Select Committee on Transport Written Evidence


Memorandum submitted by the Single-Engine Turboprop Alliance (SETA)


  SETA is an industry lobby group representing manufacturers of single-engine turboprop aeroplanes, current and potential operators of such aircraft and other parties with a direct interest in the issues relevant to the commercial operation of these aircraft.


  The UK CAA is acknowledged as one of the leading aviation safety regulation authorities in the world. As regards large civil airliners, it has produced a framework of regulatory activity and monitoring within which the industry has achieved exceptional standards of safety. In this field (large jet airliners), the UK has a recent safety record which probably places it second only to the USA in the world ranking1. To a large extent, the staffing and emphasis within the CAA is to concentrate on this obviously important section of the industry. As regards small aircraft and their operation, the UK safety record relative to other countries is notably less good; there is less understanding within CAA of the realities of such operations and the approach can be unreasonably heavy-handed and expensive to industry. This submission concentrates on one current issue where the CAA is out of step with other major aviation countries and their position is preventing the adoption in the UK of safety improvements now being realised elsewhere, precluding the use by UK operators of safer, more efficient and less polluting aircraft both in the UK and elsewhere in the EU. Meanwhile, operators in seven European countries are permitted to use these aircraft commercially.

  The particular issue of current concern on which we wish to focus is that of the commercial operation of single-engine turboprops. For almost all practical operations in Europe, this requires their operation to include flight at night and in Instrument Meteorological Conditions (IMC, ie in cloud or poor visibility, without the ground being in sight). In 1948, when only piston engines were in use in civil aviation, the International Civil Aviation Organisation (ICAO), which sets minimum standards for international flights, required single-engine aircraft to operate by day, in Visual Meteorological Conditions (VMC) and such that the aircraft could glide to a site suitable for a forced landing in the event of an engine failure. This was fully justified in 1948. With the advent of the jet engine and, more recently, exceptionally reliable turboprop engines, a class of modern single-engine turboprops have entered service. Requirements have been developed allowing these aeroplanes to be approved for commercial operations at night and/or in IMC subject to suitably high engine reliability, compliance with modern design requirements and enhanced equipment, training and operational rules. Such operations are now allowed in the USA, Canada, Australia and many other major aviation countries; indeed, countries representing the majority of the world's civil aviation activity have given such approvals to their operators. The UK CAA has resisted progress with the European regulations and continues to do so in spite of clear and independent evidence that such operations are safer than the comparable light twin-engine aeroplanes (mostly quite old) that UK operators are forced to use. This is the current issue that we will use to support our proposals as regards the CAA. The details are given in the full report, the synopsis of which is provided as an Annex: Single-Engine Operations—The State of Play". (The full report has also been submitted for reference. All of the other reports referenced in this report and in the State of Play" are available if required).

3.  ICAO

  The International Civil Aviation Organisation (ICAO) proposed work to amend and update its Standards and Recommended Practices on a range of subjects in its Annex 6, Operation of Aircraft. Among these was the issue of Commercial Operations by SingleEngine Turboprops. This issue was reviewed by the Working Group of the ICAO Onerations Committee and new Standards developed, using, particularly, the draft proposals for the European Joint Aviation Regulations (JARs). The CAA participated in this work raising various aspects which found no favour in the Committee as a whole. The new Standards were developed and approved by ICAO's Operations Committee, Air Navigation Commission and Council, with minimal change, in four years, from 2001 to March 2005—fast by ICAO standards. The UK raised an objection when the final proposals were circulated to all Member States, but it appears that there was no other problem raised by the other 190-odd countries so that the new Standards come into effect worldwide on 24 November 2005. As is normal, it is expected that the great majority of States will amend their national regulations to be identical or consistent with the ICAO wording. The CAA's position appears to be to continue not to allow such operations, thereby preventing UK operators from using aeroplanes which have been shown, with adequate statistical confidence, to be safer than the light twins that they will have to continue to use. No relevant or valid criticism of the accident rate comparisons have been made by any of the countries involved in this worldwide process and in the JAA Working Group report the CAA agreed that the safety of the single turboprops was better or equivalent to that of the comparable light twins now used in the UK.


  The work by the European Joint Aviation Authorities (JAA) and now the European Aviation Safety Agency (EASA) to produce new requirement proposals to allow the approval of suitable single-engine turboprops at night and/or in IMC started in earnest in 1997. CAA was heavily involved in the Working Groups, which included three sub-groups from 1999 to 2001, fielding a team or individuals for all groups or sub-groups. The experts involved changed totally twice and there appeared to be no handover" or consistency in the lines taken. The number of meetings held was in the region of 33 and the costs to industry of attending these are estimated to be around £450,000. The cost to the National Aviation Authorities (NAAs) must be similar; in the case of the CAA, the costs, of course, ultimately again fall on the UK industry. In the first years of this long process, the CAA was virtually the only dissenting voice; more recently at least two more NAAs have sided with the CAA.

