FEES AND CHARGES MEMORANDUM Fees... · despite only modest increases in line with inflation, and...

EUROPEAN UNION AVIATION SAFETY AGENCY

FEES & CHARGES REVIEW

© European Union Aviation Safety Agency. All rights reserved. ISO9001 Certified. 1 Proprietary document. Printed copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.

An agency of the European Union

FEES AND CHARGES MEMORANDUM

The European Union Aviation Safety Agency (EASA) is in the process of reviewing the fees and charges (F&Cs) it levies on its applicants for the issue of certificates and approvals.

The proposed amendments are important in order to:

— modernise the F&Cs system in line with the latest innovations and emerging technologies, and with EASA’s extended scope of activities according to Regulation 2018/1139;

— ensure that EASA continues to have the necessary resources to fulfil its mission and meet the growing needs of applicants and the travelling public for high-quality certification and approval services in the context of an increasingly competitive aviation industry; and

— constantly improve the application of the F&Cs system to reduce its administrative burden on both EASA and its applicants.

This memorandum details the proposed amendments and their objectives following a brief description of the context in which this F&Cs review is conducted. The F&C review is an ongoing process and the proposal might still be modified in the next months. The main parts modified since the original memorandum was distributed in June 2018 are highlighted.

The memorandum is structured as follows:

INTRODUCTION

A. CONTEXT OF THE F&Cs REVIEW

B. NEED FOR AND OBJECTIVES OF THE F&Cs REVIEW

C. PROPOSED AMENDMENTS TO THE F&Cs SYSTEM

D. NEXT STEPS

APPENDIX A: PROPOSED PRICE TABLES

APPENDIX B: MAIN OPTIONS CONSIDERED BUT NOT RETAINED





INTRODUCTION

The aviation industry is changing rapidly. More people are flying to more destinations. Organisational

business models are being transformed to accommodate drones, digitalisation, robots, connectivity

and additive manufacturing. New entrants to the market are designing, manufacturing and operating

products. The pace of innovation is increasing.

As an aviation safety regulator, EASA must keep pace with these developments and continue to ensure

the level of safety and added value for which it is recognised worldwide.

A hallmark of quality worldwide

Internationally accepted standards are a major contributor to growth, particularly for innovative

technologies. EASA standards are recognised globally and, as an international benchmark, are

increasingly being adopted by other regulators as an alternative to developing national standards.

EASA invests heavily in the gradual convergence of international aviation safety regulations towards a

level that is equivalent to its own. Establishing mutual trust among national regulators is a continuous

task that requires leadership, effort, and technical knowledge.

Industry benefits directly from this harmonisation because it facilitates market access worldwide,

reduces time to market, increases overall safety levels, and lowers costs. Indeed, the quicker new

certified products and services can be brought to the market, the safer and more efficient the market

will be. Achieving EASA certification is a de facto demonstration of meeting appropriate safety

standards for any national regulator worldwide.

A responsive, long-term partner

EASA is to a large part financed by fees charged to applicants that benefit from its services.

EASA is therefore keenly aware that its services have to be of high quality to justify the cost. Thanks

to its quality management system that complies with the ISO 9001 standard, EASA is able to

demonstrate continuous improvements. This is essential in view of the increasing aircraft fleets that

are flying under the EASA oversight, leading to higher exposure and more accountability.

EASA is valued as a stable, long-term partner and due to its comparatively small size compared to

other regulators, is regarded as a dynamic, innovative organisation. A recent example is the

introduction of risk- and performance-based oversight that will optimise over time the compliance

efforts made by industry. EASA’s management is committed to manage lead times and increase the

transparency of the certification process. By investing in digital transformation programmes, EASA

intends to establish the world’s most connected and efficient certification process for aviation.

The need to amend the fees system

EASA has not adjusted its fees materially since 2014. In addition, as from 2016, EASA supports

additional staff costs linked to pension contributions. After a thorough review, EASA has come to the

conclusion that the revenues from some of its services no longer cover the associated costs and it

therefore needs to adjust its pricing. The proposal set out below aims to bridge this gap in revenues

as of 2020, taking into account forecast developments over the next 5 years.





Additional benefits for industry

At the same time, EASA has taken steps to improve the way it charges by reviewing every service and

fee category. Applicants will see that:

— in addition to existing privileges for minor changes/minor repairs, design organisation approval

(DOA) holders may now also be granted privileges, under conditions, to carry out some major

change work and Maintenance Review Board items;

— DOA holders with an existing alternative design organisation approval for European technical

standard orders (ETSOs) can lighten their management burden by incorporating the privilege

under their DOA and benefit from a reduction in EASA’s level of involvement (LoI) in some

individual projects;

— fees proposed for product design certificates now cover Operational Suitability Data (OSD) and

Management Review Board (MRB) activities;

— significant leaps in fees among adjacent categories have been smoothed out; and

— a new range of partnership services will be offered in order to support research as well as

development activities and innovation.

EASA has overhauled the annual price adjustment mechanism. A regular price review mechanism will

allow to gradually adjust prices in a transparent and structured way, reflecting not only cost evolution

(including necessary investments) but also efficiency gains, for which specific targets will be defined

and to which EASA will commit. This structural mechanism will be embedded in the 3-years Single

Programming Document, approved by EASA’s Management Board and monitored through the same

governance system.





A. CONTEXT OF THE F&Cs REVIEW

Financing EASA

To fulfil its tasks, EASA mobilises resources that are financed by several sources (including a contribution from the Union and participating States) and fees paid by applicants for, and holders of, certificates and approvals issued by EASA, and charges for publication, training and other services.

The current review focuses on fees and charges (F&Cs).

The Fees & Charges Regulation

Commission Regulation (EU) No 319/20141 (the F&Cs Regulation) determines the cases where F&Cs are due, their amount, and how they are to be paid. The fees levied by EASA for most of its certification and approval activities are ‘yearly fixed fees’ calculated on an annual basis.

Fees for most product certification activities are determined by the nature of the activity (e.g. major change approvals or continuing airworthiness activities) and other factors that are specific to each activity (e.g. maximum take-off weight (MTOW), or complexity). Fees for most organisation approval activities are determined by the type of organisation approved (e.g. design or production organisation) and other factors specific to each organisation type (e.g. turnover, number of staff, or type rating).

While the F&Cs Regulation provides a fixed fee for most certification and approval activities, other activities are charged at an hourly rate.

The F&Cs Regulation provides a mechanism by which all fees and charges are automatically adjusted annually in line with the change in the Harmonised Index of Consumer Prices (HICP). HICP inflation has been relatively low in the last few years. Since the adoption in 2014 of the current F&Cs Regulation, HICP inflation led to a total cumulative increase of only 2.3 % over the last 4 years, the equivalent of a mere 0.6 % increase per year.

B. NEED FOR AND OBJECTIVES OF THE F&Cs REVIEW

The adoption of the current F&Cs Regulation in 2014 led to substantial improvements. It introduced a simple, predictable and widely accepted approach based on annual flat fees for the majority of certification activities. Until recently, the revenues generated supported EASA’s need to grow and strengthen its position as a global leader.

While the foundations of the current F&Cs Regulation remain appropriate today, the need to modernise some important aspects emerged recently. This comes as no surprise knowing that between 2005 and 2008 the F&Cs Regulation in force at the time was the object of regular minor amendments, while the current F&Cs Regulation has not been amended since 2014, and once it is adopted, the revised F&C Regulation is expected to enter into force in 2020. However, for various reasons detailed in the following sections, more frequent adjustments of the F&C are required to ensure the Agency’s budget is sustainable over time. Indeed, the costs and revenue projections informing the revision in 2014 turned out to be more pessimistic than actual results, leading to initial surplus being accumulated. This surplus, combined with cost control, allowed to sustain the Agency despite only modest increases in line with inflation, and postpone the revision until 2020. With the

1 Commission Regulation (EU) No 319/2014 of 27 March 2014 on the fees and charges levied by the European Aviation Safety Agency,

and repealing Regulation (EC) No 593/2007 (OJ L 93, 28.3.2014, p. 58).





next revision of the regulation EASA intends to achieve a more transparent and measured system that allows smaller, more regular adjustments that track actual conditions more closely.

The main objectives of the F&Cs review mirror the three main causes for the emerging need to modernise the current F&Cs Regulation:

1. Adapt to new technologies and additional responsibilities for EASA;

2. Create a sustainable system allowing long-term financial stability, to balance financial deficit and a forecast of deficit growth, due largely to preserving expertise and covering staff pension contributions previously financed from EU subsidy;

3. Further streamline the application of the F&Cs system.

New technologies and new responsibilities for EASA

The current F&Cs Regulation provides a fee structure based on specific product categories (such as ‘fixed-wing aircraft’, ‘rotorcraft’, ‘airships’ and ‘balloons’) and organisation categories (such as ‘design organisations’ and ‘maintenance organisations’). Those categories are fixed and are intended to be mutually exclusive and collectively exhaustive. Accordingly, the certification fees for any aircraft that cannot be categorised as either ‘fixed-wing aircraft’, ‘rotorcraft’, ‘airship’ or ‘balloon’ will automatically be calculated using an hourly rate. The same holds true for other product categories and organisations.

However, the aviation industry continues to introduce innovative products and technologies that challenge traditional categories. For example:

— Remotely Piloted Aircraft Systems (RPASs), commonly known as ‘drones’;

— hybrid fixed-wing/rotor aircraft that are designed to take off vertically using tilting rotors and change configuration in flight to create lift using fixed-wings during cruise;

— electrical engines that form integral part of an aircraft framework.

In parallel, Regulation 2018/1139 has extended the scope of organisations EASA can approve. However, the current F&Cs Regulation does not provide for an appropriate fee structure for these new organisations. Fees will thus be calculated on an hourly rate — an approach that applicants describe as unpredictable and that generates considerable administrative burden for both EASA and its applicants compared to a flat fee.

EASA thus needs a more flexible method of charging for novel products and organisations. To ensure cost-reflectivity, this new flexible proposal embraces the risk-based approach being adopted by EASA at technical level.

