Over the last few months since I became aware of how much debate the fr.only situation was causing I have discussed the points put forward in euroga at every opportunity. I have spoken with club members, instructors, examiners and a couple of DGAC employees.
They tend to just smile give a shrug and don’t really understand the problem. If I say that pilots are concerned that the air police might cause them problems, they laugh and the comments go from highly unlikely at worst to a that wont happen.
There are many pilots flying into fr.only airports regularly, from all over Europe, I would think there are quite a few on this forum, perhaps they would say if they had ever been approached by the air police with regard to use of the French language and what happened.
The latest posts about use of an interpreter. I know there are many people here who have experience of writing rules, and know how difficult it is to draft a set of rules which are not too draconian but at the same time get across the point.
If we disect the rule. First why are there French only airfields. The answer is safety.
There are around 560 CAP airfields in France. That is airfields open to the civil aviation public. The fr.only is split between three types of airfield operation.
1/ Small fields owned by local councils and operated by the local club, with no tower, no fixed ground to air radio.Such as LFFK
2/ International airports out of hours, when they become class G, again no ground to air radio eg. La Rochelle
3/ An airfield where the AFIS is employed by the local council who can only communicate in French and when the AFIS is not around is still open to traffic.
In all three cases some 90 odd percent of the traffic is flown by French pilots of whom only about 10% speak English.
Up until about some 10 years ago all these situations would have been non radio but the regulators looked at each situation and decided where it would be safer if pilots gave position reports on the radio following the US model in some ways but that it would be less safe if French was not predominant.
So to return to interpreters.There are different meanings to the term interpreter. There are those who are simply bilingual and those who translate legal documents for state bodies and must appear on an official list of approved translators. The regulation we are talking about here, deliberately in my opinion, does not specify.
So if you are flying into any of the above mentioned airfields, except during the AFIS hours in 3/ above an interpreter could be covered by the pilots partner reading from a crib sheet (even taken from Babel or google) as long as they do it with the correct aeronautical phraseology. The regulation does not say that the interpreter needs to be a pilot or take over as PIC or have an R/t licence or even that the interpreter should be human.
The same is true of the AFIS in 3/ , however, common sense says that the interpreter would have to be a bit more fluent in the French language.
I and many of the people I have spoken to are of the opinion that this is why this regulation was written the way was and positioned where it is.
gallois wrote:
The regulation does not say that the interpreter needs to be a pilot or take over as PIC or have an R/t licence or even that the interpreter should be human.
“Alexa, say request joining information in French”
gallois wrote:
The regulation does not say that the interpreter needs to be a pilot or take over as PIC or have an R/t licence or even that the interpreter should be human.
To me, “qualifié pour utiliser la radiotéléphonie” sounds like someone that is trained to use R/T. Whether that means a R/T licence is not 100% clear either way, but I wouldn’t bet it doesn’t. I think as a matter of general law, emitting on this frequency range requires a licence, punto basta. That’s why we, as pilots, get a R/T licence as part of our pilot licence, that’s why AFIS people have a licence, etc. In Luxembourg, “travailleur qualifié” means having a job that requires a diploma of a certain level. And the French version of FCL says “pilot qualifié”, “instructeur qualifié” and “examinateur qualifié”, which I take each time to mean “having the necessary licence, or rating in the licence”.
“doit connaître les expressions conventionnelles et usuelles” sounds to me like someone that knows specifically French aeronautical phraseology. That knowledge can come from reading the phraseology guide on the DGAC, I see no requirement for official recognition of that fact.
My guess is that this was not written with the private pilot coming into a French-only field in mind, but more organised crews and operators (such as commercial transport), and this is the formal way of saying:
Whether this would be enforced is another question altogether. In Luxembourg, “I know a person that knows a person that knows a person that got into trouble in France for not having French LP in their licence and having used French on the radio, even at a non-French only airfield”. So we make efforts to get French LP in our (Luxembourgish) licences, or carry around a letter from the (French) DGAC recognising us French LP, … What “trouble”? Don’t know. Maybe just a stern talking to by a ramp checker / gendarme / …, but the gendarme was actually wrong on the law. Happened for intra-Schengen flight “immigration requirements” (Deauville airport still told me I should show my ID to the friendly officers sitting in the office next door because intra-Schengen but international flight), may happen / have happened for LP issues.
