BAOA’s Update

Update: October, 2020


  • Aircraft/Engine leasing declared financial services by Govt. of India:- BAOA has been taken up the issue of making leasing of aircraft and engines less costly and get relief in taxation burden for the same. The matter was taken up last year with Senior Economic Advisor of MOCA. Members are requested to refer to the gazette notification issued by GOI making provisions for establishment of IFSC in India to make leasing of aircraft, engines and other critical spares, like landing gears etc, easier and less costly. Through this gazette notification, ‘operating leasing’, which was not a financial product earlier, is now categorized as a ‘financial product’. MD BAOA had meeting in MOCA to organize a more detailed session for our members later, conducted by pioneers in this field in India, to let NSOP/GA operators drive maximum benefit from this relaxation. This is part of project “Rupee Raftar” and aimed at Indian SPVs entering leasing business in a big way to save on tax and foreign currency.
  • Letter to PMO /Home Secretary & Secretary MoCA on Levying ‘Unauthorized Stay Charges’ by MIAL on NSOP/GA aircraft during period of ‘complete lockdown’ dt. 25 September 2020:- The issue of levying of ‘unauthorized stay’ by MIAL, on outstation aircraft which couldn’t move out of Mumbai before complete lockdown was implemented, has now been taken up at higher level. Letter written in this regard to PMO / Home Secretary / Civil Aviation Secretary. This matter is also being separately pursued with AERA as a part of determination of aeronautical tariff by it for the third control period from 2019-2024. Members are requested to visit AERA site to go through Consultation Paper (CP) 25/2020-21 on MYTP for MIAL and send their comments to MD BAOA by 5th November 2020, positively.
  • Letter to DT Section on MoCA - Suggestions for restructuring DGCA dt. 25 September 2020:- MOCA had sought our suggestions on restructuring of DGCA to achieve better efficiency and transparency. Suggestions sent by BAOA to MOCA. We have recommended, ultimately, constitution of Civil Aviation Authority on the lines of FAA and EASA, as a long-term measure.
  • Meeting with BAOA and FBO Concessionaires dt. 08 October 2020:- On directions from MOCA, DIAL organized web meeting between BAOA and the two concessionaires at Delhi. Issues of ‘self-maintenance by larger NSOP operators’, ‘hangar rental’ and ‘rationalization of GH charges’ were the main issues discussed during this meeting to find a collaborative approach to progress these matters. Thereafter, BAOA had a follow up meeting with Economic Advisor MOCA to discuss ways to move forward. Another meeting, chaired by Economic Advisor MOCA has been planned next month with DIAL and its concessionaires to achieve tangible results.
  • Draft revision to CAR Section 7 Series J Part IV – “Duty Period, Flight Duty Period, Flight Time Limitations and Rest Periods: Flight crew engaged in Scheduled Commuter, Non-scheduled, General Aviation including State Government and PSU Operations.” comments required by 04th November 2020:- Members are requested to refer to the draft CAR issued by DGCA on FDTL having specific provision for NSOP operators. Members are requested to send their comments by 31st October 2020 to enable us compile all inputs before sending finalized comments on the CAR to DGCA.
  • Consultation Paper No. 35/2020-21 In the matter of Determination of Tariffs for Aeronautical Services in respect of Chhatrapati Shivaji International Airport, Mumbai (BOM), for the Third Control Period (01st April 2019 to 31st March 2024):- MIAL has submitted their proposed ATP/Tariff Card to AERA as required under the CP vide their letter no. MIAL/CEO/047 dated 15.10.2020. AERA has issued Consultation Paper (CP) 35/2020-21 to determine aeronautical tariff at Mumbai (MIAL) for the third control period, till 2024. While we are examining the various aspects of this CP in consultation with our Mumbai based members, all other members are requested to go through this CP and send their comments by 5th November 2020.
  • Letter to Ms. Vandana Aggarwal, Economic Advisor on Revision of AAI hangar rental charges due to pandemic situation dt. 21 October 2020:- The issue of rationalization of AAI hangar rentals during the pandemic times was discussed at length with MOCA (Economic Advisor). MOCA wishes to have a more balancing approach to address the issue and, not merely waive off the rental for the users of the hangars, in view of serious reservations expressed by AAI in this regard. Therefore, the letter has now been sent to MOCA after due consultations with the affected members.
  • Minutes of the meeting held on 21.08.2020 to discuss the issues related to Business Aviation/General Aviation:- DGCA has finally issued minutes of the web meeting held with BAOA members on 21st August 2021. We have been able to revive the issue of waiving cabin crew requirement for aircraft having 19 or below seats. Accordingly, letter, in this regard, has been sent to DGCA for progressing the matter further. Members are requested to refer to the minutes to note the action being taken on points discussed during the meeting. The next meeting has been planned by DGCA for the first week of next month. Members are requested to send agenda points, with brief write up, by 31st October 2020, positively.
  • Update: September, 2020


    • First GA/BA Terminal in Delhi - inaugurated by Minister of Civil Aviation:- The exclusive ‘state of the art’ first GA Terminal of its type in India was inaugurated in Delhi by the civil aviation minister on 17th September 2020. This GA Terminal is located close to an operational runway and has all the modern facilities, besides having custom/immigration set up. There are 57 parking stands available for GA aircraft only. The maintenance hangars, too, are already under construction at the same site that are meant exclusively to provide ‘continuous airworthiness maintenance’ support to GA aircraft. This fulfills the long pending demand of the industry and would set trend for creating similar type of ‘terminal’ at other metros in the country. Members are requested to give wider publicity to this development that has been completed during the challenging Covid-19 times.
    • BAOA-CII partnership for GA/BA exclusive Web Conference on 10th September 2020:- BAOA and CII partnered to conduct first of its kind exclusive ‘web conference’ only on GA industry. There was enthusiastic participation from most of our industry partners in this day long webinar. Both MOCA and DGCA actively participated through senior representatives.
    • Comments on AERA CP - 31 & 32 of 2020 - Compensating loss of FTC revenue to airport operators dt. 17 August 2020:- Comments sent on AERA’s CP, aimed at compensating for loss of revenue to public airports due to abolishing of FTC. It has been our stand that, instead of increasing ‘landing charges’, there should be marginal increase in UDF to compensate the loss of revenue. We shall keep our efforts on in this direction for a more sustainable aviation ecosystem, especially for small aircraft industry.
    • Letter to JDG, DGCA on ‘RHS PPC’ Requirements for Turboprop Aircraft below 5700 Kgs dt. 02 September 2020:- The issue of RHS PPC, for aircraft below 5700kgs, has come up recently due to differing interpretation by some FOIs of DGCA. We have written the letter, in detail, to let DGCA consider appropriate modification/change in the current regulations on this. The issue is being closely followed up and, it is expected, that necessary changes would be effected soon.
    • Letter to DG, DGCA on BA Test amid ongoing Covid 19 Pandemic dt. 06 September 2020:- BAOA has represented against the recent order of DGCA on BA check. We have asked for airlines standards not to be imposed on NSOP/GA operations. The matter is under active consideration of the regulator. Letter on BA order written to DG, DGCA asking for adopting monthly average for BA tests in NSOP/GA rather than daily percentage, as required for airlines operators.
    • Restructuring of DGCA-seeking written suggestions/comments from the Aviation Industry:- MOCA has sought inputs on restructuring of DGCA, with the aim to ‘review functioning along with current structure & assessing manpower requirement for the next ten years. Members are requested to send their suggestions by 25th September 2020, positively.
    • Update: August, 2020


