UKCAA – John Vincent

To provoke

Social media provocateurs are on the rise. Say something that’s a bit on the edge and wait for the avalanche of responses. It’s a way of getting traffic to a site. The scientific and technical sphere has these digital provocateurs less than the glossy magazine brigade, but the phenomena is growing.

Take a method or technique that is commonly used, challenge people to say why it’s good while branding it rubbish. It’s not a bad way to get clicks. This approach to the on-line world stimulates several typical responses.

One: Jump on-board. I agree the method is rubbish. Two: I’m a believer. You’re wrong and here’s why. Three: So, what? I’m going to argue for the sake of arguing. Four: Classical fence sitting. On the one hand you maybe right on the other hand you may be wrong.

Here’s one I saw recently about safety management[1]. You know those five-by-five risk matrices we use – they’re rubbish. They are subjective and unscientific. They give consultants the opportunity to escalate risks to make new work or they give managers the opportunity to deescalate risk to avoid doing more work. Now, that’s not a bad provocation.

If the author starts by alleging all consultants and managers of being manipulative bad actors that sure is going to provoke a response. In safety management there are four pillars and one of them is safety culture. So, if there are manipulative bad actors applying the process there’s surely a poor safety culture which makes everything else moot.

This plays into the discomfort some people have with the inevitable subjectivity of risk classification. It’s true that safety risk classification uses quantitative and qualitative methods. However, most typically quantitative methods are used to support qualitative decisions.

There’s an in-built complication with any risk classification scheme. It’s one reason why three-by-three risk matrices are often inadequate. When boundaries are set there’s always the cases to decide for items that are marginally one side or other side of a prescribed line.

An assessment of safety risk is just that – an assessment. When we use the word “analysis” it’s the supporting work that is being referenced. Even an analysis contains estimations of the risk. This is particularly the case in calculations involving any kind of human action.

To say that this approach is not “scientific” is again a provocation. Science is far more than measuring phenomena. Far more than crunching numbers. It includes the judgement of experts. Yes, that judgement must be open to question. Testing and challenging is a good way of giving increased the credibility of conclusions drawn from risk assessment.

[1] https://publicapps.caa.co.uk/docs/33/CAP795_SMS_guidance_to_organisations.pdf

SPO 2

An instant reaction to Single Pilot Operations (SPO) is like the instant reaction to completely autonomous flight. “I’m not getting on an aircraft without a pilot!” Then to justify that reaction fatal accidents of the past are cited. Typically, this is to remind everyone of the tragic Germanwings accident[1]. It was 24 March 2015, that an Airbus A320 was crashed deliberately killing all onboard.

However, it’s wise to remember that the likelihood of incapacitation[2] is much greater than that of the malicious behaviour of the pilot in command. Cases of malicious behaviour leading to a catastrophic outcome are truly shocking but extremely rare.

One fatal accident, that is still disputed is EgyptAir Flight 990[3] that killed 217 people in 1999. The possibility of inflight pilot suicide is unnerving, since on the face of it there is little any of the aircraft’s cabin crew or passengers can do to stop it.

This could be a future opportunity to use automation to prevent these scenarios occurring. Afterall the aircraft knows where it is and that a sustained high-speed dive towards the ground is not normally intended. A safety system exists to do this[4], but its outputs are not connected to the aircraft’s flight controls.

Humans being adaptable, extremely creative and capable of highly irrational actions, it’s unlikely that malicious behaviour resulting in aviation accidents will ever be reduced to zero. This is said regardless of the procedures or technology involved. The fate of flight MH 370 remains a mystery.

Thus, the prominent safety issue in respect of SPO is pilot incapacitation. Where the pilot in command is no longer able to perform as expected. That is, if the aircraft flown is not capable of safely landing itself. The objective always being safe continued flight and landing.

I’ve had the “1% Rule” rule explained to me by a notable aviation doctor, but I must admit I didn’t fully take it in. So far, the rule has stood the test of time. When the pilot in command of a Czech Airlines aircraft collapsed and died on route from Warsaw to Prague in 2012, the co-pilot took over and everyone got home safely.

Any automated co-pilot must be at least as capable as a human co-pilot in all aspects of operation of an aircraft. The key word here being “all”. It’s not enough to have the functions necessary to undertake safe continued flight and landing. Task such as communicating with the cabin crew and passengers must also be considered. Including preparation for an emergency landing.

