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-   -   IMC proposal (https://www.pprune.org/private-flying/390826-imc-proposal.html)

wsmempson 1st Oct 2009 19:33

IMC proposal
 
Do I hear on the grapevine (and the F***r forum) that there is a concrete proposal from the EASA working group concerning the IMCR for europe? An enroute rating which requires VFR when you depart and land....?:rolleyes:

BEagle 1st Oct 2009 19:46

Some members of the FCL.008 group have indeed proposed such a lunatic chocolate teapot rating....

Nothing like the tried and tested UK IMCR! It would require the same theoretical knowledge requirements as the PPL / IR, yet would include no instrument approach privileges whatsoever.

Pace 1st Oct 2009 19:46

We did this one a few weeks back. The idea did not go down to well amongst the save the IMCR brigade (may I add justifiably so)although sadly its exactly what I personally was fearing would come out of EASA.

Do a search and you will find a lot on the subject already discussed.

Pace

IO540 1st Oct 2009 20:54


It would require the same theoretical knowledge requirements as the PPL / IR
I don't think that is at all the case, Beagle. It may be worth reviewing the proposal, as published in e.g. Flight Training News some months ago.

I am in two minds about this thing.

On the basis that an extra privilege is always a good thing, this would be a fantastic thing for European private pilots.

The catch for UK pilots is that one could not fly approaches with it, which represents a significant loss of privileges. The other catch is that while UK's "liberal" VFR departure arrangements (anything above OVC002 is OK) VFR departures are not possible from Class D airports in lower than about OVC012-015.

IMHO there needs to be a basic IAP say an ILS... tricky.

flybymike 2nd Oct 2009 00:08

Class D VFR departure minima are 1500 feet broken or overcast and 5k Vis.
Special VFR departures require minimum 10k ( without an IR/IMC rating)

Thus, 1501 feet and 5.1k means no problem. 1499 feet and 9.9k means no go.

Perverse but that's UK air law for you....:rolleyes:

BEagle 2nd Oct 2009 03:22

IO540, the proposer of the absurd chocolate teapot rating stated:


I came up with the concept of an En-route Instrument Rating. This would allow access to all classes of airspace in line with the EASA principal that license privileges should not be defined by airspace class.
The associated weather limitations would be such as to make it almost certain that a departure and arrival could be conducted under VFR. The course for this would be similar in length to the IMC, about 15 hours, part of which would be conducted in an ATO. The TK test would be the same as for the IR. It was not felt that the lesser TK was warranted given the cost and the fact the EIR holders would be sharing complex airspace.
My bold lettering for emphasis. 'TK' means theoretical knowledge.

'Almost certain that a departure and arrival could be conducted under VFR' is wholly unacceptable. I invite the originator of this nonsense to define, to the satisfaction of any legel weasel, what is meant by 'almost certain'....:hmm:

The entire EIR concept is ridiculous - fortunately opposition to the idea is growing, both nationally and internationally.

The Visual Flight Rules require the following limits inside controlled airspace:


Flight within controlled airspace
27.—(1) Subject to paragraph (4), an aircraft flying within Class B airspace—
(a) at or above flight level 100 shall remain clear of cloud and in a flight visibility of at least 8 km; and
(b) below flight level 100 shall remain clear of cloud and in a flight visibility of at least 5 km.
(2) Subject to paragraphs (3) and (4), an aircraft flying within Class C, Class D or Class E airspace—
(a) at or above flight level 100 shall remain at least 1,500 metres horizontally and 1,000 feet vertically away from cloud and in a flight visibility of at least 8 km;
(b) below flight level 100 shall remain at least 1,500 metres horizontally and 1,000 feet vertically away from cloud and in a flight visibility of at least 5 km.
(3) An aircraft shall be deemed to have complied with paragraph (2)(b) if—
(a) the aircraft is not a helicopter and it—
(i) flies at or below 3,000 feet above mean sea level;
(ii) flies at a speed which, according to its airspeed indicator, is 140 knots or less; and
(iii) remains clear of cloud, with the surface in sight and in a flight visibility of at least 5 km; or
(b) the aircraft is a helicopter and it—
(i) flies at or below 3,000 feet above mean sea level; and
(ii) remains clear of cloud, with the surface in sight and in a flight visibility of at least 1,500 metres.
(4) Paragraphs (1) and (2) shall not apply to a helicopter that is air-taxiing or conducting manoeuvres in accordance with rule 6(i).
Note in particular the provisions of 3(a)(iii). The average spamcan driver only needs to be clear of cloud and in sight of the surface under VFR in a Class D CTR but must have 5km in-flight visibility.

