G-KEST
15th Aug 2005, 22:04
This may well be the longest post ever on Pprune but it just might be worth you taking some action as the CAA intend to make us all considerably poorer.
I attach my own submission in response to the CAA charging scheme proposals which might come into force in January 2006. The final date for responses to be received by the CAA is 5 September 2005. I hope you find my thoughts of interest and I would appreciate any suggestions for change since the CAA has told me that amendments are permissible but only up to the final submission date.
It is absolutely imperative that all of us in General Aviation participate in this exercise as "stakeholders". We have been invited to do so by Mike Bell, the Group Director, Safety Regulation himself. It is my feeling that SRG are, to a certain extent, embarrassed by the size of the charge increases in many cases. It is the Big Guns of civil aviation who have put so much pressure on Sir Roy McNulty to initiate the JRT process and, probably, the manner in which the JRT was constituted as far as GA representation was concerned. A really huge adverse reaction by General Aviation enthusiasts might sway the balance in our favour.
The biggest complainant was, I understand, British Airways whose current problems make their perception of a cross subsidy in favour of GA very small beer indeed. They are at present reputed to be losing in one day 2.5 times the annual sum they were grumbling about to the CAA FAC and chairman. How are the high and mighty fallen.....!!!
Obviously any duplicated submission is not going to receive much detailed attention by the CAA so please feel free to select from my own ideas those you find particularly apt in your own cases.
The web address for this saga at the CAA is -
http://www.caa.co.uk/default.aspx?categoryid=850&pagetype=90&pageid=4950
You will find the relevant response form in that section and this is the only format acceptable to the Authority so please take time to use it. I found it reasonably straightforward.
Rest assured, in my personal opinion, if we do not act due to the usual GA apathetic approach then we do deserve all we will get. It is no use grumbling later when it hits us all in one form or other.
Cheers,
Trapper 69
________________________________
General comment
As long as the JRT report remains on the table at the CAA it hangs like the proverbial Diocletian sword over the head of UK General Aviation. Not especially in this round of consultation but certainly for the future.
The leaked first draft of the JRT report back in the early months of 2005 showed the CAA what a wind they had sown. They did indeed reap the whirlwind in terms of letters and emails to the CAA chairman, the DfT and to members of Parliament. This has caused many of the JRT original proposals to be watered down in this round of consultation.
The thrust of the complaint by the larger UK aviation industry that they subsidise GA totally fails to acknowledge the debt they owe to GA. This in terms of the supply of aircrew, often self sponsored to achieving the professional licences necessary. The same is true of aircraft engineers and other technicians, many of whom are "poached" from GA. Often regional airports have only developed to their present capacity thanks to the previous level of movements by GA aircraft over many decades. Aircraft that are often no longer welcome or subject to punitive levels of user charge.
It has to be remembered that the larger commercial end of UK civil aviation enjoys benefits GA does not share. Examples are such as the ridiculously low rate of duty on turbine fuel as opposed to Avgas. No VAT on airline tickets. The ability to pay for goods and services out of income before tax rather than after as is the case in the majority of GA end users.
From a safety aspect the majority of GA pilots pay for their flying out of a pot of disposable taxed income which competes with all other aspects of life involving expense. If the costs of flying go up then, unfortunately, the pot remains the same and less flying can be afforded. Even perhaps to the extent of folk giving up altogether. If an individual can afford less flying each year then he or she will be less proficient due to lack of recency and currency. This might well lead to an increase in the GA accident rate. Surely this is not what does the Safety Regulation Group of the CAA intend. Whether intended or not it is likely to happen.
Finally, and most importantly, the UK air display industry provides what has become the second most popular form of outdoor public entertainment in this country. It attracts over 6 million spectators annually to watch some of the most exciting visual and aural aerial acts by both military and civilian aircraft and aircrew. There is little doubt that this reinforces the benefits of aviation to a huge cross section of our population and contributes in no small way to air-mindedness here in the UK. Air-mindedness that is absolutely vital to "UK Limited" when it comes to public support for aviation especially when applies to decision making in local councils and at Westminster along with the European Parliament.
It is indeed a tragedy that the protestations to the current CAA chairman of their failure to win the argument within the FAC has now resulted in this hugely expensive work by the JRT which might have a disastrous effect on the segment of UK aviation that really subsidises the airline industry. This both in the current round of consultation and those in the future years.
