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What determines whether an aircraft is IFR certified?

Equipment carriage for IFR is not a simple topic.

In countries where you can fly IFR OCAS (which for IFR means in Class G) the equipment carriage is really basic. You don’t need BRNAV, for which the only GA-practical means of compliance is an IFR GPS (or a KNS80 with antenna filters!).

So e.g. pilots who fly around the UK Class G on their IMC Rating can just do it with an Ipad, a Garmin 496, etc, etc. And since UK IFR in Class G, occassionally popping into Class D, is basically identical to VFR (there is no IFR clearance) you want VFR mapping which you won’t get on any certified (panel mounted) avionics (some old Avidyne MFDs and maybe latest Garmins excepted). Speaking of Avidyne, off topic, what do they do now that Jepps have dropped the VFR charts in 2013?

IFR in CAS (what I call Eurocontrol IFR) requires the whole IFR equipment list.

So I don’t quite get it when e.g. a French pilot says his C172 is not IFR according to the club rules. So long as he flies in Class G, he doesn’t need any special kit. For Class E, he would do…

Administrator
Shoreham EGKA, United Kingdom

Silvaire wrote:

Re ramp checks, I think once IFR “certification” is removed as a periodic maintenance concept, so does the possibility of a ramp check on that basis. That aside, in the US where the concept has never existed, pilot pre-flight responsibility is the same as for VFR except for different equipment required and a different biennial check: pitot static is added to the VFR encoder check for transponder equipped planes. Either is indicated by a note in the airframe maintenance log. That’s all the paperwork you need to be legal, you don’t carry the maintenance logs in plane regardless, and in any case it’s a ramp check, not a how did you get here check.

I like the term “how did you get here check”, I’ll remember it for the next ramp check in France to test their humour.

Since I will soon go flying in the US again, could you clarify this seeming contradiction to me please? The biennial checks are recorded in the airframe maintenance log, but you don’t carry those in the plane. Am I correct to assume that the verification of the biennial checks are not the object of ramp checks in the US?

Interestingly enough, the LBA has thought of this problem when they wrote the NfL which @TobiBS linked to and they include this wonderfully nebulous statement:

Es hat sich in der Vergangenheit bewährt, die „LBA Form 22 RTS“ an Bord des Luftfahrzeuges mitzuführen, sodass der Prüfstatus und der Ausrüstungsstand des Lfz bei Bedarf belegt werden kann.

Translation:

It has proven its worth in the past to have the LBA form 22 RTS on board the aircraft, so that the inspection status of the aircraft can be documented when required.

Thanks, but no thanks. They “recommend” to have this so as to avoid further harassment, even if it is not a legal requirement. It sounds like a “recommendation” of the cosa nostra to pay your protection money. “You don’t have to pay it, but we really recommend you do it anyway.”

Instead when faced with this problem, they should have thought for two seconds to conclude: “Hm, we are going to prescribe different maintenance actions for VFR and IFR, but there is no such distinction in the ARC and the laws, maybe we’re on the wrong track here”…

Peter wrote:

So long as he flies in Class G, he doesn’t need any special kit. For Class E, he would do…

Now you are talking about airspace requirements for navigation equipment (regulated in NCO.IDE.A.195 “Navigation equipment”), which is a little different question (but in practice even more limiting than this minimum list in Part.NCO.IDE.A.125 “Operations under IFR — flight and navigational instruments and associated equipment”).

NCO.IDE.A.195 starts with:

Aeroplanes operated over routes that cannot be navigated by reference to visual landmarks shall be equipped with any navigation equipment necessary to enable them to proceed in accordance with:
(1) the ATS flight plan; if applicable; and
(2) the applicable airspace requirements.

But if I already fail to verify that my radio and transponder may be used for IFR, I don’t worry yet about these airspace navigation equipment requirements. That will come in the next thread.

Rwy20 wrote:

So I can safely assume that all the equipment that I listed for the trusty C172 further up in this thread will conform to that requirement, because if it weren’t then I wouldn’t find them in the panel of the aircraft if it has an airworthiness certificate, which I duly checked as a pilot?

Well, I think there lies a potential trap but I’m not really familiar with the rules. Just because something looks like an attitude indicator or “GNSS navigator” doesn’t mean it was actually certified as such (if it wasn’t, you can’t use it as such outside of emergencies and it won’t satisfy an equipment requirement). It could get even more interesting if you consider installation. This can be resolved by a placard (e.g. for situational awareness only).

Rwy20 wrote:

which details the periodicity in which you have to check your transponder, radios etc. and the methods by which these have to be checked if you want to use the plane for IFR. Is that now bollocks?

I believe this should be part of the maintenance program. And I think even the EASA’s MIP has some avionics ground test in it. And it makes sense to me. E.g. all installed transponders should be checked, it shouldn’t matter whether it’s mandatory or not or IAW what flight rules you fly. And of course, if your program needs approval of your NAA, they can make demands.

Martin wrote:

I believe this should be part of the maintenance program. And I think even the EASA’s MIP has some avionics ground test in it. And it makes sense to me. E.g. all installed transponders should be checked, it shouldn’t matter whether it’s mandatory or not or IAW what flight rules you fly. And of course, if your program needs approval of your NAA, they can make demands.

