Supplementary memorandum submitted by
the Association of Licensed Aircraft Engineers
I have followed the inquiry with interest. In
my 53 years of professional involvement with aviation, I have
not witnessed so many changes as have occurred recently.
The CAA. within the working remit, handles matters
very well. Unfortunately the changes to which I allude, are not
of the CAA's making. They all come from a new strata of bureaucracy
imposed upon them from Europe, the European Aviation Safety Agency.
EASA makes the rules but relies on National
Airworthiness Authorities to interpret and enforce them in their
own country. We are finding that individual nations are interpreting
them in different ways, and the standard of enforcement varies.
Within the International fraternity of aircraft
engineers, we have noticed a lack of requirement for standardisation.
EASA has this marked down for investigation but under their timetable
it will not be started for another four years. They have not as
yet even appointed a Head of Department!
The overall problem is that the CAA has to be
financed by the industry. At the Annual Congress of Aircraft Engineers
International in Athens to which ALAF. is affiliated, Eric Sivel
of EASA gave us an introductory presentation. When I enquired
when FASA was going to look into charges of National Regulatory
Bodies, in the interest of a level playing field, he replied,
If UK operators do not like the charges they can always go to
another EU country for maintenance where the charges are less...or
where there are no charges at all".
Most CAA mandated inspections of foreign manufactured
aircraft were withdrawn when EASA took over. However EASA is now
slowly bringing out the very same directives as EASA Airworthiness
Directives and in addition are adding to the list, AD's that were
mandated by other National Airworthiness Authorities that had
been previously withdrawn.
I therefore feel that it is imperative that
our CAA be financed from the national purse. Who is being protected?
The passengers and the general public. (Q54). Our mail and much
freight are carried by air. The Police and Air Ambulance use aircraft.
Flying training, including some of the military, use light civil
registered GA aircraft. Aviation begins with General Aviation.
There are serious problems on standardisation.
We do not have a common uniform standard as promised. Individual
countries are still pretty much doing as they please, with EASA
incapable of controlling it. The government's papering over the
cracks with the calming statement of it's a transitional period"
is nonsense. European aviation co-operation has been around for
about 35 years. The Joint Airworthiness Authority started in the
early 90's. EASA is just an extension ofJAA.
The regulations are almost identical and with
a bit of tweaking here and there, would be acceptable. So in my
opinion, we should be highlighting that EASA is really at least
15 years old. It took over responsibility for a known quantity
and yet allows the same failings to continue. This cannot be classed
as a transitional period."
Under the old scheme of things, if we wanted
to fly an aircraft whose C of A had expired we filled in a one
page Fitness for Flight Certificate. Now, for an EASA Permit to
Fly, we have to apply on a three-page form to a CAA regional office
and pay a fee. If we want to apply for a modification we now have
to apply to EASA through our local area office on a nine-page
form and have our bank sign the last page. This is not in the
spirit of the Hampton Report.
Most General Aviation Companies are small businesses
and this kind of autocracy places an onerous burden upon them.
Ms Buck stated that EASA are no more expensive, but we beg to
differ, for example it now costs about £98 to apply for an
EASA Permit to Fly now issued by the CAA. This used to be issued
by a Licensed Engineer as a Fitness for Flight.
If Europe is not brought into line, the UK aviation
industry will not be able to compete and we will witness another
Rover" situation, ie loss of a further world beating industry.
General Aviation is too big for its regulation
to be delegated to organisations like the BritishGliding Association,
or the Popular Flying Association, and should remain under the
The environmentalists have had their say, aviation
does listen to their worries and much has already been done to
help. Research particularly in Germany, has given us quieter aircraft
by fitting silencers, refining the aerodynamics, the design of
quieter propellers and more efficient gas turbine design. However
to embody these modifications in this country, invokes further
excessive charges from our CAA. All airfields, including farm
strips, take enormous care to route their movements away from
urban and noise sensitive areas.
The future will bring further improvements particularly
with new or improved power sources. Will the UK be there or will
regulatory charges have priced us out of the market?
21 February 2006