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

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?

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.

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.

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

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?

At this moment in time yes.

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

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

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

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.

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

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....;)

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.

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

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

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

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.

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.

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.

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.

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.

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.

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".

Bookie - exactly.

Without meaning to be pedantic I would only quibble with the word "easy". I know what you mean but it may send the wrong message.

The key is exactly as you write - easy to do from the standpoint of schooling being supplied at a point convenient to the average PPL who has a day job and four weeks holiday a year. Inevitably a PPL IR is not "easy" and it shouldn't be - but the training should be totally relevant with as much emphasis as possible on practical training and much less emphasis on unnecessary and bloated theory the majority of which is simply irrelevant to the needs of a PPL IR holder.

I agree with Bookworm. The FAA IR is every bit as good as a JAA IR But if you offered the IMCR as a sub FAA IR to the Americans no body would bother with it.
Why because the FAA IR is designed to achieve a standard which is sensible, cost effective and does not require months of study.
This is what I hope EASA are doing and will continue to do up until the real date of 2016 not 2014.
By september november they should have completed their study of the FAA system and JAA system to complete their ideas on PPL FCL before moving onto a similar study on commercial licences but the driving force is to simplify not complicate.

Pace

The more I think about it the more I wonder whether we need a more clearly defined separation between private and commercial pilots? The training world (beyond the PPL) is controlled by relatively few commercial operators who doubtless exercise considerable influence throughout Europe. They clearly have vested interests and the last thing they want is a "simpler" IR. However the number of private pilots they tutor is miniscule. We all know how few private pilots in Europe have an EASA IR. They would not be bothered to loose the few private pilots that past through the system each year

We accept a PRIVATE pilots license and we dont restrict how a pilot with a PPL shall operate - VFR into the largest hubs is entirely acceptable. Flying IFR is no more difficult with the correct tuition, and it seems logical that an IR attached to a PRIVATE license should be a PRIVATE IR. With that distinction it would enable the rating to be far better designed around the needs of the private pilot without compromising safety.

It is not on the road map, and its not going to happen, but fun to muse.

The risk with that, which I believe is real in Europe's highly politicised aviation regulation / ATC union / airline pilot union dominated climate, is that that would result in "private IR" holders being excluded from a lot of airspace or airports.

They are already excluded (by pricing) from many airports which are not busy, just for the manager's laugh, and airspace issues would be a disaster.

If it wasn't for ICAO, GA would be dead in nearly all of the world including most of the "civilised" world, except a few countries which have a long history of private flying (USA, UK, Germany, France basically). We must stick to ICAO licenses and ratings, or face extinction of GA and especially IFR GA.

I am not convinced for the reasons given.

I see no reason why the private IR couldn't be an ICAO license - after all the FA IR is ICAO compliant without the bloated theory content.

Moreover as I said earlier the PPL is ICAO compliant BUT is a private license without commercial privileges.

If airports want to exclude private flights they will do so anyway - either using pricing or as we are seeing in Belgium - other means. Realistically how many private light singles or twins go into Gatwick at the moment and for how long has this been the case?

No, I don't think yours is a reason for not developing a private rating, but, as I said earlier, this is all dream world, its not about to happen so what I think is irrelevant in the big scheme of things.

The problem might/will be 'who is qualified to teach', as debated in other Threads by the flying instructors and examiners?

Even if the proposals you suggest were viable, the provision of instructors to teach the IR are not it seems.

The question might not be 'I want to do an IR', but 'do you have any instructors to teach an IR'?

KR

FOK :)

You might envisage that. However, it doesn't tally with the fact that FCL.008 was chaired by the IAAPS nominee, and that the training industry has been extremely supportive of the CBM-IR. Thus I suggest we cross that particular bridge when we come to it.

Yes. All that's needed is to make the existing European IR suited to its purpose, private or commercial. Obviously at the moment its too complicated and has a great deal of content that's irrelevant for both. Then air transport pilots get (oddly enough ;)) an ATP. There is no logical linkage for licensing between meteorological conditions during the flight and whether the pilot is being paid or not.

Some guys in the hangar next to mine share a 182 and are all getting their FAA instrument ratings. Their instructor is an AA check pilot and its great for me too - I get a smattering of free ground instruction from being in the hangar next door!

.

Why not? Surely if there was a simpler IR and I presume we are talking about the extensive ground exams then there would be a much higher demand for training rather than the few sponsored by mum and dad into a career in aviation!
Making the process more streamlined and as you put it "simpler" while achieving the same end result will mean that the training industry will have far higher influx of students both commercial and private into the training industry.

There was an extensive study carried out between FAA trained ATPs and JAA trained ATPs the conclusion was while both took different routes to the qualification they both achieved the same quality of pilot at the end of the process.
Complex does not mean better nor does it mean more trade for the training industry! I would suggest the opposite is the case.

Hence the present study of the two systems to see where there is common ground and where simplification can be achieved without loss of safety.

Pace

Bookworm

I dont understand your point.

I know you will be aware of the proposed CBM-IR fees - why wouldn't the training industry lap up these proposals. I know you will also know the cost of the FAA IR theory. There is no proven case that the theoretical content for private pilots is necessary or justified and the bloated costs add insult to injury. It is unjustified day light robbery. I wouldnt mind if it could be justified on safety grounds.

It is equally unjustified daylight robbery for any pilot, no? The relatively simple, attainable-for-all FAA instrument rating does not distinguish between private and commercial pilots for instrument rating... because the distinction makes no sense.

