AOPA and IAOPA clarrify their position on the IR and IMCr

[bookworm]

I would take issue on the size of the population.

It's not the size of the population that's the issue, but the number of accidents. Fortunately, fatal or serious aviation accidents are rare enough that it can take decades to accumulate sufficient statistics to provide the safety case you seem to seek.

Imagine there's a rate of 10 fatal accidents per year. Is a safety measure that cuts the underlying rate by 10% worthwhile? It would save a few lives each year, so a regulator should probably consider it.

But how do we prove the effect of such a safety measure? Imagine we can compare 10 years with the measure (let's say there are 100 accidents) against 10 years without it (let's say there are 90 accidents). Is that a statistically significant reduction? Not even close. At those rates, you'd need something like 40 years with and without the measure to see a statistically significant difference. And that assumes a perfect control, i.e. that nothing else has changed in those 40 years to skew the results.

My impression is that there are very few accidents involving either instrument rated or IMC-rated pilots that can be clearly attributed to IF aptitude -- a lot fewer than 10 per year. That means that, unless we are prepared to write off lost lives simply as data, regulation has to be built to some extent on plausibility of cause and effect as well as statistics.

[Fuji Abound]

Yes, but the IMC rating has been with us for a very long time and a great many hours have been flown by IMC rated pilots.

Are you suggesting that if there has only been one IMC related accident in that time the evidence can be ignored as not statistically sound? It seems to me there is no evidence the rating is unsafe because essentially there have been no accidents. The accident rate of course many increase from zero but applying your logic it would need to increase by a great deal over a long period of time before the rating could be judged unsafe.

How many hours and decades would you want?

Moreover how much more or less statistically sound are the proposed changes? There seems to be no evidence what so ever to support the changes.

It feels to me someone just thought it was a good idea which is in fact exactly what you are suggesting.

[mm_flynn]

Fuji,

With regard to the IMCr safety. In the CAA's last 10 year analysis, considering accidents within the UK (which allows for analysis of all of the facts using the matching AAIB reports) there were two fatal accidents involving IMCr pilots in IMC conditions (1 CFIT, 1 loss of control following an engine failure). There was (from memory) 1 CFIT for an IR rated pilot (ATPL descending from enroute into the sea).

With only 3 fatal accidents in the decade it is a very small sample. As I have already said, there is no indication I am aware of as to even the number of pilots with a current IMCr vs IR - let a lone the amount and type of flying they do.

However, as a very anecdotal comments. When I am out at the airport on a cold and rainy day, the aircraft coming in are (in rough frequency) the local charter operator (CPL/IR, locally based turboprops (unlikely to be IMCr pilots), NReg aircraft (almost surely FAA/IR, and G-reg (of whom a number of the pilots I know are IRs and the rest are IMCr holders) - So I lean towards a view that IMCr holders are small fraction of the pilots flying on bad weather days. Of course, if I were based in the midlands, on a grass strip, with no local charter operator, I might have a very different view.

[IO540]

A great debate, this, and a lot of people are right IMHO.

The "IR traditionalists" will never admit just how much less pilot expertise is required to fly IFR safely, relative to the amount of crap one has to learn to get the IR. And I suspect many of them don't actually know - they are instructors/examiners who have never flown IFR for real, or not in anything remotely recent.

MM-Flynn's points are probably very right, but lots of things are self limiting as regards risk. The IMCR is self limiting due the factors he lists, but the IR (as it would be used by private pilots) is also self limiting, due to

- most GA "wreckage" can't reach the levels at which Eurocontrol routings are reasonably easy to develop (basically, FL100 plus)

- most GA "wreckage" can't reach the levels at which a non-deiced plane is going to be viable enroute i.e. flying VMC above typical N European stratus cloud tops (basically, FL120-FL160), so the risk of (to quote the often expressed fear of ATCOs) the airways clogging up with Cessna 150s is practically zero

- most Eurocontrol routings need oxygen, but a lot of pilots won't use the stuff

- many/most (?) owners of genuinely IFR capable planes already have an IR so there would not be any great pent-up demand

- most IFR GA would be flying in the great empty void FL100-FL200 in which there is almost no enroute traffic, and Eurocontrol routings don't compute through terminal areas...