      • Minutes of the meeting held on 03.07.2020 to discuss the issues related to Business Aviation/General Aviation:- We have now received the finalized minutes of the meeting held in MOCA last month. These minutes have also been marked to DGCA by MOCA and we are in constant contact with DGCA for necessary ‘follow up’ on the issues listed in the minutes. Members are requested to pay particular attention to points listed at item vi & vii of the minutes, wrt ‘simulator training / re-currency of crew and individual issues on medical validity, for taking timely action in collaboration with DGCA. MOCA has also asked DGCA to consider BAOA’s request to make carrying of cabin crew optional for NSOP ac
      • Matter concerning ‘unauthorized stay charges’ at MIAL during ‘lockdown period’ taken up with AERA/MOCA- letter written to Chairman AERA for taking corrective action on MIAL levying ‘unauthorized stay charges’ on outstation ac during the ‘complete lockdown period’. MOCA has also written to MIAL on this issue earlier, which has been quoted with the letter sent to Chairman AERA. BAOA is following up on this issue with AERA/MOCA.
      • Draft Agenda points for monthly meeting in DGCA for issues related to NSOP/General Aviation Dt. 21 August 2020- Intimation has been received from DGCA that the next meeting with NSOP/GA operators is being planned for 21st August 2020. The draft agenda, comprising seven items, has already been sent to DGCA and being shared with members. Members are requested to suggest any additional items, to be discussed with DGCA, during the proposed meeting on 21st August. Please send your suggestions with brief ‘write up’ on the issue by coming Tuesday, 18th August, positively.
      • ‘SOP’ to be shared with MoCA for smooth operations of helicopters in the country- After due consultations with BAOA, MOCA had written to all ‘states’ to appoint a ‘nodal officer’ in each one for ensuring smooth ‘point to point’ movement of helicopters, without any prior approval of the concerned district authorities. Some states, while confirming appointment of ‘nodal officer’, have asked for a ‘SOP’ to issued for the purpose. Members, flying helicopters, are requested to send their valuable inputs in this regard by 20th August 2020 for preparing a draft SOP to be proposed to MOCA. Please treat it as most urgent.
      • BAOA Meeting with MoCA, Eco. Adviser Dt. 13 August 2020- A team of BAOA comprising MD and two GB members had meeting with Senior Economic Advisor to MOCA on 13th August 2020 to discuss issues concerning rationalization of ‘maintenance hangar charges’ at public airports as aeronautical services and discontinuation of royalty/’revenue share’ on maintenance services carried out at these hangars located on public airports. This important matter is being pursued in a steady and logical way. Members will be kept informed of the further progress in due course.
      • ‘Way Forward’ for GA/BA MROs in India submitted to Sr. Economic Advisor MOCA- As a ‘follow up’ of recent announcement during ‘union budget’, MOCA is coordinating between defence and civil aviation for kickstarting civil MRO activities in a big way in India. MOCA is keen to ensure that major MRO activities get started for NSOP/GA/BA industry too to make India a regional hub. Points sent by BAOA as ‘way forward’ for GA/BA MRO hub in India. Members are welcome to send further inputs in this regard as the matter continues to be under discussion with MOCA/MOD.
      • BAOA-CII partnership for GA/BA exclusive Web Conference on 10th September 2020- The aviation wing CII is keen to partner with BAOA for its first ever conference, specific to GA/BA industry, on 10th September 2020. BAOA members interested in participating in the event are requested to send their willingness at info@baoa.in . The conference is likely to be attended by senior officials from MOCA/AAI/DGCA/BCAS.
      • Update: June/July, 2020


        • AGM-10 held on 30th June 2020:- In view of the COVID-19 pandemic, this year’s AGM of BAOA was, for the first time, organised through web. Some foreign members were also able to participate in this web-meeting. Besides, other items on the agenda, AGM approved the ‘draft balance sheet’ of BAOA for the FY 2019-20 and appointed auditors for the current FY 2020-21. Following are the two other major items of the AGM-10 and GB-50 meeting which preceded AGM-10.
        • • Annual review given by MD BAOA. MD BAOA gave annual review of BAOA’s activities during the last one year. Members are requested to go through the presentation given by MD and send their queries/comments on it along with any new suggestions/proposals.

          • Moratorium on payment of BAOA’s membership fee. It was decided in the GB-50 meeting a day before AGM-10 that, due to financial crisis being faced by members as a result of nation-wide lockdown, the payment date for renewal of BAOA membership would be extended up to 30th September 2020. All members are requested to clear their membership dues for the current FY, if not already paid, by the revised payment date of 30th September 2020 to ensure their membership status remains in ‘good standing’.

        • Web-meeting/discussions on 10 July 2020 with JS (UP) MOCA 'Social Impact of GA, as relevant to India':- As a ‘follow up’ of report released us on ‘social impact of GA/BA in India during the last BizAvIndia conference in Hyderabad during March 2020, BAOA partnered with Prat & Whitney Canada to give presentation on optimising growth of helicopter industry in India, especially the HEMS operations, which have not yet taken off in India despite the great potential that exists. This presentation was well received and appreciated by MOCA. We have recommended multi-use philosophy for helicopters till demands picks up in individual sub-segments of helicopter industry, like ‘disaster relief’, ‘search & rescue’, HEMS etc.
        • Synergy between defense & civil aviation industry for MRO growth in India:- Govt. of India has constituted a high-powered committee comprising ministries of civil aviation and defence to prepare road-map for growth of MRO industry in India, as envisioned in the last union budget. MOCA has asked for MD BAOA to be part of ‘Joint Group’ of the stakeholders to suggest measures to achieve synergy and create volumes in MRO business in India for attracting investment and achieving optimal growth. Members are requested to go through the following ‘Terms of Reference’ of the ‘Joint Group’ and send their valuable suggestions/inputs in this regard:
        • • Capability/infrastructure mapping and value mapping of both civil and defence MROs currently existing in India.

          • Identify areas, items and resources which can be shared.

          • List the components/LRUs/services which are currently being imported along with their value.

          • Identifying such activities/services which can be started immediately and followed by other activities in phases.

        • Letter to JS(UP) on Levying ‘unauthorised stay charges’ by MIAL on NSOP/GA during lockdown period:- MOCA had held meeting with BAOA on GA/BA matters on 3rd July 2020 to discuss progress on all issues affecting the industry. The important issue of huge amount of penalty being levied on NSOP/GA operators on the pretext of ‘unauthorized stay charges’ at MIAL, during the period of complete lockdown, was discussed during the meeting. MOCA agreed to take up this issue with MIAL. Letter sent to JS, MOCA after the meeting. The matter is being followed up with the ministry and further progress would be shared with the members in subsequent updates.
        • Online (virtual) Stakeholders' Meeting by AERA on Consultation Paper issued for IGI Airport, Delhi (DIAL), for 3rd Control Period Dt. 17 July 2020:- BAOA was invited by AERA to participate in stakeholders meeting to discuss ‘Multi Year Tariff Plan’ (MYTP) of DIAL, for the next five years, on 17th July 2020. BAOA has asked for rationalisation of hangar and GH charges for NSOP/GA as currently these charges are not being applied on NSOP/GA as per AERA Act and approved tariff plan. Comments sent to AERA in this regard. Members are advised to send their individual comment too, in this regard, to AERA before the due date of 30th July 2020.
        • GB Discussion on 8th July 2020 – Way Ahead:- As a follow up of the GB-50 meeting, governing board members had another web meeting on 8th July to discuss future action plan for the next one year. The final document prepared in this regard, sent to all members. All Members are requested to send their valuable inputs to help us further fine-tune the future strategy for BAOA.
        • Update: May, 2020


          • MoCA order dated 25.05.2020 regarding recommencement of domestic air services by non-scheduled and private operators:- As govt. eased restrictions, BAOA worked closely with MOCA for issue of Order specific to NSOP/GA operations clearly bringing out the main differences with airlines operations. Please refer ‘Order’ of MOCA dated 25th May 2020 for NSOP/GA specific provisions in it. BAOA is now working with MOCA for providing ‘electronic platform’ to let NSOP/GA operators share passenger information with state govt. as per the specific requirements of each. Suggestions from members are requested in this regard by 30th May 2020
          • Letter to Secretary, MoCA, Use of Terminal 1-D for re-commencement of NSOP/GA operations:- BAOA has written to MOCA to consider allowing NSOP/GA operations from already operational GA/BA Terminal at 1D, instead of T3 as planned by DIAL. The same was reiterated during web-meeting with MOCA on 23rd May. It would be advisable for members to put in a similar requests to airport operators where separate terminal are available for GA/BA movements.
          • Standard Operating Protocol (SOP) for Private aircraft and Charter operations on international sectors in view of COVID -19 pandemic:- BAOA worked closely with MOCA for issue of separate SOP for recommencing international operations by Private and NSOP operators. This SOP has been prepared specifically for GA/BA industry. Please refer ‘Order’ of MOCA dated 26th May 2020
          • Letter to Cabinet Secretary on ‘Easing of Restrictions for NSOP/Pvt. Charter flights for Business/Professional/Medical use':- BAOA had earlier, during this month, had written to Cabinet Secretary for easing restrictions of flying for NSOP/GA..
          • Recommendation and Suggestions to FICCI:- BAOA discussed the medium and long-term steps required to support the GA/BA industry to overcome the effects of long lockdown period. Secretary CA also joined the meeting towards the end and asked for specific recommendations to be sent in this regard. please find our recommendations in three parts, as per the following three categories:
          • • COVID lockdown related financial assistance

            • Post COVID related policy and regulatory assistance to boost general aviation sector

            • Financial and Policy support from the Govt. (Helicopter segment of GA/BA/NSOP industry)

          • CII National Committee meeting on Civil Aviation on 18th May 2020:- MD BAOA participated in CII’s National Aviation Committee meeting on 18th May to discuss various measure required to boost the industry after operations restart. CII proposes to have meeting with MOS CA early next week to present comprehensive medium/long term measures in this regard. Besides the two issues ‘drones’ and eGCA, other issues under our consideration are; MSME status for small NSOP operators and ‘GST rationalization applicable to NSOP’/ATF to be brought under GST. Members are requested to send their suggestions in this regard by 30th May.
          • Update: April, 2020


