Response 77919524

Back to Response listing

About you

D. Are you answering as:

Please select one item
(Required)
Radio button: Unticked Resident affected by aviation
Radio button: Unticked Airline passenger
Radio button: Unticked Member of the General Aviation community
Radio button: Ticked Member of the commercial aviation industry
Radio button: Unticked Military
Radio button: Unticked Government and / or other regulators
Radio button: Unticked Representative or national organisation or institute
Radio button: Unticked Elected political representative

G. Do you consent to your response being published?

Please select one item
(Required)
Radio button: Unticked Yes, with personal identifying information (name, location, respondent category, organisation, additional information - please note your email address will NOT be published if you choose this option)
Radio button: Ticked Yes, anonymised
Radio button: Unticked No

General observations

1. Do you agree with the overall approach taken in the strategy, as described here?

Please select one item
Radio button: Unticked Yes
Radio button: Ticked Mostly
Radio button: Unticked No
Overall approach - comments
I do not believe that Government is best placed to set the policy objectives in that it is not sufficiently closely connected to all the relevant stakeholders, instead relying on advice from bodies like the CAA and consultancies such as York Aviation. As such there is the potential to miss the crucially important voices of the GA community and the population at large. The APPG on GA needs rot be included in the policy framework setting in a more formal capacity, as does AOPA.

Policy 'ends'

2. Has the CAA identified the right Government policies in this strategy?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked Mostly, but some Government policies are not relevant
Radio button: Unticked Mostly, but there are existing Government policies missing
Radio button: Ticked No
Right government policies - additional comments
The fundamental piece missing from policy is the integration of communities to utilise a commonly owned airspace. At the present time too much emphasis is placed on commercial traffic. Whilst it is acknowledged that UK airspace is cramped and the country is highly reliant on a sensible growth strategy for commercial aviation, more needs to be done to allow integration of charter and GA activity within that airspace. The secondary issue is that primacy is afforded to the military when setting up Restricted and Danger areas, but the volume of that airspace is disproportionate to the size of our military. More needs to be done to manage Danger area activation by specific requirement rather than by default. And more needs to be done to promulgate the status of airspace to all users.

‘Ways’ of modernising airspace

3. Do you agree with the 14 initiatives set out in the strategy?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked Mostly, but some initiatives are not relevant
Radio button: Ticked Mostly, but some other initiatives are missing
Radio button: Unticked No
Agree with 14 initiatives - additional comments
Previous comment refers.

Gaps identified in the strategy

4. Have we identified the right gaps? Are there any that we have not identified?

Gaps in the strategy?
The fundamental missing piece is that the interests of users under 5700kg are largely ignored or else overridden. There seems to be no formal acceptance that GA users (including flight schools and charter) are part of the same ecosystem as large commercial and that the stifling of one area has caused and is causing significant problems in staffing across all of the aviation sector (military and civil) in both aircrew and engineering / technical sectors. The link to education and STEM is now better recognised but the strategy around joining up these interests to build a common picture is still very limited. The Apprenticeship tax (levy) is also now operating against the best interests of the aerospace sector.

Approach to the ‘means’ of modernising airspace

5. Do you agree with our approach of asking those organisations tasked with delivering the initiatives to set out deployment plans to identify the means (resources) necessary?

Please select one item
Radio button: Ticked Yes
Radio button: Unticked No
Deployment plans - additional comments
Yes, but with a caveat. There are not enough stakeholders at the table. Indeed I am living proof of that fact.

Governance

6. The draft governance structure in this document was developed by the Department for Transport, CAA and NATS working together. Do you agree with the approach set out here?

Please select one item
Radio button: Unticked Yes
Radio button: Unticked Mostly
Radio button: Ticked No
Governance - additional information
The field is too narrow and too narrowly focussed. At the very least we need a "small aeroplanes directorate" equivalent in the UK, or preferably still a new regulator that sits between the LAA and CAA (dubbed by me the GAA), taking care of all interests above that of the LAA and below 5700Kg. The GAA would sit outside EASA but would seek reciprocity with EASA and the FAA. The GAA should be a member of the Governance structure.