2013 – year of threats and opportunities

2013 will be a make-or-break year for general aviation in Europe, with the industry's future prosperity likely to be ordained by decisions made in the next 12 months. IAOPA Senior Vice President Martin Robinson has set out the issues that need to be tackled during a year of upheaval in which the European Aviation Safety Agency will see a change of leadership, and hopefully of attitude to a general aviation industry that is battling an unprecedented recession while struggling to cope with costly, unnecessary and badly-written new regulations.
Patrick Goudou retires in July after ten years as Director General of EASA, a period which has been characterised by inflexible bureaucratic diktat, deafness to industry and GA market contraction. His departure coincides with the EASA's Management Board's deadline for EASA to produce a set of internal guidelines designed to restore some common sense to rulemaking – something that should have been done before the first rule was written a decade ago. Will change at the top make a difference? Under Goudou, EASA has shrugged off every criticism, whether from the European Commission, the Parliament, the aviation industry or its own Management Board, and has justified every new imposition by referring to the Basic Regulation, the EC's framework document which it takes as its bible. For that reason, Martin says, amendment of the Basic Regulation is vital if any of our goals are to be achieved – and the only chance we have for amendment falls early in 2013.
New opportunities are opening up, too – the European Parliament has gained more powers over the Commission, and IAOPA will be putting ever more effort into lobbying the Parliament in 2013. MEPs are keen to understand why Europe, with a larger population than America, has a general aviation industry that is a fraction of the size of America's, turns over €30 billion compared with America's $103 billion and employs one quarter as many people. They can see that comparative regulation is the root of the problem, and that change has got to come.

Martin Robinson writes:

As we look forward to 2013, the only thing I can say with any certainty is that there will be more change for GA to deal with. General aviation begins and ends with the student pilot – everything follows on from there. If GA is to have a sustainable future in Europe, we must have more students learning to fly. For every ten new pilots a certain number, perhaps four or five, will buy an aircraft. Others will join groups, and the remainder will rent. Their activity supports an entire industry. Each time you fly, think about what proportion of your hourly cost goes to support the CAMO/maintainer, the avionics engineer, the insurance company, the fuel supplier, the hangar, the airfield, and all those people who provide the support activities to make GA possible. The European Commission has to understand that if we are to have a sustainable future, there must be proportionate safety rules that are affordable. With fewer people learning to fly, costs have risen to an extent where GA it is out of reach for an ever greater number of people.
The EASA rulemaking programme has created a level of uncertainty that has had a negative impact on that part of GA which is most affected by EASA regulation. Coming at a time of recession across the world, it has had a particular impact on those GA businesses that rely on the student pilot market. I am not laying all the blame at EASA's doorstep, but it, along with the Commission and European states, must shoulder a measure of the responsibly for the poor health of our industry.
Since EASA began life over ten years ago (and while I was invited to the birth, I wasn't invited to the 10th birthday party!) IAOPA has consistently supported the development of risk-based European aviation regulation. As far as IAOPA is concerned, EASA has never produced the goods; we continue to push for it. The first order of business should be that EASA understand the risks it intends to regulate. It can only do that if it has good quality safety data on which to base risk assessments. The risk assessment then needs to be costed against the proposed fix, in order to insure proportionality in the rules and to avoid forcing the regulated to incur huge costs in guarding against a low level of risk.
IAOPA has repeatedly called for regulators to conduct segmented cost-benefit studies when proposing new rules. EASA, by its own admission, has very little GA data to go on. It follows logically that any Regulatory Impact Assessment (RIA) the Agency produces is fundamentally flawed. There is no quality control or checking of RIAs – therefore the entire system of rulemaking in my opinion is broken. How can EASA or the Commission ever measure the performance of the rules, and whether or not they achieved what they set out to achieve?
But does anyone care? I think not. Does anyone check whether the regulations meet Europe's own 'smarter regulations' standards? Or the UK's  'cut the red tape challenge'? How can it, when on FCL alone, pilot licenses have gone from 4 sides of paper to 17 pages. The cost of this increase in bureaucracy is not considered by EASA in its RIAs, and yet most businesses at this time cannot pass on increased charges to their customers, and have to absorb them at a time of already extreme stringency.
IAOPA Europe calls upon each European member state to take responsibility for ensuring the right conditions for making GA viable. We request that each member state produces a RIA in response to EASA's consultations. This should be seen as assisting the Agency in its rulemaking tasks.
IAOPA Europe also asks its affiliates in each state to work with its own authorities to achieve this request. IAOPA Europe stresses the need for a proper safety partnership between the regulator and regulated – and that means the member states, the Commission, EASA and industry all have a role in delivering safety.
Other associations choose to work with the regulators in the belief that tweaking or rewording regulations can lessen the impact. However, IAOPA Europe believes that a poor rule will always be a poor rule, no matter how much you tweak it.
A great deal is resting on the outcome of the work done last year to change the way EASA works, but it would be wrong to think that EASA will experience a Road to Damascus conversion and IAOPA is not banking on such an outcome. IAOPA will be increasing its political activities in Brussels with a view to getting an early amendment to the Basic Regulation, which is necessary if we are to achieve all the other goals that we have set. If we do not do something in early 2013 we are unlikely to get another opportunity to amend the Basic Regulation before 2015, and any change would not come into effect until 2017 or 18, and who knows what state general aviation will be in then. The 2013 deadline comes about because from 2014 there will be a new Transport Commissioner and a new Parliament and we will effectively be starting our campaigns all over again.
When we ask you to engage with your MEPs and Parliamentarians, please do so. I believe in people power, but complacency is our biggest enemy – so please actively support your local AOPA and help to recruit more members to the fold. We must continue to push for change at all levels, and although the Commission paper on a Sustainable Future for General and Business Aviation was supported by MEPs through 36 resolutions, what we need now is a proper policy for the development and growth of GA in Europe – a policy that can help deliver that sustainable future.
Lets make sure that 2013 is the year that sees the beginning of a prosperous future for GA in Europe and across the world. A very happy New Year to all our members in Europe and in 69 countries around the world.

