Law – Page 8 – John Vincent

Brexit & Aviation 63

43 days left until Brexit, if it happens[1]. As the UK Parliament continues to vacillate so the European Parliament (EP) has decided. Yesterday, in Strasbourg the EP voted through a regulation on Brexit and aviation safety. The European Union (EU) will continue to recognise aviation safety approvals in the UK for at least an interim period in the event of No Deal outcome to Brexit[2].

The withdrawal of the UK from the EU without an agreement affects the validity of certificates and licenses originating from the UK. A regulation proposed in December last[3], has now been debated in the EP. Amendment were adopted by the EP on 13 February 2019 on the proposal for a regulation of the EP and of the Council on certain aspects of aviation safety with regard to the withdrawal of the UK from the EU[4].

These measures give UK based aerospace companies a short time to adapt to a new situation. It gives some grandfather rights to approvals granted before Brexit day.

There will be decisions to be made by companies. To go for a national approval hoping that a set of bilateral deals will be sorted out in the fullness of time. To go for a European approval as a “third country” or by move business to an EU Member State. Or, in fact combinations of these possibilities.

Dither in the UK. Speedy implementation in the EU. Draw whatever conclusion you like.

[1] https://howmanydaystill.com/its/brexit-6

[2] https://www.adsgroup.org.uk/blog/eu-aviation-safety-regulation-for-a-no-deal-brexit/

[3] http://www.europarl.europa.eu/RegData/docs_autres_institutions/commission_europeenne/com/2018/0894/COM_COM(2018)0894_EN.pdf

[4] http://www.europarl.europa.eu/sides/getDoc.do?type=TA&language=EN&reference=P8-TA-2019-0107

Brexit & Aviation 53

Thanks to the entry into force of Regulation (EU) No 996/2010 on the investigation and prevention of accidents and incidents in civil aviation, there’s a European Network of Civil Aviation Safety Investigation Authorities (ENCASIA). This coordination group came together in early 2011, while I was at EASA at the receiving end of their Safety Recommendations.

There’s 90 days left until the Brexit countdown runs out on 29th March 2019[1]. Even in a so called “No Deal” Brexit, there’s a proposal for an EU Regulation to extend temporarily (for 9 months) the validity of certain aviation safety licences. But as far as I can see there’s nothing proposed in relation to Regulation (EU) No 996/2010.

ENCASIA works on improving the quality of air safety investigations and strengthening the independence of the national investigating authorities. In the past, there’s often been conflicts between judicial authorities and those tasked with independent technical investigations.

Safety investigation authorities vary greatly in size and experience across Europe. Two of the largest are the Bureau d’Enquêtes et d’Analyses pour la Sécurité de l’Aviation Civile[2] in France and the Air Accidents Investigation Branch in the UK[3].

Can we assume that Brexit of no Brexit these important aviation safety organisations will continue to work together? Let’s hope so. It’s essential that safety concerns that are Europe wide are addressed across Europe.

[1] https://interactive.news.sky.com/2017/brexit-countdown/

[2] https://www.bea.aero/no_cache/en/

[3] https://www.gov.uk/government/organisations/air-accidents-investigation-branch

Brexit and Aviation 46

It’s reported that, International Airlines Group (IAG), the owner of British Airways (BA), has approached the Spanish Government for help over the possibility of a No-Deal Brexit. They still seem confident that the EU and the UK will put an agreement in place that allows flights to continue even in a No Deal situation. That said, current rules mean the company must be over half EU owned and controlled to be considered “European”.

Today, IAG is the parent company of Aer Lingus, BA, Iberia and Vueling. It’s a Spanish registered company with shares traded on the London Stock Exchange and Spanish Stock Exchanges. Today, the corporate Head Quarters for IAG is in the UK. In Brexit and Aviation 23, I raised these issues but considering the airlines operating certificates rather than the ownership issue. If IAG are to comply with the EU ownership rules then, essentially it becomes a Spanish company. Now, I wonder if the UK Brexiters had that in mind in 2016?

Ownership arrangements do get complicated. For example, 25% of London Heathrow airport is owned by Ferrovial, S.A., a Spanish multinational company. London Gatwick airport is owned and managed by Global Infrastructure Partners (GIP) and a consortium of its co-investors. So, I’m guessing that Brexiters don’t concern themselves too much with ownership and control. It’s just not on their radar.

