IMC Rating - Lobby your MP

[Whopity]

The point we are all missing is that on safety grounds the IMCR was never in threat.

Then why was there no provision for it in the EASA-FCL draft? How would a rating continue for which there was no legal provision?

??? what is the cost beyond a 1 hour per year check flight

Between £660-£800 per year.

[Whopity]

The point we are all missing is that on safety grounds the IMCR was never in threat.

Then why was there no provision for it in the EASA-FCL draft? How would a rating continue for which there was no legal provision?

??? what is the cost beyond a 1 hour per year check flight

Between £660-£800 per year.

This is because in the UK Class G one can fly IFR freely, with almost no specified equipment and in practice a handheld GPS does the job. And even if non-radio IFR in Class G was banned, it could never be enforced so anybody doing it will carry on doing it. One doesn't need an IR for this. The IMCR is practically required for landing on an official instrument approach, but enroute nobody knows what you are doing.

That was the original purpose of the IMC, to allow pilots to continue a privilege that formerly did not require any rating, in any aircraft they happened to have. It was never intended for long range flying.

[mm_flynn]

Originally Posted by Whopity

Between £660-£800 per year.

What are you doing ?? !

[FullyFlapped]

Hey - here's a crazy idea ... why not keep the IMCr in the UK only, AND have the Euro-en-route-only IR available as well ....

Kind of ticks most of the boxes your average UK pilot might need, at home anyway ?

[LH2]

I see a problem with AOPA's writeup:

The IMC rating is one of the significant factors contributing to the UK’s high GA safety rate, which is far better than the rest of Europe - France has some 90 fatalities a year, Germany about 80, the UK 20 to 25.

I know they're asking you to tell this to a politician (a professional liar with no regard for or understanding of facts), but from a personal perspective, I would never put my signature to a statement as fallacious, tendentious and unsubstantiated as the above. I am sure the educated users of this forum can immediately see the many blatant problems with it.

Without wishing to speculate as to the possible origin of that statement, and obviously assuming that it was not done in bad faith, I would suggest that AOPA might wish to amend their advice to their members.

Similarly:

There is no credible suggestion that it is unsafe, and there is a mountain of evidence that it makes better pilots and has saved many lives.

What they are saying here, in as biased a way as could be managed is: there are no scientific studies that we are aware of which assess the impact on safety (or lack thereof) of the IMC rating. Even if there was such a study (which would be very costly), it is by no means certain that it would yield any meaningful conclusions.

To put an absurd example which follows their line of reasoning, one could say that the safety impact of the IMCR is as beneficial as employing undertrained ATCOs unable to express themselves in proper English. After all, AOPA's fatality figures for the UK are comparable to those for Spain (median of 24 deaths/yr for the last 18 years. Mean somewhat higher courtesy of Spanair, data from CIAIAC bulletins). Not to mention Andorra's perfect air safety record

Now in my opinion, and I have no axe to grind and don't care about AOPA or the IMCR either way, they are focusing it the wrong way by trying to sell it as a safety issue (something which they cannot factually substantiate) when at the end of the day the only provable benefits are economic.

To take Mike Cross' example, I don't think anybody has ever suggested that doing what a mountain qualification allows you to is an exercise in safety--it's quite the opposite IMO, but without it you couldn't take rich people right into the heart of the Alps and Pyrenees for a day of skiing and then back to their homes elsewhere in the continent, neither would the concerned areas benefit from the presence of people with considerable disposable income (private mountain pilots) throughout the year.

So there you go. I just wanted to point out that whatever the results of their lobbying attempt, if that's what it is, they are doing their credibility no favours with poorly conceived statements as the above, any good points notwithstanding.

[S-Works]

Now in my opinion, and I have no axe to grind and don't care about AOPA or the IMCR either way, they are focusing it the wrong way by trying to sell it as a safety issue (something which they cannot factually substantiate) when at the end of the day the only provable benefits are economic.

I have tried to make that very same point a number of times. The argument should be based on the loss or training and the opportunity to help pilots maintain currency and learn enhancing skills rather than what I feel is a very melodramatic tack.

[mm_flynn]

I think the safety argument is somewhat more complex.

