I have seen a non ADF Cessna 182 being MOR’d before they allowed GPS substitution for the hold.
That MOR won’t go very far? unless CAA can prove it was flying NDB hold and NDB approach in IMC without ADF?
C182 is certified for IFR and NCO does not require equipment carriage for instrument approach in VMC, zlitch, nada
You can legally file IFR request to fly NDB hold followed by NDB approach in C182 with no ADF, if it’s done in VMC !
I can see how filing Airways IFR and flying ILS in G-reg Rans7 can get MOR followed by CAA action, even if it’s done on sunny days
Peter wrote:
if you closely examine UL build quality there is no doubt how the empty weight is achieved
Well. I have duly examined the “build quality” of many planes. ULs typically fall into:
Certified aircraft are all very heavy. The main reason is they are tall and wide. It’s just the way things are. For the same rigidity/strength a big diameter pipe must have larger thickness than a small diameter pipe. Increase the width by a factor 2, and the weight goes up by a factor 2 to the third (or something like that). For most 2 seaters of normal speed envelope, it’s not the sheer strength that will be the dimensioning factor, but rather a skin thickness that can be handled without deforming too easily (An aircraft that you can simply poke your finger through is not a good solution).
The smaller you can make the aircraft, the lighter it becomes for the same relative strength. And the decrease in weight is highly disproportional the decrease in size. A fast cruising all carbon UL will typically withstand 10+ Gs. It’s not because it has to be that strong, but mostly because building it with thinner material specs would be silly.
The LAA specifies a minimum wing loading below which it won’t consider an aircraft suitable for IFR. I would imagine most microlights would be excluded on this basis, at least within the UK.
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.
Sure, but look at it from the regulatory POV. You are trying to create two kinds of “IFR”. Proper IFR, and “IFR in CAVOK”. It’s never gonna fly.
It’s like my scuba cylinder (used mostly for spraying and such like). If it has a GROUND USE sticker, it needs a test every 5 years, otherwise every 1 year. If the scuba shops want to make more money, they just say “weee know that youuuu will peel off that sticker and go scuba diving with it hahahaha”.
Like in the Annex 1 world, a lot of types are OK for IFR (in IMC) and a lot aren’t but somebody has to organise an approval programme and drive it. The UK LAA did one but AIUI has run out of resources. Personally I think the LAA programme made some dodgy assumptions; basically avoiding IMC, which everybody knows isn’t going to happen and you don’t need to watch YT videos to work that out.
Does Germany really ban autopilots on ULs?
Peter wrote:
Does Germany really ban autopilots on ULs?
Affirm. There are no installation rules available on to which an autopilot could be legally installed (that is my understanding). However, I just ran it through google, changes are announced for mid 2023.
I think it’s worth mentioning that regarding stuff like this (but also regulations in general), the pilots themselves are surprisingly often their own worst enemy.
Example
but somebody has to organise an approval programme and drive it
Pilots in general aren’t dead stupid and they don’t as a general rule live in a vacuum. That is only the typical pilot assumption: everybody else are dead stupid, but not me 
In principle one could do what the LAA started to do for UK Annex 1.
Then one can try to do mutual agreements with other countries for IFR privileges. As I wrote previously, one UK RV owner who got IFR approval (he’s unfortunately dropped out of flying since) reported that France accepted it but no luck with Germany.
This would suggest that a similar programme in Germany (whether Annex 1 or UL) might need some hard pushing. But, if successful, it would be interesting because Germany is the only country in Europe where foreign reg Annex 1 can be permanently based (permit for 180 days at a time) so you could have stuff like the Lancair Evolution based there, as N-reg. Still, IFR only in DE is not much use.
Peter wrote:
Sure, but look at it from the regulatory POV. You are trying to create two kinds of “IFR”. Proper IFR, and “IFR in CAVOK”. It’s never gonna fly.
The USA already has some meaning of “light IFR” and “hard IFR” legally, namely, FIKI IFR vs non-FIKI IFR. Some aircraft are only approved for non-FIKI IFR.
I don’t see that as applicable.
“FIKI” is a purely US term in legal terms because it maps onto US wx services. In practical terms it is unenforceable except in the most extremely obvious departure circumstances.
So e.g. the inability of a “plastic” Lancair to be “US FIKI” does not detract from the legality of it departing into solid IMC. And that is what is really handy about IFR. Depart in fairly crap wx and climb to VMC on top for the cruise.
But also the US is not Europe. Uncertified IFR works in the US because of very different attitudes to personal freedoms, and very different national CAA funding systems. It is mostly prohibited in Europe because of the prescriptive regime here (“We know what is good for you”) and because the regulatory business skims money from the whole ecosystem directly (in the US, indirectly, via the general taxpayer).
Peter wrote:
Uncertified IFR works in the US
In essence it doesn’t. LSA has a “no IFR” restriction, and it’s the only uncertified class of GA aircraft there (2 seat or more). Experimentals are homebuilt and – tada : experimental Thus certification of any kind is not even thinkable because nothing is mass/factory produced. Every experimental aircraft is a prototype. Of course this makes them uncertified, but they are first and foremost experimental, then homebuilt. Very different from LSA.
However, the IFR-part of experimental aviation is NOT experimental. There is no practical way of installing uncertified IFR avionics. It’s fully possible, but all IFR avionics have to show adherence to airspace requirements, and to do this for a new instrument costs way more than a fully equipped RV (maybe 10-20 RVs or more for all I know).
The US approach (except the LSA part) makes sense, and it is a 100% pragmatic approach. The same approach is used in many European countries (with ULs instead of LSA as the exception)
The correct thing to say is that uncertified IFR does not work anywhere. The reason is cost due to airspace requirements, nothing else. All places where there is a pragmatic approach to aviation, rather than downright dogmatic approach, IFR in experimental aircraft will work also economically, but only with certified IFR avionics.
The main problem in Europe, at places where this dogmatic approach exists, is that most GA pilots also inherits this dogmatic approach.