Financial deficit and forecast of deficit growth

In 2016, for the first time since the F&Cs Regulation was introduced in 2014, the F&Cs levied by EASA were insufficient to cover the costs of its certification activities. According to EASA’s forecasts, this deficit will continue to grow in the future. This is due to several factors:

1. Expertise in new technologies. The challenge for EASA goes beyond a simple revision of its fees structure. EASA must also create the conditions to invest in building its internal knowledge and constantly look to attract the world’s best talent to ensure it remains at the forefront of innovation and provides its applicants with the best services possible. Fees mostly cover the cost of EASA’s staff that work on certification activities. These include aeronautical engineers and other aviation experts whose primary goal is to ensure safety of the public. Innovation





drives increased costs for all activities of EASA, and fees have proven to be insufficient to cover those growing costs.

2. Changing business models. EASA has typically worked on several type certificates per year in the past, the fees accounting for a material part of the total fees levied. The volume of type certification activities, however, has decreased recently. This is a consequence of the decision by some large aircraft manufacturers not to launch new programmes and to instead focus on developing derivatives and major changes for their existing platforms.

In turn, the complexity of the derivatives and major changes has risen, increasing the cost of any single certification activity. Despite this increase in costs, the level of fees levied per certification activity has remained unchanged (save for inflation adjustments). As a result, the fees levied for the certification of a derivate or major change have become insufficient to cover the costs of certification. The issue is exacerbated by the increase in the volume of derivatives and major changes that EASA certifies.

3. Higher expectations from the public and applicants. Public expectations for safe, reliable, comfortable and environmentally friendly air transportation solutions are increasing globally. Applicants are expected to include the very best of technology in their products and services, and to do so quicker than ever before. At the same time, the emergence of new aviation players from developing countries changes the dynamics of the industry following decades of consolidation, leading to increased competition globally.

In turn, expectations from applicants towards EASA are also increasing: applicants demand quicker, more efficient, more transparent and more predictable certification services from all their regulators. As EASA mobilises resources in an effort to better meet those needs, the costs of its services increase and surpass the fees levied for them.

4. Inadequate yearly adjustment mechanism. Staff costs, which account for the majority of EASA costs, and fees are not adjusted in line with the same index. As a result, costs have grown more quickly than revenues since 2014.

5. Outsourcing strategy. To match the growing workload, deal with the cap set by the EU budgetary authority on the number of experts EASA is allowed to hire as well as to optimise the use and sustainability of the EU national aviation authorities’ (NAAs) technical capacities, EASA relies on NAAs to perform traditional certifications analysis. The cost of outsourcing to the NAAs is borne by EASA and represents a significant portion of its total costs. Again, costs have risen at a rate that is significantly greater than HICP inflation. Since fees have only increased in line with HICP inflation, the situation has further contributed to costs growing more quickly than revenues.

6. New approach to certification and approval. EASA is constantly looking to improve its ways of working. For example, EASA is strengthening its processes on determining its level of involvement (LoI) in certification projects. Based on this, EASA will systematically determine its LoI in a risk-based manner. With that, it will focus on high-risk elements during a certification project. In line with this new risk-based approach during initial certification, EASA also adopted a plan to ensure appropriate oversight during continuing airworthiness. This includes how resources are allocated among activities and what costs are incurred at different phases of the life cycle of a product or an organisation. This in turn requires a rebalancing of fees among activities.

At the same time, EASA regularly reviews its internal procedures and ways of working at all levels of the organisation to ensure it continues to make the very best use of its resources. The goal is to limit the need to mobilise additional resources in the future despite the growing volume of highly specialised work generated by emerging technologies. Improved efficiencies, however, will by





themselves be insufficient to address the forecast growing deficit, and amendments to the F&Cs are thus inevitable to address the deficit.

Opportunities to further streamline the application of the F&Cs system

EASA has identified other opportunities to further improve the F&Cs Regulation. These opportunities are aimed at simplifying the application of the F&Cs system for both EASA and its applicants, leading to savings on both sides.

C. PROPOSED AMENDMENTS TO THE F&Cs SYSTEM

Taking into account the feedback received from its applicants, EASA has identified three categories of amendments to the F&Cs Regulation it wishes to propose:

1. Adapt fees to new technologies and to the future extended scope of responsibilities of EASA.

EASA proposes to:

— adopt flat fees for the certification of new products that are currently not covered by flat fees in the current F&Cs Regulation;

— redefine existing fee categories of ‘fixed-wing aircraft’ and ‘rotorcraft’ to clarify how new hybrid aircraft models should be classified;

— introduce a flexible risk-based pricing mechanism to set fees for the certification of novel products and organisations that are currently not covered by an existing fixed fee structure in the F&Cs Regulation but that are still too nascent for EASA to propose a flat fee at this point.

2. Adjust F&Cs to ensure present and future cost-reflectivity.

EASA proposes to:

— adjust the fees for loss-making services so they cover their full costs. This includes introducing charges for third-country operators (TCOs) for additional activities required for some third-country operators;

— replace the current automatic price adjustment mechanism based on HICP inflation by one that captures the true cost increases EASA is subjected to through a transparent governance model embedded in the Single Programming Document and approved by the Management Board, including a commitment by EASA to achieve efficiency gains.

3. Introduce amendments to improve the overall efficiency and application of the system.

EASA proposes other amendments aimed at improving its overall efficiency, such as:

— streamlining and defining different categories of “major changes” replacing “derivatives” to ensure clarity among the applicants;

— changing the metric used as a basis for setting fees for the approval of production organisations from turnover to number of staff and price of most expensive products, given the challenge applicants and EASA face under the current system to determine the appropriate scope of activities to be considered in calculating turnover;

— simplifying the MTOW fee tier structure for the certification of small fixed-wing aircraft, and adapting it to new market realities;





— modifying the flat fees to include Operational Suitability Data (OSD) and Maintenance Review Board (MRB) activities, currently charged separately through hourly rate, to simplify the process for both the applicants and EASA;

— creating a flat fee for Flight Simulation Training Devices (FSTD) activities; and

— creating a flat fee for MRB activities.

The proposed amendments are further detailed in the following tables.





PROPOSED AMENDMENTS CATEGORY #1: Adapt F&Cs to new technologies and to the future extended scope of responsibilities of EASA

# Proposed amendment Targeted issues Description of the proposed amendment

Intended benefits Assessment of impact

1 Introduce a new fee structure for the issue of type certificates and the continued airworthiness of remotely piloted aircraft systems (RPASs) – fees proposal not yet presented in this memorandum.

— The current F&Cs Regulation does not provide a flat fee for the certification of RPASs.

— The existing ‘fixed-wing aircraft’ and ‘rotorcraft’ categories are not fit for purpose for RPASs, which are fundamentally different machines.

— The absence of flat fees in a dedicated product category table in the F&Cs Regulation leads to uncertainty on the fees to be levied for the issue of certificates for RPASs, ultimately negatively impacting on innovation in this field.

— Introduce new fees for the issue of certificates and continued airworthiness of RPASs.

— Structure the fees to follow the RPAS classification in the EASA Opinion 01/2018, following stakeholders feedback that the originally proposed fees based on use cases might not be the most appropriate structure.

— Set fees such that they are cost-reflective

— Increased certainty and predictability of fees payable by applicants for the certification of RPASs thanks to a tailored fee structure aligned with the coming regulation.

— Improved cost-reflectivity of fees.

— TBD as soon as the proposal is more mature.

2 Redefine ‘fixed-wing aircraft’ and ‘rotorcraft’ fee category definition

The traditional distinction between ‘fixed-wing aircraft’ and ‘rotorcraft’ is challenged by hybrid aircraft that are designed to take off vertically using tilting rotors and change configuration in flight to create lift using fixed-wings during cruise.

— Amend the definition of the ‘fixed-wing’ category for ‘horizontal take-off and landing (HTOL) aircraft.

— Amend the definition of the ‘rotorcraft’ category for ‘aircraft with vertical take-off and landing (VTOL) capabilities’.

— Improved clarity on which category hybrid aircraft fit in (i.e. VTOL, if the aircraft has vertical take-off and landing capabilities).

— Improved cost-reflectivity, given the aircraft complexity (and expected certification workload) of a hybrid aircraft is closer to that of a rotorcraft than of a fixed-wing aircraft.

No financial impact anticipated for applicants and EASA inasmuch as hybrid aircraft are classified as ‘rotorcraft’ under the current F&Cs Regulation.



© European Union Aviation Safety Agency. All rights reserved. ISO9001 Certified. 10

Proprietary document. Printed copies are not controlled. Confirm revision status through the EASA-Internet/Intranet.


# Proposed amendment

Targeted issues Description of the proposed amendment Intended benefits Assessment of impact

3 Adopt a flexible risk-based fee-setting mechanism for novel products and organisations

— The current F&Cs structure is not fit for purpose for novel products that integrate technologies new to EASA.

— The current F&Cs structure is not fit for purpose for novel organisation types not currently approved by EASA and for which no fees are set, but possibly included in the scope of activities of EASA under the Regulation 2018/1139.

— In these cases, the current F&Cs Regulation provides the ability for EASA to charge such activities using an hourly rate, but doing so is uncertain for applicant and could lead to inappropriate results; indeed, the first applicant to apply for the certification of a novel product or the approval of a novel organisation type would bear all the costs of EASA knowledge-building needed to complete the activity for the first time, to the unfair benefit of the following applicants whose costs for certification or approval would be much lower given the ability for EASA to leverage the knowledge on the novel product or novel organisation type it has already developed.

— The above, leads to uncertainty for applicants and impedes innovation.

— Introduce a flexible risk-based approach to setting certification fees for novel products and organisations.

— Novel products will be those of such innovative nature that it falls outside existing certification specifications and corresponding applicable means of compliance. Novel organisations will be those whose type is not the object of an existing fee table.

