The need for licensed aerodromes for light aircraft

[G-KEST]

There is a joint CAA/industry study group, recently organised, that is looking at small licensed aerodromes and the present requirements of Article 101. The CAA would appreciate the widest possible consultation and contributions to the work of the study group.

I am a member of the group having been nominated by the PFA however if you prefer to liaise with your own representative bodies then other organisations such as AOPA(UK), AOA, BBGAA, BGA, BMAA and GAPAN have put forward individuals who are also group members.

It may be that radical change in the need to use a licensed aerodrome for aircraft below 2730KG especially for training may result. There are a number of anomalies in the present requirements that need sorting out in any case.

I would much appreciate any comments you may have on this subject either on this thread or in a PM to me. Your ideas will then be put forward into the study group melting pot.

Many thanks,

Barry Tempest FRAeS

:ok:

[Mike Cross]

My personal view, for what it's worth:-

The licensing requirement stems mainly from the concept of Public Transport and Aerial Work. It presumes that members of the general public who are paying for a flight need additional protection because they do not have the knowledge to make a proper assessment of the risk involved. I don't have a problem with that if you are offering pleasure flights or air taxi/charter.

However someone who has decided to embark on a course of flying lessons is in an entirely different position. I would like to see at least that training for the grant or renewal of a non-commercial license or a rating thereon is treated as a Private Flight (whether or not the instructor is remunerated).

I would also like to see the requirement for the field to be licensed to be withdrawn and replaced by a requirement that the field is suitable, having regard to the type of aircraft and the training to be undertaken. This would bring the requirement for the airfield in line with that for the aeroplane (i.e. that it suitable for the purpose rather than certified for the purpose).

Mike

[2Donkeys]

This would bring the requirement for the airfield in line with that for the aeroplane

Not sure I understand that. Aircraft used for flight instruction must be on a Public Transport C of A unless the pilot happens also to be the owner.

Are you suggesting that this restriction should also be dropped Mike?

2D

[matspart3]

Please tread very carefully with this one....

The requirement to train only at Licensed aerodromes is often perceived as an unecessary cost burden on the GA training industry, but in many respects, it actually helps the industry thrive.

Imagine if the flying clubs at Gloucester, Shoreham, Biggin, Cranfield etc. all suddenly decamped to Little Snodbury-on-the-Wotsit. They (i.e. the Clubs) might well save a few quid on hangarage & landing fees in the short term, but how long do you think their former bases could continue to trade with, potentially, a large percentage of their business disappearing overnight?

The larger GA airfields are highly dependent on this revenue stream, and without it, they'll be housing estates quicker than you can say John Prescott.

We all know how increasingly difficult it is for GA to gain access to decent Airport facilities (such as hard runways, lighting, navaids, ATC) at a reasonable cost, with the larger Regionals squeezing tiddlers out, but it is vitally important that we take a long term view on this.

Having said that, the Licensing process is way over the top in some respects for the smallest aerodromes....CAP168, the Licensing document, applies the same rules at Hal'penny Green as Heathrow, and a shake up of the system is long overdue. My fear, however, is that EU Single European Skies legislation will quickly supersede most thing at a national level.

[G-KEST]

Mike,

You wrote -
The licensing requirement stems mainly from the concept of Public Transport and Aerial Work. It presumes that members of the general public who are paying for a flight need additional protection because they do not have the knowledge to make a proper assessment of the risk involved. I don't have a problem with that if you are offering pleasure flights or air taxi/charter.

The anomaly is that. at the moment, A to A pleasure flights in aircraft of less than 2730KG need to use a licensed aerodrome yet A to B air taxi flights by day do not. Quite ridiculous IMHO.

Cheers,

Barry

[Mike Cross]

Sorry 2D, should have explained better.

The a/c needs to be on PT C of A not because it is being used for instruction but because it is being used for aerial work.

On the other hand the a/d needs to be licensed because it is being used for training, not because it is being used for aerial work.

This leads to the odd situation where if A is licensed and B is not, a student can log handling exercises on a trip from A to B but not on the way back.

If a flight for the purpose of training for a non-commercial license were to be treated as a Private Flight it would naturally follow that there would be no need for a PT C of A, as currently applies to training for a Microlight PPL.


Matspart

Not sure I follow your logic. If the a/d does not need to be licensed the costs would reduce and the owners would be able to pass that on in reduced rent.

It's not necessary to have a hard runway, navaids, lighting or ATC to be licensed. Old Sarum is an example that comes to mind.

