FAQ Answer

FAQ Answer

As the activity within the derogation period is likely to be extremely busy, will the resources within the CAA be able to cope?

The CAA will manage its resources to ensure that the transition process runs as smoothly as possible. Stakeholders can assist this process by submitting their declaration of compliance from the Accountable Manager within a reasonable time period before the end of the derogation period. (last updated September 2013)


Flights Operations - General

  1. When will the amended Air Navigation Order be drafted, published and live?
  2. Will there be any cost to the operator for the issue of an EASA Implementing Rules Air Operator’s Certificate?
  3. Will there be a self–assessment compliance document template or will operator need to produce their own? And will it be available in an electronic format?
  4. With EASA, why do we still need the Air Navigation Order? Is there an overlap and what is the difference?
  5. Can a new application be made for the grant of an EU-OPS/JAR-OPS3 Air Operator’s Certificate during the derogation period?
  6. Does the operator or the CAA determine if an operator is Complex or Non-Complex?
  7. Can an existing EU-OPS/JAR-OPS3 Air Operator’s Certificate be varied during the derogation period?
  8. If any operator meets any of the criteria for Complex operator, does that automatically make the operator a Complex operator?
  9. When is the earliest date an operator can start the transition process for the grant of an EASA Implementing Rules Air Operator’s Certificate?
  10. Can a Non-Commercial Air Transport operator, operating complex aircraft have the Management System of a non-complex operator?
  11. Is the CAA going to produce a template/example for Section A3 of the Operations Manual?
  12. Will the differences/compliance checklist completed by the stakeholder have to be agreed by the assigned Flight Operations Inspector?
  13. Will the CAA accept an operator managing risks to “as low as reasonably practicable” and not ‘an “Acceptable Level of Safety” and could this be justified in court?
  14. Will the differences/compliance checklist required for the transition to the EASA Implementing Rules be tailored for non-complex operators?
  15. With the EASA Implementing Rules requiring a change of title from Quality Manager to Compliance Monitoring Manager, is there not going to be a disconnect where the same person also holds the Quality Manager post defined by EASA Part M and EASA Part 145?
  16. Can an operator of a State that has opted-out fly in States which have chosen to implement EASA Implementing Rules?
  17. Will the transition to the EASA Implementing Rules require Operations Manuals/Quality Manuals to be re-written?
  18. Will there be any grandfather rights in respect of Minimum Equipment Lists ie should operators not submit amendments to Minimum Equipment Lists for the time being?
  19. If another Member State has accepted an alternative means of compliance, can this automatically be used by a UK stakeholder?
  20. Will there be a charge for the change in Air Operator’s Certificate documentation?
  21. How can standardisation be achieved between the Member States?
  22. It was suggested that the requirement for a pilot to sign off the pre-flight inspections was no longer in the EASA OPS rules. Is it not in the in the cover regulation?
  23. Will Alternative means of compliance be published and submitted to EASA?
  24. Is the Pre-Flight Check as defined in the Flight Manual the same as the Daily Check?
  25. As the activity within the derogation period is likely to be extremely busy, will the resources within the CAA be able to cope?
  26. Should the correct nomenclature for the new requirements not be EASA-OPS?
  27. How much scope does the CAA have if it transpires that the introduction of an EASA Implementing Rule causes an ‘unintended change’ (unforeseen problem)?
  28. If the CAA applies the maximum derogation period, will an Operator be able to operate to PART-SPO?
  29. ORO.GEN.AOC.100(c) says:

    (c) Applicants shall demonstrate to the competent authority that:
    (1) they comply with all the applicable requirements of Annex IV to Regulation (EC) No 216/2008, this Annex and Annex IV (Part-CAT) and Annex V (Part-SPA) to this Regulation, as applicable;

    You could read this as saying that operators need to produce a cross reference document linking every relevant heading in the legislation to the Operations Manual. Is that really what’s required, or do we arrive at that position as a result of discussions and oral questioning?
  30. What is the intent of Implementing Rule AOC.ORO.AOC.125 with regard to non-commercial operations of aircraft listed in the operations specifications by the holder of an AOC?