— Applicants seeking the certification of a novel product or the approval of a novel organisation will be required to initiate a Technical Advisory Contract (TAC) or a similar contract with EASA, to clarify the technical details of the project in order to assess the workload and the fee. The analysis which will be conducted in order to assess the risk and workload will be charged on hourly basis and will reduce the workload required in the actual certification/approval phase.

— During the assessment phase, EASA will determine a fixed price for the activity in the form of a financial quote based on an estimate of the risk level of the product/organisation.

— Increased certainty and predictability of fees thanks to the fixed-fee approach.

— Improved cost-reflectivity and fee accuracy given the detailed assessment through a technical advisory contract (TAC) or similar contract, and the alignment with EASA’s new risk-based approach to certification/approvals in estimating the risk and workload needed for the service.

— Increased support to innovation.

— EASA expects the majority of products certified and organisations approved to be considered ‘traditional’ and not affected by this proposal.

— Applicants whose product or organisation is considered novel could see in certain circumstances a decrease or increase in their fees compared to the most similar product or organisation for which a flat fee exists, depending on the degree of novelty.






PROPOSED AMENDMENTS CATEGORY #2: Ensure present and future cost-reflectivity of F&Cs



4 Adjust the fee for loss-making services

— The F&Cs levied by EASA are insufficient to cover the costs of its certification and approval activities, resulting in a deficit.

— For many activities, costs have grown quicker than (and now exceed) fees, resulting in activities that are now loss-making. By 2020, all groups of activities are forecasted to be loss-making.

— While EASA is taking all necessary actions to ensure it remains financially strong and able to fulfil its mission as a regulator, improved efficiencies will by themselves be insufficient to address the forecasted growing deficit and amendments to the F&Cs to address the deficit are thus inevitable.

Increase the fees for the following activities to ensure all services cover their full costs (see Appendix A for resulting new prices):

Supplemental Type Certificates (STCs);

Major changes (incl. derivatives – now replaced by “complex significant change”);

Minor changes;

TC continued airworthiness and removal of rebate for holders of TCs in identical categories – the fee increase in this area has been limited, to partially compensate for the impact of the rebate removal;

Design Organisation Approval (initial);

Design Organisation Approval (continuous);

Product Organisation Approval (initial and continuous): various adjustments through changes in fee structure (see proposal #8 below);

Maintenance Organisation Approval (initial);

Maintenance Organisation Approval (continuous);

European Technical Standard Orders Approval (initial);

European Technical Standard Orders Approval (continuous).

— Ability for EASA to mobilise the necessary resources to fulfil its mission as a regulator.

— Improved cost-reflectivity of fees.

— High quality of services kept and continuous improvement offered by EASA to its applicants.

— Some applicants are expected to see an increase in the fees they pay for their requests for certification and approval services.

— EASA estimates that the direct impact on the amount of fees paid by applicants generally could range between approximately 0 and 35 % depending on the mix of services they receive from EASA.








5 Introduce a fee for additional activities required for some third-country operators (TCOs)

— The authorisation and continuous monitoring of TCOs is currently provided free of charge to the operators.

— The situation is not consistent with the general principles ruling the financial scheme of the Agency. In particular, some TCOs require significant additional technical investigation but are not requested to pay any fees for the extra activities required.

— The Agency initially proposed to levy a flat fee for the authorisation and continuous monitoring of TCOs based on the total fleet size (<10, 10–50 or >50) and the category of aircraft the TCO flies (‘large’ if at least one aircraft in the airline fleet has an MTOW greater than 45.5 tonnes, or if at least one aircraft can carry at least 20 passengers).

— Based on stakeholder feedback, alternative options were considered. The current proposal is performance-based charging, and would limit charging only to technical meetings in Cologne and on-site visits.

— Allows partial self-financing of the activity.

— Only the TCOs which require deeper assessment according to Part-TCO will be required to pay.

— Only a very limited number of TCOs would be impacted: the ones needing an on-site visit or a technical meeting in Cologne.

— In the past some fear has been expressed on the risk of retaliation by other countries. EASA believes the currently considered option minimises this risk.

6 Introduce a yearly fee adjustment mechanism that accounts for the expected evolution of EASA costs, including efficiency gains

The current F&Cs Regulation provides that fees and charges increase automatically every year in line with HICP inflation, a metric that leads to increases that are systematically below the growth rate of the EASA costs (especially staff and outsourcing costs).

— The yearly fee adjustment mechanism will be replaced by one that captures all relevant EASA costs, allowing EASA to agree on a 3-year budget of costs and investments with its Management Board (MB), including the European Commission, EASA Member States and aviation industry and to then adjust its fees yearly in line with these costs, including a commitment to achieve predetermined efficiency gains.

— The price review mechanism will have an underlying performance plan fully embedded in the Single Programming Document (SPD), with the same governance mechanism, i.e. PAR and MB.

— The performance plan will be established by EASA for a 3-year “reference period”. It will be reviewed every 3 years, not annually like the SPD.

— EASA will establish a clear mechanism to monitor the elements that define the % of price adjustment, including efficiency.

— Price adjustments will apply as a % change to all flat fees (and hourly rate) included in the F&C regulation. The financial situation per group of activities will be continuously monitored and the specific prices will be reviewed through Comitology when needed.

— Ensures EASA remains financially solid in the future and has the necessary resources to fulfil its mission as a regulator.

— Removes the need for periodic large fee adjustments at every revision of the F&Cs Regulation to make up for the otherwise growing gap between revenues and costs.

— Ensures EASA commits to efficiency gains, embedded in the performance plan.

The fee adjustment mechanism will properly capture all cost increases EASA needs to bear and factor in efficiency gain targets EASA will commit to. This will contribute to cost-reflectivity.






PROPOSED AMENDMENTS CATEGORY #3: Introduce various other amendments to improve the overall efficiency and application of the F&Cs system



7 Define the scope of what constitutes a ‘major change’ versus a ‘complex significant change’ (replacing the “derivative” concept)

— In the current F&C regulation, the categories ‘derivative’ and ‘major changes’ are not defined, creating confusion among applicants.

— As a result, applicants tend to apply for ‘major changes’ for which the fee is lower, even though in some instances the more appropriate category would be ‘derivative’.

— Change the category of ‘derivatives’ to ‘complex significant change’.

— Change the category of ‘complex major change’ to ‘significant major change’.

— Define how these categories differ – see Appendix C.

— Introduce a model fee in order to reflect a new model in the TC.

— Improve clarity for applicants on what constitutes each category.

— Align the categories to the technical work performed.

— The introduction of a model fee adds the option to apply for a new type of change that might be interesting for industry.

EASA expects that a few applications for major changes will be reclassified as complex significant change and vice versa, although the exact number is expected to be small.








8 Change the metric used as basis for pricing the approval and surveillance of production organisations from turnover to the number of staff and the price of most expensive products

Although conceptually sound, the use of turnover as basis to determine the fees for product organisations proves problematic in its application. Indeed, for organisations that have more than only a production function (which is often the case), EASA must determine the exact part of the organisation that is attributable to production to calculate turnover properly. This can lead to uncertainties and the need for both EASA and the applicant to dedicate resources to clarify how the turnover should be calculated in any given year.

Introduce a new fee table that is based on number of staff and highest priced product.

— The number-of-staff metric is objective and easier to apply given it is included in the POA documents of the applicant; it is also already successfully used in determining the approval fees for design and maintenance organisations.

— The use of the highest priced product is also a metric that EASA believes will be easier to apply given the large spreads between the three categories it proposes.

— Taken together, these two metrics will be good proxies to the risk level represented by an organisation and the level of workload required by EASA to approve it.

— Applicants will benefit from greater certainty and predictability in determining the fees that are applicable to them.

— Both applicants and EASA will also gain efficiencies by saving on time that is often required from them to determine the scope of the applicant’s organisation to consider in calculating the turnover.








9 Simplify and adapt to new realities the MTOW fee tier structure for the certification of small fixed-wing aircraft (now horizontal take-off and landing (HTOL) aircraft)

For certification activities related to small fixed-wing aircraft (now HTOL aircraft), fees vary depending on the MTOW of the aircraft. The current F&Cs Regulation provides for a structure of fee tiers as follows (from heaviest to lightest):

— > 150 tonnes;

— 50 to 150 tonnes;


— 5.7 to 22 tonnes (including high-performance aircraft (HPA));

— 2.0 to 5.7 tonnes (except HPA);

— < 2.0 tonnes (except HPA);

— very light aircraft, powered sailplanes, sailplanes;

— light sport aeroplanes.

EASA identified three opportunities to simplify and improve the above fee tier structure:

1. The ‘light sport aeroplanes’ category could be merged with the ‘very light aircraft, powered sailplanes and sailplanes’ category.

2. ‘Very light aircraft’ will be easier to scope if it was defined by its MTOW as it is done with heavier categories.

3. Raising the bar of 2.0 tonnes to 2.73 tonnes will make the tier limit consistent with technical requirements (certification rules applicable to aircraft that have an MTOW below 2.73 tonnes are simplified).

Adopt the following simplified fee tier structure:

— > 150 tonnes;



— 5.7 to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes);

— 2.73 to 5.7 tonnes (including HPA over 1.2 up to 2.73 tonnes);

— 1.2 to 2.73 tonnes (including HPA up to 1.2 tonnes);

— < 1.2 tonnes.

— Simplified fee tier structure that is more predictable and manageable for both applicants and EASA.

— Better coherence with technical requirement categories.

The main impact will be for applicants that apply for the certification of a product whose MTOW is between 2.0 and 2.73 tonnes. EASA observed an unusually low number of applications for fixed-wing aircraft whose MTOW is between 2.0 and 2.73 tonnes. By changing the boundary of 2.0 tonnes to 2.73 tonnes, EASA anticipates an increase in the number of applications for the certification of aircraft within the 2.0–2.73-tonnes range.








