Aviation – Page 33 – John Vincent

Brexit and Aviation 34

Another busy day of government publications. Amongst the many papers to arrive have been the 3 on civil aviation published by the UK Department for Transport (DfT). These are technical notices that set out plans put in place, in the “unlikely” event that the UK leaves the EU without a deal. These links are to the technical notices on:

Generally, the advice is for the aviation industry to review potential implications for supply chains and staff with specialist qualifications. The information shows the potential impact of a no deal scenario is extremely high. There is a wish that, even with no Brexit deal there’s still enough mutual interests to keep all parts of aviation running.

However, for pan-European organisations this senario will be as destructive as an Icelantic volcano. Estimates of costs rise rapidly for everyday that no deals are implemented, recognised and working. The impact goes beyond just EU – UK relations because the EU’s existing agreements and working arrangements will no longer apply to the UK. To get over this the UK is declaring its intention to recognise EU standards of security and safety. Hopefully this will be enough for other nations aviation authorities to carry on regardless.

The UK CAA has published its own information that covers the subjects in more detail[1]. Some of the questions and answers remain open. The words: ask EASA, appear numerous times.

What is clear is that the implication of these technical measures is to duplicate activities. Certificates and licences will need to exit in European form and in UK form. A period of adaption is contemplated on the UK side, but the outcome will be the need for compliance with new national regulatory requirements. It’s rather like turning the clock back to a time before the Joint Aviation Authorities (JAA). There’s no guarantee that there will be mutual recognition even if there may be a common benefit in maintaining a level playing field.

There’s no aviation safety value in duplication. In fact, there is a potential safety down side. Given that there’s finite expertise and resources dedicated to safety work spreading those more thinly isn’t going to help anyone. If there’s divergence in processes and procedures who knows what might fall down the cracks.

It’s worth saying that during all of this change in the UK the internal market for the EU27 will continue to work. The citizens of the EU27 will continue to benifit from their common system for aviation safety and security.

[1] https://info.caa.co.uk/eu-exit/

Brexit and Airworthiness

Without going into the whole history of the last 50 years, there has been considerable success at harmonisation of aircraft certification rules in Europe. Not only at a level of the requirements and specifications to be applied by the processes and procedures used too.

Now to consider a “no deal” outcome of the negotiations between the EU and UK. This is the case where there are no working arrangements or informal agreements of any kind on the day after the assigned leaving date of leaving the European Union (EU).

In accordance with the Chicago Convention there are a series of certificates that are mandatory in international civil aviation. Those concerning aircraft airworthiness are in the articles of the convention and its Annexes, most particularly Annex 8 and its associated manual.

The complete framework of European aviation regulation is compliant with these standards. So, a European aircraft Type Certificate (TC) or a Certificate of Airworthiness (CofA) or an Airworthiness Release Tag (EASA Form 1) is recognised across the globe. To build this European system, decades of cooperative working and confidence building were invested. It’s is not only that the rules and procedures are agreed and correct, it’s also that their implementation delivers the desired results.

In a “no deal” outcome of the negotiations between the EU and UK the EU Regulations responsible for this regulatory system no longer apply in the UK. Now, I have assumed that the technical content of these regulations will be adopted lock-stock and barrel into UK law. Thus, the situation may be that the UK will not change any aspect of the rules and procedures for the issuance of a certificate on the day after Brexit.

The significant difference that arises is that the certificate issued will be a National certificate and not a European one. Thus, it will not be automatically mutually accepted by EU Member States. For existing certificates, the UK may choose to adopt all those that exist at the time of change. Nevertheless, each one of these would need to be accepted as a UK National certificate.

The European system does validate certificates from “third countries” but this is usually done under the framework of a working arrangement or a Bilateral Aviation Safety Agreement (BASA). If no such arrangement or agreement exists, then either there’s no recognition or an ad-hoc grandfathering of privileges might prevail. Such ad-hoc measure might be time limited and contingent upon the conduct of an audit.

In any event the movement of aircraft and related products, parts and appliances between the UK and EU Member States will not be as free as it is now. In the extreme worst case “no deal” there will be no movement. This would be commercially catastrophic for all sides.

