Still work in progress

Has it really been 100 days since the final, final, final Brexit day? 

The UK left the European Union (EU) on 31 January 2020.  A Withdrawal Agreement (WA) that the UK Government agreed with the EU, established a transition period that came to an end the day this year started.  Now, a new EU-UK Trade and Cooperation Agreement (TCA) has been in force for 97 days. So, it’s not a bad time to have a go at writing a 100-day review.  It’s often a period of reflection that is used to assess a newly elected politician.  It gives an indication of the direction of travel. 

Last year, although it was a top priority of UK industry to stay in, the UK has left the European Union Aviation Safety Agency (EASA) based in Cologne.  So, there’s no official UK participation in the EASA activities by right and the UK is treated as any other 3rd Country.  EU law no longer applies to the UK. Much of what was previously applied has been swept up in new UK Legislation[1]

Regulation-wise, to figure out where we are now, it’s necessary to combine the officially published corresponding text of UK Legislation and EU Commission Regulations with the EASA Acceptable Means of Compliance and Guidance Material, including amendments.  Some smart people have done this work, but the challenge will be keeping the whole paperwork construction up to date. 

Informed commentators have often said that a Bilateral Aviation Safety Agreement (BASA) and a Comprehensive Air Transport Agreement (CATA) are needed between the EU and UK.  To some extent the TCA starts the ball rolling by calling for the establishment of a number of committees. 

On the basis that there’s far to much still in flux to discuss, I’ll bite off one key aviation related subject. 

Despite the massive impact of the COVID pandemic on international civil aviation there remains a demand for qualified engineers.  In many ways their roles as Airworthiness Inspectors or Licenced Aircraft Maintenance Engineers have become even more important than ever. Traditionally, there’s no doubt that the UK has been good at training aircraft engineering personnel. Students from all over the world have gained their licences in the UK.  It’s one of the most demanding professions in the world but their dedication to the highest standards keeps flying safe. 

Whilst the UK was a member of the EASA system a licence granted in the UK by an approved organisation was recognised throughout the EASA Member States and beyond.  One of the powerful arguments for continued participation in EASA was the avoidance of the duplication of approvals, certification, and licencing. Each duplication comes with a fee and time consuming paperwork.

The political decisions having been made and that’s exactly what we now have in place. Duplication. In fact, it’s worse than that because there’s asymmetry in the current situation. 

The UK CAA advises Part 66 licence holders to take action to minimise impact on their privileges.  There are several combinations and permutations that can be considered.  There’s a useful updated section of information for licensed engineers on the UK CAA website[2]

Engineers who continue to release EU-registered aircraft to service outside the UK will need to transfer their licence to the National Aviation Authority (NAA) of an EASA Member State. If an engineer works outside the EU and UK, on EU-registered aircraft, a UK Part-66 licence will no longer be valid. 

If an engineer has a non-UK Part-66 licence they will be able to continue to work on UK-registered aircraft for up to two years after the end of the transition period, unless your licence changes or expires (whichever occurs soonest).

There’s also an exemption for engineers who hold a EU Member State issued EASA Part-66 licence who only received
or changed their EASA licence after the departure of the UK from the EU.

All of this is high politics because a Part 66 licence, UK or EU is granted on the same technical basis. Yes, there’s potential of regulatory divergence or new ways of doing business in future. However, it’s difficult to understand what the justification for any divergence might be but the possibility exists.  And as avid Brexit supporters like to point out the UK is no longer subject to EU legislation.  That has no impact of the UK’s need to meet its international obligations. Both UK and EU need to be complient with the ICAO Convention.

There’s much work in progress. Now, is a moment when it all looks like a kitten as been playing with a large ball of wool that has rolled down a staircase.


[1] https://info.caa.co.uk/uk-regulations/

[2]https://info.caa.co.uk/uk-eu-transition/licensed-engineers/

Flight, Risk & Reflections 16.

