421C

I started a thread called Scrap the IMCR or something like that arguing the fact that trying to save the IMCR would play right into the hands of EASA with those proposals that is what appears to be happening.

EASA would purely take what is available already in Europe, tinker with it a little and call that the EIMCR but it would not in anyway resemble what we have in the UK in any shape, form, or manner.

The other option in my thread was to make the IR more attainable to the working pilot who doesnt have the time to study for exams for a couple of years in their free time and much of it having little relevance in a practicle sense in flying in the IFR system.

The flying standards should be the same as the full IR but the study time more relaxed and directed at PPL IR flying rather than 747 over the world flying.

We all know the FAA IR is much easier for the time stretched PPL to achieve.

We all know that safety comparisons between EASA and FAA IRs show that neither is better or safer than the other but the EASA variety is more directed to a profession in aviation and on a sort of university study basis.

The big problem with all this is the PPL is given very little importance in the scale of things unlike in the USA. Many European countries had hardly any GA and many were actaully opposed to GA.

The massive costs imposed on aviation by quangos and regulators echoes what happens in European society which is obsessed with the big brother state so we are all on a loosing battle as our freedoms and individuality are eroded day by day :sad:

Pace

The source of the ridiculous 'almost certain' came from the following extract submitted to FCL.008 by one of its UK members, who also admits to proposing the Chocolate Teapot Rating:

Read FTN and/or GA to find out more......

I agree, but the conditions must be such that they can maintain VMC for the entire route including the departure and arrival segements. Whilst many may bend the rules, in new EASA parlance the clouds have to be pretty few and far between to meet the legal requirments. You can forget about departures or descents with broken forecast.

The law aside the more adventurous VMC pilot will successfully dive through the gaps in the clouds to maintain VMC but I dont want pilots doing that in my ATZ thank you.

I fly aeros; when we topple the AI above a broken overcast finding a way down through a small gap is not a problem, but it sure as hell scares many PPLs to death.

As I said earlier the modus operandi of an Instrument Rated pilot is quite different. He is not concerned about flying an approach down to 1,000 feet. He is not interested in dodging between clouds having been flying on instruments for the last hour. In fact the last thing he wants is an unusual attitude.

It is just madness to expect him to dodge the broken bits at 1,000 feet during the arrival segement - indeed a recipe for disaster just so he can claim he was VMC thoughout the approach segement.

In reality I dont believe that whoever dreamed this up has got any concept of real world flying on instruments with the weather we have in Northern Europe.

As to the mountain rating, I agree, teasing aside, I have no objection with the French keeping it.

With friends like that...

Joking aside, I know that's taking your views out of context, but neither an en-route IMC rating with VFR arrival nor an "accessible IR" cuts the mustard.

As lots of us are saying, an "almost certain" VFR arrival is a fantasy.

Equally, an "accessible IR" isn't really accessible to the majority of PPLs unless it's virtually as accessible as the current IMC rating. Most IMC rating holders would probably not use it enough to remain current (=safe) in airways, SIDs, STARs etc. I'm all in favour of making the IR more accessible, but that's not enough.

The IMCR is an en-route IMC qualification but allowing instrument approaches to conservative minima. That's what we need, it almost certainly saves lives, and it's worth fighting for. On safety grounds alone, I really hope our representatives face down any opposition to its retention in the UK.

I agree with you. I think the IMCr works well in the UK and I don't think any EASA qualification will be a direct substitute for it - either an EIR or a more accessible IR. So I hope the UK can find a way to hang on to it because EASA isn't going to accept it and despite the campaign, I don't see the UK leaving the EU over it.

And I am saying that an en-route qualification isn't fantasy. It isn't fantasy because an entire country (Australia) seems to know something you don't. It isn't fantasy because pilots fly VMC on top and arrive VFR. It isn't fantasy because IR and IMCr rated pilots fly enroute IMC today to arrive at VFR-only airports the whole time. How often do they have to divert to their IFR alternate? Rarely. And an EIR holder would need a sufficiently good forecast to turn that rarely into a very rarely indeed; just as, amazingly, VFR pilots manage to fly in marginal VFR and very rarely need an instrument approach.

