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Descending through cloud without a procedure

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Old 17th May 2006, 15:19
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justinmg

In the CAA doc you link to the words "To conduct an ILS approach
inside or outside controlled airspace one (FM immune) ILS receiver is
required" do indeed appear. The question is where from; the CAA writes a lot of "guidance material" which has no legal basis.

Referring to Schedule 5, ILS (category G in the table) is required when

(c) when making an approach to landing at an aerodrome notified for the purpose of this sub-paragraph

I don't disagree with you at this point (though your view is suprising since a lot of people have looked at this before) but where can one find a list of aerodromes notified for the purpose of the table in Schedule 5?

rustle

My "sample size" of IMCR instructors is about 10, over say 5 years, of which none had a valid IR, and only about 1 or 2 ever held an IR. For various obscure reasons I flew with several myself, none of them being any good for teaching how to go places.

My comment on JAA IR training not teaching people how to get about on the practical UK IFR scene is confirmed by every JAA IR holder I have met; perhaps a dozen. The JAA IR training is wholly geared up for would-be ATPs. However, all of those I have met knew the stuff from previous experience, typically using the IMCR, so they were not in the slightest bothered and they just regarded the "IR" as a highly desirable airways ticket. The poster starting this thread seems to be an exception in that he seems to have got himself an IR without ever having done any real IFR flying, which is very unusual for someone who isn't an aspiring ATP (perhaps he is).

I can also add, from personal experience, that the FAA IR does teach you what you need to know to fly IFR/airways. Unfortunately it teaches this relative to the American IFR system. In Europe, airways route planning can be a nightmare, and in the UK pilots do stuff which Americans would be horrified at (like DIY approaches) but then the Yanks don't need to do them because most places over there have an IAP.

My comments on the general standard of PPL training being crap are based on a pretty large sample size of instructors. Also, every time I fly I see or hear somebody whose instructor should be spoken to.

I think a lot depends on the pilot's motivation. Probably the majority of punters just want to learn to fly for the fun of it, and post-PPL there is very little motivation. It's also difficult to rent reasonable quality planes and even when you can you cannot take it away for a holiday etc.

Those with firmer ambitions and suitable budgets become owners or part-owners and they have a strong incentive to push themselves beyond the training they receive. They do real long trips, navigate with better methods, and take extra time to learn the more advanced stuff. This applies to both the PPL and the IMCR level; an IMCR holder without proper access to something decent is going to chuck it in pretty soon too.

Unfortunately only a tiny minority of punters are in the above category, so the training business doesn't have to produce competent pilots. If they did, the PPL would be 100hrs min and few would bother. So I can comment but I can't offer a solution. If every punter turning up with a PPL came along in a modern spaceship and wanted an instructor who will teach him how to get about the UK and Europe, there would be mayhem.
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Old 17th May 2006, 18:30
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Originally Posted by IO540
justinmg
Referring to Schedule 5, ILS (category G in the table) is required when
(c) when making an approach to landing at an aerodrome notified for the purpose of this sub-paragraph
I don't disagree with you at this point (though your view is suprising since a lot of people have looked at this before) but where can one find a list of aerodromes notified for the purpose of the table in Schedule 5?
Agree absolutely. I rang Humberside and Doncaster (SATCOs), and they were not sure but thought that they were included. I asked the CAA but they did not understand the question. Might try again.
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Old 17th May 2006, 20:03
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Thanks Flyingforfun, an interesting reply.

Rustle said:
The poster starting this thread seems to be an exception in that he seems to have got himself an IR without ever having done any real IFR flying
Too true Rustle, looking back at my logbook reveals an astonishing 10, yes juts ten IFR flights before taking and passing my multi engine IR. There were a few flights just doing approaches and the rest was in a sim. But I basically have no experience of real IFR flying, and even less of planning routes since it was all laid out on a plate (excuse the pun). I know several people who did their IRs at other schools and are in the same position as me.

