Saving the IMC. Did we do enough? Can we do more?

[Level Attitude]

Given AOPA's latest statement, of 20th March, on the IMC ( Welcome to AOPA UK )
it seems all hopes of saving it for the future is based on amending FCL.600
to allow for National differences to continue.

I understand that "high level" "behind the scenes" discussions have been,
and remain, on-going - but National differences do seem anathema to EASA.

Just to ensure nothing is overlooked, and given that all the important bodies
(CAA, AOPA, etc) follow PPRuNe avidly, perhaps we should all contribute our
ideas of what should have, and more importantly, what could still be done to
help ensure the IMC or IR(R) continues to be available to pilots in the future.

Some to start off:

In all meetings with EASA the CAA could not demonstrate how important
the IMC rating was to the UK as it had no idea how many current IMC holders
there were.
From 2008 onwards the CAA should have required that it was informed
of all IMC renewals (just like other Ratings) and, in my opinion, it should
still instigate this asap.

To "help" our European colleagues, the CAA could have changed the
IMC Rating to a more recognisable format:
ie: Valid for 24 months from date of Test.
Renewal, or Revalidation, by Test.
If Revalidated in the last 3 months of validity then valid for 24 months
from date of expiry of previous Rating.

IMC is not valid for IFR in Class A airspace. Change that to not valid for
IFR in Airways. Even combined with the proposed EIR that should not
(especially with clever wording) give full IR privileges (which is what
EASA don't seem to like).

Change the Restriction from UK Airspace only to Airspace of EASA
members who accept it (not quite getting rid of National differences
but wording can be important)

Maybe nothing should be done until the Single European Sky has been
implemented for a while.
So that what classes of airspace are in use, for what purpose, and hence
what privileges are required, is fully understood.
In this case could a temporary change to FCL.600 be requested?

[stickandrudderman]

It seems to me that nobody had addressed the point that the "S" in "EASA" stands for "Safety" and their first fallback position should be just that. If it improves safety, which it demonstrably does, then they simply shouldn't have the power to remove it let alone make us plead to keep it.

[Johnm]

EASA has an objective to achieve a high uniform level of safety across the EU. Unfortunately it is staffed largely by bureaucrats who know little of aviation or by ex engineering QA folks from the airlines.

They believe that as long as the paperwork is uniform and consistent their goal will automatically be achieved.

Yes you know that's nonsense and I know that's nonsense but anyone who has met a ISO 9000 or health and safety consultant will have seen the syndrome and Cologne is staffed almost entirely by such folks as far as I can make out.

[soaringhigh650]

The IMC rating is just an IR with 15 hours of the training.

[RedKnight]

Does the AOPA statement effectively suggest that the IMCR will be unavailable after April 2014 to new/unrated pilots? And that anyone who wants to obtain an IMCR for all practical purposes (i.e. such that it is valid on EASA aircraft and for EASA licensees) needs to obtain the rating before that date?

[S-Works]

At this moment in time yes.

So anyone wanting this valuable privilege needs to get cracking and trained. I am taking bookings....

[Whopity]

it seems all hopes of saving it for the future is based on amending FCL.600
to allow for National differences to continue.

This is by far the simplest way of dealing with the bureaucracy and only requires the addition of one line of text into the regulation. It was there in JAR-FCL 1 so could easily have been copied.

EASA has an objective to achieve a high uniform level of safety across the EU.

Think about it - "Uniform" determines the Lowest Common Denominator - the bottom line, not a high standard!

the "S" in "EASA" stands for "Safety"

Looking through the English dictionary the word "Shyster" seems more applicable in the EASA context

[Sillert,V.I.]

Originally Posted by soaringhigh650

The IMC rating is just an IR with 15 hours of the training.

The way I see it, an IMC rating gives you enough training & experience to fly under IFR without killing yourself; an IR rating gives you enough training & experience to fly in Class A without inconveniencing other users of that airspace.

