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Specific Themes/Current Issues

Sporting & Recreational Aviation Presentation to Nigel Griffiths MP Gerald Howarth MP Lembit Öpik MP Lord David Trefgarne. By

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Specific Themes/Current Issues

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  1. Sporting & Recreational AviationPresentation toNigel Griffiths MP Gerald Howarth MP Lembit Öpik MP Lord David Trefgarne By Sir John Allison – President Europe Air SportsDavid Roberts – Treasurer EAS, BGARoger Hopkinson – PFA, GA AlliancePaul Draper – PPL/IR Europe, GA Alliance 6 June 2005

  2. Specific Themes/Current Issues • Insurance - Historic aircraft - Burden on all sport & recreational flying • CAA - Mixed empathy with Sporting & Recreational Aviation (S&R A) - Currently seen as biased to CAT - Need for S&R A representation - Need for “grass roots” review of regulatory structure for S&R A - Scope and detail of regulation - JRT Charges review (see later) • UK Airspace changes(current list 14) - Increases in controlled areas - difficulty of access to and cost of regional airports • EASA - Regulations burdensome - Maintenance costs increases • Single Sky - Current & ongoing

  3. Today's S&R A “Drivers” • Changing World • Increases in Commercial activity (5%/7% pa ongoing) driving out S&R A • ICAO (CAT) standards and initiatives being applied to S&R A • European Community (Harmonisation) • Single European Sky (SES) • European Aviation Safety Agency (EASA) • Domestic Position • Government policy & DfT • CAA (pressure on mandate/existence) • Military requirements Domestic “management” of authority exchange not visible

  4. Negative Drivers on UK S&R A – Slide 1 • Poor relation in Transport policies • Not in Transport & Regional White Papers • Airfields under pressure • No recognition of “National Aviation Resource” • Commercial pressures against S&R A (and GA) • Airlines (some, BA, Monarch) see GA as economic target despite pilot self funded entry now at 86% • Economic (S&R A has many small SME’s - £5.2 Bn t/o) • GA as business tool not seen (except @ election) • S&R A poorly presented/understood • High proportion Recreation & Sporting • Educational & Social importance • Environmental

  5. Negative Drivers on S&R A – Slide 2 • Reactive not Proactive to Law/Regulation (esp. SES) • Not recognised in Single Sky Regulations • Not even recognised in initial CAA SES response • Consultation response often weak • European S&R A relatively passive • Lobby post NOT Involvement Pre • Organisations mostly run by unpaid volunteers • Perception of a “Rich Mans Sport” • “They can pay” – says Sir Roy McNulty when briefing. • “If businesses fail so be it” - JRT.

  6. Negative Drivers on UK S&R A – Slide 3 • User Pays philosophy • Easy political response • Non recognition of “user” and who “affected” • Airspace & CAA not “designed” for S&R A • Change to “Beneficiary Pays” • Over regulated as CAA & Eurocontrol mainly run by/for CAT with no GA Board representation • Relative discouragement • Cf. US FAA supports S&R A and economic benefit • Similarly France and other nations • Youth discouraged = industry dies • Suspect CAA “favours Commercial” eg UK Aviation Club

  7. S&R A Current European issues • Single European Sky Regulations 2004 • Framework, Airspace, Interoperability, Service Provision (very prescriptive) • Common Requirements • Charging Regulation • Airspace Design • SESAME • EASA ( a lighter touch?) • Continuing Airworthiness • Maintenance Organisation Approvals • Certifying Staff • Training Organisation Requirements • Annex 2 (Important element for Sports aviation) • Domestic (see later)

  8. Joint Review Team The Domestic challenge CAA Charges

  9. JRT Stated Objectives • Consensus on impact of EASA on SRG • Remove/minimise Charging Scheme cross subsidies • Identify opportunities to increase efficiency • Improve charges consultation • Conclude for 2005/6 charges proposals “Underlying need to meet regulatory oversight balancing transparency, cost relatedness and equity”

  10. JRT “Expectations” from First Draft • £5.5M from >15 Ton AOC to < 15Ton • Heavy AOC benefit (Light AOC lose by £4.5M) • GA increase 60% (£1M) • Threat of additional EASA charges • GA/S&R A Specific increases • Permit to fly +182% over 4 1/2 years • Display permit + 250% over 3 years • Design Approval +68% • Design Approval (Part 21 Subpart J) + 570% • Aerodrome charges lower end +124% • Oxford £4K to £19K • Small Licences £776 to £3,860 • Lasham £0 to £4K

  11. Failures/inconsistencies in first draft • Failure in respect of Objectives • EASA cost evaluation not achieved • Few proposals on “cost efficiency” • Few/no proposals on deregulation • No improved consultancy/transparency • No impact assessment • Negative on GA/S&R A (Economic, social etc) • Cost allocation equity • Airline and Permit treated as one (£600 GAD Organisation/individual treated the same) • Safety driven by Commercial not GA/S&R A activity • Would CAA be “as is” for S&R A if started today?

  12. S&R A JRT Response (Slide 1) • Representation inadequacy • Broader representation refused • Level Playing field inequality • Fuel tax • Overall comparative costs UK/elsewhere • Analysis of beneficiary ie. cost, proportionality & Equity • Safety should be based on use = seats/km • Press for reduced regulation

  13. GA/S&R A JRT Response (Slide 2) • Consultation Failure & Inequity • Moral & Legal Social & Economic obligations (no impact statement and objectives achievement review) • Requirements of Sponsorship Statement • Cabinet Office Principles of good regulation • ANO Regulation 6 (part 11), Authority conduct • Judicial Review (CAA regs1991) • Parliamentary Inquiry into CAA Finances

  14. In summary what does S&R A wish to see? • Regulation on a more appropriate & lower cost basis • The automatic inclusion of S&R A within UK & European Transport Policies • Policies that reflect S&R A’s value to the long term economy • Recognition that GA/S&R A is a valuable business tool and recreation resource • Adequate and equitable access to airspace and airports • UK Government commitment to • full consultation both for internal UK matters and when formulating the UK’s position on European matters • seek fair and proper GA/S&R A representation on the relevant UK and European Boards • A fair and level playing field when considering costs, charges and taxation

  15. Back up Information

  16. UK Aircraft Disposition Total 22,777 Excl. Circa 1000 “N” Reg Incl Circa C of A 1000 CAT

  17. UK Pilots Total 61,106 Many professional also fly S&R A types

  18. Comparative Costs Typical operating costs for C150/DR400 in:- UK Switzerland France Sweden Canada Australia USA

  19. Some Specifics • Insurance • Mode S Transponders • 8.33 KHz spacing below FL 195 • UK Airspace changes (current list 14) • Detection & Recognition • ATC outside controlled airspace • UAV consultation • Mandatory ELT& survival equipment • EASA & Mtce / DOA approval • UK resident “N” registration & FAA licences • Instrument Approach - transfer to Industry • GPS Approaches • Airport security proposals for light aircraft

  20. Approves/ Supervises Proposes legislation Appoints Citizens Co-decision States EU Law European Union - Structure Commission Parliament Council

  21. ICB Chaired by CION 2 Reps per State Eurocontrol (obs) Single Sky Committee DfT MOD FCO Cabinet Office CAA DAP,SRG,ERG,Legal NATS EAPC SES SG DAP SRG ERG Legal SES WG Single European Sky - UK Input Commission

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