Ive had a look at the document, but was unable to download the response document for some reason, I'll try again later. It really looks like they have almost no knowledge of what GA is when they drafted the document, or maybe GA to them is a Gulfstream V. I see the military are in there with concessions- as they fly 10 times less than civil aircraft (well 10 times less than well used airliners I agree, but probably a lot more than the average private aircraft per year!)
I will be sending in my reply this week, I hope everyone else will be too we really do need to fight this now before it is too late.
If they want to charge VFR aircraft for all this, when will they start charging Cyclists for using the roads- they use all the road infrastructure, we do not use most of the ATC/Nav services.
Certainly a fixed charge per year per aircraft would be very unfair, many aircraft are used very infrequently compared to others in use all of the time. There is already a massive fuel tax, why cant the Government use that to pay for a VFR exemption. Why should we pay fuel tax when Airline and Corproate users dont (Jet A1 users)
As for WBS's comments,
Yes there might be a minor increase in safety if everyone had mode S (but mode C would also be sufficient) But then again it would also be safer if no one flew- Its safe enough already thank you.
Uk alone in the western world not requiring transponders??? Where did you get that from?? I have flown GA in France, Switzerland, Germany, Belgium, USA in the last month, in none of these countries is a transponder mandatory.
4096 codes is not a problem for GA, it only seems to be a problem for airliners, wanting to keep the same code for a long distance- maybe this is why we have to change codes when going into Italy??
I dont see the need for more CAS at all, except in cases of new airports. Surely as we now have very few Boeing 707s or Super Constellations with poor climb performance, we can raise the base of controlled airspace around many airfields by 500ft or maybe more, particularly a long way from airfields. And as more and more Airliners have GPS/FMS, surely there is no longer any requirement for low level procedural approaches, flying miles outbound from some becon at 2000ft etc. The airspace and procedures need to be updated to take into account modern methods.
And with less military aircraft, their airspace should become more available and be made class G.
Lets remember that most VFR GA aircraft can fly where they want without any ATC or any ground based Navaids. We talk to ATC sometimes to get clearance through their zones, but these zones are there to protect the airliners, not for GA's benefit, so its the airlines who should pay for this benefit, it is them who need parts of the airspace to be controlled. We are not using the system because we need to, we are using it because the airlines want us to.
Similarly VFR flight plans, apart from the search and rescue standpoint (which is virtually non existant) they are filed because we are told we have to file them to meet a bureaucratic rule. Thus they are filed for the benefit of the bureaucrats, so it is them who should pay, be it customs, immigration or some other agency. After all I dont have to notify anyone if I drive from Paris to Brussels, so why should I have to notify someone just because my flight goes over a border. (a bit off topic this, but presumably there will be charges for flightplans)