On the other hand, who cares. No-one is trying to "sell" the EIR to UK IMCr pilots in order to stop them campaigning to save the IMCr. I only hope that campaign's pleas are heard by people more tolerant and broad-minded than the IMCr campaingners themselves.....I still find it ironic that their imaginations can't stretch to en-route IFR but expect others to stretch to understanding why the world's least-demanding IFR qualification (the IMCr), granting the same privileges as the IR for all the most demanding IFR tasks, is a "life-saver" whilst any other proposal is lunacy/fantasy/chocolate teapot/danger/ etc etc.

Keeping the IMCr in the UK is a good thing because it has been shown to work. Not because any other formualtion for any other country is unworkable. The FCL008 initiative for an accessible IR is a potentially great step forward, and the EIR is a further step to make the accessible more accessible - by giving people an interim stage, to learn some basic instrument flight skills and build some experience in undemanding IMC. It is not particularly intended to be a qualification vast numbers of people would want as their end goal. But some may want the ability, on a marginal day, to fly through or in a layer rather than underneath it, when the forecasts suggest this can be done safely. Heaven forbid that some pilots in some countries might have aspirations different from those of UK IMCr holders who want nothing more and nothing less than the IMCr privileges.....

rgds
421C

...and another thing. When is AOPA going to publish its IMCr survey findings? Since Approach privileges are so critical to IMCr holders and En-route IFR privileges on their own are so worthless, no doubt that survey will show most IMCr holders regularly flying instrument approaches in IMC.....let's wait and see....

What they may know but I don't: how do they ensure that there will be a hole in the clouds at their destination? Perhaps that works in Australia, I don't think it would in typical UK weather.
I can speak only for myself, but I always have an alternate with an instrument approach to enable a safe descent through cloud if the cloudbase is below MSA. Either I land at my alternate, or (if the weather is good enough) rely on visual positioning from the instrument approach to the VFR-only destination.
I think that the difference between "rarely" (but I can safely do it) to "very rarely" (because I'm not qualified to do it) is vast.

We're talking PPLs in typical SEPs and UK airspace, cruising between 2000 feet and about FL060. In the UK, if you are IMC (or VMC on top of overcast) at that sort of height then you generally can't say with any certainty that cloud base at your destination will be above MSA.

The thing is: if the cloud base is definitely going to be 2000 feet or more, you don't need en-route IMC as you can fly VFR below. If the forecast cloud base is less than 2000 feet, then there's a significant risk that it may turn out to be less 1000 feet, which makes a descent through IMC without an instrument approach risky.

Clearly we're not going to agree on this, but I don't think an en-route only IMC qualification is any practical use, and worse: it encourages dangerous practices.

Furthermore, you cannot say that something that works in one country (e.g. Australia) will therefore work in the UK, where airspace is different, climate is different, terrain is different etc. etc. To try to extrapolate from one country to another is nonsense.

Fredacheck,

The same way pilots everywhere else in the world do, who fly VFR on top on PPL privileges. They use weather forecasts and weather observation.

I wasn't doing that. I used the Australia example to counter Beagle's instant dismissal of the EIR as a fantasy/chocolate teapot nonsense with the obvious example that a sensible country like Australia (that has much in common with the UK in terms of the culture of regulation and FCL) has found an enroute rating workable. I know Australia is different, but how exactly is it different such that a qualification that works there is utterly unworkable here?

How about when the cloudbase is 2000' for your departure and 2000' for your arrival but is lower somewhere enroute. Is this so amazing a possibilty? Of course not. The longer your trip, the more likely you are to be uncertain about enroute weather, or risk some very marginal scud-running.