  In the earlier stages of the process, CAA cited the Airworthiness Requirements Board and the Operations Advisory Committee as having been consulted and claimed that they had received support for their policy. These bodies (now disbanded) have, in the past, played a valuable role. In a case such as this where the issue is highly controversial and industry and the Authority are deeply divided, the process is, we suggest, flawed. Apart from the fact that the membership of the Board or Committee is heavily biased towards the larger operators, the Paper presented is written by the CAA staff, presented by the CAA staff and defended by the CAA staff; it is also confidential and not available to industry as a whole. It can hardly be expected adequately to reflect the concerns of the operators and manufacturers involved, and thus a balanced set of evidence is not available. On particularly controversial issues, the consultation process, we suggest, should include a Paper from the relevant part of industry and probably a representative at the meeting to have the opportunity to counter-balance any points claimed by the CAA staff.

  A feature of the JAA, and doubtless the EASA, systems is that the main Committees (or Sectorial Teams") delegate the detail to a system of Working Groups. These would explore controversial issues, review evidence and try to produce proposals to resolve the differences. If National Authorities have particular problems with the proposals, it is essential that they participate in the Working Groups, hear all of the arguments and work to seek a solution. CAA has been a powerful and effective voice in the Groups and has often been constructive in finding solutions or compromise. However, in the last two years, they have not attended some of the Group meetings and since they have more problems with the proposed rules than any other Authority, this greatly reduces the value and cost effectiveness of the meetings. One might argue that an Authority with deep concerns about aspects of proposed regulations, and which does not attend meetings, justify its position and make itself familiar with all of the arguments, should forfeit the right to oppose the adoption of the proposed Final Rule (but this is unlikely to be accepted by the Authorities!)

  The JAA process has dragged on for nine years, largely due to the resistance of the CAA. Even though they have agreed the key comparative accident rate figures, they subsequently argue that there is insufficient statistical confidence". With the very high safety standards of modern aircraft, accidents or hazardous events will inevitably be small samples. (The application of regulations relating to twin-engine aeroplanes operating over long distances involving long periods to reach a suitable diversion airfield have to be based on minimal numbers of events"; that is the nature of modern regulations). Even though industry had provided data on the statistical confidence of the accident rate comparisons, an independent aviation statistician was employed to give a second opinion and this substantiated the validity.


  The data summarised in the Annex makes it clear that this is the core of the issue. The overall Fatal Accident Rate for modern Single-Engine Turboprops is 4.27 per million hours. That for comparable piston-engined Twins ranges between 10 to 23 and for turboprop Twins between six and 20 per million hours. The UK record for these twins is twice as high as that for the USA at around 20, which should alone be sufficient incentive to allow safer modem aircraft. The UK operators are forced to continue using these twins even though the evidence clearly shows that the modern single-engine turboprops used by most of the world are two to three times safer.


  The issue of the commercial operation of suitable single-engined turboprops has been used to highlight some of the problems with the CAA's regulation of civil aircraft safety as perceived by industry and some other JAA authorities. In the context of the EASA and common European regulations which are binding by law, it is suggested that the CAA should:

    1.  Continue to participate fully in the development of European and international aviation safely regulations, but work more in partnership with its European brother Authorities, rather than pursue a separate line.

    2.  Where it has major concerns regarding aspects of proposed regulations, give a high priority to attendance at the relevant Working Groups.

    3.  Seek greater consistency in the line taken by its experts, particularly when circumstances require the experts to be replaced on committees and working groups.

    4.  Ensure that its policies are consistent with the evidence agreed by its experts; (avoid giving any impression of don't confuse me with the facts, my mind is made up").

    5.  Be much more willing to adopt requirements that fully reflect ICAO SARPs.

    6.  Accept the importance of progress in the complex and lengthy process now facing European regulations, and ensure that the CAA is not responsible for work being stretched out over nine years at major expense to the industry and all Authorities.

    7.  In future consultation forums, invite papers and representatives on deeply controversial issues from both sides", and not limit the (confidential) input to CAA staff only.

    8.  As regards the operation of light aircraft, adopt a lighter touch, placing greater reliance on other Authorities work, as has been the case for airworthiness issues. This would greatly reduce costs.

  In the context of the single-engine turboprop issue, CAA should ensure that the fare-paying public have the opportunity to fly in modern aircraft that have been shown to be safer and therefore:

    1.  Boldly propose to its European partners a finish to the endless and increasingly circuitous debate and the immediate adoption of the ICAO SARPs into JAR-OPS and its EU successor, or, as second best, adopt JAR NPA-OPS 29 in its latest form.


1.  Fatal Accident Rates for World Regions and Countries: Western-built Jet Aircraft Operations, 2000-04 inclusive", Report RA/2005/05 Issue 1, 9 August 2005.

10 November 2005

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