Lionel I would love to hear more about the person who had the French LP problem, and when.
I agree with you that the words qualified in R/t confuses. But I don’t recall having to have r/t in the brevet de base, and I’m not sure it is part of the Ulm licence. Of course as a student pilot you didn’t get the r/t stamp until you passed the PPL. You could I suppose argue that the instructor is PIC and therefore there is an r/t qualified person on board, but surely the same argument holds true of a pilot and interpreter. So perhaps you are correct and that line is more aimed at commercial traffic. Most of the airfields in question do not have ramp checkers they normally don’t have anybody at the times when fr.only would apply. In some ways, that’s the point.
Jacko wrote:
I agree that nobody in France gives two hoots about this
It is more an “amplified version of thing to watch or gotchas” while in flying France coming mainly from neighbour Brits visitors 
(of course there are closed airfields in France that will use that “french only” pretext to kick anyone out, but for most other nobody really cares)
Talking on ULMs in France, there is also that famous ban on ULMs inside big airports CTRs (mainly with the RT compliance pretext)
I have seen some around in big places where no one cares to check that it has a MTOW>650kg and stall>42kts
Have you even seen the checklist of legal things you need to have/watch for before driving a G-reg car in France (I spent a decade with a car in Paris, I never noticed that you need to go that deep until I crossed la Manche the opposite way from Folkstone to Calais 
)
Thanks for putting me right Jacko.Like many of us here, some years ago we were able to take our PPL’s to the local DGAC office and get a Brevet ULM by equivalence.I didn’t bother and so have not really studied an up to date ULM licence.I am assuming it is the instructor that signs you off as apt for the r/t. Does it also mean that you get level 6 French language proficiency as you would if you did your PPL training in France?
Ibra, are there different rules for driving a Brit reg car in France from driving a French reg car? (Sorry off topic, but interested)
Over the last few months since I became aware of how much debate the fr.only situation was causing I have discussed the points put forward in euroga at every opportunity
This debate is NOT limited to EuroGA and it should not be a debate at all. But it has been since all the time I can remember since I started back flying in 2009.
The first thing I saw about this was that a very highly respected airline pilot and chief instructor at a popular aeroclub in Switzerland was grounded by air police for the lack of French LP and forced to organize a French instructor to fly out of an airfield they had used for decades without problems. He was there with a Stearman also not the first time. This was approximately in 2010. I knew this guy personally and i challenge anyone calling him a capable of telling fake stories. He was one of the very best guys we had in GA in Switzerland and there were over 1000 folks at his funeral after he died in a mid air 2 year ago.
In that discussion, it transpired that the swiss FOCA hurried to provide French LP on the request of several aeroclubs in the Geneva Area because their members had been harassed and they had to abandon airplanes at French aerodromes nearby, again after decades of practice. Now these were French mothertongue people who had the Swiss license but who had never realized there even was french LP.
At that time, as I say around 2010 or so, the discussion triggered and MANY people desisted of flying to France as a consequence. Out of fear of retribution but also out of principle as they understood that the FR only rule meant they were not welcome there anymore. Again, calling all these stories lies is too cheap, there were too many of them for them all to be fake and I personally heard them from people I would trust with my life. They had NO reason to make this up. None, whatsoever.
They were threatened with huge fines but I never had a written proof that anyone has been fined. So what I think it was at the time was action by local air police or local airfield kings who wanted to retribute for being forced to do the English LP, which as you say many French people refuse to do, again mostly out of principle rather than ability. It nevertheless left a very bad feeling with many GA pilots particularly in the German and English speaking world where people are generally law abiding and “laisser faire” is an unknown concept.
I realize that after these discussions, many people have inquired with the DGAC and elsewhere and always got the answer that they did not know of the problem. What I think happened is that the local enforcers got slapped on their hands and told off for what they had done or maybe were simply informed that this was not official DGAC policy, but neither the DGAC nor any other legal organisation like for instance EASA ever openly commented on this in a binding way. When I adressed this at a EASA GA roadmap meeting in 2017, the speaker there said he was “aware of the problem” but could not provide a binding answer.
