Brexit & Aviation 57

It’s reported that the Director General of the British Chambers of Commerce said: “There are no more words to describe the frustration, impatience, and growing anger amongst business after two and a half years on a high-stakes political rollercoaster ride that shows no sign of stopping.[1]

I’m sure that those words would be echoed by a great number of people in the aviation sector.

A defeat of 230 votes is massive.  MPs have rejected the Prime Minister’s proposals by the biggest UK Government defeat in modern history.  That ought to be a signal to change direction but we have yet to see if a new approach will be forthcoming.

Beyond the political hoo-ha there’s the need to act.  A great deal of implementing legislation needs to be passed through the UK Parliament, whatever the destination.  Naturally, this is needed if the Article 50 letter is not withdrawn and the whole Brexit process stopped.

The European Union (EU) continues to flourish despite having faced innumerable hard problems thrown at it over many decades.  This is not Greenland[2], this is a large and prosperous Country giving up its membership of the EU.  Thus, the avoidance of the loose-loose scenario, of a No Deal Brexit should be at the top of everyone’s priority list.  Meanwhile large sums of money, that could have been used growing European businesses are being pumped into contingencies.

If this Withdraw Agreement (WA) is not acceptable as it stands then it may return as WA2 but don’t expect that to be substantially different from what’s already on the table.  Alternatively, there could be public vote to consider the options.

The e-mail subscriptions to “SkyWise[3]” is useful to stay up-to-date with news, safety alerts, consultations, rule changes and airspace amendments from the UK CAA.  The site has a section for EU exit alerts.

There is useful material out there, but it indicates a poor state of readiness given all the caveats and unknowns that exist.  Just as business leaders are warning, the UK is like a super-tanker heading for the rocks.   72 days isn’t long to put that right.

[1] https://news.sky.com/story/growing-anger-frustration-and-impatience-from-businesses-over-brexit-11608581

[2] https://www.politico.eu/article/greenland-exit-warning-to-britain-brexit-eu-referendum-europe-vote-news-denmark/

[3] http://skywise.caa.co.uk/category/eu-exit/

 

 

Brexit & Aviation 56

On the 23 June 2016, the United Kingdom (UK) voted in an advisory referendum to leave the European Union (EU).  74 days to go before the date scheduled for Brexit and the Country is still vacillating.

As time ticks away its not a bad idea to have an eye on priorities.  If there’s some issues that rank above others in importance.  This is recognised throughout aviation.   It’s the way we construct an Aircraft Flight Manual (AFM).  Top of the list in an AFM are the Emergency Procedures.  It seems to me that we need a set of Brexit Emergency Procedures.  The future relationship between the UK and EU remains unclear and may do so for a long time.  That said, I’m not alone in considering what might happen in the different scenarios that can come into play[1][2].

Having made this proposition what would be in such a set of procedures?  Here’s a non-exclusive list of major topics that can not be left to chance.

  • Air Services Agreements
  • Safety Regulation
  • Security Management
  • Air Traffic Management
  • Environment

Today, civil aviation is regulated at European level.  All 5 of these subjects have been addressed in recent advisory publications at both national and European level.  However, it is still up to individual aviation stakeholders how and when they react.  There are no new directives that mandate a course of action for air transport services, even the essential ones.

If chaos does ensue on the effective withdrawal as of midnight (00h00) on 30 March 2019, then it will not be easy to understand where blame should rest.  The resolution of problems will need a forum to coordinate fixes too.  That is the unfortunate nature of the current situation.

Aviation is a dynamic part of the UK, contributing £52 billion to UK gross domestic product (GDP) and supporting close to one million jobs[3].   To be where we are now, with only 74 days to go is highly disadvantageous, to say the least.

[1] https://www.internationalairportreview.com/article/75237/brexit-and-aviation/

 

[2] https://www.iata.org/policy/consumer-pax-rights/Pages/brexit-study.aspx

 

[3] https://www.instituteforgovernment.org.uk/explainers/european-common-aviation-area-brexit?gclid=Cj0KCQiAg_HhBRDNARIsAGHLV53iNpXElpsIy2vuN9a9jRIYGMWjwTEZ7Slm5UDYXZQqeRMgkMpaUcgaAhxqEALw_wcB

 

Brexit and Aviation 40

There are some documents that are essential for the smooth operation of aviation.  When it comes to moving products, parts or components of aircraft around the world the Authorised Release Certificate is key.  This certificate must be trusted and accepted by those who receive it.  Even with an international framework that describes how this is done this acceptance is not automatic.

In Europe, the format of Authorised Release Certificates has been harmonised after decades of work.  In addition, work has been undertaken harmonise the instructions for completing these standard release forms.

The EASA Form 1[1] is the Authorised Release Certificate provided by a manufacturing organisation (Part-21 POA holder) for stating that a product, a part, or a component was manufactured in accordance with approved design data.

What that means is that the form accompanies an aircraft product, like say an engine, and if it’s not valid that product cannot be used.  Organisations doing maintenance, repair and overhaul must keep detailed records when working on an aircraft.

As an example, in Europe we may have a British manufactured aircraft engine being fitted to a Spanish registered aircraft in a German hanger by an engineer who holds a Dutch licence.   For this to happen in an approved manner the paperwork must be accurate, complete and valid.  If the EASA Form 1 coming with the British manufactured aircraft engine is not recognised, then the work described above cannot take place.

I’ve described this situation because there’s the possibility that in a full “No Deal” Brexit there will be no automatic recognition of a British issued EASA Form 1.

This is not the first time I’ve mentioned the EASA Form 1[2].   The reason for mentioning it again is that I became more acutely aware of this problem when visiting a major conference and exhibition in Amsterdam.  On Wednesday last, I chaired a one-hour panel discussion on: “Regulatory Changes and Challenges”.  This included a Policy Specialist (Brexit) from the UK CAA.   He described the preparatory work that’s being done and some of the differences in positions between UK published papers and EU published papers.  To date, the UK CAA and EASA are not in formal talks.  Both are ready to initiate technical discssions but this is being held up by the lack of clarity in relation to the withdrawl agreement (See exchange of letters from June/July).

I conclude that rash headlines that suggest a “No Deal” option is doable are way off the mark.  The regulatory maxim – trust but verify – must be satisfied one way or another.

[1] https://www.easa.europa.eu/faq/19466

[2] https://johnwvincent.wordpress.com/category/form-1/