UK GA heli flyers please read this

[Flingingwings]

Guys and Gals,

Sorry if this has been posted before.

Forwarded this by HCGB. Seems that Jeremy has located yet another potential expensive change that unified Euro rules are suggesting.

I have been lazy and pasted his email. Please note the cut off date for any replies if you wish to raise an objection.

Mods any chance you could keep this as a 'sticky' till after 17th?

EU - Charging to fly

We have until Sept 17 to object - please respond

Under the European Single Skies Policy to which the UK signed up earlier this year, all aircraft, regardless of whether they are IFR or VFR, and with no minimum weight cut off, could be required to pay for use of 'services' provided, such as air traffic control, NOTAMS and weather information, search and rescue etc.
whether used or not. No exemptions are offered in the draft proposals even for gliders, microlights or balloons. The proposals seem to have been drafted without any thought of the impact on General Aviation (GA).

Costs are to be apportioned on a total, not marginal, cost basis so that VFR aircraft will, for example, bear the cost of a VOR if it provides a service in uncontrolled airspace. This will be regardless of whether the aircraft actually uses the VOR.

Nothing in the draft proposals suggests that even a light aircraft flying non radio, from one private strip in uncontrolled airspace to another will escape being charged. The proposals apply to all civil air traffic. It will be up to the governments of individual states to decide how the payments are levied. The actual draft proposals are attached, and more details may be found at http://www.eurocontrol.int/enprm/

UK Government is sympathetic to GA and wants to exclude us from charges, as at present, but the proposals do not permit that unless the Government pays the costs thereof to the Air Navigation Service Providers - and it won't.

Eurocontrol is undertaking a consultation on the charges and we have until 17 September i.e next Friday, to respond. Not only has Eurocontrol imposed this outrageously short deadline, but responses must be made on its official form, a copy of which is attached.

I don't think that I need spell out what this proposal could do to European GA. Unless we protest we could end up paying for airspace every time we fly, even if we talk to no one. Remember mode S can track you.

The more INDIVIDUALS (in addition to organisations) who respond to the proposals the better. Closure date is 17 SEP and comments MUST be on the attached form or they will be ignored.

I attach:-
The proposals
The Blank Response Form
The HCGB response
It is essential that all members respond to all or some of the points - as usual it is the number of responses that matter.

The key issue it to urge Eurocontrol to exempt all aircraft that weigh less than 2000kg from the proposals, as is the case at present. See Article 6 (3) and 6 (4).

Sorry this is rather late - I've been consolodating the response from other GA organisations.

If anyone thinks of an extra arguements which should be included, please let me know.

Jeremy James
Hon. Sec
HCGB

[delta3]

Quite interesting,

If I read the material it looks like (we=eurocontrol) :
- because we are not so efficient we will charge differently
- we will pretend we look at cost benifit relation but this is cosmetics
- we will probably charge more, because we will centralise more, and because of a potential economies of scale we want more of the thing
- the users are IFR and VFR, (quite simplistic)

What I would like to know is:
- what are reasonable user categories
- what are reasonable costs/charges/benefits for a service
- does one have a choice in selecting services (looks to me fundamental if wanting to provide efficient services : dont forget to ask the customer and leave him some kind of choice)
- is there a proven/highly likely potential for economies of scale, given the efficiency track record (or lack of it), or do they (again) want to multiply administrations and associated costs. After all 'efficient' should somehow mean paying less for the same or I am I wrong..
- is Eurocontrol a cost center or a profit center.... Using profit center tactics for a cost center does not really work, because in a real profit center the customer decides.

I'am curious what the Belgiums are doing with this (not that I am of any authority what so ever), but in GA circles I did not hear anything yet, other then that they will very likely postpone mode S....

[Heliport]

AOPA

News from AOPA: Eurocontrol Charges

www.aopa.co.uk




You may be aware of the current Consultation in relation to a new Charging Scheme which the European Commission through Eurocontrol is proposing to adopt. However, it has NOT been made clear to us whether comments will be considered from individuals and that is why we are asking you to send them to the persons named at the end of this letter.

The Single Sky Regulations came into effect on the 20th April 2004 – in fact there are four Regulations:-

EC Reg 549/2004 Framework


EC Reg 550/2004 Service Provision

EG Reg 551/2004 Airspace

EC Reg 552/2004 Interoperability

Eurocontrol has been given the task (by mandate) to develop the Implementing Rules for each of the Regulations.

The current Consultation on the development of Rules to support a common Charging Scheme for air navigation services will have an impact on General Aviation unless it is opposed – attached is a copy of our response, you will see that it follows a very mechanical process which must be adhered to as failure to do so will result in the submission being returned. Also attached are the blank forms that you need to use.

