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Old 30th Jul 2003, 16:40
  #81 (permalink)  

 
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Charlie, cheers for the info. However when I contacted the French authorities, they said that the British Validation of the IR [ie. without formality being allowed to fly IFR outside CAS] was basically good enough for them. You are probably correct in the Flight plan bit, but the way it was described to me is that the British validation of the IR would be accepted in France. As in the UK you're restricted to outside CAS then in theory you could file IFR from an airport in France which is outside CAS to an airport in the UK inside class D and as long as you remain outside CAS until the FIR boundary you'll be legal [assuming hold IMC rating as well]. Of course you'd be better off in an N reg....

EA
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Old 30th Jul 2003, 17:06
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Englishal

Between you and the DGAC, you have without doubt managed to confuse one another.

For clarity we are talking about a UK PPL who also happens to have an FAA PPL/IR. We are talking about flight in the UK and France in a G-reg aircraft.


The UK CAA does not "validate" an FAA IR as such. Rather, it recognises the standard of flying reached, and grants a UK IMC rating without further test or written exam. On receipt of the IMC rating, the pilot may then exercise the privileges of the IMC rating. Even if the pilot elects not to get an IMC rating, he is one step up on a basic UK PPL. His FAA PPL (even without IR) does not restrict him to flight in sight of the surface. This is a particular restriction of the CAA PPL. Whilst he cannot fly in cloud, he in entitled to fly above a sold layer of cloud. The British rules of VFR permit this, as they do in most other countries.

Flight inside a cloud (in other words, IMC, and therefore IFR) is a different story.

In the UK this is OK once our hypothetical pilot gets his IMC rating (on the back of his FAA IR). Now he is bound by the privileges of his IMC rating.

The IMC rating is not valid in France, so when he crosses the channel, he must fall back onto his basic licence privileges. These still permit flight above a covered cloud layer under VFR (because of his FAA PPL), but do not permit flight in cloud.

If the pilot wished to obtain a validation by the French of his FAA IR, allowing the full use of its privileges, he could do this. Such validations are normally only issued for 6 months, and will only be issued to non-EU nationals, temporarily resident in the EU. A Brit who goes to America and obtains his FAA IR will therefore not be able to obtain such a validation.

Do not try to fly in cloud in France on the basis of the UK PPL and and FAA IR. You are definitely illegal doing so. If you have a letter from the DGAC saying something other than this, then you should scan it in, and you will become a hero to millions (well thousands)

2D
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Old 30th Jul 2003, 17:16
  #83 (permalink)  
 
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englishal

I tried to file an IFR flight plan in France, for flight outside CAS, and they refused to accept it because it was not in the airways.

What do you know about the position on this one?

Nobody asked me what license I had at the time, so hopefully that's not relevant to the question...
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Old 30th Jul 2003, 17:22
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There is no concept of IFR outside the controlled airspace in France (or many other places for that matter). This is one of the reasons why we can be reasonably sure that there has been some confusion between the DGAC and Englishal.

This said, controlled airspace in France works in a very different way to the UK. Most airspace is not controlled, and even the airways are only controlled by level (semi versus semi+500) below FL115. As a result, IFR flights are positively separated from VFR flights by virtue of being part of the "system", and being under radar control, from take-off to touch-down. They are controlled in this way, because unlike the UK, there isn't the controlled airspace to keep the VFR flyers out. This only comes into play above FL115, where airways become Class D, and VFR pilots are rarely cleared to go, despite the theoretical possibility.

The concept of randomly entering a cloud and declaring yourself IFR as occurs in the UK is simply not recognised, and neither is the concept of an uncontrolled IFR flight as commonly conducted by IMC-rating holders.

2D
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Old 30th Jul 2003, 17:29
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Agree 110% 2D ;D

I think engishal has become horribly confused by the fact that he can fly VFR over a covered layer of cloud, relying on his FAA PPL. The only thing that stops anybody else from doing that is a CAA PPL licence restriction, that has been carried through into UK issued JAA PPLs. The Visual Flight Rules have always allowed flight out of sight of surface in most countries.

This is obviously not the same thing at all as going into IMC. I hope englishal is able to clarify this point online, so as to avoid confusing other pilots and potentially encouraging them to break the law or worse, put themselves in danger.

