This is an HTML version of an attachment to the Freedom of Information request 'General Aviation during COVID-19'.

From:
[redacted]
To:
[redacted]@mac.com
Subject:
FW: General Aviation in Scotland - Ref: TS2021/3294 
Date:
01 March 2021 15:22:00
Dear [redacted]
Thank you for your e-mails of 1 and 24 February about General Aviation in 
Scotland. I apologise for the delay in responding.
Under the current lockdown measures flying for leisure purposes is not permitted. 
As you are aware, to minimise the risk of spreading the virus, people must stay at 
home as much as possible and are only permitted to leave home for essential 
purposes. Flying for leisure does not constitute an essential purpose. Flying is 
permitted, however, in order to maintain aircraft.
It remains the case that any decision to open an individual airfield is a matter for 
the operator of that airfield
Yours sincerely
[redacted]
Aviation Policy
Transport Scotland
From: [redacted]@mac.com> 
Sent: 24 February 2021 09:37
To: Scottish Ministers <xxxxxxxxxxxxxxxxxx@xxx.xxxx
>
Cc: [redacted]@transport.gov.scot>
Subject: Fwd: General Aviation in Scotland
Dear Sir/Madam,
I originally sent the below to [redacted] however have not received a response. Appreciate 
he's likely very busy and perhaps it should have been directed at someone else, so if you 
can pass it to the appropriate office it would be munch appreciated.
It seems unambiguous at this point that Recreational General Aviation is permissible as 
"outdoor recreation" to be carried out in accordance with The Health Protection
(Coronavirus) (Restrictions and Requirements) (Local Levels) (Scotland) Regulations 
2020 and this is supported by guidance issued to the Gliding community by Sport Scotland 
https://sportscotland.org.uk/media/6421/gliding-phase-3-5-level-guidance-15022021-
approved.pdf
It's also come to my attention that most flying schools and other recreational aviation 
businesses have now been informed they are not entitled to the grants from the Strategic 
Framework Business Fund as they were "not required to close or modify operations under 
the COVID-19 protective measures" - yet some airfields are prohibiting General Aviation 
activities so they have, of course, been forced to close (indirectly) 
These airfields are generally pointing to the DfT statement which is an interpretation of the 
The Health Protection (Coronavirus, Restrictions) (All Tiers) (England) Regulations 2020,

and does not apply in Scotland. 
Skill atrophy is a serious concern, even amongst recreational aviators, and many of us 
would greatly appreciate clarification (or an official statement from Scottish Ministers) 
with respect to whether or not (as long as all the same precautions are observed as in 
Gliding, Hang-Gliding, Sailing, Angling, Canoeing etc all permitted in Level 4 according 
to guidance published by Sport Scotland) this activity can continue subject to the 
provisions of the current Regulations (including travel within local area only, the gathering 
rules etc.)
Kind regards,
[redacted]
Begin forwarded message:
From: [redacted]@mac.com>
Subject: General Aviation in Scotland
Date: 
1 February 2021 at 16:02:33 GMT
To: [redacted]@transport.gov.scot
[redacted],
Can you please confirm if the following guidance is applicable in Scotland, as 
there seems to be some confusion within the GA community and local 
aerodrome, most referring to this document (which appears to apply to 
England only);
https://www.gov.uk/government/publications/coronavirus-covid-19-general-
aviation/coronavirus-covid-19-general-aviation
This refers to England and states "no leisure flying is permitted [in England]" 
which is understandable, as The Health Protection (Coronavirus, Restrictions)
(All Tiers) (England) Regulations 2020 (the "English Regulations") prohibit 
leaving the place you are living for a number of reasons, one of which is
'exercise'. Despite the fact that the RYA has confirmed that "boating" is 
considered exercising, and apparently so is fishing, I can understand that 
General Aviation would not be considered exercise. 
However, the The Health Protection (Coronavirus) (Restrictions and 
Requirements) (Local Levels) (Scotland) Regulations 2020 (the "Scottish 
Regulations") differ considerably from the English ones, notably that they 
allow exercise or recreation, that must start and end at the same place within 
the local government area the the person lives.
I believe, therefore, that recreational aviation would be considered "outdoor 
recreation", and as long as the rules on gatherings are observed (i.e. you fly 
only alone, or with members of your own household, or the other limited 
permitted gatherings such as extended households) and you do not leave your 
local area to access the aircraft, then it is currently permitted?
This would parallel the guidance that has been issued on boating by the RYA

where you may continue to go boating following the rules on outdoor 
gatherings, and as long as your boat is kept in the same local authority area as 
you live. 
It would be really helpful if the Scottish Government would publish guidance 
alongside their English counterparts at the DfT as it does seem to cause a lot 
of confusion, resulting in some aerodromes being operational and some not.
As a General Aviation pilot myself, but also someone who has spent a lot of 
time studying human factors in my professional career, my primary concern is 
the skill atrophy and lack of proficiency by grounding recreational pilots for a 
long period of time will likely present a higher risk than the risk of COVID-19 
when engaging in GA activities in a safe and socially-distant manner; this is a 
concern that has been shared by other organisations and is very apparent in the 
US via NASA's ASRS reports showing deviation from approved processes 
amongst commercial aviators because they are "rusty" having flown less due 
to the COVID-19 situation.
I should stress that I am in no way underestimating the seriousness of COVID-
19, and sadly have lost people I know to this terrible disease, but admire the 
Scottish Government for maintaining a proportionate approach to the 
Regulations and the continuation of allowing recreation, rather than just
'exercise', at Level 4 - and the positive impact this has on mental health - and 
would appreciate clarity on whether or not this includes recreational aviation. 
Kind regards,
[redacted]