News
CAA NATMAC Informative Letter – 23 August 2010
VHF Aeronautical Communications Frequency and Transponder Code Requirements – London 2012
Aeronautical VHF communication frequencies and transponder codes are a very limited resource, and the greater demand for these resources as a result of the expected increase in air traffic during the London Olympics in 2012 will require extensive planning.
In order to allow time for the assessment and provision of VHF aeronautical communications frequencies and transponder code requirements for the London 2012 Olympics, any organisation intending to amend existing, or establish additional, services are required to inform the Directorate of Airspace Policy of provisional requirements no later than 31 December 2010 by completing the form(s) online at www.caa.co.uk/2012CodeRequests.
17th BBGA Farnborough Week Reception
21 July 2010, The Palace of Westminster
Once again this popular event, kindly hosted by Gerald Howarth MP, was well attended by close to 200 people. Guests were treated to a pleasurable evening within this most prestigious location steeped in over 150 years of parliamentary history, which afforded the opportunity to meet Members in both Houses of Parliament, government officials, business colleagues and friends.
Special thanks to our sponsors, Cessna Aircraft Co (UK), Martyn Fiddler Associates, ARINC Direct and Hawker Beechcraft.
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BBGA Golf Day – Friday 30 July 2010
The Annual BBGA Golf Day was held again at The Berkshire Golf Club for the Bombardier Trophy played for in the morning on the Red Course and the Universal and Weather Greensomes Trophy in the afternoon on the Blue Course.
Bombardier Trophy
First – Greg Bruh, Astrojet with 46 points.
Second – Paul Stephenson, Bombardier with 39
points.
The nearest the pin on the 4th hole was Andrew Woolfson and on the 13th Hole it was Robin Williams.
Universal & Weather Greensomes Trophy, Stableford Scoring
First – Dave Hewson of Bombardier and Alexis Grabar of Avolus
Second – Wally Epton of WJE Associates and Paul Stephenson of
Bombardier
Third – Robin Williams of Universal and Steve Wells of Twinjet
The longest drive on the 15th hole was Craig Scolding and nearest the pin on the 2nd hole was Greg Bruh.
BBGA is grateful to the sponsors Bombardier, and Flight Safety. Universal and Weather are thanked for providing the prizes for the afternoon’s competition as are Bombardier who provided them for the morning.
There was unanimous approval for continuing the Golf Day next year at the same location.
Finally thanks are due to all those who took part in the BBGA Annual Golf Day and helped to make it a success; without them there would be no Golf Day.
John B Robinson
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| Bomdardier Winner – Greg Bruh of Astrojet | Bombardier Second place – Paul Stephenson |
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| Greensomes Trophy Winners – Dave Hewson, Bombardier and Alexis Grabar, Avolus | Greensomes Trophy Second place– Wally Epton, WJE and Paul Stephenson, Bombardier |
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| Greensomes Trophy Third place – Robin Williams, Universal and Steve Wells, Twinjet |
The FAA’s Final Rule: re-registration and renewal of aircraft registration
Please take note that the FAA has issued its Final Rule regarding the Re-Registration and Renewal of Aircraft Registration. The Final Rule will be effective on October 1, 2010. All U.S. registered aircraft will need to be re-registered. Failure to comply with the rule will result in the cancellation of the United States registration of the aircraft. Please click on link below for the full notice regarding the announcement.
BBGA Member – Air Service Training – to run Part 66 Category B Module 16 Piston Engine Course
BBGA Member company Air Service Training have confirmed that they will be running a Part 66 Category B Module 16 Piston Engines course in November. This modular course has a duration of 2 weeks and will commence on 15th November, at our main site in Perth, Scotland.
AST are offering all BBGA Members a discount.
Tuition fees with BBGA discount will be £544 + vat.
The fee covers the technical training notes, 32 hours per week instruction and the approved examination on the last day. Those meeting or exceeding the 75% pass mark, will be awarded a Certificate of Recognition of Approved Examination, acceptable to all EASA full member authorities.
To find out more information about course or to book your place please contact: Diane Duncan, telephone: +44 (0)1738 877105.
Or go to www.airservicetraining.co.uk
Technical Director/Chief Operating Officer position
At a recent BBGA Council Meeting it was decided to restructure the Chief Executive Role at BBGA.
It has now been decided to take on a full time ‘Technical Director/Chief Operating Officer’ with adequate specialist industry experience and knowledge. This position will require the ability to take forward ‘briefs’ from BBGA’s committees and members, supported by other industry specialists as appropriate, to participate in the various external committees and with official bodies such as EASA, CAA, DTI, DfT, Revenue & Customs, EEC etc.
Guy Lachlan will now remain Chief Executive on a part-time basis specifically to cover responsibilities of developing the image and position of BBGA within the aviation industry and critically the outside commercial and public worlds. This activity is expected to advance the position of BBGA both ‘Politically’ and also commercially by way of increased participation in industry concerns.
The position of Chief Technical Officer/Chief Operating Officer will be advertised shortly together with a job description. However, in the meantime, if you know anyone who might be interested in such a role we would welcome their CV.
To Air Navigation Services Stakeholders
The European Commission is holding a public workshop on the approach and processes for setting Single European Sky EU-wide performance targets. This workshop will be held on Thursday 27th May 2010 in Brussels (Europa Room, Eurocontrol), 96 rue de la Fusée). The meeting will commence at 10.00 am and end at the latest at 4.00pm.
The Commission’s intent in holding this workshop is to launch the process for ensuring that the EU-wide targets required by the Single European Sky performance scheme are established in a transport manner and with the involvement of all interested parties and in time for adoption by the Commission by December 2010.
In this context, the Commission will be supported by the Performance Review Commission until such a time as a Performance Review Body is formally designated by EASA.
A copy of the Agenda can be obtained from Mrs Chiappara from European Commission at giusi.chiappara@ec.europa.eu
In order to comply with security procedures, participants must register by email to Mrs Chiappara (giusi.chiappara@ec.europa.eu) by 20th May 2010.
