Call for evidence outcome

Civil Aviation Authority review: summary of responses

Updated 17 July 2023

Background

A call for evidence on the effectiveness and efficiency of the Civil Aviation Authority (CAA) was published on 28 November 2022 and remained open for responses until 29 January 2023.

The findings from the call for evidence have helped to inform the Review of the CAA . The CAA review’s terms of reference sets out the review’s focus on providing a detailed assessment of the effectiveness and efficiency of the CAA’s functions and structures, governance, and accountability to Parliament and to the Department for Transport (DfT). We carried out interviews and meetings with individuals and groups of stakeholders and initiated a call for evidence to seek opinions about the CAA, including its strategic objectives, experiences as users of CAA’s ‘paid for’ services and CAA’s engagement with stakeholders.

Stakeholders, individuals and organisations submitted responses to questions using an online web form. In total, 444 responses were received online or by email. The majority of responses followed the call for evidence questions. Where email responses did not follow the call for evidence questions the review team analysed them individually. These 26 responses could not be included in the call for evidence quantitative analysis but they were considered by the review. A selection of anonymised quotes have been included in this report to highlight common themes from these responses.

Additionally, we received further evidence from a consumer magazine including many emails specifically dealing with customer experience relating to an individual airline. This evidence also fed into the review, but as it did not follow the questions, is not numerically accounted for here. The call for evidence questions did not explicitly consider the CAA’s internal governance or its formal relationship with DfT. These themes were explored in depth during a series of stakeholder events with representatives from airlines, airports, airport community groups, general aviation and emerging technologies and meetings with DfT and CAA officials.

Summary

The call for evidence asked questions spanning a range of areas relating to the work of the CAA. A wide range of stakeholders responded. Some responses were very detailed and expressed a broad range of opinion. This report summarises the key trends from major stakeholder groups, as well as some question responses which have informed the recommendations.

Responses to the call for evidence were split into 2 main groups:

• responses from 287 individuals
• 157 responses on behalf of organisations

418 of these responses used the web survey and 26 organisations provided email responses. Some of these email respondents did not follow the structure of the call for evidence, and we have analysed these emails separately rather than attempting to assess how they might have responded to the call for evidence questions.

A list of respondents, including the organisations that responded, can be found in overview of individuals and organisations who responded to the call for evidence.

This report is exclusively a summary of responses to our call for evidence and does not include feedback gathered at the stakeholder events and consultations held with commercial airlines, airports, General Aviation (GA) sector, airport community groups and emerging technology companies as well as meeting with numerous other stakeholders. These meetings also informed the review’s recommendations.

What respondents said about CAA’s performance

The UK CAA has been recognised as a leader in aviation regulation globally for decades and as an influencer and key partner with National Aviation Authorities and international organisations. Despite more recent challenges in managing many new work steams and structures resulting from the UK leaving the European Union, and the COVID-19 response…(we) consider that the CAA maintains a high level of effectiveness, capability and trust across most areas of its broad remit.

The CAA has broadly speaking coped well in meeting its duties and responsibilities through what has been an extremely challenging environment for the aviation industry…Now is an appropriate juncture at which to examine how the CAA has performed through this period, what has worked well, and to consider what might be best done differently, and to examine future priorities.

(We) commend the CAA on how it has handled the Brexit transition period. The CAA ensured it was prepared for all negotiated outcomes and other eventualities, and it has generally been successful in ensuring as much stability as possible for businesses and consumers as it has handled change and taken on new responsibilities.

With regards to economic growth and recovery, the CAA’s approach to the post-pandemic operational ramp-up was largely positive, with regular engagement and discussion concerning the challenges that we expected to encounter, including from a safety and security perspective. This was constructive and helpful in ensuring the safe and secure restart of passenger flying at scale, commencing in 2021 and finally being achieved in 2022.

The CAA is slow to respond to key events, and there is no evidence it is being held to account for timely delivery of its responsibilities.

The CAA’s strategic direction on supporting economic growth also does not stand comparison with other sectors and other economic regulators.

Trends for individuals

Questions in the call for evidence were structured to give 5 options, ranging from strongly agree to strongly disagree. Strongly agree was always a positive response to the question.

In total, around 70% of all respondents were individuals expressing their own opinions.

Across all questions and individuals, 15% of responses either agreed or strongly agreed with the questions and 57% of responses either disagreed or strongly disagreed.

Looking at sub-groups of Individuals, members of the public and passenger or cargo customers of UK aviation had the most positive responses, with 27% responses from members of the public and 30% responses from passenger or cargo customers of UK aviation being agree or strongly agree.

