Even the CAA are anti a number of the proposals and urging everyone to provide their feedback
http://www.caa.co.uk/docs/1/DAP_SES_DP6_Charging.pdf
They recognise the need for reform, to proportion costs for IFR traffic appropriately but think the inclusion of 30 smaller airfields in the UK is an unnecessary burden. Unfortunately they don't mention GA.
I have not crafted my response in detail yet, but it will include:
Whilst I broadly agree there could be a case for reform:
1. We are already paying tax through AVGAS when JETA1 is not taxed - this should be redirected and factored in.
2. If an airport benefits by having airspace allocated to it for free (Class D & above) why should we have to pay to go through it under VFR conditions?
3. Regulation should encourage cost effective provision, there is nothing in the proposals that encourages people to reduce their cost base - its back to the old cost+ system!
4. If a country doesn't want the burden of setting up new accounting systems for SAR, MET & AIS why force them?
5. If we are paying for services what representation do we have on their control and availability?
6. If we pay by time in the air, and are held up by ATC, we would then be paying more- again the system would encourage a bad service.
7. What work has been done to ensure the administrative burden proposed is actually justified in leading to improved services, rather than actually costing more than any benefits it may provide.
D&O