Training from Unlicensed Airfields ?

[belowradar]

Lot's of talk and speculation but wondering if anybody has any concrete facts. I got lost in the maze of EASA npr and CAA are unable to advise.

So when can we start training from unlicensed airfields? does anybody know a date ?

Or am I being too simplistic for EASA / CAA

Anything definite much appreciated

[BEagle]

The CAA consultation date for the proposal to amend Article 126 of the UK ANO to permit flight training in Aeroplanes and Helicopters from unlicensed aerodromes closed on 10 July 2008.

An outcome is still awaited!

See: Consultation - LAASG FTSG Proposals | Consultations | CAA (http://www.caa.co.uk/default.aspx?catid=1710&pagetype=90)

[Mickey Kaye]

Please hurry up

[belowradar]

Thanks Beagle for clarifying

Looks like a great deal of time is being wasted on this proposal

[BEagle]

Any delay is undoubtedly due to the need to establish the impact of EASA part-FCL NPA17 and part-OPS NPA02.

The CAA were very supportive of the LAASG study; however, it would be nugatory effort to embark on the necessary legislative changes to the ANO only to have some €urocrat overrule them in a couple of years time.

[Whopity]

Flight training from unlicensed aerodromes was offered to industry on a plate in 1995. Out of 2500 letters of consultation sent out, only 125 individuals replied, of those around 70 turned down the offer!

The LAASG working group completed their recommendations over 3 years ago; some industry members of that group expressed their concern that the necessary safety processes would probably cost as much if not more than the current licensing system.

The group were also aware that any recommendations they might make would probably be replaced by EASA regulation within a few years. As EASA do not have a licensing system for aerodromes, it is probable that there will be no change until EASA comes of age, on the grounds that there is little point introducing a legal change that may scrapped as soon as it is incorporated.

Realistically, if it happens March 2012 is a likely date.

[belowradar]

OK I will stop checking EASA and CAA websites and file this away for a few years.

[julian_storey]

I'm generally of the view that aviation in Europe is horribly over regulated, but it seems to me sensible that flight training (which by its nature carries more risk than normal GA flying) is best carried out at a licensed airfield which has proper crash / fire cover?

[Whopity]

Interestingly one of the facts presented to the LAASG committee was that there was no evidence to show that proper crash / fire cover had ever saved a life in the ab-initio training environment. Ironically at the time the committee were in session, there was an accident involving a motor glider where fire destroyed the aircraft following a take off incident. Motor gliders operated under the BGA do not need a licensed aerodrome for training, due to the reduced risk as they carry a limited amount of fuel.

[belowradar]

At the moment we have an unlevel playing field whereby trial lessons can be flown from an unlicensed airfield in a microlight but not in a C152 or similar training aircraft.

Also many existing training providers operating from licensed airfields have in effect a monopoly on flight training. These operators will face competition when the rules are changed and so they quite understandably resist any changes.

[BulldogBT]

I am interested to know why some airfields in europe conduct PPL training from un-licensed airfields now.. and also flight training when the airfields are closed (unlicensed). I know this occurs in France, if we are in Europe then surely the rules should be aligned with all of europe. Also there are an odd airfield in the uk that conducts training and you really have to ask how it is licensed in the first place, with this in mind are they any safer than a well run un licensed air field...:confused:

[Whopity]

Licensing of aerodromes is unique to the UK. In France they simply operate to ICAO Annex 14 there is no licencing as such.

The requirement to conduct PPL training from a licensed aerodrome is in the UK ANO; It is not not applicable in any other State, hence:

CAA Stds Doc 39:
Use of an overseas training location will not be approved unless it can be demonstrated that the aerodrome, heliport or landing site can at least meet the requirements of CAP 168. In particular, evidence must be provided that rescue and fire-fighting services, capable of meeting the response times detailed in CAP 168 Appendix 8 are available whenever flight training is taking place. This is called nearest equivalence so as not to make it unfair to UK RFs who have to comply with Art 126.

