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 Consultation.

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 proposal.

Deadline: 17th September 2004
 
FMI: www.aopa.co.uk