Notification of additional night-time fuel saving routes (NFSR)
IMPORTANT – FLIGHT SAFETY NOTICE
Use of Decision Altitude (Height) in Continuous Descent Final Approaches
Synopsis
EUROCONTROL has been advised of concerns about the use of Decision Altitude/Height (DA(H)) instead of Minimum Descent Altitude (MDA(H)) as the aerodrome operating minima (AOM) on some non-precision approach charts produced by Jeppesen for countries applying “EU Ops”. This has become a source of confusion and has implications for aircraft operators.
Analysis
Commission Regulation EC 859/2008 dated 20 August 2008, EU Ops 1.430(d) 2 (applicable from 16 July 2011) states that “all non-precision approaches shall be flown using the continuous descent final approaches (CDFA) technique”.
EU Ops, 1.435.9 defines CDFA as, “A specific technique for flying the final-approach segment of a non-precision instrument approach procedure as a continuous descent, without level-off from an altitude/height at or above the Final Approach Fix altitude/height to a point approximately 15m (50ft) above the landing runway threshold or the point where the flare manoeuvre should begin for the type of aircraft shown”. Moreover, Appendix 1 (New) to OPS 1.430, states that, “the missed approach, after an approach has been flown using the CDFA technique, shall be executed when reaching the decision altitude (height…”.
Note: Additional CDFA guidance material is currently under preparation.
Jeppesen only publish DA(H) on CDFA-based, non-precision approaches where the equivalent national AIP minima is shown as an OCA(H). Where national AIP minima is shown as a MDA(H) or for non-CDFA-based, non-precision approaches, Jeppesen continues to publish MDA(H).
ICAO PANS OPS definitions:
- Minimum Descent Altitude/Height (MDA(H)): “a specified altitude or height in a non-precision approach or circling approach below which descent must not be made without the required visual reference”
- Decision Altitude/Height (DA(H)): “a specified altitude/height in a precision approach or approach with vertical guidance at which a missed approach must be initiated if the required visual reference to continue the approach has not been established”
- Obstacle Clearance Altitude/Height (OCA(H)): “The lowest altitude or the lowest height above the elevation of the relevant runway threshold or the aerodrome elevation as applicable, used in establishing compliance with appropriate obstacle clearance criteria”
The DA(H) value shown on the Jeppesen charts is at least equal to the published national AIP (OCA(H)) minima for a non-precision approach. Importantly, however, the DA(H) published on the Jeppesen charts does not include any add-on to account for any height loss during the initiation of a missed approach. This is not mentioned directly on the charts, but it is described in the Jeppesen Briefing Bulletin JEP 08-D and in the legend pages to the Jeppesen Airway Manual.
EU Ops 1.430 (a)1 states that, “an operator shall establish, for each aerodrome planned to be used, aerodrome operating minima…”
Your Attention is Required
Aircraft operators are invited to:
- Note the issue above specifically with a review of the need to consider the requirement for an add-on factor to account for height loss at missed approach initiation
- Share their operational experiences
It is critical to flight safety that pilots brief the DA(H) or MDA(H) (as appropriate) so that there is no ambiguity as to what minimums are being used irrespective of the type of approach being flown.
Rockwell Collins EASA Approved Part 147 Training
Rockwell Collins UK currently have a range of EASA part 147 approved “B2” and “B1 to B2” conversion courses scheduled.
Current course availability is detailed below for your information. Courses can be delivered at your own facility on request.
You may register for this class by contacting Philip Jellyman at +44 (0)118 935 9073 or pjellyma@rockwellcollins.com
Specific location details and a course syllabus will be provided upon registration.
NATA Releases Video Briefing: “Hypocrisy”
The National Air Transportation Association (NATA) has issued the third release in the "Coyne‘s Video Briefings" series titled “Hypocrisy.” In this video, NATA President James K. Coyne asserts that the best way to get the economy moving is to get America moving. As President Obama prepares to deliver his first State of the Union address, Coyne points out that in his first year as president, Obama has used general aviation more than any other president in history. He goes on to thank President Obama for setting such a good example, and proving that general aviation is, indeed, a vital part of America's economy. A new video will be released every few weeks and will focus on “hot topics” and important current events affecting the association‘s membership and the general aviation industry at-large.
“These video briefings allow me to speak directly to our members on current political and financial issues affecting their companies,” Coyne stated. “I will also be able to provide some candid perspective as to how these issues impact the bottom line of aviation businesses and what actions our members can take to ensure that their companies are protected from new taxes and unnecessary regulations.”
BBGA and Signature Immigration Demonstration
The initial demo at Signature was organised by BBGA, and was designed to show UKBA personnel that physical face-to-face interviews upon immigration might not be necessary for all cases, especially those assessed as low risk.
MedLink Haiti earthquake relief effort
MedAire’s 24/7 MedLink Global Response Center is reaching out with an offer of support for those flying to Haiti and the surrounding region for earthquake relief efforts.
For a limited time, MedAire will provide:
- Free MedLink dedicated hotline for telephone medical advisory services, day or night, in flight or on the ground. Our global medical provider network and hospital databases are current and our staff is prepared for round-the-clock support. Additionally, our medical professionals can assess your passengers or crew for their medical fitness to travel by air.
- Free medical situation summary reports for Haiti to help you assess your medical risk and prepare for travel to the region. These alerts will be e-mailed as events unfold.
To activate these services – now available through Feb. 20, 2010 – click here.
MedAire is the aviation industry leader in providing emergency medical kits and equipment throughout the world. For the last three years, the company’s manufacturing division has been supporting a local organization in Haiti by donating outdated but usable medical supplies each month. To date, MedAire has supplied more than 18 tons of medical supplies and will continue these efforts with this organization throughout the recovery.
For more information, visit www.MedAire.com or call +1-480-333-3700.
FLIGHT SAFETY Notice – HindSight10
SKYbrary have issued the 10th Edition of HindSight that can be found on the website – skybrary.aero and covers the following subjects that are well worth a read:
Level busts – cause and consequence
Maritime kite flying
TCAS 11 and level bust
Mode S helping to reduce the risk
Misuse of lasers – illumination of aircraft and ATC towers
Traffic decrease appears to reduce, no recovery in sight
Eurocontrol traffic figures for October show a small decrease of traffic compared to September, in line with the traditional winter season pattern which has started this year a little bit later than normal.
