EASA screws the use of GPS approaches

[IO540]

Details here (http://www.pplir.org/index.php?option=com_content&task=view&id=548).

Pretty unbelievable.

Firstly, some years ago, EASA made GPS approach approval a Major mod, costing 4 figures (for paperwork, basically).

Then somebody must have told them that if they carry on like that, they can forget GPS approaches in Europe because almost nobody will be flying them.

So they relented and made the GPS-approach POH supplement a Minor mod... (other POH supplements, including one for flying LPV GPS approaches, remain a Major mod under EASA, making EGNOS a bit of an irrelevance).

Now they are back with an "Operational Approval" being required for any kind of GPS approach, for any EASA registered aircraft.

Idiots, working in some bunker, not listening, and totally out of touch with reality :ugh:

[VMC-on-top]

All the more reason to stay on the N reg?

[10W]

I think your last sentence sums them up perfectly IO540 :ok:

[stiknruda]

Happy to send you my old nav-school whiz-wheel, if that'll help you out;)
?

[maxred]

Correct me if I am wrong, but were only a very small minority of UK, 'GA' airfields up to the task, Shoreham being one of them??

[IO540]

Currently yes, but what about the future?

[Justiciar]

I wonder how the two european established manufacturers of IFR capable GA aircraft feel about this, i.e. Diamond and Tecnam, not to mention the many LSA manufacturers who might have hoped that their aircraft might one day obtain approval for IFR operations.

Why don't EASA just come out and say "we are banning all non commercial IFR flying". That might focus attention on the loss of an important safety aspect to IMC skills.

[IO540]

An effective technique is to draw their attention to it.

Most manufacturers are out of touch with new regs. A few years ago I phoned up and then faxed the marketing execs of all turboprop and bizjet manufacturers, drawing their attention to the then DfT proposals to kick out N-reg planes from the UK. Almost none of them were aware of it... Socata and Pilatus were not aware, amazingly.

When the EASA version came out, I did the same exercise. Socata were by then aware. Cessna were not, and they said they will take it very seriously.

EASA makes a big point of not being influenced by commercial interests, which is why their committees are mostly anonymous, but this makes them vulnerable to having a lot of "work" trashed at a very late stage, when it is realised what they have done.

With a bit of work, this GPS approach operational approval will also get trashed because it is so totally barmy, but it won't happen without some concerted effort because if EASA is left alone they are capable of anything no matter how stupid.

BTW, both EU-reg and N-reg are equally affected by this, especially as the NY IFU is almost certain to wash its hands of any approvals. They have already washed their hands of avionics 337s etc.

The upshot will be that GPS approaches will become legally unusable, even for aircraft with an existing approved GPS installation, forcing people to fly the conventional-navaid approach but obviously using a GPS, which is fine but hardly the point, and is a longer track because you have to go through the charade of flying the outbound leg, etc. It will also result in published GPS approaches being flown as "VFR", and in more DIY approaches being flown.

[soaringhigh650]

IO540, I think you should apply for a job at EASA and lead the team. :ok:

[Justiciar]

both EU-reg and N-reg are equally affected by this, especially as the NY IFU is almost certain to wash its hands of any approvals.

I though that was the way it read, but didn't like to say!

The regualtions appear to say that with third country registered aircraft, it is the state of establishment of the operator that will have to give the approval, not the state of registry of the aircraft. That seems to fly in the face of ICAO conventions. How is that going to work?

[Fuji Abound]

I guess this is all about EASA being wary of this dangerous new technology and heaven forbid pilots flying GPS approaches coupled with ensuring someone in EASA land holds all the cards as to what crews can and cant do. It is in many ways an extension of the N reg debate.

Simply put EASA doesnt want anyone flying GPS approaches unless they can pin the responsibility on an EASA member state for authorising the crew to fly the approach.

Doubtless it is also part of a revenue generating policy now that every airline in due course will probably have to pay a fee to one or another of the national authorities. Inevitably for them it is just another regulatory fee that in the great scheme of things doesnt add up to much and will be passed on to the paying passengers, but equally it is another nail in the coffin to most GA pilots who are struggling to make the flying sums add up at the moment.

It is complete and utter nonesense of course and yet another example of the complete incompetance of EASA.

[IO540]

it is the state of establishment of the operator that will have to give the approval

I didn't spot that... that's nasty! Just like the anti N-reg proposal, based on the nebulous concept of the "operator".

[Justiciar]

this is from the PPL/IR site:

SPA.GEN.100 Competent authority

(a) The competent authority for issuing a specific approval shall be:

for the commercial operator the authority of the Member State in which the operator has its principal place of business; and
for the non-commercial operator the authority of the State in which the operator is established or residing.
(b) Notwithstanding (a)(2), for the non-commercial operator using aircraft registered in a third country, the applicable requirements under this Part for the approval of the following operations shall not apply if these approvals are issued by a third country State of Registry:

Performance-based navigation (PBN);
Minimum operational performance specifications (MNPS);
Reduced vertical separation minima (RVSM) airspace.

