Saving the IMC. Did we do enough? Can we do more?
Join Date: Jan 2001
Location: In the boot of my car!
Posts: 5,982
Likes: 0
Received 0 Likes
on
0 Posts
Agreed, but as Mad_Jock stated it is the renewal process of the FAA IR that concerns EASA, there is no annual recurrent testing unless you are going for a type rating recurrent course, it is self certification.
For a PPL IR It would be sensible to have an annual check ride and that is something that could be added to a more FAA (lLike) EASA iR.
I never indicated it should be a carbon copy
There is little difference in the flight training infact some reckon the FAA flight side is more difficult while the study side a lot easier and less time consuming
Pace
Join Date: May 2001
Posts: 10,815
Likes: 0
Received 0 Likes
on
0 Posts
I suspect that is correct pace I have heard that the IR is alot more partial panel and the oral is alot more in depth. But if you wait and transfer across to ATP in the sim on a type its easier than a EU LPC. The oral work on the FAR's is the challange.
The EASA theory isn't as bad as you think.
The question banks are allowing people to get 99% averages.
Even when I did them when JAR first came in and there was some 1000 questions on photo copied paper knocking around they wern't that bad.
The EASA theory isn't as bad as you think.
The question banks are allowing people to get 99% averages.
Even when I did them when JAR first came in and there was some 1000 questions on photo copied paper knocking around they wern't that bad.
A lot of ill-informed nonsense here about the UK IMCR....
No, it is not just a 'get out of trouble' rating. That's the first myth to dispel. It is a rating which, in 40 years of experience, has proved to provide privileges entirely commensurate with the experience, training and testing requirements associated with the rating. Unlike the FAA IR which is rarely, if ever, retested, the UK IMCR requires a comprehensive retest of IF skills (including limited panel unusual attitude recoveries) every 2 years.
The approach privileges have a minimum decision height of 500ft and a minimum descent height of 600 ft. These are currently only 'recommended' values; if EASA accepts the FCL.600(b) proposal, we intend to ask the CAA to make these 'mandatory' values.
If there's any 'overkill', it stems from the ridiculous CAA attitude that the IR should be a 'last chance check' of suitability for airline employment, rather than a check of IF skills.
The UK IMCR / IR(R) is an entirely adequate rating, which is both proportionate and safe and which must be retained.
As for the FCL.008 C-b M IR coming to this theatre soon, I wouldn't bet on that. If a vote has to be taken on all of FCL.008 rather than just parts of it, you can rest assured that at least one Member State will oppose it - because they have grave concerns about the proposed EIR. That's not the UK, incidentally.....
No, it is not just a 'get out of trouble' rating. That's the first myth to dispel. It is a rating which, in 40 years of experience, has proved to provide privileges entirely commensurate with the experience, training and testing requirements associated with the rating. Unlike the FAA IR which is rarely, if ever, retested, the UK IMCR requires a comprehensive retest of IF skills (including limited panel unusual attitude recoveries) every 2 years.
The approach privileges have a minimum decision height of 500ft and a minimum descent height of 600 ft. These are currently only 'recommended' values; if EASA accepts the FCL.600(b) proposal, we intend to ask the CAA to make these 'mandatory' values.
If there's any 'overkill', it stems from the ridiculous CAA attitude that the IR should be a 'last chance check' of suitability for airline employment, rather than a check of IF skills.
The UK IMCR / IR(R) is an entirely adequate rating, which is both proportionate and safe and which must be retained.
As for the FCL.008 C-b M IR coming to this theatre soon, I wouldn't bet on that. If a vote has to be taken on all of FCL.008 rather than just parts of it, you can rest assured that at least one Member State will oppose it - because they have grave concerns about the proposed EIR. That's not the UK, incidentally.....
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
Thank fully the current system seems to keep people like you with your attitude out the airspace I am flying in, long may it continue 
Actually I am happily flying in all the same airspace as you although with oxygen only perhaps not as high!
Actually I think you will find even the humble PPL will be operating in the same class D airspace as you albeit not in IMC.
