IMC/Night for Permit types: Time for a change

[Mike Barnard]

Isn't it time that Permit-to-fly aircraft be allowed to fly in IMC and at night? Many Permit types, if suitably equipped, would be equally at home in such conditions as Certified types, and I'd suggest it's an outdated anachronism that they are not allowed to do so. Indeed, exactly the same aircraft ARE allowed to fly on instruments and at night in many other parts of the world - notably America.

What I'm interested in, is who would support such a move? Many Permit owners would not be interested in IMC or night flying, and that's absolutely fine. Many aircraft on the PFA register could not practically be equipped for it. But then again, I suspect there are quite a number of owners of certified aircraft who already fly IMC, but would be very happy to change to a Permit machine, with attendant savings in cost, and much wider choice of types.

If the degree of interest is sufficient I and others would be willing to work with a like-minded group to explore 'the art of the possible'.

This message also goes out any who would be willing to share their direct experience and passion for helping make this happen. We are confident that with a correctly researched and professionally presented case, now would be the perfect time to push for this privilege within the broader EU framework.

[S-Works]

I would switch to a permit hotship in a heartbeat if I could exercise my IR in one.

Glass cockpits, fast, easy to maintain and cheap mogas, what more could one ask!!

I would be happy to be involved and may even be able to drag AOPA into the discussions.

[coodem]

Thats all that is stopping me flying PFA, I'm sure that most new modern PFA aircraft are better equipt than most of the other IR equipt aircraft dating back to the 70's.(Which happens to be most the aircraft the average pilot can get his hands on to fly IR)

Time for a change I think

[Fuji Abound]

It probably is (time for change) but it would be interesting to know exactly what is involved in gaining IFR certification.

There is the implied suggestion in this thread that it is only concerned with instrumentation, however for me IFR certifcation should also say something about how the aircraft will behave if struck by lightening, or have to cope with the vast amount of water that might be trying to drown the engine in some cloud, never mind how stable the aircraft might be on an approach dowm to minima in choppy conditions.

In short the instruments may well be up to the job, but is the aircraft?

The fact the aircraft can pass through a few hundred feet of benign cloud to cruise "on top" may not be the only use a pilot has in mind once he hears it is "IFR certified".

[Say again s l o w l y]

I think it would be a good thing, unfortunately without an "approved" IFR fit then I'll keep looking for that squadron of airborne pigs. I reckon they might evolve wings before the CAA lets this through!

[smarthawke]

My understanding is that it has a lot to do with an aircraft's natural stability - for the most part non-certified stuff aren't as stable as certified. Of course if a particular type could be proven to pass the required standards that a certified aircraft complies with then who knows.

For now, I'll be happy when the UK air is proven to be as strong as that in the rest of the world to allow RV-6s to aerobat (legally...)!

[Humaround]

I doubt it's true that Permit aircraft are inherently less stable than certified types. There is a big range of performance and characteristics on the register.

Vans RV's, for example, (many of which fly IFR in the States) may be very responsive, aerobatic even :) but they fly as if they're on rails. Responsive doesn't equal unstable.

[Mike Barnard]

Paul and others, thanks for your supportive input on this.

The 'specific approval' route had also been in my mind, however to get there we need a good deal of objective data. Most of this is likely to be available from within the aviation fraternity itself ... most flyers relish a challenge, even more so if it means fighting for new freedoms even for other folks.

So, we’re already soliciting input from a number of aviation forums to gauge interest and comments. And it’s coming in thick and fast.

But we need objective data showing whether homebuilt IFR operation is statistically more risky than certified IFR operation taking into account variables such as pilot experience, actual weather conditions etc. Also the degree of risk undertaken by 'scud runners' vs. moderate IMC flight. I'm confident sufficient contacts exist to help with this within those countries which permit homebuilt IFR.

Aircraft stability requirements will be crucial, so let’s propose a set of realistic criteria rather than simply acceding to Design Guidelines written around the needs of aircraft built to carry fare-paying passengers. Again, we can look to folks in other countries for assistance.

Aircraft systems, too will need evaluation and a pragmatic recommendation based on a realistic Risk Assessment / Hazard Analysis. There's a good starting point already at http://www.pfa.org.uk/cgi-bin/ultimatebb.cgi?ubb=get_topic&f=8&t=000889#000005.

