Category: British

Brexit and Aviation 40

There are some documents that are essential for the smooth operation of aviation.  When it comes to moving products, parts or components of aircraft around the world the Authorised Release Certificate is key.  This certificate must be trusted and accepted by those who receive it.  Even with an international framework that describes how this is done this acceptance is not automatic.

In Europe, the format of Authorised Release Certificates has been harmonised after decades of work.  In addition, work has been undertaken harmonise the instructions for completing these standard release forms.

The EASA Form 1[1] is the Authorised Release Certificate provided by a manufacturing organisation (Part-21 POA holder) for stating that a product, a part, or a component was manufactured in accordance with approved design data.

What that means is that the form accompanies an aircraft product, like say an engine, and if it’s not valid that product cannot be used.  Organisations doing maintenance, repair and overhaul must keep detailed records when working on an aircraft.

As an example, in Europe we may have a British manufactured aircraft engine being fitted to a Spanish registered aircraft in a German hanger by an engineer who holds a Dutch licence.   For this to happen in an approved manner the paperwork must be accurate, complete and valid.  If the EASA Form 1 coming with the British manufactured aircraft engine is not recognised, then the work described above cannot take place.

I’ve described this situation because there’s the possibility that in a full “No Deal” Brexit there will be no automatic recognition of a British issued EASA Form 1.

This is not the first time I’ve mentioned the EASA Form 1[2].   The reason for mentioning it again is that I became more acutely aware of this problem when visiting a major conference and exhibition in Amsterdam.  On Wednesday last, I chaired a one-hour panel discussion on: “Regulatory Changes and Challenges”.  This included a Policy Specialist (Brexit) from the UK CAA.   He described the preparatory work that’s being done and some of the differences in positions between UK published papers and EU published papers.  To date, the UK CAA and EASA are not in formal talks.  Both are ready to initiate technical discssions but this is being held up by the lack of clarity in relation to the withdrawl agreement (See exchange of letters from June/July).

I conclude that rash headlines that suggest a “No Deal” option is doable are way off the mark.  The regulatory maxim – trust but verify – must be satisfied one way or another.

[1] https://www.easa.europa.eu/faq/19466

[2] https://johnwvincent.wordpress.com/category/form-1/

 

Brexit and Aviation 39

IMG_E4817
Accident Recorder

Reading reports of air accidents is not everybody’s cup of tea.  Nevertheless, the insights they contain are a constant reminder that no matter how safe civil aviation maybe, it can always be better.  There’s always something to learn.

This week, US accident investigators issued a report on what could have been an immense catastrophe.  Planes full of passengers came within 60 feet of each other as an Air Canada flight[1] was about to land on a taxiway by mistake.  This happened just before midnight on 7 July 2017 in San Francisco.  The US National Transportation Safety Board (NSTB) said that: “Over 1,000 people were at imminent risk of serious injury or death.”

As people have commented this is a stark reminder of the worst civil aviation accident that ever occurred.  In 1977, 593 people died when two Boeing 747 planes collided on a runway in Tenerife on the Canary Islands.

Because of the San Francisco incident, the NTSB is considering recommending that accident cockpit voice recorders record the last 25 hours of flying time.  The current US rule is for 2 hours and then the recording overwrites.

So, what has this got to do with Brexit?

After a series of accidents in the last decade, including the Malaysian Boeing 777 mysteriously lost over the ocean (flight MH370), Europe acted.  A detailed rulemaking process resulted in a EU Regulation[2] that includes key changes to mandatory accident flight recorder rules.  These required changes to planes that must be made in a practical manner to meet a deadline specified in the EU Regulation[3].  The rule applies to large planes manufactured after 1 January 2021.  Clearly, that date is after Brexit’s infamous 29 March 2019.  I cannot imagine that, whether the UK is in the EU or not, it would make any changes to this planned implementation date.  However, a mandatory action, like this one must be incorporated in the applicable national legislation.  That is how it would be applied to British registered planes.

That’s the interesting point.  Will all those European actions with implementation dates after 29 March 2019 be copied into UK law?  It would be good to see the answer “yes” written down.

POST POST NOTE: I hear the answer is “no”.  Although all the applicable European law will be copied into UK law a mandatory date that is in the future will be edited out.

