Select Committee on Transport Written Evidence

APPENDIX 1: Memorandum submitted by Mr Paul Green


  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.


  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.


  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.


  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.


  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?


  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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