IMCR (again)

[Mike Cross]

For those who are not AOPA UK members and therefore do not see the magazine here are a couple of links to pdf 's of articles in the current issue. These are provided with the consent of the publisher.

The files are quite big (300 and 700k) so don't try this on a mobile device!

http://www.joinaopa.com/Documents/AWFU1.pdf
http://www.joinaopa.com/Documents/IMCletters.pdf

For anyone not from the UK, the UK IMC rating involves less training than an ICAO IR and allows flight in UK airspace classes D and below in circumstances when compliance with IFR is required. As a national rating it is threatened by EASA's proposals for FCL changes.

[bookworm]

For anyone not from the UK, the UK IMC rating involves less training than an ICAO IR and allows flight in UK airspace classes D and below in circumstances when compliance with IFR is required.

Really? Because what it says in the article is:

As we make clear in this magazine, the IMC rating is no such animal, was never intended to be an ‘IR lite’ and allows the holder to do nothing more than he can do with a PPL, although it does slightly reduce visibility minima.

Who should we believe, Mike? What should I tell my MEP?

[Mike Cross]

Ah Mr Bond, you are toying with me.

We both know that Schedule 8 of the ANO in relation to the Privileges of the PPL (A) says:-

He shall not:
.......
(c) unless his licence includes an instrument rating (aeroplane) or an instrument meteorological conditions rating (aeroplanes), fly as pilot in command of such an aeroplane:
(i) on a flight outside controlled airspace when the flight visibility is less than
3 km;
(ii) on a special VFR flight in a control zone in a flight visibility of less than 10
km except on a route or in an aerodrome traffic zone notified for the
purpose of this sub-paragraph; or
(iii) out of sight of the surface;

........



(e) unless his licence includes an instrument rating (aeroplane), fly as pilot in command or co-pilot of such an aeroplane flying in Class A, B or C airspace in circumstances which require compliance with the Instrument Flight Rules;
(f) unless his licence includes an instrument rating (aeroplane) or an instrument meteorological conditions rating (aeroplanes), fly as pilot in command or co-pilot of such an aeroplane flying in Class D or E airspace in circumstances which require compliance with the Instrument Flight Rules;

That's taken from the privileges for a UK PPL, the UK CPL privileges include similar restrictions.

As I'm sure you know the privileges of a JAA PPL(A) call up JAR–FCL 1.175 "Circumstances in which an IR(A) is required" which includes

(b) In JAA Member States where national legislation requires flight in accordance with IFR under specified circumstances (e.g. at night), the holder of a pilot licence may fly under IFR, provided that pilot holds a qualification
appropriate to the circumstances, airspace and flight conditions in which the flight is conducted.
National qualifications permitting pilots to fly in accordance with IFR other than in VMC without being the holder of a valid IR(A) shall be restricted to use of the airspace of the State of licence issue only.

It's the proposed abolition of that paragraph from JAR–FCL 1.175 that would kill the UK IMCR.

[bookworm]

It's the proposed abolition of that paragraph from JAR–FCL 1.175 that would kill the UK IMCR.

So, is AOPA campaigning to retain a rating that (per 1.175(b)) "permit[s] pilots to fly in accordance with IFR other than in VMC" (in particular in class D to G airspace, which surrounds every airport but one in the UK) or is it campaigning to retain a rating that "allows the holder to do nothing more than he can do with a PPL, although it does slightly reduce visibility minima"?

If it is in fact campaigning for the former, is it not somewhat disingenuous to write the latter? Or has it decided to support the retention of the training for the rating but not the privileges that go with it? I'm sure we'd all manage to support that.

AOPA’s Chief Executive Mar tin Robinson says: “It’s as though the British were banned from wearing seat belts because cars in another country didn’t have them, and the drivers of a third country thought they were dangerous."

It's not the wearing of the seat belt that is contentious, is it? It's the legal privilege of driving at 200 mph in fog if you're wearing one that the other states aren't very keen on.

[Mike Cross]

You need to ask questions like that of the people who wrote the things you're enquiring about.

My pragmatic approach says that it's worked OK for many years and it does not appear to be broke. It would be good if a way could be found not to throw the baby out with the bathwater of EASA's standardisation.

We already have an NPA proposing that individual States can designate airports for which a Moutain Rating will be required. Why not allow States to designate (if they wish) airspace in which the privileges of a national qualification may be exercised?

Just an idea....

[bookworm]

I think the problem with that is that it needs an objective metric applicable across the EU. Designating Cambridge a mountain airport in an attempt to keep the Dutch out (assuming the NL didn't designate any of their own) would be anticompetitive and would probably raise a few eyebrows at EASA. To allow the UK to arbitrarily designate the airspace in which the IMC rating can be used would discriminate against the guy in France who would also like to train people to fly in IMC in less crowded air closer to home but can't because the DGAC won't designate it as IMC-rating-proof.

It would be good if a way could be found not to throw the baby out with the bathwater of EASA's standardisation.

