UK Means of Compliance for Vertical Take-off and Landing aircraft under Special Condition VTOL

Closed 5 May 2023

Opened 20 Mar 2023

Contact

Airworthiness Policy Team

AWConsultations@caa.co.uk

Feedback updated 15 Nov 2023

We asked

The purpose of the consultation was to seek your comments on proposed Means of Compliance & Guidance in support of UK Special Condition SC-VTOL, for the certification of electric vertical take-off and landing aircraft.

You said

There was clear support for adoption of the proposed MOC and guidance. Commenters recognised that the material is consistent with that introduced by EASA and that this will benefit UK industry by reducing safety barriers for export to the EU. Respondents also supported the continuation of harmonisation efforts with the USA.

One respondent provided a variety of editorial and technical comments against the material, these were mainly additional to comments that had previously been made by the respondent organisation to EASA, during its consultation process for the MOC in 2020 and 2021.

As MOC to a Special Condition, the published content is not binding. It is a way, but not the only way to show compliance to SC-VTOL. It is therefore possible for an applicant for certification to propose an alternative MOC; provided that this enables a satisfactory demonstration of compliance to the safety objective within SC-VTOL itself. With this broader context in mind, when we reviewed the above comments, we determined that some were of a general nature, while others reflected developing experience with a particular aircraft design. It is also recognised that as a new aviation sector, eVTOL designs are varied and continue to evolve. As such SC-VTOL and the associated MOC are a starting point, and these will evolve with experience from industry and the regulators. We consider that the best way forward, in order to support the over-arching objective of harmonisation with both FAA and EASA, is to retain the MOC text as published and to bring these insights into conversations with other regulators, as we learn through undertaking certification programmes.

There was no objection to the proposed Means of Compliance & Guidance in support of UK Special Condition SC-VTOL, for the certification of electric vertical take-off and landing aircraft.

We did

We are grateful for the submissions received, we have reviewed each comment and provided feedback to respondents as appropriate.

As described above the consensus from respondents was in support of adoption and implementation of the referenced MOC, and of CAA’s continued efforts toward harmonisation with FAA and EASA for this new aviation sector. Where changes to the published material were proposed, and recognising that CAA is committed to evolving SC-VTOL based on experience across both industry and other regulators; it has been decided that these should be addressed either within the broader frame of harmonisation or where appropriate, through consideration of alternative MOC within the certification process.

Note: At the time we published our MOC adoption proposal, the document MOC-3 SC.VTOL Issue 1, had completed EASA Open Consultation, and was in their Comment Response (CRD) process. This has been finalised and Issue 2 was published by EASA on 21 June 2023. We have reviewed issue 2 of the EASA MOC (and CRD) and consider the finalised version to be acceptable to CAA. We have also reviewed it against comments submitted to CAA in response to our MOC adoption proposal. The commenter has confirmed that their comments made to both CAA and EASA, have been satisfactorily resolved by EASA in their final version, Issue 2.

We will proceed to adopt the Means of Compliance & Guidance in support of UK Special Condition SC-VTOL, for the certification of electric vertical take-off and landing aircraft.

Published responses

View submitted responses where consent has been given to publish the response.

Overview

Following the decision in 2022 to adopt the Special Condition VTOL (SC-VTOL) as the basis for certification of Vertical Take-off and Landing (VTOL) aircraft, the CAA is proposing adoption of EASA Means of Compliance (MOC) to SC-VTOL to aid the development of guidance for Original Equipment Manufacturers (OEMs) entering or intending to enter into the certification process for VTOL aircraft.

These aircraft are developing fast and the CAA recognises the importance of enabling the certification process for the benefit of the UK aviation sector. The CAA has been an active member of the collaborative project to develop safety standards within Europe for eVTOL since before EU exit. MOC material is needed to enable industry to demonstrate compliance to the SC-VTOL standards already adopted. The work on MOC started in 2018, with the identification of a priority list of topics.

The MOC for priority 1 and 2 topics have been published by EASA, priority 3 topics were subject to public consultation in 2022 and resolution of comments is almost complete. Priority 4 topics are being drafted and are planned for release shortly.

The CAA independently concluded that in order to enable the latest design of VTOL related certification projects and the validation projects where EASA is the Certification Authority, and after establishing no technical objections to the EASA MOCs to SC-VTOL as published, the proposal is to adopt the MOCs in their most up-to-date version. 

The CAA intends to introduce into its regulatory framework the MOC to SC VTOL by adoption of the materials developed in collaboration with EASA and the eVTOL industry.  Your feedback will help us to better understand the potential issues or improvements before we finalise these.

What are Means of Compliance to Special Conditions?

Special Conditions are detailed technical specifications prescribed by the CAA for a product where the related current certification specifications do not contain adequate or appropriate safety standards for that product. This is usually because the product has novel or unusual design features relative to the design practices on which the applicable certification specifications are based.

Means of Compliance are developed for Special Conditions to provide further direction to OEMs on how these safety requirements can be met.

This consultation

The CAA is consulting on the approach to adopt EASA MOCs to SC-VTOL at their latest version, consisting of the following documents.

Priority 1 and 2 MOC topics are contained in:

Priority 3 MOC topics, for which comment resolution is due to complete in March 2023:

Why your views matter

It is important to the CAA that everyone has an opportunity to voice their opinion on matters that could affect them. There is also a legal requirement to consult when creating detailed specifications and guidance material, due to the legal status of these documents.

We welcome comments from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry, whether as an aviator, aviation consumer and/or provider of related products and services.

How to respond

We have extended the closing date to 5 May 2023.

We cannot take into account comments received after this date. We will assume that all responses can be published once the consultation has closed. There is an option to request for your name to remain private, but in any event your email address will never be published.

Please submit your comments using the online survey link below. 

What happens next

At the end of the response period, we will review your comments and submissions and publish the results. Your feedback will be considered during the development of the regulatory changes.

Audiences

  • eVTOL sector interest groups

Interests

  • Special Condition consultations
  • MOC to Special Conditions
  • AMC & GM consultations