Penny Washers says:
Flylogical is clearly upset that his free ride with the Bulldog (paid for all these years entirely by BAE Systems Plc) has at last come to an end.
It is hardly fair to blame de Havilland Support for this new situation. They have dropped their Design Authority status in favour of the much simpler, and cheaper, Type Responsibility Agreement, which enables Bulldogs (among others) to remain on C of A if the owners so wish.
As
Big Sand noted, DHSL will have certainly known about the impending "fiscal cliff" many years ago. The original contract from BAE will undoubtedly have had a finite term associated with it (no commercial contract has unlimited duration). DHSL should therefore have been preparing for the transition in a professional manner, involving the Bulldog owners, the ultimate stakeholders, in the process. Instead of which, it seems they scrambled for a chair when the music stopped.
A main objection of mine and other owners I've talked to is the way in which this transition was conducted. DHSL unilaterally abandoned the Bulldog TCH without any consultation with the owners. Then, in the same announcement, we were informed that the exclusive TRA would be awarded to DHSL. There was no consultation or any effective opportunity for owners to have a say on this important decision. We were then informed by DHSL that we had to pay them on the order of GBP 800 plus VAT in order to retain our CofA. Again, no consultation, discussion, or negotiation. Given the manner in which the entire process was handled, suitable alternate providers of the TRA simply didn't have the opportunity to compete against DHSL.
So far, you have no problems with that, Flylogical?
Actually, I do. See above comments.
But in the real world, rents have to be paid, liability insurance funded,
We **do not** owe DHSL a living. If they wish to charge a given price for a service they offer, it should be us the customers who decide if their offering is worth the money they are asking. The TRA holder serves the aircraft owners, not the other way round. DHSL should describe what services they are offering, and we should assess if we wish to procure their services. If we don't, we should have the option to choose a competing offer. However, the manner in which DSHL were essentially imposed on us as the exclusive TRA holder, makes it effectively impossible for us to question their offering if we wish to retain our CofA. This is anti-competitive, and raises important questions about competition law.
I specifically asked the CAA what fees DHSL have to pay for the TRA rights. Their answer was "none". So, if you are referring to other CAA fees that DHSL have to pay, unrelated to the Bulldog TRA, then these are of no concern to us.
and the staff have to live.
Again, we do not owe DHSL a living. Their internal costs are of no relevance to this discussion. What matters is whether or not they can provide a decent service at a sensible price to their customers. If not, they should not be in this business. Customers are the most valuable commodity a business can have. DHSL should treat its customers as a valued asset. Without customers, and without BAE subsidies, they are done for.
Divide all these expenses by the number of Bulldogs which are to remain on C of A, and the answer is never going to please you.
The concept of running a viable business on the potential income generated from merely administering the TRA for the Bulldog fleet (60 or so aircraft) is simply not viable (if indeed that is what you are suggesting ?). The corollary of this is that we Bulldog TRA members should certainly not be subsidising DHSL's internal costs for their other activities unrelated to the Bulldog TRA.
Moreover, when questioned on the price-point of approximately GBP 800 (plus VAT) for the TRA, DHSL responded by saying that they assumed an implicit opt-in of 20% or so of Bulldog owners, the remaining 80% they assumed would opt for a Permit-To-Fly. By contrast, in a recent survey conducted by the Bulldog Owners' Club, 80% or so of owners said they would prefer to remain on the CofA if the price was reasonable. By simple arithmetic, this suggests that DHSL could achieve the same target revenues by charging GBP 200 (plus VAT) as opposed to GBP 800. Now, GBP 200 is still a significant sum to pay, so DHSL need to explain to us what sevices we will receive for the money. If DHSL had consulted us before the transition, they might have won our sympathy, and we could together have negotiated sensible terms including price etc.
Those owners who use their Bulldogs for commencial purposes will have to take this on as an extra operating expense
...but if this goes unchallenged, so do the others who wish to retain their CofA, even if they are not operating commercially. For example, I am in this category. I need to invoke the privileges of my IMC rating in order to operate safely in adverse weather conditions. I cannot do so on a Permit.
, but there is always the option of converting to permit operations for all the rest.
This should **not** be a decision forced upon us by DHSL's business practices. Apart from any other considerations, a Bulldog on a Permit will be worth less than on a CofA when it comes to re-sale. Will DHSL compensate us for that loss in value caused by their unilateral actions and policies ? (I thought not).
.... but the CAA Information Notice para. 4.3.1 clearly states that owners using their aircraft for commercial activities should have an agreement in place with the TRA holder by the 1st May 2012.
See my first point. The current state-of-affairs (in terms of choice of TRA holder) was effectively imposed on us as a "done deal". If you now question DHSL directly, they simply point to the CAA notice and, in effect, hide behind it. That is unacceptable (at least to most of us) and needs to be challenged. As I explained when I started this thread, the CAA have made it clear that "they have to take notice if the majority of Bulldog owners are dissatisfied with the current TRA arrangements". So, this is an opportunity to change the situation should the majority of the Bulldog owners wish to do so.
I suggest that if you order a taxi, you should be prepared to pay for it. Otherwise, take the bus.
That is an odd analogy...but let's continue with it. First, I did not "order a taxi". If I did, I would call a firm of my own choosing that charges sensibly and communicates with me effectively. I would certainly not willingly give my business to a company that imposes itself at the front of the queue saying "you have to pay me this amount, or you don't travel".
Finally, it seems that DHSL are now uncommunicative with the Bulldog owners who are challenging them. Many people have questioned their pricing and have tried to get clarification on the terms of the TRA etc. They have either had no response, or received a rebuttal saying "refer to the CAA notice if you have any further questions about the TRA".
In my own case, my correspondence to DSHL has gone unanswered for six months. All I've received is a note to the effect of "we are too busy attending to airworthiness issues to answer your questions just now". Once the six-month point transpired, I posted this thread.
I've recently reported DHSL's lack of responsiveness to the CAA. Their comment was "That's not an effective way for them to deal with their customers". Indeed.