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I do not argue, here, of the rights or wrongs of the particular rule or whether or not it meets international best practice. But flying in France to fields which are unmanned I cannot get away from the fact that this is a regulation set down by the DGAC.
I do not have the motivation to fight this rule and my training is such that I am quite at ease carrying out the procedure as ruled in the knowledge that to do otherwise would be to commit an infraction.
I am just trying to point out to others that if you do as has been suggested (whether you think it is safer to do so or not) you will have committed an infraction and you could be sanctioned.

France

gallois wrote:

But flying in France to fields which are unmanned I cannot get away from the fact that this is a regulation set down by the DGAC.

I recall flying to St.Yan when I was doing my initial IFR there was no ATC, but there was an IAP and if I remember right the Missed approach was used as SID. I am not aware that in France you are or were allowed to fly self defined SID/IAP’s in G without the aerodrome actually having one. Otherwise, what would keep you from McGyvering a GPS approach e.g. to Courchevel or Megeve or let some enterprising souls take off from there in zero vis? I can not believe that Part-SERA or NCO allow this or at lest that this was the intention?

LSZH(work) LSZF (GA base), Switzerland

Of course, I do MVL during my dual flights which usually happens in CAVOK and the logic usually applies as the circuit is busy and there is no VFR/IFR priority

However, I will be impressed if you can find someone who does it at LFAT at 830ft MVL instrument circling minima then visual circuit between wind turbines with ceiling at 1000ft? are you aware of DGAC IRI/IRE who will do it in those conditions?

I will not, I prefer to chicken out and land on straight-in and make my life easier and take care of any paperwork later but YMMV

Last Edited by Ibra at 13 Nov 14:49
Paris/Essex, France/UK, United Kingdom

Actually the MVL at LFAT is 570 ft if you have the QNH so I would be surprised if an IFI or IFE would not expect you to do an MVL of 830ft without airfield QNH.
But as I wrote I am not in the business of telling people how they should fly or set their limits.I would expect anyone who acts a PIC to be able to think for themselves. However, sometimes we can miss or forget something in the regulations.
So I thought it might be an idea to point out that what you suggest is in fact against regulations, unless someone can point out where it is not.

France

 I am not aware that in France you are or were allowed to fly self defined SID/IAP’s in G without the aerodrome actually having one

Not sure about the various public airports but on your private aircraft in your private grass strip or backyard with your own operator manual, who has the authority to say NO? (other than pilots you would come across in clubhouse or online)

Actually the MVL at LFAT is 570 ft if you have the QNH so I would be surprised if an IFI or IFE would not expect you to do an MVL of 830ft without airfield QNH.

That is another unrelated distinction, I was assuming no QNH, be hey if you do ILS then MVL at 570ft in LFAT by circling South followed by visual circuit to the North you are 100% dead, I will let you find out why…

If I have to fly a visual circuit in LFAT in very marginal conditions to please whoever want to get pleased and see one, I will do it with autopilot at 2000ft in IMC inside clouds at the base of Echo, straight & level like a King then join again for straight-in IFR landing like a Princess, I leave VMC scud runs and terrain proximity flying to the experts !

Last Edited by Ibra at 13 Nov 15:30
Paris/Essex, France/UK, United Kingdom

Mooney_Driver wrote:

So basically the german rule applied also elsewhere that IFR in G airspace is prohibited has been overruled by Part NCO and Part SERA.

Before SERA, that rule was specific to Germany and some other countries. The UK, France, all of Scandinavia, just to name a few, have always allowed IFR in class G airspace, also for CAT. You’ll find lots of destinations in Sweden where airlines fly uncontrolled IFR.

So non-commercial IFR in class G, which generally is a small band of height AGL is allowed. Ok, fine. I was under the impression though that this is primarily intended for IFR approaches to airfields without ATC, hence in and out of airfields which have an IAP/SID but not for self-made procedures.

The “small band” is specific to Germany and some other countries and is due to their choice of airspace structure. The UK, France, all of Scandiavia, just no name a few, do not have this narrow band. I agree that the German airspace structure makes uncontrolled IFR enroute both unfeasible and unnecessary.

IMHO, that EASA rule will kill many people in the future, once people realize what has been done here.

