EASA AND THE IMCR - NEWS

[Pace]

Timothy

Yes quite happily! The IMCR was pushed at EASA as a safety addon for the VFR pilot! The safety angle was shown to be the case especially regarding the attrocious French VFR accident rates compared to UK VFR accident rates.

As such they were forced to do something as an addon for VFR pilots which added some instrument capability and privalages without being a mini IR.

EASA would not put anything in place which would fight with their own beloved IR so put in the EIR which would be an enroute to the IR ie a modular part of the IR.

Basically they have added their own acceptable IMCR and acceptable means without approaches.

Pace

[funfly]

Pace is getting to a valid point - the IMC rating is not wholly about flying under instrument conditions, it is about offering an ADDITIONAL level of pilot training that can take a pilot to an enhanced level of flying skills and can add to the safety of his/her flying by the ability to use instrumentation. I see no reason why the training and the qualification should not continue for this sake alone even if there was no official 'out of sight' privileges gained. In my case I never flew in instrument conditions but the IMC training, post PPL, made my flying better, more precise and more enjoyable.

[IO540]

I don't disagree with you but you could make the same point about the full IR.

Both of them enhance the ability to fly under VFR

The only difference between the IMCR and the IR is the big increment in the hassle, cost, hassle, cost, ongoing hassle, ongoing cost, in getting the IR and keeping it

In fact I would argue that you need an "instrument capability" to fly VFR to anywhere near the license privileges e.g.

- at night
- in haze
- in difficult lighting conditions
- in a lack of a horizon
- when there are no visual nav references
- anytime you don't want to bust airspace

[Timothy]

Ironically, I have long argued that it is somewhat irresponsible (both of the authorities and individual pilots) to allow people who are not capable of instrument flight to command an aircraft.

Can you imagine a "good weather" driving licence, where the driver is disqualified from entering rain, and is likely to crash if he does?

The tiny amount of instrument flying in the PPL is clearly inadequate.

So, if I were King, I'd probably make the EIR a compulsory part of the PPL. Don't worry, though. Neither of my parents is a Queen

[Whopity]

The tiny amount of instrument flying in the PPL is clearly inadequate.

We used to have 4 hours of it, but it created a level of overconfidence in some pilots who would press on in conditions that they should not have been flying in. It was taken away from aeroplanes under the JAA umbrella, but given to the helicopter pilots who are allowed to fly VFR in lower visibility. The same overconfidence has appeared in some areas.

This alone indicates a little knowledge can be a dangerous thing, if you half train people to do any job, some will think they can do the whole job. And what is to stop them?

[Genghis the Engineer]

Originally Posted by Whopity

We used to have 4 hours of it, but it created a level of overconfidence in some pilots who would press on in conditions that they should not have been flying in. It was taken away from aeroplanes under the JAA umbrella, but given to the helicopter pilots who are allowed to fly VFR in lower visibility. The same overconfidence has appeared in some areas.

This alone indicates a little knowledge can be a dangerous thing, if you half train people to do any job, some will think they can do the whole job. And what is to stop them?

Interesting that this is very similar to the arguments that led to removal of spinning from the PPL syllabus (and it's not even in the CPL now, or was it ever?)

By extension of course, don't teach people to fly at-all, then they won't feel tempted to try, and thus safety is substantially enhanced!

G

[Fuji Abound]

Interesting that this is very similar to the arguments that led to removal of spinning from the PPL syllabus

Genghis

While I have some symphathy with your argument (and in jest it was probably partly meant) I think there is an important distinction.

While I personally think spin training is a good idea I am not sure how many people's lives it actually saved. The reality is the only time inexperienced pilots manage to spin the aircraft is close to the ground in the circuit at which point the spin training will probably be of little help. In fact it seems to me most pilots are so scared of the stall they back off well before.

On the other hand the biggest killer remains flying into IMC or some variation thereof - CFIT which more often than not arises from flying into IMC.

So if the evidence was piltos were killing themselves in self induced spin accidents it should be taught: whereas the evidence is people are killing themselves in IMC so I suspect it is really important that is taught as well as possible at the PPL stage without of course turning a PPL into a mini IR.

[Genghis the Engineer]

It was partly in jest. However...


- The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC. So the current concentration on stall avoidance is pretty sensible.

- CFIT is a relatively small killer, but still significant, and so I don't actually support the view that we should eliminate instrument training for PPLs - I think it does have value.

- There was, historically, a big dip in spin-related fatal accidents when it was eliminated from the UK PPL syllabus, for whatever reason.

