UK CAA Performance Based Regulation Conference · • Our new owners took over in June 2012 - $1.2 billion. • 9.8 million passengers in 2013. • Voted “Best European Airport:

UK CAA Performance Based Regulation Conference Gatwick Hilton May 19th 2014

Agenda 10.00 – 16.00

10.00 - 10.10 Welcome, introductions and agenda review Mark Swan

10.10 - 10.25 Keynote speech: Performance based regulation Andrew Haines

10.25 - 10.45 The EASA ambition for performance based safety regulation Trevor Woods

10.45 - 11.00 The UK CAA’s transformation to performance based regulation Ben Alcott

11.00 - 11.20 Panel discussion and questions Andrew Haines (chair)

11.20 - 11.40 Morning Break

11.40 - 11.55 An airline operator’s perspective Garry Copeland

11.55 - 12.10 An airport operator’s perspective David Wilson

12.10 - 12.25 An ANSP (CANSO) perspective Jeff Poole

12.25 - 12.40 Integrating ground handling Kirsten Riensema

12.40 - 13.00 Panel discussion and questions Mark Swan (chair)

13.00 - 14.00 Lunch

14.00 - 14.45 Working Sessions – Benefits and Challenges CAA Facilitators

14.45 - 15.00 Afternoon Break

15.00 - 15.45 Plenary discussion and questions – Benefits and Challenges Mark Swan (chair)

15.45 - 16.00 Closing presentation Mark Swan (chair)

16.00 – 17.00 Afternoon Tea Reception

Keynote: Performance Based Regulation Andrew Haines Chief Executive CAA

The EASA ambition for performance based safety regulation

Trevor Woods EASA, Approvals and Standardisation Director Gatwick, 19 May 2014

Evolution of Safety

19/05/2014 CAA performance based regulation conference 5

Technical Factors

Human Factors

Organisation Factors

Considerations for the Future

Economic Pressures Air Traffic Growth New Technology New Business Models (multinational) Cooperative Oversight (EU/BASAs) Environmental Pressures Security Precautions Etc..



“...improve the performance of the European aviation system with regard to safety, competitiveness, environmental protection and quality of air services provided to citizens, by setting appropriate regulatory framework.”

Ref: EC doc: “Policy initiative on aviation safety and a possible revision of Regulation (EC) No 216/2008…”, 26 March 2014

Commission Policy Objective

Layers


ICAO

EU/EASA

National AA

Organisation

Performance Based Environment


Safety Performance Measurement and Risk Assessment at a Total System level

Enablers for PBE

Data Driven Decision making based on SPIs*

Mature Safety Management Systems and State Safety Programmes Information Sharing Cultural Change Authority and Organisation Requirements Responsibilities and Enforcement Resources Common Terminology.


* SPI: Safety Performance Indicator

Prescriptive Rules vs PBR


PBR focus on achieving desired performance Improved understanding of risks Identification of mitigations Better targeting of resources Flexibility We need a mix of both.

Prescriptive Clear minimum Captures lessons from

history Interoperability Simple philosophy

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Risk and Performance Based Oversight


Relies on SPIs and PBRs

RBO: focus on risk PBO: focus on overall performance

Compliance Effective Compliance

Relies on available information

Continuous Monitoring

Organisational Risk Profile

Surveillance Interval /Target


EASA Regs, SMS and RBO

Domain Reg./NPA/RMT SMS

provisions?

RBO provisions

?

ATM Reg. 1035/2011

Aircrew Reg. 1178/2011

Air Operations Reg. 965/2012

Standardisation Reg. 628/2013

Aerodromes Reg. 139/2014

Continuing Airworthiness (M/145) NPA 2013-01

Continuing Airworthiness (66/147) NPA 2019-19

Initial Airworthiness MDM 060

Reporting 376/2014 (from 15/11/15) Reg. 376/2014 Feed Feed

Example “Horizontal Rules”


Authority Requirements NAA oversight programme to account for:

specific nature of the organisation complexity of its activities, results of oversight activities based on the assessment of associated risks

Oversight cycle may be extended (max 48 months) if: the organisation has demonstrated an effective identification of aviation safety hazards and management of associated risks

Organisation Requirements identify safety hazards evaluation, management of associated risks, verify effectiveness.

