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Inquiry into the remit and work of the Civil by cqb96228

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									                             Inquiry into the remit and work of the Civil Aviation
report title
Inquiry into the remit and
work of the Civil Aviation
                             Authority (CAA)
Authority (CAA)


ref
SBAC-CAT-PPR-05-1022
(1.0)                        Introduction

issue
1                            1. SBAC is the national trade association representing 2,500 companies supplying
                                the civil air transport, aerospace defence, homeland security and space markets
date                            operating in the UK economy. Many SBAC members are involved in the
14/11/05
                                manufacture of equipment and components for aircraft as well as whole aircraft
                                and are therefore very familiar with the CAA activities associated with safety and
                                certification.

                             2. The remit and scope of work undertaken by the CAA has changed significantly in
                                recent years. In particular, the safety and certification of aircraft and their
                                components and equipment including design, now falls under the auspices of the
                                European Aviation Safety Agency (EASA) who have subsumed many of the
                                responsibilities previously vested in the CAA.

                             3. SBAC members have extensive experience of working with the Civil Aviation
                                Authority and hold the service that they have offered in very high regard. The CAA
                                has traditionally operated to a very high technical standard, both in the certification
                                of equipment and aircraft, and organisational approval and oversight that many
                                would attest to being the best in Europe.



                             Service to the aviation industry

                             4. Employees of the CAA have traditionally been drawn from industry and it is felt that
                                this commercial level of training and understanding has helped underpin an
                                excellent working relationship between members of the aerospace sector and the
                                CAA.

                             5. Of particular note was the efficiency of the service provided, the ability of staff to
                                respond to the needs of companies seeking certification and, in some
                                circumstances, going beyond the call of duty to work with members if there was an
                                urgent need for certification, testing or validation. One member remarked that a
                                CAA employee test piloted an aircraft on a Saturday morning to ensure that the
                                programme could proceed to deadline. This type of working relationship has
                                enabled the authority to successfully work with industry and lead to a workable
                                process that delivers certification of equipment and aircraft to a very high standard.

                             6. Many of the functions that the CAA has traditionally been responsible for have
                                been transferred to EASA. The transition of responsibilities from CAA to EASA,
society of british
aerospace companies             under EU Regulation 1592/2002, is taking place in phases and SBAC is concerned
duxbury house                   about:
60 petty france
london
sw1h 9eu                                    a. the lack of clarity in the process of implementation including the
united kingdom                                 completion dates and the degree of functions that will be shared
tel
                                               between EASA and CAA
+44 (0) 20 7227 1000                        b. the impact on the efficiency of certification which has been
fax
                                               significantly affected.
+44 (0) 20 7227 1067
email                                       c. financing of EASA
post@sbac.co.uk
web
                                            d. financing of the components of CAA that remain in place.
www.sbac.co.uk                              e. loss of staff with considerable expertise from CAA from the regulatory
                                               environment (ie experienced CAA staff not transferring to EASA)

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7. The CAA’s style is generally pragmatic and commercially appropriate and its
   regulation style is less prescriptive than it used to be. This comes from it
   encouraging industry to adopt a safety case management system approach to their
   business and regulating it via audit rather than inspection.



Transition of roles from national aviation authorities to EASA

8. Regulation (EC) No 1592/2002 of the European Parliament and of the Council set
   out the aim of bringing about common rules in the field of civil aviation and
   establishing a European Aviation Safety Agency (EASA).

9. The aim of the European Aviation Safety Agency (EASA) is to develop and
   regulate aviation safety rules and, in particular, ensure their uniform application
   within the EU, whilst seeking harmonisation with US and other world rules.

10. The process of transferring roles from CAA to EASA is taking place in stages.
    There is a lack of clarity amongst members at the stage EASA will take
    responsibility for some specific functions. Currently EASA is sub-contracting many
    certification tasks to the CAA and other national aviation authorities during an
    unspecified transition period. Airworthiness and safety responsibilities are being
    taken over gradually; operations and licensing appear to be the next in line.

11. There appears to be a mismatch between the speed at which the CAA is reducing
    its activities and which EASA is increasing theirs. Employees of the CAA, with
    considerable expertise, are not being recruited by EASA and there is a concern
    amongst members that expertise is being lost from the field that will be both difficult
    and costly to replace. This has implications for the effectiveness, cost and
    efficiency by which EASA conducts its role. There is a lack of transparency on how
    the process is moving forward.

