How do you get "a much better indication"?

I agree with that, and flyability is an issue. However, there's nothing difficult about setting up a safe trajectory into Egelsbach. You don't approach it down a valley. If you simply put in waypoints and calculate minimum levels to establish a 3 degree descent (preferably 4 degrees, but 3 degrees doesn't hit anything) then you fly a safe trajectory. That the Citation crew did not do that contributed to their demise. It would be possible to put an LPV into 27 at EDFE as far as the final approach segment goes: the problem is the missed approach segment and the conflict with 18 departures from EDDF, which is why there is no published approach.

Well on my aircraft, at least, it tells me if I am outside a guaranteed safe vertical and horizontal profile, when I have reached the MAP and shows my position on a geo-referenced approach plate.

Your other point is very interesting :ok:: I didn't know the reason for the lack of an IAP at Egelsbach. Given the point you make, I suppose it would have made for an interesting situation had the Citation flown what I assumed to have been a home made approach and then gone missed. Would they have ended up conflicted with EDDF traffic?

In practice, with the performance of a Citation, no more practical risk of that than a missed approach in good VFR by day I would think. The EDDF CTR starts about a mile beyond the end of the runway. So turn away to the south and climb to about 1400 ft. But almost impossible to construct a turning missed approach in compliance with PANS-OPS, which assumes a 2.5% climb (150 ft per nm). I wouldn't be surprised if a Citation could exceed that by a factor of 5 to 10.

Thanks for that!!

I recently chatted to a few IR and IR(r) students at various schools around London, some at fields without any published approaches over the last few weeks.

I was absolutely horrified when several of them told me that they had been taught to follow a "set of instructions to get back to the field safely in marginal conditions" which involved following radials from nearby VOR/DME. I asked how low they descended, and they told me a figure that sounded too low to be above MSA in these areas. I looked at them and paused for a minute... before asking what the MSA was in the area...

I am not only horrified to find out how many people would descend below MSA, but also at the fact that they were TAUGHT this! I find it absolutely crazy!

I then prompted them about doing a cloud break at a nearby aerodrome, and continue VFR, VMC the whole way back (note the difference between scud running); and some just retorted "why?" And others saying that they didn't even know they could do this!

I find this VERY worrying.

Anyone else think that this may be a good time to press the UK CAA to make GPS approaches more widely available at smaller airfields with/without ATC and make it more affordable paperwork-wise due to the HUGE safety increase provided? More and more IR/ IR(r) training planes being equipped with G430 / G430W / other glass - is it not time to start making approaches in the UK more widely available?

I'm a bit surprised that you didn't realise the reality.

Yes GPS works to a different accuracy to old radio nav kit. The sooner the CAA gets modern approaches to more airfields the better.

Good Business Sense:
Class G or class A it makes no difference. You cannot descend below the altitude approved by the state, which is either your safety altitude or the aerodrome minima if landing.

"Aerodrome" is defined in the regs as anywhere intended to be used for the arrival, departure or surface movement of aircraft.

ShyTorque:

I expect everyone understands 5015. What seems to be eluding you for some reason is that 5015 does not allow you ignore all the other regulations. SERA is not a complete stand-alone set of regulations, it is only a common core. If you go to the ANO and/or Part-NCO you find the other stuff a private pilot has to comply with.

Let's call it what it is then. It is how the competent authority interprets their own legal definition :ok:

Here it is again:

"User-defined approaches can be dangerous and are not authorised."

And here are the current regs again:

ANO:

For flights under Instrument Flight Rules, the pilot in command must select and use aerodrome operating minima for each departure, destination and destination alternate aerodrome which must not be lower than those notified, prescribed or otherwise designated by the relevant competent authority

Part-NCO:

For instrument flight rules (IFR) flights, the pilot-in-command shall select and use aerodrome operating minima for each departure, destination and alternate aerodrome. Such minima shall not be lower than those established by the State in which the aerodrome is located, except when specifically approved by that State

And here is the ICAO stuff it is based on:

ICAO Annex 6 2.2.2.2 Aerodrome operating minima:

The pilot-in-command shall not operate to or from an aerodrome using operating minima lower than those which may be established for that aerodrome by the State in which it is located, except with the specific approval of that State.

