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Brexit and general aviation, UK leaving EASA, etc (merged)

Jacko I think the seed corn is already there:

http://publicapps.caa.co.uk/docs/33/CAP%201414%20-%20ANO%20review%20CRD.pdf

But the elephant in the room has been these changes have only been applicable to national Annex 2 aircraft, if the remit is expanded to EASA type on G Reg in UK airspace….

Last Edited by Balliol at 26 Jun 08:47
Now retired from forums best wishes

But the elephant in the room has been these changes have only been applicable to national Annex 2 aircraft, if the remit is expanded to EASA type on G Reg in UK airspace….

I was just going to say this is Annex 2 only. If the CAA allowed FAA STCs for ICAO CofA planes, as Australia reportedly does, that would be the biggest piece of dynamite in GA for a long time. For a start, it would eliminate the crazy stuff like 2×GNS. It would eliminate most of the EASA STC moneymaking business, too, which is why there has been massive resistance to such a move within the EASA world. All of the “customers” in the business want this but they can’t have it.

If the CAA allowed this, it would be applicable to G-regs worldwide.

However I doubt UK CAA will do this because it would massively p1ss off EASA, and they have stated they want to remain EASA-aligned. Well, as far as is politically required i.e. making useful exceptions where they are reasonably below the radar And allowing FAA STCs would chuck a hand grenade into EASA.

Administrator
Shoreham EGKA, United Kingdom

Prior to EASA existing, many European NAAs had separate bi-lateral agreements with the U.S. In the case of the UK CAA, FAA STCs were accepted without additional technical investigation in accordance with BCAR B2-2 using a simple AD282 application which resulted in an Airworthiness Approval Note being issued. It typically took 4-6 weeks and cost about £250 in 2003. EASA are gradually coming back to what had been in place for many years before.

Incidentally, if installing dual GNS-W in N reg aircraft, you follow an FAA Part 23 AML STC owned by Garmin. It’s because Garmin didn’t choose to validate it with EASA that some EU companies have chosen to do new EASA STCs.

Avionics geek.
Somewhere remote in Devon, UK.

wigglyamp wrote:

Prior to EASA existing, many European NAAs had separate bi-lateral agreements with the U.S

Norway still do. According to that agreement anything produced in the US and approved by the FAA, will also be approved in Norway and vice versa, as far as I know. A Norwegian registered US made aircraft does not have to be in accordance with EASA regulations to be airworthy according to LT (NCAA). It can equally well be in accordance with FAA (technical) regs by the looks of it (but don’t take my word for it , I’m an homebuilt experimental dude). It was talk about that agreement being replaced by a common EASA thing, but I don’t think that has happened.

I had a look. the agreements are still in place, and also includes modifications, repairs etc.

edit:
Found a cool document from the FAA about all this here. The FAA has an agreement with the EU, but NOT with EASA. Consequently Switzerland and Norway have separate agreements with the FAA. Which of course means the UK would also need a separate agreement with the FAA rather soon (and Norway and Switzerland), or the UK and the US/Norway/Swiss cannot do business.

Does EASA represent any other countries on aviation matters when working
with the United States and the FAA?
Yes. The non-EU European countries, Iceland, Liechtenstein, Norway, and
Switzerland, are identified as “EASA associated countries.” EASA, as in the case with
EU Member States, is the single approval authority for design related activity within the
associated countries. Responsibility for production related activity still rests with the
individual national aviation authority. While not an EU member, the associated
countries retain their sovereignty to conclude international agreements/bilateral
agreements with third countries. However, they may not conclude agreements which
would contradict the interests of EASA. Since these countries are not in the EU, they
are not eligible for the full range of EASA membership entitlements.
The U.S. government has bilateral aviation agreements (BAA) in place addressing
airworthiness certification with Norway and Switzerland. For validation projects
involving these countries, EASA will act as the technical agent for those BAAs, but the
U.S./EU Agreement is not applicable

So it really looks like any US STCs etc are automatically valid also in Norway and Switzerland (as long as they don’t contradict the interests of EASA, whatever that means, the interests of German aircraft repair station lobbyists?)