We'll also need help on Law vs. Guidance, and particularly those which were initiated in an earlier era and where progress has overtaken the original need. UK overflight is one example. Hands up anyone?

Also operational limitations. The ambition is to satisfy the genuine needs of the majority of Night/IMC users, not built 200+kt hot ships capable of flying auto-land in 100m vis. Using a hand-held GPS. Perhaps a departure vis of 1800m, an approach cloudbase of 500', no forecast icing or convective activity would be realistic?

That each homebuilt is subtley different may possibly be overcome by approving both the specific pilot and the specific aircraft together?

Lastly, both Francis and Graham at PFA HQ have kindly offered their support (NOT time!) to help guide and critique this effort.

As you can see there’s much to do, so to repeat the original plea … if you can help in any capacity, we’d love to hear from you!

[justinmg]

I got my IMC 18 months ago. I then got a PFA aircraft 6 months ago, and wish that I could fly IMC.
My RV9 is just a stable as the PA28 I trained in. I am fully in favour.

[smarthawke]

The stability issue was told to me by an ex-CAA guy with 18,000 hours of small plane experience and is more about positive stability issues way beyond what we normal pilots encounter in normal flight.

This was a conversation after he'd done some wonderful unusual attitudes in my RV-6 and thought it was an absolute delight.....

With Permit aircraft still unable to cross built up areas at any height despite my 6 cruising at 160kts IAS whereas an Auster or Chipmunk can legally do the 'able to glide clear' bit, I fear there are many rivers to cross on the way to Permit aircraft flying IMC - but good luck!

[DaveW]

With Permit aircraft still unable to cross built up areas at any height...

There's encouraging movement on that front as well; the PFA submitted a paper to the CAA proposing removal of that restriction about 3 weeks ago, according to Graham Newby on the PFA bulletin board.

I have to say that this initiative, the overflight removal one, a possible upcoming EASA "Experimental" category and potentially a more accessible JAA IR are all reasons to be more positive about GA operations than for several years. (OK, there are some opposing negative issues such as encroaching CAS, Mode S, much more commercial traffic in Class G etc, but on balance I'm feeling the glass is being topped up to half full. :ok:)

[DaveW]

So to get PFA-issued permit a/c exempt from the daytime VFR restriction would first involve getting the CAA to lift the restriction that aircraft directly permitted by the CAA could be exempt from the restriction. Therefore, the process has nothing to do with the PFA, except as a potential lobbying force.

But that's exactly the point - to make a compelling logical safety case (by lobby) to the regulatory authorities - CAA/EASA - that aircraft that currently operate on a permit, with suitable flight characteristics and equipment, are acceptably safe for the permit to cover flight in other than day VFR.

I don't understand your contention that e.g. Vans offering certified aircraft would be cheaper - that's certainly not the case in the US, where Experimental RVs have been flying in night and IMC for many years.

[D SQDRN 97th IOTC]

will be on a permit to fly
can't imagine the CAA saying that aircraft has to bimble around at 1500ft VFR with all the cessnas and PA-28s in the Barkway to Brookmans PK gap in between Luton and Stanstead when it goes to Biggin for the 2008 airshow....
I think CAA will eventually allow some aircraft to operate IFR
But don't hold your breaths

[DaveW]

The Vulcan's permit will restrict it to VFR.

I'll try and find a link to confirm.

[Mike Barnard]

Hi DaveW,
Any luck with the Vulcan VFR question ?
Mike

[DaveW]

Sorry - forgot to look!

Have done now, and Post No.7 on this thread (http://www.tvoc.co.uk/forum/cgi-bin/ikonboard.pl?act=ST;f=35;t=23) on the 'Vulcan to the Skies' web site forum states VFR only.

She will also be limited to 17,500 feet altitude.

[IO540]

The stuff about permit types not having good enough stability is rubbish, if made as a general statement.

There are various things which affect whether IFR certification is possible. I don't know much about this but it's stuff like sufficient provision for conducting lightning strike currents. Gliders have had their control cables melted by strikes - this is not useful!! There is a long list of stuff which has to be complied with; much of it is probably out of date or debatable but some is sensible.

