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IFR in G in Belgian airspace

Has anyone made or is aware of any successful application to the Belgian CAA based on AIC 003/2018? local copy

The Belgian CAA is expecting a submission of an operator-specific “safety case” for IFR in G in Belgian airspace going forward and I am trying to see whether I can use an existing one (as per sections 4.4 and 4.7).

Separately, an interesting statement in the AIC is


A survey of the European aviation environment shows that the relevant practices applied in, for instance, the members of the European Union are far from uniform and range from bans to unconditional acceptance of such operations. Some States in which the practice is banned are in fact looking at ways of making such operations possible.

Wolfgang

EGTF, EGLK, United Kingdom

This AIC is completely outrageous.

They write


Neither ICAO Annex 2 – Rules of the Air, nor the SERA – Standardized European Rules of the Air contain provisions that would forbid such operations. However, they do not contain guidance about the conditions that should be applied to such operations. In the circumstances, it is up to the National Authorities to allow or prevent such operations and to develop any restrictions or conditions to be applied when conducting such operations.

This is, first of all, wrong, since SERA 6001 explicitly allows IFR in class G

(g) Class G. IFR and VFR flights are permitted and receive flight information service if requested. …

so it is not up to the national authorities to allow or prevent such operations.

Also, the operating rules are set out in Part-NCO, NCC etc and again they cannot make up their own rules. For commercial operators, which need approval for their manuals, they can (within limits) do that, but not for private ops.

An appropriate reply might be to ask them if (a) they intend this to apply to operations under part NCO / NCC, and if so, )b) what law empowers them to make rules in addition to what is contained in SERA or Part-NCO/NCC.

Last Edited by Cobalt at 07 Jun 15:16
Biggin Hill

Indeed. That first paragrapgh could have come straight DFS.

The hogwash that follows makes it totally unpratical for the private flyer of course.

Anyway, I get the impression that this AIC is more geared towards OCAS airport operators that wish to introduce instrument approach procedures, not at all at single pilots wishing to fly enroute IFR OCAS. It looks like the author doesn’t even have that on his scope.

Also, with the existing airspace structure, I am not sure how practical enroute IFR OCAS is. In Belgium, this would mean flying between 1000 feet AGL and 4500 feet MSL, generally. And in that altitude band, there are huge amouts of danger areas, CTRs and TMAs..

Mainz (EDFZ) & Egelsbach (EDFE), Germany

boscomantico wrote:

Also, with the existing airspace structure, I am not sure how practical enroute IFR OCAS is. In Belgium, this would mean flying between 1000 feet AGL and 4500 feet MSL, generally. And in that altitude band, there are huge amouts of danger areas, CTRs and TMAs..

Away from EBBR and EBLG, the “low area flying golf” areas raise G airspace, especially in the south-east. Basically on week-ends, and not to FL95, but still. The higher ones are activated on request of the glider clubs, so I suppose that also brings increased mid-air risks.

Last Edited by lionel at 07 Jun 16:44
ELLX

lionel wrote:

so I suppose that also brings increased mid-air risks.

Not quite sure I follow that reasoning. IFR still requires the see-and-avoid principle when flying in VMC. If in IMC, then there should not normally be any VFR traffic. Or are you referring to a special glider permission to fly in IMC in Class G airspace?

LSZK, Switzerland

boscomantico wrote:

Also, with the existing airspace structure, I am not sure how practical enroute IFR OCAS is. In Belgium, this would mean flying between 1000 feet AGL and 4500 feet MSL, generally. And in that altitude band, there are huge amouts of danger areas, CTRs and TMAs..

Agreed, and the idea here is for icing situations in winter whereby I might like to fly at 3000 ft MSL, e.g. the on the route between KOK and LNO. I do realise that there is the Brussels TMA around Brussels airport for which I would need a standard IFR clearance but then I could fly the rest of L607 route below the MEA in class G. The idea is (if and if necessary due to icing) that as after crossing the English channel I would fly on a standard IFR clearance but have the ability to go below the airway MEA to fly in G when and if necessary. I had to do so around KOK due to icing previously (I think descending to 4000 ft MSL) and Brussels Control had to hand me to Oostende Approach for their TMA. So the idea is that I might want to continue at 4000 ft MSL in G (which technically won’t be allowed anymore starting 2019) and stay with Brussels Control to help me sort out getting through the Brussels TMA by giving me vectors. Without the approval Brussels Control might not accept me flying IFR in class G.

Wolfgang

EGTF, EGLK, United Kingdom

lionel wrote:

Away from EBBR and EBLG, the “low area flying golf” areas raise G airspace, especially in the south-east. Basically on week-ends, and not to FL95, but still. The higher ones are activated on request of the glider clubs, so I suppose that also brings increased mid-air risks.

I am not sure that risk would apply only in class G. I think that risk is almost equal in class E where VFR traffic can fly without radio contact and without transponder. There is obviously no IFR/VFR separation and VFR traffic information is based only on what the controller can see. I had previous IFR flights in Germany at FL60 where I either encountered VFR traffic flying between/around clouds, encountered gliders and even a hot air balloon on the flight path. The see-and-avoid principle applies in VMC conditions, the theoretical reduction of risk in class E is that VFR flights are supposed to follow class E minima instead of class G minima (and minima are the only real protection) but I am highly doubting that VFR pilots can/would properly assess distance to clouds or visibility accurately. So let’s say if I am descending out of a cloud base in class E at 700 ft/min (which is at standard 3-degree descent rate at 140 kts TAS) and the VFR pilot were to properly stick to the 1000ft vertical distance from clouds (vs clear of clouds for class G), I would have around 1 1/2 mins to detect and react to the conflicting VFR traffic.

Comparing flying in Germany vs the UK, I therefore find the discussion around higher mid-air collision risk with VFR traffic in class G vs class E generally rather theoretical and hence try to stay in class A, B, C or D whenever possible. Am happy to be corrected in my thinking that class G vs class E minima make a significant difference when it comes to avoiding mid-air collisions between IFR and VFR traffic.

Wolfgang

EGTF, EGLK, United Kingdom

I don’t think there’s much risk of collision – unless some @sshole is OCAS in IMC with no TAS or ADSB squitter.

Glenswinton, SW Scotland, United Kingdom

Without the approval Brussels Control might not accept me flying IFR in class G

Brussels Control couldn’t care less. They won’t tell if you don’t :-)

EBST, Belgium

Am happy to be corrected in my thinking that class G vs class E minima make a significant difference when it comes to avoiding mid-air collisions between IFR and VFR traffic.

At least 50% of conflicting traffic one sees on TCAS is never spotted visually (in CAVOK conditions) so I doubt it makes any difference.

And if you are in IMC, almost no GA is flying anyway; the traffic density is perhaps 1% of what it would be in VMC. Flying enroute in IMC is very safe.

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Shoreham EGKA, United Kingdom
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