UK CAA PROMISES NOT TO GOLD-PLATE EURO REGS

04 Jun 2013

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The CAA has issued an update on pilot licensing promising not only to offer better service but also not to "gold-plate" EASA regulations - something it has been accused of in the past.

The introduction of the new European regulations for pilot licensing has resulted in a significant amount of change for UK pilots in the past year, says the CAA. It has also impacted the CAA's systems and processes.

So far in 2013 the CAA has provided over 11,000 licences and ratings to pilots. But the systems and processes that we use to undertake this work are in need of significant updating and this is now starting to take place.

A root and branch review of the licensing process has already started to deliver significant improvements that will continue over the next few months. These include:

• Setting up a central hub to handle transactions that is led by a new team providing a stronger focus on customer service and deploying resources more effectively
• Putting in place a tracking system for each transaction that allows us to actively pursue any item that has not been processed in the expected timescale and also allowing us to respond more quickly to customer queries
• Developing easier access to material and guidance on licensing issues, primarily through online factsheets
• Undertaking a comprehensive review of queries and complaints to target improvements
• Regularly retraining our teams on key EASA changes and implementing quality assurance checks on all our work
• Working with stakeholders to capture their views and ideas on how to improve our systems
• Making as many of our forms and transactions online as soon as possible

Many of these improvements are already making a difference with the turnaround time for new licensing transactions now within our published code of practice target of 10 days, and in some cases down to five working days.

Future of the IMC rating
We are still in discussion with the UK Government, the European Commission and EASA on the possibility of retaining the UK’s Instrument Meteorological rating (IMCR) for new applicants post April 2014. It has already been agreed that pilots who hold the IMCR before that date may retain it on their European Part-FCL licences as a restricted Instrument Rating. We will continue to issue updates on the IMCR status as this work develops.

Training organisations
The EU regulations also introduce increased oversight of flight training organisations carrying out training for private licences. As we are satisfied that these schools currently achieve acceptable safety standards we are working with the industry to introduce the new requirement with the minimum regulatory burden.

We are still working on proposals but our initial thoughts on where costs for industry could be cut include:

• Delegating the oversight of the schools to a third party organisation, potentially an industry representative group
• Providing a free template manual for training schools to use. The manual is one of the key requirements for the approval, and a template will save organisations a considerable amount of time and reduce our oversight and costs
• Ensuring that we only use staff that are suitably qualified and experienced in the GA sector

We will also seek to impose the minimum amount of regulations allowable, including the option to extend the frequency the schools are audited from every two to every three years.

We aim to provide industry with our full proposals in July and will be running a series of road show events for organisations to find out more.

UK implementation of European regulations
As far as licensing policy is concerned, the CAA has also clarified how it will interpret existing national standards under EU regulations. The existing national standards documents provide guidance only and the CAA will not be imposing upon stakeholders any requirement to comply with material in these. We have committed to eliminate any ‘gold-plating’ of EU regulations, and will not impose any higher standards, or extra requirements than those required by the EU.

The obligation is to meet the requirements in Part FCL and Part ORA. This can be achieved by following EASA’s Acceptable Means of Compliance (AMC). Where these don’t exist, guidance material from our existing standards documents can be used, supported by an equivalent safety case. In this case we will make a decision whether this should be proposed as alternative means of compliance and submitted to EASA.

In the future we will re-publish the content of the standards documents as AMC and guidance material.

As well as the improvements to our licensing role the CAA has committed to responding positively to the recent Government Red Tape challenge on General Aviation. We will publish our full responses and proposed actions to the challenge in the coming months.

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