Speculating about ad-hoc or emergency measure is difficult. One analogy that could shed light is that of the position of Turkey. In 2009, the Joint Aviation Authorities (JAA) was disbanded. Non-EU members of the JAA like; Norway, Iceland, Switzerland and Liechtenstein joined the European system. Turkey did not. There is a working arrangement between the EASA and Turkish DGAC[1] but it is limited. Relationships like these are subject to continuing negotiations which are not without frustration.

[1] https://www.easa.europa.eu/sites/default/files/dfu/WA%20SAFA%20Turkey.pdf

Deal or No Deal?

These articles are written to consider a “no deal” outcome of the negotiations between the EU and UK. This is the case where there are no working arrangements or informal agreements of any kind on the day after the assigned leaving date of leaving the European Union (EU). Several assumptions are made in this article:

Agreements and arrangements existing prior to 1973 have been superseded, are obsolete and are not applicable;
UK will remain a member of the intergovernmental bodies; like EUROCONTROL and ECAC;
UK will notify ICAO of its change of status in respect of Annexes to the Chicago Convention;
UK will take EU legislation into National legislation via a series of Statutory Instruments;
EU will view UK as a “third country” and
There is a common interest in adhering to international norms.

Today, civil aviation is a shared competence within the EU. That implies that if there is no specific EU legislation addressing a subject then National regulations prevail. Therefore, a good starting point is to consider the current directly applicable EU legislation.

In the regulatory spectrum there is a Basic Regulation and a series of implementing Regulations. Each Part to each implementing Regulation has its own Acceptable Means of Compliance and Guidance Material (AMC/GM). These considered to be non-binding “soft-law. Additionally, Certification Specifications (CSs) are also related to the implementing Regulations, like AMC/GM they are non-binding.

These Regulation extend over Airworthiness, Air Operations, Personnel Licensing, Air Navigation Services (ANS), Air Traffic Management (ATM), Rules of the Air, Aerodromes and Accident Investigation.

Recently, the Basic Regulation (EC) No 216/2008 has been repealed and replaced with Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91.

Here’s a list of pertinent EU Regulations with their former references:

Initial Airworthiness (Part 21).

Commission Regulation (EU) No 748/2012 of 03/08/2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisation.

Additional Airworthiness Specifications.

Commission Regulation (EU) 2015/640 of 23/04/2015 on additional airworthiness specifications for a given type of operations and amending Regulation (EU) No 965/2012.

Continuing Airworthiness.

Commission Regulation (EU) No 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances, and on the approval of organisations and personnel involved in these.

Air Crew.

Commission Regulation (EU) No 1178/2011 of 3 November 2011 laying down technical requirements and administrative procedures related to civil aviation aircrew pursuant to Regulation (EC) No 216/2008 of the European Parliament.

Air Operations.

Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

Third Country Operations (TCO).

Commission Regulation (EU) No 452/2014 of 29 April 2014 laying down technical requirements and administrative procedures related to air operations of third country operators pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

Air Navigation Services (ANS) common requirement.

Commission Implementing Regulation (EU) No 1035/2011 of 17 October 2011 laying down common requirements for the provision of air navigation services.

ATM/ANS safety oversight.

Commission Implementing Regulation (EU) No 1034/2011 of 17 October 2011 on safety oversight in air traffic management and air navigation services.

ATCO – Air Traffic Controllers Licensing.

Commission Regulation (EU) 2015/340 of 20 February 2015 laying down technical requirements and administrative procedures relating to air traffic controllers’ licences and certificates pursuant to Regulation (EC) No 216/2008.

Airspace Usage requirements.

Commission Implementing Regulation (EU) No 1332/2011 of 16 December 2011 laying down common airspace usage requirements and operating procedures for airborne collision avoidance.

Standardised European Rules of the Air (SERA)

Commission Implementing Regulation (EU) No 923/2012 of 26/09/2011 laying down the common rules of the air and operational provisions regarding services and procedures in air navigation.

Aerodromes.

Commission Implementing Regulation (EU) No 139/2014 of 12/02/2014 laying down requirements and administrative procedures related to aerodromes pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council.

