The proposal relates to alleged infringements of the Common Rules of the Air (Commission Implementing Regulation (EU) No. 923/2012) also known as SERA, and of any UK national rules of the air. There is no indication that it will only apply to CAT.
As discussed above, the proposal opens the door to vastly different punishments in England (unlimited fine) compared with Scotland (max. £5,000). Some may say that serves the horrid Sassenachs right for being, well, English
, but I'm not so sure.
Also, since the proposal refers to a European Regulation, levels of fines which vary widely across the EU might be seen as contrary to the spirit of the Single European Sky. In this respect I would welcome input from other countries – what is the maximum fine in your country for infringement of the Common Rules of the Air (aka SERA)?
There’s not much real meat in the DfT/CAA consultation. There’s no regulatory impact assessment, allthough it does seem to be characteristically packed with nonsense such as the assertion that the "preferred option" will result in fewer ROTA/SERA infringers being blasted out of the sky…
As for the cost of sending RAF aircrew to escort or guide an alleged infringer - well, we don't pay them to polish their backsides in the mess all day so they might as well get in their aircraft and do something practical.