[idle stop]

It's getting there.....
The following was reported on behalf of a CAA spokesman (his caveat in quote marks at the end) to the BHA/CAA On-Shore Liaison Committee (Helicopters) in October 2009:

The Light Aviation Airports Study Group (LAASG) was established in 2005 as a result of suggestions from Industry & Recreational Flying Organisations relating to the regulation of light aviation aerodromes. A Flight Training Sub-Group (FTSG) of the LAASG was formed to consider proposals to allow flight training at unlicensed aerodromes.
The FTSG concluded that allowing fight training at unlicensed aerodromes was a viable option, so the CAA conducted a public consultation on a proposal to amend the ANO accordingly. The consultation showed a significant majority of support for the proposal from consultees.
The FTSG met in Oct 2008 to decide the way forward and industry members undertook to produce a revised Code of Practice. At the subsequent meeting of the FTSG in June 2009, the draft Code of Practice was discussed and it was apparent that Industry members did not wish to have “ownership” of a Code of Practice, nor did they wish to enforce it or incur any liability from it. The CAA has therefore undertaken to review existing guidance material in CAP 428 “Safety Standards at Unlicensed Airfields” as an alternative to an industry Code of Practice.
Approval is being sought from CAA senior management to proceed towards an ANO amendment and to produce suitable guidance material for operators who may wish to train from unlicensed airfields. The ANO amendment is likely to take some time because the Department for Transport's Legislative programme is heavily populated, but it may be possible to issue exemptions in advance of the ANO change going through.
Work on the guidance document will start within the next month and is expected to be complete by the end of the year, including the necessary internal review processes.
“I emphasise that this summary is purely my understanding of where progress with this issue has got to now, and is no guarantee of the final outcome. Therefore it should not be relied upon to make any business decisions until a formal announcement is made by the CAA, which will be widely publicised”

[Whopity]

Approval is being sought from CAA senior management to proceed towards an ANO amendmentA CAA/Industry working group recommended this over 3 years ago as there was no safety case to support licensing aerodromes for training. CAA senior management overruled the recommendation at that time despite the fact there was no safety case to justify such action. Are we to believe that a democratic process is still at the discretion of a senior manager, who quite probably has no relevant expertise, whilst those with relevant expertise have established that there is no safety case to prevent this. Ex 10 Stalling comes to mind.

[hugh flung_dung]

"... Ex 10 Stalling comes to mind. " :confused:

HFD

[Whopity]

OED: Stall = Play for time; Block; Delay; Obstruct; Evade; Deceive

[hugh flung_dung]

Aha! Sorry, the obscure wit brain cells must still be recovering from the Christmas pud :O

[Mickey Kaye]

Is the licensing of aerodromes a large stream of income for the CAA?

[Whopity]

I think that the idea was that by not requiring a licence it would open up more airfields for training rather than result in less licensed aerodromes overall. So the revenue should remain much the same.

[WestWind1950]

Licensing of aerodromes is unique to the UK.

not true, Whopity. ALL German airfields are certified/licensed, at least for particular types of aircraft, so it's not unique to the UK.

If an airfield is only certified for gliders and/or powergliders, you cannot land/take-off and definitely not train there with a Cessna. Also, all airfields are required during opening hours to have someone at the field to cover rescue equipment and work the radios (lots of hot discussion about this going on for years).

Training is a risky business and I feel it's only right that it should be conducted at certified fields only......being certified, there is a certain guarantie that it is kept in order (grass cut, etc.).

[Whopity]

I thought that in Germany, Aerodrome Licensing is decentralised i.e. not a
task of the Nation‘s Federal Government. National Law makes A/D operator – not CAA -responsible for granting safety and order at the airport!

Ths is effectively what the LAASG proposal was about, to remove the need for a State issued aerodrome license and for operators to regulate themselves in order to comply with Annex 14. i.e. self certification. Some of the aerodrome operators saw this as more onerous than the current licensing system.

[belowradar]

Ah yes .... the secure feeling of knowing that the grass has been mown to a maximum height of 2cm :p

I feel much better now, at least I am not like those wreckless fools who fly's when the grass is undetermined - perhaps we could add it to the TAF and METARS (yes I am being sarcastic)

[homeguard]

Having studied the LAASG 'Draft code of Practice' on the face of it no one should think that it is a matter of operating out of anywhere without a care.

There is a continued reference within the document to standards already in place for licensed aerodromes. With regard to provision of Emergency Services, by another example, that section uses such phrases as; 'capable' and 'suitable' and 'sufficient people with the knowledge...'. and 'clearly marked'. Who will be the judge of all this.

Unless any organisation wishes to stick its neck on the block it is going to be wise to meet nearly all if not all the current licenced aerodrome standards.