The reality is that a clever instrument pilot can fly what I would call "imaginative VFR" and - ecept for not being able to overtly fly approaches around Europe, or depart into low cloudbases - get away with it. This is what a lot of the "lightweight category" crowd undoubtedly do and this is what I would be doing if I had one. Many are fully IFR equipped; they can have great glass cockpits, 3 servo autopilots, you name it.

In the UK this isn't an issue because of lack of enforcement of obvious breaches of VFR rules, so people depart "VFR" into OVC005. This is fine if you have the kit and know what you are doing. Having the legal certification allows you to do it abroad. So it's no use looking at the CAA - their hands are tied by ICAO CofA requirements. The US Experimentals can fly IFR in some cases but they can fly only in US airspace....

[DFC]

IO540 makes a good point- US experimental types can do all sorts of things - but only in CONUS.

Forget the Vulcan - I expect that we are talking about piston engines types for this proposal.

No overflight of built-up areas at any height, no night flight and no IMC are in a large part down to the fact that in general it is accepted that a permit to fly aircraft is likely to have an engine faulire or even a series of engine failures in any one day. It was not unusal in past times to have 2 or 3 failures in a good days flying on an old 2 stroke.

In recent times engines such as the Rotax 912 have brought reliability close to that often available from Lycoming and Continental types.

One cal lobby all one wants but without data, the CAA or EASA is going to find it hard to justify making changes.

Who is going to complete and pay for the certification flight testing, reporting and other reams of work required to progress such a proposal to EASA approval.

The result will of course be a fully IFR equipped and mose S equipped aircraft with several Kgs of equippment. How many will spend £10s of thousands equipping their low cost aircraft for IFR flight just to sit and wait for their slot time.

Think beyond the bimbling round in Class G - there will not be much of that available to IFR flights who can not meet the full certification requirements including pilot licensing in the not too distant future.

The CAA are perfectly willing to lift the no night flight no aerobatics and no IFR flight from a permit to fly provided that the proposer can demonstrate to the satisfaction of the CAA that safety is ensured.

Please feel free to spend £500,000 to £750,000 doing that for your £20,000 or less aircraft.

Let me know when you are starting, I'll help you spend your money. :D

Regards,

DFC

[MikeJ]

DFC,
Its so depressing that someone with obviously so much experience and knowledge has the image you give of permit aircraft.
The 1980's saw the start of the major revolution in volume, very high quality, kit production in the US, all based round certificated engines. After the Glasair and Lancair came the Vans RV series. Ther are now over 5000 RV's flying in the world, nearly all having Lycoming or Continental engines, only the very latest, the RV12 has a Rotax 912, now that they are certified. There are, of course many other types, but several RV10's are being built in the UK, with 260hp Lycoming 540 engines and 4 seats.

Of the 2000 PFA aircraft flying in the UK, many hundreds not only have certified engines but full panel of primary instruments and decent avionics. What is so wrong is any implication that the same limitations should apply to all of the very wide range of quality of permit aircraft.

You seem to talk with some authority in saying that the CAA will relax these limitations if shown that there is no safety issue. This does give me a crumb of comfort. But to suggest that this should mean satisfying full certification requirements must be absurd, especially given the excellent record of safety of this class of aircraft, and the lack of bad experience in the several countries which allow IFR in those homebuilts which meet specified, reasonable requirements.

[IO540]

As I said, it's not up to the CAA. The CAA could allow you to fly anything in UK airspace. You can now buy a lightweight plane (I use the term loosely) and fly it in the UK, no problem.

But you need a permit to go abroad. The time to get this varies, according to my information. Think of it as having to do the Special Branch for Jersey/Ireland/IOM notification but instead of 12hrs, having to apply anything up to 1 month in advance. It's a bit like a little project of mine: popping across from Crete to Libya; reckon on a few months to get it sorted (I gave up).

To some, this is OK, and of course if you never go abroad (sadly true for the vast majority of UK PPLs) it's also OK. There are also a lot of retired people in GA and they tend to have plenty of time on their hands. Otherwise, a sub-ICAO aircraft is completely useless.

And for JAA to agree to some kind of pan European scheme would take years.

