The Malone Column
The radio licence costs how much? Truthfully?
Imentioned a while ago that down here at Bodmin we’ve been stuck with an 8.33khz frequency, which means we’ve had to buy a new transmitter and spend time and money promulgating the news. Well, at the same time we received an invoice from the CAA for £3,350 for next year’s radio licence, which set our airfield manager Jay Gates to wondering why a small grass airfield with an air-ground radio should suffer such a hearty financial imposition. Jay asked around, did a bit of research and ran his own parameters through the CAA’S online tool for working out radio licence fees, and to his surprise he found that by his calculation the Authority should be charging us not £3,350, but £200.
Now even I, without a calculator, can work out there’s a big difference there. I looked at the online tool myself, and for the life of me I couldn’t make head or tail of it. If you’re interested, google ‘CAA radio licence fees’ and click on ‘application fee calculator’−you’ll see what I mean. You’ll get an Excel file called ‘illustrative model of bespoke fee derivation process’ and to my mind it might almost have been cunningly designed to baffle.
Anyway, Jay was sure of his ground and wrote to the CAA in the following terms: ‘Our Circular DOC, as per your illustrative model of bespoke fee derivation process, should only be considered as C-10/30 and, as we are converting this year to an 8.33khz channel, this should attract a capped licence fee of £200. However, we have received an invoice for £3,350, which is a full £3,150 over what it should be.’
Ominous silence from the Authority. With the payment deadline looming, Jay spent a month chasing the matter around Kingsway and Gatwick. The runaround started with: “We can’t seem to find your email…” Just four days before execution date, the CAA finally came back and said yes, he was right. The original invoice was cancelled and another, for £200, was substituted.
But Jay had also pointed out to the CAA that for at least three years Cornwall Flying Club had been charged £3,350 when according to his calculations (and given that we previously had a 25khz frequency) the bill should have been a maximum of £650. Could we have our money back, please. The response from the CAA’S Radio Licensing department: “Unfortunately we are unable to refund a licence fee paid for previous years.”
I think we’ve been mugged. Even if the CAA’S bill was based on data provided by the flying club (and we’ve had a change of management, so the position is unclear) we must expect that personnel in the Authority’s radio licensing department who designed the tool by which calculations were made, and who were dealing with these applications every day of their lives, would have recognised that something was amiss when a small grass airfield looked like it was controlling everything in the South West. And as we have incontrovertibly overpaid, we’re entitled to a refund.
I wouldn’t be as vexed as I am were it not for the fact that I think the whole spectrum pricing business is a racket that tramples on safety in the rush for gold. Back when people started muttering about running out of aviation frequencies, AOPA Germany produced an algorithm showing there were enough for aviation’s needs, now and forever, if the 27 frequency allocation offices in Europe were amalgamated to address overlap and wastage. But several countries, including Britain, claimed that frequency allocation was “a matter of national sovereignty” and said there would be no amalgamation.
What they meant was that they’d discovered something new they could charge for, and they intended to milk it dry. Up to then, they’d levied small administration fees for spectrum, but with the mobile phone business getting its boots on, the airwaves had become eye-wateringly valuable. In fact the Treasury has made more than £25 billion by flogging off spectrum since the turn of the century. Out of thin air!
Then of course the question was asked: why are some people getting radio spectrum for nothing? In aviation’s case, the answer was ‘safety’−but they soon found a dodge around that, which they called Administrative Incentive Pricing (AIP). By charging for aviation frequencies, they claimed to be encouraging people who weren’t making full use of theirs to relinquish them. That might sound plausible to the layman, but only if he thinks a relinquished VHF frequency with a line-of-sight range can be bodily transported to be used elsewhere. The Wireless Telegraphy Act 2006 granted Ofcom the power to set licence fees, and they set out a list of aeronautical R/T fees in the Wireless Telegraphy (Licence Charges) Regulations 2011. That was amended by the Wireless Telegraphy (Licence Charges) (Amendment) Regulations 2014, which came into force in June 2016 and put the prices up. Under the bonkers logic of AIP, given that a 8.33 is a third of 25, the 8.33khz licence cost a third of the 25khz licence. The rest of the formula was pretty opaque, and could easily have caught people out.
Anyway, our Chairman Darren Fern wrote to our MP Scott Mann, who’s a member of the All Party Parliamentary Group on General Aviation, and Grant Shapps’s people went to bat for us with the CAA. And they certainly get a fast response! Within days we’d been contacted by senior executives who wanted full details, and they must have raised a hue and cry because answers that might have taken weeks came by return. First, they apologised for the £3,350 bill, which was generated by a computer and sent out unchecked. Beyond that, no dice−the previous years’ bills had been calculated on the basis of our own information, the slice of air we had claimed was not so outstandingly unreasonable as to excite comment, and the money had been passed straight on to Ofcom−and that’s a one-way street.
So in effect, we’ve been mugged, but it’s our own fault for stumbling by mistake into a dark alley.
It’s possible that Bodmin is not alone in being blind-sided by this; worth checking whether you, too, received a computergenerated demand, and you’re paying for too much real estate.
We’ve written to our MP and the APPG to thank them for trying, and we sit licking our financial wounds. At the end of the year Ofcom will cut out the middleman and trouser the radio licence fee itself, so now the government arm that forces us to have a radio for flight training is different from the government arm that forces us to pay for it. I can’t imagine Ofcom will be more knowledgeable than the CAA about the UK’S airfields; Ofcom won’t know anything about GA finances either, so they may get even more ambitious. I forecast fun and games.