Use this forum to flag up examples of red tape and gold plate
By Arnold Rimmer
#1363103
GOLD PLATING. Months ago I emailed. Martin Robinson of AOPA was supposed to be involved in assessing the submissions identifying gold plate and the CAA was going to respond.
So far, I can't find anything.
Is this something that has been swept under the carpet?
By Mick Elborn
#1363149
Arnold, you are right. CAA asked Martin if AOPA could provide a portal for people to raise Red Tape issues, which we did here on the aopa website. CAA promoted it.

As I understand it, Martin reviewed and collated each of the issues raised ( the online form collected a whole 11 genuine ones in total) and made these known to the CAA. What they did with them I don't know, but possibly have been incorporated into their thinking. These are the subject areas raised online :

The requirement to renew an MEP rating or an I/R that has lapsed by one day to be carried out at an ATO.
EASA permit renewal
EASA permit aircraft maintenance
CAA PPL licence application
CAA Publication Subscriptions - Document Notification Service
The Permit renewal for EASA Permit aircraft
EASA minor mod process
Annual permit process for EASA permitted aircraft
The JAR Med colour vision requirements.
Licensed aerodromes and the AIP and NOTAM system
Inner Area Airspace at London Heathrow CTR

How these have affected the CAA's Red Tape Challenge report or their approach to EASA I don't know.

If you sent emails rather than use the online form then I suggest that you follow up with whoever you sent them to.
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By trevs99uk
#1363973
I sent about 5 GoldPlating requests to nogoldplating and have never had a response to any of them.

First one was for hours flown in Microlights to count towards SEP hours.

Second one was ref 8.33 khz radios from 2018.
And funny enough i read this on Eurocontrol website today. Which means the CAA are Goldplating this one as they could allow exemptions, particularly to General Aviation.
The main message focused on the mandatory implementation dates and the requirement to retrofit all aircraft with 8.33 kHz capable radios by the end of 2017. It was also noted that Member States could potentially apply exemptions to the implementing rule; these exemptions are expected to be managed at national level.

Have to look back through my email for the others.

Would like the CAA to issue a listing of all the responses they had to NoGoldPlating.
And why they rejected some, i presume that's why we've not heard anything..

trevor
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By The Westmorland Flyer
#1365031
trevs99uk wrote:Second one was ref 8.33 khz radios from 2018.
And funny enough i read this on Eurocontrol website today. Which means the CAA are Goldplating this one as they could allow exemptions, particularly to General Aviation.
The main message focused on the mandatory implementation dates and the requirement to retrofit all aircraft with 8.33 kHz capable radios by the end of 2017. It was also noted that Member States could potentially apply exemptions to the implementing rule; these exemptions are expected to be managed at national level.

I have been banging on about this on these fora and in my communications with CAA SARG for the past year or two.You are absolutely right that the Eurocontrol regulation permits local variation that could, for example, mean that the vast majority of GA would not need 8.33. You are also correct that the CAA is manifestly ignoring this derogation and I can see how that could be interpreted as gold plating.

Quite why the CAA is behaving in this way, with the obvious safety implications of low end GA pilots/airfields deciding to go non-radio rather than chuck out perfectly serviceable radios is hard to fathom.
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By Pete L
#1365166
Talking to Phil Roberts at the GA day, I don't think they're ignoring the possibility - the impression I got was they don't have a good answer yet.
By Arnold Rimmer
#1365340
On 8.33, I refer to the comments I have made before. If Ofcom are making huge amounts from licensing 8.33, the CAA are unlikely to opt out of implementation and deprive the Government of income.

This is another issue dragging on far too long without any sign of sensible decisions being made.
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By The Westmorland Flyer
#1365348
But Ofcom isn't making huge amounts from 8.33. On the contrary, an 8.33kHz channel costs exactly one third the amount charged for an equivalent 25kHz channel. It is a rather odd by-product of the topsy turvy world that has allowed Ofcom to get away with applying spectrum pricing to an internationally protected chunk of radio spectrum.

The combined, and entirely unique to the UK result is that it is in airfields' commercial interests to go to 8.33kHz but that is more than offset by the immense cost to the dozens or even hundreds of aircraft owners who have to replace their serviceable 25kHz kit.

You're right about it dragging on though.
By Arnold Rimmer
#1365360
The Westmorland Flyer wrote:But Ofcom isn't making huge amounts from 8.33. On the contrary, an 8.33kHz channel costs exactly one third the amount charged for an equivalent 25kHz channel.


But if 8.33 was not being introduced, would Ofcom be increasing the price for 25kHz channels to push people to 8.33??
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By Keef
#1365410
From the original OfCom proposal to price for the airband spectrum, which was absolute twaddle (I've still got a copy here, together with the long response a group of us wrote), it's clear that OfCom have no interest in safety, efficiency, or anything else. They're a pure tax-collecting body with a very high target income. They're not going to be deflected, regardless of the damage done.

The CAA seems to have little say in what OfCom gets up to, however daft and counter-intuitive it may be. 8.33 was the perfect excuse to charge three times the base price for a 25kHz channel, so they did.
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By Pete L
#1365919
We've all got a golden opportunity to badger our politicians for the next four weeks. They won't remember you on the doorstep - I can just imagine the response from our local Green Party candidate - "What's a kilohertz and why would you want more of them? Is it sustainable?" but it might remind you to fill their postbag afterwards - constituency MPs are fairly diligent about chasing that sort of stuff up. Other than that, its whoever, if anyone, is the next minister for GA.
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By kanga
#1366034
Keef wrote:..it's clear that OfCom have no interest in safety, efficiency, or anything else. ..

The CAA seems to have little say in what OfCom gets up to, however daft and counter-intuitive it may be....


.. because this reflects the remits drafted for both by Treasury, given to them by Ministers, and approved by Parliament (as Primary Legislation was needed to establish both). There's only one way whereby those remits can be changed .. :roll:
By Arnold Rimmer
#1382857
Has anyone seen anything more on this? Are the CAA or AOPA going to address any gold plate issues?

Now Grant Shapps is Minister of State for International Development, have we lost one of our advocates?
By James Chan
#1384700
Not specifically in relation to the above but the event at Duxford earlier this year promised a fresh look at many things and a real focus on GA. I sort of got the hint that we needed to bear with them initially while they address their huge plate of issues and not get all upset and angry before it has even begun. If you want a further update I suggest you contact Martin directly.