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EASA screws the use of GPS approaches

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EASA screws the use of GPS approaches

Old 13th Jun 2011, 20:04
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what are you talking about....

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 didnīt prepared on the ground (just reading Machadoīs survival manual few weeks back)
Thatīs 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.
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Old 13th Jun 2011, 20:12
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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 )
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Old 13th Jun 2011, 20:21
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to IO 540

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....
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Old 13th Jun 2011, 21:01
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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?
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Old 13th Jun 2011, 21:06
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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.

Last edited by IO540; 13th Jun 2011 at 21:16.
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Old 13th Jun 2011, 21:58
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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?
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Old 13th Jun 2011, 22:36
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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.
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Old 13th Jun 2011, 23:45
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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.

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.
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Old 14th Jun 2011, 03:38
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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.
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Old 14th Jun 2011, 06:49
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Nah you cant exclude a liability which kills you due to negligence as mr cessna knows only too well.
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Old 14th Jun 2011, 07:13
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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
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Old 14th Jun 2011, 08:41
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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:
  1. Performance-based navigation (PBN);
  2. Minimum operational performance specifications (MNPS);
  3. 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.
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Old 14th Jun 2011, 09:13
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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
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Old 14th Jun 2011, 09:28
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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 ).
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Old 14th Jun 2011, 09:31
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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.
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Old 14th Jun 2011, 09:44
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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.
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Old 14th Jun 2011, 09:51
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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
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Old 14th Jun 2011, 10:15
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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.
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Old 14th Jun 2011, 10:35
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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.
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Old 14th Jun 2011, 11:53
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I think it's time to stop moaning and actually go and do something about it!
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