Single European Sky is here, now comes the bill
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This thread seems to have drifted off its original topic.
For those sidetracked by the Mode S issue
No problem with stickying this important topic, the fact that it was not before is because no one made the request ... but you have now.
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No problem with stickying this important topic, the fact that it was not before is because no one made the request ... but you have now.
Didn't need to stick it, it more or less stuck itself as it is a popular thread that kept going to the top of the page.
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Let's do the only thing we can do, read the papers, send in the official document with our remarks.
Next weekend would be a good time to read the documents as published on Eurocontrol website.
Not doing anything is not going to bring any results.
When I was flying an \'over 2 tonnnes\' aircraft a couple years ago, the Eurocontrol charges for IFR were about equal or greater than the price of fuel, so maybe this will get your attention.
Next weekend would be a good time to read the documents as published on Eurocontrol website.
Not doing anything is not going to bring any results.
When I was flying an \'over 2 tonnnes\' aircraft a couple years ago, the Eurocontrol charges for IFR were about equal or greater than the price of fuel, so maybe this will get your attention.
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Ive had a look at the document, but was unable to download the response document for some reason, I'll try again later. It really looks like they have almost no knowledge of what GA is when they drafted the document, or maybe GA to them is a Gulfstream V. I see the military are in there with concessions- as they fly 10 times less than civil aircraft (well 10 times less than well used airliners I agree, but probably a lot more than the average private aircraft per year!)
I will be sending in my reply this week, I hope everyone else will be too we really do need to fight this now before it is too late.
If they want to charge VFR aircraft for all this, when will they start charging Cyclists for using the roads- they use all the road infrastructure, we do not use most of the ATC/Nav services.
Certainly a fixed charge per year per aircraft would be very unfair, many aircraft are used very infrequently compared to others in use all of the time. There is already a massive fuel tax, why cant the Government use that to pay for a VFR exemption. Why should we pay fuel tax when Airline and Corproate users dont (Jet A1 users)
As for WBS's comments,
Yes there might be a minor increase in safety if everyone had mode S (but mode C would also be sufficient) But then again it would also be safer if no one flew- Its safe enough already thank you.
Uk alone in the western world not requiring transponders??? Where did you get that from?? I have flown GA in France, Switzerland, Germany, Belgium, USA in the last month, in none of these countries is a transponder mandatory.
4096 codes is not a problem for GA, it only seems to be a problem for airliners, wanting to keep the same code for a long distance- maybe this is why we have to change codes when going into Italy??
I dont see the need for more CAS at all, except in cases of new airports. Surely as we now have very few Boeing 707s or Super Constellations with poor climb performance, we can raise the base of controlled airspace around many airfields by 500ft or maybe more, particularly a long way from airfields. And as more and more Airliners have GPS/FMS, surely there is no longer any requirement for low level procedural approaches, flying miles outbound from some becon at 2000ft etc. The airspace and procedures need to be updated to take into account modern methods.
And with less military aircraft, their airspace should become more available and be made class G.
Lets remember that most VFR GA aircraft can fly where they want without any ATC or any ground based Navaids. We talk to ATC sometimes to get clearance through their zones, but these zones are there to protect the airliners, not for GA's benefit, so its the airlines who should pay for this benefit, it is them who need parts of the airspace to be controlled. We are not using the system because we need to, we are using it because the airlines want us to.
Similarly VFR flight plans, apart from the search and rescue standpoint (which is virtually non existant) they are filed because we are told we have to file them to meet a bureaucratic rule. Thus they are filed for the benefit of the bureaucrats, so it is them who should pay, be it customs, immigration or some other agency. After all I dont have to notify anyone if I drive from Paris to Brussels, so why should I have to notify someone just because my flight goes over a border. (a bit off topic this, but presumably there will be charges for flightplans)
I will be sending in my reply this week, I hope everyone else will be too we really do need to fight this now before it is too late.