As expected the traffic gap between 2008 and 2009 continues to decrease, as we overlap with the period 12 months ago in which the downturn had taken hold. Although we expect November to be the first month during which we will show ‘growth’ compared to 2008 traffic, real signs of recovery, as opposed to a stabilisation of decline, continue to be too erratic to indicate a definite upturn in the coming months.
The attached figures show the year to date growth UK average daily flights at -19.8%, compared with the EU average of -16.6%.
Luton is still disproportionately badly affected by the downturn with -26.9% average daily departures, year to date. Our belief is that at least some of this decrease is due to immigration procedures at Luton, causing migration to other UK and EU airports.
Safety Management Systems Workshop
BBGA held a Safety Management Systems Workshop for Business and General Aviation at FlightSafety International’s premises at Farnborough in October 09.
The IBAC workshop, which is specifically aimed at the needs and resources of SME’s, is of particular significance to Flight Operations Managers, Safety and Security Managers, Chief Pilots, Managing Directors, Finance Managers, CFOs and Accountable Managers. It was very well received by those that attended (see photo).
Consisting of a two-part course based on the IBAC methodology and toolkit, the first two days comprised an introduction to the SMS concepts and principles and the third day was dedicated to the application of the IBAC SMS toolkit.
Special thanks go to Joel Hencks of AeroEx.eu who was the facilitator of the Workshop, FlightSafety International, Farnborough for hosting the meeting and MedAire Limited who kindly sponsored a lunch during the workshop.
We are planning to run a further Workshop in the UK from 2nd–4th June 2010 inclusive. Please contact the BBGA office for further information: e-mail: Anne Seckington or telephone +44(0)1844 237020
To the Aviation Community
This information is relevant to aircraft operators subject to UK Regulation under the EU ETS.
As you know, the EU Directive to include aviation within the EU Emissions Trading Scheme (EU ETS) came into force in February. All flights departing from and arriving at EU airports will be included in the EU ETS from 2012, and aircraft operators will be required to monitor emissions from 1 January next year.
The UK is responsible for regulating 891 aircraft operators under EU ETS. Aircraft operators subject to regulation by the UK must submit an application for an emissions plan as soon as possible, and by the deadline given in the legislation of 12 November 2009.
The UK Government is very keen to draw the attention of operators regulated by the UK to the important deadlines on the horizon and ensure they are aware how to comply. To that end the UK’s DGCA has written an open letter to the industry, a copy of which is attached to this email. I am also attaching a short ‘key facts’ guide to aviation EU ETS which gives useful background information on the system.
The letter is also being published on the Department for Transport’s website www.dft.gov.uk/pgr/aviation/environmentalissues
Matthew Griffin
UK Department for Transport
matthew.griffin@dft.gsi.gov.uk
UK Emissions Trading Scheme
By now, all operators on the UK Emissions Trading Scheme list produced by the European Commission should have received a communication from the Environment Agency (EA) containing details of how to log into the Aviation ETS registration website. Accessing the website will enable operators to complete and register their Emissions Plan (compulsory, £750) and Benchmark plan (optional, £830). If you are on the operator list but have not received an email, please contact etaviationhelp@environment-agency.gov.uk as soon as possible, with a copy to BBGA.
The deadline for completion of these tasks is 12th November 2009.
FAQ’s
- I am not on the list and I believe I should be – what do I do?
You should not be on the operator list if
- you are public transport and the aircraft operated by the AOC holder (whether public or private category) emit a total of less than 10,000 tonnes of CO2 per year (equivalent to about 4 million litres of Jet A1)
- you are private category but only operate aircraft of less than 5,700 kg MTOW
If neither of the above apply to you and you are not on the list, you will likely not be included in the scheme initially. To ensure you do not receive a penalty for non-registration, contact etaviationhelp@environment-agency.gov.uk explaining why you think you should be on the list, with a copy to BBGA, and ask the EA to confirm that you are not on the UK list. Remember to check the lists for all other European countries you fly to, in case your operator name is there. If it is, you will need to make contact with that foreign country’s ETS regulator. BBGA can help you do that.
- I am on the operator list and I shouldn’t be – what do I do?
Contact etaviationhelp@environment-agency.gov.uk explaining why you think you should not be on the list, with a copy to BBGA, and ask the EA to confirm their agreement with your assertion, or state what further proof of they require to reinforce your claim.
- Should I register a Benchmark plan if I am a small operator?
The Benchmark plan is used to calculate your entitlement to free allowances, and is optional. It is only needed if you intend to apply for a free allowance of carbon permits. Because of the way the system is designed, Corporate-type aircraft will only ever receive a small percentage of free allowances – say between 5% and 15% - so the costs of being compliant may outwieigh the benefits of the free allowance. As a rule of thumb, BBGA suggests that if your fleet’s annual fuel consumption going forward is expected to be less than 500 tonnes (say 1,000,000lb / 625,000 litres) per year, it probably is not worthwhile to register a benchmark plan. If your fuel consumed per year is 3,000 tonnes, you could qualify for free allowances worth between £12,000 and £35,000 per year depending on now full you fly your aircraft and how far you fly, so it probably is worth applying. Contact the BBGA office if you need advise on this topic.
- What if I don’t have an approved emissions plan by 12th November?
If you have not submitted an emissions plan by 12th November, the EA is likely to try to fine you. They are approving plans on a first-come, first-served basis, so our advise is to submit it well before the deadline so there is no argument about not being approved before the deadline. If you are having difficulty completing the plan, contact BBGA for help.
- Has PAGODA been approved yet for small emitters?
No, PAGODA (the EuroControl system for estimating fuel consumption for all flights covered by the scheme) has not yet been officially approved by the European Commission. When completing the EA webform, our advice is to state that leg distances will be drawn from PAGODA data, and tick the box which says this is a method approved by the Commission. The EA assure us that they will accept forms completed in this way.
- For the Benchmarking plan, I have heard that I can assume that the aircraft always flies with a full passenger load, because as a charter operator I have no control over how many passengers are on board – is this true?