Incidentally, we have been talking a lot about France here. This would all be true in Germany, the other country mentioned by englishal. They take licensing more seriously than the French, and being caught flying IFR without a valid instrument rating is punishable by large spot fines and worse.

Charlie

Charlie.
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Old 30th Jul 2003, 17:43
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For clarity, I wrote and asked them about a UK [JAA PPL] with and FAA licence issued on the basis of this JAA licence with an FAA IR bolted on [US Test passed] flying a UK registered aircraft in French airspace. I have the reply somewhere and I'll see if I can find it and I'll post it here if I do. In the meantime I recommend that anyone interested in this route write directly to each relevant authority in turn to get it in writing.

In the UK even without an IMC rating a JAA PPL with FAA IR can fly in accordance with IFR [ie. in IMC out of sight of the surface] outside CAS. ANO 2K 21[4] states you can exercise all the privileges of the FAA certificate [ICAO cert even if based on JAA Cert] in a G reg, including ME, complex and IR but para (ii) prohibits flight in accordance with IFR in CAS.

A 'standard' FAA cert issued on basis of JAA licence prohibits flight above the cloud for a vanilla PPL due to CAA restrictions as stated, but once IR'd this restriction no longer applies.

Hope this helps a bit,

Rgds
EA
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Old 30th Jul 2003, 17:49
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So are you still trying to say that a UK PPL with an FAA PPL IR can fly in IMC in French airspace in a G-reg aircraft?

Charlie.
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Old 30th Jul 2003, 18:00
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The issue as far as France is concerned relates to the legality of flying "outside controlled airspace" under IFR.

The entire IFR system does not work in a way which recognises the existence of IFR flights outside controlled airspace, and it is not possible for a French pilot to be authorised to fly in this way. In many respects, it is a sysem that an FAA pilot should be very familiar with, because the system works in a very similar way.

Because a practice is legal in the UK, there is no requirement for all other contracting states to accept UK pilots flying in that manner in their own airspace. The general principle here is that where two rules conflict, the more restrictive applies.

2D
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Old 30th Jul 2003, 18:07
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Ok last post on this subject....

What I'm saying is that I wrote to the DGAC and explained that I hold a JAA PPL and also an FAA PPL issued on the basis of the JAA licence, and that I also held FAA ME and IR's [US test passed]. I asked them that if I was PIC of a G reg A/C in French airspace could I exercise the same privileges as the CAA allow me to exercise in a G registered aircraft in the UK, using my FAA ratings, namely to exercise the privilegs of my ME rating in a G registered aircraft and to exercise the privileges of my IR in a G regestered aircraft but subject to the restriction of outside CAS. Their reply was that they would accept the same as the CAA when flying a G reg aircraft, BUT NOT an F reg aircraft. For this you need a validation of your IR which you can't get unless you are non-resident in the EU.

So thats my story, anyone who wants to persue this further I suggest you contact the CAA and DGAC [ICAA, REGIERUNG VON OBERBAYERN etc.....] directly. I've researched this a fair bit and I'm convinced however to stop me getting sued I will add the disclaimer "it is your own responsibility to check the accuracy of this information before acting on it"...or something like that Maybe there was some miscommunication somewhere, so in order to clarify it in more detail I have written to the DGAC again asking them specific questions to which I hope to get a reply........time will tell !

Cheers
EA
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Old 30th Jul 2003, 18:17
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Hopefully you can be tempted to one last posting on this subject...

Just to clarify...

What are you suggesting that you *are* allowed to do? You are presumably accepting that you cannot file an airways flight plan in France?

So what can you actually do? Imagine that you are on the ground at an overcast Dieppe, and you want to fly to an overcast Pontivy (airfield in the North West with NDB approach) both outside controlled airspace. Are you suggesting that you can legally fly from one to the other, at IFR levels (ie semicircular) on an IFR flightplan, and shoot an approach at the destination.

What do you do about the airways you cross along the way?

Who provides separation between you and other aircraft?

Who do you talk to enroute?

How do you get your IFR flight plan accepted by Eurocontrol, who will only validate an airways routing? IFR flights in France without a flightplan are not allowed.

To what minima can you shoot the approach?


Genuinely interested to hear what you think you are allowed to do, because your interpretation makes no sense at all to me.