G

[IO540]

The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC. So the current concentration on stall avoidance is pretty sensible.

Would it not be better to train people to avoid low and slow flight?

I think too many pilots fly too slowly; maybe 10kt above Vs, wallowing around the circuit, because they were trained like that.

[Fuji Abound]

- The biggest killer if you plough through the GA safety stats is LoC at low level, usually in VMC. So the current concentration on stall avoidance is pretty sensible.

Is that right?

[Timothy]

We also have to confess that CFIT is far from limited to VFR pilots.

Indeed the last four high profile cases have been with rated (variously IMCR and IR) pilots screwing up badly in one way or another.

[Genghis the Engineer]

Originally Posted by Fuji Abound

Is that right?

Yup, see the recent GASCo 29 year UK fatal accident statistics review....

25% LoC VFR
16% Low flying / aeros
12% CFIT
12% Forced Landing
8% Loc IMC
6% mid-air
5% ground collision
4% airframe failure
4% low approach
3% medical or suicide
5% undetermined

(I've only got a draft to hand, so if you have a final version, the numbers may be very slightly different, but not much.)

So 33% definitely attributable to LoC, and when you analyse them the vast majority were low level. Odds are that a proportion of the 16% low flying and aeros involve some form of low level LoC also.

From that, I'd say that LoC - usually low level, is probably 3-4 times as regular a killer as CFIT.

G

[Genghis the Engineer]

Originally Posted by IO540

Would it not be better to train people to avoid low and slow flight?

I think too many pilots fly too slowly; maybe 10kt above Vs, wallowing around the circuit, because they were trained like that.

Interesting perception - why do you think that?

My experience is that PPLs are more likely to fly too fast and get badly behind the aeroplane, rather than fly too slow and nibble the stall. The stall related LoC accidents tend to be finals, go-around or climbout, when you have to be fairly near the stall anyhow.

G

[Pace]

I do think there is an element of truth to what 10540 says.
I have flown with many pilots who get
Slow and you have to prompt them.
There are equally some who seem oblivious to wind and shear conditions and peg the same old speed.
Looking at the LOC VFR how many are minimal VFR or almost IMC ?

Pace

[Genghis the Engineer]

Originally Posted by Silvaire1

Would you also outlaw aircraft that cannot be controlled in the clouds? Just curious - it would outlaw much of the GA fleet, or at least 1/2 of my fleet! It does sound like a logical extension of current Euro regulation.

Given the amount of time we all spent doing partial panel training, I suspect that your statement isn't true.

It may be unwise, but it is possible to fly just about anything in cloud, and control it. The only exception that I can think of are weightshift microlights, where there is significant evidence this'll probably end in tears - but pretty much any fixed wing aeroplane with an ASI, altimeter and compass (which is all of them) can be flown and controlled in cloud, although doubtless T&S, DI/HSI and AI make life far safer and easier.

G

[Contacttower]

Coming back to the NPA....

Having now read the thing in it's entirety it seems to be a fairly reasonable document.

I would highlight several issues however that I think need expansion on or modification:

1. This has already been raised several times but in terms of the EIR the VFR to IFR transition needs to be thought through quite carefully. At the moment the proposal is to allow departures in VFR only and not be allowed to enter IMC below 1000ft above the highest obstacle with 5nm. Now as far as I can see from the NPA there is no explanation as such of how this will be achieved; the proposed flight test syllabus does not include SIDs but at the same time nowhere in the NPA does it say that they are prohibited. To make things simple (especially from an ATC point of view) it would seem sensible to allow them to fly the SID but state that it must be visual for the first 1000ft after departure. If there is no SID then simply revert to the 1000ft within 5NM of highest obstacle rule.

With arrivals a similar clarification is needed. Although some posters have make reference to needing to be visual by the IAF I don't see this specific statement in the NPA. Only that the arrival and landing must be VFR. As with departures it seems sensible to allow them to fly the start of the STAR at least since otherwise it will be a pain for ATC.

I suspect the reason SIDs/STARs are not included is because once you teach people to fly them you have taken up more hours and the advantage of just doing the EIR as opposed to doing the IR in one go decreases. If they can be included though in the proposed minimum instructional hours for the rating it would seem to make sense to do so.