I cannot see how an operator will persuade any third party state in which it is established to act as "competent authority" when under ICAO the authority must be the state of registry. So, if you are based in Switzerland operating N reg aircraft are the Swiss really going to "approve" anything just to please EASA? They would probably not have legal authority in their own country to do so.

The "established" or "residing" bit is almost incapable of enforcement and certainly not in the context of someone about to fly an approach! Think of a businessman flying a "N" reg with perhaps residences in France or the UK but also in Switzerland, the Isle of Man, Hong Kong or Jersey. He may have multiple businesses or interests in these various states. Who can say where he is "established" or "residing"? To try and attach a defined regulatory impact to people operating in a modern global economy is quite absurd.

It is true that people have a residence for tax purposes and for assessing the proper law for say probate or a divorce, but those assessments tend to be made ex post facto. That is quite different from someone on a particular day of the week trying to work out whether they come within the regulation or not. Many people will fin dit virtually impossible to work out whether they are caught by it or not, but more to the point which hard pressed CAA or police force is going to enquire into all this.

[IO540]

Not sure if this is relevant but these EASA proposals are not just for the EU countries.

The countries which joined JAA but remained non-EU (Switzerland, Norway, Croatia, etc) have signed some kind of agreement to be bound by EASA-generated regulations.

However I agree that this is a weird precedent, for non-AOC operations. These have always run on ICAO principles.

It is all the same stuff as EASA is doing on FCL, however. They are using the fact that (a) ICAO allows each member to retain total sovereignity over its airspace and (b) the EU has the power to force each EU country to file any difference to ICAO that the EU sees fit. It's a very "3rd World" way of doing business, which the civilised world abandoned in the 1950s.

The "established" or "residing" bit is almost incapable of enforcement and certainly not in the context of someone about to fly an approach! Think of a businessman flying a "N" reg with perhaps residences in France or the UK but also in Switzerland, the Isle of Man, Hong Kong or Jersey. He may have multiple businesses or interests in these various states. Who can say where he is "established" or "residing"? To try and attach a defined regulatory impact to people operating in a modern global economy is quite absurd.

It is true that people have a residence for tax purposes and for assessing the proper law for say probate or a divorce, but those assessments tend to be made ex post facto. That is quite different from someone on a particular day of the week trying to work out whether they come within the regulation or not. Many people will fin dit virtually impossible to work out whether they are caught by it or not, but more to the point which hard pressed CAA or police force is going to enquire into all this. Of course, but how many GB have been used up in these forums wondering about how it might work?

Just because a crap law has been drafted and passed doesn't mean it is completely ineffective. In the UK it would be very unlikely but the EU is quite capable of it. My concern would be insurance, not a ramp check.

[Justiciar]

(a) ICAO allows each member to retain total sovereignity over its airspace

True, and the convention allows a state to deny recognition of foreign licences to its own nationals (I can't recall which article it is) but that is a very 20th century attitude to sovereignty which is arguably out of place in the 21st Century. Nationality, though, is an easy basis for excluding privileges if that is what you want to do: if you have a UK, Frence, Swedish etc passport then you can't use the licence in our airspace.

Unfortunatley for EASA, in the context of the global 21st century that would be a massive own goal, actually making it more difficult for your citizens to use a qualification than for jonny (non EU) foreigner to do so. Hence this dogs breakfast which piles cost onto everyone. The whole purpose of ICAO was of course to prevent exactly this sort of protectionist stance.

I don't believe that things will ever change fundamentally as micro managing every facet of human activity by detailed regulation is a European mindset. Their paranoia is fueled by a dislike of things Angl-Saxon in general and American in particular and this is compounded by the general economic success of the US and the UK (current recession not withstanding) as compared to negligible growth in the EU. For example, no one is more vexed than the French at the dominance of Anglo-Saxon law firms in the global legal market, driven mainly by the relatively few restrictions compared to the EU on how law firms practice and the fact that much of the global market works to Anglo-Saxon rules on doing business . Their remedy to this situation is not to deregulate their own professions but to try and impose restrictions on foreign firms trying to practice (fortunately without much success).

[IO540]

I am starting to wonder how much it would take for EASA to ground me.

The Brussels fascists declare "everybody" around here flying IFR needs an EASA IR. So I am doing an EASA IR now (in addition to my FAA CPL/IR) which is not even legal to fly my own plane...

The Brussels fascists declare that you need the country of operator residence approval to fly GPS approaches. I don't fly GPS approaches because everywhere I fly to where there is or might be one and where there are Customs/Avgas, I find a conventional-navaid approach (which I can fly with the GPS anyway), or an ILS.

[Sir George Cayley]

IO,

What about a situation where there was a more convenient runway which has no ordinary navaids, but is designing a GPS approach. Would that sway you?

SGC

ps I think to get Brussels to be facists would take quite a left swing:rolleyes:

[IO540]

I guess that, in years to come, we will see a lot of "sub 737 size" airfields around Europe go all-GPS.

Currently, this is not the case, which is just as well.

In the UK, it hardly matters because the mandatory-ATC requirement keeps GPS approaches from spreading to where they might be really useful.

Hopefully the idiots at EASA will be straightened out by then, otherwise few people will be flying these approaches.

