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Homebuilt / ultralight / permit (non ICAO CofA) and IFR - how?

As I have said many times, I have no interest in IFR. It would be of little help to me in the flying I do. The only thing that would make my life easier for A to B flights would be a helicopter. Having said that, the general perception of IFR in GA aircraft down on continental Europe is a very odd one to me. There is no logic behind it, only “draconish” rules for the rules sake exclusively.

In Norway, the regulations say that it is 100% up to the PIC to decide of he/she will fly VFR or IFR. What the CAA requires is:

  1. The aircraft has the required avionics and instruments
  2. The pilots has the required rating
  3. The aircraft is not a UL
  4. (The POH also has to be followed, but this has nothing to do with IFR vs VFR. This is the same for certified, experimentals and ULs)

Experimentals, no problem. I would think most IFR flown by GA is in experimentals. The reason is that most high performance experimentals with IFR avionics are owned by professional pilots. They would much rather have an RV as a hobby than an archaic spam can. A note here is that all IFR avionics must in practice be certified, because no one makes non certified avionics that adheres to airspace requirements.

Regarding UL, the current regulation is VFR day exclusively. In addition, VFR on top is not allowed. New regulations are coming later this year. With those regulations:

  1. VFR night will be allowed
  2. VFR on top will be allowed

This has been on a hearing. The discussion right now is about BRS. In the original suggestion the CAA wanted VFR night and VFR on top to have the requirements of BRS. There are good reasons for and against the requirement of BRS. NLF (the GA association in Norway) does not like the BRS requirements, the CAA does. I am an engineer, and while theoretical musings can be made for and against, the basic practical fact is that a BRS will solve all thinkable safety issues about VFR N and VFR on top, and it is a dead simple requirement that is dead easy to check (by the CAA). It’s surprising to me that NLF tries to complicate this.

The current regulations for flying in controlled airspace with an UL is similar. The regulations simply say that transponder and radio is required, and that the PIC has the theoretical and practical knowledge (RT exam and EP of level something). With a PPL, RT and EP is implicit. An UL can be flown just fine without RT, EP, transponder and radio, but NOT in controlled airspace.

Regarding IR in an UL. Why not? But this will for sure require IR rating and (certified) IR avionics. A nice glass panel with all the bells and whistles will not do.

The elephant is the circulation
ENVA ENOP ENMO, Norway

Airborne_Again wrote:

Remember that ULs are nationally regulated. E.g. none of the above is true in Sweden.

Thanks for pointing that out!

Ibra wrote:

The other thing about UL is the majority are owners clock load of hours and have a lot of experience and they know about their limits

The problem is the new breed who buy these advanced UL with zero prior experience, get taught by some random instructor and go the next day hanging on AP in bumpy cloud sitting on 10lbs/ft2 wing load

Yes but isn’t that all the same true for certified aircraft? You can buy a brand-new something and go cloud busting. It’s no difference between microlight and certified.

RobertL18C wrote:

an airport in the UK with IFR approach control and an instrument approach is almost certainly going to MOR your arrival

And that is where I see the safety issues. If people are pushing the limits of microlights (and so far there is no extraordinary number of accident reports) but cannot rely on any assistance (radar, vectors, approach) because the breaking of laws would be appalent then, you’re doomed to find a way out.

So wouldn’t it be safer and easier to open up a way here? I can absolutely understand that any aircraft carrying paying passengers has to fulfil certification levels, but why not open a door for two seaters?

LeSving wrote:

VFR night will be allowed
VFR on top will be allowed

This refers to Norway, I assume. So yes there are changes, one just has to know what’s valid in which country. (I didn’t know, for instance, that VFR on top was/is in fact not allowed and might be the same in other countries..)

Germany

UdoR wrote:

three axis autopilot (not allowed, I know).

Under for eg. Polish register you can have autopilot and fly UL’s VFR night :).
I think Germany is stupidly restrictive here.

http://www.Bornholm.Aero
EKRN, Denmark

RobertL18C wrote:

an airport in the UK with IFR approach control and an instrument approach is almost certainly going to MOR your arrival.

how would they know its UL? Especially for foreign registry.. I got a choice to register my Savannah either as UL or experimental . I opted for UL for easier maintenance and little less mandatory equipment ,but the fact is you cannot be sure before you check my papers. Some makes (CTLS comes to mind) can be UL or certified.