 

[1] https://www.ctvnews.ca/mobile/canada/air-canada-close-call-came-a-few-feet-from-possibly-being-worst-aviation-accident-in-history-1.4131146

 

[2] COMMISSION REGULATION (EU) 2015/2338 of 11 December 2015 amending Regulation (EU) No 965/2012 as regards requirements for flight recorders, underwater locating devices and aircraft tracking systems.

 

[3] ….with respect to the carriage of CVRs with extended recording duration for large aeroplanes, provision should be made for the introduction of CVR with a recording duration of 25 hours on board aircraft, manufactured after 1 January 2021, with a maximum certificated take-off mass of over 27 000 kg.

1st rule – Count

At moments of fundamental change, I wonder: what is the first rule of politics?  A lot the possible first rules of politics are cynical or so basic it’s easy to forget their importance.  I like James Hacker from the BBC series Yes Minister: “Never believe anything until it’s officially denied”.  Another rule in that vein is: “It’s never the crime, it’s always the cover-up.”  One of the more useful first rules, attributed to a US politician, is: “You can’t win unless you’re on the ballot.”  That rule I’ve often practiced.  It doesn’t matter how low the likelihood of winning a vote maybe the simple fact is that; first your name must be on the ballot paper.

Here’s a first rule that’s fundamental in a democracy.  Lyndon B Johnson’s first rule of politics is one of the best, namely: “practitioners need to be able to count.”  Commentary and speculation fill enormous amounts of air-time and space but in the end the kind of Brexit we get, if at all, will be down to a count.

Learn to count as a basic first rule.  Even with the most fantastic deal, if the votes are not there to make it happen it will not happen.  That means; European and British politicians lining-up in Parliament to vote for a deal.  It means; Countries lining-up to ratify a deal.  It means; getting from A to B without too many major hiccups.

Reports are that UK Government whips are in talks with 25 Labour MPs to push a deal through Parliament.  May’s Cabinet is giving her one last chance to sell a Brexit plan.

The run up to the 18 October, European Council (Art. 50) will see complex arithmetic being done repeatedly.  Will the sums add up?  And if they don’t why shouldn’t the question be put back to the people?

Anyone able to count can see that the current situation is extremely precarious.  My personal judgement is that the current optimism, that there will be a non-disruptive Brexit Withdraw Agreement, that satisfies enough of the key players is inappropriate.

Maybe that’s why it’s being reported that the European Commission plans a fast-track a process to address the potential turmoil of a “No Deal” Brexit.  That would mean putting in place emergency means to amend rules in just a few days.

There’s wisdom in being prepared.

 

Brexit and Aviation 36

No week goes by without Brexit developments.  This week has been no exception for European aviation and aerospace.  In the background there’s been the UK Conservative Party conference in Birmingham.  All that has been revealed is that we are still in limbo land or a limbo in the air, as one might say.

The UK Government technical papers for a Brexit ‘No Deal’ scenario for Aviation Safety, Flights and Aviation Security have been out for several days.  The variety of different commentaries ranges from the don’t bother – this will never happen to the downright cataclysmic grounding of all flights.

Nevertheless, the impact of a “no deal” scenario is still being understated because of the long-term regional repercussions.  The lines on the map that divide up airspace in Europe are changing.  If other nations, see that we can not deal with that reality why would they open their skies to us?

The Royal Aero Society have updated their thoughts on the implications of Brexit[1].

On the rules for slot allocation at airports, the current rules for the allocation should remain unchanged in the event of “no deal”.  However, a proposed “recast” of the current EU Slot Regulation is planned.  A problem arises in that the UK will not have a say on future EU legislation to create a market for slots and this has its own downside.

On the profesional aviation personnel side, concerned aircraft engineers are seeking information about a non-negotiated EU exit.   British issued Licenses that are now valid in the EASA Member States, will not be valid in those States as of midnight (00h00) on 29 March 2019 unless a deal is done.

Now the EU institutions are engaged in identifying and putting in place new preparedness measures in anticipation of Brexit.  This week it is worth taking note that EASA has started to process applications for Third Country approvals from existing UK approval holders[2].  There’s additional administration and costs but at least organisations holding recognised approvals have a pathway to retaining those approvals.

On a subject that may at first glance seem unrelated the European Aerospace Associations have announced a Safety Management System (SMS) Industry Standard[3].   Here we can see the practical advantages of having a common rulebook.

