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Part-NCO summarized

On a completely unrelated note, and just to change the subject: This is a picture that I took in May of the Senjatrollet, the world’s largest troll. It lives on the beautiful Norwegian island of Senja and even has its own entry in the Guiness Book of World Records! The nearest airfield to visit Senja is Bardufoss, where you can get rental cars. It’s still over an hour’s drive to the island, but well worth it.


The light wasn’t ideal in the morning, but at least the visit was still free since the park was just about to open for the season.

Must get this trip report written some day…

Rwy20 wrote:

Must get this trip report written some day…

Looking forward to read it!

ESSZ, Sweden

Peter wrote:


1) Page 2 – The “established or resident in an EASA member state” – where is the reference for those words?

I see your point, I think. It’s certainly intended, though the cover regulation of 965/2012 includes explicit mention of BR Article 4(1)(c) operators (the established and resident ones) for CAT, but not for NCO/NCC. I wouldn’t rely on that.

2) Page 7 – ELA2 is given as less than 2000kg. Elsewhere here, in the ELA1/2 threads, 2700kg or so has been mentioned as the ELA2 limit.

Then the other threads are wrong. It’s defined in Part-21.

3) Page 11 -
Only one 8.33 radio is required. There are still major avionics shops which tell you this is wrong. Somebody needs to educate them.

To be clear, duplication is not required by Part-NCO. There may be other considerations.

Life jackets are required in SEPs when out of glide range. Do they need to be worn, or merely carried?

“shall be worn or stowed in a position that is readily accessible from the seat or berth of the person for whose use it is provided”

“The relevant PBN navigation specification…” – this is a clear statement of the need to have an AFMS approving BRNAV, GPS approaches, etc. Most GA planes don’t have this.

Consider the extensive GM on that.

“Any navigational database … must be current” – this is of interest to those whose GPS AFMS authorises flying with an out of date database cycle provided the pilot has verified the IAPs etc have not actually changed. The relevance of this is on a ramp check by a well briefed policeman who is out to get you

Again, consider the GM in AMC2 NCO.GEN.105

(d) An expired database may only be used if the following conditions are satisfied:
(1) the pilot-in-command has confirmed that the parts of the database which are intended to be used
during the flight and any contingencies that are reasonable to expect are not changed in the
current version;
(2) any NOTAMs associated with the navigational data are taken into account;
(3) maps and charts corresponding to those parts of the flight are current and have not been
amended since the last cycle;
(4) any MEL limitations, where available, are observed; and
(5) the database has expired by no more than 28 days.

Laws which seek to impose a restriction have to be read as they are written, and the benefit of an ambiguity is construed against the party seeking to impose the restriction

Jason – the default position under the law (of any civilised country; I am not 100% sure that applies to all of what we call “Europe”) has to be like that. If I draft a law saying you have to wear yellow underpants while flying your Mustang, then immediately you know that you are OK if wearing black ones, or flying a PA28. That’s even if it is obvious that my intent was just to make sure you are wearing underpants of some sort. If I then see you flying with black underpants, and don’t like it, and my prosecution has failed (obviously) I can take you to a higher court and try to generate some case law, or in due course try to re-draft the original law. But as I say the initial prosecution is almost certain to fail.

Contra proferentem is a principle of contract law. It’s not a principle of interpretation of criminal laws and codes.

LeSving wrote:

Maybe “no visual horizon” has a special meaning in the UK, I don’t know. But “no visual horizon” is literally not what NCO.IDE.120.A is about. It’s exclusively about your ability to navigate without additional (navigational) instruments. The questions this rises is what about a moving map app on a pad, is that “additional instruments” ? IMO it is not, additional instruments must be ADF/VOR/DME/IFR GPS or something else installed in the airplane.

Gosh, what a lot of heat about a few words! In my defence, anyone who attempts a summary of legislation is bound to apply some interpretation, otherwise the only possibility is to quote the rules in full. That’s what you got here.

The ICAO Annex 6 Part II wording refers to:

“All aeroplanes when operated in accordance with the instrument flight rules, or when the aeroplane cannot be maintained in a desired attitude without reference to one or more flight instruments, …”

The NPA and the early drafts use these words, and I think it’s quite clear what it means (a need to supplement visual cues with flight instruments to stay the right way up, which I abbreviate to “no visual horizon”). I believe that remains the intention of the rule. It is certainly not intended to refer to navigation equipment. But somewhere along the line it got changed to

“or in conditions where the aeroplane cannot be maintained in a desired flight path without reference to one or more additional instruments”

I can’t see any reference to it in the explanatory note. I didn’t read that as anything different. The extra instruments, after all, refer to vertical speed and stabilised heading, which is not about attitude, so I can imagine someone took issue with that aspect and the wording got changed. But the word “additional” may be significant, I think.

I’ll make some enquiries and see if I can find out what happened.

Gosh, what a lot of heat about a few words! In my defence, anyone who attempts a summary of legislation is bound to apply some interpretation, otherwise the only possibility is to quote the rules in full.

Don’t worry, no need to defend anything here. Everybody who knows what the term summary means, knows that…

Mainz (EDFZ) & Egelsbach (EDFE), Germany

bookworm wrote:

Gosh, what a lot of heat about a few words! In my defence, anyone who attempts a summary of legislation is bound to apply some interpretation, otherwise the only possibility is to quote the rules in full. That’s what you got here.

Well, seems the heat is directed directly towards me (as usual) for being so “free spirited” as to question you. But, let’s put that aside. My objection is that the summary changes the meaning of the wordings in the regulations.

