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Low Approach - SERA 3105/5005 - Germany

Steve6443 wrote:

Be grateful you’re on EuroGA
I am, otherwise I wouldn’t be here. Your story about the UK was just sad to read, I thought that it was a typical German thing to be a rule niggler, but it seems that other nations are good at it too. Just saying… Dutch people are also very good at it. Actually, after living now for 10 years in Germany, I’m convinced that the average German is way more relaxed than his/her reputation.

Steve6443 wrote:
Hmm… EDLW used to charge for a low approach, so it’s not as if EDDF couldn’t charge. Indeed, looking at the actual Landing Fees from Dortmund Airport, they’re still charging €3,50 per 1000kg MTOW or part thereof for an approach….. So if a low approach is indeed illegal, then EDLW have effectively decided to make a financial profit from an illegal act….
Well… I did several low approaches in EDLW in the past, but our aeroclub never got an invoice. I do know that EDLP sends an invoice per approach for many years. They charge a low approach almost the same, as a full stop landing. Very cheap however is EDVK, where you can do 5 landings (full-stop or T&G) for the price of 1. At least it was possible up to last year, but I guess, they didn’t change the “practice offer 5 for 1”.

At first, when I heard that EHAM doesn’t charge for T&G’s, I was very surprised. It was almost too good to be true. But it indeed was true and Eurocontrol even didn’t charge me for the approach fee. I guess EHAM is one of the most spectacular big airports in Europe with its 6 runways. It impressed me a lot and the Schiphol controller was a very relaxed guy.
Last Edited by Frans at 03 Jun 19:47
EDKM, LSZC

Arun wrote:

Today I asked EDDN tower for a low approach but was denied.

Interesting. Did that 6 weeks ago when I had the whole CTR for myself and got cleared immediately. Probably a new thing caused by the situation at EDDF.

EDQH, Germany

Patrick wrote:

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

Now I have written to EASA too. Thank you for the link @Patrick

huv
EKRK, Denmark

I just talked to a friend how has some insider information about the cases at EDDF. It seems to be indeed Fraport how started to report the low approaches since a few months. The DFS (German ATC Company) informed their Tower controllers about the cases, so low approaches might get refused in the future.

EDKM, LSZC

huv wrote:

Patrick wrote:
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
Now I have written to EASA too. Thank you for the link @Patrick

EASA Response:

Dear___,

With reference to the below information, we thank you for having provided the candidate issue form related to the provisions in SERA.3105, SERA.5005(f) and SERA.5015(b).

The Agency assessed the information provided in your notification and identified the need to issue additional guidance in order to provide clarity with regards to the interpretation of SERA.3105. This rulemaking action will be covered by rulemaking task RMT.0476 that is on the regular update of the standardized European rules of the air, and will result in an Agency Decision.

Should you have questions, please do not hesitate to contact us.

Best regards,

Impact Assessment Team
European Union Aviation Safety Agency
Hungriger Wolf (EDHF), Germany

Patrick wrote:

and will result in an Agency Decision

Which I guess means that they will make an AMC that states that the provision in the SERA paragraphs you mention is not intended to prohibit practise approaches. Or something like that.

ESKC (Uppsala/Sundbro), Sweden

Airborne_Again wrote:

Which I guess means that they will make an AMC that states that the provision in the SERA paragraphs you mention is not intended to prohibit practise approaches

That will be very interesting to see, what and how they formulate is. AMCs can lay out the law, but they can not correct the law.

When the law says “low approaches are not allowed except when acceptable” it is perfectly fine if an AMC lays out “acceptable cases with respect to this rule include e.g. practice approaches, …”. In this case the law, however, says “low approaches are not allowed”. It is not within the scope of an AMC to state “in contrast to what the law says, they are actually allowed in the following cases”.

They need to find a loophole…

Germany
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