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

The UK is peculiar with its central data collection via NHS. No such thing exists in most other countries.

It doesn’t exist in the UK either… my understanding is this:

The NHS has a computer record which your GP can access. Also a hospital you go to can access it, when actually needed e.g. you turn up with a missing arm and they want to see if you are on warfarin.

Separately from that, if you go to a hospital, and say they stick some titanium in your leg, that hospital will start a paper file on you. Nobody outside that hospital will see that file and, for practical purposes, only you (personally) can get to see it and e.g. photograph it, under close supervision. Others in the business can “sneak in” and take a look but e.g. a surgeon who did you as a private job in the (NHS) hospital cannot, in theory, see the record. The file will be appended to but only if you go back to that same hospital. Your GP doesn’t get that file.

So it is all over the place.

AFAIK various attempts to centralise it have all failed, basically due to a lack of “buy-in” from the people who would have to use it, hacking concerns, project mismanagement, the NHS being unable to specify what they want and thus getting ripped off by big IT companies at every opportunity, etc. Also centralised records would need to be held on computer which is way too complicated when actually doing some job on somebody. Handwriting on a bit of paper is much easier. And e.g. implantable items are bar-coded and the barcode is peeled off and stuck in the file. In some hospitals it is scanned so some seem to use a computer record to some degree. Any paper then needs to be scanned in… more staff…

There is a number of pilots here who work in the NHS and maybe they can correct / fill in the above.

Obviously you could bypass the system but to be sure you would need to get treatment outside the UK and if they ask for the details of your GP you either say you don’t have one (unlikely but possible) or refuse to tell them. The really big mistake is to tell anybody you are a pilot; then even an optician gets a heart attack and IME will refuse to supply glasses other than to a fresh prescription – even if you insist they are for driving a car (you have to go mail order, or find an optician run by a gentleman from India )

Administrator
Shoreham EGKA, United Kingdom

UK appears to remain EASA member?

From here:
Britain must follow Brussels rules on aerospace after Brexit to protect industry, says House of Commons committee – The Independent

LFHN - Bellegarde - Vouvray France

I don’t think there’s any doubt the UK WANTS to stay part of EASA. The question is whether the EU will allow it. I know there are other countries who are not part of the EU but are part of EASA but remember that there is a political point at play; that the UK must be punished for leaving.

Darley Moor, Gamston (UK)

Neil wrote:

that the UK must be punished for leaving.

Although I am sure that the UK Brexit supporters would like to portray it that way in order to make excuses for themselves, the fact is that the UK are trying to get all the advantages from the EU without any of the obligations that go with it. It started in 1973 when they joined, and culminated with “I want my money back”.

Now that the UK is leaving, the EU can start a new relationship with the UK from a blank sheet of paper. It used to be the UK demanding special arrangements to remain. Now the EU can set the conditions for them to join. After the UK having twisted the EU’s arm for so long, it is quite refreshing. Let us please enjoy this divorce for a bit before we contemplate a renewed relationship.

Last Edited by Aviathor at 19 Mar 21:41
LFPT, LFPN

Leaving politics and ideology aside, I guess big industry player in both sides of EU or UK WANT the UK to stay in EASA mainly for cost efficiency and to maintain regulatory alignment under “common law”, so as Neil says the question is whether UK can stay in EASA without accepting ECJ rules…the other two alternatives are ICAO or copy past of FAA or brand new UK national system that is accepted by 200 countries.

Remember that the legacy JAA system (which was not driven by EU political integration: it includes non-EU states) has been pushed by big business for the same industry reasons but never succeeded as it did lack ECJ oversight to provide a “legal framework”.

Paris/Essex, France/UK, United Kingdom

Aviathor wrote:

Now that the UK is leaving, the EU can start a new relationship with the UK from a blank sheet of paper. It used to be the UK demanding special arrangements to remain. Now the EU can set the conditions for them to join. After the UK having twisted the EU’s arm for so long, it is quite refreshing. Let us please enjoy this divorce for a bit before we contemplate a renewed relationship.