Pace 2nd Oct 2009 09:39


'Almost certain that a departure and arrival could be conducted under VFR' is wholly unacceptable. I invite the originator of this nonsense to define, to the satisfaction of any legel weasel, what is meant by 'almost certain'....
Beagle

Almost certain I would guess would be based on the fact that your departure must be in VFR conditions plus a margin to return in VFR conditions.
This would all be based around actuals and TAFS.

Your arrival would have to be forecast as VFR Conditions in the TAFS as would your diversion airfield plus the relevant time margins to remain that way.

The reference to "Almost certain" is simply that nothing to do with weather is ever certain.

My guess is that this would be based around actuals and TAFS which could easely be placed in a legal form.

I could see them concocting a special emergency for the rating where if the almost certain failed to materialise you would be radar vectored onto an ILS and airfield where there were high minima. You would be a special case and treated that way.

For me the stupidity of all this is the fact that you will have to do all the IR studies and exams. This is the very thing that has put working pilots off a european IR.

The flight test is a piece of cake but months and months if not years of ground studies dealing with irrelevant material is the main reason pilots run off to the FAA IR instead.

Pace

IO540 2nd Oct 2009 10:17

Yes, the weather would have to be by the TAFs - a bit like the FAA 1/2/3 rule for having to have a planned alternate when IFR.

Re the TK requirement - this statement refers NOT to the present 9-exam (PPL/IR) TK but a supposedly much reduced version, appropriate to private IFR flight. Obviously I agree that if the present TK was involved then the whole scheme would be just plain silly - you may as well get the full IR :)

A remaining thing I don't like is that this proposed rating will still have to be taught by professional FTOs, not by your old PPL school. This is a MAJOR issue, as IMHO the majority of UK PPLs are not within practical driving range of a commercial pilot FTO for doing a flight the same day. And if you introduce hotel residence then the whole thing becomes highly unattractive. You may as well take a cheap flight down to say Greece and do the full IR down there. A huge reason why the FAA IR has such a penetration among US pilots is that they can do it as a natural continuation of their training.

On the plus side, when I look back on my long VFR (pre-IR) trips across Europe, some of which had ~ 700nm legs out of the UK, most of them could have been done under this proposed IFR rating, and they would have benefited hugely from the enroute IFR clearance. Only on one or two did the IMC-R (which I also had) get used to get back in.

Overall, I am in two minds about what to think about this. I do think an ILS should be a part of it, otherwise how the hell do you deal with the case of a really duff TAF? I believe the Australian one has an SRA in the basic module, but SRAs are apparently extremely rare in Europe (I don't recall seeing one). One can always get vectors down to the MVA but usually the MVA is way above the VFR minima...

TWR 2nd Oct 2009 10:54

I have the impression that there are a lot of misunderstandings about the current theoretical IR(A) requirements. You have to take 7 written exams. For these to pass you need the ATPL books.

But you only need to know certain parts of these books. Every time you come across a topic that has "commercial jet operations" written all over it you'll see in the notes provided by EASA that this topic is outside the scope for PPL/IR. Even for the much feared meteo exam.

I did the course in distance learning and it costed me 2 half-days at the FTO for evaluation. Luckily I knew the material and I didn't need extra tutoring. But the important thing is I did it at home, in my own time. I passed the exams at the first attempt. I can't say I really needed to study things I found irrelevant. OK, maybe the license-requirements-bit in "Law".

In my opinion the theoretical exams are hugely over-estimated. It is still a lot to learn,
but how you do it is totally up to you.

Pace 2nd Oct 2009 11:09

10540

The stupidity is that regardless of approaches you will have to be trained to fly on instruments for letting down through cloud. Flying in CAS will also mean flying to IFR tolerances so a stronger instrument training than at present.

Not seeing the ground will mean you will have to navigate using nav aids, airways points etc. In case the whole lot goes pear shaped you will still have to be trained on instrument landing procedures in case of an emergency.
So????

I must admit I never like the idea of transitioning from IFR to VFR. That is a known risk area.

I was never for saving the IMCR for just the reasons portrayed and have had many arguements here for my views. I always feared you would end up with a gesture IMCR and having made that gesture a way out for EASA ever having to make a proper achievable PPL IR.

As is said " Be careful what you wish for".

Pace

Pace 2nd Oct 2009 11:14

TWR

Be honest how long did the distance learning take 2 weeks??? I know people who have tried the whole ATP and are still at it after 18 months.

I also know a very experienced jet pilot on an FAA ATP who gave up with lack of time and motivation. He started off well then work and family problems meant he shelved the lot.

I also ask if that is the case how do you explain so many going the FAA IR way instead?

Pace

Captain Stable 2nd Oct 2009 11:21


The reference to "Almost certain" is simply that nothing to do with weather is ever certain.
And then we get to the difficult bit.

The weather during Mr. EIR's flight was pretty much as forecast. However, at his destination and for any airport within distance of the fuel he has remaining, the weather is OVC008.

