CRD 2008-07 Part II - European Aviation Safety Agency - Europa

CRD to NPA 2008-07 24 Nov 2010
framework necessitates an in-depth further study.
comment 626 comment by: European Sailplane Manufacturers
response Noted
The European sailplane manufacturers still do not consider the fees & charges
levied by EASA as fair or feasible.
1. The fees are in the end all based on the assumption that one work hour
at EASA is worth 225 Euro. This is simply not justified in a so called
industry where hourly rates are at least lower by a factor of three!
2. The fees for certifiacion of products have to be paid annually as long as
the certification takes. Thereby EASA is not really inclined to work
faster! Experience has shown that the EASA system makes time for
certification longer.
3. Certification of engines and propellers is disproportionate high when
compared to the fees for a ne aircraft.
4. The fees listed here are correct but it is not mentioned that the
application for and the upholding of organisation approvals cost
additional money. It is also these fees which make the business case for
small manufacturers quite difficult.
All legal approvals remain issued by the Agency under its fees and charges
system. This fees and charges system is considered by stakeholders as being a
major hindrance to certification of new aircraft or to certification of changes or
repairs to existing aircraft. The fees and charges regulation is adopted by the
Commission. The applicant pays the fees to EASA. The contracts between EASA
and NAA or qualified entities when they are allocated tasks by EASA contain
the financial arrangements between EASA and NAA or QE. Modifying this
framework necessitates an in-depth further study.
comment 680 comment by: Deutscher Aero Club e.V. (DAeC)
response Noted
The Deutscher Aero Club e.V. welcomes the envisaged alleviations to the
certification process in order to revitalise the light aviation market. However
unless the fees & charges regulation is revised as well the result will not be
lasting.
All legal approvals remain issued by the Agency under its fees and charges
system. This fees and charges system is considered by stakeholders as being a
major hindrance to certification of new aircraft or to certification of changes or
repairs to existing aircraft. The fees and charges regulation is adopted by the
Commission. The applicant pays the fees to EASA. The contracts between EASA
and NAA or qualified entities when they are allocated tasks by EASA contain
the financial arrangements between EASA and NAA or QE. Modifying this
framework necessitates an in-depth further study.
comment 688 comment by: Evektor
EVEKTOR position: current level of fees and charges isn't acceptable for noncommertial
operation. 6000€ per year of on-going certification has no
ekvivalent round the world and therefore current fees and charges has the
discrimination function and don't contribute to competetiveness of european
producer.
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