I'm not going to defend the position, but I can go some way to explaining it. I've been negotiating rulechanges with CAA (on behalf of various GA players) for quite a few years, and with more success than most - but a great deal of frustration.
The order in which you negotiate a rulechange with the CAA is something like this:-
(1) Put together your proposal, together with justification (which primarily needs to show a minimisation of liability to the CAA).
(2) Via an appropriate organisation's representation put the proposal to the relevant regular steering group - these meet somewhere between 3 monthly and annually.
(3) Probably wait some months (my personal record is over 18) for CAA to decide what they think.
(4) Repeat stages (2) and (3) as many times as necessary to get it right.
(5) CAA will then put the proposed rulechange firstly to it's senior management, then out to public consultation. This takes a few more months.
(6) If there isn't major disagreement from anybody, make a few tweaks, and a few months later it becomes law.
The fastest I've ever managed a significant rulechange was 18 months, and 5+ years is not unusual. Of course, when it gets that long, there are generally personnel changes, industry reps losing the will to live, and a constant need to re-educate people at CAA and elsewhere in what you wanted and why. There's also the risk that the steering group that you were routing it through might get abolished en-route, requiring you to start again.
It's an absolute nightmare of a system, but generally NOT the fault of the individuals with the CAA. The organisation's senior management have never seen any benefit in either delegating real power to it's working level managers, nor in a major streamlining of the system. (There are many ways in which it could be). That said, it is getting harder, as the authority is becoming less competent, meaning that you are often negotiating with staff who don't properly understand what you are telling them - this is particularly frustrating.
EASA has streamlined it a bit, but then messed the whole thing up further by insisting that they'll now only negotiate with pan-european organisations. So, your proposals have to go through 2 or 3 layers of "organisation" outside EASA before you can start to negotiate properly.
I am not defending this process, as an aerospace manager I can see many ways of making it all work far better - and I suspect so can much of CAA's middle management. But, that's how it is at the moment.
In the meantime, if you want to negotiate with either CAA or EASA you must:-
- Understand the process, and who is involved in it as far as possible.
- Speak on behalf of a UK/European organisation, and have their political backing.
- Have an absolute and dogged determination to make it happen, and be prepared for several years of repeating yourself at meetings to changing or bewildered authority staff.
- The ability to justify what you want in excruciating detail, with particular reference to achievability, minimising liability to CAA/EASA, and precedent.
G