Reply from Rob McGregor at the CAA
A response to my email within 24 hours - and he's a heli pilot. So c'mon Rob - what's your pprune handle ??
"Thank you for taking the time to give me your views on the discussion paper. You have raised some interesting points which I have noted in the spreadsheet of comments received.
At this stage the CAA is seeking opinion regarding the minimum height over congested areas and outside congested areas. I can see that you like the rule in FAR 91.119 and so, I guess, you would support 1,000 ft over congested areas and no closer than 500 ft from any person vessel vehicle or structure. We plan to issue a second round of consultation with the rule refined in these areas, towards the end of January.
FAR 91.119 is very simple. Unfortunately, America being a place with lots of wide open spaces, their low flying rules are not, generally speaking, detailed enough to suit the heavily populated countries of Europe. That said, you will see that the primary paragraphs in our proposal for the revised UK rule are very similar. What takes up the space are all the alleviations that are necessary in order to interface the wishes of pilots with the safety and wishes of those of the rest of society.
You will see that under the existing and proposed UK rules:
1) Aircraft can fly lower than the normal minimum height over congested areas when they are operating in a control zone in accordance with a special VFR clearance.
2) It is accepted and expected that, in accordance with the rule that allows helicopters to fly over congested areas, that a helicopter pilot will be able to do a safe, engine off landing on an empty football pich. (N.B. remember that the term 'congested area' has a specialised meaning in aviation law).
3) The UK has, for example, alleviations for gliders, aerial spraying, police helicopters, the saving of life, and even a proposal to ease the problems of becalmed balloons.
A qualified helicopter pilot does not need a licensed aerodrome at which to practice PFLs and confined areas, but there could obviously be a problem with PFLs to below 500 ft in the open countryside if the ICAO form of the rule was adopted without associated and numerous alleviations. However, the main concern which the restriction of training to licensed aerodromes is aimed at is safety (rescue and fire fighting) for the pilots involved."
Yours sincerely
Rob McGregor
P.S. I am, actually, a helicopter pilot myself