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

Transitional 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 and applicable descriptor, select the drop down for each associated assumptions and insert the total estimated cost for each assumption.

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.

19. Descriptor 1 – Familiarisation Costs

This descriptor aims to collect an estimation of all potential costs related to familiarisation activities to ensure that at operator and contracted activities levels, all relevant staff and organisations are aware of the new requirements.

These should not include costs that would be covered by or achieved with training.

20. Descriptor 2 – Oversight Implementation Costs

This descriptor aims to collect cost estimations on the implementation of the oversight programme.

It should be proportional to the cargo operations and network operated in domestic and/or international operations.

It should be aligned with existing oversight cycle rationales established by the operator’s compliance monitoring and safety management systems.