NCO.IDE.A.120 b) does indeed read:

Aeroplanes operated under visual meteorological conditions (VMC) at night, or in conditions where the aeroplane cannot be maintained in a desired flight path without reference to one or more additional instruments, shall be, in addition to (a), equipped with: (the list of equipment)

Which is a rather compact sentence with lots of information. However, the meaning is seemingly rather clear, and it is also repeated in 120 c) IMO, a summary should expand a bit on this, because everything after the first comma is new to everyone. VFR on top (for instance) requires full N-VFR equipment with Part NCO. But it also raises some questions. For instance, if you navigate exclusively with a nav app, which most do, can the airplane be maintained (by the pilot) in the desired flight path without the nav app? Or, is a nav app not part of what is referred to as “additional instruments” ? If a nav app is not part of “additional instruments”, then you cannot use a nav app for flying on top, even if you have all the additional equipment in 120 b, which means you also need IFR avionics of some sort. And it’s not only for on top, it’s for any conceivable condition.

The elephant is the circulation
ENVA ENOP ENMO, Norway

LeSving… you are being too verbose for what is quite a simple issue. Flight path means trajectory. Trajectory <> navigation.

LeSving wrote:

Well, seems the heat is directed directly towards me (as usual) for being so “free spirited” as to question you.

It is amazing how you interpret sentences in English in the most creative ways. Frankly I think it would be the same in Norwegian. I think you suffer from tunnel vision

LeSving wrote:

I disagree. Part NCO is very specific about what is meant, and it is: the aeroplane cannot be maintained in a desired flight path without reference to one or more additional instruments

This is very different from: or where there is no visual horizon

No it is not, and I am going to try to explain why.

What does that even mean? “no visual horizon” ? There is no visual horizon flying in valleys and lower than the mountain tops, but visual navigation is fully possible.

It means that you are not able to distinguish where up and down are.

LeSving wrote:

Or, is a nav app not part of what is referred to as “additional instruments” ? If a nav app is not part of “additional instruments”, then you cannot use a nav app for flying on top, even if you have all the additional equipment in 120 b, which means you also need IFR avionics of some sort. And it’s not only for on top, it’s for any conceivable condition.

Why are you so focused on navigation? When you are struggling to maintain the blue side up, navigation is the least of your concerns.In any event, where does this particular section of Part-NCO mention anything about on-top?

Maintaining a flight path does not refer to the projection of your flight path on the ground. It means keeping the blue side up; control attitude, altitude and heading.

(b) Aeroplanes operated under visual meteorological conditions (VMC) over water and out of sight of the land,
Over water, if you do not see land, you may have a white-out condition where it is extremely difficult, if not impossible, to distinguish sea from sky, for example on a hazy day over the Channel, Skagerak or between Bodø and Leknes to pick a couple of examples closer to home. So although you technically comply with VMC in terms of 5+ km visibility and distance from clouds, you are effectively in instrument conditions. Please note that this cannot be interpreted as referring to VFR on-top.

or under VMC at night,
at night it can be difficult to determine where is up and down if there is no visible light on the ground, or even if there is you may get “false” horizons

or in conditions where the aeroplane cannot be maintained in a desired flight path without reference to one or more additional instruments,
This refers to any conditions where it might be difficult to keep the blue side up (the “blue side” refers to one half of the attitude indicator which were blue and black)…

shall be, in addition to (a), equipped with:
(1) a means of measuring and displaying the following:

…and in that case you need some attitude instruments to replace the lack of a visual horizon.

(i) turn and slip;
Believe it or not, this is an attitude instrument and can be used as a back-up for the AI together with the Altimeter and/or VSI. That said, a pilot that has not received IMC training (partial panel) would probably be screwed if the AI went booom. Many pilots with IMC training have.

(ii) attitude;
This is the attitude instrument by excellence.

(iii) vertical speed; and
Together with the turn and slip it constitutes a back-up for the AI. It allows the pilot to verify that the AI indication is correct.

(iv) stabilised heading;
(2) a means of indicating when the supply of power to the gyroscopic instruments is not adequate; an
(3) a means of preventing malfunction of the airspeed indicating system required in (a)(4) due to condensation or icing.
Your instruments do you no good if they do not work

So the purpose of this is to say that if you plan a flight where there is any risk that you may not have a visual horizon, you need instruments that will replace this visual horizon. It has NOTHING to do with navigation, hence your iPad is irrelevant.

This is very different from: or where there is no visual horizon

No. That is exactly what it means. It has everything to do with a visual horizon.

Last Edited by Aviathor at 29 Aug 06:57
LFPT, LFPN

Shorrick_Mk2 wrote:

Flight path means trajectory. Trajectory <> navigation.

The term “flight path” alone could be interpreted as (including) navigation, but the fact that part-NCO has a separate rule (NCO.IDE.A.195) concerning equipment for “Navigation” makes it clear that is not intended.

Also, the use of the term in other parts of EU-OPS (part-NCC and part-CAT) confirms this.

Last Edited by Airborne_Again at 29 Aug 07:14
ESKC (Uppsala/Sundbro), Sweden

Thank you to those who have tried to put this concept in other words with such patience.

Upon reading the requirements for flight over water again (and again ), I noticed that this may be quite prescriptive as to the functional equipment that you need to have. I have seen planes with three independent artificial horizons, one of which operated by vacuum pumps and the two other on independent electrical circuits. But according to Part NCO, you would still need a turn coordinator on such a plane, right? Or could you make use of some pilot’s discrection and declare that you have an equivalent level of safety with such a plane? (I would even argue it would be a better level of safety.)

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