Select Committee on Transport, Local Government and the Regions Appendices to the Minutes of Evidence


Memorandum by National Air Traffic Services (AT 31)

THE AIR TRANSPORT INDUSTRY

1.  INTRODUCTION

  1.1  The Committee has announced its intention to undertake a short inquiry into the impact of the 11 September terrorist attacks on the air transport industry. This memorandum is offered as a contribution to the inquiry and highlights the main effects of the downturn in air traffic on NATS' business outlook and explains the steps we are taking to address those effects.

2.  THE PUBLIC PRIVATE PARTNERSHIP

  2.1  There has recently been a good deal of press speculation, as well as interest in the House, about the implications of the downturn for the NATS Public Private Partnership (PPP). The PPP was established on 26 July and it was only a matter of weeks before the company was facing the most serious challenge in its history.

  2.2  We strongly believe that the rationale for establishing NATS as a PPP remains sound, with a clear alignment between the public interest and the interests of the airline community in maintaining a safe, effective and efficient air traffic control service. NATS remains committed to delivering to its customers and stakeholders the enhancements which the PPP is designed to achieve—our objective is to deliver the following benefits, while at the same time maintaining our status as a world leader in the safe operation of air traffic control systems:

    —  the introduction of increasingly competitive charges;

    —  improvements in the procurement and delivery of new technology;

    —  the introduction of private sector business skills and experience in the areas of procurement, planning and delivery of major capital investment projects;

    —  bringing into operation Europe's largest new control centre at Swanwick on 27 January 2002;

    —  a sustainable, long term investment programme for the introduction of advanced systems; and

    —  a leading position for the United Kingdom as we move towards EU integration under the Commission's "Single European Sky" initiative.

  2.3  The establishment of the PPP has given NATS the commercial freedom and structural incentives required to improve the efficiency of the business and, under normal market conditions, the PPP framework provides NATS with the resilience and commercial freedom to respond to the fluctuations of the economic cycle. However, the scale of the present economic downturn in the air transport industry is unprecedented. The present situation was not predicted when the PPP was implemented, and when decisions were taken on the financial structure of the Company based on forecast economic conditions. The company is addressing the impact in the same way as any other commercial business by adjusting our costs and financial commitments to take account of the new economic conditions.

3.  IMPACT OF 11 SEPTEMBER

  3.1  It seems likely that the effects of 11 September on the industry worldwide will be unprecedented in their severity. For example, the International Labour Organization (ILO) issued a statement on 30 October noting that "the events of 11 September were unlike any other shock experienced by the industry to date. They have had a unique, unprecedented, devastating and immediate impact on all segments of the industry with unpredictable economic and social consequences. It is expected to take years for the industry to reach the same levels as before 11 September 2001. The air transport industry employs some four million persons worldwide, of which more than 200,000 have lost their jobs or will in the immediate future."

  3.2  At the time of writing, the economic outlook remains very uncertain and it is still not possible to predict with confidence the future level of demand for NATS' services. The initial response from the industry to the events of 11 September has been a significant reduction in capacity, with reductions in frequencies and aircraft sizes, and some shedding of routes. With the introduction of Winter schedules, it appears that scheduled services are being reduced by up to 20 per cent on the North Atlantic and by up to 10 per cent on some European routes. In contrast, the market for services provided by the low cost carriers on European and domestic routes has remained strong.

  3.3  The outlook for traffic volume in the medium term depends on a number of factors which are difficult to quantify. The most crucial factor is the willingness of people to resume flying, particularly in the US and on North Atlantic routes. Second, with the recent collapse of Sabena, Swissair and Canada 3000, and with other airlines known to be in financial difficulties, we expect to see further industry consolidation. The recent press reports about a possible link between British Airways and American Airlines provide evidence of this likely trend, but the rate at which consolidation will take place in the industry remains uncertain. A further important area of uncertainty is that the US airline industry is currently being supported by the US Government, but it is unclear how long this support will last or what will happen if and when it is withdrawn.

  3.4  North Atlantic traffic accounts for 14 per cent of NATS traffic but produces 44 per cent of NATS income. In consequence, given the marked reduction in this traffic, the impact on NATS of the events of 11 September has been particularly severe. The weight and distance formula used to calculate NATS en route charges means that some types of flight (typically North Atlantic arrivals, departures and overflights by heavy aircraft) produce a higher yield than others (eg short haul flights by low cost carriers). It is against this background that NATS is now facing a potentially significant shortfall against the revenue predictions made at the time the PPP transaction was completed at the end of July.

