For those who aren't members of AOPA, here's the text of a members' email which went out a couple of days ago on the CAA inquiry. (In fact, only 1,355 emails went out before the system crashed, so some members may not yet have theirs). You may find some of it useful:
To all AOPA members and supporters
There are two major issues which require your attention AND ACTION right now. The first concerns a House of Commons Transport Select Committee investigation into the whole structure and remit of the Civil Aviation Authority. The second concerns the Department for Transport’s consultation on foreign registered aircraft operating in the UK.
Both of these issues have long-term ramifications for general aviation and present threats and opportunities. Because of consultation deadlines we are unable to wait for the next issue of General Aviation magazine to put the facts before you and ask you to respond. Please, therefore, read the attached notes and make representations to those named. These notes are based on AOPA’s submissions, which are not yet fully finalised. If you believe you have observations which ought to be included in AOPA’s submissions, please email
[email protected].
I'll post the N-reg consultation document in an appropriate place.
Reality check for the CAA
The Commons Transport Select Committee has announced a far-reaching investigation into the efficiency and operation of the Civil Aviation Authority – an investigation that has been roundly welcomed by AOPA and which follows an unprecedented level of Parliamentary action by our supporters in the Commons and the Lords, including shadow defence minister Gerald Howarth MP, deputy Leader of the House Nigel Griffiths MP, Lembit Opik MP, and Lords Goschen, Trefgarne, Rotherwick and Stevens.
This is an unprecedented opportunity to improve the safety of general aviation in this country by fitting regulation more closely to our needs, and introducing logic and common sense to the oversight of GA. Please do not pass up this opportunity – write to, and email, the committee with your views.
You may consider that some of what follows is suitable for inclusion in your own submission to the committee. You may think this is all tosh and make a submission from scratch. Either way, PLEASE HAVE YOUR SAY. The committee needs to understand the depth of general aviation's dissatisfaction with the CAA.
TOP COVER
AOPA will be making the point that it is undesirable for there to be no "top cover" for the CAA. The Authority effectively decides what work it should do, how many people it needs to do it and how much it should charge for the work. Because of the 'safety' aspect of the CAA’s remit, it is difficult to challenge its decisions. Yet the CAA is no different from any other authority in that it is subject to the bureaucratic pressures of empire building, featherbedding and jobs for the boys. The CAA needs a permanent, independent review body to which industry can appeal when it believes it is being imposed upon for all the wrong reasons.
TIPPING POINT
The CAA's record on safety in general aviation needs to be split off from the overall safety picture. In fact, UK large public transport operations are safer than those of, for instance, the United States, where airline safety is poorer largely because of the record of commuter airlines, which have no real parallel in the UK. But in purely general aviation terms, the UK's safety record is no better than that of the United States - and may be marginally worse - despite the overwhelmingly greater burden that the CAA imposes on general aviation when compared to the FAA. It does not follow that more regulation equals more safety. In fact, AOPA argues that in some circumstances the opposite is the case. Those countries in Europe which have regulated general aviation almost to vanishing point have the poorest safety records. What improves safety is pilot currency and practice, and the ever-increasing burden of CAA charges on general aviation mean that UK general aviation pilots are not as current as they could be. AOPA believes that CAA charges have already gone beyond the 'tipping point' at which regulatory costs become a drag on safety, and that a substantial reduction in the CAA's financial impost on general aviation would make flying safer.
CARRYING THE CAN
AOPA believes the structure of the hiring practices of the CAA are not optimal, and that as a result the Authority is too easily able to wash its hands of its mistakes. The executive directorship of the CAA should not be a short-term appointment, and there should be an end to the practice of hiring military officers who build second and third index-linked final salary pensions in executive positions while crossing off the days to retirement. An example of the negative effect of this practice is the introduction by the CAA of JAR-FCL, which the current Head of Safety Regulation recently termed "a disaster" and for which he apologised. Yet there is no one around to answer for the decisions that were made at the time – all have moved on. Similarly, those who are making even more disastrous decisions today on CAA charges will not be around to answer for their mistakes in four or five years. This must stop, and the CAA must hire an executive cadre with proven commercial capabilities and a knowledge of general aviation as well as an overriding safety responsibility.
ROBBING THE POOR
For charging and oversight purposes, the CAA must stop treating aviation as a single entity. The airlines cannot be equated with GA. Airlines are overwhelmingly a leisure industry, with more than 75 percent of passengers flying for fun. They are massively subsidised, pay no fuel tax or VAT and tickets, buy cheap aircraft thanks to government subsidies to manufacturers, enjoy bilateral deals which stifle competition and profit from passenger departure tax, which they bank for 90 days before passing on. They get direct government handouts of £2,320,720 a year to keep running unprofitable routes. They are hugely profitable. By contrast, more than 70 percent of general aviation flights are for business or flight training. GA pays a full measure of fuel tax and VAT, its margins are razor-thin or non-existent, and it is shrinking. GA pilots who go to the airlines provide de facto subsidies of between £50,000 and £100,000 each in the cost of training for which the airlines once paid. The commercial reality of general aviation must be recognised by the CAA, and its regulation costed accordingly.
BORING REPEATS
There must be a more robust attitude to repetitive inspections, which risk bringing the CAA into disrepute by looking like make-work, make-money projects. An installation check on a simulator is justified, even at a CAA price of £10,000. A follow-up inspection a year later may also be justified, but further annual inspections costing thousands of pounds when nothing has changed are unnecessary financial impositions on training schools and student pilots. Similarly, repetitive inspections of aerodromes where nothing has changed should be replaced by an audit system. There is no justification for requiring aerodromes to pay thousands of pounds for new surveys every five years when nothing has changed. Every CAA repetitive inspection should be scrutinised for value.
Every department of the CAA should be required to justify its existence. AOPA questions whether the CAA needs a medical department when medical checks can cost-effectively be carried out by the private sector, where the real expertise lies. Does the CAA need a standing legal department? Can the work of the CAAFU be more cost-effectively carried out by the private sector with no diminution of safety? Why should the CAA place restrictions on private examiners who perform the work of the CAAFU? Does the CAA need offices in Kingsway as well as Gatwick, and regional offices around the country? Is it necessary for the CAA to issue licences when the work could be done more quickly and cost-effectively by agencies such as the DVLA? This Select Committee investigation provides a vital opportunity to take a clean-sheet approach to the level of involvement the CAA in general aviation. Is it possible to remove every aircraft under 5,700kg from CAA oversight and transfer responsibility to industry, as has been done with most permit aircraft?
PROFIT MOTIVE
AOPA questions the requirement for the CAA to make a six percent return on capital. The norm for the public sector is 3.5 percent. Why should the regulation of aviation safety attract a more onerous profit requirement?
You will certainly have your own opinions on some of these matters, and NOW IS THE TIME TO MAKE THEM HEARD.
Please send a paper copy of your submission to:
Transport Committee
House of Commons
7 Millbank
London SW1P 3JA
and email an electronic copy to
[email protected] before November 14th.
For a few more details on the Transport Select Committee's CAA brief see the website
http://www.parliament.uk/parliamenta...s_notice09.cfm
Please send a copy of your response to
[email protected]