No, the UK will not accept this. They will need data on real payloads for every flight made under the scheme.
If your question is not addressed by the above list, please contact BBGA for further help. We will do our best to ensure that all members are fully compliant with the 12th November deadline.
BAA announces Heathrow's 2010/11 Airport Charges Consultation is Finalised
The timetable for Heathrow’s 2010/11 airport charges consultation has been finalised and the critical dates are set out below:
| BAA circulate consultation documents | 30 Oct. 2009 |
| Consultation ACC meeting | 18 Nov. 2009 |
| Airline written responses | 02 Dec. 2009 |
| 2010/11 prices announced | 23 Dec. 2009 |
| Prices application form | 01 Apr. 2010 |
Details of the venue and agenda of the meeting will be announced in due course.
Operating “5th and 7th Freedom Flights” from the UK
What are 5/7th Freedom Flights?
The ‘freedoms of the air’ were defined in the International Air Transport Agreement in 1944. The first four freedoms describe the circumstances under which operators might enter airspace, land, and carry passengers and cargo from their home country to another and back.
The fifth and seventh freedoms have occasionally caused confusion and require permits to operate out of the UK. The ‘fifth freedom’ provides for an aircraft of one country to transport passengers or cargo between a second and third country on a flight originating in, or ultimately destined for, the first country.
The ‘seventh freedom’ is an unofficial variation on the fifth freedom (also known as the ‘free standing’ fifth freedom) and defines the rights of an operator to fly between two foreign countries without any connection to the operator’s home country.
Do I need a permit?
In the case of the UK, all fifth and seventh freedom flights require a permit from the UK DfT for commercial flights operated by non-UK registered aircraft. For non EU operators, any flight where passengers/cargo are to be transported for reward from the UK to a country other than the operator’s own (i.e. a ‘third country’) will require a permit.
For non-UK EU operators, a flight that carries passengers/cargo from the UK to any country other than the operator’s home country or the European Common Aviation Area (ECAA), Switzerland and Morocco will require a permit.
Permits are required for:
Non-EU operators |
EU operators |
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| If operating for hire or reward to any third country from the UK. | If operating for hire or reward to any third country other than the ECAA, Switzerland and Morocco from the UK. |
Requests for permits are considered by the DfT, which consults the BBGA in the case of proposed unscheduled commercial movements of aircraft not covered by a bi-lateral/multi-lateral aviation agreements with the UK. The expectation is that such permits will only be requested if there are no suitable UK-registered aircraft available.
Permits applications can be obtained from the UK DfT here.
Information on states within the ECAA can be obtained here along with a map.
Important Information for Operators
The European Commission deadline (August 31st) for operators to provide the relevant Administering State with the proposed Monitoring Plan is fast approaching. Many States – including the UK - have delayed the deadline, but others (e.g. France) appear to be holding to August 31. As an assistance to operators who are Small Emitters, the International Business Aircraft Council (IBAC) has posted guidelines on their website. Please note that the European Commission has been provided with a copy of the Guidelines to see if they will verify the information but to date the EC response has not been received. Operators can use the material at their own discretion – at this point it is likely better than nothing given the looming deadline. The Guidelines consist of a simplified explanation of the vast amount of information on the EC site and a simplified reporting template that operators can use to report to their Administering State. If you are not sure of your Administering State, please refer to this official list. All flights operated by a listed operator will be administered by the State that operator is allocated to. If an operator operates both public and private category flights, all flights by that operator will be counted as public transport for the sake of this scheme. All public transport operators with emissions of less than 10,000 tonnes of CO2 per year (approx 4 million litres of Jet A1) are excluded from the scheme, and should not be on the operator list.
Please see the IBAC Home Page for the current Guidelines. They will be updated regularly so it is suggested that if any operator makes use of the Guidelines and the reporting template they take the most current version from the website.
BBGA will be issuing UK-specific guidance for the majority of our members, who will be administered by the UK for the purposes of EU ETS, in due course. The UK deadline for the submission of emissions plans is now 12th November. See Latest UK news from the Department of Energy and Climate Change (DECC).
NATMAC Informative Letter Concerning the Regularisation of Class E Durham Tees Valley Control Zone (CTR)
NATS – Clear of Conflict DVD
In coordination with the Business Aviation Safety Partnership team (of which BBGA is an active member), NATS has released their DVD “Clear of Conflict” which is designed to help crews and controllers alike become more aware of some of the foibles of TCAS 2 annunciation. There is particular emphasis on the “Adjust Vertical Speed” command, which can be misleading and has led to level busts and losses of separation. There is also a good explanation of why it is important for VFR traffic to use their transponders in order to protect themselves from close encounters with TCAS-equipped aircraft, and what controllers are doing to maintain their currency on TCAS technology. It is good revision for pilots of all levels, and we have limited copies at the BBGA offices for distribution to interested members. Please contact info@bbga.aero if you would like a copy.
Planning application to increase total aircraft movements to 120,000 per annum at London City Airport
Location
London City Airport, Hartman Road, Sivertown, London. E16 2PX
Proposal
Application under Section 7 of the Town and Country Planning Act 1990 to vary conditions 13 and 15 of the outline planning permission no. N/82/104 dated 2/05/85. This was previously varied by the Secretary of State on 26/09/1991 and the London Borough of Newham on 21/07/98 and 11/07/07, in order to allow up to 120,000 total aircraft movements per annum, (number of total movements in 2006 was 79,616).
Application number 07/01510/VAR
The BBGA recently wrote to the council with views on the application and has now received a reply stating that the council as decided to Approve Variation of Condition.
BBGA Golf Day – Friday 31 July 2009
The Annual BBGA Golf Day was held again at The Berkshire Golf Club for the Bombardier Trophy played for in the morning on the Red Course and the Universal and Weather Greensomes Trophy in the afternoon on the Blue Course.
As usual the both courses were in immaculate condition giving an honest test to the golfers. 42 players took part in the morning and 40 in the afternoon.
