Select Committee on Transport Written Evidence


Memorandum submitted by the Royal Aero Club

  We are pleased to present the views of the Royal Aero Club of the United Kingdom on this matter. The views in this submission complement those of several member associations of the RAeC and also of the GA Alliance, of which the RAeC is a member.

  This submission focuses on one or two particular strategic issues, in relation to the role of the CAA, for the future of recreational and sporting aviation in the UK.


  Founded in 1901, the RAeC is the overarching body in the United Kingdom in all matters of aviation sport. Its 12 full member associations have a combined individual membership of some 72,000 representing the UK at the highest level in every aspect of sports and recreational aviation. The RAeC is the UK member of the Federation Aeronautique Internationale (FAI), the World governing body of sport flying, and the UK member of Europe Air Sports (EAS), which co-ordinates responses to legislation and regulation affecting recreational flying within the European Union. Representatives of the RAeC and its member associations are to be found in senior positions in these two international organisations and the influence of the RAeC in their thinking and activities is significant.


  The RAeC and its member associations have always had an excellent relationship with the CAA. There is little doubt that in this regard the National Aero Clubs of many other countries envy UK sports aviation its regulator. However, the World and, more specifically, Europe have changed much in recent years, as has the environment in which General Aviation (GA) operates. The Transport Committee inquiry into the remit and work of the CAA provides the RAeC with a timely opportunity to suggest overdue changes in the way its members' activities are regulated. These changes offer the possibility of eliminating the avoidable cost of sports aviation to the taxpayer without detriment to safety, generally accepted to be the most important criterion when considering aviation. At the same time, such changes would remove an outdated and somewhat bureaucratic burden that is not only hampering the development of sports in which Britain excels, but is also stifling the growth of sports aviation as an important economic and social sector.


  The RAeC's major criticism of the role and remit of the CAA is that, whilst a peripheral part of its task involves the active regulation and supervision of sports aviation, it bears no responsibility for safeguarding the future of this activity. Furthermore, there is within the CAA an understandable desire to justify its existence by retaining work that a more commercial organisation would long ago have eliminated or delegated, even when such work is of little or no value. The evidence of this is to be found in box-ticking and paper-shuffling for which the RAeC's members must pay, even when this work duplicates their own activities and introduces long delays into their own systems. A typical example of this is the partial verification of pilot licence information, which is already verified far more completely by the issuing sports aviation organisations, which have better access to the necessary information. In summary, the CAA has in many respects operated with a long screwdriver", at considerable cost, when in reality there has been no case to do so in many aspects of recreational and sports aviation.


  That there is another way is beyond question. One has only to look at the role of the Deutscher Aero Club (DAeC), a members' self-funding organisation directly responsible to the German Bundesministerium für Verkehr, Bau- und Wohnungswesen (Ministry of Transport) for the design, airworthiness, licensing and operations of German sports aviation. In Germany much of the work with regard to sports aviation—which in the UK is undertaken by the CAA—is the responsibility of the DAeC. Similarly, the Letecká Amatérská Asociace CR (LAA) is directly responsible to the Czech Ministry of Transport for many aspects of the supervision of sports aviation in the Czech Republic, a country which, free from the burden of a slow, restrictive and retentive civil aviation authority, now has a light aircraft industry that is the envy of other nations, producing new and innovative aircraft that are exported worldwide. The decline of the UK's light aviation industry is evidence of the inadequacies of the British system. The problem has been, in part, the prohibitive costs of certification but, to a far greater extent, the result of bureaucratic delays, which have been introduced by a CAA under-resourced for the work it believes it must do in a particular way, because it always has, and to justify its existence.


  UK sports aviation neither has nor desires the centralised structure to be found in Germany. Nevertheless, within the RAeC are associations that regulate much of their own activity and which, with little significant change to their organisation and structure, could take total responsibility for their sport, directly accountable to the Department for Transport rather than working under the participative and detailed supervision of the CAA. It is, of course, in large part thanks to the contribution of the CAA that these associations have reached this level of competence. However, now that even the youngest of these associations, the British Microlight Aircraft Association, has been managing its own activities including training, examining, licensing, design, airworthiness and operations for over 20 years, total delegation is a natural next step. Other organisations, such as the Popular Flying Association, which has for many years controlled the home building of aircraft, and the British Gliding Association, which has an enviable 57 year history in managing virtually all aspects of gliding in the UK, have long since proved their capability and responsible approach.


  It is unreasonable to create a regulator and then to be surprised when this entity has a predisposition to increase rather than reduce regulation. Furthermore, as the regulator has the primary objective of safety, against which all other objectives are secondary, it cannot be blamed for being biased in favour of maintaining an excessive involvement in the detail of sports aviation activities rather than risk being accused of being insufficiently diligent in its work. Like any parent in relation to maturing children, the CAA is reluctant to acknowledge the state of competence and maturity of the sports aviation organisations it has helped develop. Furthermore, the creation of the European Aviation Safety Agency (EASA) has put many CAA employees in fear for their jobs. Through EASA, the EU is progressively introducing pan-European frameworks, regulations and rules that are now superseding national rules. The CAA will still have a role but limited to overseeing implementation of EU rules, not creating the regulations and rules. For these reasons there is a visible tendency for the CAA to be predisposed to retain control. Despite this, it is widely accepted that the time has come for change.


  The RAeC therefore recommends that all activities currently undertaken by the CAA with regard to sports aviation be reviewed with the objective of delegating them to those air sports aviation organisations capable of undertaking the task. In some cases this would mean such organisations continuing to do what they have been doing successfully for many years in a self-regulated environment, but in future, for some, in an EU regulated framework. In this regard the imperative should be to delegate all activity to competent bodies and justify retention by the CAA rather than the reverse. In the event that the CAA retains any direct involvement in sports aviation, safety objectives should be balanced against commercial and financial objectives. This will lead it to the constant review of its activities with the aim of eliminating work if it becomes of no value.

  It is probable that the RAeC is pushing at an open door in these recommendations. Although it is rather too early in the life of EASA to see how its plans will develop, all the indications are that its inclination will be to transfer responsibility for sports aviation to those bodies that can demonstrate their competence and qualification. In fact, in the first stage of EU Regulation (Reg 1592/2002), it was EASA's intention that national air sports governing bodies (such as the BGA, BMAA, PFA etc) could be designated the Competent Authority for their particular activities. However, the regulation left it to Member States to decide this and in the UK the Department for Transport appointed the CAA as the Competent Authority for all civil aviation, probably without consideration of the intention behind the EU Regulation. Furthermore, a large proportion of UK sports aviation activity has been excluded from the control of EASA thus far, by means of inclusion in Annex II (the exemptions from regulation) to Regulation 1592/2002. It is known that the intention of EASA, and hopefully the Commission and in due course the European Parliament, as regards the next stage of EU Regulation on Operations and Licensing, is to empower air sports associations as assessment bodies".

  For these reasons the RAeC believes it to be entirely appropriate to make these recommendations considering the changes coming from Europe.


  The wider aviation world offers many examples of the way in which sports aviation can be run in a more satisfactory manner without reducing safety and at a significantly lower cost to the taxpayer and the sports aviator. The RAeC would welcome the opportunity to provide the Transport Committee with details of these and, indeed, any further points it may require to assist in its deliberations.

11 November 2005

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