A Wish List

On February 10, 1929, J.R.D. Tata became the first Indian pilot to obtain a licence. In 1932, he founded Tata Airlines, the first in India and laid the foundation of commercial aviation in the country. Tata Airlines, rechristened as Air India, was taken over by the Government in the post-Independence era and for some inexplicable reason, continues to survive. However, long before Tata Airlines launched scheduled operations it was operating a mail service to Karachi. Thus, Business Aviation (BA) in India is older than scheduled commercial operations. And if 1932 is taken as the beginning of BA in India, it is 82 years old.

While scheduled commercial aviation has generally been thriving, BA in India remains in the dumps. The reasons are plenty and most are no secret. Resolution of most of the issues needs no advanced problem solving skills. This article identifies issues that plague BA in India and suggests remedial measures without indulging in a blame game.

The Issues

The Indian civil aviation industry today can be proud of a reasonably vibrant Directorate General of Civil Aviation (DGCA). It is staffed by capable and dynamic flight inspectors under the leadership of Captain Rajiv Gupta, the Chief Flight Operations Inspector (CFOI). Working beyond the call of duty they are always eager to help. However, they are understaffed and are short of resources. But it was heartening to hear on the phone that the CFOI had a clean desk with no pending files. Surprising efficiency! And then blaming the bureaucracy for all ills has become fashionable. Not this once, as every protagonist here is a ‘field guy’ with bags of experience, positive attitude and a feel for the problems. There is light at the end of the tunnel.

A well-formulated Civil Aviation Regulation (CAR) is always a good starting point. The DGCA has laid down a CAR that covers both scheduled operators and Non-Scheduled Operators Permit (NSOP) holders. There is no CAR for private operators. As a result the NSOP holders are stifled and the private operators are at sea. Operations in BA are generally constrained, and ‘private operations’ flirt on the border of illegality. The Business Aviation Operators Association (BAOA), an organisation representing the interests of BA, has recently submitted a draft CAR for approval by DGCA. This is awaiting incorporation.

Flight and Duty Time Limitations (FDTL) are stipulated to protect the interests of the fare-paying passenger. However it has no locus standi the world over when it comes to ‘private operators’. By applying the same yardstick across the board, the regulator is displaying a degree of shortsightedness. BA operators don’t operate to a schedule. Of necessity, their operations need to be flexible. After all, business aircraft are bought for convenience; shackling them defeats the purpose.

As recently as December 10, 2013, the regulator issued a CAR on Adverse Weather Operations (AWO). The CAR raises the operating weather minima for BA operators by 400 metres for Runway Visual Range (RVR) and 100 feet for Decision Altitude (DA) and Minimum Descent Altitude (MDA). This is over and above the minima laid down for scheduled operators and is called the ‘Restricted Minima’. This was earlier 100+ metres for the RVR and 50+ feet for DA. The training of BA pilots, both initial and recurrent and currency requirements are common with airline pilots. Hence a restrictive operating environment for BA pilots does not make sense.

Advances in technology and evolution of aviation think tanks the world over have led to the minima being lowered. Raising these in India is regressive pushing the system back by more than a few decades. In the United States, BA pilots are allowed to continue approach for landing down to their minima even if the weather is below authorisation. In case the pilot can discern the required visual reference, they are allowed to land. Informally this is called a ‘look see’ approach procedure and open to only BA pilots. Imposing additional restrictions on BA pilots in India is reflective of a Third World syndrome.

BA operations are generally on a small scale with restricted manpower and infrastructure resources. Due to their size, investment and purpose, BA operations need to be ‘lean and mean’. The scheduled operators on the other hand, are well staffed and have huge resources at their disposal. To expect BA operators to adhere to the same regulations as the airlines is unrealistic and kills the goose that lays the golden egg. Typically, BA operators in India have just one or two aircraft. For them to employ a Flight Safety Officer or a Security Officer does not make sense unless the regulator intends to create avenues for employment. To expect a single aircraft operator to write a flight safety manual and a security manual and obtain approval by the DGCA where a large number of such manuals are pending for more than two years due to shortage of manpower, is unrealistic. All these are cost-additive and only accelerate the demise of BA operations in India.