I also think it makes sense, as the FAA does as well. The question is, can I or do I have to know as a pilot about what the owner wrote in his maintenance program? I.e. “this plane will only be used for VFR flight, so we don’t need to maintain the pitot heat” (not that I know what work you would want to do on it other than switch it on and see if it heats, which I do on pre-flight), or “we don’t have to check the transponder every 12 months”.

And can or must the owner have to prevent me from flying a plane IFR because he wrote in his maintenance program that his plane will only be used for VFR?

My real, pragmatic problem is that my club thinks that IFR is dangerous anyway and best avoided altogether. So if it costs them only one extra dime to have an “IFR” aircraft, they won’t want to spend it. But…

Peter wrote:

So I don’t quite get it when e.g. a French pilot says his C172 is not IFR according to the club rules

It is not a club rule. My club rules don’t say anything about VFR or IFR, except that we have higher minimum fuel requirements than the regulation, but even those don’t explicitly say that this is for VFR. (I just checked, it’s a blanket statement that you have to have 45 minutes of reserve fuel.) At the moment, the problem boils down to the OSAC (Organisme pour la Sécurité de l’Aviation Civile), which makes the technical rules for civil aviation in France.

Last Edited by Rwy20 at 26 Aug 09:43

Peter wrote:

In countries where you can fly IFR OCAS (which for IFR means in Class G) the equipment carriage is really basic. … IFR in CAS (what I call Eurocontrol IFR) requires the whole IFR equipment list.

Well, I don’t really agree. One has to differentiate airspace requirements from the rest. You need the equipment required by the manufacturer for IFR (which stems from certification) and you also need to meet operational requirements. Even in class G in my opinion. Otherwise it’s like flying IFR with (night) VFR-only plane. B-RNAV and P-RNAV are airspace requirements. Just like RVSM approval. And if you can’t navigate using visual references, you need navigation equipment and it has to be certified as per NCO.IDE.A.100(a)(3) already mentioned here (195 states requirements for navigation equipment).

Rwy20 wrote:

The question is, can I or do I have to know as a pilot about what the owner wrote in his maintenance program?

I don’t think you have to. I think there’re pilot’s responsibilities and operator’s responsibilities (to simplify it in this case, it should be generally the entity renting it to you). How do you know what they did at the last annual? Do you check ADs and mandatory SBs? It’s not pilot’s responsibility to do an annual before take off. You either trust them (otherwise I hope you wouldn’t be flying their aircraft) or not. If something goes wrong because they screwed up maintenance, it’s on them. In the US, you could obviously look up whether legal counsel ever delt with this or ask yourself. I’m not a lawyer, but requiring this doesn’t seem reasonable. Obviously, if your club maintains it’s not IFR, you fly IAW IFR anyway and there turns up to be a problem with some equipment needed for IFR, it could be interesting (I would still think it’s on them unless the equipment was appropriately placarded or it was at least in the logs).

I don’t think he has to prevent you from flying IAW IFR (that’s not reasonable), but there might be requirement somewhere that such a plane must be placarded “VFR only” or something like that.

PS: Equipment can fail at any time and it might take time before someone notices/ check is performed so it shouldn’t be a serious problem, but if there is fallout and you did preflight check properly, you IMHO should be fine (you did what is expected of you). But what are we talking about really? If your navigation equipment is iffy, ATC should notice you’re going where you aren’t supposed to. Transponder? It should be obvious. Instruments? You’re trained to recognize there is an issue and fly partial panel. Worst case scenario is that the club will refuse to fix the offending device and instead placard it INOP preventing you from flying IFR.

Last Edited by Martin at 26 Aug 10:50

What Martin writes is exactly how I (with my Swedish experience) look at this.
If the POH/AFM of an aircraft says IFR is allowed then I assume that the maintenance is done accordingly to keep all systems in such a shape that what’s written in the POH is fulfilled. Otherwise I would expect the aircraft to be placarded VFR Only or to find a note in the Hold Item List.

ESTL

The answer really is ask them.

Let’s assume it can be done and that they actually did it, that is you need a proof (a piece of paper) of some check to fly IFR. First of all, said piece of paper isn’t among the documents to be carried. That is governed now by EU reg and I don’t recall there being provision for state of registry mandating some additional documents. And how is one supposed to know this? You could very well be from a different EASA MS where there is no such thing. Obvious solution would be to require that piece of paper in order to issue ARC unless the aircraft is limited to (night) VFR. And what about self declared maintenance programs? You could try asking EASA if OSAC isn’t helpful. I think one would win this in court but one usually avoids having to go there.

Last Edited by Martin at 26 Aug 11:59

Martin wrote:

The answer really is ask them.

What was the question again? Ask whom?

Sorry, but there has been so much written here that it would be helpful if you could quote the bits you are referring to.

Rwy20 wrote:


Since I will soon go flying in the US again, could you clarify this seeming contradiction to me please? The biennial checks are recorded in the airframe maintenance log, but you don’t carry those in the plane. Am I correct to assume that the verification of the biennial checks are not the object of ramp checks in the US?

Nothing related to maintenance records can be checked in a ramp check, because maintenance records aren’t carried on the plane. I’ve yet to meet anybody who had a random FAA ramp check, but I understand sometimes they go to airshows. Verifying the transponder and pitot static checks is also not part of an FAA annual inspection, but as Peter and others are apt to point out, there may be some insurance related issue if you don’t get them and fly where they are legally required.

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