Mission Statement

Mission The mission of IAOPA Europe is to promote, preserve and protect General Aviation and Aerial Work activities and their economic value within the ICAO North Atlantic/European Region. Goals Promote safety in all general aviation and aerial work activities; Ensure equitable access to airspace and aerodromes; Develop, promote and preserve aerodromes; Advocate fair and reasonable user charges and taxation; Defend against unreasonable regulation; Participate in the development and implementation of Pan-European activities to ensure that the needs of all General Aviation and Aerial Work users are properly addressed; Present a positive and balanced view of General Aviation and Aerial Work activities to the public, emphasizing enjoyment and value provided; Provide the resources to accomplish the European Region's objectives. Objectives Promote activities designed to promote, preserve and protect aerodromes; Seek opportunities to build new aerodromes, convert existing military aerodromes to civil use and gain access to all existing airports on a fair and equitable basis; Ensure that any implementation of managed/controlled airspace allows for the needs of General Aviation and Aerial Work; Prevent unnecessary VFR flight restrictions in managed/controlled airspace; Minimize or eliminate inappropriate fees and taxes levied on General Aviation and Aerial Work activities; Require proof of the need for and benefits accruing to proposed communication / navigation / sureillance equipment requirements; Support a realistic, economic transition to satellite based communication, navigation and surveillance sysems and support all relevant trials; Minimize all JAA requirements Regularly communicate news of IAOPA European activities and accomplishments to the aviation press and affiliates. IAOPA Statement on Privatization 1999 OCT 29. To be presented at ICAO ANSConf2000, 2000 June Background The International Council of Aircraft Owner and Pilot Associations represents the interests of 51 affiliate AOPAs worldwide, each located in an ICAO contracting State. Those organizations represent the interests of more than 400,000 general aviation and aerial work pilots and operators. Our principal areas of interest are access to airports and airspace, user charges and taxation, flight crew licensing and the promotion of general aviation and aerial work as valuable forms of international transportation. Privatization Our understanding of the term privatization is the sale, lease, change of management or release of a government owned or operated enterprise, such as an airport or air traffic service, to private organizations or government corporations. In reality, few aviation infrastructure assets are fully privatized, rather they are corporatized or commercialized, with governments retaining substantial amounts of control over the entities. For purposes of this paper the term privatized will be used interchangeably with corporatized, with the understanding that the net effect involves aviation infrastructure and services being transferred in whole or part to a non-sovereign agent. As governments have found it difficult to operate public infrastructure responsively, efficiently and cost-effectively, they have resorted to the sale, lease or change of management of public facilities. The common rationale for these actions is greater efficiency, increased responsiveness to user needs, and reduced costs. Inherent in these transfers is a series of conditions dictated to the new enterprise that will ensure the safe and reliable continuation of the availability or essential facilities and services. Overview Providing certain essential services and facilities is generally considered to be the responsibility of governments: military, police, fire protection, elementary education, and, increasingly, social services. Traditionally, air traffic services and some airports have been included in this group of essential facilities and services, to be provided by a government organization and staffed by government employees. The worldwide privatization revolution of the past decade has dramatically changed the relationship between citizen/recipient and government/provider of these traditionally government-provided services. While some aspects of privatization have proved successful, privatization as a whole is not viewed as a success by the general aviation and aerial work communities. General Aviation and Aerial Work Needs and Desires General aviation and aerial work activities traditionally have operated at the margins of an air transportation infrastructure, which is principally designed for the world’s airlines. This arrangement has, for the most part, worked well since GA/AW operations tend to avoid large hub airports and busy terminal areas during peak periods. Yet, GA/AW interests have always protected their ability to operate in the air traffic system and at major airports. They have retained airport and airspace access largely through political and public opinion processes, by actively advocating the value and utility derived from GA/AW operations. With large- scale privatization of airports and air traffic services the principal access determinant may become the ability to pay. Because of this shift GA/AW interests are concerned with their continued ability to freely operate within the aviation infrastructure. Of great concern is the effective double taxation of GA/AW operations. Virtually every country imposes an aviation fuel excise tax, yet provision to apply these revenues to the aviation infrastructure is employed in few countries. With privatization, a formal fee-for-service structure is imposed for most aviation services, adding