12. SBAC would like to see a clear timetable and transition plan for the transfer of
    specific functions from CAA to EASA. Incorporated into this timetable should be
    clear projections of staffing/expertise needs future finance arrangements and an
    analysis on how future needs will be met.



Financing the CAA/ influencing EASA

13. CAA is committed to self-financing and is required to make a 6% return on capital;
    this is excessive particularly when compared to other departments/agencies across
    government.

14. It is not clear what the role of CAA should be as EASA increases its share of
    activities. Industry cannot afford to pay twice. It is difficult for SBAC to comment
    on the precise financing arrangements since the forward development plan of
    EASA and CAA is unclear. However, if the majority of functions are subsumed by
    the European body, as was originally intended, it is not clear that the future role of
    the CAA will extend far beyond an advisory role to the Department for Transport
    who are the UK’s representatives on EASA. Whilst the former activities of the CAA
    in working directly with industry may have helped inform the advice it provided to
    the UK’s representatives, a lower level of hands on activity, especially within the
    commercial and transport aircraft related segments, diminishes the benefit of this
    advice. In the light of this, SBAC recommends that there should be a formal
    mechanism by which industry feeds its views to UK representatives on EASA.




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Processing Certification

15. The process of certification has become more time consuming since operations
    were taken over by EASA. This appears to extend from a lack of clarity between
    the two organisations concerning areas of responsibility and an over cautious
    interpretation of rules by CAA. There have been circumstances where a
    certification process that should have taken two weeks has taken twelve to
    complete. This level of delay has implications for the successful operation of a
    globally competitive industry.

16. It is important to achieve clarity between the successful functioning of CAA and
    EASA in the certification of equipment, since such significant delays undermine the
    competitiveness of UK industry. SBAC would like to see a clear performance
    target from EASA to turn around certification within a defined time period.



Need for a clear UK airspace policy on Unmanned Aerial Vehicles

17. The CAA has passed all clearance activity for Unmanned Aerial Vehicles (UAV)
    below 150kg to a newly formed company, USS in Aberporth. Clearances for UAVs
    above 150kg are the responsibility of EASA.

18. SBAC is concerned that this arrangement has created a potential for inconsistency
    in the approach to certification of UAVs operating in UK airspace. We would be
    interested to see this issue explored and would specifically be interested to know
    what the CAA remit will be in the future for UAV certification under 150kg and what
    its relationship will be with EASA in this regard.

19. SBAC would also be interested to understand how the CAA intends to position
    itself within the Single European Sky initiative and what impact is expected. In
    addition, how will the CAA link with the insertion into air traffic for UAVs?



Business friendly approach

20. It is important that EASA remains accessible and responsive to the needs of
    commercial enterprises. Industry has benefited from a good working relationship
    with the CAA and it is important for safety and the competitiveness of the industry
    that this goodwill is transferred to EASA.

21. The location of EASA in Cologne poses particular challenges to SMEs and it is
    important that accessibility issues are addressed in some way. In the ordinary
    operation of a straightforward certification there is little change in the application
    process for a company that applies to EASA rather than the CAA, other than
    directing the application to Cologne. However, where there is a problem with the
    application and a meeting is required to resolve this, the impact upon SMEs of
    travelling to the EASA offices in Cologne rather than a UK office to resolve this can
    be considerable, particularly if multiple visits are required.



Concluding remarks

22. The remit, structure and powers of the CAA are going through a period of
    substantial transition. The performance of CAA in relation to its statutory objectives
    and functions has been historically good and industry has enjoyed a good working
    relationship with the authority.

23. The lack of clarity in the transition process between CAA and EASA has created
    some operational difficulties most notably the length in processing certification
    applications. As the process of transition moves forward there is the potential for
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    additional problems to arise. A clear timetable and transition plan for the transfer of
    specific functions from CAA to EASA should be made available to industry so that
    such problems can be averted; this timetable should contain projections of staffing
    needs and future finance arrangements.

24. Industry and air safety have benefited from a good working relationship with the
    CAA; it is important that EASA remains accessible and responsive to the needs of
    commercial enterprises.

25. The significant changes in the remit, structure and role of the CAA affect the ability
    of the authority to advise UK representatives on EASA. In light of this changing
    role it is appropriate that a formal mechanism is developed by which industry feeds
    its views directly to UK representatives at the Department for Transport.




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