Accident Investigation.

Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC Text with EEA relevance.

Occurrence Reporting.

Regulation (EU) No 376/2014 of the European Parliament and of the Council of 3 April 2014 on the reporting, analysis and follow-up of occurrences in civil aviation, amending Regulation (EU) No 996/2010 of the European Parliament and of the Council and repealing Directive 2003/42/EC of the European Parliament and of the Council and Commission Regulations (EC) No 1321/2007 and (EC) No 1330/2007 Text with EEA relevance.

There’s no doubt that the above list gives an impression of complexity. That said, a few minutes looking at National legislation immediately gives the same impression. In civil aviation, not everyone needs to know everything. Clearly, engineers need to know about airworthiness, pilots and air traffic controllers need to know about licencing and companies need to know about organisation approvals.

Keeping up-to-date requires attention to detail. At the heart of these Regulations is the international framework provided by the Chicago Convention. In that respect, the scope for change in the content of these Regulations, even when incorporated in UK legislation, is limited. Most of the listed Regulations received much input from the UK in their formation.

That is why I have assumed that even in a “no deal” situation the UK will take EU legislation into National legislation via a series of Statutory Instruments. If this does not happen there is little that can be said about what might happen. An unstable situation would result since it is not possible to replace all the above aviation regulation with another new set in the time remaining.

Next my articles will address each subject in turn.

Brexit and Aviation 33

Today, I’d like to note a couple of items that shed light on the peculiar predicament of these times.

UK Parliament has an “Exiting the European Union Committee[1]” that is appointed by the House of Commons to examine the expenditure, administration, and policy of the Department for Exiting the European Union and related matters falling within the responsibilities of associated public bodies. That’s a mouthful but it’s a committee that considers the details of the Brexit activities that the UK Government are undertaking.

Today, this committee published a report titled: The progress of the UK’s negotiations on EU withdrawal (June to September 2018), Ninth Report of Session 2017–19, Report, together with formal minutes relating to the report – HC 1554. Love the Parliamentary language. It’s not designed as a light bed time read. As I was scanning the pages for interesting material on aviation I came across the reference to a “BREXIT – Risk Assessment” by AIRBUS from June. I’d not seen this high-level 2-page document before. Then came the moment I nearly fell off my chair. To quote the text:

“Every week of unrecoverable delay would entail material working capital impact, re-allocation cost, cost for inefficient work, penalty payments to customers and up to €1B weekly loss of turnover. Despite the incremental stocks, the disruptions in a no deal Brexit situation are likely to add up to several weeks; potentially translating into a multi-billion impact on Airbus.”

My first though was – that must be a typo. One billion a week! Now, I know that AIRBUS has a healthy aircraft order book, but those costs are phenomenal. Potentially a dreadful waste that no sensible company would put up with for any longer than was necessary. I believe that would mean the UK losing its position as major civil aerospace manufacturing Country in short order.

The second item that caught my eye was the letter that ADS[2] got having written to the European Commission about the need for technical discussions to take place between the Civil Aviation Authority (CAA) and European Aviation Safety Agency (EASA) to prepare for Brexit. Basically, the formal answer is that this is on hold. I don’t find that the least bit reassuring given the time to do something useful is ebbing away. This regulatory preparation is important for either of the two scenarios – that’s a Withdrawal Agreement is ratified or that “no deal” is agreed before withdrawal date.

[1] https://www.parliament.uk/exeucom

[2] https://www.adsgroup.org.uk/reports/24195/

Brexit and Aviation 32

2903_brexit Tuesday, chief #Brexit negotiator Michel Barnier will brief the EU 27 Member States Ministers about the ongoing talks with the UK[1].

“The Ministers will discuss the state of play of the negotiations, concerning both the completion of the work on withdrawal issues and the discussions on the framework for future EU-UK relations. Ministers will also look at the annotated draft agenda for the next meeting of the European Council (Article 50) of 18 October 2018.”

An agreement on a future relationship can only be negotiated and concluded once the UK has become a “third country” with respect to the EU. That’s after 31 March 2019.

