Single European Sky is here, now comes the bill

[BossEyed]

Time marches on... Sept 17th is a week away.

If you want to respond (and you SHOULD), but are not sure what to say as wading through the bureaucratese of the Consultation Document (CD) is a painful chore, then I commend to you the AOPA UK website :

They've identified the main points for us, and even hint at the areas of primary concern for you to prioritise:

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

It'll take 30 minutes of your time to cut, paste, garnish with your own opinions (very important), print, stick in an envelope or on a fax machine and send.

If you want some hints for said garnish, I would suggest asking for a clear and transparent Regulatory Impact Assessment (the RIA as described in the CD is superficial to say the least) and Cost Benefit Analysis. My understanding is the the EU rules require this from our "servants".

Do it today - you know you want to. The alternative is

[skydriller]

I have filled in a response sheet and sent it off, as I dont want to be paying for a service I dont recieve. I looked at the AOPA site and I note they only refer to Class F and G airspace (unless Im missing something).....so It appears they approve of VFR traffic paying to fly in Class E (where you dont need a service or have to talk to anyone) or Class D which both surround alot of GA Aerodromes and you dont get a choice about talking to ATC - even though the onus is still on you to avoid other traffic by see & avoid, though you may be under ATC control. I just cant believe so many people appear to have accepted that we will be charged, as if this is normal.....

Also interesting to observe is that no-one at my aeroclub in France knows anything about this proposal or the Mode S issue. Their response is 'Oh, Boff, l'Europe encore!!!' or 'its not for us, just the airlines'. The website for Eurocontrol is in English only as far as I can see, so how are Pilots from other European countries supposed to understand the proposals and have the chance to reply? Anyone seen anything on all this in French or German? I wonder if this is because the French wont have anything to do with the issue, or if when the rules are implemented they will just ignore them, as they do most European legislation they disagree with.

Regards, SD..

[Mak]

After reading the proposed legislation I posted the following reply to Eurocontrol:

Comment:

Currently a/c under 2000Kg MTOW are exempt from airspace charges. From my reading of the proposed legislation, no guarantees are given that such exemption would be maintained for recreation VFR or IFR flights. A blanket levy affecting all airspace users unevenly penalises recreational users of the system, who are already burdened with heavy fuel duties and, shortly, the requirement for model S compliance. It will ultimately result in reduced safety for all airspace users as I explain in greater detail under “Reasons for comment”.

Reasons for comment:

My personal experience as a private pilot suggests that recreational users are very light users of the air traffic control system. I would like to see this situation improved in the direction of greater usage, not reduced usage. However any charging scheme can only result in a reduced usage.

Greater usage of the ATC system on the part of recreation users gives ATCOs improved situation awareness in and around their airspace. It also improves the same situation awareness of the participating pilots reducing the potential for airprox, airspace violations and of all accidents related to continued VFR into IMC conditions, such as CFIT.


Proposed changes:

Delete article 14, clauses 2,3 and 4.

Insert new clause:
“'Aircraft with a certified MTOW of 2000 kg or less and seating for no more than 6 persons including the pilot-in-command shall, when operated anywhere within Eurocontrol airspace, be exempt from en-route charges'


Beagle: thanks for the inspiration.

Someone will be looking at the number of replies as a measure of general feeling and it is important that as many pilots as possible post their comments to the legislation rather than relying on organisations such as AOPA.

[six-sixty]

I am confused, but Article 1, Scope para 3 says something to the effect that:

"this regulation shall not apply to air navigation services made available at aerodromes with less than 10,000 IFR arrivals per year".

Does this not mean that theoretically, flights from small field to small field with no flight information or the like provided or necessary en route would be exempt?

Sorry to look daft - I want to try and send something in the time available, but want to make sure i understand precisely what i am arguing against.

[dirkdj]

This only means that Eurocontrol won't bill the charges for smaller airports, they will be billed by other agencies such as the local provider or airport.

[LowNSlow]

Times a running out people. Get on the AOPA website, download the form and get it sent. You don't have to post it, it can be done by email.

[G-KEST]

Prompted by the NATS staff newspaper I have looked today at the CAA response to the SES chrging proposals. It is a well thought out position paper BUT there is no mention whatsoever of General Aviation and the likely impact of the proposals as posed by EUROCONTROL on our side of aviation.

A side on which the airlines depend for their future supply of pilots but one that has no way of reclaiming the added cost of the charges proposed other than by digging deep into taxed income or by increasing the astronomic hourly charge of hiring a club aircraft.

What a dreadful comment that the CAA cannot even mention the impact on us - merely the airlines who enjoy so many advantages in taxation and the low duty on Avtur.

I would just love to be wrong here but I do not think I am.

If you want to make a resonse then the email address is -
[email protected]
or
[email protected]

I will refrain from any jest on these two, no doubt excellent, ladies who are to field your blitzkreig.

Cheers,

Trapper 69

[six-sixty]

"A side on which the airlines depend for their future supply of pilots"

Not if they can help it much longer they won't, hence the new ICAO multi-crew licence which will be with us very shortly, and is mostly sim based. A guaranteed supply of fresh faced first officers who will never have had to suffer the indignity of flying an aeroplane.

The airlines know that GA doesn't feature in their future, the CAA know it, so why on earth would the CAA bother defending it?

[G-KEST]

If you want to read the CAA position paper on the SES charging scheme then it is at-
http://www.caa.co.uk/docs/1/DAP_SES_DP6_Charging.pdf
Responses as above.
Cheers,
Trapper 69

[G-KEST]

Well folks, it looks as if all the efforts may have been worthwhile.

