After reading the proposed legislation I posted the following reply to Eurocontrol:
Comment:
Currently a/c under 2000Kg MTOW are exempt from airspace charges. From my reading of the proposed legislation, no guarantees are given that such exemption would be maintained for recreation VFR or IFR flights. A blanket levy affecting all airspace users unevenly penalises recreational users of the system, who are already burdened with heavy fuel duties and, shortly, the requirement for model S compliance. It will ultimately result in reduced safety for all airspace users as I explain in greater detail under “Reasons for comment”.
Reasons for comment:
My personal experience as a private pilot suggests that recreational users are very light users of the air traffic control system. I would like to see this situation improved in the direction of greater usage, not reduced usage. However any charging scheme can only result in a reduced usage.
Greater usage of the ATC system on the part of recreation users gives ATCOs improved situation awareness in and around their airspace. It also improves the same situation awareness of the participating pilots reducing the potential for airprox, airspace violations and of all accidents related to continued VFR into IMC conditions, such as CFIT.
Proposed changes:
Delete article 14, clauses 2,3 and 4.
Insert new clause:
“'Aircraft with a certified MTOW of 2000 kg or less and seating for no more than 6 persons including the pilot-in-command shall, when operated anywhere within Eurocontrol airspace, be exempt from en-route charges'
Beagle: thanks for the inspiration.
Someone will be looking at the number of replies as a measure of general feeling and it is important that as many pilots as possible post their comments to the legislation rather than relying on organisations such as AOPA.