.. .. .. and at what height were you visual?

I wasn't. IR Renewal. Go figure.

So lets see not visual at DH lets say 250, sys asy, go around initiated, IMCr, with ME simulated asy not visual on a NDB DME with go around intiated at 750and the difference is?

Actually I withdraw that - I agreed not to get into this debate and I know where it is going.

I agree the IR sets a different standard.

Lets leave it at that.

Deciphering that the best I can, the answer is 500 feet and over a minute assuming a standard ROD.

IR renewal to answer your previous question: No "visual" as it was screens up, not some silly "foggles" - does that help?

Oh goodness - why.

What the hell just this once. I promise it really is the last.

.. .. .. and the FAA IR who does 6 approaches in six months.

Oh I know, that is a part 38 sub ICAO IR so it doesnt count, but the 25 month compulsory renewal with an asy go around is a sub sub not even ICAO rating so it counts even less. :}.

So lets see, one does it to 200 feet (without silly foggels I have noted), one doesnt do it at all perhaps for years, and one does it every 25 months (with sill foggles I have noted) 500 feet higher.

So the examiner passes the first, never meets the second, and even though the third nearly kills him, also gives him a pass.

Yep, I have got it now.

Some simple concepts about minima and what is legal.

An IMC is not type specific, and can be obtained in a non-complex SEP.

It can also be renewed in a non-complex SEP once every 25 months irrespective of whether it is used in a MEP/SEP/SET whatever.

Notwithstanding that, you could legally fly a complex MEP (if you are so rated) in IMC to the same IMC-rated minima - which on any other day you would argue is the same minima as an IR holder (albeit with 1800m met viz in lieu 800m RVR)

There is no requirement to ever learn, practise or be tested on assymetric IMC flight as an IMC holder: Not once every 25 months, not ever.

That ain't right and won't ever be accepted by EASA - deal with it. :8

Now if you want to start discussing why a (non-ATP) FAA IR is worth an IMC rating and not an IR that's another thread for another day. :D:p

I think you have just totally missed the point. Go figure.

The concept of what is legal and what is safe diverging is not something new in aviation and is certainly not confined to the IMC rating. Debate about the legality of twins in IMC etc does not make the concept of the rating flawed and need not form part of what we are trying to 'sell' to Europe.

All this talk about what idiots in planes could do seems slightly pointless considering that no one seems to have ever had an accident trying to do them. OK someone might do something stupid in future....but that is will be because he displayed poor judgement and not because the IMC rating is wrong.

Is that a researched fact or a "Fuji fact"?

I believe you are wrong, and no: I am not doing all your homework for you :8

No, I read in Pilot:

'there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record'

So it would appear that even though there is scope within the IMC rating for foolish yet legal behaviour thankfully no one has yet come to grief exploring it.

Ah so you read it in a magazine so it must be true? Go and have a look at the AIB reports and then come back to us with an assessment. Maybe even have a look for some famous cases?


And the point is?

rustle said:
Actually, it's an "AOPA fact"... see pages 4 and 6 of the December 07 issue of General Aviation!

Any prospect that the juvenile point scoring can cease? Nah, I thought not! This really has turned into a "size of willy" debate.

Pity.

Yes it really has.

However you are correct in your assessment of the issue I was trying to get at.

The point I was trying to make is that any rating is about drawing lines in the sand.

I might happen to think that an EASA IR who does not fly a single approach in 9 months and then go to minima is a very dangerous pilot. For that reason I might happen to think that an FAA IR holder who regulalry does an approach to self certify currency is a far safer pilot.

I might think that to fly an twin IR then the minima requirment should be a sim check every six months.

I might think that a compulsory revalidation every 25 months for instruments skills and annual revalidation for ME skills and the knowledge that my instrument rating should not be used to fly to anything like minima unless I am very current makes for a safer pilot.

As has been demonstrated you might think because you fly an asy approach to minima behind the screens once a year that must be part of a definitive standard.

The danger is because you have worked so hard to achieve a particular standard you think that is the only standard that should exist and the only way of ever doing it. After you have been doing the job for ten years your thinking often changes.

One point to take away from all of this is that in a number of studies there is good evidence to suggest that the most significant factor in accident occurence is not a pilots motor skills but their over confidence. In an intersting recent study it was consistantly the IRated pilots who were slower to react because they wrongly felt their skills should get them through the problem.

EASA of course has also to draw lines in the sand.

However, I am not aware of ANY evidence to indicate the IMCr is an inherently unsafe rating. Fortunatley whether you are signed up to it or not most agency appreciate they have a responsibility to assess regulatory impact.

EASA may kill of the IMCr as an administrative convenience but that would be a travesity for an agency who has as their primary objective - safety.

Not really, imho.

On countless threads here and elsewhere people have argued that an IMC rating holder is not bound by higher DA/MDA limits than an IR holder.

I have highlighted one thing about an IMC rating that someone from EASA might think is a bit "iffy": That there is no legal requirement for arguably one of the most demanding missed-approach procedures to have been taught, practised or tested.

For my efforts I'm told by FA that I have totally missed the point. :rolleyes:

That isn't "willy waving" on my part.

Bose has asked a few times what, exactly, is being asked for. i.e. which licence do people actually want to attach this "retained IMC-R" onto.

Not had an answer yet, and that isn't "willy waving" on bose's part either.

Are posters really so stupid as to think that myself and/or bose are the only people in Europe who might actually ask any questions and expect something better as an answer than "you have totally missed the point"?