I believe the IMC-rating's success story underpins the safety case for the attainable IR, which should offer better privileges than the IMC rating on barely more flight training. While adolescence is often a painful time, one could claim that the IMC-rating baby has grown up.

[Pace]

I believe the IMC-rating's success story underpins the safety case for the attainable IR, which should offer better privileges than the IMC rating on barely more flight training. While adolescence is often a painful time, one could claim that the IMC-rating baby has grown up.

Bookworm

Amen that says it all I agree with you!

We are fighting a misguided battle with the IMCR when we should be fighting for an attainable EASA PPL IR .

As for the French when have they ever complied with anything European that doesnt suit them?

Pace

[topoverhaul]

The attainable IR works perfectly well in FAA land, why should FCL-008's proposals for an attainable IR not also work very well in EASA land?

The EIR does not ban approach training it just doesn't require such training. (bottom right corner of page 17)

[IO540]

I believe the IMC-rating's success story underpins the safety case for the attainable IR

Couldn't agree more (predictably) but the problem is that we are not going to get an "attainable" IR, using the probably most widely accepted definition of "attainable" in this context, which is the US one:

1 - 1 exam
2 - largely competence based
3 - doable at your old flying school
4 - rolling currency
5 - PPL-level medical

It looks like the current proposals offer #2 but the others (esp. #3) are just as important to getting market penetration.

We are never going to get an FAA IR equivalent because

a) European regulators hate the FAA system because it is being continually rammed up their noses, so while they are content ripping off FAA certification regs and sticking their own document headings on them they will not go for what will be an FAA-like IR

b) In Europe, the political (airline pilot, NAA, union) landscape is such that it is judged important to have the same IR for private flight as for the ATPL. A failure to maintain this is judged as carrying a risk of private IFR being segregated by airspace class, one day, and that would strip the IR of any real utility value. In the USA this is not an issue because of historical acceptance, the ATPL having a tighter checkride than a CPL/IR, type rating checkrides being done to ATP standards, etc.

This is why the IMCR should be preserved in the UK. It serves a well defined user base. The IR, in whatever form it arrives (if indeed it does arrive) is always going to be aimed at a different market: reasonably current (well funded) aircraft owners.

[dublinpilot]

but the problem is that we are not going to get an "attainable" IR

And that is the reason that people are fighting to save the IMCR. They don't believe that they are being offered an attainable IR.

[S-Works]

And that is the reason that people are fighting to save the IMCR. They don't believe that they are being offered an attainable IR.

Which is pretty amazing considering that no one has seen the NPA......

A bit like the frenzy around the Apple iPad this week.

[IO540]

And that is the reason that people are fighting to save the IMCR. They don't believe that they are being offered an attainable IR.

They might get the IR which has reportedly been developed by FCL-008 (NPA not out yet) but anyone even half watching this game would be mad to bank a significant capability objective (an instrument qualification) on a promise of anything, let alone something which is easier than what came before.

[Pace]

10540

No one is expecting an EASA IR modelled on an FAA IR.
The Europeans would never create an IR which in their perception downgraded what they already have.

That is why I always felt that whatever would have to be based on a modular route leading to what they already have in place.

Lets be honest the biggest block to the EASA IR is time followed by cost.
A basic IR Exam designed around lower airspace and PPL requirements with the possibility of self study or completion within a 2 week full time course would cover that.

The PPL IR could then easely sit further exams to expand that IR to CPL/ATPL level.

The Medical for the PPL IR should be based on the class 2 as for any private flying.

The CPL/ATPL would require a class 1.
Coming to the flying side no one is suggesting a lowering of flying standards certainly not me. I would even go with give and take by making the flight test even tougher

The flight test is the ultimate guage of a pilots flying abilities and mental abilities to multi task and scan.

How pilots get to that point is pretty irrelevant. It maybe through years of experience it maybe through amazing abilities but the flight test with a designated examiner is the ultimate test for the IR.

Yes there should be a structured training programme but far more adaptable to the ability of the individual pilot than at present.

A pre test test with a sign off for the Real thing would weed out the hopefuls but not ready pilots who would be time wasting by going for the real thing.

The IMCR has shown the safety benefits to the VFR private pilot. It will never be accepted in Europe but it is a model to be used to fight for better things. With our liability culture no one would dare remove it in the UK SO what are we fighting for?

I wish half the efforts put into the IMCR had been directed at the PPL IR then we may have been in a far stronger position than now.

Pace

[mm_flynn]

Originally Posted by Pace

I wish half the efforts put into the IMCR had been directed at the PPL IR then we may have been in a far stronger position than now.

I don't believe any significant effort (beyond forum contributions and IMCR's petition) have been made until very recently to save the IMCr. Certainly AOPA UK appear to have done nothing effective (Pat doesn't even seem to be able to read the current regulations!), where as there has been a fair amount of work on making the IR more achievable.

Originally Posted by Pace

How pilots get to that point is pretty irrelevant. It maybe through years of experience it maybe through amazing abilities but the flight test with a designated examiner is the ultimate test for the IR.

