difference in IR and IMC rating
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The 500/600ft figures have appeared in various CAA advisory flyers, in the IMC Rating written exam (very naughty as they are not in the ANO and therefore not law) and in the fullness of time they have passed into aviation folklore, alongside not leaning below 3000ft, GPS being prohibited for primary nav, GPS being prohibited full stop, GPS not working due to "terrain shielding" ("Safety" Sense Leaflet #25) etc ![Embarrassment](https://www.pprune.org/images/smilies/embarass.gif)
The CAA issue various bits of paper; for example they tell you to add 1/3 to the POH takeoff roll if it is grass, another 1/3 if the grass is wet, etc. Not wholly unreasonable stuff, for certain types of landing gear anyway, but not law and that is a crucial distinction.
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The CAA issue various bits of paper; for example they tell you to add 1/3 to the POH takeoff roll if it is grass, another 1/3 if the grass is wet, etc. Not wholly unreasonable stuff, for certain types of landing gear anyway, but not law and that is a crucial distinction.
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The IMC is very useful and providing you keep current with flying IMC makes you safer. I have a session with a friend or instructor periodically when I fly on instruments from just after take off to DA/MDA on instrument approach.
An acquaintance of mine has done the FAA IR. He is used to doing academic courses including oral exams. He described the FAA IR skills test as the most dfficult exam he has ever done. A two hour oral exam was followed by the practical test where he did various things such as airways flying, various approaches etc. without being told in advance anything about what he was going to do.
The FAA IR is perceived, wrongly it seems, to be easier because there is only one exam, a lower total hours flying requirement and you can count instrument flying done previously towards your hours, up to a limit (not sure what it is!). The JAA IR is more tedious because you have 7 exams (£55 each)usually done in two sessions, plus compulsory 2 weeks (done separately) of consolidation at a ground school. The cost of the academic side is probably about £2,000 and then you have the flying! With the FAA IR you can home study and then do the single exam at any flight training organisation.
The flying you do for the IR you do is the same whether you are PPL only or going for a CPL/ATPL, though some PPLs go for the single engine IR, which is 5 hours less. The only medical requirement for the IR above a PPL is a special hearing test.
An acquaintance of mine has done the FAA IR. He is used to doing academic courses including oral exams. He described the FAA IR skills test as the most dfficult exam he has ever done. A two hour oral exam was followed by the practical test where he did various things such as airways flying, various approaches etc. without being told in advance anything about what he was going to do.
The FAA IR is perceived, wrongly it seems, to be easier because there is only one exam, a lower total hours flying requirement and you can count instrument flying done previously towards your hours, up to a limit (not sure what it is!). The JAA IR is more tedious because you have 7 exams (£55 each)usually done in two sessions, plus compulsory 2 weeks (done separately) of consolidation at a ground school. The cost of the academic side is probably about £2,000 and then you have the flying! With the FAA IR you can home study and then do the single exam at any flight training organisation.
The flying you do for the IR you do is the same whether you are PPL only or going for a CPL/ATPL, though some PPLs go for the single engine IR, which is 5 hours less. The only medical requirement for the IR above a PPL is a special hearing test.
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If you have an IMC rating, and fly IFR in IMC, does the aircraft equipment also have to be IFR immune?
I understand it costs a lot to maintain an a/c as IFR immune, if so, how many clubs/owners have truly IFR immune aircraft?
Just a thought
GB
I understand it costs a lot to maintain an a/c as IFR immune, if so, how many clubs/owners have truly IFR immune aircraft?
Just a thought
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GB
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does the aircraft equipment also have to be IFR immune
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Many aircraft have FM immune equipment and I don't think there is any additional cost of maintaining them over non-FM immune. Not having FM immune means that you cannot do an ILS or VOR approach in IMC (but you can legally do the far less accurate NDB/DME approach).
Of far more importance is the lack of de icing or anti icing on most single engined GA aircraft. This severely limits flight in IMC for substantial parts of the year. So for that matter does not having an auto pilot as prolonged flight in IMC is very taxing without one.
Unless you plan prolongued tours or business trips in Europe IFR and have the right sort of aircraft then an IR is an expensive luxury. As has already been said, you can fly IFR in all UK airspace except class A with an IMC. Personally, I would not plan a flight which involved any significant IMC on the back of an IMC rating - flying IFR does not of course mean that you are in IMC.
