AOPA and IAOPA clarrify their position on the IR and IMCr

[BEagle]

For an Intermediate Instrument Rating appropropriate to the knowledge, experience and skill of a relatively inexperienced instrument pilot, it is only reasonable that the privileges of that rating should be commensurate.

Put simply, all such pilots probably require is a rating which entitles them to fly an aircraft under IFR and in IMC in departure, en route and arrival phases of flight in airspace approved for such use by national airspace authorities. Theoretical knowledge, language proficiency, medical requirements, flight training and testing should be proportionate for a rating which would require a 600ft cloudbase and 1800m visibility for take-off, landing and at an alternate with approach minima no lower than 'full IR minima' +200ft for precision and +250ft for non-precision approaches.

Alternatively, spend thousand of pounds more and obtain the 'full' IR, whose full privileges you will probably never need.

[englishal]

I think there should be an ATP(L) test personally.

[IO540]

Theoretical knowledge, language proficiency, medical requirements, flight training and testing should be proportionate for a rating which would require a 600ft cloudbase and 1800m visibility for take-off, landing and at an alternate with approach minima no lower than 'full IR minima' +200ft for precision and +250ft for non-precision approaches.

The problem with such an approach (no pun intended) is that yet again it will not work with the existing ATC framework - which simply operates on the basis that the pilot has the privileges for the published approach.

There will never be any mechanism in place for anything different, not least because nobody will ever be able to prove at which point the pilot became visual.

This is why the IMCR legal privilege is the published approach. The extra 500ft or whatever is just a recommendation which in a single crew / private flight scenario is totally unenforceable.

[Fuji Abound]

Everyone seems to get terribly excited about flying an ILS to minima.

I would like to know where is the evidence that flying an ILS approach to minima is so very risky.

I have read plenty of FAA accident reports involving ILS approaches. There are many cases of loss of control during the approach phase but very few of these seem to be solely attributable to a pilot who is unable to fly the needles accurately.

Moreover the reality is it is rare for a private pilots to fly to minima. The very personna of private flying is not too fly in the most challenging conditions, unless you are flying regularly in all weather. Unless that is something you regularly attempt it is very very rare to encounter conditions to minima on an ILS.

Why is it we need to regulate personal discipline from private flying.

Personally all other factos being equal I find the final approach of an ILS one of the easiest aspects of instrument flying.

[421C]

Europe has structured the ATPL into a free gift to any fATPL pilot reaching 1500hrs with the MCC time etc. So, since the ATPL is basically a bogus thing over here for anybody with a RHS MCC job

This is a misconception IO. The vital bit you omit is that you need to have a Type Rating on a multipilot aircraft. The European system is more restrictive than the US one, in that it is harder to get an ATPL.

The US ATP can be done in two ways. The "GA" route, where you get 1500hrs and the various other hours requirements, the ATP written and then you take a check ride on a piston twin (or even single) just like any other check ride. Alternatively, you do a Type Rating. TRs are all to ATP standard, and when you pass a TR, if you meet the requirements for an ATP, the Examiner can issue you an ATP along with the Type Rating. This is absolutely equivalent to the EASA method - except the EASA method includes 3 additional criteria: you must have the MCC qualification, you must have a TR on a multipilot aircraft and you must have 500hrs of multicrew time.

Englishal,

I think there should be an ATP(L) test personally.

There is. It's the Type Rating you need to qualify for an ATPL.

Think of all Type Ratings as being ATPL checkrides. The US (and other ICAO countries) have an easier/more flexible route to get an ATPL by taking a checkride on a Type that doesn't require a TR.

brgds
421C

[IO540]

This is a misconception IO. The vital bit you omit is that you need to have a Type Rating on a multipilot aircraft. The European system is more restrictive than the US one, in that it is harder to get an ATPL.

The US ATP can be done in two ways. The "GA" route, where you get 1500hrs and the various other hours requirements, the ATP written and then you take a check ride on a piston twin (or even single) just like any other check ride. Alternatively, you do a Type Rating. TRs are all to ATP standard, and when you pass a TR, if you meet the requirements for an ATP, the Examiner can issue you an ATP along with the Type Rating. This is absolutely equivalent to the EASA method - except the EASA method includes 3 additional criteria: you must have the MCC qualification, you must have a TR on a multipilot aircraft and you must have 500hrs of multicrew time.

Indeed, but this just leads to the question I was posing earlier, which is why not tie (in JAA-land) professional pilot status to the ATPL?

Instead of tying it to the IR, which is what happens now and this is the "elephant in the room" that has always blocked any progress being made on a more accessible private IR.

