the ceiling above the minimum enroute IFR level.

Therefore, the idea is based on our friend inbound to Bournemouth using what is common elsewhere in Europe -

GABCD request descent to 3000ft.

GABCD is VMC request cancel IFR.

GABCD IFR canceled at 1230 report Hengistbury Head VFR for joining instructions.

As I understand the EIR it is simply permitting those pilots that currently fly VFR on top to be able to fly IFR in the middle part if they choose / if weather / airspace dictates. Therefore, I believe that the minima required +/- 1 hour of ETA will be 5Km and ceiling above minimum IFR altitude or perhaps a blanket 3000ft AAL.

What has not been spoken of yet is what equipment would be required for enroute IFR flight. The nav equipment required for IFR flight today is mostly made up of landing aids and as far as enroute is concerned, a Garmin 430 would be suficient for most if not all enroute flying.

Thus a typical UK flight would be depart Compton Abbas, climb to 2300ft (min IFR level) + in VMC VFR. Then request IFR Airways join at SAM FL60 (by this time VMC on top) and route Airways to the CI CTR entry where at an appropriate time the aircraft can descend IFR to the minimum level and when VMC cancel IFR and proceed (in this case) Special VFR to the appropriate VRP.

That is an improvement over what the current IMC holder has to do - remain below the airway and be special VFR from the zone boundary.

[Fuji Abound]

Thus a typical UK flight would be depart Compton Abbas, climb to 2300ft (min IFR level) + in VMC VFR. Then request IFR Airways join at SAM FL60 (by this time VMC on top) and route Airways to the CI CTR entry where at an appropriate time the aircraft can descend IFR to the minimum level and when VMC cancel IFR and proceed (in this case) Special VFR to the appropriate VRP.

Hence my point - pilots descending outside of CAS and probably with no radar cover to break cloud at some height of which they have no certainty (the best they can do is assume the base will be the same as the nearest METAR or ATIS) unless of course they only fly when their departure and arrival are CAVOK - not many of those days around these parts I am afraid, but it should be OK UK to the South of France. I am looking forward to the hords of pilots doing that trip. Sorry, but it is not going to happen, hence my earlier comment - simply a solution looking for a problem that doesnt exist!

The real problem is pilots want to fly form Lydd to Bournemeouth (well maybe not Bournemouth but since it was part of our earlier discussion) for a bacon buttie or to meet up with their mates - they want to fly when there is cloud between 1,500 and 3,000 and they want a nice an easy approach at each end with a cloud break a comfortable way above the deck. They dont mind too much if there is no formal approach in the ATZ as long as they can tell all and sundry they are overhead and descending through IMC for a visual circuit, but they would prefer some sort of IAP. They know it is not for now, but they think the Authorities will be looking to the future becasue they have heard of GPS and even EGNOS, to the day when every grass patch can have its own GPS letdown that will safely guide them to 800 feet for a visual approach. Ideally they want to cruise along in the sunshine above a messy cloud layer that so often characterises these shores but is otherwise pleasantly benign and not the sort of stuff you really want to be beneath. I reckon there are a few pilots who want the same thing in Northern France - but who knows, that is another story. It is not rocket science. If they get that in some form which doesnt involve them spending three weeks at Oxford learning stuff they already know or dont need to know then I guess they will be happy.

Some of them have been doing this stuff for years. They arent going to be too happy when they are suddenly told they cant - well they cant without spending a significant sum of money. Some, maybe a lot, will just keep on doing it with descents outside CAS or the ATZ. Some, maybe quite a few, will give up. I suspect a few, a very few will toddle off to Oxford. It saddens me we encourage people into illegality, or to give up, or to do something unsafe because it is the only option, or to spend more money to do somehting they are already doing safely - that is the only reason I write about it. 5 of my mates all have IMC, they all use the IMC as I have described, none of them want to do an IR, not least becasue they really havent the time or inclination. Are these 5 the exception or do we all know a pilot or two in this baot?

Seems to me that is definitely not what they will get with the EIR.

[IO540]

Worth mentioning that the claim of there having been just one fatal accident involving a pilot exercising the privileges of the IMCR came from the then head of licensing of the CAA, at a CAA/EASA conference c. 1/2008 where I was present and was taking detailed notes.

The claim did suprise a lot of people but nobody I came across was able to categorically refute it.

The CAA man said they went through the accident records back to the start of CAA records. I don't recall how far back it was.

I suppose one could arrive at different figures according to the criteria used. For example a fatal crash of an IMCR holder flying VFR would not count. Similarly for an IMCR holder flying an unpublished approach. Similarly for an IMCR holder flying an ILS in France. Similarly if the IMCR was lapsed. The only thing that would count would be a valid IMCR holder flying a published IAP in UK airspace, overtly under IFR.

A part of the lack of official data on the accident rate of the IMCR (safety = no accidents = no data!! ) is that once you get the IMCR, you renew it every 25 months with an instructor but he just signs your logbook; no paper is returned to the CAA. So the CAA has no good data on how many valid IMCR holders there are. They do know that something over 20,000 (the figure was mentioned at the conference) were issued in total since c. 1969.

My guess, from speaking to pilots at random and knowing (also from the CAA) that about 20,000 UK pilots have valid medicals and presumably are doing some flying) is that a few thousand are currently valid.

Every year, loads of VFR pilots kill themselves doing all kinds of stuff, some in IMC. But it is very very rare to hear of a PPL+IMCR killing himself by bodging an IAP, or in a CFIT.

It doesn't matter how you look at it or what assumptions you make; the accident rate of IMCR holders (once you exclude irrelevances like somebody killing themselves flying illegal IFR outside the UK, which frankly is done by plenty of VFR pilots too) does appear to be very very good.

One could argue, and I would agree, that the good safety record of the IMCR is due to much of the UK being relatively flat i.e. not Switzerland, or Nepal

But it is just possible that the stats are actually telling us that the level of flying competence required to deal with IFR is much lower than the regulators keep pretending And I would be the first to agree with that. My son could fly an ILS on the sim at 12 and has flown a number of them on the bigger CPL training sims at flying exhibitions. And any monkey can fly headings and levels in IMC - assuming a level of cockpit automation appropriate to real-world IFR flight.