Additionally, during their EU27 Leaders’ summit in Salzburg on 19 – 20 September 2018 hosted by the Federal Chancellery of Austria there will be a discussion on #Brexit. The discussions during this informal summit will be reflected in the work and the conclusions of the next meetings of the European Council.

The preparedness notices related to aviation, published by the EU in January[2] and April[3] this year continue to be applicable. Yet, we have not seen a formal UK public response to these notices. With such slow progress the once-unthinkable prospect of a “no-deal” #Brexit is becoming a real one.

These notices set out the consequences of the withdrawal of the UK from the EU without a formal, ratified agreement. The implications are stark.

Aviation is undergoing major changes, with challenges like; the growth of air traffic, economic and environmental pressures, digitalisation, new technologies, drones, cybersecurity and other security issues. All of these are pan-European challenges. None of them can successful be addressed by one Nation alone. The regulatory framework in which aviation operates is a key factor in its performance. The chaos that a “no deal” #Brexit may bring will impact this significantly.

[1] http://www.consilium.europa.eu/en/meetings/gac-art50/2018/09/18/

[2] https://ec.europa.eu/transport/sites/transport/files/legislation/brexit-notice-to-stakeholders-air-transport.pdf

[3] https://ec.europa.eu/transport/sites/transport/files/legislation/brexit-notice-to-stakeholders-aviation-safety.pdf

Investigation

Will Brexit have a significant impact on civil aircraft accident investigation? Probably not but it will not make it easier and there are some pitfalls.

Cooperation between independent National accident investigation bodies has been a part of their make up for a long time. The international framework is dominated by ICAO Annex 13 to the Chicago Convention. At its core these standards and recommended practices are stable, well used and gets an update about every decade. In the UK, the Air Accidents Investigation Branch[1] (AAIB) investigates civil aircraft accidents and serious incidents.

In the EU, the applicable law is Regulation (EU) No 996/2010[2] – Investigation and prevention of accidents and incidents in civil aviation. Before this Regulation came into being a Directive 94/56/EC encouraged investigators to work together and apply the standards of Annex 13.

To some extent EU Regulation 996/2010 was forged because of the need to define in law the relationship between the European Aviation Safety Agency (EASA) and the 28 independent investigation bodies in the EU. The first Basic Regulation, that launched EASA had little to say on how the bodies should work together.

There’s a strong need for EASA, National Aviation Authorities (NAAs) and Civil Aviation Safety Investigation Authorities (as they are defined in the Regulation) to work together.

It becomes essential to be able to share confidential and sensitive information when accidents and incidents happen. Corrective action often needs to be taken quickly. It is the EASA and NAAs with industry who must take that action. A sound legal framework helps to ensure that information flows and responsibilities are clear.

Post March 31, 2019 the above Regulation will cease to be directly applicable. Naturally, the affected parties could choose to continue to apply its provisions. Even in the worst case “no-deal” scenario it would be unthinkable that an arrangement to share confidential and sensitive information wouldn’t be worked out.

In addition, here’s several areas where attention may be needed.

The Regulation sets-up a European Network of Civil Aviation Safety Investigation Authorities. Will UK AAIB continue to participate in that network?

EASA sets standards and approves Cockpit Voice Recorders (CVR) and Flight Data Recorders (FDR). Will UK AAIB be consulted on the amendments to standards?

Will the status of UK Investigation Reports and Safety Recommendations remain the same?

[1] AAIB is a branch of the Department for Transport.

[2] https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/384433/Regulation_996_2010_of_20_October_2010_accident_investigation.pdf

Licences

There is a buzz in the media about commercial pilots’ licences.

It’s almost as well to start with the question: why do pilots need a licence? The roots of pilot licencing go to the earliest days of flying. Quickly it was realised that specific attitudes, skills and knowledge were essential to be able to fly safely. To start with licences were not mandatory. That changed markedly when civil aviation became commercial. The need for mandatory licencing was well established in the 1940s when the International Civil Aviation Organisation (ICAO) came into being.

