Crossing Alps and Oxygen - rules?
 

Hi All,

Yep, another stupid question, because I am trying to check my understanding and interpret rules and regs...

As some of you know from previous posts, I am flying D-Reg aircraft in Germany at the moment and have a UK Issued JAR-PPL. To keep safe all the advice I have been given is to look at the German and UK Regs and then abide by the most restrictive "profile".

So, here's the question I am looking at crossing the Alps, and have found/been advised of some easy-ish routes but they require short periods to pop up to FL115, to ensure cruise above MSA and compliance to Semi-Circular Rule. (FL100 to FL105 would be sufficient for MSA only)

From looking at the rules the most restrictive in this area are the UK Regs, O2 when between FL100 and FL130 for a period of 30 minutes or more. Which is ok, except for the investment in the O2 equipment. But is this 30 minutes, the total time above FL100 for the flight or each period above FL100... and if it is a period of time is there a recovery period below FL100 that you need before you are allowed back up without O2.

With all that said, looking at the flight planning I can do the first 45 minutes below 8000ft (so a low risk of hypoxia), then climb to FL95 for the first part of the alpine crossing, peaking at FL115 for about 5 to 10 minutes to cross the pass (total time above FL100 would be 20 to 25 minutes estimating climb performance), then returning to FL95 for about 30 minutes, before needing FL115 again for about a similar period to cross another line of hills; then for a nice long prolonged decent to sea-level (I can debate shock-cooling on the way down :ok: ).

Does anyone have a view if this would be legal?

Cheers

Jon

The rules you quote apply to commercial operations.

For a private flight the recommendation is that you use oxygen above FL100, but that's where it ends with a recommendation. As far as I'm aware there would be nothing illegal in spending an entire flight at FL115 with no oxygen.

Take aircraft performance into account though, very low pressure altitude.

The rules that apply are the German ones. The UK rules apply to UK registered aircraft.

On a practical note, get a pulse oximeter. They're very cheap these days. That will allow you to monitor your oxygen saturation. Typically, this persuades pilots to go buy oxygen kit!

Excuse me if I missed something, but how can the UK ruling be relevant? Unless my schooling was really far off, no part of the Alps is in UK airspace. Surely one has to comply with Somalian ruling while in Somalian airspace, with Kyrgistan ruling in Kyrgistan airspace, and so on?

That said, I feel quite certain you'll not have to deal with the, ahem, unique, quadrantal or was it semi-quadrantal altitude ruling. In decent places (which in this case even includes continental Europe), eastbound courses (or was it headings?) go on odd flight levels, westbound on evens. Allow for a few exceptions, though.

Jan
 

There are no ''Rules'' for oxygen use for UK registered private flights, only sensible recommendations.
Regulations apply to Commercial Air Transport operations with fee paying customers.
Flight for short periods ie crossing the alps above 10000ft. should pose no problems for a fit person.
I believe EASA of course, are trying to regulate private flights as AOC ops in the future.
(one of the initial requirements was a question for rate of climb after engine failure for single engine aircraft!!)

Italianjon, if you are flying VFR, then the semi-circular rule is only a recommendation, and the safe altitude marked on the chart (grid MORA; MSA is minimum sector altitude, a totally different animal) will only apply if you are not in sight of the surface, otherwise you can route around the highest points.

Regarding the oxygen requirements when flying non-commercially, you are better off checking your own tolerance to hypoxia - either use a pulse oxymeter as Bookworm recommends, or get yourself thoroughly checked in a hypobaric chamber - I know there is one at the Institute of Aviation Medicine in Prague, and probably a handful more of them around Europe. From my prior mountaineering experience, skinny people are usually more tolerant to hypoxia than fat ones. Also, smoking even a single cigarette reduces your tolerance for up to a day afterwards.

Thanks for the quick answers.