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Originally Posted by tmmorris
Giloc - thanks, I knew it was mandatory... assuming the AIP carries the force of law... Does it?
Tim
Tim
"Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach."
I find it hard to interpret that as anything other than a recommendation!
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Re FM immunity, this is worth checking but my understanding is this:
It is mandatory for IFR in controlled airspace. This means Class A-E.
Most planes available for self fly hire are not FM immune, which is why PPL-level instrument training usually takes place under VFR and keeping out of CAS, and if they go into CAS, in IMC.... well.... it's a case of ask no questions tell no lies![Embarrassment](https://www.pprune.org/images/smilies/embarass.gif)
So I think that flying the typical old wreck, you could fly an ILS into Biggin (VFR or IFR) but not into Bournemouth. Into the latter, you would have to do it as a practice approach under VFR conditions.
This is a big reason why the GNS430 is popular: you get an FM immune radio, VOR and LOC. People certainly aren't buying it for it's superb large legible moving map display
To replace a couple of conventional radio/nav receivers with FM immune ones is a few k, which is why nobody does it unless they have to.
Unfortunately, once you start looking up the mandatory equipment requirements for IFR in CAS, you find you need an ADF too... and a DME.
On the IMCR minima, I agree with giloc; it's a recommendation. It says so.
It is mandatory for IFR in controlled airspace. This means Class A-E.
Most planes available for self fly hire are not FM immune, which is why PPL-level instrument training usually takes place under VFR and keeping out of CAS, and if they go into CAS, in IMC.... well.... it's a case of ask no questions tell no lies
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So I think that flying the typical old wreck, you could fly an ILS into Biggin (VFR or IFR) but not into Bournemouth. Into the latter, you would have to do it as a practice approach under VFR conditions.
This is a big reason why the GNS430 is popular: you get an FM immune radio, VOR and LOC. People certainly aren't buying it for it's superb large legible moving map display
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Unfortunately, once you start looking up the mandatory equipment requirements for IFR in CAS, you find you need an ADF too... and a DME.
On the IMCR minima, I agree with giloc; it's a recommendation. It says so.
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Regarding FM Immunity, it looks as if the previous wording has been revoked and this wording issued: http://www.caa.co.uk/docs/224/srg_ga...mune%20GE4.pdf
My reading is that wording for a/c < 5700kg, non FM comms are not an issue, but non-FM ILS/VOR are restricted to VFR only regardless of airspace. Non-public transport flights may have only a single non-FM immune ILS/VOR in CAS. Therefore, as there are no requirements to carry radio nav aids in Class G, the CAA would prefer you to DR in IMC! However, the implication is that you can use your non-FM immune VOR in uncontrolled airspace because the authority can never doubt otherwise.
AIC Pink 87 is very badly worded. It suggests that even non FM Comms in any aircraft must be placarded and limited to VFR only and it refers to a long time defunt AN 84.
My reading is that wording for a/c < 5700kg, non FM comms are not an issue, but non-FM ILS/VOR are restricted to VFR only regardless of airspace. Non-public transport flights may have only a single non-FM immune ILS/VOR in CAS. Therefore, as there are no requirements to carry radio nav aids in Class G, the CAA would prefer you to DR in IMC! However, the implication is that you can use your non-FM immune VOR in uncontrolled airspace because the authority can never doubt otherwise.
AIC Pink 87 is very badly worded. It suggests that even non FM Comms in any aircraft must be placarded and limited to VFR only and it refers to a long time defunt AN 84.
Thanks for the reference HWD.
One could argue that explanatory note 4 is just that, but it does make it harder to argue that flying an ILS does not require an ILS receiver, even though Schedule 5 does not mention it explicitly!
The placards required by AWN 84 limit non-immune equipment in light aircraft to "LA Class 3", which permits their use "for the facilitation of any flight outside controlled aispace under IFR or VFR". That would seem to meet the requirements of paragraph 2 of the directive.
One could argue that explanatory note 4 is just that, but it does make it harder to argue that flying an ILS does not require an ILS receiver, even though Schedule 5 does not mention it explicitly!
