A Common Language - An Ocean Apart

steve_ford_author

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Steve Ford
It was suggested by @midlifeflyer that I kick off a thread regarding the differences between GA flying in the UK/Europe and the USA.

Well....there are many and it is difficult to know where to start. So the best thing to ask, is if you have flown in the UK, what jumped out as being the big challenges and differences? Apart of course, warm beer and everyone talking weird ;)

To help the uninitiated... below is a link to the UK "Skyway Code" which I guess is our version of the "Airman's Information Manual".

Something to keep you busy over the festive period :rolleyes:

 
Last I was in Europe (2007 - 2010), gliders were much more accessible, affordable, and had more freedom to fly than single engine pistons.

Also, night VFr doesn’t really exist, either.
 
A few things that I have found, having flown extensively in both:

- IFR in the UK is much less usable/accessible for small GA like ours. However, IFR outside of controlled airspace, without talking to ATC, is permitted. No mid-air collisions have ever occurred from this.
- Airspace in the UK/EU is generally more congested and less "joined up" as each country has slightly different philosophies.
- Class A airspace can be found down at normal GA levels; just a few thousand feet.
- Airports in the UK/EU have restricted opening hours. Many don't allow night flying. On longer trips, especially international, timing airport opening hours can be a real challenge. Some airports I have flown into have entire days where they just don't open, and operating outside of their hours is not allowed.
- The need for PPR is very common, although usually pointless.
- Avgas availability in the south of the EU can be challenging.
- Handling fees in the south of the EU are quite common. It's a bit more "third world" in that regard (more corruption/kick-backs to get a monopoly on handling at airports, for example). Greece is a particularly bad example.
- Altimeter setting is different. Apart from using different units (standard pressure setting is 1013), the UK uses "QFE" at most airports. This setting gives a reading of "0" on the altimeter at field elevation. It only works because the UK has no high airports, and is a bit pointless. I don't like it.
- Transition level is generally very low, and changes daily. We're talking 4,000 - 6,000ft typically, instead of 18,000 as in the US. This can cause confusion with vertical separation from the aforementioned crowded airspace.
- ATC in the UK is generally less competent and capable. I have been asked to keep clear of airspace because they had a single 152 and one A320 in the zone. In the US, controllers fit light GA into the flow at places like JFK without breaking a sweat.
- Flying destinations in the UK and EU are generally more varied and interesting. In the US, everywhere is pretty much the same, apart from the scenery. Across the pond, the variety of cultures, history and so on mean that it feels like you're really flying to new places, not just bouncing around within the same old same old.

I'm sure I'll think of many more...
 
There are for sure many more differences.

One additional one is that pilot ratings expire, so that if you don’t use an IFR rating on a European license, eventually you don’t have it any more. This motivates some European pilots to get ‘stand alone’ FAA pilot certificates - a German friend just spent 10 days staying with us in the US to get this done, the process is simpler than it once was.

Flight training by independent instructors in individually owned planes is legally limited in scope, most training must be done by schools in their own aircraft. Sometimes a helpful school will put a clients plane on their program.

European VFR charts aren’t consistently updated or maintained by a central authority and vary between countries, so those in use are mostly compiled and sold in uniform electronic format by commercial companies.

Class A airspace has the effect of outlawing VFR in large expanses of airspace, generally around cities. This pushes GA down to very low altitudes (1000 ft is typical) for huge areas around some large airports. Northern Italy is renowned for this and an accident scenario there involves somebody taking off from a VFR-only outlying airport, flying around at low altitude in marginal VFR trying to pick up an IFR clearance, then hitting terrain before they do so.

Transponders are required to enter Class D airspace and generally Mode S is mandated. Explicit clearances are also required to enter any airspace Class D and up (as for US Class B), not just two-way radio communication. Despite this there are some areas with limited radar coverage meaning regular position reports and time-at-VRP predictions must be provided as you fly along VFR through a huge controlled airspace area, as requested by ATC. Again, in my experience this is common in Italy but not so much in some other places.

There is no government ADS-B infrastructure in Europe although some generally high end aircraft are individually equipped.

Flight over large cities in single engined aircraft is often illegal, being subject to a ‘glide clear’ requirement that is very strictly interpreted. You won’t fly a single engine plane over London or Paris like you might over New York or Los Angeles.

