As this subject has come up quite a lot recently I thought this might be of interest:-
gnss_based_instrument_flight_procedures_implementation_for_general_aviation_pdf
Especially for those flying the RNP approach at Ouessant LFEC.
GSA/EGNOS have published some brilliants documents on the topic, from 2019, the one you quoted regarding “AD implementations of RNP to non-INST or non-ATS RWY”
Recently in Oct2021, regarding “legal assessment of IAP to non-INTS or non-ATS RWY”
https://www.euspa.europa.eu/sites/default/files/uploads/safety_assessment_guidelines_for_ga.pdf
Both are some of the best documents on the topic legalities (tells you nothing how to avoid obstacles & traffic in Golf after all it’s in PIC hands in Golf), I think their conclusion the best compromise and way to proceed forward is an RNP-A that terminates with circling & visual manoeuvring and likely with +500ft MDH, which is very reasonable in non-ATS or non-INST RWY…
The bottle neck is still the ability to operate uncontrolled IFR on auto-info or air-to-air while remaining in “ATS system” most countries tend to terminate IFR clearances (namely going missed, flying to alternate and rejoin IFR), the moment you are on your way to non-INST or non-ATS RWY…unless you made the right arrangements, at the end of the day it’s all what matters: ATC to keep an IFR flight plan alive, the rest is PIC risk appetite and flight utility and can be managed safely by GPS savvy pilot !
Actually, that’s not the case in France. Basically, once you have filed a flight plan and opened it with an ATS (an examiner confirmed at my latest revalidation that you could do this by telephone with any local(?) ATC) it constitutes an implicit clearance for the flight plan even if one takes off from 1 FIR and to land in another at the other side of the country. The eAIP refers to this, and interestingly it makes a comment about downstream “link ups” ( now I take this to be implicit clearance) into and through border FIRs such as London Information which makes some of the posts about being dropped on an IFR flight plan when one leaves and enters CAS as IMO not being within the spirit if ATS agreements ar the expense of pilot and aircraft safety.
Please note I am writing of FIRs not CTAs CTRs etc and IMO this implicit clearance is for " the flight plan as filed, validated and opened, should be to destination whether that is inside or outside CAS.
**The reason I put a"?"next to the word local is that the examiner gave me an example of an airfield in the Alps having a FPL opened by telephone by an ATS which wasn’t IMO local.
Indeed, French ATS do maintain an open IFR flight plan and they will assure further airspace clearance for flight in Golf “as filed” (either on transits, or permanently outside, or during descentes bellow radar MVA & radio MEA or even when going bellow MSA before coming back on radio), however, one has to be careful with “open IFR flight plan” and “airspace clearance”, especially in places like Paris TMA where there is “no IFR FPL inside” and you are not supposed to fly FPL “as is” on lost comms
The key thing for France is that you always need to ask for IFR start up (“mise en route IFR”) even for Golf IFR and respect EOBT/CTOT as it’s mandatory for air traffic management in controlled portions, if you ever plan to fly in airspace or published routes
It’s an exception rather than the norm, most country where I have flown ATS terminate IFR bellow airway MEA and wash their hands, even in UK where Golf IFR is normalised it’s not a trivial exercise: going back into en-route airspace after leaving system at DET and missed at Stapleford is not a walk in the park, I will let you imagine losing COM/TXP/GPS scenarios…
Is lost comms that prevalent? To fly IFR in France the MEL according to a NCO sheet * put out by ANPI (the instructors organisation here) you need 2 x8.33 VHF radios and a modes S transponder. So at least if you lose 1 radio you have got a reserve.
I have often flown POGOs in and around Paris but I have always filed the flight plan on the telephone , but the last time was about 2 years or more ago.
Back then the lost comms procedure was the ICAO lost comms whilst in a radar coverage area. Has it changed over the last few years?
* I can post this sheet if you are interested, but it is a graphic (cartoonish) representation which I have read some people on here don’t like.
2*8.33khz radio for legal IFR is BS, sorry, I have no idea who comes back with this c**p again and again, over and over, do people even get tired of this one day? I am not sure who are ANPI? and how much insight they have on NCO equipment topic? or if they own or maintain IFR aircrafts? but I suggest anyone to have a read of the rules, the only non-complex sub 2T aircrafts I am aware to be certified with 2 radios for IFR in MEL in their AFM/AFMS are “G1000 aircrafts”
For practical flying, by no mean have two radios (or like me 4: 2 in aircraft and 2 handhelds) as backup for IFR NORDO or ease of single pilot IFR operations (ATIS & ATC2) but to say it’s a legal requirement is a bit of stretch, for example, I think it’s “illegal” to fly IFR in radar TMA without autopilot but I tend to keep this to myself as it’s not in the rules 
You can lose both aircraft radios just as you descend bellow airspace and handheld is of no help, I have been in this case with a friend in his SR22 mid English Channel when “he decided it’s ok to keep punching through with FIKI ON”, I told him it was not a good idea but I was not expecting all the radios to give up !
Back then the lost comms procedure was the ICAO lost comms whilst in a radar coverage area. Has it changed over the last few years?
I think you should not fly the “standard ICAO lost comms” inside Paris TMA, there is a special non-standard lost comms procedure for Paris TMA (you need DME for lost COM), it’s described in AD AIP if you look in details there is no “7min & revert to FPL”
It would be interested to know if you would apply “ICAO FPL lost comms while OCAS IFR in IMC” off radar & off airway while going to LeBourget? or in UK OCAS and back into airspace by climb? or in Germany bellow MRVA and back into airspace by climb? or I have flown in both countries, I don’t think I would do that
In any case, a PIC who “can’t operate like VFR OCAS” or “are not current in VFR flying” (manage lost comms or navigation, fly own procedures, mix with other traffic, read en-route notams while owning their distances to obstacles, traffic or clouds…) are best advised to stay in controlled airspace and stick to published routes all the way while IFR in IMC under ATC watch…
Sometimes I don’t understand what you are saying. I will post the ANPI NCO communication I was referring to as soon as I have my tablet nearby. As I explained ANPi are an instructors organisation in France, Association Nationale des pilotes instructeurs, although I received it through the FFA.
As I mentioned normally the lost comms procedure is published on the charts for the airfield but the 7 minutes with radar or 20 minute without ICAO notms for lost comms is in the AIP. So yes if not contradicted in the airfield charts and if VMC was not possible I would follow the ICAO regs which I believe are also the French regs for lost comms.
All I am saying is “7min & 20min” are not the prescribed lost coms for Paris TMA, please check what is written in French AIP AD the next time you fly around area, especially if inbound from Golf
The myth of 2*8.33khz radios for IFR is dead since some ramp check incident in Netherlands, long story short: you can legally fly IFR with one 8.33khz radio in 90% of IFR SEP…still very interested in reading what the ANPI says about the topic if you have their document? maybe there is some legal text in the ANPI doc that Mr Jose from EASA (Director of Network Manager) is not aware of?
Ibra wrote:
The myth of 2*8.33khz radios for IFR is dead since some ramp check incident in Netherlands, long story short: you can legally fly IFR with one 8.33khz radio in 90% of IFR SEP
@Airborne_Again has got the link to that Eurocontrol letter that yes, you can fly IFR with just one radio.
arj1 wrote:
Airborne_Again has got the link to that Eurocontrol letter that yes, you can fly IFR with just one radio.
The letter is also linked to in Ibra’s post above.