Worldwide COVID-19 deaths have now topped 1.9 million[1].  Uncertainty continues to cripple civil aviation. The lack of joined-up working across the globe is disappointing to say the least.  Different actions and support package of varying degrees are confusing and inconsistent. Many self-inflicted obstacles have led to aircraft operators burning up cash at an alarming rate. No one denies that the spread of COVID-19 is one of the biggest challenges to face all types of transport systems, but governments have created as many problems as they have solved.  Serious concerns about new variants of COVID-19 are leading to additional travel restrictions[2].

Cargo operators and airports are stepping up to distribute the vaccines for COVID-19. Aviation will continue to play a vital role in that distribution[3].

The UK has now left the European Union (EU), and the transitional period has expired.  The UK Government will be publishing UK aviation law (including retained EU law) on the website www.legislation.gov.uk in due course. The new deal that has been struck has several appendixes but overall, it’s quite thin.

EU aviation regulations (hard law) are often accompanied by Acceptable Means of Compliance (AMC), Guidance Material (GM), Certification Specifications (CS) and other technical information (soft law). For the time being the versions of AMC, GM, CSs and other technical information in force on 31 December 2020, remain policy in the UK.  In time one would expect to see a British aviation publication system that maintains these as new national documents. 

Now, the prospect of divergence means that readers should check both national and EU sources to get a full picture of the relevant material for civil aviation in the European region.  At this moment there are no administrative procedures for the harmonisation of technical requirements between the UK and EU.  Fortunately, both parties start from a harmonised position. How long that will last is anyones guess.

The EU-UK Trade and Cooperation Agreement announced on 24 December 2020 (TCA) is one hell of a lot better than the often threatened No-Deal outcome between the parties. However, it’s a long way from the comprehensive aviation and air transport agreement that industry and informed commentators, and indeed the EU-UK Political Declaration said was needed.  The TCA foresees cooperation between the EU and UK, but a lot remains to be done. There’s a great deal of committee work to come. It’s important to continue to stay alert for regulatory changes that are to come.


[1] From Johns Hopkins University

[2] https://www.oag.com/coronavirus-airline-schedules-data

[3] https://twitter.com/A4Europe/status/1346842821064589314?s=20

Flight, Risk & Reflections 15.

A large full moon graced the December sky early this morning. The local park was a picture of frosty ground, joggers and dog walkers, magpies and one or two wrens hopping around as the sun rose.  I looked up and slithers of cloud gave a reddish hew to the eastern sky. I remembered the farmer’s rhyme: Red in the morning, shepherds warning. Also, clear to me was the absence of aircraft streaking across the cold sky.  I’m located only a few miles north of London Gatwick airport.  Last December the same scene would have included aircraft contrails going left and right as morning flights arrived and departed London. 2020 is a year like no other.  In this pandemic year worldwide, deaths now approach 1.8 million. 

The UK left the European Union (EU) on 31 January 2020.  A Withdrawal Agreement that the UK Government agreed with the EU established a transition period that comes to an end in a couple of days.  I think many people are mighty relieved that the UK and EU reached an agreement in principle on Thursday 24 December 2020. This is about as last minute as it was possible to be in the long negotiations. 

All being well, a new agreement between the EU and UK should start from New Year’s Day, 1 January 2021.  This EU-UK Trade and Cooperation Agreement includes obligations on both parties for air transport and aviation safety. Again, many people will be mighty relieved that these topics are addressed.  In all I’ve written in this blog there’s been much speculation about the road ahead. Now, for the first time in four and a half years we have some indication of what comes next.  Like any long story, it’s not all good and its not all bad. 

There are implications for all aspects of European aviation.  In air transport, UK aircraft operators will not have the freedoms of the past. They may need to restructure to be able to offer comprehensive services to the destinations currently flown. Low-cost operator Ryanair is implementing voting restrictions on company shares owned by non-EU nationals from New Year.

It’s good to see the emphasis on cooperation[1] on aviation safety.  New dedicated committees will look at how to work together in the future.  I hope they work at a technical level and renew cooperation rather than further politicising inter-institutional relationships.  Regulatory duplication and barriers need to be avoided.  Now, practical processes and procedures must make good on the promise of close cooperation. The need to ensure implementation of aviation safety rules and regulations has not diminished.

