TC Rule change idea to enhance Safety.

[Rookie50]

I have a passion for safety, especially GA safety, my context.

It seems to me an obvious fact, night operations raise risks dramatically even VFR, especially IFR.

Therefore I believe a simple TC rule change would cut accidents down, I place it here for discussion.

Very simple. Any pilot wishing to file IFR, where any part of the flight is conduring the hours of legal darkness as defined by the CARS, must hold a Night IFR rating. This would be a simple experience sign off, much like VFR OTT.

NIGHT IFR rating Would be issued by proving the following flight experience:

50 hours Actual IMC experience, whether PIC, under instruction, or SIC. No simulators, no hoods. Actual.
25 hours night experience, same as above. At least.

I think that's reasonable, will allow pilots in commercial ops to fly -- SIC -- and restrain new IFR GA guys like me, and (shiver) instruction by low timers in such conditions.

Thoughts?

FWIW as a baseline, I have @ 900 TT, about 80 odd hours actual IMC. I never have, and not sure I ever will, mix night and IMC, certainly low ceiling IMC. Just too risky for me, flying SP and don't fly enough.

[valleyboy]

I guess it boils down to what night flying actually is. "Night IFR", when I first saw that it figured it was a typo. When flying IFR at night when does night rating take over from an IFR rating. Night VFR can be the killer night IFR not so much. If you are stressed out by flying in actual IMC does it matter if it is dark or bright the end results might be the same. Conduct an IFR approach in the present day the runway is straight ahead and you are on profile. Night flying IFR doing circling approached was another time and yes I considered that "high risk" some places I went 20kts downwind was far better than circling. As far as rule changes, we have so many rules now, you have the right idea. Not comfortable, don't go. Decision making is the trick and rules will never improve on that.

[Meatservo]

I consider it to be utterly unnecessary. Safety would be better served by simply requiring an instrument rating and instrument currency for anyone who wishes to operate at night, period. Private pilots will perhaps find this unfair, but since we're talking about imaginary new rules that could make things safer- that would be one of them. Most of Canada is pitch black at night and unless you've got a good moon, you're going to be on instruments most of the time.

As for actual IFR flying at night, it's easier. With weather at minimums, you're going to have an easier time making out the threshold and runway edges because they're lit up. In fact at some airports with low minimums and very bright lights, I'm not even sure I'm even out of the clouds or not, because the lights burn through whatever low vis there is and I can see the runway just fine without being aware of having emerged from the clouds at all. Sometimes I am sure I would have missed in the daytime in the same conditions.

Frankly, if you can't conduct an IFR flight at night, you have no business conducting one in the daytime, either. The whole idea is that you should be able to do the whole thing without being able to see out the window at all, from just after takeoff until just before landing. Whatever colour the nothingness outside the window is, should be immaterial.

[Rockie]

Ditto.

Aside from the fatigue factor IFR at night is actually easier in some respects (min viz as mentioned) or no different than day IFR. Night VFR is a different story and than includes circling.

[photofly]

Most single engine GA planes like the one the OP flies have so-so cockpit and instrument lighting so it is harder to make out what you're doing at night.

Having yet more rules, restrictions and ratings isn't going to do squat for safety. That having been said, how about a FI-I rating?

[JasonE]

Most single engine GA planes like the one the OP flies have so-so cockpit and instrument lighting so it is harder to make out what you're doing at night.

Having said that, having yet more rules, restrictions and ratings isn't going to do squat for safety.

I agree here & highly recommend having enough daytime hours to be completely familiar with the plane you are going to fly at night. I flew a different model 172 once at night (which I had very little time in) and struggled to find everything in the dark as quickly as I would have liked, but was perfectly legal.

[Rockie]

I flew a different model 172 once at night, which I had very little time in and struggled to find everything in the dark when I needed.

A flashlight with a red filter works pretty well, but a familiarity with any aircraft you fly (day or night - IFR or VFR) is a good idea.

[JasonE]

I flew a different model 172 once at night, which I had very little time in and struggled to find everything in the dark when I needed.

A flashlight with a red filter works pretty well, but a familiarity with any aircraft you fly (day or night - IFR or VFR) is a good idea.

I now wear a red headlamp at night, which works well when I need it (especially in my own plane which also has all red lighting.)

[Rookie50]

Ditto.

Aside from the fatigue factor IFR at night is actually easier in some respects (min viz as mentioned) or no different than day IFR. Night VFR is a different story and than includes circling.

I think Fatigue is a huge and under reported factor for night accidents. I especially think night circling approaches are ugly. I've done a day circling approach to minimums, that was sporty enough, after a 3 hour flight, most of it busy, and in bumpy IMC. I think physical capacity is a factor, and reserves of focus and concentration, simply run out in some situations.

[Rookie50]

I consider it to be utterly unnecessary. Safety would be better served by simply requiring an instrument rating and instrument currency for anyone who wishes to operate at night, period. Private pilots will perhaps find this unfair, but since we're talking about imaginary new rules that could make things safer- that would be one of them. Most of Canada is pitch black at night and unless you've got a good moon, you're going to be on instruments most of the time.

