PFLs & Low Flying
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PFLs & Low Flying
There's an interesting section in this AAIB report:
What do others think? Could the paper be good news, which could protect Instructors from the full weight of the CAA? Could it turn out to be a ‘Poisoned Chalice’ causing more harm than good or is it merely a CAA/DFT paper-pushing exercise? And does it mean that the CAA are finally admitting that they are seen as too 'Heavy-Handed' as was the general consensus from my last thread?
Over to my fellow PPRuNers. . . .
BH
Concerns related to the legal status of practice forced landings
The instructor remarked that the success of his ensuing landing was very much the result of regular practice in simulated forced landings which he had carried out. He pointed out, however, that the provisions of the existing Rule 5 seriously limited the opportunity for, and the realism of, such practice. It is a widely held view in the flying training community that the CAA will take firm action against those who break the rule, regardless of whether the transgressors are doing so in a reckless fashion or inadvertently breaking the rule as part of a responsibly planned and realistically carried out training exercise.
The rule is recognised to be a valuable safeguard against both nuisance and danger to third-parties. However, its perceived rigidity and lack of identification of the needs of training, by a considerable proportion of Flight Instructors, is seen as a factor increasing the risk to both aircraft occupants and third parties, by reducing opportunities for realistic training. In particular, at those airfields where engine failure after takeoff (EFATO) demonstration and practice cannot be carried out legally at a sufficiently low height to be a realistic training exercise it is felt that a greater risk of causing danger to the public exists from poor handling of genuine engine failures at takeoff.
The risk of a genuine failure resulting in an accident must, however, be balanced against the risk of one of the necessarily much greater number of practised failures going seriously wrong. The conditions under which Flight Instructors may give effective engine failure and forced landing training without transgressing the provisions of Rule 5 would, therefore, appear to depend on their having a clear understanding of the Authority's philosophy and preferred best practice for such training and of their being convinced of the soundness of both.
It is, therefore, recommended that the CAA publish a paper, for the information of Flight Instructors in particular, on engine failure and forced landing training, making clear their philosophy and promulgating what they believe to be acceptable best practice.
The instructor remarked that the success of his ensuing landing was very much the result of regular practice in simulated forced landings which he had carried out. He pointed out, however, that the provisions of the existing Rule 5 seriously limited the opportunity for, and the realism of, such practice. It is a widely held view in the flying training community that the CAA will take firm action against those who break the rule, regardless of whether the transgressors are doing so in a reckless fashion or inadvertently breaking the rule as part of a responsibly planned and realistically carried out training exercise.
The rule is recognised to be a valuable safeguard against both nuisance and danger to third-parties. However, its perceived rigidity and lack of identification of the needs of training, by a considerable proportion of Flight Instructors, is seen as a factor increasing the risk to both aircraft occupants and third parties, by reducing opportunities for realistic training. In particular, at those airfields where engine failure after takeoff (EFATO) demonstration and practice cannot be carried out legally at a sufficiently low height to be a realistic training exercise it is felt that a greater risk of causing danger to the public exists from poor handling of genuine engine failures at takeoff.
The risk of a genuine failure resulting in an accident must, however, be balanced against the risk of one of the necessarily much greater number of practised failures going seriously wrong. The conditions under which Flight Instructors may give effective engine failure and forced landing training without transgressing the provisions of Rule 5 would, therefore, appear to depend on their having a clear understanding of the Authority's philosophy and preferred best practice for such training and of their being convinced of the soundness of both.
It is, therefore, recommended that the CAA publish a paper, for the information of Flight Instructors in particular, on engine failure and forced landing training, making clear their philosophy and promulgating what they believe to be acceptable best practice.
Over to my fellow PPRuNers. . . .
BH
Last edited by Big Hilly; 13th May 2004 at 21:17.
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BH,
Spin training was taken out of the syllabus because there were more people coming to harm doing this than from spin accidents.
I would wager a fair stake that the same could happen by 'relaxing' the rules regarding PFLs and EFATO training.
If it ain't broke don't fix it is not a bad adage.
The current rules allow apparently sufficient room for people to get adequate training as there doesn't seem to be a lot of evidence that stacks of folk get it dramatically wrong.
Looking at (fatal) accident rates it seems that the continued flight into IMC is still at the top and for accidents in general the league is lead by lack of general handling skills during take-offs, landings and fuel management.