That remains to be seen. The UK has always had that rule and we haven’t seen a lot of people being killed by it. Certainly more people have been killed flying in marginal VFR.

Still, IMHO this is NOT a free for all to do their own IFR procedures: minimum flight altitudes over built up areas and over non-inhabited areas still apply. Doing a SID or IAP into an airfield which has no such proceedure would forcibly violate the minimum flight altitude rules.

No, they don’t. SERA says that minimum altitudes apply “Except when necessary for take-off or landing”. (SERA.3105) This applies both to VFR and IFR. Note that there is no rule that specifically says you may fly below minimum altitudes when following a departure or approach procedure.

I guess what this discussion shows (aside from different approaches to risk management) is that although SERA has been with us for 7-9 years and part-NCO for 5-8 years (countries had some choice of implementation date) people who had a license earlier than that still apply the old national regulations they were once taught even though they have been replaced by EU regulations. I find that a bit disconcerning.

Last Edited by Airborne_Again at 13 Nov 15:41
ESKC (Uppsala/Sundbro), Sweden

Peter wrote:

Who is the sim pilot?

I suppose @boscomantico refers to the fact that I worked in flight simulation for some 20 years parallel to my real world flying and being a dispatcher and later met guy and wrote for a flight sim mag for 13 of them, until 2013 that is. Long time. I have not used flight simulators since the mag I worked for stopped and am as far away from flight simulation now than I am from my MEP and IR which expired before that. If it was meant as an insult, well, won’t work. It is a phase of my life I am proud of and it resulted in a lot of good friendships and a published book. Not to speak of many real nice experiences I could never have had otherwise and a hunger for playing with airplane performance which will never cease. Ah yea, and it also paid for my plane and flying the first few years.

And of course while I am very much involved in the ops of my airplane, there is no denying that I have not flown since 2018 mainly for lack of time and the decision that watching my daughter grow up close by is more important.

@Airborne_Again has got it right when he sais that I never fully grasped the full significance of what SERA and Part NCO allow regarding this kind of operation. I am also too far away from current day IFR (my last IFR flying dates from about 2000) so I suppose my MEP and IR experiences are by now worth nothing, which is obviously why people like me have to redo 7 subjects if I ever want to fly IFR again. The chances I’ll be able to do that is close to zero though for lack of time.

So I will shut up regarding these matters. I am still very much involved with performance and technical stuff and from time to time help people buy airplanes. That is probably all I’ll do in the future… also fine. I have nothing left to prove other that I can bring up and provide for my child and see her grow up. All that counts to me.

Last Edited by Mooney_Driver at 13 Nov 17:06
LSZH(work) LSZF (GA base), Switzerland

Mooney_Driver wrote:

I suppose boscomantico refers to the fact that I worked in flight simulation for some 20 years parallel to my real world flying and being a dispatcher and later met guy and wrote for a flight sim mag for 13 of them, until 2013 that is. Long time. I have not been a simmer since the mag I worked for stopped and am as far away from flight simulation now than I am from my MEP and IR which expired before that. If it was meant as an insult, well, won’t work. It is a phase of my life I am proud of and it resulted in a lot of good friendships and a published book. Not to speak of many real nice experiences I could never have had otherwise and a hunger for playing with airplane performance which will never cease.

If that’s really what he meant I find it strange. You have never given the impression of being anything but a “real” pilot. Also, your experience in flight dispatch and meteorology has been valuable to many discussions. That you haven’t flown for a few years doesn’t change that. I do hope you’ll get back to flying eventually. Your daughter will love it!

Last Edited by Airborne_Again at 13 Nov 16:21
ESKC (Uppsala/Sundbro), Sweden

I obviously meant the guy who just registered here and then said

to the plain facts:

and then

i could verify that he flew out 23

and then

i tried to reconstruct the flight on my fs2020

Mainz (EDFZ) & Egelsbach (EDFE), Germany

Well, cpt_om_sky is one of many people who join up just to comment on an accident thread and then disappear, never to be seen again. His first post sounds like he is an instructor, but with a totally empty profile, who knows?

Trying it on a flight sim is better than trying the same route in a real plane and ending up in the mountain also.

Still, nobody has posted the exact regulations applying at LOIH.

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Shoreham EGKA, United Kingdom
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