I am just a bit cheesed off that much of the regulation in this game is done by such complete idiots, living in some hole in the ground information-wise while enjoying the fat expenses-fuelled EU lifestyle.

[englishal]

Frankly, EASA are a bunch of WAnchors.

[BEagle]

Frankly, EASA are a bunch of WAnchors.

That is a grossly unfair thing to post, englishal...:=










A wanquerre does at least know what he's doing, whereas EASA haven't a b£oody clue what they're doing!

[bubo]

I fully understand EASA position.
Being really fresh EASA IR rated, it was a mental math excerise to fly a NDB approach, recognising position of the needle against gyro and heading bug in cross wind. It took me several approaches to be became at least somehow comfortable with that. The ADF needle swinging also brings some uncertanity. On the last 3 approaches in the training I was flying GPS/NDB appr using GPS which we didn´t prepared on the ground (just reading Machado´s survival manual few weeks back)
That´s too easy and it would allow GA pilots more comfortable and easier way to get throught clouds and flying overall. EASA stands for european aviation SAFETY agency and having allowed flying GPS only approached would be too safe...bastards.

[IO540]

Bubo - you should write to your MEP and get him to question EASA's motives, rather than voting YES on everything EASA / EU does, which the Czech politicans are very good at.

IO540 (also from CZ :) )

[bubo]

to IO 540 - believe it or not, but I did comment EASA FCL and have done other stuff, not just write messages on this and other forums...I am just now browsing EASA web page to find out which stage is the proposal right now, if I can use their nice tool to enter comments. Other steps are TBD, MEP is a good suggestion
BTW, I believe you are from CS ;-) like me, CZ is just last 18 years....

[AdamFrisch]

Idiotic question from non IR rated forumite:

IO, could one not "design" ones own GPS approach for an airport? I mean, all one needs to do is go there in fair weather, establish parameters for a descent without bumping into stuff and then sell it/give it other pilots? Be your own little one man Jeppesen?

Sure, it would be illegal to fly it, but how exactly would they know that you did fly it without sitting next to you?

[IO540]

I believe you are from CS ;-) like me, CZ is just last 18 years.... Yes, LKPR 1957-1959, LKPM 1959-1969 :)

Your MEP is the best bet. EASA couldn't care less what you write in their comment website. You could write that you are about to blow up the Earth; their response would be that this will be OK after the EU-US Bilateral Treaty on Earth Destruction is signed. And they will drag out the used Trabant salesman Mr Seebohm saying that the treaty is imminent.

It's obvious from the Transport Committee videos that the assholes in charge of EASA fear the Euro MEPs most of all. They like any form of democracy as much as Count Dracula liked sunlight.

IO, could one not "design" ones own GPS approach for an airport? I mean, all one needs to do is go there in fair weather, establish parameters for a descent without bumping into stuff and then sell it/give it other pilots? Be your own little one man Jeppesen?Yes of course. You would not be able to load it into the GPS database as a "proper" GPS approach but you could save it as a flight plan comsisting of a set of user waypoints, etc. A number of these already exist. You have to manually switch the GPS lateral deviation sensitivity to 1nm FS and then 0.3nm FS. But apart from that it is avionics-functionally equivalent to a published GPS approach. You should design it with a topo chart and test fly it in VMC, obviously. Choose a generous MDH e.g. 800ft.

Sure, it would be illegal to fly it, but how exactly would they know that you did fly it without sitting next to you? It is 100% legal to fly a DIY approach, GPS or conventional-navaid, in a G-reg, in any airspace which does not prohibit this (and the UK doesn't prohibit it).

It is probably not legal to do it in an N-reg (FAR 91.175), even outside the USA.

Lots of DIY approaches are flown into airports which don't have ATC, UK and abroad. In many cases it is really easy to do it perfectly safely e.g. if the airport is on the coast. With ATC present, it is a little more tricky, but nearly all airports with ATC also have a published IAP so you just fly that.

[AdamFrisch]

How would you make it so that it can be loaded by the GPS like a real one? Is there a special programming involved in this as in a language, or could you yourself construct in the GPS by entering coordinates etc?

What I suppose I'm asking is: why doesn't someone do this for all airports, sell them and make some money? If EASA or Jeppesen won't play, this is an opportunity for someone else. If I was in a jam and had to choose between a non approved GPS approach into a smaller field IMC or a most likely closed (it's England after all where airfields close at 4pm and you need to fax a PPR two months in advance to be allowed to land) non-responding towered airport miles away, guess what I'd chose?

[Fuji Abound]

Af

One word - liability.

As soon as you sell your homework for consideration the buyer is entitled to expect the product is fit for purpose. Should it prove for example you havent performed the survey to icao standards or havent the requisite regulatory approval dont bother opening the post just send it unopened to your lawyer with a very big cheque.

[AN2 Driver]

Why don't EASA just come out and say "we are banning all non commercial IFR flying". That might focus attention on the loss of an important safety aspect to IMC skills.

Well, why limit that to IFR. I have a feeling that their "vision zero" in terms of safety occurrences might well include the scenario where they will ban any and all non commercial aviation, if they thought they could get away with it. :mad:

They like any form of democracy as much as Count Dracula liked sunlight.

