IFR in CT? Confusing info at FD FAQ?

[Acensor]

I'm completely out of my turf regarding IFR and have no intention of ever flying anything but day VFR, But my potential co-owner of is instrument rated and the question of if he'd ever be able to fly it IFR came up.

 

The seller, who is an airline pilot*, said in reply to my inquiry on if it had enough avionics for IFR ...

> The CT is well loaded as far as the LSA category goes, meaning you have

> way more than you need for daytime VFR. But the only navigation receiver

> is the GPS. And is doesn’t matter what you put in it, LSAs are not IFR

> certified. It does have a way fancier glass panel than anything I’ve

> ever operated before, including at the airlines. But there is no ice

> protection, and I really don’t think it’s stable enough to fly through

> the clouds for any length of time, even if you were inclined to.

 

But for what it may be worth I pass on this item from the FAA rules expert for LSA at the EAA which spears to contradict that "no IFR in LSA" idea:

 

"Question :

Do the ASTM standards require that SLSAs used for IFR flight meet the requirements for IFR specified in FAR 23, e.g, FAR 23.1323 para. d? In fact, is it even legal to fly IFR in an aircraft which doesn't meet the IFR requirements in FAR 23?

Answer :

FAR Part 23 does not apply to light-sport aircraft in any way. For Special Light-Sport Aircraft (SLSA) the FAA operating limitations allow the aircraft to be operated under IFR if the aircraft is equipped in accordance with FAR 91.205. However, in order to legally operate the SLSA under IFR the aircraft and engine manufacturer must also document that they allow the aircraft to be operated under IFR as well. If either the airframe or engine manufacturer prohibit the aircraft from operating under IFR it cannot be operates as such even if the FAA allows it via the operating limitations."

 

So sounds like IFR in an SLSA isn't necessarily out if the question if it has the right instruments and Flight Design would support it.

And here's what Flight Design says in their FAQ:

"29. Depending on local regulations and installed equipment it is possible to operate a CT under IFR in non IMC conditions."

Which is kind of weird and confusing to me as to my limited understanding the time it's most critical to fly IFR is in IMC. "Non IMC" would mean VMC-VFR conditions, right? What's the point of flying IFR in VFR conditions?

Could that be an error on the FD site, that the meant "non VMC"? I sent FD a note, but no reply yet.

 

Alex

* The fact that a commercial pilot not limited to LSAs and had ~$120K to shop in 2006 chose a CTSW IMO speaks well for CT.

[Anticept]

As per 91.327 Aircraft having a special airworthiness certificate in the light-sport category: Operating limitations.

 

(d) Each person operating an aircraft issued a special airworthiness certificate in the light-sport category must operate the aircraft in accordance with the aircraft's operating instructions, including any provisions for necessary operating equipment specified in the aircraft's equipment list.

 

 

With that said, if we review the AOI for the CTLS, we see on page 2-4, the following:

 

 

2.6. Other limitations

 

Warning: The aircraft is not certified for aerobatics!

 

The aircraft may only be operated during the day or night in visual flight conditions.

 

Flight into instrument meteorological conditions (IMC) is prohibited.

 

Flight into icing conditions is prohibited.

 

Turns steeper than 60 degrees of bank are prohibited.

 

Flight operations are not recommended during strong, gusty winds or wind speeds on the ground of more than 46 km/h (24kts-30 mph).

 

 

With that said, we need to make sure we understand thoroughly, two things:

 

First, the terms "IFR" and "IMC" are not interchangeable. When we say "IFR", what we usually mean to say is "IMC". "IFR" can be flown while in VMC conditions. The FD CTs are only forbidden from flying into IMC, but you can fly them IFR (useful for training under the hood).

 

If a light sport manufacturer does not forbid IMC, then the aircraft can be flown IMC. Although, Rotax doesn't want you flying into IMC unless you are using their certified 912 model, but it's the airframe manufacturer that has the final say in the matter, as light sport aircraft are certified as a whole unit.

[Acensor]

Thanks AntiCept and MovingOn.

 

 

"2.6. Other limitations

 

.......The aircraft may only be operated during the day or night in visual flight conditions.

 

Flight into instrument meteorological conditions (IMC) is prohibited.

 

Flight into icing conditions is prohibited.".

 

That pretty much closes that off. AND your comment explains why FD give qualified blessings to IFR and then throws in "in non-IMC condition". (To quibble..."IMC conditions" is redundant... as "IMC" alone means "instrument meteorological conditions", so that's line saying "The Los Angeles Angels" which them means "the the angels angles." .)

 

 

Of course no one should or would want to fly into icing conditions in any plane at any time.... especially as with the CT and many other aircraft having no deicing features.

 

 

Wonder if reclassifying as experimental takes one off the FD POH leash? With my current experimental I got to, in fact had to, write my own POH.)