costs for the GA/AW operator with little demonstrable benefit. Access to and equity in use of aviation systems are the principal concerns of GA/AW interests when considering privatization. Airports Within the past fifteen years roughly 100 airports have been privatized worldwide. In doing so the governments of the United Kingdom, Australia, New Zealand, Canada, South Africa, Mexico, Argentina, Germany and others have essentially cashed-in their aviation infrastructure investments. While these divestitures ostensibly were accomplished for reasons of increased efficiency and service levels, in reality the sudden infusion of cash from the sale of valuable infrastructure and inability to meet the demands of users may have greatly contributed to the privatization rush. What have these changes meant to GA/AW? Increased fees. Mexico recently imposed high passenger and handling fees on general aviation flights at their newly privatized airports, yet few services or facilities are provided. Loss of access. Toronto’s Pearson International now bans general aviation during certain periods. In other cases, high landing fees for small aircraft form an effective barrier to the use of metropolitan area airports. Loss of airports. Canada’s large scale sale of air carrier airports may make it economically infeasible for some municipalities to operate their airports. These are just a few of the negative effects that airport privatization has had on GA/AW operations. In general, privatized airports mean higher fees and reduced access for general aviation. The primary alternative to major metropolitan area airport access is to use conveniently located general aviation airports. Yet, this type of airport is rapidly being lost to real estate development and environmental concerns. And, the desirability of well-situated general aviation airports has been discovered by smaller/startup airlines, causing a new round of competition for increasingly scarce metropolitan airports. While some may see increased fees and reduced access as the inevitable consequence of efficiency measures and free enterprise, the change comes as a bitter blow to GA/AW operators who lose substantial utility for their aircraft. More significantly, many communities’ link to the world of business and commerce flows through its airport; economic viability may be stunted or eliminated with the loss of a small municipal or rural airport. For all the negatives associated with airport privatization, the privatization/commercialization of a few municipally-owned airports, notably in the United States and Australia, has improved access and reduced fees at those facilities for GA/AW. The key to these successes appears to be the involvement of community leaders and aviation interests in improving the value of the airport asset for both user and community. While these isolated examples are encouraging, the required personal involvement will be difficult to insure on a broad scale. Air Traffic Services Canada, Australia, New Zealand and a number of European nations have privatized/corporatized their air traffic services systems to varying degrees since 1987. While isolated examples of reduced delays and increased efficiency in these systems are touted, it is difficult to develop an overall opinion about such activity. IFR fees for small general aviation aircraft appear reasonable within Canada but may increase substantially when improvements are needed. Germany recently attempted to impose a DM7000 annual system access charge on all aircraft. New Zealand has recently instituted charges fees for weather briefings and flight plan handling, a significant safety issue. Small aircraft pay no IFR route charges in Eurocontrol (largely due to its inability to account for the large number of general aviation aircraft in Europe) but access to the system is often difficult to obtain due to system inefficiencies. In countries charging for air traffic services, aircraft may attempt to avoid enroute and terminal charges by operating in marginal VMC conditions, creating a safety hazard. In many countries less than five percent of all IFR flights are flown by GA/AW. Because of this it is difficult for them to have a significant voice in planning and operating the ATC system. If as in Eurocontrol they pay no route fees, they have little standing in the control/operation of the system. These dilemmas raise significant questions of equity and access for GA/AW interests. As noted above, significant safety concerns arise from the imposition of charges for enroute and terminal charges for IFR and controlled VFR operations. A more insidious and potentially severe hazard is created by emerging fees for weather briefings and aeronautical information services for VFR operations; avoiding these essential preflight elements for the sake of economy is a strong temptation for operators. Privatization Concerns Economic viability of privatization agents. Operations and capital funding is easily obtained in good economic time, but will privatized entities survive during economic downturns? Deficit spending/financing may only be available through governments in bad times-will they be willing to bailout private enterprises or government corporations? Financing less popular facilities/sectors. Major airports and associated air traffic services will always enjoy sufficient funding to remain "non-profitable"; what of small commuter airlines or general aviation airports/air traffic areas? If a government wishes to divest itself of all or its least profitable facilities, will it be possible to continue to operate them privately without subsidy? Governance of the privatized entity. Will the board of directors of the