I just checked ICAO Annex 2. It seems that neither EASA nor the UK has come up with anything new.
SERA.5001 seems to be taken straight out of Annex 2, and the UK ORS seems to be identical to the exemption UK has announced to ICAO a long time ago. (“Supplement to Annex 2 – Rules of the Air”).
So, nothing has happened. And harmonization has failed again.
Harmonisation of rules can only serve one sole purpose – giving certainty to pilots/operators that they know the rules they have to stick to, and don’t have to rummage through hundreds of pages of paper to find them.
So, in principle, allowing relaxation of rules nationally still achieves the objective of harmonisation, and hence isn’t a problem.
The only problem is the other way round – because then we would go back having to read 100’s of pages to make sure I follow the rules.
Also, this thing presumes that the rules are sensible in the first place. The funniest one: EASA regs for CPL were written in a way that technically required 6 hours multi-engine to take the CPL skill test, because somebody forgot to insert the words “If the skill test is taken in a multi-engine aircraft”.
- Some countries (e.g, Spain) enforced the rule and only issued CPL if the experience requirements were met - UK issued a formal exemption from the unintended rule - Most countries probably just ignored it until it was fixed a few years later.Cobalt wrote:
So, in principle, allowing relaxation of rules nationally still achieves the objective of harmonisation, and hence isn’t a problem.
Well, what about the pilot of that IFR flight popping out of the clouds at 1500 ft who thought that he would have 1000 ft or 1500 m between him and the VFR aircraft, but actually finds it right in front of him? Is that not a problem?
Jacko wrote:
I’m surely missing something, because I simply don’t understand this rationale. … I can’t imagine a situation where she would drop an A380 on top of me out of a fluffy white cloud just to see if I’m paying attention.
What you’re missing is that not dropping an A380 on top of you out of a fluffy white cloud means that the controller is separating you from the A380. So what you’re saying is that the controller already separates you from IFR traffic in class D. However…
alioth wrote:
To change this to the SERA rules would effectively prohibit VFR to most airports in the UK for about 350 days a year otherwise which would be a severe and intolerable constraint for most of GA (and cause serious capacity issues with everyone asking for SVFR clearances).
And it would cause serious capacity issues with everyone asking for SVFR clearances because that would mean that the controller would have to… wait for it… separate you from the IFR traffic.
So ATC operates the airspace in a way that assures separation, and the UK VMC minima are relaxed because it assumes that separation. But if you actually ask ATC to take responsibility for separation, that would cause serious capacity issues. Hmm.
bookworm wrote:
Well, what about the pilot of that IFR flight popping out of the clouds at 1500 ft who thought that he would have 1000 ft or 1500 m between him and the VFR aircraft, but actually finds it right in front of him? Is that not a problem?
In reality VFR traffic isn’t put onto the instrument approach (that’s pretty much the only place IFR traffic is going to be descending in class D at 1500 feet) so this won’t happen in UK class D airspace.
In reality UK class D is operated more like USA class B airspace. Perhaps one day airspace will be reorganized and simplfied but that’s an enormous job, and in the meantime it’s much more practical to put in the exception to SERA and operate UK class D as it’s operated for (safely) for many years, rather than completely screw over VFR traffic.
Incidentally, the cloud clearances for class D in the US are much more reasonable than what is specified in SERA, and IFR isn’t colliding with VFR in the US either. It’s all very well just taking a carbon copy of the ICAO VFR clearances and putting them in SERA, but one must remember a huge (most?) number of ICAO contracting states are authoritarian regimes with private flying almost non existent or banned altogether, so they won’t care about absurd cloud clearance requirements.
alioth wrote:
In reality VFR traffic isn’t put onto the instrument approach (that’s pretty much the only place IFR traffic is going to be descending in class D at 1500 feet) so this won’t happen in UK class D airspace.In reality UK class D is operated more like USA class B airspace.
Right. So they’re separated then. So why not label it “SVFR” rather than “VFR”.
Because SVFR is still different. Even USA class B has different rules for SVFR than normal VFR (where available, not all US class B airspace allows SVFR). Also I suspect ATC can actively stop separating you when you say “visual” with some traffic. With SVFR, the visibility can be poor enough that you will not get visual with traffic even just 4km away.
alioth wrote:
Also I suspect ATC can actively stop separating you when you say “visual” with some traffic.
Visual with the guy that’s just about to pop out of the bottom of the cloud, you mean?
With SVFR, the visibility can be poor enough that you will not get visual with traffic even just 4km away.
The visibility is the same whether you label it VFR or SVFR in the circumstances. We’re only dealing with cases with a vis > 5 km anyway.
bookworm wrote:
Visual with the guy that’s just about to pop out of the bottom of the cloud, you mean?
I think the point is that under radar control in Class D, this doesn’t happen often enough in the UK to offset the risk associated with overcrowding that SERA.5001 would cause in adjacent Class G.
It’s like repairing a railway. It’s safer for the engineers if we close the track and work in daylight, but if that creates overcrowding elsewhere in the network, the overall risk is worse.
After the IMCR debacle, and the way in which EASA tolerates some member states’ de-facto ban on GA precautionary landings, it’s anybody’s guess what the “S” in EASA really stands for. :(
I wish people would stop solving imaginary problems. These rules were operating safely for decades, without a single incident.
Separation is hugely misunderstood. Controllers do not knowingly put traffic in conflict. The main difference is that formal separation requires 3 to 5 nautical miles distance, depending on distance from the radar head, or only one aircraft in a procedure or in the control zone at the same time if procedural separation is provided; they have more leeway in Class D.
This is why Class D, while formally not providing separation of IFR from VFR traffic, is completely adequate. Under VFR, they can have four aircraft in the visual circuit. Under SVFR, only one, and he has to land when somebody else wants to fly an approach.