By comparison, aeromedical examiners and commercial pilots had the most negative responses, with 69% of responses from aeromedical examiners and 67% responses from commercial pilots being disagree or strongly disagree.

Trends for organisations

In total, 132 responses were received on behalf of organisations. These were broken down into sub-groups. The highest proportion of this demographic of respondents (61%) were organisations regulated by the CAA for the safe operation of aviation.

Overall, organisations often responded neutrally to the call for evidence, with 29% of their responses being ‘neither agree nor disagree’. Other responses were, 26% were disagree, 20% were strongly disagree, 22% were agree, and 3% were strongly agree.

Remotely piloted aircraft systems (RPAS) operator organisations responded the most negatively, with 62% of their responses being disagree or strongly disagree. Organisations regulated by the CAA for consumer protection responded the most positively to the survey, with almost 58% of their responses being agree or strongly agree.

The most positive feedback from organisations related to the questions on enforcement of consumer protection, with 46% of responses being agree or strongly agree.

Questions about the CAA’s customer service performance in comparison to other aviation regulators had the highest proportion of negative responses and the highest proportion of strongly positive responses, with 65% of organisations responding negatively and 13% responding positively.

The questions around the CAA’s enforcement of consumer protection and effectiveness at regulating the sector received the most positive responses from all groups of individuals. 37% of responses to the CAA’s enforcement of consumer protection were either agree or strongly agree and 27% of responses to the CAA’s effectiveness at regulating the sector.

The questions which received the most negative responses were around the CAA’s effectiveness in acting on feedback and how the CAA’s customer service compares to other regulators, with 86% of individuals responding negatively to the CAA’s effectiveness in acting on feedback and 80% to how the CAA’s customer service compares to other regulators.

Responses to questions on feedback

The call for evidence asked respondents a range of questions about how they were able to give feedback to the CAA and how they thought it was used. These questions received some of the most negative responses. In particular:

• question 30.1 – 69% of respondents disagreed or strongly disagreed that the CAA seeks feedback to improve its performance
• question 30.2 –72% of respondents disagreed or strongly disagreed that the CAA seeks feedback to improve its customer service
• question 33 –73% of respondents disagreed or strongly disagreed that the CAA acts upon customer feedback

Individuals (77%) were considerably more negative than organisations (55%) in this area.

What respondents said about CAA’s requests for and response to feedback

As part of its industry engagement, the CAA does regularly seek feedback on its proposals and thinking, including calls for evidence and consultations.

No clear system for providing feedback and no response as to how feedback is acted upon.

We have regular and constructive exchanges with the CAA (and DfT) which includes conversations around how we can collectively deliver on our objectives more effectively.

…Says the right things but no follow through in outputs…

When we offered our perspective and feedback, we found that the CAA team was open and willing to change their processes to the extent that was possible under the rules and regulations which they operate. However, at no point was our feedback actively sought out.

Feedback questions are often tailored to give the wanted response.

We see examples of both positive and negative response to feedback- though generally a tendency to defend current positions. Response is very slow.

I have volunteered feedback to the GA unit on the issues regarding UK permit aircraft travelling to GA states. The response was friendly but has not resulted in any change.

Responses to questions on engagement

The call for evidence asked respondents about how the CAA engages with different groups, stakeholders, the public, air passengers, air operators, those regulated by the CAA and government regulators.

• question 29.1: In your view, to what extent do you agree or disagree that the CAA engages with stakeholders?
• question 29.2: In your view, to what extent do you agree or disagree that the CAA engages with the public?
• question 29.3: In your view, to what extent do you agree or disagree that the CAA engages with air passengers?
• question 29.4: In your view, to what extent do you agree or disagree that the CAA engages with air operators?
• question 29.5: In your view, to what extent do you agree or disagree that the CAA engages with regulated parties?
• question 29.6: In your view, to what extent do you agree or disagree that the CAA engages with government regulators?

Overall, respondents tended to respond negatively on the theme of engagement. The most negative responses were to the CAA’s engagement with those regulated, where66% strongly disagreed or disagreed (question 29.5) and stakeholders, where 63% strongly disagreed or disagreed (question 29.1).

The responses from individuals and organisations on the CAA’s engagement were similar. The greatest difference between individuals’ and organisations’ perceptions was on the CAA’s engagement with air operators. Organisations had a more positive perception than individuals, with 48% giving a positive answer compared to 25% for individual responses. When asked about the CAA engagement with government regulators and air passengers, a high proportion of both individuals and organisations gave a response of ‘Neither agree nor disagree’.