2.2.4.7.2 Aeroplanes operated in accordance with the instrument flight rules shall comply with the instrument approach procedures approved by the State in which the aerodrome is located.

Note that in no case is there a caveat that made-up minima can be substituted for approved minima even if you really really intend to land.

Oggers, you are simply regurgitating what you wrote earlier. I do read the regulations, I'm very much aware of what they say.

I take it (looking at what you have written here and elsewhere on the forum) that you make most of your flights departing from a fully IFR equipped airfield, climbing to your MSA on a SID inside CAS and remaining so until your STAR and IFR letdown to a nicely lit runway. I have no issues with that although some don't have that privilege and there is a very different world outside of that type of operation.

Again, you are confusing the rules about airfield operating minima with other IFR rules. How do you think an IFR transit is done when operating from non-airfield sites?

Well I assumed that everyone was taught well enough to know what they SHOULD do. Especially at IR(R) level. Ie... Descend to MSA, if you still can't see anything - request cloud base at a local aerodrome, if it is high enough to maintain VFR below, do a cloud-break approach. Then decide whether to commit to the approach, or to continue to your original destination VFR in VMC at or above the approach's minimums.

Not "follow X radial of VOR Y and at Z nautical miles DME continue descending below MSA". That is NOT what anyone should EVER do.

But then again, about 80% of them had never heard of an SRA... Sooooo.... Maybe I once again had too much faith in the teaching. Don't these instructors get taught how to teach? Don't they have renewals?

Anyway... How can we attempt to lobby the UK CAA for safer approaches for ALL airfields? I think this is particularly important right now, as we seem to have more and more accidents relating to people doing their own "ad-hoc" approaches. I find it very worrying. If at least these pilots, irrespective of pressures, had an alternative, then maybe there would be fewer accidents.

oggers
 

In almost everything you've just quoted the word aerodrome is included, yet again. What if you don't use aerodromes, I'm being serious - many operations don't ! I guess if you're nowhere near an airport your references don't count - maybe that's why 5015 is a standalone section of law?

For my sins, amongst may other technical manuals and publications, I've assisted with the writing of large sections of air law for three different countries - I'm happy to be corrected by a decent argument but until then I'll stick to my view.

One last thing - do you have a reference in law for, "User-defined approaches can be dangerous and are not authorised"? I know it was in a GA safety leaflet (you know my opinion of it) but there is no back up reference for the statement in law. Now, whether you think it is good airmanship or not, where is the law that underpins it ?

We're obviously from different schools so I'll leave you to it. No need to respond to the questions above.

All the best

Apart from forced landings, all normal flying whether at London Airport or Farmer Giles' farm strip is at an 'aerodrome':

From ANO2016

I think this is where the definition of an aerodrome becomes important. If you don't use an aerodrome, then technically, you can't be flying. An aerodrome is usually defined as: "An aerodrome or airdrome is a location from which aircraft flight operations take place, regardless of whether they involve air cargo, passengers, or neither." So if you takeoff or land somewhere, where aircraft flight operations don't take place - well... They are technically taking place during your event (as your event of takeoff / landing is construed as a "flight operation"), and therefore would be bound by the same rules and regulations.

I am not an expert in law, nor in Instrument Flight Rules, nor do I wish to entertain the possibility of having someone who is properly trained to fly under IFR, do something so reckless and dangerous. IAP exist for a reason, they are very stringent for a reason. The scary thing is that we all know the reasons why - and yet we are still discussing and entertaining this possibility as a "normal" occurrence which I find greatly worrying!

I think you will find that you have ample available reading regarding MSA.

It's important not to pull words out that you like from a sentence/para - it needs to be read in full i.e. in context - below para C helps my point - i.e. even a disused airport does not count ?