I am thinking along the lines of aircraft performance, because at FL115 I can get over the top, where as staying at FL95 would mean a possible quick climb needed, or a very quick self-taught lesson on Chandelles in tight spaces. I prefer over the top :ok:

Yep, just realised myself that Article 54 applies to public transport, not private ops. So thanks for the advice on the pulse oximeter, I will definitely get one of those. I have also seen the Oxygen Pulse machines, which do not need O2 bottles to be refilled - any experience with those? I might pick one up next time I am in the states (assuming I am correct that the EASA certification for O2 equipment has actually been dropped in line with what I have read today)

To answer the point about which regs apply, this is the part where I am slightly nervous and edging on the safe position. I have had a fair few beers at the flying club discussing whether to swap my UK-Issued for a DE-Issued... (Many reaons not to, 1 is that work is a temporary contract here and so I will return to Blighty at some point and 2 is the beloved IMCr). The main topic of the debate has been how rules apply. Yes, German rules for sure because it is a D-Reg, but do the UK ones apply as well because I am a UK-PPL licence holder. A way to try to illusrate what I am saying is that I am told (still need to find the reference) that German PPLs are limited to below FL125 without Oxygen, but if UK had set the limit to FL100, which would apply... just as much as if I am G-Reg in UK I can fly IFR in both VMC/IMC, but if I flew a D-Reg into UK airspace could I do the same probably not; even though we now have an "EASA issued IR(A-Restricted UK)" or whatever it is going to be called this week.

I take your point about semi-circular vs quadrantal rule, but these are not exceeding any human factor limit placed by the licence. In the debates and conversations at the club we are sort of applying the "on an aircraft the rules of the state of registration apply unless the local regulations are more strict" principle... and wondering if this is relevant to licence issue as well.

Yep, fair point, but they are mountains, and if weather picks up and clouds roll in then I would like to know that I'm not going to hit anything, so that I can work on other "issues" at that time, like getting back VMC - I would not cross unless the forecasts were basically CAVOK with light winds... but you never know.

To move your state of licence issue you will need to satisfy the state of permanent residence requirements. It is also not a five minute job to do so.

Jan the rules apply to the registration where ever the aircraft is in the world. If its on the N reg but in Blighty and flown by an FAA certified pilot then the aircraft must be operated according to the FARs. In addition the pilot (and aircraft) may be governed by the rules of the country in which the aircraft is operated.

It does raise an interesting question I hadn't previously considered; a CAA pilot is entitled to fly an N reg aircraft in UK airspace - presumably said pilot is not required to comply with the FARs since he does not hold a FAA ticket? I wonder?

As to the question why would you worry about the MSA? If you are crossing in VMC and the weather is suitable you are not restricted by the MSA. Indeed in the right conditions you can literally see your whole way across and make a reasonably informed judgement as to whether (or not) the flight is possible. If on the other hand you are crossing with the expectation of entering IMC then you would be nuts not to carry oxygen and have the capability not only to use it but to use it for potentially a longer period of time. I accept then if the winds are strong you may well wish to be above the MSA if not much higher, but then again that may be another variation of conditions to avoid for a first time crossing.

I am not convinced that o2 use is optional in a G-reg on a private flight - ANO amendment

A while ago I wrote this up and (if you don't want to read it all) if you scroll to the very end you can see what I currently fly with i.e. the MH composite cylinder, MH 1st stage reg, O2D2 electronic demand reg, and the plain cannulas. This is simply the best kit.

For low level use i.e. below say FL150, you would be fine without the O2D2 and just using the oxymiser/oxysaver cannulas, but you will get through a lot more gas (comparison) which is OK if you have a big cylinder and have a handy refill facility back home (some have, some haven't).

Whether you will be OK is impossible to say. I once flew with an instructor, who refused o2 saying he doesn't need it. At FL120 he could not read the altimeter... which looking at his general fitness was not suprising. And he wasn't even a smoker. On o2, he was fine within seconds.

I use o2 anytime at FL100 or above, and one arrives fresh instead of shagged :) This is despite having once participated in a flight test to FL120 with a group of pilots and I was way better than any of the others in the blood o2 and heart rate figures.

The other thing is that if you fly so close to the mountain tops, you are vulnerable to up/downdraughts caused by wind flowing over them. If you are say 1000ft above, even 10kt of wind could easily kill your ability to hold altitude if you are near your operating ceiling there. You need to either pick a very calm day, or fly a fair bit higher (and then you really must have o2). In my trip reports you can see how I go about this, but then I can go to FL200 which is very handy.