[1] https://www.bbc.co.uk/news/world-europe-32072218

[2] http://www.avmed.in/2012/02/pilot-incapacitation-debate-on-assessment-1-rule-etc/

[3] https://www.theguardian.com/world/2002/mar/16/duncancampbell

[4] https://skybrary.aero/articles/terrain-avoidance-and-warning-system-taws

Air Safety List 2

It may seem obvious that there should be an Air Safety List that bans airlines that do not sufficiently met international standards. It’s a right that exists within the Chicago Convention[1]. The first words of the convention concern sovereignty. Every State has complete and exclusive sovereignty over their airspace. From the first days of flight the potential use of aircraft to wage war was recognised. Thus, it could be said that the first article of the Chicago Convention existed even before it was written down and agreed.

However, it’s similarly recognised that the future development of international civil aviation has always depended upon agreements between States. Without over-flight and permission to land in another country there is no international civil aviation.

I do remember some agonising over having an explicit list of banned countries and airlines. In a liberal democracy choice is greatly valued. Here the choice concerns passengers being permitted to board aircraft from another country where there is knowledge of safety deficiencies related to the operation of the aircraft of that country. Should the law make that choice for the air traveller, or should the air traveller be free to make an informed choice?

There lies the crux of the matter. How do ordinary citizens, without aviation safety expertise make judgements concerning complex technical information? Understanding the implications of failing to meet the International Civil Aviation Organization’s Standards and Recommended Practices (SARPs)[2] is not so easy even for aviation experts.

Additionally, there is the issue of third-party risks. It would not be wise to permit foreign aircraft, whose safety is not sufficiently assured, to fly over a nation’s towns and cities.

Regulatory legislation was framed not only to put airlines on the Air Safety List but to take them off the list too. In fact, sometimes this is harder law to frame. In this case the decisions must be made in a fair, transparent, and technically rigorous manner otherwise the politics of such choices could overwhelm the whole process.

There’s been much success in this endeavour. It’s clear that this is a valuable aviation safety measure. It may have driven some contracting States to improve the performance of their airlines.

[1] https://www.icao.int/publications/Pages/doc7300.aspx

[2] https://www.icao.int/safety/CMAForum/Pages/default.aspx

Walk the line

Aeronautical products must be certified before entering transport services. Is certification too complex? Is it too expensive and thus a barrier to innovation? Hasn’t deregulation delivered successes since the 1970s? More choice and more aviation services across the globe.

These are perfectly reasonable questions. They are asked frequently. Especially during economically tough times and when new products are pushing to get operational. In answering, it’s all too often a butting of heads that results. Industry puts its point. Authorities put theirs. Commercial reality and public interests settle at some point which leaves the debate on the table for next time.

Walking that line between satisfying the demand of the new and protecting the good safety performance of the aviation system is a perpetual challenge. It goes without saying that we all know what happens when the line is crossed. Textbooks will continue to chew over stories like that of the Boeing 737 MAX development. In fact, the stories of safety lapses are an important part of the learning process that led to aviation’s admirable safety record.

The counter argument is that we are in a new situation and that technology has significantly changed. This argument of the “new” is not new. Every major new step encountered significant hurdles to overcome. Pick-up the story of the development of the Boeing 747[1][2] and it’s a real dramatic page turner. However, the problem remains the same but as much innovative thinking needs to go into certification as the products that are certified. There’s a reason that’s difficult and its called legacy.

On the public’s behalf, how big is the risk appetite of the certification authorities? At the same time how far do the innovators want to push the envelope knowing that liability rest on their shoulders?

What I find inadequate is that when reading reports like “Funding Growth in Aerospace[3]” I find little, or no consideration is given to funding regulatory improvement. Arguments are for product development and little else. It’s as if certification activities are to be blamed for holding up innovations introduction to service but forget any thought of increasing the resources for certification activities.

It’s short-sighted. Believe it or not there is money to be made in testing and validation. There’s money to be made in education and training. These go hand in hand with efforts to exploit innovative products.

[1] https://www.bbc.co.uk/news/business-37231980

[2] https://www.theguardian.com/science/2016/sep/07/joe-sutter-obituary

[3] https://www.ati.org.uk/publications/

Air Taxi 3

Urban mobility by air, had a flurry of success in the 1970s. However, it did not end well.