Occurrence Reporting Regulation


Report

•Just Culture

Competent Authority

ECR

EASp

Network of Analysts

SSP

Key Ingredients

SMS/ Reporting SSP/ PBO PBR/ Standardisation ICAO Annex 19


ICAO

EU/EASA

National AA

Organisation

•ECR •Network of Analysts •Reporting Culture •EASp •SPIs •Mix of Prescriptive and PBR.

Thank you for your attention

Additional Slides


Standardisation Model overview

Time Elapsed

Output Levels

Determine

frequency and

scope of

inspections

Follow-up Indicators

Authority Indicators

Safety Indicators

Activity Indicators

1 100

0

Other

EASA

Authority

Data input Rating calculation Overlay indicators Output validation 2 3

A B C D

General Indicators

SIS

19

•ANALYSE AND

PRIORITISE

•ACT AS APPROPRIATE

•FOLLOW-UP

•COLLECT INFORMATION

•Web-based •interface

•(Multi)annual •Programme

•The Model

Comprehensive Inspection

Focused Inspection

Ad Hoc Inspection

Off-site Finding

Continuous Monitoring

Status

New Risk Based Approach for Assessing Authorities [628/2013]

20

Reorganisation of EASA

•Organisation setup based on the following principles: • Robust Product Safety function (integration of Certification and Rules);

• Strong Safety Oversight function (integration of Rulemaking and Standardisation); • Data driven Safety Strategy function; • Customer oriented administrative function;

• New Structure:

• Executive Directorate • Certification Directorate • Flight Standards Directorate • Strategy and Safety Intelligence Directorate • Resources and Support Directorate

21

22

Delivering Performance Based Regulation in the UK Ben Alcott Enhancing Safety Performance CAA Programme Director

Transforming the CAA to a performance based regulator

23

The drivers for performance based regulation


The operating environment

The regulatory framework

The need to maximise opportunities from Industrys’ SMS

Delivery of the better regulation agenda

24

What does CAA’s transition to performance based regulation mean in practice for you?

A holistic, “entity” based approach

Targeted, consistent, and proportionate oversight

New conversations based on risk and performance


25

Safety Review Board Safety Action Group (SAG)

Data Information Decisions Prioritised and Proportionate Actions

CAA Capability Areas

Industry Sectors

CAA Executive and Board

• Entity & Sector Risks • Better Regulation Opportunities

2. Safety Management 2 External information

3. Strategy and Governance 3 • Feedback and Direction

Industry challenge

1. Performance Based Oversight 1

Key Processes for the CAA

26

The next two years……

Jan 14 Apr 14 Jul 14 Oct 14 Q1 (’15) Q2 (’15) Q3 (’15) Q4 (’15) Q1 (’16) Q2 (’16)

90 AOC led Entities Fixed: Phase 1

60 Helicopter Led Entities: Phase 1 Flight Ops led

Entities

50 EASA Aerodromes and 30 additional to be rolled out over 15 months

ANSP led entities (numbers/schedule to be determined in Feb)

AW led entities (numbers/schedule to be determined in Feb)

90 AOC led Entities Fixed: Phase 2

60 Helicopter Led Entities: Phase 2

Planning

Proportionate involvement; e.g. adoption of ESP principles

Entity Groups

Aerodrome led Entities

ANSP led Entities

Airworthiness led Entities

Other (GA, CPG, PPT).

Two year Deployment Schedule

Bus

ines

s ch

ange

driv

en b

y E

SP

Pro

gram

me

Develop and implement Internal SMS (phase 1)

Developing and deploying the next generation of the tools to enable PBO ways of working Influence

tech roadmap, planning

IT Tools Project

Enabling the above rollout…

Mature SMS developing (Phase 2 assessed) Internal

SMS


27

Our Vision

To transform the CAA into a Performance Based

Regulator, working with industry to demonstrably

reduce safety risk across the total aviation system

and develop the capabilities required for future

regulators.


28

Thank you for your attention


29

Panel Discussion and Questions Chaired by Andrew Haines Chief Executive CAA

30

Break

20 minutes

31

An Airline Operators Perspective Garry Copeland Managing Director UK Operations British Airways

CONFIDENTIAL - Seasonal Readiness

Performance Based Regulation CAA conference May 14


• The aviation industry has traditionally relied heavily on auditing to deliver oversight, compliance, product quality and safety.