If they want to charge VFR aircraft for all this, when will they start charging Cyclists for using the roads- they use all the road infrastructure, we do not use most of the ATC/Nav services.
Certainly a fixed charge per year per aircraft would be very unfair, many aircraft are used very infrequently compared to others in use all of the time. There is already a massive fuel tax, why cant the Government use that to pay for a VFR exemption. Why should we pay fuel tax when Airline and Corproate users dont (Jet A1 users)
As for WBS's comments,
Yes there might be a minor increase in safety if everyone had mode S (but mode C would also be sufficient) But then again it would also be safer if no one flew- Its safe enough already thank you.
Uk alone in the western world not requiring transponders??? Where did you get that from?? I have flown GA in France, Switzerland, Germany, Belgium, USA in the last month, in none of these countries is a transponder mandatory.
4096 codes is not a problem for GA, it only seems to be a problem for airliners, wanting to keep the same code for a long distance- maybe this is why we have to change codes when going into Italy??
I dont see the need for more CAS at all, except in cases of new airports. Surely as we now have very few Boeing 707s or Super Constellations with poor climb performance, we can raise the base of controlled airspace around many airfields by 500ft or maybe more, particularly a long way from airfields. And as more and more Airliners have GPS/FMS, surely there is no longer any requirement for low level procedural approaches, flying miles outbound from some becon at 2000ft etc. The airspace and procedures need to be updated to take into account modern methods.
And with less military aircraft, their airspace should become more available and be made class G.
Lets remember that most VFR GA aircraft can fly where they want without any ATC or any ground based Navaids. We talk to ATC sometimes to get clearance through their zones, but these zones are there to protect the airliners, not for GA's benefit, so its the airlines who should pay for this benefit, it is them who need parts of the airspace to be controlled. We are not using the system because we need to, we are using it because the airlines want us to.
Similarly VFR flight plans, apart from the search and rescue standpoint (which is virtually non existant) they are filed because we are told we have to file them to meet a bureaucratic rule. Thus they are filed for the benefit of the bureaucrats, so it is them who should pay, be it customs, immigration or some other agency. After all I dont have to notify anyone if I drive from Paris to Brussels, so why should I have to notify someone just because my flight goes over a border. (a bit off topic this, but presumably there will be charges for flightplans)
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It's easy to respond to the eurocontrol consultation. Don't be put off by the form. No need to suggest specific wording changes, just make the case against any action that would 'impose or increase' the costs of recreational light aviation.
Bearing in mind that the people who decide will probably not be aviators, but economists - think about what you say. Target comments at the detrimental effect any new charges would have on the benefits light aviation brings to local economies and on the already hard pressed aviation industry (where are they going to get pilots from if people can't afford to learn).
Might also be worth raising the transaction costs involved in any mechanism for charging recreational VFR flights.
Bearing in mind that the people who decide will probably not be aviators, but economists - think about what you say. Target comments at the detrimental effect any new charges would have on the benefits light aviation brings to local economies and on the already hard pressed aviation industry (where are they going to get pilots from if people can't afford to learn).
Might also be worth raising the transaction costs involved in any mechanism for charging recreational VFR flights.
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Even the CAA are anti a number of the proposals and urging everyone to provide their feedback
http://www.caa.co.uk/docs/1/DAP_SES_DP6_Charging.pdf
They recognise the need for reform, to proportion costs for IFR traffic appropriately but think the inclusion of 30 smaller airfields in the UK is an unnecessary burden. Unfortunately they don't mention GA.
I have not crafted my response in detail yet, but it will include:
Whilst I broadly agree there could be a case for reform:
1. We are already paying tax through AVGAS when JETA1 is not taxed - this should be redirected and factored in.
2. If an airport benefits by having airspace allocated to it for free (Class D & above) why should we have to pay to go through it under VFR conditions?
3. Regulation should encourage cost effective provision, there is nothing in the proposals that encourages people to reduce their cost base - its back to the old cost+ system!
