Watching UK Prime Minister Johnson’s speech, made in Old Royal Naval College at Greenwich yesterday, there’s no doubt the setting was impressive. The words were not so impressive. In fact, they were downright confusing. Phrases like: “Free trade is the only certain way of uniting people in the bonds of peace” are peculiar given that the UK has just left one of the world’s most successful projects for free trade and peace.
There were jaunty references to being like Canada, or Australia or something akin to these two Commonwealth States. The vision painted by Johnson had none of the precision or artistry of the walls in the recently restored Painted Hall. Even so, there was an echoing theme that the UK wouldn’t follow any rules other than its own.
The reference to a country that’s bigger in physical size but smaller in population and that has a larger neighbour to the south, is interesting from an aviation perspective. It’s true that Canada has its own aviation regulatory structure. It hosts the international organisation that is responsible for aviation standards, namely ICAO. In addition, it has major aerospace design, manufacturing and maintenance companies as well as international operators.
However, Canada’s free trade agreement (CETA) with the European Union (EU) doesn’t eliminate all tariffs and quotas. Built over many years, for aviation there is a level of mutual recognition between Canada and the EU.
In 2011, an agreement on civil aviation safety between the EU and Canada entered into force. Part of this agreement includes detailed working arrangements. This international cooperation was agreed when both sides demonstrated to the other that they had the regulatory competence and capacity to satisfy each other’s needs. The work is by no means finished.
So, yes perhaps it is the case that carbon copy rules, or complete harmonisation between parties is not the only route to mutual recognition. Usually, regulatory differences exist not because parties want them to exist for their own sake but that each party has a different set of experiences. In design certification, the reason for a great number of rules and standards can be traced back to accidents and incidents. Not everyone has had the same history or operates in the same environment (social, political, economic and so on). Regulatory maturity is only established over decades. Then regulators can assess each other’s systems and decide that arrangements, like accepting each other’s certificates can be done safely. What I’ve described doesn’t happen overnight. A conservative, with a small “c”, approach is taken to aviation safety because the consequences of getting it wrong can be tragic.