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

But an agreement over cloud clearances in class D is hardly likely to make any difference.

Andreas IOM

So as you know, I own an fly a G-REG plane and live in France – where my plane lives, I also have a French issued EASA license with an instrument rating. So I asked the DGAC the question with Brexit, what changes for me? This is the reply I got. (I have blanked the names of the people to contact as to not upset anyone at the DGAC) but think the info might be useful. (it’s google translate so I have added clarifications rather than rewritten in what I assume to be correct English :-))

Regarding the subject of airworthiness:
If the CAA UK issues him (* edit – the plane) an ICAO level certificate of airworthiness then he (The plane again) can continue to fly in France.
The rules for continuing airworthiness will be those defined by CAA UK, in particular with regards to the license / approval that a mechanic / workshop must have to work on the airplane.

Regarding the subject of pilot license:
Again it is the CAA UK which will decide the type of license to hold to fly on the plane and in particular if it recognizes French EASA licenses.
If you have any questions on the pilot license subject, please contact Ms. (removed) in copy.

Regarding the OPS subject:
The NCO regulations still apply.
The supervisory authority will be the DSAC if, in fine, the United Kingdom is considered a third State.
If you have any questions on the OPS subject, please contact Mr. (removed) n copy.

LFHN - Bellegarde - Vouvray France

That is all exactly spot on

The UK has stated they will honour EASA papers for at least 2 years, and probably for ever.

With licenses issued or validated by the State of Registry, you can fly worldwide.

A very correct ICAO response.

Administrator
Shoreham EGKA, United Kingdom

LFHNflightstudent wrote:

Regarding the OPS subject:
The NCO regulations still apply.

They do, but that’s not the full answer. I would be surprised if you did not also have to follow UK OPS regulations.

ESKC (Uppsala/Sundbro), Sweden

I would be surprised if you did not also have to follow UK OPS regulations.

Are there any of relevance, different from EASA ones, I wonder?

Administrator
Shoreham EGKA, United Kingdom

No yet. But remember we doing all that to be independent and different. So I’m sure UK Ops will change to show how independent we are.

Nympsfield, United Kingdom

IMO the ops regulations will remain much the same as they are now I.e. you will need to follow the most restrictive between the country of registration and the territory being overflown. That is how N reg aircraft fly in Europe now. There might also be the case that the regulations governing the pilots licence may also need to be taken into account. Eg An N registered aircraft, flown on a UK licence over France needs to follow the most penalising/restrictive regulation of the 3.

France

Indeed, but that was always the case, to the extent that the State of Registry controls what the aircraft can do, anywhere in the world, and decides what privileges (if any) a foreign license can be used for on that aircraft.

That is just standard ICAO.

ICAO also gives every Contracting State absolute sovereignity over its airspace (otherwise none of the ~200 countries would have signed it, and bear in mind a significant % of them still engage in cannibalism ) and this means local regulations take precedence where they are stricter.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

Any treaty Brussels signs with the UK will be based on a “level playing field” which is the EU’s raison d’etre

Sure – the bad news for our friends in the UK is, however, that in the European concept of a “level playing field” team Europe can send 460 Mio. players on that field while UK has only 66 Mio.

LFHNflightstudent wrote:

(The plane again) can continue to fly in France.

Depending on how you read this statement this is either exactly ICAO or going quite a bit beyond ICAO: If you read it literally “fly in France” it’s exactly ICAO but I assume not answering the original question.

What’s relevant for G-reg owners in France and all other EASA-states is not, if their planes are still allowed to fly in France, but if they may be operated and stationed in France – that is quite a different question and if the CAA is honest, they can’t answer it yet because there is not even a concept for a bilateral EASA/UK-CAA agreement for the future.

And even if they will be allowed to be stationed/operated within EASA-land, there’s no protection against additional administrative burdens (e.g. something like the infamous German “Zuverlässigkeitsüberprüfung” but applied to owners/operators/planes) that require additional paperwork every x months or even every flight.

Germany

but if they may be operated and stationed in France – that is quite a different question and if the CAA is honest, they can’t answer it yet because there is not even a concept for a bilateral EASA/UK-CAA agreement for the future.

France has no long term parking restrictions on non-EU foreign regs. Only Denmark and Norway have. No agreement is required. France is full of N-regs for example.

France proposed max 90 days’ parking for N-regs in 2004. When it reached a certain political level, they dragged out a scapegoat and sacrificed it. Apparently, Dassault (which back then operated the government there, reportedly ) said they would lose 50% of their business. The UK tried something similar in 2005. I remember those days well…

something like the infamous German “Zuverlässigkeitsüberprüfung” but applied to owners/operators/planes) that require additional paperwork every x months or even every flight.

What is that? Germany has no long term parking restrictions either.

Only homebuilts / Annex 1 are restricted, but they are restricted in most of Europe. A foreign reg (EU or not) homebuilt cannot be based in France for more than 28 days.

If I had a certified G-reg in Denmark or Norway I might be concerned but even then it is highly unlikely to be a problem since N-reg is hugely politically provocative, due to Part 91, freelance maintenance, etc which is basically what Brussels and various national CAAs hate (freelance capabilities, equated with dodgy work, which of course doesn’t exist under Part M ) and due to endless trade wars with the US which also brought us MacD, KFC, John Wayne, Trump, and all the other symbols of the unacceptable face of capitalism The UK, in comparison, will continue something like Part M, if not precisely Part M, because lots of people have vested their livelihoods in that system and the suppression of freelance maintenance here in the UK is pretty well complete, especially above 1200kg.

Administrator
Shoreham EGKA, United Kingdom
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