Balloon Repair Station

Fighting the good fight in Rome – Don Cameron addresses EASA

1 Cameron Concept G-CERHThe 2014 EASA Annual Safety Conference took place on the 15-16 October at Radisson Blu Es Hotel in Rome and as EASA’s widely publicised ongoing efforts towards creating a ‘simpler, lighter, better regulatory framework for General Aviation (GA)’ this formed the basis of the Conference’s debates, lectures and discussions. The two day conference, one of the biggest involving GA to be conducted in Europe, involved over 50 speakers addressing more than 350 attendants, representing 250 organisations from 30 countries, all related to GA including associations, industry and authorities. During the conference a series of Panel Discussions took place addressing a range of important themes including Pilot Licencing, Airworthiness for small aircraft and other elements of EASA’s infamous GA Roadmap. EASA reported that ‘The panels provided a forum for fruitful discussion, with the participation of a varied group of speakers drawn from all areas of the General Aviation Community including, Regulators, Clubs and Associations and Industry. The conference closed with Patrick Ky presenting the Six Commitments of EASA to the rest of the GA community’.

Don Cameron had been invited to speak at one of the eight panel discussions and, as luck would have it, and it has always been the case that being in the right place at the right time has produced some of the best results, when he turned up at the hotel to check-in he bumped into Andrew Haines, head of the CAA, Tony Rapson, important person in the CAA and none other than Grant Shapps, the MP responsible by shaking up the CAA and demanding that they get on with the Red Tape Challenge and the current Chairman of the British Conservative Party on the way out for some nosh. He was invited to join them for dinner so dispensed with the booking in paperwork and had their collective arms off. The dinner was spent discussing the plight of the balloon industry, the sport and General Aviation in general and, as a result, when Grant Shapps stepped forward to deliver the speech that opened the Conference on the Wednesday morning the contents not only echoed the discussions from the evening before but left the audience in no doubt that it was clearly aimed at the failings of EASA in the way that they have treated General Aviation and those in the industry and if GA was to continue then something serious had to be done.

The discussions and speeches that followed focused on the need to have proportional rules. Patrick Ky (EASA’s Executive Director) said “We are creating a more proportionate framework, focusing on safety culture, safety promotion and common sense! We are in the start of the process and I believe we are on the right path. During the conference we showed the first concrete results of our determination and used the opportunity to listen and discuss with the whole General Aviation community”. For the future he said “In six months we will give the next progress report at the AERO 2015 exhibition.”

The EASA Safety Conference Rome 2014 Report by Don Cameron
The EASA Safety Conference took place on 15 and 16 October 2014. Its subject this year was General Aviation and the slogan was ‘Towards simpler, lighter, better rules for General Aviation’. The unanimous views expressed were that EASA had done a very bad job for general aviation, even the EASA people agreed that change was needed.

I spent the evening before the conference with Andrew Haines (CEO of UK Civil Aviation Authority), Tony Rapson (Head of General Aviation at CAA), Grant Shapps MP (Minister in UK Government) and, for a short time Patrick Ky (Head of EASA). I was impressed by the determination of these top-level people to do something about the wave of bureaucracy that has swept over us. There is a definite hope for change and I think we must thank Patrick Ky for this change of direction.

Grant Shapps MP, a cabinet minister, has been behind the Red Tape Challenge in the UK and made a superb speech to open the conference. He is a flyer himself and chooses to fly a US registered aeroplane to avoid the European bureaucracy. His speech left the delegates in no doubt that something must be done to remove the burden that has descended on the whole of general aviation since the beginning of EASA.

The conference was organised as eight panel presentations. At each, the members of the panel were invited to make a statement. This was followed by discussion within the panel and questions and contributions from the floor. I was on the second panel European General Aviation ‘A diverse landscape’. My opening remarks are reproduced below.

Over the two days the message was unrelenting. EASA has subjected general aviation to an intolerable burden of bureaucracy which has made no contribution to safety whatever. Graphs were shown of USA accident rates which are well below those of Europe despite a much more liberal system.

There were few good words for EASA’s regulations. Steve Jones of Southern Sailplanes in the UK said he would be different and say something good about EASA regulation. It had made several of his competitors give up in frustration! But his gain was not so great, because the customers too were giving up in frustration. He asked, “Is this what they really intended?”. We must now wait and see what will happen. There was widespread agreement that something must be done to produce simpler, lighter, better rules for General Aviation. We must now make sure that it happens.

EASA Annual Safety Conference address by Don Cameron at the Second Panel
EASA has been a disaster for sport ballooning. The increase in regulatory burden, none of which has added anything to safety, has threatened to kill our activity. Older balloonists are giving up and younger ones are not entering the sport due to the burdens. Costs have increased beyond recognition. If the latest pilot licensing proposals had gone ahead, the cost of sport ballooning would have risen even more. It costs about 180 Euros per hour to actually run the balloon. On top of that it would have taken 360 Euros per hour to satisfy the regulators, a tripling of costs. This does not count the waste of time which would have been caused. Its cancellation is a relief.