IMO there should be a way for experienced IMC holders to obtain some credit for experience gained flying in real-world instrument weather towards a full IR rating, providing of course their instrument flying is of a sufficiently high standard to pass the requisite flight test.

[Whopity]

IMO there should be a way for experienced IMC holders to obtain some credit for experience gained flying in real-world instrument weather towards a full IR rating,

This is included in the NPA covering the Competence based IR which is likely to go ahead.

[BEagle]

The so-called 'AOPA statement' was in fact cut and pasted from an e-mail I sent to a fellow director - without my knowledge.

However, since it simply summarises the current situation, I'm not particularly bothered.

The reason I first drafted the FCL.600(b) amendment proposal is that it would not be UK-specific. It would also enable other Member States to meet their national needs - for example, why should a Frenchman flying a French aircraft from one small French aerodrome to another be required to communicate in ICAO Level 6 English when flying IFR? Curiously, the EIR doesn't include such a requirement... Also, it would mean that gliderists could develop suitable ratings which would allow them to be towed up to cloudbase at high elevation aerodromes without the tug pilot needing to hold an IR or the glider pilot a SCR.

But it would also secure post-Apr 2014 initial issues of the IR(R) for those who have never held IMCR privileges, of course....

[Jonty]

Having done a PPL with IMC rating many years ago, I personally feel that the IMC rating should be replaced with a full instrument rating.

However, I also feel that the PPL should contain more instrument flying in the syllabus.

[Sillert,V.I.]

Originally Posted by Jonty

Having done a PPL with IMC rating many years ago, I personally feel that the IMC rating should be replaced with a full instrument rating.

However, I also feel that the PPL should contain more instrument flying in the syllabus.

I'd agree that PPL's would likely be safer if they had better instrument flying skills, but without the opportunity to practice, it's not so easy to keep those skills current. The IMCr gives you enough training to be able to safely practice solo instrument flying and to build confidence in your own time. Without the ability to (legally) fly in real IMC, any skills learnt during ab-initio training will fade with time & that all-important confidence needed to maintain control after losing visual reference will be lost.

There are still too many accidents resulting from loss of control after inadvertent entry into cloud - most could have been prevented if the pilots concerned had just kept flying the aeroplane, but when the crunch came, they lacked either the skill or the confidence to do so.

The step from PPL to full IR is just too big for the majority of recreational pilots.

[CaptainChairborne]

However, I also feel that the PPL should contain more instrument flying in the syllabus.

The price of avgas has gone through the roof, airspace in the UK gets more and more complicated, the number of exams has gone from six to seven and will soon be nine, the minimum time to get a PPL used to be forty hours, now it is forty five. There is a correlation between these disincentives and the falling number of people getting and keeping a PPL. GA is in big trouble, making it even more onerous is not going to help

Reducing the number of accidents by making it harder to fly isn't really an answer. China and Japan have very low numbers of GA accidents, mainly because they have no GA

There are still too many accidents resulting from loss of control after inadvertent entry into cloud - most could have been prevented if the pilots concerned had just kept flying the aeroplane, but when the crunch came, they lacked either the skill or the confidence to do so.

I agree, but all those pilots had passed the Human Factors/Flight Safety Exam. They had done a minimal amount of instrument flying during their PPL course and had demonstrated to an examiner that they could do a rate one turn to get out of cloud. You can only go so far in protecting people from themselves

[tmmorris]

The step from PPL to full IR is just too big for the majority of recreational pilots.

Do you mean the step in skills, or the step in training time and costs?

I think the latter is more of a problem than the former; but the biggest issue is currency. For many pilots it is expensive/impractical to maintain even FAA IR levels of currency (one IAP per month). I am in the lucky situation of being based at an airfield with an ILS and even I struggle to fit in the one approach per month (which I aim for as an IMCR holder as this seems a sensible approach - with a personal minimum of 500ft precision/600ft non-precision but on the understanding this is voluntary and not mandatory - an argument for another time :-) )

Tim

[Sillert,V.I.]