2. The proposed 100hrs of theoretical study seems excessive, especially since the EIR and IR written exam are proposed to be the same. I know in reality people will use distance courses a lot but overall the process of taking the writtens sounds like it could still be rather laborious; distance courses as I have found myself with the JAA IR are a bit of rip off and complicate the process when actually the FAA way of just learning the stuff and then getting an instructor to check your knowledge and sign you off is perfectly adequate. However I commend the suggestion in the NPA that the written exam could be done all in one sitting. They have scratched off a lot of garbage from the written exams but as IO540 pointed out on another thread there is still the fear that the actual quality of the remaining questions will still be poor.

3. The proposal for the conversion of foreign IRs seem reasonable, ie no required dual time, just a flight test. However I would like to know what they mean by 'demonstrate' knowledge of Air Law, HPL etc? A chat with the examiner? Just take the written exams?


I would encourage people to comment on the NPA with their thoughts. EASA may or may not listen but reading this NPA it would seem they have at least attempted to deal with the PPL/IR issue so its probably worth contributing.

[IO540]

Indeed the last four high profile cases have been with rated (variously IMCR and IR) pilots screwing up badly in one way or another.

I am not completely sure which four you refer to, though one of them must be the recent one near Nice.

When I read some accident report (and I have read many many) I try to take something home from it.

The problem I have with the "IR holder CFITs", and these are usually discussed here on pprune fairly thoroughly and much more so than on any other forum, is that they are just plain weird, bizzare, nonsensical.

N2195B (which lived in "my" hangar) was an IR holder who was > 2T but his Seneca did not have the 1999kg STC, and this was possibly a factor in why he flew mostly VFR on his long foreign trips. I happen to know (can't say how) that he used to file around 10 Eurocontrol flight plans per year, so he did know about "IFR". His final flight was "VFR", mostly in IMC (the BEA report doesn't say that but they barely bother in their GA reports), and into conditions which made it clear he never even checked the BBC weather, let alone looked at tafs, metars, mslp, radar, IR, whatever, as well as having no clue that there is "terrain" in the lower bit of France. A very good friend of mine was the last to see his family alive, and when he pointed at the OVC006 RA conditions (what a scream, filing "VFR", hey?) he was told by the highly intelligent PhD economist pilot that he "always flies". With no oxygen, he cut off his wx escape routes, apart from a 180 which he was unlikely to consider anyway. What is one supposed to make of that?

N403HP crashed after cancelling IFR, which he did about 50-100nm before his destination. Not clear why he cancelled IFR so far back. He then flew what looks to me like a pretend visual circuit, for the benefit of Vienna radar, in absolutely solid IMC, and crashed while doing that. He could have popped into LOWW which was 5 mins' flying time away and auto-landed his Jetprop on their ILS. A highly intelligent businessman with a CPL/IR and CFII. What is one supposed to make of that?

Regarding the last one, little is known and those who were flying in the group are not talking, but the appearance is that he crashed while pottering about, presumably in IMC (who actually does a CFIT in VMC, short of flying in a canyon?), before he managed to collect an IFR clearance. I hate to speculate on this one because so little is known but I won't be shocked to learn he had no oxygen and was thus trying to fly low in that area, where airway routes are unavailable below FL150 or whatever.

So it looks like most if not all CFITs of IR holders happen when they are not using their IR.

I am not aware of a CFIT in the UK, or connected with the UK, where one could say "damn I could have fallen for that one". I had a very sticky one on Greece last year, pottering around among hills in ~ 1k viz while trying to collect an IFR clearance from a couple of units which were both snoozing, but I had a GPS running a real topo map.

There have been CFITs in the USA where subtle avionics issues were possibly implicated. For example a pilot I know researched a number of CFITs of aircraft carrying a KMD550 MFD, whose colour terrain/elevation depiction contains absolutely life-threatening defects (basically, missing mountains, due to Jepp having downsampled the elevation data by averaging adjacent heights, rather than by taking the highest value) and these pilots hit isolated peaks. OK, they were dumb to rely on the kit to fly an off-airway DCT because the MEA concept is then void, but...

Interesting perception - why do you think that?

I repeatedly see people fly very slowly in the circuit. Really slowly, and I am talking about a C152 doing ~60kt.

They also have a very common habit of drifting downwards. Where I am, the cct is at 1100ft, with terrain around the dw/base turn area of 840ft (especially if you fly a wide cct). But I often see people flying the final leg somewhere down on the ground, flying much of it maybe 300ft AGL, very hard to spot, and then they suddenly pop up on very short final. Very few are flying a "glideslope" or a stabilised approach trajectory.

My experience is that PPLs are more likely to fly too fast and get badly behind the aeroplane, rather than fly too slow and nibble the stall.

