BRUSSELS, Dec 13 (Reuters) - The United States is urgently calling for clarity on which aviation safety regime the British aerospace industry will operate under after the country leaves the European Union, to avoid increased certification costs for airlines and manufacturers.
The head of the U.S. Federal Aviation Administration (FAA) is in London and Brussels for talks with both sides on whether Britain can retain a role in the European Aviation Safety Agency (EASA) and said the FAA needed clarity on that by early next year.
"The UK's status (within EASA) does evaporate upon exit from the EU so the question becomes 'what is going to replace it?"' Michael Huerta told reporters before meeting with the EU executive, the European Commission.
The FAA and EASA are responsible for certifying aircraft components from manufacturers in the United States and Europe and automatically recognise each other's safety certifications.
If Britain quits EASA its own aviation regulator, the Civil Aviation Authority (CAA), will need to assume EASA's role in supervising manufacturers, raising questions about whether it has the capacity to do that.
"If there is now no EASA regulatory oversight over the United Kingdom's manufacturers we have no way of relying on EASA's oversight and certification so therefore we would need to make our own findings, manufacturer by manufacturer. And that is highly disruptive, highly costly for manufacturers to ensure that they can comply with FAA standards for manufacturing," Huerta said.
The United Kingdom has said it expects to remain part of EASA, although that raises thorny questions about the jurisdiction of the EU's top court, which London does not want to submit to.
An official from the UK's CAA said on Monday that the agency was not planning for a new independent aviation safety system in the UK.
"We have to wait and see what the outcomes are going to be but we've made very clear to our government what we are actually looking for and how we might seek to achieve that," said David Kendrick, Head of Airline Licensing, Consumer and Markets Group, CAA at a conference in Brussels.
Huerta said it was "absolutely critical" to know how aviation safety would be governed in the UK.
"Will the United Kingdom continue to be an active participant in EASA, will it subscribe to EASA rules or is it their desire to set up something different and separate from that?" he said.
"Our preference would be not so much about a particular outcome but more about having certainty about what the outcome is so that we have a target that we're shooting for." (Reporting by Julia Fioretti; Editing by Greg Mahlich)