            • Financial & Regulatory Measures Required due to COVID-19 crisis and kickstarting ‘Aviation Industry’:- MD, BAOA participated in video conference organized by FICCI’s National Aviation Committee yesterday, in which more than eighty aviation professionals took part to discuss immediate measures to be recommended to the govt. to help the aviation industry survive through the current unprecedented crisis. Secretary and Joint Secretary in civil aviation ministry also joined the video conference for half an hour. Based on discussions during the video conference, and inputs received from our members, the email was sent to FICCI last night. Members are requested to go through our recommendations and suggest any additional points to be included when these recommendations are deliberated again in the ministry early next week. Secretary CA mentioned during the video conference that he would be calling reps of the industry separately to move forward on the issues raised by associations representing various segments of the industry.
            • Letter to Hon’ble Minister of Civil Aviation ‘Grant of permission for NSOP/Pvt Charter aircraft for Business/Professional/Medical use’- BAOA has separately written to HMOS Civil Aviation to permit operations of NSOP/GA aircraft immediately, with ‘social distancing’ norms in place.
            • Letter to Ms. Usha Padhee, Joint Secretary MoCA – ‘Circular on ARC renewal of NSOP/GA Aircraft’- BAOA has written to MOCA, as well as DGCA, to amend the ARC renewal Circular more broad-based to include all the aircraft due for renewal during the lockdown period. The issue is under active consideration.
            • Letter to Capt. Atul Chandra, CFOI DGCA ‘COVID 19 - Impact on Pilot Refresher & IR at International TRTO’- BAOA has written the letter to DGCA to extend ‘Annual Refresher Training’ validity by three months for pilots due for it in April this year. Further, it has been requested to allow IR/PPC check on the aircraft due to current unavailability of simulators.
            • IBAC Position on CORSIA Baseline due to COVID-19- IBAC prepared a ‘discussion paper’ for setting ‘baseline’ due to COVID-19 situation. As members would be aware, CORSIA is an offsetting scheme of ICAO to reduce carbon emissions from international civil aviation operations. IBAC is aiming for fair and equitable ‘market based measure’ (MBM) parameters to be followed for implementing this scheme. Members are requested to go through the paper and send comments, if any, by coming Monday.
            • Update: March, 2020


              • Annual BizAvIndia Conference 11 March 2020:- The annual event of BAOA – BizAvIndia 2020 – was successfully conducted on 11th March in Hyderabad, on the sidelines of Wings 2020, the ‘four-day’ event of air show and conferences held by ministry of civil aviation from 12-15th March. Notwithstanding the unprecedented situation prevailing globally due COVID 19 threat, we had reasonable attendance for the afternoon conference and the networking dinner, that followed. The discussions during the conference were rich in content with forward looking approach. Following three separate sessions were held during the conference:
              • BizAvIndia Conference Sessions: -
                • Panel Discussion I: Boosting Economic Growth with Business and General Aviation

                • Panel Discussion II: Safety / Infrastructural / Security Challenges for achieving optimal growth of GA/BA in India and, the way forward

                • Speakers/ Discussion – Session III: Emerging Trends & technologies to boost GA/BA growth in Asian region.

              • Social Impact of General Aviation, Concept paper by Pratt & Whitney Canada with collaboration with BAOA:- The concept paper, on ‘social impact of GA/BA industry’, globally, and its relevance to India, that Pratt & Whitney prepared in collaboration with BAOA, was released at the beginning of BizAvIndia conference in Hyderabad on 11th March. There were simultaneous ‘press releases’ at Montreal and Hyderabad to mark the occasion. Please see the link. Press Release
                The full report is already available on BAOA’s website for study by the industry professionals. Please visit the link Concept paper for complete report. Inputs from our esteemed members, suggesting ‘follow up actions’ are welcome.
              • Letter to DGCA on “COVID 19 - Impact on Pilot Refresher & IR at International TRTO”:- In view of the prevailing restrictions on international air travel, BAOA has written letter to DGCA requesting for extension of validity of refresher courses & IR required to be done by Pilots of NSOP/GA/BA at foreign TRTOs. The matter would be followed up by personally interacting with concerned officials of DGCA. Further inputs from members are welcome.
              • Update: February, 2020


                • Meeting in DGCA dt. 04 February 2020 with NSOP/GA operators to discuss GA/BA issues:- This month’s meeting at DGCA HQ was held on 4th February, progress on all the earlier issues was discussed and some fresh points like – timely disposal of critical issues and issue of final GTO CAR - were also discussed. Finalised minutes issued by DGCA would be circulated to all the members. The next monthly meeting with DGCA will be held on 31st March. Members are requested to send fresh agenda points for the meeting by 10th March.
                • Meeting under the chairpersonship of Smt. Usha Padhee, JS, MoCA on 06 Feb 2020 discuss the issues related to Business and General Aviation (BA/GA):- MOCA held meeting with BAOA on GA matters on 6th February to discuss issues needing directions from MOCA. Please refer draft minutes shared with MOCA for reference. We have been able to revive the issue of cabin crew waiver for
                • BAOA's Presentation to Chairperson AERA dt. 04 February 2020:- BAOA’s team gave a comprehensive presentation to Chairperson and members AERA to highlight aeronautical charges unfairly affecting NSOP/GA industry. We have, in particular, emphasized on high rentals for maintenance hangarage being paid on hourly basis. All the issues raised during the presentation are being followed up with AERA.
                • Comments on AERA CP 17/2019-20 on for providing Ground Handling Service At Rajiv Gandhi International Airport, Hyderabad:- Comments submitted to AERA on CP seeking stakeholders’ views on GH charges at HIAL. We have brought up the issue of unreasonable ‘concession fee’ and differential charges for NSOP. Further inputs from members are welcome.
                • BizAvIndia 11 March 2020 at ‘The Park, Hyderabad’. All our esteemed members are welcome to BAOA’s annual event – the BizAvIndia 2020 at Hyderabad on 11th March:- Detailed program will be sent soon. The event starts with conference at 12:30pm at hotel The Park Hyderabad. The theme of this year’s conference is ‘socio-economic impact of GA/BA industry on nations’. There is no delegate fee for BAOA members. Please attend in good numbers along with senior representatives from the company. The conference will be followed by networking dinner at the same venue at 8pm. Each company is expected to be represented by two senior officials
                • Update: January, 2020


                  • Meeting in DGCA dt. 06 January 2020 with NSOP/GA operators to discuss GA/BA issues:- Due to DGCA officials being busy on 31st Dec, the last month’s meeting was held on 6th January 2020 with participation of around 20 members. We are still awaiting issue of finalised minutes of the meeting from DGCA. In the meanwhile, members are requested to see the proposed draft minutes sent to DGCA for approval. Please note that separate FDTL CAR for NSOP has been held up due to ongoing court case. BAOA had ‘follow up’ meeting on ‘GTO for small aircraft operators’ with Dy CFOI and additional inputs have already been submitted to CFOI for finalisation of the CAR on GTO. Further, members are requested to give their views/inputs on the QRs for categorisation as ‘suitably qualified pilot’ for conducting ‘line-training of P-2’ in NSOP/GA industry. Please send your inputs by 31st January 2020.
                  • Meeting under the chairpersonship of Economic Adviser, MoCA on 20/12/2019 to discuss the maintenance hangarage for NSOP:- MOCA had called a meeting of all the affected stakeholders to discuss the ‘right of self-maintenance’ and tariff for ‘maintenance hangarage’ as aeronautical charges. BAOA strongly emphasised on the need to rationalise these two issues soon to achieve optimal growth of small operators of NSOP/GA. The issue was again taken up later during meeting on 10th January 2020 with Economic Advisor to discuss GST applicability on aviation industry. We are in touch with MOCA for final directive to be issued in this regard.
                  • Rationalisation of FTC Charge levied by Airport Operators on Aviation Turbine Fuel (ATF) across all Airports in India:- Members would be aware that BAOA has been, for the past two years, raising the issue of FTC (fuel throughput charges) at public airports being levied by airport operator. The FTC has been a ‘royalty’ being taken from fuel companies by airport operators who, in turn, pass on these charges to operators. Our two years of efforts have finally paid off and ministry issued directive to AERA on 8th January asking for withdrawal of FTC from all public airports. This would result in cumulative saving of around Rs forty crores to NSOP industry and open the door to address all other royalties being levied on small aircraft industry as ‘market access charge’ or ‘share of revenue’. In this regard, please read para 3 of MOCA’s letter carefully.
                  • Meeting under the joint chairpersonship of Ms. Vandana Aggarwal, Economic Adviser (Civil Aviation) and Shri Yogendra Garg, Principal Commissioner (Policy), Department of Revenue (DoR) on 10th January, 2020 to discuss GST:- BAOA attended the meeting in MOCA to discuss GST applicability on aviation sector. We have emphasised on the requirement to treat NSOP at par with scheduled airlines for applicability of GST, being in the same category of ‘commercial operations’ as per ICAO’s definition. The issue of different interpretation of 12 & 18% GST on charter fights was also pointed out for issuing necessary clarification and the right interpretation as 12% applicable to NSOP flights. Our suggestions were supported by Economic Advisor MOCA and well received by representative from Deptt. Of Revenue.
                  • Meeting with DIAL on 17 January 2020. BAOA had meeting with Chief Commercial Officer of DIAL on 17th January 2020 to discuss issues concerning NSOP/GA industry at DIAL:- President BAOA, AVM Chauhan was also present during the meeting wherein issues like – ‘self maintenance for CAR 145 approved operator’, development of MRO facilities at DIAL, ‘rationalisation of GH and maintenance hangarage charges’ - were discussed in detail. We are following up on these issues and members would be kept updated.
                  • Update: December, 2019




