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Along with the other European Union member states, the UK is currently part of the European Aviation Safety Agency. Based in Cologne, Germany, this EU body is responsible for all aspects of civil aviation safety — and an unlikely source underlined its importance.
Speaking at the UK’s Aviation Club last week, U.S. Federal Aviation Administration’s chief Michael Huerta explained the seriousness of the UK’s situation with regards to aviation safety.
Huerta pointed out that currently the UK benefits from the being part of EASA and that when it leaves the EU it will need to be replaced or there would be the very real possibility of an “interruption of service.” To put it another way if the UK doesn’t sort something out there will be big problems.
“With very limited exceptions the United Kingdom’s aviation products are currently certified by the European safety agency or EASA and service providers such as maintenance repair and overhaul facilities are certified using EU regulation and EASA procedure,” said Huerta.
“If the UK does not maintain an associated or working arrangement with EASA upon leaving the EU, the UK will quickly need to re-establish competencies in specific areas especially around certification of new aviation products. And additionally, the U.S.-UK bilateral aviation safety agreement has been largely dormant for a number of years. Well it needs to be updated and put in place to be enforced upon the UK’s exit from the EU. Now this is manageable but it will take time and it will depend on clarity around the UKs relationship with EASA going forward.”
When the UK leaves the European Union it will be forced to replace thousands of regulations with some of its own.
Aviation is one of the areas where the EU plays a crucial role for the UK and if airports aren’t going to grind to a halt on March 30, 2019 , the UK needs to either re-establish its own regulatory framework or apply to retain certain memberships.
The two-year Brexit timeframe doesn’t give the country’s negotiators a lot of time.
The EU’s market liberalization revolutionized the industry and helped bring down prices across the continent. Airlines want to see continued access to the European Common Aviation Area (ECAA) and also want clarity on topics such as ownership. Both of these have generated plenty of headlines but there is also the complex issue of aviation safety to consider.
As Huerta said, there are couple of ways the UK could handle aviation safety regulation after Brexit. One avenue would be to rejoin as a non-EU member state, like Norway, but in effect this would be the worst of both worlds with the UK forced to comply with all regulation but without voting rights. It would also mean being subject to European law, which was one of the reasons given for leaving the EU.
Failing this, the UK could decide to go it alone. It would be possible to do this but it would take plenty of time and money, and as Andrew Haines, the chief executive of the UK’s Civil Aviation Authority said in a speech in December, 2016, there are other reasons to be fearful of this approach.
“Let’s just imagine the UK was to withdraw from EASA altogether and adopt our own framework – although I’m yet to meet anyone of substance that supports that approach. It is, of course, theoretically possible and let’s just suppose we established the best aviation safety regimes in the world, It would mean a major increase in UK regulatory regime, potentially represent a major barrier to track increased costs and yet we would also risk becoming a backwater in terms of wider impact,” he said.
Negotiations between the UK and EU started on Monday and would need to be concluded by the end of March 2019. Aviation safety will no doubt crop up at some point and will just be one of the issues that needs to be ironed out if the industry is going to enjoy a seamless Brexit.