National Aviation Policy 2019 and Failure of Aviation Industry

Many of the Aviation companies in General Aviation have closed since the inception of NAP 2015 and thereafter its revision in 2019. The policies focus on the facilitating the investor but have excluded the entrepreneurs.

The investors also run away once they see a complicated system where they cannot start the business even in two years time frame. The industry is made so difficult and such systems have been developed which are not business friendly and ease of doing business is far fetched thing of the unknown.

We being the member of Aviation Over Sight Committee of Pakistan have suggested following changes to National Aviation Policy in March 2021 but to our surprise most of the SROs which were issued to facilitate the industry were cancelled in 2021/2022 budget so we are not likely to see any developments in the Aviation Sector in near future which definitely has the potential to create jobs and a big economic opportunity.

CAA (Air Transport) Licenses Issuance, Security Deposit and Security Clearance

Air Transport Licenses be issued within 72 hours and process must be made easy, the Economic Regulation system is too complicated, it should be left to the business owners and the required documents be reduced. Just the current audited financials should be sufficient to evaluate the financial position if the investors and it should be left to the business owner to evaluate his or her own investment.

The security deposits are very hefty. The aircraft operate only from Pakistan Civil Aviation Authority (CAA) airports, incase of defaults the aircraft can be held back from flying till the time the CAA dues are cleared, this is standard industry practice the world over. In this way we will not block the heavy amount of the operator which will help them in running finance etc.

CAA takes notice of large-scale domestic flight cancellation

Security clearance is not bad but the time taken for the security clearance deters the businesses and it is more than a year or two in various cases. A business has a cost of doing business every day, it has rentals, salaries and related expenses with such system we can never encourage the businesses. This thing is difficult to understand once you are on the other side of the table but please realize that we didn’t have any much growth in Aviation Sector and those involved are doing it as a passion else the business sense is lagging. For security clearance etc we can ask for an undertaking that incase the security clearance is denied for any reason the business license will be suspended or revoked.

Normally it takes about a year or even more for the operator to start business once they get the Air Transport License, so what we are looking at is more than two years to just start the business with the present systems in place. At least I am not willing to recommend Aviation Business to any investor with such cumbersome systems. We are suffering here ourself as we were determined to bring our other aircraft to Pakistan and to shift the complete business to Pakistan but now we are holding back all our plans.

Student Pilot Permit or License

Worldwide it is the simple process of issuance of Student Pilot Permit or License but for our CAA it take a year or two.

Internationally after Medical Fitness for flying is determined the prospect Student is Issued a Permit or Student Pilot License by a CAA designated person in the Flight Schools. The details of the process is available on TC website, most of the countries follow this including the one where 9/11 happened. We can continue to seek security Clearance from the agencies and ask the Student to Submit an undertaking that if clearance is denied his privileges of SPL will be revoked and Commercial Pilot License will only be issued once security clearance is received (if at all its needed).

Last year we lost a big contract from China for the training of pilots for an airlines as they couldn’t understand about the lengthy process for issuance of visa and student pilot permit and instead opted for USA for the training. Definitely it resulted in loss of foreign exchequer and several jobs in a much needed Pandemic time. That particular contract could have been sufficient for the survival of all the flying schools in the country for the years to come.

One WINDOW Operation

PCAA may appoint a POC for all operators and prospect operators which may be made responsible to communicate on behalf of CAA for any department and should provide a solution to the problems in 24 to 48 hours after due communication from the concerned departments of CAA. At present it is a difficult process since we have to deal with so many departments separately for our different requirements and no one is comfortable in this regard.

Another bird-hit incident at Karachi International Airport
Bird-hit incidents with the PIA aircraft on the rise
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Aircraft and Parts Import

It is mentioned in Both NAP 2015 and NAP 2019 that parts import is free and some aircraft can also be imported without Customs duties etc. This may be made a part of Customs Policy else all efforts will be futile. For AOG once we work internationally, we pay thru credit card and ask some one to fly immediately with the parts, we call it onboard courier. This way we recover the grounded aircraft in few hours. Please also add in Customs Policy that payment proof to be accepted by custom once its made thru credit card or by any bank transfer means.