If you don't want to shut down when the field gets waterlogged or you want to operate retractables then a hard runway is probably a good idea. If you want to offer night ratings lighting could be useful.

I doubt there is much danger of wholesale decampment to Little Snodbury-on-the-Wotsit. You ain't going to move somewhere that hasn't got the facilities you want.

Mike

[BEagle]

We have been waiting for well over a year for the CAA to move forward on this.....

My view is that there should be a continuous 'grading' of all aerodromes (sites habitually used for the operation of aircraft) from Heathrow down to Little Piddle on the Gusset...

If someone wishes to conduct some form of training, then guidelines should exist for all aerodrome features - runway length and surface, fire and medical availability (not necessarily on site) etc etc. So the organisation intending to conduct training could then establish, for example, that the site met the requirements for NPPL Mircrolight, SLMG or SSEA training and for PPL SEP training, but was unacceptable for MEP training.

Delete: "Licensed or Government Aerodromes"

Insert: "Approved Training Aerodromes"

Then specify how to achieve the relevant approval.

[bar shaker]

I think the anomolies are the system are best demonstrated at Popham (amongst others) where one runway is licenced and the other is not.

Beagle makes a very good case and a rationalisation will help the growth of the NPPL SEP.

I do not subscribe to protectionist measures. Otherwise, lets ban PPLs from learning in the US.

If the owners of Sodding Typical Airfield can make money on £7.50 landing fees and a school rent that gives rise to 152 lessons at £85, then that's a good thing. It certainly won't put the Shoreham, Southend and Biggins of this world out of business. It may even reverse the decline in GA business and cause growth, through better affordability.

[DubTrub]

One can in fact learn to fly at an unlicenced aerodrome, if one chooses microlights. They have two seats, can be 3-axis, high-performance, MTOM 450kg (I think), and require exactly the same skills to be learned as those for an "aeroplane". These unlicenced fields require no fire crew, runway "slopes", no 2 metre x 2 metre yellow "C", etc etc.

Not only is an unlicensed aerodrome not required, but the instructor, who may receive remuneration, does not require a commercial license.

But if one wishes to learn to fly an aircraft with MTOM 451kg, the rules are quite onerously changed (under current legislation).

I would suggest that any training up to PPL standard could be conducted at "approved" airfields [approved perhaps by organisations like the BMAA]. Any training thenceforth towards any "professional" licence would need to be conducted under circumstances appropriate to the type of professional licence being sought.

[tmmorris]

And the current rule that includes Government aerodromes actually includes some which would not get a license under CAA rules - Abingdon, for example, or Lee on Solent. This is a bit unfair on the likes of Shobdon who have to maintain licensed standards for training.

Tim

[HelenD]

If it were possible to use different airfields for training and if the schools did decamp to those places do any of you really think they will lower the fees we pay? I think they will just charge us the same and pocket the difference as profit

[englishal]

Isn't this just another example of rules in the name of safety, which don't actually do anything to increase safety? Unlicensed field operators get around it by flying to a licensed field and doing one landing as far as I know.

[Rod1]

I would like to see the existing rules for microlights extended to aircraft up to 2000kg. Lets get on with training enthusiasts on PFA aircraft from farm strips for NPPL.

Rod1

[BEagle]

Rod1 - that wold be very true but for one thing. The chiselling rule-bending ways of a few which would queer the pitch for the legitimate enthusiasts of whom you speak.

Also, I depair of the 'Peoples' Front of Judaea' attitudes amongst all the various groups claiming to 'represent' GA. It just makes them all look utterly puerile with their inter-magazine bitch fights and turf-protectionism. Time they learned to co-operate and move on!

[bar shaker]

I don't think anyone wanted the current battle, mentioned by BEagle,but you cannot expect an organisation not to react when its income stream is directly threatened.

Anyway, back to how some good may come of it. The BMAA has a good training and examining infrastructure and, as aresult of the PFA action, is currently holding a ballot to seek approval for administering Permit aircraft above 450kg.

The current BMAA NPPL training regime could also easily be adapted to extend to this class. The schools are there, the training regime is there and I suspect the customers are there.

At the moment it is easy to go from NPPL microlight to NPPL SEP with a credit for the microlight training hours. But you cannot credit the NPPL SEP hours to JAR if they were not done at a licenced field. With EASA curently encouraging the setting up of Euro wide NPPL ratings (to be called RPPL) the relaxation of the licenced field requirement is something that may well happen any way and would be good news for those wanting to use this training route and progress further.

Once the RPPLs are established, it is envisaged that countries will accept each others RPPL holders, as is the case with microlight pilots, but not, at present, the case for GA NPPLs.

