Londra – Il voto favorevole all’uscita dall’Unione Europea, espresso dalla maggioranza degli elettori britannici partecipanti al referendum consultivo del 23 giugno 2016, ha colto di sorpresa l’intero panorama politico dell’Isola, in primo luogo i “Remainers” ma anche, e incredibilmente, i “Leavers”.
Molta acqua è passata sotto i ponti da quel giorno di giugno, con colpi di scena più o meno attesi – le dimissioni di Nigel Farage, la caduta del governo Cameron, l’ascesa di Theresa May e il giudizio dell’Alta Corte sul diritto del Parlamento a votare l’autorizzazione ad invocare l’Articolo 50 del TUE – ma, dal punto di vista della vera e propria uscita del Regno Unito, poco o nulla è successo. I maggiori alfieri del “Leave” si sono dileguati all’indomani del voto e l’assenza di un piano di azione è diventata sempre più palese.
Questo, almeno, fino allo scorso 17 gennaio. Dal podio di Lancaster House, infatti, Theresa May ha delineato il suo piano per l’uscita del Regno Unito dall’Unione Europea. Lo scopo di questo articolo è di avanzare alcune ipotesi sull’impatto di quello che si può ribattezzare “Piano May” sull’industria dell’aviazione civile. Per far ciò inizieremo con una breve disamina dei diversi modi con cui è possibile, per un paese, rapportarsi con l’UE; dopodiché effettueremo un breve excursus sul piano May, e, infine, cercheremo di capire quale impatto potrà avere una “Hard Brexit” sull’aviazione civile continentale.
I rapporti UE-mondo: modelli a confronto
E’ possibile, ad oggi, identificare tre modelli di massima per descrivere i rapporti tra Unione Europea e paesi terzi, differenti tra loro su due punti chiave: accesso al mercato comune europeo e libertà di movimento della popolazione (reciproca).
Il primo modello è quello svizzero. La Confederazione ha sottoscritto un accordo di libero scambio con l’UE, grazie al quale può accedere al mercato europeo. L’accesso, però, è solo parziale – gli istituti bancari, per esempio, devono avere una base in Europa per operare con l’Unione – mentre il diritto alla libera circolazione e residenza dei cittadini di entrambi i contraenti è garantito. I più ricorderanno, infatti, il referendum del 2014 con cui i cittadini elvetici hanno chiesto di ridurre il diritto di ingresso nel paese degli immigrati europei, in particolar modo dei “frontalieri”; il cui risultato non è stato ancora implementato anche a causa delle rimostranze europee.
Il secondo modello è quello norvegese, per molti versi identico a quello svizzero se non per una premessa: la Norvegia non ha sottoscritto un accordo di libero scambio, optando invece per accedere al mercato unico tramite la membership dell’EEA, European Economic Area. La teoria cambia, ma la pratica no; anche in questo caso l’accesso è solo parziale e la libera circolazione delle persone rimane garantita.
L’ultimo modello è quello di un paese come la Russia, che non ha un accordo di libero scambio con l’UE e, allo stesso tempo, limita l’accesso al proprio paese ai soli cittadini dotati di visto. Esistono numerose gradazioni di colore, un’infinita scala di grigi tra questi tre modelli, in base al grado di libertà accordato al movimento di merci e persone.
Il piano May
Si è spesso sentito parlare di “Soft” e “Hard Brexit”. Cosa si intende? Soft Brexit è senza dubbio il modello svizzero-norvegese, mentre Hard Brexit è il distacco completo. I punti provenienti dal discorso di Lancaster House descrivono indubbiamente una Hard Brexit: uscita dal mercato unico, pur ricercando un accordo di libero scambio, fine dell’unione doganale, restrizioni all’emigrazione dal Continente, opt-out dalla Corte di Giustizia europea.
Non rientra nello scopo di questo articolo giudicare la bontà del Piano May, le sue possibilità di successo o l’impatto che avrà sulle economie europea e britannica; ciò che preme, invece, è capire che effetto avrà sull’aviazione civile.
Brexit e aviazione civile: un impatto su due fronti
L’impatto di una Hard Brexit sul settore dell’aviazione civile può essere sentito su due fronti. Il primo sarebbe la perdita dello status di vettore comunitario da parte delle compagnie aeree britanniche; il secondo, correlato al primo, è l’accesso allo spazio aereo – e agli aeroporti – comunitari.
Vettore Comunitario
La definizione di vettore comunitario è contenuta nel regolamento 1008/2008 del Parlamento e del Consiglio, “recante norme comuni per la prestazione di servizi aerei nella comunità”. In base al regolamento, un vettore comunitario è in possesso di una licenza di esercizio e di un Certificato di Operatore Aereo (COA or AOC nella dizione inglese), emesso dalle autorità di un paese membro, non solo dell’UE ma anche dell’EASA, European Aviation Safety Agency, creata col regolamento 1592 nel 2002.
E’ chiaro che, uscendo dall’UE, il Regno Unito – e la sua Civil Aviation Authority – perderebbero automaticamente la propria appartenenza all’EASA. Di conseguenza i COA emessi dalla CAA non saranno più considerati come europei. Questa situazione renderebbe di fatto obbligatorio, per EasyJet, trovare un nuovo COA comunitario in tempi brevi, operazione che potrebbe essere complicata da azioni di lobbying da parte di compagnie, considerate come “campioni nazionali”, che avrebbero tutto da guadagnare dalla sparizione di un player importante, e penetrante, come EZY nel mercato aereo civile comunitario.
