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VS11
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 2:39 pm

MillwallSean wrote:
What this really means is higher costs and less competitive players in the UK. For aviation there are presently two players. One in the US and one in Europe. The UK supply chain is presently geared towards the European company. Hence, for us (my company) our UK production units will see higher costs. They need to be EASA certified and we have to move to ensure that such certification now takes place under a different regiment. The EU tends to stipulate that such certification takes place within the EU should the host nation not have an agreement that recognises the competency of the civil aviation regulators ability to certify parts etc from that territory (and even then, specific additions are expected) something Airbus/Boeing notices continuously.
We might then also have to pay an additional fee to be CAA certified. BUT that will come after we have gained EASA certification.
Some of you may remember the millions of dollars to certify 787-300 discussion from a decade ago and US has such high trade barriers its cheaper for Airbus to run assembly lines for large industrial goods in the states vs sticking to an EU production line.
https://www.seattlepi.com/business/arti ... 239464.php

Another example of what this madness will lead to. UK used to be the place to be when you wanted medicines certified in the EU. Te EU didn't just certify for the EU market but had and have deals with another 50 or so independent nations that accept EU certification (mainly Asia and Africa). The certification will remain the same just that it now needs to be undertaken within the EU of which soon the UK is no longer part.
My sister works for AstraZeneca in Cambridge. For their medical research testing facility they have had to duplicate what's in Cambridge and build an identical (slightly more modern) new facility outside Stockholm (at a site they abandoned 5 years earlier). This to the tune of 600 million (and I dont remember whether she said that was 600 million Euros, SEK or Pounds).

Humans are dumb. One group who thinks an island is powerful and still see the world through the lens of a long lost empire. Another that will smile and at the same time place costs on UK business all under the disguise of level playing fields - while not mentioning that most of their own production is outsourced to say Romania or Slovakia. Level playing field, hmmm...


Both Romania and Slovakia are in the EU so it is the same regulatory playing field. But, yes, it was well known that hard Brexit would make it more difficult for UK businesses to be competitive outside of the UK. The present UK Government, however, has accepted this trade-off and is telling the UK public to basically get used to it. I agree it defies economic logic but it is what it is. There is no vacuum in business and someone else will fill in the void whether it is in aviation, medicine, manufacturing or financial services (where it will be a real bloodbath with equivalence, clearing and so on).
 
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Revelation
Posts: 24613
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 4:39 pm

I think a question not really being answered here is "does a major subassembly like a wing get certified by the nation hosting its production or by the nation certifying the aircraft?". I thought it was the later, but maybe it is the former, or some combination of both?
Wake up to find out that you are the eyes of the world
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Wake now, discover that you are the song that the morning brings
The heart has its seasons, its evenings and songs of its own
 
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par13del
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 4:52 pm

Even if not certification, there can be many other aspects affected by not being a member of the EU or out of EASA. Working conditions and standards, employment practices, factory infrastructure, raw materials, the list can be endless.
 
VS11
Posts: 1661
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 4:57 pm

Revelation wrote:
I think a question not really being answered here is "does a major subassembly like a wing get certified by the nation hosting its production or by the nation certifying the aircraft?". I thought it was the later, but maybe it is the former, or some combination of both?


Maybe the new UK regime allows UK subassembly to operate under grandfathered certification standards for existing products.
 
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Revelation
Posts: 24613
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 5:22 pm

VS11 wrote:
Revelation wrote:
I think a question not really being answered here is "does a major subassembly like a wing get certified by the nation hosting its production or by the nation certifying the aircraft?". I thought it was the later, but maybe it is the former, or some combination of both?


Maybe the new UK regime allows UK subassembly to operate under grandfathered certification standards for existing products.

Perhaps, but that is not really addressing the question.

So, are the 787 wings certified to Japanese standards or US?

My guess would be that the entire aircraft is certified to FAA standards, but it'd be nice to have clarification.

I thought I read MROs that did work to aircraft operated by US airlines had to have FAA licenses and use FAA standards.

This would mean FAA would have authority over an operation not on US soil.

Thus there is at least one type of precedence that suggests EASA could retain authority over GKN facilities in the UK, Canada could have authority over the Belfast A220 factory owned by a US firm, FAA could have authority over a factory in Japan making wings for 787, etc.

I don't see why UK CAA would need to be involved in a part being made on UK soil for an aircraft certified under EASA standards. I know aircraft have production standards and each production line gets certified but I don't see why it'd need to be UK certification if the aircraft as a whole is being certified to EASA standards.