As Beagle rightly points out there is so much utter nonsense spouted it is not surprising we are where we are. The real problem is that in a way you are culpable when pilots kill themselves and that is why I am still passionate about this one - dont forget it. All the time you realistically deny private pilots the training they need you are culpable.
It is not about tolerances, it is not about the FAA rating is better or worse, it is about whether the EVIDENCE is that the rating is safe - that is all that matters. There is no evidence the FAA IR with it multiple guess exams and practical approach to training is ANY less safe - in fact there is evidence it is SAFER. There is so much evidence that private pilots with an IR are safer pilots that if you are not aware of the evidence and have any interest at all in this subject take a little time to do some research.
Thinking about it none of this really matters and I dont know why I still feel so passionate about it because I have heard the same arguments for as long as I can remember and doubtless it is part of the reason we are set on the course we are. Personally I dont care.
It is worth thinking about though the next time a private pilot kills themselves for the most common reason pilots kill themselves whether you have helped perpetuate some of these myths and just how proud you feel of supporting a system that has resulted in less than 5% of European pilots having an instrument rating and but thank God for our IMC rating a record in the UK which would be a as poor as Frances were in not for the IMC rating.
Personally I think you have nothing to be proud of.
Join Date: Jan 2001
Location: In the boot of my car!
Posts: 5,982
Likes: 0
Received 0 Likes
on
0 Posts
As for the FCL.008 C-b M IR coming to this theatre soon, I wouldn't bet on that. If a vote has to be taken on all of FCL.008 rather than just parts of it, you can rest assured that at least one Member State will oppose it - because they have grave concerns about the proposed EIR. That's not the UK, incidentally....
Beagle
I know you are a great supporter of the IMCR!
I never was not because of the IMCR or its quality or what it has achieved but because we were looking at a rating which would be universally accepted Europe wide.
I saw fighting for the IMCR as a distraction away from what we should have put 100% into fighting for which was an FAA style IR! A full IR with departure and approach as well as enroute.
The EIR is a flawed part way house with a number of safety threats to the holder who could be forced to land half way along his route with 200 foot cloudbases below his blissful in the sun cruise above cloud.
No ability or experience to get down.
I have flown into Barcelona numerous times CAVOK over the airport while thick dense cloud over the mountains where Tommy EIR rated has to be visual and leave the airway a recipe for disaster
Pace
Last edited by Pace; 27th Mar 2013 at 13:39.
Join Date: Jul 2010
Location: USA
Posts: 563
Likes: 0
Received 0 Likes
on
0 Posts
It is a rating which, in 40 years of experience, has proved to provide privileges entirely commensurate with the experience, training and testing requirements associated with the rating.
If there's any 'overkill', it stems from the ridiculous CAA attitude that the IR should be a 'last chance check' of suitability for airline employment, rather than a check of IF skills.
That is what the ATPL checkride is for!!
Last edited by soaringhigh650; 27th Mar 2013 at 14:52.
Join Date: May 2001
Posts: 10,815
Likes: 0
Received 0 Likes
on
0 Posts
The ATPL check for years was a paperwork exercise in the UK.
And for a long period when JAR came in it continued to be a tick box intially just taken as your normal LPC after getting the aquired hours and then as box to be ticked.
Some European Countries its a bit more involved requiring a state examinor not a company one and also the test is seperate and done from the LHS seat with LOFT exercises.
The SPA-ME-IR was the only real test when the examinor was independent and salaried allocated by a central office with nothing dependent on a pass or fail.
And for a long period when JAR came in it continued to be a tick box intially just taken as your normal LPC after getting the aquired hours and then as box to be ticked.
Some European Countries its a bit more involved requiring a state examinor not a company one and also the test is seperate and done from the LHS seat with LOFT exercises.
The SPA-ME-IR was the only real test when the examinor was independent and salaried allocated by a central office with nothing dependent on a pass or fail.
If this is really is the case then nobody has properly explained why it was rejected and thrown out the window by EASA.
It will be difficult to plan and execute a flight using the EIR at times. Explaining to an unfamiliar controller than you can accept vectors, but not a STAR and that you may only fly under VFR in the terminal area isn't going to be easy. But if you can, then why not?