There are unconfirmed reports that the Eurocontrol council of ministers have totally rejected the proposal to levy charges for using the SES concept on VFR flights or on IFR flights in aircraft of less than 2MT. In other words the current situation as has been the case since Eurocontrol started charging back in the 1970's.

I am sure all the efforts put into personal responses either direct or through the GA representative bodies have played their part in forming, or even changing, the opinions of those who control Eurocontrol.

The CAA SES seminar in Manchester on Tuesday next, 12 October, may now be a bit of an anticlimax however there is still the matter of ATS approvals and aerodrome approvals and the impact on UK aerodromes and smaller regional airports. I am certain there will be much of interest there.

If the reports are correct then a huge thank you to all who got off their butts and actually DID something to assist GA fight those who would attempt to make our flying more expensive, more complex and less fun.

Cheers,

Trapper 69

[BEagle]

I've heard the same thing, Trapper69.

Also that the Eurocontrol people have been accused of attempting to introduce legislation in an 'ungentlemanly way'.....

And again, thank you to all those who gave a hand to rebuff this Eurocratic absurdity.

[Whipping Boy's SATCO]

Having been present at a number of the Eurocontrol workshops, I must agree that there was a fair amount of federalism kicking around. However, it was disappointing to note that the overwhelming number of member states appeared to be quite happy to roll over and have their tummy's tickled.

Furthermore, at the last workshop, it became rather apparant that the EC 'observers' were not completely impressed with many of the Eurocontrol proposals.

I think the phrase is "Contact, wait. Out."

[G-KEST]

Last week I wrote - "Well folks, it looks as if all the efforts may have been worthwhile. There are unconfirmed reports that the Eurocontrol council of ministers have totally rejected the proposal to levy charges for using the SES concept on VFR flights or on IFR flights in aircraft of less than 2MT. In other words the current situation as has been the case since Eurocontrol started charging back in the 1970's."
After attending the CAA seminar at Manchester it rather looks as though those unconfirmed reports were in error. In fact due to the UK governments refusal to pick up the tag of exempting UK aircraft flying VFR and IFR if under 2MT in terms of paying the ANSP for their costs we will ALL be stuck with EUROCONTROL charges for all of our flying. I suppose there may be some letouts to be announced but do not hold your breath if you fly any GA aircraft, powered or otherwise: heavier or lighter than air.
Hope fully when they look at the complexity of any charging scheme they will back off but I really doubt it.
We tried - we really did.
Commiserations,
Trapper 69

[Flying Tooth Driller]

<<After attending the CAA seminar at Manchester it rather looks as though those unconfirmed reports were in error. In fact due to the UK governments refusal to pick up the tag of exempting UK aircraft flying VFR and IFR if under 2MT in terms of paying the ANSP for their costs we will ALL be stuck with EUROCONTROL charges for all of our flying.>> - from: G-KEST

The UK always gold plates any European rule............

However, if the other States really are against charging us, why won't we have to obey their ruling?

[G-KEST]

There are a few things that everyone can do to try to get Eurocontrol to see reason. If all forum readers could write or email their local MP and regional MEP's it could bring pressure on the UK Department for Transport and the Transport Commissioner in the EU in Brussels to revise their stance in terms of levying SES charges from General Aviation. Although there is a small working group now set up by the DfT with representatives from AOPA, PFA, GASCo and the PPL/IR Network to discuss ways by which the SES charges could be applied to GA the DfT has fully committed itself to making sure GA are to pay what they see as facilities provided even if they are not used by GA. What a dreadful state of affairs.
Why not spend a little time enlisting the aid of your democratically elected representatives in Westminster and Brussels? It just might pay off in applying pressure to the bureaucrats within DfT and in Eurocontrol through the EU parliament.
In sorrow.
Cheers,
Trapper 69

[Chilli Monster]

Before anyone does anything may I suggest a read of the Letters page of Flight international, edition out this week. Interesting letter from someone there at Eurocontrol who clearly states that a) There will still be no charge for IFR flights below 2000kg and b) any charging for VFR flights will be down to national authorities decision - they're not interested.

Shall we find out who the bad guys are first?

[robin]

Chilli Monster

We know that already - it's the wonks at the Treasury who don't want to lash out their (our) cash, the airlines who don't understand why they should pay all this money for Eurocontrol when we don't, and government who have a fear of upsetting business

[High Wing Drifter]

Chilli,

There was a similar post in www.ukga.com a few weeks back.

[bookworm]

Shall we find out who the bad guys are first?

Why should we bother to do that?

Surely it's more fun, when a body with "Euro" in the title says

"We'd like to consider what the rules might look like with a clean sheet of paper in front of us -- we might not need rules at all -- what do you think?"

to rally the troops against any body with "Euro" in the title to fight this "threat".

Surely we're better off trusting our good old British authorities who protect our freedom to fly by retaining 170 Additional Airworthiness Directives (and the like) that no one else thought were necessary, and by prohibiting us from using GPS as a primary means of navigation more than 10 years after the FAA introduced their GPS approach overlay program. The other chaps are foreigners, aren't they? The can't be up to any good!

[G-KEST]

Chili Monster had it about right six months ago.

The final EU proposals on the charging scheme have just been released and it confirms that aircraft weighing less than 2MT will be exempt any charges and that states will have the chance to exempt VFR flights by aircraft of any weight.

I think this satisfactory result may well be due to the huge amount of lobbying by GA right across the board from associations to individuals.

Cheers,

Trapper 69