The placards required by AWN 84 limit non-immune equipment in light aircraft to "LA Class 3", which permits their use "for the facilitation of any flight outside controlled aispace under IFR or VFR". That would seem to meet the requirements of paragraph 2 of the directive.
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We are getting a long way from the original subject, though I suppose the essential difference between the IMCR and the IR is the ability to fly IFR abroad....
This leads to equipment requirements abroad. These are in each country's AIP, in the GEN 1.5 section.
A UK CAA concession might be worthless in practice.
This leads to equipment requirements abroad. These are in each country's AIP, in the GEN 1.5 section.
A UK CAA concession might be worthless in practice.
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The 500ft precision and 600ft non-precision absolute minima apply to IMC rating holders and are mandatory and the ANO says so.
Article 49 clearly says that pilots of non-public transport aircraft are not to descend below the notified minima unless the required visual references are established and maintained.
Notified means: Information set forth in a document published by or with the authority of the CAA and entitled Supplement (NOTAM)
or AIP and for the time being in force. (my emphasis).
AD 1-1-6 of the AIP is very clear saying that "This section of the AIP specifies the notified method of calculating Aerodrome Operating Minima (AOM) for the purpose of
Article 39 (Public Transport Aircraft not registered in the United Kingdom) and Article 40 (Non-public Transport Aircraft)."
(The article numbers were changed in the last ANO amendment.)
The AIP goes on to say;
3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC
Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State
in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.
To put that in simple terms;
The ANO says that pilots must comply with Notified minima. Notified means published in the AIP or NOTAM etc and the AIP says that the 200ft addition is advisory but that the absolute minima of 500ft precision and 600ft non-precision are mandatory.
That is the legal basis and that is why they are mandatory and why they are in the exam still.
Thus ILS with 200ft DH will mean 500ft DH legal minimum for an IMC holder.
---------
As for FM immune requirements.
There is a very simple way to think of the FM issue pertaining to ILS and VOR equipment. If it is not FM immune it is U/S.
If you would not rely on a U/S instrument or navigation system to navigate in IMC or make an instrument approach in IMC then you would not use a non-FM immune system.
DME and ADF are not limited by the requirements. Thus I would not see a probem with flying to a destination in class G airspace where the approach would be an NDB or NDB/DME and if required by law, the alternate also had an NDB or NDB/DME procedure available. eg Blackpool.
However, regardless of airspace, flying an ILS or VOR procedure with U/S equipment would be illegal.
There is no law that says one can not fly an aircraft in VMC using visual navigation while looking at the indications on an unserviceable ILS or VOR indicator. That is the legal basis of IMC training in VFR - the instructor is visual and navigating visually and can ensure the safety of the aircraft.
People are silly to pay for training with U/S equipment even if it is for the IMC rating. Many operators have used FM immune as an excuse to push up prices but never fitted the equipment.
Regards,
DFC
Article 49 clearly says that pilots of non-public transport aircraft are not to descend below the notified minima unless the required visual references are established and maintained.
Notified means: Information set forth in a document published by or with the authority of the CAA and entitled Supplement (NOTAM)
or AIP and for the time being in force. (my emphasis).
AD 1-1-6 of the AIP is very clear saying that "This section of the AIP specifies the notified method of calculating Aerodrome Operating Minima (AOM) for the purpose of
Article 39 (Public Transport Aircraft not registered in the United Kingdom) and Article 40 (Non-public Transport Aircraft)."
(The article numbers were changed in the last ANO amendment.)
The AIP goes on to say;
3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC
Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State
in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.
To put that in simple terms;
The ANO says that pilots must comply with Notified minima. Notified means published in the AIP or NOTAM etc and the AIP says that the 200ft addition is advisory but that the absolute minima of 500ft precision and 600ft non-precision are mandatory.
That is the legal basis and that is why they are mandatory and why they are in the exam still.
Thus ILS with 200ft DH will mean 500ft DH legal minimum for an IMC holder.
---------
As for FM immune requirements.
There is a very simple way to think of the FM issue pertaining to ILS and VOR equipment. If it is not FM immune it is U/S.
If you would not rely on a U/S instrument or navigation system to navigate in IMC or make an instrument approach in IMC then you would not use a non-FM immune system.
DME and ADF are not limited by the requirements. Thus I would not see a probem with flying to a destination in class G airspace where the approach would be an NDB or NDB/DME and if required by law, the alternate also had an NDB or NDB/DME procedure available. eg Blackpool.