Canadian Joni Mitchell is one of the most celebrated singer-songwriters and my favourite. She has tapped into the social and environmental issues that have concerned a lot of us for decades. Of her large catalogue, I can’t tell you how much I love this song[1]. The shear beauty of the lyric.

Anyway, it’s another track on the album called “Hejira” that I want to refer. When I looked it up, I found out, I was wrong. The song I want to refer to is on the 1975 album “The Hissing of Summer Lawns”. The song “Harry’s House[2]” contains the line “a helicopter lands on the Pan Am roof like a dragon fly on a tomb.” Without going into what it’s all about, the lyrical image is that flying from a city skyscraper roof was seen as glamorous and the pinnacle of success.

In 1970, prominent aviation authorities were talking about the regulatory criteria needed for the city-centre VTOL[3] aircraft of the future. Then on the afternoon of 16 May 1977, New York Airways Flight 971, a Sikorsky S-61 helicopter, crashed[4] on Pan Am’s building rooftop heliport[5]. That ghastly fatal accident reset thinking about city centre operations air transport operations.

So, what’s different 50-year on? Proposals for city centre eVTOL operations are much in the News. City planners are imagining how they integrate an airborne dimension into public transport operations. Cars, busses, trains and eVTOL aircraft may all be connected in new multimodal terminals. That’s the city transport planners’ vision for less than a decade ahead.

For one, the vehicles are radically different. Yes, the physics of flight will not change but getting airborne is quite different between a conventional large helicopter and the plethora of different eVTOL developments that are underway across the world.

Another point, and that’s why I’m writing this piece, is the shear amount of safety data that can be made available to aircraft operators. Whereas in the 1970s, a 5-parameter flight recorder was thought to be neat, now the number of digital parameters that could be collected weighs in over thousands. In the 1970s, large helicopters didn’t even have the basic recording of minimal flight data as a consideration. The complexity in the future of eVTOL will be, not how or where to get data but what to do with all the data that is streamed off the new aircraft.

Interestingly, this changes the shape of the Heinrich and Bird “safety pyramid” model[6]. Even knowing about such a safety model is a bit nerdy. That said, it’s cited by specialist in countless aviation safety presentations.

Top level events, that’s the peak of the pyramid, remain the same, but the base of the pyramid becomes much larger. The amount of safety data that could be available on operational occurrences grows dramatically. Or at least it should.

POST: Growing consideration is being given to the eVTOL ecosystem. This will mean a growing need to share data Advanced Air Mobility Portal (nasa.gov)

[1] https://youtu.be/nyj5Be5ovas

[2] A nice cover https://youtu.be/bjvYgpm–tY

[3] VTOL = Vertical Take Off and Landing.

[4] https://www.nytimes.com/1977/05/17/archives/5-killed-as-copter-on-pan-am-building-throws-rotor-blade-one-victim.html

[5] https://www.thisdayinaviation.com/16-may-1977/

[6] https://skybrary.aero/articles/heinrich-pyramid

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 14

air air travel airbus aircraft — Photo by Pixabay on Pexels.com

It’s unusual to see such unity amongst aviation organisations across different sectors of the industry. That unity is about the European Union Aviation Safety Agency (EASA). Established in 2002, the EASA has more than 800 aviation experts and administrators from its Member States. A while back a UK Parliament Select Committee report[1] found: “There is widespread agreement that continued membership of EASA would benefit the UK and the EU.” Aerospace businesses, unions and academia are unanimous in support of remaining in EASA.

The BALPA (The British Airline Pilots Association)[2] said: “we need to maintain current EU and UK access to our aviation markets and to maintain EASA safety regulation”.

UK aviation industry body, ADS’s Chief Executive said[3]: “We have been clear that continued participation in EASA is the best option..”.

Even on Saturday, the UK CAA’s own website continued to say: “The CAA has been clear since the EU referendum that we consider the most positive outcome for UK consumers and the aviation industry would be one where the UK has continued participation in the EASA system with existing systems of mutual recognition between the UK and EASA Member States remaining in place.”

So, there’s one area where people and organisations are overwhelmingly unified – we need to maintain current EU and UK access to our aviation markets and to maintain EASA safety regulations.