Recommended Minimum Physical Characteristics also detail minimum clearances from obstructions which are difficult to seperate from that required of a small licenced aerodrome and to ensure 'duty of care' is achieved satisfactorily the priocess will require an expensive qualified survey.

It would seem difficult if not impossible, in my view, to demonstrate to an investigator following an incident why the unlicenced safety management system should be different, in being less, from the nearby 'special catergory' club operated licenced airfield nearby!

Planning Permission will, of course, be required owing to a change of use. Best of luck with that one.

[WestWind1950]

actually, a court decision after an accident set 10 cm as maximum length the grass should have. Before that, the rule of thumb was "short".

The German fields go through a certification process which is coordinated, and later certified, by the local state authority (state CAA if you so wish). The process includes hearings with ATC, the city where the field is located, possibly other local authorities... and not to forget the environmentalists :* After all are heard, then the state authority gives out the licence/certification. Even the smallest glider or ultralight field goes through this process.

For bigger fields, the process is even more complicated and often includes public hearings and/or court hearings.

The fields then have to abide by the regs within the certification... if they don't, and something happens, the owner may receive a heavy fine or the field closed. Sometimes inspectors visit the fields, spot checking whether they are holding up to the requirements. :suspect:

[Mickey Kaye]

OMG - The CAA are going to allow training from unlicensed airfields

FLYER Airportal - General Aviation News (http://www.flyer.co.uk/news/newsfeed.php?artnum=963)

[homeguard]

Before anyone gets too carried away, it is not a matter of training just anywhere.

Although the aerodrome will not be required to be licenced for training stringent minimum standards will still be required. The difference is that the Flight Instructor and/or the Aerodrome operator will be the responsible persons to ensure that suitable minimum standards are in place. Currently CAA inspectors ensure that the licensing standards are met. Comply with those and you've done your best.

At the present time the CAA licencing is rigid and is not tailor made relecting the actual use of the aerodrome. However following the ANO change CAP 428 Safety Standards for Aerodromes is to be revised and will be the guidance. Anyone falling short of the guidance but continuing training may be liable for a possible claim following an accident/incident and should the standards employed be found to be less than the guidance.

The majority of the new requirements will not be that much less than as now but will be able to be varied to meet the actual type of use!

[Mickey Kaye]

Any ideas what its stance on fire cover will be?

[homeguard]

Depending on the operations at the field fire cover could be as extensive as now or somewhat less.

Until the CAA re-publish CAP428 we don't know the devil in the detail. My understanding is that some of the high end licensing requirements such as the fire crew being able to operate offsite to a given radius will be an airfield operations decision. Such a requirement does not feature in the LAA proposed 'code of practice'.

It may even be that an Instructor could reasonably decide to operate, ensuring only that there are a few 'competant' persons available with a couple of fire extinguishers in the boot of the car and a mobile phone to dial 999! A competent person is yet to be defined.

It would certainly be reasonable to expect that the number of competent people on the ground - which could be 1 - will have the ability to operate the available fire fighting kit and also provide basic first aid as do most businesses already.

[Tinstaafl]

If you're really lucky maybe all that licencing &RFF crap will be removed entirely, allowing training from any field that's suitable for the aircraft. That's how Oz & the US do it.

Many years ago Oz used to require ab-initio training from either a licenced field or a 'training Authorised Landing Area' (tALA). In either case RFF was not required. A standard ALA met certain requirements w.r.t surface, width & obstacle clear gradients eg 1:20 obstacle clear slope) . A training ALA had greater buffers applied eg 1:30 for the obstacle gradient. The tALA requirement was removed in the '80s or eary '90s. As far as I can determine there has been no difference in safety outcomes between training on a licenced or attended field vs. some strip with no one around that meets the aircraft requirements.

[jez d]

While deregulation can only be a good thing, I'm not sure that many of the airfields currently licensed purely for the purposes of being allowed to conduct flight training will actually choose to become unlicensed.

Pros


Cheaper to operate an unlicensed airfield than a licensed one, if the RFF requirement for unlicensed airfields yet to appear in CAP428 is less onerous than for licensed airfields.
A lack of CAA audit will mean a saving of £2,000 per annum
No requirement for radio service could save £2900 per year if Ofcom go ahead with their VHF charging schemeCons


A lack of CAA audit may mean that unlicensed airfield operators would be more exposed to litigation, although their 'code of practice' will presumably provide some form of protection?
No ATZ
A change of status to unlicensed may require a new planning application with the local council, which could open the doors to NIMBYs and avaricious property developersAny further pros and cons anyone can think of?