“Aerodrome”—

(a) means any area of land or water designed, equipped, set apart or commonly used for affording facilities for the landing and departure of aircraft; and

(b) includes any area or space, whether on the ground, on the roof of a building or elsewhere, which is designed, equipped or set apart for affording facilities for the landing and departure of aircraft capable of descending or climbing vertically; but

(c) does not include any area the use of which for affording facilities for the landing and departure of aircraft has been abandoned and has not been resumed;

For example, there are many more, when a police helicopter lands in a field or on a road or when a rescue helicopter lands on a rock shelf half way up a mountain does that make it an aerodrome .... I would say no as it's ;

not designed for;
not equipped for;
not set apart for;
not affording facilities for;


For info MSA

One Definition;

The Minimum Sector Altitude (MSA) is the lowest altitude which may be used which will provide a minimum clearance of 300 m (1 000 ft) above all objects located in the area contained within a sector of a circle of 46 km (25 NM) radius centred on a radio aid to navigation.

- Normally quoted around an airfield (found at the top of most IFR charts) - sometimes cut into different sectors with different altitudes quoted.

But.... The landing or departure of aircraft HAS been resumed - because you have landed there, despite it generally being marked as "disused".

One could argue - even in your rather extreme case, that if nothing else, the aircraft (irrespective of type) has been able to land, therefore, in context, as you suggest, the landing site chosen "afforded" the aircraft thus being a suitable location for such purpose.

ps: sorry for splitting hairs - this doesn't amend the fact that MSA in the "class G, IR(R) world" generally means Minimum Safety Altitude, which relates to being at least 1000' above the highest obstacle within 5nm of track.

Alex90

?

Happens hundreds of times per week in the UK

Re. splitting hairs - in the Commercial Class G IR world MSA relates to my post above and has nothing to do with class G per se and, as far as I'm aware, there is no official term such as "Minimum Safety Altitude" i.e. no definition, ICAO or otherwise. I'm sure many people use these aberrations in various ways but they mean nothing in themselves and they are incorrect.

Once again, the importance of quoting the entire law i.e. all the text ..... The RULE is as follows .... you've left out ..... "Except when necessary for take-off or landing"

SERA.5015 Instrument flight rules (IFR) — Rules applicable to all IFR flights
(b) Minimum levels
Except when necessary for take-off or landing, or except when specifically authorised by the competent authority, an IFR flight shall be flown at a level which is not below the minimum flight altitude established by the State whose territory is overflown, or, where no such minimum flight altitude has been established:
(1) over high terrain or in mountainous areas, at a level which is at least 600 m (2 000 ft) above the highest obstacle located within 8 km of the estimated position of the aircraft;
(2) elsewhere than as specified in (1), at a level which is at least 300 m (1 000 ft) above the highest obstacle located within 8 km of the estimated position of the aircraft.


I think we've done this to death now - I'm done - happy landings

Good Business Sense:

As I pointed out when you posted that objection the first time, it is the generic term in the regulation for anywhere that you take-off or land.

Here is are the actual definition from ICAO:
And from SERA:
As far as the regulations about aerodrome minima go there is nothing in the regs that require the 'aerodrome' to be anything more than the place you intend to land, be it a field, or a flight deck. And in case you are wondering I am familiar with operating from such sites.

You and ShyTorque are both in error in believing that the regulations pertaining to aerodrome minima do not apply to sites that are not - to use the vernacular - 'airports'. But wouldn't it be a nice get out of jail card to play. 'Technically I didn't bust my minimums because I was actually making an approach for the purpose of landing iaw SERA 5015 in the field next to the airport and therefore minima do not apply'.

It makes no difference to me how many technical manuals or legal documents you claim to have written. It is the stuff you are writing here that is in error.

- Past tense

CAP793
The regular use of an area of land or water for aircraft take-offs and/or landings amounts, in law, to the establishment of an aerodrome.

Oggers, I refer you again to the text from the AAIB report I quoted in post #105.

There was no comment from the CAA on that recommendation and there has been no change under SERA to the regulations that were in force at that time.

Enjoy your airline flying and ILSs.