This is not a subject to ignore because despite liberalisation there are precise rules on ownership and control within EU legislation. These are important in the EU but not so much as a matter of regional protectionism as to ensure that there’s a level playing field for fair competition between companies.

Last week, the European Air Law Association (EALA) held their annual conference in Brussels. The EALA was created 30 years ago when the supranational European institutions, including the European Commission and the European Parliament, started to take policy and legal action in the field of air transport.

This year, their guest speaker was Director-General for Mobility and Transport, DG MOVE, Mr Henrik Hololei. He confirmed that in respect of Brexit, that no detailed negotiations had taken place between the EU and the UK on air services and they will not occur until there is an agreement on the Withdrawal Arrangements. Hololei noted that in the most extreme No Deal scenario, on the first day of Brexit there would be no flights between EU and UK. This is a possibility depending on how the negotiations proceed.

In the No Deal circumstances, the UK Government maybe confident that it would be able to negotiate new, or reinstate old bilateral agreements with EU Member States. The first of these might be possible, with good will on all sides but the second is just not possible.

The critical date of 29 March 2019 is approaching fast. Jo Johnson has resigned as a Transport Minister, saying the country is: “barrelling towards an incoherent Brexit” and calling for another referendum. Crunch time is here.

Brexit and Aviation 39

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.

[1] https://www.ctvnews.ca/mobile/canada/air-canada-close-call-came-a-few-feet-from-possibly-being-worst-aviation-accident-in-history-1.4131146

[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.

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:

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

Aerodromes.

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.

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

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

Brexit & Aviation 25

Changing perspectives on Brexit, I’ll consider it more from the point of view of being an air passenger. I’ve written about aviation’s regulatory framework and the impacts on industry, but I fly too. So, what’s likely to change with the passing of March 2019?

Today’s UK News is about the UK-based airline Virgin Atlantic and their story on ques at London Heathrow airport[1]. On 6^th July, non-EU visitors had to wait for up to 2 hours and 36 minutes at Heathrow. That’s a lot to add to the end of a long-haul flight. Brits may be accustomed to queuing, but it annoys and frustrates most people.

I’m lucky. I have a shiny new British passport with the words “European Union” on the front cover. As a British passenger, I can use the electronic passport gates which currently are open to EU passengers.

Currently Europe’s busiest airport, that’s the EU’s busiest airport isn’t offering good services to non-EU visitors. Will this change after March next year? Or will EU passengers get more hassle than they do now? There’s media speculation about a Brits only immigration line at airports but what could that possibly mean in reality? No one knows.

Regulation (EC) No 261/2004[2] isn’t liked much by the aviation industry but passengers have been happy to see this legislation enacted. Now, will an Air Transport deal between the EU and UK include consumer rights such as flight delay compensation? Even if the intent of this Regulation is copied into UK law it wouldn’t be much good applied to non-UK airlines. I understand that Switzerland participates in 261/2004. So, it should be possible for a post-Brexit UK to participate in the legislation. This needs to happen otherwise British passengers delayed by EU airlines will not be appropriately compensated. A notice to this effect has been published.

When traveling we like to keep in touch with family, friends and colleagues. Today we get mobile phone roaming in the EU at domestic prices. This requires continued regulation of prices by UK and EU networks. Will this end? No one knows.

The UK Government continues to say: “Our focus is making a success of Brexit and attempting to get the best deal possible. A deal that is in the interests of both the United Kingdom and the European Union. And one that takes in both economic and security cooperation.”

Flying to and from the UK may change after March 2019. Unless the above issues are fully addressed the experience maybe a lot worse than it is today. So, be prepared.

[1] https://uk.reuters.com/article/uk-britain-airports-virgin-atlantic/heathrow-airport-passport-queues-reached-two-and-a-half-hours-in-july-data-idUKKBN1KY0PC

[2] Regulation (EC) No 261/2004 of the European Parliament and of the Council of 11 February 2004 establishing common rules on compensation and assistance to passengers in the event of denied boarding and of cancellation or long delay of flights……………………….

Brexit & Aviation 24

Like it or not, the holiday season will end. Facts are incontrovertible. The UK and EU have just a few months to finish a Withdrawal Agreement. This is to allow for scrutiny and ratification in both the UK and the EU’s 27 Member States. A Withdrawal Agreement must be signed in October and that’s just days away.

