As with our lives, this APPG has suffered from dreadful upheavals during the last couple of
years owing to the Covid-19 Pandemic.
Our aviation Sponsors have of course been suffering severe losses with aviation being so
badly affected and thus our income has suffered and has been severely depleted.
But whilst it may seem like we have been in a hiatus the last 2 years our working groups and
members have been doing all they can. The Airfield Working Group have been working in
conjunction with the GAAC and giving advice to many airfields under threat. The Airspace
team have been working on several Airspace Change Proposals. The Tax and Regulation
Working Group have been busy with the Treasury on various Tax issues and licensing
matters. The STEM team have been busy trying to set up a nation-wide network. So even
without money to offer them much needed support our Volunteers have been working hard
for you, our aviation community.
We intend to shortly start trying to get our Sponsors back to supplying us with much needed
support so we can get even more done but meanwhile here are some of the Working Group
Aims for the upcoming period.
Airfield Working Group:
Under the leadership of John Gilder:
CAA Airfield Advisory Team This has proved to be a bit of a failure in its ability to
understand what is required and therefore has not been adequately staffed. As an APPG we
understand that the Department for Transport had the best of intentions, but it has not
been a success. We continue in a dialog with them on this matter.
MHCLG – We continue to discuss ways to ensure the safety of airfields against being lost to
development. Many proposals have been made to them which we hope will be incorporated
into future legislation.
ANO – The situation regards the application of the ANO to both Licensed and Unlicensed
airfields need to be clarified and presented to the CAA for future reference. When we
challenged the CAA on Eshott Airfield, it replied that the refusal to act was based on advice
from their Legal Department so that is where we need to start. This is one area where the
Airfield Advisory Team seem to have a differing view to that of the CAA themselves.
GA Advocate – This was also well intended but, is a totally mismanaged attempt to follow up
on work done originally by Byron Davies. With the sad passing of Phil Dunnington, who was
the GA Advocate, it is important that his replacement is given the right focus.
We are advising on over 30 airfields on protection and planning matters, and I’ve produced
a brief report on our currently active workload for the GAAC Board this is set out below
Tax and Regulation Working Group:
Under the leadership of Charles Henry.
The issues being pursued include:
1. VAT on Professional Training being reduced and hopefully zero rated
2. Registration and funding of Apprenticeships needs to be improved
3. Tax and Duty on Fuels (SAF & TEL other)
4. LPA/CAA/AAT Regulation re Airfields
5. VAT on safety devices (Electronic Conspicuity, BVLOS components) should all be zero
rated.
6. Simplification of Theoretical Knowledge for PPL Flying Instructors (Revert to old BCPL
level)
7. Greening GA: preparation of simple system for Pilots to offset CO2 emissions by planting
trees
8. The regulation of DTO’s needs to be more sensible than current restrictions allow.
9. The UK licence requirements need to be overhauled and made easier for other ICAO
licences to be agreed under BASA (Bilateral Aviation Safety Agreements).
Airspace Working Group:
Under the leadership of Steve Noujaim and Pete Stratten:
Throughout the year worked on collaboration and facilitation to enhance the position of GA
with regard to airspace. Such work has included producing a joint principles document with
BALPA, GATCO, AFISO, GAA and HCAP.
Additional work as part of the Airspace Modernisation Strategy review working group and
with NATS, NERL, identifying positions where intent and policy is aligned. It has been a
beneficial exercise as GA has identified many areas where if truly aligned, some significant
benefits can be reaped with regards to airspace.
All participants expect the CAA to deliver and assist in this programme but, it seems that
they are often stifled by either a drive to align with ICAO, PANS OPS and or to align with now
outdated EASA regulation thereby missing opportunities to innovate and develop modern
airspace solutions or to capitalise on available and developing technologies. Examples
include driving and supporting a Detect and Avoid solutions for RPAS or the implementation
of simple and innovative GNSS solutions supported by EC without recourse to old and
outdated ATC solutions and regulations.
CAA require significant pressure to deliver a suitable containment policy that embraces 21st
century Nav Performance, this aligned to a more pragmatic and open EC policy alongside a
full and proper Airspace Classification review that delivers significant results will make a
difference to our operation.
