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Old 1st Aug 2003, 06:02
  #101 (permalink)  
 
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Interesting but perhaps irrelevant twist.

Before the licence privileges were changed in 1996, IMC rating holders were prohibited from flying IFR in certain controlled airspace notified for the purposes of [some paragraph of] Schedule 8 of the ANO. Foreign IR holders using the validation of their IR on G-reg were prohibited from flying IFR in certain controlled airspace notified for the purposes of [some other paragraph of] Schedule 8 of the ANO. The notifications were broadly similar and included most of the majors.

But while the IMC-rating privileges stopped at the FIR boundary, presumably the ICAO IR was rendered valid in all controlled airspace outside the UK.
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Old 1st Aug 2003, 06:46
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Ok, time to respond

Right I've been on to the DGAC and asked them the following:-

Dear Sir,

I would be grateful if you could clarify the following points with regard to flying a UK registered aircraft [G reg] in French airspace. I hold a JAA PPL issued by the UK CAA and also an FAA PPL with Instrument and Multi Engine ratings. The CAA allow me to fly as pilot in command a UK registered aircraft in accordance with IFR [in the cloud and out of sight of the surface] while outside controlled airspace. The FAA IR validation is an informal process detailed in The UK Air Navigation Order 2000 applies this ruling in Article 21 Paragraph 4. Can you confirm that the French authorities would also allow me to fly in accordance with IFR outside French controlled airspace while in command of a G registered aircraft.Many thanks for your time, I look forward to hearing from you.
------------------------

Now today [yes I contacted them yesterday and received the reply today, full marks to them] I received a response from them, this is what they said:-
------------------------

Delivered-To: [email protected]
Subject: FAA IR and JAA Licence
To: [email protected]
X-Mailer: Lotus Notes Release 5.0.5 September 22, 2000
From: "BARDET Sophie - DAC-N" <[email protected]>
Date: Thu, 31 Jul 2003 14:27:08 +0200
X-MIMETrack: Serialize by Router on CS-NORD/DGAC(Release 5.0.5 |September 22, 2000) at
31/07/2003 14:29:15


Sophie BARDET
Direction Aviation Civile Nord
Subdivision Réglementation et Contrôles Techniques
Tél : 01.69.57.74.42
Fax : 01.69.57.74.71
E-mail : [email protected]

Dear Sir,

If the UK CAA allow you to fly as a pilot in command a UK registered aircraft in accordance with IFR while outside controlled airspace in a private aim, you can do the same in France.
Best regards.

Sophie Bardet.
---------------------------

So if I may seem confused by this issue this is why. I have been told by the French that I am allowed to fly IFR in uncontrolled airspace, so please explain...........

Remember this is not isolated to France, what about Ireland?

Cheers
EA
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Old 1st Aug 2003, 14:55
  #103 (permalink)  
 
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englishal

I think that the conversation has moved on. I think that both bookworm and I have acknowledged the interpretation of the rules that Mme Bardet appears to confirm to you.

The real question is what, if anything, this confirmation does for you? Filing and executing a flight plan under IFR that causes you to remain outside controlled airspace in France is a practical impossibility because of the structure of the airspace, and is something that would be very alien to the controllers that would work your flight.

What do you think?

2D
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Old 1st Aug 2003, 15:36
  #104 (permalink)  
 
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2Donks

I am sure you have personal experience of the limitations you have highlighted, therefore please do not regard my question as a challenge.

France has a significant area of uncontrolled airspace, with a large number of airfields within.

How would a fully licenced IR pilot arrive or depart from airfields such as Abbeville, Amiens or LeMans in IMC?

If in fact they are able, what radar cover would be available to them?
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Old 1st Aug 2003, 16:02
  #105 (permalink)  
 
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Its a good question. France is not significantly different to the UK in this regard.


When flying IFR to an airfield outside controlled airspace, your flightplan will nominate either an airways intersection or a beacon on the airways structure close to your intended destination. The plan will end with DCT.