10 Adjust the fees for certification activities for aircraft whose MTOW is between 2.0 (currently 2.73) and 5.7 tonnes to reduce the drastic increase of fee levels

EASA observed an unusually low number of applications for fixed-wing aircraft whose MTOW is between 2.0 (currently 2.73) and 5.7 tonnes. This is most likely due to the fees increasing substantially when an aircraft is classed as having an MTOW above 2 tonnes instead of below. For example, in the current F&Cs Regulation, the fee to issue a type certificate jumps from EUR 13 940 to EUR 263 800 for a fixed-wing aircraft whose MTOW is above 2 tonnes.

Reduce certification fees for fixed-wing aircraft whose MTOW is between 2.0 (currently 2.73 tonnes as per above recommendation) and 5.7 tonnes (see Appendix A for exact proposed fees).

Support the design and certification within EASA’s Member States of small aircraft, in line with EASA’s General Aviation Roadmap.

EASA expects the decrease in fees to attract more demand for certificates in the targeted categories, mitigating the decrease in fee revenues caused by the decrease in fees.

11 Introduce fixed fees for the certification of Flight Simulator Training Devices (FSTD)

Fees levied for the certification of Flight Simulator Training Devices are currently calculated on an hourly rate basis. This creates uncertainty for applicants who do not get a definite view of the fees for the certification until the certification is actually completed. It also increases the administrative burden to manage such fees, both for EASA and the applicants, as EASA needs to keep track of all worked hours in order to be able to issue an accurate invoice, and applicants are required as per their internal policies to monitor and diligently review the hours underlying the invoices received from EASA before paying them.

Introduce new annual flat fees for the certification of Flight Simulator Training Devices, with different prices depending on whether the simulator is a Full Flight Simulator (FFS), a Flight Training Device (FTD) or a Flight and Navigation Procedure Trainer (FNPT).

Taking into consideration further impact assessment, especially in the low range, the fee structure and amounts initially proposed have been revised, introducing a complex/non-complex approach.

The new flat fees are expected to lead to greater fee predictability for the applicants as well as to a lower administrative burden to actually manage their application.

The flat fees have been structured and calculated such that they reflect as best as possible true cost of certification (based on the average number of hours typically dedicated by EASA on such activities), therefore it is not anticipated that applicants will see a big shift in the fees they ultimately pay for these activities.








12 Introduce fixed fees for the Maintenance Review Board (MRB) activities

Fees levied for the Maintenance Review Board activities are currently calculated on an hourly rate basis. This creates uncertainty and increases the administrative burden of managing those fees, as discussed above for FSTDs.

Introduce new flat fees for the approval of Maintenance Review Board (MRB) activities, with different prices for initial MRB report and revision of MRB report.

The new flat fees are expected to lead to greater fee predictability for the applicants as well as lower administrative burden to actually manage their application.

The flat fees have been structured and calculated such that they reflect as best as possible the cost of approval of Maintenance Review Board activities, based on the experience gained with MRB applications.

13 Introduce fixed fees for the Certification Support for Validation (CSV)

Fees levied for the Certification Support for Validation are currently calculated on an hourly rate basis. This creates uncertainty and increases the administrative burden of managing those fees, as discussed above for FSTDs.

Introduce new flat fees for the approval of Certification Support for Validation activities, with different prices for service packages:

— Individual Service – scope comprised of validation support for RTC, STC and Complex Significant and Significant Major Changes, as well as technical support related to compliance finding activities

— Large - scope comprised of validation support for STC, Major Changes and Repairs applicable to HTOL >5,7t, Large VTOL and Turbine Engines

— Medium - scope comprised of validation support for STC, Major Change and Repairs for other categories than covered by the Large Service Package, and ETSOA

— Small - scope comprised of administrative tasks, without involvement of EASA technical staff

— The new flat fees are expected to lead to greater fee predictability for the applicants as well as lower administrative burden to actually manage their application.

— Service Packages and related F&Cs are differentiated based on higher effort from EASA’s side.

— GA and smaller applicants should benefit from the lower fees of the Medium package.

The flat fees have been structured and calculated to reflect as best as possible current hourly rates charged, based on the experience gained with CSV applications.








14 Include the cost of Operational Suitability Data (OSD) certification as part of relevant existing flat fees for the certification of products

The fees for the approval of Operational Suitability Data are currently charged on the basis of an hourly rate. This creates uncertainty and increases the administrative burden of managing those fees, as discussed above for FSTDs. Furthermore, OSD has become a compulsory part of the certification of products, and charging separately for this activity has become conceptually illogical.

Include the cost of OSD certification in the relevant existing flat fees, i.e. fees for type certificate, supplemental type certificate and major changes.

The new flat fees are expected to lead to greater fee predictability for the applicants as well as lower administrative burden to actually manage their application.

The change will lead to an increase in the relevant existing flat fees for the certification of products, however applicants will no longer be charged separately for the OSD activity. As a result, applicants will generally not see a difference in the fees they pay for the certification of their products and will benefit from simplified invoicing and fee structure.








15 Simplify the criteria defining situations where “annual fees for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No 216/2008” (continuous airworthiness fee) are charged on an hourly basis instead of using a flat fee

Continuous airworthiness fees are currently charged on an hourly basis for aircraft of which less than 50 examples are registered worldwide. The objectives of this rule are still valid today, however its application has raised complexities for both applicants and EASA given the potentially high number of sources needed to determine how many aircraft are registered worldwide. These complexities are causing important inefficiencies EASA aims to fix.

Continuous airworthiness fees will be charged on an hourly basis instead of using a flat fee (1) for aircraft of which less than 50 examples are produced or that are out of production for more than 30 years; (2) for engines and propellers of which less than 100 examples are produced or that are out of production for more than 30 years; (3) for European technical Standard Orders (ETSOs) of which less than 200 examples are produced or that are out of production for more than 15 years. Continuous airworthiness fees for European technical Standard Orders (ETSOs) have been adjusted downwards in line with the abolition of reductions applied to the second and subsequent certificate in the same value category. The new rule will also clarify that while it remains the responsibility of the applicant to demonstrate that such criteria are met, applicants will have no more than 1 year after an invoice is issued to make such demonstration in order for the invoice to be retroactively adjusted. Finally, the new rule will provide that in no case the total fees charged for the period in question on an hourly basis can exceed the fees that would have been paid by the same applicant had the continuous airworthiness fees been calculated using a flat fee for that period.

The new rules are expected to greatly simplify the administration of the continuous airworthiness fees for small productions and for aircraft out of production, both for applicants and EASA, saving costs and offering increased efficiencies to both by having the rule criteria application rely on information held by applicants (number of examples produced and time of production ending).

Beyond the efficiency gains, EASA does not expect the new rule to impact the fees currently paid by the majority of applicants that were aimed by the initial rule.








16 Introduce flat fees for Minor Changes and Minor Repairs for Parts and Non-installed equipments.

Correct an omission in the current F&C Regulation.

Introduction of a flat fee table for minor changes and minor repairs for Parts and Non-installed equipments.

Administrative changes without technical involvement will continue to be charged as administrative reissuance of document.

The new flat fees are expected to offer predictability and certainty for applicants.

The impact is expected to be limited given the low number of applications in this category.

17 Harmonise the interpretation of “number of staff” as headcount for all types of organisation approvals.

“Number of staff” is currently interpreted as headcount for some type of organisations, as FTE for others.

“Number of staff” will be interpreted as headcount for all organisations.

The new interpretation is expected to improve the application of the F&C system.

The change in interpretation might affect the fee categorisation for some organisations, especially DOAs.

D. NEXT STEPS

EASA invited 3200 applicants, i.e. applicants that currently hold or have held at least one certificate from EASA over the past 5 years; 40 RPAS related organisations; Advisory groups (A4A, IATA, European Regions Airline Association, ASD, CANSO, EHA, GAMA, FNAM) to take part in a stakeholder consultation through an online survey. The F&C modification proposal has been revised following the consultation, as reflected in this revised memorandum.

EASA has informed its main advisory bodies, the SAB and MAB, about the main modifications proposed. SAB and MAB have been invited to comment on the proposals.

The European Commission, supported by EASA, is drafting the F&C Regulation for consultation with the EASA Committee in June and October 2019. The European Commission will also consult in that period the EASA Management Board, which will consult the SAB. The new F&Cs Regulation could enter into force by 2020.





APPENDIX A: PROPOSED PRICE TABLES

Part 1

Tasks charged a flat fee

Table A1

Type Certificates and Restricted Type Certificates for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft

(Formerly Fixed Wing Aircraft)

Current fee structure (adjusted for forecasted inflation until 2020, EUR)

New proposed fee structure

(2020 fees, EUR)

Over 150 000 kg 1,890,315 Over 150 tonnes 2,055,230

Over 50 000 kg up to 150 000 kg 1,620,270 Over 50 up to 150 tonnes 1,693,040

Over 22 000 kg up to 50 000 kg 540,090 Over 22 up to 50 tonnes 564,350

Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft)

405,068 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)

420,700

Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft)

279,364 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)

123,130

Up to 2 000 kg (except for High Performance Aircraft) 14,762 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)

15,890

Very Light Aeroplanes, Powered Sailplanes, Sailplanes 7,381 Up to 1.2 tonnes 5,300

Light Sport Aeroplanes 5,539





Table A2

Type Certificates and Restricted Type Certificates for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)

Current fee structure (adjusted for forecasted inflation until

2020, EUR)

New proposed fee structure (2020 fees, EUR)

Large 491,376 Large 476,100

Medium 196,550 Medium 190,450

Small 24,611 Small 23,850

Very light rotorcraft 24,611 Very light aircraft 23,850





Table A33

Type Certificates and Restricted Type Certificates for Other Aircraft

Current fee structure (adjusted for forecasted inflation until

2020, EUR)


Balloons 7,381 Balloons 7,380

Airships Large 40,909 Airships Large 42,950

Airships Medium 16,362 Airships Medium 16,360

Airships Small 8,186 Airships Small 8,190





Table A4

Type Certificates and Restricted Type Certificates for Propulsion



(2020 fees, EUR)

Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW

418,305 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW

405,310

Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW

278,835 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW

270,170

Non turbine engines 36,917 Non turbine engines 36,920

CS-22.H, CS-VLR App. B engines 18,458 CS-22.H, CS-VLR App. B engines 18,460

Propeller for use on aircraft over 5 700 kg MTOW 12,613 Propeller for use on aircraft over 5 700 kg MTOW 12,610

Propeller for use on aircraft up to 5 700 kg MTOW 3,601 Propeller for use on aircraft up to 5 700 kg MTOW 3,600

CS-22J Class Propeller 1,800 CS-22J Class Propeller 1,800





Table A5

ETSO Authorisation for Parts and Non-installed equipments



(2020 fees, EUR)

Value above EUR 20,000 9,298 Value above EUR 20,000 9,300

Value between EUR 2,000 and 20,000 5,316 Value between EUR 2,000 and 20,000 5,320

Value below EUR 2,000 3,082 Value below EUR 2,000 3,090

Auxiliary Power Unit (APU) 221,119 Auxiliary Power Unit (APU) 221,120





Table A7

Supplemental Type Certificates for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft




Complex Standard Simple

Complex Significant

Significant Standard Simple

Over 150 000 kg 63,752 13,608 3,876 Over 150 tonnes 952,500 76,480 16,325 4,650

Over 50 000 kg up to 150 000 kg 38,262 10,887 3,050 Over 50 up to 150 tonnes 680,880 45,900 13,055 3, 655

Over 22 000 kg up to 50 000 kg 25,511 8,165 2,775 Over 22 up to 50 tonnes 378,140 30,600 9,790 3,330


15,303 5,443 2.775 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)

290,420 18,355 6,535 3,330


4,681 2,150 1,080 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)

153,120 5,610 2,575 1,290

Up to 2 000 kg (except for High Performance Aircraft)

1,970 1,228 614 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)

6,140 1,970 1,230 610

Very Light Aeroplanes, Powered Sailplanes, Sailplanes

307 307 307 Up to 1.2 tonnes 3,630 310 310 310

Light Sport Aeroplanes 233 233 233





Table A8

Supplemental Type Certificates for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)



(2020 fees, EUR)

Complex Standard Simple Complex

Significant Significant Standard Simple

Large 49,138 7,371 2,457 Large 321,710 58,945 8,840 2,945

Medium 24,569 4,914 1,970 Medium 188,500 29,475 5,895 2,360

Small 9,828 3,685 1,228 Small 15,080 11,795 4,420 1,475

Very light rotorcraft 1,112 487 307 Very light aircraft 9,610 1,110 490 310





Table A10

Supplemental Type Certificates for Other Aircraft



(2020 fees, EUR)



Balloons 1,048 487 307 Balloons 3,630 1,050 490 310

Airships Large 12,284 9,828 4,914 Airships Large 37,700 15,970 12,780 6,390

Airships Medium 4,914 3,929 1,970 Airships Medium 15,090 4,910 3,930 1,970

Airships Small 2,457 1,970 985 Airships Small 7,520 2,460 1,970 990





Table A11

Supplemental Type Certificates for Propulsion



(2020 fees, EUR)




12,284 7,371 4,914 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW

190,090 14,735 8,840 5,895


7,371 5,782 3,855 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW

185,830 8,840 6,940 4,625

Non turbine engines 3,442 1,536 773 Non turbine engines 34,710 3,440 1,540 770

CS-22.H, CS-VLR App. B engines 1,726 773 371 CS-22.H, CS-VLR App. B engines 17,410 1,730 770 370

Propeller for use on aircraft over 5 700 kg MTOW

2,457 1,228 614 Propeller for use on aircraft over 5 700 kg MTOW

7,020 2,460 1,230 610

Propeller for use on aircraft up to 5 700 kg MTOW

1,843 921 466 Propeller for use on aircraft up to 5 700 kg MTOW

2,140 1,840 920 470

CS-22J Class Propeller 921 466 233 CS-22J Class Propeller 1,080 920 470 230





Table A12

Supplemental Type Certificates for Parts and Non-installed equipments



(2020 fees, EUR)



Value above EUR 20,000 Value above EUR 20,000

Value between EUR 2,000 and 20,000


Value below EUR 2,000 Value below EUR 2,000

Auxiliary Power Unit (APU)

7,371 4,914 2,457 Auxiliary Power Unit (APU)

136,280 7,370 4,915 2,460





Table A13

Major Changes and Major Repairs for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft




(2020 fees, EUR)

Derivatives Complex Standard Simple Model fee*

Complex Significant


Over 150 000 kg 650,332 53,797 9,880 3,526 Over 150 tonnes 100,000 800,000 78,010 14,330 5,110

Over 50 000 kg up to 150 000 kg

390,242 26,920 7,413 2,266 Over 50 up to 150 tonnes

59,880 479,050 39,030 10,750 3,290

Over 22 000 kg up to 50 000 kg

260,090 21,540 4,946 1,769 Over 22 up to 50 tonnes

39,910 319,280 31,230 7,170 2,560


208,094 13,460 2,467 1,769

Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)

31,930 255,450 19,520 3,580 2,560


98,487 3,696 1,726 858

Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)

15,110 120,900 5,360 2,500 1,240


3,442 1,356 614 307

Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)

530 4,230 1,360 610 310






2,955 307 307 307 Up to 1.2 tonnes 450 3,630 310 310 310

Light Sport Aeroplanes 2,213 233 233 233

*The model fee covers the addition of a model to the type design and shall be levied per application and model. It must be associated with an application for

standard, significant or complex significant change. In case several changes applied for separately lead to the addition of one model, these changes shall be assessed

altogether in order to determine whether the “complex significant” fee applies.





Table A14

Major Changes and Major Repairs for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)



(2020 fees, EUR)


Complex Significant


Large 196,550 36,853 7,371 2,457 Large 30,160 241,280 53,440 10,690 3,560

Medium 122,844 19,655 4,914 1,716 Medium 18,850 150,800 28,500 7,120 2,490

Small 12,284 7,868 3,685 985 Small 1,890 15,080 11,410 5,340 1,430

Very light rotorcraft 7,381 1,048 487 307 Very light aircraft 1,130 9,060 1,050 490 490








Table A16

Major Changes and Major Repairs for Other Aircraft



(2020 fees, EUR)

Derivatives Complex Standard Simple Model fee* Complex


Balloons 2,955 1,048 487 307 Balloons 450 3,630 1,050 490 490

Airships Large 24,569 9,828 7,371 4,914 Airships Large 3,770 30,160 14,250 10,690 7,120

Airships Medium 9,828 3,929 2,944 1,970 Airships Medium 1,510 12,060 3,930 2,940 1,970

Airships Small 4,914 1,970 1,472 985 Airships Small 750 6,030 1,970 1,470 990








Table A17

Major Changes and Major Repairs for Propulsion



(2020 fees, EUR)


Complex Significant



85,567 6,788 2,499 1,504


13,130 105,040 9,840 3,620 2,180


73,706 3,685 1,250 752


11,310 90,480 5,340 1,810 1,090

Non turbine engines 12,306 1,599 741 371 Non turbine engines 1,890 15,110 1,600 740 500

CS-22.H, CS-VLR App. B engines

6,153 741 371 307 CS-22.H, CS-VLR App. B engines

940 7,550 740 370 370

Propeller for use on aircraft over 5 700 kg MTOW

3,082 1,324 307 307 Propeller for use on aircraft over 5 700 kg MTOW

470 3,780 1,320 500 500

Propeller for use on aircraft up to 5 700 kg MTOW

943 995 307 307 Propeller for use on aircraft up to 5 700 kg MTOW

150 1,160 1,000 470 470

CS-22J Class Propeller 477 498 159 159 CS-22J Class Propeller 73 590 500 160 160





Table A18

Major Changes and Major Repairs for Parts and Non-installed equipments



(2020 fees, EUR)


Complex Significant


Value above EUR 20,000

Value above EUR 20,000



Value below EUR 2,000

Value below EUR 2,000

Auxiliary Power Unit (APU)

57,080 3,685 1,228 741 Auxiliary Power Unit (APU)

8,760 70,070 3,690 1,230 740








Table A19

Minor Changes and Minor Repairs for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft




(2020 fees, EUR)

Over 150 000 kg 943 Over 150 tonnes 1,890

Over 50 000 kg up to 150 000 kg 943 Over 50 up to 150 tonnes 1,890

Over 22 000 kg up to 50 000 kg 943 Over 22 up to 50 tonnes 1,890

Over 5 700 kg up to 22 000 kg (including High-Performance Aircraft) 943 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes) 1,890

Over 2 000 kg up to 5 700 kg (except for High-Performance Aircraft) 307 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes) 610

Up to 2 000 kg (except for High Performance Aircraft) 307 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes) 500

Very Light Aeroplanes, Powered Sailplanes, Sailplanes 307 Up to 1.2 tonnes 310

Light Sport Aeroplanes 233





Table A20

Minor Changes and Minor Repairs for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)

Current fee structure (adjusted for forecasted inflation

until 2020, EUR)


Large 487 Large 970

Medium 487 Medium 970

Small 487 Small 970

Very light rotorcraft 307 Very light aircraft 490





Table A22

Minor Changes and Minor Repairs for Other Aircraft



(2020 fees, EUR)

Balloons 307 Balloons 490

Airships Large 858 Airships Large 1,720

Airships Medium 487 Airships Medium 970

Airships Small 487 Airships Small 970





Table A23

Minor Changes and Minor Repairs for Propulsion



(2020 fees, EUR)


635 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW

1,270


635 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW

1,270

Non turbine engines 307 Non turbine engines 610

CS-22.H, CS-VLR App. B engines 307 CS-22.H, CS-VLR App. B engines 370

Propeller for use on aircraft over 5 700 kg MTOW 307 Propeller for use on aircraft over 5 700 kg MTOW 500

Propeller for use on aircraft up to 5 700 kg MTOW 307 Propeller for use on aircraft up to 5 700 kg MTOW 470