APPG GA has some work to do on the following.
1. Ensuring that a wide-ranging EC policy that capitalises on all forms of EC to produce an air
picture is developed (rebroadcast) and used as part of the AMS programme.
2. To produce a containment policy that supports minimum airspace by acknowledging the
enhanced navigation capability that is provided by GPS. The policy should not be predicated
on PANS OPS 8168 obstacle clearance criteria.
3. Advocate a 3.5-degree GNSS solution (offset where necessary) at every GA airfield
(subject to obstacle clearance) Highlight Class G operations which presently allow long final
approaches VFR and do not require an Airspace Change Proposal. A delivery date for this
important infrastructure needs to be provided.
4. Minimal airspace advocated, but not delivered. IAP design and airspace volume should be
predicated on reduced track mileage as part of an environmental drive. Amazingly, Kemble
GNSS solution is almost 50 nautical miles from the missed approach point around the
procedure back to touchdown! A more sensible view needs to be taken by the CAA.
5. A use it or lose it airspace allocation system that is reviewed annually. Such a system
should be based on IFR departures and arrivals only. The Germans do this.
6. Pilot/Operator input and representation into any airspace sign-off at CAA triple A level.
We cannot invent an Air Traffic airspace nirvana for Air Traffic Controllers. ATC are there for
pilots.
7. Airspace that retrogrades to Class G uncontrolled airspace should not be part of the CAP
1616 process or indeed require compliance. Class G is the default airspace in the UK FIR.
(Cardiff CTA 8) is a proof that requiring an ACP to relinquish airspace just does not work.
8. Direct CAA as part of its Terms of Reference to support UK PLC (As with the FAA in the
USA) by considering the economic effect of its regulation and designing such regulation to
support the UK economy and its competitiveness versus other States.
STEM Working Group:
Under the leadership of Karen Spencer:
In November the group met and decided to review terms of reference and Update key
priorities
They also welcomed attendees from the General Aviation, Safety and Skills Team at the DfT
who gave an overview on their current thinking on Skills Strategy.
The group agreed that a key focus remained developing a talent pipeline for the industry,
particularly in the technical / vocational space. As part of this, the following work is being
undertaken with support from colleagues running the Talent Retention Platform and the
BBGA.
· Awareness raising of the needs for technical/vocational skills within DfT
· Establishment of a College Aviation Network with a view to establishing Centres of
Excellence in Aviation Skills Training
· Bringing together key partners to better connect young people with training and
employment opportunities through the Aviation Skills Retention Platform and associated
systems
So far 21 colleges have identified themselves as being active in the field on Aviation
Technical Training in England. There are cold spots in Birmingham and around Gatwick,
however we are establishing connections. The network will come together in February,
supported by input from the ASRP and the BBGA, to form early plans for establishing
Centres of Excellence with a view to (a) delivering improved training that meets need and
(b) helping inform and shape future policy.
In addition to the work establishing a network, there have been various visits to institutions
and round table discussions with the DfT and other bodies to raise awareness of issues and
possible solutions.
In conclusion:
It is evident, that we are still here and active. As things get back to normal, we intend to
become increasingly more active. The current Chairs are Kelly Tolhurst in the House of
Commons and Lord Davies of Gower (Byron) in the House of Lords.
You may be interested in seeing just this last month Lord Davies taking up the mantle in the
House of Lords on EGNOS and difficulties involving third country pilots’ licences and
residency – please follow the link:
https://hansard.parliament.uk/Lords/2022-01-25/debates/0FC987F1-271D-4512-A6D4-
03997FD0B657/TransportAct2000(AirTrafficServicesLicenceModificationAppeals)(Prescribed
Aerodromes)Regulations2022#contribution-E5F48E92-DA5A-40ED-935D-B6B1A777868E
In addition we had a meeting with the Aviation Minister on the 8th March where we
discussed difficulties within Aviation. These included, but were not limited to, Third Country
Licences and registered aircraft based in the UK. EGNOS and the safety implications, MOR
issues and Airshow safeguarding.
And Finally:
We wish you all safe flying and a healthy 2022. We will give you a further update at a future
date.