I think this is yet another of those arguments that will only be properly answered if someone ends up in court and a judge makes a ruling!

ShyTorque

You are really clutching at straws. That pre-dates all the current regs. What an AAIB inspector thought might have been legal in 2009 is a very tenuous basis for rejecting the current regulations and advice from the CAA that has all undergone a major change since the report's recommendation to close off that particular loophole. It doesn't occur to you that the recommendation was acted on or perhaps rendered moot by the intro of EASA Ops.

This thread is about unpublished let-downs for private pilots. There is no confusion, the regulations on aerodrome minima apply to IFR approaches (whether the 'aerodrome' happens to be a field or a proper airport). This from the UK AIP has not previously been "regurgitated":

4.12 Aerodromes Without Published Instrument Approach Procedures
4.12.1

For an aircraft landing at an aerodrome without an instrument approach procedure either:

a. a descent should be made in VMC until in visual contact with the ground, then fly to the destination; or

b. an IAP at a nearby aerodrome should be flown and proceed as in (a); or

c. if neither (a) nor (b) is possible, first obtain an accurate fix and then descend not lower than 1,000 ft above the highest obstacle within 5 NM (8 km) of the aircraft. If visual contact (as at (a) above) has not been established at this height, the aircraft should divert to a suitable alternate with a published instrument approach procedure.

I don't see how the CAA could spell it out any more clearly than that.:ugh:

Good Business Sense

Ha! You are having a laugh! The definition in SERA and ICAO annex 6 is current.

I see what you have done though, you have conflated what constitutes an aerodrome for the purposes of licensing (CAP793) with what constitutes an aerodrome for the purposes of determining aerodrome minima. I salute your audacity :ok:

...but what constitutes an aerodrome for the purpose of determining aerodrome minima is still any place used for the departure, approach or surface movement of aircraft. As per the still current definition used in Part-NCO as well as SERA and ICAO annex 6.

It's EASA Air Ops that's the issue here. Allow me to quote some snippets:

CAT.OP.MPA.125 Instrument departure and approach procedures
(a) The operator shall ensure that instrument departure and approach procedures established by the State of the aerodrome are used.
(b) Notwithstanding (a), the commander may accept an ATC clearance to deviate from a published departure or arrival route, provided obstacle clearance criteria are observed and full account is taken of the operating conditions. In any case, the final approach shall be flown visually or in accordance with the established instrument approach procedures.

NCC.OP.115 Departure and approach procedures
(a) The pilot-in-command shall use the departure and approach procedures estab*lished by the State of the aerodrome, if such procedures have been published for the runway or FATO to be used.
(b) Notwithstanding (a), the pilot-in-command shall only accept an ATC clearance to deviate from a published procedure:
(1) provided that obstacle clearance criteria are observed and full account is taken of the operating conditions; or
(2) when being radar-vectored by an ATC unit.
(c) In any case, the final approach segment shall be flown visually or in accordance with the published approach procedures.

NCO.OP.115 Departure and approach procedures — aeroplanes and heli*copters
(a) The pilot-in-command shall use the departure and approach procedures estab*lished by the State of the aerodrome, if such procedures have been published for the runway or FATO to be used.
(b) The pilot-in-command may deviate from a published departure route, arrival route or approach procedure:
(1) provided obstacle clearance criteria can be observed, full account is taken of the operating conditions and any ATC clearance is adhered to; or
(2) when being radar-vectored by an ATC unit.

Note the conspicuous absence of NCO.OP.115(c). Just in case you think it's an accidental omission, here's the corresponding bit from SPO, which tends to deal with both complex motor-powered aircraft and non-complex aircraft:

SPO.OP.115 Departure and approach procedures — aeroplanes and heli*copters
(a) The pilot-in-command shall use the departure and approach procedures estab*lished by the State of the aerodrome, if such procedures have been published for the runway or FATO to be used.
(b) The pilot-in-command may deviate from a published departure route, arrival route or approach procedure:
(1) provided obstacle clearance criteria can be observed, full account is taken of the operating conditions and any ATC clearance is adhered to; or
(2) when being radar-vectored by an ATC unit.
(c) In the case of operations with complex motor-powered aircraft, the final approach segment shall be flown visually or in accordance with the published approach procedures.