But I'm not involved in manufacture of parts for the aviation industry, which is why I'm asking so many questions.
Wake up to find out that you are the eyes of the world
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Wake now, discover that you are the song that the morning brings
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mjoelnir
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 5:38 pm

IMO the changes caused by the UK leaving EASA are exaggerated here. Regarding frames produced and certified in the EU, nothing big will change, apart from those frames needing a CAA certification to be used in the UK. Components produced for those frames need to be certified by EASA.

Regarding frames produced and certified in the UK, including parts produced in other countries, they will need CAA certification before they can go for other certifications.

Increasing the number of certifying authorities will increase cost. The advent of EU (EEA) wide certification lead to a significant decrease in cost for a lot of industries, as the number of certification authorities were decreased from 27 (30+) to one.

In this case the certification authorities will increase by one again. I see no good in this decision, but it is not a catastrophe.
 
peterinlisbon
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 6:00 pm

Hopefully the Isle of Wight will also be getting it's own aviation authority soon, because people there also want to be able to make up their own aviation rules and not have these things dictated to them by mainlanders.
 
blueflyer
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Re: UK leaves european aerospacesafety agency

Sun Mar 08, 2020 6:37 pm

bennett123 wrote:
Presumably, he assumes that all Brits working for EASA will quit and fly home.

If he does, he is even dumber than he looks. Recent history ought to tell him that Brits working for EU institutions will get a second passport and keep their job rather than go "home." Why does he think there are so many non-Brits "experts" representing the UK in trade negotiations sitting across the table from the Brits representing the EU?
 
strfyr51
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Re: UK leaves european aerospacesafety agency

Sun Mar 08, 2020 11:36 pm

par13del wrote:
mxaxai wrote:
Which ultimately increases the certification cost since an extra agency needs to review the documentation. Also possibly diverging standards, thus more tests and documentation as well as potentially delayed certification in the UK. But that applies to all manufacturers.

What standards, a company in the UK is building wings for Airbus based on what Airbus wants. Now if Airbus is going to say that the workers must be of a certain age, no sweat shops, those are social items, what would the technical items be, do the wings themselves have to be certified away from the frame?

No the wings can be built anywhere in the UK as they're major subcontractors, they could build wings for Boeing Just as easily or Lockheed Martin. All the need to do is stick to the drawings given to them. This is all alarmist thinking. Especially since NOTHING has TO CHANGE!
 
redroo
Posts: 584
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Re: UK to leave European Aviation Safety Agency

Sun Mar 08, 2020 11:45 pm

australia manages on it own. CASA works with EASA and FAA. Sometimes it sets its own rules. The world moves on.
 
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LTU932
Posts: 13726
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Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 2:46 am

mjoelnir wrote:
IMO the changes caused by the UK leaving EASA are exaggerated here. Regarding frames produced and certified in the EU, nothing big will change, apart from those frames needing a CAA certification to be used in the UK. Components produced for those frames need to be certified by EASA.

Regarding frames produced and certified in the UK, including parts produced in other countries, they will need CAA certification before they can go for other certifications.

Increasing the number of certifying authorities will increase cost. The advent of EU (EEA) wide certification lead to a significant decrease in cost for a lot of industries, as the number of certification authorities were decreased from 27 (30+) to one.

In this case the certification authorities will increase by one again. I see no good in this decision, but it is not a catastrophe.
So overall, it is safe to assume whatever is already certified today, will keep certification under the CAA leaving EASA for reasons of grandfather rights?
Sometimes the only thing more dangerous than a question is an answer. - Ferengi Rule of Acquisition 208
 
Scotron12
Posts: 496
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Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 2:53 am

Not grandfather rights per se, but acceptance of already EASA certifications, just like is recognized now.
 
marcelh
Posts: 1043
Joined: Wed Jun 19, 2013 12:43 pm

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 6:52 am

Revelation wrote:
I think a question not really being answered here is "does a major subassembly like a wing get certified by the nation hosting its production or by the nation certifying the aircraft?". I thought it was the later, but maybe it is the former, or some combination of both?


Are the subassembies for the 787 which are built in Japan certified by the Japanese?
 
mxaxai
Posts: 1990
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Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 9:41 am

I figure that for this topic, a look into COMMISSION REGULATION (EU) No 748/2012 of 3 August 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 organisations could help. https://eur-lex.europa.eu/legal-content ... d1e492-1-1

It covers the scope:
1. This Regulation lays down, in accordance with Article 5(5) and Article 6(3) of Regulation (EC) No 216/2008, common technical requirements and administrative procedures for the airworthiness and environmental certification of products, parts and appliances specifying:
(a) the issue of type-certificates, restricted type-certificates, supplemental type-certificates and changes to those certificates;
(b) the issue of certificates of airworthiness, restricted certificates of airworthiness, permits to fly and authorised release certificates;
(c) the issue of repair design approvals;
(d) the showing of compliance with environmental protection requirements;
(e) the issue of noise certificates;
(f) the identification of products, parts and appliances;
(g) the certification of certain parts and appliances;
(h) the certification of design and production organisations;
(i) the issue of airworthiness directives.