CS-22J Class Propeller 159 CS-22J Class Propeller 320





Table A24

Minor Changes and Minor Repairs for Parts and Non-installed equipments



(2020 fees, EUR)

Value above EUR 20,000 Value above EUR 20,000 1,860

Value between EUR 2,000 and 20,000 Value between EUR 2,000 and 20,000 1,070

Value below EUR 2,000 Value below EUR 2,000 620

Auxiliary Power Unit (APU) 487 Auxiliary Power Unit (APU) 490





Table A25

Annual fee for holders of EASA Type Certificates and Restricted Type Certificates and other Type Certificates deemed to be accepted under Regulation (EC) No

216/2008 for Onboard Piloted Horizontal Take-Off and Landing (HTOL) Aircraft (Formerly Fixed Wing Aircraft)



EU Design

Non EU Design

EU Design Non EU Design

Over 150 000 kg 1,141,602 408,139 Over 150 tonnes 1,155,160 360,270

Over 50 000 kg up to 150 000 kg 903,221 267,503 Over 50 up to 150 tonnes 975,480 274,490

Over 22 000 kg up to 50 000 kg 272,163 101,982 Over 22 up to 50 tonnes 293,940 110,140


44,489 15,112 Over 5.7 up to 22 tonnes (including HPA over 2.73 up to 5.7 tonnes)

48,050 16,320


4,924 1,726 Over 2.73 up to 5.7 tonnes (including HPA over 1.2-up to 2.73 tonnes)

5,320 1,770


2,457 826 Over 1.2 up to 2.73 tonnes (including HPA up to 1.2 tonnes)

2,460 830


1,112 371 Up to 1.2 tonnes

900 370

Light Sport Aeroplanes 826 275

For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments

No reduction applied to the second and subsequent Type Certificates, or Restricted Type Certificates.





Table A6


216/2008 for Onboard-Piloted Vertical Take-Off and Landing (VTOL) Aircraft (Formerly Rotorcraft)



(2020 fees, EUR)

EU Design Non EU Design EU Design Non EU Design

Large 111,830 35,773 Large 102,930 37,740

Medium 55,915 19,708 Medium 57,190 21,280

Small 22,112 8,165 Small 23,880 8,670

Very light rotorcraft 3,696 1,228 Very light aircraft 3,700 1,230

For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments






Table A7


216/2008 for Other Aircraft



(2020 fees, EUR)

EU Design Non-EU Design EU Design Non-EU Design

Balloons 1,112 371 Balloons 840 360

Airships Large 3,685 1,228 Airships Large 4,000 1,330

Airships Medium 2,457 815 Airships Medium 2,460 820

Airships Small 1,970 657 Airships Small 1,970 660

For holders of multiple Type Certificates and/or multiple Restricted Type Certificates, a reduction to the annual fee is applied to the second and subsequent Type Certificates, or Restricted Type Certificates, in the same category as defined by MTOW or by value of parts and Non-installed equipments.






Table A29


216/2008 for Propulsion



(2020 fees, EUR)

EU

Design Non EU Design

EU



113,419 33,750 Turbine engines with take-off thrust over 25 KN or take-off power output over 2 000 kW

120,090 32,140


56,709 28,222 Turbine engines with take-off thrust up-to 25 KN or take-off power output up to 2 000 kW

58,180 27,450

Non turbine engines 1,228 434 Non turbine engines 1,120 140

CS-22.H, CS-VLR App. B engines 614 307 CS-22.H, CS-VLR App. B engines 610 310

Propeller for use on aircraft over 5 700 kg MTOW 921 307 Propeller for use on aircraft over 5 700 kg MTOW 420 220

Propeller for use on aircraft up to 5 700 kg MTOW 466 159 Propeller for use on aircraft up to 5 700 kg MTOW 240 50

CS-22J Class Propeller 233 74 CS-22J Class Propeller 230 70







Table A30


216/2008 for Parts and Non-installed equipments



(2020 fees, EUR)

EU Design Non EU Design EU


Value above EUR 20,000 4,766 1,589 Value above EUR 20,000

2,440 680

Value between EUR 2,000 and 20,000 2,383 794 Value between EUR 2,000 and 20,000

1,290

460

Value below EUR 2,000 1,197 572 Value below EUR 2,000

520 420

Auxiliary Power Unit (APU) 90,015 27,534 Auxiliary Power Unit (APU)

87,880 10,510


No reduction applied to the second and subsequent ETSO Authorisation.





Table A8

Design Organisation Approval – Approval Fee



(2020 fees, EUR)

1A 1B 2A

1C 2B 3A

2C 3B

3C 1A 1B 2A

1C 2B 3A

2C 3B

3C

Staff related below 10 14,402 11,331 8,472 5,719 4,427 Staff related below 10 14,400 11,330 8,470 5,720 4,430

10 to 49 40,507 28,932 17,357 11,575 10 to 49 40,510 28,930 17,360 11,580

50 to 399 115,749 86,838 57,821 44,298 50 to 399 179,410 134,600 89,620 68,660

400 to 999 231,497 173,570 144,659 121,785 400 to 999 358,820 269,030 224,220 188,770

1,000 to 2,499 462,995 1,000 to 2,499 717,640

2,500 to 5,000 694,386 2,500 to 5,000 1,076,300

Over 5,000 3,857,937 Over 5,000 5,979,800





Table A9

Design Organisation Approval – Surveillance Fee



(2020 fees, EUR)

1A 1B 2A

1C 2B 3A

2C 3B

3C 1A 1B 2A

1C 2B 3A

2C 3B

3C

Staff related below 10 7,201 5,666 4,236 2,859 2,213 Staff related below 10 7,200 5,670 4,240 2,860 2,210

10 to 49 20,259 14,466 8,684 5,782 10 to 49 20,260 14,470 8,680 5,780

50 to 399 57,821 43,398 28,932 23,150 50 to 399 78,060 58,590 38,930 31,250

400 to 999 115,749 86,838 72,330 63,646 400 to 999 156,260 117,230 97,650 85,920

1,000 to 2,499 231,497 1,000 to 2,499 312,520

2,500 to 5,000 347,246 2,500 to 5,000 468,780

Over 5,000 1,929,498 Over 5,000 2,604,820





Table A33

Alternative Procedures of Design Organisation Approval



(2020 fees, EUR)

1A (Type certification) 7,943 1A (Type certification) 7,940

1B (Type certification – Continued airworthiness only) 3,177 1B (Type certification – Continued airworthiness only) 3,180

2A (Supplemental type certificates (STC) and/or major repairs) 6,354 2A (Supplemental type certificates (STC) and/or major repairs) 6,350

2B (STC and/or major repairs – Continued airworthiness only) 2,648 2B (STC and/or major repairs – Continued airworthiness only) 2,650

3A (ETSOA) 6,354 3A (ETSOA) 6,350

3B (ETSOA – Continued airworthiness only) 3,177 3B (ETSOA – Continued airworthiness only) 3,180





Table A34

Product Organisation Approval – Approval Fee



(2020 fees, EUR)

Turnover (EUR) < 1,000,000

11,077 Highest Priced Product

Below 5,000 EUR

Highest Priced Product Between 5,000 and

100,000 EUR

Highest Priced Product Above 100,000 EUR

Between 1,000,000 and 4,999,999 61,422 Staff related below 100

20,650 39,710 55,600

Between 5,000,000 and 9,999,999 218,578 100 and 499 31,770 63,540 111,200

Between 10,000,000 and 49,999,999 327,866 500 and 999 59,570 119,140 238,280

Between 50,000,000 and 99,999,999 379,122 1,000 and 4,999 158,850 317,700 794,250

Between 100,000,000 and 499,999,999 442,238 5,000 and 20,000 595,670 1,191,380 2,779,880

Between 500,000,000 and 999,999,999 775,294 Over 20,000 992,810 1,985,630 3,971,250

Over 999,999,999 2,948,256





Table A35

Product Organisation Approval – Surveillance Fee



(2020 fees, EUR)

Turnover (EUR) < 1,000,000

7,995 Highest Priced Product

Below 5,000 EUR

Highest Priced Product Between 5,000 and 100,000

EUR

Highest Priced Product Above 100,000 EUR

Between 1,000,000 and 4,999,999 38,961 Staff related below 100

13,770 26,480 37,070

Between 5,000,000 and 9,999,999 51,944 100 and 499 21,180 42,360 74,120

Between 10,000,000 and 49,999,999 77,942 500 and 999 39,710 79,430 158,850

Between 50,000,000 and 99,999,999 184,266 1,000 and 4,999

105,900 211,800 529,500

Between 100,000,000 and 499,999,999 245,688 5,000 and 20,000

397,130 794,290 1,853,250

Between 500,000,000 and 999,999,999 491,376 Over 20,000 625,000 1,323,750 2,647,500

Over 999,999,999 2,337,213





Table A36

Maintenance Organisation Approval – Initial Fee



(2020 fees, EUR)

Staff related below 5 3,696 Staff related below 5 3,700

5 to 9 6,153 5 to 9 6,150

10 to 49 15,885 10 to 49 24,620

50 to 99 25,416 50 to 99 39,400

100 to 499 33,973 100 to 499 52,660

500 to 999 46,914 500 to 999 72,720

Over 999 65,870 Over 999 102,100

Technical Rating A1 13,534 Technical Rating A1 20,980



Technical Rating A4 614 Technical Rating A4 950

Technical Rating B1 6,153 Technical Rating B1 9,540


Technical Rating B3 614 Technical Rating B3 950

Technical Rating C 614 Technical Rating C 950





Table A37

Maintenance Organisation Approval – Surveillance Fee



(2020 fees, EUR)


5 to 9 4,924 5 to 9 4,920

10 to 49 12,708 10 to 49 15,250

50 to 99 25,416 50 to 99 30,500

100 to 499 33,973 100 to 499 40,770

500 to 999 46,914 500 to 999 56,300

Over 999 65,870 Over 999 79,000




Technical Rating A4 614 Technical Rating A4 740



Technical Rating B3 614 Technical Rating B3 740

Technical Rating C 614 Technical Rating C 740





Table A38

Maintenance Training Organisation Approval – Approval Fee



(2020 fees, EUR)