  3.5  In summary, there is continuing uncertainty about the financial consequences for the Company, and about the overall scale and duration of the downturn and the longer term recovery profile. Current expectations are that it will be 18 months or more before we see any return to the levels of growth experienced in recent years.

4.  RESPONSE

  4.1  Many of our customers are having to make drastic cost cuts to remain in business. Like any well-managed business facing this situation, NATS too is acting to reduce costs and conserve cash. Clear principles have been established for this process and they have been in place throughout the Business Planning process which is currently in progress. The Company will not over-react to the situation, and it will not make any changes that could compromise either the safety of operations or the integrity of NATS systems. Staff issues will be managed properly, maintaining the commitment to the current Staff Surplus Agreement.

  4.2  The main strands of the emerging business plan are as follows:

    —  a Long Term Investment Plan that provides capacity ahead of demand yet maintains flexibility to adjust project timings to match traffic growth.

    —  a competitive sourcing approach for Commercial Off The Shelf (COTS) based systems.

    —  targeted cost savings in engineering/R&D, through staff reductions arising from efficiency measures, reductions in requirements and collocation, as well as through optimisation of maintenance contracts.

    —  a Human Resources and Change Plan to drive up management capability, introduce new performance management processes and improve employee relations.

    —  business efficiency measures to reduce overhead and support costs through organisational review, improved business systems, a shared services approach for Human Resources, Procurement and Facilities Management, and a new accommodation strategy.

    —  validating the safety implications of each aspect of the business plan.

  4.3  With the completion of the Business Planning activity, there should be a clear view on how much money can be saved while ensuring that we continue to provide a safe and effective service. The Plan has been reviewed by the NATS Board, which now comprises both Government and Airline Group directors. The next step in the process is that the Plan will be the subject of a period of consultation with customers and other stakeholders including the CAA. There will be a series of staff open meetings from early December and the first meeting of the Stakeholders Council is due to take place on 24 January when the Plan will be a major item on the agenda for that meeting. The Plan will receive its final sign off at the end of March.

  4.4  Despite the Company's best efforts to generate internal efficiency improvements, it remains possible that these savings will not be sufficient to bridge the gap between income and expenditure. In that case, like any other company in similar circumstances, there will be discussions with our regulator, shareholders and lenders to close the gap. We believe it is important to be able to demonstrate that we have made our best effort to solve the problem, and that on that basis the banks, our Government and the Airline Group shareholders and the CAA will have confidence in providing any necessary support.

  4.5  The Company remains committed to meeting the regulatory requirement to reduce en-route charges by RPI—3 per cent in 2002, unlike our European counterparts many of whom are proposing to increase prices by between 10 per cent and 25 per cent. We will be examining whether subsequent price reductions of RPI—4 per cent, RPI—5 per cent and RPI—5 per cent in the succeeding three years remain appropriate in the new circumstances.

5.  CONCLUSION

  5.1  NATS, as an integral part of the aviation industry, is exposed to the events of 11 September in the same way as its airline customers. It has a heavy exposure to North Atlantic traffic, which is particularly affected by the present downturn and may be further affected as US Government subsidies to its airline industry reduce.

  5.2  NATS is taking action to contain its costs to reflect the traffic downturn in so far as it is practical to do so and consistent with the Company's commitment to maintaining safety and standards. We have established a close dialogue with our shareholders, lenders and the regulator with a view to ensuring that the PPP structure is robust to the current financial situation and continues to deliver the benefits for which it was established.

National Air Traffic Services Ltd

28 November 2001

Memorandum by the Air Travel Insolvency Protection Advisory Committee (AT 32)

THE EFFECTS ON THE AIRLINE INDUSTRY OF THE EVENTS OF 11 SEPTEMBER

  I understand that the Committee will shortly be conducting an investigation into the impact on the aviation industry of the September terrorist attacks in the United States. I am writing to you in my capacity as independent Chairman of the Air Travel Insolvency Protection Advisory Committee ("ATIPAC"). As Members of the Select Committee will be aware, ATIPAC is a Committee set up by the Secretary of State for Transport, Local Government and the Regions to advise on the financial protection arrangements for air travellers and customers of air travel organisers. Its membership includes the principal industry bodies, consumer and independent representatives and nominees from the Civil Aviation Authority and the Air Travel Trust.

