Select Committee on Transport Written Evidence


APPENDIX 25

Memorandum submitted by Air Medical Ltd.

1.  INTRODUCTION

  Air Medical Ltd. (AirMed) is the largest operator of fixed wing Air Ambulances in the UK. Based at Oxford airport the company was established almost 20 years ago, has AOC number GB1171 and currently operates nine Air Ambulances as well as a number of passenger and freight aircraft. AirMed appreciates the necessity for and value of effective regulation. AirMed has in general a very high regard for the work undertaken by the CAA and in particular for those members of the CAA that work with us on the day to day aspects of maintenance and operations. However, there are two specific issues that AirMed would like to raise.

2.  THE ISSUES

  (a)  In order to compete with the low cost providers, ensure their flights run to schedule and to improve turnaround times, carriers such as British Airways are increasingly giving up providing stretcher capacity on their regular flights. Responding to the resulting increase in demand for Air Ambulances, AirMed recently bought and imported two aircraft from the USA. In so doing AirMed has had very recent experience of how the Civil Aviation Authority works and interacts with EASA on certification issues. In the opinion of AirMed, the procedures that have been established for EASA and the CAA to deal with certification matters are inadequate.

  (b)  AirMed is the UK's only operator of single engine turbine aircraft on a Type B Operating Licence AOC for public transport. Unlike the situation in many other European countries as well as the USA and Canada, it is economically unsustainable to operate single engine turbine aircraft in the UK because of restrictions imposed by the CAA. A proposal to enact legislation across all of Europe that would as a minimum ensure uniform rules for the operation of this type of aircraft, has been in the process of being developed for the last nine years. The CAA's attitude has continuously been to avoid seeking a decision on the issue and indeed it has done everything possible to ensure that it cannot be held responsible for any decision that is eventually taken. This has been detrimental to UK operators, is not what any industry expects from its regulator and has given other European operators a competitive advantage over their UK peers.

3.  CERTIFICATION

  EASA became responsible for the certification of aircraft in the European Community from September 2003. In the absence of EASA having the appropriate staff to undertake their certification responsibilities, it was agreed that National Aviation Authorities such as the CAA would act as a sub-contractor in their respective countries and do the work for EASA for a predetermined period. More than two years later the details of how the CAA works as a sub-contractor to EASA for certifying aircraft imported into the UK, do not appear to have been agreed. Reference to this is made in CAA Board Minutes that are published on the CAA's website. The situation is exacerbated by a submit your proposal and we will tell you what's wrong with it" approach when what industry needs is guidance to get it right first time. As a direct result of this, AirMed suffered delays in the certification of a Piper Cheyenne PA31T2 that it wished to put onto its AOC and operate as an Air Ambulance. The financial costs of this delay have been considerable and our confidence in the ability of the CAA and EASA to ensure a smooth transition towards EU Ops, (or is it EASA Ops?) is now very low.

4.  OPERATIONS

  The chosen method for transition from a number of national regulators of aviation to a single European regulator is having an unintentional effect. In essence the management of the CAA appear to be becoming reluctant to make decisions for which they feel may be held responsible in the future. They see the arrival of EU Ops as a way of delaying decisions, therefore passing the responsibility and any potential liability onto management of EASA.

  If the legislative process to decide whether or not European countries can agree on commonality of operating procedures for single engine turbines can take nine years and still have no end in sight, how many other Operational issues are being delayed for the same reason? What is the impact on safety?

5.  PROPOSALS

  The above two examples have been used to highlight some of the problems with EASA and the CAA's regulation of civil aircraft as perceived by AirMed, an Operator of a General Aviation fleet. It is suggested that the CAA should:

    1.  Continue to participate fully in the development of European and international aviation safety regulations, but work more in partnership with other European National Authorities, rather than pursue a separate agenda.

    2.  Understand that decisive rulemaking is beneficial to industry. Delays in making decisions are costing industry a considerable amount of money and creating a competitively uneven playing field.

14 November 2005



 
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