Memorandum submitted by the Helicopter
Club of Great Britain
The Helicopter Club of Great Britain represents
the owners of approximately 33% of UK registered helicopters,
as well as over 500 UK helicopter pilots.
We support and reiterate the submissions of
the General Aviation Alliance, AOPA and the GAAC, and endorse
the points they have raised, in their papers to you.
We would like to add just a few examples of
CAA over regulation, and contrast some of their requirements against
those of the US Federal Aviation Authority. The efficacy of aviation
regulation is judged against accident statistics, and it is accepted
by both the aviation industry, UK General Aviation and the CAA
itself that the accident rate in the USA is the same or even a
little safer than the UK, despite the gold plated" regulation
1. The CAA charges helicopters double the
cost that fixed wing aircraft are charged for a Certificate of
Airworthiness, and this is charged every three years. In the USA
there is no fee.
2. Single engine helicopters are prohibited
from flying IFR in the UK, although single engine fixed wing are
permitted to do so. Clearly a modern turbine helicopter with autopilot
is safer in IFR than a 30 year old fixed wing. In the USA single
engine helicopters may fly IFR with an autopilot.
3. The CAA pilot Instrument Rating requirements
are excessively onerous, with many historical anachronismseg
hours spent tracking NDB beacons, when, in the real world, they
are being removed from service by the CAA! The written examinations
are over detailed, outdated, and can only be taken a few times
a year at a specified location. In the USA the Instrument rating
qualification teaches pilots the same skills (but not the old
NDB) but with greater student ease, relevance and practicality.
Written examinations can be taken at multiple locations, at a
time of the student's choosing, with instant results. The whole
UK process is unnecessarily complicated, outdated and hostile,
and consequently, few non commercial pilots do it. In the USA
over 50% of pilots have the IR; in the UK it is 2%.
4. The CAA demands both an IR and VFR test
flight on every helicopter type every year. This is gross overkill,
costly and inconvenient. The FAA requires simple recent relevant
flight experience or a flying test once per year, and on any type.
5. The CAA does not accept FAA qualifications
to fly many business jets. Despite fulfilling the strict criteria
in the USA, British pilots then have to do flights in the UK before
the CAA will accept their type qualification.
6. The CAA demands all aircraft and helicopters
be fitted with a Mode S transponder by 2008. This is despite the
fact that no use of the information will be made by ATC outside
controlled airspace. As if it weren't enough that the aircraft
owner must buy a new transponder and pay for its fitting, the
CAA is demanding a £400+ fee for their approval" to
fit it! They could be accused of making new rules like this just
to create revenue!
7. The CAA, whilst staffed with generally
well meaning people, are divorced from safety reality, and over
regulate and over prescribe in the extreme. There is an attitude
that only the CAA knows best, and that the nation that produces
most aircraft can't possibly judge their safety.
8. The CAA does not accept the maintenance
certificate from any qualified organisation as they used to. Now
an AOC holder has to have each certificate specially approved,
which inhibits the free flow of aircraft/helicopters from one
operator to another.
9. The Government requires the CAA to earn
a 6% profit on capital employed each year. Other similar organisations
only need to produce 3%. The Government are, by this rule, making
a profit out of safety. This is simply wrong. It must change.
This is just a short selection of the many hundreds
of unnecessary impositions the CAA makes on aircraft owners and
pilots in general, and Air Operator Certificate holders in particular.
These imposts do not make British skies safer than those of the
USA, merely more expensive.
I could give more examples, but I'm sure you
can see that severe and radical change is needed at the CAA if
a modern, accountable, efficient and user responsive regulator
is to emerge from the present bloated monolith.
As an industry, aviation is drowning in paperwork
that achieves no increase in safety, but instead hinders free
and efficient operations and reduces efficiency. All this achieves
is to keep the overstaffed CAA in work.
14 November 2005