FD
Spin training was taken out of the syllabus because there were more people coming to harm doing this than from spin accidents.
I would wager a fair stake that the same could happen by 'relaxing' the rules regarding PFLs and EFATO training.
If it ain't broke don't fix it is not a bad adage.
The current rules allow apparently sufficient room for people to get adequate training as there doesn't seem to be a lot of evidence that stacks of folk get it dramatically wrong.
Looking at (fatal) accident rates it seems that the continued flight into IMC is still at the top and for accidents in general the league is lead by lack of general handling skills during take-offs, landings and fuel management.
FD
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I think that by the time you get to 500'agl you know whether the PFL would 'work' or not. Remember also the wording of the rule - you can go lower than 500' as long as you are more than 500' from man made objects, vessels etc. i.e. pick a big field then you can go as low as you want. You can also practice the entire PFL at an airfield (provided it is not too busy). I find that carrying out a PFL from start to finish at a grass airfield is an extremely valuable exercise and is probably more difficult than landing in a field (which would hopefully be bigger and wider). I can't imagine the CAA changing this rule. I'm not sure I agree with the previous post - I don't think reducing/changing the 500' rule would cause more accidents - but it would be likely to cause more complaints, particularly from livestock owners/horse riders (and I suppose the possibility of accidents on the ground with the latter).
The EFATO question is much more difficult. I think if you practice EFATOs at an airfield with a reasonably long runway and the student demonstrates that he/she points the nose down and aims somewhere sensible I think that's about all that can be taught. I'm not sure how much skill is actually required in an EFATO. Provided you don't stall the aircraft, surely the outcome depends on the ground around you, which is either favourable or not. I wouldn't fancy having an EFATO at Southampton...
I think spin training probably has a place in training (although probably not for PPL), but I would never ever do it without a parachute.
And on the IMC question - if we had a sensible instrument rating in this country with the emphasis on currency (i.e. FAA IR requires 6 approaches in 6 months) pilots would be much more skilled at IMC flying and people would stop using the IMC rating as a 'get me home' rating (which is not a particularly sensible idea, IF should be practiced often). But I'll stop now - I could go on all night...
Samson.
The EFATO question is much more difficult. I think if you practice EFATOs at an airfield with a reasonably long runway and the student demonstrates that he/she points the nose down and aims somewhere sensible I think that's about all that can be taught. I'm not sure how much skill is actually required in an EFATO. Provided you don't stall the aircraft, surely the outcome depends on the ground around you, which is either favourable or not. I wouldn't fancy having an EFATO at Southampton...
I think spin training probably has a place in training (although probably not for PPL), but I would never ever do it without a parachute.
And on the IMC question - if we had a sensible instrument rating in this country with the emphasis on currency (i.e. FAA IR requires 6 approaches in 6 months) pilots would be much more skilled at IMC flying and people would stop using the IMC rating as a 'get me home' rating (which is not a particularly sensible idea, IF should be practiced often). But I'll stop now - I could go on all night...
Samson.
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I'm sorry, but as someone who has routinely practiced forced landings down to 100' I totally disagree with the above opinions. You cannot always tell how a PFL is going to pan out until you are well established on final which I would suggest takes you some way below 500'. At 100' YOU KNOW whether you actually would have made it and also get a damn good look at the field - was it actually a good choice in the first place?
As for 'if it ain't broke don't fix it' - I think, and obviously the AAIB agree, it is and needs review urgently.
As for 'if it ain't broke don't fix it' - I think, and obviously the AAIB agree, it is and needs review urgently.
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The issues raised by this include:-
(1) the form of Rule 5, and
(2) the attitude of the CAA to alleged infringements of rule 5, particularly in connection with forced landing training and practice.
On (1), the CAA has been consulting interested parties on a revision of rule 5. It is a pity that BEagle appears to have left us for "that place whereof we do not speak" (rumour suggests that he's gone off to get his headset painted), as he might have some valuable insights here, both as an instructor and because he has been in contact with the CAA about the proposed rule amendment.
As to (2), Flying Lawyer has the most relevant experience of this, and has publicly expressed concern that the CAA's attitude is unhelpful. The AAIB report invites the CAA to consider and publish its position, but I do not know if the CAA is going to respond to the invitation. The AAIB is an organisation distinct from the CAA.