It’s interesting to note that each party to the agreement may request consultations at any time concerning the safety standards maintained and administered by the other party in areas relating to aeronautical facilities, flight crew, aircraft and the operation of aircraft.  This suggests conditions for dealing with the immediate outcome of aircraft accidents and serious incidents but it’s not explicit.  As I found in the early days of the European Aviation Safety Agency (EASA), from 2004 a lot depends on how the relevant legal texts are interpreted. One small sentence can mean much if the parties choose to make it so.  A deal maybe agreed but this is not done. This is the start of work that can build a successful aviation system.  With good will on both sides this can happen, but it will take a decade of effort. 


[1]The Trade and Cooperation Agreement establishes the following Specialised Committees:……

(b) The Specialised Committee on Air Transport;

(c) The Specialised Committee on Aviation Safety;

Flight, Risk & Reflections 14.

The end of the transitional period of the process of UK withdrawal from the European Union (EU) is just days away. I believe most people are looking for some light at the end of the tunnel. A tunnel that we have been in since mid-2016. Now, that light looks dim. Dim as a dull cold winter’s day.     

The EU has triggered Brexit No-Deal contingency plans[1].  These plans are to ensure basic services between the UK and the EU for 6 months in 2021. Then it’s anybody’s guess what will happen.

Flying is down to levels last seen in the 1970s. This maybe joy for those who protest at aviation’s environmental footprint. But, given that aviation will be vital to power the world out of the economic crisis brought on by the COVID-19 virus, this is not good news. 

Said it before but I’ll say it again, the triple blow of a Brexit No-Deal and COVID-19 and urgent need for action on Climate Change are going to mean hair shirts years ahead. There’s a great deal of bluff from politicians but the bills keep mounting up. We cannot ignore the oncoming trains. 

Worldwide COVID-19 deaths have now topped 1.6 million[2]

In this crisis, there’s no doubt that the UK has a superbly capable science community. Within that specialist community there are world renowned experts[3]. They work in a global context.  So, the persistent echo of nationalism in politicians COVID-19 response is saddening.  Recently politicians have spoken as if the task of public safety regulation was a competition.  This is sheer folly. It undermines trust.  Ensuring either vaccines or transport systems are safe is NOT a matter for national competition.  We all have vulnerabilities and safety is only assured when we are all safe. 

The triple whammy means the UK aerospace industry is under pressure and needs strategic support from the UK Government to sustain its high value jobs. So far, a deaf ear is all they offer businesses that create prosperity across the country. 

Also, on the horizon is that the UK will be under pressure to scrap European tariffs applied to Boeing imports imposed as a result of the international dispute between Boeing and AIRBUS. The subsidy dispute was between the EU and US and so lawyers are saying the UK should step aside. Sadly, this is the sort of situation that will make Europeans seriously question future aerospace investments in the UK. 


[1] https://www.consilium.europa.eu/en/press/press-releases/2020/12/16/council-endorses-transport-contingency-measures-in-case-of-no-deal-brexit/#

[2] https://www.statnews.com/feature/coronavirus/covid-19-tracker/?utm_campaign=cv_landing

[3] https://www.bbc.co.uk/iplayer/episode/m000qdzd/panorama-the-race-for-a-vaccine

Flight, Risk & Reflections 13.

Last night, chatting about presentations and simple ways of making them better, I was reminded of: Ethos, Pathos, and Logos.  It’s ancient advice about how to persuade an audience of a point of view. The importance is to see a place for all three in a presentation. 

Looking at the day’s news, I see we are still on the brink of a deal. Negotiations drag on and on. Both EU and UK give the impression that they are stretching their negotiating mandates to try to come up with a good solution but time is ticking.