I turn now to detailed comment on your, potentially ruinous for GA proposals.
(continued in the next instalment)
(continued from part one)
Consultation document on CAA charges
Paragraph 1
Only one GA representative organisation, the BBGA, was a member of the appointed JRT. This despite urgent protestations to the CAA chairman by AOPA(UK), as an FAC member, to be included. No representation whatsoever was included from the sporting and recreational element of GA. An element that is the largest by far in terms of participants in UK civil aviation.
Paragraph 2
In any case the only voices on the FAC from private, sporting and recreational aviation in the UK are from the private pilot membership of AOPA and the RAeC of the UK. Such organisations as the PFA, BMAA, BGA, BHPA, BPA, HCGB, LFA, FFA, BBAC and the BMFA among many others have no place at a forum which can determine the financial future, or otherwise, of their aviation pleasures in life.
The time recording system introduced right across SRG from 1997 was not, at the time I retired in 1998, in any way mature. This then lead to a haphazard allocation of working hours by individual staff. There is no doubt that, on the basis of the TRS data - itself subject to an independent analysis, there is an element of cross subsidy but no account is taken of the benefits to the airlines and the airport system provided in the form of provision of personnel who have obtained their qualifications and training while in GA, often at their own personal expense with no element of sponsorship.
Paragraphs 3 and 4
There needed to be an additional principle as follows-
"To evaluate the benefit to UK Limited and to the "heavy" AOC operators and larger regional airports provided by GA in terms of the supply of professional aircrew and licensed engineers along with GA aircraft movements which boost the possibility of an airport obtaining some variety of controlled airspace.
No mention is made of the minority report submitted by the BBGA along with the JRT report to the CAA chairman.
Paragraph 5
I consider this a distorted view since the voice of private, sporting and recreational general aviation was not heard within the JRT deliberations.
Charging principle 1.
It is vital to remember that, to the very best of my knowledge, aviation is the only UK industry or activity to bear the cost of its own policy and regulation. All others have such costs borne by government departments from general taxation. This has been the case since the CAA was set up in 1972 though the phasing in of charges was done over a period of years. The only single aspect paid for by the DfT is that of AREIB in terms of their investigation and enforcement role where 100% of their costs are reimbursed.
Charging principle 2.
On a personal basis I do not accept this since, to my knowledge from 1984 to 1998, the CAA did not engage in navel gazing or self-evaluation. Efficiency is not measured or risk-benefit analysis undertaken or even if the process could not be more efficiently delegated to industry or the representative bodies.
Charging principle 3.
This is only valid if sensible and appropriate. I really do doubt if the time allocation system is accurate since wasted time is always considered to be zero but does in reality form a significant proportion of any individual’s working day.
Additionally no account is taken in terms of those on the ground who benefit from safety in aviation.
It is demonstrably unfair to pass on to GA any under-recovery to merely balance the books.
Charging principle 4.
Why not pass on non-statutory activity undertaken by the CAA and in particular the General Aviation Department, to outside organisations such as CHIRP and GASCo. Third parties on the surface benefit from SRG work in terms of such malodorous aspects as the precipitous falls of "blue ice" from the skies. Surely the DfT should foot the bill here.
Is there any "loss leader" consideration in costing CAA courses for foreign agencies in terms of enhancing the possibility of future overseas contracts?
Charging principle 5.
My perception of the real GA subsidy to "heavy" AOC operators must be accepted. The retiring British Airways CEO\'s remarks recently did nothing to reduce his, possible unwarranted, reputation within GA as being descended from those who were deported as criminals from the UK to his native country or, alternatively, face execution.
Charging principle 6.
It is absolutely essential that any aspect must be agreed by industry in terms of it being both necessary and appropriate. There can be no "blank cheques" here if GA is to survive, never mind thrive and prosper.
Charging principles 9/10/11.
In my experience prior to 1998 the cost of dealing with enquiries from the public and MP\'s was not charged out back o the DfT for repayment. The enormous cost of policy work leading to legislative change was never charged out to the DfT. It should be as otherwise they would have to duplicate the expertise in SRG - a nugatory exercise indeed.