I would be inclined to regard a CAA policy/best practice statement as a good idea, but it's fair to point out that there are potential difficulties for any body with enforcement powers, in any field of activity, in making statements as to its general approach, as such statements can lead to people setting up arguments that they have a legitimate expectation that the authority will always act in a certain way, rather than taking a view on a case by case basis. The Inland Revenue, for example, gets a lot of this.
PS, Big Hilly, maybe it's a good thing that BEagle isn't here, as he's even more of an apostrophe-nazi than me. What is it about pilots that makes them such serial apostrophe abusers? Is there a genetic link between pilots and greengrocers?
(1) the form of Rule 5, and
(2) the attitude of the CAA to alleged infringements of rule 5, particularly in connection with forced landing training and practice.
On (1), the CAA has been consulting interested parties on a revision of rule 5. It is a pity that BEagle appears to have left us for "that place whereof we do not speak" (rumour suggests that he's gone off to get his headset painted), as he might have some valuable insights here, both as an instructor and because he has been in contact with the CAA about the proposed rule amendment.
As to (2), Flying Lawyer has the most relevant experience of this, and has publicly expressed concern that the CAA's attitude is unhelpful. The AAIB report invites the CAA to consider and publish its position, but I do not know if the CAA is going to respond to the invitation. The AAIB is an organisation distinct from the CAA.
I would be inclined to regard a CAA policy/best practice statement as a good idea, but it's fair to point out that there are potential difficulties for any body with enforcement powers, in any field of activity, in making statements as to its general approach, as such statements can lead to people setting up arguments that they have a legitimate expectation that the authority will always act in a certain way, rather than taking a view on a case by case basis. The Inland Revenue, for example, gets a lot of this.
PS, Big Hilly, maybe it's a good thing that BEagle isn't here, as he's even more of an apostrophe-nazi than me. What is it about pilots that makes them such serial apostrophe abusers? Is there a genetic link between pilots and greengrocers?
Last edited by FNG; 13th May 2004 at 07:32.
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RS,
The AAIB invites the CAA to write a piece of advice so that FIs know what the CAA considers to be best practice.
They very much balance their view by stating:
Not sure whether your interpretation of their advice indicates that AAIB think the rules should be changed.
I read it to mean that they would like a clarification on what the CAA thinks would be the best way to train folks for FLs and EFATOs.
Would be good to read BEagles comments.
FD
The AAIB invites the CAA to write a piece of advice so that FIs know what the CAA considers to be best practice.
They very much balance their view by stating:
The risk of a genuine failure resulting in an accident must, however, be balanced against the risk of one of the necessarily much greater number of practised failures going seriously wrong.
I read it to mean that they would like a clarification on what the CAA thinks would be the best way to train folks for FLs and EFATOs.
Would be good to read BEagles comments.
FD
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RE. "Spin training was taken out of the syllabus because there were more people coming to harm doing this than from spin accidents."
I'd like to know where this comes from. Got any qualified reference to it? Statistics?
I do remember seeing that a vast majority of fatal accidents were 'loss of control' ie stall/spin when really they were only dealing with an engine failure or some other less fatal event.
Perhaps that is too great a thread-slip here. Just interested.
I'd like to know where this comes from. Got any qualified reference to it? Statistics?
I do remember seeing that a vast majority of fatal accidents were 'loss of control' ie stall/spin when really they were only dealing with an engine failure or some other less fatal event.
Perhaps that is too great a thread-slip here. Just interested.
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FNG, True indeed about the ‘apostrophe abuse’. Alas, I spotted it too late and you can’t change thread titles once posted. ‘What is it about us pilots that abuse the apostrophe so?’ I suspect it’s because our aircraft don’t come fitted with them; the MEL is normally limited to exclamations and expletives!!! 
On a serious note, it is indeed a shame that BEagle has gone off to ‘foreign climes’. This is exactly the sort of thread on which his immense experience, knowledge and clear-thinking used to come to the fore.
BH
On a serious note, it is indeed a shame that BEagle has gone off to ‘foreign climes’. This is exactly the sort of thread on which his immense experience, knowledge and clear-thinking used to come to the fore.
BH
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Fear not, Big Hilly, I will not tell Lynne Truss.
It really is a pity that BEagle's toys have pulled the yellow and black handle in his pram, as his input to this discussion would have been useful.
It really is a pity that BEagle's toys have pulled the yellow and black handle in his pram, as his input to this discussion would have been useful.
