Brexit and Aviation 39

Accident Recorder

Reading reports of air accidents is not everybody’s cup of tea.  Nevertheless, the insights they contain are a constant reminder that no matter how safe civil aviation maybe, it can always be better.  There’s always something to learn.

This week, US accident investigators issued a report on what could have been an immense catastrophe.  Planes full of passengers came within 60 feet of each other as an Air Canada flight[1] was about to land on a taxiway by mistake.  This happened just before midnight on 7 July 2017 in San Francisco.  The US National Transportation Safety Board (NSTB) said that: “Over 1,000 people were at imminent risk of serious injury or death.”

As people have commented this is a stark reminder of the worst civil aviation accident that ever occurred.  In 1977, 593 people died when two Boeing 747 planes collided on a runway in Tenerife on the Canary Islands.

Because of the San Francisco incident, the NTSB is considering recommending that accident cockpit voice recorders record the last 25 hours of flying time.  The current US rule is for 2 hours and then the recording overwrites.

So, what has this got to do with Brexit?

After a series of accidents in the last decade, including the Malaysian Boeing 777 mysteriously lost over the ocean (flight MH370), Europe acted.  A detailed rulemaking process resulted in a EU Regulation[2] that includes key changes to mandatory accident flight recorder rules.  These required changes to planes that must be made in a practical manner to meet a deadline specified in the EU Regulation[3].  The rule applies to large planes manufactured after 1 January 2021.  Clearly, that date is after Brexit’s infamous 29 March 2019.  I cannot imagine that, whether the UK is in the EU or not, it would make any changes to this planned implementation date.  However, a mandatory action, like this one must be incorporated in the applicable national legislation.  That is how it would be applied to British registered planes.

That’s the interesting point.  Will all those European actions with implementation dates after 29 March 2019 be copied into UK law?  It would be good to see the answer “yes” written down.

POST POST NOTE: I hear the answer is “no”.  Although all the applicable European law will be copied into UK law a mandatory date that is in the future will be edited out.




[2] COMMISSION REGULATION (EU) 2015/2338 of 11 December 2015 amending Regulation (EU) No 965/2012 as regards requirements for flight recorders, underwater locating devices and aircraft tracking systems.


[3] ….with respect to the carriage of CVRs with extended recording duration for large aeroplanes, provision should be made for the introduction of CVR with a recording duration of 25 hours on board aircraft, manufactured after 1 January 2021, with a maximum certificated take-off mass of over 27 000 kg.

Brexit and Aviation 38

Today’s batch of posted Government notices have a weakness that is too obvious to mention.  Piecemeal publications addressing what seem like random subjects on decidedly technical issues are great for the administrators and lawyers of service providers.   However, there’s no easy to understand information for the general public.   It’s good to know what the implications of “No Deal” are for package holidays[1] but little of what is provided will help the average British shopper.  If someone buys a holiday packages from an EU based travel company, they may or may not be protected depending upon whether that company has a UK business.  Try explaining that to someone scanning the INTERNET and comparing travel deals.  Yes, the fine print always matters but if you think you’re dealing with a reputable travel company and the price is right, a Government technical notice may not be high on your mind even if you know it exists.  The national media are making their own reading of the notices and that paints a gloomy picture for spring next year in the UK.  Here’s the view from ITV.

So, my advice is; have a good winter break and don’t book anything for April 2019.  It would be as well to look at the individual airline and travel company too.  Some will be better prepared than others.  Some will have special terms and conditions to cope with potential problems.  Some will still be pretending the change is minor or will go away.

Another of the big Brexit issues that isn’t given much attention is the coincidence of risks.  What I mean by this is that; normal emergency planning is focused on one major event.  A hurricane, a banking crisis, a plane crash are all examples of catastrophes where a Government should have an emergency plan.

The problem with Brexit at 00:00 on 29 March 2019 is that everything will happen at once.  I’m not saying the weather will change, although who knows? but each sector will go through a significant transition at the same time.  Even within each sector, like Aviation, every part of it will have to transition in one moment.  Some parts will be impacted, and others will not.

Trying to anticipate all the combinations and permutations of interdependencies and interconnections that will be impacted is a daunting task.  Because of the limited time and the sheer complexity of the task even a good analysis will miss important connections.

On the political front all we hear is – it’ll be alright on the night.  It may be comforting to think that a smooth and orderly Brexit is possible in ALL scenarios.  However, you would be foolish to be taken in by such an assurance.   Unprecedented disruption is likely in a real “No Deal”.

I’ve got a couple of events in the calendar where Brexit will be a topic.  One is a conference in London called: Negotiating Brexit:  Where Now? Conference[2].

The other is a “Regulatory Changes and Challenges” panel session at MRO Europe[3], taking place in Amsterdam between 16-18 October.