Balloons are simple devices. They are little more than bags of hot air controlled by a few ropes. They have been flying for 231 years and they do not resemble aeroplanes in any way. I have to keep reminding people of this, “They do not resemble aeroplanes in any way!” They have a lower fatal accident rate per million hours than any other form of sporting flight. They do not need the regulations that have been developed for aeroplanes. Other sports like sailing, mountaineering and horse riding are more dangerous, but do not have to suffer aeroplane rules. Despite this, we have always suffered from aeroplane rules, inappropriately applied. In the UK, this had been moderated by detailed negotiation between the CAA and the British Balloon and Airship Club over many years, treating every issue in detail, one by one. Practical arrangements had been achieved.

The arrival of EASA has been a disaster. EASA has imposed rules, not only designed for aeroplanes, but rules designed for commercial airliners. One burden is imposed after another; one cost after another; one waste of time after another, with no contribution to safety whatever.

There are burdens on manufacturers. Where we needed one approval, we now need four. For each, we must spend hours creating completely stupid expositions, hours in discussion with officials and hours following bureaucratic procedures. And, of course, paying fee after fee after fee. How astonished we were to discover, after we had gained EASA approval to manufacture balloons, that we needed further approvals (and further fees) to repair them - something we had been doing for the previous 30 years.

There are burdens on maintenance. Part M has been utterly inappropriate for our sport. Inspectors, who worked as volunteers before, now have so much bureaucracy that many have resigned and those that remain will only work for money. The need to have an ARC is complete nonsense, it is a certificate to certify that there is a certificate!

We had voluntary airworthiness control in the UK for 40 years and there was no accident which greater control could have prevented. Most other European countries during that time had compulsory airworthiness certification. The result was that most of the innovations took place in the UK and the safety culture evolved by the British Balloon and Airship Club was the best in Europe. Most of the world records were achieved by British pilots or in British-built balloons. Special-shape balloons were first produced in the UK. Hot-air airships were first produced in the UK. Large balloons for passenger carrying were first produced in the UK. This is not because the British are more intelligent than people in other countries, it is because freedom allowed progress to take place. How big a field experiment does EASA need?

The latest proposal, thankfully cancelled, was for many new burdens on pilot licensing. The excellent safety record of balloons has been achieved by learning with friends and passing a check flight. EASA proposed that all instruction must be with a qualified instructor who will have to be paid. Every instructional flight would be recorded in a central ATO where an administrator would have to be paid. Even after gaining a licence they wanted regular flights with a paid instructor. Yet they are quite unable to point to an accident record which would make this necessary. This has now been withdrawn, but only after much trouble and expense had been incurred.

A supreme example of incompetent regulation was the proposal for pilots’ medicals. It had been proposed that balloonists should have a Class 2 Aviation medical which costs about €200 and a day’s work lost. Balloons have been flying for 231 years and there has never been an accident due to a medical cause. Once again, how big a field experiment do they need? It is not just a statistic, there is a clear physical reason, because an aeroplane landing without control is likely to be fatal, but that is not true in a balloon which will descend at a speed that is unlikely to cause injury. There is one case of a medical incident in a balloon. In the USA a pilot died while in flight. The balloon came down and the two passengers were unhurt.

This is an example of lazy and incompetent regulation. It would take only a few hours to understand the history and the difference in risk between aeroplanes and balloons. But instead of taking that trouble, they proposed regulations with a wave of the hand, costing balloonists hundreds of thousands of Euros.

I was shocked to hear one of the regulators at a recent meeting saying that ballooning was one of the most dangerous forms of flight. In fact, the opposite is true. Some figures from the commercial balloon scene are;
In UK, 1 fatality from an estimated 1,440,000 passenger flights = 0.69/106
In Turkey, 4 fatalities from an estimated 3,600,000 flights = 1.11/106
This is far better than any other form of sporting aviation and comparable with some airlines. To be making regulations while so utterly ignorant of the statistics is disgraceful. Of course, these statistics are for fatal accidents I do not have the data for minor accidents, indeed there are those who say that every balloon landing is a minor accident!

I have to say that I am totally unhappy, even angry, with the regulations that EASA has produced. But some of what I am hearing over the last few months seems to say that many in EASA now realise how dreadfully wrong they have been and that a lighter touch is needed. The words I hear are good. I can only hope it will be reflected in reality.2 Bristol 2014

You can access all the Panel Presentations and the Agenda from the Download box at https://www.easa.europa.eu/newsroom-and-events/events/2014-easa-annual-safety-conference. For further information about the conference you can contact ilias.maragakis@easa.europa.eu

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