CAP3082 Consultation on Changes to UK Regulation (EU) No. 965/2012 with regards to the Specific Cargo Compartment Safety Risk Assessment

Closes 2 May 2025

One-off costs

To enable an accurate assessment to be conducted, the CAA is inviting air operators to provide an estimate of costs and benefits that should be considered as a result from adoption and implementation of the proposed changes.

We have factored the following four types of costs in this consultation, which address the principal areas the CAA believes may be impacted by the adoption and implementation of the proposed changes:

  • One-off Costs – resulting from the implementation of the changes
  • Transitional Costs – resulting from the transition to the new requirements
  • Ongoing Costs - annual costs required for maintaining and upkeeping the new SMS and CMS requirements.
  • Benefits - resulting from adequate mitigation of an uncontrolled fire in the cargo compartment resulting from items being carried.

Each cost type will have a series of associated descriptors to allow necessary granularity of the estimations and what covered.

In case we have not captured all potential associated costs, we have included at the end of this section, an additional opportunity for estimation of ‘Other Costs’ not considered previously, to be entered.

When responding to this part of the consultation, go to each of the types of costs listed, its applicable descriptor / specified cost,and please insert the total estimated cost in £ (GBP) for each.

At the end of each type of cost there is a free text box into which additional information can be entered, for the purpose of explaining a rational or providing clarification deemed necessary by the commentator.

Please provide as much detail as possible, as this will allow the CAA to account for as many variables as possible in the impact estimation.

15. Descriptor 1 - Staff Resourcing

This descriptor aims to capture number of staff needed for the initial implementation and estimated role related costs that may be incurred. 

These costs should be reflective of the operator’s size, its cargo and/or passenger operations and its network (domestic and/or international). 

This descriptor should consider costs which are in addition to existing Safety Management and Compliance Monitoring activities which are currently required to be in place under the purview of The Air Operations Regulation.

16. Descriptor 2 – Staff Training

This descriptor aims to collect estimated costs required for training of all personnel, which may include development costs with training platforms, materials and individual training costs.

The estimate should consider additional training to what the operator is already required to have in place for the Safety Management Compliance Monitoring Systems.

17. Descriptor 3 – Administrative Costs

This descriptor aims to collect an estimate of all potential costs related to administrative functions that would be needed for the implementation of the changes to the regulation.

18. Descriptor 4 - Other One-Off costs

This descriptor allows for any other one- off costs that may not have been captured in the previous cost types.