Brexit and Aviation 37

Let’s lift our eyes up from the endless ping-pong at Westminster and look across the globe.

It’s 25C and sunny in Montréal, Canada[1].   It’s one of the best times of the year to visit the city with the kaleidoscope of leaf colours.  In the heart of the city is the mountain site of Mount Royal Park.  Now, it’s a beautiful place to walk and take the air.  Based in that fair city, many of the world’s States have a permanent mission to the International Civil Aviation Organization (ICAO).   The city has a long association with civil aviation.

The 13th Air Navigation Conference[2] has just opened in Montréal.  Almost 1300 delegates from 110 countries and 32 international organisations are meeting at ICAO.

That includes all the European Union (EU) and all its Member States.  At the Air Navigation Conference European Coordination meetings are held.   Europe is presenting: 13 Working Papers and 7 Information Papers[3].  3 of those Working Papers are from the European Aviation Safety Agency (EASA).

Europe is also represented by European Civil Aviation Conference (ECAC), European Organisation for Civil Aviation Equipment (EUROCAE) and European Organisation for the Safety of Air Navigation (EUROCONTROL).   So, you can see that coordination is of the utmost importance.

I see that Kirsten Riensema, a former UK Air Navigation Commissioner was elected Chair of the 13th ANC.  That’s a demanding role.

I was fortunate to be part of the European delegation at the 12th ANC back in 2012[4].   These international conferences advance topics such as; the safety, efficiency, interoperability and capacity air traffic systems for the future.   A united approach is the best one to bring about results.

Today, the UK is a vital part of that European delegation.  It’s unclear where the UK will stand when the 14th ANC comes around.









Y2K was real

Brexit uncovers the stark difference there is in the way people assess risk.  There’s a range of responses to alerts, concerns and warnings.  Legitimate concerns are being raised by respected professional organisations who have a great deal of accumulated experience.  Yet, a large group of people react with a dismissive attitude to these concerns.  Often that that’s the form of simple statements like; we’ve been through all this before, it’s all fear mongering and this wasn’t a problem before 1973.  Brexit concerns are real.

I’ve found one of the most irritating and wrong dismissive statements is about the “Millennium bug[1]”.  It goes something like this: you remember all that fear mongering back in the late 1990s?  Everything was going to stop and grind to a halt, but it didn’t.  It was all a waste of money because nothing happened.  That’s what’s happening now with Brexit.

I admit that standing here in 2018, what happened around 1999 does sound bizarre.  A massive public information campaign altered everyone to the problem that computers of the time had with the practice of representing the year with two digits.  In our INTERNET age none of this makes much sense.  However, this basic design deficiency of the date roll-over at the start of the year 2000 had the potential to cripple 20th Century computer systems.

Risk management is about identifying problems and then putting in place measure to deal with those problems.  It’s all very well to dismiss problems after the event.  In fact, after enormous efforts have been made to overcome those problems.  That simple hindsight view can be downright foolish and dangerous.  It can be to invite catastrophe.

Since, at the time I was working avionic systems at the UK CAA, I can tell you of the real experience of solving the Y2K problem[2].  Yes, it was a real problem with the real potential of crippling aircraft computer systems.  Not every case was critical and not every case was fixed.  A great deal of work was done surveying those aircraft computer systems.  Checking that potential failures were identified and fixed or that the systems were retired.  Processes and procedures were put in place to make sure aircraft continued to fly safely.

The work done was a success.  That success was evident because no lives were lost, no major disruption took place and life continued smoothly after midnight on 31 December 1999.  So, now when I hear people quote this event as an example of fear mongering and it’s immensely irritating.  It’s more than that, it’s downright senseless to walk around with such ideas.

Today, our more complex and interconnected computer systems are threated in different ways.  Cyber attacks are real.  It seems strange to have to say that, but they are real.  Alerts, concerns and warnings should be heeded.  It’s negligent not to prepare.  I’m with the Scouts moto[3].







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.









Brexit and Aviation 35

The UK Government has published a round of aviation Technical Notices, laying out what the UK will do in the event of a “No Deal” Brexit.  No deal means no Withdrawal Agreement.  One thing I can do here is to highlight some of the responses to these “No Deal” papers.

ADS is a trade body for UK Aerospace, Defence, Security and Space companies[1].  They are trying to get the information out to the aviation and aerospace industries.  It really is a case of being prepared.

The airlines organisation, IATA warned on that the Government’s papers on a “No-Deal” exposed the “extreme seriousness” of what is at stake.  The UK would probably leave the European Common Aviation Area.  However, even if something is possible in theory, it doesn’t mean its going to happen.  So, the idea of all aircraft being grounded after Brexit day is more extremely improbable than unlikely.