Article 2
Products, parts and appliances certification

1. Products, parts and appliances shall be issued certificates as specified in Annex I (Part 21).
2. By way of derogation from point 1, aircraft, including any installed product, part and appliance, which are not registered in a Member State shall be exempted from the provisions of Subparts H and I of Annex I (Part 21). They shall also be exempted from the provisions of Subpart P of Annex I (Part 21) except when aircraft identification marks are prescribed by a Member State.

This applies to all parts. Subassemblies that are transferred within a company are obviously exempt. Non-certified parts that are integrated into a fully certified product are also okay. If we look at an aircraft, major assemblies like wings, fuselage etc. make up the aircraft itself and are certified with it*. Replacable sub-assemblies and parts, like engines, gear and avionics, need their own certification. Bolts, wires and sheetmetal are a bit of a gray area since they're not really line replaceable units but may need replacing during heavy maintenance; I figure that it's up to the (certified) MRO to ensure that they release only airworthy aircraft.

Rolls Royce, for example, holds an EASA type certificate for each engine. As do PW and GE.

* Obviously the certifying company needs internal processes and documentation to prove that the product was built in accordance with its certification.
Design [and Manufacturing] organisations

1. An organisation responsible for the design of products, parts and appliances or for changes or repairs thereto shall demonstrate its capability in accordance with Annex I (Part 21).
2. By way of derogation from point 1, an organisation whose principal place of business is in a non-member State may demonstrate its capability by holding a certificate issued by that State for the product, part and appliance for which it applies, provided:
(a) that State is the State of design; and
(b) the Agency has determined that the system of that State includes the same independent level of checking of compliance as provided by this Regulation, either through an equivalent system of approvals of organisations or through direct involvement of the competent authority of that State.

So it all comes down to whether each agency accepts their counterparts' certification. The keyword being 'equivalent'. Without a legal definition of equivalency, this can mean anything from 'roughly similar' to 'absolutely identical'.
 
FluidFlow
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Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 9:56 am

While I do not think that there will be a direct problem for Airbus or Boeing sourcing parts from the UK, how will RR be affected? Their engines now have to be certified by at least three agencies (UK, EASA and FAA) to be used in most of the world (does the Chinese Agency copy EASA/FAA certifications or do they certify themselfs?).
 
mxaxai
Posts: 1990
Joined: Sat Jun 18, 2016 7:29 am

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 10:49 am

FluidFlow wrote:
While I do not think that there will be a direct problem for Airbus or Boeing sourcing parts from the UK, how will RR be affected? Their engines now have to be certified by at least three agencies (UK, EASA and FAA) to be used in most of the world (does the Chinese Agency copy EASA/FAA certifications or do they certify themselfs?).

All parts will need CAA certification if they are used in the UK. RR, PW, GE, doesn't matter.

I expect the CAA and FAA to copy each others certifications quickly, if only to stick it to the EU. Unless of course the UK really want to do their own thing ...
 
VFRonTop
Posts: 353
Joined: Fri Oct 12, 2012 6:02 pm

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 11:02 am

Does this mean that UK participation in EUROCONTROL and the ECAA are also under review?
 
FluidFlow
Posts: 724
Joined: Wed Apr 10, 2019 6:39 am

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 11:07 am

mxaxai wrote:
FluidFlow wrote:
While I do not think that there will be a direct problem for Airbus or Boeing sourcing parts from the UK, how will RR be affected? Their engines now have to be certified by at least three agencies (UK, EASA and FAA) to be used in most of the world (does the Chinese Agency copy EASA/FAA certifications or do they certify themselfs?).

All parts will need CAA certification if they are used in the UK. RR, PW, GE, doesn't matter.

I expect the CAA and FAA to copy each others certifications quickly, if only to stick it to the EU. Unless of course the UK really want to do their own thing ...


Yes but if they are not used in the UK but produced in the UK it is different right?

All parts will need CAA certification if they are used in the UK. RR, PW, GE, doesn't matter.


So sourcing parts in the UK will not need CAA certification.

