British – Page 48 – John Vincent

Brexit and Aviation 36

No week goes by without Brexit developments. This week has been no exception for European aviation and aerospace. In the background there’s been the UK Conservative Party conference in Birmingham. All that has been revealed is that we are still in limbo land or a limbo in the air, as one might say.

The UK Government technical papers for a Brexit ‘No Deal’ scenario for Aviation Safety, Flights and Aviation Security have been out for several days. The variety of different commentaries ranges from the don’t bother – this will never happen to the downright cataclysmic grounding of all flights.

Nevertheless, the impact of a “no deal” scenario is still being understated because of the long-term regional repercussions. The lines on the map that divide up airspace in Europe are changing. If other nations, see that we can not deal with that reality why would they open their skies to us?

The Royal Aero Society have updated their thoughts on the implications of Brexit[1].

On the rules for slot allocation at airports, the current rules for the allocation should remain unchanged in the event of “no deal”. However, a proposed “recast” of the current EU Slot Regulation is planned. A problem arises in that the UK will not have a say on future EU legislation to create a market for slots and this has its own downside.

On the profesional aviation personnel side, concerned aircraft engineers are seeking information about a non-negotiated EU exit. British issued Licenses that are now valid in the EASA Member States, will not be valid in those States as of midnight (00h00) on 29 March 2019 unless a deal is done.

Now the EU institutions are engaged in identifying and putting in place new preparedness measures in anticipation of Brexit. This week it is worth taking note that EASA has started to process applications for Third Country approvals from existing UK approval holders[2]. There’s additional administration and costs but at least organisations holding recognised approvals have a pathway to retaining those approvals.

On a subject that may at first glance seem unrelated the European Aerospace Associations have announced a Safety Management System (SMS) Industry Standard[3]. Here we can see the practical advantages of having a common rulebook.

During my time at the UK CAA, I was a member of the Prospect Union[4] (Formerly IPMS). I’m pleased to see their recent publication on the future of aviation and Brexit “safety and resilience – not a race to the bottom”. One of their recommendations is new to me and I must admit the idea hadn’t occurred to me before. It is “breaking up the Civil Aviation Authority and establishing a new UK Aviation Safety Agency” thus further separating the functions of economic regulation and safety regulation. Somehow, I don’t think that’s the biggest concern just now.

[1] https://www.aerosociety.com/news/a-no-deal-brexit-the-aviation-implications-part-2/

[2] https://www.easa.europa.eu/brexit-negotiations

[3] https://www.asd-europe.org/aerospace-associations-announce-safety-management-system-sms-industry-standard

[4] https://www.prospect.org.uk/

Brexit Expo

Truly we are in strange times.

Earlier this year, I did the tour of the Royal Albert Hall. Yes, I would recommend it even though it’s part of the standard London tourist trail. The story of the building is fascinating. How and why it got built. The person to thank for it is Prince Albert of Saxe-Coburg and Gotha, the husband and consort of Queen Victoria. This forward-thinking German was a great supporter of public education.

The legacy of the Great Exhibition of the Works of Industry of All Nations of 1851, was the Hall and the Museums in that quarter of London. The Crystal Palace was the first World’s Fair. Albert died suddenly in December 1861. Much of the money, coming from the Great Exhibition, that was allocated to build the Hall was spent on his memorial.

On the South Bank of the river Thames lies the legacy of the Festival of Britain. This took place in the summer of 1951. We need to remember that Britain was still in the grips of post-war food rationing[1] at that time. The plan was to celebrate the centennial of the 1851 Great Exhibition. Unlike the Great Exhibition, the Festival of Britain was about promoting British architecture, arts, science, technology and industry. In late 1951, as Churchill was returned as MP, his first move was to clear the South Bank site believing the project to be socialist propaganda.

So, the history of great exhibitions and festivals is a chequered one.

The next World’s Fair is planned for 2020 in the UAE. A site has been chosen between the cities of Dubai and Abu Dhabi. 132 Counties, including the UK, have announced their participation in the 2020 World’s Fair.

Today’s Conservative proposal for a 2022 Festival of Britain is strange to say the least. Apparently, funds have been allocated and, in Party conference week, the PM is hoping to appease Brexit supporting MPs with this retro-adventure. Unsurprisingly, Social Media is lighting up with ridicule. Some see Theresa May dressed up as Britannia and handing out goodies to all commers.

