Changes to Air­craft Age- Based Re­quire­ments Would Pro­mote Thai­land’s Com­pet­i­tive­ness

Thai-American Business (T-AB) Magazine - - Contents - Writ­ten by: Michael Doyle

The Thai cab­i­net’s re­cent ap­proval of an ini­tia­tive to make Thai­land a re­gional avi­a­tion hub has gen­er­ated ex­cite­ment among many aero­space in­dus­try lead­ers. Aero­space ex­ec­u­tives agree that due to its cen­tral lo­ca­tion in the re­gion, vi­brant tourism in­dus­try, and in­dus­trial ca­pac­ity Thai­land is well suited to be­come a re­gional aero­space hub. How­ever, there are sig­nif­i­cant chal­lenges to mak­ing this am­bi­tious plan a re­al­ity.

One of these chal­lenges in­volves bal­anc­ing the need to make Thai­land’s reg­u­la­tory frame­work more com­pet­i­tive in re­la­tion to that of its neigh­bors, while at the same time main­tain­ing high air­craft safety stan­dards.

AIR­CRAFT AGE RE­QUIRE­MENTS AND THEIR IM­PLI­CA­TIONS

All air­craft op­er­at­ing out of Thai­land are re­quired to be reg­is­tered with the Civil Avi­a­tion Author­ity of Thai­land, or CAAT.

In or­der for the Royal Thai Gov­ern­ment to suc­cess­fully es­tab­lish Thai­land as an avi­a­tion hub, one of the things that will need to oc­cur is that the num­ber of Thai­land-reg­is­tered air­craft will need to in­crease sig­nif­i­cantly. More reg­is­tered air­craft would mean more de­mand for maintenance and re­pair, train­ing, and other multi- re­gion op­er­a­tion sup­port ser­vices and would help to at­tract a crit­i­cal mass of avi­a­tion ser­vice com­pa­nies with the ex­per­tise, ca­pa­bil­i­ties, and re­sources nec­es­sary to make Thai­land an avi­a­tion hub.

One le­gal re­quire­ment for air­craft reg­is­tra­tion vir­tu­ally unique to Thai­land that has a sub­stan­tial neg­a­tive im­pact on the avi­a­tion in­dus­try here ( both di­rectly and in­di­rectly) is im­pos­ing age lim­i­ta­tions on air­craft reg­is­ter­abil­ity. Un­der the cur­rent rules, if a Thai or for­eign com­pany seeks to reg­is­ter a fixed wing air­craft that is over 16 years old ( from the date of man­u­fac­ture) such reg­is­tra­tion would be de­nied on the ba­sis of air­craft’s age.

Sim­i­larly, if a Thai or for­eign com­pany seeks to reg­is­ter a he­li­copter that is over five years old ( from date of man­u­fac­ture) such reg­is­tra­tion would also be de­nied on the ba­sis of the air­craft’s age.

The above two air­craft age re­stric­tions make lo­cal op­er­a­tors re­gion­ally un­com­pet­i­tive from a cost­ing stand point as they re­quire Thai­land op­er­a­tors to pur­chase newer air­craft while op­er­a­tors else­where in the re­gion, such as in Sin­ga­pore and Malaysia, are not bound by any air­craft age re­quire­ment.

For ex­am­ple, sup­pose a Thai­land op­er­a­tor wishes to pur­chase a fleet of five heli­copters for use by oil and gas com­pa­nies with plat­forms off­shore. In this sit­u­a­tion, the Thai­land op­er­a­tor would be forced to in­vest in the pur­chase of heli­copters un­der six years old whereas op­er­a­tors from Sin­ga­pore and Malaysia would be free to pur­chase older heli­copters.

Ac­cord­ingly, if the gov­ern­ment were to do away with the above- de­scribed air­craft age lim­i­ta­tion it would work to:

1) in­crease the num­ber of Thai­land reg

is­tered air­craft, 2) make Thai­land op­er­a­tors more price

com­pet­i­tive re­gion­ally, 3) at­tract global avi­a­tion com­pa­nies to

es­tab­lish op­er­a­tions here,

which would cu­mu­la­tively help to make Thai­land an avi­a­tion hub.

It is un­der­stood that the gov­ern­ment’s pri­mary rea­son for im­pos­ing these air­craft age lim­i­ta­tions is due to safety con­cerns.

AIR­CRAFT AGE LIM­I­TA­TIONS AND SAFETY

Although pro­mot­ing air­craft safety should al­ways be of pri­mary con­cern, us­ing air­craft age lim­i­ta­tions as a way to pro­mote safety is, how­ever, mis­placed as ev­i­denced by the fact that the avi­a­tion reg­u­la­tors in coun­tries like the U. S., Canada, Aus­tralia, UK, Ger­many, Malaysia and Sin­ga­pore do not im­pose any such age lim­i­ta­tions.

It should also be noted that af­ter the air­craft has al­ready been reg­is­tered in Thai­land there is no longer any age lim­i­ta­tion ap­pli­ca­ble which brings into ques­tion the link be­tween air­craft safety and air­craft age in the first place.

In ad­di­tion, an In­for­ma­tion Pa­per is­sued by the fore­most global civil avi­a­tion body ( the In­ter­na­tional Civil Avi­a­tion Or­ga­ni­za­tion or ICAO) in Fe­bru­ary 2015 states as fol­lows: “The anal­y­sis of the im­pact of air­craft safety does not sup­port sim­ple age­based re­stric­tions as the most ef­fec­tive mech­a­nism to main­tain avi­a­tion safety.”

In­stead of im­pos­ing age lim­i­ta­tions for reg­is­tra­tion, a more pro­duc­tive way for the Thai gov­ern­ment to pro­mote air­craft safety would be to in­stead re­quire strict en­force­ment of the reg­u­la­tions stated in the ag­ing air­craft pro­gram as is­sued by the air­craft’s man­u­fac­turer. This is pre­cisely the course of ac­tion that neigh­bor­ing aero­space hubs have taken and that in­creased level of rigor in­stills com­pli­ance at the op­er­a­tor level, which will ul­ti­mately serve to in­crease the safety cul­ture in the in­dus­try.

In ad­di­tion, Thai­land has been a mem­ber of ICAO since 1947 and ICAO also is­sues its own guide­lines with re­spect to the in­spec­tion of ag­ing air­craft by the op­er­a­tor, au­di­tor and the gov­ern­ment reg­u­la­tor which it ex­pects all of its mem­bers to fol­low. These guide­lines are very well es­tab­lished and con­sid­ered best prac­tices in the in­dus­try. There­fore, if the Thai­land gov­ern­ment were to is­sue reg­u­la­tions specif­i­cally re­quir­ing all op­er­a­tors to strictly fol­low these es­tab­lished guide­lines it will en­sure that the high­est safety stan­dards and best prac­tices are ap­pli­ca­ble to all Thai­land op­er­a­tors.

By in­sti­tut­ing these ac­cepted safety reg­u­la­tions, ad­vo­cat­ing ad­her­ence to es­tab­lished ICAO pro­ce­dures/ guide­lines, and do­ing away with the cur­rent air­craft age re­stric­tions, the Gov­ern­ment would send a very strong sig­nal to the global mar­ket that Thai­land is se­ri­ous about mod­ern­iz­ing its avi­a­tion reg­u­la­tory regime.

It would also im­me­di­ately in­crease Thai­land’s re­gional com­pet­i­tive­ness in the aero­space sec­tor and lay the ground­work for Thai­land to be­come a re­gional aero­space hub.

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