- private GA rarely flies proper-IFR in really poor weather. In fact, IMCR pilots fly in worse weather; one can fly "VFR" in IMC at 2400ft in a typical OVC007 warm front scenario, but one would not go properly IFR in that because the route will be FL100 plus, but the 0C level will be say FL060 (like today; I've just been up there), and the tops will be ~ FL250, so without proper de-ice this is a no-go because the option of a descent to warm air is not there (short of an emergency declaration, and in much of Europe the obstacle clearance will be an issue) and a climb to VMC will mean transiting through 8000ft of icing conditions and anyway nothing short of a PA46 is going to make it there... Generally, I have flown in much worse conditions on the IMCR than I have flown on the IR.

- the vast majority of long distance touring is done in reasonable weather, because who wants to go somewhere when it is pi55ing down with rain?

However, how relevant any of all this is, I don't know. Rationalising is a wsate of time. The actual obstacles are wholly political...

[englishal]

Stats can be used to "prove" anything you want.

As there is a direct corrolation between the size of hard disks and global temp, does that mean that hard disk size has lead to global warming?!

I wonder how many IMC rating holders have been killed during an approach? This would be telling info because this would determine if the approach is really so dangerous you couldn't trust EIR flyers to carry one out safely?
I knew a reasonably high time IR'd pilot who is now ashes scattered in the Pacific Ocean as he managed to fly into a mountain on an approach in a perfectly servicable aeroplane.

IO is right when he says the IMCr (or EIR...) would be self limiting. I wouldn't choose to fly in really ****e weather - A choice someone flying for someone else can't always make, which is why I reckon the "not authorised for public transport operations" would make a lot of sense.

[IO540]

AIUI, it is politically absolutely vital to not give the "god appointed guardians of IR purity" any excuse for saying they are sharing airspace with less capable users, as that would lead to segregation by airspace class, which would destroy the private IR.

But there is already a precedent for a difference: it is the PPL/IR v. CPL/IR. The former is 7 exams; the latter is 14 exams. In the former exams, there are not supposed to be any "professional flying" i.e. jet or FMS related stuff. Yet both have exactly identical private flying privileges.

And obviously a PPL/IR cannot do PT work anyway.

So I don't see a problem.

[mm_flynn]

In the last decade no one has died flying an approach in IMC in the UK (although one CPL/IR in Oxford came very close).

A number of people have died flying approaches outside the UK (but there is no comperable IMCr population). In general, those have been approaches in and around mountains (which for the most part don't exist near UK instrument approaches.) This goes back to a very big safety feature of the IMCr - its limitaiton to UK only - on most UK approaches, if you use 600 ft as your MDA, you can be 10 miles left or right and still live.

I think the main reason for the differenc in PPL/IR and CPL/IR is that the whole TK structure was designed around commercial training and they 'forgot' about PPL operations. The CPL exam (as I understand it) is actually the ATPL knowledge (ex. MCC).

[maxred]

Io540 - Just About Right

Thanks IO540, accurate post. I am one of the stats - IMC/NIGHT/Multi, I fly a fully equiped IFR aircraft - transit to Spain /South of France, and will always go VFR. In fact the one time we took an A36 Bonanza to Perpignan, with a 'full' IR pilot in charge, and full IFR flight plan, he nearly killed us in a night approach to the airfield. i.e he got lost on the procedure. I got it visual and then gently assisted.
I enquired a great deal about a full IR. I have resisited, waiting for the EASA situation to develop. What I require as a GA/PPL is a rating that will develop my own skills, keep me as safe as I can be, and let me deal with personal minima. All of this within a realistic budget and achievable within lifestyle constraints.
The one other issue we all face, is recency. To fly full IFR, and be competent, takes a lot of regular flying. I personaly could not do that much to keep current, hence the dilema over the full IR rating.

[BEagle]

1.The CAA, many instructors and others have advocated the IMCr as a 'get you home' rating.

Have they really? I've see that old chestnut in many articles written about the IMC rating, but you tell me where the CAA makes such a statement.

[FREDAcheck]

My requirements may be a bit lower than maxred's, and I really don't want an IR and wouldn't use it enough to be current.

