Peter wrote:
When I was looking for someone to do the FAA 2-yearly altimeter check and quoted some references here to a well known UK shop, I got this nice reply
I heard of a case where there was a disagreement about the interpretation of regulations between a CAMO and the owner of an aircraft with a self-declared maintenance programme. The owner contacted the Authority for guidance and it agreed with the owner’s interpretation of the rules. (Which was completely obvious to anyone who had actually read the regs.) The final reply from the CAMO was along the lines of what Peter got from the avionics shop, but less nice.
There’s no shame in not knowing all the fine details in fast-changing regulations, but there is in not wanting to accept it when it is pointed out to you.
If only it worked like that.
You speak to your maintenance organisation and they read the regs and they think you have a point. They then speak to their inspector who disagrees.
So nothing changes.
You could of course change to another maintenance organisation but its 100 miles away and it they have the same inspector.
Thanks for referencing my page, someone just pointed out to me that it’s talked about here. The content is still current to the best of my knowledge, for those wondering. I just haven’t been active on the blog and EuroGA for some time. I wanted to do a CS-STAN installation of a wing mounted GoPro and document it on the blog, but Covid messed with that plan… the plan to be the one pilot with a legally installed external GoPro in Europe ;-)
What I possibly omitted on the blog about IFR equipment is the Eurocontrol requirements. It is not very transparent to me which country requires basic rnav over e.g. FL95 and other levels. But it doesn’t really affect anyone because there is noone flying IFR in Europe without DME or GPS.
ArcticChiller wrote:
What I possibly omitted on the blog about IFR equipment is the Eurocontrol requirements. It is not very transparent to me which country requires basic rnav over e.g. FL95 and other levels. But it doesn’t really affect anyone because there is noone flying IFR in Europe without DME or GPS
All EC countries have introduced BRNAV above FL95, probably since 2000, it’s bellow FL95 where things may differ?
Under FL95, UK has not introduced BRNAV for IFR OCAS outside ATS routes: ok to fly IFR RNAV5 with VOR/VOR or VOR/DME or KNS80 without having IFR GPS, the question for how long? I think it’s forever 
This concession will be of limited in other countries where IFR = FPL+CAS+RT+ATC>FL100
ArcticChiller wrote:
Thanks for referencing my page
1. Type certificate: Kinds of operation
Does the type certificate data sheet or POH list IFR as a possible kind of operation?
@ArcticChiller: what if the plane is so vintage it does not have a POH and the TCDS does not say anything about type of operations?
Arne wrote:
what if the plane is so vintage it does not have a POH and the TCDS does not say anything about type of operations?
Is there an actual case of such a vintage airplane that is not Annex I and therefore under national regulation (and hence typically VFR only) anyways?
If the plane is an EASA airplane it cannot operate operate under national rules. Our 1959 Cessna 175 is such an example (normal EASA airplane) where the TCDS does not mention the flight rules, because it was certified under the old CAR 3 certification basis. In our case the POH simply mentions that the plane may be equipped to fly under IFR and at night. This is very specific to each airplane prior to CFR23/CS23, so it’s best if you specify what plane you are asking about. A general answer is almost impossible to give.
If there’s no mention of IFR in both the TCDS and the POH, then you’ll need someone with more expertise than I’m able to provide.
Just be aware that there are planes that cannot fly under IFR because of simple things missing, like a pitot heat. I would assume that old planes with pitot heat will usually be IFR equipable, but that’s only conjecture
Malibuflyer wrote:
…Annex I and therefore under national regulation (and hence typically VFR only)
Is that really the case? If the aircraft was IFR capable when it was under national regulation before EASA why should it not remain so?
ArcticChiller wrote:
If the plane is an EASA airplane it cannot operate operate under national rules. Our 1959 Cessna 175 is such an example (normal EASA airplane) where the TCDS does not mention the flight rules, because it was certified under the old CAR 3 certification basis.
Anything originally certified a long time ago is the same way: From memory, Mooneys built before the late ‘60s and Maules built today are two other examples. Specific certification for IFR was not ‘a thing’, the plane just has to be equipped for IFR per FAA regs. The general answer you’re looking for is that there is no limitation, nor was there intended to be.
Let’s consider a Reims F172M. I don’t have access to its POH but a placard over the baggage compartment says :
Icing conditions forbidden. This airplane is authorized to VFR DAY AND NIGHT
Is there any chance this plane will ever fly IFR one day ?
