Thread by @KidTempo

Jet engines are not my area of expertise, but I am an auditor (and not the accounting kind) so let's do this thing.

(Bear in mind that I'm making some generalisations here and I haven't had time to actually do any research so don't take any specifics as gospel)

https://twitter.com/JamesHarris1u/status/1049213365778825216

"Important" industries tend to have one or more international agencies or regulators. For aviation, the ICAO sits at the top with the FAA, the EASA, and probably a whole load of national agencies as the actual regulators.

At the highest level, all regulators generally align their regulations (on procedures, parts, testing, etc.) up to a certain point, at least in so far as to accept each others certification. This allows a EASA-certified plane to fly within the FAA jurisdiction, and vice-versa.

EASA-certified plane parts must also comply with EASA regulations, be inspected and certified by the EASA. To fit a non-certified part would cause the plane to lose its certification.

I don't know if the EASA tests/audits are all conducted using EASA inspectors/auditors, or if they accredit regulators at a national level. Lets pretend that they do and the UK's Civil Aviation Authority (CAA) has been accredited by the EASA.

(Just making it absolutely clear that the CAA is something I made up - I think it used to, it may still do - it may or may not actually exist)

As a national regulator, the CAA may be accredited to certify some or all of the EASA's regulations. It may be limited to part of the scope - for example it can certify the maintenance, but not manufacturing procedures, etc - or it could have full accreditation and do it all.

The CAA would be regularly audited by the EASA to ensure that it is enforcing the regulations and following the test guidance etc. The inspectors/auditors themselves may be separately accredited by the CAA, the EASA, or both.

Now, if, as a result of #Brexit, no provision has been made to continue the relationship between the CAA and the EASA, then whatever the CAA is responsible for is no longer certifiable.

CAA-certified aeroplane parts cannot be used.
CAA-certified maintenance is no longer valid.
Without certification planes won't fly - not because they can't, but because they will be uninsured - and no company will risk flying without insurance (if it's even legal to do so).

Can the CAA get re-accredited by the EASA? Yes (in fact, it may not even lose its accreditation in the first place). The simplest option is that the CAA continues functioning as before as an EASA-accredited regulatory body...

... but, there are caveats.

The CAA would have zero input into the decisions made by the EASA. It would have to follow EASA direction in all things and essentially be a subsidiary agency. Parts manufacturers may have to either get EASA certification, or CAA and EASA certification.

The CAA may be stuck between a rock and a hard place since any changes to national laws could invalidate their certification. If, for example, environmental laws were changed, the CAA would still have to enforce the EASA standard - or worse, if they were changed then...?

The fact that ministers would be able to change rules and regulations with their Henry VIII powers means they could, without warning, ground the entire industry - possibly inadvertently (but also as a bellicose gesture to the EU, the twats).

The alternative would be for the CAA to try to be accepted as a top-tier accredited regulator - that would probably mean getting the approval of all the other regulators. This wouldn't be so hard, since presumably the CAA would effectively be starting with EASA regulations.

Of course, at this higher level there would probably have to be nation-state agreements about ring-fencing parts of the regulation so they can't be changed by mischievous ministers - that takes time (think months rather than days).

Both of the above options assume that the CAA is accredited to the full scope of the EASA regulations (and that it exists). If it is only accredited to provide certification for a partial scope, then it needs to put in place regulations, processes and procedures for the gaps.

The CAA may need to get hold of qualified inspectors, auditors and administrators to cover the functions currently covered by the EASA. For highly specialised roles, this may be no easy task.

Once it has done all that, it has to persuade the other aviation regulators that it is competent to certify the full scope.
This is not just certifying the UKs planes to fly in other's airspace and use their airports, it's servicing other nation's planes when at UK airports.

In addition to the above, it *still* doesn't mean that UK aero parts will be accepted for use in the EASA, FAA, etc. Regulators are very protective of their jurisdiction - manufacturers will need to get EASA certification to sell parts for EU-built planes (in addition to CAA)

The CAA becoming a top-tier regulator will take much longer than just becoming an extension of the EASA - maybe a year or two at least.

And if the CAA doesn't exist... well it's possible to build up a regulator from scratch, but it won't be easy and it will take a lot of time and money. I'm not sure how the UK will get by without air travel for 2+ years.

It can short-cut and just copy and paste regulations from someone (like the EASA) but it will struggle to find enough competent people to fill the roles. It could also pay the EASA large sums of money to be the UK's regulator while it builds it's own, thats an (expensive) option.

The point I'm trying to make here is that while it's not impossible for the UK to divorce itself from the EU's agencies, it is time consuming, expensive, and fraught with difficulties. If anyone tells you it's simple, they're either idiots or liars, or both.

This is just one example, at a *very* simplified level (and I'll just reiterate that it's mostly made up to try to illustrate the concept of accredited regulators - it is not factually based).

There are literally dozens of industries that have the same question marks hanging over them - some of them very important ones like Pharma & Medical, Agriculture, Chemicals, and many more.

Some will be fine - they're already following a global standard and their regulator is either global, or they are under the jurisdiction of a national regulator accredited at the global level. Many- and that tends to include the "important" industries - are not.

In a NoDeal #Brexit - huge sections of the UK economy will be in turmoil - not (just) because of the government having no tbi-lateral trade agreements and having fucked up the customs arrangements...

... but also because they will suddenly be without certification and cannot legally be sold in the countries they export to. Negotiating bi-lateral trade agreements will be, in many cases, only half of the battle.

The UK shall also need to establish an accredited regulator and have its certifications recognised, which could take as long, if not longer.

#Brexit - bad.

Yeah, I'm an auditor. Nobody likes auditors turning up, especially when they least expect it.