I don't know if I'm a typical IMCR flyer, but I'll bet I'm not alone. I rarely fly because I have to get from A to B - I fly for fun. And flying any distance in low vis at tree-top height isn't. Fun, that is. There are many days in the UK when a flight can be completed above the clag (or even in it), but a VFR flight would be unpleasant and possibly dangerous. An en-route IFR rating wouldn't help. Very often such days have cloudbase down to 1000 feet, sometimes below, which may well be below MSA. (And if the cloudbase were well above MSA, then I wouldn't need the IMCR anyway - I could fly VFR below - so why on earth would I want an en-route IFR rating?)

It's often said that IMCR pilots are not current enough to fly approaches to anything like normal minima - I may be one of those pilots. So I don't fly with TAFs predicting cloudbase below 1000 feet. In the event I get down to MSA and I still can't see, I feel competent enough to fly an approach down to 800-1000 feet AAL. That's exactly what the IMCR allows me to do, and safely I reckon.

IMCR can be much more than a "get you home" rating; it allows you to fly safely on many UK days where VFR flying would be risky. But it's not "IFR-Lite". And it certainly isn't en-route IFR; I think that's pretty much irrelevant to UK flying.

[bookworm]

Have they really? I've see that old chestnut in many articles written about the IMC rating, but you tell me where the CAA makes such a statement.

This is the closest I've seen:

Safety Sense Leaflet 23: Pilots: It's Your Decision

More than three quarters of the
pilots killed when they lost control in
IMC were flying in instrument
conditions without an instrument
qualification. Disorientation can affect
anyone, particularly those who have
not been adequately trained to fly on
instruments, and kept in practice. It
is important to be able to see and
recognise cloud ahead early enough
to avoid it safely. Even an IMC rating
does not impart sufficient skill for
prolonged, intentional flight in
instrument conditions. Unless you are
in regular instrument flying practice it
should only be regarded as a
minimum skill to ‘get out of trouble’
if an unintentional excursion into IMC
occurs.

"Unless you are in regular instrument flying practice" is, of course, an important conditional.

[mm_flynn]

Thank you BW.

My recollection is GASIL and SafetySense both make these type of comments periodically.

I don't agree with the comments - my point was simply there have been a number of people who advocate this limited role of the IMCr (and a reasonable number of pilots who seem to agree), and this view is likely to result in a lower fraction of IMCr operations occurring in hard IMC than IR operations.

However, I do agree with IO's point that trogging around at 2500 feet in turbulent IMC (and IMCr) is much harder than having a coffee at F100 in an airway and glorious sunshine (an IR).

[englishal]

The reason I say "not for public transport operations" rather than "PPL/IR" is so that a CPL holder, or indeed an FI could hold one. In the case of an FI, they *should* have some sort of instrument qualification for safety but what you find in the UK is that many of them get the IR and a year later let it lapse until they get into the Boeing - something quite rare in the USA where the majority of FI's also have an IR (I don't know any without). A CPL holder who, for example, does stuff like aerial photography, aircraft deliveries etc. and doesn't normally need a full IR, should probably hold some sort of IQ in case the sh*t hits the fan.

A EIR with precision approach capability would be perfect in these cases.

[IO540]

I have resisited, waiting for the EASA situation to develop

Lots of people have done that. Bad move. Even from now, you would have 3 years to the earliest possible EASA attack on the FAA route. 3 years of priceless IFR around Europe.

you tell me where the CAA makes such a statement.

It has been repeated in many publications. As well as bookworm's example, there is GASIL and GASCO - both written to read like they are written by the CAA itself, distributed to the G-INFO database which is obtained from the CAA, so in effect CAA-sponsored.

It's a very tiresome statement to find around the place, over and over.

IMCR can be much more than a "get you home" rating; it allows you to fly safely on many UK days where VFR flying would be risky. But it's not "IFR-Lite".

Why not??? What is the actual operational difference? Having to work out Eurocontrol routings?

And it certainly isn't en-route IFR; I think that's pretty much irrelevant to UK flying.

Only because one "can" fly around the UK in Class G, at low levels. But a reasonably long trip is possible in the UK, south to Scotland can be 500nm. Why not fly it full IFR?

[FREDAcheck]

Quote:

IMCR can be much more than a "get you home" rating; it allows you to fly safely on many UK days where VFR flying would be risky. But it's not "IFR-Lite".

