A viation W atch A ction C ommittee

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					                                                                    Tel : 27-21-7041620
A viation                                                          Fax : 27-21-7032393
        W a tc h                                                Mail : awac @iafric a.com

              A c tion                                                    .O.
                                                                          P Box 14363
                     C         om mittee                                      Kenwyn
                                                                                 7790


The Commissioner
South African Civil Aviation Authority
Ikhaya Lokundiza
Building 16
Treur Close
Waterfall Park
Bekker Street
Midrand

                                                                       10 November 2006

Dear Sir,

DRAFT AIC 18.18 – COMMENTS FROM INDUSTRY

Introduction

It is with growing concern that AWAC received the draft AIC 18.18 released by the
SACAA at the beginning of November 2006. In the light that this document was
drafted in response to an agreement that was reached by the General Aviation
Council representatives and the SACAA on 19 October 2006, we deem the said
document to be out of alignment with the SACAA’s undertaking. The objective at the
Industry Liaison Forum was that the new AIC should reflect the intent of the original
AIC’s and thereby restore the status quo as it existed before the implementation of
the revised Part 43 on 4 August 2006.

The document, rather than giving relief, introduces various new requirements which
were never consulted on nor agreed upon by means of the SACAA’s obligatory
channels of communication.

Comments

The members of AWAC hereby request that the draft AIC 18.18 should be withdrawn
and the previous AIC’s 18.18 and 18.19 re-instated. The loose wording (paragraph 4
in the previous AIC 18.18 and paragraph 3.9.1 in the previous AIC 18.19), that led to
the current situation arising, needs to be corrected. We consider this necessary since
the draft AIC 18.18 changes the meaning and intent of the original AIC’s pertaining to
this matter.

Salient points which require rectification in the draft AIC are set out below.

   1. Paragraph 4‘s wording could lead to ambiguous interpretation in future.

   2. Paragraph 6 in totality is anomalous to the agreement reached at the Industry
      Liaison Forum. By restricting the use of non commercial aircraft to the
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   immediate family of the owner, it does not recognise that a large number of
   aircraft used for private purposes are company owned. A further category of
   airworthiness is also introduced which will be difficult to administer.

   The most damaging aspect of paragraph 6 is that it seeks to differentiate
   between commercial and non commercial operations. This raises a multitude
   of problems which are listed here in point form.

       •   Privately owned aircraft are used for commercial purposes as the
           need arises. This happens on an infrequent basis and therefore the
           assumption that TBO will be reached before 12 years is incorrect. In a
           similar fashion a charter operator might purchase an aircraft with low
           time on the engines but little calendar time remaining and would
           therefore face the unnecessary cost of overhauling.
       •   There is an absence of statistics that indicate that there is an
           additional risk in operating a well maintained engine past the 12 year
           limit.
       •   The proposed differentiation will be difficult to administer by the
           SACAA and large scale unhappiness with this ruling will promote a
           culture of non-compliance in an industry that is financially sensitised. It
           will require additional manpower resources from the SACAA.
       •   The re-sale value of affected privately used aircraft will plummet. This
           ruling will effectively create two re-sale markets which will result in
           major losses for those in the industry which in turn will impact on the
           ability to own aircraft of many current owners. The result will be a
           negative ripple effect in the industry.
       •    The repealed AIC 18.18 and 18.19 went to great lengths to show that
           there was no basis for implementing the manufacturer’s
           recommendation. It further did not distinguish between commercial
           and non commercial operation. We fail to understand how these
           arguments have suddenly become null and void.