airport or ATC corporation adequately accommodate the needs and desires of all users or just those who pay the most? Does the government impose some form of social or community responsibility on the privatized entity? "Non-profit margins". Most airport and ATS corporations are financially classified as either governments or non-profit entities. Gold- plating facilities, poor contractor/project monitoring and excessively high staffing levels are a few examples of organizational faults leading to increased charges. Will it be possible to ensure effective oversight of these elements, especially if controlling authorities are airline or government dominated? Access. Maintenance of equitable access to airports and air traffic services is essential to the continued viability of GA/AW, regardless of who provides those services. Will the ability to pay or fee levels become the principal access determinant? Service levels. The sheer numbers and economic power of airlines and their passengers may dominate customer service goals and concerns for privatized entities. The needs and desires of GA/AW operators must share a place within those concerns. Safety. While all privatized entities profess a strong allegiance to safe operations, the drive to economic success may unduly influence that dedication. Strong oversight by regulatory authorities and legislated safety goals are increasingly important in a privatized system. Conversely, this motivation should not cause system "gold plating" or over-design; both risk and cost-benefit analyses must be employed to determine an appropriate safety balance. Conclusions Privatization/corporatization of the aviation infrastructure contains both benefits and detriments for GA/AW interests. Our greatest concern is that user fees will become the principal determinant of access and service levels in privatized systems. In all but a few of the public discussions on the subject the terms "general aviation" and "aerial work" are seldom heard; the predominance of airline interests is overwhelming. here must be an equitable place for GA/AW interests in any aviation service privatization scheme. Determination of equity or access based solely on ability to pay will create a system destined to provide poor service, high prices and neglect of minority users. Approximately three- quarters of the worldwide general aviation and aerial work activity is conducted for some business, economic or government service purpose. GA/AW brings value to the communities they serve. But, that value may be stifled or even eradicated if excessive charges or reduced access to essential facilities are imposed under the guise of efficiency or economic incentive. Finally, profit motive must be tempered not only with a dedication to service excellence but principally to a service designed to provide the highest levels of safety to all users. IAOPA Statement on Economics of Airports and Air Navigation Services 1999 DEC 02. To be presented at ICAO ANSConf2000, 2000 June Background General aviation and aerial work (GA/AW) operations form the foundation of the world’s air transportation system. Airline pilots are created through its training, critical care is provided to the populace through emergency medical service aircraft, and business aviation supports national and international commerce; GA/AW forms an essential and significant force in the world of air transportation. The more than 600,000 pilots and 300,000 aircraft engaged in general aviation and aerial work operations throughout the world comprise a majority of aviation operations; they contribute significantly to national and international economies. Their needs must be accommodated when planning and operating the aviation infrastructure. The great majority of worldwide aviation facilities and systems are designed and operated for the benefit of the airlines. GA/AW generally operates at the margins of this system, taking advantage of capacity unused by air carriers. Therefore, any discussion of funding the aviation infrastructure must realize that GA/AW operations command only a small fraction of all services provided in the total system. Further, the majority of GA/AW operations are able to operate safely without using many air navigation or traffic services. Airports Organization. While the organization and control of international airports means little to the general aviation/aerial work operator, several features of that organization tend to have a significant impact. If the airport is a government owned/operated entity, the operations are usually stable and predictable. Yet, these operations may be rigidly structured and unable to respond to user demand. conversely, while private ownership may lead to more flexible and user- oriented operations, user fees and charges will probably be higher than at a government-run facility. And, as airport operation becomes fully privatized the ability for users to receive funding support from government excise taxes fades rapidly. Therefore, the ability of an organization to adequately support user needs at a reasonable cost is the key to an effective and efficient airport operation. Capacity Management. As capacity demands increase, airports should first look to operational efficiency and innovative solutions before any artificial allocation or queuing schemes are imposed. Additional runways and taxiways, more efficient air traffic management, land-and-hold-short provisions and land-long techniques for smaller aircraft are examples of what can be done to improve airport capacity without imposing artificial restrictions. Only after all of these operational enhancements have been explored should artificial capacity constraints be