• Conventional auditing will likely remain a component of the oversight toolbox

• Conventional auditing at or beyond the limits of usefulness in continuously improving safety and performance

• As the industry strives to continuously improve

performance, conventional oversight processes giving repetitive, low level, findings drive an environment of preoccupation, distraction and complacency.

A tool at its limits.


A burden beyond effectiveness?

• BA experience: • 'Its big, so it's got to be risky! • 'No one else's audits are good enough' • 'If all the boxes are ticked, it must be all right'

• In 2013: • External audits: 8 ACAM, 17 CAA, 5 foreign regulator, 109 SAFA • Internal audits: 82 physical, 53 desktop, 254 ARC's, 17 safety culture Zero level 1 findings, 117 level 2, 77 level 3 Generated 597 ASRs, 281 MORs


Good or bad?

• BA experience based on: • 280+ aircraft of seven major types • Part M, Part 21, Part 145, Part 147, Flight

Training Organisation. • 250,000 cycles per annum • 362,000 flight hours PA. • 1,745,000 Engineering load hours ASR rate of 1.4/1000 hours MOR rate of 0.7/1000 hours How does we and the regulator use data to access and address risk?


Technology and quality assessment?

• New generation aircraft and supporting ground technology

• Can audit be effective? • How do auditors stay current and

know what the risk areas are? • Do we know how increasing

automation and information integration will influence future risks?

• What information will guide us?


Raising the bar and dealing with the future

• Conventional audit won't disappear, part of a risk based oversight tool kit • Intelligent and skilled use of data to identify and address risk • Huge challenges as technology evolves and drives different risks. • Huge need for constant skills development and familiarity with current

challenges and risks, not perceived risks based on out of date experience

• Paradigm shift will require knowledgeable and skilled people working in an open, collaborative environment

• Legal responsibilities of accountable managers and regulators will not go away.

• We welcome the opportunity to have a true Performance Based Regulation and oversight debate.

38

An Airport Operators Perspective David Wilson Chief Operating Officer Edinburgh Airport

Facts and Figures

• We are the 5th busiest airport in the UK. • Our new owners took over in June 2012 - $1.2 billion.

• 9.8 million passengers in 2013. • Voted “Best European Airport: 5m - 10m Passengers” at the 8th

Annual ACI EUROPE Best Airport Awards for the third year in a row.

• 43 airlines – 130 destinations. • New long haul routes and growing with

existing customers.

40

Voted Europe’s Leading Destination at the World Travel Awards 2012. Source: World Travel

Awards 2012

Voted Best UK City in the Guardian, Observer and guardian.co.uk Readers’ Travel Awards. Source: Guardian

The population of Edinburgh is expected to grow 10% by 2025. Source: Office for National Statistics (2010)

Source: ETAG Key Figures 2012

Edinburgh – the city • Scotland’s capital, home to half a million people.

• The UK’s largest tourist market outside London, over 3.69 million people visit the city annually – 2.35 million from the UK, 1.34 million from overseas.

• 41% of visitors to the city arrive by plane.

• Host of the largest annual ticketed event in the world world’s largest arts festival - almost 1.9 million tickets were issued for the 2011 Edinburgh Festival Fringe.

Growth Plans

• Flights to and from Edinburgh are expected to increase by 25% in 2020 carrying 29% more passengers than in 2014.

• £150m investment in the next 5 years.

• Introduction of Advanced Airfield and Airspace Management Concepts.

1. Loss of Control

2. Runway Excursion

3. Controlled Flight into

Terrain

4. Runway Incursion

5. Airborne Conflict

6. Ground Handling

7. Fire

CAA Significant 7

Significant Number CAA Response EAL Response

1. Loss of control

2. Runway Excursion

3. Controlled Flight into Terrain

4. Runway Incursion

5. Airborne Conflict

6. Ground Handling

7. Fire

CAA Significant 7

Performance Based Regulation

Less:

• Ticking Boxes.

• ‘One size fits all’ type rule making.

• Over compliance with European regulation.

More:

• Commercial Awareness.

• Focus on the significant risks – by sector.

• Sharing information and best practice.

Increase Effectiveness

• Focus safety management on the most important risks to our customers.

• Develop robust safety cases for advanced operations (e.g. reduced spacing via PBN).

