Air Safety List 2

It may seem obvious that there should be an Air Safety List that bans airlines that do not sufficiently met international standards. It’s a right that exists within the Chicago Convention[1]. The first words of the convention concern sovereignty. Every State has complete and exclusive sovereignty over their airspace. From the first days of flight the potential use of aircraft to wage war was recognised. Thus, it could be said that the first article of the Chicago Convention existed even before it was written down and agreed.

However, it’s similarly recognised that the future development of international civil aviation has always depended upon agreements between States. Without over-flight and permission to land in another country there is no international civil aviation.

I do remember some agonising over having an explicit list of banned countries and airlines. In a liberal democracy choice is greatly valued. Here the choice concerns passengers being permitted to board aircraft from another country where there is knowledge of safety deficiencies related to the operation of the aircraft of that country. Should the law make that choice for the air traveller, or should the air traveller be free to make an informed choice?

There lies the crux of the matter. How do ordinary citizens, without aviation safety expertise make judgements concerning complex technical information? Understanding the implications of failing to meet the International Civil Aviation Organization’s Standards and Recommended Practices (SARPs)[2] is not so easy even for aviation experts.

Additionally, there is the issue of third-party risks. It would not be wise to permit foreign aircraft, whose safety is not sufficiently assured, to fly over a nation’s towns and cities.

Regulatory legislation was framed not only to put airlines on the Air Safety List but to take them off the list too. In fact, sometimes this is harder law to frame. In this case the decisions must be made in a fair, transparent, and technically rigorous manner otherwise the politics of such choices could overwhelm the whole process.

There’s been much success in this endeavour. It’s clear that this is a valuable aviation safety measure. It may have driven some contracting States to improve the performance of their airlines.


[1] https://www.icao.int/publications/Pages/doc7300.aspx

[2] https://www.icao.int/safety/CMAForum/Pages/default.aspx

Walk the line

Aeronautical products must be certified before entering transport services. Is certification too complex? Is it too expensive and thus a barrier to innovation? Hasn’t deregulation delivered successes since the 1970s? More choice and more aviation services across the globe.

These are perfectly reasonable questions. They are asked frequently. Especially during economically tough times and when new products are pushing to get operational. In answering, it’s all too often a butting of heads that results. Industry puts its point. Authorities put theirs. Commercial reality and public interests settle at some point which leaves the debate on the table for next time.

Walking that line between satisfying the demand of the new and protecting the good safety performance of the aviation system is a perpetual challenge. It goes without saying that we all know what happens when the line is crossed. Textbooks will continue to chew over stories like that of the Boeing 737 MAX development. In fact, the stories of safety lapses are an important part of the learning process that led to aviation’s admirable safety record.

The counter argument is that we are in a new situation and that technology has significantly changed. This argument of the “new” is not new. Every major new step encountered significant hurdles to overcome. Pick-up the story of the development of the Boeing 747[1][2] and it’s a real dramatic page turner. However, the problem remains the same but as much innovative thinking needs to go into certification as the products that are certified. There’s a reason that’s difficult and its called legacy.

On the public’s behalf, how big is the risk appetite of the certification authorities? At the same time how far do the innovators want to push the envelope knowing that liability rest on their shoulders?

What I find inadequate is that when reading reports like “Funding Growth in Aerospace[3]” I find little, or no consideration is given to funding regulatory improvement. Arguments are for product development and little else. It’s as if certification activities are to be blamed for holding up innovations introduction to service but forget any thought of increasing the resources for certification activities.

It’s short-sighted. Believe it or not there is money to be made in testing and validation. There’s money to be made in education and training. These go hand in hand with efforts to exploit innovative products.


[1] https://www.bbc.co.uk/news/business-37231980

[2] https://www.theguardian.com/science/2016/sep/07/joe-sutter-obituary

[3] https://www.ati.org.uk/publications/

Air Taxi 3

Urban mobility by air, had a flurry of success in the 1970s. However, it did not end well.

Canadian Joni Mitchell is one of the most celebrated singer-songwriters and my favourite. She has tapped into the social and environmental issues that have concerned a lot of us for decades. Of her large catalogue, I can’t tell you how much I love this song[1]. The shear beauty of the lyric.