Now, EASA have taken over certification from JAA and they appear sympathetic to the issues. However, they are under-staffed and are (AIUI) subcontracting a lot of the work back to the national CAAs - this is a bit like getting a convicted shoplifter to manage your shop because you haven't got the time to run it. I guess that in a few years' time this will change... then we might have a pan-European entitlement to fly the lightweight types, and that would do most people because European geography is relatively contained. Not many pilots fly to Africa, or Russia, or the Middle East.

I don't think DFC works for the CAA but the CAA is irrelevant now, other than a delaying mechanism.

As to lightweight planes flying IFR around Europe - I don't think people appreciate the kind of mission capability that is required. I know every pilot reckons his plane is the real entry level for proper flying :) but look at this: the bases of Eurocontrol routes are about 7k ft. The 0C level in N Europe tends to be ~ 10k much of the year. The terrain of course varies, from zero to 10-15k ft. Cloud tops (stratus) tend to be 8k-16k. To do this properly you need a plane which can climb to 18k feet, possibly collecting a bit of ice on the way up. Most permit types can't do that. Many don't even have a half working heater. You also need the equipment to navigate and communicate, fly absolutely any published instrument approach (details given to you with 40 miles to run). Oxygen, naturally. You also need an IR............. there is close to zero chance of anything significantly changing on that one in the next few years.

One could build a fantastic non-CofA plane which would run circles around most current IFR tourers but marketing issues ensure that non-CofA types are lacking in some essential departments, to keep them cheap while good enough for VFR. AERO 2007 had hangars full of these things and they are great fun for VFR (and drilling unofficial holes in clouds when necessary) but won't hack it for long legs at FL160.

So there is more to this than first appears.

The actual flying in airways is a piece of cake. There is a great void below ~ FL290 in which there is practically no traffic, but you need to be able to get up above the tops, say FL160, in the first place.

It's also no place for engines which, according to many, fail every few hundred hours. That is complete unacceptable. Rotax engines are much better now but US schools have been chucking Rotax engines planes as fast as they can get rid of them, due to constant failures.

As regards flying IMC in the UK, you can do it right now, in anything. It may be illegal but you will not get caught if doing it enroute. I think the "could not care less" attitude to what people do in Class G is largely accepted by the CAA, but the downside of this is that they don't feel any pressure to do anything official.

[scooter boy]

Having flown permit and certified on both sides of the Atlantic I can tell you that the US system of allowing night and IMC for permit aircraft works well provided it is interpreted sensibly.

Factors getting in the way of this are - generally worse Wx over here, very limited range of night flying destinations over here and higher population density over here i:e you are more likely to hurt someone on the ground if you mess up.

I agree with a previous poster - there is a huge chasm of difference between ascending/descending through a couple of thousand feet of warm stratus to get on top and flying in solid IMC/icing having departed into windy OVC 0200 and landing into the same.

IMHO the best way is to continue with the current system, i:e loosely interpreted VFR for permit aircraft, the minute the CAA get involved the price will become astronomical, the aircraft will weigh a ton and you will be wishing you had never asked for it - after all if you do mess it all up in IMC the chances are you are not going to be around to face the music, so why do you need it to be legal?

SB

[MikeJ]

IO540,
I generally find I agree with your approach to flying matters, but your last post on this thread does need some response.
1. The CAA is the sole authority on limitations on UK permit aircraft. Not only does the CAA have unfettered rights under the ANO to set such limitations as it thinks fit, but EASA specifically has no authority, at least at present, on Annex II aircraft, which include all home built aircraft.

2. The 1980 ECAC Protocol specifically enables home built aircraft of any signiture country free access to all others. Whilst politics being what it is, not all European countries signed it, and inevitably, it is being interpreted slightly differently where it has been signed, particularly in relation to microlights. Nevertheless, for Group A homebuilts, free coming and going without prior permission of UK aircraft is welcomed by Austria, Switzerland, Germany, Holland, France, Hungary, Ireland, Denmark, Sweden, Finland, France, Luxembourg, Malta - (just some examples). Some others, eg Norway, Spain, Portugal, require prenotification a couple of days before by fax of Permit and Insurance, response always having been positive.

