APPENDIX 9
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.
FUNDING
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.
INDEPENDENT REVIEW
MECHANISM
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.
DUPLICATION OF
EFFORT
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?
GA IS DIFFERENT
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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