                    • Minutes of Meeting in DGCA dt. 26 November 2019 under the Chairmanship of Sh. Atul Chandra, CFOI with NSOP/GA operators to discuss GA/BA issues:- Tthe minutes recently issued by DGCA on the monthly meeting held on 26th November. Some issues like separate FDTL for NSOP and amendments to Aircraft Rules on ATPL have made progress. Members are requested to go through the minutes and send their comments / suggestions / inputs on each item for meaningful discussions on pending issues still under consideration during future monthly meetings in DGCA. Please send your suggestions for new items to be included in agenda for the next meeting, planned for 31st December 2:30pm, by 24th December to be forwarded to DGCA soon.
                    • MoCA reply on various points raised by BAOA:- Please see reply and gist of replies received, as given below, from MOCA in response to our letter written on 29th July 2019 regarding FTC, GH charges and tariff of maintenance hangars. BAOA has raised these issues again as some of the information contained in the letter is not factually correct.
                    • - Fuel Throughput charges (FTC) on ATF be done away and considered for merging with UDF charges to meet the overall ARR requirement of the airport.
                    • - Ground Handling’ charges at the airport, though aeronautical in nature as per the AERA Act, cannot be fixed on a cost-plus basis. AERA has suggested ‘self-ground handling’ or ‘ground handling under own arrangements’ be considered for non-scheduled / charter operators. This would need tweaking the existing GH Policy of MoCA.
                    • - Maintenance hangar charges as ‘housing charges’ at airports be aeronautical only when aircraft are parked there on an hourly basis for essential maintenance services under CAR 145 related work. Hangars on monthly lease to be treated as ‘non-aeronautical’ in nature.
                    • Letter to Ms. Vandana Aggarwal, Eco. Adv on MoCA’s directions on implementation of AERA order on levying ‘housing charges’ at public airports:- Letter written to Economic Advisor to MOCA on the need to implement AERA’s order on ‘housing charges’. Subsequent to receiving this letter, MOCA held a meeting of all the stakeholders on 20th December to threadbare discuss the issue in a fair and transparent manner. We are awaiting minutes of this recently held meeting and would share it with members soon.
                    • Comments on AERA CP 11/2019-20 in respect of M/S Globeground India private limited(GGI) for providing Ground Handling Services at Kempegowda International Airport, Bengaluru:- Comments sent by BAOA on GH charges at BIAL. We have pointed out that unreasonable ‘concession fee’ is the root cause of high GH charges and the same need to be rationalized.
                    • Letter to DG, BCAS on proposal for Aviation Security Training Institute (ASTI):- BAOA has written a letter to DG BCAS suggesting a separate AVSEC training center approval for NSOP and GA industry. Further progress in this matter will be shared with all our members.
                    • Update: November, 2019




                      • Letter to Economic Advisor MOCA on ‘use of maintenance hangarage at public airport for NSOP Operators dt. 29 October 2019:- BAOA has taken up the issue of lack of maintenance hangar availability for NSOP/GA operators at airports to allow for self-maintenance of own aircraft, if so required. Since enabling India to become maintenance hub is one of the stated aims of the government in the last union budget, we have apprised MOCA of the unfair denial of self-maintenance right to NSOP/GA operators by airport operators. The issue is likely to be discussed in the stakeholders consultation meeting by MOCA to hear views of all concerned.
                      • Comment of AERA on CP 10/2019-20 on in respect of M/S Celebi NAS Airport Services India Pvt. Ltd (M/S CELEBI NAS) for providing Ground Handling Services at CSMI, Mumbai:- Consultation Paper (CP) issued by AERA to determine GH tariff at Mumbai was shared with our members. Based on one comment received from EIH Aviation, the draft has been prepared for submission to AERA on 20th November 2019.
                      • Letter to DGCA on Revised comments on Amendments in Section M, Schedule II, Aircraft Rules 1937:- Based on our further discussions with DDG Training & Licensing DGCA, we have now submitted revised comments on the draft ‘gazette notification’ issued by MOCA to amend existing requirements for grant of ATPL. These comments are now specific to the proposed draft amendment and, we shall be submitting comprehensive suggestions for further rationalizing training and licensing requirements for aircrew after receiving more inputs from our members. Please send your inputs for changes in CARs /Aircraft Rules pertaining to training and licensing by 15th December 2019.
                      • Letter to DG, DGCA on Threshold time for NSOP Operators dt. 21 October 2019 & request for meeting on threshold time:- The letter sent to DG DGCA requesting for expeditious release of the already finalized CAR to increase ‘threshold time’ for NSOP to 120 min. This being part of comprehensive CAR on EDTO, involving scheduled flights too, has not progress to finality, as yet. BAOA is looking at all possible options to get it resolved soon.
                      • Update: October, 2019




                        • AERA letter on Ground Handling Charges for NSOP/GA:- Members are aware of the continuous efforts being made to rationalize ‘ground handling’ (GH) charges being levied on NSOP/GA industry at public airports. The hefty increase in GH charges by concessionaires at Delhi (DIAL) was taken up with the statutory body ‘Airport Economic Regulatory Authority” (AERA). The issue was further taken up by AERA with DIAL. AERA has not accepted plea of DIAL for treating GH charges as non-aeronautical and directed that concessionaires file their tariff plan with AERA immediately. It is expected that concessionaires should file tariff plan with AERA before the end of this month and the same would be put up by stakeholders consultation. Members using GH services at DIAL are advised to insist on paying only the charges previously approved by AERA till revised charges get approved.
                        • Letter to Chairperson AERA on levying ‘housing charges’ for hangars at pubic airports:- We have taken up the issue of non-implementation of AERA’s approved tariff, on ‘housing charges’ (parking in hangar), specifically affecting NSOP/GA industry due to most operators not in possession of own hangars. Chairperson AERA has personally spoken to MD on the issue and asked for comprehensive presentation covering the issue of all the aeronautical charges affecting NSOP/GA industry. Members are requested to send their well considered suggestions in this regard by 28th October as our presentation is slated to take place in the first week of November.
                        • Comments on AERA CP 07/2019-20 in respect of M/s Celebi Airport Services India Pvt. Ltd. for providing GH services in IGIA:- BAOA has sent comments on CP issued by AERA for determining GH charges by Celebi Airport Services at Delhi. We have objected to the practice of fixing GH charges by ‘soft touch’ approach method and suggested to adopt a more rational ‘cost plus’ method for fixing the GH charges, categorized as aeronautical services at public airports.
                        • Comment on MoCA notification on Amendments in Section M, Schedule II, Aircraft Rules 1937:- BAOA has been asking for rationalization of experience requirement for issue of ATPL by DGCA. This issue has been one of our main agenda points in meetings with MOCA/DGCA to effect changes in Aircraft Rules in this regard. Finally, MOCA published draft gazette notification last month proposing to rationalize the existing provisions in Aircraft Rules. BAOA has sent comments to DGCA/MOCA in response to the government’s gazette notification.
                        • Letter to DG, DGCA on ‘threshold time’ for NSOP:- There has been inordinate delay from DGCA for issuing the amended CAR, on increasing ‘threshold time’ for NSOP from 90’ to 120 min, in spite of decision in this regard finally taken in the meeting with NSOP operators and finally approved by CAR Group, thereafter. WE have now written to DG DGCA to get the amended CAR issued soon.
                        • Extension of Implementation of Aviation English Language Proficiency (ELP) for Flight Crew:- The issue of extending date of ELP approval for flight crew further after 31st October was taken up with DGCA. The Public Notice issued by DGCA on 14th October extending date of implementation to 1st January 2020.
                        • Update:September, 2019




