Do you have any other comments on the Aeronautical Product Approvals Fee Modernization Proposal? | Modernizing fees for Aeronautical Product Approvals | Let's Talk Transportation

IE10 and below are not supported.

Contact us for any help on browser support

Do you have any other comments on the Aeronautical Product Approvals Fee Modernization Proposal?

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
    1. The change in fees is justified in the proposal with the statement “A key principle underlying any cost recovery initiative is that service recipients who receive a direct benefit above those enjoyed by the general public should pay a greater share of the costs.” There is no definition or justification of what that greater share should be however. It is also misleading to say that Applicants are necessarily receiving a direct benefit from TCCA services: TCCA involvement in the certification programs of delegates is oversight mandated by regulation, not a service requested by the Applicant. We recommend that a distinction be made for fees charged for Delegate oversight to reflect this. Similarly, fees should not be charged for changes approved by a delegate where there is no revision t the type approval document.2. As mentioned previously, TCCA defines their own scope of Delegate oversight, so simply increasing fees will push the costs of TCCA work onto the Applicant without any accountability on TCCA that their work is of benefit to the public good. TCCA lacks binding policy on what their involvement in a certification project should be, leaving that decision up to individuals at the working level, which in our experience leads to significant variation in TCCA involvement that is independent of the risk or complexity of the certification project. TCCA needs to be required in the regulation to be more accountable to industry on how they are allocating their resources, if the industry is expected to share more of that burden.3. The proposed service standards in Annex C have little value for anything other than routine administrative submissions, as they only refer to response times to acknowledge the listed submissions and assign personnel to a project. We appreciate that certification submissions are inherently complex, difficult to plan, and subject to frequent change, making any service level commitment at the project-level difficult. We would suggest a service standard with more granularity, with time limits for the many specific actions within the certification process. As the proposal would involve accounting of TCCA expenditures anyway, this should be readily achievable.
  • NATA1 6 months ago
    There is also the question raised about the expertise of the regulator in the design and approval process. Technology being incorporated today by Canadian OEM/MRO requires knowledge of the science that is being applied to the newer engineering processes. It has been suggested that an enhanced process of delegation to the industry could be achieved. It was also suggested there could be a process of secondment of TC personnel to gain the new knowledge and skill sets to better provide approval oversight.