Frankly I am in awe of people who can jump in a plane and fly long distance IFR 'off the cuff'.

While I have little sympathy for an fATPL or IR holder and/or flying instructor who doesn't know the "rules" about, or procedures for, descending through cloud
Its not that I don't know the rules, its that I was not tested or trained and have never had to descend through cloud in uncontrolled airspace. The only time I have descended through cloud has been on ILS and NDB approaches at familiar training airports with a zillion hours instuctor or examiner by my side.

I'm not looking for sympathy, I'm looking for advice, and I think quoting my profile shouldn't have any bearing on this. Just because I instruct doesn't mean I have to be a super proficient walking-IFR-rule-book-pilot. Bear in mind, I have only done 11 IFR flights the last of which was nearly a year ago.
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Old 17th May 2006, 20:25
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Dude

It was actually me who wrote the first quote you attribute to rustle

The best way, perhaps the only way I can think of, of learning how to fly private-GA either in

a) airways around Europe, or

b) IFR around the UK (IMC Rating sort of thing)

is to fly around with someone who knows how to do it. And the two styles are significantly different.

I know of a number of serious-budget people who went to the USA, came back with an FAA PPL/IR, bought a brand new top-end IFR piston single, and "rented" somebody like that to fly with them to far away sunny places.
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Old 17th May 2006, 21:21
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Isn't IFR flying in controlled airspace just about filing a sensible route at a sensible level, picking up a clearance then either fly the route as filed if cleared or following headings and altitudes as assigned by ATC. In uncontrolled / class G you plan a sensible route and altitude/level and try and get whatever radar service you can along the route.

Its not really rocket science! I think the art is more pre-flight / groundbased in making the right go/no go descision based on forecasts, alternates and available outs with sensible fuel reserves for the conditions!
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Old 17th May 2006, 22:26
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To look at the equipment requirements first.

There is a big difference between a requirement for certain certified and serviceable equipment to fly in certain airspace and a requirement to have certain certified serviceable equipment in order to complete a procedure that relies on that equipment.

For example and authority may require that all aircraft operating in certain airspace classes must have 75Mhz Marker beacon equipment. That does not mean that a) without a marker beacon receiver it is OK to fly in airspace of that class because there are no markers in that airspace. or b) that there will be any requirement to use the marker beacon equipment in certain airspace of that class.

That is simply that authority saying what equipment is required before flying in that airspace class.

In general in Class G, no equipment is required. However, if you decide to fly IFR in IMC with no serviceable certified nav equipment and either infringe airspace or have a CFIT or near CFIT accident, or get lost and run out of fuel then it probably goes without saying that the operation was reckless.

As for flying an ILS with non-FM immune equipment.

All ILS equipment is unserviceable unless is meets the requirements of Annex 10. Meaning that unless the equipment is FM immune then it can not be relied upon to fly an ILS.

Similarly information provided by a non-FM immune VOR receiver can not be relied upon because according to Annex 10 it is unserviceable.

NDB and DME equipment are not affected by the FM issue.

Can you rely on a non-FM immune VOR? - NO.

Why, because it is legally U/S.

Can you rely on a non-FM immune ILS? - NO

Why, because it is legally U/S.

There is nothing wrong with using a non-FM immune ILS or VOR in a situation where the actual position of the aircraft can be confirmed by other means eg visual. eg when training and the aircraft is in VMC but the student is behind screens.

When talking about non-FM immune VOR and ILS systems everyone seems to think along the lines of so what, the errors are mostly theoretical and as I am only using it enroute well above obstacles there will not be a problem.- Wrong!

VOR tracking is often used as the basis of procedural ATC separation. Using non-FM immune equipment could cause a loss of separation........which would be reckless would it not?

I am sure that no one here would try to fly an ILS with a U/S ILS system anywhere. For non-FM immune read U/S for IFR IMC purposes.

