JAA Instrument Rating vs. National IMC Ratings

By Leland Vandervort

For many private pilots in Europe, it is a major goal to attain the Instrument Rating, which extends the privileges of the licence holder to fly in Instrument Meteorological Conditions and under Instrument Flight Rules in uncontrolled and controlled airspace (including Class A airspace, such as TMAs and Airways).  Unfortunately, however, the JAA regulations for attaining the Instrument Rating makes the task, at best, impractical, or at worst, impossible.

Part of the difficulty for the average PPL to obtain a full JAA Instrument Rating lies in the training requirements and regulations.  The JAA makes no distinction between the use of an Instrument Rating for private or commercial purposes.  Unfortunately the training requirements do not lend favourably to the average Private Pilot’s means.

First of all, the JAA stipulates that an approved ground school course of study must be completed and ground exams passed prior to commencement of the Instrument Rating flight training.  For the average PPL, however, this would mean setting aside time for full-time in-residence courses, which are more suited to Commercial Licence candidates.  Yes, many organisations do provide “distance learning” courses; however all of these organisations require a one-week residential course for each module in addition to the distance-learning work.

Furthermore, many of the approved training organisations for the Instrument Rating do not (or will not) perform training for the PPL/IR, but have no problem at all doing Instrument Rating training courses for the CPL/IR, yet just about every training organisation can do the IMC rating.  For the ground training, a number of training organisations place requirements that the ground courses for the Instrument Rating can only be attended in conjunction with a course of study for Commercial Pilots Licence.

Since the average PPL generally does not have the time to dedicate to such residential training, their flying activities being used primarily for leisure and personal use only, the practicality of this training is cumbersome and indeed prohibitive for the majority of PPL holders.

The actual flight-training requirements are long and arduous in addition to the ground courses.  The overall training programme may very well be justified if the pilot were intending to use the same airspace as the “big iron”; in other words Class A controlled airspace in full compliance with Instrument Flight Rules.  The average PPL, however, will have neither the desire to fly in Class A airspace, nor (in most cases) will the average light aircraft be suitably equipped for flight in Class A airspace (i.e. FM immunity, Dual Altimeters, Class 1 avionics, Anti-icing capability, etc.)  In fact, the average PPL will wish to use his instrument experience to avoid being “caught out” in case of deterioration of weather, or to allow cross-country flights under Instrument Flight Rules in either uncontrolled airspace, or lower class controlled airspace (such as class D or E).

As a result of the difficulty for the holder of a Private Pilot’s Licence to feasibly obtain a full JAA Instrument Rating (PPL/IR), many people have been “circumventing” this by obtaining an FAA Restricted PPL and then an FAA Instrument Rating on top of it.  Some people then, whilst in Europe, choose to fly only aircraft on the FAA register, and others take the option of converting the FAA Instrument Rating back to a full JAA Instrument Rating, thus bypassing a large portion of the tedious and bureaucratic pre-requisites.

Several European countries already have a national rating which allows some form of flight in IMC and in some cases allows IFR outside of controlled airspace or even in some classes of controlled airspace.  (None, however, currently allow flight in Class A airspace, which is solely possible, and quite rightly so, with a full Instrument Rating under IFR and with stringent requirements on the aircraft equipment.)  Generally, the training requirements for such a national rating are much less stringent than for the full Instrument Rating, and are thus much more attainable and attractive to the private pilot wishing to operate in IMC and for non-public transport use.

From as early as 1996, the Joint Aviation Authority in Europe had begun working on a blueprint for a Europe-wide version of these national ratings, and initial blueprints included the name “All Weather Rating”.  This rating was to extend the privileges of the JAA PPL to allow the pilot to fly in reduced weather minima, out of sight of the surface, and operate in certain classes of airspace under Instrument Flight Rules.  This rating, however, appears to have been left by the wayside, and nothing has been discussed within the JAA for a few years.  Indeed now that the JAA is being superseded by the new European Aviation Safety Authority (EASA), there is even less movement on the issue.

There appears to be some evidence, however, that the UK IMC rating played a major part in the blueprint for the proposed JAA All Weather Rating, and this may be found by analysing the content of the UK Air Navigation Order.