It is very relevant - I am not aware of any significant relaxation on the European view that formal training is required (maybe quite a lot less than today, but that which is required is still very likely to be at a limited number of FTOs). Hence, the IMCr type rating will continue to be relevant into the future and deserves a good (and successful) defense.

[IO540]

Lets be honest the biggest block to the EASA IR is time followed by cost.

Yes, but the devil is in the detail.

If e.g. you have to go to an FTO, that will discourage most pilots because most pilots don't have an FTO in an easy driving distance. This seemingly trivial requirement means hotel residence for both the ground school (if any) and for the flying element. This may be OK for an unemployed and nearly skint 21 year old ATPL candidate but anybody who thinks this is not a huge hassle for somebody in a later part of their life is not living in the real world.

The reason the FAA route has been so popular with owner pilots is not because it is easier, or because maintenance is cheaper (it isn't). I don't think the IR is easier, and nowadays, with the TSA+Visa hassles thrown in, and the virtual necessity of having to go to the USA for the checkride, it carries a lot of completely pointless hassle. As well as, due to the US portion, the prob99 inability of doing the checkride in your own (or identical) plane which is a huge drawback because you end up doing a lot of training which is partly wasted because it isn't on the type.

What the FAA route has always offered, and continues to offer, is flexibility. Most plane owners are time-poor cash-rich business/professional types who can swallow a lot of work but only in small flexible chunks. For example I know one pilot (now flying a new £3M turboprop) who flew around Europe, on business, with his FAA instructor in the RHS. Really handy for him. This was in the days of fairly easy to arrange UK FAA checkrides and he probably paid a few k for that, too.

I don't think anybody in EASA fully understands these factors. Yes the ground school of 9 or 11 or 14 exams is a lot of swatting which is hard for anybody who is probably really sharp but probably last studied at univ etc 30 years previously. If I had to do the JAA IR I would pay almost any money (say £5k) to avoid the exams, and others I know have found routes around them (some of which still exist but are a lot of roundabout hassle). But there is other stuff which needs to be dealt with also. Not understanding this goes hand in hand with not understanding why the IMCR has been so popular; it is popular for the same accessibility reasons the FAA IR benefits from.

[Pace]

It is very relevant

MM

Maybe I didnt make myself clear. I was trying to say that the IR flight test and tolerances required is the best way of determining whether a pilot has the abilities to fly to those tolerances, deal with all the multi tasking required with navigation, aircraft management, radio operation and instrument scan, emergencies etc.

How the pilot gets to such a competant level is irrelevant ie he should be able to do the training at his local flying club as with the IMCR. only the pre test signoff would have to be done at a designated FTO before taking a full IR test.

Pace

[mm_flynn]

Pace,

I agree with both of your paragraphs. Unfortunately I don't believe EASA agrees with

[a pilot] should be able to do the training at his local flying club as with the IMCR.

- hence why this is relevant.

[Fuji Abound]

Which is pretty amazing considering that no one has seen the NPA......

It is not amazing at all.

Why do you think there was so much frenzy around the iPad?

.. .. .. well obviously because the product was released by a company perceived as being very successful and very good at producing innovative products.

So why would people speculate before the NPA?

Well how about because they are pretty cynical about everything that has gone before.

Ignore history at your peril - there is never any guarantee that history will not repeat itself, but it has a nasty habit of doing so, and most astute people have learnt that the hard way.

Celebrate on the streets if we are wrong, and dont be at all surprised if we are right. My way you will not be surprised whatever the outcome, your way you have only got a 50:50 percent chance of being right and it will be too late to back another horse if you are wrong.

[OpenCirrus619]

Personally my view is:

• IMCr has made a great contribution to safety.
• IMCr is accessible - the training requirements are modest, but (empirically proven) to be sufficient for holders to exercise the privileges safely.
• IMCr is not so expensive that pilots who fly for pleasure cannot afford it.
• IMCr has reasonable revalidation requirements meaning holders DO keep the rating current - completing any required "brush up" training in the process.

If the EASA replacement greatly increases cost and/or training required people are just not going to be able to afford (money and/or time) to get it - thus reducing safety.

Also the idea of an "En-Route" qualification is laughable - I'm not even going to dignify that with a comment ( if I indicate my feelings about anyone who doesn't understand why I'll get banned ).

One compromise would be for EASA to introduce an IR that includes various privileges (in the same way your licence has ratings attached). The "basic" one would be sub-ICAO and allow IMCr privileges. Additional "ratings" would allow flight in class A/B, RVSM, ... - once all the ratings were added it would become ICAO compliant.

Not stricly on the subject: I do wonder if some of the people pushing the "IR or nothing" agenda already hold IRs and are being slightly elitist. Perhaps it would help to make more informed views on posts if people declared what rating they held.

OC619 (IMCr)

[IO540]

I gather (but could be wrong) the EIR would require a VFR-IFR-VFR flight plan (Z) and would thus be no worse than flying VFR (VMC on top; widely done) in terms of the "end bits". You would have the additional benefit of an enroute IFR clearance.

I do wonder if some of the people pushing the "IR or nothing" agenda already hold IRs and are being slightly elitist

There is always an element of that...