Can I fly my LSA IFR?

I’ve seen discussions about flying IFR or in IMC in Light-Sport airplanes on various forums over the years.  There’s a lot of misinformation and confusion about what is legal and what is safe and what is right (all of which can be different courses of action depending upon the circumstances).  Well, grab a carbonated beverage and let’s talk about it.

When can you fly “IFR” in the US?  Well, by “IFR,” I guess you mean participating in the Instrument Flight Rules environment; filing an IFR flight plan, using radar and navigational aid guidance along a cleared route with Air Traffic Control direction.  Normally, any airplane minimally equipped in accordance with the 14 CFR 91.205 can participate in the National Airspace System under IFR.  Notice, I didn’t say anything about flying through clouds.

Are there times when you might want to fly IFR but not in IMC?  Sure.  A few jump to mind.  Using Air Traffic Control services reduces risk of inflight collision, even more so than just “VFR Flight Following” since Flight Following can be terminated due to controller workload, but not IFR services.  It’s also nice to have a “wingman” on the ground who can help you out if you need it.  If you live near the DC Metro area, an IFR Flight Plan gets you through the DC Air Defense Identification Zone without all the non-standard VFR coordination requirements.  So yeah, there are lots of times I might want to fly IFR even if not through clouds.

When can I fly in IMC (Instrument Meteorological Conditions)?  Well, that’s a tougher question.  Aircraft that have “Standard” Airworthiness Certificates are issued Type Certificates (TC’s) that either include or exclude operations under IFR.  If IFR operations are included in the TC, then aircraft so manufactured, equipped, maintained and operated in accordance with their TC and 14 CFR Part 91.205 are authorized to fly in IMC under IFR rules.  But how about Light-Sport airplanes?

Well, airplanes (like LSA and Experimental) that have been issued a “Special” Airworthiness Certificate are each given “Operating Limitations” by the FAA at certification.  These Operating Limitations must physically accompany that pink Airworthiness Certificate in the airplane, so if you haven’t checked them out, do so.  They will tell you if flights under IFR or in IMC are permitted or not.  The governing FAA Order which establishes which Operating Limitations would be issued “today” changes from time to time, so you’re specific Operating Limitations may be worded differently than another’s Operating Limitations issued only months earlier or later. 

For us here at American Made Aviation, the Van’s RV-12 S-LSA we operate has an Operating Limitation that says, “This aircraft is to be operated under VFR, day only, unless appropriately equipped for night and/or instrument flight in accordance with 14 CFR Part 91.205, and when allowed by the manufacturer’s operating limitations.”  Turns out that Van’s Aircraft prohibits “flight in IFR/IMC conditions” in the RV-12 S-LSA Aircraft Operating Instructions (AOI’s).  So RV-12 S-LSA operators, like American Made Aviation, cannot fly this aircraft in the clouds.  The AOI placard is a little ambiguous, though.  Is it “IFR or IMC” prohibited or “IFR and IMC” prohibited?  Van’s Aircraft’s website (https://www.flyrv12.com/slsa-ifr-operation-and-training/) makes it clear that if minimally equipped and maintained in accordance with 14 CFR Part 91.205, participating in IFR is fine but not in IMC.

The bottom line is, for airplanes issued Special Airworthiness Certificates, read your Operating Limitations to determine the conditions under which you might operate under IFR or in IMC.  As a Rule of Thumb (with many exceptions), if equipped and maintained in accordance with 14 CFR Part 91.205, S-LSA’s won’t be able to operate in IMC and Experimentals (E-LSA and EAB) by and large will.

We haven’t talked about whether it’s a good idea to fly your Experimental in IMC.  That’s a bit beyond the scope today.  But please consider what kind of weather conditions are appropriate for your homebuilt and which ones are just not smart to challenge…  And on the flip side, there may be times you have to fly your S-LSA in IMC, mostly because you find yourself in a spot and declaring an emergency and flying SAFELY through clouds is the right thing to do to preserve life. 

If you’ve got some feedback for me, don’t hesitate write me at fly@americanmadeaviation.com.