Paragraph 6
I am of the opinion that the CAA has not significantly reduced its staff in terms of voluntary or compulsory redundancy with the advent of EASA. Some staff have voted with their feet in terms of moving to EASA or industry employment. The staff unions, of which I am a retired member, will certainly oppose any redundancies to the last ditch, of that I am certain. The costs to SRG will be enormous. Who is to pay???
If insurance costs to SRG are rising then may I respectfully suggest you find another broker or underwriter. It is a competitive market out there. Use it.
The increases in charges made for FY 2004/5 in percentage terms went up by approximately 1.6%, a figure in line with UK inflation. You decided not to introduce a revised scheme of charges to come into force for FY 2005/6 that, if the same sort of percentage increase had been applied, would have gone through almost without significant comment from industry or GA interests. That was your decision and, frankly, your mistake in terms of revenue. Do not put the financial blame onto GA to attempt to rectify your mistake.
I note your comment that "the CAA continually strives to reduce the overall cost of regulation and the regulatory impact on all sections of the aviation community". Times seem to have changed.
The JRT report is still on the CAA financial departments table. Its implications are fairly clear from the table in para 6. In particular the GA and AAC schemes income is planned to rise from 211K in FY2005/6 to 395K in FY 2007/8, a difference of 184K. This represents a percentage increase of over 87% over three years or 29% per year - a truly swingeing increase that will impact GA very seriously.
Paragraph 7
7.1
AOC/POC schemes.
Your proposals will have the effect of seriously damaging the sub 15 MT AOC operators financial viability to the extent that you risk seeing many go to the wall. Do you want this to happen? If so then remember all those professional aircrew who gain their initial commercial experience with such operators. This to the benefit of the "heavy" AOC operators who then "poach" them from their smaller brethren.
7.2
GA and AAC schemes.
Apparently some two thirds of GAD costs are now paid for by "heavy" AOC operators. This possibly equates to the costs incurred in policy aspects by a significant proportion of GAD staff, both FSO\'s and administrative. Surely this does need to be paid for by the DfT as, in the absence of the CAA and especially GAD within SRG, they would have to provide the required level of expertise from their own government departmental resources no matter what Gordon Brown might think.
7.2.2
You state the assumption that volumes will remain similar to those in 2005/6. I really do think you are underestimating the damaging effect your charging scheme proposals will have on the level of activity. This in many areas, not merely that of GA and AAC activity.
I note your intention to conduct a review of GAD activity and have seen the letter from the CAA chairman sent out to representative organisations recently. I commend the idea but dread to think just who will be appointed to any review team bearing in mind the vital need for a real appreciation of the art of the possible in GA. An appreciation somewhat rarely found in my own experience.
Your charging proposals in this scheme amount to an increase of approximately 8.4% in the effective period April 2004 to January 2006 or some 33 months. This equates to approximately 3.3% per annum. Even this is above the rate of UK inflation.
The outraged reaction to the leaked JRT draft report almost certainly had a huge impact on the CAA as a result of pressure from individual "stakeholders", MP\'s, the DfT and, I believe significantly, by the avalanche of protesting letters and emails which thumped onto the desk of the CAA chairman. I bet Sir Roy McNulty\'s PA wore out several letter openers and consumed much of the remaining Amazon rain forest in dealing with them. I am reminded of that wonderful phrase beloved of Sergeant Jones of "Dads Army" fame - "They do not like having it up them..............!!!!!!!!". How true, how very true.
7.3
Aerodrome licensing etc scheme.
Licensed ATC is not necessary for GA in terms of probably 98% of that done in the UK in day VFR "see and avoid" conditions.
The efforts of the joint CAA/GA industry Light Aviation Airports Study Group which has had some 6 meetings so far in 2005 may well remove the need for virtually all small licensed aerodromes to have any form of CAA regulated licence. A measure long overdue for the last 39 years to my certain knowledge. It should be noted that the FAA regulates only 10% of all the aerodromes in the USA in any way. Even then their oversight is a "paperwork" exercise by submitting a box-ticked proforma. Any physical inspection process by the FAA is only as a result of an accident or incident in order to check the veracity of the placed ticks.