I read a very interesting book the other day written by a former GDR and Interflug captain. In the days before the fall of the wall, they there could fly only in strictly organized "aeroclubs" or for the military or Interflug. No private aviation at all. I recall from my friends in BG that it was the same thing there, they had a (military) aeroclub plus nothing.

Why do I get the feeling that this is where some folks at EASA would LOVE to go? As it is, they are doing a very good job at it... with the latent insecurity of what they might come up next, they have virtually paralyzed the European GA market to the extent that hardly anyone will take the decision to buy or operate a private plane anymore, out of fear of whatever rug one is standing on being pulled from under them.

Yes, LKPR 1957-1959, LKPM 1959-1969

Might be, IO540, that you'll need to move west again some day if you want to continue flying. The mindset of that age has invaded Europe to an extent I would never have thought possible.

Friend of mine put it that way after a long flight to Asia with a group of private planes:

" The degree of freedom that a country offers it's citizens can to some extent be measured by the distinction whether private aviation is allowed in a country or not. "

A startling but yet true statement. And outright frightening if we see EASA's rampage on our freedom, investment and lives to be only the beginning.

[AdamFrisch]

You must be able to protect against the liability, I'm sure. Just have them do an agreement like you do on any software purchase.

[Fuji Abound]

Nah you cant exclude a liability which kills you due to negligence as mr cessna knows only too well.

[IO540]

How would you make it so that it can be loaded by the GPS like a real one? Is there a special programming involved in this as in a language, or could you yourself construct in the GPS by entering coordinates etc?

As a practical answer: you could of course do it, by

- reverse engineering the copy protection scheme on the flash cartridge
- reverse engineering the database encoding
- inserting your own procedure into the database
- re-encoding the database
- programming a flash cartridge with the new database

and repeat this every 28 days, because the Jepp database changes will wipe out your edits.

I honestly have no idea if anybody has done this, and very much doubt anybody would bother.

It is widely believed a number of people have cracked Step 1, because that allows database subscriptions to be shared among GPSs. The copy protection scheme varies between Honeywell and Garmin but cannot be that hard, and I know some MFDs are trivial and are cracked simply by purchasing an unusual flash card writer from a German company.

If you create a set of user waypoints, perhaps also using some existing database waypoints, and load them into a flight plan, you get the same effect anyway - except you don't get the automatic lateral sensitivity increase at/past the FAF (you have to do it manually).

Commercially, nobody is going to touch this, for liability reasons. IAP design is a well documented procedure (TERPS in the USA, something else over here) and anybody can do it, but if you want to go low down you need a physical obstacle survey done. If you are happy with an MDH of say 600-800ft, you can just do it off a 1:25k contour map, and any remaining uncertainty is cleared by a test flight in VMC.

Very few people have been killed by flying DIY approaches. Those that have probably did not do the procedure design properly. I know one bloke who did a CFIT on a DIY IAP and amazingly survived, but he forgot to design the missed approach segment, and ...... crashed when he went missed :)

[421C]

The regualtions appear to say that with third country registered aircraft, it is the state of establishment of the operator that will have to give the approval, not the state of registry of the aircraft. That seems to fly in the face of ICAO conventions. How is that going to work?


No. The regulations say (my underline)

(a) The competent authority for issuing a specific approval shall be
1. for the commercial operator the authority of the Member State in which the operator has its principal place of business; and

2. for the non-commercial operator the authority of the State in which the operator is established or residing.

(b) Notwithstanding (a)(2), for the non commercial operator using aircraft registered in a third country, the applicable requirements under this Part for the approval of the following operations shall not apply if these approvals are issued by a third country State of Registry:
Performance-based navigation (PBN);
Minimum operational performance specifications (MNPS);
Reduced vertical separation minima (RVSM) airspace.


Para b makes it clear that a private aircraft registered in a 3rd country may operate under an approval from the state of registry.

[englishal]

IO, could one not "design" ones own GPS approach for an airport?
Even easier, and what the FAA did yonks ago was create "Overlay" approaches. In other words they said "Here's an old NDB/VOR approach into XYZ, we realise that NDB's are ****e, and GPS is far mor accurate and so now you can officially fly it using GPS as primary reference". The Approach plate is labled something like "VOR or GPS RWY 30".

Of course anyone with an IFR certified GPS and any sense of self preservation will activate the XYZ NDB approach on the GPS and fly it using the GPS, possibly backing it up with the ADF, even in Euroland.

Beagle is correct of course, Anchors are useful, and wanqueering might even be fun of the right person does it, EASA are neither useful nor fun ;):p

[IO540]

Para b makes it clear that a private aircraft registered in a 3rd country may operate under an approval from the state of registry.

Indeed, but this is additional to the GPS approach approval which an N-reg will typically have, and I don't see the FAA setting up a "special procedure for European owners" for generating these approvals.

Even easier, and what the FAA did yonks ago was create "Overlay" approaches. In other words they said "Here's an old NDB/VOR approach into XYZ, we realise that NDB's are ****e, and GPS is far mor accurate and so now you can officially fly it using GPS as primary reference". The Approach plate is labled something like "VOR or GPS RWY 30".