Outside of the negotiating room there remains the task of convincing different audiences that a deal is a good one. So, what of the classical three. In the UK, the media and politicians revel in Pathos. It’s almost as if the other two are consigned to be back seat drivers. For Ethos and Logos, objectivity is a must. Being honest means being factual. Arguing rationally means applying the facts.

Unfortunately, there are only a handful of places to go for that objectivity in the British media. So, it does make a difference to read the foreign media.  For some common sense, I recommend the thoughts of Julian King[1], the UK’s last European commissioner.  I agree that everybody stands to lose out with No-Deal.

This week we carry on with a multitude of unknowns. Only one thing is for sure. Life after 31st December will be different[2]

I do wish press articles would not say: “Otherwise, the U.K would have to strike individual agreements with EU countries to bypass these concerns, ……” Striking individual agreements with non-EU countries is what is happening. Striking individual agreements with EU countries will not happen. The reason for this is that for the major areas of interest the EU has competence[3].

It’s worth noting that the harmonisation of civil aviation requirements and procedures started a long time before the formation of European Union Aviation Safety Agency (EASA).


[1] https://www.irishtimes.com/opinion/brexit-the-uk-and-eu-both-need-to-put-aside-emotion-and-cut-a-deal-1.4425580

[2] https://www.politico.eu/article/5-things-to-know-about-post-brexit-aviation-airlines-eu-transition-cargo-travel-passengers/

[3] https://europa.eu/european-union/topics/transport_en

Flight, Risk & Reflections 8.

2-years ago I wrote: “Early in the year, prudently the EU published a series of notices concerning the “No Deal” outcome.  These were stark and based upon the UK becoming a “Third Country” with a blank sheet of paper in front of it.  That’s a Country with no special arrangements with the EU.” It seems that they (EU) were very prudent

That said, let’s be optimistic. News reports are that the UK and EU have transitioned into an intensive phase of negotiations with the aim of getting a much-cherished Free Trade Agreement (FTA)[1].  Here we are coming up to the last week of October 2020. 

Although the outcome remains unclear the wisdom of being prepared for the end of the Transition Period is unquestionable[2]. Aviation has been trying to get to grips with the ups and downs of Brexit for 4-years, but this is the real crunch time. 

As I’ve commented before, the departure of the UK from the European Union Aviation Safety Agency (EASA) was unexpected only a year ago but it’s going to happen on 1 January 2021. This will mean more “red tape” and regulatory costs for UK industry, but the UK Government is unmoved in its position. 

For aircraft design, UK based Design approval holders need to apply to the UK Civil Aviation Authority (CAA) for a UK Design Organisation Approval (DOA)[3]. The UK CAA will continue to apply the European rules as set out in Regulation EU No 748/2012 that determines the rules for the certification of design organisations. Part-21 subpart J of this Regulation concerns the Design of aircraft or the associated components.

For aircraft production, UK based production approval holders are advised to apply for an EASA Third Country Production Organisation Approval (POA)[4]. The same is true for those maintenance organisations who want to work on European Member State registered aircraft.  This is an administrative procedure within EASA and so certificates will only be issued to UK organisations, all being well, after the transition period has expired. 

A lot will depend on what’s in any EU-UK aviation agreements as to any mutual acceptance or recognition of approvals.  Now, no one is able to predict the outcome of negotiations. We all must rely on statements from the UK Government and EU Commission on the latest progress of negotiations. 

To me this is a mighty strange state of affairs. If I reflect on the detailed and thoughtful groundwork done for the creation of EASA back in 2002-3, it’s as if a everything has been thrown to the four winds.  


[1] https://www.bloomberg.com/news/articles/2020-10-25/brexit-talks-extended-to-oct-28-as-u-k-indicates-optimism

[2] https://www.adsgroup.org.uk/blog/prepare-for-the-end-of-the-transition-period-with-our-brexit-webinars/

[3] https://www.caa.co.uk/Commercial-industry/Aircraft/Airworthiness/Organisation-and-maintenance-programme-approvals/EASA-Part-21/Apply-for-a-Part-21-Subpart-J-approval/

[4] https://www.easa.europa.eu/brexit-early-applications#others

Flight, Risk & Reflections 4.

