Inquiry into the CAA

[Dave Unwin]

It has come to my attention that the Transport Committee of the House of Commons has decided to launch an inquiry into the remit and work of the Civil Aviation Authority. The Committee intends to look at the following issues:

• the remit, structure, and powers of the CAA;
• the performance of the CAA in relation to its statutory objectives and functions
• the effectiveness and efficiency of the CAA’s regulatory framework
• the effectiveness and efficiency of the CAA in the general discharge of its duties;
• the effect of growing international and European Union cooperation on the work of the CAA.

The Transport Committee have invited interested parties to submit written memoranda to the Committee before Monday November 14 2005, and I would suggest that if you’re a PPRuNer then you’re an interested party! It is important that you tender your views when you’re asked for them - so get writing. Memoranda should be a maximum of six A4 pages in length, and the committee asks that you please submit a single hard copy of your memorandum by post to;-
Transport Committee
House of Commons
7 Millbank
London
SW1P 3JA

and an electronic version preferably by e-mail to [email protected] or alternatively on a disk with the hard copy. If you are unable to submit an electronic version of your memorandum, please take particular care to ensure that your submission is legible. All submissions should be final and complete; the Committee does not accept draft memoranda or subsequent amendments. Memoranda submitted to the Committee should be kept confidential until published by the Committee.

I don’t think I’ve ever met a pilot who didn’t have a view on the CAA, so this is your chance to get those views heard, by people that might make a difference. And do bear in mind that you've got less than a month to respond.

Dave

[ozplane]

Thanks for the heads-up on this one. I'm surprised that no-one has responded as it seems like a good opportunity to point out the perceived shortcomings of the CAA. I'll be replying. Did this come about as a result of lobbying by the tri=party group of House of Commons flyers?

[CPilotUK]

I'm surprised that no-one has responded

It's early days, considering that this thread started 9:34 this morning; I'm sure this thread will become busy once everyone gets home.

I received the news release from my flying club this afternoon.

[rustle]

Dave, hope you dont mind, I've cross posted this on the FLYER forum as well :)

[Fuji Abound]

OK - I think we PPRuners should use this thread to put together a memorandum on N reg and PPL IR - all contributions welcome! I think it is a pretty important regulatory issue.

[rustle]

I think we PPRuners should use this thread to put together a memorandum on N reg and PPL IRThe other 9,999 threads about it not enough then, Fuji Abound? ;)

[BEagle]

The problems with the CAA are mainly due to not enough staff - and that they also have to make a working profit thanks to Mad Maggie T.

[Dave Unwin]

No prob Rustle - the more the merrier.

[IO540]

It would be useful to know the bounds of what is going to be acceptable here.

At one end of the scale one could simply state that the CAA should be disbanded and that the UK Govt should contract the FAA to do its job. That would work perfectly well, would be FAR (no pun intended) better for most UK pilots, but is exceedingly unlikely to be adopted!

However, even if the above was on the cards, where does EASA come into the picture? EASA has already taken over certification and the CAA does little more than give its opinion to EASA and then pass bits of paper across. EASA will take over FCL from JAA soon, which will leave the CAA as nothing more than the UK office of EASA.

So, the CAA is now largely irrelevant when it comes to making big rules. It is just a bunch of people left to fight various turf wars, between themselves and EASA, and between themselves, while waiting for their jobs to gradually disappear, while deciding whether to charge £50 or £150 for renewing a PPL.

Now, one could shut down EASA and contract the FAA to do the work and that would be absolutely brilliant. Or one could achieve the same result by setting a European agency (EASA?) which is told to adopt FAA regs lock stock and barrel. How likely is this? EASA is going to have to take on board FAA certification anyway, if it wants to have any hope of evicting the several thousand N-reg planes parked around Europe, and a pretty full acceptance of FAA licenses and more importantly the IR is going to have to be a part of that.

But EASA isn't listening here (or anywhere else perhaps). This is a purely CAA matter.

What am I missing?