Sticking to a preplanned MSA in mountains is important (if one is flying that close) because of the risk of false horizons.

IMC over the Alps is tricky because the OAT is likely to be below 0C even in the summer. I have done many crossings (straight over the top; I don't do "mountain flying") and have never seen a positive OAT. So there is a risk of structural icing, and you have cut off the best escape route which is a descent into warmer air but without going below the MSA.
He is required to comply with FAA regs because he is still flying an N-reg but is merely using non-US pilot papers, permitted in accordance with FAR 61.3.

PS having crossed with your earlier post I am not sure the Alps are a place to be for unintentionally entering IMC or concerning yourself about MSAs in case you do and while you are sorting yourself out. It really is a recipe for disaster.

I know it is often said but unless you are instrument capable avoid IMC crossing the ALPs at all cost.

As I said earlier on the "right" days the visibility is amazing and you can literally see whether or not your route is clear the whole way across.

I appreciate the weather can change even contrary to the forecasts and I also fully appreciate you just could find yourself with few alternatives even though that should be highly unlikely. By all means have the ability to get above the weather but use that ability as an absolute last resort unless you can be assured of a visual climb and it really is the only way of completing the trip. Crossings North to South seem to be most likely to encounter weather at the southern end that is worse than forecast but if you have ended up VMC on top the southern side of the alps is no place to be descending in IMC without instrument currency, not least because it can often become clagged in to low levels.

My interpretation of oxygen is the same as PeterH's - I dont see how this can be interpreted as a recommendation.

Sorry, in Germany when flying VFR above 5000ft amsl or 2000ft above ground it is MANDATORY to maintain a Flight Level according to the semicircular rules (55,75,95,115 from 0 - 179 degrees magnetic track, 65,85,105 etc from 180 degrees to 359 degrees).

Please note that this is NOT valid when climbing or descending or if following such rules would put you in contradiction with maintaining VMC conditions.

These rules are listed under the German LuftVO Anlage 3, Paragraph 31.2 for VFR, 37.3 for IFR......

Always satisfying when you finally agree with me........:D:D

I'd welcome arriving shagged for a change;)

O2 advice apart, one of the main things to plan for carefully is not just the weather but specifically the presence of wave conditions. In the area of the Alps I fly a lot the active wave areas are fairly predictable for different wind directions, but that does not hold true for all alpine areas. Even well above mountain tops one can get caught in heavy sinking air (20 kts plus) and getting into wave rotor can be like being inside a tumble dryer with total loss of control. It is extremely violent and frightening for the uninitiated. e.g in a N/NW wind, to the south of the 10,000 ft Pic de Bure which is NW of Gap (France) in the Durance valley.

So when you plan your route look specifically at weather data that provides forecast wave conditions and avoid that like the plague, at least the down parts of the wave or the areas of rotor below the wave contact points.

It's different for me in that as a (mainly) glider pilot with many alpine hours I often seek the wave in the mountains, but one has to be very cautious, and in a powered aircraft it is a different ball game to a high performance glider. Hope that helps.

IOW, it is completely unenforceable ;)

Same as in the UK.
What sort of wind speed would one need to see a 20kt vertical speed (2000fpm)?

I suspect that the winds produced in the Alps on a day like this or this would result in virtually no vertical airflow.

This would be different (look how close the isobars are over the Alps). The troughs are just a bonus, for character building :) However, I did the flight UK-Croatia at FL190 and, from my writeup

The effect of the ~ 20kt northerly wind flowing over the mountains was only just felt at the level flown, with no turbulence most of the route and very light turbulence near the end.

so clearly altitude helps a lot. FL190 was about 8000ft above the general terrain.

Similarly, on this trip, I was about 7000ft above the terrain and felt almost no turbulence despite a >30kt wind flowing straight across the Pyrenees.

This excellent leaflet from New Zealand is worth a read.

There is a very rough rule of thumb which goes something like: for every 10kt of wind speed across the ridges, you want to be 1000ft above the terrain, to keep the vertical speed of any downdraught below 200fpm. I think that is probably about right for low wind speeds. Above 30-40kt wind speeds, I reckon things are going to get a lot more exciting.

But in this case we don't know the aircraft type so, as usual, chewing away on insufficient information.