I would also observe that while one needs the MCC TR for the JAA ATPL, this is going to be more or less automatic for anybody with a RHS job (and without a RHS job they have no chance of getting it anyway - short of self funding the MCC hours!). That person (CPL/IR) will already have the TR and can hardly fail to accumulate the other requirements eventually. In fact, in today's pilot job climate, they will accumulate them a lot sooner than the move to the LHS

That one can do a "GA ATPL" in the USA (I could do one in my TB20) just makes it even more admirable that the USA is happy with the ATPL as the "professional pilot hallmark", while the JAA ATPL (which is totally inaccessible to a GA pilot) is apparently not good enough for the same purpose over here.

[421C]

The problem with such an approach (no pun intended) is that yet again it will not work with the existing ATC framework - which simply operates on the basis that the pilot has the privileges for the published approach.

There will never be any mechanism in place for anything different, not least because nobody will ever be able to prove at which point the pilot became visual

Neither of those are an issue. ATC does not depend any "single published" minima that all pilots must have the same privileges for - they cope with a variety of operator-determined minima that ATC will have no idea of. ATC/ATIS report the conditions, the operator determines his minima and whether he can accept the procedure and when/if he has to go missed. The list of operator-specific factors that modify the published minima is endless - everything from company limits on procedure types, to weight and conditions determining climb gradient on the MAP to crew currency on a specific procedure, to stabilised approach criteria which mean that ATC can never know for certain, given reported weather conditions and the published minma, whether or not a given aircraft will complete a given procedure.

The IFR system currently works without any mechanism to prove at which point a pilot became visual, so why is this a barrier to any other method?

The actual barrier to an intermdiate IR being meaningfully easier than a full IR is that making the departure and approach minima a bit more restrictive doesn't meaningfully change the Theoretical Knowledge and Flight Training and testing requirements from a full IR.

brgds
421C

[IO540]

Do you think ATC would cope with pilots being unable to accept any instrument approach?

I think that's quite different to having traffic which can in all cases fly the ILS down to 200ft (or whatever), and with nearly all CAT being able to fly it even lower.

Your point about a wide range of operator minima [not being ATC's business] is on the mark but at the same time this is what makes the case for any sub-full-IR privilege very hard to make, because "the other side" is going to argue exactly this line.

[421C]

Indeed, but this just leads to the question I was posing earlier, which is why not tie (in JAA-land) professional pilot status to the ATPL?

I think this is a misconception too. Perhaps there is an element of the IR being a "gatekeeper" for professional pilot evaluation in the UK - because the initial IR test in the UK can only be done by a CAA Examiner. But that is NOT a JAA or EASA requirement. In fact, under EASA, the UK system will not be able to continue, and any Examiner will be able to do an initial IR test. The requirements for the IR stem from several intersecting items of JAA/EASA philosophy and some historical hapstance.
The philosophy is that of approved training organisations and approved courses. The hapstance is that the JAA IR was designed as part of an integrated ATPL course, and not much thought went in to making more flexibile routes more available. There is not really much opposition from the professional pilot community to a more flexible IR for "status" reasons - the pro-pilots "status" comes from the rather difficult requirements for the ATPL, of which the IR is only an element. However, regulators and commerical airpace users are concerned that any user of the IFR system must be able to meet a common, high standard for pilot knowledge and training.

The FCL008 objective, as I understand it, has been twofold.
1. to make the theoretical knowledge for the IR specific to the privileges granted - and not a super-set bundling in other commercial and advanced aircraft knowledge
2. to make the training process by which someone can sit the IR Flight test include a more flexible and competence-based method.
But, the key point is that all IR applicants will need to pass the same TK exams and Flight test - therefore there can not be an accusatioon of "lower standards", which is the kiss of death in Europe on this subject!

brgds
421C

I would also observe that while one needs the MCC TR for the JAA ATPL, this is going to be more or less automatic

But I am not sure what point you are making with this observation? The requirements for getting a JAA ATPL are very demanding. It happens that the flight test requirements can be complied with before the hours requirements. But there is no question that someone getting a JAA ATPL has, following their CPL/IR and MCC qualifications, passed a further test to ATPL standards, their Multipilot aircraft Type Rating. (just to be clear, the MCC is a seperate qualification and course from the TR)

[421C]

Do you think ATC would cope with pilots being unable to accept any instrument approach?

I'm not sure what that question is getting at? They cope with VFR traffic which can't accept any IAP?