4. If a country doesn't want the burden of setting up new accounting systems for SAR, MET & AIS why force them?
5. If we are paying for services what representation do we have on their control and availability?
6. If we pay by time in the air, and are held up by ATC, we would then be paying more- again the system would encourage a bad service.
7. What work has been done to ensure the administrative burden proposed is actually justified in leading to improved services, rather than actually costing more than any benefits it may provide.
D&O
http://www.caa.co.uk/docs/1/DAP_SES_DP6_Charging.pdf
They recognise the need for reform, to proportion costs for IFR traffic appropriately but think the inclusion of 30 smaller airfields in the UK is an unnecessary burden. Unfortunately they don't mention GA.
I have not crafted my response in detail yet, but it will include:
Whilst I broadly agree there could be a case for reform:
1. We are already paying tax through AVGAS when JETA1 is not taxed - this should be redirected and factored in.
2. If an airport benefits by having airspace allocated to it for free (Class D & above) why should we have to pay to go through it under VFR conditions?
3. Regulation should encourage cost effective provision, there is nothing in the proposals that encourages people to reduce their cost base - its back to the old cost+ system!
4. If a country doesn't want the burden of setting up new accounting systems for SAR, MET & AIS why force them?
5. If we are paying for services what representation do we have on their control and availability?
6. If we pay by time in the air, and are held up by ATC, we would then be paying more- again the system would encourage a bad service.
7. What work has been done to ensure the administrative burden proposed is actually justified in leading to improved services, rather than actually costing more than any benefits it may provide.
D&O
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Even the CAA are anti a number of the proposals and urging everyone to provide their feedback
Who tf is advising the government about these proposals if it isn't the CAA?
...and why are they (CAA) reliant on GA and other users making sense of proposed changes from Europe?
WTF do we pay the CAA huge amounts of money for if it isn't to look after UK aviation interests?
a bizarre situation indeed...
Anyone from the CAA got a comment?
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Reading through the CAA document I can see nothing there for GA and recreational flying.
One line - on page 2
"Larger Aircraft have to pay higher charges than small..."
combined with
"larger aircraft are no more difficult to move through most airspace than smaller ones"
could be construed as saying the airliners are being over-charged and a re-balancing of charging is needed so that smaller aircraft pick up more of the bill
I don't suppose that the airlines stake in NATS could possibly be influencing things??
One line - on page 2
"Larger Aircraft have to pay higher charges than small..."
combined with
"larger aircraft are no more difficult to move through most airspace than smaller ones"
could be construed as saying the airliners are being over-charged and a re-balancing of charging is needed so that smaller aircraft pick up more of the bill
I don't suppose that the airlines stake in NATS could possibly be influencing things??
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Okay, let's look at the usage fee issue and see where we are then...
Today of the 7 ICAO classes of airspace the UK uses 6 (no "C")
So "Pilot-X" in his C150 decides to go from farmstrip-1 (Class G) to farmstrip-2 (Class G) and he's transiting nothing higher than class E en-route and keeping well clear of the military low flying areas.
He's availed himself of NOTAM and MET from AvBrief where he is a paid-up subscriber.
He's VFR, talks to no-one en-route or at either farmstrip, and he keeps his conspicuity 7000 code plus "C" on from takeoff to touchdown.
Who should he pay, and for what should he pay?
---------------------
Sometime in the future, when airspace is reclassified either "Known" or "Unknown", the same pilot makes the same flight using the same tools talking to no-one, only this time he remains entirely in the "unknown" class of airspace.
Who should he pay, and for what should he pay?
---------------------
If you think he should pay for the use of the airspace whilst not receiving nor requiring any service from any ground-based aids/persons/authorities then sit back and enjoy - this is what will happen by default.
If, however, you think that charging fees in the scenario described above is wrong then you need to do something about it and that means responding to Eurocontrol in their preferred format
, and copying it to the DfT.
They'll charge you for the air you breathe if you let them.
Unfortunately the people "responsible" for looking after Civil Aviation in the UK seem to have dropped the ball.
