IMC Rating News

[Mike Cross]

For those who are not AOPA members and therefore do not see the magazine here are a couple of links to pdf 's of articles in the current issue. These are provided with the consent of the publisher.

I know the IMC is an emotive issue, please curb your emotions and comply with Flyer's rules, a lack of personal attacks and abuse would be appreciated.

The files are quite big (300 and 700k) so don't try this on a mobile device!

http://www.joinaopa.com/Documents/AWFU1.pdf
http://www.joinaopa.com/Documents/IMCletters.pdf

[AFSAG]

thanks for the links.
At present, with my IMC rating, if the destination airport is below minimums for VFR, but above minima for me with my IMCR I can legally conduct an approach and land. Am I correct in thinking that if the IMCR is not retained, and instead I am granted the EIR this will no longer be possible, and I will need to divert elsewhere? As there do not appear to have been any significant number of incidents attributable to IMCR holders continuing an approach unwisely, what is the safety case for this step? I appreciate there may be a European harmonization issue, but I can't understand the safety case. Please note, I make no comment about taking off intentionally into IMC or otherwise, and dont wish to open the debate about intentional, planned IMC flight vs unexpected IMC flight.
If the above is correct I dont see how anyone can ignore a safety case on the grounds of European harmonization.
Maybe my best option is to go and do the full IR, I enjoy the bookwork, can afford it over a year or 2, and like to think I will use it regularly enough, and at least won't be in limbo whilst EASA deliberates. What do people think?

[bookworm]

Maybe my best option is to go and do the full IR, I enjoy the bookwork, can afford it over a year or 2, and like to think I will use it regularly enough, and at least won't be in limbo whilst EASA deliberates. What do people think?

I don't understand why you'd do that. All the proposals at EASA are to make the IR considerably more attainable. Your IMC rating will remain valid "whilst EASA deliberates", and you'll be in a much better position to make a decision after their opinion is published later this year. It seems very unlikely that EASA will make it harder to get an IR.

[IMCR]

Bookworm

Exactly.

[Mike Cross]

I'm told that at a meeting yesterday the new CEO of the CAA Andrew Haines said that the policy of the CAA is to fully support the IMC rating and that Mike Smethers, who is chair of the EASA management
board and a member of the CAA board, has been asked to find a way forward.

Don't let that stop anyone from campaigning.

[derekf]

I fully support the campaign to save the IMCR in the UK, and I fully support the FCL.008 initiatives for a more attainable IR (and the modular interim euro-wide EIR) - both different issues and both need fully supporting.
I'm just a little disappointed that AOPA are still banging on about 'one person' on FCL.008 attempting to 'get rid' of the IMCR and this despite the fact they had a rep on the same committee. I don't want to get back into the individual discussions again (done to death in previous threads) but disappointing the the author(s) need to keep peddling the same rubbish in otherwise good articles.

[Bald Sparrow]

Don't let that stop anyone from campaigning.

Results of my letter campaign so far are:

Letter and email to Eric Sivel at EASA - no reply

Letter to UKIP MEP's - no reply

Letter to my MP - acknowledged saying he will get back to me (and, to his credit, I am sure he will).

[G-BLEW]

I've just read the following in the current IAOPA newsletter

The CAA’s explicit statement has given great heart to the campaign to save the IMC rating, a 15-hour flying course which teaches pilots to keep control of an aircraft in cloud and to land safely. It confers no additional privileges over the PPL apart from a small reduction in visibility minima, which are higher in the UK than in much of Europe.

My bold.

Could someone please explain this to me? If the only difference was a reduction in visibility minima then that would be easily dealt with. The IMCr allows holders to fly enroute in IMC and to fly approaches to minima in IMC and I don't see how omitting this fact is helping the cause.

Ian

[ChrisShackleton]

I fully support the IMC and its intentions, but its a shame that as a holder of an NPPL (a CAA licence) I am not allowed to add this rating to it.

So when I read things like 'when the inevitable happens & a PPL strays into IMC' (or similar) I wonder if I should stop flying before I become an accident statistic.

Is AOPA working on this at all? I guess not.