As you get close, the airways controller in France will often clear you direct to the initial holding fix for the approach in use at the airfield, having negotiated a level to arrive at the beacon with the local airfield controllers.

Once close to the holding fix, you will be handed over to the airfield controller who will procedurally separate you from other IFR and VFR traffic until you land.

Should your destination be one which does not have ATC, but rather has FISO-like service, the same applies, with the FISO providing traffic information on other visual traffic, and multiple IFR aircraft self-announcing their positions in the procedure. This is not fun, and the UK looks upon this with a certain degree of horror, although it is currently in a consultation process to move the same way on a limited basis.


Departures work again in the same way they do in the UK. The FISO or Tower controller contacts the local airways authority, passes a clearance to the aircraft, and typically once the aircraft climbs through 1000 feet, he is handed to Paris Control (or as appropriate), who IDENT him and the flight then continues under radar cover by a mixture of airways and direct routings.

This all works because the radar controller is free to vector IFR traffic and offer it DIRECT routings without needing to worry about whether or not the pilot can accept IFR clearances into controlled airspace, or across an airway. Traffic is typically worked at levels above FL50, making radar coverage, no issue.

Being constrained to operate at lower levels implies that radar coverage will be poorer leaving controllers unable legally to offer a service - something which ordinarily cannot happen to an IFR flight in France because of the accepted routings which they follow.

Hope this clarifies

2D



POSTED SLIGHTLY LATER THIS MORNING BUT MERGED BY PPRUNE...


Puzzled by Sophie Bardet's earlier response to englishal, I have written and more recently spoken to her myself this morning.
Dear sir,

What the CAA agree on their aircraft is their business. We don't have anything to say about this. As it has been written to you, YOU HAVE TO know the british and the french regulations to be able to choose the more restricted when you fly over France, one of these says that we do not reconize the unvalidated FAA IR for flight under IFR in French airspace.By sending us the copies of your licences and your privileges (US & British), we would be able to give you an accurated answer.

Sophie BARDET
Direction Aviation Civile Nord
Subdivision Réglementation et Contrôles Techniques
Tél : 01.69.57.74.42
Fax : 01.69.57.74.71
E-mail : [email protected]
In this note, and during the conversation that followed, she appeared to retract her earlier suggestion that what the CAA accepts, the DGAC accepts too.

I still suggest extreme caution here. Ramp checks are an everyday occurance in France. Those who worried about carrying certificates of free circulation for their aircraft should certainly worry about arriving on an IFR approach in a G-reg aircraft with nothing but an unvalidated FAA IR.

2D

Last edited by 2Donkeys; 1st Aug 2003 at 16:45.
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Old 1st Aug 2003, 17:00
  #106 (permalink)  
 
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2D

Thanks for your very clear answers.

Apropos the French reply, hopefully someone will do as she asks and all will become clearer.
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Old 1st Aug 2003, 17:05
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I am on the case now!


2D
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Old 1st Aug 2003, 17:16
  #108 (permalink)  

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Just a little addition to 2D's explanation; it also happens in France that radar will "release" you to the destination AFIS and you call only to find that they are not there.

I've never known the legal position in these circumstances, but I have generally proceded, making blind calls, and have always popped out into VMC before having to decide whether to make an IFR approach.

I don't know what I would do if the cloudbase were below MSA on one of these occasions...I guess do whatever felt safe and expeditious.

W
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Old 1st Aug 2003, 17:17
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2D et al,

I am just confirming what I have always said [or rather told by the DGAC], ie. you can fly in accordance with IFR [out of sight of the surface in IMC] outside controlled airspace in France on an FAA IR in a G reg aircraft. There is no doubt about this, it has been confirmed by the French CAA. There is also no doubt that you can do the same in the UK.

Now how you do this may be a mystery, but I bet if you go back to the French authorities and ask whether you NEED to be on an IFR flight plan that they will turn around and say "If the CAA say you don't need to be on a flight plan, then you don't need to be on one in France". Suddenly the concept of a European IMC rating of sorts has been born. I could in theory depart from an un controlled field in France, and while being responsible for my own navigation transition through or in IMC whilst remaining outside CAS. Not much different to flying around the UK with an IMC rating is it?