I have crossed the Alps in twins and jets on numerous occasions be very careful!

Even on relatively mild wind days you can get local conditions where you will get massive sink.

Regarding oxygen the FAA limits are no oxygen to 12500. 12500 TO to 13999 feet for 30 minutes. 14000 feet and above oxygen at all times! PAX on at 15000.

I am sure Americans do not have better lungs than us.

I have never had a problem at 12500 and once ran out of oxygen at FL160 again no problems for the 20 minutes I had to stay there but pressure breathed!

As a Scuba Diver I am used to breath control! Pilots who feel funny at lower levels think its altitude causing it but often it can be anxiety causing over breathing!!!

But people vary! I knew one glider pilot who was a heavy smoker and went funny at FL80.

You should be OK to FL120 so do a test flight?

If you have never flown the Alps really do be very selective when you do it or dont do it at all!!!
If you are flying 1013 check what the real altitude is??
Get a transportable oxygen bottle for the trip as its a good safety backup.

Pace

italianjon, this is a legal question so it needs to approached in a legal way.

You are flying in a German registered airplane in German airspace with a UK license. We can forget about the license here, it is not relevant to something like aircraft equipment. Oxygen is not about preventing license holders to climb higher than altitude X but about requiring the use of supplementary oxygen or a pressurized cabin.

Airspace could be a factor, there is law requiring you to carry certain equipment while flying in certain airspace. For Germany one example is the DME for every IFR flight (a lot of N-regs don't do this and don't know that they can be fined with up to 50 000 € for that). In this case, there isn't anything related to oxygen.

What remains is the law pertaining the equipment of aircraft. More specifically, there is § 11 of the 3rd implementation ordinance of the regulations for operating aircraft, 3. DV LuftBO in German legal speak. The LuftBO applies to all aircraft on the German register and its § 21 contains the requirements for oxygen but limited to commercial flights. The 3. DV LuftBO adds requirements that ally apply to non commercial flights. Here is what it says regarding oxygen:
The provision applies to all aircraft, not only commercial. Note that it only talks about "supply available", it doesn't require you to actually breathe oxygen.

Unless you're in a C152, 30 minutes is plenty of time to cross the Alps although 12 000 ft is not enough in all areas. The US rules on oxygen are more relaxed than what we find in Europe.

Thanks again all for this information it is really helping me understand stuff. As Peterh337 mentioned, the complete info is not out, so let me fill that in a bit, and then you can all tell me that I am mad. :uhoh:

I am IMC+Night with about 180 hours total time. Most of the flights have been in the UK obviously, but with a fair amount of Cross-Channel to France and Channel Islands, so I am familiar with all the Flight Plans etc. I have always tried to do something safe but challenging when I fly. Sort of so that I have 180 hours, not 1 hour 180 times... if that makes sense.

The aircraft that I have access to at the moment are C152, C172P and PA28-161. (I could get access to a C182 with a wobbly prop and a fuel injected C172 as well, but this raises my next question about Differences Sign-off under EASA, could a German Instructor sign me off on Differences for these aircraft?) As my preference would be for the C182 or Fuel Injected C172 as they have higher Service Ceilings. The PA28, I would only attempt on a CAVOK day where I could see right over the Alps, High Pressure on a winter day perhaps, but basically when I would be willing to bet my pension that the weather isn't going to change for a while. So at the moment I am settling on a C172, books says service ceiling 14,000ft; obviously I would trial this before hand if I can find a gap in some airspace or a very nice controller, but I would also go up with a pulse oximeter and take some notes on my own performance. But this will restrict me to about FL140, if I can find some O2 or FL120 without.

There are two destinations I have in mind, 1 is Portoroz in Slovenia and the other is Parma in Northern Italy. The two VFR routes that have been recommended to me are Innsbruck-Brenner Pass-Bolzano and Innsbruck-Pfunds-Malles Venosta-Merano-Bolzano; both bring you to approximately the same place. I would choose the upwind of the larger peaks based on the day. For the Portoroz flight I am looking at continuing east along the valley north of Bressanone, which would route towards Lienz before turning south to track just east of the Aviano CTR Boundary. But from what I am reading in the info that you have all provided it is probably best to head south over Bolzano and get out of the higher regions of the Alps as quickly as possible. This would reduce the time in the regions of FL100 to FL120 down to about 20 minutes. Also I guess if I planned a routing, on the Portoroz flight, south of Aviano CTR, once I got to Trento I could start looking to get a short cut through the CTR.