Despite my views concerning the cruelty of the way in which treatment was so unpleasantly meted out to a certain person, I haven't gone off to another site to the exclusion of PPRuNe, it's just that I've only had very limited Internet access for the past few days. Not wishing to pursue the laws applying to libel, I will take your slighting reference to toys and prams as being made in jest, FNG.
My comments made to the CAA (and I discussed them at length with chum Tudor) concerning Rule 5 were:
"The conduct of legitimate emergency training exercises has frequently resulted in nugatory enforcement action by the Authority. I would welcome an opportunity under the (Rule 5 revision) proposal to introduce legal protection to FIs and student pilots teaching or practising approved emergency training exercises.
I consider that a new Sub-paragraph should be added to Sub-para (5) stating:
(An aircraft shall be exempt from compliance with: )
(m) paragraph (2) when being flown for the purpose of conducting routine emergency training with the prior approval of an authorised Flight Instructor.
I consider that such an amendment would give reasonable legal protection to the legitimate conduct of essential training exercises whilst maintaining protection for the general public from unauthorised low flying."
They didn't adopt it though.
My comments made to the CAA (and I discussed them at length with chum Tudor) concerning Rule 5 were:
"The conduct of legitimate emergency training exercises has frequently resulted in nugatory enforcement action by the Authority. I would welcome an opportunity under the (Rule 5 revision) proposal to introduce legal protection to FIs and student pilots teaching or practising approved emergency training exercises.
I consider that a new Sub-paragraph should be added to Sub-para (5) stating:
(An aircraft shall be exempt from compliance with: )
(m) paragraph (2) when being flown for the purpose of conducting routine emergency training with the prior approval of an authorised Flight Instructor.
I consider that such an amendment would give reasonable legal protection to the legitimate conduct of essential training exercises whilst maintaining protection for the general public from unauthorised low flying."
They didn't adopt it though.
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I personally don't think that Rule 5 should have any impact on PFL's. I don't think you should practice them within 500' of any person / structure / blah, and as mentioned, find a nice empty field and you can go down to 100' if you want.
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A jest indeed, Beagle, and I hope that your toys won't sue anybody. I am glad that you are still here. I gather that someone else's toys had a rough time, ejecting through a rotor disc.
Your rule 5 suggestion appears to me to be a sensible one. I think that it would best if the exemption were restricted to dual flights with an instructor in command, or to tests.
Al, isn't the problem that you may not see Mr Grumpy in the field until it's too late?
Your rule 5 suggestion appears to me to be a sensible one. I think that it would best if the exemption were restricted to dual flights with an instructor in command, or to tests.
Al, isn't the problem that you may not see Mr Grumpy in the field until it's too late?
Last edited by FNG; 15th May 2004 at 15:06.
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Serves him right for sun bathing nude in the sugar beet.
PS: Don't worry Al, a rule 5 bust is the least of your worries: the Apostrophe Cops are on your case....
PS: Don't worry Al, a rule 5 bust is the least of your worries: the Apostrophe Cops are on your case....
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in Germany the problem is solved by the flight schools receiving specific permission to fly below the legal altitude during required training. This is only allowed during basic training and not during practice after you have your licence. This practice has been used for years with no problem and didn't change after JAR-FCL was employed except that now the school must apply for it, before it was always automatically in it's certification.
Occasionally organisations offer special "safety classes" for licenced pilots in which they want to include these emergency trainings below legal limit (500' rule). The permission for it can also be applied for at the authority and it will usually be granted for this specific course.
The various local authorities used to designate particular areas for this practice, but now they usually don't. Too often the students would guess what excercise was going to be done, just because the instrutor headed toward the practice area... thus, it was no "surprise" any more.
Westy
Occasionally organisations offer special "safety classes" for licenced pilots in which they want to include these emergency trainings below legal limit (500' rule). The permission for it can also be applied for at the authority and it will usually be granted for this specific course.
The various local authorities used to designate particular areas for this practice, but now they usually don't. Too often the students would guess what excercise was going to be done, just because the instrutor headed toward the practice area... thus, it was no "surprise" any more.
Westy
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See also
[ineffective link deleted]
Edit: My link was duff, but it has been posted correctly by Heliport, below.
[ineffective link deleted]
Edit: My link was duff, but it has been posted correctly by Heliport, below.
Last edited by FNG; 18th May 2004 at 18:50.