Let’s look at one more civil aviation issue. The continuing airworthiness of a civil aircraft is dependent on the exchange of information between authorities and organisations across the globe. This is flow of information is practically improved if working arrangements or bilateral agreements exist between Countries. These are built on mutual interest, trust and a long-established familiarity with each other’s regulatory systems.

Yes, the duties of Countries under their obligations as signatories of the Convention on International Civil Aviation, dated 7th December 1944 (known as the “Chicago Convention”) exist but these are the basics and even then, those basics are often given scant regard.

In the 1970s, some European civil aviation authorities started to co-operate to produce common “Joint Airworthiness Requirements.” Even before the 1990 Cyprus arrangement[1] in Europe, both the US and European authorities had been working to harmonise rules and reduce duplication of regulatory activities.

Today, a mature EU-US bilateral is in place. So, if a British manufacture wishes to export an aviation product to the US it can do so with relative ease. As per Subpart G 21.A.163 of Commission Regulation 748/2012, the holder of a production organisation approval may issue authorised release certificates (EASA Form 1) without further showing. That EASA Form 1 is then recognised in the US.

The Treaty’s Article 50 clock stops at the end of March 2019. It’s reasonable to ask the question; what Authorised Release Certificate will be used in the UK after that date and will it be recognised?

Anyone know?

All the loud yah-boo politics, so loved of Westminster, doesn’t offer an answer.

NOTE 1: The EASA Authorised Release Certificate is known as the EASA Form 1.

NOTE 2: The FAA Authorised Release Certificate is known as the FAA Form 8130 -3, Airworthiness Approval Tag^[2]^.

[1] ARRANGEMENTS CONCERNING THE DEVELOPMENT, THE ACCEPTANCE AND THE IMPLEMENTATION OF JOINT AVIATION REQUIREMENTS

[2] Reference: FAA Order 8130.21H—Published August 1, 2013, Effective February 1, 2014.

Brexit & Aviation 23

Hearing hard core Brexiters herald statements from IAG S.A.[1] about working though Brexit is strange to say the least. By the way, if you’ve never heard of them the International Airlines Group was created in 2011, is one of the world’s largest airline groups and includes British Airways. It’s a Spanish registered company with shares traded on the London and Spanish Stock Exchanges. IAG operational headquarters is in London.

At the point of the 2016 UK referendum IAG shares took a hit. Ever since then there has been a consistent recovery in their position. Brexit, or no Brexit they are well placed on both sides of the fence. Today, their airlines have Air Operator Certificates (AOCs)[2] in the EU. After the end of March next year its likely those AOCs will remain unchanged. The basis for their UK operators validity will shift from European Regulation to National Legislation.

Despite the high level of integration of the European aviation market place there is no single European registry of aircraft. Each ICAO Contracting State has its own aircraft registry.

However, to fly into the EU all non-EU aeroplane operators must have a Third Country Operators (TCO) authorisation[3]. This is a way of ensuring that non-EU aeroplane operators are compliant with all applicable technical standards of the Annexes to the Chicago Convention.

In the EU the authorities undertake ramp inspections of aeroplanes in operation.

Naturally, after the end of March next year aeroplane operators who transition from being EU operators to non-EU aeroplane operators will need a TCO authorisation. In theory, this should be an administrative matter since the transitioning operators already meet the applicable standards.

The TCO authorisation process can require that an audit be performed at the operational premises of the aeroplane operator. This is one of the tasks undertaken by the European Agency EASA.

It’s worth noting that the TCO only considers the safety-related part of foreign operator assessment, whereas operating permits (commercial traffic rights) are issued by individual EU Member States. In many Brexit articles these often a confusion between safety related rules and commercial related rules. It’s generally the case that operating permits are not granted unless the TCO is in place first.

So, far from the Brexiters cries of: “take back control” the result of all this is that our interdependence across Europe changes but remains. And for very good reasons too.

[1] https://www.londonstockexchange.com/exchange/prices-and-markets/stocks/summary/company-summary/ES0177542018GBGBXSET1.html

[2] https://www.skybrary.aero/index.php/Air_Operator_Certificate_(AOC)

[3] Commission Regulation (EU) No 452/2014 (the ‘TCO Regulation’)