Select Committee on Transport Minutes of Evidence

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  Most CAA mandated inspections of foreign manufactured aircraft were withdrawn when EASA took over.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are adding to the list, AD's that were mandated by other National Airworthiness Authorities that had been previously withdrawn.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 National Authority.

  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

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