I think that's quite different to having traffic which can in all cases fly the ILS down to 200ft (or whatever), and with nearly all CAT being able to fly it even lower

But there can be a lot more variety in the RVR minima for different operators, and all sorts of things limiting minima lower than 200', and all sorts of things limiting minima on an NPA. Again, why is this a problem for ATC?

[englishal]

I'm not sure what that question is getting at? They cope with VFR traffic which can't accept any IAP?

But they are not "IFR".

[Mickey Kaye]

Neither is there any reason for the IR to be taught only at professional FTOs.

"If you don't go for demonstrated competence, the whole thing is bogus.

"Industry interests" is what that bit is about.

And this prevents penetration of the GA market, because most pilots are not within "same day drive there and fly" distance of a pro FTO, so are looking at a residential deal.!"




Totally agree if you can pass the check ride then you are fit to hold an IR full stop.

[bookworm]

Theoretical knowledge, language proficiency, medical requirements, flight training and testing should be proportionate for a rating which would require a 600ft cloudbase and 1800m visibility for take-off, landing and at an alternate with approach minima no lower than 'full IR minima' +200ft for precision and +250ft for non-precision approaches.

So I'll ask you, as I did on the other forum, to identify which aspects of theoretical knowledge, language proficiency, medical requirements are relevant only in the last 250 ft of an IAP. Then we'll understand what is necessary for the full IR but not the limited IR you propose.

[Fuji Abound]

Bookworm

How do you rationalise the lesser training requirments of the IMCr with its excellent safety record? In other words what is the magic that seems to keep these pilots safe without their having done a full IR?

[bookworm]

In other words what is the magic that seems to keep these pilots safe without their having done a full IR?

The disproportionately burdensome training requirements of the JAA IR. Safety in IF comes mostly through experience and currency, not through endless hours of training at an approved school.

[Fuji Abound]

I was considering the merit of setting an exam - if the "student" passes he is good to go, how he achieved the standard is irrelevant. This could be applied to any walk of life and any exam. If a lawyer were to pass the bar exams then he should be good to practice.

The weakness in that argument is that any exam tests only certain aspects of the training a student has received. The exam may not reveal certain weakness and may not cover the whole syllabus. We take a certain comfort that because the student has covered an approved course he has been exposed to all the material whether or not it is assessed at exam level.

Some professionals go a stage further and require the student to undertake a period of mentoring after passing their professional exams.

Perhaps mentoring is an answer. Pass the IMCr, however you can, demonstrate 25 hours of IT in your log six months after and five hours with an instructor and you are good to go with a full IR (the numbers are arbitary).

Bookworm - thanks for clarrifying your position.

[bookworm]

I was considering the merit of setting an exam - if the "student" passes he is good to go, how he achieved the standard is irrelevant. This could be applied to any walk of life and any exam. If a lawyer were to pass the bar exams then he should be good to practice.

I remember a talk from a long retired CAA CFE. He described the procedure of old, where an applicant for an IR would turn up and hire the CAA DH Dove on which the test was to be conducted and pay his fee for the test. He would undoubtedly fail first time, but the examiner would give him useful corrective tips through the test. The next time, he would perform better, but probably still fail. After a half dozen such "tests" the applicant would get quite good, and might well pass. Not ideal, as you point out, hence the introduction of the requirement for mandatory training, which is now at the other extreme.

Bear in mind that the ICAO IR requires only 10 hours of instrument training. It does however, require 40 hours of total instrument experience. It seems unlikely that 10 hours of training would be sufficient for most to pass an IR test, thus the practical minimum training is likely to be 20-25. I doubt many would disagree.

With the IF from the PPL, that leaves about 10 hours of IF to be acquired before an IR can be issued. Whether or not that requirement for extra experience has a safety case is debatable -- I think the stats you quote for the IMC rating are impressive, but are based on sufficiently small accident rates that it's difficult to reach significance. The 40 hours is however, an ICAO standard, and for the sake of such standards, I think the cost of accepting an extra few hours of IF is outweighed by the benefit.

So how does the candidate acquire such experience? One option is mentoring, though that has the issue of who is in command, the mentor or the mentee. Another is that the candidate could be permitted to pick up useful instrument experience in a relatively benign environment which wouldn't require the hardest bits that the IR demands. For example, you might permit the candidate to fly in IMC enroute but avoid instrument approaches...

[englishal]

Though the "en-route" bit is the easiest. We came back from Valenica a while back and the actual routing was dct barcelona dct <somevoronthefrenchborder> dct some other french VOR dct Gurnsey dct SAM then some STAR into Stanstead which became vectors. A couple of flights should suffice.