It was always on the cards that the new UK Conservative Government would revisits this subject. This was even though the firm planning assumption that everyone had made for the last 4-years was based on the UK’s continued membership of EASA.

Now, the UK Transport Minister with such responsibilities says that the UK will withdraw from the EASA. Implementing that policy change the UK Department for Transport has said: “Being a member of the European Aviation Safety Agency is not compatible with the UK having genuine economic and political independence.” This does not preclude the UK continuing to work with the EU to establish a new regulatory relationship, but it’s a tall order with only 10-months remaining on the clock.

I think this a bad decision. Not sound or rational or in the interests of the UK. Here, I’ll look at the apparent justifications.

Compatibility with genuine economic and political independence

This suggests that membership of the EASA would impede the UK from taking any action it wishes. There are 4 non-EU members of EASA. One of them is our near neighbour Norway. CAA Norway has the responsibility to oversee and regulate all aspects of civil aviation in Norway. That applies to the Norwegian flights that are based out of London Gatwick. In matters of aviation regulation, whether it’s at ICAO, EASA, EUROCONTROL or ECAC Norway speaks with economic and political independence. It applies Norwegian law. It does not seem to be impeded in advancing its aviation interests.

Being a member of EASA is not possible outside Single Market

This has been well debunked. The manner with which non-EU States participate in the EASA is not the Single Market provisions. There is a “Basic Regulation” that establishes EASA[4]. The Article 129 of the Basic Regulation addresses participation of European third countries. Yes, it does say that such non-EU States need to adopt and apply Union law in the fields covered by the Basic Regulation. However, this text does say how this is to be done. In fact, the UK has done this, at least until the 31^st December 2020. All that is needed can be done in UK law. If EASA rules or standards are considered to be too low, there’s no impediment to enhancing them as required.

We’ll be wanting to develop our own aircraft certifications

The implication is that the UK will want to do something radically different from the international community. That maybe the case for research into new air vehicles but if the UK wishes to sell such products in the international marketplace it will need to met international rules and standards. A domestic industry providing Urban Air Mobility (UAM) vehicles will need to compete across the globe. EASA is preparing itself to better support innovation from industry (e.g. Artificial Intelligence, block chain technologies, extensive automation and eVTOL aircraft). Lack of harmonisation, duplication and fragmentation in this field serves no good purpose.

4. UK expertise can be used as leverage in negotiations

Across the globe, the aviation industry and most States say that aviation safety is not a matter of competition. There’s a great reliance on cooperation and sharing information to ensure that no State is left behind. A just safety culture is one where working togther is normal. It’s difficult to improve safety when people imply blame and echo a negative attitudes. To imagine this subject to be a matter for open commercial competition is flying against all international best practices.

5. A wish to not be subject to the rules made by others

No man is an island[1] If this reasoning is applied literally then it’s impossible to participate in any international organisation. In most cases it’s preferable to participate and have a significant influence on any rules. The Convention on International Civil Aviation (known as Chicago Convention), came to be in 1944. Since we (UK) do not control ICAO, should we now withdraw? Clearly that would be a nonsense. In our own region of the world, namely Europe, it would be wise to act skilfully to maximise the influence that is available not to walk away.

I join other aviation professionals in thinking it’s extraordinary how little the UK Government is prepared to consult with industry, consider cost and benefits and explain any new arrangements that will need to be put in place in a short time. At one time there was a stubborn insistence that major changes should not be introduced without a detailed impact assessment. Now, anything goes if the Minister likes it.

Reference: UK CAA Statement on future relationship with the European Union

[1] MEDITATION XVII, Devotions upon Emergent Occasions, John Donne.

[1] https://researchbriefings.parliament.uk/ResearchBriefing/Summary/CDP-2018-0233

[2] https://www.balpa.org/Media-Centre/Press-Releases/Brexit-There-is-no-WTO-default-for-aviation-so-UK

[3] https://www.adsgroup.org.uk/news/newsroom/statement-on-transport-secretary-comments-on-easa-membership/

[4] 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,

Brexit, Aviation and the Withdrawal 13

WP_20170826_008 For decades we (UK) have been interwoven with the EU in an intricate pattern that is complicated and often not well understood even by those who are supposed know. The twists and turns of the last 4-years have brought about a situation where those who say: absolute independence outweighs the risk of being “shackled” to the EU, now govern the UK. The idea of common interests and common solutions to common problems has gone out of the window.