Whatever the merits of large exhibitions and festivals surely it makes more sense to have a greater presence in world-wide events than it does to build domestic palaces? If Brexit goes ahead or not, Britain must market what it does. The audience is the world. Shows of nationalism are unlikely to archive any positive or useful goals. Just more division.

This light-weight Conservative proposal is misguided and wasteful.

[1] http://news.bbc.co.uk/onthisday/hi/dates/stories/july/4/newsid_3818000/3818563.stm

Brexit and Airworthiness

Without going into the whole history of the last 50 years, there has been considerable success at harmonisation of aircraft certification rules in Europe. Not only at a level of the requirements and specifications to be applied by the processes and procedures used too.

Now to consider a “no deal” outcome of the negotiations between the EU and UK. This is the case where there are no working arrangements or informal agreements of any kind on the day after the assigned leaving date of leaving the European Union (EU).

In accordance with the Chicago Convention there are a series of certificates that are mandatory in international civil aviation. Those concerning aircraft airworthiness are in the articles of the convention and its Annexes, most particularly Annex 8 and its associated manual.

The complete framework of European aviation regulation is compliant with these standards. So, a European aircraft Type Certificate (TC) or a Certificate of Airworthiness (CofA) or an Airworthiness Release Tag (EASA Form 1) is recognised across the globe. To build this European system, decades of cooperative working and confidence building were invested. It’s is not only that the rules and procedures are agreed and correct, it’s also that their implementation delivers the desired results.

In a “no deal” outcome of the negotiations between the EU and UK the EU Regulations responsible for this regulatory system no longer apply in the UK. Now, I have assumed that the technical content of these regulations will be adopted lock-stock and barrel into UK law. Thus, the situation may be that the UK will not change any aspect of the rules and procedures for the issuance of a certificate on the day after Brexit.

The significant difference that arises is that the certificate issued will be a National certificate and not a European one. Thus, it will not be automatically mutually accepted by EU Member States. For existing certificates, the UK may choose to adopt all those that exist at the time of change. Nevertheless, each one of these would need to be accepted as a UK National certificate.

The European system does validate certificates from “third countries” but this is usually done under the framework of a working arrangement or a Bilateral Aviation Safety Agreement (BASA). If no such arrangement or agreement exists, then either there’s no recognition or an ad-hoc grandfathering of privileges might prevail. Such ad-hoc measure might be time limited and contingent upon the conduct of an audit.

In any event the movement of aircraft and related products, parts and appliances between the UK and EU Member States will not be as free as it is now. In the extreme worst case “no deal” there will be no movement. This would be commercially catastrophic for all sides.

Speculating about ad-hoc or emergency measure is difficult. One analogy that could shed light is that of the position of Turkey. In 2009, the Joint Aviation Authorities (JAA) was disbanded. Non-EU members of the JAA like; Norway, Iceland, Switzerland and Liechtenstein joined the European system. Turkey did not. There is a working arrangement between the EASA and Turkish DGAC[1] but it is limited. Relationships like these are subject to continuing negotiations which are not without frustration.

[1] https://www.easa.europa.eu/sites/default/files/dfu/WA%20SAFA%20Turkey.pdf

Brexit and Aviation 31

It’s now under 200 days until the end of the Art. 50 Brexit negotiating period. I’m guessing that’s why we have had an absolute deluge of technical guidance papers popping out of the UK Government[1]. Although many are in the “unlikely event of the UK leaving the EU without a deal” it’s almost as if that’s the aim. Incidentally, some papers drop the “unlikely” altogether.

If only this huge effort could have been channelled towards something useful. Certainly, to apply so much civil service effort to health and education would have been a much better idea.

13 September 2018 has been a busy day for the Government’s publications people. As yet, there’s no paper on my favourite subject: Aviation. That’s still in the works.

There’s a hint of what maybe to come. Here’s some words form the paper on vehicle Type Approval.

“After March 2019 if there’s no deal. In a no deal scenario, type-approvals issued in the UK would no longer be valid for sales or registrations on the EU market. EC type-approvals issued outside of the UK, would no longer be automatically accepted on the UK market. This means that affected manufacturers would need to ensure that they have the correct type-approval for each market.”

So, duplication, extra costs and other such waste is on the way.

Here’s a random list of the papers published:

Haulage permits and trailer registration

Arrangements for future haulage permit and trailer registration schemes after leaving the European Union (EU).