attempted. Of all the economic mechanisms used to control capacity, slot allocations are the least desirable for GA/AW. This is because the concept of equal access is often biased in favor of the air carrier. High minimum fees are also used to effectively restrict GA/AW access to busy international airports, yet these fees tend to exclude both GA/AW and smaller air carrier aircraft even when excess capacity exists. But, peak-hour access fees, if applied equitably, often control demand during an airport’s busiest periods. The ultimate and ideal capacity enhancement tool is additional airports. Strategically located reliever airports with ready access to major metropolitan areas not only relieve capacity pressure on principal international airports, they also create additional economic centers and reduce ground transportation congestion within metropolitan areas. While many governments have effectively discarded the idea of constructing reliever airports because of environmental and land use pressures, others have succeeded in placing additional airports at the periphery of heavy populated areas. To succeed, these new facilities are located near public transportation that provides easy access to city centers. Financing. The fact that an airport is government owned and/or operated implies that its operation is being provided for the public good or advantage. In this case, capital financing should be principally accomplished through the use of excise taxes tied to the operation of the aircraft using the facility. Fuel excise and passenger ticket taxes are an example of this type of tax. Additionally, landing and facility use fees may also be applied to individual aircraft operations to pay for operational expenses. Privately owned and operated airports may receive capital grants or loans from States in recognition of the value and economic advantage provided by a healthy national and international air transportation system. However, much of the capitalization will be accomplished through facility improvement set- asides derived from the full range of airport revenues. Finally, airport corporations issuing equities and bonds may provide the ideal means of raising funds for capital improvements. ‘Assigning aircraft and passenger use fees at airports must recognize that GA/AW operations use but a small fraction of the infrastructure and cause little maintenance-related expense. Essentially, GA/AW operations operate at the margins of the air transportation environment and effectively use only excess capacity and services. Therefore, allocation of airport access and use fees for GA/ AW ‘should reflect only the marginal costs for their operations. The existing guidance provided for Airport Charging Systems contained in ICAO Document 9082/5 provides succinct and appropriate counsel: Airport charges levied on international general aviation should be assessed in a reasonable manner, having regard to the cost of the facilities needed and used and the goal of promoting the sound development of international civil aviation as a whole. Air Navigation Services Organization. Governments have an obligation to their citizens and foreign visitors to provide basic services that bring order and safety to the polity in pursuit of legitimate goals. Among these are provision for air navigation services (ANS) that provide for the safe, orderly and efficient flow of air traffic. Whether the government or a private enterprise provides these services is irrelevant; however, the provision for and oversight of these services is the responsibility of the government. (ANS associated services include: navigation. and communications infrastructure, air traffic services, meteorological services, search and rescue, and aeronautical information services.) Capacity Management. Again, artificial metering mechanisms, like slot allocation, peak-hour charges and high minimum charges, are viewed as last- resort actions when considering management of air traffic capacity. Innovations such as direct routing through area navigation (RNAV) processes, reduced vertical separation minimums (RVSM and intelligent structuring of airspace to accommodate both VFR and IFR users are examples of creative capacity management.) Only when the absolute capacity of a route segment or terminal sector is reached should queuing methods be used. But, the method used to determine system and segment absolute capacity should be subject to review by both government regulators and users. Principles of fairness and equity should govern ATM within a State. Efforts to accommodate all types of operators must be made. Financing. Financing the basic ANS infrastructure should be accomplished by the State, using excise taxes derived from either fuel tax revenues or passenger ticket taxes. And, since basic civic safety and order functions are involved in providing ANS, a portion of the State’s general revenues should also be used to create a safe and efficient infrastructure. Once the capital, research and development, and future improvement costs of operating an ANS system have been accommodated through tax revenues, operational costs may be recovered through similar methods or a system of graduated user charges. The use of tax revenues to fund system operations and maintenance is preferable due to the ease of collection of revenues and the lack of need for a complicated accounting system. However, if direct user charges are employed, a graduated system of fees should be used that recognizes both value for services received and the obligation for a State to provide basic safety services to the traveling public. For instance, requiring a private pilot to pay a significant fee for a meteorological and