Rule 5 Amendment?
Joined: May 1999
Aviation Qualifications: ATP+Mil
Posts: 27,401
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From: Quite near 'An aerodrome somewhere in England'
Oops...
Fortunately I sent my comments to the correct address!
No reply as yet - but I share Aussie Andy's view that the oft-maligned Authority does now listen to our views. Long may that continue! Incidentally, I also proposed a new paragraph to give legal backing to the conduct of routine emergency training approved by authorised FIs:
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.
Fortunately I sent my comments to the correct address!
No reply as yet - but I share Aussie Andy's view that the oft-maligned Authority does now listen to our views. Long may that continue! Incidentally, I also proposed a new paragraph to give legal backing to the conduct of routine emergency training approved by authorised FIs:
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.
Why do it if it's not fun?
Joined: Jul 2001
Posts: 4,782
Likes: 12
From: Bournemouth
I wouldn't like to see a "routine emergency training" exemption limited to flights approved by FIs. I quite regularly do "routine emergency training" such as PFLs without approval by an instructor.
I think this is something which we all need to get involved in. But since I'm not an expert in these matters, I'll certainly be reading everything which anyone posts here very carefully first! Others have noticed glaring problems with the proposals which went straight by me on my initial reading.
FFF
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I think this is something which we all need to get involved in. But since I'm not an expert in these matters, I'll certainly be reading everything which anyone posts here very carefully first! Others have noticed glaring problems with the proposals which went straight by me on my initial reading.
FFF
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Joined: Dec 2001
Posts: 546
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From: europe
The first question is why change, and there is an option suggesting keeping the rule as is.
The objective stated is to align with IACO, or perhaps JAA rules. We have seen in the case of the NPPL the usefulness of having national flexibility to suit local conditions.
Another objective is to make the rule more readable, and the question is then does the proposal achieve any substantial improvement.
In the discussion document/proposals para 4.4 is written as a blank cheque, intentionally or otherwise.
The proposal reads as if it is helicopters which are driving the changes, so it is for those experienced in their operation to come up with rules suitable for their type of flying. This will not necessarily translate to be suitable for light fixed wing craft.
A hugely important question for the GA fraternity is, will any rewrite of the rules make it more certain that pilots incorrectly accused of infringements will be aquitted.
As to any safety consideration, the question to be asked is how many accidents have occoured while keeping to the current rules.
Flight under the London TMA, and into airfields in this area already requires particular care, will any of the proposed changes make this safer or worse.
It is my opinion that the present 500 ft rule gives much more flexibility than the proposed, is understood by all pilots, and any change may well introduce problems, some of which have been discussed in this forum.
Having made the above comments I would like to read more opinions before submitting comment to the CAA.
The objective stated is to align with IACO, or perhaps JAA rules. We have seen in the case of the NPPL the usefulness of having national flexibility to suit local conditions.
Another objective is to make the rule more readable, and the question is then does the proposal achieve any substantial improvement.
In the discussion document/proposals para 4.4 is written as a blank cheque, intentionally or otherwise.
The proposal reads as if it is helicopters which are driving the changes, so it is for those experienced in their operation to come up with rules suitable for their type of flying. This will not necessarily translate to be suitable for light fixed wing craft.
A hugely important question for the GA fraternity is, will any rewrite of the rules make it more certain that pilots incorrectly accused of infringements will be aquitted.
As to any safety consideration, the question to be asked is how many accidents have occoured while keeping to the current rules.
Flight under the London TMA, and into airfields in this area already requires particular care, will any of the proposed changes make this safer or worse.
It is my opinion that the present 500 ft rule gives much more flexibility than the proposed, is understood by all pilots, and any change may well introduce problems, some of which have been discussed in this forum.
Having made the above comments I would like to read more opinions before submitting comment to the CAA.
Joined: Feb 2002
Posts: 265
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From: don't know, I'll ask
I agree with bluskis. 500 from something or someone is easy to understand. Hieghts above ground preclude low level over the sea and unihabited ares, and as an early poster said, round mountains etc, non of which will add to safety, but remove the fun.
The no landing within 1000 metres of a 1000 person organised outdoor gathering has some interesting airfield closing potential.
Let's say renta crowd got 4,000 people together (not impossible 250,000 went on th liberty an dlivlihood march) organised an open air gathering within 1KM of Heathrow, Stanstead, Luton and Birmigham all day on easter saturday - that would shut down everything quite well under the new proposal. Even a good sized fete in the village near your local airfield would put you out of business on a summer saturday!
Keep it the same I say, and have sent my 2p worth to the CAA, an welcome their open consultation - well done to them.
The no landing within 1000 metres of a 1000 person organised outdoor gathering has some interesting airfield closing potential.
Let's say renta crowd got 4,000 people together (not impossible 250,000 went on th liberty an dlivlihood march) organised an open air gathering within 1KM of Heathrow, Stanstead, Luton and Birmigham all day on easter saturday - that would shut down everything quite well under the new proposal. Even a good sized fete in the village near your local airfield would put you out of business on a summer saturday!
Keep it the same I say, and have sent my 2p worth to the CAA, an welcome their open consultation - well done to them.
Joined: May 1999
Aviation Qualifications: ATP+Mil
Posts: 27,401
Likes: 857
From: Quite near 'An aerodrome somewhere in England'
I have now had an informative reply from Rob. It would appear that, due to the plethora of commas, sub-para (5)(c) is open to ambiguity of interpretation. It's supposed to read that take-offs, landings, practice approaches and checking navaids or procedures at licensed or Government aerodromes only are exempted from the rule regarding 1000 gathered in the open! As are take-offs and landings at any other aerodrome in another country.