2D

Last edited by 2Donkeys; 30th Jul 2003 at 18:28.
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Old 30th Jul 2003, 18:34
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I really hope you reply to 2D englishal. Those questions are exactly where I was coming from. What would you say to Paris Control after you had left the ground at Dieppe? Thank you for clearing me direct to DVL, but I can't accept because even though I am in cloud at FL60, that path would take me into a Class D zone and across 5 airways. In fact, the only way I can get to DVL is to descend below FL30 and skirt round the edge of two control zones... all whilst flying IFR.

Doesn't really wash does it? Cummon englishal...

Charlie.
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Old 31st Jul 2003, 03:46
  #92 (permalink)  
 
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2Donkeys

Thanks for confirming the bit about airways.

It sounds like if flying in France with the right licenses etc (e.g. FAA PPL/IR, N-reg plane) and outside CAS, one can legally fly VMC on top (and call yourself "VFR") but one must not transit through clouds on the way up or down.

Presumably this is (practically) nonsense as those French PPLs who take advantage of their "VFR on top" allowance cannot fly around for hundreds of miles looking for holes in the clouds...

It seems obvious to me that to fly in anything other than perfect weather in non-UK Europe one needs the full IR, and matching the a/c country of reg, or some endorsement of the IR.

No wonder most serious pilots are going the FAA IR / N-reg route.
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Old 31st Jul 2003, 04:40
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IO540

France is a big country with lots of different weather. Quite often good in the south, fog over Lille, and clear again to the NW.

Flying over the Massive central you would not want to be squeezing between the cloud base and the 5700 ft hills if you were a French pilot flying from Bordeau, but would probably find Lyon in the clear.

The French have developed, or use, some rules to make flying in their environment practicable. The UK has done the same with the 70% perpetually miserable weather there, and uses the IMC rating.

Now what's wanted is a sensible combination , and an elimination of the effect of the N and G and F on the paintwork.

As an IMC holder you must have heard of TAF's and Actuals. I have a suspicion that rather than swan around until the fuel runs out, the average French pilot plans on the basis of them.
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Old 31st Jul 2003, 13:59
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Bluskis tells us:

Now what's wanted is a sensible combination , and an elimination of the effect of the N and G and F on the paintwork.
The French and US airspace system and flight rules are remarkably similar to one another. Only the UK sticks out like a sore thumb with its extensive enroute controlled airspace system and IMC rating.

What is needed is some mutual recognition of licences, but in the current climate, that seems somewhat unlikely.

Charlie.
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Old 31st Jul 2003, 15:33
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IO540

Thanks.

You are right that whilst it is legal for French PPLs to fly out of sight of the surface, many flying clubs prohibit it amongst non IR pilots because of the risks associated either with the layer closing up (these guys have no appreciable IFR training).

Other clubs take the line of enforcing strict Met minima before a pilot can climb on top, intended to ensure that he can get back down again with some certainty. Either way, this is is something of a fringe activity for basic PPLs to become involved in, despite the fact that it is legal.

Englishal

You often find people arguing for things on points of legal principle, only to find that should they attempt to apply their logic to the real world, it is totally unworkable. I suspect that Englishal is in that position now. Having argued the legality of flight "outside controlled airspace" under IFR in France, it is difficult to know what that means and how you would apply it. The entire IFR system in France is geared towards conventional airways IFR flight, and unlike the UK where pilots outside controlled airspace often blur IFR and VFR to suit the prevailing met conditions, the rules in France are as night and day. I do hope that you will respond to my earlier posting, if for no other reason than to help me to understand how you think you would apply the privileges you think you have in French airspace.

2D
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Old 1st Aug 2003, 01:47
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Devil

How do you get your IFR flight plan accepted by Eurocontrol, who will only validate an airways routing? IFR flights in France without a flightplan are not allowed.
(FPL-GABCD-YG
-M20P/L-SR/C
-LFAB1800
-N0150A030 DCT DPE DCT SFD VFR
-EGHI0040
-0)
NO ERRORS

There, that wasn't too hard was it.

For the most part, of course, I agree -- the French airspace system is designed for IFR flight to be in airways, and doing otherwise might confuse them. The applicability of an IR-in-class-F/G-only has to be minimal.

But I don't think there is a prohibition on IFR in class G in France, is there?
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Old 1st Aug 2003, 02:09
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There is no prohibition on IFR in class G in France. But there is a prohibition of IFR flight without a Flight Plan and a specific prohibition on IFR flight without a validated Instrument Rating.