  ATIPAC's particular concern is that the effects of the attack have already had a significant effect on consumer confidence and on the demand for leisure air travel; as a result, we believe it is realistic to assume that there will be an increase in the number of tour operators that fail over the coming months, possibly including companies of a significant size.

  This will not of itself necessarily cause a problem to the public because of the high level of protection given to them by the Air Travel Organisers' Licensing (ATOL) system. However, the ATOL system is itself dependent on the Air Travel Trust Fund, which provides the back-up for the individual bonds that tour operators provide as a condition of being granted licences. The Fund is currently in deficit, and cannot be replenished by a levy on holidays without primary legislation to establish the necessary powers. This has been promised by successive DTLR Ministers since the collapse of ILG in 1991, but Parliamentary time has never been made available and there are no current plans to introduce the necessary legislation. In the meanwhile the Trust has continued to pay claimants using borrowings guaranteed by the Secretary of State: the debt currently amounts to just under £9 million, and interest amounted to over £0.5 million in the last financial year.

  ATIPAC has repeatedly made clear its view that borrowings are not a satisfactory long-term solution, and that deficit financing is not a proper basis for a major public protection system. A bill to establish levy powers would be uncontroversial; indeed, the industry is in general concerned that the longer the delay, the greater will be the burden on the industry and the travelling customer when the debt has to be repaid.

  ATIPAC believes that there is no reasonable excuse for the long delay that has occurred. We would like to suggest that Committee Members press DTLR Ministers and officials on why they have taken no action; whether they are aware of the damaging effect of delay and uncertainty; and how they will respond if there are heavy calls on the Trust Fund's borrowing facilities over the next year.

  I am enclosing for the Committee's information copies of ATIPAC's latest report, in which it drew the attention of the Secretary of State to the problem in very clear terms.

John Cox

Chairman

31 October 2001

Memorandum by Airport Coordination Limited (AT 33)

INTRODUCTION

  Airport Coordination Limited (ACL) is the appointed Coordinator of the UK's four fully coordinated (Heathrow, Gatwick, Stansted, and Manchester) and two coordinated (Birmingham and Glasgow) airports. It also acts as a schedule facilitator and data collection agent for other UK airports.

  ACL was asked to provide the Transport Sub-Committee with data on the slots requested and allocated to airlines for the Summer 2002 season, compared with Summer 2001. This is in support of the Sub-Committee's inquiries into the impact of the events of 11 September.

  The data requested is provided in the table below.

COMMENTS

  Airline schedules are coordinated on a seasonal basis—summer and winter. The seasons coincide with the daylight-savings-time clock changes in late March and October. The coordination process requires airlines to submit their planned schedules for the forthcoming summer season in mid-October the previous year (ie, five and a half months prior to the start of the season).

  At early stages in the scheduling process airline requests tend to overstate true demand and the number of slots allocated normally decrease by the start of the season as airlines finalise their flying programmes. Also, at capacity constrained airports like Heathrow and Gatwick, the number of slots allocated is more a function of capacity availability than airline demand (which far exceeds capacity).

  Year-on-year comparisons of slot requests and allocations may provide a general indication of demand. There are specific factors that serve to distort the data for Gatwick and Stansted, however, which are explained below:

Gatwick

  Gatwick is showing a significant increase in slot requests for Summer 2002 (+12 per cent). The number of slots allocated is only up by 1.8 per cent due to the capacity constraints at the airport.

  This high level of demand arises from a combination of incumbent carriers that have claimed their "grandfather rights" to slots and other carriers, principally low-cost carriers, that see an opportunity for expansion at the airport. The increase in slot requests thus overstates true demand to the extent that incumbent airlines may yet cancel some slots in excess of their requirements following the events of 11 September. ACL is not in a position to quantify this effect, however.

  There is generally great uncertainty surrounding the future of Gatwick, particularly as British Airways reviews its future strategy.

Stansted

  The number of slots requested and allocated for Summer 2002 is down significantly (11 per cent and 9 per cent respectively) compared with Summer 2001. This appears to be due to a reduction in overbidding for slots rather than a reduction in true demand.

