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New regulations threaten twilight/pyro air displays

Posted: Fri Nov 22, 2019 2:23 pm
by Adam
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/

Re: New regulations threaten twilight/pyro air displays

Posted: Fri Nov 22, 2019 3:08 pm
by RyanS
I was wondering what your thoughts on this were. Interesting that nothing is allowed after twilight!

Re: New regulations threaten twilight/pyro air displays

Posted: Fri Nov 22, 2019 6:11 pm
by Adam
People had certainly been arguing for night displays to be allowed for some time. Until recently, there was a pretty positive feeling and a lot of people seemed to think a change was imminent. Sadly it's gone the other way, which is a rather unpleasant surprise. To quote one of my colleagues earlier today: "We think the changes are unnecessary and will actually make our displays more difficult and more dangerous." I'm sure some of the proposals are well-intentioned, but they have been created by people with little knowledge of pyro displays and are being implemented in a very unhelpful way.

Re: New regulations threaten twilight/pyro air displays

Posted: Fri Nov 22, 2019 8:02 pm
by Flightline Uk
There are some flaws in the consultation document clearly not least the rules about burning embers over water. That comes from a lack of experience within the CAA in a field which seems to change year-on-year. I think its incorrect to say the UK are 'world leaders.' The first full pyro show in the UK was only 2010. In the US they've been going for over 30 years (More if you count Art Scholl's 1974 display). By comparison, the UK is still finding its feet within the evening/night show business as is demonstrated by the relative lack of variety on the circuit.

I suspect the CAA is looking to the US which has far more experience and imposes a minimum 500ft rule which they seemed fairly locked on to. A quote from the ICAS Performer Safety Documentation - 'Voices of Experience':
"With the night pyro show, the most important thing is safety. It has a higher floor, 500 feet, and higher weather minimums, five miles visibility and a 2,500 foot ceiling."


If we had the 2500ft ceiling in Europe/UK, I doubt I've seen even half the evening shows I have seen!

A further quote from Steve Oliver in the same publication:
"My Chipmunk carries fountains, also called gerbs, which are what stream out the long trails of sparklers and fire that come off the wingtips. I also carry custom-built, 8 shot 30-mm Roman candles that shoot out colored balls. I encase them in steel tubes and have a big titanium plate that goes on the wingtip before the mounts go on. The titanium gets discolored from the extreme heat, but it protects the wingtips. I’ve never had an issue with this, but — on a rare occasion — fireworks can go high order. That means, they explode all at once, make noise and shake the airplane, then they shoot out fire balls.

So, you do have to be careful not to fly below the 500 foot night floor for aerobatics because a fire ball could set a field or something else on fire. That has happened to some people."
It is unwise to ask for massed responses to a consultation without giving people the actual quantifiable evidence. A few well written evidence based responses are far better than 10's of well meaning but essentially fact-less ones. Simply saying 'it's more dangerous' without backing that up with data is a fruitless exercise. I hope that some of the more experienced Event organisers, Flying Display Directors and display pilots take time to respond to changes in the whole document. It is very clear that the CAA need precise and risk-based evidence to provide them with direction.

Re: New regulations threaten twilight/pyro air displays

Posted: Fri Nov 22, 2019 9:13 pm
by Adam
I certainly think the "world leaders" comment is fair. After all, British teams include the world's largest formation pyro team, the formation team which carries the most pyro per aircraft, the solo display act which carries the most pyro per aircraft and one of only two teams in the world to perform true night formation aerobatics with pyrotechnics. New to the party, certainly, but already one of the world leaders without doubt.

If the CAA are attempting to copy the US rules, they're not doing a very good job of it, given the 500 foot hard deck is only enfored at night or while pyrotechnics are being fired, whereas the proposed UK 500-foot will apply equally to non-pyro displays at twilight (ie. during the day) at all off-airfield shows. The 500-foot minima is also being proposed without modification to other related rules, such as weather minima. For example, the minimum altitude is now equal to the minimum permitted cloud base for some types of displays, which is clearly not sensible as it would drive pilots into cloud.

While a high hard deck at night has its merits for pyro- and non-pyro displays, we strongly dispute the idea that a blanket daytime MPRH is a sensible approach for the purpose of avoiding fire. The idea that smoke grenades and, for example, waterfalls should be treated the same is absurd. Pyrotechnics used for low-level parts of the display are specially-selected. In many cases, they are grade 1.4S "proximate" pyro approved for use indoors and within crowds - clearly a 500 foot minima is overkill. Smoke grenades, for example, are also pyrotechnics - again, a 200 foot minima for the use of this kind of smoke is simply not needed. A MPRH would also be virtually unworkable with parachute displays and glider displays. The proposed individual minima for different types or classes of pyro, without the 200ft MPRH, should suffice.