[NorthSouth]

Mike Cross:if A is licensed and B is not, a student can log handling exercises on a trip from A to B but not on the way backReally? How does that square with ANO Art.101(1) which states: "An aircraft to which this paragraph applies shall not take off or land at a place in the United Kingdom other than: (a) an aerodrome licensed under this Order for the take-off and landing of such aircraft..."

I have heard numerous people arguing that by stopping the lesson just before you join the circuit of the unlicensed field you have somehow changed the purpose of the flight therefore 101 no longer applies but that sounds highly dubious to me. But you seem to be arguing that licensed fields are only required for take-off, not for landing. I'd be interested to hear where you get that from.

NS

[Genghis the Engineer]

An obvious question - is there any real safety benefit from training at a licenced airfield, assuming that in any case the instructor has an obvious responsibility to ensure that the field would be fit for the task.

So, for example, would an XC from (say) White Waltham have any greater safety or training benefit in going to Thruxton (which is licenced) than to Popham (which is not)?

G

[Mike Cross]

NS

An interesting point.

I wasn't going by my own interpretation of the rules but by anecdotal references. I have heard it suggested that if you take off from an unlicensed field you cannot log the time but that once you have done a landing at a licensed field you can then start logging it.

The article is subject to interpretation by the courts and is another example of the twisted loigic employed in drafting. I wouldn't argue with your interpretation.

The purpose is clearly to ensure that students perform take-offs, landings and circuit work at licensed aerodromes. Where it gets daft is in the assumption that a flight has one and only one purpose.

So the purpose of the flight is
1. To carry the student as a passenger to the exercise area.
2. To teach the student some general handling outside of the ATZ.
3. To return the student as a passenger to the a/d.

Where does that leave one?

Common sense says that the student is not acting in any capacity for the take off or landing but is Pu/t from the time the instructor says "you have control" until he takes it back again for the landing. The ANO and Common Sense though have little in common and and Art 101 would say he can't log it.

A good illustration of the need for reform?

Mike

[homeguard]

A student remains a student at all times that a lesson is being conducted from the briefing to the end of the debrief.

The qualification; to be one and not the other is not whether they are actually controlling the flight of the aircraft but whether they are being instructed. During a lesson the student should never be passive. They will be observing throughout. If i was the student and my instructor told me to entertain myself for a few minutes while i do the take off and fly to the training area, "i'll let you know when we are there". Well, i would expect only to pay for the period that i was being taught and not chock to chock. I would also change my instructor or flying school.

Mike your interpretation is perverse and not in accordance with any syllabus of which i am aware.

[Tinstaafl]

I've mentioned it in other threads, however...

Oz (& I believe the US) place no restrictions on the use of unlicenced landing areas for training as long as the strip is suitable for the a/c. I've never been able to find a difference in accident rates, injuries or deaths between the three countries so why bother with this unnecessary restriction in the UK?

[Mike Cross]

Homeguard

Sorry, you misunderstand me.

I agree with NS and yourself on the interpretation of Art 101. Hadn't read it before my earlier post - mea culpa.

My suggestion remains though that the rule should be changed. Barry has asked for opinions and my preference would be that the requirement for a licensed a/d to be used should be removed. At the end of the day it should be down to the instructor/training organisation to decide what combination of conditions is suitable for training. Those conditions include the student, the instructor, the aircraft, the aerodrome and the weather. They make these decisions every day.

The current arbitrary distinction between microlights and SEP has been overtaken by technology. The Dyn-Aero MCR-01 microlight has a 75% cruise of 135kt. Compare that with the average training aircraft.

The licensing of an aerodrome is not really relevant to the ab-initio environment, where training takes place only in relatively benign conditions - daytime VMC, good vis, no precipitation, no high winds, strong crosswinds or turbulence.

Mike

[NorthSouth]

No offence Mike, but if you want to make a serious contribution to this debate I'd suggest that knowing what the relevant piece of legislation actually says, and relying on something other than second- or third-hand anecdotes, might be a good starting point.

As to the generalities, what is it that those of you who want to train at unlicensed fields want to get rid of? Is it the fire truck? Or the trained rescue personnel? Or the control of obstacles around the airfield? Or the aerodrome manual? And if you did get rid of some or all of those, and had a regime where people simply relied on the airfield being 'fit for purpose', who would decide what 'fit for purpose' is? And who would check that people are actually applying those standards?

RFF Category Special is already designed specifically for fields where only light a/c instruction happens and the CAP168 obstacle surfaces for a small GA airfield are minimal.