Some countries (e.g. Croatia, a popular GA destination) require continuous radio contact for all traffic, VFR or IFR. A few countries like Ireland require flight plans for every flight (although not so many today) and a flight plan is generally required to cross borders. Cross border VFR flight plans are passed to ATC as well as IFR plans, and it may be necessary to cross the border at a specific place.

Otherwise, VFR traffic that wants ATC service typically contacts a dedicated ‘information’ frequency, segregated from IFR ATC. This may introduce issues if wanting to cross complex airspace. ‘Pop up’ IFR is meanwhile considered a symptom of poor planning, sometimes a regulatory offense, not a tactical tool for safety enhancement.

Many airports are VFR only, and IFR procedures at non-tower airports don’t exist as I understand it. Perhaps there are some exceptions.

Airspace around airports has ICAO lettered classification (as used by FAA) overlaid on top of obscure additional classifications like ATZ, CTR and CTA. There is no one-to-one correspondence as in e.g. FAA Class D airspace invariably meaning a small airport’s control zone, in Europe it’s more complex. Conversely, small UK airports which require contact with a radio operator having ambiguous duties are located in Class G uncontrolled airspace. Go figure.

In many countries off airport landings on private land are illegal, even with landowner permission. Also, landing at an unattended airport may in some places be illegal - Germany being the classic example. Private airports are often required to keep a log of all movements, subject to audit.

Complex aircraft maintenance regulation means that you generally need multiple mechanics and organizations to maintain a simple certified plane. $5000 annuals for a C150 aren’t at all unusual, even when the plane has no issues. The mix of national and EASA regulations is complex enough that many or most owners don’t understand what rules apply to them. People budget huge sums for maintenance of simple certified planes, led into it by Maintenance Organizations who are happy to take their money. Parts installed on any certified aircraft generally require an EASA Form 1 (like an FAA 8130-3) which makes used, airworthy parts legally unusable. People install them anyway ‘off the books’.

A European certified aircraft type must by regulation have a ‘design support organization’. Governments don’t maintain the engineering capability to manage ADs etc that the FAA does. If that commercial organization ceases to exist, the formerly certified plane is typically downgraded to an annual permit to fly that prevents any commercial use, but may allow more owner maintenance. The owner has no choice but to go along with this, like it or not, and international operation may also be affected.

Experimental category for homebuilt aircraft does not exist in many places, and their regulation is delegated by national governments to commercial ‘associations’ that approve both homebuilt aircraft type configurations and individual aircraft for operation in that country. Changes from an approved configuration mean an application and approval process. Anything they do has associated fees. You can also expect fees from national CAAs for almost everything they do, and slow service.

The process and legality of flying homebuilts between countries is complex and variable. Like US to Mexico or Canada the requirements depend on individual national policies and treaties, but the countries are small so these rules are commonly ignored in Europe. Doing so puts the pilot at significant risk in case of a mishap. Also IFR approval for homebuilts is rare, so homebuilt operations are legally limited to VMC. This is also ignored by some.

GA in many European countries (e.g. Italy, Spain and France) is becoming dominated by weight limited ULs flown with sub-ICAO pilot qualifications. These have similar issues with IFR and cross border travel to that of homebuilts, and may also have restricted access to controlled airspace, depending on country. Some of the rules are unusual, like altitude ceilings in Italy that vary by the day of the week, effective across the whole country. The benefit is less regulatory burden for owner and pilot, allowing a greater number of average income people to fly in Europe as US pilots might expect, but at the price of restrictions keeping them at (mostly grass) airfields away from cities and larger airports. That also keeps them out of the way of commercial aircraft, versus supporting international flights or integrating ‘little guy’ GA operations into the national airspace structure like FAA.

Avgas in Europe is $10-12/gallon… unless you’re in Serbia where for some reason Avgas is about the same price as in the US. The Channel Islands between England and France also offer something similar, due to their particular tax structure. And some people can use Mogas (automotive gasoline) at perhaps $7-8/gallon.
 
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Man, I love USA and Canada for the freedom of flight and cheaper flying. So much unnecessary bureaucracy in Europe.

To add to the previous post, when we flew in Greece, we not only had to be in contact with ATC while VFR, we had to request every single change in altitude and heading, and receive permission before we could make the change. And we had to be super nice and patient with the controllers, as they can easily deny a request just if they are miffed at you.
 
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