Select Committee on Transport Written Evidence


APPENDIX 24

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 imposed here.

  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 anachronisms—eg 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 The written examinations are over detailed, outdated, and can only be taken a few times a year at a specified location.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 The whole UK process is unnecessarily complicated, outdated and hostile, and consequently, few non commercial pilots do it.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



 
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