However, regardless of airspace, flying an ILS or VOR procedure with U/S equipment would be illegal.
There is no law that says one can not fly an aircraft in VMC using visual navigation while looking at the indications on an unserviceable ILS or VOR indicator. That is the legal basis of IMC training in VFR - the instructor is visual and navigating visually and can ensure the safety of the aircraft.
People are silly to pay for training with U/S equipment even if it is for the IMC rating. Many operators have used FM immune as an excuse to push up prices but never fitted the equipment.
Regards,
DFC
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DFC,
Your interpretation of the relevant part of the AIP seems to be one of two possible interpretations. Your quote, but with the emphasis in a different place:
With the emphasis this way round, the word "recommended" could be interpreted to apply to the whole of the paragraph.
The word "absolute" does not have to mean mandatory; my dictionary gives a number of definitions of the word, including "not relative" and "independent". So I think there is a valid argument for the "absolute" to mean that the addition of 200' to the minima is the first part of the recommendation, but then there is an independant minimum, which is not relative to the first part, of 500' or 600' as appropriate; both of these are included in the paragraph which, as a whole, is merely "recommended".
That's certainly the way I read the paragraph when I first came across it, and it's the way several other people I know interpret it too, but I can also see how it might be interpreted the way you describe. (My dictionary also gives alternative definitions of "absolute" as meaning "unrestricted" or "complete" which would fit in with your interpretation.)
FFF
--------------
Your interpretation of the relevant part of the AIP seems to be one of two possible interpretations. Your quote, but with the emphasis in a different place:
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach
The word "absolute" does not have to mean mandatory; my dictionary gives a number of definitions of the word, including "not relative" and "independent". So I think there is a valid argument for the "absolute" to mean that the addition of 200' to the minima is the first part of the recommendation, but then there is an independant minimum, which is not relative to the first part, of 500' or 600' as appropriate; both of these are included in the paragraph which, as a whole, is merely "recommended".
That's certainly the way I read the paragraph when I first came across it, and it's the way several other people I know interpret it too, but I can also see how it might be interpreted the way you describe. (My dictionary also gives alternative definitions of "absolute" as meaning "unrestricted" or "complete" which would fit in with your interpretation.)
FFF
--------------
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Good last point. If it was law, wouldn't it be written in legalese - long sentences with no commas to avoid precisely that kind of confusion?
But if its in the ANO, you ignore it and you have an incident then it will be that much harder to avoid problems with your insurers and charges of negligence. Isn't the highway code similar? Not "law" but if you don't comply, you open yourself up to more problems than otherwise.
But if its in the ANO, you ignore it and you have an incident then it will be that much harder to avoid problems with your insurers and charges of negligence. Isn't the highway code similar? Not "law" but if you don't comply, you open yourself up to more problems than otherwise.
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Flying For Fun,
Nice try and I am sure that many IMC holders would like it to mean that.![Big Grin](https://www.pprune.org/images/smilies2/eusa_clap.gif)
The interpretation of the statement in the AIP does not revolve around how you read the paragraph with regard to the words recomended or absolute. The important word I am told is in fact but.
Check your dictionary for a definition of the word but.........conjunction - however, on the other hand.
Thus in simple terms the IMC rating holder is recomended to add 200ft to all minima however (on the other hand) the absolute minima is 500 precision and 600ft non-precision.
For your interpretation of the paragraph to work, the word but would have to be removed and replanced with and
Here is your interpreataion;
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, and with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.
However, the actual words are;
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.
I do agree that the paragraph can be confusing but the training material, teaching of the rating, the exam and the CAA all follow the common line that 500 precision or 600 nonprecision are absolute minima.
Personally, I find that this is not simply a wording problem- an ILS wih no obstacles and IR hoder's DH of 200ft will see the IMCR pilot use a DH of 500ft minimum. An extra safety margin of 300ft.
Now add in some serious obstacles and terrain and make the IR holders DH 600ft. The IMCR holder can now use 800ft DH. A much reduced safety margin despite the fact that the environment is less forgiving!
It would be far simpler for pilots to understand, for pilots to calculate and also far safer if the IMCR holder was simply required to add 300ft to the IR rating holders minima regardless of approach.
