Select Committee on Transport Minutes of Evidence

Memorandum submitted by the Royal Aeronautical Society


  1.  The Royal Aeronautical Society (RAeS) is the Learned Society for the Aerospace and Aviation community. Based in London, it has a world-wide membership of over 19,000, with over 13,000 in the UK. Its Fellows and Members represent all levels of the aeronautical community both active and retired. Through its various Boards and Committees, it can draw upon considerable experience and expertise in aviation matters. In addition, the Society has over 120 organisations who have joined its Corporate Partners scheme.


  2.  The RAeS welcomes the Committee's inquiry into the remit of the CAA. The Society has a number of concerns about the CAA's role, especially in respect to Light and General Aviation. Nevertheless it should be emphasised that the Society recognises the important of the CAA to UK aviation and the fundamental role it plays in ensuring the safety of the general public and confidence in the construction and operation of aircraft in the UK.


  3.1  The Strategic and Regulatory Reviews initiated by the CAA earlier this year implies a desire on its part to create a best practice regulatory framework with the minimum amount of unnecessary bureaucracy; a position consistent with the Cabinet Office Guidelines Making a Difference study on Reducing Bureaucracy in Central Civil Government".

  3.2  The CAA responsibility for economic regulation of the industry should be re-defined to ensure a cost-effective, value for money safety regulation in order to encourage enterprise and innovation in both commercial and general aviation sectors of the UK aerospace industry.


  4.  With respect to the issues you wish to review, we have the following observations, with some illustrative examples.


  4.1.1  Compared to many other countries, General Aviation in the UK is over-regulated in too many areas resulting in a high cost environment leading to the loss of aerospace innovation, companies and jobs in the UK. A good example is the constraints imposed by the CAA on the experimental use of aircraft. Other countries such as France, USA, and New Zealand have more appropriate regulations that encourage innovation.

  4.1.2  In order to encourage enterprise and innovation in Commercial and General Aviation, the CAA should have a wider range of responsibilities similar to those of comparable agencies in some other countries. These should:

    —  encourage innovation to create jobs and exports (eg US, France, NZ);

    —  encourage development of skills by pilots and aircraft engineers (eg US, Australia);

    —  encourage sport and recreational flying to create jobs in airfield operations and maintenance (eg US, France);

    —  encourage businesses to use General Aviation aircraft to enhance business performance (eg US); and

    —  In order effectively to fulfill these responsibilities, the CAA should report to the DOT on safety, the DTI on innovation, and the DFE on skills.

  4.1.3  The CAA requirement to make a financial return is unreasonably high. The CAA should only be required to make a 3.5% return on capital, the norm for the public sector, rather than 6% currently demanded of the CAA.

  4.1.4  CAA should be answerable for its decisions to an independent review body. Currently appeals are heard by the CAA's own staff.

  4.1.5  The CAA's legislative constraints and Terms of Reference have created an organisation focussed on regulating Commercial Air Transport, with adverse impact on General Aviation regulation. This has contributed to the decline of the UK GA industry.

  4.1.6  We are also concerned that there is a perception that few CAA staff have the appropriate expertise to understand the specific requirements of General Aviation. CAA staff should be primarily commercial and/or general aviation professionals.


  4.2.1  More regulation does not necessarily mean more safety. The UK's safety record for GA is no better than that of the United States—and may be marginally worse—despite the far greater burden that the CAA imposes on general aviation when compared to the US Federal Aviation Authority (FAA). The affordable cost of compliance has reached a level that may be detrimental to safety in General Aviation.


  4.3.1  Pilot training, currency and practice is the key to safety in general aviation. The ever-increasing burden of CAA charges on general aviation mean that UK general aviation pilots are not as current as they could be.

  4.3.2  Future flight crew from the UK train for their qualifications, often at their own expense, within General Aviation, and frequently do this overseas where the regulatory costs are less. This means fewer UK jobs in flight training, maintenance and airfield operation.

  4.3.3  On the other hand, the recent introduction of the National Private Pilots Licence, with reduced limitations on pilot medicals, training and operations, is an excellent example of an initiative that balances risk and regulation for the benefit of all stakeholders.


  4.4.1  All work of the CAA should be subject to a Risk based Value for Money Assessment. The CEO of the Australian Regulatory Authority has stated that We will not turn our backs on any sections of the industry, but we cannot—and will not—continue devoting equal time and energy to areas of industry that pose little risk to public safety."

  4.4.2  The CAA should adopt more widely their power to delegate work to suitably qualified and experienced organisations or people. For example, delegation of work on aircraft of less than 5,700kg operated for private, sporting and recreational purposes to appropriate industry bodies such as the Popular Flying Association (PFA), British Gliding Association (BGA), and the British Microlight Aircraft Association (BMAA), or to qualified individuals to make reports to them on aspects that are perceived to be safety critical. Such delegation would not have the high level of overheads that apply to CAA staff, and therefore result in more cost-effective regulation.