I am with Foxmoth on this... Sounds like a neverending argument...

Law or not; Just don't be stupid. Value your life and those of others both in and out of the aircraft. Don't descend below MSA (irrespective of your definition) unless you're on an IAP or in VMC remaining visual until you touchdown.

HAVE COMMON SENSE. Live to fly, don't fly to die!!!

Yes bookworm I agree that part of the regs permits a deviation from published procedures which could be interpreted as permitting a user defined approach all the way from safety altitude to landing. I think it is the only place in the regs where the argument that non-approved approaches are legal has any basis. But the problem is it is contradicted by so much of the other regs and information from the CAA that I have already posted.

One thing that is definitely a red-herring is the notion that a landing site is not subject to the regs pertaining to aerodrome operating minima if it is not a proper airfield. And another red-herring is that ad-hoc descent below safety altitude in IMC is permitted on the basis of SERA 5015. But that one you posted above does on its own merit suggest that an unpublished let-down might be legal for non-complex, non-commercial operations.

That.

However much folks may argue about the legal interpretation of the rules & regulations, historically enforecement has generally been the province of a higher authority whose judgment is instant, final, unforgiving and not subject to appeal.

You've said that twice now, but I'm still waiting for an example where that instant, final, unforgiving judgment was passed on the design of the approach rather than its execution.

Oggers, again, you regurgitate the same wording that is available to all. Again, the term "should" has never prefaced a mandatory item.

"Should" indicates advice. If the wording read "shall" or "must" I would agree it was mandatory. But it doesn't, even under framework of SERA, which you rather strangely seem to think I haven't read.

The new regulations have had a very significant effect on certain parts of the U.K. industry. Thankfully the CAA have listened to the coal face in a number of areas and gave allowed certain easements. I'm grateful to have been asked for my personal input in a couple of areas in that regard. This (topic under discussion) is one area where SERA has not imposed further restrictions, despite Oggers thinking otherwise.

However, I most definitely wouldn't ever advise any pilot, "private" or otherwise (SERA doesn't differentiate, Oggers) to descend below MSA on a whim, for obvious safety reasons and I certainly would not do so. IFR flights need to be very carefully planned with nominated diversions found as necessary. That latter requirement remains in the ANO, but it rather strangely states:

"If, according to the information available, an aircraft would as regards any flight be required to be flown in accordance with the Instrument Flight Rules at the aerodrome of intended landing, the pilot in command of the aircraft must select before take-off a destination alternate aerodrome unless no suitable aerodrome suitable for that purpose is available.

The text I have quoted in bold would rather tend to lead a pilot into the very situation we are discussing! The only possible reason for that wording isn't immediately obvious, but it allows a pilot to use judgement on a forecast weather clearance, such as early morning fog. My personal judgement would be not to take such a risk.

That is a separate issue to the legality of a descent below MSA when necessary to do so in order to land, iaw SERA 5015.

What hasn't really been discussed fully is what constitutes a published approach/letdown and what doesn't. For example, the meaning, in legal terms, of "published". In the past I've been given details of a number of approaches designed and fully surveyed by a CAA recognised expert which the CAA has been fully aware of. You won't find them in any flight guide or the AIP. Some of them are for easily recognised airfields and some are not. Where might an approach be classed as "published" and where might it otherwise exist?

Bookworm, I think he's referring to final judgement passed by smiting the earth! ;)

But a published approach, flown badly, is also highly likely to suffer the same consequence.

The devil is usually in the execution (perhaps an appropriate choice of word in this case?). Sadly arguing about whether they crashed because of a failure in the design of a homemade approach, or its subsequent execution, doesn't change the fact that they're now dead.

There are plenty of examples of a badly executed approach where disaster has been averted only because of the additional safeguards built into operating in a properly regulated and controlled environment.