Beagle - it was actually Winston C who decided the CAA should be self funding. Maggie T merely made paying for things a less dirty phrase :O

[Fuji Abound]

"The other 9,999 threads about it not enough then, Fuji Abound?"

Thanks for the :D .

Threads of course they can ignore, do you think it is so easy to ignore House of Commons Committees. :D :D

[Pat Malone]

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/parliamentary_committees/transport_committee/trans05_06_press_notice09.cfm

Please send a copy of your response to [email protected]

[MikeGodsell]

Dont' know if this offering will be of any use, its how I feel and I have sent it to the committee.

In considering the function & purpose of the CAA, it would be useful to make a comparison between the regulation & maintenance of cars, and of light aeroplanes (simple single engine, less than 2700 KGs weight).
For both private cars and privately owned light aeroplanes, the main motivation for owners to observe rules & regulations is insurance. No sane car driver or aeroplane pilot would travel anywhere without valid accident insurance, to do so would risk legal action & financial disaster.
However the simple and straightforward car MOT checks, and drivers responsibilities, are in stark contrast to the layers of regulation, the expense, and the numbers of persons involved, in assessing the safety of a small aircraft to fly.
Even if the aeroplane is absolutely 100% physically fit to fly, with all systems correctly maintained and inspected, the absence of a single signature on some obscure document is enough to invalidate the insurance. Indeed we have now reached the point where owners are spending more & more time and money on checking layers of paperwork, to assess the legal & insurance status of the aircraft. This often limited time & money would be better spent on new parts and physical checks, which genuinely enhance the fitness to fly.
For example, the so called Certificate of Airworthiness (C of A) issued at 1 & 3 yearly intervals by the CAA, should be more accurately named a “Certificate of Legality” It has nothing to do with the fitness for flight of an aeroplane, it is only concerned with the “fitness” of vast numbers of documents and contributes nothing to safety.
The C of A should be issued to certify only that an aircraft conforms to design regulations, type certificate, etc. It should thereafter remain valid for the life of the unmodified aircraft. The main concerns of both owners and insurers would then be the actual physical fitness for flight of the machine.
Responsibility for fitness should be placed on the owner. He should be able to access a number of specialist workshops able to carry out and certify engine overhauls, avionics, repairs, etc. The aviation equivalent of MOT establishments should assess aircraft condition and issue an aviation MOT certificate annually. At least one layer of CAA regulation should be removed to allow owners to maintain their aircraft, and engineers to practice engineering. Both groups need to know that insurers will be mainly concerned with aeroplane fitness, and not numbers of signed documents.

The simplest way to achieve this is to put all simple single engine light aircraft on the PFA permit scheme, and do away with CAA over regulation.

MG

[David Roberts]

In reply to Mike Godsell –

Under EASA and EU Regulation 1592/2002 Part 21 (Original Airworthiness including Type Certificates) the C of A is issued as a permanent status and is then backed up periodically with an Airworthiness Renewal Certificate (ARC). The means of achieving an ARC is enshrined in the draft Part M of EU regulations, which for light aircraft and air sports aircraft (gliders etc) is currently subject to an NPA from EASA (closing date for comments 24 November). All this affects, or will affect the UK and will in effect supersede the CAA system we have known for so long.

At Europe Air Sports (EAS), which is a voluntary organisation whose members are the National Aero Clubs in the EU, and certain pan-European air sport associations, set up to represent the interests of the lower end of GA – generally below 5.7MT - we are holding a two day workshop with EASA in Cologne on 4-5 November to debate Part M. Sadly, to date, there has been little or no interest in being involved in these consultations and representations from the light aeroplane world (i.e. powered flyers) as distinct from the glider pilot, balloonists, microlight, home-built communities. Though in fairness IAOPA (and AOPA in the UK) play their part but not of course through EAS as AOPA / IAOPA are separate bodies from EAS.

The issues Mike raises such as pilot owner maintenance are very much part of the agenda we are addressing. But there are some very big issues over and above that example that we need to fight for, not least a very bureaucratic and potentially expensive approach to maintenance that will make the CAA look like a soft touch by comparison.