The derogation in terms of movements by heavier aircraft than appropriate for the category of aerodrome licence is to be reduced from the present "less than 700 movements in the busiest quarter" to "less than 25 per annum". The mind boggles at the magnitude of the potential reduction in numbers. Why.........??? Are you insinuating that your policy up to now has been too permissive....??? Surely not.
The current Aerodrome licensing charges are incorrectly quoted in terms of the lowest category aerodrome day only licence at present available but now to be discontinued whether or not any night flying is possible at a particular venue.
The increases proposed for both aerodrome and ATC licensing are horrendous. Percentage increases of 386% for aerodromes accepting aircraft of between 2.73 and 6 MT are suggested and ATC provision at aerodromes employing up to five ATCO\'s are intended to rise by 500%. Have you any concept of the damage this will cause...???
(continued in part three)
(continued from part two)
7.4
Personnel licensing scheme.
You propose a new charge, for the approval of microlight schools offering FIC, of £280 with a, presumably annual, renewal charge of £250. This for work that could be done by the BMAA as is, I understand, presently done for SLMG FIC training by BGA clubs.
Charges for the initial and renewal of both private and professional pilots licences are to rise by approximately 7% and 9% per annum respectively. An increase well in excess of inflation. It is not beyond the wit of man or even the CAA to delegate the administrative element of the issue or renewal of a pilots licence, especially those in the private sector, to industry, as has been the case with the NPPL. This with no adverse safety implication and a huge financial benefit to both the CAA and to those outside.
7.5
Airworthiness etc scheme.
Your proposal to introduce a charge of £1675 for "stand alone" Part M subpart G and F for aircraft weighing up to 5.7 MT is iniquitous bearing in mind such approval will usually be funded by an individual or very small company.
Permits to Fly are to be subject to horrendous level of increase in charges that will affect non-PFA or BMAA administered aircraft. These include all "warbirds" and ex-military jet types. Your current income here is £156K and this is proposed to rise to £663K, some 425% over 4.5 years or about 94% per annum. What a disastrous increase for the operators of, what might well be termed "heritage", aircraft that contribute enormously to the living history of UK aviation.
Permit charges for those aircraft less than 2730 kg will rise by 23% as will the maximum charges imposed on such aircraft. Huge increases once more that directly impact on the private GA owner operator.
I note in one of the documents reference to the cost of CAA staff time being, inclusive of overheads, £172 per hour. Assuming a 7 hour working day, a 5 day working week and a 48 week working year with an 80% efficiency factor to allow for sickness and other absences this gives a 1344 hours per annum. If this figure is multiplied by £172 then the cost becomes £231,168. Assuming an overhead margin of 100% of labour cost then the salary cost per CAA employee is now £115,584. Salaries seem to have risen by over 250% since I retired in 1998 though my CAA pension has not. This by a factor of, possibly, 10 despite its index linking. The IPMS has achieved veritable wonders in terms of improvements in terms and conditions for its members and others in SRG in but seven years. Nevertheless I do prefer retirement to the Belgrano. Later in another document I have noticed that an FSO in GAD costs £84 per hour as opposed to the £172 quoted above for a surveyor in DMSD. My previous remarks on the level of salary increases are thus negated since the £84 per hour would give an annual salary level of £56,448, a figure not too far removed from my final salary by approximately 25% or around 3% pa index linking. I do wonder however as a professional pilot FSO qualified in many disciplines how I was valued at less than half the worth of a surveyor in DMSD. Supply and demand I suppose. As long as there is no well-remunerated work outside the RAF for navigators or for medically rejected civil airline flight deck crew the CAA will have a ready supply of professional aircrew to fill FSO vacancies. However from time to time, and I submit from a degree of personal experience, a questionable efficiency potential.
Charges for approval of organisations are intended to rise by 168% over three years or 56% per annum. This will have an awful financial implication to those affected and will cause an immediate increase in the charges to their customers.
7.6
Aircraft registration scheme.
There is to be a 20% increase in aircraft registration scheme charges. This, presumably, to justify the additional expense imposed by the CAA adopting the checking of aircraft insurance imposed by new EU requirements. The DfT should bear these costs since it is their legislation that has given rise to them.
(thats all folks - hope you read it all.