Bombardier Trophy
First – Ed Matthews of Cessna Finance with an amazing 46 points playing off a handicap of 12
Second – Mike Dinn of the British Antarctic Survey with 40 points
Third – Tom Perry of Cessna with 39 points
Fourth – Robin Williams of Universal and Weather with 37 points
Fifth – Alexis Grabar of Avolus with 35 points, winning on a count back of five playersThe nearest the pin on the 5th hole was Tom Perry and on the 10th hole Brad Jones of Heathrow Weekend
Universal & Weather Greensomes Trophy
First – Robin Williams and Steve Wells of Twinjet with 43 points, Robin was suitably embarrassed and said that he would try not to let it happen again!
Second – Mike Dinn and John Robinson of BBGA with 37 points
Third – Christian Rooney and Edward Hopper of Bookajet with 35 pointsThe longest drive on the 6th hole was Alexis Grabar and nearest the pin on the 13th was Brad Jones; he must be very accurate on the short holes winning two of them!
BBGA is grateful to the sponsors Bombardier, Cessna, Flight Safety International and Shell. Universal and Weather are thanked for providing the prizes for the afternoon’s competition as are Bombardier who provided them for the morning. Hamlin Engineering kindly donated some sports shirts also as prizes.
There was unanimous approval for continuing the Golf Day next year at the same location and in anticipation of this, the date of Friday 30th July had already been booked.
Finally thanks are due to all those who took part in the BBGA Annual Golf Day and helped to make it a success; without them there would be no Golf Day.
John B Robinson
VAT on aircraft over 8000kg
Following the announcement last month that the European Commission was seeking to overturn the UK’s zero-rating of VAT on aircraft over 8000kg. BBGA has made repeated requests for a meeting from HMRC. Our goal is to establish the proposed HMRC position, and present industry’s perspective – including possible unforeseen consequences of complying with the request noting that the European Directive has been shown to be inadequate even for airlines (as the recent Cimber Air victory in the European Court of Justice showed). The text below is the latest response from HMRC, and although it recognises our interest in the topic does not as yet concede to a meeting. BBGA has copied this information to the Parliamentary Aviators Group and asked them for assistance in securing the desired meeting. The text of the HMRC response is as follows:
“This request is being dealt with by the VAT Transport Policy Team, led by the Policy Manager, Jack Warr. I am sorry that I am unable to enter into any discussions at present, as we are still considering the options open to us before we respond to the Commission. No decisions have yet been made as to what, if any, changes are to be made to the legislation, but it is our usual practice to consult with industry in this eventuality. We have noted the interest of the BBGA, following receipt on 1 July of the email from Dean Carey of your organisation, and you will have the opportunity to comment in any consultation which may be held.”
We will continue to press for a meeting to put our views to the officials concerned before the UK position is submitted.
Amazing and impressive statistics contained in H. RES 508
Some very amazing and impressive statistics are contained in H. RES 508. Did you know there are nearly 600,000 licensed pilots in the United States and an estimated 500,000 of these pilots fly general aviation aircraft? Did you also know there are more than 231,000 active general aviation aircraft in the United States? Most importantly, the general aviation industry contributes more than $150,000,000,000 to the United States direct and indirect economic output.
NATMAC Informative: Airspace Change Proposal – Notification of the Receipt of an Airspace Change Proposal for the Reclassification of the Glasgow Control Area (CTC) from Class E to Class D
Latest traffic figures from EuroControl show improvement in Business Aviation movements
The latest traffic figures from EuroControl show an improvement in Business Aviation movements compared to recent months, although overall the UK’s June year-on-year figures still show a 20% decrease from last year. Of particular concern to our Luton members is the fact that Luton remains more than 32% down on a year ago, which we believe is driven largely by the ‘difficult’ approach taken by Immigration personnel at that airport. BBGA has brought this issue to light with the UK Border Agency, which has undertaken to look further into it and assess whether they agree with our reasoning. Luton Airport management is convinced that we are correct, and with the combination of the economic downturn and Business Aircraft flocking elsewhere to avoid unfriendly treatment, are as keen as we are to get the issues resolved. In a related move, BBGA member Air Routing International has withdrawn their cooperation at Luton Airport on the UKBA’s E-Borders programme, frustrated at the one-way attitude to data sharing and cooperation. Hopefully this action, combined with our barrage of letters and emails to UKBA management, will encourage UKBA management to listen to our members’ many concerns about immigration management.
UK Implementation of EU ETS to be delayed
Following continued delays in the publication of the ‘definitive’ operator list by the European Commission, the UK Department for Transport (DfT) has decided to postpone the implementation of the UK’s programme, which encompasses more operators than any other EU Member State. This means that the planned 31st August deadline for ETS registration now will not apply, and the UK deadline will now be set roughly three months after the publication of the Commission’s list to allow time for the UK legislation to become official. The Commission’s operator list is now anticipated to be published in early to mid August, although this puts it in the middle of the European vacation period so that date may itself be at risk. If the EC list is published on schedule, the UK deadline could now be some time in November 2009 at the earliest.
An official communication from the DfT and the Department of Energy and Climate Change (DECC) to all known UK operators will be issued later this week, and will include details of where to view and download their draft legislation so that operators can become fully versed in its requirements while the legislation passes through governmental approval.
The Commission is also yet to publish two other vital pieces of information, namely a) a decision on the use of Pagoda, EuroControl’s fuel consumption estimation tool, which is a vital component of a simplified system for small operators, and b) the overall aviation ‘benchmark’ of fuel use which becomes the basis of the future emissions cap. Both of these elements are vital to the success of the scheme, but Pagoda approval is especially important for BBGA members as without it small operators will be forced to use a cumbersome, expensive and bureaucratic system of fuel measurement which will cost many times the cost of the CO2 emissions alone.
BBGA will publish further updates as we lead up to the launch of the UK programme, and will be assisting members to become compliant with the UK’s version of the scheme through the most cost-effective methods. In the meantime, operators expecting to be included in the scheme should ensure that they have a documented system in place which will capture aircraft type, registration, payload and city pairs for all flights to, from or within the EU so that this process can be used as part of their future compliance.
CAA publishes final decision on Mode S expansion
The UK Civil Aviation Authority (CAA) today published its final decision on proposals for a second phase of expansion in the use of Mode S transponders in UK airspace.