Focus on Brussels in 2013

IAOPA’s Brussels lobbyist Lutz Dommel is planning an active year, focusing both on individual issues and general support for GA. One of the most pressing issues at stake in the legislative process between the European Commission and the Parliament is the new rules for non-commercial complex aircraft – that is, aircraft with more than one turboprop engine or at least one turbo-jet engine – which is being discussed intensively and in which IAOPA has taken the lead. Lutz says: “The current draft of EASA and Commission foresees the introduction of performance requirements similar to or beyond those for commercial air transport. This would affect around 900 of the 1400 airfields in Europe, for which the runway lengths would not be sufficient any more and non-commercial operations with aircraft like the King Air would have come to an end. This represents a severe threat for Europe’s GA infrastructure as those operations provide for a substantial part of the income of many airfields across Europe. Members of European Parliament who have been informed about the forthcoming regulation now understand the effect of such over-regulation, going beyond ICAO requirements, and plan to examine and reject the proposal of EASA and Commission if necessary.”

Administration changes at AOPA Greece

Youli Kalafati, long-standing president AOPA Greece, has resigned from her post. She has been appointed a Director of the Civil Aviation Authority and has decided it is not wise to hold both posts at the same time. Mr. Anton Koutsoudakis is now the new President.
IAOPA Senior Vice President Martin Robinson paid tribute to the work Yiouli has done on behalf of GA in Greece and across Europe. "Progress on fostering general aviation in Greece has been greater than anywhere else in the world," he said, "and the credit is due to Yiouli and her team at AOPA Greece. We wish her well in new position, in which she is responsible for all Greek airports. Having someone in such a position who understands general aviation can only be a positive factor for all of us. Yiouli will remain a member of AOPA Greece and we will continue to value her advice."

Meet your controller

Air Traffic Services of Greece, supported by AOPA, organised a 'Meet your Controller' initiative on December 13th, Anton Koutsoudakis reports. AOPA members and other holders of pilot licenses were invited to attend guided tours in the premises of Athens ACC and Athens Approach centre. At the same time, representatives of flight training organisations, flying clubs and of course the Board of AOPA had a meeting with high-ranking ATC officials to discuss local air traffic problems.

AOPA-NL fights Eindhoven infringements

AOPA-Netherlands is participating in an infringement-reduction exercise in the Eindhoven area, near the Belgian border, and is asking European pilots to increase their awareness of controlled airspace around the airport because about half of all infringements are by foreign-registered aircraft.
Eindhoven Airport (EHEH) is used by airlines and state aircraft, but only local general aviation aircraft have access to the airport. Eindhoven has a Class C CTR up to 1500 feet and a Class D SRZ from 1500 feet to FL 65.This SRZ will be converted to a TMA in 2013. The SRZ is not on the actual VFR charts.
In the infringements reduction programme in which AOPA-Netherlands is participating, AOPA analyses the ‘hot spots’ and tries to reshape the outline of controlled airspace for more convenient navigation, while keeping as much open airspace as possible. AOPA is also educating pilots as to where the hot spots are, and since about 50% of infringements are by aircraft from other than Dutch registration, it has asked IAOPA Europe to make known the whereabouts of the Eindhoven hotspots.
A PDF of the relevant charts can be downloaded from the AOPA Netherlands website. Click here then click on: Artikel hotspot Eindhoven – WG AI – v1 0. The PDF also carries a chart of the design of the new Eindhoven TMA, which becomes effective in April 2013 and will be depicted on the VFR Chart for 2013.

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