I think that training should cover all areas of operations at least once- in the case of a full IR, anything that may be thrown at you, from LDA, SDF, Back Course, ILS, NDB, GPS approaches, as well as holds, SIDs and STARs.

However in reality in JAR land, trypical instrument rating profiles go between about 3/4 airports - if you fly from Bournemouth for example, you'll do approaches at Exeter, yeovil, Southampton and maybe Alderney - over and over again until you are good enough to satisfy the examiner you can fly to these airports. Also if you book the examiner on a Friday, he likes Southampton as it is close and he can knock off early (for example).

So if the "cut down IR" only included ILS then the training can be significantly cut down, the theory can be significantly cut down, and the cost can be significantly cut down. If one is then only allowed to file to an airport with Precision approach there is no worries with ATC telling you to shoot the NDB approach and you saying "uuurrrr, sorry". It also prevents one having to buy a Crystal Ball to determine the exact weather at 10:37 at the destination. Seems very sensible to me, and the practical test standards can be equal for the enroute and approach portions.

The addition of an Oral exam, which could test the applicants knowledge on all aspects of the cut-down IR would weed out those who don't really know what they are talking about.

[Fuji Abound]

Bookworm

I love the way in which you have lead the audience into your final line

For example, you might permit the candidate to fly in IMC enroute but avoid instrument approaches...

It is a well constructed post.

I suspect many of us would agree with you were it not that the rumoured proposals contain no proposed transition from the EIR to approach capability. Moreover once again based on the rumours they provide no mechanism for preserving the rights of what some already do.

It has always sat very uncomfortably with me when any Authority proposes to withdraw rights when there is no safety case what so ever for doing so. If the evidence was that existing IMCr holders were involved in a higher than acceptable rate of accidents during the approach phase of an instrument sector I doubt any of us could or indeed would wish to resist the tide of change. However that is not the case.

I would take issue on the size of the population. I dont think so far as instrument qualifactions go in Europe the population of IMCr pilots can be considered small or unrepresentative by any stretch. I do accept that the vast majority of IMCr holders are not flying IAPs to minima, but then how many private IR holders do so? I know a fair few who impose higher personal minima. Moreover if the population has proved they are able to excercise sufficient self regulation so as to achieve a remarkable safety record is this such a bad thing. In reality most professions these days rely on self regulation - aviation is one of the few arenas where pilots are re-tested. Whether aviation has also taken this too far I am not sure. Is there any evidence that since the two yearly flight review was introduced in Europe the accident rate has fallen? Is there any evidence that FAA IR holders who, in the majority self certify currency are less safe that their European counter parts?

As usual there seems to be all too much legislation which doesnt seem to be based on any hard evidence or proper studies of the data. Is this really how we have taken to regulate society? Safety based on politics and commercial interest.

[mm_flynn]

Originally Posted by Fuji Abound

Bookworm

How do you rationalise the lesser training requirments of the IMCr with its excellent safety record? In other words what is the magic that seems to keep these pilots safe without their having done a full IR?

The IMC rating, as currently constructed has a number, of features you would expect to help with the low number of accidents.

1. The CAA, many instructors and others have advocated the IMCr as a 'get you home' rating.
2. It has a minimum visibility requirement for landing and takeoff that means you need to be ICAO Class G VMC after you breakout of the clouds
3. The CAA recommend significantly higher minima than the system minima
4. The nature of UK airspace restricts the operating envelop in most parts of the country to be low altitude, making knowledge of higher altitude operating procedures and weather phenomenon less relevant.
5. The geographic restrictions
   • make understanding procedures in the general sense (vs. UK specific procedures) irrelevant.
   • restrict typical weather phenomenon to temperate maritime
   • provide a generally benign and consistent geographic environment

The first three points are likely to have reduced the number of 'challenging' IFR operations to a very small number vs. IR holders. It is likely that the small number of 'Active' [as in using their approach capability for below Class G VMC operations) IMCr pilots helps signficantly to keep the accident statistics down (think Concord moving from safest to least safe aircraft in the world in the course of 15 minutes). To my knowledge, there is no data on relative exposure of IR pilots and IMCr pilots, so it is difficult to make a statement about the relative safety.

The geographic restriction and de facto altitude limitations, I think significantly reduces the relevant theoretical knowledge.

This is offset by a more 'complex' MSA planning requirement in that one must actually look in detail at the charts for obstructions and terrain as you can not use published MEAs and MORAs. However, in most areas of the UK this is offset by the generally consistent elevation (and may be part of the reason for the relative frequency of Southern based pilots collecting granite North of the boarder.