                          • Monthly Meeting in DGCA dt. 27 August 2019 under the Chairmanship of Sh. Atul Chandra, CFOI with NSOP/GA operators to discuss GA/BA issues:- The last month’s meeting in DGCA was held on 27th August under the chairpersonship of CFOI. The meeting was attended by more than 15 members of BAOA. Agenda for the meeting was shared with all our members seven days in advance. Issues like ‘threshold time’, FDTL and ‘directive on GTOs’ have been finalised. Final CARs on all these three issues are expected to be issued during this month only. Among the fresh issues discussed during the meeting, ‘experience required for grant of ATPL’ and ‘filing difference for allowing international operations of aircraft mandated for retro-fitment of FDR by DGCA’ were progressed during the meeting. Minutes of the meeting are expected to be received from DGCA soon and will be shared with all members. Next meeting has been planned for 2:30pm on 23rd September (Monday). Members are requested to send agenda points for the forthcoming meeting by 12pm on 16th September. Please share thorough research done on the issue, from the perspective of ‘global best practices’, while proposing agenda points.
                          • Meeting with Joint Secretary Ms. Usha Padhee dt. 09 September 2019 on “Operationalization of the small aircraft for the small Airports under UDAN”:- A meeting was held in DGCA on 9th September to discuss optimal utilization of spare capacity available with NSOP operators to connect remote/hilly areas under the UDAN-4 scheme of MOCA. It has been apprised to MOCA that, for success and long-term sustainability of remote connectivity schemes, it has to be ensured that ‘chartering of the complete aircraft’ or ‘per seat payment by state/central govts.’ should not cause any financial loss to the NSOP operators. MOCA is working on different options in this regard and likely to allow limited publishing of schedule to NSOPs, taking part in next UDAN-4, to optimize the available spare capacity.
                          • Letter to CFOI, DGCA on “Modification of FCL 03/2012 dt. 20 August 2019Letter written to DGCA on modifying existing FCL 03/2012 to allow similar ATPL privileges to helicopter pilots, as is given to fixed-wing pilots. This issue was debated during the last monthly meeting held in DGCA on 27th August. The discussions remained inconclusive due to some observations made by DGCA’s officials.
                          • Letter to JDG, DGCA on “Amendments in Section M, Schedule II, Aircraft Rules 1937” dt. 23 August 2019:- Letter written to DGCA on further amendments required for grant of ATPL. As already mentioned above, this is a ongoing issue and well-researched inputs from members are critical to get the required changes approved in the existing provisions of Aircraft Rules. Members are requested send their inputs by 16th September, latest.
                          • Letter to DG, BCAS on “ Aircraft Entry for Foreign Visitors” dt. 30 August 2019:- The issue of ‘airport entry pass’ (AEP) to bona-fide engineers and ‘sale/purchase personnel’ continue to be a thorny issue due to existing procedures for issue of AEPs in such cases. BAOA has taken up this issue with DG, BCAS to rationalise the procedure, in line with global best practices.
                          • Update:August, 2019




                            • Monthly Meeting in DGCA dt. 30 July 2019 under the Chairmanship of Sh. Atul Chandra, CFOI with NSOP/GA operators to discuss GA/BA issues:- In accordance with decision taken during meeting with Secretary CA on 16th July 2019, the monthly meeting in DGCA with BAOA, on the last Tuesday of each month, restarted on 30th July 2019. President and MD BAOA attended the meeting. The earlier draft CAR on ‘threshold time’ was discussed again this week with DGCA and the final CAR is expected to be issued by the end of this month. Further, CAR for separate FDTL, in case of NSOP operators, would also be issued by this month end. DGCA is soon going to issue specific CAP for operating GTOs, for which inputs had been taken from BAOA earlier. Members are requested to send agenda points, by 16th August, for the next meeting in DGCA scheduled to be held on 27th of this month. DGCA has insisted on agenda points to be sent a week before the meeting.
                            • Letter to Secretary, AERA on “Hefty increase in GH charges by concessionaire at DIAL” dt. 24 July 2019:- BAOA has taken up the issue of recent hefty increase in ‘ground handling charges’ at DIAL with AERA and sought clarification from the regulator in this regard. The matter is being aggressively taken up in other forums also to rationalise these charges in accordance with provisions of AERA Act.
                            • Letter to Joint Secretary, Ms. Rubina Ali on “option of Ground Handling under own arrangement to non-scheduled commercial operations” dt. 29 July 2019:- As follow up of discussions with Secretary CA on 16th July, a letter has been sent to Joint Secretary, in charge of airports, to amend the current provisions in GH policy of MOCA and grant option of self-handling to NSOP operators by forming a consortium. This issue would be further followed up depending upon the response received from MOCA.
                            • Meeting with Ms. Vandana Aggarwal, Economic Advisor dt. 07 August 2019:- MD BAOA had discussions with Economic Advisor in MOCA on rationalising ‘custom duty’ for import of aircraft between commercial and non-commercial categories to encourage consolidation in the industry leading to efficient operations of ‘aircraft management companies’. The ‘concept paper’ shared with MOCA in this regard. Further, the issues of self-maintenance and, 5% GST on all categories of aircraft spares were also emphasised during the meeting. Updates on these issues would be shared with members subsequently.
                            • Update:July, 2019




                              • Comment on AAI’s paper on Philosophy of aeronautical charges at non-major airports dt. 22 June 2019:- BAOA participated in the stakeholder meeting held by AAI on 22nd June to discuss philosophy of deciding aeronautical charges at non-major airports, not falling under the preview of AERA. The meeting was attended by Chairman AAI. We have asked for removal of royalty element from all types of aeronautical charges at public airports. We have specifically mentioned about the royalty being charged on ATF, GH Charges and hangar use for CAR 145 related maintenance. Further, BAOA has categorically stated that aeronautical charges at non-major airports should continue to be cross-subsidized through additional revenue received from major airports.
                              • RTI Reply on Amendment of Schedule II of the Aircraft Rule, 1937 (Section M & N) dt. 27 June 2019:- We have, finally, received information on the amendments proposed by DGCA to rationalize requirement for grant of ATPL and bring these at par with best global practices. The RTI reply received from DGCA in this regard. There are still some issues, like getting credit for co-pilot hours, which need to be addressed..
                              • Letter to JDG on Revision of Threshold Time for Non ETOPS-NSOP Aircraft dt. 09 July 2019:- We continue to pursue the issue of revision of threshold time for NSOP to 120 min. The matter has progressed since then and we expect final CAR to be issued by the end of this month.
                              • Meeting with Secretary, CA to discuss the way forward for NSOP/General Aviation dt. 16 July 2019:- BAOA members participated in good numbers in the meeting held at MOCA on 16th July 2019 under the chairpersonship of Secretary CA to discuss issues affecting NSOP/GA industry in India. MD BAOA gave the presentation during the meeting. We have highlighted all the major issues not conducive to optimal growth of NSOP/GA in India. MOCA is expected to soon issues minutes of the meeting to share the decisions taken to address the issues highlighted during the meeting.
                              • Update:June, 2019




                                • Follow up meeting on 30.04.2019 under the Chairpersonship of JS(U) on issues related to General Aviation:- BAOA had meeting in MOCA to discuss ‘follow up’ actions on important issues already taken up at different meetings held earlier. As regards Threshold Limit to 120 min, two meetings have taken place with FSD and DAW in DGCA, since then. The issue is likely to be finalised soon.
                                • Letter from DGCA on ‘Specific Recommendations on Pilot Licensing Requirements for Smaller Fixed Wing/Rotary Wing Aircraft’:- DGCA finally replied to our suggestions for changed approach to ‘training and licensing’ standards for aircrew and align them with global standards. Inputs from members, on DGCA’s replies, would be crucial to progress all the suggestions to logical end. As regards simplifying ATPL regulations covered at para 5 of DGCA’s letter, BAOA has already sought details on proposed DGCA’s draft from MOCA.
                                • Comment on AERA CP 03/2019-20, determination of aeronautical tariffs in respect of Jay Prakash Narayan International Airport, Patna for the first control period (01.04.2018-31.03.2023):- Two separate letters sent to AERA regarding MYTP for Patna airport. In the follow up meeting at AERA, it has been proposed to consider deleting FTP and meet the resultant ARR shortfall through UDF. BAOA is working to eliminate royalties from aeronautical tariff at public airports. In another letter on the same issue, BAOA has asked for of GH charges at Patna airport to be fixed by AERA as per AERA Act. The matter is being followed up with MOCA, as advised by AERA during stakeholders meeting held on 7th June 2019.
                                • Follow up letter with Secretary, MoCA on Rationalisation of Aeronautical Charges at Public Airports operating under PPP model:- Members are requested to send their comments on the latter written recently to Secretary CA, as ‘follow up’ of the stakeholders meeting held at AERA for Patna airport. We have asked for complete rationalisation of aeronautical tariff at public airports, especially the hitherto unregulated GH charges and the maintenance hangar charges. AERA has suggested for self-handling to be allowed for commercial non-scheduled operators in India and the same has been taken up with MOCA for implementation through amendment in GH Policy. Members are welcome to send further suggestions in this regard.
                                • Letter to Economic Advisor on Proposals for GST Council & Union Budget dt. 12 June 201:- BAOA has sent specific suggestions to MOCA for rationalising GST/BCD applicable on GA/BA industry like - GST on charter flights, sale of aircraft within India, import of aircraft for NSOP/Corporate/Individual use. These suggestions have also been taken up through industry bodies like CII, FICCI, ASSOCHAM and PHD Chamber.
                                • Meeting with Head FSD on ‘CAP on GTO’ dt. 04 June 2019:- DGCA is soon planning to issue new CAP on GTO, as none exists at present. In this regard, BAOA had meeting with CFOI and other FSD officials on 4th June at DGCA HQ. DGCA has sought inputs on rationalising ground training requirements for aircrew, post type rating / endorsement at ATO/DTL. Members are requested to send their suggestions on modifying existing ground training requirement, ASAP, to help us finalise BAOA’s recommendations in this regard.
                                • Update:April, 2019