--------------

As for DIY approach procedures.

Yes indeed, the 1000ft within 5nm of the aircraft requirement does not apply when approaching to land. After all at touchdown the separation is 0!. Furthermore, when completing a published approach procedure, the obstacle clearance will be at times less than 1000ftand the area taken into account far smaller than 5nm from the aircraft.

So yes indeed there is nothing stopping someone at the moment from constructing a home made procedure. If that procedure does not comply with the requirements of DOC8168 then it is very easy to say reckless operation when something goes wrong.

There is one other fly in the ointment..........the navaid used must have been approved for use as an approach aid. One can not use an enroute VOR/DME as an approach aid. Such use as an approach aid requires a survey and a calibration flight..........all very expensive.

Thus the CAA are indeed quite happy for a person to construct a homemade procedure and do the obstacle survey, non-visual aid survey, flight checking by an approved checker, design of the procedure accordng to DOC8168 by a qualified procedure designer etc etc..........all for personal use to show that the operation is not reckless endangerment!

Otherwise, you could simply have a rule that you will be visual at the enroute MSA. As I am sure you will know that system has other benifits relating to the requirements to have alternates for IFR IMC flights.

Regards,

DFC
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Old 18th May 2006, 00:39
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I've just started IMC training, and one of the first things that was re-iterated from night rating days was that if (in Class G or in the Procedure) you're in IMC, you do not decend below your MSA or MDA, no matter how well you know your position.There aren't any rules regarding descent through cloud as such in Class G, so the normal cross country nav theory applies.
Regards
JonW
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Old 18th May 2006, 07:22
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DFC

As is often the case, you mix up real stuff with your imagination, making it all sound very authoritative. I just hope that you are not an instructor! I have known a number like that; they make up stuff as they go along, all very convincing.

In general in Class G, no equipment is required. However, if you decide to fly IFR in IMC with no serviceable certified nav equipment and either infringe airspace or have a CFIT or near CFIT accident, or get lost and run out of fuel then it probably goes without saying that the operation was reckless.


The above is an example.

In any discussion of what is legal, one must totally separate what is legal, and what is sensible. Otherwise, the discussion descends into something totally pointless.

If you want an example of "reckless" look no further than the standard practice in the flight training industry where people go off flying having checked their fuel on board purely by reference to a piece of paper back at the school.

Can you rely on a non-FM immune VOR? - NO.
Why, because it is legally U/S.


Then, close down all flying schools. They train with non-FM VORs all the time Reference please for the words "legally U/S".

One can not use an enroute VOR/DME as an approach aid

Reference please, applicable to private flight.

JonWhitehouse

Very true about not going below the MSA but you have to land eventually. Obviously one would rather land at a proper airport with an ILS or whatever, but the point is that it is legal to fly a DIY instrument approach.

It goes without saying that one must do it very carefully but that is a whole different point.

One day, probably after a lot of the CAA have retired on their generous civil service index linked pensions, we might get GPS approaches into airfields that currently have no approach at all (and have no ATC which is a requirement for any published approach at present). Then, these discussions will be as moot as they are in the USA right now.
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Old 18th May 2006, 10:10
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IO540,

To put it in simple words;

A non-FM immune ILS or VOR system is U/S. Put another way, it no longer meets the required standard for it to be used as intended.

It is not sensible or legal to use U/S equipment as a sole source of navigation information on an IFR flight.

What you say about the fuel issue is totally true and an unnecessary shoddy practice in this age.

Then, close down all flying schools. They train with non-FM VORs all the time Reference please for the words "legally U/S".

No. I said that there is nothing wrong with this provded that another appropriate way to confirm the position of the aircraft is available. You will find that most of those schools will do the IMC training in VMC and in visual contact with the surface.

You could very rightly say that charging someone a sum of money to do IMC radio navigation training with U/S equipment which legally can not be used as intended is not providing value for money.