Between 5 and 9 10,463 Between 5 and 9 10,460



Over 99 57,610 Over 99 57,610

Fee for the second and subsequent additional facility 3,526 Fee for the second and subsequent additional facility 3,530

Fee for second and subsequent additional training course 3,526

Fee for second and subsequent additional training course

3,530

Fee for training course approval Fee for training course approval 3,530





Table A39

Maintenance Training Organisation Approval – Surveillance Fee



(2020 fees, EUR)





Over 99 52,950 Over 99 52,950

Fee for the second and subsequent additional facility 2,648 Fee for the second and subsequent additional facility 2,650

Fee for second and subsequent additional training course Fee for second and subsequent additional training course

Fee for training course approval 3,526 Fee for training course approval





Table A40

Continuing Airworthiness Management Organisation Approval



(2020 fees, EUR)

Approval fee 52,950 Approval fee 52,950

Surveillance fee 52,950 Surveillance fee 52,950

Initial Approval Surveillance Initial Approval Surveillance

Technical rating A1 (airplanes above 5.7 ton)

13,238 13,238 Technical rating A1 (airplanes above 5.7 ton)

13,240 13,240

Technical rating A2 (airplanes below 5.7 ton)

6,619 6,619 Technical rating A2 (airplanes below 5.7 ton)

6,620 6,620

Technical rating A3 (helicopters)

6,619 6,619 Technical rating A3 (helicopters)

6,620 6,620

Technical rating A4 (all others)

6,619 6,619 Technical rating A4 (all others)

6,620 6,620





Table A10

Acceptance of approvals equivalent to ‘Part 145’ and ‘Part 147’ approvals in accordance with applicable bilateral agreements



(2020 fees, EUR)

New approvals, per application and per period of first 12 months 1,800 New approvals, per application and per period of first 12 months 1,800

Continuation of existing approvals, per period of 12 months 900 Continuation of existing approvals, per period of 12 months 900





Table A42

Third Country Operator


(2020 fees, EUR)

On-site visit* 19,000

Technical meeting in Cologne 10,000

*Travel cost and travel time charged using F&C regulation provisions for audits outside the EU





Table A44

Flight Simulator Training Devices (FSTD) – Approval Fee

Charged per application


(2020 fees, EUR)

Flat fee per location 12,350

Single Engine / Aircraft

Configuration Double Engine / Aircraft

Configuration 3+ Engine / Aircraft Configuration

Full Flight Simulator (FFS) 32,110 39,520 45,940

Flight Training Device (FTD) 13,590 16,070 22,480

Single Engine Piston or equivalent Multi Engine Piston or equivalent

Single Multi Engine

turboprop or turbofan or equivalent

Flight Navigation Procedure Trainer (FNPT)

9,880 13,590 18,530





Table A45

Flight Simulator Training Devices (FSTD) – Surveillance Fee –

Charged on an annual basis


(2020 fees, EUR)

Flat fee per location (complex) 5,560

Flat fee per location (non-complex) 2,780

Single Engine / Aircraft

Configuration Double Engine / Aircraft




Single Engine Piston or equivalent Multi Engine Piston or equivalent

Single Multi Engine

turboprop or turbofan or equivalent

Flight Navigation Procedure Trainer (FNPT)

3,710 4,940 7,410





Table A46

Flight Simulator Training Devices (FSTD) – Extended Evaluation Programme (EEP)

Charged on an annual basis


(2020 fees, EUR)

Flat fee per location (complex) 11,120

Flat fee per location (non-complex) 5,560

EEP 3 years Single Engine / Aircraft

Configuration

Double Engine / Aircraft




Single Engine Piston or equivalent Dual Engine Piston or equivalent

Single Multi Engine

turboprop or turbofan or

equivalent

Flight Navigation Procedure Trainer

(FNPT) 1,900 2,310 3,300

EEP 2 years Single Engine / Aircraft

Configuration

Double Engine / Aircraft




Single Engine Piston or equivalent Dual Engine Piston or equivalent Single Multi Engine





turboprop or turbofan or

equivalent

Flight Navigation Procedure Trainer

(FNPT) 2,350 2,970 4,330

Table A47

Certification Support for Validation (CSV)

Individual Service Service Package

Hourly rate Large 2,500

Medium 1,000

Small 250





Table A48

Maintenance Review Board (MRB) – Initial Approval and revisions

Initial MRB report Revision of MRB report

350,000 Low activity project 10,000

Standard activity project 90,000





Part 2

Certification tasks or services charged on an hourly basis

Table A49

Certification tasks or services charged on an hourly basis

Hourly rate

Applicable hourly rate [EUR/h] 247 (*)

(*) including travel cost within the Member States

Hourly basis according to the tasks concerned2:

Production without approval Actual number of hours

Transfer of certificates Actual number of hours

Approved Training Organisation certificate Actual number of hours

Aero-medical Centre certificate Actual number of hours

ATM-ANS organisation certificate Actual number of hours

Air Traffic Controller Training Organisation certificate Actual number of hours

EASA Acceptance of Operational Evaluation Board Reports Actual number of hours

Other Special FSTD activities Actual number of hours

Approval of flight conditions for Permit to fly 3 hours

Alternative Methods of Compliance to AD's 4 hours

2 This is a non-exhaustive list of tasks. The list of tasks in this Part is subject to periodical revision. Non-inclusion of a task to this Part should not be automatically construed as

indicating that the task cannot be performed by the European Aviation Safety Agency.





FAA Basic STC one serial number 2 hours

Administrative reissuance of document 1 hour

Capability Check 1 hour

Export certificate of airworthiness (E-CoA) for CS 25 aircraft 6 hours

Export certificate of airworthiness (E-CoA) for other aircraft 2 hours

Part III

Charges for appeals

Table A50

Charges for appeals

Charges for appeals shall be calculated as follows: fixed charge shall be multiplied by the coefficient indicated for the corresponding charge category for

the person or organisation in question

Fixed charge 10,000 EUR

Charge category for natural persons Coefficient

0,1

Charge category for legal persons, according to financial turnover of the appellant in euro Coefficient

less than 100,001 0,25

between 100,001 and 1,200,000 0,5





between 1,200,001 and 2,500,000 0,765

between 2,500,001 and 5,000,000 1

between 5,001 and 50,000,000 2,5

Charge category for legal persons. according to financial turnover of the appellant in euro Coefficient

between 50,000,001 and 500,000,000 5

between 500,000,001 and 1,000,000,000 7,5

over 1,000,000,000 10





APPENDIX B: MAIN OPTIONS CONSIDERED BUT NOT RETAINED

Adjusting fees for all F&Cs activities with a blanket increase

EASA could increase all F&Cs by applying a blanket percentage increase to all fees. The impact for each

percentage point increase would amount to approximately EUR 1 m per annum.

Advantages

The advantage of this solution is its simplicity and uniformity, as well as relative ease of implementation. Such

amendment could also be adopted irrespective of any changes to the F&Cs structure of tiers. Provided that the

increase is moderate, the solution would not be likely to attract strong opposition.

Disadvantages

One-off price increase is unlikely to improve sustainability of EASA’s budget over time and the process of

amending the F&Cs Regulation would have to be replicated with each following increase. The increase would

make the financial viability of EASA very sensitive to volume mix change, knowing that some activities are loss-

making. Additionally, if the increase is significant, applicants are likely to resist the changes.

Introducing a fast-track process

EASA could introduce a fast-track service for its applicants — it could charge an extra fee for a guarantee to the

applicant that a certification application will be dealt in priority to other applications, which is a common and

generally accepted service in other areas, such as passports or visas.

Under this new system, EASA would not commit to a specific turnaround time, given EASA’s primary focus on

safety; however, fast-track services would increase the likelihood of the applicant getting a swifter response

from EASA.

Advantages

Introducing a fast-track service could provide faster services to applicants that value speed of response the most,

improving the quality of service EASA provides to its applicants.

Disadvantages

In order to prioritise work for requests for fast-track services, EASA would have to increase its internal work

capacity (in order to work quicker on those requests), otherwise the logical consequence will be that requests

for non-fast-track services will be dealt with at a lower speed. This would mean that unless EASA is indeed able

to increase its capacity internally or through additional outsourcing, the applicants that will typically ‘suffer’

from a decreased quality of service are those that are less willing or unable to pay for such fast-track service,

and it is expected that these applicants, more often than not, are ‘smaller’ applicants. In other words, there is a

high likelihood that such solution would penalise ‘smaller’ applicants at the expense of ‘large’ applicants.

Furthermore, there is a risk that the fast-track service may lead to the perception from the public that whatever

fast-tracked work done by EASA may have been done quicker and to lower quality standards (even if, in fact, the

fast-track service would only have an impact on prioritisation of work). This could lead large manufacturers as

well to shy away from this service: if there was ever an accident involving a product that was certified under the





fast-track scheme, the risk of negative public perception of the safety quality standards could affect the applicant

as well.

Adopt a purely hourly rate approach

EASA could change the overall F&Cs structure for one based entirely on hourly rate. This means that EASA would

levy fees from applicants based on the number of hours spent. The same hourly rate could be used for all

certification activities, or a different hourly rate could be used depending on the applicant (e.g. a cheaper rate

for ‘small’ applicants) and the type of work (e.g. a more expensive rate for more complex work).

Advantages

An F&Cs system based purely on an hourly rate could be described as the ‘perfect cost-reflective system’. This

approach would eliminate the need to set and adjust different fixed fees for all products and organisations that

EASA certifies and approves, and could fully accommodate new technologies. This approach would mirror that

used by some NAAs.

Disadvantages

An hourly rate approach was used in the past by EASA, but it decided to move away from that system for reasons

that still appear to be valid today. Indeed, despite the transparency of hourly rates, applicants have low

predictability of the total fee they have to pay for certification and approval activities. This is especially important

for ‘small’ applicants for whom EASA’s F&Cs may constitute important regulatory barriers to enter their

respective markets, and especially an issue for very large certification undertakings such as type certificates.

