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When bureaucracy and overregulation pose a major hazard to safety

Malibuflyer wrote:

Annex 14 Part 9.2

It is a rule, not a recommendation. As with any ICAO rule obviously states can deviate (ICAO has no governing power) and in this case many do – but that doesn’t change the nature of being a rule.

Actually it is a “standard”, not a rule. Anyway, why is that particular standard more important than other standards that are not applied to every airfield e.g. 2.4.1 that states that an aerodrome reference temperature shall be established? (I know that licensed airport all have a reference temperature.)

ESKC (Uppsala/Sundbro), Sweden

alioth wrote:

The automotive equivalent of needing a person on the airfield, for instance, just in case you crash – would be to require marshalls along any road in a rural area and close the road when no marshalls are available, just in case you crash your car.

No – the equivalent of closing airfields if mandatory personal is not present is closing parking garages if mandatory personal is not present – and guess what! At least in Germany there are many garages that close over night!

Roads are not closed w/o marshals as class G airspace is not closed w/o ATC.

Plus: Operating rules for road traffic force truck drivers to park their trucks on highways as parking lots are completely filled up but the drive must not drive beyond “crew duty hours” at all. Equivalent of that operating rule in air traffic would be that pilots are forced to do an off field landing if they can not reach an airfield within duty time restrictions – just imagine that !!!
Driving through a pedestrian zone is not “less forbidden” than flying through a forbidden airspace…


Airborne_Again wrote:

e.g. 2.4.1 that states that an aerodrome reference temperature shall be established? (I know that licensed airport all have a reference temperature.)

What is an unlicensed airport or which airports do not have a reference temperature defined?


Malibuflyer wrote:

The flight you show in the picture is perfectly doable – with the right plane with the right equipment.

Well, “the picture” only shows a small part of the “overall picture”, aircraft, crew and other POB included, so difficult to judge based on just “the picture”. But you are right. Of course we all know TS are typical of afternoon summer wx in central/southern France, in Italy and the Alps and flying in summer afternoons in these areas is about managing TS. We were flying Southbound from Bretagne, initially intermittently IMC at FL190 and we knew from the forecast and the onboard satellite picture we would face one squall line in central France and another buildup was growing at the Pyrenees. Although our aircraft is happier at FL190, especially at ISA+13, we climbed FL210 to remain VMC and facilitate negotiating TS. We managed to remain VMC at that altitude which allowed us to cross the first line via a significant gap. With the clear picture now in view, backed up by the satellite, it was not a problem to plan , while already 150NM away, a slight detour 20NW westwards to avoid the storms over the Pyrenees via the gap you see on the RH side of “the picture”. Bordeaux ACC was very accommodating. It was severe clear from then on to destination which allowed us to descend to an easier FL190 for the last hour of the flight. Satellite wx is an extremely useful essential tool for serious cross country flying.

The above is irrelevant to my point. Given the option, and in general, flying at that time adds a much more significant hazard than landing at an unmanned but otherwise perfect day-VFR airfield well before civil twilight. The problem is the lack of such legal option. The point is pilots should be given the tools to make the best decisions on safety grounds. Unfortunately, safety ranks low in the effort-ranked list of items required to plan a long GA cross country flight in EU.

LESB, Spain

I have a pretty good knowledge about government certification of cars, and in the US we view the European (and particularly German) practice in that regard as exactly the kind of overdone, ineffective practice that’s being discussed here. Car models as a whole are not government certified in the US prior to sale, nor are parts and accessories certified prior to sale, and cars are not periodically inspected for compliance against any Federal automotive ‘type certificate’. What is Federally certified are specific items of useful interest, notably safety equipment and exhaust emissions compliance. The car does not have a type certificate or TCDS because it and the bureaucracy/inspections associated with it would add no value.

Same thing with VFR flight corridors/routes/procedures and also the existence of a special ATC service for VFR only. Except in very specific situations, I’m thinking of ‘no radio required’ corridors through Class B or C airspace, their existence adds no value and in any form is an example of over-regulation.

The unattended airport, fire fighter availability and associated ICAO standard is equally ridiculous, and unless you’re actually living under law legislated by the UN, which thankfully none of us are, is absolutely the kind of thing that is properly ignored by real legislators and real stake holders alike.

In the resource limited real world, any and all money and attention that can be freed up from no-value-added nonsense will add to safety. That should be the number 1 concept in any regulator or pilots mind.

Last Edited by Silvaire at 07 Oct 18:27

Malibuflyer wrote:

What is an unlicensed airport or which airports do not have a reference temperature defined?

Maybe the correct word is “uncertified”, in the sense of certification according to EU regulation 139/2014.

I would say that uncertified airports generally don’t have a reference temperature defined. My home airport certainly doesn’t. I doubt that even in Germany airports such as Grube EDHB or Rerik-Zweedorf EDCR (the first ones I found) typically have defined reference temperatures.

ESKC (Uppsala/Sundbro), Sweden

Jacko wrote:

Ben Franklin, they who can give up essential liberty to obtain a little temporary safety, deserve neither liberty nor safety.

I did not know that one…thx for posting!

LESB, Spain

Don’t often find myself agreeing with Silvaire but on this one… 100%.

The US is full of totally unattended “airfields” – often little more than a cracked, weed-infested runway. Land there all you want. If you crash and burn, somebody might find the wreckage a few days later (Alpine County CA, M45 comes to mind, or Ruth, CA T42 – home to my retirement project airport café, “T42 and two for tea”). If you think that’s too risky – don’t go there.

As for GPS overlays – the whole point of overlays is that they DO NOT need to be designed. There’s already an NDB or VOR approach, fly it using GPS instead, with an accuracy of a few metres instead of half a mile on a good day. In practice I’m sure that’s what everyone does in Europe as well, but you have to have the useless ADF in the plane just to be legal.

LFMD, France

Malibuflyer wrote:

Sorry, but that is a very bad example – and actually harms the case more than it helps:

I think it is a pretty good example personally. Undue restrictions on opening hours will almost certainly put at least marginal pressure on pilots to try and make the mission.

Put yourself in the context of the incredibly restrictive and stupid opening hours of most Greek airports and I bet it puts pilots in the situation of pressured operations all the time.

Upper Harford private strip UK, near EGBJ, United Kingdom

@gallois of course I am against PPR

My point was on the mechanics of emergencies, while before getting to MAYDAY stage, bureaucracy matters !
They matter for “I don’t like it” stage (but irrelevant for “I am in deep troubles” stage)

Paris/Essex, France/UK, United Kingdom
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