True, and this is something which Jepp do in-house, but the overlays can be done only where a conventional IAP exists. An IFR GPS will contain such overlays, though (for me, UK, KLN94) the representation is often pretty basic and I find it a bit confusing, and it is easier to fly the published IAP using the OBS mode of the GPS.

Of course anyone with an IFR certified GPS and any sense of self preservation will activate the XYZ NDB approach on the GPS and fly it using the GPS, possibly backing it up with the ADF, even in Euroland.

Exactly.

This is what airlines do. They fly NDB approaches (to various Greek islands, etc) using the FMS (which in reality means INS with DME/DME and, on modern planes, GPS, corrections). The procedure varies according to their AOC manual. All need the navaid to be not notamed INOP. Some need it to be tuned and idented. Some need the ADF to be checked at the top of descent (I believe this is a UK CAA one). One I heard of requires the ADF to be within 5 degrees all the way down, which is silly as it would mean you will never get into any coastal airport whose final approach track is not perpendicular to the coast (unless you ignore the ADF, obviously ;) ).

[Justiciar]

Taking a wide overview it seems to me that sports and commercial aviation are separating through a combination of security and "safety" (of commercial traffic) concerns, not to mention ill targetted regulation. The tendency of individual airports to exclude GA either directly or through high landing fees and mandatory handling is contributing to this. This tendency in Europe seems to be mirrored in the relative dearth of certified GA aircraft manufacturers in Europe (Diamond, Tecnam with its certified twin and soon to arrive four seater, and what used to be Robin). Every other manufacturer is going the LSA/VLA route which at present are day VFR only aircraft. They will use small airfields which will not be able to afford any form of instrument approach, GPS or anything else.

The EU missed a trick when they drafted the basic regulation. Really, I don't think they wanted to be involved in GA at all and had they done a better job of drafting it they would not have been. As it is we have the ludicrous situation where a Spitfire is Annex II but a C150 not; where a Bulldog is Annex II but the very closely related Pup is EASA!

If the EASA PPL allows VFR on top then for most pilots the only limitation in practical terms will be descending in IMC.

[Fuji Abound]

I have said for some time that EASA would have had a far easier ride if they had realised the dichotomy between the needs pf private light aviation, and commercial and public transport.

Whether they want to see the dichotomy is another issue of course - some would say not.

[Genghis the Engineer]

A small correction Justicair - VLA category aeroplanes can be "certified" by every standard you might wish to apply, they can be used for training, hire, tourist flights - you name it. Many VLA aeroplanes have an EASA CofA (that many LAA aeroplanes are also VLA is because manufacturers choose to go the kit route, which is the main reason CofA then becomes impossible for that airframe.)

It just that VLA (which was actually based upon BCAR Section S, the UK's microlight regulations) is a low-cost simplified certification standard which limits aeroplanes to day-VFR, it is also limited to fixed gear 1 or 2 seat aeroplanes with an MTOW not above 750kg. That could, for example, be a C152!

Interestingly, the FAA who accept VLA (despite it being a European requirement), created their own bolt-on to allow a bit of additional certification to permit night and IMC. This seems to work fine over there so a DA40, a European aeroplane, for example, can be flown IMC on the N-reg, but not on the G/F/D/etc. registrations.

This is cost effective in the USA because CS.VLA+bolt-on is still much less complex than CS/FAR-23 which is the normal certification standard for light aeroplanes; part 23 is designed for aircraft up to about 5700kg, including multi-engine, pressurised, retractable - and that all escalates the cost and complexity.


I don't think anybody has tried, but I suspect strongly that if you took to EASA a certification proposal of the FAA method of CS.VLS + bolt-on, for a basic 2-seater certified for night and IMC, they'd probably accept it with some work. It would just take a damned good certification engineer to make the case, and I'm not sure than any of the European little aeroplane manufacturers (a few of whom do employ engineers that good) have either tried, or realised that they could.

G

[Justiciar]

A small correction Justicair - VLA category aeroplanes can be "certified" by every standard you might wish to apply, they can be used for training, hire, tourist flights

Sorry, yes I was aware of the Restricted Type Certificate, which I believe means that you can fit uncertified parts and still use it for training. This could be said to be a step forward in a rather bleak landscape of regulation, but I have not seen any figures as to what the likely annual maintenance costs of an aircraft of a restricted certificate are.

It does make you ask what the EASA rationale is for this if it is not to put clear water betwen "sports" aviation on the one hand and commercial operations on the other. What they appear very uncomfortable with is having a class of aircraft which overlap the two categories of operation. A lot of the root problemis with the categorisation of what is and is not an EASA aircraft.

[IO540]

Maybe there is a logic to the EASA regulation but I fail to see most of it.

Comparing it with some corporate behaviour I have seen over the years, it has every sign of being a private project of a very small number of individuals, who are running their own private agendas.

The agendas are pretty obvious, when you occassionally bump into people from these bodies. They give you the standard bull***t about Europe needing regulation, but when you tell them you are a GA pilot, they start sweating and excuse themselves. Quite comical sometimes...

