Part 139 D&E Aerodromes Update: Unanimous Decision from the Board Of Directors

Letter from the AOPA Namibia President

12 April, 2022

Dear AOPA Namibia Member,

The AOPA board has discussed the recommendations of the Technical Sub-Committee (TSC) on Aerodromes and Safety.

This email serves to inform you of the unanimous decision taken by the board following consideration of the recommendations of the TSC and consultation with members in all membership categories.

Actions to be taken by AOPA Namibia:

  1. AOPA Namibia will officially inform the NCAA that AOPA will draft a new set of proposed regulations pertaining to Part 139, as applicable to D&E aerodromes. We will not accept the invitation from the NCAA (click the link to read a PDF copy of the invitation) to nominate one (1) or two (2) candidates to attend a working session on the 27th April. Instead, we shall inform the NCAA that we will only accept the invitation on condition that ;
  • the entire Technical Sub Committee of AOPA (Aerodromes and Safety) is able to attend the proposed working session with the NCAA
  • we do not discuss the NCAA’s version of the document at the working session, but we only present and discuss OUR proposed version

The reason we are taking this stance is that over the past three years we have had numerous meetings, discussions and negotiations and have sent numerous letters and proposals to the regulator in this connection, all to no avail. Furthermore, we maintain that Part 139, as applied to categories D and E aerodromes are only a “recommendation” from ICAO, which the NCAA has no mandate to enforce.

  1. AOPA will select and appoint individuals from within the Technical Sub-Committee to form a 139 Task Team, whose first task it shall be to inform themselves of the best practice in similar and appropriate geographies, especially in the USA. Once they have formulated their proposals, the task team will be required to consult widely with representatives from all membership categories in order to ensure that our proposals are acceptable to all of our members.
  2. No members of the 139 Task Team involved in drafting our proposals shall be remunerated by AOPA.
  3. The CEO of AOPA shall provide the NCAA with our proposed Part 139 on Monday 25th April, two days prior to the working session.
  4. Should the NCAA refuse to accept our terms, we will move for a complete withdrawal of Part 139 as it applies to D&E aerodromes, for which we are prepared to interdict the line Minister.

Note that we have seen 139 practically destroy GA in Zambia, because there was not a strong enough body to oppose its implementation. The same appears to be happening in SA. 

We must avoid this at all costs.


Mark Dawe
AOPA Namibia

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

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