OBJECTION TO PROPOSED REGULATION PART 139 SUBPART 5

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"The proposed changes to the legislation, if written into law, will effectively curtail the major portion of all recreational flying".

OBJECTION BY EAA OF SOUTH AFRICA TO PROPOSED REGULATION PART 139 SUB PART 5: 
LICENCING AND OPERATION OF AERODROMES FOR AIRCRAFT WITH MCM 450KG TO 5700KG

The Experimental Aircraft Association of South Africa and its Chapter members constitute a special interest group (or Aviation Recreational Organisation, ARO) in compliance with CAR 149 of the SA CAA CATS regulations. The origins of the Experimental Aircraft Association date back to 1954 in the USA and, in South Africa, to 1957.

The innovation and design conceived by its members has laid the foundation for many of the aircraft we see in the Type Certified category in existence today, and this emphasizes the legitimacy of the EAA.

The Experimental Aircraft Association of South Africa is also represented on the board of the Aero Club of South Africa, whose charter is the promotion and preservation of recreational and innovative aviation in South Africa.

Having perused and scrutinised the proposed amendments to PART 139 Sub Part 5 in discussions held on the 27 February 2016, a quorum of the EAA of South Africa EXCO is strongly opposed to the proposed amendments as laid out in Part 139 Sub Part 05.1 through 7.  

For the reasons that follow, we place on record our objection to this insertion (Sub Part 5) to the regulation as of the 27 February 2016. (Comments close by 12 March 2016.)

Private landing strips and runways have been in existence for almost 100 years in South Africa and we see no reason for the proposed onerous regulations to control such private entities in the manner as set out in SUB PART 5.

Most of the private airfields in South Africa are grass roots airfields and the owners are enthusiasts and passionate aviators who encourage aviation in South Africa.

The proposed changes to the legislation, if written into law, will effectively curtail the major portion of all recreational flying, as many aircraft either use, or are based at unlicensed/private airfields.

The financial implications of the proposed changes would render these unlicensed/private airfields unviable, and most would close down immediately. Without airfields from which to operate, many recreational aircraft would be disposed of, primarily out of the country.

The effects on the people employed in the recreational and NTCA aircraft industry would be considerable, as many derive their income from the aircraft operating from such airfields.

It is not practical, workable or enforceable to require a private airfield/runway to maintain the same standards and services as those required for an airfield supporting Commercial Operations.

The EAA view the additional financial burden of the proposed legislation as draconian and without foundation or merit, and it is the opinion of the EAA that it would sound the death knell to General Aviation in South Africa.

Paul G Lastrucci

EAA of SA National President

 

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