Mr. EIR departed in all good faith having checked TAFs and METARs, but the weather stubbornly refused to co-operate and the front did not clear. He has not been trained to fly an instrument approach, and may not legally fly one. His aircraft is suitably equipped, having ILS, ADF, DME, Pitot heat etc.

But he hasn't been trained.

In 30 minutes or so his situation will rapidly become an emergency due to low fuel.

So, in order to save his life, he has (a) to break the law and fly outside the privileges of his licence and (b) fly a procedure for which he has received absolutely no training whatsoever. If he screws up the approach and has to go around, he will be straight back into the murk, already stressed and worried, will have to transfer back to instruments.

You estimate - what are his likely chances of survival?

Speaking for myself, I would far prefer him to be IMC rated. Otherwise we are sacrificing his life for bureaucracy.

Pace 2nd Oct 2009 11:29

Captain Stable

Good points but there is another! He may take off VFR in good weather. He may have brilliant weather at his destination but enroute on top of an overcast he develops a problem! he needs to land! he checks the weather at the airfields near him! Overcast 200 600 metres vis what does he do?

Pace

TWR 2nd Oct 2009 11:37


Be honest how long did the distance learning take 2 weeks???

It took me 4 months of daily study, combined with a full time job to be ready for the exams. Since it is my hobby and the books were fluently written, motivation was no factor.

I too know people who have tried the ATPL and they succeeded. Even after 18 months. That is a matter of personality and is true for whatever studies you take up.

Pace 2nd Oct 2009 11:58


It took me 4 months of daily study, combined with a full time job to be ready for the exams. Since it is my hobby and the books were fluently written, motivation was no factor.

I too know people who have tried the ATPL and they succeeded. Even after 18 months. That is a matter of personality and is true for whatever studies you take up.
TWR

Well done but your last statement about personality says it all. You have to be the type who will dedicate a block of time every day to the studies and we are not all like that. Working people with families also have priority commitments attached to their work or families which puts a ? over dedicating a block of time every day.

You could argue and his has been tried that all that study makes for better IR pilots. That has been proved to NOT be the case much to the dismay of EASA as in a major study the EASA and FAA pilots were compared with neither being safer than the other. The conclusion was that the training was different but the end result the same.

Pace

TWR 2nd Oct 2009 12:18

Being a safer (= better ?) pilot has more to do with currency and skills than with theoretical knowledge. I'm happy with the "story behind things" I got during the study.

But it's a choice you as an individual make. I think there is a big difference in saying that the EASA IR reqs are waaaay over the top for a PPL/IR and the fact that some people prefer a "need to know"-course and spend their time rather on practice than on study.

But it's true that I can't tell the difference in reality between FAA and EASA-rated pilots.

Pace 2nd Oct 2009 12:34

TWR

The difference is maybe that in Europe the emphasis is more towards career flying while in the USA GA has always been far more prominant.

Many areas of Europe have had negligable GA and the politics are not motivated towards rich men and their toys as many would see it.

Like any professional Career whether its being a doctor vet etc there should be some sort of university degree and in some ways the ground studies appear to be an attempt at creating a quasi university degree in flying for professional pilots.

Where does that leave the PPL in Europe? I am afraid the PPL in Europe doesnt really figure much in the equation and is eyed as the lowest of the low and that probably poses the biggest problem of all.

Pace

Shunter 2nd Oct 2009 12:46

The problem with the theory is that most of it is gash, and completely irrelevant to GA pilots. 90% of it gets core-dumped as soon as the exams are over. The only bits I really remembered were from the Met exam.

You CAN'T do this with the FAA IR, as you get a VERY severe oral grilling before you even get into the aircraft to do your flight test. No such grilling is undertaken in Euroland.

TWR 2nd Oct 2009 12:54

That is where you an I differ in opinion. Year after year EASA revises the theoretical requirements (read; reduces the topics to be known for the exams) in a more or less logical manner. The days one had to study worldwide climatology and INS etc etc are gone. And the actual questions are no brain-teasers neither.


It is nowhere near a university level (even for the ATPL). That was different in the pre-JAA days, when you were required to be able to design you own jet-engined aircraft with astronavigation tools and such. At least it was in Belgium...

Instead of criticizing EASA for what the IR could be (FAA alike) I'd like to congratulate them (already) with the job they've done over the years. My impression is that from time to time they tend to be open for improvement.

Pace 2nd Oct 2009 13:15

TWR

If that is the case they should design a course which you attend full time for 2 weeks. At the end you come out with all the exams signed sealed and delivered. Another 2 weeks if you want ie a month in total you come out with all the ATP exams completed and signed off.

That scenario is perfectly achievable with the same quality of PPL/IR or ATP.
When EASA do that? :D

Then the working man can take two weeks off and the ground studies are done and dusted for his PPL IR :)

Pace


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