So we are getting the prejudices of these few people, modified by the subsequent horse trading among the CAAs of the member nations.

Almost everybody involved is not and never has been a pilot. Sivel has a PPL and occassionally rents out a Cessna or similar, and that is about the pinnacle of aviation experience in EASA.

[soaringhigh650]

I think it's time to stop moaning and actually go and do something about it! ;)

[Genghis the Engineer]

Sorry, yes I was aware of the Restricted Type Certificate, which I believe means that you can fit uncertified parts and still use it for training. This could be said to be a step forward in a rather bleak landscape of regulation, but I have not seen any figures as to what the likely annual maintenance costs of an aircraft of a restricted certificate are.

It does make you ask what the EASA rationale is for this if it is not to put clear water betwen "sports" aviation on the one hand and commercial operations on the other. What they appear very uncomfortable with is having a class of aircraft which overlap the two categories of operation. A lot of the root problemis with the categorisation of what is and is not an EASA aircraft.

Basically, I think that the powers at EASA believe that they should be in charge, feel the need to re-invent the wheel - but simply aren't clever or competent enough (or well enough resourced to do so), and they have egos that don't accept that the wheel doesn't need reinventing, nor that some things don't actually need regulating by them.

G

[proudprivate]

or well enough resourced to do so...



With a budget of € 107 Million, supplemented by some abused/siphoned off accession funds and regional developement aid across central Europe, I think most of us would be capable of reaching EASA's rulemaking objectives, which are :

To establish and maintain a high uniform level of civil aviation safety throughout all the Member States;
To ensure a high uniform level of environmental protection throughout all the Member States;
To facilitate the free movement of goods, persons and services;
To promote cost-efficiency in the regulatory and certification processes;
To promote Community views regarding civil aviation safety standards and rules throughout the world.

[Genghis the Engineer]

With a budget of € 107 Million, supplemented by some abused/siphoned off accession funds and regional developement aid across central Europe, I think most of us would be capable of reaching EASA's rulemaking objectives, which are :

To establish and maintain a high uniform level of civil aviation safety throughout all the Member States;
To ensure a high uniform level of environmental protection throughout all the Member States;
To facilitate the free movement of goods, persons and services;
To promote cost-efficiency in the regulatory and certification processes;
To promote Community views regarding civil aviation safety standards and rules throughout the world.


That's approximately 90% of what the UK CAA has as an annual budget for a single European country.

But the resources that really matter are the high quality people. There are a few in EASA - but very few.

G

[Justiciar]

To facilitate the free movement of goods, persons and services;
To promote cost-efficiency in the regulatory and certification processes

I can't wait for them to get around to addressing those objectives :ugh::ugh:

[FlyingStone]

Genghis, you probably meant DA20, which is certified according CS-VLA - DA40 is a CS-23 aircraft...

On the VLA subject: I find CS-VLA in present form pretty useless standard, especially if one is trying to build and certify aircraft that would be able to sell. For example, an average Lycontinental in the CS-VLA weight range has a fuel flow of about 20l/h in cruise. If you want to go to places, you need range of about 4 hours + reserves - this means 100 liters of fuel, which makes about 80 kg. Put up 2 people with 90 kg each (after all, it's not 1950 anymore) and you get 180 kg, and adding fuel this gets you to 260kg of load. The CS-VLA limits the maximum takeoff mass to 750kg, which basically gives you 490kg of basic empty mass and I think it's damn hard to make a useful and safe aircraft for "going places" operation that light. This is what made DA20 (until 800kg exemption from CS-VLA, which Diamond got this year) virtually one-seater for most cross-country flights, unless you like to stop every hour or hour and half to refuel. Not to mention that I don't see any practical point in limiting CS-VLA aircraft to night flying. I agree, aicraft must be equipped with similar equipment for night flying (lights, turn coordinator, artificial horizon, etc.) that CS-23 (or common sense for that matter) requires, but to forbid night flights in a brand new full-equipped aircraft just because some EASA bureaucrats failed to adjust the old JAR-VLA standard to the new world - and at the same time, permit night flights in 40 year old spam can, which probably doesn't have half the equipment of a new VLA aircraft, and there's a large posibility that more than half of installed equipment isn't working - just because it's Part 23 certified. That's crap.

Back to the topic: In my opinion, DIY approaches aren't the real solution, ATC in many places around Europe would file a report if you got in under very marginal weather. To add, it would be very suspicious if a single-engine GA aircraft made it to the runway (by flying a DIY GPS approach), when an airliner/business jet flying the same approach you tell ATC you'll be flying couldn't. The main disadvantages of DIY GPS approaches (when there is adequate obstacle clearance) are:
- it increases your workload (especially if you have to put in a lot of waypoints for the approach)
- it's far, far from legal
- you don't have the luxury of published GPS approaches, such as LPV, etc.
- ...

