Select Committee on Transport Written Evidence


Memorandum submitted by the Popular Flying Association


  The Popular Flying Association (PFA) is the representative body in the United Kingdom for amateur aircraft construction, sports and recreational flying. It represents some 8,000 members and, on behalf of the CAA, supervises the airworthiness of over 2,000 light aircraft in the UK with a further 1,500 in construction or restoration. This unique airworthiness function permits us to approve the design of amateur built aircraft and to supervise their construction, continued airworthiness and maintenance. Currently there are over 260 different aircraft types which the PFA has approved for amateur construction in the UK. On behalf of the CAA we issue and renew the Permits to Fly which stand in the place of Certificates of Airworthiness for these aircraft. This work requires us to work very closely with the CAA and particularly with the Safety Regulation Group. CAA airworthiness engineers are appointed to oversee and audit our work and we deal with them on a daily basis. We are part of a sector of aviation increasingly being referred to as Sports and Recreational Aviation, a definition which separates us from the operating commercial implications of General Aviation and brings very different social and economic benefits to society and the community. By comparison with many other nations, in our sector of aviation we experience a much higher level of regulation, overseen by CAA, than others require.


  In accordance with its remit, the CAA is focussed very much on the civil air transport industry. Its consultations are invariably with Industry" and the Sports and Recreational" segment of the General Aviation (GA) aviation sector, of which we are a significant part, is rarely included or properly considered. As an example, during its recent industry wide review of charges, the Sports and Recreational segment was specifically excluded from the work so as to enable a consensus to be reached with the main body of Industry. This review moved regulation costs from the commercial elements of Industry who were represented onto we who were not. We had expected that the CAA, as the regulator and in accordance with the principle of fairness that the CAA had set itself, would protect our interest but it did not do so. Indeed, the CAA has repeatedly claimed that we were represented in this work and this has recently been stated by the Parliamentary Under-Secretary of State for Transport in the House of Commons. Despite being often repeated this is unfortunately not the case.

  We consider that the remit of the CAA should be expanded to provide a formal responsibility to the development and protection of UK aviation beyond that for the civil air transport industry. The CAA is currently conducting a Strategic & Regulatory Review of GA in UK and this could form the basis for such an expansion of remit to encompass the Sports and Recreational element of GA.

  The structure of the CAA is also based on its civil air transport remit and there is no representation on its Board for the wider UK aviation interests, particularly Sports and Recreational aviation. We believe that the CAA Board should include such representation amongst its non-executive members.

  The CAA holds absolute power over the PFA, its members and their aircraft. Its sets the regulations under which we operate and it supervises the detail how we apply them. Our core business is safety and there are occasions when we have a safety related issue that we have to put to the CAA for consideration with a view to making some change. We find that in general, applications to the CAA to change procedures or regulations are not progressed in a timely and positive manner and this is out of step with the open culture that is at the core of air safety throughout UK aviation. For safety issues we find this unacceptable but we have no appeal at a working level short of the Secretary of State for Transport. We believe that:

  (a)  The CAA should progress safety related matters as expeditiously as it would expect us to do and should adopt the open and proactive culture embraced by rest of UK aviation.

  (b)  We should be able to appeal to an independent person or body about working level matters related to air safety.


  During its recent review of costs and charges, the CAA made much of its scrutiny of its own effectiveness and efficiency in cost terms. However, examination of its final report showed much of this work to be superficial and aimed at justification rather than improvements. This is to some extent understandable because the scrutiny was carried out by the CAA departments themselves and they would be unlikely to declare themselves inefficient. The CAA sets its own charges to cover its costs so there is no commercial imperative for it to be efficient. Major Industry organisations can exert pressure on the CAA to reduce the regulatory and cost burden on their business but Sports and Recreational Aviation has no such leverage; it needs a champion to protect it.

  All the users" of CAA regulation would agree that the CAA is not efficient enough, is not sufficiently cost effective and is not reducing in proportion as responsibilities pass to the EU. Nevertheless, this is the basis on which the CAA is going forward into the complex period of transfer of responsibilities to Europe.


  It is clear that with much aviation regulation being transferred to Europe, the CAA should be aiming to be much smaller and in the meantime be working hard to ensure that UK aviation is not disadvantaged by the transfer.

  The CAA should be downsizing but does not appear to be doing this enthusiastically and as it effectively regulates itself, there is little pressure for it to do so. The EU regulatory regime will be different to the traditional UK model and this is something we must accept. By comparison with many other nations, we currently experience a much higher level of regulation, overseen by CAA, than other European nations require. We now see UK regulations and charges being adjusted so that they can overlay the EASA arrangements and charges making UK aviation even more regulated and expensive than aviation in the rest of Europe.

  The focus of EASA is understandably on the regulation of commercial aviation but Sports and Recreational Aviation has been almost entirely disregarded. As a result, many regulations that are appropriate for airlines are being applied to us by default, creating a very difficult environment. We would expect the CAA to champion the cause of UK aviation into Europe but it is not doing so.

15 November 2005

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