The fact you can list some scenarios where it isn't of practical use doesn't mean anything. It's equally easy to list many scenarios where it is sefl-evidently useful, to be effectively a VFR pilot as far as weather forecasts at arrival and departure airports are, but to be an IFR pilot enroute. Everything from the instructor or aerobatic flyer who wants to pop-through a 2000' layer for training through to someone who wants less restriction and less uncertainty flying long VFR trips. No-one is claiming any particular level of "usefullness" for the EIR, certainly not as high a level as an IR or IMCr, merely that it's usefulness is not zero as the "chocolate teapot" camp claim.

Does the Australian "IMCR" not have an SRA as the basic module privilege?

I believe that the proposed "enroute IMCR" would be fine if its first module had an SRA. Otherwise, it doesn't add up to me because in any case where the destination is not VFR (but was forecast such otherwise the flight would have been scrapped) the pilot will have to declare a mayday - but he will not have the skills to fly any IAP. The mayday will legalise the situation but the pilot is likely to get killed if he cannot get down without losing control or whatever.

I think of this stuff in terms of what I would teach someone as the absolutely basic requirement if I cared for them. It would be a "PPL" with an ILS. But I think that is just too radical in this case in which politics is 90%.

I don't know what the big deal is with "approaches". Surely the more dangerous phase is departing INTO IMC?

If they are so keen to limit the EIMCr then limit it to precision approaches - even a well trained monkey could fly an ILS..

421C

You have laboured the "Australian experience" with which you are clearly familiar. I assume you have flown in Australia and are aware how their instrument training works?

Well when this came up before I made it my business to see how the Australian model works.

I wonder whether your experience is the same as mine?

I would be interested to know your thoughts on what GA pilots do in Australia if they want an instrument rating and how many hold a command instrument rating.

It worries me when we refer to other models. It is all well and good if we really understand those models and can point to some sound material on how those models work but I dont see our being pointed in the direction of any substantive studies - infact I dont even see our being pointed in the direction of any studies at all.

Would you like to do so?

You refer to AOPA UK's IMC survey. That would be the one that has been running for an eternity. That would also be the one that was devised largely by the pilots on Flyer. It was a good idea, but sadly has been totally discredited. Any statistician worth his salt will drive a cart and horses through the way the questions were formulated, the promulgation of the survey, the controls to prevent duplicate replies, the effect of "leaking" data and, if we ever see the results, their interpretation. To do these things properly costs money and sadly that is something AOPA UK does not have - or at least they are not prepared to invest it in this particular direction. Sadly I know of more than a few wags who have completed the survey - shall we say with their tongue very much in cheek.

IO540,
We don't know the EIR syllabus, so I don't know whether it includes some emergency use of IAPs in the training.

But the key answer to your pointis that this potential scenario exists today with the vast majority of the world's PPLs who have VFR-on-top privileges. They are equally vulnerable to destination forecasts changes and just as untrained to fly IAPs.

I am not saying the EIR is brilliant and flawless. Frankly, I tend to think the ICAO system works pretty well when sensibly implemented, so the ideal answer is an accessible full IR, like the FAA one. But any EASA accessible IR is unlikely to be as accessible as the FAA one, so there does seem to be an argument in favour of an intermediate step if one can be found. Europe won't accept the IMCr, because it doesn't work in European airspace (ie. they won't accept it any more than the CAA would accept IMCr holders in Class A). The FCL008 group tried to find an acceptable intermediate qualification. I can't think of a better one that would be acceptable to Europe, so I guess it seems like a good idea to me.

brgds
421C

I guess that about sums up EASA - we are so bereft of ideas it is the best we can come up with - so everyone will just have to put up with it.

What a very sad iditement of the whole process - and we are prepared to go along with it.

Even the most elementary of discussions sets out all the reasons why it is a silly idea. You have some really experienced instrument pilots and instructors on here telling you it will not work. EASA needs to wake up and smell the coffee - it is them that is out of step with everyone else.

Lambs to the slaughter comes to mind.