I can't see how not having a crash truck is a good idea when you are sending someone with 10hrs TT off solo for the first time.

[bar shaker]

Northsouth

Your theory ignores the incredibly succesfull training regime at microlight schools.

No fire truck, no dedicated rescue team, still no obstructions and just 2 or 3 pages in the rules book. You may think that this means people are dying of horrible deaths, on a daily basis, but the reality is somewhat different.

Take away the cost of that lot and the cost of sending someone down to inspect it all and tick all the boxes, every so often, and it starts to make a big difference in the cost of running an airfield.

[homeguard]

The statistics do not support a requirement for an aerodrome to be licenced for training. But, to use accident statistics only as a determiner it would follow that Heathrow dosn't need to be licenced. Surely a chicken and egg arguement.

However, it is more complicated than that. The current aerodrome licencing system sets a minimum standard which, for some strange reason, is aligned to fuselarge length and width. In my experience the inspectors do their best to work with you in achieving the minimum. They do not come to shut you down! But, it is not the minimum physical standards that are the problem for most operators, it is the bits in between that are costly. Incidentally i visit, on a regular basis, many private strips that are far superior than some licensed fields.

Throughout the years that this arguement has continued the nit picking requirement of keeping logs. Fire fighter currency, first aid recurrent training, fire tender and equipment inspections, dedicated housing for the fire truck and equipment etc, has mushroomed. It is almost impossible to achieve all this without a number of full time staff at a debilitating cost.

WHY! Well the british desease to have an arse kicking procedure in place. It is almost incidental that an accident takes place - only that there is an arse to kick, later.

A 'Licenced Aerodrome' is also immotive. Try applying for planning permission to open a 700m Licenced Strip. Within weeks there will be a very active opposition group screaming that the next step will be an international airport within a few years. I do not know of any private strip owners who have experienced this phenomenon.

Schools should be required to be registered with the CAA as now and provide details of the teaching facilities, aircraft used and details of the physical characteristics of the strip (aircraft to be used; manual peformance x a safety factor) including the minimum TORA and TODA of each runway. The CFI should have set down minimum experience and be able to demonstrate a relevant knowledge with regard to the minimum standards to be met. An FI(r) with a days experience could be the CFI under the current rules. So, we set out the minimum standards to be met for the training that will take place rather than a minimum aerodrome standard that may not be directly relevant.

The laws of duty of care and professional liaibilty takes care of the rest. Without the need for licencing a flying school/club would need only to apply for planning permission for their business and NOT for an 'Airport'.

[Max AirFactor]

Homeguard, Spot on!

And when this is all in place, I would want to stock the School with a fine variety of factory built RVs (that can fly over built up areas) and are available to hire to the Club members.

MAF

[homeguard]

Absolutely.

If an aircraft is good enough for training ab-initio students it must be good enough to hire!

[NorthSouth]

Homeguard:The statistics do not support a requirement for an aerodrome to be licenced for trainingI'm open to persuasion but how would the stats show this? You'd have to compare training conducted at a licensed airfield with the same type of training conducted on the same types of aircraft at a comparable unlicensed airfield - i.e. training conducted illegally.

bar shaker:
You can't compare microlights with SEPs. Speeds, fuel capacities and complexity are all different. In any case surely the microlight accident rate is much worse than SEPs?

Maybe I'm a cynic, but given that there are threads not a million miles from here recounting tales of schools and clubs at licensed fields doing illegal trial flights, having physical punch-ups and instructors getting lost, and all that within a regime supposedly policed by the regulator, it seems to me that self-regulation of ab initio GA training, with everything relying on the trustworthiness of a CFI, would open up the possibility of all kind of abuses.

NS

[bar shaker]

NorthSouth

You are missing two points:

1) Accidents in training, on any type of aircraft, are incredibly rare. Of those, the number that were landing or take off incidents, at the field, is even rarer. Of those, the number where injuries were reduced by the presence of a fire truck... I think you see what I mean.

I suspect that of those that involved solo pilots, the number that called up for help before crashing would be none. In short the licence required safety crew made no difference to training accidents.

2) When you talk about complication differences, I assume we are comparing the classic solo hack, the Cessna 152 with... with what exactly?

Landing a modern three axis microlight is no different from landing a forty year old 152, except the microlght may require better energy management. But if you have only ever landed both at an 800m runway, how well will you cope when you need to put it into a 400m field of crops? Or a 300m field?

The one thing that the statistics do show, time after time, is that a forced landing away from the field should be survivable every time, but it is exactly this that kills the most pilots.

Pilots should experience everything in their training, including getting into small grass strips. Letting them train at such places can only enhance the quality of pilots.

If the cost difference encourages more people into flying, its a win-win situation.

NorthSouth, do you fly into grass strips, or are they too dangerous for you?

[NorthSouth]

bs: I see what you're getting at. But since training at unlicensed fields isn't allowed, how can we know that the rarity of accidents at training airfields isn't something to do with the licensed status e.g. runway dimensions, runway inspections, absence of obstacles? The only way you'd get the stats is by running a trial with SEP training at unlicensed fields. As for whether a fire truck helped, I don't know how you'd find any stats on that.

Re grass strip experience, I absolutely agree that every PPL should have this in their training. We have one licensed grass runway within half an hour's flying and try to give students experience on it. And yes, I do fly into short grass strips for fun too.

There are a number of licensed grass airfields with quite short runways e.g. Derby, so it's not as if the licensing regime is stacked against them per se.

Also agree that one of the big risks in terms of fatal accidents is PPLs doing forced landings. But I don't really see how training at unlicensed fields would improve this. Getting in to a 600m grass strip which you planned to fly to is totally different from finding and reaching a field from 2000ft when your engine quits. Students are taught PFLs and cannot pass their test without demonstrating that they could get into a field safely. The main problem in the past has been PPLs never practising PFLs once they get their licence, but the JAR-FCL and NPPL reval regime has gone some way to addressing that in the 1hr reval flight every 2 years.

Don't get me wrong, I'm all for reducing the cost of training if it can be done safely, I just can't quite see how it would be done and remain to be convinced about the stats.

NS

[Genghis the Engineer]

bs: I see what you're getting at. But since training at unlicensed fields isn't allowed, how can we know that the rarity of accidents at training airfields isn't something to do with the licensed status e.g. runway dimensions, runway inspections, absence of obstacles? The only way you'd get the stats is by running a trial with SEP training at unlicensed fields. As for whether a fire truck helped, I don't know how you'd find any stats on that.
That would be quite easy - microlight schools don't require a licenced airfield, but many do train on licenced fields.

So, go and compare the accident stats for microlight schools on licenced and unlicensed airfields. Since the syllabi, intructors qualifications and aeroplanes should be the same, I'd regard that as a fair comparison.

For a truly unbiassed comparison, pick a few schools with aeroplanes like CT, Eurostar, C42 - which have pretty much light aircraft characteristics.

G

[homeguard]

North south

Every accident is notifiable and the full story is reported, such as the attendance of a fire service (Truck) if any and the place and circumstances leading up to the accident. Reports are required of ALL 'Accidents' and 'Incidents' whether at a licenced strip or not.

The CAA collects this data which is provided to them by the AAIB. There are many sources available, such as Gasil and on the CAA website where you too may read them. You only have to bother. Those involved in promoting the changes have put a lot of unpaid work into the research. Don't patronise them and deny the existence of research simply because you have yet do do any or it hasn't been shown personally to you. I'm, sure that you take my point.

Below is a link where you may start, if you so wish. GASIL is sent automatically to all aircraft owners, operators and flying schools and contains reports of all accident within the previous period. You may also be put on the mailing list by contacting them. The CAA tour the country extensively throughout the year giving safety evening at venues where all are welcome. They are well publisized and worth attending. It saids a lot for our PPL fraternity that these evening are so well attended on all occasions.

http://www.caa.co.uk/docs/33/CAP735.PDF[/URL]

The only reasoned opposition to the changes, expressed so clearly at various seminars that i have attended, have been out of a fear of commercial disadvantage.

[Tinstaafl]

I argue it's also a fair comparison to compare licenced vs unlicenced with overseas training where training at unlicenced fields is allowed. That gets around the UK unavailability of GA training records at unlicenced fields.

The a/c are the same, the laws of physics are the same, landing & take-off is the same etc etc.

[LowNSlow]

I think that airfields which only currently have a requirement to be licensed due to the training activities on them should be granted a status of their own. As somebody said earlier, as soon as the general public hear the phrase "licensed airfield" they think Heathrow not Popham.

If an airfield owner wants to operate flight training (up to PPL I'd suggest) then the CAA should assess the airfields suitablity for training. This would address potential obstacles, runway width, length etc. whilst removing the more onerous and, as shown by the microlight fraternity, mostly unnecessary restrictions within the current system (fire engine, dedicated medical personnel etc.). Taking Popham as an example of a well run unlicenced airfield, how many times has a fire engine or a medic been required there due over the last five years?