Nothing General About It!

The nation already has elements necessary to support the complete range of general aviation activities–airfields, MRO facilities and market opportunities. However, the disconnect amongst these elements needs to be bridged through regulations as also support from all the stakeholders for the potential of general aviation to be exploited in full measure.

In a broad sense, general aviation may be defined as “all flights other than military and scheduled airline flights”. It is necessary for those in charge of aviation to be sensitised on the fundamentals of general aviation as bulk of the world’s air traffic falls in this category. The disconnect within the system at all levels of general aviation is so large that it is easier to operate a scheduled airline than to run non-scheduled operations. Prospective operators give up midway out of frustration and the existing ones are in perpetual conflict with the system. It is about time the complexities of general aviation are addressed, knowledge gaps in the system bridged and dedicated regulations are put in place. Emerging markets in Tier- II, III and other smaller cities, creation of Civil Aviation Authority and implementation of policy on air connectivity to remote and inaccessible regions, are the new developments that will impact general aviation in India.

As per a report by the Ministry of Civil Aviation (MoCA), published in February 2012, the future of the country’s aviation lies in small aircraft. This is a good start-point to revisit the current regulations to facilitate general aviation. Small aircraft are a preferred choice for general aviation operators due to their low operating and maintenance cost. Regulations must enable general aviation operators to access uncontrolled airstrips across India for last-mile air connectivity. As the existing regulations for general aviation are totally inadequate, there is need for new regulations to address all elements of general aviation beginning with permission to import aircraft to grant of non-scheduled operator’s permit (NSOP) and over a dozen steps in between. General aviation is currently regulated by the Civil Aviation Regulations (CARs) that are formulated essentially for scheduled operations. The new regulations for general aviation could be titled as General Aviation Regulations (GAR). There is considerable potential for general aviation in India as is evident in the intention of the Government of Kerala to implement a seaplane project. Finalisation of civil aviation policies by some of the state governments, foreign direct investment (FDI) into Indian carriers and permission to private carriers for importing aviation turbine fuel (ATF) will definitely boost general aviation directly or indirectly. But for general aviation to grow and flourish, formulation of GAR is the only solution.

Potential for General Aviation

General Aviation Statistical Data and Industry Outlook 2012 released by General Aviation Manufacturers Association (GAMA) presents positive growth in Asia Pacific, Middle East, Africa, Latin America and negative growth in North America and Europe in respect of induction of new piston, jets and turboprops airplanes. Growth in respect of piston and turbo class of aircraft for the Asia-Pacific is stated to be 16.3 and 17.4 per cent from 2011 mark of 15.6 and 14.4 per cent respectively. GAMA represents more than 70 leading manufacturers of general aviation airplanes across the globe. Narrowing down to India, in 2012, the empowered committee of the MoCA approved import of over a dozen aircraft for both non-scheduled operations and private use. This indicates that despite the difficulties, general aviation will grow in the coming years. There is also considerable potential yet to be tapped in the unchartered territories of general aviation such as skydiving, tourism, pilgrimage, hobby flying and so forth. A common sense approach to GAR is needed keeping the geo-socio-economic paradigms in view. This will benefit all sections of the society making flying affordable and enjoyable. GAR should encourage the use of single-engine aircraft for general aviation operations as long as they are technically suitable and safe. It is only logical that due to low operating cost of smaller airplanes and with government support, operators would be able to offer affordable air travel to the masses in Tier-III, IV and V cities that are emerging as new economic centres but lack air connectivity. General aviation can also expect indirect growth due to FDI by foreign carriers.

Existing Regulatory Environment

General Aviation in India operates in quite a hostile regulatory environment. The regulatory authority is understaffed with around 35 per cent posts still vacant. As issues related to general aviation, especially in the airworthiness and safety regimes have lower priority, they are invariably delayed indefinitely. There are also some perplexing dichotomies inherent in the regulations. For example, a nonscheduled operator can fly passengers in single-engine piston airplane but cannot ferry cargo, while as per CAR Section 3 of Air Transport, single-engine piston airplanes are not permitted to operate at night or in instrument meteorological conditions. There is undoubtedly a need to formulate de novo a dedicated regulatory framework for general aviation.

Formulating GAR

GAR need to be drafted by experts from across the aviation industry with in-depth understanding of general aviation drawn from aviation-related institutes and individuals engaged in flying, training and aviation administration. GAR will lead to quantifiable primary, secondary and tertiary benefits to the stakeholders engaged in all general aviation activities and add value to the economy in the long term. GAR will complement the current and future air travel needs emerging in the wake of socio-economic paradigm shift in Tier-III, IV and V cities. As per reports, there are nearly 500 airfields in India, both operational and non-operational. There is immense potential for air connectivity to Tier-III, IV and V cities as also remote and inaccessible areas of the country that are going to witness economic resurgence. There is good scope for operating small eight- to ten-seat turboprop or piston-engine aircraft. For example, in Gujarat which has the highest number of airfields in the country, the average distance between the airfields being less than 300 nm, operating small aircraft profitably is feasible. Odisha with its 20 airfields also has tremendous potential for general aviation activities. For intra-state connectivity, 18- to 20-seat airplanes are best suited to maintain healthy ratio between direct operating cost, revenue and affordability. Role-specific short take-off and landing (STOL) airplanes are best suited to operate out of the hundreds of unused airfields in India.

