must obtain information from the flight information centre to enable the flight to be conducted safely within the aerodrome traffic zone
Which raises the question, what information do we actually need to be safe?
QFE/QNH? Clearly not if we’ve been paying attention en-route and/or have a GPS receiver, or if we’re able to judge height by gawping out of the window instead of fiddling with our panel knobs and TV screens.
Wind? A guess will be good enough for government work. Frankly, I couldn’t care less what a FISO or ATCO thinks the wind is at his or her measuring station.
Runway in use? Well, that’s usually blitheringly obvious, but not always. Some airfields switch runways just to share the joy of departing traffic among the neighbours.
Traffic/birds/drones? We’re not going to quit looking out of the window just because a FISO says “no known traffic to affect”. Nor, when she says “land at your discretion” does that imply that it’s safe for us to do so.
Ah, a radio mandatory zone which is non mandatory. I hadn’t considered that possibility.
My bad.
Airborne_Again wrote:
It wouldn’t.
It would. But much is up to the “competent authority” here. In G we have TIA and TIZ airspaces. They are RMZ, and no alternate provisions are described except:
Realistically how many people are there who still fly non-radio? I live in Wales and don’t usually request a radio service but have a handheld with enough range for ATZs.
I have done so twice – once due to a failure in the air and once due to a fault found on the ground and not wanting to waste a day’s flying. I called up in advance, explained the situation and agreed to do an overhead join so I had time for a good look around before joining the circuit. This was at a very quiet (on that day) airfield with a/g radio only. I think it would have been foolish on a busy day or at a bigger airfield.
It was nice to have the legal option of flying without a radio, but not something I can imagine people doing much of in these days of cheap handhelds.
In about 1991 or so the US rationalized airspace to eliminate almost all redundant airspace definitions and use the (then new) ICAO defined classes A-F, unambiguously and without further subdivision. I think that change in Europe would be equally beneficial. Here’s some that should go away…
RMZ
TMZ
TMA
ATZ
CTA
CTR
For some reason there are still a couple of TRSAs in the US (it’s not clear to me why) and ‘ Mode C Veils’ which are now essentially TMZ/ADSBZs with a more descriptive name that now needs an update, but otherwise it’s much less confusing to have only A-F lettered airspace.
That aside, the way a pilot could indicate he has the required info at a non-ATC airport without having needed to establish two-way radio communication is to say so on his first radio call. I cannot see how that would fail to meet the requirement as written. If the regulatory intent was to mandate two way radio contact, it should have been written that way. Maybe this has something to do with mandating two way radio contact on something called Air to Ground? The whole thing is silly regardless.
That aside, the way a pilot could indicate he has the required info at a non-ATC airport without having needed to establish two-way radio communication is to say so on his first radio call. I cannot see how that would fail to meet the requirement as written. If the regulatory intent was to mandate two way radio contact, it should have been written that way.
Couldn’t agree more, but a cynic might say that the new pronouncement that ATZ entry now requires what is effectively a personalised clearance, will provide plenty of fodder for infringement statistics and the Gasco courses.
TMA, CTA and CTR are just more specific names, they are Class D – A, nobody needs to know what they are, so they don’t belong on that list.
And we should be grateful for the RMZ and TMZ, because all other options (class D airspace or above) are more restrictive
I’m glad nobody needs to know what CTR etc means, because I have no idea 
The basic principle should be that if concepts and names aren’t necessary, eliminate them. Class E airspace seems to be a pretty good solution to airspace requiring less ATC interaction etc than Class D airspace which should in turn be run properly, not like Class C or above.
I think there are three levels of communication and airspace authorization that can apply:
1) Pilot must obtain the airport info by any means before entering the airspace but does not need to demonstrate how he got it, nor to establish two way radio communication
2) Two way communication must be established to obtain the info, after which he can enter the airspace
3) A clearance is necessary in addition to two way radio communication
Number 1 is how the regulation in this UK case is written and is roughly equivalent to the FARs covering US uncontrolled airports in Class E airspace. Number 2 is roughly equivalent to US Class D or C airspace, number 3 is roughly equivalent to Class B airspace. Why anybody might attempt to interpret this UK regulation to indicate that entry requirements for an uncontrolled field are equivalent to those of Class B airspace I have no idea.
Silvaire wrote:
I think there are three levels of communication and airspace authorization that can apply:
It depends what the purpose is. It’s not clear to me what purpose you are thinking about. IMO the main purpose of airspaces is separation and traffic flow. Pilots are generally good at this on their own, but it requires that they communicate. You need to know position and intention of the planes around you. Hence G and RMZ is all that is needed, in principle. At some point though, it’s better to have a separate unit/person to have the total oversight, and a step further is controlled flight.
I’ve read rule 11 until I’m blue in the face and there’s no way I can interpret the requirement to receive information as requiring two-way radio contact, or form a view that being told to standby by an AFISO means that I cannot enter an ATZ.
Clearly I make a call before reaching the ATZ boundary when inbound to one of these fields, and would not dream of transiting their ATZ without calling. But when inbound the call is not always answered immediately (or with an A/G service, even at all) and I have never considered the ATZ boundary to be a line I cannot cross without having a two-way exchange vis a vis the QNH and runway in use.
What makes their interpretation untenable, in my view, is the similar wording (paragraph 4 of rule 11) for when an A/G service is provided rather than AFIS. Plenty of A/G services are often only manned some of the time – and this is not a formalised thing with hours that it is and isn’t manned, it’s just that sometimes you get no reply because no-one is near the radio or they’re busy doing something else and you carry on as normal. Often it reverts to effectively air-to-air, and one pilot might pass another the QNH and runway in use, but even if you hear nothing at all you just carry on. You certainly don’t refrain from entering the ATZ because you’ve not managed to get two-way with the person on the ground.
For their interpretation to hold water they need more explicit wording in paragraph 3 rather than essentially the same stuff as paragraph 4.
My deduction is that the whole thing is being driven by the AFISOs at Barton. They have a busy place to run and in order to lessen the chaos from their perspective they would like the ATZ boundary to be a barrier that no-one can cross without a clearance from them. Of course it is not a clearance technically, but it is in practical terms because they can deny entry at will just by saying standby. They’ve decided this is the system they’d like, tried to back it up with an ‘interesting’ interpretation of rule 11, and pretty much implemented it.
I wonder what the right places are to make representations about this?
