APPENDIX 40
Memorandum submitted by the Single-Engine
Turboprop Alliance (SETA)
1. INTRODUCTION
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.
2. THE ISSUES
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.
4. JAA/EASA
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.
5. COMPARATIVE
ACCIDENT RATES
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.
6. PROPOSALS
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.
REFERENCE
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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