EU Emissions Trading Aviation Seminars
Presentation slides from the E U Emissions Trading Scheme Seminar held in Manchester on 1 June 2009.
BBGA Condemns Plane Stupid’s ‘Ignorant Stunt’
Making the Case for Business Aviation
Good morning, and welcome to our session entitled “Making the case for Business Aviation”. My name is Guy Lachlan from the British Business and General Aviation Association, or BBGA. The BBGA is engaged in the promotion of the business of Business & General Aviation, and our members range from operators to maintenance companies, and manufacturers to handling companies. Our aircraft-operating membership is almost exclusively made up of companies which use their aircraft as workhorses; either to train pilots or as a means to increase the efficiency of their own or their client’s main business.
With me on the platform are Colin Steven from aircraft manufacturer Embraer, Trevor Esling from the Cessna Aircraft Company, Frank Noppel from Cambridge-based Air taxi operator Ambeo, and Markham Jackson from the Baltic Air Charter Association, and together the five of us are going to try to give you an idea of the value of Business Aviation – not just to the people directly employed on the aircraft, but also to the wider regional and national economies. After all of us have spoken, we hope to have time for a Question-and-answer session so that any remaining questions you have can be addressed.
Before we start, I would invite you to look around the new hangar in which we are seated as a fine example of some of the direct value that can be brought by this sector of aviation. Marshall Aerospace has been involved in Business Aviation maintenance really since the inception of Business Aviation in this country more than 80 years ago, and this hangar is the latest iteration of that involvement, with its highly-skilled workforce engaged in all aspects of maintenance and modification of these aircraft which play a key role in international business.
I would like to thank Marshall Aerospace for hosting this talk in such an appropriate location, and although the ambient lighting conditions make it too bright for PowerPoint slides, transcriptions of the talks from each presenter will be available on our Association’s website in the next few days.
Now, what is the value of Business Aviation?
Business Aviation comprises about 8% of IFR Air Traffic in Europe, and it directly contributes some £3.5 Billion to the UK economy, through the employment of some 50,000 people in the United Kingdom engaged in the manufacturing, maintenance and operation of Business Aircraft. Those aircraft are used by a variety of individuals and companies as a tool to improve their performance.
However, unlike investment in other types of tooling, quantifying the indirect economic value of Business Aviation to the individuals and companies using it in preference to commercial airline transportation is difficult to accomplish. Investment in a manufacturing machine tool can easily be assessed in terms of greater throughput, shorter set-up times or greater reliability. Investment in business aviation as a transportation tool produces similar benefits (higher output, faster reaction times and greater reliability), but because the output is not typically core to the business in question, it cannot easily be measured in the same way. This was painfully obvious when the ‘big three’ US car company executives were being grilled recently in Washington DC: When asked which of them was parking their aircraft in order to fly home on the airlines, none of the executives had an answer to show that their use of an aircraft was not a needless luxury, but a key productivity tool to leaders of global companies- especially at a time of crisis. The lack of an answer was very telling – those executives would have expected instant answers themselves from a subordinate seeking capital expenditure approval, so why did they find it difficult to produce the same kind of answers at that critical moment for business aviation? The answers should have been fast and confident – business aviation allows the company to operate more efficiently in bad times as well as good times.
Studies have shown that companies with access to business aviation perform around 10 % better than those without, and in a 1995 study the Department for Transport recognised that, quote: “Aviation facilities are the third most important factor influencing inward investment decisions.” More recently, a January 2009 report from the European Commission entitled “An Agenda for a Sustainable Future in General and Business Aviation” stated that “General and Business Aviation provides closely tailored, flexible, door to door transportation for individuals, enterprises and local communities, increasing mobility of people, productivity of businesses and regional cohesion”.
I would suggest that the five key indirect benefits of Business Aviation are Flexibility and Convenience; Time Savings, Cost Savings, Deal Facilitation and Safety and Security, and I would like to look at each of these in turn:
Firstly, Flexibility and Convenience
Companies needing to reach multiple destinations in a single day rely on business aviation. This type of itinerary is often impossible to keep using other modes of transportation. Business Aircraft typically fly from regional airports such as Cambridge, not served by airlines, and fly on direct routes not constrained by airlines economics. The recent turmoil in the airline industry has seen many marginally-profitable routes cancelled or scaled back in the interests of airline profitability. While this is only an inconvenience for leisure travellers, a business relying on transporting key personnel clearly cannot be disrupted in this way. The only way to fly where a company needs to go, when it needs to get there, is by business aviation. Businesses looking for locations in which to establish new operational hubs for senior executives increasingly look for business aviation connectivity as part of their decision-making process. It follows therefore, that a community fostering business aviation links will attract more of these valuable and prestigious businesses to their locale. The December 2008 PricewaterhouseCoopers report on the economic impact of business aviation in Europe quoted a user as saying “The advantage of business aviation is the speed at which it can move people point-to-point, and this really helps businesses in regions which are not particularly easy to get to…..this means that I think the business aviation impact on regional economies is large.”
Secondly, Time Savings
Business aviation is a time multiplier allowing key employees to do more, faster. Much like an investment in state-of-the-art computer software, a business aircraft boosts employee efficiency and productivity. Using business aviation, executives are able to conduct multiple meetings in multiple locations without the frustrations, delays and inconvenience of overnight stops. In addition, because the aircraft are frequently connected to the ground by phone, fax and email, time spent in the air is not dead time as it is in the airlines. Just as time-savings in the factory example above are key to the investment decision, time-savings for executives are tangible and of value to the company employing them. It follows that companies making prudent use of business aviation will run more efficiently than those that do not, and those companies will be more beneficial to their host locale.
Thirdly, Cost Savings
Surprisingly, business aviation can often be cheaper than its commercial alternative. This is especially true on routes not served by low-cost airlines which are milked by traditional carriers enjoying a lack of competition on the route. Modern options for fractional ownership and on-demand air taxis such as offered by Ambeo, mean that these cost savings can be enjoyed without the capital expense of an aircraft purchase.