Again.
Today of the 7 ICAO classes of airspace the UK uses 6 (no "C")
So "Pilot-X" in his C150 decides to go from farmstrip-1 (Class G) to farmstrip-2 (Class G) and he's transiting nothing higher than class E en-route and keeping well clear of the military low flying areas.
He's availed himself of NOTAM and MET from AvBrief where he is a paid-up subscriber.
He's VFR, talks to no-one en-route or at either farmstrip, and he keeps his conspicuity 7000 code plus "C" on from takeoff to touchdown.
Who should he pay, and for what should he pay?
---------------------
Sometime in the future, when airspace is reclassified either "Known" or "Unknown", the same pilot makes the same flight using the same tools talking to no-one, only this time he remains entirely in the "unknown" class of airspace.
Who should he pay, and for what should he pay?
---------------------
If you think he should pay for the use of the airspace whilst not receiving nor requiring any service from any ground-based aids/persons/authorities then sit back and enjoy - this is what will happen by default.
If, however, you think that charging fees in the scenario described above is wrong then you need to do something about it and that means responding to Eurocontrol in their preferred format
, and copying it to the DfT.They'll charge you for the air you breathe if you let them.
Unfortunately the people "responsible" for looking after Civil Aviation in the UK seem to have dropped the ball.
Again.
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I think down&out makes a good point regarding fuel tax. We pay road tax for the upkeep of our road network and services. AVGAS buyers contribute to a similar level.
I understand that JET A1 is being considered for taxation (as a separate issue to Euro-CONTROL). I imagine that a small contribution from JET fuel tax might make this whole issue disappear. Not sure how EuroCONTOL would take that suggestion though.
That way the industry can make some sort of meagre payback for getting pilots who have trained themselves.
J
I understand that JET A1 is being considered for taxation (as a separate issue to Euro-CONTROL). I imagine that a small contribution from JET fuel tax might make this whole issue disappear. Not sure how EuroCONTOL would take that suggestion though.
That way the industry can make some sort of meagre payback for getting pilots who have trained themselves.
J
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I really don't want to shatter anyone's illusions, but if you think arguing with Eurocontrol and/or Dept. for Transportation and/or the CAA will be difficult you may as well forget any hope in hell of arguing with The Treasury about ringfencing any of the Avgas/Avtur taxes for aviation.
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Down&out's points above could be the nucleus of a list of considered comments that the busy (or merely lazy) Ppruner could send off to Eurocontrol with his/her "Consultation Response Sheet", or paste into an email, without having to undertake onerous independent research of the issues.
Interesting name, "Eurocontrol", conjuring up neo-orwellian visions of unseen sinister tentacles enveloping every little airfield, every grass strip ....... And I'm not even paranoid!
Interesting name, "Eurocontrol", conjuring up neo-orwellian visions of unseen sinister tentacles enveloping every little airfield, every grass strip ....... And I'm not even paranoid!
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rustle, a couple of points. The CAA (I presume that is who you are implicating) has not dropped the ball. It is the Government who have signed-up to SES and the European Commission has tasked EUROCONTROL with drafting some of the Implementing Rules (Common Requirements, FUA, Interoperability, Airspace Design and Charging) that are already mandated, in EC law, in the Framework Document. Consequently the UK (ie CAA and DfT) has to go into bat against all of these draft rules in an attempt to influence them before they are signed-off, and made legislation under qualified majority voting, by the EC. You imply in another post that it is ironic that the CAA ask to aviation community for ideas and hint that this is somewhat a ludricous state of affairs. What would you prefer, a CAA that follows it's long-standing reputation and makes arbitrary, ill-informed decisions?
If you really wish to have a transparent understanding of the process the UK is being forced to follow, please PM me and I can arrange for you to have a face to face discussion with the very people who are trying to make sense of European legislation. I cannot promise all the answers you wish, but I can tell you that this will help you understand how the regulatory authorities are trying to fight the UK corner.