To whom it might interest –
Initial draft prepared in period mid July to mid August 2005 and finally crafted into CAA acceptable format on15 August 2005
Cheers,
Trapper 69
:mad: :mad:
I attach my own submission in response to the CAA charging scheme proposals which might come into force in January 2006. The final date for responses to be received by the CAA is 5 September 2005. I hope you find my thoughts of interest and I would appreciate any suggestions for change since the CAA has told me that amendments are permissible but only up to the final submission date.
It is absolutely imperative that all of us in General Aviation participate in this exercise as "stakeholders". We have been invited to do so by Mike Bell, the Group Director, Safety Regulation himself. It is my feeling that SRG are, to a certain extent, embarrassed by the size of the charge increases in many cases. It is the Big Guns of civil aviation who have put so much pressure on Sir Roy McNulty to initiate the JRT process and, probably, the manner in which the JRT was constituted as far as GA representation was concerned. A really huge adverse reaction by General Aviation enthusiasts might sway the balance in our favour.
The biggest complainant was, I understand, British Airways whose current problems make their perception of a cross subsidy in favour of GA very small beer indeed. They are at present reputed to be losing in one day 2.5 times the annual sum they were grumbling about to the CAA FAC and chairman. How are the high and mighty fallen.....!!!
Obviously any duplicated submission is not going to receive much detailed attention by the CAA so please feel free to select from my own ideas those you find particularly apt in your own cases.
The web address for this saga at the CAA is -
http://www.caa.co.uk/default.aspx?categoryid=850&pagetype=90&pageid=4950
You will find the relevant response form in that section and this is the only format acceptable to the Authority so please take time to use it. I found it reasonably straightforward.
Rest assured, in my personal opinion, if we do not act due to the usual GA apathetic approach then we do deserve all we will get. It is no use grumbling later when it hits us all in one form or other.
Cheers,
Trapper 69
________________________________
General comment
As long as the JRT report remains on the table at the CAA it hangs like the proverbial Diocletian sword over the head of UK General Aviation. Not especially in this round of consultation but certainly for the future.
The leaked first draft of the JRT report back in the early months of 2005 showed the CAA what a wind they had sown. They did indeed reap the whirlwind in terms of letters and emails to the CAA chairman, the DfT and to members of Parliament. This has caused many of the JRT original proposals to be watered down in this round of consultation.
The thrust of the complaint by the larger UK aviation industry that they subsidise GA totally fails to acknowledge the debt they owe to GA. This in terms of the supply of aircrew, often self sponsored to achieving the professional licences necessary. The same is true of aircraft engineers and other technicians, many of whom are "poached" from GA. Often regional airports have only developed to their present capacity thanks to the previous level of movements by GA aircraft over many decades. Aircraft that are often no longer welcome or subject to punitive levels of user charge.
It has to be remembered that the larger commercial end of UK civil aviation enjoys benefits GA does not share. Examples are such as the ridiculously low rate of duty on turbine fuel as opposed to Avgas. No VAT on airline tickets. The ability to pay for goods and services out of income before tax rather than after as is the case in the majority of GA end users.
From a safety aspect the majority of GA pilots pay for their flying out of a pot of disposable taxed income which competes with all other aspects of life involving expense. If the costs of flying go up then, unfortunately, the pot remains the same and less flying can be afforded. Even perhaps to the extent of folk giving up altogether. If an individual can afford less flying each year then he or she will be less proficient due to lack of recency and currency. This might well lead to an increase in the GA accident rate. Surely this is not what does the Safety Regulation Group of the CAA intend. Whether intended or not it is likely to happen.
Finally, and most importantly, the UK air display industry provides what has become the second most popular form of outdoor public entertainment in this country. It attracts over 6 million spectators annually to watch some of the most exciting visual and aural aerial acts by both military and civilian aircraft and aircrew. There is little doubt that this reinforces the benefits of aviation to a huge cross section of our population and contributes in no small way to air-mindedness here in the UK. Air-mindedness that is absolutely vital to "UK Limited" when it comes to public support for aviation especially when applies to decision making in local councils and at Westminster along with the European Parliament.
It is indeed a tragedy that the protestations to the current CAA chairman of their failure to win the argument within the FAC has now resulted in this hugely expensive work by the JRT which might have a disastrous effect on the segment of UK aviation that really subsidises the airline industry. This both in the current round of consultation and those in the future years.
