Memorandum submitted by the British Microlight
The BMAA is a member of both the General Aviation
Alliance and the General Aviation Awareness Council, and fully
supports the submissions those two bodies have made to you. However
we have some additional comments that you may wish to take into
consideration. The BMAA holds approvals from the CAA for the airworthiness
of the UK microlight fleet and for the licensing of microlight
pilots under the National Private Pilot's Licence.
1. THE REMIT,
From the viewpoint of a recreational flying
association, in the not for profit" sector, whose members'
primary aim is to enjoy affordable aviation", the CAA is
seen as an increasingly expensive and increasingly less competent
regulator. While our relationship with individual members of CAA
staff remain cordial and professional, it is increasingly apparent
to us that we are being expected to maintain standards to continue
to hold our CAA approvals that the CAA itself cannot meet. For
example we have waited just under a year for a response to a proposed
amendment to our Technical Procedures Manual, which forms part
of our Airworthiness Approval, and have been awaiting since June
2004 the re-issue of an exemption affecting hundreds of our members
or for alternative arrangements to be made. However we have fixed
periods to respond to issue reports raised at audit by the CAA,
failure to respond in time will result in the suspension of our
approvals. A double standard we feel.
To us the CAA remit appears to be weighted towards
the protection of the UK's airline industry and does not take
sufficient account of the value of the recreational flying sector,
both in attracting people into aviation, many of whom go on to
fly professionally, and in providing employment via flying schools,
microlight and other aircraft manufacture, and other SMEs providing
products and services to the sector. We feel that the CAA remit
should include the requirement to provide a viable GA sector in
the UK while taking a realistic and sympathetic view of the cost
and bureaucratic burden experienced by the recreational pilot.
As an Association that is directly accountable
to its members and cannot increase membership fees without a democratically
achieved mandate at its AGM, we feel under-represented in the
structure of the CAA that is able to increase its charges with
minimum consultation, to the benefit of the commercial air transport
sector, but to a significant degree at our expense. We believe
that the CAA Board should have representatives from GA as a whole
and from the recreational flying sector in particular.
Each CAA department should be examined to ensure
it is delivering value for money, is doing so at the least cost
possible to those it regulates and, with particular reference
to the recreational sector, is delegating as much responsibility
as possible to sporting and recreational flying organizations.
The CAA effectively holds a monopoly for the
regulation of UK aviation, in that those that find its charges
too expensive have no alternative for the supply of the services
they require. The CAA's charging scheme should take more account
of the ability to pay" of those that it affects, and should
consider delegating more of the provision of services to the recreational
sector if, by doing so, those services could be delivered at lower
2. THE PERFORMANCE
CAA IN RELATION
We entirely concur with the GA Alliance comments
on this topic and would add that, as EASA is taking on responsibility
for more and more regulation of European aviation, we would expect
to see a commensurate reduction in CAA costs and staffing levels.
Measures to achieve this, such as the rustication of CAA offices,
should be seriously considered, as in addition to the cost savings
that may be achieved, the current locations make it both difficult
and expensive for representatives from the recreational flying
sector to attend the plethora of consultative meetings, review
boards and steering groups that they are expected to contribute
to. While this example may seem trite and possibly mean spirited,
it is very annoying to receive expensive looking Christmas cards
each year from several different CAA departments knowing that
the fees paid to the CAA by our members have paid for the cards,
and the postage!
3. THE EFFECTIVENESS
We have nothing to add to the comments made
by the GA Alliance and the GAAC.
4. THE EFFECTIVENESS
CAA IN THE
We entirely agree with the GA Alliance comments
about the need to suspend an increase in CAA charges pending the
Strategic and Regulatory reviews of GA by the CAA. We have seen
a drop in our membership levels since the EC's introduction of
compulsory insurance this year; although we appreciate that this
measure was not supported by the CAA and the Government, it has
tripled the insurance premiums of many of our members. Anecdotal
evidence is that some microlight pilots have given up flying because
it is becoming too expensive but others, particularly those that
fly old microlights, worth only a couple of thousand pounds, within
their local area are choosing to fly outside the law. Such pilots
may think that the likelihood of being caught is so low that it
is worth the risk. We are concerned that if charges increase further,
then even more pilots will choose not to comply with the regulations.
Such a disincentive to comply does not, in our view, represent
effective or efficient regulation.
5. THE EFFECT
See our comments at Paragraph 2 above.