Area forecasts are rarely very specific regarding minimum cloudbase. However, one EIR advocate maintained that only TAFs and METARs were necessary to use the rating safely. So we turned the question over to EASA and asked them to state whether they considered that the current ICAO en-route forecasting criteria were sufficient..... Needless to say, they stated that they were sure that these criteria were entirely adequate. To (mis)-quote Mandy Rice-Davies, "Well they would, wouldn't they?".
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
If this is really is the case then nobody has properly explained why it was rejected and thrown out the window by EASA.
In previous debates we always liked to point out not a single pilot has ever been killed whilst exercising the privileges of an IMC rating. Even the CAA said so!
After a huge amount of research doubtless by the most ardent detractors someone came up with one possible and highly debatable example! I cant even recall the circumstances and it was really clutching at straws.
By any definition that is a remarkable standard, especially compared with the number of pilots killing themselves every year in instrument conditions with ICAO IRs.
The explanation is actually quite simple. EASA was intended to unify standards. The IMCr was a unique British rating and didnt fit well into this model. National pride was a huge factor - the German's had no interest in adopting a peculiarly British rating, that they didnt understand anyway. Then there was the problem of it being sub ICAO - EASA doesnt really understand anything that is sub ICAO. Then there was the problem of our airspace structure being very different from the rest of Europe. Only we define all our airways (well almost all) as class A. The there was the problem that this thread illustrates so well of those pontificating on matters about which at best they knew nothing, and at worst had very different motives. I could go on.
Are these proper reasons - in some cases yes, in some cases certainly not. The missed opportunity was to find a formula that took the best of the IMCr and integrated this into the best of EASA - the EIR was not that formula, abolishing the IMCr was not it, and the proposed IR is not it.
Join Date: Jan 2001
Location: In the boot of my car!
Posts: 5,982
Likes: 0
Received 0 Likes
on
0 Posts
one EIR advocate maintained that only TAFs and METARs were necessary to use the rating safely.
again little Tommy is struggling along on Top of solid! Departure weather great destination great! Enroute not so great! Infact the airports below are all reporting Overcast 200! Little Tommy has a problem! " oh dear I need to divert what do I do ? ".
Oh well
Pace
Last edited by Pace; 27th Mar 2013 at 15:44.
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
Pace - I think you will find EASA has banned en route emergencies. 
No, as I understand it, the theory is you stay on top (in IMC or not as the case might be) and ONLY descend at your destination if they have stayed visual as predicted by the TAFs. If not, you divert to your alternate, assuming that has stayed visual, and if not you divert to somewhere that is, and if not you declare an emergency.
If you have a problem en route you divert to where ever is visual and if there is no where visual you declare an emergency.
The theory is emergencies will almost never happen, and if they do there will be somewhere to go visual, and the TAFs are almost never wrong but if they are your alternate will be good.
To be fair the theory probably stands up most of the time - it is rare for the destination and two alternates to both predict a visual approach and all three to fall below visual. The theory doesnt of course take into account an en route emergency but given most EIR holders will be flying singles I guess the most likely emergency will be an engine failure in which event you are coming down whatever (and would be just with a PPL with on top rights) - just better hope you have a chute.
In your case EASA would probably say you chose your alternates unwisely!
No, as I understand it, the theory is you stay on top (in IMC or not as the case might be) and ONLY descend at your destination if they have stayed visual as predicted by the TAFs. If not, you divert to your alternate, assuming that has stayed visual, and if not you divert to somewhere that is, and if not you declare an emergency.
If you have a problem en route you divert to where ever is visual and if there is no where visual you declare an emergency.
The theory is emergencies will almost never happen, and if they do there will be somewhere to go visual, and the TAFs are almost never wrong but if they are your alternate will be good.
To be fair the theory probably stands up most of the time - it is rare for the destination and two alternates to both predict a visual approach and all three to fall below visual. The theory doesnt of course take into account an en route emergency but given most EIR holders will be flying singles I guess the most likely emergency will be an engine failure in which event you are coming down whatever (and would be just with a PPL with on top rights) - just better hope you have a chute.
In your case EASA would probably say you chose your alternates unwisely!
Last edited by Fuji Abound; 27th Mar 2013 at 16:18.