There are a few volunteers doing this representative work at EU level, which is where all the regulatory action is now, and I happen to be one of them. We could do with some financial support through the National Aero Club (s), in our case (UK) the Royal Aero Club, or direct donations to EAS.

I know this piece is a bit of the main them of this thread – which is about Parliamentary inquiry into the (future) role of the CAA, but nevertheless there is a link of course.

[MikeGodsell]

Thanks David.

Can you post addresses of EAS, and R Ae C both for my and others use.

I would be glad to give what help I can, and wish you well in your negotiations.

MG

[chrisN]

In case David (who is very busy) does not see the question too quickly, the web sites of EAS and RAEC are:

http://www.europe-airsports.fai.org/

http://www.royalaeroclub.org/raechome.htm

Chris N.

[ChampChump]

I just thought I'd bring this up into view again..

I hope no one minds.

[MikeGodsell]

The ARC (airworthiness renewal certificate) could provide just the flexibility in light aeroplane maintenance that I had in mind.

My wish list would be for any EASA aircraft, to be able to renew the ARC, at any JAA 145 or EASA maintenance base in any EU country.
That way local authorities like the British CAA and French GSAC, etc, would be out of the picture, and logically all EASA aircraft would have an EU registration number.

Could it be that a bit of common sense is about to be imposed on the CAA and others!

MG

[Mandator]

We are starting to get some good input on this thread.

For David: rest assured the powered boys are working on inputs to the debate on Part M etc. No doubt I will see you in Cologne on 4th/5th November and my Company will be submitting a comprehensive piece to the Transport Select Committee before 14th November as well as presenting some ideas at Cosford at the end of the month.

What everyone is forgetting, however, is that Part M will not apply to the so-called Annex II or non-EASA aircraft - everything from Tigers and Chipmunks to Austers (for the time being anyway), Bulldogs, Stampes and some Cubs etc etc etc. It is the CAA that will invent the new rules for the maintenance of these types and we have already heard Jim McKenna (CAA Chief Surveyor) suggest that the CAA will migrate BCARs towards EASA requirements. The key thing is that for Annex II aircraft we now have the opportunity to suggest a more tenable maintenance regime to the CAA which, if it has the motivation of Parliament behind it (in the shape of the Transport Select Committee), might be pursuaded to act with a lighter touch than the present assumption that everything on the register is an A380.

It is vital that as many people as possible contribute to these consultations - only 219 submissions were made to the CAA GA costs study. That is not enough if we are to demonstrate the strength of feeling there is on these issues. Care is needed to ensure that all submissions are individual - in the costs study consultation the CAA counted 59 inputs all saying exactly the same thing about air display charges as just one point. It is vital also that target dates are met - anything submitted after the target will be ignored.

So, to everyone who cares about the future of any facet of light aviation in our country - get writing, please.

[Johnm]

Slightly confused now, I've already written re CAA suggesting they be required to turn poacher and keep EASA Gamekeeper from going OTT as well as getting their own sense of proportion back. Are we now being asked to write to EASA, if so what about??

[chrisN]

Johnm, see the first post on the thread;

"Inquiry into the CAA
It has come to my attention that the Transport Committee of the House of Commons has decided to launch an inquiry into the remit and work of the Civil Aviation Authority. The Committee intends to look at the following issues:

• the remit, structure, and powers of the CAA;
• the performance of the CAA in relation to its statutory objectives and functions
• the effectiveness and efficiency of the CAA’s regulatory framework
• the effectiveness and efficiency of the CAA in the general discharge of its duties;
• the effect of growing international and European Union cooperation on the work of the CAA.

The Transport Committee have invited interested parties to submit . . . ."

Assuming yours was a genuine question and you really did not know, the straight answer is that EASA is a European body. The Transport Committee of the House of Commons is a UK thing, part of the UK parliamentary system of examining the various arms of government, quangos (of which CAA is one) etc.

Chris N.