[IO540]

A good summary, but

Back to the topic: In my opinion, DIY approaches aren't the real solution, ATC in many places around Europe would file a report if you got in under very marginal weather. To add, it would be very suspicious if a single-engine GA aircraft made it to the runway (by flying a DIY GPS approach), when an airliner/business jet flying the same approach you tell ATC you'll be flying couldn't.However, this would not happen because DIY approaches get used only in places where there is no IAP published at all. I agree that in Germany, one needs to be very careful because some pilot(s) have been done for apparent IMC flight under VFR, near an airport.

Anywhere where an airliner will be going is going to be a proper IAP.

The main disadvantages of DIY GPS approaches (when there is adequate obstacle clearance) are:
- it increases your workload (especially if you have to put in a lot of waypoints for the approach)True, but normally you don't need many waypoints. You don't need any more waypoints than for any standard GPS approach i.e. the T-shape.

- it's far, far from legalThat depends on where, etc.

- you don't have the luxury of published GPS approaches, such as LPV, etc.LPV doesn't exist yet. I gather there are some trials going on. LPV will be great when it comes, for those who have the latest equipment, but the flight manual supplement is an EASA Major Mod the cost of which (4 figures) will drastically retard its adoption by GA. Also, in the UK, GPS approaches will remain largely irrelevant all the time the CAA requires ATC as mandatory for any IAP.

[IO540]

If it was not for the powerful, well organised and well managed US AOPA, and the long precedent in the USA for GA being used for real travel, I would think that their "sports pilot license" (which doesn't need an aviation medical, provided you have not actually failed an aviation medical previously) is a bad idea because it is the thin end of a wedge which might result in exactly that separation, whose eventual outcome is the pushing of all GA into a VFR-only ghetto in which the only viable aviation activity is £100 burger runs or, for a suitably eccentric retired person, flying a microlight from the UK to Kathmandu against all the odds.

One of the greatest challenges in Europe, for supporters of "private IFR", is how to counter the loud cry of the "professional pilot lobby" that everybody sharing the same airspace must have the same papers, and their aircraft must meet the same requirements.

On any closer examination, that requirement has a poor logical basis but it is emotionally very convincing and a lot of people have bought into it, both in ignorance and because it suits the grinding of their particular axes.

The preservation of IFR capability, fully ICAO, is a cornerstone of maintaining utility value in GA, without which it will end up as a farm strip activity.

[Genghis the Engineer]

FlyingStone - yes I meant the DA20, but I disagree with you about payloads. Take for example a Grumman AA5: IMC capable, MTOW 998kg, typical empty weight about 670kg - that's 1/3rd payload. (Strangely my 1947 4 seat taildragger which has been happily doing long trips for 64 years quite safely is rather better than that, but I'll work with the Grumman as an example.)

So, at 750kg, using the same fraction, that gives 250kg useable payload. Bang on 2x90kg plus 100 litres, or 5+ hours (with a modern engine such as the 912), of fuel.

For that matter, shave 8kg off the MTOW of a Cessna 152 and you have an IMC/night capable aeroplane that falls into the VLA category, with an exemplary safety record, and 260kg useable payload.

So, sorry, I just don't agree. VLA weight limits are quite capable of delivering safe and capable aeroplanes.

But on the other hand I do agree with you, a VLA+night+IMC code already exists in the USA, could easily exist here, and it is nothing but a bureaucratic piece of sillyness that stops that being validated and used here in a Euro-version.


A general question by the way, one can wade through the AIP of course, but does anybody know of a single list of UK airports with GNSS approaches?

G

[Justiciar]

One of the things people in the US are concerned about is GA here going down a similar route - but as it is the idea of GA being a "sport" has not stuck except maybe for specialized areas like gliding and aerobatics

Perhaps "recreation" would be a better word. I would hate the thought of GA going the route I describe but a look at the way European GA has already gone confirms that this is the case. I really cannot comment on the US, which has a much better developed GA scene, I suspect. However, even there changes in lifestyle and cost is having an impact. Certainly the recession has been hard on all manufacturers, but the way the likes of Cessna and Piper are or were going speaks volumes.

Europe is different because there is not the same tradition of touring to the degree seen in the US and today getting anywhere is cheaper with Ryanair, even if it makes you want to kill something afterwards.

[IO540]

It is however the case that on my trips around Europe I see a lot of very nice airports which would not be there if all planes landing were "hang-gliders with a lawn mower on the back" :)

IFR GA is what keeps the facilities up, and what keeps the training system going.

Notwithstanding that the vast majority of the pilots never proceed to IFR capability, eliminating this would push GA into farm strips.

but does anybody know of a single list of UK airports with GNSS approaches?

I am sure it has been posted, but for a start, and taking "GA" ones only:

Lydd
Shoreham
Gloucestershire
Blackpool??

There are others e.g. Gatwick and Heathrow but they are not relevant to GA.

[Genghis the Engineer]

And Exeter certainly.

But, again - is there a central list?

G

[soay]

Blackpool were in the trial, but didn't succeed in getting approval for the approach.

[mad_jock]

Inverness as well.

http://www.caa.co.uk/docs/33/CAP773.pdf

Think it was in 2007/8 I tried it once and it was a PIA because it wasn't in the trimble and the flight conditions that were required meant we could always get in visually and I couldn't justify the additional flight time.

