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!
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