Today, Article 32 “Licenses of personnel” of the Chicago Convention is clear:

a) The pilot of every aircraft and the other members of the operating crew of every aircraft engaged in international navigation shall be provided with certificates of competency and licenses issued or rendered valid by the State in which the aircraft is registered.
b) Each contracting State reserves the right to refuse to recognize, for the purpose of flight above its own territory, certificates of competency and licenses granted to any of its nationals by another contracting State.

Today, the EU Basic Regulation and its implementing rules apply in the UK. Today, we have a harmonised system with mutual recognition in 32 European States[1]. We respect and recognise each other’s pilot licences.

Tomorrow, post March 31, 2019, the EU Basic Regulation will not apply in the UK[2]. Tomorrow, UK law may be a straightforward copy of the exiting EU law. At that time mutual recognition is not guaranteed unless an agreement is in place.

So, EU will need to decide – will it recognise a National licence from a “third country” that uses the “same” rules? Will any recognition be dependent upon rules continuing to be harmonised? What level of standardization auditing will maintain confidence that the system works?

I can’t answer these questions (yet).

POST: It’s 3-years on from this posting. A licencing imbalance has prevailed during that time. As of 1 January 2023, the UK will cease to recognise EASA-issued licences and certificates for the operation of UK (G-registered) aircraft. Whatever happened to hopes for mutual recognition? Pilot licensing | BALPA

[1] Licences issued by the National Aviation Authorities (NAAs) according to a set of common rules applied by the European Aviation Safety Agency, known as EASA – Flight Crew Licensing (EASA-FCL).

[2] https://ec.europa.eu/transport/sites/transport/files/legislation/brexit-notice-to-stakeholders-aviation-safety.pdf

Brexit and Aviation 30

The summer holidays are ending, and the prospect of autumn is all around. Fortunately, the summer weather continues, and the BBC PROMS[1] have one more week to run. The House of Commons returns on Tuesday, 4 September[2]. Already, UK MPs are lining up in front of the media with 101 opinions on where Mrs May is right, wrong, sad, mad and maybe the only game in town.

Where the political pendulum will settle is anyone’s guess. To give it a jolt there’s the Party conference season to come too. I’ll be down in Brighton this year.

In the statements coming from negotiations in Brussels[3], last week there’s some constructive and positive sounding words. The UK’s White Paper contains the recognition of the European Court of Justice as the ultimate arbiter of EU law. This sticks in the throats of Brexit fundamentalists. But it is pragmatic, as it’s the only way that 27 remaining EU Member States can be bound. This does open the door to the UK’s wish to remain a member of the European Aviation Safety Agency (EASA).

Typically, several airlines release their late spring schedules for the following year in September. That task is going to be tricky this year given the uncertainty that continues as negotiations unfold. The schedule from 1st of April 2019 will likely mean that tickets sold will have terms and conditions saying this is subject to a new regulatory environment.

In my view the notion that UK airlines will be unable to fly into and out of the Europe is not plausible[4]. There’s been a lot of sensationalist media coverage and some badly written papers about what is theoretically possible as a worst-case scenario. There may be fewer routes, higher costs and restrictions, but it’s overwhelmingly in the interest of both sides that flights continue post-Brexit. It’s clear that the EU is not going to ignore its own legal framework, but parties reciprocate when it’s in their interests to do so.

What my advice? Plan a good winter break somewhere in Europe. The days of cheap flights to unusual destinations maybe ebbing away. At least from us in the UK. It’s sad to see such a curtailment of freedom of movement. The blame lies firmly on the shoulders of a generation of unimaginative politicians.

[1] https://www.royalalberthall.com/

[2] https://www.parliament.uk/about/faqs/house-of-commons-faqs/business-faq-page/recess-dates/

[3] http://europa.eu/rapid/press-release_STATEMENT-18-5403_en.htm

[4] http://www.travelweekly.co.uk/articles/308215/easyjet-remains-confident-on-brexit

Brexit and Aviation 29

The negotiations continue but the water is muddy brown and impenetrable. EU-UK technical level meetings took place on Wednesday and Thursday this week. The assurance has been given that there are few remaining issues with the Withdrawal Agreement and the future relationship discussions. On Friday there’s to be a principals’ meeting with Michel Barnier, the European Commission’s Chief Negotiator, and Dominic Raab, UK Secretary of State for Exiting the EU.