I hope some people don't take my posts personnaly, I am mearly trying to find a way that someone with a perfectly good IR can use the system to their advantage without breaking the law. If I fly to LFAT and end up shooting the ILS to get in in IMC I have broken the law, even though I am just as "qualified" as the fATPL holder who has just exited OAT with minimum hours. All becasue the tail letter happens to be a G rather than an N. Of course I could go out and fork out the several grand to convert my IR, or buy an N reg plane. Why fork out a few grand to convert my IR for private use? I have already proved my level of competence just in an N reg. Why should I buy an N reg? I am in a G reg syndicate, and to be honest a G reg and N reg fly exactly the same. [though I'm coming around to the point that I'd probably be better off just buying my own N reg aircraft and be done with it] I don't nescessarily want to fly in IMC in France, it just leaves open a useful tool for someone to "get home" if caught out by the weather which invariably happens in the UK / Europe.

I just used France as an example [probably a bad one as they don't seem to know what you can and can't do any more than we do ], what about flying in Ireland? Never done it but the same will probably apply there, they will more than likely accept the CAA's endorsement of a foreign IR with the same restrictions on it.......

Still I wouldn't exercise any of these "privileges" without having a written letter in my possession saying what I'm allowed to do, so use extreme caution if you do decide to do it.

Anyway I've said my piece now, I suggest that other people can continue the campaign if they want, and maybe by campaigning this will lead to an affordable European Private IR . Its no good sitting around and bitching if you never end up doing anything about it.

Happy flying
EA
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Old 1st Aug 2003, 17:23
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LFAT sits in a Class E zone, which for the purposes of IFR flight is controlled airspace....

2D
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Old 1st Aug 2003, 17:28
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Truce!

[yea I know. I was making the point that it is illegal for me to shoot the approach there becasue I don't have an N painted on the tail]

2D,

Fancy calling a truce to this topic? I think I'm now suffering from repetitive strain injury from all this typing

I think the moral of this story is that if you're going to try to fly IFR abroard you have to make damn certain that you are legal. The DGAC appear to change their story every now and then so what I suggest is that anyone who's interested should write a letter [not email] to the relevant authority spelling out exactly what they want to do and to get a reply that you carry with you. I'm going to do this anyhow. Better be quick though as France goes on holiday for the summer soon

2D raised some good topics and clearly knows the IFR regs in France better than I do, however it doesn't help when the DGAC then turn around and say that I can do what I suggest. Maybe there is a loophole allowing what I suggest or maybe there is utter confusion and it is clearly impossible......

Anyway, happy flying, I hear the weather is going to be good next week, so hopefully we won't need any of this IFR nonsense anyway

bye for now
EA

Last edited by englishal; 1st Aug 2003 at 17:51.
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Old 1st Aug 2003, 20:45
  #112 (permalink)  
 
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In this note, and during the conversation that followed, she appeared to retract her earlier suggestion that what the CAA accepts, the DGAC accepts too.
I would imagine, 2D, that Mme Bardet skipped the course in Advanced Comparative Airspace Structure that you and I took in our spare time over the last few years. As such she probably doesn't understand the issue in detail, but has twigged that there is an issue and is leaning towards the more conservative option of quoting the regs and refusing to interpret them. I'd probably do the same.

The DGAC is obliged by the Chicago Convention to accept the licence privileges that the CAA render valid for flight in a G-reg aircraft, just as she clearly asserts in her first message to englishal. The DGAC is, however, under no obligation to adapt its Rules of the Air to make those privileges useful!
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Old 1st Aug 2003, 23:27
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This is a brilliantly helpful thread - thank you all.

englishal

Yes, go for N-reg. You don't have to BUY one; you can go from G-reg to N-reg (most cost effectively done at the CofA annual, or any other service which takes a few weeks for that matter) for about £2k, with a subsequent cost of some £500/year. You get various benefits:

