Originally Posted by
Captain Jock
There is indeed not much activity on this in PPRUNE. I know at least one organisation who will be affected by this who are pursuing it with the CAA/AOPA. This looks like the most effective, or in fact the only way, to respond. I am not holding my breath!
AOPA's approach seems to be that we should be proposing an alternative means of mitigating the problem. That seems to me to be misguided. We should simply say the proposed change is unsafe and unnecessary and we should keep the current exemption. Here's why:
1. SVFR transits through busy CTRs will be subject to massive delays due to the need to separate all SVFRs by minimum 3nm horizontally from all IFR traffic. Controllers will quickly get fed up with the increased workload and will deny SVFR requests.
2. The alternative - asking for a straight VFR clearance and complying with min 1000ft vertical separation from cloud - means pilots will be flying much lower than they currently do, leaving less margin for terrain/obstacle/traffic avoidance and increasing the risk of a bad outcome in the event of engine failure.
3. The reality and perception of difficulty getting a VFR/SVFR transit will mean lots more light aircraft routing around CTRs, causing traffic bottlenecks, increased risk from low level over-water flights and greater risk of vertical and horizontal infringement of the very controlled airspace they are seeking to avoid.
You have until this Friday to respond. Please do!
https://consultations.caa.co.uk/futu...ss-d-airspace/