NOTAM briefing and for filing a VFR flight plan prior to flight may subvert safe operations. This is because the pilot may choose to avoid these essential safety services in an effort to avoid the charges associated with the services. Therefore, consideration must be given to providing essential services using tax revenues in support of safe operating practices. Again, the existing guidance provided for air navigation services charging systems contained in ICAO Document 9082/5 provides succinct and appropriate counsel: The charges levied on international general aviation should be assessed in a reasonable manner, having regard to the cost of the facilities needed and used and the goal of promoting the sound development of international civil aviation as a whole. Regulatory Aspects All taxes, fees and charges associated with airport and ANS must be established as a cooperative effort between government regulator, service provider and service user. Only a joint effort of this nature will yield a workable, safe and effective aviation infrastructure. Dictated funding systems or those biased for or against any user segment will cause users and providers to subvert the system in an effort to achieve perceived equity. Finally, once planning and use mechanisms are put into place an ongoing dialog is necessary to preserve the system. Conclusion Provision for an ideal aviation infrastructure should adhere to international standards and recommended practices, be responsive to user needs and employ cost recovery methods that realistically reflect an equitable assignment to both user and the polity ultimately benefiting from the air transportation system. IAOPA (EUR) Resolution on VFR-Traffic in Russia (Resolution draft by AOPA Russia, adopted on 101st RM 1999 OCT 09. Text may be edited for formal compliance) IAOPA 101st European Regional Meeting urges the Russian Federal Authority for Aerial Transport and other concerned Russian government bodies: to take practical steps toward implementation of an airspace classification allowing for low-level uncontrolled airspace for VFR-traffic to designate entry points and routes within the country for international VFR-traffic to revise the structure of navigation charges alleviating financial pressures on international General Aviation traffic. IAOPA expects these measures to bring about a remarkable increase in international General Aviation activity in Russia and offers the concerned Russian authorities co-operation in working-out respective regulations. Statement by IAOPA European Region on ATM 2000+ Policy Themes at Eurocontrol Provisional Council It is generally well understood that General Aviation (GA) has about four times more the number of aircraft using the airspace than the Commercial Air Transport (CAT) sector, thereby making GA the largest airspace user. However, unlike the CAT sector, GA does not require a complex and expensive system and it must not be expected to pay for it. The general profile of commercial flight means that airspace is mainly occupied above FL 200 en route, although some smaller CAT operators may fly at lower levels. Therefore any expansion of managed airspace should permit VFR flights to operate unrestricted up to FL 120 AGL – where the basic principle of VFR is see and avoid -- whereas an IFR operation in managed airspace is likely to be under some form of control. Furthermore, any expansion of managed airspace should only be accepted on a case-by-case basis. Airspace planners should be required to consult with user groups on any proposal, taking into consideration relevant compliance cost assessment. Where new airspace requirements require the fitting of new equipment, an in- depth cost-benefit-study should be made available to user groups for consultations, prior to any change being implemented. GA/AW is willing to participate in changes, but only where low-cost, certified avionics are available. The ATM 2000+ Strategy Volume I is a good attempt by ECAC to get Europe's airspace into a common system, however the benefits of this new strategy for GA/AW are still unclear and need discussion. IAOPA (European Region) POLICY on Fuel Taxes Whereas: it appears that increased charges are being levied against General Aviation and Aerial Work operations by the Authorities; Whereas: there is a misconception that General Aviation and Aerial Work do not contribute their share in the CNS recovery of infrastructure costs; Whereas: IAOPA firmly believes that users should only pay for services the receive and require for their operations; Whereas: DOC 9632-C/968, concerning taxation in the field of international air transport states that the ICAO policy shall apply whether an aircraft is engaged in an individual flight, or in the operation of an air service, and whether or not the operation is for remuneration; Whereas: the ICAO policies in clauses 1, 2 and 3 make the resolution applicable to all aircraft engaged in international operations, scheduled, non-scheduled and private flights; Whereas: the majority of our members fly aircraft which use aviation grade fuel, and in most countries this fuel is subject to taxation, whilst commercial aviation primarily uses kerosene which is exempt from tax; IAOPA(EUR), at its 97th Regional Meeting, Resolves: that in the countries where aviation fuel is used by General Aviation and Aerial Work operations, and is subject to the payment of fuel tax, this revenue should be collected and invested in the aeronautical infrastructure and towards the services supplied and used by General Aviation and Aerial Work operations. Furthermore: IAOPA(EUR) requests that all individual European AOPAs encourage their Authorities to follow this line.