I turn now to detailed comment on your, potentially ruinous for GA proposals.
(continued in the next instalment)
(continued from part one)
Consultation document on CAA charges
Paragraph 1
Only one GA representative organisation, the BBGA, was a member of the appointed JRT. This despite urgent protestations to the CAA chairman by AOPA(UK), as an FAC member, to be included. No representation whatsoever was included from the sporting and recreational element of GA. An element that is the largest by far in terms of participants in UK civil aviation.
Paragraph 2
In any case the only voices on the FAC from private, sporting and recreational aviation in the UK are from the private pilot membership of AOPA and the RAeC of the UK. Such organisations as the PFA, BMAA, BGA, BHPA, BPA, HCGB, LFA, FFA, BBAC and the BMFA among many others have no place at a forum which can determine the financial future, or otherwise, of their aviation pleasures in life.
The time recording system introduced right across SRG from 1997 was not, at the time I retired in 1998, in any way mature. This then lead to a haphazard allocation of working hours by individual staff. There is no doubt that, on the basis of the TRS data - itself subject to an independent analysis, there is an element of cross subsidy but no account is taken of the benefits to the airlines and the airport system provided in the form of provision of personnel who have obtained their qualifications and training while in GA, often at their own personal expense with no element of sponsorship.
Paragraphs 3 and 4
There needed to be an additional principle as follows-
"To evaluate the benefit to UK Limited and to the "heavy" AOC operators and larger regional airports provided by GA in terms of the supply of professional aircrew and licensed engineers along with GA aircraft movements which boost the possibility of an airport obtaining some variety of controlled airspace.
No mention is made of the minority report submitted by the BBGA along with the JRT report to the CAA chairman.
Paragraph 5
I consider this a distorted view since the voice of private, sporting and recreational general aviation was not heard within the JRT deliberations.
Charging principle 1.
It is vital to remember that, to the very best of my knowledge, aviation is the only UK industry or activity to bear the cost of its own policy and regulation. All others have such costs borne by government departments from general taxation. This has been the case since the CAA was set up in 1972 though the phasing in of charges was done over a period of years. The only single aspect paid for by the DfT is that of AREIB in terms of their investigation and enforcement role where 100% of their costs are reimbursed.
Charging principle 2.
On a personal basis I do not accept this since, to my knowledge from 1984 to 1998, the CAA did not engage in navel gazing or self-evaluation. Efficiency is not measured or risk-benefit analysis undertaken or even if the process could not be more efficiently delegated to industry or the representative bodies.
Charging principle 3.
This is only valid if sensible and appropriate. I really do doubt if the time allocation system is accurate since wasted time is always considered to be zero but does in reality form a significant proportion of any individual’s working day.
Additionally no account is taken in terms of those on the ground who benefit from safety in aviation.
It is demonstrably unfair to pass on to GA any under-recovery to merely balance the books.
Charging principle 4.
Why not pass on non-statutory activity undertaken by the CAA and in particular the General Aviation Department, to outside organisations such as CHIRP and GASCo. Third parties on the surface benefit from SRG work in terms of such malodorous aspects as the precipitous falls of "blue ice" from the skies. Surely the DfT should foot the bill here.
Is there any "loss leader" consideration in costing CAA courses for foreign agencies in terms of enhancing the possibility of future overseas contracts?
Charging principle 5.
My perception of the real GA subsidy to "heavy" AOC operators must be accepted. The retiring British Airways CEO\'s remarks recently did nothing to reduce his, possible unwarranted, reputation within GA as being descended from those who were deported as criminals from the UK to his native country or, alternatively, face execution.
Charging principle 6.
It is absolutely essential that any aspect must be agreed by industry in terms of it being both necessary and appropriate. There can be no "blank cheques" here if GA is to survive, never mind thrive and prosper.
Charging principles 9/10/11.
In my experience prior to 1998 the cost of dealing with enquiries from the public and MP\'s was not charged out back o the DfT for repayment. The enormous cost of policy work leading to legislative change was never charged out to the DfT. It should be as otherwise they would have to duplicate the expertise in SRG - a nugatory exercise indeed.