Last Edited by LeSving at 26 Jun 12:02
The elephant is the circulation
ENVA ENOP ENMO, Norway

Very interesting. So I wonder why I had to seek out EASA STC’s for everything I did to my airplane when in fact the US one would have been sufficient? It appears to me that Switzerlands CAA does not quite follow this but instead tries to be even more Easa conform than EASA itself.

For Britain, my expectation is that they will need to stay within EASA, probably as an associated member like those listed, and therefore nothing will change. Britan will need to negotiate an aviation agreement with the EU anyhow, probably not unlike the one we have which gives Swiss carriers and Swiss operators (private or not) the same privileges as EU ones, with the exception that the Swiss CAA officially has no say in the legislative process.

LSZH(work) LSZF (GA base), Switzerland

In the case of the UK CAA, FAA STCs were accepted without additional technical investigation in accordance with BCAR B2-2 using a simple AD282 application which resulted in an Airworthiness Approval Note being issued

Astonishing! The CAA AAN database (still online) must be a goldmine of stuff. A pity the search feature on it is rubbish; with no consistency of word usage stuff can appear under all sorts of headings. Did this database (terminated c. 2003 AFAIK) ever appear as a PDF?

Who could apply to the CAA? Was it only a CAA Level 2 company? If so, one would have to add the company’s fee on top.

According to that agreement anything produced in the US and approved by the FAA, will also be approved in Norway and vice versa, as far as I know. A Norwegian registered US made aircraft does not have to be in accordance with EASA regulations to be airworthy according to LT (NCAA). It can equally well be in accordance with FAA (technical) regs by the looks of it (but don’t take my word for it , I’m an homebuilt experimental dude).

It would surprise me if Norway ever accepted FAA STCs directly. Accepting FAA STCs at time of US to Norway registry transfer is however normal; a different case totally. Somebody would have mentioned this by now, I am sure.

Also, those treaties were problematic to say the least. I discussed this with a then JAA Director (Fergus Wood) some years ago. JAA killed all those treaties, c. 1999. However the US never recognised JAA (they still struggle to recognise EASA – they regard it as not representing the individual countries’ interests, ho, hum, I really cannot see why… – and the UK vote will hardly help ) and they worked from their end as if they still existed. Also many European countries, the UK included, continued to sort-of recognise them, behind (the toothless) JAA’s back. EASA killed the treaties even more officially (having EU’s backing) but I know a DAR guy in the USA whose day job is preparing certification under those treaties (well it was last time I was in touch, maybe 2 years ago).

So it really looks like any US STCs etc are automatically valid also in Norway and Switzerland (as long as they don’t contradict the interests of EASA, whatever that means, the interests of German aircraft repair station lobbyists?)

The bit in brackets (my bold) basically means No I simply don’t believe it.

Administrator
Shoreham EGKA, United Kingdom

I don’t know about Norway, but straight acceptance is not unprecedented….as you point out Australia accepts FAA STCs, and in fact all foreign STCs including EASA at face value with no additional paperwork….they are treated as if they had been issued by CASA…

https://www.casa.gov.au/standard-page/awb-00-16-issue-1-acceptance-foreign-supplemental-type-certificates-stcs

YPJT, United Arab Emirates

Peter wrote:

The bit in brackets (my bold) basically means No I simply don’t believe it.

I think you are right, but the reason is more as Mooneydriver mentioned. It’s more the results of a political game, and the EU (Sweden and Germany in particular) is the main trading partner for Norway, so it is best to be a good boy (unlike the UK ) There is no good reason US STCs cannot be taken as is, this is no stranger than taking EASA STCs, EASA regulations and so on.

The elephant is the circulation
ENVA ENOP ENMO, Norway

172driver wrote:

Can someone enlighten me as to the difference – as some here claim – between EASA and the EU. On my new EASA license it says:

Finally got my EASA FCL one day after the JAA expired Anyway, this is what a non-community EASA FCL looks like:

The elephant is the circulation
ENVA ENOP ENMO, Norway

LeSving wrote:

It was talk about that agreement being replaced by a common EASA thing, but I don’t think that has happened.

AIUI, EEA Agreement should take priority over other treaties. It doesn’t forbid them and it isn’t an absolute rule, but a serious reason is needed for deviation. Otherwise, EU could get upset. However, I’m by no means an expert on this.

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