• There seems to be very strong evidence that GA in the UK is significantly safer than in most other European countries.
  (based on fatal accident rates/100k hrs. Note the number of GA hours flown in Spain is likely much lower than the UK but results in a similar total number of deaths)
  .
• There are many factors which might influence accident rates and are significantly different between the UK and other European countries.
  .
• There is no study which in anyway tries to quantify these differences, hence argument is based on 'logic' rather than statistics. In this context it seems more reasonable to attribute significance to the IMCr rather than for instance the CAA's approach to GPS)
  .
• The people seeking to retain the IMCr are, in general, coming from a safety vs utility perspective. In that IMCr trained pilots are clearly safer undertaking ILS approaches in IMC than people with only a PPL. Some people argue this as improved safety and some as improved utility.
  .
• There is a reasonable body of anecdotes with regards to IMCr 'saves'.
  .
• IMHO it is more objective to say 'the IMCr greatly increases utility with no observed decline in safety'.

In summary, I think AOPA's document is 'reasonable' in the context of a lobbying letter (where after all you are presenting as positive a picture as possible) and a substantial improvement on the factually untrue statements they have made in recent magazine articles.

[ScouseFlyer]

At the risk of some slight thread drift why in principle could the CAA not take the same approach with the IMCR as the French have with their LNMA licence introduced to get around the maintenance regime for certain types of aircraft under part M.ie a local licence exercisable only within the borders of that country?As usual the French seem to have,under pressure from disgruntled citizens,managed to find a solution that "bends the rules" to inject some pragmatism into EU bureaucracy.

SF

[FREDAcheck]

Because the French (and other) governments do that sort of thing, and we don't. Any questions?

[englishal]

I don't think anybody has ever suggested that doing what a mountain qualification allows you to is an exercise in safety--it's quite the opposite IMO, but without it you couldn't take rich people right into the heart of the Alps and Pyrenees for a day of skiing and then back to their homes elsewhere in the continent, neither would the concerned areas benefit from the presence of people with considerable disposable income (private mountain pilots) throughout the year.

You have some odd views. Of course it is about safety, mountain flying is completely different to normal flying and seeing the number of brits who try to take a fully loaded PA28 into a 7000' airport on a 30C day is scary - even scarier I met two airline pilots who were just about to do this.....They had never flown in the mountains before.

Stats of the type above are meaningless. What you need is an accident / fatality rate per X flying hours. There may only be 100 pilots in France, and 20,000 in Englad for example.

The NTSB publish these for the USA and one thing that is clearly shown is that an instrument qualified pilot is far less likely to die due to the weather. This, I assume, also translates back to the IMC rating, so therefore one can assume that there is actually a safety case to keep the IMCr.

But yes, I don't see why the CAA can't just say "up yours" to EASA and allow the IMCr to remain...the French do it all the time....

[LH2]

I think the safety argument is somewhat more complex

Correct, that is my point.

There is no study which in anyway tries to quantify these differences, hence argument is based on 'logic' rather than statistics

I disagree about it being based on "logic". Quite the opposite, the statements which I dispute in AOPA's writeup as quoted by M. Cross are based on fallacy, as is my Spanish example.

I suspect what they did was pull some fatality figures off the respective national investigation agencies' publications / websites, without regard to their different fields of competence and methodologies. For example, the BEA investigates, and includes in its statistics almost every kind of aerial activity such as microlight and paragliding (enormously popular in France) while the AAIB, to my knowledge, doesn't. As you can appreciate, that results in two different populations (in the statistical sense) that you are trying to compare across.

Furthermore, even if the validity of those comparisons could be determined (which is possible, it just takes a bit of work) and there was found to be a statistically significant difference (which is a further half an hour of a statistician's time) there is the much hairier job of a) establishing correlation, and b) establishing causality between any such hypothetical difference and the fact of having or not having an IMCR, either as opposed to an IR, or as opposed to vanilla VFR privileges.

The people seeking to retain the IMCr are, in general, coming from a safety vs utility perspective. In that IMCr trained pilots are clearly safer undertaking ILS approaches in IMC than people with only a PPL

I believe it has been discussed before and I do not wish to start that debate again, but from a safety point of view the pilot with only a PPL has the advantage, as he is not authorised to fly in IMC conditions and therefore has to stay on the ground, which greatly reduces your chances of becoming involved in an aviation accident, whatever the weather. But of course we understand that this is not really viable on account of the British weather, so one comes up with an arrangement that allows people to fly in more marginal weather than would otherwise be possible, thus giving an utility advantage as you well state, but a priori reducing safety as you have now increased the exposure, purely from having another plane in the air which otherwise wouldn't be there and without regard to any other factors.

