Spurred on by G-NIAC, can anyone give a TLDR for what ACTO35 enabled?

I’m currently struggling to see what is stopping a sqn paying for regular flying time at a local private airfield.

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How long have you got…

In short, convoluted permission chain for cadets to fly in Non Service aircraft - initially only powered aircraft were mentioned, but after I stamped my feet, gliders were subsequently introduced.

It worked for a while, then it would seem that risk-aversion came into play & the ACTO was frozen.

As of email sent to our Region in Feb 2019:

Flights in Non-Service Aircraft (formerly regulated by ACTO 35)

  • The Duty Holder Advice Note (DHAN) submitted to 22 Gp requesting a number of sites be authorised has been returned to 2 FTS for more work.
  • It is likely that a new starting point will be to request authorisation of RAFGSA sites with the potential to move on to RAF Flying Clubs, RAF Microlight Clubs and, eventually, a small number of British Gliding Association Clubs.
  • Flights in Non-Service Aircraft of any description will not be authorised for the foreseeable future. Further updates will be provided by the undersigned once 2 FTS staff the revised DHAN to 22 Gp.

So, even if a BGA site or a CAA-approved flying club = a no-no for any ACO-coordinated activity. Risk-aversion as I see it!

Our sqn jumped through all the hoops of ACTO35 in order to get some cadets gliding. That is the ONLY gliding we have managed as a sqn over 4-5 yrs of the “freeze.” A couple of individual cadets were lucky enough to get some gliding as part of this year’s Aerospace Camp, but of course, a 2 FTS facility.

Total lack of information flow = another summer lost for flying opportunities.


ok . . . so that one line in the email is all that’s actually blocking flights in non-service aircraft?

I guess where i’m coming from is, there is no policy in place explicitly allowing Air cadets to participate in archery, no guidance on what qualifications are needed etc etc, except for one single line saying

“activities must be listed as approved activities in the current ATC Indemnity and Insurance Scheme booklet in ACP 300. All staff who supervise AT activities away from the sqn bounds, must hold the appropriate National Governing Body (NGB) qualification and/or a statement of competence delivered by an appropriate technical expert. They must also be current and authorised to conduct AT through the Wg AT Register.”

so why can’t we apply the same common sense to flying? All staff who supervise flying activities must hold the appropriate civvi Flying Qual and be approved by the Wing aviation officer.

Been there, tried it, hit the brick wall. Went with Reg Av Off to local BGA in order to work out plan for simple, automatic approval. Currently frozen out on high.

There are various Duty Holders in the chain, which I think is causing the problem (who will accept the “risk?”) To me, there should be NO issue to use a suitable BGA site or CAA-approved flying club - they are regulated / monitored.

After all the ACO isn’t the top of the safety list for Tutor mid-airs or props coming off the aircraft…


nice to have a couple of replies from CAC, but I feel she’s kinda missing the point that we have a platform for keeping people informed that isn’t in the public eye . . . SharePoint.

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Not missing it, deliberately avoiding it. Much simpler to say “must wait until details are done” than give any details on the process of getting it done.

Besides, just because things are on SharePoint doesn’t mean they necessarily stay private, we’ve seen that with VoV.

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Well yes, that is a fair point, but you’d hope communications to the corps could be sent out without sensitive information.

There was a progress / policy / whatever meeting at Syerston on 11 Aug; nothing heard about the content or the results. No news = bad news.

My guess is that risk-aversion is holding this back, going a long way up the DH chain. I can (very slightly) understand concerns about Cadet Bloggs flying off with Joe Smith (unknown person / limited flying experience, maintenance schedule as & when) but there should be no such issues for a BGA facility or a CAA-approved flying club.


but even then there was a minimum experience to achieve :

For flying/powered aircraft

Minimum pilot experience required for pilots providing flights under ACTO 35 are as follows:

  1. 250 Hrs Total.
  2. 10 Hrs on Type.
  3. 2 Hrs Last 30 days.

And for gliding

Minimum pilot experience required for pilots providing flights under ACTO 35 are as follows:

  1. 250 Launches Total.
  2. 50 Launches on Type.
  3. 10 Launches last 30 days.

in both cases

To ensure parity with military pilot age considerations, the maximum age of pilots to fly cadets is 65 and minimum age 21 years

the rest of the document was simply indicating that the pilot and aircraft needed all the right bits of paper in place (ie pilots need to hold a licence, aircraft need proof of airworthiness), under what conditions pilots need to hold a suitable DBS certificate, and then the (RAFAC) forms required to fill in to get it rubber stamped by HQAC (2FTS)
with then annexes explaining the process of what happens to the RAFAC admin forms once completed

As a pilot myself who has taken 30+ friends flying, be that for an hours evening flight around the local area or a 4hr round trip cross-country flight do i feel that these conditions are fair?