UK nationals in the EU: essential information

Information on the rights and status of UK nationals living and travelling in the European Union (EU).

Passport rules for travel to Europe after Brexit

Advice for British passport holders in the unlikely event of the UK leaving the EU without a deal.

How to prepare if the UK leaves the EU with no deal

Guidance on how to prepare for Brexit if there’s no deal.

‘No deal’ Brexit advice for businesses only trading with the EU

HMRC letters to VAT-registered businesses only trading with the EU that explain changes to customs, excise and VAT in the unlikely event that the UK leaves the EU without a deal.

European Regional Development Funding if there’s no Brexit deal

How current and future European Regional Development Fund projects would be affected if the UK leaves the EU with no deal.

Trading goods regulated under the ‘New Approach’ if there’s no Brexit deal

How trading in harmonised goods regulated under the ‘New Approach’ would be affected if the UK leaves the EU with no deal.

Upholding environmental standards if there’s no Brexit deal

How businesses and others regulated through environmental quality standards would be affected if the UK leaves the EU with no deal.

Travelling to the EU with a UK passport if there’s no Brexit deal

Check whether you would be affected by changes to rules for British citizens travelling to some European countries after March 2019 if the UK leaves the EU with no deal.

Recognition of seafarer certificates of competency if there’s no Brexit deal

How seafarers would be affected if the UK leaves the EU with no deal.

Merger review and anti-competitive activity if there’s no Brexit deal

How merger review and investigations into anti-competitive activity would be affected if the UK leaves the EU with no deal

Accessing public sector contracts if there’s no Brexit deal

To explain how existing or potential bidders for UK public contracts and public sector buyers would be able to access and publish future public procurement contract opportunities if the UK leaves the EU with no deal.

Using and trading in fluorinated gases and ozone depleting substances if there’s no Brexit deal

How businesses dealing with fluorinated gases (F-Gases) and ozone depleting substances (ODS) would be affected if the UK leaves the EU with no deal.

European Social Fund (ESF) grants if there’s no Brexit deal

How organisations receiving European Social Fund (ESF) grants would be affected if the UK leaves the European Union (EU) with no deal.

Industrial emissions standards (‘best available techniques’) if there’s no Brexit deal

How standards for emissions from industry affected by the Best Available Technique (BAT) regime would be affected if the UK leaves the EU with no deal.

Reporting CO2 emissions for new cars and vans if there’s no Brexit deal

How vehicle manufacturers would be affected if the UK leaves the EU with no deal.

Travelling in the Common Travel Area if there’s no Brexit deal

Confirmation that the Common Travel Area arrangements and the associated rights and privileges of British and Irish citizens are protected if the UK leaves the EU with no deal.

Vehicle type approval if there’s no Brexit deal

How vehicle and component manufacturers would be affected if the UK leaves the EU with no deal.

Driving in the EU if there’s no Brexit deal

How holders of UK driving licences would be affected if the UK leaves the EU with no deal.

Trading under the mutual recognition principle if there’s no Brexit deal

How importing and exporting non-harmonised goods would be affected if the UK leaves the EU with no deal.

Getting an exemption from maritime security notifications if there’s no Brexit deal

How shipping companies would be affected if the UK leaves the EU with no deal.

Travelling with a European Firearms Pass if there’s no Brexit deal

How travelling with a European Firearms Pass would be affected if the UK leaves the EU with no deal.

Data protection if there’s no Brexit deal

How the collection and use of personal data would change if the UK leaves the EU in March 2019 with no deal.

Trading in drug precursors if there’s no Brexit deal

How trading in drug precursor chemicals would be affected if the UK leaves the EU with no deal.

Appointing nominated persons to your business if there’s no Brexit deal

How appointing a nominated person to carry out duties on your behalf when selling certain goods would be affected if the UK leaves the EU with no deal.

Running an oil or gas business if there’s no Brexit deal

How oil and gas energy businesses would be affected if the UK leaves the EU with no deal.

Funding for UK LIFE projects if there’s no Brexit deal

How organisations receiving funding under the EU LIFE programme would be affected if the UK leaves the EU with no deal.

What telecoms businesses should do if there’s no Brexit deal

How the telecoms regulatory framework would be affected if the UK leaves the EU with no deal.

Mobile roaming if there’s no Brexit deal

How leaving the EU without a deal would affect mobile roaming in EU and EEA countries.

Connecting Europe Facility energy funding if there’s no Brexit deal

How applying for and receiving energy grants from the Connecting Europe Facility (CEF) fund would be affected if the UK leaves the EU with no deal.

Broadcasting and video on demand if there’s no Brexit deal

How the rules for broadcasters and providers of video on demand services would change if the UK leaves the EU with no deal.

[1] https://www.gov.uk/government/brexit

Investigation

Will Brexit have a significant impact on civil aircraft accident investigation? Probably not but it will not make it easier and there are some pitfalls.

Cooperation between independent National accident investigation bodies has been a part of their make up for a long time. The international framework is dominated by ICAO Annex 13 to the Chicago Convention. At its core these standards and recommended practices are stable, well used and gets an update about every decade. In the UK, the Air Accidents Investigation Branch[1] (AAIB) investigates civil aircraft accidents and serious incidents.

In the EU, the applicable law is Regulation (EU) No 996/2010[2] – Investigation and prevention of accidents and incidents in civil aviation. Before this Regulation came into being a Directive 94/56/EC encouraged investigators to work together and apply the standards of Annex 13.

To some extent EU Regulation 996/2010 was forged because of the need to define in law the relationship between the European Aviation Safety Agency (EASA) and the 28 independent investigation bodies in the EU. The first Basic Regulation, that launched EASA had little to say on how the bodies should work together.

There’s a strong need for EASA, National Aviation Authorities (NAAs) and Civil Aviation Safety Investigation Authorities (as they are defined in the Regulation) to work together.

It becomes essential to be able to share confidential and sensitive information when accidents and incidents happen. Corrective action often needs to be taken quickly. It is the EASA and NAAs with industry who must take that action. A sound legal framework helps to ensure that information flows and responsibilities are clear.

Post March 31, 2019 the above Regulation will cease to be directly applicable. Naturally, the affected parties could choose to continue to apply its provisions. Even in the worst case “no-deal” scenario it would be unthinkable that an arrangement to share confidential and sensitive information wouldn’t be worked out.

In addition, here’s several areas where attention may be needed.

The Regulation sets-up a European Network of Civil Aviation Safety Investigation Authorities. Will UK AAIB continue to participate in that network?

EASA sets standards and approves Cockpit Voice Recorders (CVR) and Flight Data Recorders (FDR). Will UK AAIB be consulted on the amendments to standards?

Will the status of UK Investigation Reports and Safety Recommendations remain the same?

[1] AAIB is a branch of the Department for Transport.

[2] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/384433/Regulation_996_2010_of_20_October_2010_accident_investigation.pdf

Mettle and Mulligrubs

My last post had a glimmer of optimism about it. As the week progresses the basis for that optimism is subsiding. Slowly but surely. One cause is the endless, wholly erroneous diatribe of macho language that bleeds from the Brexit supporters. So, much effort and energy are being expended provoking conflict, heightening tensions and blaming others.

Constant uncertainty of the Brexit clock ticking is doing damage, even as we speak. The health of manufacturing confidence has reached a low. Contingency measures are kicking-in as companies move out of the UK. Hard working, tax paying, long-standing EU nationals are drifting away.

As real impacts are being felt by real people, so our politics seems more unreal. The UK is divided between people who are head-down studying, training or working and frantic groups that are fighting ancient battles. Politically Left or Right there’s a myopic obsession infecting public life.

Former governor of the Bank of England, Lord King has branded Brexit preparations as: “incompetent”. He’s coming from a position of supporting Brexit. My answer to him is the earthy historic phrase: you can’t make a silk purse out of a pig’s ear. The poor of preparation started the day an “advisory” referendum was proposed and driven through by a gambling PM.

Now, we have the ridiculous situation of the Brexit secretary Raab saying those in Parliament worried about warnings of damage to the UK car industry: “show more mettle”. Again a 17th century phrase. Maybe it’s time to revive some other historic words and phrases from that era.

Government is telling a: “Banbury tale” which is a form of: “cock and bull” story. That’s a ridiculous story, or a tale that rambles on without going anywhere. How apt for Brexit. Particularly considering that David Cameron’s constituency was in Oxfordshire.

I’m always astonished how many Brexiters are “mulligrubs”. That’s people in an exaggerated bad mood all the time. How they keep it up being so sullen when they “won” the referendum in 2016 is beyond belief. That word rolls off the tongue so maybe it’s worth reviving.

