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
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
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
(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;
(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
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
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
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.
UK AIRSPACE POLICY
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
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
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
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