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What are the UK legalities regarding flying in IMC in IFR OCAS with an EFB?

My flying buddies and I are struggling to find any legislation detailing the use of an EFB (e.g. SkyDemon) in IMC when flying OCAS.

Not that we’d want to, but IIUC, in theory we can dead reckon whilst IFR in IMC with just a chart and a stopwatch?

Is it possible to upgrade that method by adding an EFB and still remain legal?

Lee
Barton EGCB, United Kingdom

Yes.

Regulations cover equipment carriage, not equipment usage.

You need to carry the equipment for the airspace class and the flight conditions (IFR or VFR). I don’t know what the current regs are for this; I could never find EASA regs for this as they are all over the place. But how you actually navigate is up to you.

Administrator
Shoreham EGKA, United Kingdom

Lee wrote:

My flying buddies and I are struggling to find any legislation detailing the use of an EFB (e.g. SkyDemon) in IMC when flying OCAS.
Not that we’d want to, but IIUC, in theory we can dead reckon whilst IFR in IMC with just a chart and a stopwatch?
Is it possible to upgrade that method by adding an EFB and still remain legal?

I think if you fly in IMC, so you fly IFR, you have to comply with min equipment carriage, for example, GEN 1.5 (5.2) lists it:
https://www.aurora.nats.co.uk/htmlAIP/Publications/2023-10-05-AIRAC/html/eAIP/EG-GEN-1.5-en-GB.html#GEN-1.5.5.2

I think, legally, you might be correct when you just cross a small area of poor vis (fly through cloud), otherwise you need some radionav, be that VOR, GNSS, NDB, DME, etc. Please also note that 5.2.3 shows an example of an acceptable means of compliance, not the minimum. minimum is 5.2.1.

EGTR

That’s just the kind of thing I was hoping to clarify.

Where does the legislation state that electronic navigation is a requirement?

The way I understand it presently, it’s legal to DR the whole route if you were that way inclined (which I’m not).

And if it does say that for example GNSS or similar radnav is required, is SkyDemon with a back-up sufficient, legally.

Lee
Barton EGCB, United Kingdom

Regulations cover equipment carriage, not equipment usage.

You can navigate legally by following a rubber duck floating in a bucket of water.

There is a very old discussion about this in Usenet, which can be found by searching for a “tuna sandwich”

Administrator
Shoreham EGKA, United Kingdom

Right. That was my understanding from your first reply.

The second paragraph of the second reply through me again though.

Did I misunderstand the ‘legality when in cloud’ (i.e. proper, sustained IMC) part?

Lee
Barton EGCB, United Kingdom

Interesting because the text seems to say that DME is required for IFR flight, regardless of the class of airspace. I would say that 5.3 is necessary as well as 5.1 – there is ni “for example” or whatever to imply that something other than 5.3 is acceptable.

LFMD, France

@johnh, actually, text says that is an AMC, it does not say it is the ONLY AMC. :) And for Part-NCO you need just AMC, those don’t have to be approved by CAA (like it is mandatory for Part-CAT).
I have an e-mail from the CAA where they’ve answered the question “do I need installed DME and ADF h/w for an IFR flight if I’m not planning to use those for the flight?” with “you don’t need DME/ADF if you don’t plan to use those”.
You need a backup (which they insist should be onboard and not just a Mode-S + Radar vectors) if your primary nav device failed, i.e. have a second VOR if you use VOR, or have a VOR (or ADF) if you use a GNSS for nav, something like that.

EGTR

A search finds an awful lot of reading.

There have been changes in recent years e.g. equipment duplication is not required and this also affects 8.33 i.e. only one radio is required.

Problem is that pilots are like women on a dating site: read between the lines and look for all kinds of stuff which nobody intended to be there

Administrator
Shoreham EGKA, United Kingdom

Peter, I think the summary is that a pilot could anything they like, as long as everything is OK.
If one wants to gauge the consequences in case of a potential incident, I’ve been given an advise previously to describe the flight conditions as a line in AAIB’s report: “knowing … pilot has elected to …”, and if it sounds scandalous, you might want to reconsider. :)

EGTR
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