The collaboration day for UK industry with the CAA marks a new approach to working together between UK airworthiness organisations and the national regulator. A wide range of airworthiness interests are now represented – a significant shift from the days where only scheduled airlines held such meetings together with the CAA. Our model has evolved to include not only airlines, but also independent Maintenance Repair Organisations (MROs), British Helicopter Association (BHA), Aircraft Owners & Pilot Association (AOPA), Association of Remotely Piloted Aircraft Systems (ARPAS) and British Business & General Aviation (BBGA). With this group now acting as one voice we can present a unified industry perspective to our colleagues in the CAA.
Our approach to working with the CAA means that the industry team meet regularly to identify and prioritise key issues that need to be addressed with the CAA. Subsequently, an executive team engages in detailed discussions with the CAA’s Chief Surveyor and the relevant members of the airworthiness team who can best contribute to resolving these specific issues. Working with a smaller team facilitates efficient progress and helps yield positive outcomes for the industry.
However, the focused approach described above does have its downside, as it might limit interaction between the wider industry and the CAA’s staffs compared to in the past. To address this, the annual collaboration day is the opportunity to provide transparency for industry and the wider CAA airworthiness team. This provides Industry representatives with the opportunity to see that the issues they have been raising to their Executive Committee (ExCom) are being addressed, while also allowing the CAA to hear wider perspectives from industry, rather than hearing through the prism of one set of people. Now we have passed through the pandemic, we plan to have an annual Airworthiness event for the foreseeable future.
Airworthiness Update
The topics for the event were mutually agreed upon by industry and the CAA, resulting in a comprehensive coverage of all the material most relevant to airworthiness in the UK aviation sector in.
We began with a comprehensive review of CAA activities briefed by the Chief Surveyor, which gave us a good idea of the changes which are taking place at the CAA. As well as several structural changes it was acknowledged that some elements are still in transition. We were provided with an explanation as to why oversight will need to change in the context of BREXIT. The most obvious example was the increase in overseas 145 approvals and managing over 400 approvals will provide a challenge unless a change is made.
Airworthiness Policy update
The legal team provided us with a comprehensive explanation of their ongoing projects aimed at driving change in legislation. It is fair to say that one of the questions most frequently asked is how we can avoid deviating from EASA and ICAO regulations to ensure that the cost of ownership is not impacted when moving assets globally.
What became clear is that the legal process is far more complex than many of us initially thought. EU regulations cannot be adopted as written and passed into the UK statute. Without even considering the different origins of both legal systems the structure of drafting things is different and what that means practically is that everything must be rewritten by the CAA legal team before presenting that to the DfT. The DfT’s legal team then reviews the content and often struggles with the terms that have different meanings within the global community. As a result, a key word will be rejected because of perceived risk of litigation, ultimately bringing the process to a halt.
This approach means that fundamentally the whole process is resource intensive both in the CAA and at the DfT. Consequently, it is essential to carefully handle the implementation of any legislative changes, making the priorities which we place on the action list very important. We cannot afford any wasted effort on a legislative change unless it really benefits industry performance and safety regulation.
UKCAA BASA
The work which has been taking place on BASA negotiations was also surprising to many of the attendees and the presentation material showed us several agreements which had already been ratified and a number of those were unilateral.
While these agreements may not be the full bilateral agreement which we may like to have with EASA, it is however still positive to see that we are trying to open doors where possible. It is important to acknowledge that the CAA team were searching for information from industry to help them make a business case for entry into certain large markets.
Customer Experience
We were presented with the programme for the complete update of the CAA’s approach to customer service. This involves a three-year programme starting effectively form March 2024. However, work is already underway, and we were presented in an earlier session a new digital approach for Engineering licences, which I will discuss later. The emphasis on improving customer service was a central recommendation of the recent report delivered to the CAA from consultants commissioned by DfT. The project lead on this programme was very keen to collaborate with industry and to consult with us to secure appropriate priorities where feasible.