Some commentators think that UK-EU flights and airport security may stay roughly the same in a “no deal” case, but this relies on the Government forming lots of mini mutual agreements with the EU to ensure continuity[2].  It’s a sort of let’s be good to each other even though we failed one negotiation and let’s do a “no deal” light.

Politically, the aviation papers reveal how much uncertainty remains just six months from Brexit day.  The result they have had not so much to provide guidance and public reassurance but to kick-off a stream of negative stories in the Press[3].

The professional aviation Press is none too complementary about the possibility of a “No Deal” outcome.  The Government papers seems to have confirmed theories that had already done the rounds[4].  Perhaps one is new and that concerns the Part-TCO safety authorisation.  Prior to being an EASA Member State, the UK did not have a Part-TCO regulation.  Now, the papers suggest that a new UK Part-TCO safety authorisation may be established.  No doubt that would be useful to bringing in much needed fees to fund all the new work coming the way of the UK CAA.

Several subjects have had no mention – yet.  Will aviation training schools have to change their workings?  Will cooperation on safety planning, occurrence reporting and accident investigation continue smoothly?  Will air traffic service providers continue to cooperate?

At the global level is likely that both EU and US will not want to change their current agreements.  Thus, the UK will need to fit in and prove that it’s effectively discharging its new responsibilities.  It’s evident that the UK CAA is recruiting staff and they will have much to do.









Brexit and Aviation 34

Another busy day of government publications.  Amongst the many papers to arrive have been the 3 on civil aviation published by the UK Department for Transport (DfT).   These are technical notices that set out plans put in place, in the “unlikely” event that the UK leaves the EU without a deal.  These links are to the technical notices on:

  1. Aviation security if there’s no Brexit deal
  2. Aviation safety if there’s no Brexit deal
  3. Flights to and from the UK if there’s no Brexit deal

Generally, the advice is for the aviation industry to review potential implications for supply chains and staff with specialist qualifications.  The information shows the potential impact of a no deal scenario is extremely high.  There is a wish that, even with no Brexit deal there’s still enough mutual interests to keep all parts of aviation running.

However, for pan-European organisations this senario will be as destructive as an Icelantic volcano.  Estimates of costs rise rapidly for everyday that no deals are implemented, recognised and working.   The impact goes beyond just EU – UK relations because the EU’s existing agreements and working arrangements will no longer apply to the UK.  To get over this the UK is declaring its intention to recognise EU standards of security and safety.   Hopefully this will be enough for other nations aviation authorities to carry on regardless.

The UK CAA has published its own information that covers the subjects in more detail[1].  Some of the questions and answers remain open.  The words: ask EASA, appear numerous times.

What is clear is that the implication of these technical measures is to duplicate activities.  Certificates and licences will need to exit in European form and in UK form.  A period of adaption is contemplated on the UK side, but the outcome will be the need for compliance with new national regulatory requirements.  It’s rather like turning the clock back to a time before the Joint Aviation Authorities (JAA).  There’s no guarantee that there will be mutual recognition even if there may be a common benefit in maintaining a level playing field.

There’s no aviation safety value in duplication.  In fact, there is a potential safety down side.  Given that there’s finite expertise and resources dedicated to safety work spreading those more thinly isn’t going to help anyone.  If there’s divergence in processes and procedures who knows what might fall down the cracks.

It’s worth saying that during all of this change in the UK the internal market for the EU27 will continue to work.  The citizens of the EU27 will continue to benifit from their common system for aviation safety and security.



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.



Deal or No Deal?

These articles are written 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).  Several assumptions are made in this article:

  1. Agreements and arrangements existing prior to 1973 have been superseded, are obsolete and are not applicable;
  2. UK will remain a member of the intergovernmental bodies; like EUROCONTROL and ECAC;
  3. UK will notify ICAO of its change of status in respect of Annexes to the Chicago Convention;
  4. UK will take EU legislation into National legislation via a series of Statutory Instruments;
  5. EU will view UK as a “third country” and
  6. There is a common interest in adhering to international norms.

Today, civil aviation is a shared competence within the EU.  That implies that if there is no specific EU legislation addressing a subject then National regulations prevail.  Therefore, a good starting point is to consider the current directly applicable EU legislation.

In the regulatory spectrum there is a Basic Regulation and a series of implementing Regulations.  Each Part to each implementing Regulation has its own Acceptable Means of Compliance and Guidance Material (AMC/GM).  These considered to be non-binding “soft-law.  Additionally, Certification Specifications (CSs) are also related to the implementing Regulations, like AMC/GM they are non-binding.

These Regulation extend over Airworthiness, Air Operations, Personnel Licensing, Air Navigation Services (ANS), Air Traffic Management (ATM), Rules of the Air, Aerodromes and Accident Investigation.

Recently, the Basic Regulation (EC) No 216/2008 has been repealed and replaced with Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91.