Some common themes could be identified from respondents’ explanation of their responses. Respondents suggested that the CAA does engage but could do so more effectively. This was supported by the view that frequent and effective engagement from the CAA wasn’t consistent, even within sector groups. One comment stated that ‘engagement is difficult for everyone but major industry players’.

What respondents said about CAA’s engagement with stakeholders

(We) welcome the open access that the CAA allows across a number of levels, from CEO and relevant Executives through to the ‘working group’ level.

(airline/s) enjoy generally positive working relationships with the CAA and recognise it is as an effective regulator.

The CAA continue to work closely with (us) on operational matters. On occasion the (CAA) teams have provided excellent advice on operational matters, often sharing best practice from other…The CAA compliance teams always approach these matters in an open, candid and collaborative manner.

There is a high degree of trust and open dialogue between CAA and (airline/s). In our experience, communication between the CAA and (airline/s) is relatively good, albeit with improvement required…This is very welcome, serves better regulation and should be encouraged and maintained.

We would recommend much more formal and regular engagement with the industry.

…there is not always the same level of engagement at board level – in particular, with the (Non-Executive Directors), who have poor visibility within the sector. This needs to improve, in particular as the CAA looks to increase its remit and role within the sustainability agenda.

Responses to questions on growth and innovation

The call for evidence asked respondents 3 questions on the promotion of economic growth and innovation.

• question 24: To what extent do you agree or disagree that the CAA supports economic growth of the aviation sector through its regulatory decisions?
• question 27.1: To what extent do you agree or disagree that the CAA supports technological innovation across the sector?
• question 27.2: To what extent do you agree or disagree that the CAA supports operational innovation across the sector?

Just under three-quarters of individuals and around 60% of organisations responded negatively to question 24. The GA community responding as individuals – including pilots (commercial and private) and professional drone operators – were particularly strongly negative. There were more mixed views across different types of organisations. Remote pilot aviation system operators were the most negative and airlines and some representative bodies giving positive responses.

Explanatory responses on economic growth suggested that parts of the sector feel over-regulated. In particular, the GA community (inclusive of drone operators) reflected on the impact of the burden of regulations on the sector. Many respondents also felt that the pace of some regulatory decisions was slow, which they feel impacts the sector.

On question 27, the responses on technological innovation were more positive than those on operational innovation. Individuals gave a more negative view than organisations with 60% of responses to these 2 questions being negative, compared with less than half of organisations.

Some respondents provided additional information about their answers saying processes are perceived to be slow and/or outdated. Different regulatory regimes in other countries, in particular the USA were mentioned by some respondents, largely from the GA community.

What respondents said about CAA’s focus on growth and innovation

(If) the aviation sector is to achieve this ambition and realise the economic, social, and environmental opportunities of the 21st century, there must be a reset in the CAA’s approach to innovation and economic growth.

(We) agree that the CAA’s high level strategic vision should continue to focus on key areas such as safety, security airspace oversight, as well as enabling the recovery of the aviation sector and supporting sustainable growth through innovation and technology. However, despite these high-level objectives, there are significant gaps on duties that the CAA has responsibility for, as well as a clear outline of how to achieve their goals.

(This is a) timely opportunity for government to help the CAA reset its trajectory by empowering a bold evolution in its approach to innovation, underpinned by significant improvements in the regulator’s effectiveness and efficiency. Taking this opportunity will ensure the sector can continue to innovate to meet the challenges of the 21st century, and realise the huge economic, social, and environmental opportunities of the future.

The innovations developed by industry and being adopted in a global context will require the CAA to be fast moving in its safety and regulatory role, including collaboration on those developed overseas and certified by overseas regulators.

Its strategic focus areas are broadly the right ones, emphasising risk-based oversight supporting innovation and growth, and improving the sector’s environmental performance.

The status quo is delaying major benefits from enhanced public services and improved safety cases through to economic growth and productivity gains across multiple sectors.

…it is right that the CAA considers supporting sectoral growth to be an important part of its remit, albeit we believe this consideration should be more formalised than it is currently…

Responses to questions on consumer protection

There were 2 questions on the enforcement of consumer protection:

• question 51: To what extent do you agree or disagree that the CAA effectively administers the ATOL Scheme?
• question 52: To what extent do you agree or disagree that the CAA effectively enforces consumer rights with its current powers?

Overall, this subject received the most positive responses from all groups with 39% of respondents agreed or strongly agreed with the statements.

More respondents agreed that the CAA effectively administers the ATOL scheme than agreed that it enforces consumer rights. Nearly two-thirds of responses from organisations were positive about ATOL administration and less than 3% of organisations disagreed or strongly disagreed.

Individuals also generally responded more positively to the CAA’s administration of ATOL, 47% strongly agreed or agreed and 12% disagreed or strongly disagreed.