Returning to the engineering licence digitisation a pilot programme has been initiated and three organisations have volunteered to support the trial. In addition to these larger organizations, it was decided that testing small and medium-sized enterprises (SMEs) and independent individual applicants would also be a valuable test.
We are currently waiting for the slide pack briefing the above CAA programme.
PBR/PBO
This area has always been one of great interest to industry since the model shown to us over six years ago instilled certain beliefs and expectations of progress in 18-24 months.
We were provided with the above presentation, and it is interesting to note that the language has now shifted from performance-based oversight to Risk Based Oversight. This shift is significant because it suggests that organisations are now evaluated on the risk that they pose, with their performance being of secondary importance. The initial concept of PBR/PBO was that well performing organisations would be managing the compliance requirements outlined in the regulations and the oversight would be based on emerging risks from other sources. If this approach had been implemented as planned both industry and regulator would have required fewer resources without compromising safety.. In practice that would have allowed the regulator to use additional resources on areas of concern on issues, or in organisations who are not performing as well as expected. The presentation was still theoretical at this stage, and we have a fair way to go to meet our initial expectations.
AOB
There were a few questions raised on the day and several questions posed in advance. The details of those responses from the CAA will be supplied in due course. In practice all questions were answered on the day, and nothing needed to be taken away.
The areas discussed were SPO and the difference in operational requirements with Part 91 operations being less onerous than our requirements for G registration.
The topic of military pathways for recruiting personnel into civil aviation was discussed and we were made aware of progress with the Army to develop accreditation for serving staff. This has not been actively developed with the other two services at this time. This initiative aims to address the shortage of staff in the aviation industry and any opportunity such as this is welcomed.
The topic of EASA part 147 approved training currently not being accepted as AMC for UK registered aircraft remains unresolved. There is no logical reason for this restriction, purely a legislative block.
Finally, we agreed that the day was a very worthwhile exercise and that we would repeat the event in 2024.
The collaboration day for UK industry with the CAA marks a new approach to working together between UK airworthiness organisations and the national regulator. A wide range of airworthiness interests are now represented – a significant shift from the days where only scheduled airlines held such meetings together with the CAA. Our model has evolved to include not only airlines, but also independent Maintenance Repair Organisations (MROs), British Helicopter Association (BHA), Aircraft Owners & Pilot Association (AOPA), Association of Remotely Piloted Aircraft Systems (ARPAS) and British Business & General Aviation (BBGA). With this group now acting as one voice we can present a unified industry perspective to our colleagues in the CAA.
Our approach to working with the CAA means that the industry team meet regularly to identify and prioritise key issues that need to be addressed with the CAA. Subsequently, an executive team engages in detailed discussions with the CAA’s Chief Surveyor and the relevant members of the airworthiness team who can best contribute to resolving these specific issues. Working with a smaller team facilitates efficient progress and helps yield positive outcomes for the industry.
However, the focused approach described above does have its downside, as it might limit interaction between the wider industry and the CAA’s staffs compared to in the past. To address this, the annual collaboration day is the opportunity to provide transparency for industry and the wider CAA airworthiness team. This provides Industry representatives with the opportunity to see that the issues they have been raising to their Executive Committee (ExCom) are being addressed, while also allowing the CAA to hear wider perspectives from industry, rather than hearing through the prism of one set of people. Now we have passed through the pandemic, we plan to have an annual Airworthiness event for the foreseeable future.
Airworthiness Update
The topics for the event were mutually agreed upon by industry and the CAA, resulting in a comprehensive coverage of all the material most relevant to airworthiness in the UK aviation sector in.
We began with a comprehensive review of CAA activities briefed by the Chief Surveyor, which gave us a good idea of the changes which are taking place at the CAA. As well as several structural changes it was acknowledged that some elements are still in transition. We were provided with an explanation as to why oversight will need to change in the context of BREXIT. The most obvious example was the increase in overseas 145 approvals and managing over 400 approvals will provide a challenge unless a change is made.