Paragraph 6
I am of the opinion that the CAA has not significantly reduced its staff in terms of voluntary or compulsory redundancy with the advent of EASA. Some staff have voted with their feet in terms of moving to EASA or industry employment. The staff unions, of which I am a retired member, will certainly oppose any redundancies to the last ditch, of that I am certain. The costs to SRG will be enormous. Who is to pay???
If insurance costs to SRG are rising then may I respectfully suggest you find another broker or underwriter. It is a competitive market out there. Use it.
The increases in charges made for FY 2004/5 in percentage terms went up by approximately 1.6%, a figure in line with UK inflation. You decided not to introduce a revised scheme of charges to come into force for FY 2005/6 that, if the same sort of percentage increase had been applied, would have gone through almost without significant comment from industry or GA interests. That was your decision and, frankly, your mistake in terms of revenue. Do not put the financial blame onto GA to attempt to rectify your mistake.
I note your comment that "the CAA continually strives to reduce the overall cost of regulation and the regulatory impact on all sections of the aviation community". Times seem to have changed.
The JRT report is still on the CAA financial departments table. Its implications are fairly clear from the table in para 6. In particular the GA and AAC schemes income is planned to rise from 211K in FY2005/6 to 395K in FY 2007/8, a difference of 184K. This represents a percentage increase of over 87% over three years or 29% per year - a truly swingeing increase that will impact GA very seriously.
Paragraph 7
7.1
AOC/POC schemes.
Your proposals will have the effect of seriously damaging the sub 15 MT AOC operators financial viability to the extent that you risk seeing many go to the wall. Do you want this to happen? If so then remember all those professional aircrew who gain their initial commercial experience with such operators. This to the benefit of the "heavy" AOC operators who then "poach" them from their smaller brethren.
7.2
GA and AAC schemes.
Apparently some two thirds of GAD costs are now paid for by "heavy" AOC operators. This possibly equates to the costs incurred in policy aspects by a significant proportion of GAD staff, both FSO\'s and administrative. Surely this does need to be paid for by the DfT as, in the absence of the CAA and especially GAD within SRG, they would have to provide the required level of expertise from their own government departmental resources no matter what Gordon Brown might think.
7.2.2
You state the assumption that volumes will remain similar to those in 2005/6. I really do think you are underestimating the damaging effect your charging scheme proposals will have on the level of activity. This in many areas, not merely that of GA and AAC activity.
I note your intention to conduct a review of GAD activity and have seen the letter from the CAA chairman sent out to representative organisations recently. I commend the idea but dread to think just who will be appointed to any review team bearing in mind the vital need for a real appreciation of the art of the possible in GA. An appreciation somewhat rarely found in my own experience.
Your charging proposals in this scheme amount to an increase of approximately 8.4% in the effective period April 2004 to January 2006 or some 33 months. This equates to approximately 3.3% per annum. Even this is above the rate of UK inflation.
The outraged reaction to the leaked JRT draft report almost certainly had a huge impact on the CAA as a result of pressure from individual "stakeholders", MP\'s, the DfT and, I believe significantly, by the avalanche of protesting letters and emails which thumped onto the desk of the CAA chairman. I bet Sir Roy McNulty\'s PA wore out several letter openers and consumed much of the remaining Amazon rain forest in dealing with them. I am reminded of that wonderful phrase beloved of Sergeant Jones of "Dads Army" fame - "They do not like having it up them..............!!!!!!!!". How true, how very true.
7.3
Aerodrome licensing etc scheme.
Licensed ATC is not necessary for GA in terms of probably 98% of that done in the UK in day VFR "see and avoid" conditions.
The efforts of the joint CAA/GA industry Light Aviation Airports Study Group which has had some 6 meetings so far in 2005 may well remove the need for virtually all small licensed aerodromes to have any form of CAA regulated licence. A measure long overdue for the last 39 years to my certain knowledge. It should be noted that the FAA regulates only 10% of all the aerodromes in the USA in any way. Even then their oversight is a "paperwork" exercise by submitting a box-ticked proforma. Any physical inspection process by the FAA is only as a result of an accident or incident in order to check the veracity of the placed ticks.
The derogation in terms of movements by heavier aircraft than appropriate for the category of aerodrome licence is to be reduced from the present "less than 700 movements in the busiest quarter" to "less than 25 per annum". The mind boggles at the magnitude of the potential reduction in numbers. Why.........??? Are you insinuating that your policy up to now has been too permissive....??? Surely not.