The responses about CAA’s enforcement of consumer rights were less positive. 34% of organisations strongly agreed or agreed and 27% disagreed or strongly disagreed. For individual respondents 28% strongly agreed or agreed and 39% disagreed or strongly disagreed

Explanations of responses shared positive experiences of the ATOL process, but also noted that there are some current enforcement issues with perceived airline rule-breaking, and issues which are not covered by the ATOL scheme. Whilst not in scope of the questions, it is worth noting that several responses questioned whether the CAA have the appropriate powers to enforce some of these regulations.

There were also a small number of responses reflecting on issues facing passengers with reduced mobility, particularly in light of travel disruption across summer 2022. We also received a detailed response from a consumer organisation, sharing consumer correspondence relating to one particular airline. This was noted and discussed in the review process but falls outside the call for evidence reporting.

What respondents said about CAA’s focus on consumers

We see a number of positives in how CAA oversees consumer protections in the marketplace…

The CAA must have enforcement tools available that will enable it to act swiftly to stop consumer detriment where it has been identified.

We believe that the CAA is overall an effective regulator that provides strong support for the sector. However, we do believe that there are examples where CAA regulatory decisions are not supporting the economic growth of the aviation sector (or the consumer interest) as well as they should.

Trends in responses from General Aviation

To account for the breadth of the GA community, we combined responses from a number of the individual sub-categories, including private pilots, professional drone operators and sports and recreational aviation participants. In all, we received 135 responses from these subgroups.

Responses from the GA community were generally more negative than average across all individuals. 59% of responses from the GA community expressed negative views and 13% of responses from the GA community expressed positive views.

Like other individual respondents, the GA community felt most positive about the CAA’s enforcement of consumer protection, 35% of responses being either agree or strongly agree and effectiveness at regulating the sector, 27% of responses being either agree or strongly agree.

The GA community gave the most negative responses to the question on how the CAA’s customer service compares to other regulators with 84% of responses being disagree or strongly disagree. and the CAA’s effectiveness at acting on feedback 83% of responses being disagree or strongly disagree.

Trends in responses from airlines

In total, 18 responses were received from airlines that were suitable for quantitative analysis. Several airlines, including some of the larger airlines, responded to the call for evidence without referencing the specific questions asked, and these have been read and assessed separately. Of these responses in total, 40% responded positively, and 37% responded negatively to the questions asked.

50% of the airlines responded negatively in reference to the CAA acting upon feedback and 25% responded positively.

For questions relating to value for money, responses were neutral or positive. The highest response category was ‘neither agree nor disagree’, with 39% of those answering on behalf of airlines choosing this category. The next highest proportion of respondents, 23%, chose ‘agree’.

On the effectiveness of CAA engagement, 47% of responses were positive on this theme and 33% of responses were negative.

The majority, nearly two-thirds, of airlines expressed positive views on enforcement of consumer protection.

Trends in responses from airports

Eight airports provided responses for the quantitative analysis of the call for evidence. Many airports, including some of the larger airports, provided responses separately from the call for evidence questionnaire, and these have been read and assessed separately. This section summarises the responses from the questionnaire responses.

Generally, those responding on behalf of airlines gave much more positive responses compared to the responses overall.

47% of airport responses were either agree or strongly agree compared with 26% either disagree or strongly disagree. This is different from the trends seen in other respondent groups.

This was not seen in response to value for money questions. Airport responses were most negative for this question theme, with 63% disagree or strongly disagree and 19% agree or strongly agree.

The theme of engagement was answered more positively. Looking at CAA engagement with all groups 48% of respondents answered ‘agree’ and 100% of respondents agreed that the CAA effectively engages with air operators (though this specific question had fewer respondents).

63% of airport responses agreed or strongly agreed that the CAA effectively promotes economic growth and innovation, with 15% disagreeing, and 22% neither agreeing nor disagreeing.

Finally, 70% of airports agreeing with the questions about the enforcement of consumer protection, and only 10% disagreeing.

Overview of individuals and organisations who responded to the call for evidence

Respondent type	Number of responses
Individuals	287
On behalf of an organisation	157
Total	444

Category of organisation respondents	Number of organisation respondents by category
Trade / Representative organisations	36
Remotely piloted aircraft systems	29
Other	24
Airline and tour operator	23
An aircraft design, production or maintenance organisation	11
Aviation training and/or examination provider	10
Airports	9
Advanced air mobility / Space organisations	6
Government / Political	4
Cargo Operators	3
Air navigation providers	2
Total	157

Organisation titles in alphabetical order

Please note that some organisations responded collectively.