                                  • Minutes of the meeting under the chairpersonship of Secretary (CA) held on 14.03.2019, to discuss the issues arising from ATF Throughput, Infrastructure and Into Plane Charges:- BAOA is focussing on rationalising all the aeronautical charges to lessen the burden of operating costs on the operators. In this direction, we have been working with MOCA to ensure ‘fuel throughput charges’ are not subjected to ‘tax on tax’ and these remain simple ‘pass through charges’. In this regard, presentation was given to HMOS in September last year and a separate letter sent to Chairman AERA in Feb 2019. These are ongoing efforts and we hope to see the positive result soon on rationalisation of ATF charges at public airports.
                                  • Letter to CFOI, Comment on Draft Revision to CAR Section 8 Series S Part I - Requirements for Extended Diversion Time Operations (EDTO) for Commercial Air Transport:- The letter sent to CFOI as comments on revised CAR on EDTO. It has been reiterated that the draft CAR is, in fact, a step backward and the whole issue needs a relook in line with existing regulations of FAA / EASA on EDTO. Further inputs from members are welcome.
                                  • Letters to Secretary, CA and Chairperson, AERA on Rationalisation of Aeronautical Charges at Public Airports operating under PPP model:- Letter written to Secretary CA and Chairman AERA on the issue of royalties continuing to be part of aeronautical services even after enactment of AERA Act in 2009. These royalties / ‘revenue share’ unfairly add to cost of operations making long-term operations unviable for airlines, both scheduled and non-scheduled. BAOA also intends to work with industry bodies like CII/FICCI/ASSOCHAM/PHD Chamber to rationalise all such charges and reduce operating costs for aircraft operators.
                                  • Letter to Chairperson AERA on Increase in Rentals at G5 Building IGI Airport, Terminal 1:- This issue affects GA/BA operators having their offices in G+5 building at IGI Airport. DIAL had not increased rentals of these offices for two years after BAOA represented against high rentals in 2016. However, this year the rentals have been increased by 7.5%. We have now written to Chairman AERA to intervene and rationalize the yearly increase as per CPI/WPI.
                                  • Update: March, 2019




                                    • Minutes of meeting held under chairmanship of HMOS on 18th Feb:- MOCA duly responded to our letter mentioned in the last month’s updates and meeting of stakeholders was called on 18th February, which was chaired by HMOS Shri Jayant Sinha himself. All important issues of GA/BA were highlighted during the meeting, in which Secretary CA and DG DGCA were also present. The important issue of rationalising ‘training and licensing requirements of aircrew’ was specifically mentioned during the meeting and updates sought on the present status of changes recommended by BAOA in Aircraft Rules. We have sent reminder to MOCA last Friday asking to provide updates soon on this issue.
                                    • Third Meeting of the CII Aviation Committee dt. 20 March 2019:- BAOA continues to partner with CII to take up important GA/BA issues with MOCA and other government bodies like BCAS and AAI. The GA team of National Aviation Committee of CII is headed by MD BAOA. The 3rd meeting of CII Aviation Committee was held on 20th March at India International Centre, chaired by Sr Economic Advisor of MOCA. We have highlighted issues like ‘policy on aircraft management companies’, rationalisation of import duty on aircraft in NSOP and GA categories, for seamless use of same aircraft in both, and expediting CISF manning of all licensed airports to address doubts of defence forces on safe operations of NSOP/GA aircraft from smaller airports.
                                    • Rationalisation of Rental Charges at T1 G5 Building for FY- 2019-20:- BAOA’s members, occupying offices at G+5 building at IGI T1, would recall that there have been no annual increases in office rentals during the last two FYs due to strong stand taken by us on existing high rentals. However, this year DIAL has proposed 7.5% increase from 1st April 2019. BAOA has again raised objection to it and asked for roll back and to link any subsequent annual increase to WPI / rate of inflation. Affected members are requested to write to DIAL, individually too, for rolling back the proposed increase and rationalization of annual increase in the later years. Please email copy of your mail to MD BAOA for our further reference.
                                    • Meeting in AERA dt. 26 February 2019 on Direct Levying of Fuel Throughput Charges to oil Companies by Airport Operators:- BAOA has been fighting hard for removal of FTC (Fuel Throughput Charges), a royalty payment to airport operator, which escalates FTC to 60% higher figure in some states due to ‘tax on tax’ (VAT & excise duty) being applied by oil companies on ATF. AERA called a meeting of all the stakeholders on 26th February to discuss the issue and subsequently meeting was also held in MOCA under chairmanship of Secretary CA.
                                    • Revision to CAR Section 2 Series F Part XX - Age of Aircraft to be imported for Scheduled / Non-Scheduled including Charter, General Aviation and other Operations:- Members are requested to go through the changed parts of revised draft CAR (para 3.1 to 3.4) on age of aircraft for import to India. While the age bar for aerial work has been completely removed, there are new Notes (1 & 2) on flying / maintenance carried out during the last six months. Members are advised to note the changes.
                                    • Update: February, 2019




                                      • Letter to Hon’ble Minister of State, MoCA on pending GA/BA issues of monthly stakeholders meeting needing immediate action by MoCA:- As our members may be aware, Mr. R.N. Choubey, Secretary CA superannuated on 31st January after a very distinguished tenure. In order to keep up the tempo, the letter was written to HMOS requesting for ‘follow up’ action on issues pending since the last monthly stakeholders meeting that was held by outgoing Secretary on 9th January. HMOS has positively responded to our request and a notice has just been received from MOCA for stakeholders meeting next week to discuss pending issues under the chairpersonship of HMOS. Members would be kept updated on progress achieved during this meeting.
                                      • Letter to JS, Ms. Usha Padhee on Manning of all licensed airports by CISF:- As a follow up of discussions on ‘security issues at airports’ during Global Aviation Summit held in Mumbai last month, BAOA wrote the letter to Ms. Usha Padhee, JS MOCA for expediting CISF manning of all licensed airports in India. This issue is likely to be discussed during the next meeting on GA/BA issues under chairpersonship of Ms. Usha Padhee. Members are welcome to send any further inputs in this regard, ASAP.
                                      • Letter to Chairperson, AERA on direct levying of Fuel Throughput Charges (FTC) to Oil Companies by Airport Operators:- The levying of ‘fuel throughput charges’ on ATF is being taken up with MOCA for complete rationalisation of the issue. MOCA is strongly of the view that ‘tax on tax’ for FTC on ATF should not be there at all. BAOA has written the letter to AERA asking for collection of FTC, as ‘pass through’ charge, directly invoiced by ‘airport operator’ to oil companies and, not be part of total ATF bill raised by oil companies against aircraft operators. The matter is being progressed with AERA and MOCA.
                                      • Draft Comments on CAR for issue of Indian licenses and aircraft rating to pilots holding licences/rating issued by contracting states of ICAO:- Draft CAR of DGCA, seeking comments from stakeholders on ‘requirement for issue of Indian licenses for foreign license holders, has been on DGCA’s website since 23 January 2019. The last date for submission of comments being 22 February 2019, members are requested to send their comments, on the proposed response to DGCA, by 18th February 2019
                                      • Update: January, 2019