Similarly, the Customs Policy may please be amended thru Ministry of Finance for Import of Aircraft and Parts at no duties etc and clearance be facilitated on 24/7 basis so that aircraft ground time is reduced to Minimum. Operators be permitted to the carry the possible parts on board in any incoming flight with its representative carrying them if needed. Whatever facilities were given earlier have been withdrawn in the previous budget so a continuous negative growth is likely to continue.

Aircraft Age Restrictions

We are a developing Nation and aircraft age restrictions are even not applicable in USA, Canada or Europe. For any Aircraft the age is not an issue for keeping it in Airworthy condition, the aircraft is air worthy by following Maintenance Planning Document (MPD)/Aircraft Maintenance Program (AMP) provided by the Manufacturer. If that program is followed the aircraft is fit to fly.

Still if this restriction is required for some reason that are not understandable to aviation community at least as the life of aircraft cannot be determined with its age, some time the aircraft has just flown less than 10% of its allowed flight hours life on its airframe and is in storage for long time, on which the operator can get a good deal on price so we may impose the restriction that at least 40 to 50 % of the life must be remaining on Airframe, the engines be excluded as engine are a replaceable part or we can say minimum 50 % engine life should also be remaining or the engines should be on some overhaul and replacement program like JSSI/Aviall (CAMP) which guarantees engine overhaul or replacement etc.

CAA Licensing Exams

A time limitation may kindly be added for developing our own Licensing Examination system as outsourcing to UK will not be cost effective for Student Pilots or the Pilots. Moreover, an out sourcing which drains the foreign exchequer should not be acceptable and it’s also worth mentioning that it’s being done in violation of PPRA rules.

TPRI and Airlines

Restrictions on operation for only three sectors be lifted from TPRI License as for a small aircraft operator it is only possible to operate from its base. If operator is based at XYZ station he be allowed to operate on as many station as he may deem fit commercially. With this the limitation of operations on socio economic routes from Airlines be lifted. As Airlines are not obliged to operate on Socio Economic routes once it is not commercially feasible for them. However, an interline or code sharing between the TPRI and Airlines be encouraged to create a win win situation for all.

Bird hit cases on the rise, Wake Up CAA!!
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Open Sky Policy

It has only helped the foreign Operators to uplift the maximum passengers traffic load from Pakistan and the beneficiaries were the handling companies that to just a small piece of cake as for as Pakistan is concerned. Bilateral agreements may be revised so that we provide an opportunity for growth to Pakistani Operators.

General Aviation/TPRI

  • No aircraft Age Restrictions at all.
  • NOC for import of aircraft be given in 03 days and DG CAA may have the authority to issue NOC for such import.
  • No any kind of fees / taxes be applied for import or operations for any aircraft with 19 or less seats.
  • Flight Checks by CAA inspectors abroad.
  • No CAA inspector should go for Simulator Checks of Pilots as the inspectors are less qualified than the pilots and a Flight Simulator instructor of the facility abroad actually conducts the test and CAA Inspectors just MONITORS it with a heavy cost to the operator without any gains on Safety or Quality.

Burdon of CAA staff Training

No CAA Pilot or engineer be trained on owner’s or operator’s expense. If CAA wants to train its people than CAA should pay for that. If GCAA, UAE sends its staff they do it on their own expense and nothing is charged to the operator. This is a burdon on ooerator without any gains on Safety or Quality.

Issues and Shabby looks of General Aviation Area, JIAP, Karachi

We have space available in General Aviation Area at Karachi, it needs some development. Sewerage system is bad that a lot of rain water accumulates in GA and protection of aircraft becomes difficult. This may be improved and space created for more businesses. Electricity connection and per unit rates are very high. To avoid heavy charges we opted for solar and wind power energy and are a 100% green aviation company of the world, hence, the rates of electricity needs to be rationalized.

