View Full Version : BMAA News Item: BMAA Response to Southend ACP

18th December 2013, 12:39

Dave Smith
18th December 2013, 13:53
A very thorough response.

18th December 2013, 13:58
Ta, and the early version with Stansted in the header instead of Southend has been corrected. Thanks to eagle eyed Deepak.

18th December 2013, 15:10
Hi Geoff,

I read your excellent LSA airspace consultation with interest. Thanks for your work and representation.

Though now when I read your response number 014 within the table of responses, Im a little confused on the definition of Special VFR in the context of the NPPL(M).

As I understood it, SVFR was requesting VFR clearance to access class A airspace, whereas if we request a transit through class D (going over the top of Luton for example), this is a transit treated as standard minima.

I must admit my understanding of SVFR has always been a bit confused. You are saying (in the consultation response) that a class D transit is effectively SVFR, is that correct? I have read and heard various things (which may be of dubious credibility some of it possibly gleaned from the GA community which may not be applicable to NPPL) implying that there is a difference between a standard class D transit and a SVFR transit.

It is kind of a moot point from my perspective since I would never bother asking for a transit unless the visibility is really good, but I admit to being a little confused by the rules!

18th December 2013, 15:36
Hi Andy,
The European Air Law changes planned for late 2014 change the definition of SVFR. SVFR becomes a special approval to fly VFR when conditions otherwise would not allow. In Class D airspace min visibility for VMC is 5Km. The new rules would allow a SVFR clearance if, for example, the visibility was actually only 4KM. However the national licences, the PPL M and the NPPL, do not allow the holder to accept a SVFR clearance if the visibility is less than 10Km. There is a certain exception for the PPL M that does not apply to the NPPL. Additionally the European rules require a minimum height above ground level of 500 feet and in Class D a minimum distance vertically from cloud of 1000 feet. This means that you would need at least 2000 feet cloud base to sensibly transit through Class D. Of course you could be given a SVFR clearance to be closer than 1000 feet to the cloud base, but then you might be restricted by the visibility if less than 10Km.
To try to alleviate what could become a general problem for us in the future I have asked the UK CAA to remove the visibility minima from national licences, they are not applied to EASA licences. This will go some way to resolving the SVFR problem.

18th December 2013, 16:14
Thanks... As I thought, it's getting a little complicated /emoticons/smile.gif

The CAA seem to have taken this out of the CAA UK VFR flight guide... not sure why.

http://www.island-images.co.uk/ATC/zRon2012/UK%20Airspace.jpg (http://www.island-images.co.uk/ATC/zRon2012/UK%20strong/strongstrong/strongAirspace.jpg)

(please cut and paste the link.. forum doesn't like the % symbols)

Alan Batchelor
18th December 2013, 20:23

Good response thanks. There still appears to be a reference to Stansted in the document, in your table point 012 when referring to page 34. Did you mean Southend here?

best regards


18th December 2013, 21:44
Oh nuts!

Donald Walker
18th December 2013, 22:04

19th December 2013, 09:43
Fixed it.

Alan Batchelor
19th December 2013, 10:03
Thanks Geoff.

Let's hope the combined responses put paid to this imposition. Fingers crossed. I note that the GAA response suggests a Radio Mandatory Zone instead of Class D CAS - a much better solution than CAS if indeed a solution is needed.


19th December 2013, 12:29
I hope that this clumsy grab for airspace is seen for what it is. I would expect the CAA to reject the proposal with fairly strong words to LSA. When will the results become available?

Kevin Armstrong
5th January 2014, 20:29

Although not worth a fat lot, my congratulations on the superb work, and hearty thanks for the detail, clarity and tone of the response.

We may disagree on airworthiness policy but on this sort of issue your expertise and grasp is peerless, and I'm glad you are on the case.

Last year I pootled past Southend's centreline but clear of their zone, using Stoke as a waypojnt both ways en route to St Omer; the way out was a late summer Friday and return Sunday, at no stage were aircraft being routed in or out. Recall a Scottish Gentleman on ATC duty who was polite and professional, but remain baffled as to the reasoning behind this over the top proposal. Strong possibility of an increase in Stansted airspace busts, as unless you have a GPS on board pinpoint accuracy can be difficult for those unfamiliar with the area, or who only go through once or twice a year, as I do.

Even with GPS, careful height-keeping with a decent buffer under the LTMA near Boreham, going Southwards saw a large CAT passing left to right on the nose a couple of miles away, obviously going into Stansted. He was low at 2000' despite zone height on chart being 2,500, so routed a bit more to the left for comfort. This wouldn't be as easy under the proposal.



Alan Batchelor
28th January 2014, 12:59
Geoff Weighell wrote: .... In Class D airspace min visibility for VMC is 5Km. The new rules would allow a SVFR clearance if, for example, the visibility was actually only 4KM. However the national licences, the PPL M and the NPPL, do not allow the holder to accept a SVFR clearance if the visibility is less than 10Km. There is a certain exception for the PPL M that does not apply to the NPPL....
Geoff What is this exemption or exception for us wrinklies who are holding on to our PPLA (D) licences, which doesn't apply to the NPPL?


28th January 2014, 17:00
The PPL M allows the holder to accept a SVFR clearance in less than 10 km visibility in accordance with specified local arrangements on on specified routes. An example is the Fairoaks ATZ part of which lies within Heathrow CTR which is Class A airspace. An aircraft flying within that zone is complying with SVFR if able to maintain 3 km. The holder of a NPPL cannot fly within the same airspace in less than 10 km because they must have at least 10 km for SVFR flight without exception.

Alan Batchelor
28th January 2014, 17:18
Ok Geoff.

Thanks for that. It might just be useful if or when Southend gets it's Class D zone!



Alan Batchelor
10th March 2014, 12:27
The sponsor report on the Southend Airspace Proposal consultation is published here:

http://ripassetseu.s3.amazonaws.com/www.southendairport.com/_files/documents/mar_14/SOUTHEND__1393932493_Consultation_Report_Issue_1_1 .pdf

Usual dismissive stuff!


10th March 2014, 17:00
As expected a pre-determined report to be followed up by a "detailed review" which, to nobodies suprise will almost certainly produce a result which has already been written.

It does seem a faily typical "consultation".


10th March 2014, 17:01
Can't blame them, they've got an advocacy job to do. The CAA decision-makers however...