APPENDIX 1: Memorandum submitted by Mr
Paul Green
1. INDEPENDENT
REVIEW BODY
I believe that it is undesirable for there to
be no Independent Review Body" for the CAA.
The Authority effectively decides what work
it should do, how many people it needs to do it and how much it
should charge for the work. Because of the safety" aspect
of the CAA's remit, it is difficult to challenge its decisions.
Yet the CAA is no different from any other authority in that it
is subject to the bureaucratic pressures of empire building, featherbedding
and jobs for the boys. The CAA needs a permanent, independent
review body to which industry can appeal when it believes it is
being imposed upon for all the wrong reasons.
2. SAFETY AND
A POINT
TOO FAR
I understand it to be, that in pure GA"
aviation terms, the UK's safety record is no better than that
of the United States—and may be marginally worse—despite
the overwhelmingly greater burden that the CAA imposes on general
aviation when compared to the FAA. It does not follow that more
regulation equals more safety. In fact, AOPA argues that in some
circumstances the opposite is the case.
Those countries in Europe which have regulated
general aviation almost to vanishing point have the poorest safety
records. What improves safety is pilot currency and practice,
and the ever-increasing burden of CAA charges on general aviation
mean that UK general aviation pilots are not as current as they
could be. AOPA believes that CAA charges have already gone beyond
the tipping point" at which regulatory costs become a drag
on safety, and that a substantial reduction in the CAA's financial
impost on general aviation would make flying safer.
3. DO WE
HAVE THE
RIGHT MAN
FOR THE
RIGHT JOBS?
Could it be that the structures of the hiring
practices of the CAA are not optimal, and that as a result the
Authority is too easily able to wash its hands of its mistakes?
The executive directorship of the CAA should
not be a short-term appointment, and there should be an end to
the practice of hiring military officers who build second and
third index-linked final salary pensions in executive positions
while crossing off the days to retirement. An example of the negative
effect of this practice is the introduction by the CAA of JAR-FCL,
which the current Head of Safety Regulation recently termed a
disaster" and for which he apologised.
Yet there is no one around to answer for the
decisions that were made at the time—all have moved on.
Similarly, those who are making even more disastrous decisions
today on CAA charges will not be around to answer for their mistakes
in four or five years. This must stop, and the CAA must hire an
executive cadre with proven commercial capabilities and knowledge
of general aviation as well as an overriding safety responsibility.
4. SHOULD WE
REALLY PAY
AN EQUIVALENT
FEE TO
THAT OF
VIRGIN ATLANTIC
OR BRITISH
AIRWAYS
For charging and oversight purposes, the CAA
must stop treating aviation as a single entity. The airlines cannot
be equated with GA. Airlines are overwhelmingly a leisure industry,
with more than 75% of passengers flying for fun. They are massively
subsidised, pay no fuel tax or VAT and tickets, buy cheap aircraft
thanks to government subsidies to manufacturers, and enjoy bilateral
deals which stifle competition and profit from passenger departure
tax, which they bank for 90 days before passing on. They get direct
government handouts of £2,320,720 a year to keep running
unprofitable routes. They are hugely profitable. By contrast,
more than 70% of general aviation flights are for business or
flight training. GA pays a full measure of fuel tax and VAT, its
margins are razor-thin or non-existent, and it is shrinking. GA
pilots who go to the airlines provide de facto subsidies
of between £50,000 and £100,000 each in the cost of
training for which the airlines once paid. The commercial reality
of general aviation must be recognised by the CAA, and its regulation
costed accordingly.
5. REPEATED PROCESSES
FOR PROCESS
AND MONEY
MAKING SAKE?
There must be a more robust attitude to repetitive
inspections, which risk bringing the CAA into disrepute by looking
like make-work, make-money projects. An installation check on
a simulator is justified, even at a CAA price of £10,000.
A follow-up inspection a year later may also be justified, but
further annual inspections costing thousands of pounds when nothing
has changed are unnecessary financial impositions on training
schools and student pilots. Similarly, repetitive inspections
of aerodromes where nothing has changed should be replaced by
an audit system. There is no justification for requiring aerodromes
to pay thousands of pounds for new surveys every five years when
nothing has changed. Every CAA repetitive inspection should be
scrutinised for value.
Every department of the CAA should be required
to justify its existence. AOPA questions whether the CAA needs
a medical department when medical checks can cost-effectively
be carried out by the private sector, where the real expertise
lies. Does the CAA need a standing legal department? Can the work
of the CAAFU be more cost-effectively carried out by the private
sector with no diminution of safety? Why should the CAA place
restrictions on private examiners who perform the work of the
CAAFU? Does the CAA need offices in Kingsway as well as Gatwick,
and regional offices around the country? Is it necessary for the
CAA to issue licences when the work could be done more quickly
and cost-effectively by agencies such as the DVLA? This Select
Committee investigation provides a vital opportunity to take a
clean-sheet approach to the level of involvement the CAA in general
aviation. Is it possible to remove every aircraft under 5,700
kg from CAA oversight and transfer responsibility to industry,
as has been done with most permit aircraft?
6. A PROFITEERING,
PUBLIC SECTOR
BODY?
Why should the CAA seek to make a 6% return
on capital? The norm for the public sector is 3.5%. Why should
the regulation of aviation safety attract a more onerous profit
requirement? Where is this additional money going? Its not going
on Safety, its not going on additional value adds services for
the consumers. Profits should be made from internal Efficiency
and Effectiveness. If the CAA were a commercial, private sector
body—it could easily find other ways of cutting operational
costs to increase profit without negatively affecting its consumers.
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