EASA committees will be wetting themselves with laughter if that's the best argument winner put forward.

[In a whiny 12 year old girlie voice] "You have totally missed the point. Go figure." :D

Brilliant.

EASA will probably create two "private" pilots licenses - so the IMCr will have to be attached to one or the other.

I am convinced EASA will take a long hard look at the safety record.

As Islander2 has so well pointed out:

"there has never been a fatal accident resulting from pilots legally using the privileges of the rating in a serviceable aeroplane in UK airspace, a remarkable safety record" (Source AOPA)

I am convinced AOPA will take note of the views expressed by UK pilots and by our Euro MP's - in particular Mr Kirkbride who has already got the Commissioner's attention.

So AOPA are wrong then bose? That's funny.....:E

I try and keep a sense of proportion in all this but it is very difficult. There is clearly a matter of basic principle at work here. There are those (many?) in Europe who see VFR sports flying as essentially incompatible with any formalised IMC qualification below that of an IR. The attitude appears to be that an IR is a professional qualification and amateurs have no business trying to fly IFR under any circumstances – or at least unless they have a £0.5m aircraft which can keep up with the heavy stuff. Hence the reluctance to reduce the theoretical knowledge requirements, for example, so that the IR can be more suited to the private pilot.

On the other hand we now hear a lot about regulatory impact assessment and devolving power down. This latter was a key theme in recent consultations. There appears to be no evidence that the IMCR contributes anything significant in the way of safety concerns. Indeed, you might argue that France, with no IMCR or equivalent has a substantially higher fatality rate because of the lack of any formalised IFR flying that the IMCR provides for; likewise, the US is on a par with the UK (where I believe about 50% of pilots hold the FAA IR, which though not “easier” to obtain in the flying sense is more practical and has a training regime much more accommodating to and less costly for the private pilot who has work and other commitments).

There are huge advantages to the IMCR which have become submerged in theoretical arguments about what the IMCR holder can do as compared to the IR holder. There is no evidence that these concerns have any basis in actual evidence of the way the IMCR operates in practice. Among the benefits are:

• Hugely improved skill at flying in IMC, which I have certainly found of benefit if only during inadvertent flight into IMC;
• The ability to descend through cloud from VMC on top or to gain VMC by ascent through cloud;
• The ability to fly precision and non precision approaches if required if weather at destination is IMC
• Improved VMC minima

These are all definite benefits which contribute to safety. Yes, it might encourage pilots to fly in whether which is too marginal from the start, but there is again no evidence that this happens more frequently with holders of an IMCR than it does with basic PPLs (or NPPLs). In fact the better appreciation of flying in IMC might reduce rather than increase the chances of this happening. Too often the professional “we know best” brigade stamp on proposals which bring genuine safety benefits without any evidence to support their arguments. We see this time and again in aviation. This is a British and European disease. The existence of the IMCR is a beacon in a generally unimaginative regulatory environment.

Going further, the proposal to restrict the rights attaching to foreign based aircraft will strip away the rights of those owners holding an FAA IR to exercise the privileges of that rating by requiring them to place their aircraft on the EASA register. Again, there is no evidence that N registered aircraft in Europe are a safety issue, either because of their maintenance safety record or because of the quality of the IFR flying performed by their pilots.

So, in neither case has any convincing argument been made out, either for excluding an IR from the LASL or for excluding foreign based aircraft. These issues are now (as I under stand it from the recent European Parliament debate) in the political arena and may remain so for some time. They are not a done deal and the carve-up which has already happened behind the scenes and which has resulted in exclusion of any IFR rating from the LASL need not happen. There is a lot of hand wringing on these threads with an “I told you so” approach coupled with the attitude that it is now all a done deal. As far as I can see it is not. If the petition and these threads do any good it will be to on the one hand alert the politicians and on the other to make those in the representative organisations aware that the flying public may not be happy at what is being said, done and agreed to in their name. Certainly, the current perception is that the committees have a cosy agreement to carve it all up and then feed it to the politicians to rubber stamp. It will do none of us any harm if the politicians flex their muscles for a change and show them that they are not just a push over.

safety or practicality
 

Excuse me for a simplistic view but isnt the desired outcome supposed to be that ALL pilots ONLY do what is safe and for the legislators to make sure that what isn't safe is no longer legal?:confused:
And to that end there is an increase in quality of training and a decrease in ambiguity? If that were the case would not the (rest of the ) Europeans increase their levels of training to ours and not for us to lower our STANDARDS to theirs?

TRACK RECORD OF EEC initiatives / policies?

The "European" shambles (read EEC) created the common agricultural policy and common fisheries policy that have disasterous effects financially and environmentally but if they do that with Aviation the end result will cost lives.:ugh:

The problem here is that the rest of Europe seems to be arguing that the IMCR is not conducive to safety - though there is no evidence of this other than to say that applying it to different European airspace structures would reduce safety.

Always be wary of the "safety" argument. Almost any daft bit of regulation can be dressed up as being necessary for "safety" without any evidence that it produces a measurable benefit in exchange for the inevitable increase in costs and the burden or regulation. Witness the JAR, which as compared to the old regulations have produced no measurable increase in safety of flying.

Justiciar, I think your post above of 10:06 is the best summary anybody could manage of the situation.

It isn't a done deal and a lot can still be done at the political level - despite the various vested interests that are trying to screw things from both the sports-VFR and the CAT ends of the flying spectrum.