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Safe, Socially-responsible & Competitive Aviation – For a 3-Dimensional EU Aviation Strategy

This ECA Position Paper describes Europe’s professional pilots’ position and pre-requisites for the EU Aviation Strategy and Package that is to be published by the European Commission on 7 December 2015. 

Executive Summary
  • Europe’s aviation ‘eco-system’ will only prosper and generate jobs and growth if the EU promotes its three central pillars: Aviation Safety, Social Responsibility, and Competitiveness based on Fair Competition.
  • Today, each pillar is under significant pressure and needs coordinated efforts to ensure the overall system has a long-term future. This requires political will.
  • Hence, the Aviation Strategy must be more than a description of where we are, want to go, and what needs further study. Instead, concrete detailed proposals to tackle the existing problems and to strengthen all 3 pillars are required:

1) Aviation Safety must be Non-Negotiable:
- To achieve this, EASA must be equipped to properly oversee National Aviation Authorities (NAAs), promote cooperative safety oversight, and to intervene in a case of ‘failing NAAs’ and ‘failing operators’. It is crucial that the shift to performance-based safety regulation does not become a back-door for light-touch & self-regulation, and that ‘creative’ business models and atypical employment forms are restricted and cannot undermine safety. Also, pilot training must be strengthened; and safety be put first when integrating ‘drones’ into Europe’s airspace.

2) Social Dimension to become an Integral Part of aviation policy:
- To reverse the trend towards ‘casualisation’ of work and to keep aviation attractive for young people, the EU must eradicate atypical employment forms that distort competition, can negatively impact safety and result in abusive practices. Pay-to-Fly schemes must be banned and be replaced by a mandatory Approved Cadetship for Pilots. Reg. 83/2014 & Reg. 465/2012 need to be revised to better define the air crews’ “home base”, and so should be Reg. 1008/2008 to better define “the Principal Place of Business” of an airline, based on substantial aviation activity. Finally, the EU must prevent social dumping, ‘flags of convenience’ and the replacement of EU crews with cheap labour imported from third countries.

3) Competitiveness & Fair Competition with 3rd Countries:
- To ensure EU carriers can compete on equal terms, 3rd country airlines’ anti-competitive behaviour must be tackled. This includes careful checking of the merits of negotiations with Gulf countries and a robust negotiating mandate focussed on fair competition while further traffic rights should be frozen. The EU Ownership & Control rules must not be relaxed (neither on a reciprocal basis) but must be further strengthened to ensure ‘effective control’ is in EU hands. Reg. 868/2004 should swiftly be revised to make it an effective tool. Any bilateral/ multilateral liberalisation must foster fair competition & social rights, and an ILO/ICAO Convention to address social impacts of market opening is required.

The European Cockpit Association (ECA), representing over 38,000 pilots from national pilot associations in 37 European States, promotes a safe, competitive and socially responsible aviation sector, generating growth, connectivity and providing quality employment in Europe. It is those 3 dimensions that the Aviation Strategy and Package must strengthen:

Aviation Safety + Social Responsibility + Competitiveness / Fair Competition