BA operators are generally dependent on aircraft handlers or support organisations called fixed base operators (FBOs) that provide logistics, technical and operational support at outstation airfields. However, due to a lack of understanding of the requirements of BA operations, technical knowledge, training and infrastructure, most FBOs are ill-equipped to handle BA operations. None of these have aircraft towing facility. Only Mumbai has a well-equipped crew lounge. Facilities at Delhi airport are most pathetic. Even as the largest airport in the country, it does not even have a lounge for BA pilots. The only handler available at Delhi operates out of a cramped and dinghy office. Members of the crew generally wait on the roadside squatting on their baggage.

Parking for BA aircraft is a nightmare especially at Mumbai airport, as parking slots are not available at the hub of BA operations in India. Most BA operators are compelled to park their aircraft in neighbouring airfields such as Nagpur, Surat, Ahmedabad and Nasik. They have to fly into Mumbai when needed and this translates into prohibitive costs forcing several operators to close shop.

Another impediment at Mumbai is the imposition of curfew hours for BA operations. These restrictions translate not only into inconvenience for the users but also affect bottom lines in the balance sheets. Curfew hours are from 0800 to 1000, 1730 to 1930 and 2115 to 2315. As a result, pilots cannot beat the foggy conditions both in Delhi and Mumbai. Coupled with the restricted minima imposed by the CAR on AWO, operations out of Mumbai are severely curtailed. Curfew hours frequently lead to the violation of FDTL. After landing at 1930 hours pilots cannot get airborne before 0800 hours the following day. They have to per force wait till 1000 hours. BA operators will need two sets of crew to beat this situation which is unaffordable.

The already overburdened BA operators were stressed further when the government imposed prohibitive duty on import of aircraft for private use while NSOP operators were exempt. Several individuals and companies imported aircraft for private use under NSOP to evade import duty. This further complicated an already muddled industry. The list of issues is long and unending but resolution of some of these important issues may lighten the burden on BA operators.

The Way Ahead

Problems with BA operations are simple and call for simple solutions. To begin with, the DGCA could create a separate desk under a suitable official to handle all aspects related to BA operations. This will ensure that BA operations have the well-deserved exclusivity and are not clubbed with scheduled operators. The desk ought to be staffed by officials familiar with BA operations including at least three dedicated ‘Flight Inspectors’. A separate CAR for BA operations drafted in consultation with BAOA will give the intended boost to BA operations. The issues of restricted minima need to be addressed immediately. There is a provision for waiving the restricted minima on request.

It does not make sense for each operator to draft and obtain approval for its own flight safety/security/operational manuals. This will require sizeable investment in manpower by DGCA. The regulator should provide a template based on the various CARs and circulars and the operator be required to fill in the blanks only. This will dispense with the need for extensive scrutiny saving time and manpower. The DGCA needs to facilitate online filing and disposal of applications, suggestions or grievances. This will bring in transparency and eliminate middlemen and touts. This is no rocket science in today’s day and age.

Presently, BA operations require a number of permissions necessitating voluminous documentation and delay. The regulator could introduce a net-based single-permit system incorporating all requirements. It should manifest itself as a ‘bar-coded sticker’ rather than as a file or document. It would be easier for issue as well as inspection. And of course it is highly illogical for every operator to maintain a security officer. Security of the aircraft inside the airport is the responsibility of CISF and the BCAS. It should remain so. With multiple agencies responsible, security only gets diluted.

Conclusion

BA operations are not run only by the DGCA; the operator has an equal, if not greater, responsibility. Presently, most BA operations are run either by the HR departments, family loyalists or even by the Personal Assistant to the CEO. Thus the present state of affairs of BA is largely a result of mismanagement and lack of domain knowledge. Efficient and capable administrators need to be inducted to manage operations. Problems of BA operations are unique and hence need to be handled by domain specialists.

Stress, time constraints, budgets, weather, red tape and attrition are commonplace in BA operations. Talent and resources are available in abundance and hence managers need to outsource to ensure economy of scale and decongest time/resources. Managers need to invest in technology to reduce stress and in the long run, save time and money.

BA is the barometer of the economy. BA operations are not about a few billionaires jetting out on holidays to exotic destinations; it’s about wealth and employment generation for the nation. And of course BA is the manifestation of a self-confident nation in the international arena. Yes, the wish list is long and Santa needs to come quickly but Christmas appears to be far off. So it is a clarion call to all stakeholders in BA, the managements, the regulators and the pilots to come together to work cohesively towards safe and efficient operations.