Whilst AOPA has attempted to provide answers to each of the articles you may wish to concentrate your replies in respect of only 2/3 articles – numbers 6 & 14 for example.

The basic principles evolve around each Member State deciding on which volume of airspace to which they wish to apply charges. This, in effect, could place some of GA’s activities into boxes of airspace, clearly from a safety point of view this is unacceptable. AOPA believes that as a principle Classes F&G airspace should be considered as non charging volumes of airspace as Class G serves the needs of both GA and the military.

The Commission in Article 14 tells the State that they have the power to grant exemptions but where exemptions are given, the State must pay for them. In our view this will have an impact on the Lower Airspace Radar Service (LARS). This is currently funded by way of a rebate of Eurocontrol Navigation Charges totalling £1.6 million annually – the UK Department for Transport estimates the true cost of LARS as being nearer to £7 million. If each GA aircraft has to cover this cost it would be equal to about a £1,000 p.a. per aircraft! So we are concerned about the future of LARS.

We are also concerned about how the proposed charges would be collected. Unlike Commercial Air Transport Operations VFR flights do not always go in straight neat lines so the formula of weight x distance does not work for VFR! If an annual charge were levied by the Member States on their own GA operators, this would be similar to the road tax we pay on our motor cars. However, it would not necessarily be the same amount in each Member State and, as in road tax, there would need to be bilateral agreements in place in order to fly in other Member States. But, an annual tax is completely different from a charge for air navigation services. To start with, the EU has no competence in the area of taxation. If charges for services are to be imposed on GA for flights that are proportionate to the level of service being provided then it is likely that the cost of collection will be greater than the charge itself. This would be unfair and a contravention of the Treaty of Rome i.e. the freedom of movement.

In effect our position is that the status quo should be maintained and that is no charges for VFR flights or IFR flights for aircraft with a MTOM of < 2 tonnes. No charges for flights that arrive and depart at the same aerodrome and no charges for training flights.

The Commercial Air Transport industry receives billions of Euros of subsidies by way of no fuel tax and no VAT on the sale of airline tickets. They use the airspace to make profits for their shareholders whilst GA activity is usually funding from an individual’s tax income. The individual also pays the duty on AVGAS plus the VAT every time they go flying.

The time to act is now! Please add your voice to the Consultation.

Send a copy to Alistair Darling, Minister of Transport, your local MP and MEP and also send a copy to John Arscott at the CAA, DAP and to AOPA.

The more replies the better chance we have to fight off this proposal.

Deadline: 17th September 2004


Martin Robinson
Chief Executive AOPA UK



Send your comments to:-

1. Your own MP

2. Alistair Darling MP
Minister of Transport
Department for Transport
76 Gt Minster House
Marsham Street
London
SW1P


3. Air Vice-Marshal John Arscott
Director of Airspace Policy
45-49 Kingsway
London
WC2B 6TE


The AOPA website has downloadable blank reponse forms and suggested responses which can be copied.

[headsethair]

Ah. So this is where Galway airport got its inspiration! For those who haven't heard - it now costs you two-thirds of a landing fee NOT to land at Galway. This is a transit fee for using their airspace.
And that's airspace with no radar or VOR.
Any comments yet from the IAA ?

[Head Turner]

For those who happily joined Europe you can be sure that regulation after regulation will pour out of every Euro-buro. Health ans Safety regs manifest out of Germany as seems every other rule and regulation. This, my friends is one of many awful things you should expect and for sure it will get no better.

It's time the BRITISH learned to use the word 'NO' which is in our vocabulary I believe!

[helicopter-redeye]

An alternative may be to vote for Mr Kilroy Silk to get us out

[WestWind1950]

Head Turner

Health ans Safety regs manifest out of Germany as seems every other rule and regulation.

where do you get that idea? The German's usually got involved too late... all the regs were already done! And we are just as fighting mad at the supposed European regs!!
We have on top of that the problem of getting the stuff translated into German... one problem you guys DON'T have. Good example: we still are working on JAR-OPS 3 change 1 even though change 4 has long been out (or is there even a change 5 in the mean time??).

We always assumed that you UK people or the French are behind the mess..... :E

Westy

[Vfrpilotpb]

Sadly all politicians spout on about things they know little about, by doing this the crazy folk who drive Dynamically unstable pieces of machinery will always seem to luck out by the imposition of some stupid rules which always seem to stem from Brux.

Apart from Lambit Optic(cant remember his full name) the Lib guy do any other MPs or MEPs or Ministers or Shadow Ministers connected with the UK, fly anything more than their ego's?


Vfr

[muffin]

One of the current Cabinet Ministers (can't remember his name) got his PPL(H) recently. There was an article about him in the last HCGB mag.