Airworthiness Policy update
The legal team provided us with a comprehensive explanation of their ongoing projects aimed at driving change in legislation. It is fair to say that one of the questions most frequently asked is how we can avoid deviating from EASA and ICAO regulations to ensure that the cost of ownership is not impacted when moving assets globally.
What became clear is that the legal process is far more complex than many of us initially thought. EU regulations cannot be adopted as written and passed into the UK statute. Without even considering the different origins of both legal systems the structure of drafting things is different and what that means practically is that everything must be rewritten by the CAA legal team before presenting that to the DfT. The DfT’s legal team then reviews the content and often struggles with the terms that have different meanings within the global community. As a result, a key word will be rejected because of perceived risk of litigation, ultimately bringing the process to a halt.
This approach means that fundamentally the whole process is resource intensive both in the CAA and at the DfT. Consequently, it is essential to carefully handle the implementation of any legislative changes, making the priorities which we place on the action list very important. We cannot afford any wasted effort on a legislative change unless it really benefits industry performance and safety regulation.
UKCAA BASA
The work which has been taking place on BASA negotiations was also surprising to many of the attendees and the presentation material showed us several agreements which had already been ratified and a number of those were unilateral.
While these agreements may not be the full bilateral agreement which we may like to have with EASA, it is however still positive to see that we are trying to open doors where possible. It is important to acknowledge that the CAA team were searching for information from industry to help them make a business case for entry into certain large markets.
Customer Experience
We were presented with the programme for the complete update of the CAA’s approach to customer service. This involves a three-year programme starting effectively form March 2024. However, work is already underway, and we were presented in an earlier session a new digital approach for Engineering licences, which I will discuss later. The emphasis on improving customer service was a central recommendation of the recent report delivered to the CAA from consultants commissioned by DfT. The project lead on this programme was very keen to collaborate with industry and to consult with us to secure appropriate priorities where feasible.
Returning to the engineering licence digitisation a pilot programme has been initiated and three organisations have volunteered to support the trial. In addition to these larger organizations, it was decided that testing small and medium-sized enterprises (SMEs) and independent individual applicants would also be a valuable test.
We are currently waiting for the slide pack briefing the above CAA programme.
PBR/PBO
This area has always been one of great interest to industry since the model shown to us over six years ago instilled certain beliefs and expectations of progress in 18-24 months.
We were provided with the above presentation, and it is interesting to note that the language has now shifted from performance-based oversight to Risk Based Oversight. This shift is significant because it suggests that organisations are now evaluated on the risk that they pose, with their performance being of secondary importance. The initial concept of PBR/PBO was that well performing organisations would be managing the compliance requirements outlined in the regulations and the oversight would be based on emerging risks from other sources. If this approach had been implemented as planned both industry and regulator would have required fewer resources without compromising safety.. In practice that would have allowed the regulator to use additional resources on areas of concern on issues, or in organisations who are not performing as well as expected. The presentation was still theoretical at this stage, and we have a fair way to go to meet our initial expectations.
AOB
There were a few questions raised on the day and several questions posed in advance. The details of those responses from the CAA will be supplied in due course. In practice all questions were answered on the day, and nothing needed to be taken away.
The areas discussed were SPO and the difference in operational requirements with Part 91 operations being less onerous than our requirements for G registration.
The topic of military pathways for recruiting personnel into civil aviation was discussed and we were made aware of progress with the Army to develop accreditation for serving staff. This has not been actively developed with the other two services at this time. This initiative aims to address the shortage of staff in the aviation industry and any opportunity such as this is welcomed.
The topic of EASA part 147 approved training currently not being accepted as AMC for UK registered aircraft remains unresolved. There is no logical reason for this restriction, purely a legislative block.
Finally, we agreed that the day was a very worthwhile exercise and that we would repeat the event in 2024.
