VFR flight on-top

[englishal]

The holder of an FAA PPL/IR can regard that as equivalent to a PPL/IMC for flying G-reg aircraft in the UK (I think the CAA has to "validate" it, for a fee).

Not quite. The FAA IR will allow flight in "Uncontrolled airspace" in accordance with IFR but not in "Controlled airspace". The IMC rating allows flight in class D "Controlled airpspace" and below but you do need the IMC rating issued (for 64 quid) and hence a CAA / JAA licence to add it to.

Now I believe there is some confusion as to the meaning of "Controlled airspace", I believe the intention is /was to allow a foreign IR holder to fly in accordance with IFR everywhere except class A airspace - "Controlled airspace with reference to IFR flight" (hence the same as an IMC holder), but because of the wording in the ANO which states "outside controlled airspace" this effectively bans flight in any controlled airspace. The CAA used to have a FAQ page on their website which states that a foreign IR holder "Can exercise the same privileges as an IMC rating holder" which was removed, probably at the onset of JAR. The original IMC rating issued on a CAA PPL I believe had the same restrictions of "outside controlled airspace". Now did this mean completely outside CAS or just outside class A CAS?

To be continued......

EA

[DFC]

The old IMC rating had a restriction "only outside controlled airspace".

When this restriction was in place, it had the same effect as the current restriction because places like Bristol, Cardiff, Southampton, Bournemouth etc had no "controlled" airspace.

At that time all such airfields had "Special Rules Airspace".

The system changed with the introduction of Classes A to G.

Showing my age now!!

Regards,

DFC

[2Donkeys]

Not strictly true DFC. You may recall that there was Type A and B special rules airspace. Certain Special Rules Airspace was OK for IMC ratings, many were not, as you say.

I understand Englishal's point, having discussed it at length a month or so back. I am less convinced that having the theoretical ability to fly IFR outside controlled airspace has any practical meaning in countries outside the UK. Most places don't segregate IFR flights from VFR using controlled airspace in the way that we do, and insist on an IR for all IFR flights irrespective of the prevailing weather conditions.

Its an interesting debate, but perhaps an academic one only.

2D

[IO540]

Presumably it is academic because once one needs an IR, one can fly in the airways, so IFR outside CAS becomes less significant. But some people might like to get a view out of the window, while retaining the ability to fly in IMC/on-top as necessary.
This is relevant outside the UK.

[Bluebeard777]

As an FAA PPL I have wondered what "in sight of surface" means in the UK, in practical terms.

When you're flying along above broken clouds, when the gaps in the cover are getting smaller, at what point are you no longer in sight of the surface? Is this to be construed literally?

For example, if you can see 10 miles away a dark patch in the cloud cover, which you interpret as a hole, is this sight of the surface? Or if you can see a mountaintop 50 miles away, is this sight of the surface? (!)

[pulse1]

I would be very interested in some thoughts on Bluebeard's question too.

For example, sometimes you can be flying across the channel and experience extensive sea fog. You can know that the weather at your destination and alternate is CAVOK but, for some miles in mid channel you cannot see the surface (although you can kid yourself that you can see it in the distance).

Over land that would be unacceptable, for me anyway, but over the sea there is little chance of hitting anything if you had to come down with engine failure.

[englishal]

The point I made earlier is totally academic, however if the CAA turned around and said "a foreign IR holder can exercise the same privileges as an IMC holder" then this would allow flight in Class D and below, and hence if the French agreed to allow the same privileges as the CAA allow in a G registered A/C then you could enter airways in France and file an IFR flight plan.....a cheaper alternative to the JAA IR for the PPL.....

Cheers
EA

[DFC]

2Donkeys, you are correct. In fact shortly after the introduction of the A-G system, IMC holders could only fly IFR in airspace published for the purposes of section whatever in the ANO. Not every class D zone counted...example, Cardiff was OK for an IMC holder but Manchester was not. I think that the latest version is the more simple and thus safest.

Bluebeard777,

Very good point.

A pilot who is a NPPL holder can fly at 4000ft, 1000ft above a solid overcast. The flight is legal because 20nm in the distance, the surface of Ben Nevis is in sight sticking up above the overcast.

Perhaps this case clearly shows that having the current rule has no basis in safety.

My suggestion would be for the law to be changed to enshrine a requirement for a pilot to always be in a position to reach the surface without flying outside the privileges of their licence if an engine failure required the aircraft to land. Note that I say "reach the surface".

Thus;

Pilot flying above an overcast would need an IR or IMC in a single engine. In a multi, an IR or IMC would only be required if the single engine ceiling was lower than the required distance from the cloud tops.

