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Homebuilt / ultralight / permit (non ICAO CofA) and IFR - how?

RVs are all-metal though, aren’t they? No problem there – just got to sort out the avionics requirements.

Administrator
Shoreham EGKA, United Kingdom

RVs are all-metal though, aren’t they? No problem there – just got to sort out the avionics requirements.

Yes but that is just one aspect of build quality and type. Not all experimentals are suitable for inverted flight, a competent person has to determine if the lubrication suitable is suitable. There is no reason why it would be exceptionally difficult to create an experimental that is safe for IFR. I have never heard of a high accident rate with experimentals under IFR in the US.

Quite often when I see some details about a certified aircraft, I get the strong feeling of being more competent myself

With just a permit to fly, I don’t see how you ever would be allowed to fly outside your own country. Experimentals are annex II. EASA will not now and not ever touch annex II. They are not part of EASA regulations.

Ultralights have the same problem, but since they are, well ultra light, VFR day only etc, and those basics are the same all over Europe, you are allowed to cross borders. You have to file an application for every country though.

There is nothing preventing permit to fly to also include IFR – in theory, but then you would need a set of new regulations all over to be able to cross borders, and lots of problems to even get the equipment approved.

Experimentals have to have a c of a. Then the whole problem becomes a no issue. American homebuilts registered as experimentals do indeed have Special C of A. They are not Permit to Fly – aircraft. Every single individual has its own C of A with restrictions imposed by the FAA.

It is important to understand the difference between experimental class aircraft and certified class aircraft. Certified aircraft receives C of A based on certification, ex class aircraft receives C of A based on examination and test flying of each individual. This is how it’s done in the US, Sweden, Norway (after a “break” of 6 years), and many other places.

Norway and Sweden has always been tied to the EAA. This has recently been enforced rather drastically, where anyone wanting to build or own an experimental, cannot do so without being a member also of the main organization, not just the local Norwegian branch.

The UK have the LAA, which seems to be different, much stricter somehow, but I don’t know much about it.

The elephant is the circulation
ENVA ENOP ENMO, Norway

With just a permit to fly, I don’t see how you ever would be allowed to fly outside your own country. Experimentals are annex II. EASA will not now and not ever touch annex II. They are not part of EASA regulations.

All ECAC members allow experimentals of other ECAC members to enter their airspace without prior permission. This permission is contained in the AIP and in most cases is limited to VFR/daytime.

There is nothing preventing permit to fly to also include IFR – in theory, but then you would need a set of new regulations all over to be able to cross borders, and lots of problems to even get the equipment approved.

No, all you need is an AIP change that removes the “VFR/daytime” restriction. Avionics requirements are already laid out in law in all states. Already today there are major differences (e.g. Germany requires a DME for all aircraft in its airspace even when not required for the approach).

The real difference between C of A aircraft and homebuilts doesn’t lie in the design standards. It lies in the fact that homebuilds, by definition, are not constructed in approved and regulated production facilities. So there can be no assumption that a particular aircraft has been built in accordance with the design standard (and thus each individual example of the type must be test flown and data recorded to show that it really does fly as expected).

With just a permit to fly, I don’t see how you ever would be allowed to fly outside your own country.

This has been happening for many years, and I have done it myself. It’s based on mutual acceptance and respect for other countries’ design approval and flight testing standards. This can either be by membership of groups such as ECAC (as #15) or simply by mutual acceptance between two individual states.

The design standards for ‘homebuilds’ can be rigorous. For example, in the UK the standard for microlights (ultralights) is the BCAR (British Civil Airworthiness Regulations) Section S. This gives a voluminous set of standards any new UK design must meet before being given type acceptance as a microlight. It’s no longer a question of putting a lawnmower engine on a kite and hoping for the best

TJ
Cambridge EGSC

All ECAC members allow experimentals of other ECAC members to enter their airspace without prior permission. This permission is contained in the AIP and in most cases is limited to VFR/daytime

That is true. And it is VFR day only.

No, all you need is an AIP change that removes the “VFR/daytime” restriction

Probably also true, but much easier said than done. The VFR day only was put there for a reason.

The laws already have the Special C of A. It was originally put there to cover special cases. Experimental class aircraft is such a special case. Why make this more difficult than it is? With a C of A there is no question.

Last Edited by LeSving at 23 Apr 10:06
The elephant is the circulation
ENVA ENOP ENMO, Norway

All ECAC members allow experimentals of other ECAC members to enter their airspace without prior permission. This permission is contained in the AIP and in most cases is limited to VFR/daytime

What aircraft types does this automatic permission apply to?

It can’t be all “homebuilts” because e.g. I recall somebody in the UK having waited 2 months for a permission from Spain.

Avionics requirements are already laid out in law in all states.

Those, however, are requirements for certified aircraft. I am not sure if the regs are drafted exactly in those terms (i.e. ICAO CofA) but it is clearly implied when one talks about IFR. But, surely, much of the point of going “non-ICAO-CofA” is precisely to avoid having to fit certified avionics! You want to use Dynon gear for 5k, instead of a GTN750 (or whatever) for 25k. You do not want to install a DME (5k-10k).

And, as I said above, you also want to be able to fly Eurocontrol (high altitude) IFR but that will require RNAV1/PRNAV in some years’ time, which will never be met using the non-TSOd avionics, so IFR certification done the way people want it (using uncertified avionics) is going to be worthless. If you want to fly IFR but not Eurocontrol IFR (IFR in CAS, etc) then you are looking at IFR in Class G, basically, and you can do that already, illegally, but you will never get caught unless you are unable to make a VFR arrival.

IFR in Exp works in the USA because (a) they don’t have any fancy €-land gold plated avionics requirements and (b) the more upmarket Exp pilots (e.g. turboprops) will spend the money on certified avionics because it is worth it for the mission capability.

Administrator
Shoreham EGKA, United Kingdom

The real difference between C of A aircraft and homebuilts doesn’t lie in the design standards. It lies in the fact that homebuilds, by definition, are not constructed in approved and regulated production facilities. So there can be no assumption that a particular aircraft has been built in accordance with the design standard (and thus each individual example of the type must be test flown and data recorded to show that it really does fly as expected).

Exactly. This is what certification is all about. A paper showing each individual part is fabricated according to certain standards an processes, along with material sheets etc. If the paper is OK, the part is OK, per definition.

For a homebuilt each step of the process is signed off by a CAA appointed person. Then the CAA inspects and sign the finished aircraft. In the US it is enough with the final inspection.

The elephant is the circulation
ENVA ENOP ENMO, Norway

I don’t think I am making myself clear

IFR for “homebuilts” will deliver very little value in Europe unless huge exemptions are made on equipment requirements.

Already, you need a BRNAV approved IFR GPS installation to fly IFR in any CAS.

Administrator
Shoreham EGKA, United Kingdom

BRNAV approved GPS would certainly be more expensive than a non-approved GPS, but certainly not prohibitive one would have thought for the extra capability it could bring. Some of these aircraft are very fast and efficient, so the upgrade could well be worthwhile.

EGBP, United Kingdom
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