GA Alliance of whom LAA are a member has responded to this. The consultation is very much based on the proposals arising from the Sir Joseph Pilling Report following his Strategic Review of CAA in 2008. We have concerns that it is almost impossible to evaluate the effect of this proposal on our (GA) sector which is mentioned only twice within the document – once being in the context of charging GA for the costs of the CAA’s enforcement activities! The principle of the proposal is  “…. placing the consumer and the environment at the forefront of the CAA’s decision making, while maintaining the CAA’s emphasis on safety”. We believe this potentially creates an unprecedented conflict of interest between a safety and customer mandate which has not been adequately discussed with GA in the context of the Pilling review. The void of any discussion, post Pilling and before this proposal was issued, is of further serious concern. In addition, for our sector there is no explanation, or consideration as to how GA fits into the apparently dual consumer/safety arrangement which is clearly focused on commercial, not sports and recreational activities. This whole lack of consultation is underwritten by impact assessments within the consultation which largely state “not available” or “to be advised”, rendering them useless in a consultation context.

Actually we are saddened by this. We have gone to lengths to develop close working relationships with DfT (who issued this consultation) as well as CAA both as a self initiative and as a result of the post Strategic Review General of Aviation published in 2006 in which we, together with other GA and Sports and Recreational bodies, were heavily involved and invested much time and effort. We could then, we believe, reasonably have expected pre discussions on this, which has been the case on other matters in recent times. Our needing to object to such a consultation is in fact a failure of the consultation process on this occasion.

For detail of responses see www.gaalliance.org.uk under the section “Position and Data Papers”. This matter was recently the subject of a question in the House of Lords on 30 March when Lord Rotherwick tabled a question “ ….  to ask Her Majesty’s Government whether the consultation on proposals to update the regulatory framework for aviation complies with the criteria set out by the Better Regulation Executive” A WAV file of this is available here. The respondent is Lord Adonis (Secretary of State for Transport)