Therefore, as I have said on my previous post, you have a demonstrable economic benefit (or utility value as you call it), which personally I find a good selling point in itself as previously illustrated.

IMHO it is more objective to say 'the IMCr greatly increases utility with no observed decline in safety'

I agree that such a wording would be an improvement over the original version, however I would leave out the complement clause altogether.

In summary, I think AOPA's document is 'reasonable' in the context of a lobbying letter

I could not possibly comment on that point, not being very familiar with lobbying or politics in general. However, from the point of view of someone who values integrity, I could not put my signature to something I know or strongly suspect to be a lie. Mine was a general commentary on that sense.


Englishal

You have some odd views. Of course it is about safety

Methinks you have misinterpreted me. In Europe the mountain qualification allows you to fly in, land, and take off from areas which would otherwise be off-limits for fixed-wing aviation. The exercise of the privileges of such a qualification entails a very significant level of risk, even if that risk is of course lower than faced when operating into those sites in disregard of the regulations.

That leaves countries that have the qualification exposed to higher accident rates than countries which don't, all other things being the same. My point with that example was to show that it is not necessary to pull the safety card to achieve the goal at hand--indeed, to my untrained eye that looked like a rather poor move.

seeing the number of brits who try to take a fully loaded PA28 into a 7000' airport

This is off-topic, but I presume you are not talking about Europe? The only aerodromes at or above 7000ft in Europe are classed as altiports and a mountain (or site) qualification is a requirement, not merely a recommendation.

[Pace]

The safety benefits of the IMCR are not that all IMCR pilots start cloud flying using the IMCR as a mini IR to fly approaches into airports.

I would guess that out of all IMCR rated pilots only a small fraction would use it in anger as a means of getting around.

The safety benefits are to the VFR pilot not to the IFR pilot who would be safer with a full IR.

Although used by some in anger the majority I know of fly VFR with it as a safeguard incase they get into bad weather.

Others will use it with a high cloudbase to get on top.

It is an extension of a pilots skills and that is probably where the safety benefits arise and gives him more options/weapons to use if his VFR flight goes marginal or worse IMC.

Then why was there no provision for it in the EASA-FCL draft? How would a rating continue for which there was no legal provision?

Whopity

There would not have to be! It would be treated as a special case excemption for the UK due to the UK being an island with unique weather characteristics.

Example you could make a law which states that in Europe the transition Altitude was 8000 feet. Some countries may have high mountains making this impossible or dangerous so they would be treated as special case to the normal.

Pace

[englishal]

This is off-topic, but I presume you are not talking about Europe? The only aerodromes at or above 7000ft in Europe are classed as altiports and a mountain (or site) qualification is a requirement, not merely a recommendation.

You are right, I am talking about the USA, where no such "mountain rating" is required. However one would be a fool to fly into a 7000' airport without doing some training, but essentially everyone who flies in the USA is exposed to high alt airports...

But stats can be used to "prove" or disprove whatever you want. I bet you could prove that IR'd pilots have a higher fatality rate in IMC conditions than an IMC rated pilot for example. I base this on the fact that more IR'd pilots have been killed in CFIT type accidents than IMCr'd pilots. IN fact saying this, you could prove (via stats) that the IMCr'd pilot is in fact the most safe pilot - less have been killed in CFIT accidents than IR'd pilots, and less have been killed in weather related accidents than vanilla PPL's...Therfore there must be a safety case for the IMCr?

[mm_flynn]

Originally Posted by englishal

I bet you could prove that IR'd pilots have a higher fatality rate in IMC conditions than an IMC rated pilot for example. I base this on the fact that more IR'd pilots have been killed in CFIT type accidents than IMCr'd pilots. IN fact saying this, you could prove (via stats) that the IMCr'd pilot is in fact the most safe pilot - less have been killed in CFIT accidents than IR'd pilots, and less have been killed in weather related accidents than vanilla PPL's...Therfore there must be a safety case for the IMCr?