If I can summarise the discussion so far tho.

Achimha,you said: -

Thanks for your notes of the legal position. This reads to me like 12,000ft legal limit without O2 on board, as you say it only says I need a bottle. But this reads to me that if I go above 12,000 I do not need O2 unless I am there for 30 minutes or more, but I need it on board to bust 12,000. Is that a correct interpretation?

Fuji,

Yes agreed with you. Although someone once told me that a big issue in mountains is that clouds can whip up quickly. Now although I can fly on instruments, being halfway across the Alps when I suddenly have to fly IFR is not exactly where I want to be... I have a IMCr not a full IR, and no real de-icing equipment. So thoughts were, be above MSA, stay there and have a chat to ATC for some vectors. That niggle has stayed with me, and so I am just thinking if the clouds pulled in quick what would I do.

David Roberts, thanks for the advice on waves, are there any good websites for this info, I will Google it later, or is it down to experience. I'm assuming that the downwind side should always have the greatest interest.

Pace, I've taken what you've said on board and will check my O2 performance with altitude.

Peter, I wish I had access to something that could get me up to FL180 etc and stay there, without me getting very bored on the way up. I do read your trip blogs they are very informative and to be honest are inspiring me to give things a go, albeit with a lot of care because I recognise I am not the most experienced.

If you can get to FL140 you should be fine on a nice calm day.

Remember that the claimed ceiling will be achieved only in ISA conditions. In Sep/Oct you should be OK but much of this "summer" I have been seeing ISA+10 to ISA+15 and that knocks anything up to 3000ft off the ceiling.

Flying abroad is no problem and your 180hrs is fine. I was doing trips like this with less time. You just have to get your ducks in a row and do the planning and understand aircraft performance; stuff not necessary if going to say Bembridge :)

That's not a good strategy. For serious flights you need proper navigation which means a decent GPS. ATC will not offer vectors below their minimum vectoring altitude and that is usually a few thousand feet above the general terrain in the Alps. But you need to avoid IMC because of the icing risk; you will not have an escape route via a descent.

No, you need oxygen after 30 minutes at > 12 000ft. The law doesn't say what kind of system or that you actually have to breathe it. Once you climb above 13 000 ft, you need oxygen on board. If you don't have any and cruise at FL125, you have to descend after 30 minutes.

In reality nobody cares about this. I have never been asked by ATC to respect the semicircular rules and I regularly fly even levels (IFR) or other direction level in airspace C (which implies ATC clearance to do so). In my understanding, this is more a historical thing back when radar coverage was limited.

Peterh337,

I agree now hence "My thoughts were..." not are :ok:

Achimha, thanks with FL125 for 30 minutes that at least offers me compliance with semi-circular for the return leg. Even if it's not that adhered to.

Just adding that any tests you make to check out your own comfort altitudes should be done with another pilot who does have oxygen as he can monitor you in safety while on your own you cannot monitor yourself. The symptoms of hypoxia can be overconfidence and not realising you are making mistakes

Pace

I assume you wouldnt consider this trip without good GPS. On that basis I am not sure where you think ATC might come in with vectors? Over the Alps unless above the MSA they are not going to give you vectors, and in any event they arent going to see cloud on their radar (as opposed to precipitation). As with any flight above the MSA and IF in CAS you could request x degrees left or right for weather but the request is based on your visual perception of the weather ahead, or, if fitted, the weather information in the cockpit. To be frank at the point at which you start requesting vectors around weather unless you are very comfortable with what you are doing you might well do better with another plan (like turning back) because certainly I find when ever you start requesting vectors around weather there is a very good chance you will end up in IMC for a period of time. Once in IMC over the ALPs what are you going to do, even with ATC's help? You could ask for a climb, but you might not achieve VMC on top before exhausting your aircraft's performance, and you could ask for turns, but neither you or ATC will have much idea whether this is likely to take you out of the weather. Of course, what you cant do is ask for a descent which is often a good get out of trouble solution where the MSA is much lower and/or where you know there is VMC below. If you elected to stay in IMC for however long it took aside for the icing risk which is very real, you cant expect ATC to vector you "out of trouble". As a last resort it could be an option, but you definitely should not have got yourself into that situation in the first place unless you were also "happy" to take responsibility for your own navigation including diversions and for some unexpected reason (like dual GPS failures) things haven't gone well!

