The UK will leave the European Union Aviation Safety Agency (EASA) on December 31, when the transition period ends for the country’s departure from the European Union (EU). The UK Department for Transport (DfT) confirmed the plans over the weekend in a short statement after transport secretary Grant Shapps unexpectedly shared the news with U.S. publication Aviation Week in a March 6 interview.
The abrupt change in policy dashes the hopes of the UK’s aviation industry, which has collectively expressed a strong preference for staying within the EASA's jurisdiction. Industry groups had hoped that the UK would follow the example of Switzerland, which, despite not being an EU member state, is a part of EASA. The decision raises serious questions about the willingness of leading aerospace manufacturers to keep production in the UK due to potentially burdensome requirements to get separate UK type certification and approvals.
“Being a member of the European Aviation Safety Agency is not compatible with the UK having genuine economic and political independence,” said a DfT spokesperson in a written statement. “We will maintain world-leading safety standards for the industry, with the Civil Aviation Authority (CAA) taking over these responsibilities and will continue to work with colleagues in the EU to establish a new regulatory relationship.”
UK aerospace, defense, and space industry group ADS expressed disappointment at the government’s decision to abandon EASA membership. “We have been clear that continued participation in EASA is the best option to maintain the competitiveness of our £36 billion aerospace industry and our access to global export markets,” said ADS chief executive Paul Everitt. “UK influence in EASA contributes to raising standards in global aviation, supports collaboration with our international partners, and helps make our industry attractive to the investment it needs to be home to the development of a new generation of advanced aircraft technology.”
Everitt indicated that he felt the government has changed course, moving away from earlier indications that it would seek to keep the UK in EASA. “Government had promised it would consider harmonization where it is in the UK interest and will be led by the evidence on the future of aviation safety regulation,” he said. "We are disappointed that it has not taken a more ambitious approach. It is essential that it works with us to deliver a regime that does not put jobs at risk in an industry that employs 111,000 people in highly-skilled roles across the UK.”
Industry lobbyists now are urging the UK government to agree to a Bilateral Aviation Safety Agreement (BASA) with the EU, as it has with several other countries, including the U.S., Canada, Brazil, and Japan. They argue that such an agreement should result in the CAA's standards not deviating much from EASA's because the two agencies have indicated they remain closely aligned on all aspects of safety regulation.
“[UK] Industry supported continued membership of EASA, but we were always clear this couldn’t just result in the UK being a dumb follower of EU rules,” said the Airlines UK trade association. “We urge that negotiations start as soon as possible on a BASA with the EU, so that this can be concluded by the end of December. Crucially, the starting point must be the current rule set for commercial aviation, which the CAA played such a key role in establishing.”
What remains unclear is how the UK government intends to ensure that the CAA controls the resources to resume responsibilities for regulation and certification that it has not held since EASA formed in 2002. The agency’s last annual report, for the financial year ending on March 31, 2019, talked of “contingency arrangements for a no-deal EU-exit” but did not specifically mention the prospect of the UK leaving EASA.
The CAA reported that revenues declined last year by more than 21 percent, to £150.2 million, and an operating loss of £2.7 million—albeit largely due to exceptional payments required for the agency’s pension scheme. The UK government has yet to explain how the CAA will find the financial resources to support its significantly expanded role from the end of this year.
“[The CAA] has been planning for this outcome since the 2016 referendum [in which the British electorate voted to leave the EU] and we are prepared to take over regulatory responsibilities from EASA,” said CAA director Tim Johnson. “There will be no immediate changes to aviation regulations at the end of this year, because of these preparations.”
Leading aircraft manufacturers Airbus and Boeing have yet to indicate how the UK’s departure from EASA might affect their plans for manufacturing in the UK. Both companies, and the wider aerospace supply chain, might well feel discouraged by the potentially onerous necessity to seek UK certification in addition to EASA approval.
In January, Airbus indicated that it hoped to keep its main UK civil aircraft production facilities at Broughton and Filton, but at the time the most of the industry assumed that the UK would remain a member state of EASA. Airbus employs around 13,500 people in the UK.
The terms of the wider trade agreement now being negotiated between the UK and the EU might well influence the willingness of leading aerospace OEMs to remain in the country. The two sides appear far apart, and the UK’s Conservative government bluntly insisted on its unwillingness to be bound by any EU requirements for common regulations. It has indicated that if no progress in trade talks happens by June, it may unilaterally end negotiations triggering the so-called hard Brexit that most of the business community has implored the government to avoid.
A “Brexit Risk Assessment” document published by Airbus in June 2018 said the company would likely see a serious disruption in the flow of parts and/or discontinued airworthiness of equipment made in the UK in the event of a no-deal Brexit. "[A no-deal Brexit] would force Airbus to reconsider its footprint in the country, its investments in the UK and at large its dependency on the UK,” said the European aerospace group.