If you choose non-comparable populations you can prove anything (eg mice run faster than cats (sample is live mice and dead cats)). If you choose comparable populations (eg pilots flying piston aircraft in the UK with PPL, IMCr, IR ) you will find the UK has no exposure data (we can not establish how many flights, hours, in what conditions, or even how many people are in each population). As such, it is almost impossible to make a statistically valid comment on the relative safety of PPL, IMCr and 'PPLIR' operations. Additionally, the level of accidents in the IMCr and IR population are so low that it would take decades (over which time technology shift would be very relevant) to build a valid sample.

To the best of my knowledge, European aviation safety statistics are reported on a consistent basis (accidents in the population/ 100k estimated hours of the population). However, as LH2 points out, the nature of the activity could be highly skewed. Within the UK the different elements of GA have very different accident rates.

[Islander2]

Originally Posted by Mike Cross

AOPA is suggesting people lobby their MP's not their MEP's

Originally Posted by Pat Malone, AOPA UK, writing in Pilot Magazine, February 2010

Please also write to your MEP seeking support in the European Parliament for an administrative change by EASA.

So which is it, Mike?

You say in post #16 that "a device must be created to allow it as a UK only rating", then immediately suggest it could instead be an EASA rating free to be adopted or not by NAAs as they see fit, each of whom who would determine what privileges they attach to it. Surely, it is time for more clarity than that in terms of the objective for this campaign!

Regrettably, nothing I see here or in the responses (albeit few in number) to the publication of this initiative on the LAA Forums gives me any confidence at all that AOPA is mounting a formidable campaign to retain the IMCR as a UK-only rating, or that it is giving any serious regard to the dangers, if it encourages people to seek a European-wide rating, of knocking EASA off-course from the implementation of an FAA-style achievable IR.

First it choses to promote a description of IMCR privileges that is (to anyone with any knowledge whatsoever of the subject) a complete and laughable misrepresentation. Then it mounts a 'lobby your MP' effort that is devoid of any clear and detailed advice as to what it is that MPs (or MEPs!) are to be asked to achieve.

Given that (paraphrasing Pat Malone's words) AOPA has never had such a large postbag advocating action on any other topic, it all seems pretty unimpressive.

[Ryan5252]

At the risk of sounding naive, should someone not possibly look at the possibility of making a PPL-IR more reachable for someone who does not intend on going down the fATPL route for the foreseeable future? I will of course be looking to add an IMCR to my PPL when the time comes but ultimately I think the IR is the way to go but I think as things are currently anyone who is going for an IR is also going for a CPL at minimum therefore the prices seem to be inflated. I think this is hugely unfair and somehow we have become to accept the IMC rating as 'the best we can do'.

Why?

[derekf]

Ryan - a more attainable IR is what FCL.008 has come up with and we wait to see what happens in the NPA.

This is a separate issue to that of trying to save the UK IMCR.

Both efforts need fully supporting IMHO.

Unfortunately all those IMCR holders based in Jersey who use it to reduce the viz requirements from 10k to 3k when SVFR in the CI zone do not have an MP to write to

[IO540]

should someone not possibly look at the possibility of making a PPL-IR more reachable

There is a parallel process in EASA to do just that. Min 15hrs training, and largely competence based like the FAA one (de facto) is.

Doesn't deal with all the "accessibility issues"; e.g. still have to (stupidly and pointlessly) do it at a professional FTO, the Class 1 audiogram is still there (no Demonstrated Ability option except on Renewal medicals) and some other stuff which will all together IMHO greatly reduce the "GA buy-in" compared with U.S. FAA IR pilot population percentages.

It looks good, but only a fool will put his life on hold waiting for a more reasonable IR - this has been promised for so long... and earliest possible delivery is 2013.

Get your IMCR and use it.

[Mike Cross]

Islander2 (and others).

What I have posted is a suggestion. The reader is free to do with it as he wishes. If it's useful to you then use it, if it's not for you then bin it. Your choice entirely.

[neilgeddes]

At the risk of sounding naive, should someone not possibly look at the possibility of making a PPL-IR more reachable for someone who does not intend on going down the fATPL route for the foreseeable future?

I agree. A PPL/IR is desirable but the onerous theory exams make it unrealistic for most IMCr private pilots who likely have full time jobs and families.