UK CAA heel dragging on GPS approaches, including LPV, and approaches with no ATC, and CAP1122

Timothy wrote:

How ironic that I can’t get into a big tarmac runway because of a 500’/1500m visibility requirement, but I can get into the grass field nearby using the Visual Approach to whatever minima I choose.

As an Instrument pilot, where exactly would the 500’/1500m minima restrict your flying in the UK?

Anyway, coming back to what you said, it looks like the CAA is more objecting because of lack of infrastructure at the typical GA aerodromes (instrument runways, ATC) rather than the procedure design itself. Hence my question; it previously sounded like they faulted the procedure desgin.

Looking at Germany, well, the procedure design itself is also very rarely a problem. Egelsbach is one famous exception, where it is not possible to design an approach which doesn’t significantly imparing operations at EDDF.

Otherwise, it is usually the lack of Instrument runways at GA airfields. They have typically been built decades ago, in confined spaces, without paying Attention to These things. So, nowadays, the runways are too short, too narrow, the Taxiways are too close to the runway, there are obstacles, etc.

Hence the move to allowing basis Instrument approaches to non-Instrument runways. Austria has gone forward a lot on that, as the busiest GA airfields there now have these basic approaches. Germany is much slower in this regard, for some reason I don’t know.

Don’t know if these appraoches would be possible in the UK. Sure, they might not help you on OVC003 days, but it would the transition from enroute a much more orderly one.

The biggest problem of the UK I think is ATC and airspace structure. The requirement of having ATC for instrument approaches doesn’t exist in Germany and France. AFIS is enough. But Germany has the class E blanket, and “area ATC”. In the UK, the concept of area ATC is unknown. Instead, dozens of little “Islands” of ATC units across the country, all doing their thing, as we know. Very very costly, and very very inefficient. And no way of protecting IFR traffic on instrument approaches in IMC, due to almost no class E. The UK doesn’t seem to be able to go this way, although I am sure that they have had a very close look at the “German ATC model” many years ago and evaluated it. Sure, having no class E and lots of class G has its advantages, but overall, I think the German ATC model is the better one in this day and age.

I find Timothy’s posts very useful and reasonable, and I don’t agree much with the above. I don’t see him defending the CAA.

Back onto topic: I think the problem to get past with the CAA is that tacitly, the feeling is probably that if pilots crash on home made approaches, then that’s their fault, but if the CAA approves an approach with lighter regulation, and someone happens to crash, then it’s someone’s fault at the CAA. Like all civil service, I suspect the CAA’s modus operandi is “avoidance of error at all costs”, and the best way to avoid error is to simply do nothing then no one can blame you for anything.

I must admit I find Timothy’s position a bit confusing. Sometimes he’s saying we must fit in, not complain as the CAA are desperate to come down on us or get ga out of the way. Othertimes something needs to be done about it.

The lack of GPS approaches really does seem like a missed opportunity to help GA and increase safety. Is it just a love of red tape within the CAA that is refusing to progress them.

boscomantico wrote:

As an Instrument pilot, where exactly would the 500’/1500m minima restrict your flying in the UK?

Um…in the Midlands every day Friday to Sunday, for example.

Off_Field wrote:

Sometimes he’s saying we must fit in, not complain as the CAA are desperate to come down on us or get ga out of the way. Othertimes something needs to be done about it.

That’s because the situation is never black and white. It is nuanced. The GA department of the CAA is generally very good (except where it comes to licence processing). AAA is doing a poor job with approaches. In the infringement discussion I just seek after truth. A lot of fantasies are given airtime but I see some of the reality of what goes on.

Timothy wrote:

The CAA announced many years ago (to much fanfare) that they were going to introduce a cheap, fast-track way of introducing RNP approaches to GA airfields without ATC and instrument runways.

Several airfields put in a lot of time, effort and money to make proposals and the CAA almost completely failed to deliver, until the various airfields fell by the wayside of CAA intransigence, delay and lack of understanding.

