Yes, your TCDS holds similar Operations Capabilities and limitations as the MS 893, subject to the TB20 AFM minimum requirements.
I´m not sure if the TC IFR certification requirements are still valid, since as mentioned above, it seems EASA regs have change at some point around 2020, with regards to the minimum navigation equipment requirements. I´ll need to start digging into this stuff. Nobody ever said it was going to be easy. Thanks for the link – I´ll have a look. Cheers.
Hold on guys, IFR certification is NOT an equipment only – what I tried to make clear previously already.
Just take one easy example = Socata MS 892 does not have any conducting material for static protection put under the aircraft surfaces as the MS 893 does have – meaning there is no, not any, lightning protection on the 892, while it is on the 893. You don’t want to fly IFR or even IMC without lightning protection whatsoever! I did have quite some strikes in IMC flights and also on IFR still being VMC (getting too close to nasty cloud bitches … too young too stupid too self-confident) and strongly advice against even trying to think!
A friend owns a 892, was just talking to him in the evening on the constructional differences to a 893 and got a clear answer = never, never ever give a thought on trying to get a 892 on standards for IFR certification for a bargain, it is either dangerous or more expensive than a wife plus a dozen concubines (No, I did not ask him how he came to exactly that conclusion …).
Just take one easy example = Socata MS 892 does not have any conducting material for static protection put under the aircraft surfaces as the MS 893 does have – meaning there is no, not any, lightning protection on the 892, while it is on the 893. You don’t want to fly IFR or even IMC without lightning protection whatsoever! I did have quite some strikes in IMC flights and also on IFR still being VMC (getting too close to nasty cloud bitches … too young too stupid too self-confident) and strongly advice against even trying to think!
Isn’t that a “practical” matter? See here and especially here.
On your criteria, a big chunk of the list here would never get it.
Not saying you are wrong 
BTW MichaLSA you appear to have an invalid email address configured for your signup, and it is bouncing.
Most of the GA fleet operating IFR now was never explicitly approved for IFR, because IFR approval was not a feature of an aircraft type certification when and where they were certified. European TCs had it first, given that Europe is the world leader in aircraft related bureaucracy, but most US types had no mention of flight rules entered in their TC. The only requirement for these types is that they are equipped for IFR, which has nothing to do with the TC. I always smile when reading how it is certain death to fly IFR in a type that doesn’t have lightning protection etc. Somehow the wood construction Bellanca Vikings and numerous other certified and E-AB types have avoided frequent demise regardless. All of them are used for IFR every day.
My advice if buying a plane to fly IFR would be to review the TC to make sure that it is not explicitly limited in this respect. My type has no explicit limitation but is implicitly limited by a Day/Night VFR instrument panel placard and a statement in the TCDS that says placards must be obeyed. My IA believes that if the plane is equipped properly in this circumstance, then you just remove the placard and that’s the end of it. But I agree its better if the issue doesn’t exist at all.
My advice is to use common sense (for the younger, that is the way our ancestors were able to invent all these crazy things).
Yes, in former times they did not put any VFR/IFR stuff in TCs, simply because they thought an aircraft as replacement for a car. Ever seen a car manual stating “do not drive at night” or “not approved to drive on a wet road”? (Ok, maybe they introduced that with Teslas …) Flying was about purely taking the chance to decide by yourself.
Btw, I treated the original Q as being one regarding an IFR certification, which is slightly different from ‘flying IFR because the TC does not prohibit it’. If you want to be ‘on the positive certified side’ one is longing for a proof to be allowed by somebody else. Not everybody sees this a the best way of living (me neither).
Yes, I have flown IFR in IMC with wood biplanes on basic instrumentation, but those I used had conducting paint to give a basic protection against statics and lightning damages. Would anybody with todays knowledge fly without that bare minimum protection? I somehow doubt, especially since our modern electronic equipment is less tolerable to such things.
@Peter: I don’t know what the problem is, checked the data and it is correct and no problem on my side.
Common sense is good and probably the most important (if one actually has that..), but obviously the legislation has to be complied with, and in my topic the concern was the latter. Is it legal to fly an appropriately equipped (Instrumentation, Navigation etc.) MS 892, not if it´s wise or safe to do so – that´s very left to the common sense, that you´re appealing for, and ultimately an individual perspective (which of course can be discussed as well).
As much as I appreciate you´re concerns about statics and lightning threats, I don´t really see any bigger threat flying VMC on a IFR flight plan as opposed to flying VMC on a VFR flight plan. I´ve mentioned already that I would not (in general) plan on flying marginal IMC (for me marginal IMC on SEPs are cloud base dependent due SEP engine out considerations) on any SEP (certified or not!).
Just to recapture my operational perspective; Filing an ATC (“Z”), Depart VFR, fly enroute IFR (Not IMC!), Arrive VFR – in general smaller regional airfields (w. no IFR approach availability anyways!). It´s just for simplicity of flight planning.
My legal concern, remains whether one can fly the MS 892 (Instrumentation and Equipment compliant with EASA (in my case)) legally with the Type Certificate as previously disclosed.
@Yeager: now we are getting closer with this information. Different NAA will act different when asked on the topic whether it is ‘allowed’ to file IFR on a VFR aircraft. IMHO, this is a still open topic and has been heavily discussed when CBIR was coming to life. Yes, many if not most FI will do certain IFR training on a VFR-only aircraft in VMC if outside ATO, even filing IFR with those aircraft and doing training approaches at large airfields. The ‘legal’ aspect then comes down to – who is enforcing it and what can possibly be the legal basis for any prosecution?
Yes, it´s the “legal” aspect that I´m mostly trying to figure out – for a variety of reasons.
I recall a Learjet and Bornholm, and that it was an aircraft with expired docs, but not much more. I´ll prob look it up late.
Would you say that the MS 892 Type Certificate is “explicitly limited” from IFR operation/capabilities, considering the TC PDF
page 18 (MS 892) vs/page 25 (MS 893).
Many thanks for all of the input you Gentlemen are providing – it´s great to be able to benefit from the experience and knowledge of other!
MichaLSA wrote:
Btw, I treated the original Q as being one regarding an IFR certification, which is slightly different from ‘flying IFR because the TC does not prohibit it’. If you want to be ‘on the positive certified side’ one is longing for a proof to be allowed by somebody else. Not everybody sees this a the best way of living (me neither).
Agree on that! Cheers.
MichaLSA wrote:
Yes, many if not most FI will do certain IFR training on a VFR-only aircraft in VMC if outside ATO, even filing IFR with those aircraft and doing training approaches at large airfields. The ‘legal’ aspect then comes down to – who is enforcing it and what can possibly be the legal basis for any prosecution?
Filing IFR aside, part-FCL does not generally require that training for the IR is done according to IFR. It requires “instrument time”, which simply means that the aircraft is controlled solely using instruments. This can be simulated in VMC. (There are exceptions, of course, where IFR is necessary for some particular training.)