Raab is confident a deal between UK and the EU is: “within our sights.” But the news this week has been up and down like a yo-yo. One minute there’s optimism and broadly 80% of the Brexit Withdrawal Agreement is concluded. Next minute we must remind people that a “no deal” scenario is getting closer and closer. There’s so much day-to-day game playing that it’s difficult to be either optimistic or pessimistic.

I must congratulate presenter Hannah Fry. Last night, by chance, I watched her BBC 4 programme called “The Joy of Winning”. That was an hour well spent. She successful opens our eyes to game theory. Not an easy thing to do in a way that keeps people watching. Adventures in maths don’t normally top the viewing figures. For this one-hour I’d recommend you give it a go.

Made me think – is anyone applying game theory to the Brexit negotiations? And if they are what does each side judge to be a win?

Switching to Aerospace. A win for Europe’s Aerospace sector would be either no Brexit or an outcome that maintains much of what has been won over decades. Europe’s Aerospace is a success. It employs at least 120,000 people in the UK[1]. The fact is the industry is highly integrated within the EU. Billions are done in international trade. And a common rulebook makes that work.

UK Brexit Secretary Dominic Raaab maybe an improvement on his predecessor. In these final months, I hope he has a sound winning strategy that is a win-win for both the UK and EU.

A so called “no deal” Brexit would be an unmitigated tragedy. It would be evidence of abject failure in negotiations. It would signal to the world a grave weakness at a time of pressure and venerability.

Is “no deal” part of a game? Like the MAD that we lived through in the 1980s – that’s the Mutually Assured Destruction of the Cold War. I don’t suppose we will know until the UK Government papers are released in 30 years’ time. I prefer to think that it is a form of game theory otherwise I must concede that we are run by ideological extremism in favour of Brexit at any cost. Not a nice thought to end the week on.

[1] @ADSgroupUK

Brexit and Aviation 28

The EU has already produced a series of notices on “Brexit preparedness”. It’s now the turn of the UK to publish notices. Taking the current course, the UK plans to leave the EU on 29 March 2019. What happens at that point remains a subject of much debate and discussion. Many hours of media time are dominated by speculation and those desperate to influence public opinion.

Brinkmanship is the apparent escalation of threats to achieve one’s aims. For brinkmanship to work, both sides escalate their threats. We never seem to be on the brink of anything good. Most “brinks” are on the edge of catastrophise, cataclysm, disasters, ruin, suffering or harm.

Pro-Brexit people often dismiss any such talk as, so called: “Project Fear”. That’s disingenuous because it’s an unscrupulous attempt to hide what brinkmanship is by definition. A threat, or outcome that no one sensible wants is ineffective unless it’s credible. It’s no good blaming anyone for this dreadful state of affairs. If the doctrine of – nothing is agreed until everything is agreed – continues, then this is what will happen.

Also, its foolish to think that this situation will only exist in the UK – EU relationship. It’s most likely to be encountered whenever the UK is negotiating with a larger Country or region. So, if Brexit happens we had better get used to it.

Naturally there’s the potential for errors or misjudgements. History is littered with brinkmanship gone wrong. It always better to have a life jacket than not have one but whether it will be any use or not is quite another matter.

Today, civil aviation is not on the list of how to prepare if the UK leaves the EU with no deal[1].

There are some inferences that can be taken from the notice on “Regulating medicines”. Basically, that’s the UK will continue to apply and accept the application of EU regulations even if there’s no deal. Ideally, the UK would like to remain part of the European Medicines Agency (EMA).

An attempt at humour, and the Bacon Lettuce and Tomato sandwich scenario after Brexit, fell flat. That said, most of the scenarios for no deal Brexit are Bl**dy Ludicrous Threats (BLTs). Better to stop this folly altogether and adopt a more practical, pragmatic and proportionate approach to EU Membership.

[1] https://www.gov.uk/government/collections/how-to-prepare-if-the-uk-leaves-the-eu-with-no-deal