Originally Posted by tmmorris

Do you mean the step in skills, or the step in training time and costs?

Training time and costs. Skills can be built with experience.

I'd agree with your comment about lack of opportunity to practice IAP's in the UK - but there are usually plenty of opportunities to fly in real weather enroute, and keeping your IMC handling skills current will go a long way to keeping you safe when you really need to use them in anger.

[Fuji Abound]

I have found concern when people belittle the IMC rating.

It is true that in the past the standard to which it has been taught has been variable. However it is equally true that there are many IMC holders that fly to every bit as a high or higher standard than IR holders.

In reality there are very few GA pilots that want to operate into and out of airports used by commercial traffic - if for no other reason than the cost. When it comes to en route flying very very few have the capability to operate in anything other than the very base of the airways. In consequence there is very little interaction between CAT and GA, and no evidence that the IMC rating is more generally unsafe. As it is it gives access to class D and, in my experience at least, I see just as many private IR holders struggling in class D as IMCr holders, and fortunately not many of either rating.

In many ways it is an IR without the overhead of irrelevant exams and a bloated training regime, moreover, proof, if any were required, that most of the theoretical training involved with an IR is an exercise in funding the training industry and little else. I know, I hear you say proof, if any more proof were required that a FAA IR fits the bill for private pilots.

Whatever will happen will happen. In a theoretical world I would add another 10 hours to the practical component of the IMCr, leave the current restrictions in place on runway visibility, and restrict the privileges such that they could only be exercised in aircraft falling below en route charges. I would then call the rating an EIR.

I think you would find that approach would save many more lives that outlawing the IMCr and replacing it with the EIR or IR, neither of which will enjoy any greater up take than has historically proved to be the case.

At the moment we seem to be planning to increase deaths, not reduce them.

[Whopity]

However, I also feel that the PPL should contain more instrument flying in the syllabus.

The UK PPL did include 4 hours which was reduced to a single lesson under the JAA. One of the problems associated with doing more IF is that it can instill a false sense of confidence in some pilots and instead of getting out of IMC conditions will actually carry on. A little knowledge can be a dangerous thing.

[Level Attitude]

why should a Frenchman flying a French aircraft from one small French aerodrome to
another be required to communicate in ICAO Level 6 English when flying IFR?

Just for flying IFR in VMC I would agree, but in IMC talking to an ATC Service I would
prefer a common language is used.

Curiously, the EIR doesn't include such a requirement...

Not so curious:
The EIR specifically excludes Instrument Approaches (except in an emergency).
IAs require comms with ATC - hence everyone listening on the same frequency should
(in my opinion) be able to understand what everyone else says.

[Level Attitude]

The IMC rating is just an IR with 15 hours of the training.

I believe it is statements such as this that got EASA all worked up
over the IMC in the first place - and it is not correct.

One specific example: The IMC is restricted to UK airspace whose
Airways are all (I think) Class A and an IMC Rating does not give the
privilege of IFR flight in Class A - therefore the IMC Rating does not allow
flight in Airways.

[bookworm]

The step from PPL [in training time and costs] to full IR is just too big for the majority of recreational pilots.

Is that not the issue to address then? I don't hear US pilots clamouring for an IMC rating (though I believe that AOPA is considering a no-privileges version of the IMC rating training course as a ‘VFR into IMC’ course). The difference seems to be that while you can do your IMC rating at a local flying club, the IR requires school that is usually focused on commercial pilot training (£££), and a set of exams at Gatwick.

The CBM-IR proposed by FCL.008 goes some way towards addressing that, but not far enough. We need to keep the pressure up on EASA to make sure the requirements for training organisations (including those that train for the IR) are proportionate and suitable for schools that serve the needs of GA pilots, not just airline-pilot factories. While the IR might need more hours than the IMC rating, the key to its take-up is to make it as easy to go to a school and say "I want to do an IR" as it now is to go to a school and say "I want to do an IMC rating".