To explain, refer to the following extract from schedule 8, part B of the UK ANO:

Instrument meteorological conditions rating (aeroplanes) shall within the United Kingdom:

a.    subject to paragraph c, entitle the holder of a United Kingdom Private Pilot’s Licence (Aeroplanes) or a United Kingdom Basic Commercial Pilot’s Licence (aeroplanes) to fly as pilot in command of an aeroplane without being subject to the restrictions contained respectively in paragraphs 2c and f of the privileges of the United Kingdom Private Pilot’s Licence (aeroplanes) or 2b vii or ix of the privileges of the United Kingdom Basic Commercial Pilot’s Licence (aeroplanes).

b.    subject to paragraph c, entitle the holder of a JAR-FCL Private Pilot Licence (aeroplanes) to fly as pilot in command of an aeroplane in Class D or E airspace in circumstances which require compliance with Instrument Flight Rules.

c.    the holder shall not fly:

i.    on a special VFR flight in a control zone in a flight visibility of less than 3 km;

ii.    when the aeroplane is taking off or landing at any place if the flight visibility below cloud is less than 1800 metres.

The interesting thing to note here is paragraph b that specifically permits IFR in class D and E airspace if the rating is attached to the JAR FCL Private Pilots Licence.  This privilege is NOT conferred on the holder of the UK PPL or BCPL.  This difference would be partly due to the former UK PPL and BCPL being replaced by the JAR FCL PPL and CPL, but also it appears that the legislative body had pre-empted the adoption of a similar rating by the JAA.  At a time when there are still in current circulation old UK PPL and BCPL licenses, what is the logic in making the distinction between the old licenses and the new JAR FCL licenses, for a rating which is currently only valid within UK airspace anyway, if not to leave provision for a future JAA rating with similar privileges?

With the specific caveat for the JAA PPL licence in the UK ANO, the UK IMC rating effectively permits flight in instrument meteorological conditions, albeit with a higher minima than for permitted with the full Instrument Rating, and in some classes of controlled airspace (Class D and E) in compliance with Instrument Flight Rules.  In effect, it allows everything that the full Instrument Rating allows other than flight in Class A controlled airspace but carries higher weather minima and decision height restrictions.

The training requirements for the UK IMC rating, and the other national ratings in place in other JAA member states, are considerably more favourable to the average PPL, and correspond more to the type of experience and flight that a PPL holder would be more likely to undertake.  The exact experience and training requirements do differ between the various member countries, but in general they consist of:

• 15 to 20 hours instrument flight training, including full, limited, and partial panel, and emergency operations.
• IFR flight planning and preparation.
• Instrument Navigation and en-route procedures
• Instrument departure, arrival, letdown and approach procedures.
• Holding patterns
• VDF approaches
• NDB approaches
• VOR approaches
• ILS approaches
• Surveillance Radar Approaches
• Precision Radar Approaches (where available)
• Guided self-study for the theoretical requirements applicable to the rating and its application leading to a written examination.
• A flight skills test consisting of pre-flight IFR preparation and an IFR departure (outside class A airspace, obviously), en-route navigation, letdown and approach, missed approach procedures, and emergency procedures.

The problem with these national ratings is that they are valid ONLY within the airspace of the issuing state, thus it is not possible to effect an IFR flight, even outside of controlled airspace and on a flight plan, across international borders while still within the bounds of Europe.

So why have the JAA delayed, or more appropriately, side-lined the “All Weather Rating”, and why is there no sign of discussion at the EASA to take up where the JAA seems to have left off in this regard?  The answer, I am sure, a great proportion of the general aviation community in Europe are anxious to find out.

It is obvious that the average PPL would not really want (or indeed need) the same privileges afforded by the full Instrument Rating.  Quite frankly, I personally wouldn’t take off in only 1800 metres visibility below cloud even if I am just transitioning to instrument flight to climb out through cloud, and I certainly wouldn’t want to attempt an approach on instruments just to break cloud and be visual with the runway but with only 1800 metres visibility except in the very worst of cases.  I think most PPL holders would be wise enough to at least insist on a bit better minima.

I would dearly love to do the I/R rather than the IMC rating (despite not seeing myself ever really wanting to use class-A except perhaps low-level airways en-route, but outside the UK there are class-C and D airways as well).  My biggest gripe is the hoops one has to jump through in Europe just to get the I/R. The process should be made much more PPL-friendly in my opinion. (I am indeed almost tempted to say that I think that the ground school requirement if used for PPL should be guided self-study as well, since all of the ground school material currently in place is also covered in the ATPL anyway, which is the more appropriate place for it.)

I am working on my IMC rating currently with one of the larger FTOs in the UK, and when I expressed an interest in doing the I/R the response was a big "negative.  We only do the IR for the commercial courses."  I can see why a lot of people use the FAA loophole for the instrument rating...