Examination of Witnesses (Questions 380-399)
18 JANUARY 2006
Q380 Mr Goodwill: I am getting the
impression that General Aviation seems to be the poor relation
and everything seems to be focused on the airlines and you are
a bit of an add-on. Would that be a right impression?
Mr Wilson: I think it is right
that the small proportion of aircraft flying without us, as the
airlines do, have the greatest attention. We would actually say
if you follow risk-based regulation through that is correct. Where
we have a problem is where we are forced to pick up regulation
which was clearly designed for others.
Mr Draper: This brings us back
to the comment which was made by earlier parties represented here
in terms of the beneficiary pays or the user pays being the principle.
At the moment the user pays and we believe very much that it should
be the beneficiary that pays. It is a fact that because of the
increasing amount of commercial airline traffic in this country
in particular, the General Aviation community is being kept out
of airspace, which one would say is our common right to be in,
in that we are having to pay for the costs of the increased airspace
funnelling the aircraft that are wanting to use it into narrower
and narrower corridors and less of it being available. As the
airline industry increases in size this will become ever more
the situation. So we are paying.
Q381 Mr Goodwill: Is this disadvantaging
companies whose main business is not aviation? For example, I
am thinking of Ford Motor Company who fly engineers to their Cologne
plant from the UK and find difficulty getting slots and they are
being disadvantaged. Is that affecting the wider economy of the
UK, the fact that commercial operations that use General Aviation
find they cannot operate as freely as they would like?
Mr Wilson: Ford Motor Company
are members of ours. It is indeed a problem in terms of slot access.
General Aviation does not seek any great favours, what we seek
is fairness. For instance, we were effectively squeezed out of
Heathrow because of slot access. Around London a number of airports
have sprung up, as indeed recommended in the White Paper, to look
after the interests of business and General Aviation: Farnborough,
Biggin Hill, et cetera. I think it is important that communities,
councils if they are involved in their particular airport, understand
the overall benefit of General Aviation. Studies that we have
show that access to sensible business class, in terms of efficiency
and timescale of travel is about third or fourth on the list of
inward investment decisions. That is the type of thing which frequently
can be provided by General Aviation aircraft whether it is a business
or an individual flying their own aircraft. To cut that down is
something that the country would do it at its risk.
Mr Robinson: In relation to things
like the Hampton Report, and we welcome the Hampton Report, there
is a need inside the Civil Aviation Authority for them to understand
the outflow of that report and to look at things like Regulatory
Impact Assessments, small business impact tests, competitive analysis.
A good example of where that would have been useful was the introduction
of JAA FCL which has had a huge impact on General Aviation. There
are fewer instrument rated pilots and there are fewer multi-engine
pilots. These statistics are from the CAA's own data. The reality
is that General Aviation is in a decline. Over 10 years ago we
were issuing 40% more licences than we are today. The activity
at airports is down between 25 and 37%. Access to regional airports
is extremely difficult as the pricing policies of these airports
keep General Aviation operators out. Taking a light twin to Bristol
Airport, one of our members recently faced a bill of £180.
The problem for General Aviation is that it is being sucked up
into the commercial area when it really needs a fresh look at
how it can continue into the future.
Q382 Chairman: To be devil's advocate
for a moment, the pressures of economics are always going to come
into play, are they not? If there is a limited amount of space,
and that includes airports as well as facilities generally, does
it not mean that there will be pressure on prices?
Mr Robinson: That may be true,
however one of the people speaking earlier on today was talking
about the slowness at which the CAA reacts to the introduction
of new technology. If we saw a GPS-based approach being introduced
to more General Aviation airfields we would have more opportunities
for General Aviation to fly safely into a greater number of airfields
and not need to come into the regional airports. The French have
done this. The French have already set this up, but we seem to
want to gold plate it and take a long time before we introduce
Q383 Chairman: To be fair, the French
are fairly brutal in their approach to using the Armee de l'Air
in air traffic control and the use of airspace. They are rather
more rigid in the general control of their airspace, do you not
think, or am I being unfair?
Mr Robinson: That has not been
my experience of flying in France. Most of the French airfields
are owned by the local authorities who seem to want to promote
Mr Draper: If I can just add to
Mr Robinson's comments. There is a safety issue in relation to
access to regional airports for the General Aviation sector in
that if we cannot get into these airports which have facilities
to enable us to practise our instrument landings, for example,
then we cannot be as safe as we ought to be and, therefore, that
should be encouragement to introduce this other new technology.
Q384 Clive Efford: We have touched
on what this question relates to but GA Alliance argues that the
CAA over-regulates General Aviation massively, sometimes to the
detriment of general safety. Other than aircraft and pilots registering
abroad, can you give examples of the CAA's regulatory regime being
detrimental to safety?
Mr Draper: There is a sort of
inbuilt safety for safety's sake when it is not actually required.
It is in the thinking, in the ethos of the CAA. Can I come back
to you with some examples of that afterwards, please?
Q385 Clive Efford: Can I perhaps
prompt a response. What we have been given in evidence is that,
for instance, relating to the UK instrumental rating, the number
of pilots who hold that qualification is 2% in comparison with
America where it is 50% and that is an area where the system is
Mr Draper: I can respond to that,
Chairman. The requirements of the JAA instrument rating acquisition
now are so difficult and for a private pilot to set aside three
months or more to obtain a rating they cannot afford to do so
if they are in business or any other activity. It costs a great
deal of money and takes a great deal of time and effort. Alternatively,
the American system, to which most of them have migrated as a
result, is where they can obtain an instrument rating much more
easily and yet it does not make any difference to the standards
of being required to fly. They are operating in the UK, admittedly
with an American registered aeroplane, equally as safely as a
UK instrument rated pilot. Furthermore, if there was any question
that they were not as safe the CAA would have to do something
about all the American pilots coming in on commercial entry forms.