Fourthly, Deal Facilitation
Business Aviation enables key staff to negotiate and sign business deals personally rather than using local staff or representatives. One deal in the headline at the moment is the pending sale of Chrysler to Fiat, which itself is using Business Aviation to enable their senior management team to carry out sensitive and highly political multi-national talks face-to-face, and if possible to conclude a deal within the window allowed by the bankruptcy court. With the required shuttling between capitals and Detroit, it is unimaginable that any company could conclude this or any similar deal without similar activity by the purchasing company’s leadership. It seems logical therefore, that countries and regions best enabling Business Aviation activity will foster more successful companies, which in turn will benefit their home country.
Lastly, the important issue of Safety and Security
When using a business aircraft, employees can meet, plan and work en route. Employees can discuss proprietary information in a secure environment and without fear of eavesdropping, industrial espionage or physical threat. If forced to compromise on this critical issue by insufficient access to business aviation, businesses will not equivocate, they will relocate to a region or country better served by access to business aviation. A facility such as Marshall’s is a magnet to the individuals and companies seeking the highest standards of safety and security for their personnel. The presence of these people in the regional economy is undeniably a good thing for any regional economy seeking to grow and succeed.
These are the answers that should have been provided by the CEO’s of the Big Three in Washington, and should be clearly and confidently stated to shareholders of any company using Business Aviation: BUSINESS AVIATION IS A SOUND INVESTMENT. This argument is not as alien as it seems – we all do the same value equation intuitively every time we use a bus instead of walking, a car instead of a bus, or a taxi instead of a car.
In addition to these semi-tangible benefits are the intangibles of Business Aviation – how much non-aviation benefit flows to an economy as a result of businesses and individuals choosing to locate in an environment benign to Business Aviation. It is very difficult to place a financial value on this number, but it seems indisputable that it is significant. Even the mighty PWC elected not to try to include this figure in their 2008 study, preferring instead to make it the subject of some future dedicated research.
So Business Aviation is valuable to an economy.
Emissions
However, there is an elephant in the room around the topic of CO2 emissions, and I would like to address that head-on.
Aviation in total contributes about 2 percent of global emissions. Business Aviation is responsible for less than 1% of that 2%. To put that into perspective, in the UK that is equivalent to each of us with a car driving just twelve miles in a year. Now, which would have a greater economic impact to the UK – each of us driving 12 miles less a year, or abolishing Business Aviation? Despite being such a small polluter, Business Aviation has been singled out for very harsh treatment under the European Emissions Trading Scheme – far more costly for our sector than for airlines.
The reason for this is that the European Union has bought the myth, sold by the airlines, that a full aircraft is an efficient aircraft. Of course, because even a full Business Aircraft is only lightly loaded, anyone believing that a full aircraft is an efficient aircraft would automatically assume that Business Aviation is less efficient than an airliner. This has resulted in Business Aviation being disproportionately penalised under the European Emissions Trading System for Aviation, which will come onto force in 2012, while airlines get a largely free ride at least until 2020.
But I would question the full aircraft equals efficient aircraft assumption: Is it really an efficient use of fossil fuels to carry a full planeload of revellers to, say, Prague for a stag night? I would say probably not, but in the Emissions Trading System, the European Government says that is a more efficient use of fuel than a Corporate shuttle engaged in securing valuable and ongoing trade deals. More challengingly, while we all enjoy holidays, what really is the economic value to the UK of a week in the Caribbean for, say, me and my family? It may have some value in terms of workforce mental wellbeing, but to my knowledge no one has studied this interesting question.
The businesses that our members operate are not extravagant or run on a ‘money-no-object’ basis; they are businesses operating on margins comparable with other industries, and either competing against foreign companies for work throughout Europe, or using their aircraft as a productivity tool for their own management team.
It seems inescapable that at some point, if we are serious about meeting our Kyoto obligations of a 20% reduction of CO2 emissions by 2020 and by 80% by 2050, at some point we are going to have to apportion (or ration?) CO2 emissions in relation to the additional value earned by each unit of emission. This is no doubt a difficult task, but the current system does not attempt to do that. As a result, Business Aviation is easily targeted by legislators seeking to raise a quick bob.
At BBGA, we are absolutely in favour of paying our way for the pollution we generate, and for the prudent use of aircraft in general. But as we believe that Business Aviation is disproportionately valuable for the economy, it follows that it should be disproportionately advantaged compared to activities which have little or no economic value – such as the twelve annual car miles I mentioned earlier.
In a sustainable economy it is clear that Business Aviation is far more environmentally efficient than the airlines in its value per unit of emissions, and it is obtaining the highest possible ratio of economic benefit to quantified emissions that is key. Hence it is not filling an aircraft with as many passengers as possible that is environmentally efficient, but rather obtaining the maximum economic value for as few emissions as possible that matters.
In conclusion, I would like to say that we are gaining an ever more complete picture of the value of Business Aviation, and it is significant. We are encouraging politicians and regulators to take that value into account when addressing a carbon-constrained economy. These aircraft are not toys or extravagances, they are meaningful and valuable efficiency-multipliers for the economy – even a far less carbon-intensive economy as envisaged by Kyoto. The value to our economy is illustrated as we look around this hangar and outside on the airfield.
That concludes my introduction, and I would now like to introduce…
Enviroment Agency Presention
‘Aviation in the EU Emissions Trading
Scheme’
Eurocontrol traffic figures for April 2009
EU-Canada Air Transport Agreement
BBGA welcomes the conclusion in Prague last week of a comprehensive EU-Canada Air Transport Agreement which paves the way for a truly common aviation area encompassing the EU, Canada and the air routes between the two.
In the first phase of the agreement, EU and Canadian airlines will have unrestricted access to EU-Canada routes, with full pricing freedom, mirroring the EU-US agreement which came into effect in 2008.
Subsequent phases of the Canadian deal, however, will go much further, permitting the operation of international services from the territory of the other (‘seventh freedom’) and, ultimately, services within the territory of the other (‘cabotage’) – a dramatic development within the ICAO framework, and one which looks likely to eclipse in practice the stalled EU/US open skies agreement.