During my time at the UK CAA, I was a member of the Prospect Union[4] (Formerly IPMS).  I’m pleased to see their recent publication on the future of aviation and Brexit “safety and resilience – not a race to the bottom”.  One of their recommendations is new to me and I must admit the idea hadn’t occurred to me before.  It is “breaking up the Civil Aviation Authority and establishing a new UK Aviation Safety Agency” thus further separating the functions of economic regulation and safety regulation.  Somehow, I don’t think that’s the biggest concern just now.

[1] https://www.aerosociety.com/news/a-no-deal-brexit-the-aviation-implications-part-2/

 

[2] https://www.easa.europa.eu/brexit-negotiations

 

[3] https://www.asd-europe.org/aerospace-associations-announce-safety-management-system-sms-industry-standard

 

[4] https://www.prospect.org.uk/

 

Brexit Expo

Truly we are in strange times.

Earlier this year, I did the tour of the Royal Albert Hall.  Yes, I would recommend it even though it’s part of the standard London tourist trail.  The story of the building is fascinating.  How and why it got built.  The person to thank for it is Prince Albert of Saxe-Coburg and Gotha, the husband and consort of Queen Victoria.  This forward-thinking German was a great supporter of public education.

The legacy of the Great Exhibition of the Works of Industry of All Nations of 1851, was the Hall and the Museums in that quarter of London.  The Crystal Palace was the first World’s Fair.  Albert died suddenly in December 1861.  Much of the money, coming from the Great Exhibition, that was allocated to build the Hall was spent on his memorial.

On the South Bank of the river Thames lies the legacy of the Festival of Britain.  This took place in the summer of 1951.  We need to remember that Britain was still in the grips of post-war food rationing[1] at that time.  The plan was to celebrate the centennial of the 1851 Great Exhibition.  Unlike the Great Exhibition, the Festival of Britain was about promoting British architecture, arts, science, technology and industry.  In late 1951, as Churchill was returned as MP, his first move was to clear the South Bank site believing the project to be socialist propaganda.

So, the history of great exhibitions and festivals is a chequered one.

The next World’s Fair is planned for 2020 in the UAE.  A site has been chosen between the cities of Dubai and Abu Dhabi.  132 Counties, including the UK, have announced their participation in the 2020 World’s Fair.

Today’s Conservative proposal for a 2022 Festival of Britain is strange to say the least.   Apparently, funds have been allocated and, in Party conference week, the PM is hoping to appease Brexit supporting MPs with this retro-adventure.  Unsurprisingly, Social Media is lighting up with ridicule.  Some see Theresa May dressed up as Britannia and handing out goodies to all commers.

Whatever the merits of large exhibitions and festivals surely it makes more sense to have a greater presence in world-wide events than it does to build domestic palaces?  If Brexit goes ahead or not, Britain must market what it does.  The audience is the world.  Shows of nationalism are unlikely to archive any positive or useful goals.  Just more division.

This light-weight Conservative proposal is misguided and wasteful.

 

[1] http://news.bbc.co.uk/onthisday/hi/dates/stories/july/4/newsid_3818000/3818563.stm

 

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

 

Brexit and Aviation 31

It’s now under 200 days until the end of the Art. 50 Brexit negotiating period.  I’m guessing that’s why we have had an absolute deluge of technical guidance papers popping out of the UK Government[1].  Although many are in the “unlikely event of the UK leaving the EU without a deal” it’s almost as if that’s the aim.  Incidentally, some papers drop the “unlikely” altogether.

If only this huge effort could have been channelled towards something useful.  Certainly, to apply so much civil service effort to health and education would have been a much better idea.

13 September 2018 has been a busy day for the Government’s publications people.  As yet, there’s no paper on my favourite subject: Aviation.  That’s still in the works.

There’s a hint of what maybe to come.  Here’s some words form the paper on vehicle Type Approval.

“After March 2019 if there’s no deal.  In a no deal scenario, type-approvals issued in the UK would no longer be valid for sales or registrations on the EU market. EC type-approvals issued outside of the UK, would no longer be automatically accepted on the UK market.  This means that affected manufacturers would need to ensure that they have the correct type-approval for each market.”

So, duplication, extra costs and other such waste is on the way.

