I've responded on behalf of my RF as follows:
Comment:
Although light ac with a MTOM < 2000 kg are currently exempt from en-route navigation charges, it is important to distinguish between the recreational use of many light ac under VFR or IFR and the use of others for purely business or commercial purposes under IFR in Class A airspace.
The current draft makes no such distinction.
Reason for Comment:
Were member states to be responsible for paying ANSPs for the cost of such exemptions for light ac, there is insufficient assurance that, for administrative convenience by national revenue collecting authorities, a blanket levy would not be imposed on users without reasonable regard for the actual level of service being afforded to, or the nature of, such flights.
Proposed Change/Text:
Delete: Article 14 clauses 2, 3 and 4.
Insert: New clause 2 as follows:
'Aircraft with a certified MTOM of 2000 kg or less, fitted with a single power plant and seating for no more than 6 persons including the Commander shall, when operated anywhere within Eurocontrol airspace with the exception of non-SVFR operation in Class A airspace, be exempt from en-route charges'
The idea of this is that, whereas perhaps someone flying a Seneca full along an airway might reasonably be expected to pay en-route charges, someone else flying a Cub from one farm strip to another, or cutting the corner of the London TMA under SVFR, should not. A line should be drawn somewhere and I think that the Cherokee 6, Beech Bonanza, Cessna 207 in Class D, E, F or G airspace is the reasonable limit whether VFR or IFR. I know that others will disagree, but I had to make my response as it would affect my members directly, not as it would affect the GA community as a whole.