So, regrettably, we can't hold the first 1000 person open-air PPRuNe bash 999 metres from Gatwick on a busy holiday weekend......
The revised draft is supposed to protect the Great Unwashed at, say, a local agricultural show from someone in a private helicopter trying to land in the car park, it would seem. But if introduced as currently written, it could cause huge difficulties for those flying from an unlicensed strip everytime Fiona and Samantha hold a pony club show within 1 km - or if yet another thieves' paradise ('car boot sale') is set up in Farmer Giles' field just over the boundary fence........
So, regrettably, we can't hold the first 1000 person open-air PPRuNe bash 999 metres from Gatwick on a busy holiday weekend......
The revised draft is supposed to protect the Great Unwashed at, say, a local agricultural show from someone in a private helicopter trying to land in the car park, it would seem. But if introduced as currently written, it could cause huge difficulties for those flying from an unlicensed strip everytime Fiona and Samantha hold a pony club show within 1 km - or if yet another thieves' paradise ('car boot sale') is set up in Farmer Giles' field just over the boundary fence........
Joined: Jan 2002
Posts: 768
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From: Paros, Greece
I also had a personal reply from Rob which raised the same concerns as BEagle mentions, but in his reply to me he didn't indicate that there was any ambiguity in (5)(c) and implied that it was indeed meant to mean no landings within 1000ft of gatherings, even at licensed airfields. He did however concede that 'this area may need revisiting'. Looks like he may have changed his mind after receiving more feedback.
After a promising start, this is again turning into somthing more typical of the CAA. The re-drafting was meant to clarify the rules and has clearly failed to do this at the first hurdle since we collectivley still cannot interpret them!
On another note, have these proposals been sent out to people involved in GA (clubs, airfields etc.) as I spoke to my CFI and some instructors yesterday and neither he or anyone else present knew anything about the proposals.
After a promising start, this is again turning into somthing more typical of the CAA. The re-drafting was meant to clarify the rules and has clearly failed to do this at the first hurdle since we collectivley still cannot interpret them!
On another note, have these proposals been sent out to people involved in GA (clubs, airfields etc.) as I spoke to my CFI and some instructors yesterday and neither he or anyone else present knew anything about the proposals.
Joined: May 1999
Aviation Qualifications: ATP+Mil
Posts: 27,401
Likes: 857
From: Quite near 'An aerodrome somewhere in England'
Sorry - it wasn't Rob who said that there was any ambiguity, it was me in my reply. His intent regarding exemptions for take-offs and landings at Licensed or Government aerodromes within 1 km is at variance with the way in which (5)(c) has been interpreted by most people in this thread.
The true intent of (5)(c), if I deduce it correctly after considering Rob's reply is something like:
'An aircraft shall be exempt from compliance with:
Paragraphs (1), (2), (3) and (4) while utilising the airspace customarily used by aircraft when landing, taking off, practising approaches, checking navigational aids or procedures in accordance with normal aviation practice at:
a. A Government aerodrome
b. A licensed aerodrome in the UK
or when utilising the airspace customarily used by aircraft when landing and taking off in accordance with normal aviation practice at any aerodrome in any other country'
However, I still think that the exemption should apply to all aerodromes; it would be unreasonable to restrict legitimate aviation activities at an unlicensed aerodrome just beacuse Farmer Giles has let 1000 thieves stage a so-called 'car boot sale' just over the boundary fence! The problem, it seems, is in deciding precisely what constitutes an 'aerodrome'......
The true intent of (5)(c), if I deduce it correctly after considering Rob's reply is something like:
'An aircraft shall be exempt from compliance with:
Paragraphs (1), (2), (3) and (4) while utilising the airspace customarily used by aircraft when landing, taking off, practising approaches, checking navigational aids or procedures in accordance with normal aviation practice at:
a. A Government aerodrome
b. A licensed aerodrome in the UK
or when utilising the airspace customarily used by aircraft when landing and taking off in accordance with normal aviation practice at any aerodrome in any other country'
However, I still think that the exemption should apply to all aerodromes; it would be unreasonable to restrict legitimate aviation activities at an unlicensed aerodrome just beacuse Farmer Giles has let 1000 thieves stage a so-called 'car boot sale' just over the boundary fence! The problem, it seems, is in deciding precisely what constitutes an 'aerodrome'......
Thread Starter
Joined: Aug 2002
Posts: 0
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From: Surrey, UK.
Hurry, hurry, hurry
Another one, where the deadline for submissions is approaching 
10. Responses
Comments on the proposals contained in this paper should be sent to:
Mr R McGregor
General Aviation Department
Civil Aviation Authority
1W Aviation House
Gatwick Airport South
West Sussex
RH6 0YR
e-mail: [email protected]
to arrive no later than 17 January 2003.
In the absence of comment the CAA will assume that there is no objection to the proposals and will proceed to the second stage of the consultation process.
Comments on the proposals contained in this paper should be sent to:
Mr R McGregor
General Aviation Department
Civil Aviation Authority
1W Aviation House
Gatwick Airport South
West Sussex
RH6 0YR
e-mail: [email protected]
to arrive no later than 17 January 2003.
In the absence of comment the CAA will assume that there is no objection to the proposals and will proceed to the second stage of the consultation process.