With apologies, I am not trying to teach you to suck eggs, or to bang on about IMC, but IMC above the Alps is really not a good idea and should be avoided at almost all cost unless you are very certain about your instrument flying and the aircraft's capability. In short unless you are very certain, the trip should be an assured VMC day and if it doesn't go to plan for any reason the old adage of turning back or diverting is a good one.

Don't forget this tool if you go flying high.

Checkmate Pulse Oximeter and Heart Rate Monitor

You can fill yer boots with oximeters here

This one is quite good, but would probably get in the way. Perhaps one could wear it on one's willy?

Might be worth taking the C172 up to Norfolk (CAS base FL200) and see how high it really goes. I wonder what the correct procedure would be to get a non-instrumented engine to the operating ceiling? A cruise climb ought to do it, I suppose, eventually. One cannot use the constant-EGT method without an EGT gauge.

I see in Cirrus's new offering they build the oximeter into the panel and, as before, the oxygen is "fitted".

Norfolk would be a good place, but I'm southern Germany at the moment... lol. A long flight for that. I can get to FL100 as it is all Class E to that level here, except for around the big airports where it is C/D. So I can probably get a good idea of climb performance to that level. I think it is C above that, so could probably ask Lagen Info for higher, they might say bog off... but you never know.

The steed does have 1 EGT gauge, in fact all aircraft I can get my hands on do, I'm not sure but the C182 might have EGT/CHT per cylinder as well; I would need to check.

I normally cruise around 6k to 8k when the leg is longer than an hour. Did Strasbourg a while ago 61 minutes wheels up to wheels down FL065. Worked well to constant EGT up to cruise and then set cruise power Peak EGT. On the way down I nudged it to about 100F ROP and then let it come back to just ROP, before nudging to 100F again. Worked well with a power on decent. Out of a PA28 got 125 to 130 KIAS all the way down to the circuit.

One EGT is better than none!

The problem of course is that you don't know if one (or more) cylinder(s) is (are) running hot and if you are using the EGT to operate at LOP then that substantially increases the danger of causing severe damage.

With a single EGT I think you are better off using the mixture control but back it up by a reasonable degree so the engine is running a little more rich, and by all means monitoring the EGT to establish whether it trends as you would expect.

You may well find that if you cross in Swiss airspace, they won't let you go into the Class C whose base is FL130 in places (was last time I looked). So you have to fly fairly close to the terrain. That's what I ended up doing on this trip in 2004.

One EGT gauge is good enough as it allows you to fly the constant-EGT climb profile, where you note the EGT after takeoff, and then gradually lean throughout the climb, keeping that value constant-ish. Some notes here (search for constant-EGT method).

I have flown - repeatedly - over several mountain ranges, not only the Alps. Leaving the O2 issue aside, trying to cross ANY mountain range with only 1000ft to spare borders on the insane, especially in an (at that altitude) totally underpowered a/c.

Do *not* assume that because it's nice and calm where you start your trip and the fcst wx is good that it will be like that at altitude and/or remain throughout your trip. Wx in the Alps especially can change at no notice at all and can easily catch you out. Always have a Plan B and enough air between you and the cumulugranitus.

Btw, you say you are in southern Germany. IIRC getting to FL120/150 is not an issue in Austria, if you want to give it a go. Then again, you'll already be half way across the Alps by then ;)

No problem, in 9 out of 10 cases you will get permission to enter airspace C in Germany as long as they get the impression that you know how to fly an airplane and do radio communication. Just give them a reason so they know that not granting the request would mean an inconvenience to you. Note that airspace E extends up to FL130 in the alpine area in Germany (marked on the VFR maps). Some months ago I went to FL200 just for fun and to test my oxygen saturation, no issue at all. They might give you a few vectors so you stay where they want you to be.