Nice catch, huv. I can use that.
I guess the two important questions are:
We should be living in the UK before EASA’s SERA, where an equivalent exemption was in the rules…
Cobalt wrote:
equivalent exemption
Was it actually written down, then? Could I have chapter and verse, to send to the CAA? There must be a proportionality argument if it used to be OK and there have been no incidents.
How long has that regulation been in force?
I have no idea. I just stumbled over the CAR in some printed presentation of ICAO differences when looking for something completely different. I believe the presentation was from 2012.
Have there been any accidents or incidents as a result?
I have never heard of an ac- or incident with this sort of activity, either.
From a risk point of view, I see this as comparably to, but arguably somewhat less risky than, going around due to not becoming visual on minimums after an approach with the intention to land. Even when perfectly flown, such missed approaches are of course performed frequently, due to either
The less risky part with a training-exemption from the ban should be that it is performed in a training environment, and that the temptation to “go a little lower to have a look” is just not there, because the aim is not to land.
turns out – I was wrong.
The pre-EASA Rules of the Air Regulations 2007 had an exemption from all general low flying rules (e.g., 500ft away from any person etc.; 1000ft above congested areas and all the other detail) for aircraft practicing approaches to a licensed aerodrome,
The IFR 1000ft-rule only had an exemption for take-off and landing, and if “the aircraft flies on a route notified for the purposes of this rule;” I have no idea whether published instrument approaches were such procedures or not.
So the letter of SERA prohibits VFR practice approaches that don’t end in a landing, which were allowed under UK rules of the air, and the letter of SERA prohibits practice IFR approaches, which may or may not have been allowed depending on whether the approach procedure is “notified for the purposes of this rule”..
However, the UK CAA has issued an exemption to SERA, in particular
The Civil Aviation Authority permits, under paragraphs SERA.3105, SERA.5005(f) and SERA.5015(b), an aircraft to fly below the heights specified in SERA.5005(f) and SERA.5015(b) if it is flying in accordance with normal aviation practices and
a) practising approaches to land at or checking navigational aids or procedures at a Government or licensed aerodrome;
b) practising forced landings if it is not flown closer than 150 metres (500 feet) to any person, vessel, vehicle or structure; or
c) flying in accordance with a notified procedure or when specifically authorised by the CAA in accordance with SERA.5015(b).
SERA 5015(b) is the 1000ft-rule in IFR, so practice approaches are fine in the UK.
Cobalt, are you sure the exemption is about approach minimums?
The subject and the title of 5015(b) is Minimum levels and I get the feeling that it is a stretch to understand this as including instrument approaches and exemptions to RVR requirements.
@huv,
There is nothing in SERA about approach minima; just about minimum height rules in general; so this exemption allows you to go below 1000ft above the highest obstacle with 8km when flying IFR for practice approaches, while SERA only allows you to do so only for landing and taking off.
I agree this is not really relevant; but there is the slightly arcane point that the EASA forgot about training / practice approaches when writing these rules, effectively banning what is neccessary for safety.
