Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence - Fourteenth Report

Supplementary Memorandum by European Regions Airline Association (AS 31A)


  Thank you for the letter of 1 April inviting our responses to questions not covered fully during the hearing on 31 March.

Do we agree that the new En-Route Centre should be operational prior to PPP?

  ERA has no formal position on this. However, ERA seeks alleviation to the current and projected delays caused by Air Traffic Control congestion in Europe by all practical and cost-effective means, and in the most timely manner.

In what ways does the evolution of the "virtual airline" make it more difficult to police industry standards and performance in the maintenance of safe operations?

  ERA does not believe that safety enforcement is made more difficult by the evolution of the "virtual airline". ERA has first hand experience in the UK. When Debonair (an ERA member) was established, it sub-contracted its operations to British World Airlines (also an ERA member), and those operations were set up using British World Airlines' Air Operators Certificate (AOC). In ERA's view, the CAA was completely capable of ensuring safe operation of Debonair through its routine monitoring of British World Airlines. There was thus no impact on safety.

What concerns do we have about foreign airlines operating into the UK which do not comply with British standards?

  ERA strongly supports the need for harmonised or equivalent safety standards to be imposed by regulatory authorities and implemented by airlines worldwide. ERA supports strong action by any regulatory authority where safety standards do not reach internationally agreed (ICAO) standards.

  With particular regard to Europe, ERA supports the liberalisation of air services across a wider group of countries, subject only to an equivalent safety standard being implemented in those countries. The European Commission supports this approach. Thus extending the EU's air transport liberalisation policy to the Central European Countries will have a positive impact on safety.

What danger is there that the JAA promotes the "levelling down" of safety standards to the lowest common denominator across Europe?

  None whatsoever. This is not to say that the CAA's standards will be accepted as the JAA standard. Many other European states have a safety record equivalent to the UK, but they have different regulations. These may be more onerous or less onerous than the existing UK regulations. The CAA should not be considered as the sole arbiter of safety standards in Europe. The process of harmonisation of JAA standards naturally requires give and take by individual state authorities. ERA believes that the harmonised Joint Aviation Requirements provide the basis for continued safe operation in JAA states.

  Harmonised regulations have the added benefit of including the collective experience and best practices of participating states on all issues, rather than reliance on a single regulator's interpretation of what is necessary.

What actions should be taken to address the problem of increasing numbers of accidents caused by Controlled Flight into Terrain (CFIT)?

  CFIT accidents have not become more prevalent. However, other safety improvements have been so substantial that CFIT is now the largest single cause of accidents worldwide, although this is not the case in Europe. There needs to be an improvement in the rate of CFIT accidents if the industry is to achieve its goal of halving the overall accident rate in the next decade.

  ERA has taken two initiatives with regard to CFIT. Firstly, we have made available to our member airlines CFIT training aids produced by the Flight Safety Foundation (FSF). FSF is an independent non-profit organisation based in the USA which is dedicated to the promotion of aviation safety. Secondly, ERA has adopted a policy which recommends all member airlines to install a version of the Enhanced Ground Proximity Warning System (EGPWS). This recently introduced system offers a significant improvement in the information available to the cockpit crew regarding terrain which the aircraft is approaching.

Are we concerned about the incidents involving the rudders of Boeing 737s?

  Any incident which may cause an accident gives rise to concern. This applies equally whether the cause is human error, unsafe operating practice, poor equipment design, or equipment malfunction. The incidents involving rudders on Boeing 737s are no different from other incidents. The industry and the regulators, particularly in the USA and Europe, have worked together to establish the cause of problems, and to correct any faults which have been found. Where any particular fault, or suspected fault, has required urgent checking or rectification, the regulators have imposed strict time constraints on the industry.

What was the reaction of our members to the Swissair MD11 accident?

  The accident and its implications were discussed at an ERA Air Safety Work Group. In common with airlines worldwide, ERA members were advised to re-examine their checklists for action to be taken in the event of smoke in the cockpit. Many ERA members use check lists provided by the aircraft manufacturer rather than creating their own operating procedures. At least one manufacturer has revised its check list following the Swissair MD11 accident. Airlines using this manufacturer's check list will have adopted the revisions.

How concerned are we by the apparent rise of unruly passenger behaviour? Can we give examples of `air rage' which have put the safety of aircraft at risk?

  ERA and its members are very concerned by incidents caused by disruptive passengers. Although the incidence of such behaviour is very low, they are more likely to endanger the safety of smaller aircraft, as there are fewer cabin crew available to deal with any incident. Whilst many airlines operate with more than the minimum number of crew required by safety regulations, some aircraft with 50 seats or fewer will have only one cabin crew and two cockpit crew on board. Aircraft up to 100 seats may have only two cabin crew and two cockpit crew on board. When a disruptive passenger cannot be quelled by a single crew member, the implications on safety are obvious. Any injury to a crew member will significantly impair the crew's ability to ensure the other passengers' s safety in the event of any other emergency.

  ERA has discussed this issue at its Air Safety Work group. Demonstrations of restraint devices have been arranged. However, ERA believes that significant achievements can be made by ensuring consistent punitive action against offenders. ERA welcomes changes in EU and UK law to facilitate prosecutions, and heavy penalties imposed by UK courts. However, ERA is disappointed that this approach is not consistently adopted internationally, and has urged the European Commission to consider action at European Union level.

Andrew Clarke

Assistant Director Air Transport Policy

22 April 1999

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