Standing out is Belgium, that centre of EU cooperation, who almost alone require a fee, 80 Euro, to be proven to have been paid before they give permission. Nevertheless, there is no significant restriction on European flight in UK Group A homebuilts. There's a paper on this on the PFA web site.
Interesting that the C.I. preserve their independence by requiring prior permission, but state that this is given by their acceptance of the flight plan. No hassle at all, I go there often.

3. As you say, 90% of PPLs don't fly abroad. Why is it not highly desirable to give at least those a very valuable upgrade, for useability of their aircraft in UK weather?

4. Very few PPLs ever fly at oxygen FLs, and your comments on this are almost irrelevant to the overall benefit to the majority. However, the very flexibilty and performance of the best kit types would give exactly the same, or better, facility if IFR flight is allowed, than you have in your TB20. I have seen a 300hp kit plane under construction which is having an oxygen system and de-iced prop fitted, in expectation of eventual IFR approval. It will cruise at least 40Kts faster than yours. And don't forget that Glasair III with a 450shp turboprop which had a photo shown on another Pprune thread a few months ago!

All the best, Mike.

[IO540]

Mike

We probably got our wires crossed on the presumed context of all this.

Even limiting IFR to the UK means potential airways operation, with the altitude/oxygen issues. I suppose one could limit these types to below Class A airspace which would be rather novel...

I would love to have a 450HP turboprop, and loads of homebuilts will run circles around a TB20 right now. I just don't think the powers to be are ready to swallow IFR flight for sub-ICAO planes, because of the implications within the UK, never mind abroad. They can't even agree to training at unlicensed airfields........

The info on 1 month wait came from a Permit flyer (on here, I believe) who waits for up to 1 month for Spain to get back to him.

I feel that in Europe an IFR approval is always going to be wrapped with a full CofA. That is how the regulation is set up. That then opens up the whole IFR can of worms.

[Mike Barnard]

I read the recent threads from DFC, IO540 and Scooter boy with great interest but with respect feel they may be missing the real point. Which is, to work together to create a rational and professional case to enable certain UK CAA Permit aircraft to operate Night and IFR in the UK. Sure, there may be some give and take to achieve this, but that's the reality of life. The game has moved on significantly in the last decade!

I'd truely welcome any and all support to help make this a reality; please PM me and I'll be please to talk it over.

Mike

[IO540]

There would be two ways to approach this:

The CAA could do a UK-only scheme. However, AIUI, EASA will have jurisdiction ever all this within a few years so this could be a wasted effort. OTOH the CAA appears to have been rather keen lately to work on a JAA IR proposal with a reduced theory content (much discussed in this forum) in the sure knowledge that EASA has already stated it wants to do something pan-European, so the motivations are clearly complex...

EASA will be running the show soon, so why not let them do it. Then we could have a pan-European scheme, which would be not only much more useful but also future-proof. They have made various noises on this subject already.

Re the business of not many PPLs ever going abroad, on reflection I don't think this is correct in this case. The population of pilots flying non-CofA types (with reasonable performance) is quite different from the much larger population of PPLs who never venture abroad. I think the former group are largely in flying for the long term, while the latter group is a much more transient portion (renters, mostly) in which most individuals will pack it in within a year or so anyway. So flying abroad would be a very significant utility to Permit type owners.

[VH-BOX]

While not holding out much hope for change, I must admit to being disappointed that an aircraft like the Stinson 108, renowned for its stability, light control forces, and ease of use on instruments, is restricted to day VFR ops. That is just one example, but there are many types previously certified, but no longer directly supported my their manufacturers, which are now operating on permits. While I can maybe see merit in the argument that non-certified types MAY constitute risk, I do not see how 'orphaned' previously certified typed do, assuming of course that this is the case, what with me being in Australia and a bit 'out of the loop'.

[Mike Barnard]

Hi!
Thanks for your latest post. The working group could always use more help, so if you're willing please let me know! 01295-770219 / 07914 976262.
Our strategy is simple:
If we want something done we have to rely on self-help. Waiting for 'others' to do this isn't an option
The UK CAA route is vital both to have the privileges granted in the UK and this have a stronger and reasoned arguement when in due course but probably MUCH later EASA take over national Permits.

Look forward to hearing from you

Mike