Pilots flying above Scattered or Broken cloud without an IR or IMC would need to be able to glide clear of any clouds in the event of an engine failure.

By making such a law, the CAA would get away from a position where the passengers of a non-IMC trained pilot flying above 7/8 cloud cover will have to depend on luck in surviving the descent through cloud by not just a pilot not qualified for flight in IMC.......but one faced with a serious emergency plus having to cope with limited instrumentation and dwindling electrical supplies.

How many basic PPLs can do a descending turn on limited pannel, not knowing that the pannel has been limited in the first place?

I don't relish the idea with an IR!!

Regards,

DFC

[S-Works]

I have just come back from the USA having started my CPL/IR out there returning in the new year to finish.

As I understand it the holder of an FAA IR rating can fly a G-REG aircraft in all UK airspace IFR. They can fly an N-REG anywhere in the world on IFR.

[2Donkeys]

Bose-x

Nope

An FAA IR can fly a G-reg aircraft under IFR only outside controlled airspace. On the strength of their FAA IR, they can apply for and receive an IMC rating which extends these privileges in line with the IMC rating.

Only in an N-reg can the FAA IR enter all airspace under IFR anywhere.

2D

[FlyingForFun]

Bose,

If, as I suspect, you're talking about flying in IMC, I agree with 2D's reply.

If you really do mean IFR, then remember that you can fly IFR in the UK without an IR or IMCR - you're just not allowed to fly in IMC.

FFF
--------------

[2Donkeys]

FFF

A Foreign ICAO licence (without an IR) is endorsed valid by the CAA for VFR privileges only. This is something of a moot point, but worth noting in the back of the mind.

2D

[FlyingForFun]

Interesting - didn't know that!

FFF
--------------

[2Donkeys]

Actually.... I modify that very slightly. Where your foreign licence permits just VFR flight (as most do, without an IR), this is all that is allowed in the UK with your CAA endorsement. Effectively, the CAA endorses your licence with all the limitations of the underlying... irrespective of the flexibility of our airspace.

2D

[S-Works]

Curious, I was under the impression that an FAA IR could fly airways in a g-Reg a/c. It seems to me that american instrument pilots who fly big jets into the UK seem to do it without problem!

So obviously what we are saying in the view of JAA is that when you change the writing on the side of an a/c from N to G the pilot becomes incompetant?

So, how do I put my A/C on the N-Reg???

B

[2Donkeys]

Curious, I was under the impression that an FAA IR could fly airways in a g-Reg a/c

You are not alone in making that mistake, but the rules are unambiguous.

The argument is often followed up with "... so the CAA think that American Airlines Pilots flying Boeings into Heathrow have similar skills to the average IMC holder..."

The FAA has a specific flight test for the ATP which is conducted substantially on instruments and to tougher margins than the CAAFU IR test.

The US IR flight test is IMHO an easier flight test than the CAA test. Whether it is so much easier that FAA IRs should only be granted IMC ratings on application, I don't know... But that is the way it is.

2D

[S-Works]

Fair enoug on the ATP stuff, but if I put N on the side of my aeroplane I can fly airways so why not with a G?

The IR training I have received in the US was of a very high standard so why is it considered inferior in a G-reg aircraft?

[2Donkeys]

It is an old an tired argument about the differences between the US IR and the CAA/JAA equivalent.

Although the FAA IR does require lower flying standards than the JAA equivalent (check out the ILS deviation allowed in the FAA PTS) I don't think that it is sufficiently different to prevent the CAA from endorsing it over.

I suspect that they don't really want to encourage lots of tiny aircraft into controlled airspace...but I may be wrong.

2D

[IO540]

Much more likely, it is a political and fund-raising issue and nothing to do with pilot skills. The FAA IR is perfectly good enough for PPL-type flying. But the CAA is not going to encourage a wholesale move of aircraft to the US register. They would lose the CofA fees, for starters. There are many people in the CAA whose jobs depend on this income.

The CAA's argument (which I heard in one of their safety presentations) is that (paraphrasing) they are responsible for crashes in UK airspace so they should get the money from aircraft and pilot licensing...

The CAA make very sure that commercial operations are on the G-reg (and require an AOC, another nice dollop of cash to the CAA). Private GA is on the fringe and they just do what they can to limit the "damage" done by migration to the US register; they cannot stop an ICAO (FAA) license holder flying a G-reg here but they could stop the "UK-resident N-reg" business completely. They have presumably decided not to do that.

[englishal]

The difference between JAA IR and FAA IR is:

about 9,000 pounds,