Worldwide IR privileges without a question
No CofA
No 50/150 services, just an annual
Lots of pilot maintenance is allowed
Lots of non CAA approved STCs
Class 3 medical (the main benefit of the NPPL in the UK.....)
+Others

Keef

I have it in writing from the CAA that a IMCR pilot flying VFR on top in France is not breaking the ANO, and that if the DGAC don't mind then the CAA don't mind either. I don't know the DGAC position on this though - but it would be very interesting since "VMC on top" is in practice what IFR flight is about most of the time. One would be illegal only for the short time it takes to get up/down through the cloud. More practically, it means one could depart the UK IFR if necessary, and stay VMC on top when going to the south of France (usually) and 100% legally all the way. Any views on this one?
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Old 2nd Aug 2003, 00:16
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VFR on top,

Its excellent to hear that it is now clear that the CAA allow IMCR PPLs to fly VFR on top outside the UK.

The French allow PPL VFR on top, so IMHO nothing needs further clarification.

This is how I have understood the matter for many years.

It would be best not to throw too many balls at the DGAC at the same time, and concentrate on what exactly the position is regarding their acceptance of FAA IR in G reg, which 2D has said he is doing.
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Old 2nd Aug 2003, 00:43
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his is a brilliantly helpful thread - thank you all.
Damn! And here I was thinking that it was a masterpiece of obfuscation... Must try harder...
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Old 2nd Aug 2003, 05:19
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bookworm

Damn! And here I was thinking that it was a masterpiece of obfuscation... Must try harder

I strongly suspect that

a) there are people who know the answers but aren't posting them on the internet (only a miniscule % of pilots are in here, and those taking advantage of some loophole won't be advertising it), and

b) there are plenty of people who just fly and don't worry about it.

I know for certain that some IMCR pilots do fly airways in France; the only thing which would stop me doing such a thing when going back to the UK (i.e. with a near-nil chance of getting caught) is my lack of airways procedure knowledge and lingo. One is a lot more likely to need to fly in IMC when returning to the UK than on the way out, for obvious reasons.

Also lots of pilots with "any old IR" fly airways routinely all over Europe, e.g. delivering planes of various registrations to customers. If you know the lingo and procedures, and fly a serious plane, nobody is likely to question it. But if you have a gold plated JAA IR and fly a 1970 C150, and fumble and stumble on the radio, you will only draw attention to yourself...

I have found the French ATC extremely professional and courteous, as soon as they can see you know what you are doing. I always plan a flight as if it was IFR, use IFR waypoints etc, and this makes their job a lot simpler. A bit like the UK really, but I found the French to be better, especially with handing out RIS very readily.
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Old 9th Aug 2003, 15:28
  #117 (permalink)  
 
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2D

Have you any news for the thread?

or English Al perhaps?
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Old 9th Aug 2003, 17:29
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Hi Blueskis,

No not yet from me.....I intend to get a list of other European CAA's and find out what their IFR requirements are.....I've just been a bit slack lately It appears that IF you can fly IFR in uncontrolled airspace without having to file a flight plan in CAS then you can use the privileges of the FAA IR in a G reg to some extent. Incidentally, if I file an IFR flight plan outside CAS in the UK, ie. from one unlicenced field to another, what happens to it? Where does it go?

Anyone want to buy into a N reg Arrow / fast single or something based down South UK? [Would like a Seneca, but think that one in Europe would bankrupt me ] I'm seriously considering getting one in the USA, and bringing it back....

Cheers
EA
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Old 9th Aug 2003, 20:50
  #119 (permalink)  

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Yes, extremely interested in an N-reg Arrow. In fact, I'm hoping that in 15 months' time (next CAA C of A due) that ours will become one.

Pity we can't just paint "N" on the side and go for it.
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Old 11th Aug 2003, 14:39
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I have a Mooney at EGTF that I am most of the way through the paperwork to convert to N Reg. By the way I looked at the cost of bringing one in from the states and it looke dmuch easier and cheaper to convert a well selected airplane.
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