Unlike the EU/US agreement, which largely ignores Business Aviation and is unequally beneficial toward US operators, It seems likely that Business Aviation will be properly included as the Canadian agreement develops, leading to real opportunities for British and other European operators, as well as their Canadian counterparts as a true ‘win/win’ scenario is allowed to develop.
We applaud the negotiators and the Czech Presidency for driving this agreement to completion, and urge them to maintain the momentum that will carry it into its crucial subsequent phases.
CAA proposed mid-year charges
The CAA today announced that their proposed mid-year charges increase, which was planned to take effect this year in light of their projected income shortfall has been cancelled for the time-being.
The BBGA, through its position on the CAA Finance Advisory Council, strongly advised the CAA to re-examine their own internal cost structures and achieve the budget through cost-cutting rather than simply passing the shortfall on to operators.
We are pleased to say that it seems that this advice has been heeded by the CAA Board for the time-being. We continue to urge the British Government to remove the unique requirement on the UK CAA to make a commercial return on their expenditure. In an EASA-governed Europe, the UK CAA’s cost-recovery system is counter-productive to UK economic well being.
Prague summit ‘opens the sky’ between the EU and Canada
On 6 May 2009, Prague hosted the EU-Canada summit. In line with the conclusions of the previous summit, EU and Canadian leaders began negotiations leading to the deal on strengthening the economic partnership.
Directorate of Airspace Policy – Policy Statement
DAP Policy for Transponder Mandatory Zones (TMZs)
Letters BBGA has submitted to the House of Commons Transport committee regarding the Use of Airspace and The Future of Aviation
Introduction of a modified ATS route structure linking the Scottish and Belfast TMAs with the Dublin TMA as part of the UK/Irish FAB development
Proposed introduction of permanent upper ATS route UM132 between TALLA VOR and IBROD
T C North – February 2009 – update
Following careful consideration from feedback received during the original consultation in 2008; from meetings last autumn with local authorities and representatives of AONBs, NATS is to conduct a new consultation on revised proposals to redraw the aircraft route map of Terminal Control North (TCN).
The second consultation will be available later this year, not before July (date to be decided). The revised airspace design is still being formulated, tested in simulation and assessed for safety, operational efficiency and impact on populations.
Watch this space for future updates in consultation dates.
Stansted G2 Public Inquiry
As released by The Rt Hon Hazel Blears MP, the formal announcement of the inquiry has been delayed and will not start on 15th April.
We understand that the Competition Commission is due to publish its report no later than 28th March
Ms Blears expects to make an announcement on the start date of the inquiry with 4 weeks of the publication of the Competition Commission final report.
NATMAC Decision Letter –
Introduction of Revised London City Standard Instrument Departure Procedures
The CAA has issued a Decision Letter relating to London City Airport SIDs which can be found on the link below.
Counter Terrorism Protective Security Advice for General Aviation
The National Counter Terrorism Security Office has produced a guide intended to give protective security advice to those who work within the General Aviation sector. It contains crime prevention material and guidance on business continuity. The advice is not mandatory but may assist those engaged within the sector to enhance security to an appropriate level at their site.
Private pleasure-flying: changes from 1 November 2008
You may be aware that HM Revenue & Customs have introduced a new duty on aviation fuel, specifically for Jet A1 (AVTUR) effective from the first November 2008.
However, this duty only applies to recreation and pleasure flights. Unfortunately the customs department has called it private and pleasure flying, so in order to make it easier to understand, I have included a note which customs have now accepted as flights which will be regarded as non-private for the purpose of not paying the new duty. (See ref to ‘Definition of private pleasure-flying defined’ in link to ’Revenue and Customs brief 50/08 below).
The new duty is important partly because the rate of duty is 52.35 pence per litre (increased from 50.35 pence per litre on 1st December 2008). When refuelling your aircraft you will be asked by the re-fueller to sign a declaration to state whether the flying which takes place subsequently to the refuelling is intended for private pleasure flying as opposed to flying on business, so considerable care should be taken to ensure that the declaration only gets signed as private if you are engaged in pleasure flying as opposed to flying supporting business interests.
We now have an agreement with the Revenue to the effect that if your flight is destined to a place outside the United Kingdom you will be entitled to 100% relief on the duty using the customs form HO60.
We are still negotiating with the Revenue to see if they will accept a payment form showing the liability with a claim for the relief of the duty attached to it, i.e. rather than paying the duty and claiming the drawback; you would attach the claim form to the payment form, and only pay any amount in excess of the relief that you would be entitled to claim – usually 100%.
The position where operators who have aircraft owned by a group of owners, where it is the responsibility of the person flying when he has finished with the aircraft to fill the tanks, and is not aware of the purpose for which the next member of the group will be using the aircraft, has been put to the Revenue. However, at this moment in time it has not yet been agreed who would be responsible for paying the duty, if any.
For the benefit of those who are supplying fuel as registered dealers in controlled oils, I have included a copy of the letter from Customs and Revenue (download pdf) and the link to Revenue and Customs brief 50/80 which also contains the ‘Definition of private pleasure-flying defined’ referred to above. A sample of the declaration which a number of oil companies have agreed meets with Revenue and Customs requirements and Revenue is available from the BBGA office.
Customs are in the process of designing a payment form in the absence of which they say they will accept a piece of ordinary writing paper. I recommend that you ask Customs via the National Enquiry line for a copy of the payment form, and when you send the form in, ask them to send you a stamped copy that you can retain in your records in order to prove you paid duty on a particular uplift of fuel.
The claim form for duty is a customs form HO60 which at present is designed as a drawback. However, if you are using the form to demonstrate why you did not need to pay, in my personal opinion, you should cross through the word drawback, and insert the word relief on the first line on the top of the form. (This form currently has to be ordered from the HMRC National Advice Service - Tel. 0845 010 9000 – Option 2)
I have also enclosed a letter from Revenue and Customs describing the procedure in more detail (download pdf) Martyn Fiddler BBGA Customs/VAT Consultant.
Martyn Fiddler BBGA Customs/VAT Consultant
BBGA Activity Report
BBGA attends meetings, working groups and committees throughout Europe representing the interests of members. The latest Activity Report can be viewed here.