• ADS
• Aero FlightOps UK Ltd
• AeroAVA Displays Ltd.
• Aerospace Technology Institute
• AH Helicopter Services Ltd
• AICES
• Air Navigation Solutions Ltd
• Aircraft Owners and Pilots Association
• Airlines UK
• Airpix Drone Solutions
• Airport Operators Association
• Airspace Change Organising Group
• AIRX Charter
• Altitude Aerial Photography Ltd
• Altitude Angel
• American Airlines
• ANDREWSFIELD AVIATION LTD
• Apian
• All Party Political Group on Aviation
• Arora Group
• ARPAS UK
• Aviation Environment Federation
• BEA Ltd
• Birmingham Airport Limited
• BM Aviation (UK) Ltd.
• Board of Airline Representatives UK
• Boeing
• Bristow Helicopters UK
• British Airline Pilots’ Association
• British Airways
• British Balloon and Airship Club
• British Gliding Association
• British Helicopter Association
• British Microlight Aircraft Association
• BT Group
• The CAA Consumer Panel
• Caledonian Advanced Pilot Training
• Cameron Young Ltd
• Carlisle Flight Training
• Channel Islands Aero Services Ltd
• The Chartered Institute of Logistics and Transport
• Jet Concierge Club
• Consumer Council
• Cormack Aircraft Services Cumbernauld Airport and Tail Draggers & Floats Flying Services
• Cranfield University
• Crows Nest Films Ltd.
• DHL
• Disabled Persons Transport Advisory Committee
• dnata travel group UK
• Drone Media Imaging
• The Drone Office Ltd
• Global Drone Training Ltd
• Droneflight Ltd
• Eagle Drones UK Ltd.
• East Midlands Helicopters
• Eastwood Media
• EasyJet
• Electric Aviation Limited
• Emirates
• European Colour Deficient Aircrew Association
• European Union Aviation Safety Agency
• Expedia Group
• Eyeup Aerial Solutions Limited
• FB Heliservices Ltd.
• Flight Composites Ltd, Scillonia Airways Ltd & O-1 Aviation Ltd
• Flying Camera Crew Ltd
• Fox Williams
• Gatwick Airport Limited
• Gatwick Airport Consultative Committee
• Gatwick Area Conservation Campaign
• General Aviation Alliance
• General Aviation Awareness Council
• Glossop Mountain Rescue Team
• Gorilla Drones Ltd
• Guild of Air Traffic Control Officers
• Clear Sky Imaging
• Heathrow Airport Limited
• Heathrow Airline Operator Committee
• Heathrow Area Transport Forum
• Heathrow Hub Ltd
• Heathrow Southern Railway Ltd
• Heathrow Strategic Planning Group
• HeliOffshore Ltd.
• HexCam Ltd.
• Highlands and Islands Airports Ltd.
• Hilton Garden Inn
• HQ Aviation Ltd
• Hurricane 501 Operations LLP
• International Air Transport Association
• IFP Design Ltd
• Independent Flight Examiners’ and Instructors’ Association
• Independent Pilots Association
• Jet2
• Joby Aviation
• Large Model Association
• Leading Edge Aviation Ltd.
• Light Aircraft Association
• Local Authorities’ Aircraft Noise Council
• Luton Airport
• Manchester Airports Group
• Marine Film Service
• Meggitt (UK) Ltd.
• Mekdem Ltd
• Metal Seagulls Ltd
• Momart Limited
• National Air Traffic Services
• Noctua Aerial Media
• Oysterair Ltd
• PPL/IR Europe
• Prospect
• QinetiQ
• RBHF Services Limited
• Reduced Mobility Rights Limited
• Rolls-Royce Plc
• Royal Aeronautical Society
• RyanAir
• Sardinian Sky Service
• Saxon-Air Charter Ltd.
• Sellafield Ltd.
• Shetland Flyer Aerial Media
• Skynique Ltd.
• Skyports
• British Model Flying Assocation
• Elite Helicopters
• Space Forge
• St. Mary’s Airport/Council of the Isles of Scilly
• Strategic Aviation Special Interest Group
• Synergy Aviation
• T Stop Aerials Ltd
• TAG Aviation
• TEXO Group
• Transport for All
• Transport Scotland Mobility and Access Committee
• UK Regional and Business Airports Group
• UK Research and Innovation Future Flight Challenge
• United Airlines, Inc.
• Uplock Limited
• UPS Group
• Vector Aircraft Services Limited
• Vertical Aerospace
• Virgin Atlantic
• Wellesbourne Matters
• Which?
• Wing Aviation LLC
• Wizz Air UK Limited
• York Gliding Centre
• ZeroAvia