The political media is full of “pickthanks”. That’s gossiping tell-tales who spreads malicious rumours to carry favour. I can see why that one died. There are better words for such people but many of them are not to be used in polite company.

Brexit isn’t an answer to our current predicament. It’s a symptom of a much deeper problem. The longer we avoid that reality the worse the situation will get. Regrets are not enough. We need serious action to rethink. Sign-up[1].

[1] https://www.peoples-vote.uk/

Britain deserves better

Post-Brexit Britain will be more bureaucratic. The recently published Government papers are full of new regulatory regimes, doubling up of registration and extra processes for British business and consumers. When Ministers say, like Dominic Raab: “the UK will be better off outside the EU in any scenario…” we all know these are meaningless words. It’s his job to say that sort of nonsense even if this is turning reality on its head.

For the Conservatives it’s too late to change direction. They know that their negotiating strategy has fallen apart. Focusing on the negative, like threats of a “no deal” have done, has alienated potential partners. During negotiations, blaming people for intransigence has been a diplomatic blunder of the first order. It’s reinforced the solidarity of the potential partners.

The first batch in a series of Technical Notices on “no deal” assume a great deal of good will on the part of the EU. Some of them ignore the constraints that apply because of existing legislation in Europe. In an emergency, circumventing Regulations can be done but its going to be hard if the only reasons are ideological and pressures are like a game of Russian roulette.

The UK voted to leave the European Union on 23 June 2016. The world of early 2019 will not be the same as the world of early 2016. Populism remains but its not gathering any head of steam. It’s a minority of ideological radicals who keep pushing their cherished project. We don’t have to accept their view of the world.

We need a #PeoplesVote. But we need a positive campaign about the benefits of European solidarity. A campaign must present the facts and expose the lies of the last referendum. Britain deserves better.

Brexit and Aviation 28

The EU has already produced a series of notices on “Brexit preparedness”. It’s now the turn of the UK to publish notices. Taking the current course, the UK plans to leave the EU on 29 March 2019. What happens at that point remains a subject of much debate and discussion. Many hours of media time are dominated by speculation and those desperate to influence public opinion.

Brinkmanship is the apparent escalation of threats to achieve one’s aims. For brinkmanship to work, both sides escalate their threats. We never seem to be on the brink of anything good. Most “brinks” are on the edge of catastrophise, cataclysm, disasters, ruin, suffering or harm.

Pro-Brexit people often dismiss any such talk as, so called: “Project Fear”. That’s disingenuous because it’s an unscrupulous attempt to hide what brinkmanship is by definition. A threat, or outcome that no one sensible wants is ineffective unless it’s credible. It’s no good blaming anyone for this dreadful state of affairs. If the doctrine of – nothing is agreed until everything is agreed – continues, then this is what will happen.

Also, its foolish to think that this situation will only exist in the UK – EU relationship. It’s most likely to be encountered whenever the UK is negotiating with a larger Country or region. So, if Brexit happens we had better get used to it.

Naturally there’s the potential for errors or misjudgements. History is littered with brinkmanship gone wrong. It always better to have a life jacket than not have one but whether it will be any use or not is quite another matter.

Today, civil aviation is not on the list of how to prepare if the UK leaves the EU with no deal[1].

There are some inferences that can be taken from the notice on “Regulating medicines”. Basically, that’s the UK will continue to apply and accept the application of EU regulations even if there’s no deal. Ideally, the UK would like to remain part of the European Medicines Agency (EMA).

An attempt at humour, and the Bacon Lettuce and Tomato sandwich scenario after Brexit, fell flat. That said, most of the scenarios for no deal Brexit are Bl**dy Ludicrous Threats (BLTs). Better to stop this folly altogether and adopt a more practical, pragmatic and proportionate approach to EU Membership.

[1] https://www.gov.uk/government/collections/how-to-prepare-if-the-uk-leaves-the-eu-with-no-deal

No half-way houses

What do you do in a deeply divided country like ours? They say perception is all. Spend just 5 minutes reading Hard Remain Tweets and then 5 minutes reading Hard Leave Tweets. These two communities will NOT reconcile in anyone’s lifetime. We have Internationalist English and the Nationalist English. They live in different worlds and their beliefs are poles apart. They delight in insulting each other in ever more creative ways. Both believe the other one is sabotaging their dreams. Strong deals, good deals, bad deals, weak deals or no deal, whatever the final deal a large proportion of the English population will object to it even if they haven’t a clue what it means. We all know the status-quo is not tenable but where do we go from here? The traditional “bell curve” of politics is taking a holiday. That’s where once many politicians looked to position themseleves with the central moderate majority.