Precise, risk-based evidence and assistance with regulating this sector has been offered to the CAA by qualified pyrotechnicians over the past year. It was not taken up. I discussed this face to face with the display pilots whom I work for before posting this, and they too have sought a wider response today. Annecdotal evidence from many people that pyro displays have never caused a serious fire is important here. Admittedly, although I pointed to the section containing the changes, I neglected to add to my first post that responses should be evidence-based, or at least annecdotal, and relate directly to named paragraphs of the draft CAP, which is the request that's been made elsewhere. I should have included that in my initial post.

Re: New regulations threaten twilight/pyro air displays

Posted: Wed Feb 05, 2020 4:32 pm
by Flightline Uk
Well, they consulted and clearly listened as it appears a far more detailed and reasoned section on twilight/pyrotechinic displays now.

https://publicapps.caa.co.uk/modalappli ... tail&id=32
This edition incorporates feedback from the Flying Display community, mostly focussed on providing further clarity where required. Further guidance has been added to improve safety at twilight displays. Additional guidance has been given for displays that use airborne pyrotechnics to further protect Spectators and minimise the risk of ground fires. The guidance for formation briefing has been expanded and additional mandatory formation briefing requirements added. Additional guidance surrounding risk mitigation to As Low As Reasonably Practicable (ALARP), and amendments to risk categorisation have been made to Appendix A (Risk Assessment).

Re: New regulations threaten twilight/pyro air displays

Posted: Wed Feb 05, 2020 5:18 pm
by Adam
Yes, and this is only half the job done! Credit where it's due, the CAA have thoroughly taken on board the industry response and updated the draft CAP accordingly. There wasn't time to implement all of the feedback though, and this is a stopgap in some ways, solving most of the bigger problems until a "flying with pyro" extension (or another way to prove pyro competency) can be added to the DA system. Once there's a formal process for approving pilots to work with pyrotechnics, it could pave the way for them to determine the MRPH of individual effects more freely themselves. So there are still some holes, but thanks to the changes, things can continue to tick over until there's time to implement a fuller solution. Some key changes from the first draft:

1. "Pyro" has been given three sub-categories, entirely based on suggestions from the industry, and the less potent pyro will now be governed less strictly. PRT3 pyro has no MRPH, and PRT1 and 2 pyro can be used down to their MRPH (rather than MRPH +200ft as before). The MRPH can be waived entirely over water or over risk-assessed areas with good fire cover - so the pyro chasers and low passes live on.*
2. The requirement to have an FDD on the ground has been replaced by a "supervised ground observer". The FDD requirement was a big deal for small/private events, so this is good news.
3. The 500ft minima for off-airfield displays has been totally abandoned, the minima will remain at 100ft over water and 200ft over land.
4. The CAA have removed the very unwise requirement for a display to be halted upon sight of any ground fire, however minor. It was pointed out that this would cause aircraft to leave the display area and thus spread any fire risk further afield - possibly over congested areas! The new draft CAP states that the display only needs to be halted when a fire poses a risk to public safety.

This was a very positive process and which involved the CAA coming back to respondants for more details, to help them further refine the draft CAP. I'm particularly pleased to see that, of my five pages of submissions, all my four key suggestions have been recognisably incorporated - although I'm sure there was a lot of overlap with other people's submissions.

*Side note - it was mentioned earlier that the CAA were simply copying the US regulations with a 500 foot hard minima for all pyro. A quick glance at the US regs seemed to confirm this, but I recently came across a video fo Julie Clark flying at Oshkosh last year (presumably before civil sunset when there is a 500ft hard deck anyway), flying almost down to ground level. She looked to have gerbs on the wingtips. This must mean the US rules have some leniency when lower-risk pyro is involved, and I wonder if either they only define "pyro" as hot-burning pyro, or if they have different classifications of pyro like the CAA's new PRT system? Frankly it would have been madness if the FAA had enforced a 500 foot hard deck indiscriminently on all pyro, and common sense dictates that it's impossible anyway (what about parachutists with smoke grenades on their feet, for example?) - so I'm not exactly surprised to have come across this. But if anyone can explain the details, or point me to the relevent regulations, I'd be very interested.