Regards,
DFC
Nice try and I am sure that many IMC holders would like it to mean that.
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The interpretation of the statement in the AIP does not revolve around how you read the paragraph with regard to the words recomended or absolute. The important word I am told is in fact but.
Check your dictionary for a definition of the word but.........conjunction - however, on the other hand.
Thus in simple terms the IMC rating holder is recomended to add 200ft to all minima however (on the other hand) the absolute minima is 500 precision and 600ft non-precision.
For your interpretation of the paragraph to work, the word but would have to be removed and replanced with and
Here is your interpreataion;
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, and with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.
However, the actual words are;
Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach.
I do agree that the paragraph can be confusing but the training material, teaching of the rating, the exam and the CAA all follow the common line that 500 precision or 600 nonprecision are absolute minima.
Personally, I find that this is not simply a wording problem- an ILS wih no obstacles and IR hoder's DH of 200ft will see the IMCR pilot use a DH of 500ft minimum. An extra safety margin of 300ft.
Now add in some serious obstacles and terrain and make the IR holders DH 600ft. The IMCR holder can now use 800ft DH. A much reduced safety margin despite the fact that the environment is less forgiving!
It would be far simpler for pilots to understand, for pilots to calculate and also far safer if the IMCR holder was simply required to add 300ft to the IR rating holders minima regardless of approach.
Regards,
DFC
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Originally Posted by DFC
AD 1-1-6 of the AIP is very clear saying that "This section of the AIP specifies the notified method of calculating Aerodrome Operating Minima (AOM) for the purpose of
Article 39 (Public Transport Aircraft not registered in the United Kingdom) and Article 40 (Non-public Transport Aircraft)."
(The article numbers were changed in the last ANO amendment.)
The AIP goes on to say;
3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC
Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State
in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.
...
That is the legal basis and that is why they are mandatory and why they are in the exam still.
Article 39 (Public Transport Aircraft not registered in the United Kingdom) and Article 40 (Non-public Transport Aircraft)."
(The article numbers were changed in the last ANO amendment.)
The AIP goes on to say;
3.3.2 IMC Rating Holder in Current Practice
3.3.2.1 Pilots with a valid Instrument Meteorological Conditions (IMC) Rating are recommended to add 200 ft to the minimum
applicable DH/MDH, but with absolute minima of 500 ft for a precision approach and 600 ft for a non-precision approach. The UK IMC
Rating may not be valid outside UK territorial airspace, therefore IMC Rated pilots should check the validity of their rating for the State
in which they intend to fly. If the rating is not valid pilots must comply with the basic licence privileges, subject to the regulations of that
State.
...
That is the legal basis and that is why they are mandatory and why they are in the exam still.
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To recomend an absolute minima or to require an absolute minima does not change the use of the word absolute.
The simplest way to look at it is;
If a person is doing the flight test for the issue of an IMC rating uses a minima of say DH 300ft on an ILS where the IR minima is 200ft they will fail for flying below the absolute minima of DH 500ft. This would be very unusual because the minima are discussed in the briefing and the flight will not depart until the candidate uses appropriate minima from the AIP. That means absolute minima of 500ft precision and 600ft non-precision.
So if it is a requirement to be complied with in order to pass a test then it is a requirement to be followed after the rating is issued.
Should the candidate make it known that they are going to use the AIP minima for the test and then use lower minima after passing, there would be a question regarding their being fit to hold a licence.
Regards,
DFC
The simplest way to look at it is;
If a person is doing the flight test for the issue of an IMC rating uses a minima of say DH 300ft on an ILS where the IR minima is 200ft they will fail for flying below the absolute minima of DH 500ft. This would be very unusual because the minima are discussed in the briefing and the flight will not depart until the candidate uses appropriate minima from the AIP. That means absolute minima of 500ft precision and 600ft non-precision.
So if it is a requirement to be complied with in order to pass a test then it is a requirement to be followed after the rating is issued.
Should the candidate make it known that they are going to use the AIP minima for the test and then use lower minima after passing, there would be a question regarding their being fit to hold a licence.
Regards,
DFC
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Originally Posted by IO540
Failing a checkride on that merely means that the examiner has formed the same opinion as lots of others; fair enough. It's only a once per lifetime checkride anyway.
IMC renewal every 25 months isn't it?
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