Let’s be clear that at a time of such troubles we need to get back to fundamentals.

“The first duty of the Government is to afford protection to its citizens.” My interpretation of the word “protection” takes in: safety, security, justice, economic wellbeing, social solidarity and environmental protection.

This is where the two camps are NOT equal. Wherever you are, you do need to pick a side. Appeasement has a poor history in all nations.

A quick look at the Brexiters priorities leave no doubt, in my mind that they are authoritarian and unscrupulous. Here’s a range of thing they want to do: One Party rule. In Parliament, shut down the House of Lords, as they say; no second house needed. More popular referendums to keep politicians on a leash. Returning capital punishment. Pulling up the draw-bridge to all but the wealthy. Privatisation of the BBC, NHS and other public bodies. Wholesale deregulation. Drastic cuts in welfare to let people sink or swim. Making dissent and protest crimes of treason. This list is a sample from Brexiters current on-line discussions.

Public safety, security, justice, economic wellbeing, social solidarity and environmental protection, will all be in jeopardy if they succeed. An outcome that “will be regretted for generations” is on the cards right now.

Let’s be clear the opinion to remain as an EU Member State is no longer the status-quo. The world has moved in the last two-years. A new dynamic exists in Europe as we face the challenges of Trump, Russia, China and the huge tech giants who dominate our lives. Nationalist voices will continue to make noise but that should on a level playing field with moderate voices.

If democratic States are to thrive and ordinary people not lose out, Government and its institutions must listen to their people. There is a growing demand and support for a #PeoplesVote. Let’s have that vote and show that the real deal is the one people want.

Brexit and Aviation 26

On my desk is coaster that says: “30 Years MOR Scheme 1976-2006”. It has the Civil Aviation Authority logo above the words. Now that was worth celebrating. Three decades of Mandatory Occurrence Reporting in civil aviation in the UK[1].

It would be difficult to put a number on the number of potential accidents and incidents prevented by the learning that has flowed from thousands of MORs. Nevertheless, there are certainly people who have been spared the fate of being involved in life threatening events.

1976 was my first year of paid employment. It was a glorious hot summer. In the autumn, I started an apprenticeship with no idea that the path of my career would lead to me working with MORs.

At that time, I was working out how to do engineering drawing and make precision items using machine tools. If remember right, being on a flat roof at Yeovil College experimenting with a solar water heater. Working out how to stop it leaking and pump at the right times.

Not my biggest interest but aviation was around me given the presence of Westland Helicopters in the town. That company had its own apprentice training school. Many of the college apprentices like me worked for small engineering companies that depended on Westland’s.

I recollect this because, at that time, my memories of a fatal aircraft accident were of the one that led to the establishment of the MOR system in the UK. In 1972, British European Airways flight 548 crashed in Staines killing 118 people on board[2]. This was a British aircraft, operated by a British company on British soil. A sad and tragic event. I plan to go to see the Trident memorial window in St Mary’s Church in Staines. The 118 stars in its border represent those who died.

The UK has contributed considerably to shaping the rules that now apply in Europe.

When I arrived in Cologne in 2004, the Directive 2003/42/EC was in place. This wasn’t the strongest piece of legislation and although it required EU Member States to have an MOR system it was weak on getting people to share information. That’s one of the big benefits of such approaches. It’s to learn from others so that you don’t have to experience the same problems.

Now, to give it the full title we have: Regulation (EU) No 376/2014 of the European Parliament and of the Council of 3 April 2014 on the reporting, analysis and follow-up of occurrences in civil aviation, amending Regulation (EU) No 996/2010 of the European Parliament and of the Council and repealing Directive 2003/42/EC of the European Parliament and of the Council and Commission Regulations (EC) No 1321/2007 and (EC) No 1330/2007 Text with EEA relevance.

Yes, that’s a mouthful but the text of the Regulation is invaluable to make a system of collecting and sharing MORs throughout the whole European aviation system. Will the UK continue to participate in this European system post-Brexit? Everyone assumes it will but the answer to the question how is – no one knows.

[1] https://www.caa.co.uk/Our-work/Make-a-report-or-complaint/MOR/Mandatory-occurrence-reporting/

[2] https://aviation-safety.net/database/record.php?id=19720618-0