• Gather and share information and good practice across the sector.

Increase Efficiency

• Use evidence to find the most cost effective way of mitigating key risks.

• Reward good performers and target oversight towards poorer performers.

• Track the costs to airports of regulation and look for ways to reduce them.

• Overall cost of operation matters and is uncompetitive in the UK.

• APD increase from £12 to £14 per passenger.

• Business rates are increasing……..£1 dep passenger

• Policing costs are increasing………£0.50 dep passenger

• CAA – Security charges

APD and cost of regulation

• The start of a more collaborative approach to enhancing safety.

• Less pass and fail, more targeting of resources to risks.

• More provision of intelligence to support Edinburgh to grow safely and efficiently.

• Recognition on the cost of regulation and taxation.

Conclusions

49

An ANSPs (CANSO) Perspective Jeff Poole Director General CANSO

50

Integrating Ground Handling Kirsten Riensema GHOST Sponsor CAA

Integrating Ground Handling into the total system risk and performance based oversight

GH is a significant part of industry overall performance

What is the Risk? • Severity x probability • Potential impact • Safety culture not as

mature as other sectors

How are we performing? • Evidence that reporting is

low • Are we measuring safety

performance as well as other KPIs?

• Do we actually understand our performance?

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What is the size of the risk?

Improvement in reporting But not across the board

0

0.1

0.2

0.3

0.4

0.5

0.6

0.7

0.8

Operator GH

Operator Operator Operator Operator Operator Operator Ground Handler

(GH)

Operator Operator

Pro

po

rati

on

of

Lo

ad

ing

Err

or

rep

ort

s re

ceiv

ed

Top 10 De-identified Reporter for Jan-Mar over Five years

2009 Q1 2010 Q1 2011 Q1 2012 Q1 2013 Q1

Accountable Managers: Should you be concerned?

• Is there a Just Reporting culture in your Ground Handling activities?

• Do investigations determine root cause? • Do your teams fully understand the balance

between safety and punctuality? • Have we done sufficient to make ourselves aware

of the right information, or is ignorance bliss?

• Direct regulation of Ground Handling? • Via our current oversight of Airports and AOCs? • Improve integration of GH/Airport/AOC/ATM

safety management? • Combined metrics, leading to targeted campaigns? • Location specific entities?

How can we include GH in Performance Based Regulation?

[email protected]

Panel Discussion and Questions Chaired by Mark Swan Group Director Safety and Airspace CAA

• Three Breakout Groups in separate rooms

• Delegates allocated at random

• Identified by badge colour

After Lunch Working sessions start at 14.00

Lunch

1 Hour

Working Sessions: Benefits and Challenges CAA Facilitators Breakout Rooms

Break

15 minutes

Plenary Discussion: Benefits and Challenges Chaired by Mark Swan Group Director Safety and Airspace CAA

Closing Presentation Mark Swan Group Director Safety and Airspace CAA

Rules introduced by EASA set the context for the UK’s transformation to Performance Based Regulation.

Conclusion EASA Pivot to Performance Based Regulation

The new rules are driving a move from:

• compliance based activities over entities we traditionally regulates; to

• Target all areas that represent a major safety risk to passengers and the public;

• Which requires a risk and performance based approach across individual entities, sectors and the total aviation system.

Conclusion UK CAA Transformation Programme

Two year Transformation Programme is in the Deployment Phase. CAA is working with Industry to generate four key outcomes:

1. Demonstrably improve levels of aviation safety in the UK and of UK entities operating globally

2. Ensure all regulatory policies and actions are proportionate

3. Coordinate industry participation in safety improvement initiatives

4. Improve the value for money of Safety Regulation/Management

The safety regulator’s business is to relentlessly interrogate two key questions 1. What safety risks does aviation pose to the UK passenger and general public? 2. Are the risks being managed effectively?

Next Steps Outputs and Feedback

• Post conference eSurvey circulated tomorrow – please provide your feedback, its hugely valuable.

• Draft report describing the outputs of the conference for review and comment (June-6th).

• Deadline for feedback on draft report (July 4th).

• Final report incorporating delegates comments published on the CAA’s website (August 1st).

Documents

UK CAA Performance Based Regulation Conference · • Our new owners took over in June 2012 - $1.2 billion. • 9.8 million passengers in 2013. • Voted “Best European Airport: