CAP 1779

[1claudius]

I am surprised to find no discussion of the implications for VFR flight in the UK if this proposal is implemented. ( 1000 ft vertical clearance from cloud in class D airspace unless special VFR). It is available online. It seems like a killer blow for flying schools in class D.

[Cenus_]

The APPG-GA response is pretty good. http://www.generalaviationappg.uk/wp-content/uploads/2019/05/CAP1779-Response-1.pdf.

One point they didn’t pick up on though is that the CAA doc says SVFR clearances are only permitted in CTRs but not CTAs (is that true? I’ve never had the need to request one), if that’s the case I can imagine the impact for pilots based at airfields nearby CTAs who currently routinely transit them being even more impactful, and the CAA seem to have excluded that factor from their analysis.

[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!

[Cenus_]

Another observation. There’s no mention in the CAA document of controllers taking the cloud base into consideration when a VFR transit will be requested. I’m not suggesting anyone should or would shirk the rules but I wonder if there’s a chance everyone will simply carry on as before...until there’s an indicent?

[NorthSouth]

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/future-safety/proposed-changes-to-vmc-minima-in-class-d-airspace/