Aircraft are built by experts, tested by experts and flown by qualified experts with exceptional skill and with multiple safety backups. Brexit has been driven by opportunist politicians who persistently distort evidence to support their beliefs with scant regard of the costs or harm done. Thus, the next steps in the Brexit EU-UK negotiations will be as difficult, as difficult as can be imagined. That’s what has indeed happened if reports of this week’s discussions are surveyed.

The UK will withdraw from the European Union Aviation Safety Agency (EASA) after 31^st December[1]. The divorce is a hard one. I can think of a lot of Brits who dedicated enormous amount of effort to European harmonisation who will be turning in their graves.

Yes, it’s true that the road that led to the EASA had its roots in the UK. When I started work at the UK CAA, the offices of the Joint Aviation Authorities (JAA) were based at Aviation House, London Gatwick. The benefit to aviation of having a common code was recognised in the 1980s. Signing of the “Arrangements concerning the Development, the Acceptance and the Implementation of Joint Aviation Requirements” (the “Cyprus Arrangements”) by 24 European States, took place in 1990.

In time, the weakness of the JAA system became apparent in that the common application and interpretation of aviation codes was not so common. The framework of European law was necessary to ensure that there was indeed a level playing field and a high level of aviation safety. In European law, a division of tasks between the EASA and the national aviation authorities was determined. EASA was given the power to carry out legally binding certification tasks, thus overcoming the limitations of the JAA system. The creation of EASA, led to the harmonisation of more existing rules and regulations and greater cooperation in the formation of new rules.

Reversing out of 30 years of progress is a challenging task. Yes, it can be coloured as a bold new era in flourishing rhetorical terms but practically it looks like a knee-jerk reaction. Not only that but the timing is awful. Market turbulence due to the contagious virus is severely impacting aviation. Not only that but the whole process of certificates issued by one authority being automatically accepted by another authority is being questioned because of the Boeing 737 MAX case.

Playing to the crowd with symbols of post-Brexit independence isn’t a wise move. It’s kamikaze.

[1] https://aviationweek.com/air-transport/safety-ops-regulation/uk-will-leave-easa-says-british-transportation-secretary

Brexit, Aviation and the Withdrawal 11

Spring 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 118

For the British politician the 31^st January 2020 is a big event. For most people in employment, the Brexit confusion and uncertainty continues at least for another 11 months. Social Media is a good indication of the conversations people in aviation employment are having. One question raised yesterday has been raised many times: After Brexit will the EASA licences that were obtained in the UK still be valid?

Despite the name, these mandatory licences are not issued by EASA in Cologne but issued by European Union (EU) Member States applying European rules. National Aviation Authorities (NAAs) have this responsibility. The European system requires EASA and the NAAs to work together. In order to get an EASA Part-66 AML (Aircraft Maintenance License), an applicant needs to show a basic knowledge in relevant aviation subjects.

Having common rules throughout EASA Member States means that they accept an EASA licence that is granted by one of those States. In addition, States across the globe, who have a relationship with the EU can choose to accept an EASA licence. That’s what happens in the United Arab Emirates (UAE) where most of the world’s Airbus A380 aircraft are based, for example.

So, the EU and the UK are entering a transition period during which UK aviation will continue to participate in the EASA systems. That means compliance with EU regulations while the longer-term EU-UK aviation relationship is worked out. Currently the UK Civil Aviation Authority (CAA) website has a statement[1]:

Engineers transferring their Part-66 licence to other Member States: While the CAA will continue to accept and process Part 66 transfer applications under existing EASA transfer arrangements until the UK leaves the EU, the procedures adopted by the receiving NAA and recognised validity of the licence during the transfer process may vary amongst EU member states. Applicants who require continuity of validity throughout the transfer process are therefore advised to apply at least 3 months prior to Exit Day and should also consider engaging with their intended receiving NAA to identify any potential issues.

Clearly, there are numerous combinations and permutations of situations that can arise for engineers working on aircraft. Given the history of licencing it’s highly likely that an arrangement will be worked out for next year, 2021. For now, each individual aircraft engineer needs to check their situation dependent on where they are working and on what aircraft they are working on, at what time.

This will put extra stress on global regulatory oversight activities too.

[1] https://info.caa.co.uk/brexit/licensed-engineers/