  Although the number of slots allocated at this stage in the process for Summer 2001 was 136,000, it had reduced to 107,000 by the end of the season. There is thus still a prospect of continued growth at Stansted despite the apparent reduction in demand.

  A significant change in Stansted traffic since 11 September has been the withdrawal of services by some European carriers (eg Lufthansa) while the low-cost carrier traffic remains robust.

SUMMARY OF SLOTS REQUESTED AND ALLOCATED AT MAJOR UK AIRPORTS

AirportSlots requested Summer 2001

Summer 2002

% ChangeSlots allocated Summer 2001
Summer 2002% Change
Heathrow335,419344,254 2.6%282,968283,563 0.2%
Gatwick206,419231,211 12.0%174,484177,657 1.8%
Stansted144,000127,579 ¸11.4%135,968123,322 ¸9.3%
Luton39,77435,376 ¸11.1%39,77435,376 ¸11.1%
London City38,90345,779 17.7%38,90345,779 17.7%
LONDON TOTAL764,516784,199 2.6%672,097665,697 ¸1.0%
Manchester146,323137,812 ¸5.8%146,323137,812 ¸5.8%
Birmingham89,71082,355 ¸8.2%89,71082,355 ¸8.2%
Glasgow62,12963,514 2.2%62,12963,514 2.2%
Edinburgh61,16167,599 10.5%61,16167,599 10.5%
Aberdeen30,98729,535 ¸4.7%30,98729,535 ¸4.7%
SCOTTISH TOTAL154,277 160,6484.1%154,277 160,6484.1%
Major UK airport total1,154,826 1,165,0140.9%1,062,406 1,046,512¸1.5%
Notes:

Data as at December 2000 and December 2001 for the Summer 2001 and 2002 seasons respectively.

For calendar reasons, the Summer 2001 season extended over a 31 week period, compared with 30 weeks for Summer 2002. Summer 2001 data are adjusted to an equivalent 30 week period for comparison purposes.

Source: Airport Coordination Ltd.


Memorandum by Timothy Nathan Esq (AT 34)

INVESTIGATION INTO AVIATION

  I write as an Air Transport pilot no longer employed in the industry, but now owner and director of a successful and expanding software house operating a twin piston engined light aircraft.

  All my flying is on business (except for a couple of hours a year training and validating.) Many of my trips around the UK and near continent would simply not be possible without light aircraft, and the way in which the company is flourishing, even in the present harsher climate, is to a great extent down to my ability to respond quickly and flexibly to customers all over the country and Europe.

  Although I write as an individual, I represent the views of many business aircraft operators, with many of whom I am in weekly contact.

  I have a number of important and separate submissions to make, in no particular order:

1.  ROUTE CHARGES

  The present scheme for Route Charges is unfair and disproportionate to the private operator of a light twin of a little more than two tonnes.

  1.1  Charges are raised for IFR movements outside controlled airspace, regardless of any services offered or used. Many IFR movements are only IFR by dint of being operated at night, and at night many Lower Airspace Radar Services (LARS) are unavailable. Furthermore, LARS services are being made severely less available, with Kent Radar, Thames Radar, Dunsfold and Luton all being withdrawn recently in the London area alone, and for compulsory charges to be raised for a reduced or non-existent service is extortionate. With NATS now denationalised there must also be a question of the legality of their raising charges for services which either are not required by the user or are not provided when they are required.

  1.2  There is also a procedure between NATS and Eurocontrol which, in normal business, would be considered very sharp practice, possibly even illegal. Accounts are raised for every flight of an aircraft over two Tonnes whether charges are due or not (ie even if the flight is VFR.) While there are mechanisms to inform the Routes Charges Office that such flights were conducted under VFR, it is the responsibility of the operator to inform NATS that a flight is exempt, rather than the responsibility of NATS to determine that the charges are due. This results in either (i) a large administrative burden on the operator to ensure that they are not wrongly charged, (ii) a burdensome procedure to claim a refund via Eurocontrol or, I suspect rather commonly, (iii) accounts which have been raised fraudulently being paid because the operator is sufficiently confused by the immensely complicated Eurocontrol invoice (the invoice is typically 12 pages long with the detail on page 7.) This underhand practice on NATS' and Eurocontrol's part should be stopped and replaced with a system whereby NATS must have evidence that a flight was operated under IFR before charges are raised.

