How to file a flight plan for IFR flights in uncontrolled airspace in France (and other places)

Except for the “surface S” thing, that seems to agree with SERA. No surprises.

There clearly is something a bit awry with the way IFPS is programmed for France. It simply doesn’t quite “fit” their airspace structure. Other countries with big amounts of class G below FL100 (UK, Poland, Sweden, etc.) have much less restrictive filing rules for IFR routes.

To expand: IFR is allowed in France’s class Golf, without any major restrictions. The only one is in the rule on minimum cruising altitudes as per ENR 1.3 (quoted above by PCV). But these are still noticeably lower than the FL70 minimum which there is on most airways in flatland France.

IFR in class G isn’t even discouraged anywhere. Consequentially, IFPS should NOT be programmed to basically make it impossible to flightplan flights below FL70. That is quite a restriction (again, not for the flying after all, but at least for the planning).

And the interesting question is: why has this “problem” seemingly never been “picked up” by anybody in France? I mean, we know that the vast majority of “small GA” in France is at the aeroclub level, where 98% of flights are purely VFR. But still, with so many private pilots as there are in France, there must be a certain (not totally insignificant) number of pilots flying “real” A-to-B IFR flights, more or less all year round, in non-deiced, non-turbo SEP aircraft. Why have they never adressed this with the DSNA?

Sure, as 9M said, one can always file for FL70, and then, if it turns out necessary due to, inform ATC about descending to a lower level. And yes, this does work without a problem (I have also done it a few times). ATC will merely remind the pilot that he will be in uncontrolled airspace, and then everything goes on as before. Also, in most cases, even in winter, one will probably not have to do this too frequently after all, because, quite often IME, one will already be above most cloud at FL70. But I still understand that Wolfang wishes to file the altitude/level which he really plans/expects to fly, and not something else.

One reason this has not been “adressed” from the pilots side is that some of those (rather few) hardcore IFR pilots might possibly just file VFR, and then fly below the icing level, in whatever conditions (VMC or IMC) they encounter, while of course declaring “VFR” to ATC/FIS.

File a series of DCT’s eg:
DCT 450000N 0010000W DCT 450000N 0012000W
It works if your waypoints are not too far away (10NM to 50 NM depending on the area)
But you won’t be able to file through a TMA for instance.
(May I suggest that autorouter could provide an automatic process?)

My method, if the weather is legally VFR (There is a full coverage of France with GAFOR to check that) is to file VFR, and then to tell ATC that I change to IFR.
They will tell you they can’t do that, but you will answer that it’s their problem, it’s your decision to make to change to IFR out of CAS. It’s perfectly legal without any permission to require
SERA.5005
(j) An aircraft operated in accordance with the visual flight rules which wishes to change to compliance with the instrument flight rules shall:
(1) if a flight plan was submitted, communicate the necessary changes to be effected to its current flight plan; or
(2) as required by SERA.4001(b), submit a flight plan to the appropriate air traffic services unit as soon as practicable and obtain a clearance prior to proceeding IFR when in controlled airspace

In France the sole constraints are
i Minimum 3000ft AMSL
ii Contact with ATS
iii Filed flight plan.

It’s usually easy to get an IFR clearance to cross a TMA at low (3000/4000ft) level (not around Paris of course!)

boscomantico wrote:

One reason this has not been “adressed” from the pilots side is that some of those (rather few) hardcore IFR pilots might possibly just file VFR, and then fly below the icing level, in whatever conditions (VMC or IMC) they encounter, while of course declaring “VFR” to ATC/FIS.

Could be. I mean not the first time I hear this.

All the discussion reminds me my very first IFR flight, a good year before I got my IFR rating (did not even know I would pass it)
From my logbook, I can read that on 26/03/2011, I flew with an instructor, an IFR flight plan (filed by phone, as far as I can remember) from LFMA to LFMV, at 3000ft AMSL (in IMC all the way)

Obviously, the tools to file FP were not the same. At the time, that was no problem for ATC. I should add that, on this route, 3000 AMSL put us into CAS.

For the short story, the only enroute instrument we had in this PA28 was… An ADF

Piotr_Szut wrote:

They will tell you they can’t do that, but you will answer that it’s their problem,

Not sure it’s the best way to get them help you
To me, in-flight IFR FP filing is not the rule (I can remember I did it once, and ATC clearly suggested it was a favor)

… But I could be too conservative on this point.

Out of controlled airspace they are not supposed to help you a lot. They just provide an information service which not more difficult to provide to an IFR flight.
I understand that the problem is that ATC can’t easily change your flight plan from VFR to IFR. But it’s their problem. The regulation is clear
SERA.5005
(j) An aircraft operated in accordance with the visual flight rules which wishes (it’s literally as you wish) to change to compliance with the instrument flight rules shall:
(1) if a flight plan was submitted, communicate the necessary changes to be effected to its current flight plan; or
(2) as required by SERA.4001(b), submit a flight plan to the appropriate air traffic services unit as soon as practicable and obtain a clearance prior to proceeding IFR when in controlled airspace

i Minimum 3000ft AMSL
FRA.5025 a)
Mise en œuvre
1) Le niveau utilisé doit être supérieur ou égal au niveau défini en SERA.5015 b) et au plus haut des deux niveaux suivants : 900 m (3 000 pieds) au-dessus du niveau moyen de la mer et 300 m (1 000 pieds) au-dessus de la surface

ii Contact with ATS
FRA.5025 b)
Mise en œuvre
Un aéronef en vol IFR en espace aérien non contrôlé établit des communications bilatérales avec l’organisme des services de la circulation aérienne assurant le service d’information de vol
iii Filed flight plan.
PLANS DE VOL FRA.4001 b) 3) Mise en œuvre
En application du b) 3) de la disposition SERA.4001, le dépôt d’un plan de vol est requis pour les vols effectués conformément aux règles de vol aux instruments.

Regulation is clear indeed.
Thanks for the reference !

wbardorf wrote:

or filing a flight plan for a route with an MEA of FL150 without oxygen onboard and then saying “unable, need a lower flight level”.

I had oxygen onboard

As for SERA, giving a further look, it appears that transposition into French regulation (SERA —> FRA), implied some light interpretations / adaptions.
All in all, it’s almost the same.
About switching from VFR to IFR in-flight, I found this: Arrêté du 21 avril 2017 relatif aux règles et procédures pour les services de la circulation aérienne rendus aux aéronefs évoluant selon les règles de la circulation aérienne générale

Where one can read this:

• on a Z flight plan, the pilot should ask 10 minutes before reaching the filed waypoint where the flight rule is to change, to get the initial clearance
• while VFR (with or without FP), and facing unforcast conditions, the pilot must give his IFR FPL over the radio. As this is unforcast, he must account for a delay, depending on trafic density, and ATC availability.