All Of Europe To Pay Aviation User Fees?
From our AOPA friends across the pond...
You may be aware of the current Consultation in
relation to a new Charging Scheme which the European Commission
through Eurocontrol is proposing to
adopt. However, it has NOT been made clear to us
whether comments will be considered from individuals and that is
why we are asking you to send them to the persons named at the end
of this letter.
The Single Sky Regulations came into effect on the 20th April
2004 – in fact there are four Regulations:-
- EC Reg 549/2004 Framework
- EC Reg 550/2004 Service Provision
- EG Reg 551/2004 Airspace
- EC Reg 552/2004 Interoperability
Eurocontrol has been given the task (by mandate) to develop the
Implementing Rules for each of the Regulations.
The current Consultation on the development of Rules to support
a common Charging Scheme for air navigation services will have an
impact on General Aviation unless it is opposed – attached is
a copy of our response, you will see that it follows a very
mechanical process which must be adhered to as failure to do so
will result in the submission being returned. Also attached are the
blank forms that you need to use.
Whilst AOPA has attempted to provide answers to each of the
articles you may wish to concentrate your replies in respect of
only 2/3 articles – numbers 6 & 14 for example.
The basic principles
evolve around each Member State deciding on which volume of
airspace to which they wish to apply charges. This, in effect,
could place some of GA’s activities into boxes of airspace,
clearly from a safety point of view this is unacceptable. AOPA
believes that as a principle Classes F&G airspace should be
considered as non charging volumes of airspace as Class G serves
the needs of both GA and the military.
The Commission in Article 14 tells the State that they have the
power to grant exemptions but where exemptions are given, the State
must pay for them. In our view this will have an impact on the
Lower Airspace Radar Service (LARS). This is currently funded by
way of a rebate of Eurocontrol Navigation Charges totalling
£1.6 million annually – the UK Department for Transport
estimates the true cost of LARS as being nearer to £7
million. If each GA aircraft has to cover this cost it would be
equal to about a £1,000 p.a. per aircraft! So we are
concerned about the future of LARS.
We are also concerned about how the proposed charges would be
collected. Unlike Commercial Air Transport Operations VFR flights
do not always go in straight neat lines so the formula of weight x
distance does not work for VFR! If an annual charge were levied by
the Member States on their own GA operators, this would be similar
to the road tax we pay on our motor cars. However, it would not
necessarily be the same amount in each Member State and, as in road
tax, there would need to be bilateral agreements in place in order
to fly in other Member States. But, an annual tax is completely
different from a charge for air navigation services. To start with,
the EU has no competence in the area of taxation. If charges for
services are to be imposed on GA for flights that are proportionate
to the level of service being provided then it is likely that the
cost of collection will be greater than the charge itself. This
would be unfair and a contravention of the Treaty of Rome i.e. the
freedom of movement.
In effect our position
is that the status quo should be maintained and that is no charges
for VFR flights or IFR flights for aircraft with a MTOM of < 2
tonnes. No charges for flights that arrive and depart at the same
aerodrome and no charges for training flights.
The Commercial Air Transport industry receives billions of Euros
of subsidies by way of no fuel tax and no VAT on the sale of
airline tickets. They use the airspace to make profits for their
shareholders whilst GA activity is usually funding from an
individual’s tax income. The individual also pays the duty on
AVGAS plus the VAT every time they go flying.
The time to act is now! Please add your voice to the
Send a copy to Alistair Darling, Minister of Transport, your
local MP and MEP and also send a copy to John Arscott at the CAA,
DAP and to AOPA.
The more replies the better chance we have to fight off this
Deadline: 17th September 2004