Select Committee on Transport Written Evidence


APPENDIX 18

Memorandum submitted by the British Microlight Aircraft Association

  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, STRUCTURE, AND POWERS OF THE CAA

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.

Structure

  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.

Powers

  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 cost.

2.  THE PERFORMANCE OF THE CAA IN RELATION TO ITS STATUTORY OBJECTIVES AND FUNCTIONS

  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 AND EFFICIENCY OF THE CAA'S REGULATORY FRAMEWORK

  We have nothing to add to the comments made by the GA Alliance and the GAAC.

4.  THE EFFECTIVENESS AND EFFICIENCY OF THE CAA IN THE GENERAL DISCHARGE OF ITS DUTIES

  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 OF GROWING INTERNATIONAL AND EUROPEAN UNION COOPERATION ON THE WORK OF THECAA

  See our comments at Paragraph 2 above.



 
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