Are these proper reasons - in some cases yes, in some cases certainly not. The missed opportunity was to find a formula that took the best of the IMCr and integrated this into the best of EASA - the EIR was not that formula, abolishing the IMCr was not it, and the proposed IR is not it.
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
Bookworm
I wasnt aware the CBM IR will address the "problems" identified in this thread as to a mechanism for EASA IR holders to obtain the rating without the overhead of the theory exams and the existing limited access to training organisations?
I appreciate the "applicant" could complete the FAA IR and then convert without these problems and only an oral examination with regards the theory, but that seems to rather defeat the object for new pilots.
I am probably missing a lot?
I wasnt aware the CBM IR will address the "problems" identified in this thread as to a mechanism for EASA IR holders to obtain the rating without the overhead of the theory exams and the existing limited access to training organisations?
I appreciate the "applicant" could complete the FAA IR and then convert without these problems and only an oral examination with regards the theory, but that seems to rather defeat the object for new pilots.
I am probably missing a lot?
I wasnt aware the CBM IR will address the "problems" identified in this thread as to a mechanism for EASA IR holders to obtain the rating without the overhead of the theory exams and the existing limited access to training organisations?
On the former, at the risk of being labelled an IMC rating detractor (which I am not), I do worry a bit that the IMC rating theory is both light and outdated. Unless I've missed an update of the syllabus, QGH procedures, VDF and ADF are unlikely to take the pilot far in the 2016+ world of IFR operation, where every instrument runway end is supposed to have APV and NDBs will have disappeared. The proposed CBM-IR has halved the theory syllabus. Nevertheless, there's lots of scope to improve on the examination administration, and I'd like to see it be as easy to take the IR TK exam as it is in the FAA world.
On the latter, organisational requirements should be at the top of the hitlist of EASA disproportionate rulemaking to be rectified in the wake of the GA Safety Strategy. Again, we need to make the European IR as accessible as the FAA IR. If the IMC rating had by some sleight of hand been made into a European rating, the ATO requirements would be no less burdensome than they are for the CBM-IR. It was simply the (misguided) European way to assume that everything to do with aviation needs an approval certificate, even if it is just an exercise in box-ticking.
On balance, I remain a supporter of the retention of the IMC rating in the UK, just as I know BEagle supports, on balance, the adoption of the FCL.008 package of CBM-IR, EIR and sailplane cloud flying rating.
Join Date: Jan 2001
Location: In the boot of my car!
Posts: 5,982
Likes: 0
Received 0 Likes
on
0 Posts
Bookworm
The route we should be taking lets hope that is the way things go
F900EX
I think it was MadJock who talked about experience with either the IMCR or the IR!
I always remember the IMCR as being a get out of jail for free card for the VFR pilot who got into minimal conditions more than a mini IR.
Having said that I knew quite a few very experienced PPLs who used it with anger and shot approaches in pretty bad weather often making life hard for themselves beating around OCAS avoiding bit of airspace to the sides and above and stuck down in the worst of weather but they were relying on hard earned experience over many years.
The majority never used it in anger and frankly a lot were not capable of using the privalages in anger.
Pace
The route we should be taking lets hope that is the way things go
F900EX
I very quickly realized the limitations of the IMC rating
I always remember the IMCR as being a get out of jail for free card for the VFR pilot who got into minimal conditions more than a mini IR.
Having said that I knew quite a few very experienced PPLs who used it with anger and shot approaches in pretty bad weather often making life hard for themselves beating around OCAS avoiding bit of airspace to the sides and above and stuck down in the worst of weather but they were relying on hard earned experience over many years.
The majority never used it in anger and frankly a lot were not capable of using the privalages in anger.
Pace
Join Date: May 2001
Posts: 10,815
Likes: 0
Received 0 Likes
on
0 Posts
There have always been two types of IMC holder.
One hard core that used it more than most IR holders outside commercial ops.
And the ones that did the rating had an occassional approach for ****s and giggles and that was about it. They might have renewed it once or twice but that was about it.
The main thing for me have been the number of expired IMC holders that have found themselves where they really didn't want to be and got themselves back on the ground safely if not in exactly text book or pretty manner.