It all came up when they thought they would get EGNOS up and running. Now that hasn't happened so fast it seems to have gone on the back burner.

I can't see european GPS approaches being allowed until the European GPS system is up and running.

UK carries out satellite guided approaches-16/09/1998-Flight International (http://www.flightglobal.com/articles/1998/09/16/42789/uk-carries-out-satellite-guided-approaches.html)

[Genghis the Engineer]

Not having tried flying one, nor likely to for a little while as nothing I fly currently has a panel mounted GPS, does anybody know why when it's (rightly) shown on NDB/VOR/VDF approaches that aeroplanes turn in curves, apparently aeroplanes flying GNSS approaches can apparently achieve perfect right angled changes in heading?

G

[Genghis the Engineer]

This (GNSS) (http://www.ead.eurocontrol.int/pamslight/pdf/4e415453/EG/C/EN/Charts/AD/EG_AD_2_EGTE_8-4_en) versus This (NDB/DME) (http://www.ead.eurocontrol.int/pamslight/pdf/4e415453/EG/C/EN/Charts/AD/EG_AD_2_EGTE_8-5_en).


G

(Qualified, but very inexperienced instrument pilot, and never been trained in GNSS approaches.)

[IO540]

On a standard T-shaped GPS/RNAV approach, the waypoint on the "T" where the vertical bar of the T joins the top bar of the T, is a fly-by waypoint.

This is an illustration of a fly-by waypoint:

http://www.faa.gov/air_traffic/publications/atpubs/atbarc/03-5_files/image004.gif

So, on your Exeter plate, TE081 is a fly-by WP.

BTW, the URL to that Eurocontrol EAD plate will vanish shortly because the company which runs the site changes all the links regularly.

[Genghis the Engineer]

Thanks, I'm now a little more educated than I was yesterday.

G

[FlyingStone]

FlyingStone - yes I meant the DA20, but I disagree with you about payloads. Take for example a Grumman AA5: IMC capable, MTOW 998kg, typical empty weight about 670kg - that's 1/3rd payload. (Strangely my 1947 4 seat taildragger which has been happily doing long trips for 64 years quite safely is rather better than that, but I'll work with the Grumman as an example.)

So, at 750kg, using the same fraction, that gives 250kg useable payload. Bang on 2x90kg plus 100 litres, or 5+ hours (with a modern engine such as the 912), of fuel.

For that matter, shave 8kg off the MTOW of a Cessna 152 and you have an IMC/night capable aeroplane that falls into the VLA category, with an exemplary safety record, and 260kg useable payload.

I think the additional weight on DA20 (which comes with BEM of ~ 550kg) is due to a bit larger permissible flight load factors, which are +4.4, -2.2 for DA20 and +3.8, -1.52 for AA-5 (I believe due to restrictive Part 23 standards for utility category aircraft). The C152 has quite similar permissible flight load factors, but on the other hand - it's the same weight as DA20 and slower for about one third.

Well, anyhow, discussion about VLA weight will most likely be redundant, since the proposal is to lift the MTOM for aircraft certified according to CS-VLA to 890 kg and at least one problem of the standard will likely become history.

[Genghis the Engineer]

I think the additional weight on DA20 (which comes with BEM of ~ 550kg) is due to a bit larger permissible flight load factors, which are +4.4, -2.2 for DA20 and +3.8, -1.52 for AA-5 (I believe due to restrictive Part 23 standards for utility category aircraft). The C152 has quite similar permissible flight load factors, but on the other hand - it's the same weight as DA20 and slower for about one third.

Well, anyhow, discussion about VLA weight will most likely be redundant, since the proposal is to lift the MTOM for aircraft certified according to CS-VLA to 890 kg and at least one problem of the standard will likely become history.

I just tried to look at EASA NPAs for that. I can't see that, but interestingly did find a 2004 EASA NPA for CS.VLA proposing night clearances.

Can you give a reference or link for the 890kg NPA, and has anybody any idea what happened to the night certification proposal?

G

[IO540]

Night cert cannot be a massive "psychology" issue because VFR-only helicopters can already fly at night (UK night=IFR).

IFR cert is a much bigger barrier, and also involves some actual capability e.g. lightning protection bonding, with embedded conductive sheets in the composite surfaces being needed for both lightning and to conduct away static so your avionics carry on working when flying in IMC.

[FlyingStone]

Genghis: EASA 2010-2013 Rulemaking Programme (http://www.easa.europa.eu/ws_prod/g/doc/Agency_Mesures/Agency_Decisions/2009/2010-2013%20Rulemaking%20Programme.pdf) - search for VLA.008.

IO540: Of course, it's not an issue with logics, since many VLA aircraft are equipped for night flying, but we are talking about EASA here, not about somebody with detectable minimum amount of common sense :ugh:

As for IFR, I agree, I think Diamond composite IFR approved aircraft (DA40, DA42) have a metal sheet in the wings and horizontal stabilizator, while DA20 doesn't have it and it's thus highly unlikely it will ever be certified for IFR in IMC flying in Europe, which for me is common sense. The static discharging wicks are also must have (not only for composite aircraft, most metal aircraft have them as well).