                                        • Comment of Draft Revision of CAR – FDTL (Flight Crew) :- BAOA remained involved in preparing draft FDTL CAR separately for NSOP/State Govt./Private aircraft owners. The draft was put up on DGCA’s website during Nov 2018 and comments were required to be submitted by 16th Dec 2018. As per inputs received from members, BAOA submitted comments, well in time.
                                        • NOTAM on ADS-B - Effected date postponed to 01-01-2020 :- BAOA took a strong stand on AIP 148/2018, issued by AAI, restricting RVSM airspace use for aircraft not retro-fitted by ADS-B equipment by 01/012019. It was pointed out to DGCA and AAI that the notice period, given in AIP, is unrealistic and not conforming to standard practice of at least one year notice period for such retro-fitment requirements. As a follow up to the letters written by BAOA and affected operators on the issue, a meeting was called in DGCA on 26th Dec 2018, chaired by JDG. As per commitment individually given by affected operators to ensure retro-fitment of ADS-B by 31st Dec 2019, AAI issued the NOTAM postponing the implementation date of AIP 148/2018 to 1st Jan 2020. Our sincere thanks to all members for fully collaborating with BAOA’s plans to address the issue expeditiously. Members are advised to ensure retro-fitment of ADS-B at the earliest due to AAI’s decision to accord priority to ADS-B enabled aircraft in TA from June 2019 onwards.
                                        • Letter to Secretary, CA on Pending issues of Monthly Stakeholder’s Meeting :- BAOA’s ongoing issues; ‘proportionate regulations, ‘EDTO’s threshold limit to 120 min’ and ‘AOR exemption for NSOP at civil enclaves’; are nearing finalisation. However, due to paucity of time, final directions couldn’t be given by Secretary CA during the last stakeholders meeting held on 9th Jan 2019. Accordingly, the letter has been written to Secretary CA requesting for separate meeting be held soon to ensure given dead-lines, to address these issues, are adhered to
                                        • Comment on AERA Consultation Paper 23-24/ 2018-19 on Aeronautical Tariff (Visakhapatnam & Bhubaneswar airports) :- BAOA continues to raise objection on authorizing ‘fuel throughput charges’ FTC as part of aeronautical tariff by AERA. Comments sent to AERA in response to Consultation Paper (CP), on Vizag and Bhubaneshwar airports issued by AERA, to determine aeronautical tariff. This issue of wrongful levying of FTC, as royalty, is also being separately pursued with MOCA.
                                        • Letter to DGCA on Validation of Foreign Licences of Flight Crew :- As was informed to members last month, pursuant to BAOA’s letter and issue being discussed with Secretary CA, DGCA amended CAR on import of aircraft to remove age bar on import of aircraft for ‘Aerial Work’. We have now taken up the issue of ‘initial FATA’ for Aerial Work to be issued for six months for aerial work involving specific projects.
                                        • Update: December, 2018




                                          • ADS-B Equipage mandate in India :- BAOA team had meeting in DGCA chaired by JDG (JS Rawat) on 22nd November and raised the issue of ADS-B being enforced for flying in RVSM air space, without any time-line for changed airworthiness requirement of retro-fitting transponder being mandated by DGCA. letter sent to JDG in this regard, with interim list of affected operators. As already advised to affected members, please send letter to JDG apprising DGCA of the plans to retro-fit ADS-B transponder in your company’s aircraft, with copy to BAOA.
                                          • Removal of age bar for import of aircraft for Aerial Work :- BAOA has been aggressively pursuing the issue of removal of age bar on import of aircraft for ‘aerial work’. The issue was raised in the monthly meeting of stakeholders with Secretary CA. Please see the draft CAR, recently issued by DGCA, providing for removal of any age bar for ‘Aerial Work’. This is a big step taken towards rationalising regulatory requirements in India for smaller aircraft of GA/BA industry. Members are requested to give wider publicity to this major success to help others operators, not yet members of BAOA, appreciate the benefit of strengthening BAOA as the platform to work for growth of GA/BA industry in India.
                                          • Meeting with Mr. SK Mishra JS MOCA on specific suggestions of proportionate regulations for fixed wing & rotary wing aircraft (07 December 2018) :- As follow up of the specific proposals, sent to DG DGCA and Secretary MOCA, for proportionate safety regulations for smaller aircraft of GA/BA industry, a detailed meeting was held with JS in-charge of DGCA matters in MOCA, Mr. S.K. Mishra. BAOA is closely working on this issue and the required changes in Aircraft Rules / CARs are being finalised with support from experts in the industry. The next discussion on the issue would take place in MOCA on 7th January 2019.
                                          • Meeting with Senior Economic Advisor :- A detailed meeting was held with Sr Economic Advisor in MOCA on 5th December 2018 to discuss the requirement to rationalise GST applicability for GA/BA industry and, treat all commercial air transport operations, scheduled and non-scheduled, at par. We are aiming to align taxation requirements, with regulatory CARs, to allow fair treatment to GA/BA industry. Members would be kept updated on further progress on this critical issue.
                                          • Update: November, 2018




                                            • Meeting with Shri Jayant Sinha, Hon'ble MoS for Civil Aviation dt. 26 October 2018 :- A meeting was held with Hon’ble MOS CA, Mr. Jayant Sinha on 26th October 2018 to discuss progress on applicability of GST fairly to NSOP/GA industry. He assured that the issue of rationalising the existing 18% GST, applicable on NSOP, is being strongly taken up with Ministry of Finance to bring parity with scheduled airlines. BAOA is closely following up the issue with other officials of the civil aviation ministry.
                                            • Presentation to Secretary (CA), monthly stakeholders meeting dt. 26 October 2018 :- BAOA made the presentation to Secretary CA during the stakeholders meeting held on 26th October in MOCA. The slow progress on issues like ‘enhancing EDTO limit to 120 min for NSOP’ and ‘waiver of AOR requirement for civil enclaves’ were highlighted during the meeting. Secretary CA has agreed to chair a separate meeting on EDTO and send official letter to MOD on waiving AOR for GA/BA industry. DGCA also committed to bring out a separate CAR on FDTL for NSOP/State Govts. by the end of November 2018, which would give relaxed requirements for NSOP operators.
                                            • Follow-up meeting under the Chairpersonship of Economic Adviser (Civil Aviation), in order to rationalise the present mechanism of invoicing of ATF Throughput Charges dt. 26 October 2018 :- The issue of double taxation on ATF, being lifted from airports across India, was highlighted during meeting with HMOS in CII on 5th September. Senior Economic Advisor, MOCA has followed up the issue and had series of meetings with ‘airport operators’, oil companies and aircraft operators. During the last meeting on the issue held on 26th October, the attached SOP has been proposed by MOCA to avoid double taxation on ATF. BAOA has expressed the view that final monthly invoice should be raised by ‘airport operators’ and not oil companies on ‘fuel throughput charge’ has been authorised by AERA in MYTP as aeronautical charge.
                                            • Meeting under the Chairpersonship of Ms. Usha Padhee, JS (MoCA), on issue related to General Aviation dt. 12 November 2018 :- A meeting was held on 12th November chaired by Smt. Usha Padhee, Joint Secretary MOCA to discuss GA issues. BAOA took up the issue of NSOP operators not being given any notice period, for retro-fitment of ADS-B transponder, in the recent AIP issued by AAI mandating use of RVSM airspace only to aircraft fitted with this transponder. The matter will be taken up again during the monthly stakeholders meeting with Secretary CA on 27th November. Members are requested to share the relevant information on affected aircraft with MD BAOA, ASAP.
                                            • Update: October, 2018




                                              • Meeting under the Chairpersonship of Economic Adviser (Civil Aviation) to discuss the issues of ATF Throughput Charges dt. 16 October 2018 :- MD BAOA had met HMOS Civil Aviation for rationalization of GST applicability for GA/BA industry. Economic Advisor of MOCA is actively working on our proposal to rationalize GST to 12% (with input tax credits). The issue of double taxation on airport charges for aviation fuel was specifically discussed in the meeting of stakeholders on 16 October to rationalize taxes on ‘fuel throughput charges’ (FTC). Members are requested to offer their comments by 25th October on the proposed SOP for separately billing the FTC component to avoid double taxation.
                                              • Letter to DG, DGCA on Specific Suggestions on ‘Way Forward’: Proportionate Regulations & Categorization of AT Ops in India :- BAOA has been actively pursuing the requirement of graded regulatory structure to optimise growth of GA/BA industry in India. Inputs / comments from members are welcome as we progress on this important requirement having far reaching consequences for our GA/BA industry.
                                              • Update: September, 2018