The current Aerodrome licensing charges are incorrectly quoted in terms of the lowest category aerodrome day only licence at present available but now to be discontinued whether or not any night flying is possible at a particular venue.
The increases proposed for both aerodrome and ATC licensing are horrendous. Percentage increases of 386% for aerodromes accepting aircraft of between 2.73 and 6 MT are suggested and ATC provision at aerodromes employing up to five ATCO\'s are intended to rise by 500%. Have you any concept of the damage this will cause...???
(continued in part three)
(continued from part two)
7.4
Personnel licensing scheme.
You propose a new charge, for the approval of microlight schools offering FIC, of £280 with a, presumably annual, renewal charge of £250. This for work that could be done by the BMAA as is, I understand, presently done for SLMG FIC training by BGA clubs.
Charges for the initial and renewal of both private and professional pilots licences are to rise by approximately 7% and 9% per annum respectively. An increase well in excess of inflation. It is not beyond the wit of man or even the CAA to delegate the administrative element of the issue or renewal of a pilots licence, especially those in the private sector, to industry, as has been the case with the NPPL. This with no adverse safety implication and a huge financial benefit to both the CAA and to those outside.
7.5
Airworthiness etc scheme.
Your proposal to introduce a charge of £1675 for "stand alone" Part M subpart G and F for aircraft weighing up to 5.7 MT is iniquitous bearing in mind such approval will usually be funded by an individual or very small company.
Permits to Fly are to be subject to horrendous level of increase in charges that will affect non-PFA or BMAA administered aircraft. These include all "warbirds" and ex-military jet types. Your current income here is £156K and this is proposed to rise to £663K, some 425% over 4.5 years or about 94% per annum. What a disastrous increase for the operators of, what might well be termed "heritage", aircraft that contribute enormously to the living history of UK aviation.
Permit charges for those aircraft less than 2730 kg will rise by 23% as will the maximum charges imposed on such aircraft. Huge increases once more that directly impact on the private GA owner operator.
I note in one of the documents reference to the cost of CAA staff time being, inclusive of overheads, £172 per hour. Assuming a 7 hour working day, a 5 day working week and a 48 week working year with an 80% efficiency factor to allow for sickness and other absences this gives a 1344 hours per annum. If this figure is multiplied by £172 then the cost becomes £231,168. Assuming an overhead margin of 100% of labour cost then the salary cost per CAA employee is now £115,584. Salaries seem to have risen by over 250% since I retired in 1998 though my CAA pension has not. This by a factor of, possibly, 10 despite its index linking. The IPMS has achieved veritable wonders in terms of improvements in terms and conditions for its members and others in SRG in but seven years. Nevertheless I do prefer retirement to the Belgrano. Later in another document I have noticed that an FSO in GAD costs £84 per hour as opposed to the £172 quoted above for a surveyor in DMSD. My previous remarks on the level of salary increases are thus negated since the £84 per hour would give an annual salary level of £56,448, a figure not too far removed from my final salary by approximately 25% or around 3% pa index linking. I do wonder however as a professional pilot FSO qualified in many disciplines how I was valued at less than half the worth of a surveyor in DMSD. Supply and demand I suppose. As long as there is no well-remunerated work outside the RAF for navigators or for medically rejected civil airline flight deck crew the CAA will have a ready supply of professional aircrew to fill FSO vacancies. However from time to time, and I submit from a degree of personal experience, a questionable efficiency potential.
Charges for approval of organisations are intended to rise by 168% over three years or 56% per annum. This will have an awful financial implication to those affected and will cause an immediate increase in the charges to their customers.
7.6
Aircraft registration scheme.
There is to be a 20% increase in aircraft registration scheme charges. This, presumably, to justify the additional expense imposed by the CAA adopting the checking of aircraft insurance imposed by new EU requirements. The DfT should bear these costs since it is their legislation that has given rise to them.
(thats all folks - hope you read it all.
To whom it might interest –
Initial draft prepared in period mid July to mid August 2005 and finally crafted into CAA acceptable format on15 August 2005
Cheers,
Trapper 69
:mad: :mad: