IIRC from previous discussions in EuroGA, some authorities (Germany?) have held that planned go-arounds/missed approaches are illegal because you would descent below the enroute minimum altitude without the intention of landing.
Now EASA has proposed a change to the Guidance Material for the minimum altitude paragraph of SERA (SERA.3105) that will make it clear that this is, in fact, legal. (At least at “proper” airports.)
GM3 SERA.3105 Minimum Heights
TERMS OF TAKE-OFF AND LANDING
In the context of SERA.3105, the terms ‘take-off’ and ‘landing’ include operations such as touch-and-
go, go-around or missed approach performed to an aerodrome or operating site for which the
necessary obstacle clearance assessment was conducted and approved by the relevant competent
authorities
While it is good to have this statement, it would actually have been much better to change SERA.3105 rather than introducing somewhere in the guidance material that when SERA mentions “landing” they actually mean a lot of things which are clearly not a landing…
I can literally smell the first (Greek, or German ?) airport managers that start to lik their fingers and prepare some more invoices for low approaches or go arounds as EASA now states that such operations actually qualify as landings and hence a landing fee has to be payed.
Malibuflyer wrote:
I can literally smell the first (Greek, or German ?) airport managers that start to lik their fingers and prepare some more invoices for low approaches or go arounds as EASA now states that such operations actually qualify as landings and hence a landing fee has to be payed.
The GM does say that go-arounds/missed approaches only qualify as landings in the context of SERA.3105 (minimum altitudes).
Some airfields in France already charge for touch and goes, although, sometimes this is at a reduced rate.
Also all bodies such as the DGAC, DSAC, FFA, FFPULM actively encourage the go around and always have done. They do it because some pilots get it into their heads that they must land even if they are too fast, too slow, not stable, can’t see the runway because of the setting sun etc, leading to an accident.
So counteracting that thinking has always been the policy here. I am happy to see EASA catching up.
Most UK airports charge. They have to otherwise the PPL schools for many miles around will fly there for touch and goes and pay nothing while taking up the airspace 
The only solution is an airport which is general taxpayer funded/subsidised, or one with little traffic.
Does this mean that a T&G at LFAT will clear customs/immigration for France? I know the answer to that 
Touch and goes are usually charged (If the wheel touches the ground it’s a landing). Low approach not so far.
@Airborne:
Yes, that GM says that in context of SERA.3105 a go around is a landing. This is, however, no new rule but as it says “guidance material”. It is a hint how such a rule should have been read in the first place. When EASA says that if they write “landing” they actually mean “a lot of things beyond what is typically called landing” it obviously will radiate beyond this specific rule.
By issuing GM the EASA is not saying “we made a mistake – sorry for that – we correct the mistake” but rather the opposite “you are making a mistake if you believe a gor around is not a landing. obviously go arounds and low passes are landings as well”.
It is one of the perils of overregulation, a vicious circle that because there are detailed rules for everything, they get interpreted to the letter so there need to be more and more detailed rules – which is an impossible task.
So while the rule itself is less-than-perfect, the simple truth is that in any set of rules, it is very hard to cater for all eventualities so perhaps the writer can be excused.
The problem here are
And then we have a rulemaking process which takes years to fix the rule.
So we end up with with a poor guy writing “Guidance Material” basically saying in a polite way “Since you cannot apply common sense to this, I have to spell out for you that practicing approaches and landings is within the scope of the rule”.
[EDIT – Crossed with @Malibuflyer, who says the same about the GM, except that I think the guy writing the GM would LOVE to insert the words “or practicing an approach to land” in the rule, but can’t since this is a convoluted process taking years]Underline
Let’s not forget “it’s just GM”, one can write their own guidance and it still have same legal value
It’s good that someone is clarifying the obvious and personally, I would not worry about financial consequences (paying landing fee) vs legal consequences (illegal low pass), the burden is on the one sending the bill to prove you have “landed” and anyway, one can always refuse to pay when they don’t like what they get, it’s called getting a good service and falls under what is called (mass) consumer protection & rights which has very well defined set of protection laws and wide scope this is different from prosecuting one single poor pilot using some dumb rule of the air, in what is called “we will get your pilot skin”
Airborne_Again wrote:
[…] operating site for which the
necessary obstacle clearance assessment was conducted and approved by the relevant competent
authorities
Does that mean that for airports which this assessment has not been done (many many VFR only airports) they don’t consider a planned go-around ok?
The fact that they needed GM and the fact that they needed to qualify the GM, suggest to me that they do have an issue with it at such airports.
I suppose it needs to be included for altiports.
Obviously the people writing the rules have no confidence that pilots have enough common sense and so need to be soon fed to stop them doing stupid things.