As for actual IFR flying at night, it's easier. With weather at minimums, you're going to have an easier time making out the threshold and runway edges because they're lit up. In fact at some airports with low minimums and very bright lights, I'm not even sure I'm even out of the clouds or not, because the lights burn through whatever low vis there is and I can see the runway just fine without being aware of having emerged from the clouds at all. Sometimes I am sure I would have missed in the daytime in the same conditions.

Frankly, if you can't conduct an IFR flight at night, you have no business conducting one in the daytime, either. The whole idea is that you should be able to do the whole thing without being able to see out the window at all, from just after takeoff until just before landing. Whatever colour the nothingness outside the window is, should be immaterial.

The vast difference in accident stats strongly suggest night operations add substantial risk. In theory it should be the same, I believe fatigue and illusions lead to a greater accident risk. Even night VFR takeoffs seem to have a stronger illusion, than day IMC takeoffs, in my admittedly brief experience. I think the transition is harder for the body to adapt to instruments at night.

[photofly]

Can you post some links to real accident statistics to support your hypothesis? Not anecdotes or one off accident reports, but aggregated statistics from across Canada or the USA?

[pelmet]

I think Fatigue is a huge and under reported factor for night accidents. I especially think night circling approaches are ugly. I've done a day circling approach to minimums, that was sporty enough.

Personally, I think competence is the under-reported factor. The lack of it is never listed as a cause but it is a factor. Low-time and occasional flyers go into conditions well beyond their capability. One of the reasons I started flying commercially was because of an approach I did many years back that was concerning in its performance.

[Rookie50]

I think Fatigue is a huge and under reported factor for night accidents. I especially think night circling approaches are ugly. I've done a day circling approach to minimums, that was sporty enough.

Personally, I think competence is the under-reported factor. The lack of it is never listed as a cause but it is a factor. Low-time and occasional flyers go into conditions well beyond their capability. One of the reasons I started flying commercially was because of an approach I did many years back that was concerning in its performance.

Pelmet, that's certainly true. But I might be able to handle a 3 hour day bumpy IMC flight, approach to minimums, just fine. A 3 hour night convective flight, after perhaps a busy day, ending with a missed approach, Ect etc? At some point I know fatigue would come into the picture for me. I've felt it.

Many factors.

[Big Pistons Forever]

Can you post some links to real accident statistics to support your hypothesis? Not anecdotes or one off accident reports, but aggregated statistics from across Canada or the USA?

The Nall report has a pretty good breakdown of accident stats. The latest is here


https://www.aopa.org/-/media/files/aopa ... report.pdf

Of note non commercial night IMC accidents are actual pretty uncommon, however the night VFR ones are where the issue is especially considering that only approximately 3 % of annual non commercial flying hours are at night

[Roar]

Frankly, if you can't conduct an IFR flight at night, you have no business conducting one in the daytime, either. The whole idea is that you should be able to do the whole thing without being able to see out the window at all, from just after takeoff until just before landing. Whatever colour the nothingness outside the window is, should be immaterial.

^ truest statement on this thread!

As for circling approaches having a greater risk that is true but not because it may happen to be night. The danger in circling approaches stems from old TERPS circling approach certification criteria. The manuvering area on old TERPS was determined by an aircrafts turning radius at a certain range of TAS (cat. A,B,C,D) problem is that this doesn't take into account pressure altitude or winds, which either individually or combined can make turning within the manuvering area impossible. Also the manuvering area radii are in NM while visibility limits are in SM, which mean you could potentially be inside the manuvering area yet lose visual contact with the airport environment, while not a huge deal as you would just conduct a missed approach at that point, but it's something to be aware of if conducting a circling approach near visibility limits.

[Black_Tusk]

If one has a night rating and valid IFR rating they are more than capable to fly IFR at night.

[goingnowherefast]

There are some countries where there is no such thing as night VFR. Can only fly VFR during the day. Any and all flying at night is IFR.

I sure wouldn't object if that rule was brought to Canada.

[Zaibatsu]

There are some countries where there is no such thing as night VFR. Can only fly VFR during the day. Any and all flying at night is IFR.

I sure wouldn't object if that rule was brought to Canada.

I was just going to say that. Night VFR is peculiar to North America. In most of the world there is no such thing.

[photofly]

In the U.K., it used to be that while all flight at night had to be under the IFR, there was a blanket exemption from the requirement to hold an instrument rating to fly IFR during the hours of darkness outside of controlled airspace - anyone could do it - as long as you remained in VMC. What a peculiarly British way to do things.

Now of course, under EASA, everyone has to comply with the Standard European Rules of the Air so that rule had to go. The rules are now so complicated nobody knows what they say. Which is a peculiarly European way to do things.

[RatherBeFlying]

Night flying, whether IFR or VFR, has to be taken seriously. Lately we've had a few sad examples of disorientation in black hole takeoffs.

Keep the wings level, maintain terrain and obstacle clearance, have enough gas, avoid circling and second approaches - and you have eliminated most of the hazards in night flying.

Unfortunately some folks get carried away by gadgetry and lose track of the basics.