I don't see that in the circuit. I am sure it does happen, but normally it would result in a go-around. Also, traffic separation issues excepted, there is nothing wrong with flying the circuit too fast. It is only on short final that you have to get it right

The stall related LoC accidents tend to be finals, go-around or climbout, when you have to be fairly near the stall anyhow.

There is no reason to be lower than 1.3 x Vs anywhere before very short final, and being at 1.3 Vs at the base-final turn is IMHO needlessly slow.

3. The proposal for the conversion of foreign IRs seem reasonable, ie no required dual time, just a flight test. However I would like to know what they mean by 'demonstrate' knowledge of Air Law, HPL etc? A chat with the examiner? Just take the written exams?

I agree with your thinking but it has always meant sitting the written exams.

IMHO, introducing an FAA-style oral exam into the European pilot training machine would scare the living daylights out of most ab initio people especially at the IR/ATPL level, not least because nearly all of them a) sat the exams months or years before they do the flight test and b) did most of the study using a QB.

[IO540]

You can fly with just a compass, in smooth conditions, to keep the wings level.

But if you get into anything remotely resembling a "bank angle" then you will not recover.

Also, for some reason, most planes are more roll-stable in a descent, so getting down is less work.

It is somewhat easier to do this stunt with a gyro compass (a DI) because it doesn't wobble about so much.

[BillieBob]

Contacttower wrote:

nowhere in the NPA does it say that they [SIDs] are prohibited.

GM1 FCL.825 states:

Since the privileges of the EIR are only to be exercised in the en-route phase of flight, the holder of an EIR should:

1. at no time accept an IFR clearance to fly a departure, arrival or approach procedure;

There is nothing to prevent procedures from being flown VFR but I don't think that's what you had in mind.

Although some posters have make reference to needing to be visual by the IAF I don't see this specific statement in the NPA.

AMC1 FCL.825 states:

A VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points. If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).

Remember that, under EU legislation, where there is only one published Acceptable Means of Compliance it is to be considered mandatory. Anyone is at liberty to propose alternative AMCs to the competent authority.

[BEagle]

AMC1 FCL.825 states:

A VFR transition point should be used in order to enable the pilot to conclude the flight under VFR to the intended destination. For this purpose, when filing a flight plan in accordance with operational rules, the holder of an EIR should include IFR/VFR transition points. If an IFR approach procedure is established at the destination airfield, this IFR/VFR transition point should be passed before reaching the Initial Approach Fix (IAF).

'Should' in EASA-speak is a recommendation, not a mandatory requirement. The circumstances described above need to be changed to become mandatory as they will then have legal strength. This could be achieved by the use of 'shall' instead of 'should'.

That is one example of the type of comment I will be making at the forthcoming workshop. It will be neither the time nor place to argue the relative merits of the IR, its theoretical knowledge requirements, nor whether they are proportionate for the proposed EIR, nor the EIR itself. To me the EIR theoretical knowledge requirements seem disproportionate for the privileges conferred - so the option to do an 'EIR' exam first, followed by a delta for the 'IR', would seem a reasonable alternative.

The workshop will really only be an information gathering session and will not be suitable venue for indicating the direction the NPA response of an individual or organisation will take. However, it may be necessary to advise EASA that, given the very short period of time which has been available to study the NPA, it does not at present seem to meet the UK's position as regards the IMCR. Rather than press the point on Friday, I hope that my fellow UK representatives and I will restrict ourselves to a few basic questions concerning the IR, EIR and 'sailplane cloud rating' within the scope of the NPA, but will be taking up the matter of the UK IMCR in UK airspace with the UK CAA and 'others' over the coming weeks.

It's possible that the EIR might be considered a 'student' rating, allowing IR students to gain the relevant experience towards the IR, rather than an indefinite V/IFR rating. Why? Because that could be a strategem to reduce opposition from ATS providers who are known to be concerned at the impact of additional IFR activity in busy sectors.

Typical questions I am already considering:

1. Define 'busy IFR airspace' for EIR training.
2. Define 'emergency IFR approach' for EIR training.
3. Were ATS providers consulted during FCL.008?
4. What is the minimum cloudbase permitted for a sailplane / powered sailplane pilot to fly in cloud with the sailplane cloud rating?

I'm aware that the level of 'bull$hit' in the IR theory requirements has already illuminated the 'BS' caption - it will take people quite a while to wade through it all, but please do so!

It will hopefully be a productive information-gathering session in Friday - and I'm looking forward to a Schnitzel und Weißbier tomorrow night at the usual place!