Here’s a list of pertinent EU Regulations with their former references:

Initial Airworthiness (Part 21).

Commission Regulation (EU) No 748/2012 of 03/08/2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisation.

Additional Airworthiness Specifications.

Commission Regulation (EU) 2015/640 of 23/04/2015 on additional airworthiness specifications for a given type of operations and amending Regulation (EU) No 965/2012.

Continuing Airworthiness.

Commission Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these.

Air Crew.

Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament.

Air Operations.

Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

Third Country Operations (TCO).

Commission Regulation (EU) No 452/2014 of 29 April 2014 laying down technical requirements and administrative procedures related to air operations of third country operators pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

Air Navigation Services (ANS) common requirement.

Commission Implementing Regulation (EU) No 1035/2011 of 17 October 2011 laying down common requirements for the provision of air navigation services.

ATM/ANS safety oversight.

Commission Implementing Regulation (EU) No 1034/2011 of 17 October 2011 on safety oversight in air traffic management and air navigation services.

ATCO – Air Traffic Controllers Licensing.

Commission Regulation (EU) 2015/340 of 20 February 2015 laying down technical requirements and administrative procedures relating to air traffic controllers’ licences and certificates pursuant to Regulation (EC) No 216/2008.

Airspace Usage requirements.

Commission Implementing Regulation (EU) No 1332/2011 of 16 December 2011 laying down common airspace usage requirements and operating procedures for airborne collision avoidance.

Standardised European Rules of the Air (SERA)

Commission Implementing Regulation (EU) No 923/2012 of 26/09/2011 laying down the common rules of the air and operational provisions regarding services and procedures in air navigation.


Commission Implementing Regulation (EU) No 139/2014 of 12/02/2014 laying down requirements and administrative procedures related to aerodromes pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

Accident Investigation.

Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC Text with EEA relevance.

Occurrence Reporting.

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.

There’s no doubt that the above list gives an impression of complexity.  That said, a few minutes looking at National legislation immediately gives the same impression.   In civil aviation, not everyone needs to know everything.  Clearly, engineers need to know about airworthiness, pilots and air traffic controllers need to know about licencing and companies need to know about organisation approvals.

Keeping up-to-date requires attention to detail.  At the heart of these Regulations is the international framework provided by the Chicago Convention.  In that respect, the scope for change in the content of these Regulations, even when incorporated in UK legislation, is limited.  Most of the listed Regulations received much input from the UK in their formation.

That is why I have assumed that even in a “no deal” situation the UK will take EU legislation into National legislation via a series of Statutory Instruments.  If this does not happen there is little that can be said about what might happen.   An unstable situation would result since it is not possible to replace all the above aviation regulation with another new set in the time remaining.

Next my articles will address each subject in turn.


Brexit and Aviation 33

Today, I’d like to note a couple of items that shed light on the peculiar predicament of these times.

UK Parliament has an “Exiting the European Union Committee[1]” that is appointed by the House of Commons to examine the expenditure, administration, and policy of the Department for Exiting the European Union and related matters falling within the responsibilities of associated public bodies. That’s a mouthful but it’s a committee that considers the details of the Brexit activities that the UK Government are undertaking.

Today, this committee published a report titled: The progress of the UK’s negotiations on EU withdrawal (June to September 2018), Ninth Report of Session 2017–19, Report, together with formal minutes relating to the report – HC 1554.  Love the Parliamentary language.  It’s not designed as a light bed time read.   As I was scanning the pages for interesting material on aviation I came across the reference to a “BREXIT – Risk Assessment” by AIRBUS from June.  I’d not seen this high-level 2-page document before.  Then came the moment I nearly fell off my chair.  To quote the text:

“Every week of unrecoverable delay would entail material working capital impact, re-allocation cost, cost for inefficient work, penalty payments to customers and up to €1B weekly loss of turnover. Despite the incremental stocks, the disruptions in a no deal Brexit situation are likely to add up to several weeks; potentially translating into a multi-billion impact on Airbus.”

My first though was – that must be a typo.  One billion a week!  Now, I know that AIRBUS has a healthy aircraft order book, but those costs are phenomenal.  Potentially a dreadful waste that no sensible company would put up with for any longer than was necessary.  I believe that would mean the UK losing its position as major civil aerospace manufacturing Country in short order.

The second item that caught my eye was the letter that ADS[2] got having written to the European Commission about the need for technical discussions to take place between the Civil Aviation Authority (CAA) and European Aviation Safety Agency (EASA) to prepare for Brexit.  Basically, the formal answer is that this is on hold.  I don’t find that the least bit reassuring given the time to do something useful is ebbing away.   This regulatory preparation is important for either of the two scenarios – that’s a Withdrawal Agreement is ratified or that “no deal” is agreed before withdrawal date.