  4.4.3  Quality Assurance principles should be applied (eg repetitive inspections of airfields, flying schools and simulators where nothing has changed should be replaced by an audit system).

  4.4.4  It may be that some work could be done more efficiently and effectively by external agencies (eg the issue of pilots' licences by the DVLA).

  4.4.5  There should be a review of the value of retaining in house capability to be a knowledgeable authority (eg Medical, Legal), compared with delegating to external agencies.

  4.4.6  Service level agreements should be agreed between CAA and industry to enable future performance monitoring and control for what is being paid for by industry.


  4.5.1  With the establishment of the European Aviation Safety Agency (EASA) the UK CAA is no longer the UK Regulator with regard to aircraft design, construction and maintenance. Within a short time Flight Operations and Flight Crew Licensing and Training will also come within EASA's area of responsibility. This will require the UK Government to review and where necessary revise the Civil Aviation Act.

  4.5.2  The Royal Aeronautical Society is concerned that EASA resources at the present time are reportedly not sufficient to deal with the tasks and responsibilities required of it, in a timescale that is appropriate to the needs of the industry. While direct regulatory responsibility is being transferred to EASA. the UK Government maintains a responsibility to the Aerospace industry in the UK to ensure that their activities are not adversely affected by resourcing issues within EASA.

  4.5.3  EASA should publish service delivery standards so that their clients, who require timely responses and decisions, understand what is expected and the industry and member governments have standards against which performance can be measured.

  4.5.4  With increasing number of responsibilities being taken over by EASA, the organisation and facilities of CAA should be reviewed to avoid current overheads being spread over fewer tasks. However, the employment uncertainties amongst staff due to EASA expansion could entail a significantly increased risk of experienced staff leaving. Equally, there is the risk that EASA recruitment may not be of sufficient immediate quantity or quality to facilitate urgent or correct judgements in respect of UK aviation safety and aviation development; certainly on a cost effectiveness basis. For example, we do not believe that EASA rules on Operations and Licensing or Glider Certification entirely meet the UK's needs.

  4.5.5  Significant increases in charging fees will have a major impact on GA costs, and hence the viability of the GA sector. Whilst we welcome the Charging Scheme reductions for GA relating to permits to fly" and Aerial Application Certificates, the increases in many other areas is likely to reduce safety by influencing pilots to fly less, and reduce jobs if flying schools and clubs close as a result.


  5.  In general, the Society would endorse the views of Bruce Byron, Chief Executive Officer of the Australian equivalent to CAA, the Civil Aviation Safety Authority (CASA). He has outlined eight principles for the development of an improved aviation safety culture in Australia. These stress that aviation safety is a shared responsibility between the regulator and industry with the most effective way of achieving safety through co-operation, not imposition.

  These are:

    —  A focus by the regulatory authority on issues that genuinely address safety, not things that simply create paperwork with little real safety benefit.

    —  Safety rules that are clear, concise and outcome based.

    —  Rules that are developed in genuine consultation with industry.

    —  A regulatory authority that limits any adverse impact on industry, with safety delivered at a reasonable cost in a professional and timely manner.

    —  Decisions and requirements the regulatory authority that follow fair, consistent and systemic processes, with no bias or favouritism.

    —  Genuine consultation by the regulatory authority on change—and listening to industry suggestions.

    —  A willingness by the regulatory authority to delegate the administration of lower priority sectors of the industry such as aerial agriculture and recreational aviation—while maintaining safety oversight and conducting audits.

    —  Regulatory authority staff acting with professional respect and courtesy.


  Earlier this year, the Society's concerns were expressed directly in a letter from its President to Sir Roy McNulty Chairman of the CAA.

  The CAA Charging Schemes are likely to have a very serious and possibly devastating effect on General Aviation in the UK, which in turn, may well undermine many aspects of air transport. Such effects on GA include:

    —  High cost and difficulty involved for small start up companies to achieve the necessary approvals to proceed with a prototype.

    —  The impact on smaller AOC operators and their dependent industries which is likely to drive even more aircraft off shore or cause businesses to close.

    —  Massive percentage increase in fees for licensed aerodromes that is likely to result in aerodrome closures.

    —  Massive percentage increase in fees for aircraft displays that is likely to result in grounding of display aircraft.

  The level of these increases appears to be based on an attempt to remove perceived cross-subsidy, without an appropriate cost-effectiveness review of alternatives or risk impact assessment on the whole GA community.

  The concern of the Royal Aeronautical Society is that the ongoing development of the aerospace profession in the UK may be adversely effected unless a more considered view of the impact on GA of the proposed charging is undertaken before commitment by the CAA."

12 November 2005

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