Well thats it folks. I wonder how many responses the CAA had received by the cut off date yesterday? I hope it was enormous since we are all affected by it.

On a Pprune forumGuinness Queen remarked “I’m not normally one for paranoia…but must admit, I don’t feel that comfortable making my feelings known and then having to put my name on it. After all, these people do FULLY control my career!”. Well as a CAA pensioner I can only point out that I could replace his word “career” with, for me, the word “pension”. I do fully appreciate his dilemma however my time with the CAA, some 14 years, leads me to a bit of reassurance. They do not harbour grudges especially if the respondant has valid arguments against what is proposed. On this occasion my informal CAA contacts have indicated that they are unhappy with the whole JRT issue and what has emerged.

Thanks for reading this along with my other postings.

Cheers,

Trapper 69

Hello there,

Here is a sanitised version of my consolidated response, finalised and sent today, 25 August, and fully de-personalised. It is vital to get any submission off using the CAA website response form by, at the latest in my opinion, next Friday 2 September 2005.

The response form and other information is available through –
http://www.caa.co.uk/charges
It is quite straightforward and easy to complete using a copy and paste technique.

Many of you, I hope, will have already sent off your response in which case I do apologise for troubling you with this email.

It is absolutely imperative that all of the “stakeholders” in General Aviation make a strong, robust and, especially, a negative response to keep up the pressure on the Authority to abandon these iniquitous charging proposals that will be so damaging to GA community at large. Failure to do so would, in my considered opinion, be unforgivable.

Cheers,

Trapper 69

_____________________________________________

Document 1: General comments
Comment 1:
An unfortunate likely effect acceptance of the current charging scheme under consultation on the viability of General Aviation commercial businesses and the continued employment of those who work in them. Not only for the FY2006/7 but for the eventual life of the JRT report proposals and future CAA SRG charging schemes.

Most of General Aviation is paid for by the end user out of taxed disposable income. This, in many cases, is a small amount.

If the cost of flying goes up then, unless the rise is less or the same as my income increase then one can afford to spend less on flying. Less flying means less spent with those who provide goods and services to enable one to fly. That inevitably has a deleterious effect on the viability of those concerns and, ultimately, on those employed by them.

At this time does UK Limited and the present government wish to see businesses failing and skilled specialist employees thrown out of work?

Another, perhaps more serious aspect, is that less flying may well result in an increase in the rate of GA accidents due to lack of currency and recency.

It might however be that the veiled intention is to kill off GA altogether leaving the skies over the UK clear for the airlines and the military.

Document 1: General comments
Comment 2:
In the USA a significant element of the cost of aviation regulation by the FAA is funded through a levy on airline ticket sales. Why can this not be the case in the UK to fund the CAA’s SRG?

Document 1: General comments
Comment 3:
As long as the JRT report remains on the table at the CAA it hangs like the proverbial Damocletian 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 is intended by the Safety Regulation Group of the CAA. 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 applied to decision making in local councils and at Westminster along with the European Parliament.

Unlike many of those airline financial executives within the CAA SRG FAC who are now so vociferous in castigating GA for their perception of its “subsidy” by their own organisations and trade associations, most who engage in General Aviation pay for their pursuit out of taxed income.

It is indeed a tragedy that their 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.

We turn now to detailed comment on your, potentially ruinous for GA, proposals.

Document 2: Consultation Document on SRG Charges
Paragraph 2: 1.
Comment 2:
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 which is the largest by far in terms of participants.

Document 3: Consultation Document on SRG Charges
Paragraph 3: 2.
Comment 3:
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 HAA, ADAE, EAC, 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.

Document 4: Consultation Document on SRG Charges
Paragraph 4: 2.
Comment 4:
The time recording system introduced right across SRG from 1997 may not be mature. This could lead to a haphazard allocation of working hours by individual staff. There is no doubt that, on the basis of the TRS data – 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.

Document 5: Consultation Document on SRG Charges
Paragraph 5: 3 and 4.
Comment 5:
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.

(end of part 1)

(part 2)

Document 6: Consultation Document on SRG Charges
Paragraph 6: 5.
Comment 6:
We 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 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.
We do not accept this since, to the best of our knowledge, SRG efficiency is not measured or risk-benefit analysis undertaken. Additionally, little consideration is given to determine 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. We really do doubt if the time allocation system is accurate since wasted time is often considered to be zero but does in reality form a significant proportion of any individuals 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 SRG and in particular the General Aviation Department, to outside organisations such as CHIRP and GASCo. Third parties on the surface benefit from SRG work such as the 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.
Our perception of the real GA subsidy to \”heavy\” AOC operators must be accepted.

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 principle 8.
This must be a joke.

Charging principles 9/10/11.
To our limited knowledge the cost of dealing with enquiries from the public and MP’s is not charged out back to the DfT for repayment. The enormous cost of policy work leading to legislative change is never charged out to the DfT. It should be as otherwise they would have to duplicate the expertise in SRG.

Document 7: Consultation Document on SRG Charges
Paragraph 7: 6.
Comment 7: We are 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 will certainly oppose any redundancies to the last ditch. The costs to SRG will be enormous. Who is to pay?

If insurance costs to SRG are rising then may we 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 which, 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.

We note with some degree of scepticism 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\”.
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.

Document 8: Consultation Document on SRG Charges
Paragraph 8: 7.
Comment 8: 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.

7.2.2

You state the assumption that volumes will remain similar to those in 2005/6. We 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.

We 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. We commend the idea as being long overdue and look forward to seeing the result of this review. We are more than willing to offer specialist advice should this be necessary.

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, we believe significantly, by the avalanche of protesting letters and emails which arrived on the desk of the CAA chairman.

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. It should be noted that only 10% of all the aerodromes in the USA are regulated in any way by the FAA. 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\”. An enormous potential reduction in numbers with no explanation given.

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…???

7.4
Personnel licensing scheme.

You propose a new charge for the approval of micro light schools offering FIC of £280 with a, presumably annual, renewal charge of £250. This for work which could be done by the BMAA as is, we understand, presently done for SLMG FIC training by the BGA in its member 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 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 in 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.

We note with a degree of alarm in one of the documents reference to the cost of CAA staff time being, inclusive of overheads, £172 per hour. Later in another document we have noticed that an FSO in GAD costs £84 per hour, once again inclusive of overheads. Why the difference. Are surveyors paid that much more than FSO’s? We are certain that very few of those employed in general Aviation are paid anything like this level of salary even if one assumes half of the figure quoted as being overheads. 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. We would however express our concern at the level of salaries offered in comparison with those on the outside.

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 on the CAA in 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.

:diablo: :diablo: :diablo: :dev2: :dev2: :dev2: 😡 😡 😡

The Vimy is arriving Saturday to depart Sunday at the start of the display. Subject of course to servicability and weather. It will be a justifiable exception to the DeH only rule and an absolutely magnificent one too.

What an achievement to successfully re-enact the Alcock and Brown crossing in 1919 from Newfoundland to Ireland. Even in this day and age the crew are brave men indeed.

To see the Vimy towering above the other types will be a sight to entrance every aviation photographer.

Cheers,

Trapper 69
🙂 🙂 🙂 🙂 😎 😎 😎 😎

Trinny,
A stylish riposte however Eric Janssonne is a good cyberspace friend who is on the spot. If he wants assistance in keeping Colmar open for use then I am only too pleased to help. I was reliant on the request for assistance in his own language as translated by Babel with judicious editing by me. As you seem to have current knowledge of the area perhaps you might care to write. Any potential airfield loss these days is a tragedy, as I am sure you will agree.
Cheers,
Trapper 69