It’s under 100 days to go to the final, final, final Brexit exit. This Autumn flying faces the quadruple threats of rising Coronavirus numbers, diminishing Government support, implementation of erratic polices and the possibility of a disorderly end to the EU-UK Withdrawal Agreement transition period. The shining light is that everyone knew that this was coming, and adding up all the turmoil of the last 4-years it has at least given industry and institutions time to come to terms with the situation and prepare accordingly.  Yes, there are a bucket load of unknowns. 

On the plus side as soon as we get past 1 January 2021 there will be less constraints for either party. The European Union (EU) will be able to go ahead with actions once blocked by the UK. Vice-versa the UK will be able to develop its own unique set of policies, rules and regulations. 

If both parties don’t lose their basic common sense there ought to be a good degree of continuing communication, collaboration and cooperation.

I agree with the AIRBUS CEO: “Aviation, an irreplaceable force for good in the world, is today at risk as borders remain closed and influential voices in Europe call for permanent curbs on flying.”

Recently the British Business General Aviation Association (BBGA) hosted a webinar [1]dedicated to all matters Brexit. Good of them to make it available on-line to non-members.

In addition, there’s a “Readiness for Brexit[2]” update from Tim Johnson, Strategy and Policy Director UK CAA now on-line. This is about the CAA’s readiness for what’s going to happen at the end of the transition period.  There’s a promise of continuity, at least for a while[3].

It saddens me greatly that the UK will no longer be part of the EU Aviation Safety Agency (EASA) system but that’s now a matter of fact. Who knows what the future may bring? It’s perfectly possible that the UK will be back in the system in the next decade.

There’s a lot of reasons why it’s going to be difficult for the UK to act entirely alone. For efficient and sustainable air traffic management the European Single European Sky (SES) project will continue to advance. It would be better for all if the UK was part of that advancement.

We need to concentrate on dealing with the present situation and maximising positive working with Europe. There are many areas of common interest. We remain a great European Country.


[1] https://www.avm-mag.com/bbga-to-conduct-brexit-info-webinar/

[2] https://www.caa.co.uk/Blog-Posts/Readiness-for-Brexit/

[3] https://publicapps.caa.co.uk/docs/33/UK%20Safety%20Regulation%20outside%20EASA%20(CAP1911)%20SEP%202020.pdf

Brexit, Aviation and the Withdrawal 11

IMG_0696Spring is beckoning.  The phoney war will have to come to an end soon.  EU-UK negotiations are set to start in the week of 2 March 2020.  There’s every good chance a close and ambitious partnership between the EU and UK can be built.

On civil aviation the UK is seeking an agreement that should: “consider arrangements typically included in EU bilateral aviation agreements”.  This is written as if the Europe has no history of deep and detailed cooperation that has been built over decades.  It’s difficult to image a blank sheet of paper in front of the negotiating teams.

On airspace use, the EU is saying that the UK should have less access to EU airspace but may have more than other third countries, if it applies by specific rules[1].  This does have the potential to take on board the interest of travellers on both sides of the divide.

On safety, the UK is a calling for a Bilateral Aviation Safety Agreement (BASA)[2].  No prospective ambition to remain part of the EU’s Agency, EASA is mentioned.

For the above there’s a paragraph heading titled “Appropriate governance arrangements” but no indication as to what they might be.  With the existing EU-US BASA[3] there’s a Bilateral Oversight Board (BOB) that is responsible for ensuring the effective functioning of the BASA.

I remember supporting that activity.  It does tend to be conducted at a high level with the respective partners.  Then detailed work is delegated to more technical activities under the watchful eye of the BOB.  Now, that kind of working arrangement does not preclude UK Civil Aviation Authority (CAA) technical staff participating in EASA working groups or vice versa.

