Low Approach - SERA 3105/5005 - Germany

gallois wrote:

What actually do you all mean by a low approach?

A “low approach” means that you make an approach but break off and go around instead of landing.

A “low pass” means that you make an approach but fly over the runway at low height instead of landing.

gallois wrote:

For those who believe a law is badly written and should be changed, I put out a challenge. Re-write the law, publish it here so it can be challenged by your peers and then if it’s good or acceptable to all

This is the EASA rulemaking process. The problem was for a long time they were not listening (“thank you for your comment. Closed”), and/or the people doing the drafting were simply incompetent.

This gave us legislation that was

• obviously wrong (for example, a CPL that had minimum multi-engine time requirements even if done on a single)
• contradictory (for example, CPL and ATPL contained PPL privileges (FCL.310 CPL / FCL.505 ATPL), but required a class 1 medical regardless (the original MED.A.030) so you could not exercise PPL privileges without a class 1 medical
• massively overburdened (e.g., the original Part-M)

All of the above were corrected by amending the legislation, but were in place for several years. Some authorities simply rolled their eyes and found workarounds, issued exemptions, or simply ignored the obvious errors, some enforced them (Germany for some time, I believe, withdrew people’s ATPLs / CPLs and reissued them as PPL).

gallois wrote:

For those who believe a law is badly written and should be changed, I put out a challenge. Re-write the law, publish it here so it can be challenged by your peers and then if it’s good or acceptable to all, we should send it to EASA’s Patrick Kye (I think he’s still there) and see if everyone there and their lawyers can agree to the changes

I have done that yesterday. Well, I didn’t send it to Patrick Ky in person, but I used the respective form (it came up in the German thread):

https://www.easa.europa.eu/rulemaking-proposal-candidate-issue-identification-form

I’ve tried to describe the safety risks involved in the ambiguity and in particular when pilots are starting to build their own work arounds (like announcing a landing and then “going around” unexpectedly) and have proposed to either change the wording in the relevant SERA paragraphs to not include exclude take-offs and landings, but also approaches to aerodromes. Alternatively, an AMC could clarify the wording as well.

Airborne_Again wrote:

A “low approach” means that you make an approach but break off and go around instead of landing.

A “low pass” means that you make an approach but fly over the runway at low height instead of landing.

Today I asked EDDN tower for a low approach but was denied. They offered touch-n-go instead. I asked wouldn’t that be ton of money and she said … maybe. I said no thanks. The lady offered ‘overfly >500’ AGL’, which I accepted.
I wonder if the correct phrase would have been ‘low pass’!

Arun wrote:

I wonder if the correct phrase would have been ‘low pass’!

“Top Gun pass” or “beat up” would be the correct RT :)

Above 500ft agl one can call it “circuit”: “low height circuit”, “bad weather circuit”…

UK ATC use “cleared for the low approach”, it still confusing as one is not sure what they are supposed to fly after (say their COM failed): IFR missed, IFR Omni/SID departure, join VFR circuit, another approach…however, everything should be clarified before reaching VFR short final or IFR IAF and maybe before starting engine: you have to book PPR slots by phone and explain what you want !

French ATC use “autorise pour l’option”, do whatever you wish and call when back above 1000ft agl

To me it seems that Euroga brings together a diverse group of pilots with a wide range of expertise. It draws on the thoughts of pilots from all over Europe and indeed from around the world. I don’t know what the number of people reading and contributing to the forum is, but I would not be surprised if it was larger than many of the organisations which already have a voice at EASA.
This is why I am suggesting, rather than to go it alone, suggestions could be debated here and then forwarded with the clout of this group of pilots behind it.
The reason I asked about what we are actually talking about is that here, and I don’t know if the DGAC has put forward differences or not, a remise de gaz (go around) is actually encouraged if you are in any doubt of a good landing and that go around can start at any time even down to a few feet above the tarmac.
You just announce it and do it. It would never be seen as illegal. It’s considered the safest reaction to any doubt. Read the weekly RECs on the FFA website.
To practice or cloud clear on IFR approaches to minima we ask for “the option” which allows us to decide at the last minute whether to go missed or not. It’s not a problem.
In this area, practice forced landing in a field is considered a good thing and where obstacles, animals and people allow we often to descend to about 50 to 100’ AGL.
As long as one is sensitive to others, it simply is not a problem.

Malibuflyer wrote:

What Germany actually did these days was a pragmatic remedy! They did not at all withdraw any ATPL/CPL but created the opportunity that affected pilots could give back their ATPL/CPL (voluntarily) and get a PPL if they wanted.

…which is was I wrote…

But this didn’t fix everything, though. For example, I have a CPL, but used it privately only so was relying on the Class 2 validity dates of the medical half of the time or more.

The UK CAA chose a different ‘workaround’ – every ATPL said ‘ATPL, CPL, PPL’ in the ‘title of licence’ section of the licence, in an apparent contravention to the principle that you can only have one part-FCL licence, arguing ‘it is really one licence, see, it is one piece of paper’.

Both approaches were better than simply ignoring it.

Malibuflyer wrote:

Here’s the final decision which is relating to this case.

Interesting. That case pre-dates the introduction of SERA by a couple of years.

Looks like under German air law, training approaches not intended to end in a landing (or touch-and-go) were prohibited at least since 1970 (article 6 of the LuftVO enacted in 1970).