i would say slightly excessive - the “average” PPL is said to fly 25-50hours a year - and so would take 5-10 years flying experience before the 250hours is reached (perhaps where the minimum age of 21 is set at, gaining a licence at 16, and flying 50 hours a year would be reached ~21

to take a passenger flying i need nothing more than to have 3 landings in my logbook in the last 90 days. there is no minimum number of hours, no minimum hours on type and the recency is as wide as 90 days not 30…

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I’m not sure that requirement is any more arduous that a Summer Mountain Leader who has to complete a minimum of 50 DAYS (so also 250hrs, if you apply a very conservative 5hr day - in reality it’s much more than this) prior to being allowed to take groups into the mountains.

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We will be fed a load of bull as to the constraints.

When I’ve spoken to people from the flying fraternity you get a load of waffle about the way we do the training, military etc etc etc and when I’ve said the cadets couldn’t give a toss if they are getting into an aircraft. It’s the thrill of it. I’ve been flying a with a mate of mine and it’s the way the world opens up underneath you that gets me every single time.

Then it’s insurance and cadets etc etc well they fly with the clubs etc under the same T&C anyone doing a have a go instructor flight.

DBS fairly easy to sort.

Not really sure given the adverse publicity, they will fly without the necessary paperwork, as they are running as a business, not some publicly funded club. So if it goes wrong and they haven’t ticked boxes, loss of business etc.

For reasons best known to themselves they seem happy to block an activity which is (or should be) central to everything we do, which if done at a local school has the very real potential to expose enthusiastic youngsters to flying more so than the closed Air Cadet / RAF world. We have had cadets take up climbing after a couple of visits with us to a local indoor wall and join canoe clubs after doing it with cadets.

When I’ve said to the “fliers” we are supposed to be promoting aviation, and what better than a situation where Cdt Bloggs goes to Up and Away Flying School with the cadets, gets the bug and goes back themselves, just gets a they can do a FS for nothing, yep but only if the tick the Air Cadet boxes and are very, very, very, very lucky.

The unfortunate thing is a dogmatic, over cautious, risk averse mindset will not be open to see the wider possibilities.

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i accept that

there is nothing stopping a non ML to walk in the Peaks or in Snowdonia in the same way there is nothing stopping me as PPL taking up friends flying,

but to take a group of people up a mountain, providing a service as a guide there is a minimum number of walks/days (hours) to achieve. likewise there is the same for the RAFAC to take a passenger.

The whole thing stinks. What can some 1 or 2* in an office decide is safe compared to people who routinely inspect sites? If the club meets the requirements for their approvers, how can we say they are unsafe?


Correct - & they didn’t have a clue about the gliding considerations - I checked with a BGA site (& BGA Chair) & asked what they used as a standard for the different “instructor” ratings. We thought ahead, halved what we thought would be reasonable / practical, & submitted to 2FTS… & then they more or less doubled the proposed requirements. :wink:

I did advise 2FTS that the powered flight requirements were excessive, but they didn’t want to move.

Don’t forget that originally, the “permission chain” was letter from parents, then authority for Cadet A to fly with Pilot A in Airframe A. They hadn’t thought about the possibility of a pilot going sick, or an aircraft having a technical issue (such as as at aero-club, etc, rather than just one pilot owning their own aircraft).

As such, there was no fall-back for Cadet A to move to a different pilot or aircraft; the only “legal” authority was to send in permission forms for cadet A to also fly with pilot B in aircraft B, etc, etc. With 3 cadets, 3 pilots & 3 aircraft options, do the maths - we had 12+ cadets to fly! Ah, 2FTS subsequently changed to a list format, so as long as all cadets, pilots & aircraft were listed / pre-approved, all eventually made simpler.

The requirements were set against the risk factor - & obviously, this has been deemed to be too high a risk!


If only - that has been the argument ever since ACTO35 came out!!

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The problem is the various FTS’ are protecting their club and will as they have since 2014, put barriers in place and if people find their way around those, find some more or just say no you can’t, end of. They will spin it’s to protect cadets, but a pound to a penny, ask parents would they sign for their children to go to a local flying club/school, as the RAF cannot supply it. Not many wouldn’t, there aren’t many things they wouldn’t gladly let their children do as '‘birthday parties’, that we could do.

Recall the days of the ‘private activity’. We did a number of things and parents were quite happy to accept there was no come back on the Air Cadets and pay for it.

Actually, a Quality Mountain Day requires SIX hours (and above SIX hundred metres at some point), so 300hrs!

That’s overly cynical; quite a lot was achieved, but much of it is work in progress. Comdt 2FTS is quite a different character to his predecessor.

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Technically not… 5hrs or more journey time. No height requirement either. See the definition of a QMD here: