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EASA points out that defacto restricted areas must be published in AIP/NOTAM

gallois wrote:

That’s my point. The height limitations above towns and cities are dependent on size as explained in the AIP and marked and detailed on charts.

Sorry, the “glide clear” rules was kind of always there, it is a universal rule for any EASA country, I thought there is an extra restriction re: towns.
And regarding the reserves and sanctuaries – the question is if is legal to fly through the area.
- If it is legal, then you mark it any colour you want, the pilot is not prosecuted.
- If the it is ILLEGAL to fly through a reserve area, then the country must document it in the AIP (AFAIK that is an ICAO requierement) and might publish it on the map.
And I think that is the nature of the EASA NPA.

EGTR

@arj1 France differs from the glide clear rule in that it gives actual altitudes for crossing certain built up areas.
IMO the rule is not there to protect you and your aircraft its there for the protection of third parties.
When you talk of whether something is legal or not you have to look at whose law you might be breaking.
In the case of reserves and sancturies the law is IMO called for by local public representatives who have been called upon to protect an area of land, animals, people or ways of life. These areas might be restricted to whom and what can enter.eg no cars, no dogs, keep to footpaths.
There would be little point in banning cars motorbikes and dogs from an area if you allow light aircraft to fly overhead willy nilly frightening and killing any bird that dares take to the air. Public opinion would certainly be against you and you might well be prosecuted for damage. Now all these things have nothing really to do with rules of the air, unless of course you make it an RA adding more pages to AIP and another coloured box with hatched lines surrounding an area, where by now a little margin had been added just like CAS in the UK. When all it really needs is for pilots to accept that there are others in this world who don’t share a love of light aircraft. To fly responsibly. Its exactly the same with noise sensitive areas. There are people living near airfields who think that noisy little aircraft should be banned or banished to working hours. Enough complaints and the local authority start asking that pilots avoid flying over such and such a place or area. Pilots don’t pay much heed and ATS pay lip service and so the local authorities make an agreement to put a blue circle round the whole village instead.of a few houses at the centre. And as the village grows so does the blue circle. Now these blue circles are included on the VACS, so now the DSAC is involved and they must decide what to do when pilots infringe the circle. They can’t do nothing.Not only are they under pressure from the NIMBYs directly, the airfield owner is also under pressure to do more and so now the airfield owner needs to bring in restrictions and so that they do not have to cut their profits through shorter opening hours they put more pressure on the DSAC to be stronger on infringers than just making infringers write a REX for all to learn.
But now these blue circles are tantamount to RAs without real legal status. So along comes EASA and regulates that these blue circles should change colour and become RAs. Of course in the making they grow a little more and now they have full legal backing and the DSAC can say I’m sorry but we need to issue a penalty because you have infringed this airspace 2 or 3 times. Yes we understand how difficult it can get in high crosswinds and parallel runways operating with different speed aircraft. But its the EU that are making us do this.
And all it really needed was for pilots to be a little more thoughtful in the first place.
More care to avoid the centre of the village, perhaps not using very noisy aircraft near the village perhaps by using the other runway or avoiding the nice warm evenings or weekends when residents are enjoying their gardens.
Freedom and pilot responsibility must run together if GA is to avoid being regulated out of existence.

France

gallois wrote:

So along comes EASA and regulates that these blue circles should change colour and become RAs.

That regulation has been in place all along. There is nothing new there. Also, EASA didn’t mention this as a rationale for the new AMC. It was my personal comment.

ESKC (Uppsala/Sundbro), Sweden

What regulation has been in place for a long time?
The LFPN blue circles have been there some time and AFAIK are still there today.
But any change to the regulation might well change this.

France

gallois wrote:

What regulation has been in place for a long time?

SERA.3105 Minimum heights
Except when necessary for take-off or landing, or except by permission from the competent authority, aircraft shall not be flown over the congested areas of cities, towns or settlements or over an open- air assembly of persons, unless at such a height as will permit, in the event of an emergency arising, a landing to be made without undue hazard to persons or property on the surface. The minimum heights for VFR flights shall be those specified in SERA.5005(f) and minimum levels for IFR flights shall be those specified in SERA.5015(b).