Chris

[Mike Cross]

Ian

My understanding is that it works like this:-

In the UK
There are bits of airspace that you can fly in as a PPL. That includes class D and below.
There are bits of airspace that you can't fly in without an IR, that includes Class A, or classes B & C when compliance with IFR is required.

License privileges generally say "He shall not....."

unless his licence includes an instrument rating (aeroplane), fly as pilot in
command or co-pilot of such an aeroplane flying in Class A, B or C airspace in
circumstances which require compliance with the Instrument Flight Rules

VFR is not permitted in Class A in the UK so flight in Class A is "circumstances which require compliance with the Instrument Flight Rules"

ROAR Rules 27 and 28 set out the visibility requirements for VFR flight. They relate to flight visibility and separation from cloud. If you cannot meet these requirements then you must fly under IFR.

An IMCR allow you to fly in class D and below in circumstances where compliance with IFR is required. IFR is required if the visibility is below the limits for VMC, therefore the privileges of the IMCR are to allow flight in Class D and below when visibility is below the VFR minima. Hence "It confers no additional privileges over the PPL apart from a small reduction in visibility minima". I suppose you could argue over whether the reduction is "small".

People's perception is that the IMC allows you to fly in circumstances when an IR is required in Class D and below, which is incorrect. The result is that people compare the training and theoretical knowledge requirements of the IMCR and IR rather than the training and TK requirements of the IMCR against the PPL.

[G-BLEW]

People's perception is that the IMC allows you to fly in circumstances when an IR is required in Class D and below, which is incorrect.

An IMCr holder can fly in IMC enoute or can fly an approach in IMC in class D or below. A PPL can't (legally) do that. Surely that's a significant extra privilege?

What can an IR holder do in class D and below in the UK that an IMCr holder cannot?

Ian

[AndyR]

Land and take off in lower visibility conditions would be one surely?

[Mike Cross]

What can an IR holder do in class D and below in the UK that an IMCr holder cannot?

Not being instrument rated I'm not overly familiar with the limitations but I suspect the legal answer is nothing. The licence privileges say you need an IR or an IMCR to fly in circumstances where compliance with IFR is required in Class D or below. In Classes A B or C you need an IR, an IMCR won't cut the mustard. In vis below VFR minima a plain Vanilla PPL is excluded not because of the class of airspace but because compliance with IFR is required and his licence priviliges say he can't fly in those circumstances wihout an IMCR or IR.

[G-BLEW]

Yup, you're right, there's the 1800m restriction. Still a bit concerned that there's no mention of any approach privileges. Don't get me wrong, I fully support AOPA in its efforts to retains the IMCr in the UK. I just don't understand the statement that a small reduction in visibility minima is the only difference betwen an IMCr and a PPL.

Ian
.

[Mike Cross]

Not sure what you mean by "approach privileges" can you point me at a bit of legislation that refers to them? Nowt that I can see in licence privileges on the subject.

The bits I know about are Rule 26

26. For the purposes of an aircraft taking off from or approaching to land at an aerodrome within
Class B, Class C, or Class D airspace, the visibility, if any, communicated to the commander of
the aircraft by the appropriate air traffic control unit shall be taken to be the flight visibility for the
time being.

and Rule 36 that says

36.—(1) Subject to paragraph (2), the commander of the aircraft shall fly in conformity with—

.......

(b) the instrument departure procedures notified in relation to the aerodrome of departure;
and
(c) the holding and instrument approach procedures notified in relation to the aerodrome of
destination.

(2) The commander of the aircraft shall not be required to comply with paragraph (1) if—
(a) he is able to fly in uninterrupted Visual Meteorological Conditions for so long as he
remains in controlled airspace; and
(b) he has informed the appropriate air traffic control unit of his intention to continue the
flight in compliance with Visual Flight Rules and has requested that unit to cancel his
flight plan.

If I fly into Bournemouth I don't have to fly the approach procedure if I can maintain VMC. If I can't maintain VMC then compliance with IFR is required, I can't fly in there unless I have an IMCR or IR and I must fly the procedure.