Then there are those of us that fly multicrew IR and want some form of instrument rating for flying singles without going for the full wack. I suspect 50% of us since converting to JAR haven't bothered to be honest keeping it current. And more than likely wouldn't hesitate either banging up into the cloud if we thought it was the safest thing to do.
In the UK IMC works because of the airspace structure. They are kept away from class A airways but still have access to the majority of instrument approaches. And landing fees take care of the rest.
There will I suspect be a huge part of the problems with certain parties is the fact they don't want a load of 80-130knt spam cans cluttering up their airways and them having to provide ATS for the increase in traffic load. And not get payed for it to boot.
It doesn't bother the UK because they can't get access to any of the enroute center services they have to sort themselves out bodging between local services and they don't screw with the flow figures.
One hard core that used it more than most IR holders outside commercial ops.
And the ones that did the rating had an occassional approach for ****s and giggles and that was about it. They might have renewed it once or twice but that was about it.
The main thing for me have been the number of expired IMC holders that have found themselves where they really didn't want to be and got themselves back on the ground safely if not in exactly text book or pretty manner.
Then there are those of us that fly multicrew IR and want some form of instrument rating for flying singles without going for the full wack. I suspect 50% of us since converting to JAR haven't bothered to be honest keeping it current. And more than likely wouldn't hesitate either banging up into the cloud if we thought it was the safest thing to do.
In the UK IMC works because of the airspace structure. They are kept away from class A airways but still have access to the majority of instrument approaches. And landing fees take care of the rest.
There will I suspect be a huge part of the problems with certain parties is the fact they don't want a load of 80-130knt spam cans cluttering up their airways and them having to provide ATS for the increase in traffic load. And not get payed for it to boot.
It doesn't bother the UK because they can't get access to any of the enroute center services they have to sort themselves out bodging between local services and they don't screw with the flow figures.
Last edited by mad_jock; 27th Mar 2013 at 18:33.
Join Date: Aug 2009
Location: Hampshire
Age: 46
Posts: 67
Likes: 0
Received 0 Likes
on
0 Posts
I think that the IMCr as it stands answers what the majority of 'spam can' GA pilots want, which is the ability to climb on top of cloud, get somewhere and make an approach safely if required. Being excluded from airways and class A is probably not a big deal and I suspect there are very few IMCr holders who would plan a flight wholly in IMC conditions as it is basically unpleasant and not really what a private pilot is indulging in their hobby for.
I know this doesn't suit the even smaller group of GA, private pilots that fly more fancy equipment at higher levels and over further distances, but it is probably reasonable that if you want to mix it with the 'big boys' then you have to accept that the airspace your playing with is fundamentally their train set, so you play by 'their' rules.
An EIR appears to me to be useless... The important bit is not getting up there, or staying up there, it is getting down in one piece! An approach IR would seem to make more sense in that case.
My IMCr has saved my bacon once and I know others who wouldn't have got themselves in such a pickle for the sake of 15 hours training, so any replacement should be as accessible as it is currently. Currency is definitely key and perhaps this needs to be tightened up a little for the purposes of establishing a rating that can be used more widely.
I know this doesn't suit the even smaller group of GA, private pilots that fly more fancy equipment at higher levels and over further distances, but it is probably reasonable that if you want to mix it with the 'big boys' then you have to accept that the airspace your playing with is fundamentally their train set, so you play by 'their' rules.
An EIR appears to me to be useless... The important bit is not getting up there, or staying up there, it is getting down in one piece! An approach IR would seem to make more sense in that case.
My IMCr has saved my bacon once and I know others who wouldn't have got themselves in such a pickle for the sake of 15 hours training, so any replacement should be as accessible as it is currently. Currency is definitely key and perhaps this needs to be tightened up a little for the purposes of establishing a rating that can be used more widely.
To me the IMC rating never made any sense as a useful rating it was more a rating to get yourself in to trouble with.
For my purposes when I was an ATPL holding UK/FE(PPL), the IMCR was precisely what I needed. I neither wanted nor needed to fly down to 200ft a.a.l. in a spamcan, but the ability to fly in cloudbases of 600 ft was ideal. Finish a training exercise above 8/8, then a quick cloudbreak to visual was perfect. Playing airliners in a light aeroplane was emphatically for others - they were welcome to it! It was boring enough in my 'day job'.
