European Transport Policy for 2010
Time to Decide

The General Aviation Awareness Council (GAAC), which oversees matters of concern to all sectors of UK GA, has submitted a response to the UK Government on the subject of the European Commission's White Paper of the above name.

The main points in the GAAC's submission are the need for a unified policy on provision of a network of UK aerodromes; the need for all EU countries to accept each others' certification approval for aircraft silencing kits; a removal of the difference in fuel duty between aviation gasoline and kerosene; and an air traffic control system that does not impose additional costs on non-commercial flights. (For more detail, see the following copy of the GAAC response.)

Note for editors: The General Aviation Awareness Council (GAAC) is the only truly representative body for GA in the UK, with 72 organisations in membership. For more information, contact David Ogilvy or Jack Wells on 020 7834 5631.

Consultation on European Commission's White Paper:
"European Transport Policy for 2010: Time to Decide"

Submission by

THE GENERAL AVIATION AWARENESS COUNCIL

Introduction.

1. The General Aviation Awareness Council (GAAC) is the body that oversees matters that are of concern to all sectors of General Aviation (GA). The Council concentrates its efforts on matters concerned with planning and education in the widest sense. A list of Member bodies of the Council is given at Appendix I.

2. GA embraces a wide variety of activities ranging from flying training to business aviation, recreational aviation and model aircraft flying. To place GA in perspective, the commercial airlines in the UK operate about 850 aircraft and use 23 airports. The UK GA fleet comprises more than 10,000 aircraft that operate from 140 licensed airports and aerodromes and more than 350 private airstrips. More than 70% of all GA activity has some business or safety purpose. 85% of all seats sold by airlines are for pleasure purposes. In the transport context our concern is more with the movement of people rather than freight.

3. Pamphlets issued by the Council have covered both planning and education. Four pamphlets produced by the Council are relevant to the "European Transport Policy for 2010: Time to Decide" consultation paper. They are concerned respectively with explaining the function and role of General Aviation ("Why General Aviation?"), the need for 'Your Local Aerodrome', how pilots and aerodrome operators can promote 'More Considerate Flying' and an environmental picture of small aerodromes in 'How Green is your airfield?' [Copies are enclosed with this submission]

General

4. Brussels Bureaucracy a) We are appalled by the increase in centralised bureaucracy that the White Paper promises. To quote: 'A large number of political measures and instruments will be needed to launch the process....... The measures advocated in the White Paper are merely the first stages of a longer term strategy.'
b) We are also bemused by such meaningless proposals as: 'satisfying the needs of users who, in return for the increasingly high cost of mobility.........companies; this will make it possible to put the user at the heart of transport organisation.'
c) We are concerned by the threat of moving from consensus to majority voting. This should be resisted wherever this would be detrimental to UK aviation interests.
d) A further example of the centralising bureaucratic flavour is the proposal, in the context of road safety, to: 'Develop a methodology at European level to encourage independent technical investigations e.g., by setting up a committee of independent experts within the Commission.'

5. So far as aviation is concerned the emphasis of the paper is on commercial air transport, to which the Council's activities are peripheral. Nevertheless the GA sector could contribute far more to the rationalisation of transport movements if there were a recognition by governments that GA has a role to play in the context of an integrated transport policy. These points were emphasised in our submission last year on the 'Future of Aviation' document.

6. The most important message of this submission is that the UK must adopt a unified national policy on aerodromes if it is to fit in with any plans for the EU area. This underlies all the comments that follow. A positive policy for aerodromes must ensue from this consultation process. GA has to be recognised as an essential element of the Europe's national transport, business and leisure infrastructure. Any policy for the future must recognise this. Proposals to constrain the growth in air transport - if this means total civil aviation activity - could introduce further distortions into the market and affect European competitiveness vis à vis the rest of the world.

'Intermodality' and 'A New Airport Infrastructure'

7. In the context of the Commission's proposals to develop 'intermodality' and 'a new airport infrastructure' a network of aerodromes that facilitates direct communication between the centres of activity throughout the EU area is essential. This would:

· Reduce the road traffic component of travel between business centres
· Reduce travel times
· Make a contribution to the reduction of road and air traffic congestion at the major airports
· Facilitate a consequential fuel saving - road and aviation fuel - and a corresponding reduction in pollution, thereby benefiting the environment.
· Improve business efficiency by enabling officials and busy executives to spend more time at work and waste less time travelling to appointments

8. New aircraft are on the stocks to meet an increased demand for this direct mode of travel, but, unless there is backing by Governments for the development of national networks of smaller aerodromes to facilitate a reduction in the dependence on the major hub airports, congestion will continue to grow and the opportunity to improve communication and develop trade will be missed. In the UK context this means that local authorities cannot be left to decide on the need for an aerodrome in their area and its operational conditions. Let them look across the Channel and learn from French towns; each sees it as essential to support a local airport..

Aviation and the Environment

9. Discussion in the white paper centres of course on commercial transport aircraft, but environmental pressure groups often seem to find noise from light aircraft more offensive than that from commercial jets. Operators of light aircraft appreciate the need to make their contribution to noise reduction by flying considerately and where practicable fitting silencing kits. There is however a significant cost to operators of light aircraft in fitting such kits. This could be reduced significantly if the UK CAA were to accept silencing kits certified by other EU countries for fitting to UK registered aircraft without requiring further certification by the Authority.

Taxation of Aviation Fuel

10. The GAAC supports the Government's view that it is not necessary to act at European level in these respects. The Council also believes that the imbalance between the tax on aviation gasoline and kerosene for domestic use should be removed and the duty on aviation gasoline reduced to the same level as that on aviation kerosene.

Creation of a Single Sky

11. Any measures that will improve the efficiency of air traffic control are to be welcomed so long as they do not incur additional costs on non-commercial flights, in particular flights operating under visual flight rules (VFR). One of our member associations, the Aircraft Owners and Pilots Association (UK), is closely involved in discussions of this topic at European level and the Council supports the stance being taken by that association. Their submission will deal with this issue in greater detail.

Shifting the Balance between Modes of Transport

12. While we argue strongly for there to be aerodrome facilities to encourage direct point to point travel, this is argued from the point of view of achieving the most efficient movement of people between points A and B. Should rail travel provide a faster connection then so much the better, but the need for a network of smaller aerodromes must not be dismissed on the grounds that rail travel might at some future date provide such a facility. The UK's under-funded rail network is unlikely to provide an alternative in the foreseeable future. Connecting the smaller centres of population by air is likely to prove to be far more efficient in both the shorter and longer term.

Conclusions

13. General. We are appalled by the threatened increase in centralised bureaucracy that can only increase the cost of GA operations and generally impair the competitiveness of EU countries.

14. Aerodromes There must be a unified policy on aerodromes for the UK if it is to fit in with any plans for rationalising transport within the EU area. This is particularly important in the case of the UK, being an offshore island to continental Europe. (Para. 6)
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15. The Environment Silencing kits already certified for use by an EU country should be available throughout the EU area without requiring separate certification by each national authority. (Para. 8)

16. Aviation Fuel Duty The anomalous difference between the duty on aviation gasoline and that on aviation kerosene should be removed and the tax reduced to the same level as that on kerosene. (Para. 9)

17. Single Sky Any measures that will improve the efficiency of air traffic control are to be welcomed so long as they do not incur additional costs on non-commercial flights, in particular flights operating under visual flight rules (VFR). (Para. 11)

General Aviation Awareness Council
19 January 2002

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