They may well get what they think they want - but it doesnt mean it makes any sense.

AOPA UK's alternative proposal is that the UK IMCR should become a part-FCL Rating, whose privileges may be exercised in categories of airspace 'where so permitted by national law'.

So, for example, in the UK that means no Class A airways and only SVFR in Class A CTRs. Other EC states could just as easily decide where it may be used, for example 'for IFR enroute navigation only' or whatever restriction applies under the law of the land - not something EASA has any jurisdiction over.

Whereas the proposed Chocolate Teapot Rating would be a mere dumbing down to the lowest common denominator. The concept is an utter crock.

Nope. You're putting me in a position I haven't taken. I joined this thread to reply to opinion that the EIR was chocolate teapot lunacy/fantasy. I just made the point that Australia has a qualification with some analogies to the EIR.

I am happy to learn from you in more detail what the Australia experience tells us about the EIR. Please tell me.

brgds
421C

No, you misunderstand me. I'm saying that the scenarios where it is of practical use are rare in UK weather conditions. Quite true. My point was that such occasions (where you can virtually guarantee cloud base above MSA at the destination, but where it's known to be below en route) are much less common than those where the cloud base at the destination may also be below MSA.

More important, this sort of rating would encourage pilots to set out on journeys that they may not be able safely to complete.

One of the factors that makes IMC flight potentially significantly more dangerous than VMC (in sight of the ground) flight is the fact that you can't see what's below you. You don't get the immediate warning that you should turn back. You rely on forecasts and judgement to, well, guess if it's safe to complete your journey. Without the safety net of an instrument approach to descend through cloud, personally I think IMC flight (or VFR on top) is substantially more risky than VMC. We don't need these extra risks, but we've got a solution: it's the IMC Rating.

And I thought replying to points made to me was the traditional way of having one of these discussions, which I have done.

So what is your better idea? You have neither convinced me the EIR is dangerous or unworkable, nor has Fredacheck convinced me that it's useless.
And what about the EASA principle that FCL priviliges may not be prescribed by national law? That seems a good principle to me, because it may protect us from special interests in individual countries banning all sorts of things. But if that helps keep the IMCr then that's fine. It doesn't stop FCL008 trying to find an intermediate rating that is acceptable across all EU airpsace. Why are the interest of those who want the ICMr kept exactly as it is totally sacred, and the interests of Europeans (and Brits) who might want to fly IFR enroute between VFR destinations utterly silly.

Fredacheck
No, I was only disagreeing with the view that it was of no practical use. I can see plenty of scenarios where it is useful. I'm not saying it's more useful than the IMCr, only more useful than nothing between the PPL and the IR if the IMCr campaign fails, and more useful than nothing for European pilots who won't have access to the IMCr.

VFR on top is perfectly acceptable in the rest of the world (I know the rest of the world has an awful habit of being out of step with the UK, so they must be all wrong....)

The EIR is an alternative to nothing between the PPL and IR for all the other pilots in Europe who won't have access to the IMCr "solution" and for UK pilots if the IMCr solution fails. It also might have value for UK pilots who might actually want to fly long trips in airways outside the UK without worrying about enroute weather, as long as their destination is VFR.

EASA itself has already proposed 'where permitted under national law' in other areas. So what is sauce for the goose....

In any case, the IMCR privileges would be universal. But airspace regulation varies from country to country. National law would limit where the rating could be used in those nations who decide their airspace structure is such that they would only permit en-route IFR (or whatever other limitation they would wish to apply to their airspace).

Agreed. However, if few people are saying its black and a few thousand are saying its white the few must ask if they are out of step.

May I refer you back to the Mountain rating. What do you do if you want to land at an altiport in Italy or Spain?

You see that is the point. It is easy to justify changes by reference to other models, far harder to produce solid evidence that these models have anything to offer. The danger is that if they are mentioned enough we all believe it without thinking to check for ourselves whether there is any substance in the argument. How many on EASA are doing just that?