Airborne_Again, our readings are different. I really hope that you are right and I am wrong.
In some ways (the IMCR/IR(R), and IFR with no plan and no clearance, for example) it makes life very pleasant. In others (completely disjoint ATC, all privately operated by different agencies; uncurated lower airspace with no central architecture and planning) it is a terrible mess.
That is true but if it wasn’t for UK’s messy Class G setup, the IMCR could never exist, because it would be a full IR in all but name, which would be completely unacceptable politically – because Europe has always used the IR to separate the “real men” (I am being deliberately backward here – like most of the players in the regulatory system) from the sheep, to make sure very few of the sheep make it to an airliner cockpit.
And look at the success of the IMCR. Some 20,000 have been issued since 1969. That is nothing short of dramatic. The UK has a huge population of IFR capable pilots, whose accident record is outstanding (almost no CFITs, etc, when actually flying under IFR). How many “private IRs” have been issued during that time in the UK? The annual numbers have always been 10-20 a year. There was a blip one year when an organised group got a ground school discount (worth about 1 avgas refuel 
) from CATS and even though most of them never got anywhere with it in the long run, it probably doubled that year’s stats. A chunk of the annual numbers are airline pilots who just happened to show up as a PPL and an IR when counted, on their way to the CPL. Overall, the numbers were insignificant. Most did the N-reg route… probably a few hundred a year (must be very few today). The CB IR has done little or nothing to help, AFAICT, because it fails to address the basic issues.
Now look at the rest of Europe. No IMCR and like the UK almost no IRs. There are lots of N-regs, and a fair few Germans did the JAA IR. A total failure for private IFR… Actually most of Europe (by land area) has almost no GA of any kind…
This is off topic but which of the two is better for GA? The IMCR and the crappy ATS services and the backward attitudes in the present-day CAA, or no IMCR and almost no IFR GA activity.
Extra CAS in the UK would be a bad thing because it creates bottlenecks, which together with the large % who are determined to fly incognito and won’t show up on any TAS/TCAS / ADS-B IN system, creates a risky environment on nice weekends.
Airborne_Again wrote:
By definition, a control zone is controlled airspace that extends from the ground up.
FWIW, the phrase "control zone’ is as far as I can tell absent from US pilot training and has been since the US adopted ICAO lettered airspace classifications circa 1991. In the US, the radio-contact-mandatory airspace associated with a smaller tower controlled airport is termed “class D airspace associated with an airport”. There are no tower controlled airports without associated Class D or higher airspace. Class E airspace to the ground may extend from that Class D but does not require contact with the tower, for example for VFR traffic flying in VMC.
Airborne_Again wrote:
The lower limit of a control area can’t be lower than 700’ AGL, so if you want to protect the whole of the IAP you need a control zone.
But the actual class D control zone wouldn’t need to be any larger than the existing ATZ in that case. It wouldn’t be necessary to have a massive swathe of class D.
alioth wrote:
But the actual class D control zone wouldn’t need to be any larger than the existing ATZ in that case. It wouldn’t be necessary to have a massive swathe of class D.
That’s what I thought at first, but then Qalupalik showed that the UK regs consider an aircraft flying the IAP to be controlled the whole time. It all depends on the interpretation of “vicinity of the aerodrome” which is unfortunately poorly defined in the regs.
The USA doesn’t really differentiate between CTR, CTA and TMA concepts. In fact one could argue that a pilot doesn’t even need to know about the concept, but that there exists a volume of airspace…
That aside, I can’t see why the IAP can’t be contained entirely within Class E, with the Class D replacing the ATZ or having similar dimensions to it. The groups of people disappointed would probably be those operating in IMC non-radio…..
The provision of an approach service well outside the ATZ needs to be paid for somehow
Airports that have ATC in Class G today will need to update their procedures in the short term, but I don’t think they’d be that costly in the long term? Class E & D can return to G where ATC is part-time and have gone home.
In future, ATC doesn’t necessarily have to be based at the airport (which can be costly) but can come out of a shared pool of resources situated elsewhere. Smaller airports would need to negotiate a deal with a suitable ANSP for approach navigation service charges to be recovered.
Just remind me – what problem is this new regulation trying to solve?
I think it’s the harmonisation of ATS procedures in EASA states.
Airborne_Again wrote:
But that is not at all what ATS.TR.110 says! To put it another way, it says that whenever there is a CTA, CTR or controlled aerodrome, there shall be an ATC unit. (My italics.) It does not say that there has to be a CTR when there is an ATC unit. In fact enroute ATC units typically do not provide services within control zones at all!
Enroute ATC units provide an ATC service in a CTA. The definition of “controlled aerodrome” has been revised in Part-ATS:
(39b) ‘controlled aerodrome’ means an aerodrome at which air traffic control service is provided to aerodrome traffic within the controlled airspace associated with such aerodrome;
(39c) ‘controlled airspace’ means an airspace of defined dimensions within which air traffic control service is provided in accordance with the airspace classification;
The interpretation that an air traffic control service may only be provided within controlled airspace is not pedantry. It is the stated position of the European Commission.
bookworm wrote:
39b) ‘controlled aerodrome’ means an aerodrome at which air traffic control service is provided to aerodrome traffic within the controlled airspace associated with such aerodrome;With this definition, it is pretty clear that you need controlled airspace.
But this definition is different from the definition in SERA. If the Commission wants all controlled airports to have an associated controlled airspace, why don’t they just write that!
