APPENDIX 14
Memorandum submitted by Mr Julian J Berry
1. REMIT AND
POWERS
With the continued —and continuing—increase
in European regulation of aviation within the UK, primarily through
EASA, the role of the CAA must change to reflect it.
The powers granted to the CAA should also incorporate
some form of external and independent appeals structure; the current
situation where the CAA is judge, jury and executioner is intolerable.
2. PERFORMANCE
The CAA has been far too heavy handed with the
regulation of General Aviation (GA) in the UK, using the mantra
of safety" as their raison d'e(r)tre. However, this
regulation has not been proportionate to the risks involved with
(GA), leading to an industry sector being burdened unnecessarily.
Several examples spring to mind, including the
failure to recognise the ICAO compliant FAA Instrument Rating,
and the reluctance to accept modifications previously certified
by other ICAO regulators (such as FAA STCs). Both of these issues
manifestly reduce the safe conduct of many UK GA flights.
The future CAA should spend far more time and
effort in promoting safe and expeditious GA activity than they
have in the past, rather than just looking at ways in which to
say No, you can't do that".
3. EFFECTIVENESS
OF THE
CAA'S REGULATORY
FRAMEWORK
I would argue that, whilst the CAA has undoubtedly
overseen an extremely safe aviation sector in the UK, this has
been done in a heavy-handed, over zealous and disproportionate
way. I would also argue that the same results could have been
achieved by a more practical & pragmatic approach to regulation.
4. EFFECTIVENESS
OF THE
CAA'S DISCHARGE
OF ITS
DUTIES
By concentrating too much on why something can
not be allowed" that CAA have failed to promote the benefit
of GA to UK PLC. The CAA have failed to ensure all users have
an equal right of access to many regional airports—so vital
for business travel—by allowing these airports to charge
punitive and disproportionate user fees. The CAA has failed to
keep up with technological advances, such as authorising GPS approach
procedures, unlike many other national regulatory bodies.
5. EUROPEAN CO
-OPERATION AND
ENVIRONMENT
I have no comments to make in this section.
7 November 2005
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