2D
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Old 1st Aug 2003, 04:17
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bluskis

Certainly I've heard of TAFs and METARs However they don't give you the accuracy to be able to plan a VMC-on-top flight and be sure there will be enough holes.

On the basis of weather forecasts, a prudent PPL cannot go anywhere if the forecast cloudbase is below the en-route MSA, end of story. And if the cloudbase is above the MSA, why fly above the clouds?

2Donkeys

Re IFR in Class G in France, I realise one needs an IR for it to be legal but, as a matter of interest, just how does one file a flight plan for that? That's what I tried once (cheekily I admit) and they refused, saying it must be an airways route. Does it mean, for example, that if you are departing an airfield in Class D then you have to be airways because the immediate area of departure isn't in Class G? It doesn't make sense unless the destination is an airfield in Class G with an IAP. I suppose that, since one needs an IR, one can go airways anyway and then the Class G bit is irrelevant except when flying to/from a Class G airfield and IFR en-route...

I know the bit about French clubs not liking VMC-on-top but I am looking at this from the POV of an owner.
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Old 1st Aug 2003, 04:28
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IO540

Despite bookworm's correct but tongue-in-cheek response to my FPL challenge, you experience is an accurate reflection of an attempt to file an IFR flightplan that does not conform with the published preferred routings. If the "strange" flightplan is not picked up at the point of submission (the usual way), you will find your route ignored and your flight guided onto airways as soon you receive your clearance.

The majority of French airports in Class D zones (and many in Class E) have SIDS and STARs to the appropriate airways joining points. It is customary when departing IFR from airports in class G to file initially DCT to a nearby VOR or intersection from which the airways structure can be joined.

Since IFR flights are under positive radar control in France, the concept of a flight being in an airway or not is somewhat irrelevant. Controllers will often tactically give a direct routing which will place the aircraft outside an airway, and therefore in class G airspace. This is not a problem under the French system, since VFR aircraft are *required* to be at semi+500 and because ATC provide positive separation for all IFR flights, irrespective of the airspace type in which they may find themselves temporarily operating.

This is why englishal's point, whilst it is not a bad academic one has no practical application to the way that IFR flight in Europe as a whole is actually performed.

2D
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Old 1st Aug 2003, 05:16
  #100 (permalink)  

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I've been watching with deep interest, and I think I see one "privilege" I didn't know I have, namely VFR on top in France in a G-reg aircraft on the basis of my FAA PPL/IR (well, ASEL/IA, but you know what I mean).

The IMC rating allows me to fly VFR on top in the UK, but isn't recognised outside the UK so I'm back to "in sight of surface" once I leave the UK on my CAA PPL.

But does my FAA PPL/IR mean I can fly out of sight of the surface in France? I'd have thought not, because it fails the "two out of three" test. I'd be curious to know!


On the more general issue of IFR flight in France: having done it several times (with an IR in the right hand seat), I can confirm that filing a non-airways route in France causes a) confusion on the part of the system/controller and b) rapid issue of a revised route.

I once managed to persuade Le Touquet to allow me to depart IFR for the UK on a direct (non-standard) route, but only (I suspect) because I would be out of French airspace within ten minutes. Even then, they weren't too happy about it.

You can usually persuade IFPS to accept a non-airways route - the "route tester" will accept routes that fail as an "airways" routing, if they are resubmitted to quote one VOR to the next VOR along the identical route. It will last until you speak to the first French controller, in my experience.

The curious thing is that, once you are "in" the airways system in France, you may then get a direct routing to a waypoint a very long way from your present position, and outside the published airways.

A couple of years ago, I was cleared direct from Rouen to Angers Marcé by Paris Control, at an IFR level. What was filed was much more complicated, using all the "right" airways. I wasn't sure how the controller expected me to navigate the direct route, in the absence of any VORs along the way, and the fact that I was below the level where I am "supposed" to use GPS. I queried it, and was asked my heading, then given a heading to steer. That matched what the GPS said. The next words from the controller to me were to hand me over to Angers - by which time we were in fine VMC and could see where we were anyway.

The solution is easy - for the moment, anyway: fly an N-reg aircraft, which makes the FAA IR valid in France. As others have said, flying IFR in France is much more like the US than the UK system anyway.
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