  1.3  There is an arbitrary weight cut-off for charges whereby an aircraft of 1.99 Tonnes receives air traffic services for free, but an aircraft of 2.01 Tonnes must pay a large charge, amounting to an extra 35 per cent of direct operating costs. This is particularly unfair on a light aircraft, which barely exceeds the cut-off and is occupying no more resource than another, which is under the arbitrary limit. Charges are made on a formula based on the square root of weight, unduly biasing the charges against light aircraft. The charges should be considerably more proportionate.

  1.4  Charges are based on weight, but do not take into account fuel usage. Duty on Avgas is such that it costs approximately three times as much as Jet A1, with the difference almost all being payable in tax. Under these circumstances it is wrong that aircraft should be taxed equally for airspace usage.

  1.5  JAA is proposing that Route Charges for aircraft in the two to 5.7 Tonne range should be simplified by making an annual charge, rather than by the present (uneconomic) system of levying a charge on each flight. It would be grossly unfair if a privately owned light aircraft operating, typically, one or two route sectors a week should be charged at the same rate as a commercial aircraft operating two or three sectors a day. It would be doubly unfair if piston aircraft were charged as much as jet aircraft for the reasons given in 1.4 above. There is a safety argument for IFR charges to be amortised over the year, as the IFR/VFR decision would not be contaminated by cost considerations. However this charge should be fair and proportionate. JAA is likely to offer member states the option or raising no charge for private category piston engined aircraft up to 5.7 Tonnes and I hold strongly that the UK should adopt this sensible solution.

2.  ATSOCAS

  2.1  The provision of Air Traffic Services Outside Controlled Airspace (ATSOCAS) has long been a contentious issue between the providers and the consumers.

  2.2  There are principally four ways in which such services are provided, being (i) Military Lower Airspace Radar Service (LARS), (ii) Civilian LARS, (iii) Units offering services on an ad hoc basis because they have the capacity and (iv) Flight information.

  2.3  Both military and civilian LARS are intended to use spare capacity from units who have to employ controllers anyway, but cannot use them full time. The service is partly funded by NATS, but does rely heavily on the provider being willing and able to allow controllers and equipment to be spared when available.

  2.4  In large part, the justification for a unit to provide a LARS service is that it helps provide a safer environment for the aircraft which form the primary responsibility of the unit. A prime example being Farnborough which has to launch and recover jet traffic through one of the busiest areas of uncontrolled airspace in the world, the corridor between Heathrow and Gatwick zones, in which there are four busy GA airfields plus a great deal of transiting traffic.

  2.5  LARS is only provided when controller workload permits and there is no obligation to provide a service, but service is usually offered.

  2.6  Examples of units which are not officially part of the LARS network but which may be prevailed upon to provide some level of service are Luton, Thames (ie London City) and Birmingham. These services are only provided when controller workload permits and, it seems, when the controller feels like it. There is no obligation to provide a service. In my experience a service is less likely to be offered than more, but I have no statistics.

  2.7  The other ATSOCAS offered by NATS is Flight Information Services. Although there is widespread misunderstanding among student and private pilots about this service, it is a non-radar service best suited to providing information about danger areas and weather and very little use in terms of providing separation between aircraft.

  2.8  ATSOCAS are not only helpful to recreational light aircraft. They are vital to air ambulance and police operations, public transport operations outside controlled airspace (particularly in North East England), business aircraft (and even politicians electioneering, as William Hague found to his near cost during the last election!) These services are not optional or frivolous.

  2.9  There are a number of shortcomings of the present system:

  2.9.1  The number of units offering LARS is decaying at an alarming rate, particularly in the London area, where they are most needed owing to traffic density. The recent withdrawals from the system in this area are mentioned in 1.1 above. Whereas two units have been added to the system recently (Bournemouth and Southend), and while this is welcome, they are not located in critical areas and London is a far more demanding area.

  2.9.2  LARS units tend to be closed when they are most needed, at night and at weekends.

  2.9.3  LARS units are soon saturated by trying to assist too many aircraft. It is, of course, at exactly these times when their services are most vital. Because LARS is only ever intended to take up spare capacity, LARS units reasonably argue that it would be uneconomic to employ extra staff and equipment to meet the extra demand.

