I was shown this local copy proposed amendment to the Swedish national regulation last week and thought I would pass it along.
In the consequences document local copy they explain that they see the current regulations as being clear as to when instrument approaches can be used but due to the accident investigations board suggestion they have produced this amendment. It seems like they are making the assumption that the regulation already prohibits instrument approaches in class-g but in their proposal, they make it explicit. There they propose that instrument procedure may only if, at a minimum, a Traffic Information Zone exists. The regulation may be commented on until 11 July.
The Royal Swedish Aeroclub (national organisation of Swedish aeroclubs) and AOPA-Sweden are writing a joint (and quite negative) comment on the proposal. I’m one of the authors.
Our main points will be that the proposal goes counter to EASAs GA Roadmap and stated intentions of having more GPS-based approaches to smaller airports and also that the proposal includes operational rules which national authorities can’t make, given that there is already an EU Ops Regulation.
We invite other organisations to sign the comment.
It is also “interesting” to note that the consequence analysis doesn’t consider light GA at all.
Point 17a is also interesting considering what TS claims as being the background to the decision (a conflict between IFR/VFR traffic) since they make an exception for “socially important” flights. Nothing would prevent VFR traffic from flying under the clouds within their approaches yet they will continue allowing HEMS, ambulance flights, etc. to continue flying instrument approaches in G airspace.
The Swedish authority just withdrew their proposal, “for further internal discussions”. We’ve heard rumours about internal opposition to the proposal.
Just out of curiosity, what would actually change?
LeSving wrote:
Just out of curiosity, what would actually change?
Several things would have changed:
There were some good things in the proposal regarding Point-in-Space (PinS) instrument approaches for helicopters in ops important to society, e.g. medical ops. But that was needed only because of the other points above.
Not sure where does this sit with EASA/NCO & EGNOS roadmap for GA
In any case individual countries can’t override NCO rules which explicitly allow uncontrolled IFR without ATS including for takeoffs/landings operations, this may not be sugar coated enough for everybody taste to swallow (I am sure lot of people will change their minds as time evolve, just like when GPS was introduced for approaches initially it was Alaska cowboy flying, then first legal published GPS IAP in Alaska for CAT in 2000, then it went into every CAT operation manual with specific NAA authorizations in 2010, now it’s worldwide ICAO thingy with mandatory PBN signoff in 2020, and I see load of low hours PA28 pilots flying Sywell RNP with barely 75h total
Obviously, NAA can easily make uncontrolled IFR impossible (just put MAX DCT = 0NM outside STARs/IAPs/SIDs for IFR in Class G 
)
Ibra wrote:
Not sure where does this sit with EASA/NCO & EGNOS roadmap for GA
It doesn’t – which I’m sure was a major reason why the proposal was withdrawn. I would have loved to be a fly on the wall at the Swedish Transport Agency.
Obviously, NAA can easily make uncontrolled IFR impossible (just put MAX DCT = 0NM outside STARs/IAPs/SIDs for IFR in Class G )
Yes, that’s the kind of thing I mean by “practical difficulties”.
Interesting. My regard for the Norwegian CAA is at an all time low ATM, and it’s because of slightly similar things. It seems they just make up stuff instead of operating within their own regulations, which is EASA regulations in these cases. It’s as if they don’t know the regulations themselves, or “pretend” it doesn’t apply to them, as if they think they can pick and choose. Anyway, could you say a bit more about where in Part-NCO this is found?
LeSving wrote:
Anyway, could you say a bit more about where in Part-NCO this is found?
It is not found explicitly, since everything not forbidden is allowed. But you can compare the paragraphs in part-NCO about use of airports and instrument procedures with the corresponding paragraphs in part-CAT to see what part-CAT requires but part-NCO does not. There is also an upcoming proposed change to part-NCO that will clarify this.