Re. the EIR, I don't think it will be 'useless' if accepted. But I do think that it will probably have little appeal / practicality.....
Last edited by BEagle; 27th Mar 2013 at 20:28.
Join Date: Jan 2001
Location: In the boot of my car!
Posts: 5,982
Likes: 0
Received 0 Likes
on
0 Posts
Beagle
I fail to understand why you fight so hard for the IMCR rather than an FAA lookalike full IR?
Never sell it to Euroland but you could sell an FAA lookalike IR
In my eyes it has served a purpose but is past its sell by date and is clouding the waters in focusing on an achievable IR for Europe as well as distracting from that goal.
Pace
I fail to understand why you fight so hard for the IMCR rather than an FAA lookalike full IR?
Never sell it to Euroland but you could sell an FAA lookalike IR
In my eyes it has served a purpose but is past its sell by date and is clouding the waters in focusing on an achievable IR for Europe as well as distracting from that goal.
Pace
Join Date: May 2001
Location: UK
Posts: 4,631
Likes: 0
Received 0 Likes
on
0 Posts
F900EX
Thanks for a reasoned post. You say you are not a rich boy but fly jets. Presumably you fly for someone else. Presumably you decided you needed a professional rating at some point and that is why you funded an IR - rightly, and necessarily so. Most PPLs are not in that position nor do they want to be. They dont have any commercial aspirations. Therefore they fund an IR or IMCr themselves and most arent "rich". Moreover they cant afford weeks off work to attend residential courses 100 miles away. That doesnt mean they want an easier rating because it doesnt need to be that way. What they want, indeed need, is rating stripped of unnecessary theory, with a practical point of supply and a means of delivery that fits in with having to work. The FAA IR has always done that very well which is why the uptake is so high - every version of European IR has failed on every one of those counts.
In some ways the IMCr makes life harder and the need for a standard higher. As Pace explains there isnt much harder operating OCAS in IMC single pilot single engine - take note all you multi engine multi crew pilots. Worse still you might well not have an A/P and pretty basic instruments. Its tough. It makes the safety record even more compelling.
Yes, many IMCr holders dont use the rating in earnest. Good. They have learned to operate within their abilities, just like any pilot. There is plenty of evidence to suggest some IR holders could have learned an important lesson when they are less than current but think because they have an IR they can blast off into any conditions.
Yes, the content of the IMCr is outdated, that is hardly a surprise having regard to the last time it was properly overhauled - that isnt the fault of the rating and it could have been overhauled had their been a will to do so.
Thanks for a reasoned post. You say you are not a rich boy but fly jets. Presumably you fly for someone else. Presumably you decided you needed a professional rating at some point and that is why you funded an IR - rightly, and necessarily so. Most PPLs are not in that position nor do they want to be. They dont have any commercial aspirations. Therefore they fund an IR or IMCr themselves and most arent "rich". Moreover they cant afford weeks off work to attend residential courses 100 miles away. That doesnt mean they want an easier rating because it doesnt need to be that way. What they want, indeed need, is rating stripped of unnecessary theory, with a practical point of supply and a means of delivery that fits in with having to work. The FAA IR has always done that very well which is why the uptake is so high - every version of European IR has failed on every one of those counts.
In some ways the IMCr makes life harder and the need for a standard higher. As Pace explains there isnt much harder operating OCAS in IMC single pilot single engine - take note all you multi engine multi crew pilots. Worse still you might well not have an A/P and pretty basic instruments. Its tough. It makes the safety record even more compelling.
Yes, many IMCr holders dont use the rating in earnest. Good. They have learned to operate within their abilities, just like any pilot. There is plenty of evidence to suggest some IR holders could have learned an important lesson when they are less than current but think because they have an IR they can blast off into any conditions.
Yes, the content of the IMCr is outdated, that is hardly a surprise having regard to the last time it was properly overhauled - that isnt the fault of the rating and it could have been overhauled had their been a will to do so.