The need for licensed aerodromes for light aircraft
 

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:

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I would also like to see the requirement for the field to be licensed to be withdrawn and replaced by a requirement that the field is suitable, having regard to the type of aircraft and the training to be undertaken.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

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

The use of Licensed aerodromes for training
 

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.

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

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

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.

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.

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.

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

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

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.

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

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!

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.

Mike Cross:Really? 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

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

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

Student or Passenger
 

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.

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?