Are the proposed revisions to Schedule V fees reasonable? Why or why not? | Modernizing fees for Aeronautical Product Approvals | Let's Talk Transportation

IE10 and below are not supported.

Contact us for any help on browser support

Are the proposed revisions to Schedule V fees reasonable? Why or why not?

5 months ago
CLOSED: This consultation mechanism is closed; However if you have comments on the Aeronautical Product Approvals Fee Modernization Proposal, please send them to CARRAC@tc.gc.ca.

CLOSED: This consultation mechanism is closed; However if you have comments on the Aeronautical Product Approvals Fee Modernization Proposal, please send them to CARRAC@tc.gc.ca.

  • David Waigh - Bombardier 6 months ago
    The Incremental increases to existing fees and charges, as well as future indexing against cost of living increases are reasonable, given that they have not been changed in several years. Absent a change in TCCA policy on what proportion of fees are to be borne by Applicants, an increase in these fees is reasonable just to restore the original balance that has been distorted by inflationary pressures over the years. That being said, this is a large increase in rate, and we would recommend that the increase be phased in with smaller increases over 5 years.The principle to introduce new flat fees for issuance of documents and approvals is reasonable, as is the proposal to introduce cost indexing to avoid repeated routine updates to the fees in the regulation.Hybrid fees are justifiable in principle, but the proposal needs to be clarified to determine if the proposed fees are reasonable in practice. In particular, the point at which hourly charges are charged instead of a flat fee must be reasonable.
  • NATA1 6 months ago
    It seems that the rationale of increasing fees by approximately three times the present rate, is that the very complex costing computations provided seems to indicate the actual cost recovery would be approximately eight times more, and that’s the enough justification to increase the fees “just” three times the present amount.However, there did not seem to be much of an analysis of the fees in which services are presently being charged, and the other fees identified that presently do not have a fee, but soon will be- Is the service still required? Is the service being provided as efficiently as possible?
  • Michael Deer 6 months ago
    It is recognized that TCCA has not changed fees and charges for many years to an increase is warranted. However, fees for applicants need to be predictable to allow applicants to include these costs when determining the business case for new products or changes to existing products. The proposal for some fees to be open ended without specified maximum is not acceptable.
  • sbuss 7 months ago
    An FAA DER may issue a TCCA accepted, FAA approval (Due to an existing bi-lateral agreement) on a repair at NO COST. The repair if produced by a Canadian DAR already comes with a cost of $180 - $220. You intend to increase the charge to $450 - $550. Any increase in repair fees will displace any existing design approval services from Canada to elsewhere. Repairs that remain in Canada will slow down as any margin for revenue is swallowed up (most straight forward repairs don't exceed 1000$) and the incentive disappears. There will simply not be an incentive to produce Canadian repair approvals, from the DAR perspective, and airlines will simply not seek Canadian repair approvals in order to avoid this existing fee. TLDR: You have introduced a tariff on Canadian aerospace engineering companies which work with Canadian airlines (and you want to increase the fee!!!). Airlines are free to avoid the fee by seeking American repair approvals. Thanks.