So people flying to FR only airfields have been in legal limbo and at the mercy of local police men either real or self appointed. If there have been no more reports, this would mean that either the air police are not sure either and desist hassling foreign pilots on this matter or have been told not to. What would have been a good sign would have been for the DGAC to write a binding opinion on this matter which would have reassured people on the matter.
The safety aspect is another matter. Nationalism and protectionism yet another. But if you see how strict people are preparing their flights, up to emailing airports or calling ahead for absolutely straightforward stuff such as parking permissions e.t.c. because some airports have their underwear in a twist on the subject, then you can imagine that there is nothng which pilots hate more than legal incertitude.
My personal uptake has been to avoid FR only airports as I do not have enough skills to fluently understand and speak French Rt despite being fluent in French conversation and because I feel that the whole FR only issue means also that those places don’t want foreign traffic but rather have the place to themselfs. Add to that the much worsened situation about customs out of Switzerland, I have not found it necessary to revisit my formerly favorite hangouts but have decided to fly in more welcome countries. Thankfully the rest of Europe gladly respects English RT and therefore the loss of France as a preferred destination did not hurt me too much.
Your effort is to be commended but unless the DGAC finally makes a very clear statement, this discussion will not go away.
I am not sure I understand you. I have never hinted that anyone is lying.I just felt that I would be better armed with facts rather than anecdotes when debating the point with people from the dgac or others.
Back in the early 1990’s there was a QRI (commercial) and a QRRI(private) exam, depending on whether you were commercial or private you had to pass one these English language exams before you could fly outside France or its territories.
Later(I don’t remember the dates) these exams were scrapped and replaced with an honour system ie you decided whether your English was good enough to fly outside France. This was replaced a few years later with Fcl 1.028. I think there was some confusion at this time and it was certainly thought necessary, by the Dgac for pilots flying in France to have minimum level 4 French language proficiency. All pilots with French mother tongue were automatically level 6 as was any pilot trained in France.The fact that the Swiss CAA would not add FLP to the licence of a pilot whose mothertongue was French surely cannot be laid at the door of the French Dgac. I was always of the impression that the police did not enforce the need for level 4 FLP to fly in France very strongly. Your post changes that but does not give any details, where, when and what happened.
With Easa came the fcl055 and from study of the AIP and from posts on this forum, particularly from Jim Bordeaux the notion of FLP level 4 or above appears to have quietly slipped away, except for French pilots or French trained pilots.
It would seem from the people I have questioned and from the debate within this thread if you feel confident enough to self announce positions in French or have a translator with knowledge of aeronautical phraseology, there is no legal reason why you should not fly to a fr.only airfield or one which fr.only out of ATS hours.
I think the idea of pilots, in their own country , being able to use airports even many International ones when there is no ATS, when in some countries the airport would be closed to all traffic, is a positive thing, even if you do have to self announce in the dreaded French language.
If you don’t want to do that there are many airfields around France where in normal airfield working hours you can speak to someone in English. In fact I would suggest that there are as many such airfields as there are in Switzerland or Germany.
It is every pilots choice to fly to France or not.Customs airfields have little or nothing to do with the subject of fr.only airfields, I would suggest, but if you do have examples of fr.only leading to penalties I would gladly take it up with the people I know from the FFA and DGAC. I can’t guarantee any positive results and I do not believe that it will cause the disappearance of fr.only airfields, the majority of pilots in France enjoy the freedom it brings too much.
Mooney_Driver wrote:
Your effort is to be commended but unless the DGAC finally makes a very clear statement, this discussion will not go away.
They may make a clear statement on it but at the cost of restricting the bellow,
gallois wrote:
I can’t guarantee any positive results and I do not believe that it will cause the disappearance of fr.only airfields, the majority of pilots in France enjoy the freedom it brings too much.
It is usually the argument why not regulate and upgrade them to English? the answer goes along “it is a bunch of local guys”
The same happens for private airstrips I visited in France, the guy give you a form to fill as member and pay 5€ membership a year, then send it to local municipality to keep his airstrip both open/closed without having to go trough the expensive licencing process (he got a complaint one day from neighbors who spotted an OO-reg aircraft and complained about it, so everybody want to keep some low profile)
