Select Committee on Transport Minutes of Evidence

Memorandum submitted by the Society of British Aerospace Companies


  1.  SBAC is the national trade association representing 2,500 companies supplying the civil air transport, aerospace defence, homeland security and space markets operating in the UK economy. Many SBAC members are involved in the 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.


  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, under EU Regulation 1592/2002, is taking place in phases and SBAC is concerned about:

    (a)    the lack of clarity in the process of implementation including the completion dates and the degree of functions that will be shared between EASA and CAA;

    (b)    the impact on the efficiency of certification which has been significantly affected;

    (c)    financing of EASA;

    (d)    financing of the components of CAA that remain in place; and

    (e)    loss of staff with considerable expertise from CAA from the regulatory environment (ie experienced CAA staff not transferring to EASA).

  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.


  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.


  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.


  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 12 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.


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


  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.


  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 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.

14 November 2005

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