Non sfuggirà che vettori di paesi non-UE – Svizzera, Norvegia e Islanda – sono tuttavia considerati come vettori comunitari. Questo è possibile in quanto ai paesi EFTA è concesso di partecipare alle attività EASA, a condizione di aver stipulato accordi che garantiscano la diretta applicabilità del diritto UE in materia all’interno delle loro giurisdizioni. Questa opzione, però, non sarebbe possibile per il Regno Unito, considerando il desiderio di Theresa May di uscire completamente dal sistema dell’Unione Europea di cui EASA fa parte.
Un altro ostacolo sulla via della definizione di vettore comunitario è quello della proprietà comunitaria del vettore aereo. Il già citato regolamento 1008/2008, all’articolo 4 punto f, specifica che, per avere un COA europeo, una compagnia aerea deve essere detenuta per oltre il 50% da parte di “Stati membri e/o i cittadini degli Stati membri”. Il controllo deve, inoltre, essere effettivamente in mani europee. Il punto f include inoltre il caso in cui il controllo della compagnia sia ottenuto attraverso imprese intermedie.
L’impatto di questa norma è particolarmente importante per International Airlines Group, il gruppo che comprende British Airways, Iberia, Aer Lingus e Vueling. Pur essendo basata a Madrid, più del 70% delle shares nella compagnia sono allocate sulla borsa di Londra, e la maggioranza dei grandi shareholders è basata nel Regno Unito. E’ impossibile stabilire con certezza quali saranno le mosse di IAG per far fronte a questo scenario, in cui la maggioranza della proprietà di BA – e anche delle altre tre compagnie non basate in Inghilterra – si trovi a non essere più considerata come comunitaria, ma l’ipotesi di uno smembramento di IAG, per assicurare la comunitarietà di Aer Lingus, Iberia e Vueling è probabile, come tra l’altro speculato da Michael O’Leary qualche giorno fa.
Accesso al mercato europeo
Il secondo problema per le compagnie britanniche in caso di Hard Brexit è l’accesso al mercato europeo, un problema non da poco se si considera che, per il solo aeroporto di Heathrow, 30% dei passeggeri sono in transito, spesso da e per l’Europa.
L’oramai noto regolamento 1008/2008 regola anche il funzionamento del mercato unico dell’aviazione civile europea, cui è dedicato il titolo III. Il regolamento concede ai vettori comunitari di operare rotte interne al territorio UE senza bisogno di permessi o autorizzazioni. In altre parole vengono “abrogate tutte le limitazioni alla libertà dei vettori aerei comunitari di prestare servizi aerei intercomunitari”. Tutto ciò verrebbe a mancare in caso di Hard Brexit, in quanto gli aeroporti britannici smetterebbero di far parte dell’Unione Europea. Il loro accesso da parte delle compagnie europee, e d’altro lato l’accesso agli aeroporti continentali da parte delle compagnie britanniche, non sarebbe più libero e immediato ma limitato a quel sistema di accordi bilaterali creato a seguito della conferenza di Chicago del 1944.
Il Regno Unito potrebbe, in linea teorica, sottoscrivere accordi individuali con i 27 paesi UE per l’accesso ai loro aeroporti, ma dal 2003 questa opzione è di fatto preclusa da una decisione del Consiglio che ha dato alla Commissione Europea competenza esclusiva per la negoziazione di nuovi accordi bilaterali tra tutti i paesi UE e il partner terzo; in questo caso, il Regno Unito. Un ipotetico accordo Open Skies tra UE e Regno Unito vedrebbe, molto probabilmente, due differenti agende a confronto; da un lato Londra sarebbe interessata ad avere una situazione quanto più simile a quella attuale possibile (libero accesso UK-UE, cabotaggio intra-UE e domestico). Dall’altro è facile immaginare che la posizione europea non sarà ugualmente aperta, se non altro per il ridotto appeal del mercato interno britannico rispetto a quello europeo. Non si può nemmeno escludere una forte lobbying da parte dei vettori europei per limitare l’accesso delle compagnie britanniche (British Airways in primis) per ridurre il suo traffico feeder e instradare il suo mercato intercontinentale sui propri hub, qualcosa che sta succedendo anche per il mercato finanziario. Va inoltre detto che un accordo Open Skies non è qualcosa che si può completare in poco tempo; quello tra UE e USA richiese quasi tre anni e mezzo di negoziazioni, dall’ottobre 2003 al marzo 2007.
Conclusioni
Dal punto di vista dell’aviazione civile il piano-Brexit di Theresa May presta il fianco alle stesse critiche – incertezza, sconvenienza economica, rischio di marginalizzazione – che si possono muovere anche da altri settori (finanza, commercio e turismo). Abbiamo visto come un’Hard Brexit può portare alla perdita dello status comunitario per le compagnie britanniche, possa portare allo smembramento di IAG e costringere la creazione di un nuovo accordo Open Skies tra Unione Europea e UK. Non si può nemmeno affermare che un’Hard Brexit possa servire a eliminare la burocrazia EASA in quanto il rispetto delle norme UE, o di altri strumenti a loro equivalenti, è una delle condizioni per l’accesso al mercato UE, col risultato che numerosi paesi hanno deciso di introdurre le regole EASA all’interno dei loro ordinamenti (si veda il caso della Turchia), un caso lampante di quello che alcuni ricercatori chiamano “fax democracy”.
In definitiva, dal punto di vista dell’aviazione civile, Brexit sembra sottostare a nessun’altra logica se non a quella populistica.
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