.....and before anyone starts, I am not a CAA man.
If you really wish to have a transparent understanding of the process the UK is being forced to follow, please PM me and I can arrange for you to have a face to face discussion with the very people who are trying to make sense of European legislation. I cannot promise all the answers you wish, but I can tell you that this will help you understand how the regulatory authorities are trying to fight the UK corner.
.....and before anyone starts, I am not a CAA man.
Last edited by Whipping Boy's SATCO; 27th Aug 2004 at 20:55.
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rustle, I think the DfT are interested, if you look in the PPL/IR site there is an article on this subject. It asks for copies of submissions to be sent to someone st the DfT, from this I can only think that they want to get some measure of the response s being made. Have you sent yours off yet.
WBSATCO I think many of us would like a briefing on this subject as it would help to make sure the replies did not contridict each other, or were just cut and paste jobs as this may not help anyone.
Mike
WBSATCO I think many of us would like a briefing on this subject as it would help to make sure the replies did not contridict each other, or were just cut and paste jobs as this may not help anyone.
Mike
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IO540 wrote .....
<What Mode S will do (assuming people don't contravene the coming regulations and leave the transponder switched on) is that it will make it easier to identify aircraft infringing some airspace. But its primary purpose is for more efficient air traffic control, which is there mostly for the airlines.>
<rant on>
It is on topic, as the introduction of Mode S in 2008, will have a £4000 (estimated) cost implication for me (for no gain), and a 3Kg weight penalty (again for no gain). Every Kg is important !
What interests me as an Area Control ATCO is how uttterly clutttered my presently cluttered radar screens will become if EVERYONE who is in the air is displayed on my screen.
At the moment, it is well near impossible to filter out all the low-level GA and military scooting around the Newcastle area. The screens can be VERY cluttered with SSR labels. I may be trying to control aircraft in the FL100-FL245 height band, but I daren't filter out the labels of traffic below that in case it is popping up or climbing out. I shudder to think what our wonderful 15 inch monitors
will look like if all microlights, PFA types, and balloons (that includes the bureacrats 
) are inluded as well.
Doubt the accountants in charge have thought of that one.
Interested too to know how many of the decision makers have recently worked a busy sector or controlled passenger carrying aeroplanes.
<rant off>
<What Mode S will do (assuming people don't contravene the coming regulations and leave the transponder switched on) is that it will make it easier to identify aircraft infringing some airspace. But its primary purpose is for more efficient air traffic control, which is there mostly for the airlines.>
<rant on>
It is on topic, as the introduction of Mode S in 2008, will have a £4000 (estimated) cost implication for me (for no gain), and a 3Kg weight penalty (again for no gain). Every Kg is important !
What interests me as an Area Control ATCO is how uttterly clutttered my presently cluttered radar screens will become if EVERYONE who is in the air is displayed on my screen.
At the moment, it is well near impossible to filter out all the low-level GA and military scooting around the Newcastle area. The screens can be VERY cluttered with SSR labels. I may be trying to control aircraft in the FL100-FL245 height band, but I daren't filter out the labels of traffic below that in case it is popping up or climbing out. I shudder to think what our wonderful 15 inch monitors
will look like if all microlights, PFA types, and balloons (that includes the bureacrats ) are inluded as well.Doubt the accountants
in charge have thought of that one. Interested too to know how many of the decision makers have recently worked a busy sector or controlled passenger carrying aeroplanes.
<rant off>
Last edited by PH-UKU; 28th Aug 2004 at 11:17.
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PH-UKU, when have you ever heard of any/many organisation , especially government, finding out the needs.
This Eurocontrol shambles is a good example. I read that they consulted an 'expert group' earlier in the year.
'Ex' as in "has been", 'xpert' as in "drip under pressure".
With modern means of communication there is no excuse for asking for wider views/opinion before progressing down the slippery slope.
And how Tony Blair and the bunch of tossers running the country expound the needs to address modern technologies passing the 'Eurocontrol' issue to the EU without so much as a thought shows how much understanding they have.