Yet another stratification of the irrational and over-complex does not seem like any kind of solution - it actually reinforces the problem.

Thread Drift
 

I do not care whether the IMC survives, or not, in it's exact current form.
But I do want a Rating that gives essentially the same privileges, for about
the same amount of training and will be valid for longer than 1 year.

Responses to my original Post started with knocking EASA (understandable,
but not helpful) and seem to have moved on to a discussion on how to make
an IR easier to obtain (discussions which, unlike for the IMC, are not time critical).

If we end up losing the IMC then, at least, I would like to ensure that
all ideas/avenues/approaches had been tried.

We should never assume that "the great and the good" have already
thought of everything. I note that BEagle states he is a director of AOPA,
so any ideas, that might just tip the balance, would be seen if posted here.

So far only Fuji (Post 16) has suggested anything, unfortunately his suggestion
is very much like the idea for an "Instrument Weather Rating" of a couple of
years ago - rejected because it gave full IR privileges on a sub-ICAO IR.

People must have some other ideas, suggestions.................

Thank you - but I don't support the idea of a sub ICAO IR, nor did I say otherwise.

That said even ICAO is not quite what it seems - have a look at the various ICAO licenses for which exemptions have been filed - they are ICAO licenses, well to all intense purposes, or are they?

The variation I proposes was to distinguish between a commercial rating and a private rating in much the same way the distinction exists between a private pilot's license and a commercial pilot's license - both ICAO licenses. The private IR would, as Bookworm suggests, create a license designed to meet the training needs of a pilot unable to fund the cost of a commercial license or the additional time to learn a deal of theory that is irrelevant to private operations. The license would never the less be ICAO compliant.

Lest we forget over 50% of private pilots in the US have an IR, less than 5% of EASA private pilots have an IR. The goal should be to achieve at least the same percentage of IR rated pilots in Europe because we know it makes for safer pilots. There is nothing in the current proposals likely to achieve this. If the IMCr is lost in the UK it will only make matters worse.

If I had just one wish, it would be that the bureaucrats learn the lessons of history; if the IR embodies bloated theoretical content that is both costly and impractically difficult to access and if the training is not widely available then the up take will be almost zero.

Hence why the training industry should welcome simplification to encourage more students commercial or private through their doors.
It is not just Private pilots who are scarce taking up full IRs but also would be commercial pilots who unless funded by wealthy parents struggle to raise the £60K plus needed!
a few years ago in these forums I was against trying to preserve the IMCR and for putting all our efforts into Getting EASA to create an FAA like IR rating.
I really hope that the information being bled to me is accurate that EASA are indeed looking at both FAA and JAA and trying to find common ground with the idea of simplification and unification of FAA and EASA where safety allows and this is not yet another trick of hand for a more sinister motive.

Pace

Pace - yes but a few training organisations have a strangle hold on the IR at the moment, and guess what, as Bookworm indicated earlier, those few are far more influential than your and my local FBO.

Commercially the last thing that is wanted is a cheaper IR or for that matter any form of cheaper commercial license training. That is fair enough - it may be wrong, but it is not an issue for this forum, which after all is concerned with private pilots.

As I said earlier, in my theoretical world there would have been a chance of distinguishing between commercial and private licenses because, I suspect, the commercial organisations wouldn't see the loss of the private punters a significant enough issue.

It is the art of the possible, and I feel their were opportunities, but they haven't been taken.

Fuji

But these larger training organisations already subcontract out to the USA for a large portion of the flight training because its a lot cheaper there than here!
Second does it make more business sense to sell a lot at a cheaper price or a little at a large price?
Any supermarket will give the answer to that
Looking at 50% of PPLs with IRs in the USA compared to 5% in Europe gives a huge potential market for selling simpler IRs to European pilots to these training organisations.
I would think that any training organisations with half a brain would encourage a simpler cheaper option???

Pace

And any craftsman or self-employed instructor will give a very different answer from the supermarkets.

Hence why craftsmen are a dying breed working niche markets and instructors do not make money.
Went into a furniture store beautiful oak all made by machine and computers for the mass market but very passable.

Pace

Pace

There arent a lot of trainee pilots to go around. Super markets sell a lot cheap because we cant control either ourselves or our stomachs so we produce more people with ever larger stomachs and the supermarkets are happy.

The airlines control the supply and demand for pilots. There are a roughly fixed numbers of commercial students each year. Making it cheaper / easier will only create more unemployed pilots. There is nothing in your model for commercial fly training setups so they neither want to make "their" product cheaper or easier. In fact more expensive would suite them.

Of course i dont dispute the airlines would like cheap pilots, but the beaucrats arent about to slow down the gravy train because they have their own vested interest.

No but the chink in the armour is the private pilot. Lets face it other than the fbos everyone sees them as a bit of a nuisance, the sort that dont fit the model. Too be fair they dont fit the model and that is why their needs should be provided for in another way.

Fuji

We could go into a long political discussion on why the USA has always been pro GA while Europe NOT!

The USA because there was often hundreds of miles between cities and GA offered a cost effective means of travel.

Europe is fairly new! a mix of individual countries many from left wing backgrounds with little or no GA preferring to keep their citizens in people carriers!

All air travel confined to state controlled carriers and not to individuals with money to buy such aircraft or move freely in our skies.
Hopefully GA will increasingly be seen as a viable business tool

Pace