Select Committee on Transport Written Evidence


Memorandum submitted by Mr Roger Chamberlain

  I am the trustee for a group of four private individuals operating a single engine light aircraft from Wellesbourne airfield in the West Midlands. The aircraft therefore falls into the General Aviation" category. We use the aircraft mostly for leisure, but it is also used for occasional business trips. The group has been in existence for 20 years, and has owned two different aircraft over that time, always on the UK G" register. The current aircraft was imported from Switzerland and transferred from the HB" register, and so several of the points I raise are with the benefit of that experience.


  The CAA is required to make a 6% return on capital, which is some way above the norm for the public sector (as I know too well from my own occupation!). Why should a regulatory body actually need to make a profit at all? How should the charging regime be established?

  Currently there is a discussion about the balance of charges between the airlines and the smaller general aviation operators. The airlines claim to be shouldering a disproportionate burden of the CAA charges, despite the fact that they enjoy many financial benefits elsewhere (no fuel tax, subsidies on aircraft purchase etc etc). General aviation pays full measure of VAT and duty on all its activities, and the profit margins in GA business (flying schools, charter flights, maintenance units, etc) are desperately slim.

  There needs to be a sensible overall balance of charges between the airlines and GA, and this leads onto a sensible level of regulation on the costs imposed for the small operations. One size does not fit all, as the issues are significantly different between airline and GA operation.


  Currently the CAA has full authority to decide what work to do, what resources it requires and how much it should charge. This will (and no doubt has) resulted in a high level of erring on the side of caution" and over-specifying requirements and resource required just to be sure". There needs to be an independent review process to ensure value for money and efficiency.

  There also needs to be a long-term view and accountability to prevent issues like the disaster" of the JAA licensing introduction. Decisions taken need to be made and responsibility taken to protect the industry and allow it to thrive.


  Despite ICAO internationally recognised standards, the CAA applies its own (usually more complex) inspections and requirements. Compared to the USA, where the vast majority of GA aircraft operate (and have been designed and built!) just as safely, there are different maintenance regimes and additional requirements and restriction on use. Our (American) aircraft has several modifications approved by the FAA (and also by the Swiss authorities which just took the FAA approval at face value) but on import to the UK, the CAA insisted on several more restrictive operating conditions for no apparent reason. Why should that be? Is the air different in the UK? Is the US approval process not robust? I don't believe the safety record of GA in the US is worse than over here.

  Do the CAA need a licence issuing department—could that be done by the DVLA in a more efficient manner? Why does the CAA need a legal and medical section—surely this could be contracted out as and when required?


  The main cause of accidents is pilot error" and the best resolution to that is training and pilot practice. The more expense that is loaded onto owners and operators, the less flying is done, and the less practice the pilots get. This is surely counter-productive after a point. I believe we are past this point already, and we should look to manage GA separately from the airline business. There really is very little overlap, and I believe the industry could self-regulate quite effectively the GA category of under 5,700kg (as is already done in some areas).

27 October 2005

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