Q386 Clive Efford: You say that it
is extremely expensive, can you give us some idea of exactly what
costs are involved?
Mr Draper: Around £30,000
but I can come back to you with some bigger figures.
Q387 Clive Efford: To get the same
qualification would be a fraction of that, would it?
Mr Draper: Absolutely.
Q388 Clive Efford: It would pay to
go all that way?
Mr Draper: Pilots do do that.
The issue is the acquisition of more safety for pilots. The CAA
and other authorities should be promoting pilots increasing their
safety ratings and this is one way of doing it, by making it easier
for them to get ratings. These private pilots are not wanting
to fly a commercial airliner, they would have to get commercial
ratings to enable them to do that, they want to be able to fly
their small General Aviation aircraft more safely, more reliably
during weather conditions in the UK and Europe and thereby do
Q389 Clive Efford: Mr Wilson, can
I return to you. You said that you feel that the CAA is reluctant
to use its powers in some areas such as ramp checks on non-UK
registered aircraft because they cannot recover the cost from
the foreign registered owner. What hard evidence do you have that
the CAA acts in this way?
Mr Wilson: Our concern is one
where there are an awful lot of aircraft, say business aircraft,
that arrive at Luton over a weekend and we would be surprised
if there were permits in place for all of those aircraft if they
are commercial carriers. Because there is not such a threat of
a ramp check we are concerned, and of course we cannot prove this
without the ramp checks having taken place, that some of those
aircraft will arrive, declare themselves to be non-commercial
flights simply on the basis there is not a ramp inspection that
is likely to take place, and therefore circumvent the regulations
requiring commercial carriers to register with the Department
for Transport before they fly in.
Q390 Clive Efford: You can give no
specific evidence to demonstrate this is the case, it is just
a suspicion you have?
Mr Wilson: It is a strong suspicion
but obviously we cannot until such ramp inspections take place.
Q391 Chairman: What sort of percentages
are you talking about, Mr Wilson? I am sure that something like
this happens but what percentage of flights would this be? It
would be a way to circumvent all sorts of laws presumably, not
just the ramp checks.
Mr Wilson: I would not say it
is a majority but it is a minority that is not insignificant.
Beyond that it would be difficult to say. There are an awful lot
of aircraft that will arrive and I think those people who are
based at Luton or other airports, I do not want to just highlight
Luton here, would question the fact whether those aircraft truly
were commercial or non-commercial.
Q392 Chairman: Have you ever raised
that with the CAA?
Mr Wilson: It is more an issue
with regard to the Department for Transport. Our concern that
we were outlining in our submission was that there should be more
funding directed to the CAA from the DfT to conduct these ramp
Q393 Chairman: What response did
Mr Wilson: People have looked
at individual cases where we have provided information where we
believe an operation has taken place illegally and in my relatively
brief tenure in this post we are not aware of any action having
Q394 Clive Efford: Assuming this
is taking place, to what extent do you think safety is compromised?
Mr Wilson: It is unlikely to have
a huge impact on safety but what it is doing is distorting competition.
Q395 Clive Efford: I do not understand.
It would concern me if somebody operating from abroad knew that
they could regularly fly in and avoid the checks. The objective
of the checks fundamentally is safety, is it not? They could actually
be flying unsafe aircraft in and out of the country.
Mr Wilson: No. I think what is
more the case is there are permit restrictions on commercial aircraft
coming into any country and an operator will wish to avoid those
permit restrictions as opposed to undercutting safety.
Q396 Chairman: What you are saying
is that these are commercial flights that are re-jigged as being
personal flights and, therefore, they escape the sort of controls
that a commercial competitor would have to comply with.
Mr Wilson: That is exactly it.
Our point in the submission was to say we believe there should
be greater funding from DfT to enable the CAA to conduct more
of these checks.
Clive Efford: Do any of you have examples
of where the CAA avoids using their powers similar to this situation?
Q397 Mr Martlew: Just on the funding
side, are you saying the government should give the CAA money
to do these checks or should it come out of self-financing?
Mr Wilson: My understanding is
that is the case today.
Q398 Mr Martlew: So the government
Mr Wilson: Yes. This is somewhere
where the government is seeking that airlines or aircraft coming
into the UK are safe. That has the added advantage of ensuring
they are abiding by permit restrictions as well.
Q399 Clive Efford: Was the General
Aviation sector encouraged to be part of the CAA's cost review?
Were the views of the GAI am taking it from the faces in
front of me that I know the answer already. How were the views
of the GA community received by the CAA?
Mr Wilson: I was a part of the
joint review team formed in this regard. It was something that
we regarded very much as a working group to look at future charging
mechanisms for the authority. We were unable to reach an agreement
on key parts of that and, therefore, BBGA did file a minority
report when that process was concluded. It was very much a working
group which then deferred what action to be taken by the CAA Board.
Our concern was the joint review team focused very much on how
to distribute charges within the current framework and we would
far sooner have seen a review with regard to who is the ultimate
beneficiary, is it correct that aviation companies pay for policy
development work which is frequently not done in other sectors,
things of this nature which were not covered to the same degree.
Dr Steeden: Being with but not
of the GA community can I answer that question on behalf of the
aerospace manufacturers and service providers. We were represented
on the joint review. As far as I recollect, we were not party
to the GA minority report. I confess, I do not know the details
of that but I think it is important to register that fact.