Use this forum to flag up examples of red tape and gold plate
By berbles
#1704851
Here’s one for the CAA Red Tape Challenge.....

let’s all push together at the CAA and DEFRA get this idiocy sorted out:

Our dog has a Pet Passport.

We can take him via ferry, EuroTunnel or scheduled airline abroad, and back.

BUT

Despite Oxford having all the microchip scanners and licences to allow import of dogs from Europe apparently you need to have a DEFRA licence to actually carry the dog. And DEFRA licences are only awarded to commercial aviation organisations. So we can’t fly him to France in our C182 (or to be more accurate we can’t bring him back).

Now if this isn’t a classic piece of lunatic bureaucracy, I don’t know what is. Surely I have a Pet Passport, I’m happy to comply with all the French vet stuff, Oxford has the scanner and the licence to use it, so what is DEFRA’s problem here?

Answers on a postcard please?
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By ChrisGazzard
#1705443
This is a really interesting one, and one I've been hammering APHA about too. It's actually an EU reg rather than a UK one, but nobody is challenging it so it just sits there.

For many years, there was no requirement to put an AOC number on the RMOP form. If you take a look at the list of approved pet carriers: https://www.gov.uk/government/publicati ... pet-travel you'll see plenty of companies that no longer exist. You'll also see plenty of management companies that don't have an AOC.

I think on the EU reg side, there was perhaps a desire to protect existing charter operators who offered pet transport. But there is also a concern that owner-pilots (or indeed truly private jets where the owner is the only person who flies and employs pilots to fly them) would either be unfamiliar with the rules, or there would be disregard for the rules when it was inconvenient for the owner (can't find a vet that's convenient, so skip the checks and hope we don't get caught). The result would be either undetected animals coming through, or pets that don't have the correct paperwork.

By requiring AOC operators to be pre-approved this adds a neutral check. As an AOC operator, I would not want to jeopardise my ability to carry pets altogether for one client who can't get their paperwork in order.

There's also the issue of Aerodrome security measures, many of the approved airports, such as at Blackbushe, don't have a monitored airside / landside point. A pet coming in on a C172 could go undetected. This is of course the case regardless of an approval process though.

But the real interesting one comes with management companies like FlightWorx etc. They don't have an AOC, and so any of the aircraft they manage that aren't on an AOC elsewhere cannot carry pets into the UK. If I am Mr Private Jet Owner with by M-Registered CJ3 for example, if I were to get this aircraft managed by an AOC operation, such as TAG or LuxAviation, regardless on whether my aircraft was actually on the AOC or not, I could bring my pet in, as all the paperwork would have the AOC holder's details on it. And APHA are clueless to distinguish the difference.

I would argue that the ops team at FlightWorx are at least as competent as the ops teams working for many AOC holders, and so it seems odd to me that they aren't able to submit an RMOP for approval. Of course this wouldn't necessarily solve your problem in a C172 though!

Colonel Panic wrote:I'd wager that it is the inability to monetise your solution that will prevent DEFRA from enabling it.

Actually there is no charge to AOC operators to register an RMOP. APHA / DEFRA make nothing from it. The pet fees you pay to aerodromes are there to cover the staff time used in processing the pet, and recoup the investment in scanners and the mandatory quarantine facilities they require us to build and never use.
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By Flyin'Dutch'
#1705525
ChrisGazzard wrote:This is a really interesting one, and one I've been hammering APHA about too. It's actually an EU reg rather than a UK one, but nobody is challenging it so it just sits there.


EU regulation? Are you sure.

I can ferry the muts between the rest of the participants of the EU project sans any problem.
By johnm
#1705531
The pet passport rules I think are EU, the limitation on entry and exit routes is UK as far as I can tell. It will be changed depending on how Brexit goes of course....
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By ChrisGazzard
#1705599
Flyin'Dutch' wrote:
ChrisGazzard wrote:This is a really interesting one, and one I've been hammering APHA about too. It's actually an EU reg rather than a UK one, but nobody is challenging it so it just sits there.


EU regulation? Are you sure.

I can ferry the muts between the rest of the participants of the EU project sans any problem.


I know but it comes down to the EU definition of “carrier”. This is what I had from APHA:

“Air carriers operating for hire and reward are required to hold an AOC and Operating Licence. Any air carrier applying for an approval should be able to produce copies of both of these documents. Unfortunately it is not possible for a private individual to become an authorised pet carrier as the Non Commercial Movement of Pet Animals Order Art 2 defines “carrier” and Art 11 defines “approval of carriers” which effectively refers to “carrying goods or passengers for hire by land sea or air “.

The requirement for an AOC has always been in place and was the responsibility of the recommending officer to have this checked prior to submitting the RMOP to ourselves for approval. However, we became aware that this was not always the case therefore including it on the PT19 as a mandatory requirement to be completed.”
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By ChrisGazzard
#1705707
Wierd.... Are APHA reading this? Got this email this morning which seems timely:

Good morning

We are currently looking to update our GOV.UK website and in particular “Approved Routes” for airlines and pet travel. A link to the webpage is attached.

https://www.gov.uk/government/publicati ... pet-travel

Please can you review the companies that have approved routes into your airport and that you have agreements with. We would be grateful if you could email us back confirming which companies still fly into your airport and which have ceased.

We would appreciate replies by the end of business on Friday 26th July 2019.

Any questions or queries please contact us.

Thank you

XXXXXXXXXXXXX
Admin Officer
Imports Team
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By berbles
#1705920
That creaking sound you can hear is the can of worms opening.....

Reading between the lines it looks like the requirement for an AOC was never stated at the start of the process but has become assumed over time and by default become embedded in the process.

There is no good reason why an AOC is required provided the receiving airport (in this case Oxford) have the necessary facilities (which they have and they have said are quite happy to process our dog). Why not simply add it to the GAR before you return (dog name, pet passport number, status = Crew, you know...) and then DEFRA or whoever can attend if they feel in the mood like the Immigration people do.
Of course there is a risk unscrupulous operators will sneak dogs in but no greater than the risk of people sneaking in immigrants via GA aircraft, which the GAR system is there to combat. Simply ensuring all dogs arriving in the UK pass through an authorised airport e.g. EGTK should close that door.

I’m sorry, I just don’t see the rationale behind the law as it stands.

And it can’t be an EU thing: they don’t care about us taking dogs in to the EU, it’s us that care about people bringing them back.

Sounds like a wonderful example of exactly what the CAA Red Tape challenge is there for. Anyone care to take up the challenge? :D :D