An EU-UK BASA maybe a new bespoke agreement but it is a distinct break with the past of cooperation.  Europe enacted a process of working together before the time of EU competence in this area.  It was on 11 September 1990, with the signing of the “Arrangements concerning the Development, the Acceptance and the Implementation of Joint Aviation Requirements” (Cyprus Arrangements), by 24 States that the Joint Aviation Authorities (JAA) came formally into being.

A BASA does weaken existing international ties because at its core is the preservation of regulatory control above and beyond joint working.   No longer is the arrangement captured in the phrase “Unus pro omnibus, omnes pro uno”[4].

I’m sure, the EU will respect British sovereignty, and Britain will respect EU Member States sovereignty.  Nice to say but such statements say nothing about common interests of which there are many in aviation.  We don’t yet know to what extent either the EU or the UK will be willing to compromise as a result of detailed negotiations, maybe long into the night.  By the middle of this year a clearer picture will emerge.

[1] https://www.instituteforgovernment.org.uk/explainers/future-relationship-uk-eu-mandates

[2] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/868874/The_Future_Relationship_with_the_EU.pdf

[3] https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:JOL_2011_291_R_0001_01&from=EN

[4] Latin phrase that means “One for all, all for one” in English.

Brexit, Aviation and the Withdrawal 7

imgid153119926One of the popular illusions that Brexit supporters carried off during the campaigning of the last few years was to persuade people that the European Union (EU) was atypically bureaucratic.  A false comparison often suggested that the UK should be more like the US and therefore less bureaucratic.  This nonsense did seem to get into the public consciousness.  Tabloid newspapers peddled the mirage of complete free trade.  Even though it’s, as I say, complete and utter nonsense.

Just a few second of reading the US Federal Register[1], as I often did in my past roles, quickly shows the complexity of the legal and regulatory processes and structures in the US.  Docket No. USTR–2019–0003 a “Review of Action: Enforcement of U.S. WTO Rights in Large Civil Aircraft Dispute” doesn’t make pleasant reading for the EU or the UK[2].   In fact, there’s nothing to choose between how hard these measures hit EU Member States or the UK.  Brexit doesn’t exist in this dispute.

The outcome of the review is that there will be an increase in the additional duty rate imposed on aircraft and parts imported from the EU and UK, effective from Wednesday, 18 March 2020.  Rightly, the UK’s International Trade Secretary has expressed concern and disappointment[3].   It’s interesting to speculate what this will do to future trade negotiations.  This isn’t the zero-tariff world that Brexit supporters promised.  In the real world, President Trump’s tariffs are popular amongst his supporter base and it’s an election year in the US.

European manufactures are also concerned and disappointed[4].  The sad aspect of this escalation is retaliation and that it’s likely that the EU will impose tariffs on new large US aircraft later in the year.

My view is that, imposing tariffs on aircraft parts is in no one’s interest and harmful to not just the commercial health of the aviation industry but flight safety and security too.

By the way, on a lighter note US fedearal administrative language is a gem: For purposes of the subheading listed below, the informal product description defines and limits the scope of the proposed action and is intended to cover only a subsection of the subheading.

[1]https://ustr.gov/sites/default/files/enforcement/301Investigations/Review_of_Action_Enforcement_of_U.S._WTO_Rights_in_Large_Civil_Aircraft_Dispute.pdf

[2] https://www.latimes.com/business/story/2020-02-14/trump-tariffs-europe-aircraft

[3] https://www.gov.uk/government/news/update-on-airbus-dispute?utm_source=1e391616-b697-49ed-bb9a-bc178465499b&utm_medium=email&utm_campaign=govuk-notifications&utm_content=immediate

[4] https://www.airbus.com/newsroom/press-releases/en/2020/02/airbus-statement-on-ustr-decision–15-feb-2020.html

Brexit, Aviation and the Withdrawal 2

Watching UK Prime Minister Johnson’s speech[1], 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[2].   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[3].  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.

[1] https://twitter.com/10DowningStreet/status/1224435858985472000?s=20

[2] https://ornc.org/our-story/royal-hospital/painted-hall/

[3] https://www.easa.europa.eu/document-library/bilateral-agreements/eu-canada