The CAA notes that since 2014 the UK has exempted any aircraft being flown within UK class D airspace at or below 3,000 feet above mean sea level from SERA.5001 (VMC visibility and distance from cloud minima). This exemption applies when the aircraft is flying in accordance with specific conditions currently set out in Official Record Series 4 (ORS4) No 1282. The exemption will remain effective (as ORS4 No 1302) until 12 September 2019.
According to the CAA, in October 2018 the Department for Transport agreed to extending the exemption on the understanding that the UK would move to comply with SERA.5001 (VMC visibility and distance from cloud minima). As a result, the SERA.5001 distance from cloud minima will apply to class D airspace in the UK at or below 3,000 feet from 12 September 2019.
The CAA are proposing changes to the requirements to provide separation between Special VFR (SVFR) aircraft in certain circumstances. Specifically, the CAA propose to remove the requirement for an ATC unit to provide separation between SVFR aircraft in certain circumstances. As a result, SVFR flights would maintain separation from other SVFR flights through see and avoid principles. The CAA state that in effect this remains the same as flying VFR in accordance with the current UK exemption.
Of course, this means that where the cloud base is 3000’ or below, aircraft that wish to operate in a Class D CTR without an SVFR clearance must remain 1000 ft below cloud base, ie significantly closer to the underlying terrain.
The BGA is concerned that using SVFR to mitigate for the impact of removing the existing exemption means an extra workload and complication for controllers and for pilots. This is likely to result in;
– a reduced level of probability for GA aircraft being admitted to a Class D CTR under these conditions
– an increased likelihood of GA traffic routing around CTRs into choke points
– gliders being even less likely to request penetrating CTRs than currently is the case as they will be unable to comply with all controller instructions to achieve the necessary separations
There is no safety justification for removing the exemption; it appears to be a legislative tidying exercise that negatively impacts GA. Basic regulation flexibility provisions should be granted to permit continued exemption.
The issue further underlines the difficulties associated with excessively large volumes of class D airspace that are an increasing feature of the UK’s lower airspace; minimising the size and volume of controlled airspace to that actually required is an increasingly pressing need that is not being addressed.
Clubs and pilots who choose to respond to the consultation should do so before the 31st May 2019. The consultation and how to respond details are available here.