THE ESAM AND THE BUSINESS PLAN
The HAA in pursuit of its goal of Self-Administration on behalf of the Civil Aviation Authority to provide operational and airworthiness oversight of the Historic Aircraft Industry in the UK has recently followed up the draft Self Administration Exposition (ESAM) submitted to the CAA and circulated to HAA Council in September 2015, with a full Business Plan expounding how the HAA would manage delegated authority. This Business Plan document is now under consideration by the senior executives within the CAA.
At present (April 2016) the CAA GA Unit is having to concentrate on their Air Show Safety Review and respond to the AAIB in respect of the Shoreham Air Show accident of last August. The HAA is expecting work on the Business Plan to resume early May. Regrettably the CAA have called a halt to further work on the ESAM until September 2016. These retardations to progress on the SAM project are frustrating, but understandable in the light of the immense seriousness and necessity for change following on from the Shoreham accident.
The HAA SAM Working Group is continuing to develop the SAM system. The HAA is engaged with politicians and other aviation organisations to assist in creating a wider understanding of what SAM means under delegated authority for oversight. This work will be on-going and later this year we expect to pick up with the CAA GAU where we left off at Easter of this year.
What is SAM?
Simply put, Self-Administration – SAM – is where the industry acts on behalf of the Regulator as the representative body responsible for safety and oversight of all activities and operations within the industry sector it represents. The historic aircraft industry under SAM would be responsible for Operational Authorisations, Initial Issue of Certificates of Airworthiness in the Special Category, and the Continuing Airworthiness for historic aircraft owners and operators.
Why Does the Industry Need SAM?
The CAA need not continue to sustain administrative oversight of the historic aircraft industry. It lacks the required expertise and numbers of staff required to support our relatively small and complex sector of General Aviation. To date the CAA has offered “risk averse” management of the industry through burdensome regulation. SAM offers a “risk management” system providing greater flexibility in operations with improved levels of safety.
What Has The CAA Been Doing?
In recent months the CAA has attempted to offer relief to the GA industry with some changes to regulations. All of these changes have been offered as exemptions to the standard regulations. Adventure Flights for passengers in historic aircraft, and maintenance approvals are being granted piecemeal to a few operators and companies. These changes are not being applied industry-wide, and the approvals are still based on individual expositions being accepted (or rejected) by the CAA.
The Historic Aircraft Industry Can and Should Do It Better
With SAM the HAA could offer a risk-managed system for the whole historic aircraft sector of GA, and with a more expeditious service, and at a more reasonable cost. The HAA aim is to offer SAM as a “can do it better, quicker and cheaper” service.
The Devil is in The Detail
The HAA Council and its SAM Working Group know that it is the detail that is important if this new system is to be a success. The Council have established a holding company – Historic Aircraft Industry Support Limited (HAISL) to deal with the detail as we make progress towards SAM. HAISL has a Board and will have a CEO, a Director of Self-Admin (DSA) and secretarial support with a base probably at Duxford.
A Little Bit About Financials
Fees for approvals will form the basis of HAISL income replacing the current fees charged by the CAA. The Operational and Maintenance Review Boards (ORB and MRB) will be formed as required from appropriate industry experts. Oversight personnel will be engaged as required on a paid contract hour basis. The HAISL will not have the overhead costs that the CAA has to meet, and therefore the charges to historic aircraft owners will be lower.
Next Steps
The SAM Exposition documents will be worked on by the HAA Council; its SAM Working Group and jointly with the CAA SAM Project Team in the General Aviation Unit at SARG HQ Gatwick. From this work will evolve an Industry Consultation document that the CAA will circulate throughout the historic aircraft industry for comment. Subject to amendment after comment the HAA expects Self-Administration to be with us in 2016.
18TH APRIL 2016