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
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
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
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
Assistant Director Air Transport Policy
22 April 1999