  2.9.4  Key to all the other problems is that LARS is funded by NATS which receives almost no income from the aircraft for whom it is primarily intended (ie light aircraft flying under VFR). Accordingly, and not surprisingly, they prefer to spend their budget on their paying customers. This issue bears directly on paragraph 1.1 above. They accept little or no responsibility for ATSOCAS, because they are a business, yet they still charge heavier aircraft as if they were a governmental body. They are trying to deny the existence of the cake and eat it!

  2.10  Many private pilots consider that NATS does have a responsibility to provide ATSOCAS because it is only because NATS demands so much sky for controlled airspace that traffic outside is forced into narrow, shallow, overcrowded corridors (between Heathrow and Gatwick, Heathrow and Luton, Luton and Stansted and Birmingham and East Midlands in particular.)

  2.11  This discrepancy between the needs of the General Aviation and the business goals of NATS is something that needs to be tackled at government level and should in the first instance be looked at by the Select Committee. There are several possible solutions:

  2.11.1  Raise a charge on all VFR and IFR flights and hypothecate this charge for the provision of effective ATSOCAS. This would be enormously unpopular among pilots and businesses working in the industry, and will be touted as a "death knell" for GA. It would also be uneconomically expensive to collect.

  2.11.2  Use some of the considerable amount of tax paid on piston aviation fuel to provide the service.

  2.11.3  Raise the taxes mentioned in 2.11.2 and hypothecate the revenue. This would be fairer and easier to administrate than 2.11.1 but would remain unpopular.

  2.11.4  Legislate that NATS must provide effective ATSOCAS as the social cost of being granted the right to control national airspace, thereby excluding much General Aviation from an asset which might be considered "public property." This would clearly be the solution of choice to GA.


3.  NOISE REDUCTION FOR PISTON AIRCRAFT

  3.1  The greatest threat to aviation in general and general aviation in particular is the objection to aircraft operation on noise grounds. Airfields are closed or severely curtailed because of noise complaints, and members of the public living near airfields are significantly inconvenienced by aircraft noise.

  3.2  There are two readily available technologies which can reduce considerably the noise produced by piston-engined light aircraft, being exhaust silencers and propellers with more, shorter blades.

  3.3  Many UK operators would fit these devices to their aircraft if it could be done for a reasonable amount of money. However, the cost of fitting only relates in small measure to engineering costs. The principal cost lies in meeting the CAA's regulatory burden. Each installation invalidates the Certificate of Airworthiness of the aircraft and it has to be re-certified by the CAA. This re-certification is hugely time-consuming and expensive.

  3.4  It would be in the interests of both the industry and the general public if this cost could be eliminated. This could be done by the CAA accepting in principal that the addition of silencer(s) and/or quiet propellor(s) does not invalidate the Certificate of Airworthiness, or, if this is unacceptable, that the Certificate of Airworthiness be revalidated in a normal triennial Certificate of Airworthiness renewal test flight.

  3.5  States like France and Germany make government subsidies to overcome this problem, and in the US, manufacturers rely on the pure number of pilots and aircraft to cover their costs.

  3.6  It is particularly irksome to those of us who wish to be neighbour friendly that the CAA is not even prepared to accept certification from other JAA states (notably Germany.) As will be pointed out below there are many ways in which the CAA follows JAA slavishly, it would be worth asking why in this particular regard it chooses to ignore an obvious benefit of membership.

  3.7  This is an area in which the CAA is being unnecessarily intransigent and could be quickly addressed by the Select Committee to everyone's benefit.

  3.8  Furthermore, owners could be encouraged to spend money on noise reduction by a significant reduction in fuel duty for quieter aircraft. One or two pence a litre would not suffice, but ten or twenty pence would make the decision to get quieter much easier to take!

4.  REGULATORY BURDEN

  4.1  Rarely does a year pass without some new piece of electronic equipment being mandated for light aircraft. Recently this has included 760 channel radios, BRNAV, FM immunity and autopilot, and shortly we expect 8.33 kHz radios and S-mode transponders to be made compulsory.

  4.2  Although the cost of these items can be rapidly amortised in commercial aircraft, they are a huge burden on private aircraft.

  4.3  I would particularly propose that if S-mode becomes a requirement for transport aircraft, many mode alpha codes would be released for use by private aircraft, thus minimising the need for them to change as well.

  4.4  It seems that the CAA does not carry out proper studies of the real regulatory impact or cost/benefit analysis of new requirements before introducing them: Mode S is a case in point. They seem to hide behind the need to implement rulings of JAA, which is neither elected nor accountable and does not take sufficient notice of the UK environment.