 

 

Alex

(This message posted with 100% recycled electrons)

[Tom Baker]

In 2010 the ASTM committee voted to prohibit flight in IMC, and the FAA stands by the ASTM on this. Prior to that time if you had the required equipment in 91.205 and your operating limitations that go with the airworthiness certificate allowed it you could fly IMC. There are a few CT's out there that can be flown in IMC legally. I don't know if you could get a pre 2010 airplane approved now or not. All of the CT's if they have the required equipment can be certified IFR and work in the airspace system.

[Acensor]

The OP was asking about an instrument rated pilot, not a Sport Pilot. His question is about the aircraft certification and limitations.

Yup.... Confirming what Tom wrote: Was asking about aircraft certification and limitations and regs. My potential co-owner is fully instrument rated and experienced at IFR. Issue is "could he ever fly the CT IFR" and as has now become clear also the related issues are is it, or can it be equipped to be fully IFR capable and could he ever fly it in IMC.

 

Alex

[sandpiper]

I have been instrument rated since about 1969 ( fixed and rotary wing) and a CFII since 2003. Perhaps the most demanding aircraft I experienced IMC was the Huey which had no AP or SAS. Especially with partial panel. However, it was a two pilot operation.

 

Most of my IFR (IMC) experience was what I would call infrequent and "light duty" so I am certainly not the voice of authority here.

 

However, even if my CTSW were properly equipped I would not consider it a decent, stable, IFR platform. And, even though I have never considered an auto pilot essential equipment for any aircraft (except for the Huey but it had two pilots) I have flown into IMC, my opinion is that the CTSW would be a bitch without one except for very short periods.

 

Just my two cents worth. Your mileage may vary.

 

 

[Anticept]

In 2010 the ASTM committee voted to prohibit flight in IMC, and the FAA stands by the ASTM on this. Prior to that time if you had the required equipment in 91.205 and your operating limitations that go with the airworthiness certificate allowed it you could fly IMC. There are a few CT's out there that can be flown in IMC legally. I don't know if you could get a pre 2010 airplane approved now or not. All of the CT's if they have the required equipment can be certified IFR and work in the airspace system.

 

This is due to the fact they have not developed IMC standards in the ATSM, so prohibiting IMC is a stopgap measure. This is expected to change in the near future.

 

This ATSM limit only applies to an aircraft which was built to the standard post 2010. If your aircraft is built to another accepted standard that does not prohibit IMC, or your aircraft was built and approved for IMC before the vote in 2010, it can be flown IMC.

[S4Flier]

And I guess the answer, it could be equipped and he could file and fly IFR in VFR weather conditions. He could not fly in actual IMC unless the plane was one of those previously certified for that.

 

IMHO, when you move on to LSA, it time to forget about IFR and IMC and enjoy the LSA for what it is.

There are two avenues to legally fly an LSA in IMC. The manufacturer may amend the operating limitation for a specific aircraft built before the ASTM prohibition or one could take the S-LSA experimental. As an E-LSA, one may then amend the operating limitations. You would need to equip as per 91.205 in both cases. Search this forum and sportpilot talk for several threads on the topic.

 

[Tom Baker]

This is due to the fact they have not developed IMC standards in the ATSM, so prohibiting IMC is a stopgap measure. This is expected to change in the near future.

 

This ATSM limit only applies to an aircraft which was built to the standard post 2010. If your aircraft is built to another accepted standard that does not prohibit IMC, or your aircraft was built and approved for IMC before the vote in 2010, it can be flown IMC.

 

They have been saying it is expected to change in the near future since 2010. There have been people quit the IFR committee because of all the problems getting a standard established.

[Anticept]

 

 

They have been saying it is expected to change in the near future since 2010. There have been people quit the IFR committee because of all the problems getting a standard established.

 

We are, of course, speaking in aviation terms. "Soon" is around 20-25 years

[Runtoeat]

My friend bought a Piper Colt and got carried away attempting to make it certified for IFR. Since he is a retired commercial pilot with full IFR rating and is also a CFII, he figured he'd use it to train IFR students. Believe he needed to have certified avionics which he spent a lot to do. This requirement rules out most CT owners who have not upgraded radio and GPS. Our Garmin transponders are certified. Our 912uls engines are not certified. His last stumbling block was the requirement that he had to have a heated pitot. This finally put him over the edge for cost and he gave up trying to get his Colt certified. This doesn't mean those CT's with glass can't be used to practice or train for IFR certification. They make great trainers for those wanting to get their instrument rating.