If it had been what colour they are going to paint the 'bogs' in Westminster, there would have been questions in the House or even a referendum.
Mike
" A totally p****d off British citizen"
This Eurocontrol shambles is a good example. I read that they consulted an 'expert group' earlier in the year.
'Ex' as in "has been", 'xpert' as in "drip under pressure".
With modern means of communication there is no excuse for asking for wider views/opinion before progressing down the slippery slope.
And how Tony Blair and the bunch of tossers running the country expound the needs to address modern technologies passing the 'Eurocontrol' issue to the EU without so much as a thought shows how much understanding they have.
If it had been what colour they are going to paint the 'bogs' in Westminster, there would have been questions in the House or even a referendum.
Mike
" A totally p****d off British citizen"
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I have just got off the phone to the researcher working with my local MP and he says that you should contact your local MP, although this is a bit late it can be raised to the government.
PLEASE DO THIS
I also contact the euro MP's for my region and have as yet had 1 reply, awaiting some action.
Mike
PLEASE DO THIS
I also contact the euro MP's for my region and have as yet had 1 reply, awaiting some action.
Mike
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The originator of this thread was not being alarmist.
In 1999, the German CAA attempted an almost idenitcal charging scheme for Air Navigation Services provided within Germany. Like the SES proposal, the Germans calculated the full cost (just liek the SES, their costing included direct and indirect costs) of the supplied services (VOR, LAR, MET etc) and then decided what would be a "fair" amount for the VFR community to shoulder. They decided around 3% would be OK. Like SES, they decided that a blanket annual charg was the best way to organize the payment. The annual charge was around £2400 per registered aircraft!
A huge outcry from the German GA commmunity (65, 000 responses inside 4 weeks), some skillful political lobbying from the DAeS and a fortunate change of Minister allowed them to overturn the proposed scheme.
The problem we have with EUROCONTROL is that they offer us just a few paltry weeks of consultation and after this it is a done deal. There will be no overturning it (just as they have given no ground with Annex II, Mode S, etc etc).
Our National Aero Clubs and Europe Air Sports are doing their best to represent us, but the only way that the Brussels chaps will really sit up and take notice is if they can smell a future problem of mass complaint from the large (700,000 Europewide) GA community.
We MUST respond individually using the EUROCONTROL pro-forma form with our howls of protest. If we do not do this small thing, then we have no right to complain when we are writing our annual cheque that will cost more than hangaring our planes.
Please write, the deadline is soon (17th Sept). Please copy your objections to your MP and MEP.
In 1999, the German CAA attempted an almost idenitcal charging scheme for Air Navigation Services provided within Germany. Like the SES proposal, the Germans calculated the full cost (just liek the SES, their costing included direct and indirect costs) of the supplied services (VOR, LAR, MET etc) and then decided what would be a "fair" amount for the VFR community to shoulder. They decided around 3% would be OK. Like SES, they decided that a blanket annual charg was the best way to organize the payment. The annual charge was around £2400 per registered aircraft!
A huge outcry from the German GA commmunity (65, 000 responses inside 4 weeks), some skillful political lobbying from the DAeS and a fortunate change of Minister allowed them to overturn the proposed scheme.
The problem we have with EUROCONTROL is that they offer us just a few paltry weeks of consultation and after this it is a done deal. There will be no overturning it (just as they have given no ground with Annex II, Mode S, etc etc).
Our National Aero Clubs and Europe Air Sports are doing their best to represent us, but the only way that the Brussels chaps will really sit up and take notice is if they can smell a future problem of mass complaint from the large (700,000 Europewide) GA community.
We MUST respond individually using the EUROCONTROL pro-forma form with our howls of protest. If we do not do this small thing, then we have no right to complain when we are writing our annual cheque that will cost more than hangaring our planes.
Please write, the deadline is soon (17th Sept). Please copy your objections to your MP and MEP.