Oportunities for General Aviation

Two major activities that can support general aviation are tourism and sports aviation. According to the annual report issued by Ministry of Tourism, domestic tourism registered an impressive growth in 2011. The top 10 states in terms of number of domestic tourists during 2011 were Andhra Pradesh, Uttar Pradesh, Tamil Nadu, Maharashtra, Karnataka, Madhya Pradesh, Uttarakhand, Rajasthan, West Bengal and Gujarat. Some of these states also seem to appear where air connectivity to the tourist destinations is either absent or poor. These gaps can be filled by non-scheduled operators with government support as in the case of Madhya Pradesh that has an agreement with a non-scheduled operator for underwriting a few seats for three years and the refund of value-added tax on fuel for five years. Mizoram, West Bengal and Chhattisgarh are likely to follow suit.

The potential for skydiving can be exemplified by the Sports Authority of Gujarat that supports skydiving activity. Similar models if adopted in other states will promote this activity that has many takers in India but due to lack of infrastructure and support, it is yet to take baby steps. Experts in the field are usually exservicemen who conduct skydiving courses hiring aircraft from flying schools. Surprisingly, there is no civil aircraft in the country approved for skydiving and the jumps are usually conducted from small aircraft like the Cessna-172.

Carriage of Cargo

While carriage of cargo is an integral part of general aviation, the regulations for carriage of cargo by scheduled and non-scheduled carriers are embodied in CARs that apply to both. This poses difficulty to general aviation class of aircraft in its ability to carry cargo especially in the single-engine category. Some general aviation class of aircraft are designed for multi-utility, i.e. for passenger, cargo, skydiving and medical evacuation. In other words, the aircraft are interoperable. But the CAR related to general aviation lack clarity as they state that only multi-engine, fixed-wing aircraft (freighter version) shall be used for carriage of air cargo. The CARs do not speak of carriage of cargo by single-engine fixed-wing and rotary-wing platforms. From the way the regulations are formulated, it appears that cargo is more precious than passengers as single-engine fixed and rotary airplanes are permitted to carry passengers but not cargo.

The average distance between international or domestic airport and airfields in Tier-II, III, IV and V cities is around 200 to 300 nm and as such, a hub-and-spoke model for cargo operations using smaller aircraft is a viable option. Delivery of goods or items that are time-sensitive such as couriers, parcels, vegetables, flowers, newspapers and life-saving pharmaceuticals can be undertaken between cities. STOL aircraft can operate out of the small airfields if GARs permit single-engine fixed-wing aircraft to carry cargo. This will allow operators to break even with the investment early, if carriage of passengers, cargo and other missions are permitted for the same aircraft as long as it is safe and technically permissible.

The Way Ahead

GARs should not be developed in isolation but should borrow liberally from the general aviationfriendly standards in flying, technical, and ground operations in other countries. For example a US private pilot licence holder can have a two-week self-flying holiday in New Zealand. The United States and Australia have a thriving general aviation industry and their success stories can be replicated here. Safety and training needs specific to general aviation, can be standardised. This will help aviation professionals to secure employment in the domain of flying, engineering and air traffic control.

While the traditional approach to put general aviation on fast track may take years due to out-of-sync and ‘follow the book’ mindset, an out-of-the-box approach is needed to expedite the process. One way is code-sharing between scheduled regional airlines and non-scheduled operators for the last-mile air connectivity. Codesharing needs to be extended to tour and travel operators including the government-owned transport departments across India. A new code-sharing arrangement between non-scheduled operators and the Indian Railway Catering and Tourism Corporation Limited (IRCTC) that runs tour packages will be of mutual benefit. IRCTC can offer new tour packages or destinations to existing ones not connected by rail through small commuter airplanes.

It takes up to a year to secure NSOP as approvals and no objection certificates (NOC) from various regulatory authorities are necessary. Some of the requirements are unheard of in developed countries. MoCA grants approval to import, acquire or lease aircraft; departments of the office of the Director General of Civil Aviation (DGCA) and the Airports Authority of India (AAI) issue NOCs; the Ministry of Communication-Wireless Planning Commission and Bureau of Civil Aviation Security issue licences and approvals respectively. This is an extremely frustrating and time-consuming process. The solution is to offer the applicants an online platform, an arrangement to save time and check malpractices. Applicants can monitor progress while authorities can display the shortcomings of the applicant online. This approach will also pave the way for payments and renewals of licences.

The nation already has the three elements necessary to support the complete range of general aviation activities. These are airfields, maintenance, repair and overhaul (MRO) facilities and market opportunities. However, the disconnect amongst these elements needs to be bridged through regulations as also support from all the stakeholders for the potential of general aviation to be exploited in full measure. There is an imperative need to remove the disparity in import duty on aircraft under private and NSOP categories, as also to rein in the cost of MRO attributable largely to high tax rates. This compels operators to seek MRO facilities abroad. GARs could possibly address this issue as well. Metros are not available for general aviation operations due to prohibitive parking charges or non-availability of parking slots. Thus, low-cost infrastructure at airfields in cities with emerging market opportunities need to be developed for general aviation. All said and done, general aviation is unlikely to flourish without the right level of support from the government and the stakeholders.