Low Flying, High Stakes: How to Apply Wise ADM to Namibia’s Important New Minimum Height Rule

The NCAA recently informed AOPA Namibia that low-flying aircraft were reported during the 2024–2025 festive season in various locations across the country.

Although AOPA hasn't been able to verify these reports or conduct its own safety assessment regarding their veracity and severity, any opportunity to discuss aeronautical decision making (ADM) when it comes to low-level flying is one worth having.

So... let’s have it.

Keep reading to learn about Namibian's new Part 91 Minimum Height (500 ft) Rule that went into on October 2024, and how it applies to VFR flying.

Namibia’s New Part 91 Minimum Height VFR Rule (a.k.a the 500 ft Rule)

Let’s begin by highlighting the new Part 91 visual flight rules that went into effect on 1 October 2024, bringing Namibian aviation regulations in line with major aviation nations worldwide.

NAMCAR 91.06.32 (Visual Flight Rules) now states:

(5) A VFR flight may not be flown – 

(a) over the congested areas of cities, towns or settlements or over an open-air assembly of persons at a height less than 1 000 feet above the highest obstacle within a radius of 600 metre from the aircraft; or 

(b) elsewhere than as specified in subparagraph (a), at a height not less than 500 feet above the ground or water unless the flight can be made without hazard or nuisance to persons or property on the ground or water and the pilot-in-command operates at a height and in a manner that allows safe operation in the event of an engine failure

except when necessary for take-off or landing, or except by permission from the appropriate authority. 

(6) An aircraft may not – 

(a) be flown over congested areas or over an obvious open-air assembly of persons at a height less than 1 000 feet above the highest obstacle, within a radius of 2 000 feet from the aircraft; 

(b) ,when flown elsewhere other than as contemplated in paragraph (a), be flown at a height less than 500 feet above the ground or water, unless if the flight can be made without hazard or nuisance to persons or property on the ground or water and the pilot-in-command operates at a height and in a manner that allows safe operation in the event of an engine failure; and 

(c) circle over or do repeated overflights over an obvious open-air assembly of persons at a height less than 3 000 feet above the surface, 

except when necessary for taking off, or landing, or except with prior written approval of the Executive Director.

What’s Stayed the Same

As before, the regulations prohibit operation of aircraft below 1,000 feet AGL over congested areas or open-air assemblies of persons, unless during takeoff or landing.

Similarly, circling over an open-air assembly of persons still requires maintaining a height above 3,000 feet AGL.

What’s Different

The major change in Namibia’s air regulations is the conditional allowance for aircraft to be flown below 500 feet AGL over non-congested areas — provided the flight poses no hazard or nuisance to persons or property on the ground, and the pilot can land safely in the event of an engine failure.

Why the Change?

This update is important.

It aligns Namibia with international aviation standards and enables critical low-level missions that often require flight below 500 feet AGL — such as:

  • Search and rescue operations;
  • Aerial firefighting;
  • National infrastructure inspections (e.g. NamPower power line patrols);
  • Wildlife conservation flights;
  • Private property inspections;
  • Aerial surveys (e.g. for land surveying or for resource exploration); and even
  • Professional film shoots.

It’s also vital for the operations of many recreational aviation activities like paragliding, hang-gliding, and certain microlight flying — which typically operate below 500 feet AGL. Under the previous minimum height rule, such flights were effectively prohibited by default.

However, just because the regulations now allow for flight below 500 feet in certain conditions, this does not mean it's wise to do. The regulations clearly reinforce that, whenever possible, a safe operational height of at least 500 feet AGL should be maintained for several important safety reasons.

Surviving the Wires Environment

Perhaps the most important reason for maintaining 500 feet or more is the reality of what’s referred to as the “wires environment” — the ever-growing network of power lines, communication towers, wind turbines and unmarked obstacles that exist in the low-level airspace.

On the outskirts of major American cities like Houston, Texas, the "wires environment" can even extend up through 2,000 feet AGL due to exceptionally tall radio towers.

Closer to home, Namibian pilots also face a growing network of low-visibility power lines, towers and wind turbines. Some towers even have guide wires that stretch laterally up to 80% the tower’s height — a serious collision hazard pilots can't see!

At typical flight speeds, most wires are invisible, and even if spotted, reacting to them in time is unlikely as vision experts state it can take up to 6 seconds for pilots to detect and respond to such obstacles.

Compounding the risk, Namibia currently lacks regularly updated sectional charts to map these hazards for pilots — a dangerous reality unfortunately created by the NCAA’s longstanding failure to maintain Namibia's flight obstacles database.

Always remember that altitude is your ally. Should an emergency occur, it can buy you critical time for fault-finding, high-pressure decision-making, and ultimately achieving a safe outcome — all the more important when carrying passengers and flying over other people and their property!

Be a Good Neighbour

What's more, flying at or above 500 feet AGL isn’t just good airmanship — it’s good citizenship.

Public perception matters, and maintaining public support and trust helps protect the future of general aviation.

When and where low-level flight is necessary, first secure property owner permission and any required permits if necessary (such as conservancy approvals for game counting flights or permits for professional film operations).

And remember that the new regulations state that your low-level flight must not create a nuisance or hazard to persons or property on the ground.

Respect the new privilege — and fly with courtesy and due regard for all the earth-bound beings below you.

Making Good Aeronautical Decisions

Every flight involves risk and it's every pilots' responsibility to mitigate those risks through wise aeronautical decision making (ADM).

If your mission requires low-level flight, thorough high-level recon and pre-flight due diligence are non-negotiable.

Ask yourself:

  • Have you identified and cleared the area for potential collision hazards — from both the ground and from a proper recon altitude?
  • Considering Namibia's variable topography flying environment, have you ensured power lines aren't spanning the canyons, valleys or rivers you intend to cross?
  • Do you understand that familiarity with an area is no guarantee of safety from hazards?
  • Have you secured permission from the affected property owners or authorities?
  • Have you reviewed applicable noise abatement procedures?
  • Are you truly prepared, your aircraft actually capable, and the surface sufficiently manageable to allow for a safe landing should your engine fail at such low heights?

If you haven't assessed the hazards, mitigated the risk or received the required approvals, good ADM compels you to remain at or above 500 ft AGL.

The Ultimate PIC Duty

As the saying goes – "a superior pilot uses superior knowledge to avoid situations that require superior skills."

Or put another way, pilots who exercise good ADM avoid stacking risks against themselves to keep their flights safe. So make sure you’re not stacking the risks against yourself if you decide to go low. 

Remember, NAMCAR 91.06.5 (Authority of Pilot-in-Command) states:

(1) The pilot-in-command is responsible for the operation and safety of the aircraft and for the safety of all persons on board during flight.

Let’s make sure our aeronautical decision making, at every height, always reflects the gravity of that ultimate duty.

P.S. — Know Your Environment

In actuality, every pilot operates below 500 feet AGL on every flight — during takeoff and landing at a minimum.

That’s why familiarity with the dangers of low-level flight is essential for all pilots.

If you’ve got a few minutes to spare, watch the excellent “Surviving the Wires Environment” video below (produced by Helicopter Association International) — a must-watch that sharply illustrates the invisible hazards all pilots must respect.

Fly smart, stay safe and happy tailwinds.

AOPA Namibia exists to protect the aviation interests, rights and privileges of ALL its members.

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