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Aero Club Communique March 2022 #5

Reminder: - Proposal to Licence Aerodromes -  Aero Club Objection This is the final reminder to be sent in by COB today. To make it easier, just complete this Google Form  See details below:

The CAA have again put forward a proposal to licence aerodromes, which will have a huge impact to cost of operation of many of our airfields, and may hamper or even curtail your operations. The link below provides the proposal that will be discussed at the next Carcom. If you would please read the entire document and comment – this first section is of significance to our recreational flying activities. Also share this to any other members or non-members alike, as it affects our entire GA / RA industry. If we don't collectively comment and oppose this proposal, it will allow this proposed amendment to be promulgated.
 
139.05.1 REQUIREMENTS FOR AERODROME LICENCE 1.
Aerodrome types
(a) An aerodrome where charter operations take place shall be licenced as a Type A aerodrome.
(b) An aerodrome where Annex 1 aviation training excluding gliders and balloons is conducted shall be licenced as a Type B aerodrome.
(c) An aerodrome that is in the proximity of existing facilities and an aerodrome where operation may conflict or create a hazard shall be licenced as a Type C aerodrome.
 
139.05.10 AERODROME RESCUE AND FIREFIGHTING

(1) The level of protection to be provided for rescue and firefighting service shall be as prescribed in the applicability table
(2) An aerodrome licensed as Type B shall have the rescue fire-fighting equipment as prescribed in table ###:

Schedule_3_SA_CATS_139.pdf 

Electronic copies of the draft Amendments are available in the South African Civil Aviation Authority website at www.caa.co.za and may also be requested from Pretty Monyela at monyelap@caa.co.za. Interested persons are hereby invited to submit written comments on these draft Amendments on or before the 26 March 2022 to the Chairperson: CARCom, for the attention of:

Sipho Skosana
Private Bag X73, Halfway House,1685
Email: skosanas@caa.co.za
(please send email in cc to office@aeroclub.org.za)

See below the Aero Club objection as lodged to the addressee above.

Dear Sipho, regarding the latest Carcom Proposal related to the Requirements for Licencing of Aerodromes as per Part 139 Subpart 5 as submitted by the CAA, The Aero Club of South Africa objects to this Proposal in its entirety.
 
The Proposal will require airfields where charter operations, training operations, and airfields in proximity locations be registered and licenced, this implies that an annual licencing fee will need to be paid, as well as the provision of emergency firefighting and medical services, not even considering the cost of implementing facility upgrades and layout in compliance with 139.05.9. The current Part 139 Aerodrome licencing requirements are applicable for operation of aircraft above 5700 kg MAUW.
 
This proposal if promulgated would have the effect of destroying General and Recreational Aviation in South Africa, due to the additional costs that will be imposed on operators and aircraft owners, furthermore it is practically unenforceable given locations of airfields around the country, and limitations imposed by geography.
 
It brings into question the reasoning why this proposal has been tabled again since initial attempts from 2016, as the landscape has not changed in South Africa, and with no evidence that current aerodromes have had any safety disadvantage of not being licenced, as operations have been carried out safely for decades. Your consideration to review this proposal would be appreciated.





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