Regards, jez

[Rispud]

Hi all,

Check these links. After about April when the ANO is changed, flying will be allowed from unlicensed airfields. Subject to planning permission, the need to have proper briefing facilities, and the local nimby'es of course.

FLYER Airportal - General Aviation News (http://www.flyer.co.uk/news/newsfeed.php?artnum=963)

Letter of Intent - Flight Training at Unlicensed Aerodromes | Consultations and Letters of Intent | CAA (http://www.caa.co.uk/default.aspx?catid=1350&pagetype=90&pageid=11200)

[xrayalpha]

Jez,

You can have an ATZ without being licenced.

I own Strathaven - unlicenced - and I enquired.

If you have a licenced airfield, you can have an ATZ and operate it with an Air/Ground service.

If you are unlicensed - and want an ATZ - you can have one, BUT....
you must provide a radio service operated by a FISO.

So what you win on licencing fees, you lose on FISO wages!!!

There is one airfield in the UK with an ATZ that is unlicensed, apparently.

[xrayalpha]

Jez,

No planning required for change of status from licensed to unlicensed. Licensing is a CAA matter.

Potentially, there is planning required to START flying training from a site, since flying training - with circuits, EFATOs etc - is a different type of use than private and personal flights.

But to change CAA status: ie from unlicensed microlight training to licenced light aircraft, is not a planning concern. Examined it at Strathaven!

Might need planning to start passenger flights, though!

[BillieBob]

jez d - What gives you the idea that there will not be a CAA audit? The Authority has already announced its intention to conduct a more thorough oversight (or even approval) of Registered Facilities ahead of the EASA Implementing Rules. Guess which RFs will come in for greater scrutiny - those at licensed airfields or those at unlicensed strips? Now guess who's going to pay for this oversight - the owner of the unlicensed strip or the RF seeking approval to operate?

According to my contacts within the Belgrano, it is the Authority's belief that not many of the currently licensed airfields will choose to surrender their licence and so the prospect of a number of RFs seeking to operate from new, unlicensed sites is seen as a fresh revenue stream.

[Mickey Kaye]

"There is one airfield in the UK with an ATZ that is unlicensed, apparently."

Any ideas which one?

[Talkdownman]

"There is one airfield in the UK with an ATZ that is unlicensed, apparently."
Any ideas which one?

ENR 2-2-2-1 (http://www.nats-uk.ead-it.com/aip/current/enr/EG_ENR_2_2_en.pdf) shows it as North Denes.

[BristolScout]

Possibly the most practical manifestation of this rule change will be to enable schools on licenced airfields to continue 'after hours' on summer evenings. It's very frustrating at the moment to have to shut up shop when the firemen go home, leaving the microlight competition able to carry on until dark.

[RVR800]

Right well I've been up and running for a week now using my back garden - its reduced costs and Im already thinking of buying a second PA28 :ok:

Take look at the CAP

http://www.caa.co.uk/docs/33/CAP428.PDF

[BillieBob]

Right well I've been up and running for a week now using my back gardenMight have been wiser to wait for the law to change but, hey, who's going to notice?Take look at the CAPAlternatively, wait for the amended version that will accompany the law change.

[Whopity]

The JAR-FCL Requirement:
AERODROMES
6 The base aerodrome, and any alternative base aerodrome, at which training is being conducted shall meet the following requirements.
(a) Have at least one runway or take-off area that allows training aeroplane to make a normal take-off or landing at the maximum take-off or maximum landing mass authorised, as appropriate:
(i) under calm wind (not more than four knots) conditions and temperatures equal to the mean high temperature for the hottest month of the year in the operating area;
(ii) clearing all obstacles in the take-off flight path by at least 50 feet;
(iii) with the powerplant operation and the landing gear and flap operation (if applicable) recommended by the manufacturer; and
(iv) with a smooth transition from lift-off to the best rate of climb speed without exceptional piloting skills or techniques.
(b) Have a wind direction indicator that is visible at ground level from the ends of each runway.
(c) Have adequate runway lights if used for night training.
(d) Have available a means of air/ground communications acceptable to the Authority.

[RVR800]

Those requirements seems reasonable, Thanks