IFR/Night Update

Back in the day, lack of IFR capability was often cited by the naysayers as a reason for not getting involved in LAAadministered aircraft. Along with the ability to use (some) Permit aeroplanes for flight training, this impediment has now been substantially removed. The numbers cleared for IFR are slowly rising and, as experience grows, the process is getting more streamlined. So, what exactly is involved in getting a clearance to fly IFR and at night?

When talking about aircraft capability, clubhouse (and internet) chat invariably focuses on the narrow specifics of instrument fit. Will my aircraft be accepted with a Dynon ‘this’ in combination with a Kanardia ‘that’? Will a full Garmin G3X system be compliant? What about a conventional six-pack of vacuum gauges?

In practice, the exact instrument fit is almost the least difficult part to get right. A traditional six-pack will do just fine, as will almost any combination of modern EFIS systems. Before we can even get to that, it’s important to consider if the aircraft type is even a suitable platform to fly IFR. Is it fitted with a suitable engine? If it is, we need to be sure all the systems work in harmony, are installed to a proper standard, operate correctly, and have sufficient redundancy to ensure you can get back on the ground if something fails. And of course, everything has to be maintained effectively and operated safely.

Why, some might say, is all this so stringent? Surely it can’t be that hard to fly a Permit aircraft in IFR – what’s the big deal? It’s surely not this hard for Experimental aircraft in FAA-land?

The opportunity for things to go wrong in IFR and at night is probably no greater than by day in VFR. But the consequences of things going wrong quickly multiply in the cloud – and in the dark. This added risk must be balanced by appropriate risk mitigations. From the CAA’s perspective, there is also the added complication that our LAA aircraft will be mixing with other IFR traffic, relying on accurate navigation, calibrated altimeters and good quality communications without the benefit of ‘see and avoid’ to keep out of the way of everything, including commercial air transport. That puts quite a high burden on us to get it right.

Many LAA members are quite understandably looking for a simple ‘cloud break’ capability and reasonably ask, why does this all apply to me? I don’t have a full IR and I don’t fly in airways, so isn’t it all a bit burdensome? The CAA’s view is that the aircraft is either approved for IFR or it isn’t. And if it is, it needs to be up to the required standard.

The starting point in determining the LAA’s philosophy for working out what the required standard is, comes via an agreement with the CAA that Permit aircraft cleared for

IFR and night should be able to demonstrate a broadly equivalent level of safety to its certified counterparts. In practice this means the LAA and, in turn, the owner, must be able to demonstrate the IFR-specific parts of the aircraft meet the requirements of lowest Certification Standard that allows IFR flight. This turns out to be CS-23.

CS-23 is several hundred clauses and sub-clauses long, and makes tough reading even for hardened engineering professionals. Fortunately, a distilled version of the critical elements, in so far as IFR flight is concerned, has been provided in a condensed LAA Technical leaflet. TL2.28 is essentially an aide-mémoire and template to provide all the required information.

Certified standard debates

Contrary to some hangar-chat, none of this means that any of the systems or equipment must be certified. Or that the aircraft will have to be rewired to a certified standard. Or that the engine or propeller must be certified. Indeed, the most basic standard IFR fit is not even required to have any NAV instruments or an approach capability at all. Similarly, there is no need to have any complex instruments (EFIS or glass panel). In most instances, well-built and well-maintained aircraft that look suitable for IFR probably are… (see sidebar, p22: Where might your IFR application go wrong?)

In the most basic terms, all that is required is to show that the aircraft can safely be piloted in IMC, the systems are reliable and that no single failure will make IFR flight impossible. Once approved, there must be sufficient information to fly and maintain the aircraft without specific knowledge of having built it.

As part of the agreement with the CAA, and the need to show equivalent standards of reliability, there is an expectation that the powerplant will be designed and built for use in aircraft. There is no need for certification, though a certified or ‘clone’ engine will be easiest to clear. VW and other automotive, industrial and agricultural-based units would need to demonstrate the same reliability as purpose-built engines, which in practice could prove very difficult. Historically the LAA has been wary of electronic ignition systems and, where fitted, has required at least one traditional magneto. This stipulation has been relaxed somewhat recently and engines fitted with two E-Mag Model P units are now accepted.

For those who argue life is easier in the USA, you might want to check carefully. It turns out that both Certified and Experimental IFR aircraft in FAA-land must comply with the same requirements, including the required annual inspections by an approved avionics shop. Strangely, the rules are simpler in some respects, in that there is no requirement in the USA to have redundant systems. If your single attitude indicator fails or the power to the whole system goes off, you could find yourself in trouble. The reader can decide for themselves if they think that is a good idea.

Team effort

In practical terms, the LAA’s objective has been to leave individual owners free to make their own choices about equipment and systems, while remaining within the confines of CS-23 and the ANO. The final authority to sign-off an individual aircraft for IFR and night, rests with the LAA’s CTO. In practice he is supported by a small cadre of IFR Assessors, test pilots, a group of IFR qualified Inspectors and as always, members of the LAA Engineering staff. As with almost all LAA activity, it’s a team effort.

All the airworthiness standards, including CS-23, involve some quite complex elements on controllability and stability and, even for VFR flight, the LAA has sometimes insisted on changes to aircraft already approved elsewhere. For IFR flight where stability is more

Top

Above Not all types of LAA aircraft are suitable for consideration for the Night/IFR approval process.

Below If you’re thinking of applying, consider what your goals are. Do you just want to be able to safely make a cloud break, or do you want a full IFR approach capability?