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Europa-List: Fwd: FW: Single Sky. All of GA to pay?

Subject: Europa-List: Fwd: FW: Single Sky. All of GA to pay?
From: Rowland Carson <rowil@clara.net>
Date: Thu, 26 Aug 2004 22:00:02

Folks - please note the following forwarded message:

>From: "Alan Burrows" <alan@kestrel-insurance.com>
>To: "'Europa Club Membership Secretary'" <europa-club@rowil.clara.net>
>Subject: FW: Single Sky. All of GA to pay?
>Date: Thu, 26 Aug 2004 09:52:33 +0100
>
>
>Hello Rowland
>
>I know you have mentioned this on the forum, but I would appreciate it
>if you could publish this in its entirety so that we can all respond. I
>don't know how to put documents on the forum so I hope you can do it for
>me. I heard one comment about should charity balloons also pay this
>ludicrous charge also..!
>Many Thanks
>
>Alan Burrows
>
>
>>  >
>>  > At a recent meeting the UK Department for Trade (DfT) revealed that
>>  > under The European Single Skies Policy to which the UK signed up
>>  > earlier this year, it has been decided that in future all aircraft,
>>  > regardless of whether they are IFR or VFR, and with no minimum
>>  > weight cut off, should be required to pay for use of 'services'
>>  > provided, such as air traffic control, NOTAMS and weather
>>  > information, search and rescue and so on, whether directly or
>>  > indirectly used. The main criterion for charging is that the
>>  > aircraft should land somewhere other than its take off point. No
>>  > exemptions are offered in the draft proposals even for gliders,
>>  > microlights or balloons. The proposals seem to have been drafted
>>  > without any thought of their impact on General Aviation (GA) and are
>
>>  > directed mostly at getting short haul airline flights to pay more
>>  > and long haul overflying flights to pay less.
>>  >
>>  > Costs are to be apportioned on a total, not marginal, cost basis so
>>  > that VFR aircraft will, for example, bear the cost of a VOR if it
>>  > provides a service in uncontrolled airspace. This will be regardless
>
>>  > of whether the aircraft actually uses the VOR.
>>  >
>>  > Nothing in the draft proposals suggests that even a light aircraft
>>  > flying non radio, from one private strip in uncontrolled airspace to
>
>>  > another will escape being charged. The proposals apply to all civil
>>  > air traffic and General Aviation (GA) is not mentioned. It will,
>>  > apparently, be up to the governments of individual states to decide
>>  > how the payments are levied. Details may be found at
>>  > http://www.eurocontrol.int/enprm/
>>  >
>>  > DfT is said to be sympathetic to the plight of GA and wants to
>>  > exclude us as per the current airways charges exemptions but the
>>  > regulations do not permit that unless the Government pays the costs
>>  > thereof to the Air Navigation Service Providers - and it won't.
>>  >
>>  > Eurocontrol has been charged with undertaking a consultation on how
>>  > the charges are to be made and has given European aviation until 17
>>  > September to make representations. Not only has Eurocontrol imposed
>>  > this outrageously short deadline, but it has also declined to
>>  > recognise any representation unless it is made on its official form,
>
>>  > a copy of which is attached.  > I don't think that I need spell out
>>  > what this proposal could do to European GA and I hope that you will
>>  > feel moved to do what you can to argue for the retention of the
>>  > current exemption for all VFR aircraft and for IFR aircraft below
>>  > the minimum weight for incurring Eurocontrol En Route charges. If
>>  > you are willing to join in, I ask that you now undertake two
>>  > tasks:
>>  >
>>  > 1.  Complete and return the attached form to Eurocontrol by e mail,
>>  > post or fax, as shown on the form. You may like to consult whatever
>>  > aviation body you belong to as to the detail of your objections and
>>  > they may have already formulated some points that they are making in
>
>>  > their own representations. I have set out on an attached sheet three
>
>>  > fundamental points that I regard as being central to the issue. The
>>  > list, however, is neither exhaustive nor authoritative: it should
>>  > not be copied out word for word or it is likely to be dismissed as a
>
>>  > mere duplicate. Set out your objections, remembering all the time,
>>  > that it is more important to get some sort of objection properly
>>  > registered than to spend days polishing up your irrefutable
>>  > arguments and then failing to get the form back in time. If you can
>>  > also find the time to copy your objections to your MEPs and MP, so
>>  > much the better.
>>  >
>>  > 2.  Contact as many GA colleagues as possible, by e mail, or
>>  > however. Send them a copy of the form and ask them to object and to
>>  > distribute the form and a similar request to all of their contacts.
>>  > An avalanche of objections from all over Europe would give
>>  > Eurocontrol a lot to think about.
>>  >
>>  > Please remember that time is desperately short and immediate action
>>  > is needed.
>>  >
>>  > Thanks
>>  >
>>  > Nigel Everett
>>  >
>>
>
>Attachment converted: PowerBook HD:Sgle sky response form.doc 
>(WDBN/MSWD) (00112B09)
>