   It is our understanding that the draft AIC seeks to provide relief by broadening
   the scope of exemption from the 12 year overhaul requirement. It does not do
   so since the existing legislation already provides exemption to non
   commercial operators. (CATS-GMR 43.02.8 )

3. Paragraph 7 (f) presumably should read 12 years and not 12 months.

4. Paragraph 8 (b) is laborious and intricate. It should be simplified to prevent
   confusion amongst owners and AMO’s.

5. Paragraph 11 should also reflect the SACAA’s obligation to consult before
   any changes can be made.


6. Paragraph 12 adds to potential costs to industry. It further introduces double
   standards by differentiating between properly maintained imported aircraft
   and properly maintained local aircraft. The RSA needs to import more aircraft
   to meet with the requirements of the country as set out in the next section.
   The effect of this is that the cost impact on the country will further stifle
   development of the transport infrastructure.
                                            3

Further considerations - Political/Social

In its mission statement the SACAA states,

“CAA is committed to providing efficient, effective and economic aviation safety and
security by-

1.     ensuring compliance and enforcement of regulations consistent with global
       best practices
2.     promoting voluntary compliance
3.     active participation and regulatory cooperation in AFI
4.     overseeing the functioning and development of the industry
5.     creating a knowledge base and customer-focused organization
6.     operating a sustainable business model “


It therefore follows that the following factors should be a guiding force in SACAA’s
policy formulation as it pertains to the development of the industry.

     1. “Every village should have access to an aerodrome”

                -State President – Sun City 18 May 2005

        The requirements of Nepad also suggest that the Southern African sub
        continent requires a strong aviation infrastructure which includes a strong GA
        sector. The necessity of the SACAA not creating unnecessary costs, to
        counter the further development of the only GA sector in sub Saharan Africa
        that can support the State President’s vision, goes without saying.

     2. “I have instructed the Department to examine these problems carefully and to
        report back to me because general aviation is a major source of revenue for
        the tourist trade, for business activity and charters, and as a training pool for
        future pilots, engineers, navigators and ground support staff that we cannot
        afford to lose.”

                -Min of Transport – Parliament 20 May 2005.

        Unnecessary costs such as premature engine overhaul will drain millions of
        Rands from the industry which will have an effect that is diametrically
        opposed to the Minister’s instruction.

     3. ” It can be concluded that GA is a major contributor to the South African
        economy and that aviation policy should also embrace the interests of this
        often less conspicuous, but active part of civil aviation.”

                -DOT White paper

     4. Since the decline in the number of military pilots trained, GA has become the
        primary supplier of pilots to the airline industry. Transformation is slow, and in
        order to encourage applications from trainees of previously disadvantaged
        backgrounds, GA training institutions need to keep their costs low. Costs such
        as premature overhaul of engines will become a major cost component
        thereby restricting entry of disadvantaged trainees. The misconception that
        GA consists predominantly of financially affluent participants is not assisting
        the policy makers in formulating sensible policies. Further, it should be noted,
                                           4

       the airlines are incurring substantial savings by having access to a pool of
       trained pilots from GA for their recruitment needs.

   5. The opportunity of South Africa acting as an African Nursery providing the
      aviation requirements of Africa cannot be lost given that GA in sub Saharan
      Africa (other than in the RSA) does little to contribute to the training or charter
      needs of Africa. We are presented with the opportunity of acting as a
      facilitator to re-establish acceptable standards in a geographical area that has
      attracted much negative attention with regards to safety from the international
      community.

Further considerations - Safety

The writer is of the opinion that the enforcement of the 12 year recommendation is of
sufficient financial quantum to cultivate a culture of non compliance which in turn
introduces a systemic fault which is a link in the chain of events that could lead to
safety standards being compromised.

There is already a negative impact on the training standards within GA as a result of
the cumulative effect of various costs. This will lead to further safety compromises.
Sensible policies, such as a blanket exemption from the 12 year overhaul
requirement, will be a step in the right direction.


Conclusion

“The CAA has a Vision of “Excellence in Aviation Safety, Security and Industry
Development”. “
                    - From the SACAA website.

AWAC respectfully requests that the Commisioner of Civil Aviation acts in the
National interest and re-instates the repealed AIC’s 18.18 and 18.19 to give effect to
the SACAA’s vision. Should the draft AIC 18.18 be implemented in its current form
the damage to industry will be irreversible.


Yours sincerely,




Paul Van Tellingen
Chairman

				
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