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