FFF,
That is what I have heard.
Currently, there are a number of operators who have "private" holding and approach procedures which are approved by the CAA for their use alone. It is not uncommon for two different operators at the same airfield to have different procedures.
Since these procedures are not published, there is no requirement for ATC.
The CAA are in the process of making a requirement that every procedure is published and there will no longer be approval for private procedures. This is tied in with proposals to make it OK for IFR approaches at airfields with only AFIS.
You are quite right to say that you can do what you like in Class G under IFR provided you remain within the law. I don't believe that will change and of course you can hold enroute in such airspace if you so choose.
However, a holding procedure based on a NDB associated with an airfield (not part of the enroute structure) is getting into a grey area.
How can the CAA require all procedures to be published etc and then allow everyone create their own home made hold which could be used as a racetrack cloudbreak procedure to some aerodrome?
Also with regard to the 1000ft rule, how do you calculate your minimum holding level?....is it based on the worst case posibility of the aircraft's position in the hold? Do you construct a holding area? You could of course make the minimum holding level 1000ft above all obstacles within 20nm but that might be a bit high in some places.
There is also the matter of coordination with local ATS units such as LARS and Approach who I am sure would like to be aware if regular holding is going to take place within their area of responsibility......gives them an area to avoid when vectoring traffic.
Finally, having spent money getting an NDB up and running, it is a shame not to be able to use it because you find that every time you climb up, some other aircraft from miles away is practising holds at your beacon!
Regards,
DFC