So UK CAA can not really stick it to the EU except they want to ground all Airbus aircraft and take their certification in the UK but I do not think the UK would kill Easyjet and IAG just for sticking it to the EU.
 
mxaxai
Posts: 1990
Joined: Sat Jun 18, 2016 7:29 am

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 11:22 am

FluidFlow wrote:
mxaxai wrote:
FluidFlow wrote:
While I do not think that there will be a direct problem for Airbus or Boeing sourcing parts from the UK, how will RR be affected? Their engines now have to be certified by at least three agencies (UK, EASA and FAA) to be used in most of the world (does the Chinese Agency copy EASA/FAA certifications or do they certify themselfs?).

All parts will need CAA certification if they are used in the UK. RR, PW, GE, doesn't matter.

I expect the CAA and FAA to copy each others certifications quickly, if only to stick it to the EU. Unless of course the UK really want to do their own thing ...


Yes but if they are not used in the UK but produced in the UK it is different right?

All parts will need CAA certification if they are used in the UK. RR, PW, GE, doesn't matter.


So sourcing parts in the UK will not need CAA certification.

So UK CAA can not really stick it to the EU except they want to ground all Airbus aircraft and take their certification in the UK but I do not think the UK would kill Easyjet and IAG just for sticking it to the EU.
Yes, although any major manufacturer will want to seek CAA certification unless they don't expect to sell to the UK*. For example, COMAC may choose not to certify the ARJ-21 with the CAA (or EASA / FAA for that matter). But since almost every modern jet is operated in the UK, the manufacturers don't really have a choice. I could see them foregoing certification in, say, Somalia, but not in a key market like the UK; especially if the manufacturer is based there.

*Alternatively, the operators would need to register their aircraft overseas. Foreign registered aircraft are generally permitted to operate under the rules of the foreign agency. Reason why all Aeroflot jets are registered in Bermuda iirc.
 
Bhoy
Posts: 554
Joined: Tue Apr 18, 2006 1:50 pm

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 6:13 pm

mxaxai wrote:

*Alternatively, the operators would need to register their aircraft overseas. Foreign registered aircraft are generally permitted to operate under the rules of the foreign agency. Reason why all Aeroflot jets are registered in Bermuda iirc.

I was under the impression Aeroflot jets were registered in Bermuda is that Russia imposed a punitive import duty to bring non-Russian manufactured Aircraft into the Country for registratiin?
 
klakzky123
Posts: 688
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Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 6:54 pm

VFRonTop wrote:
Does this mean that UK participation in EUROCONTROL and the ECAA are also under review?


Hopefully they stay in Eurocontrol but I suspect they will not be part of the ECAA. Easyjet and Ryanair both have EU and UK AOCs so they'll be ok even without ECAA membership.

Additionally, I assume that now that once the UK leaves the ECAA, they can charge overflight fees to EU airlines.
 
bennett123
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Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 7:21 pm

Presumably, the EU will be able to do likewise for UK carriers?.
 
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Phosphorus
Posts: 1035
Joined: Tue May 16, 2017 11:38 am

Re: UK to leave European Aviation Safety Agency

Mon Mar 09, 2020 7:37 pm

Bhoy wrote:
mxaxai wrote:

*Alternatively, the operators would need to register their aircraft overseas. Foreign registered aircraft are generally permitted to operate under the rules of the foreign agency. Reason why all Aeroflot jets are registered in Bermuda iirc.

I was under the impression Aeroflot jets were registered in Bermuda is that Russia imposed a punitive import duty to bring non-Russian manufactured Aircraft into the Country for registratiin?

Presumably that. Plus the fact that Russian AR are not convergent with FAR's nor with European equivalent. As a result, if you bring a "Western" plane onto RA- registry, and then want to remarket it elsewhere, a bridge check is needed. It's an expense that would be included in lease rates, and airlines don't want to eat it.
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mxaxai
Posts: 1990
Joined: Sat Jun 18, 2016 7:29 am

Re: UK to leave European Aviation Safety Agency

Tue Mar 10, 2020 12:35 am

VFRonTop wrote:
Does this mean that UK participation in EUROCONTROL and the ECAA are also under review?

The UK has indicated that they wish to leave ECAA, or rather, they don't want to accept the EU's conditions that come with it. The impact of this depends on the ongoing negotiations and could range from no change at all to massively restricted bilaterals.

Eurocontrol is entirely separated from the EU and includes countries like Turkey, Georgia and Ukraine. That said, the UK has never been the biggest fan of Eurocontrol as EC is supposed to handle all traffic combined - civilian or military - and the UK would rather handle military traffic themselves. There are provisions in place, though, to give member states plenty of options just how far to integrate their airspace.
klakzky123 wrote:
Additionally, I assume that now that once the UK leaves the ECAA, they can charge overflight fees to EU airlines.

Overflight fees are already at the discretion of each state. And guess what; the UK is the most expensive EU state: https://ops.group/blog/most-expensive-atc-in-europe/

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