Filters are relatively cheap and are a simple mod. They should have been fitted long before now. Perhaps EASA will replace the CAA bumbling with a simple sticker - U/S due Non-FM immune.

Please feel free to try and convince us that relying on U/S equipment is sensible.

Regards,

DFC
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Old 18th May 2006, 10:32
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Is there any relevence to the use of FM-immune equipment in class G airspace? the question put was simply asking if it was a good idea to descend below MSA in Class G whilst IMC. The answer is no! Not even if you think you know where you are. the MSA is there for a reason.
IO540, as you say, landing is a necessary occurance! it is not particularly relevent to the question, but a logical point to introduce nontheless. Each landing procedure has some kind of minimum imposed, even if it is a DIY, and each time, it is there for a reason. descending below it when IMC is asking for trouble.
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Old 18th May 2006, 11:51
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Originally Posted by JonWhitehouse
Is there any relevence to the use of FM-immune equipment in class G airspace?
Yes.

If the MSA has to be calculated on a ceratin distance from the aircraft position, the ability to determine that position and how accurate the information obtained from various systems has an effect on the MSA calculated.

eg. DR position......one could have to use 1000ft above all obstacles within some 60 to 120nm from the aircraft depending on how long since last fix.

Using serviceable operating VOR equipment, I believe that the error is +/- 5deg. Thus at 60nm one will be +/- 5nm from the indicated radial.

ADF not as accurate, VDF, they tell you the accuracy with the bearing.

Thus what system is used and the servicability of that system as a great bearing on the MSA. A lower MSA reduces the probability of a diversion.

Regards,

DFC
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Old 18th May 2006, 13:32
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Think you will find i asked the question about FM Immune,John
Simply because this is not covered in depth during the IMC course!!
Anyway it`s good to talk
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Old 18th May 2006, 13:47
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Of course you might be able to descend over the sea.

Fortunately not too many sailing boat masts or bridges over 200 feet.

What height would you feel comfortable descending to if you were over the sea?
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Old 18th May 2006, 14:05
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Guess that would be the old 500ft rule?Atleast your legal when you come face to face with Captain birdseye.Hope its not an a/c carrier
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Old 18th May 2006, 14:14
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The new QE2 seems to be "advertised" as the world's tallest at a little over 240 feet - slightly off topic I know.
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Old 18th May 2006, 16:21
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The legal basis for FM Immunity requirements

Interesting to note the differing opinions on this. My own opinion is that one is legally required to use FM-immune ILS equipment when flying an ILS both inside or outside CAS in the UK.

The basis for my opinion is as follows:

This ORS states that, and I quote;

1) The Civil Aviation Authority, in exercise of its powers under Article 20(3) of the Air Navigation Order 2005 ("the Order") hereby directs that:

a) where an aircraft is flying in the United Kingdom in circumstances in which it is required under Schedule 5 of the Order to be provided with specified radio
navigation equipment all such required equipment shall comply with the FM immunity requirements of Annex 10 to the Chicago Convention Volume I (Fifth Edition - July 1996 Amendment 80) and Volume III (First Edition - July 1995 Amendment 80);
Under the explanatory notes that accompany the ORS, it expands thus;

For non-public transport flights under instrument flight rules (IFR) in controlled airspace in the UK, the legal requirements include one VOR receiver (which must be FM immune). To conduct an ILS approach inside or outside controlled airspace one (FM immune) ILS receiver is required.
Now we're at the same point as has already been discussed. Is this guidance material with no legal basis, as suggested, or is this a legally binding requirement?

In my mind it comes down to Article 20(3) of the Air Navigation Order, which is a Statutory Instrument and therefore legally binding. This also explains my choice of emphasis in the first quote.