Why not??? What is the actual operational difference? Having to work out Eurocontrol routings?

I expressed myself badly. I meant, it doesn't have to be an IFR-Lite; it's useful even at the more limited scope that I described.

Quote:
And it certainly isn't en-route IFR; I think that's pretty much irrelevant to UK flying.

Only because one "can" fly around the UK in Class G, at low levels. But a reasonably long trip is possible in the UK, south to Scotland can be 500nm. Why not fly it full IFR?

I put that badly too! I meant that IMCR enables you to fly on many days when you could not fly VFR. Jim Thorpe's en-route IFR rating doesn't, as unless the cloudbase is high enough to guarantee it will remain above MSA then you can't use it. And if the weather is that good, you could fly VFR below.

But nothing wrong with long IFR trips in the UK on IMCR - I've certainly done that myself on many occasions. But I'm cautious to make sure that TAFs are good enough that I won't have to risk an instrument approach below my personal minimum of 800 feet.

[dublinpilot]

AIUI, it is politically absolutely vital to not give the "god appointed guardians of IR purity" any excuse for saying they are sharing airspace with less capable users, as that would lead to segregation by airspace class, which would destroy the private IR.

Agreed.

But I'd also point out that they have no problem sharing the airspace with both IMCR pilots and VFR only pilots, and pilots of deregulated aircraft, when it suits them

Some regularly jump through class G airspace to save some fuel.
Other in fact operate out of class G airspace to make some profits.

They are already sharing the airspace

I agree though, that that such an argument is not likely to bear fruit

[Fuji Abound]

"Unless you are in regular instrument flying practice" is, of course, an important conditional.

In any event I would hazard as relevant to an IRated pilot as one with an IR.

I am afraid IF does not make hostages of pilots flying in conditions beyond their currency nor does it check their rating.

[englishal]

"Unless you are in regular instrument flying practice" is, of course, an important conditional.

I disagree.It goes back to the self limiting "private IR".

If one is current then one can go off and fly a profile / approach down to minimums in bad weather.

If one is feeling a uncurrent, then Darwin suggests that most people wouldn't go off and do this. They may head out into some gentle IMC to refresh their skills, or employ an instructor or take a safety pilot with them. Certainly when I haven't been flying instruments for a while, I do the FAA IPC through choice (and to renew my IMCr).....

That is the beauty about private flying - one can choose whether to go or not, what weather to go in, and who to go with.

[Fuji Abound]

So back to the original question I asked.

Its odd no one seems to know much about Jim Thorpe.

It seems to me if he is one of those representing UK interests on FCL008 we would have a good idea who he represents, whether he has the mandate of that organisation and how the European en route IMC rating was developed.

Is he on a personal crusade or does he have a much wider mandate?

(and I dont mean in the sense do we agree or disagree with the enroute IMC, we have already debated that one, rather where was the forum in which the idea was developed and debated, and which organisations, if any, support the rating)

[Edited to add which on reflection I must have asked on another thread ]

[mm_flynn]

Fuji,

Are you an active member (as in attend AGMs, working meetings, write/email/call the executives to express views) of any of the aviation groups?

As far as I can tell, AOPA, IAOPA, PPL/IR, EAS have all had extensive discussions at executive and with involved membership and generally agreed a desired outcome.

I know this doesn't fit with your view (and several others on these threads), but a rating like the IMCr is pretty much impossible to get to fly within the airspace structures and regulatory philosophy of the rest of Europe. This shouldn't really be a surprise given the UKs approach to IFR and consequent airspace logic is pretty much unique in the world.

There may be a need to fudge it in order to facilitate retaining the IMCr in the UK - but that is very different than getting a useful new capability in the rest of Europe.

The key issue is making the IR more sensible, and this would over the long run solve several issues in European GA. On the path, their may be a reason for an intermediate step (and many people continue to argue for that). The 'chocolate teapot' is a proposal in that direction (but is defenitely not an IMCr replacement) - I have no idea what the view of European pilots is to the EIR.

The more UK centric organisations arae mounting the challange to retain the IMCr pretty much unchanged. And I hope they succeed. But the European organisations are working on how to move forward over the long run - which I think is probably the more important victory to secure (and I suspect the EIR isn't really an important part of this objective).