The text of the above-cited attachment (ie Nigel Everett's response) is:

>SOME COMMENTS, REASONS AND PROPOSALS REGARDING EUROCONTROL'S DRAFT 
>IMPLEMENTING RULES ON A COMMON CHARGING SCHEME FOR NAVIGATION 
>SERVICES.
>
>
>The Recitals (Numbered 1 to 14), first comment 
>
>COMMENT
>Nowhere is General Aviation (GA) even mentioned in the recitals.
>
>REASONS
>GA represents some six times as many registered aircraft in Europe 
>as does Civil Air Traffic (CAT) and yet its very existence is 
>apparently to be ignored in the reasoning behind these deliberations.
>
>PROPOSED CHANGE
>Add Recital No 15 as follows:
>
>(15) General Aviation (GA) provides a vital economic and leisure 
>contribution to European life, facilitating transport of individual 
>business people, training of future airline pilots, small air taxi 
>services, medical evacuation, surveillance operations, sporting 
>opportunities and a host of similar advantages. GA mostly uses 
>Avgas, rather than Jet fuel and as such it already makes a 
>substantial contribution in the taxes payable upon Avgas that Civil 
>Air Transport (CAT) mostly does not. GA's importance and its special 
>tax contribution are acknowledged and Charges shall not be imposed 
>upon GA that present more of a burden than it already carries.
>
>
>The Recitals (Numbered 1 to 14), second comment
>
>COMMENT
>No mention is made of the exemptions from Eurocontrol charges 
>currently enjoyed by GA, namely the exemption of VFR flights and the 
>exemption of all aircraft of less than 2 tonnes MTOW.
>
>REASONS
>There are very good reasons for the perpetuation of these exemptions:
>
>1. The GA industry would be unable to bear the cost of the proposed 
>charges and would therefore decline, to the substantial disadvantage 
>of European economy and social life and the loss of human rights.
>
>2. Either a blanket per aircraft or per aviator charge would have to 
>be imposed for reasons of bureaucratic simplicity or a charging 
>system based upon distance and weight for each journey flown would 
>prove to be more expensive to calculate and to collect than the 
>revenue that it produced. The former option is manifestly unfair and 
>thus a breach of human rights and the latter is absurd. 
>
>PROPOSED CHANGE
>  Add Recital No 16, as follows:
>
>(16) It is acknowledged that exemptions for VFR flights and for all 
>flights of aircraft of less than 2 tonnes MTOW have hitherto been 
>granted from Eurocontrol's charges for good and practical reasons. 
>These exemptions shall continue.
>
>Article 3
>
>COMMENT
>
>No exemption is shown for VFR flights and for light aircraft.
>
>REASONS
>
>The existing exemptions within the current Eurocontrol charging 
>system should continue.
>
>PROPOSAL
>
>Add clause no 11, as follows:
>
>11. All VFR flights and flights by aircraft of less than 2 tonnes 
>MTOW are to continue to be exempt from all Charges.

My reading of the comments form is that it must be submitted by 
organisations. So, I guess it's more likely to be read and taken 
seriously if you submit it as a representative for (eg) your local 
flying club, your own business (if aviation-related), etc, etc.

You can find other useful responses on the pfa website 
<http://www.pfa.org.uk> - there is a link on the opening page to 
Graham Newby's responses to 2 of the items.

Also note that if you can't work out how to download the document I 
put up on Steve & Jos's EuropaForum bulletin board, it's available 
---From the horse's mouth at <http://www.eurocontrol.int/enprm>.

regards

Rowland
-- 

| Rowland Carson   Europa Club Membership Secretary - email for info!
| Europa 435 G-ROWI (710 hours building)  PFA #16532
| e-mail <memsec@europaclub.org.uk> website <www.europaclub.org.uk>




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