[Tom Baker]

My friend bought a Piper Colt and got carried away attempting to make it certified for IFR. Since he is a retired commercial pilot with full IFR rating and is also a CFII, he figured he'd use it to train IFR students. Believe he needed to have certified avionics which he spent a lot to do. This requirement rules out most CT owners who have not upgraded radio and GPS. Our Garmin transponders are certified. Our 912uls engines are not certified. His last stumbling block was the requirement that he had to have a heated pitot. This finally put him over the edge for cost and he gave up trying to get his Colt certified. This doesn't mean those CT's with glass can't be used to practice or train for IFR certification. They make great trainers for those wanting to get their instrument rating.

 

The heated pitot and certified equipment is a requirement of part 23, and does not apply to an aircraft with an airworthiness certificate issued in the light sport category. The only required equipment is listed in 91.205. Sometimes the ASTM standards have requirements that go beyond those listed in 91.205.

[Acensor]

........ But you can install a a Garmin GNC 255 which has VOR/ILS capability.......

 

 

........The rub comes due to Rotax which prohibits IFR for the 912 engines......

 

 

 

As best I could see FD offered several different pretty robust packages/options for avionics........

 

 

Did none of them include instruments that (ignoring FD's "don't fly IMC" for the moment) come with enough goodies to fly IFR?

(Please remember I'm not IFR rated so don't know what the minimum instruments for IFR are. I would have guessed in addition to all VFR required instruments the list could include a transponder, and EITHER a gyrocompass or a TSO GPS navigation system.)

Are the factory installed GPS's FD installs consider FAA appoved navigation instruments?

(My aftermarket iFly GPS when it boots up says in different words "The FAA doesn't recognize this device as a primary navigational device.").

 

=============================

........"The rub comes due to Rotax which prohibits IFR for the 912 engines." .

 

Hmmm. If I remember right (and I might not) Rotax does not approve IMC for the 912ul and 912uls but has no such prohibition on the 912S?

 

For that matter, if we took seriously everything Rotax says about the 912ul and 912uls we would seriously limited in where we can fly.

Rotax says........

"Never fly the aircraft equipped with this engine at locations, airspeeds, altitudes, or other circumstances from which a successful no-power landing cannot be made, after sudden engine stoppage"

 

I'd be willing to bet that most every pilot here has more than once willingly and knowingly made a judgment call and flown in locations, airspeeds, altitudes, or other circumstances where there was no certainty that a successful nopower landing could be made. And in doing so they were doing nothing more dangerous than the inherent risks associated with being high above the ground dependent on an internal combustion engine to keep them there.

 

I know my CFI when I was training admitted when I pressed him that that constraint, as well as the similarly worded FAA general regulation about minimum altitude, was an at least unrealistic, if not impossible, constraint to fly under.

 

Pardon my digression and ramble off the original specific topic. Regulations that you can't really take seriously are a pet peeve of mine. They can actually be endangering us by the boy-who-cried-wolf effect. That is there are plenty of regs that are safety relevant that at least some off us might take less seriously than we should when the source of the regs or recommendation has compromised its credibility with some obviously unreasonable or meaningless CYA regs.

 

Alex

[Anticept]

>> Did none of them include instruments that (ignoring FD's "don't fly IMC" for the moment) come with enough goodies to fly IFR?

 

Mine has everything to fly IMC per part 91.205 as an experimental, but I never will, because of lightning and static issues, and I have no idea how well it can take ice.

 

>>Are the factory installed GPS's FD installs consider FAA appoved navigation instruments?

 

430's are, but none of the x96 series.

 

The x96 series GPSs cannot be used for primary navigation, as it is not certified and therefore is not allowed to be used for approaches. (note, approaches in VMC are not considered using the GPS as primary navigation, so practice approaches using it is fine).

 

>> Hmmm. If I remember right (and I might not) Rotax does not approve IMC for the 912ul and 912uls but has no such prohibition on the 912S?

 

 

It's the airframe manufacturer that has the final say, because light sports are certified as entire units. FD has deferred instructions to Rotax, however.

 

Anyways, the 912S can be flown instrument (the part 33 certified engine version) per Rotax.

[Tom Baker]

There is a CTLS in Iowa that they train in and fly IFR.

[chanik]

As someone who has carefully gone over this and posted about it previously http://ctflier.com/index.php?/topic/163-s-lsa-to-e-lsa/page__hl__chanik#entry6236 and elsewhere, I would say this thread is pretty much accurate. It seems the biggest confusion is that companies Garmin or Rotax can prohibit their products from being used, say for IMC flight. They can say so of course all they want. But those assertions have no force of law. So the x96 GPS counts under 91.205 (d)2. ROTAX prohibitions are irrelevant and they have been explicitly shot down trying to constrain maintenance qualifications, for instance It is only because the FARs explicitly give teeth to specifically the AOI that FD can prohibit IMC with their product. The standard OpLims you will get if you convert to E-LSA won't have the IMC prohibition which is one reason I went that way.