Artice 20(3) states;

(3) In any particular case the CAA may direct that an aircraft registered in the United Kingdom shall carry such additional or special radio communication or radio navigation equipment as it may specify for the purpose of facilitating the navigation of the aircraft, the carrying out of search and rescue operations or the survival of the persons carried in the aircraft.
It's a matter of personal interpretation but for me at least, this is the trump card. This statements suggests -- to me at least -- that the CAA have carte blanche to impose any additional requirements on our navigation equipment. In this instance, they specify that to fly an ILS inside or outside CAS requires FM Immune kit if performed under IFR and Article 20(3) of the ANO makes such a declaration legally binding.

This is my own interpretation, at any rate.

In summary, the rule I use for myself is that to fly an ILS anywhere in the UK under IFR requires an FM immune kit. If it ain't FM Immune, it ain't legal... unless flown under VFR, of course. That said, we are all free to draw our own conclusions.
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Old 18th May 2006, 17:19
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Looks good.

Has anybody written to the CAA? My experience is that if you send them a precise question, and set out the context so there is no possibility of mis-interpretation, they reply usefully.

A bit of a bombshell, for IMC Rated pilots renting planes from flying schools................... !!

Would also upset not a few syndicates which contains members with the IMCR, but also some VFR-only members. Such syndicates (probably the majority of piston CofA syndicates) tend to gradually fall apart over stuff like this. One I know of, a nice plane too, ended up turning over most of its membership over a nonworking ADF.
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Old 18th May 2006, 20:32
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DFC says
As for DIY approach procedures.
Yes indeed, the 1000ft within 5nm of the aircraft requirement does not apply when approaching to land. After all at touchdown the separation is 0!. Furthermore, when completing a published approach procedure, the obstacle clearance will be at times less than 1000ftand the area taken into account far smaller than 5nm from the aircraft.
The leg - Rule 5 - actually says "Exemptions from the low flying prohibitions
(a) Landing and taking off
(i) Any aircraft shall be exempt from any low flying prohibition in so far as it is flying in accordance with normal aviation practice for the purpose of taking off from, landing at or practising approaches to landing at or checking navigational aids or procedures at a Government or licensed aerodrome.
(ii) Any aircraft shall be exempt from the 500 feet rule when landing and taking off in accordance with normal aviation practice.
I leave it to you to decide whether what DFC says is normal aviation practice.
The straight answer to part of the original question is that for a non-commercial flight outside CAS it is not contrary to any part of the ANO to make an instrument let-down that the pilot creates. The CAA obviously doesn't like this - there are a couple of proposals that are being/have been consulted on here and here that make this clear. Although one of them is now quite old and doesn't seem to have led to anything I don't think it has gone away because I spoke with someone from CAA a week or two back and they said it is still under consideration.

As for is letting down in the circumstances that Dude~ first describes, speaking as a controller I would say that even if you stay legal it is unwise! There's a reason that proper IAPs need all that effort.

DFC also says
There is one other fly in the ointment..........the navaid used must have been approved for use as an approach aid. One can not use an enroute VOR/DME as an approach aid.
Not true at the moment. Lots of navaids used to have "Not to be used for instument approach" in their details in the AIP but its not there any more. If it was Rule 40 would cause you a problem because it says "the commander of an aircraft shall not make use of any radio navigation aid without complying with such restrictions and appropriate procedures as may be notified in relation to that aid unless authorised by an air traffic control unit."
 
Old 18th May 2006, 20:32
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"A bit of a bombshell, for IMC Rated pilots renting planes from flying schools................... !! "

Why - because so many are not FM immune?
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Old 18th May 2006, 21:37
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Why - because so many are not FM immune?

Yes, most self fly hire spamcans aren't.

This is based on a sample size of 10-20 that I've been in. I don't think a single SFH plane I've been in was FM immune. In fact perhaps half of them had unserviceable instruments. I did my IMC Rating in several planes; one had a working VOR, another had a working DME (no ADF), another had a working ADF (and a duff but apparently working DME). None had all three working.

So I do quite enjoy ownership now
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