As the U.K.’s vote to exit the European Union settles in, we sought out a general aviation perspective from across the Atlantic from Thomas Borchert, editor of the German-language fliegermagazin and from Ian Seager, publisher of the U.K. Flyer magazine.
From Germany
The overwhelmingly major benefit of the EU for GA pilots has been a unified customs area and the Schengen accord, which basically does away with passport controls by the border police. These two things enable pilots to roam freely (after filing a flight plan, for most border crossings) between members of both EU and the Schengen accord. No customs or border police checks, no special airports of entry to be used. It is a major freedom when using aircraft in the small countries Europe is made up of. However, the U.K., while being in the EU, has never signed the Schengen accord, so no change is to be expected there: Border controls are mandatory when going into the U.K. now, and they will remain so, with an added layer of customs getting involved.
EASA—the European Aviation Safety Agency—is Europe’s version of the FAA. Kind of. That’s because unified European aviation isn’t really: EASA makes rules, the EU enacts them to be law in each EASA member state. However, the national aviation authorities (which still exist) and in addition (in Germany, for example) the aviation authorities of the federal states within a country all get a shot at interpreting EASA’s often not-too sharply defined rules. And boy, do they ever. All differently, of course. Imagine that this is the procedure not only in aviation and you get a feel for why one could indeed vote for exiting the EU.
There are several examples of non-EU members that are still EASA members and, as such, bound by EU aviation law. Switzerland and Norway are the biggest countries in this category. So it is not unthinkable that the U.K. (or what’s left of it) will leave the EU, but remain EU-bound with regards to aviation rules. However, since the British Civil Aviation Authority has a history of being unhappy with many of EASA’s moves, this seems unlikely to me.
Here is the key problem that might result for European GA aviators from the U.K. leaving EASA: EASA loses a voice of reason. The British CAA, especially under its current leadership, has had a tremendously positive influence on EASA in many respects. It is one of the key proponents of not regulating GA in the same way airlines are regulated, which used to be EASA strategy for years and has only recently changed.
Leaving the EU and/or EASA might become a big problem for the U.K. aviation industry – or what’s left of it. Airbus has major production facilities in the U.K. Garmin has its European warehouse there. Some of the major European online pilot stores are based in the U.K. Nobody knows how that will work out, but it is safe to assume the free exchange of goods will not remain so free. If a new aircraft gets EASA certification, it will no longer automatically be certified in the U.K. If a pilot has an EU certificate, he/she is no longer automatically allowed to fly U.K.-registered aircraft. All of these things can be worked out in bilateral agreements, but how that is easier and less fraught with problems than doing it through the EU is not quite clear to me.
EASA had a bad start in general aviation. They messed up maintenance and many other areas with totally overblown regulation. They are only now coming around, ever so slowly and nobody can be sure it will last. Given enough time, this transitional period will blow over and we will have solid European aviation regulation in a few years. Not waiting out that transitional period by leaving the EU and EASA will hurt all involved, in my opinion.–Thomas Borchert, fliegermagazin
From the U.K.
The short version, from my perspective at least, is that as a nation, we are completely bonkers. Many people seem to have made a mid-term protest vote rather than the huge decision that it was.
Regarding EASA, this agency was originally run by a bunch of people who were more interested in process than outcome, and who thought that you could take commercial regulation and dilute it a bit for GA. The maintenance stuff was truly terrible. Then came a change of leadership and things are now much, much better. We have things like CS-STAN that’s more liberal than many U.S. regs. Basically CS-STAN is EASA-speak for Certification Standards/Standard Changes and Repairs. It defines how stuff is done and in lots of cases refers people to the FAA’s AC41.13 which is a short enough document and can be found here.In some cases, it seems to give our versions of A&Ps (licensed engineers in Euro-speak) the ability to sign off things that would in the U.S. require a Form 337 or perhaps the involvement of a DAR.
And when Part M light (the new maintenance regulation) comes in, it will make a huge difference.Part M is the maintenance regs and Part M Light is a better, simpler, more appropriate version. Eventually it will be down to the owner/operator to specify the maintenance regime. There will be something called the MIP or Minimum Inspection Program that is similar to the FAA’s 100-hour inspection requirement.
Some people prefer to hang on to the old “it’s all sh%$” view because the truth is some of the old sh%$ is still there, but it is getting better and there’s some really good stuff happening that requires some thought and effort.Now that Brexit is a reality, no one knows what will happen to that progress.–Ian Seager, Flyer magazine
