New regulations threaten twilight/pyro air displays
Posted: Fri Nov 22, 2019 2:23 pm
The Civil Aviation Authority are consulting on sweeping new regulations which could decimate twilight and pyrotechnic air displays in the UK. This is a call to arms to anyone who's enjoyed British pyrotechnic air displays, or has any knowledge on pyro/twilight air displays, to please reply to their consultation below. The proposed rules are unnecessary and effectively outlaw safe, established practices and will have a significant negative impact on displays.
"Twilight displays" are those taking place in the 30 minute period between sunset and the start of night time. In the UK, public display flying is not permitted at night, so virtually all pyro air displays are also twilight displays. Despite this, pyro air displays are one of the few growth areas on the British airshow scene. It's worth noting that twilight is officially still daylight, according to the Air Navigation Order; in that context, these new rules even more draconian.
Here are some of the proposed changes we are attempting to challenge:
• Minimum altitude of 500 feet for all off-airfield twilight displays (up from 200ft at overland shows and 100ft at shows over water, an increase of a factor of five!)
• Blanket minimum pyro release height of at least 200 feet for all pyrotechnic displays, stipulating that no material should still be burning as it falls below 200ft in order to avoid ground fires. The latter will apply to all types of pyrotechnics, including cold-burning pyro with no fire risk. It will effectively ban all low-level flying with cold-burning pyrotechnics, including the spectacular pyro chasers and pylon pyro runs that teams have been working so hard to develop over the past few years.
• All spinning and gyroscopic manoeuvring is to be prohibited during twilight.
• A qualified Flying Display Director with a Radio Operator's Certificate of Competence must be present on the ground to observe all pyro displays to monitor pyro fall and spot fires (currently a display pilot may also act as the FDD at the smallest shows, known as an AFDD). While it may be sensible to have an observer on the ground, neither an FDD or ROCC qualification is neccesary to assess pyro fall, spot fires and communicate this to a suitably-qualified AFDD. Indeed a person more familiar with pyrotechnic material (which most FDDs aren't) would be better placed to fulfill this role. Needing a seperate FDD will be a signficent extra complication for the small shows and private events.
• In the event of any ground fire, the display must be halted and the incident reported. This will apply regardless of the size and location of the fire, even if it is small, short-lived and in a sterile area where it poses no safety risk.
If this draft CAP is becomes a reality, it will likely come into force at the start of 2020, and it will be extremely difficult to get these rules amended or removed thereafter. To quote a well-known airshow pilot (see links below), pyro displays are "one of the few areas in a very beleaguered airshow industry where there is room for being entrepreneurial, being inventive, being imaginative," and UK teams are now world leaders in this field. It would be devastating to lose that. Every response counts!
Useful links:
Draft CAP403 proposal (see section 16, changes in red): https://consultations.caa.co.uk/ga/cap4 ... dition.pdf
Consultation response page: https://consultations.caa.co.uk/ga/cap4 ... ion/intro/
Further reading on UK pyro displays, with input from various well-known pilots: http://thisisflight.net/features/the-sk ... -imagined/
"Twilight displays" are those taking place in the 30 minute period between sunset and the start of night time. In the UK, public display flying is not permitted at night, so virtually all pyro air displays are also twilight displays. Despite this, pyro air displays are one of the few growth areas on the British airshow scene. It's worth noting that twilight is officially still daylight, according to the Air Navigation Order; in that context, these new rules even more draconian.
Here are some of the proposed changes we are attempting to challenge:
• Minimum altitude of 500 feet for all off-airfield twilight displays (up from 200ft at overland shows and 100ft at shows over water, an increase of a factor of five!)
• Blanket minimum pyro release height of at least 200 feet for all pyrotechnic displays, stipulating that no material should still be burning as it falls below 200ft in order to avoid ground fires. The latter will apply to all types of pyrotechnics, including cold-burning pyro with no fire risk. It will effectively ban all low-level flying with cold-burning pyrotechnics, including the spectacular pyro chasers and pylon pyro runs that teams have been working so hard to develop over the past few years.
• All spinning and gyroscopic manoeuvring is to be prohibited during twilight.
• A qualified Flying Display Director with a Radio Operator's Certificate of Competence must be present on the ground to observe all pyro displays to monitor pyro fall and spot fires (currently a display pilot may also act as the FDD at the smallest shows, known as an AFDD). While it may be sensible to have an observer on the ground, neither an FDD or ROCC qualification is neccesary to assess pyro fall, spot fires and communicate this to a suitably-qualified AFDD. Indeed a person more familiar with pyrotechnic material (which most FDDs aren't) would be better placed to fulfill this role. Needing a seperate FDD will be a signficent extra complication for the small shows and private events.
• In the event of any ground fire, the display must be halted and the incident reported. This will apply regardless of the size and location of the fire, even if it is small, short-lived and in a sterile area where it poses no safety risk.
If this draft CAP is becomes a reality, it will likely come into force at the start of 2020, and it will be extremely difficult to get these rules amended or removed thereafter. To quote a well-known airshow pilot (see links below), pyro displays are "one of the few areas in a very beleaguered airshow industry where there is room for being entrepreneurial, being inventive, being imaginative," and UK teams are now world leaders in this field. It would be devastating to lose that. Every response counts!
Useful links:
Draft CAP403 proposal (see section 16, changes in red): https://consultations.caa.co.uk/ga/cap4 ... dition.pdf
Consultation response page: https://consultations.caa.co.uk/ga/cap4 ... ion/intro/
Further reading on UK pyro displays, with input from various well-known pilots: http://thisisflight.net/features/the-sk ... -imagined/