The General Aviation Manufacturers Association (GAMA) has updated its White Paper on Brexit, the decision by the UK to leave the European Union, focusing on its impact on aviation. The paper was first published in November 2017.
Pete Bunce, GAMA president and CEO, told AIN at EBACE 2018 that despite the “Notice to Stakeholders” issues by EASA on April 13 this year being “draconian” with little explanatory detail, it was necessary first step and at least notified aerospace entities in the UK that any EASA approvals would cease to be valid from March 30 next year. He noted that GAMA had been among industry representatives lobbying the European Commission agency hard for many months on communicating the implications of Brexit, so they had sufficient time to prepare their businesses.
Although GAMA is based in Washington, D.C., Bunce said, “There is a special reason we put an office in Brussels and not Cologne [where EASA is based]. It’s where the key policy decisions are made. As soon as the Brexit vote was taken we [approached] our contacts at DG MOVE (The EC Directorate Generate for Mobility and Transport) and were thinking of what things it might affect.”
GAMA approached Pete Sorensen, EU policy officer international relations, aviation safety, to “work out the limits within which he was able to work with us, and how we should proceed.” GAMA, on its members, “started to push for guidance on the best case, worst case, those kind of things.” He added that GAMA represents aerospace manufacturers around the world along with MRO providers and suppliers.
Bunce told AIN that 460 entities in the UK have EASA approved repair station status (Part 145), with 172 being FAA approved as well. There are also 165 companies with Part 21 Design Organisation Approval under EASA. “So [Brexit has] a tremendous impact, in a situation where we still don’t have any clarity.”
He said that some are already preparing on the basis of a “worst-case scenario” whereby the UK would leave the EU without a deal that would keep it in the EASA system. “If the ‘Notice to Stakeholders’ is implemented as stated,” said Bunce, “the impact would be dramatic.”
“We’re in May now, and the UK negotiating paper is due to be in place in the next few weeks. We can’t have any more delay, given everything that has to happen [to prepare].” Bunce is nervous that politicians think the industry is able to “pick up the pieces” once they decide on the final shape of Brexit, with very little time to the leaving date. In addition, there is still no agreement on a possible Transition Period to the end of 2020.
“Companies big and small are all being held hostage to what happens at the political level,” said Brian Davey, GAMA's Brussels-based director for European and international affairs.
Meanwhile “the EC is being silent on contingencies,” he added. Bunce said it’s clear the EC and EASA are nervous of appearing to be “weak in their position” should it propose “workarounds” to help aviation firms with Brexit, such as a fast-track process from Part 145 approval to Part 145 Third Country Operator (TCO) approval.
“We don’t see anything from the [UK] CAA that they have a contingency plan [either],” said Davey. The CAA has estimated it would take seven years to transition to a state where it had all the capabilities EASA has now established covering the UK. Bunce added that the UK is a totally different scale to the likes of Norway and Switzerland, which have arrangements with the EU and EASA.
On EASA’s agreements with the FAA Bunce said, “It takes a really long time to negotiate bilateral safety agreements but if the CAA takes seven years to get to that level [of competency], how can we have an agreement?” This is despite the FAA stating that there is an “old bilateral” that it can fall back on, if necessary. Bunce said that would still require a lot of time to “organize and implement.”
Kyle Martin, GAMA director of regulatory affairs, said, “Nothing can move forward until the bigger picture moves forward.” He added that the June EC Council meeting was the next chance, with the UK presenting its negotiating paper. “But we’re not too optimistic.”
Bunce said, “GAMA wants to give its members clarity” but they are still waiting, despite it being an agenda items at several GAMA board meetings already.
In conclusion, Davey commented: “Even if there is a transition period [to the end of 2020], we still need a lot of time and there is still a cliff edge at the end of it.”