Here’s a random list of the papers published:

Haulage permits and trailer registration

Arrangements for future haulage permit and trailer registration schemes after leaving the European Union (EU).

UK nationals in the EU: essential information

Information on the rights and status of UK nationals living and travelling in the European Union (EU).

Passport rules for travel to Europe after Brexit

Advice for British passport holders in the unlikely event of the UK leaving the EU without a deal.

How to prepare if the UK leaves the EU with no deal

Guidance on how to prepare for Brexit if there’s no deal.

‘No deal’ Brexit advice for businesses only trading with the EU

HMRC letters to VAT-registered businesses only trading with the EU that explain changes to customs, excise and VAT in the unlikely event that the UK leaves the EU without a deal.

European Regional Development Funding if there’s no Brexit deal

How current and future European Regional Development Fund projects would be affected if the UK leaves the EU with no deal.

Trading goods regulated under the ‘New Approach’ if there’s no Brexit deal

How trading in harmonised goods regulated under the ‘New Approach’ would be affected if the UK leaves the EU with no deal.

Upholding environmental standards if there’s no Brexit deal

How businesses and others regulated through environmental quality standards would be affected if the UK leaves the EU with no deal.

Travelling to the EU with a UK passport if there’s no Brexit deal

Check whether you would be affected by changes to rules for British citizens travelling to some European countries after March 2019 if the UK leaves the EU with no deal.

Recognition of seafarer certificates of competency if there’s no Brexit deal

How seafarers would be affected if the UK leaves the EU with no deal.

Merger review and anti-competitive activity if there’s no Brexit deal

How merger review and investigations into anti-competitive activity would be affected if the UK leaves the EU with no deal

Accessing public sector contracts if there’s no Brexit deal

To explain how existing or potential bidders for UK public contracts and public sector buyers would be able to access and publish future public procurement contract opportunities if the UK leaves the EU with no deal.

Using and trading in fluorinated gases and ozone depleting substances if there’s no Brexit deal

How businesses dealing with fluorinated gases (F-Gases) and ozone depleting substances (ODS) would be affected if the UK leaves the EU with no deal.

European Social Fund (ESF) grants if there’s no Brexit deal

How organisations receiving European Social Fund (ESF) grants would be affected if the UK leaves the European Union (EU) with no deal.

Industrial emissions standards (‘best available techniques’) if there’s no Brexit deal

How standards for emissions from industry affected by the Best Available Technique (BAT) regime would be affected if the UK leaves the EU with no deal.

Reporting CO2 emissions for new cars and vans if there’s no Brexit deal

How vehicle manufacturers would be affected if the UK leaves the EU with no deal.

Travelling in the Common Travel Area if there’s no Brexit deal

Confirmation that the Common Travel Area arrangements and the associated rights and privileges of British and Irish citizens are protected if the UK leaves the EU with no deal.

Vehicle type approval if there’s no Brexit deal

How vehicle and component manufacturers would be affected if the UK leaves the EU with no deal.

Driving in the EU if there’s no Brexit deal

How holders of UK driving licences would be affected if the UK leaves the EU with no deal.

Trading under the mutual recognition principle if there’s no Brexit deal

How importing and exporting non-harmonised goods would be affected if the UK leaves the EU with no deal.

Getting an exemption from maritime security notifications if there’s no Brexit deal

How shipping companies would be affected if the UK leaves the EU with no deal.

Travelling with a European Firearms Pass if there’s no Brexit deal

How travelling with a European Firearms Pass would be affected if the UK leaves the EU with no deal.

Data protection if there’s no Brexit deal

How the collection and use of personal data would change if the UK leaves the EU in March 2019 with no deal.

Trading in drug precursors if there’s no Brexit deal

How trading in drug precursor chemicals would be affected if the UK leaves the EU with no deal.

Appointing nominated persons to your business if there’s no Brexit deal

How appointing a nominated person to carry out duties on your behalf when selling certain goods would be affected if the UK leaves the EU with no deal.

Running an oil or gas business if there’s no Brexit deal

How oil and gas energy businesses would be affected if the UK leaves the EU with no deal.

Funding for UK LIFE projects if there’s no Brexit deal

How organisations receiving funding under the EU LIFE programme would be affected if the UK leaves the EU with no deal.

What telecoms businesses should do if there’s no Brexit deal

How the telecoms regulatory framework would be affected if the UK leaves the EU with no deal.

