So IFR is not permitted outside controlled airspace in Germany.
What is the legal basis of this? Can anyone provide a written reference from which this prohibition is derived?
For practical reasons, where does one find the lowest possible IFR altitude?
Thank you,
Christian
CLE wrote:
What is the legal basis of this? Can anyone provide a written reference from which this prohibition is derived?
Actually, IFR is permitted outside controlled airspace in Germany. (SERA permits it and Germany can’t overrule that.) Indeed, there are many instrument airports in class G. On the other hand, the airspace structure and a unique interpretation of separation rules mean that it is not feasible to fly uncontrolled IFR except for arrivals and departures from these airports.
For practical reasons, where does one find the lowest possible IFR altitude?
Along ATS routes, the lowest possible altitude is stated for each route segment in AIP ENR 3 or enroute charts. For directs, the minimum vectoring altitudes apply, which you can find in AIP ENR 6.
Thank you so much, this was exactly the information I was looking for!
I haven’t seen a replacement for NFL I 254/14 which clearly states that Sera 6001g of EU regulation 923/2012 is ONLY applicable if the member states themselves allow IFR flight in uncontrolled airspace and in this case, the NFL I quoted clearly states Germany will NOT approve this.
This is a copy of the NFL, due to safety concerns, Germany will NOT permit IFR outside controlled airspace – this is why germany had so many Airspace F/HX over smaller to medium sized aerodromes. Now any IFR outside controlled airspace is only on specified IFR procedures where (eg) the routing is protected by an RMZ.
My understanding is that that NfL has been withdrawn a while ago – it is no longer listed in the list of valid and applicable NfLs as it contravenes SERA.
Germany has since decreed that IFR clearances in class E can be issued only above the MVA (see https://aip.dfs.de/BasicIFR/pages/P001EB.html), which due to airspace structure makes it relatively useless, especially in areas where class E goes down to 1,000 or 1,700 ft AGL. You could theoretically fly IFR in class G up to 2,500 ft AGL in most parts of Germany but would be limited to that altitude whilst also having to comply with minimum flight altitude and circular altitude rules.
Steve6443 wrote:
haven’t seen a replacement for NFL I 254/14 which clearly states that Sera 6001g of EU regulation 923/2012 is ONLY applicable if the member states themselves allow IFR flight in uncontrolled airspace and in this case, the NFL I quoted clearly states Germany will NOT approve this.
The crucial part of the NFL is this: “Die Möglichkeit besteht jedoch nur dann, wenn dir Mitfliedstaaten dies auf der Grundlage von Anhang SERA.5015 Buchstabe b der Durchführungsverordnung (EU) Nr. 923/2012 genehmigen.” In translation: “However, this is only possible if the Member States authorise this on the basis of Annex SERA.5015(b) of Implementing Regulation (EU) No 923/2012.”
But that doesn’t make sense. SERA.5015(b) is not about authorising anything. It concerns minimum altitudes for IFR flight. Hypothetically, the possibility of the Competent Authority to decide on minimum altitudes other than the standard ones could be used to make uncontrolled IFR impossible by formulating a minimum altitude rule so that the minimum altitude is always in controlled airspace. (I seem to recall that Germany tried that but got told off by the EU – but I might be wrong.)
Anyway, I can’t find any mention in AIP-Germany either of a prohibition of uncontrolled IFR or of special minimum altitudes for IFR. Indeed the airspace classification table in ENR 1.4 clearly states that IFR is possible in class G.
But legalities aside the question is moot because, as I wrote above, uncontrolled IFR is practically impossible in Germany except for arrivals to and departures from instrument airports in class G.
wbardorf wrote:
You could theoretically fly IFR in class G up to 2,500 ft AGL in most parts of Germany but would be limited to that altitude whilst also having to comply with minimum flight altitude and circular altitude rules.
And, crucially, you would not be able to climb into or descend out of controlled airspace IFR because of the way the DFS applies separation rules. Namely that ATC has to apply vertical separation to controlled IFR flights even to aircraft below controlled airspace. This is obviously impossible if the IFR flight is closer to the bottom of controlled airspace than the vertical separation standard. In particular this means that it is not possible to get a clearance to climb into or descend out of controlled airspace IFR. E.g. flights on Z flight plans have to maintain VMC until they have climbed to the MVA. To my knowledge, no other country interprets the separation rules in that way.