[WmInce]

As someone who has carefully gone over this and posted about it previously http://ctflier.com/i...hanik#entry6236 and elsewhere, I would say this thread is pretty much accurate. It seems the biggest confusion is that companies Garmin or Rotax can prohibit their products from being used, say for IMC flight. They can say so of course all they want. But those assertions have no force of law. So the x96 GPS counts under 91.205 (d)2. ROTAX prohibitions are irrelevant and they have been explicitly shot down trying to constrain maintenance qualifications, for instance It is only because the FARs explicitly give teeth to specifically the AOI that FD can prohibit IMC with their product. The standard OpLims you will get if you convert to E-LSA won't have the IMC prohibition which is one reason I went that way.

 

Just out of curiosity, did you upgrade your panel with Dynon SkyView?

[FlyingMonkey]

ROTAX prohibitions are irrelevant and they have been explicitly shot down trying to constrain maintenance qualifications, for instance

 

It might be a safety issue, I heard if a Rotax 912 flies into a cloud it turns into a pumpkin. Then explodes.

[S4Flier]

And the carbon fiber of our planes melt

[Acensor]

 

 

It might be a safety issue, I heard if a Rotax 912 flies into a cloud it turns into a pumpkin. Then explodes.

 

What a relief to hear it's not just Rotax's lawyers playing CYA... That it's a documented engineering flight consideration.

Restores my ability to trust every detail of Rotax recommendations. ;-)

 

Alex

[S4Flier]

Video from extensive Rotax IFR testing proving what happens in clouds:

[Anticept]

As someone who has carefully gone over this and posted about it previously http://ctflier.com/i...hanik#entry6236 and elsewhere, I would say this thread is pretty much accurate. It seems the biggest confusion is that companies Garmin or Rotax can prohibit their products from being used, say for IMC flight. They can say so of course all they want. But those assertions have no force of law. So the x96 GPS counts under 91.205 (d)2. ROTAX prohibitions are irrelevant and they have been explicitly shot down trying to constrain maintenance qualifications, for instance It is only because the FARs explicitly give teeth to specifically the AOI that FD can prohibit IMC with their product. The standard OpLims you will get if you convert to E-LSA won't have the IMC prohibition which is one reason I went that way.

 

Yeah E-LSA doesn't follow the same set of rules, but I recall reading something at one point that the FAA doesn't consider portable devices to be "suitable for the route being flown", and do not even consider them to be TSO equivalent, making this a real problem for S-LSA and standard category aircraft. I do not know if it was any sort of regulatory document though.

[chanik]

I did not upgrade to Dynon Skyview. I would challenge anyone to find an FAR that adds restrictions to the equipment requirements clearly spelled out in 91.205:

(d) Instrument flight rules. For IFR flight, the following instruments and equipment are required:

(2) Two-way radio communication and navigation equipment suitable for the route to be flown.

 

 

Like I have said before, you can only be violated referencing the federal regs. I say the garmin 496 is suitable. And technically so does FD which approves their planes for IFR (just not IMC) The FAA makes no distinction in the FARs between IFR in VFR conditions and IFR in IMC.

 

• 
   
  

[Acensor]

 

 

Yeah E-LSA doesn't follow the same set of rules, but I recall reading something at one point that the FAA doesn't consider portable devices to be "suitable for the route being flown", and do not even consider them to be TSO equivalent, making this a real problem for S-LSA and standard category aircraft. I do not know if it was any sort of regulatory document though.

 

Thought I asked THIS earlier: Aren't the factory installed CT GPS units not "portable".. And are any of THOSE TSO'd?

 

Alex

BTW:

The iFly 720 portable GPS in my current cockpit when turned on has a disclaimer that includes words something like "it is not permissible to be used as a primary navigational instrument.... Only for situational awareness.....", etc., and you have to click on "have read, understand, agree" .

Yeah, we understand why they do that. But virtually every pilot with this or similar GPS as the only GPS in the plane is lying if they say it's not their primary navigational tool on everything other than local flights.

By the way; IMO at it's price point (about $700) and sometimes higher, the iFly is very high in usability , functions , and manufacturer support.

[Anticept]

Thought I asked THIS earlier: Aren't the factory installed CT GPS units not "portable".. And are any of THOSE TSO'd?

 

Alex

BTW:

The iFly 720 portable GPS in my current cockpit when turned on has a disclaimer that includes words something like "it is not permissible to be used as a primary navigational instrument.... Only for situational awareness.....", etc., and you have to click on "have read, understand, agree" .

Yeah, we understand why they do that. But virtually every pilot with this or similar GPS as the only GPS in the plane is lying if they say it's not their primary navigational tool on everything other than local flights.

By the way; IMO at it's price point (about $700) and sometimes higher, the iFly is very high in usability , functions , and manufacturer support.

 

They would install 430's in some models, and those are TSO. x96 ones are not (396, 496, 596, 696).