Memorandum submitted by Mr Terry Hale
I'm a private pilot of about 10 years who has
just done the bravest act of my life which was to actually buy
my own aeroplane! Why do I say that this is such a brave thing
to do? Well its simply that the impression that we all have in
General Aviation is that the CAA is out to get us" and make
life as difficult and expensive as possible.
I therefore truly believe that the House of
Commons Transport Select Committee investigation into the whole
structure and remit of the Civil Aviation Authority is an unprecedented
opportunity to improve the safety of general aviation in this
country by fitting regulation more closely to our needs, and introducing
logic and common sense to the oversight of GA.
I hope that you will consider the following
points in your review.
1. It is surely undesirable for there to
be no top cover" 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. The CAA's record on safety in general
aviation needs to be split off from the overall safety picture.
In fact, UK large public transport operations are safer than those
of, for instance, the United States, where airline safety is poorer
largely because of the record of commuter airlines, which have
no real parallel in the UK. But in purely general aviation terms,
the UK's safety record is no better than that of the United Statesand
may be marginally worsedespite 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. 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 timeall
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 a knowledge of general aviation as well as an overriding safety
4. 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,
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. 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. Why does the CAA need 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
of the CAA in general aviation. Is it possible to remove every
aircraft under 5,700kg from CAA oversight and transfer responsibility
to industry, as has been done with most permit aircraft?
6. Why is there a requirement for the CAA
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?
General Aviation is in a poor state in the UK.
Let us please not miss this opportunity to help it recover.
General Aviation is important for the UK.