PIA Boeing 777 gets stuck on runway at Lahore airport
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Expensive lease rates

  • For General Aviation Development the rental/lease amount may be reduced to 50 % or even less.
  • Allocated facility and operator’s aircraft may not be restricted for any promotional activity as we are living in an era of social media and everyone carries a camera, once we are less restrictive and open, it will pave the way for the promotion of Aviation Industry.
  • Car Parking space in GA, Karachi is limited, it may be increased and Junk aircraft removed from General Avn Area. Public Toilets are not available in any GA, the one which were available have been restored by us.
  • Operator’s may not be harassed by frequent visits of Commercial and Vigilance dept.
  • We intend to establish state of the art FBO facilities at Lahore, Karachi and Islamabad as per NAP 2019 but despite our application for space allocation at Lahore the needful has not been done for months. Ease of doing business lags and prevents the growth in Aviation Sector.
  • Flying Schools just have one area for training(Steel Mills/Gharo) so we face a lot of restrictions on flying and valuable time is lost. 04 Training areas be established in the surroundings of Karachi and AIP may be amended accordingly.

Air Operator Certificate and it Renewals

Internationally, the AOC renewal inspection is done every two years and during this, after one year only one CAA representative visits the schools for verification of returns submitted and for surveillance audit for a couple of hours, similarly on second year audit only two officers i.e one from Flight Standards and one from Airworthiness do the audit but for us for a flying of 02 or 03 aircraft 10 plus officer are detailed by CAA which is not required and for those who are out of Karachi it becomes very expensive to pay for the airline tickets and accommodation for them.

World over General Aviation is not as restrictive as we have in Pakistan which has stopped the growth rather it is in negative growth, for example in USA and Canada if an advisory is issued by manufacturer as a recommendation we implement it as a compulsion. The typical example is one of our aircraft in Canada has flown more than 4000 hours without the need for its engine to be overhauled, a manufacturer only recommends an overhaul after 2000 or 2400 hours (TBO) on piston engine and if engine is running perfectly the A & P engineer (AME) certifies it for another 50 hours with certain checks and we are good to go without even going back and forth to CAA.

Efforts may be made so that our license for engineers is accepted under the gambit of ICAO the world over.

Foreign Training in Approved Facilities

If any required course/simulator training is done any where in the word and the concerned country is an ICAO signatory and that has approved the organization where the course/simulator training is done, it may be acceptable to our CAA without the need of the audit of that particular organization which is already approved by concerned CAA/NAA(This is industry practice the world over).

Type Course for Engineers

Type course for engineering training on many general aviation aircraft are not available any where in the world and we have made it compulsory for even Cessna 150/152. The type course requirement on any aircraft of 5700 KG and below MTOW be finished and should be based on the experience and in house training by MRO / AMO like it was being done previously here.

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Simulator Training

GA simulators are not available in the region, the simulator training is required every six months which becomes more costly than the flying itself. The similar training under the supervision of a DCP on the type aircraft with actual flying be considered as the replacement of simulator training. The DCP system be incorporated at the earliest so that the checks of the pilots can be conducted without the need of the audit of that particular organization which is already approved by concerned CAA/NAA(This is industry practice the world over).

Aircraft Induction

The induction inspection of the aircraft should be made optional for the importer of aircraft that it can be done either in Pakistan or Abroad.

AVGAS

AVGAS is not a regulated product as fir as the OMCs are concerned. This product may be added in Customs policy for duty free import by General Aviation companies to reduce cost of operations/pilot’s training substantially. The price in the international Market at the moment for AVGAS is Rs 158 per liter but as of today in Pakistan it is Rs 325 to 350 per liter.

Without such bold steps any Aviation Policy will not work in developing the Aviation Sector in Pakistan.

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