EETU, Estonia

ivark wrote:

how would they know its UL?

They won’t.

In Germany you can derive it quite easily from the registration, the first letter after the “D” tells you which class of aircraft it belongs to, but in other countries it is not managed like this. So as even microlights exist that have a certified sibling who should know from outside whether it’s microlight or certified?

Germany

UL reg in Cz republic: 7 characters of which the last 2 are digits. Spain: 5 characters of which the last is a digit. There must be more countries where the distinction is clear. Having said that, I know for a fact that most controllers in Spain have no idea that D-Mxxx means UL..

Private field, Mallorca, Spain

@ivark good point and am guessing they could file the equipment for an IFR airways flight plan? Although not sure if certified, they are also IFR certified? However, if it looks like a duck, swims like a duck and quacks like a duck, it is probably a duck :)

I have seen a non ADF Cessna 182 being MOR’d before they allowed GPS substitution for the hold.

Airports that mix light aircraft with heavy corporate possibly look quite closely at the lighter end if arriving IFR.

Last Edited by RobertL18C at 07 May 17:55
Oxford (EGTK), United Kingdom

aart wrote:

UL reg in Cz republic: 7 characters of which the last 2 are digits. Spain: 5 characters of which the last is a digit. There must be more countries where the distinction is clear.

Sweden, reg. begins with SE-V or SE-Y.

I sent an IFR flight plan to the Eurocontrol test validation function with aircraft type Dynamic WT 9 and registration SE-VXX (fictitious) and it was accepted! So apparently there is no check against either aircraft type or registration.

ESKC (Uppsala/Sundbro), Sweden

This topic has been discussed many times. Posts merged.

Ultimately there is a quid pro quo on ICAO certification and international flying ability. Not everybody likes this – especially people who rarely or never fly abroad, or who have cross border concessions. But it is what we have.

Plus a lot of people get regular bread on the table at home enforcing this stuff and they will not give up easily, and where they do concede, they normally make sure that the applicant’ mission profile is so severely crippled it is almost not worth it. There are powerful interests e.g. if certified GA was to disappear, the maintenance industry would also almost disappear, most airfields would disappear (no commercial property income, etc) and GA as a whole would shrink to a pure hobby activity operating out of grass strips. The CAAs would have little GA income and would be doing just airline stuff. Hmmm, do you recognise that? Again, many would like this outcome.

Eurocontrol does not check for legal IFR for the type. Their movements database includes many movements which cannot possibly be IFR. Can’t find the thread right now (is quite old) and it is quite funny. I am sure people here know where that database can be found; I just don’t have time. Someone helpful can post it. Many debates on legality; little or no enforcement. My view is that insurance may be in doubt, if the loss adjuster has a brain (often he doesn’t).

I am sure people get spotted frequently. All you need is a keen spotter in the tower. But he’s unlikely to say anything. And there are easy methods to make IFR ops non-obvious. It’s not much different from flying in IMC without an IR.

My bigger concern would be technical – see recent threads about static, bonding, etc. Unless one wishes the argue that IFR will be CAVOK which nobody in the regulatory business is going to buy into. The avionics is not an issue… well except that the cheap systems usually can’t fly an ILS. None can fly LPV. Then there is build quality (relevant to flight in turbulence); if you closely examine UL build quality there is no doubt how the empty weight is achieved, and it isn’t just minimalistic seating

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

My bigger concern would be technical – see recent threads about static, bonding, etc. Unless one wishes the argue that IFR will be CAVOK which nobody in the regulatory business is going to buy into. The avionics is not an issue… well except that the cheap systems usually can’t fly an ILS. None can fly LPV. Then there is build quality (relevant to flight in turbulence); if you closely examine UL build quality there is no doubt how the empty weight is achieved, and it isn’t just minimalistic seating

Peter, I don’t think that all types of IFR/IMC flying require all those things above – for example, an a/c flying at 3500AMSL in 4km visibility (mist), or through some very thin clouds etc.
I think we’ve discussed it many times re:light IFR vs hard IFR, so legally, for those a/c that don’t have lightning protection, they are supposed to stay away.

EGTR
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