Mobile roaming if there’s no Brexit deal

How leaving the EU without a deal would affect mobile roaming in EU and EEA countries.

Connecting Europe Facility energy funding if there’s no Brexit deal

How applying for and receiving energy grants from the Connecting Europe Facility (CEF) fund would be affected if the UK leaves the EU with no deal.

Broadcasting and video on demand if there’s no Brexit deal

How the rules for broadcasters and providers of video on demand services would change if the UK leaves the EU with no deal.

[1] https://www.gov.uk/government/brexit

 

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

 

Mettle and Mulligrubs

My last post had a glimmer of optimism about it.  As the week progresses the basis for that optimism is subsiding.  Slowly but surely.  One cause is the endless, wholly erroneous diatribe of macho language that bleeds from the Brexit supporters.  So, much effort and energy are being expended provoking conflict, heightening tensions and blaming others.

Constant uncertainty of the Brexit clock ticking is doing damage, even as we speak.  The health of manufacturing confidence has reached a low.  Contingency measures are kicking-in as companies move out of the UK.  Hard working, tax paying, long-standing EU nationals are drifting away.

As real impacts are being felt by real people, so our politics seems more unreal.  The UK is divided between people who are head-down studying, training or working and frantic groups that are fighting ancient battles.  Politically Left or Right there’s a myopic obsession infecting public life.

Former governor of the Bank of England, Lord King has branded Brexit preparations as: “incompetent”.  He’s coming from a position of supporting Brexit.  My answer to him is the earthy historic phrase: you can’t make a silk purse out of a pig’s ear.  The poor of preparation started the day an “advisory” referendum was proposed and driven through by a gambling PM.

Now, we have the ridiculous situation of the Brexit secretary Raab saying those in Parliament worried about warnings of damage to the UK car industry: “show more mettle”.  Again a 17th century phrase.  Maybe it’s time to revive some other historic words and phrases from that era.

Government is telling a: “Banbury tale” which is a form of: “cock and bull” story.  That’s a ridiculous story, or a tale that rambles on without going anywhere.  How apt for Brexit.  Particularly considering that David Cameron’s constituency was in Oxfordshire.

I’m always astonished how many Brexiters are “mulligrubs”.  That’s people in an exaggerated bad mood all the time.  How they keep it up being so sullen when they “won” the referendum in 2016 is beyond belief.  That word rolls off the tongue so maybe it’s worth reviving.

The political media is full of “pickthanks”.  That’s gossiping tell-tales who spreads malicious rumours to carry favour.  I can see why that one died.  There are better words for such people but many of them are not to be used in polite company.

Brexit isn’t an answer to our current predicament.  It’s a symptom of a much deeper problem.  The longer we avoid that reality the worse the situation will get.  Regrets are not enough.  We need serious action to rethink.  Sign-up[1].

[1] https://www.peoples-vote.uk/

 

Britain deserves better

Post-Brexit Britain will be more bureaucratic. The recently published Government papers are full of new regulatory regimes, doubling up of registration and extra processes for British business and consumers.  When Ministers say, like Dominic Raab: “the UK will be better off outside the EU in any scenario…” we all know these are meaningless words.  It’s his job to say that sort of nonsense even if this is turning reality on its head.

For the Conservatives it’s too late to change direction.  They know that their negotiating strategy has fallen apart.  Focusing on the negative, like threats of a “no deal” have done, has alienated potential partners.  During negotiations, blaming people for intransigence has been a diplomatic blunder of the first order.  It’s reinforced the solidarity of the potential partners.

The first batch in a series of Technical Notices on “no deal” assume a great deal of good will on the part of the EU.  Some of them ignore the constraints that apply because of existing legislation in Europe.  In an emergency, circumventing Regulations can be done but its going to be hard if the only reasons are ideological and pressures are like a game of Russian roulette.

The UK voted to leave the European Union on 23 June 2016.  The world of early 2019 will not be the same as the world of early 2016.  Populism remains but its not gathering any head of steam.  It’s a minority of ideological radicals who keep pushing their cherished project.  We don’t have to accept their view of the world.

We need a #PeoplesVote.  But we need a positive campaign about the benefits of European solidarity.  A campaign must present the facts and expose the lies of the last referendum.  Britain deserves better.