GM1 SERA.3105 Minimum heights
MINIMUM HEIGHTS ESTABLISHED BY THE COMPETENT AUTHORITY ABOVE THE REQUIRED MINIMUM HEIGHTS
In cases where it is considered that the minimum heights specified in SERA.5005 and SERA.5015 are not sufficient, the competent authority may establish appropriate structures, such as controlled, restricted or prohibited airspace, and define specific conditions through national arrangements. In all cases, the related Aeronautical Information Publication (AIP) and charts should be made easy to comprehend for airspace users

ESKC (Uppsala/Sundbro), Sweden

I am aware of that regulation but that has nothing to do with the blue circles at LFPN.
The blue circles come more into play on initial climb and final approach.
Those particular regulations or at least the 2nd paragraph
“not sufficient, the competent authority may establish appropriate structures, such as controlled, restricted or prohibited airspace, and define specific conditions through national arrangements. In all cases, the related Aeronautical Information Publication (AIP) and charts should be made easy to comprehend for airspace users”
Note the “such as” .
And the height limits above towns and cities are clearly mentioned in AIPs and on the charts.
I really see big risk in introducing changes to this area of existing legislation.
IMO the wording leaves an open door to much more controlled, restricted or prohibited airspace. And GA in general seems to be encouraging this.
Some regulation is of course necessary but instead of “freedom to fly”. We seem to be more concentrated on confirming whether something has been announced as legal or not. The ‘i’ s have to be dotted and the ’t’s crossed. All laws have a deal of ambiguity until they have been tested in court. Otherwise there would be no need for lawyers.
If you want young people to get turned on by GA instead of all sorts of other hobbies there must be a logical reason for any regulatory change, there must be common sense behind each regulation. As non professional pilots should stop worrying about the minutiae of regulations, plan properly and just fly.

France

arj1 wrote:

Did you mean aviation is not affected by this restriction?

No, aviation is clearly affected. Min 300 m AGL. What I meant was that this has nothing to do with any aviation regulation (say EASA, ICAO or whatever). It’s not restricted, it’s not prohibited, or any sort of aviation related special airspace, it’s just not allowed to fly below 300 m AGL because the national wild life bureau say so, and it’s in law form.

The elephant is the circulation
ENVA ENOP ENMO, Norway

LeSving wrote:

It’s not restricted, it’s not prohibited, or any sort of aviation related special airspace, it’s just not allowed to fly below 300 m AGL because the national wild life bureau say so, and it’s in law form.

In that case, Norway aviation authorities must include it in the AIP & charts, and say what are the rules. I know they are on the charts, just not sure if it says anywhere what that green area means.

EGTR

arj1 wrote:

In that case, Norway aviation authorities must include it in the AIP & charts

Not before it is in law form, which may take years, if it ever will But as I wrote further up, it’s already in the AIP (with detailed rules and all) and in the ICAO map. They are not prohibited, restricted or danger area according to aviation regulations. They are called protected areas (in the AIP), which is the correct name for other purposes also.

I have a feeling this is a bit more complicated than AA makes it. The purpose of these areas is not to restrict or prohibit GA or aviation in general. They are not there to protect aviation from danger. The purpose is to protect wild life. For SAR missions, which in Norway also is done by voluntary PPL pilots, the restrictions in these areas are obviously lifted/disregarded. These areas are common places where people are missing. Also, lots of GA is done in relation to protection of wild life and in relation to reindeers, and they will have to fly into these areas with no restrictions. Making these areas prohibited, which is the only thing they can become in aviation terms, will for most of it only create a whole lot of bureaucracy and nuisance and confusion, for minimal or no gain whatsoever.

The elephant is the circulation
ENVA ENOP ENMO, Norway

LeSving wrote:

I have a feeling this is a bit more complicated than AA makes it. The purpose of these areas is not to restrict or prohibit GA or aviation in general. They are not there to protect aviation from danger. The purpose is to protect wild life. For SAR missions, which in Norway also is done by voluntary PPL pilots, the restrictions in these areas are obviously lifted/disregarded. These areas are common places where people are missing. Also, lots of GA is done in relation to protection of wild life and in relation to reindeers, and they will have to fly into these areas with no restrictions. Making these areas prohibited, which is the only thing they can become in aviation terms, will for most of it only create a whole lot of bureaucracy and nuisance and confusion, for minimal or no gain whatsoever.

@LeSving, the right term would “restricted area” – it doesn’t mean you couldn’t fly there at all like in PA or DA, but there are some restrictions.

EGTR
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