Select Committee on Transport Written Evidence


APPENDIX 15

Memorandum submitted by the Guild of Air Pilots and Air Navigators

  The Guild of Air Pilots and Air Navigators (GAPAN) has much pleasure in responding to the request of the Transport Committee of the House of Commons to present its views on the Work of the Civil Aviation Authority (CAA)".

  In the very short time available to collate the comments of our members, we would make the following observations:

    —  The UK CAA is considered to be amongst the safest, if not the safest, regulator world-wide. So far as the Guild is aware, the CAA performs to a high standard with respect to its statutory objectives and functions; the regulatory framework is effective although some would query its efficiency.

    —  It discharges its duties in an effective manner generally although again some would query the efficiency—eg, repetitious visits where required information should have been known—and is struggling manfully to work with the fledgling European Aviation Safety Agency (EASA).

    —  This, however, comes at a cost, some would argue a fairly high cost on occasions, which is passed onto the users who are then at a commercial disadvantage to their European competitors.

    —  Funding of the CAA should be from central Government in line with other European states or from a very small surcharge to each and every passenger.

    —  The DfT requirement that CAA produce a 6% return on assets should at a minimum be reduced to 3.5% as per HM Treasury instructions, when setting fees and charges for services where there is no competition. Is there any sensible justification for a return on assets employed?

    —  The emphasis should be on safety at an economically reasonable cost, and one that all sections of the industry can bear. The planned increases for General Aviation (GA) over the next few years are a case in point where the principle of ability to pay" has not been taken into account sufficiently. Whereas the regulatory costs for some GA operations may approach 8%, those for large commercial airlines are approximately 0.2% of turnover.

    —  The new CAA Scheme of Charges bears heavily on GA, and the Guild has responded to the CAA on this matter. The Guild believes it to be entirely inappropriate to introduce such major changes in charges before the completion of the Strategic Review which the Chairman of the CAA subsequently announced. Therefore implementation of these increased charges should be delayed until the impact on GA has been assessed by this review.

    —  It is the belief of the Guild and other aviation representative bodies, that the root and branch" review of GA matters to ascertain—What they do and Why do they do it?; Is it Needed?"; if it is, Is it being performed cost effectively—is overdue.

    —  Once the GA review has been completed, there should be similar reviews of the other areas of CAA activity.

    —  The Guild believes that there is too much emphasis placed on self regulation. Some would argue that the industry would benefit from a more assertive regulator perhaps employing the use of sanctions as per the FAA, although whether the CAA has the necessary expertise is an open question.

    —  Some functions, such as airworthiness matters for foreign manufactured GA aircraft, generate inordinately high charges particularly in relation to such regulators as the FAA, and effectively force owners to stay on a foreign register. It should be noted that there is current consultation on the question of permanently UK based foreign registered aircraft.

    —  The CAA should be more pro-active in implementing controlled airspace where required by the rapid increase in civil transport operations, particularly for those airports used by the low fare airlines—eg, Coventry, Doncaster, etc—while preserving so far as is possible the airspace required by GA. It would appear that the CAA feel that it needs to await incidents" before implementing controlled airspace rather than simply protecting published procedures.

    —  Aerodromes—there is a need for a National Policy. The UK appears to lack a unified national policy on aerodromes. The CAA, as well as HMG, has a role in ensuring this. The CAA has to recognise that GA aerodromes are an essential element of the UK's national transportation infrastructure, be it for business or leisure.

    —  A national planning policy for transport should recognise the value of a network of GA aerodromes. Planning applications for new sites and the enhancement of existing facilities should be supported directly by both HMG and the CAA. This support has been absent to date.

    —  The CAA has transferred their responsibility for safeguarding GA aerodromes to Local Authorities causing serious problems. Many applications for safeguarding have been rejected because Local Authorities do not understand the subject and in one case stated that it was too busy to become involved in safeguarding matters. Responsibility should be returned to the CAA.

    —  The exclusion of GA, particularly flying training, activity from some airports and the absence of alternative sites gives rise to major problems so far as the supply of UK trained commercial pilots is concerned. The provision of GA facilities, particularly for pilot training, is a national problem.


 
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