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See https://consultations.caa.co.uk/safety-and-airspace-regulation-group/helilanes-svfr-minima-amendment/consultation/subpage.2024-01-09.4035038628/
Old: The existing weather minima for SVFR operations require pilots to remain Clear of Cloud with the Surface in Sight (COCSIS)
New: Cloudbase 1000ft above ground level (agl); Visibility 3000m for all aircraft types.
Helipaddy’s response is to reject the proposals as they may have the effect of increasing accidents.
DEADLINE TO RESPOND 12th FEBRUARY 2025
Our opinion is as follows:
6. Proposed SVFR Weather Minima
Should the revised SVFR weather minima be as proposed by the CAA, more restrictive, or less restrictive?
Answer: Less restrictive
If you chose more or less restrictive, please provide an alternative suggestion and explain your rationale:
The primary shortcoming lies in the inadequate NOTAM system (as seen in incidents like Vauxhall), rather than in the current weather criteria. The proposed minima may actually produce the opposite of the intended effect. This extensive area under consideration is largely flat, and only R160 presents any real concern. Pilots should retain authority over weather judgment rather than having it dictated by the tower.
7. Geographical Application of Revised SVFR Weather Minima
Where should the revised SVFR weather minima apply?
Answer: Other
If you chose a limited geographical area or Other, please provide details of the boundary you suggest, and the rationale:
They should not apply anywhere for helicopters, and only R160 should be considered for fixed-wing aircraft.
8. Exemptions from Proposed Minima
Should certain airspace users be exempted from the proposed minima?
If Other, please describe which users and explain your rationale:
Helicopters should be exempt. Had the minima been set lower during the Vauxhall incident, the pilot would not have been forced into clouded conditions. The real issue is the overloaded and ineffective NOTAM system, filled with so many irrelevant details that pilots often disregard it entirely.
9. AOC Dispensations
Should AOC holders be able to apply for dispensation from the proposed minima?
Answer: No
Rationale:
There should be no difference in rules for AOC holders versus private operators.
10. Operational Impact
Expected impact of the proposed SVFR weather minima on your operation:
Answer: Negative impact
Details:
Enforcing these new minima would impede transit through areas like Ascot/Burham, which are free of tall obstacles and otherwise pose no issue.
11. Safety Impact
Expected impact of the proposed SVFR weather minima on civil aviation safety in the London CTRs:
Answer: Negative impact
Details:
Introducing stricter minima could prove counterproductive. Safe operations at altitudes like 800 feet AGL are currently feasible in clear conditions, but the new rules would restrict both altitude and visibility simultaneously. The root cause of confusion—an overloaded NOTAM system—remains unaddressed.
12. Efficiency Impact
Impact on the efficiency of Air Traffic Management:
Answer: Negative impact
Details:
Heathrow controllers handle general aviation traffic efficiently. Requiring them to judge distant cloud conditions is an unnecessary complication that will likely reduce operational effectiveness.
13. Environmental Impact
Expected environmental impact:
Answer: Neutral or No impact
Details:
This change is irrelevant to environmental concerns such as fuel consumption or emissions.
14. Security Impact
Expected security impact:
Answer: Neutral or No impact
Details:
The proposal is unrelated to security matters and should not affect it.
15. Financial Impact
Expected financial impact:
Answer: Neutral or No impact
Details:
There is no evident financial repercussion tied to this proposal.
16. Additional Comments
Any further suggestions:
Address the actual issues—particularly the dysfunctional and cluttered NOTAM system—rather than imposing more restrictive minima that fail to resolve the underlying problem and instead introduce new complications.