The principal problem is the CAA requiring mitigations and procedures which are unnecessary and largely unachievable outside controlled airspace. Things like radar coverage, holds etc. and demanding levels of precision quite out of proportion to the job in hand.

I think that the reason is that the CAA is very short of qualified staff and are therefore having to use inspectors who have little knowledge and experience of the risk environment of GA. These inspectors do not understand that the alternative to having an approach is scud-running and people dying (the CAA actually recommends scud running as the way to get into VFR fields in bad weather, even though they recognise CFIT as a major killer…go figure).

The tragedy at Dunkeswell which killed the Garvey family would have been avoided if there had been an approach, instead of Philip trying to get in between the trees and the clouds.

The problem is that the CAA “own” the risk of an approved approach going wrong, but refuse to accept responsibility for the consequences of their inaction.

They talk about the commercial designers not doing their jobs properly, but the truth is that those very designers are producing work acceptable to all the other NAAs. It is the CAA’s constant demands for tiny changes as a result of nugatory omissions or inaccuracies that is resulting in the designers now turning down any potential contracts which will involve CAA oversight, because they know they will lose money on them.

What we need is a pragmatic and risk based approach, as seen over most of Europe. Let’s face it, with the DHs that the CAA is placing on new LPV approaches, we may as well use SkyDemon to get us roughly in the right place. The CAA is treating the LPV approach as a cloudbreak to VMC. Which is also failing to get the point that a higher DH is not safer. They are not comparing the risks of letting someone go down to 200’ to those of go-arounds, missed approaches and diversions in a single crew environment. There is no risk-based thinking going on.

And the upshot?

This map shows the current EGNOS based approaches in Europe:

How do they keep their jobs?

In some ways, my current thinking is that maybe we should not have any more instrument approaches to VFR airfields, because the CAA is dealing with it with such incompetence that we are better off to use our GNSS boxes to make unregulated approaches, which are not subject to any minima, rather than be limited to the ridiculously high minima they are setting (which then become law).

How ironic that I can’t get into a big tarmac runway because of a 500’/1500m visibility requirement, but I can get into the grass field nearby using the Visual Approach to whatever minima I choose.

The CAA need some serious education in GA.

A complicated and convoluted explanation that no one can verify.

boscomantico wrote:

The biggest problem of the UK I think is ATC and airspace structure. The requirement of having ATC for instrument approaches doesn’t exist in Germany and France. AFIS is enough. But Germany has the class E blanket, and “area ATC”. In the UK, the concept of area ATC is unknown. Instead, dozens of little “Islands” of ATC units across the country, all doing their thing, as we know. Very very costly, and very very inefficient.

A simple and intuitive explanation that can be verified by anyone by looking at the maps.

Hmm, which one is correct?

I guess you’d have to ask whichever of us has been working on this for the last ten years.

Bos?

Peter wrote:

The key of course is the CAA requirement for full ATC. That is a massive fixed cost, which nobody wants. And that is the biggest obstacle to IAPs in the UK.

Is that definitely still so? I have been wondering how Shoreham IAPs are going to work on weekends when Shoreham are still going to be A/G. Interestingly the approach charts have a line there saying “A/G Shoreham Radio” and I haven’t seen any NOTAMs so far saying that instrument procedures will be unavailable this coming weekend, which is already the new AIRAC cycle with the IAPs in place but expected to be A/G service according to their website. Has there been a reevaluation of the requirement for full ATC?

You are closest to Shoreham so would expect you to hear about the weekend arrangement first…

EGNC used to only have their approaches available when full ATC and not available when A/G radio.

Part of CAP 1122 was the invitation to apply for an approach without ATC provided the risks are suitably mitigated. For example, the validation I am doing this week is at a FISO field.

I think all the applicants (except the Scillies) are in that position.

So ATC is not a relevant issue.