                                                • Meeting under the Chairpersonship of Economic Adviser (Civil Aviation) to discuss the issues of GST rates on non-scheduled air transport service and chartered air transport service dt. 20 August 2018 :- Five members of BAOA’s Governing Board attended the meeting in MOCA on 20th August to discuss applicability of GST on GA/BA industry. The meeting was also attended by representatives from DGCA and Min of Finance. As desired by MOCA, detailed email was later sent to Economic Advisor emphasizing on the need to treat non-scheduled airlines at par with scheduled airlines for charging GST. The proposal is also being followed up with Hon’ble MOS CA and Min of Finance.
                                                • Presentation to Secretary, MoCA on 28th August 2018. President and MD attended the stakeholders meeting in MOCA, chaired by Secretary CA, on 28th August :- The issue of re-categorisation of AT ops and proportionate regulations for smaller aircraft of GA/BA was discussed again. DG DGCA asked for a deferring discussions on the issue for one month for better understanding of the benefits of re-categorisation. The matter continues to be actively pursued by us.
                                                • DGCA Meeting on review of FDTL CAR with Representatives of NSOP and State Government dt. 30 August 2018 :- DGCA is in the process of issuing a separate CAR on FDTL for NSOP and GA industry. Meetings on this issue have been held with NSOP/GA operators in DGCA on 30th August and 11th September. These meetings were chaired by Dy CFOI (Capt Pankaj Anand) and each suggestion from operators was objectively discussed. Draft CAR on new FDTL regulations is expected to be put on DGCA’s website by 20th September. Members are advised to send their further inputs in this regard to MD.
                                                • Second Meeting of the CII Aviation Committee dt. 05 September 2018 :- The second meeting of National Aviation Committee of CII was held under the chairpersonship of Hon’ble MOS CA on 5th September. The need for providing specific infrastructure for GA/BA industry, in a phased manner, as part of all future up-gradation/development of aviation infrastructure in the country, was emphasized again during the meeting. It has been decided to soon have specific meeting on the issue with the Head of ‘aviation infrastructure planning team’ in MOCA.
                                                • Letter to Hon’ble Minister of State, MoCA on Rationalisation of applicable GST rate on GA/BA industry & Levying of Fuel Throughput charges (FTC) on aircraft operators at Public airports :- As follow up of meeting with Economic Advisor MOCA, the issue of rationalizing GST rates for GA/BA industry, as applicable to commercial scheduled operations, was raised again with MOS Civil Aviation during the meeting on 5th September. Further, the unfair practice, by oil companies, of completely passing on the FTC, levied by airport operators, to the aircraft operators has also been taken up to reduce the burden of surging ATF bills.
                                                • Update: August, 2018




                                                  • Presentation to Secretary, MoCA on 27th July 2018 :- BAOA gave presentation to Secretary CA on important NSOP/GA issues during the monthly stakeholders meeting held in MOCA on 27th July 2018. . Revision of existing restrictions on cross-utilization of crew for NSOP operators, and increasing EDTO limit to 120 min for NSOP flights, were among the important issues on which DGCA is expected issue orders soon. There was positive response from ministry on the all the issues covered in the presentation. Members will be kept informed of the progress on all the issues presented to MOCA.
                                                  • Meeting with JS (MoCA) regarding the number of Cabin Crew upto 19 PAX dt. 20 July 2018 :- BAOA had detailed meeting in MOCA, with DGCA’s participation, on the issue of extending exemption on cabin crew requirement for NSOP flights with less than 20 pax and amendment of the Aircraft Rule 38B in this regard. Necessary follow up discussion took place during the stakeholders meeting on 27th July and instructions were given to DGCA to extend exemption and send case for amendment of Rule 38B.
                                                  • Meeting with Economic Adviser, MoCA to discuss the 'Concept Paper’ for Different Owner and Operator of Aircraft and Import Duty implications dt. 25 July 2018 :- There were focused discussions on ‘aircraft management companies’ and different owner / operator, as well as fractional ownership models. Representatives from Min of Finance also participated in the meeting and had specific queries on GST rates applicable for NSOP as compared to scheduled airlines. There will be regular follow up meetings on the issue and we are hopeful of positive outcome in the next 2-3 months.
                                                  • Letter to DG, DGCA Type Training of FOIs in NSOP dt. 06 August 2018 :- Recently, senior DGCA’s officials have been asking NSOP operators to bear the cost of type training the DGCA’s FOIs. The Governing Board of BAOA deliberated on the issue and decided to take up the issue directly with DG and Secretary MOCA.
                                                  • Update: July, 2018




                                                    • Presentation to Secretary, MoCA on 29th June 2018 :- While participating in monthly stakeholders meeting being held each month under the chairmanship, MD BAOA gave the attached presentation on some important issues affecting GA/BA industry and emphasized the need for time-bound action on all the issues. BAOA has already submitted ‘concept paper’ on reclassification of air operations in India, which would now be discussed in the presence of Secretary CA. Further directions have been given by Secretary CA to address, within 2 months, issues like ‘non-ETOPS’ operations for NSOP/GA, ‘no cabin crew for below 20 seats’, ‘removal of age bar for import of aircraft for aerial work’ and ‘cross-utilization of P1 for NSOP’. The next monthly meeting is slated for 27th of this month and members would be updated further on all these issues.
                                                    • Online allotment of slots at DIAL :- During the last monthly meeting with DIAL, it was informed that, after successfully conducting trials, Delhi airport would shift to online allotment of slots wef 1st August 2018. This would bring greater transparency and efficiency in allotting the slots available at the airport for operating flights. Members are advised to maintain punctuality in utilization of allotted slot to enable the airport operator maximize use of limited slots due to existing capacity constraints. DIAL has started sharing data with BAOA in this regard to highlight the requirement of maintaining slot discipline for efficient operations.
                                                    • Letter to AERA on Comment on AERA Consultation Paper No. 06/2018-19 In the matter of Determination of Aeronautical Tariffs in respect of Indira Gandhi International Airport, Delhi with respect to Base Airport Charges, for the Second Control Period (01.04.2014 to 31.03.2019) :- While commenting on the CP issued by AERA proposing 10% increase in aeronautical charges at DIAL, BAOA has strongly opposed such move to unfairly raise charges under SSA clauses which have become irrelevant after enactment of AERA Act. The same views were echoed during the stakeholders meeting that took place on 11th July 18, 2018. Final orders of AERA in this regard are awaited.
                                                    • Letter to AERA on Comment on AERA Consultation Paper No. 05/2018-19 In the matter of Determination of tariffs for Aeronautical Services in respect of Kempegowda International Airport, Bengaluru, for the Second Control Period (01.04.2016 to 31.03.2021) :- BAOA has raised objections on AERA authorizing Fuel Throughput Charges (FTC) at BIAL and other airports, as this charge is the ‘royalty’ being charged by airport operator to oil companies for providing access to the airport. BAOA has asked for this charge to be rationalized to minimum level, as is there at Pune. We have further argued that this charge should be absorbed by the oil companies and not to be passed through to aircraft operators.
                                                    • Letter to JS, MoCA on Waiving AOR for NSOP flights, with Foreign passengers, to Civil Enclaves at Defence Airfields :- BAOA has asked for expediting positive decision on waiving off AOR for NSOP flights to civil enclaves as this issue has been hanging on for quite some time now. Please see the attached letter sent to MOCA in this regard and the same would be followed up as agenda point during the next monthly meeting at MOCA.
                                                    • Dos and Don’ts for Operators :- The ‘safety committee’ of BAOA is preparing a list of proactive actions / checks required to avoid incidents / accidents, keeping in mind the recent fatal accident in Mumbai. The list would be shared with all our members next week. Any input in this regard is welcome.
                                                    • Update: June, 2018




                                                      • eGCA project of DGCA. The much awaited eGCA project has made progress to the next phase :- Following the meeting held by Secretary CA with on 15th March 2018, the ‘As-Is’ and ‘To-Be’ phases of the project have just been completed. DGCA would be soon floating RFP for engaging System Integrator. The ‘To-Be’ document prepared by DGCA’s consultant, indicating all that would be online, is being sent to all our members today through separate email (it is 461 page document). Members are requested to send their inputs / comments by 18th June 2018, noon time, to enable us collate the information and forward to DGCA by 5pm, same day. Contents regarding each DGCA’s department are given in the beginning. Members are requested to pay special attention to chapters 3,5 6,7,9,1011,12,13,14 and 15 while preparing their comments / inputs.
                                                      • Letter to DG, DGCA on Re-Categorization of Air Transport Ops in India :- As a follow up of the minutes issued by MOCA, post BAOA’s presentation given on 26th September 2017, the ‘Concept Paper’, suggesting reclassification of air transport operations, has been sent to DG DGCA. This is our ongoing effort to achieve proportionate and flexible regulations for small aircraft operations in India, in line with the global best practices.
                                                      • Letter to DG, Ministry of Tourism & JS, MoCA as representation against arbitrary order of UCADA :- BAOA has taken up the issue of levying unfair and arbitrary royalty / landing / parking charges by Uttrakhand administration on Char Dham charter operators. The issue was raised during the stakeholders meeting at FICCI on 4th June 2018, which was attended by MOCA and States officials. This was followed by the letters sent to DG Tourism GOI and MOCA. Progress on our representation is being closely monitored.
                                                      • Letter to DG, DGCA on Cross-utilization of Pilots in NSOP:- We continue to take up the issue of unrestricted cross-utilization of pilots for NSOP operators. The issue was mentioned by the Secret