5.  GLOBAL POSITIONING SYSTEM

  5.1  We are now in the rather topsy-turvy situation that we are obliged to carry GPS equipment to meet the Basic Area Navigation (BRNAV) requirements, but are effectively forbidden to use this equipment as a prime source of navigation.

  5.2  There are many places in the UK whose only instrument approaches depend on demonstrably inaccurate, interference ridden, unreliable and difficult to interpret old technology (NBD/ADF) but we are forbidden to use the hugely more accurate, reliable and well presented GPS system to approach these airfields.

  5.3  Anyone who has flown the NDB procedure at night to a coastal airfield such as Shoreham can testify to the fact that the approach path can be "bent" by twenty degrees or more, whereas GPS provides an accurate, reliable and safe let down superimposed on an easily read moving map.

  5.4  Other airfields which do not have any radio aids should also be enabled to publish GPS approach procedures.

  5.5  There is a perception (possibly inaccurate) that CAA conservatism is standing in the way of airfields proposing GPS approaches. There is an experimental approach being tested at Cranfield but other airfield managements certainly do not feel encouraged by the CAA to invest the money required to draft and test GPS procedures.

  5.6  The CAA should be asked actively to encourage other airfields to produce proposals for GPS approaches.

6.  PROVISION OF GENERAL AVIATION FACILITIES IN THE MANCHESTER AREA

  6.1  Manchester is now a complete desert with respect to General Aviation facilities. Unfortunately this often means that I simply leave Manchester out of my itineraries, both to my cost and Manchester's

  6.2  Manchester Airport is hugely expensive for use by a light aircraft. The total charge is well in excess of £200 for an overnight stop. It is in Manchester's interest to have business aircraft visiting and this will only come about if these costs are reduced.

  6.3  Manchester Barton, the grass runway "club" airfield near Manchester, despite its claims to be a "unique recreation and business asset of regional importance" does not permit its runways to be used by business aircraft. It does allow helicopter access, which is of some business benefit, but excludes multi-engined aircraft, which account for the vast majority of business aeroplanes. If Barton is to be a business asset this can only be achieved by either draining or hardening the runway and, arguably, slightly lengthening it. It is unlikely that Lancashire Aero Club could raise the funds to do this, especially if they continue to ban business aeroplanes, nor is it likely that they would want to while they suffer from planning blight.

  6.4  Woodford, a British Aerospace facility reasonably close to the city centre, is a near-perfect facility, yet it is closed to General Aviation for spurious security reasons. There is no reason why a GA facility at Woodford should not have independent access from the road, and create no security risk whatsoever, but BAe have chosen simply to ban visiting aircraft.

  6.5  Stretton, a disused airfield very close to the M6/M56 interchange appears to be ideally located for all types of GA, yet in a position to keep them clear of Manchester's airspace. It is apparently used at the moment for car trials. This should be investigated as a candidate to be re-opened.

  6.6  The complete absence of GA provision for Manchester should be compared to the provision around London (Farnborough, Blackbushe, White Waltham, Denham, Wycombe, Elstree, Stapleford, Rochester, Biggin Hill, Redhill, Fairoaks, Battersea) and Birmingham (Birmingham International, Wolverhampton, Coventry, Wellesbourne and Tatenhill).

  6.7  Any claim that Manchester makes to being the Second City is undermined by having poorer business aviation facilities than London and Birmingham, Glasgow and Edinburgh, Newcastle and Liverpool and even Bristol, Cardiff and Exeter!

  6.8  Government, together with the local authorities in the Greater Manchester areas, could enhance the image of Manchester as a forward looking area, and help reverse its current image of being rather focused on the past, by either helping a private operator open up one of the existing facilities or for the local authorities to do so themselves.

  All the points made in this paper have the common thread of affecting the ability and efficiency of businesses running business aircraft. The benefit to successful businesses of being able to move its executives around quickly and efficiently should be self-evident. (Members of the Committee only need to look at the use of aircraft by their own leaders, whether in Government or Opposition, to recognise the importance of being able to move people close to where they need to go, at the time they need to be there, efficiently and smoothly.) This paper has drawn the Committee's attention to a number of important points where it can make a real difference.

Timothy Nathan JP

18 December 2001


 
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