Additionally, the accuracy of fees relies heavily on all EASA staff accurately tracking the hours they dedicate to

any given activity, with the need to specifically attribute those hours to specific applicants (which can be a

challenge sometimes when work relates to more than one applicant). Finally, applicants are often required (for

internal audit purposes) to confirm the accuracy of hours charged by EASA before they can pay any invoice

issued by EASA to them, which adds to the administrative burden of applying the system for both sides.

Calculate fees as a percentage of product value or organisation turnover

EASA could consider changing the overall F&Cs structure by setting F&Cs based on the financial value of the

product or the turnover of the organisation concerned.

For product certification, initial fees could be calculated based on, for example, the catalogue price of an aircraft,

and continuous certification fees could be calculated based on sales revenues on that aircraft. This would replace

the current structure where the MTOW of the aircraft is typically used as a basis for setting fees.

Organisational approvals could be priced based on organisation turnover. This would replace the current

structure where the number of staff is typically used as a basis for setting fees, except for Product Organisation

Approvals that are currently charged based on turnover.

Advantages

The value of a product or turnover of an organisation can be said to be a good proxy to complexity and related

risks, and to the work typically required by EASA to certify or approve such product or organisation. An F&Cs

structure based on value also removes the need to regularly update the F&Cs system in line with new

technologies and innovations, as well as with inflation: by calculating fees as a per cent (%) of the value/turnover,





the approach can be applied to any type of product or organisation, even those that were not considered at the

time the F&Cs system was implemented.

Disadvantages

Such system would reduce the predictability of EASA’s revenues, and make them more dependent on industry

trends (e.g. if industry moves to cheaper products, EASA’s revenues would be directly impacted even if the

workload is constant). Another difficulty in implementing this model would stem from the fact that certification

typically precedes the phase of product development when the catalogue price is determined, hence making it

challenging for both the organisation and EASA to determine the value off which the fee should be calculated.

The same holds true for new organisations. In addition, this model would not be suitable for activities related to

modifications, because there is no catalogue price for those services. Finally, applicants may perceive this as a

revenue tax, ‘punishing’ them for being successful in their business, which could make them resistant to such a

change in the F&Cs structure.

Set fees based on complexity of product or organisation

EASA could adopt F&Cs based on the complexity of the product or organisation. Such approach is already used

for some activities, such as major changes (for which fees vary depending on whether the change is ‘simple’,

‘standard’ or ‘complex’).

Advantages

Product or organisation complexity could be described as a good proxy to workload for EASA (e.g. the more

complex a product is, the more time-consuming for EASA its certification typically is).

Disadvantages

The definition and interpretation of complexity criteria could become quite challenging for some products and

organisations. In the case of major changes, the complexity criteria actually tie up to technical criteria, which

makes the determination of complexity a relatively straightforward and objective process. Defining complexity

criteria for all products and organisations, however, could become quite challenging. Used as a price basis,

criteria would need to be created and reflected in the Regulation, and creating such a definition is likely to prove

itself a challenging task. Complexity could also be said to ‘not tell the whole story’: while a more complex product

does indeed take more time to certify, other drivers of workload include the size of the product, the number of

systems, etc., which may or may not be considered as part of a complexity metric.

Introduce risk-based pricing for all fees

EASA is currently changing the approach to the certification of products by introducing risk-based principles to

determine the ‘level of involvement’ (LoI) of EASA. Such ‘LoI’ approach will allow EASA to eventually spend less

time on products that are deemed to be low risk, and spend more time on others. One option would be to adopt

fees that are also determined by an assessment of risk of the product or the organisation, thus allowing fee

levels to be adapted in line with the workload EASA will eventually dedicate to certification and approval

activities.

Advantages

If workload for EASA will in the future vary based on risk through the ‘LoI’ approach, then determining fees based

on risk would allow them to be also aligned with workload, thus achieving the goal of ensuring that fees are





cost-reflective. Such system would also reward good applicant behaviour towards developing safe products,

because the certification of low-risk products would lead to lower fees. Finally, determining fees based on risk

level would make them fully adaptable to new technologies, as risk-assessment criteria could be designed to

apply to any product or organisation, even new ones not known to EASA when the F&C Regulation will enter

into force.

Disadvantages

There is inherent subjectivity in the process of assessing the risk of a product or organisation, and such

subjectivity could drive non-negligible disagreements between applicants and EASA regarding the level of risk

that a product or organisation represents. While such subjectivity can be structured using clear principles and

guidelines, this will require EASA’s ‘LoI’ approach to be fully developed and implemented — at this time,

however, it is still in a pilot phase. Until EASA’s ‘LoI’ approach is further defined, the level of uncertainty it may

lead to for both applicants and EASA is such that it is deemed not advisable at this time to determine fees on

that basis.

Introduce a continuous F&Cs structure

In contrast to the current ‘lockstep’ approach, EASA could move to a continuous system of F&Cs levels. That

would replace the large ‘jumps’ between the current F&Cs tiers with smaller, proportionate increases.

Advantages

This approach may seem fairer to applicants who fall just above a certain threshold and in result are required to

pay significantly more than the ones who fall just below the threshold, despite the only slight difference in the

products.

Disadvantages

A continuous F&Cs structure requires replacing the tiers, which are easy for applicants to apply, by a

mathematical formula which may prove to be significantly more complicated. Also, the continuous pricing

approach may not be beneficial to applicants if, looking at the facts, the products certified and the organisations

approved by EASA do not fall close to a limit between two price tiers, such that the problem of an important

price jump caused, for example, by the increase of the MTOW of a product by only a few kilogrammes does not

apply.

Introduce a fee table for RPASs

The Agency considered introducing a fee table for RPASs based on the use cases.

Advantages

Introducing a fee table based on use cases would increase predictability for the RPASs applicants and increase the cost-reflectivity compared to the current approach of charging by hourly fee.

Disadvantages

Since the RPASs industry is rapidly changing, the basis of use cases was considered not sustainable due to risk of quick outdate. The Agency considered another basis for the fee tables, however the industry is evolving too rapidly to introduce a proposal which would be sustainable over time and adequately address the issues of cost-reflectivity as well as be based on risk.





Introduce a charge for TCOs

The Agency initially proposed to levy a flat fee for the authorisation and continuous monitoring of TCOs based on the total fleet size and the category of aircraft the TCO flies.

Advantages

Charging the TCOs for the services they receive would be reflective of the workload this activity generates for the Agency, and would help to minimise the carelessly prepared applications, which cause significant amount of additional activity for the Agency and are not paid for. This would also help to alleviate current situation which is unfair to other applicants which need to pay fees for the certification and approval services EASA provides to them.

Disadvantages

The industry pointed towards the risk of retaliation from third countries which would impact the European operators.

Other options

Other options were considered too but, for the reasons already mentioned, disregarded based on an initial

conclusion that the new structure would not be an improvement compared to the current F&Cs system.

— Bundling of services into packages which applicants would be able to purchase in advance at a lower cost: due to the difficulty in determining the level of charges, this solution has not been further considered.

— Membership fee in exchange for an unlimited number of certifications: due to lack of cost-reflectivity, this solution has not been further considered.

— Insurance model (similar to that of an insurance company policy) whereby applicants with good track records and no incidents would be rewarded through lower fees, whereas applicants with no good track records would see their fees increasing. However, this situation would create a financial incentive for applicants not to report accidents and incidents, in fear of this leading to higher fees for them. Due to the fact that EASA wants to encourage applicants to fully report all accidents and incidents for EASA to fully document and learn from these, such financial disincentive to reporting is not desirable.

— Partial financing of rulemaking by applicants, in replacement for EU subsidies: due to the actual or perceived risk of conflict of interests (since EASA would be developing rules which those that finance their development must comply with), the solution has not been further considered.

— Fee model based on performance, which would entail ‘success fee’ in case of certification being granted: due to lack of cost-reflectivity, this solution has not been further considered.

— Auctioning system of selling certification capacity periodically to the best offer: due to lack of cost-reflectivity of the system, this solution has not been further considered.

— Dynamic model in which fees would vary based on resource capacity of EASA or the applicants’ willingness to pay: due to lack of cost-reflectivity of the system, this solution has not been further considered.

— Volume discount, i.e. a rebate to applicants based on volume of certifications and/or approvals: since this model would go against the need for EASA to set fees that also reflect each applicant’s ability to pay, and applicants that typically have the highest ability to pay are also the ones that would benefit from volume discounts, this solution has not been further considered.

— Capacity commitment, i.e. a rebate to applicants that can commit upfront to a certain volume of work to EASA: since this model would also go against the need for EASA to set fees that also reflect each applicant’s ability to pay, and applicants that typically have the ability to commit to large capacity purchase are also the ones that would benefit from volume discounts, this solution has not been further considered.





APPENDIX C:

Simple Standard Significant Complex Significant

EASA Supplemental Type Certificate (STC)

STC, major design change, or repair, only involving current and well-proven justification methods, for which a complete set of data (description, compliance check-list and compliance documents) can be communicated at time of application, and for which the applicant has demonstrated experience, and which can be assessed by the project certification manager alone, or with a limited involvement of a single discipline specialist

All other STC, major design changes or repairs

Significant’ is defined in paragraph 21.A.101 (b) of the Annex I to Regulation (EC) No 748/2012 (and similarly in FAA 14CFR 21.101 (b)).

‘Complex Significant Change’ is any significant change (ref. GM 21.A.101 of the Annex I to Regulation (EC) No 748/2012) involving at least 2 reasons justifying its classification as significant (examples of criteria as per this GM: change in the general configuration, change to the principles of construction, assumptions used for certification have been invalidated) or

Any significant change involving 2 or more examples described as significant change (column ‘Description of change’ Tables in Appendix 2 to GM 21.A.101 of the Annex I to Regulation (EC) No 748/2012).

EASA major design changes

EASA major repairs

N/A N/A

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