But you have made Neil’s point…The EU will try to make the UK pay for leaving. Which is its right of course but may have unintended consequences. I can’t believe the UK will actually leave EASA but then I didn’t think it would leave the EU so what would I know?

EGTK Oxford

Remember that the legacy JAA system (which was not driven by EU political integration: it includes non-EU states) has been pushed by big business for the same industry reasons but never succeeded as it did lack ECJ oversight to provide a “legal framework”.

JAA probably worked well enough for the bit it worked for e.g. pilot licensing (JAR-FCL PPL etc) and parts certification (the JAR-1 form). These were the parts which were of advantage to all players. What it didn’t work for was stuff for which the power of the “EU central government” was required to force through stuff which was too controversial for some countries to swallow.

My view is that the UK will remain in EASA simply because extracting it will be so complicated and with so little gain to anybody (except pure spite, as shown in e.g. post #3) that nobody will want to actually do it. It is a powerful threat though if you think through the implications (all UK commercial pilot training and all UK aircraft parts manufacturing, including those making Airbus parts, totally wiped out, for example)… and it does mean the UK CAA (which has lost most of its competent people in recent years and cannot possibly go back to running their old show) now has to totally bend over the Brussels barrel for the next 2 years or so while holding a large jar of vaseline I am sure they would have never otherwise allowed e.g. the termination of NPPL rights for certified aircraft (due April 2018) which will ground so many pilots with no safety gain whatever.

Administrator
Shoreham EGKA, United Kingdom

Aviathor summer it up well. In the end it will depend mainly on what other silly ideas and demands the UK comes up with to harm itself. There is zero interest on the continent to kick the UK out of EASA, but there was zero interest on the continent for the UK too leave the EU in the first place.

From a regulatory point of view everything but continued full EASA membership of the UK would be an unmitigated disaster for all parties involved. For pilots and aviation as a whole it could get very unpleasant.

Everything but continued full EU membership will be an unmitigated disaster for the UK anyways.

Low-hours pilot
EDVM Hildesheim, Germany

One interesting option for the UK, should it leave EASA, is to move to the US system.

FAR145 companies can be anywhere in the world and issue 8130-3 forms, and can inspect parts made by others an issue these (so FAA145 companies would make a lot of money – there is always a winner ).

The US does not geographically restrict training towards FAA licenses. It is only checkrides which have been difficult or impossible in Europe and that is due to unrelated reasons. The US also accepts training outside the US done by non-US (ICAO qualified, probably) instructors. However, the UK is in ICAO so could issue its own licenses anyway.

I am sure the CAA has worked out some fallback positions. The obvious ones would be a return of the ability to fly a G-reg on any ICAO license, but extend it to full IFR.

Administrator
Shoreham EGKA, United Kingdom

Peter wrote:

I am sure the CAA has worked out some fallback positions. The obvious ones would be a return of the ability to fly a G-reg on any ICAO license, but extend it to full IFR.

A fallback on ICAO for UK aviation is the same as fallback on WTO rules for goods or services: same as no UK tariffs on overseas imports, while it open the door for any licence holder to fly on G-regs, or any N-Reg to fly in G-airspace…it will not solve the other problem of UK aviation exports, the other viable alternative if UK leaves EASA is some FAR equivalent, as you mentioned it FAA rules has no territorial limits (many countries just copy past it) but again JAR was pushed by countries who want but did not to have a say in federal regulations (JAA countries viewed this as protectionism vs ICAO pillars that can’t be enforced by law)

Peter wrote:

What it didn’t work for was stuff for which the power of the “EU central government” was required to force through stuff which was too controversial for some countries to swallow.

Agree on this, the whole EASA thing went south when EASA Basic Regulations (inherited from EU principals and laws) did not allow for national provisions or domestic laws, so from lawyer perspective it seems that flying a C152 on a NPPL does violates some EU laws…

Paris/Essex, France/UK, United Kingdom
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