Anyway, it’s another track on the album called “Hejira” that I want to refer. When I looked it up, I found out, I was wrong. The song I want to refer to is on the 1975 album “The Hissing of Summer Lawns”. The song “Harry’s House[2]” contains the line “a helicopter lands on the Pan Am roof like a dragon fly on a tomb.” Without going into what it’s all about, the lyrical image is that flying from a city skyscraper roof was seen as glamorous and the pinnacle of success.

In 1970, prominent aviation authorities were talking about the regulatory criteria needed for the city-centre VTOL[3] aircraft of the future. Then on the afternoon of 16 May 1977, New York Airways Flight 971, a Sikorsky S-61 helicopter, crashed[4] on Pan Am’s building rooftop heliport[5]. That ghastly fatal accident reset thinking about city centre operations air transport operations.

So, what’s different 50-year on? Proposals for city centre eVTOL operations are much in the News. City planners are imagining how they integrate an airborne dimension into public transport operations. Cars, busses, trains and eVTOL aircraft may all be connected in new multimodal terminals. That’s the city transport planners’ vision for less than a decade ahead.

For one, the vehicles are radically different. Yes, the physics of flight will not change but getting airborne is quite different between a conventional large helicopter and the plethora of different eVTOL developments that are underway across the world.

Another point, and that’s why I’m writing this piece, is the shear amount of safety data that can be made available to aircraft operators. Whereas in the 1970s, a 5-parameter flight recorder was thought to be neat, now the number of digital parameters that could be collected weighs in over thousands. In the 1970s, large helicopters didn’t even have the basic recording of minimal flight data as a consideration. The complexity in the future of eVTOL will be, not how or where to get data but what to do with all the data that is streamed off the new aircraft.

Interestingly, this changes the shape of the Heinrich and Bird “safety pyramid” model[6]. Even knowing about such a safety model is a bit nerdy. That said, it’s cited by specialist in countless aviation safety presentations.

Top level events, that’s the peak of the pyramid, remain the same, but the base of the pyramid becomes much larger. The amount of safety data that could be available on operational occurrences grows dramatically. Or at least it should.

POST: Growing consideration is being given to the eVTOL ecosystem. This will mean a growing need to share data Advanced Air Mobility Portal (nasa.gov)


[1] https://youtu.be/nyj5Be5ovas

[2] A nice cover https://youtu.be/bjvYgpm–tY

[3] VTOL = Vertical Take Off and Landing.

[4] https://www.nytimes.com/1977/05/17/archives/5-killed-as-copter-on-pan-am-building-throws-rotor-blade-one-victim.html

[5] https://www.thisdayinaviation.com/16-may-1977/

[6] https://skybrary.aero/articles/heinrich-pyramid

Air Taxi

My daily routine once comprised of walking across a bridge over the Rhine to an office in Ottoplatz in Köln-Deutz[1]. That’s in Cologne, Germany on the eastern side of the river.

In the square outside the railway station is a small monument to a man called Otto. A small monument marking a massive transformation that took place in the way transport has been powered for well over than a century. This monument honours Nicolaus August Otto who created the world’s first viable four-stroke engine in 1876.

Today, the internal combustion engine hasn’t been banished. At least, not yet and Otto could never have known the contribution his invention would make to our current climate crisis. But now, rapid change is underway in all aspect of transport. It’s just as radical as the impact of Otto’s engine.

As the electrification of road transport gathers apace so does the electrification of flying. That transformation opens new opportunities. Ideas that have been much explored in SiFi movies now become practically achievable[2]. This is not the 23rd Century. This is the 21st Century. Fascinating as it is that in The Fifth Element the flying taxi that is a key part of the story, has a driver. So, will all flying cars of the future have drivers?

I think we know the answer to that already. No, they will not. Well, initially most of the electric vehicles that are under design and development propose that a pilot (driver) will be present. Some have been adventurous enough to suggest skipping that part of the transition into operational service. Certainly, the computing capability exists to make fully autonomous vehicles.

The bigger question is: will the travelling public accept to fly on a pilotless vehicle? Two concerns come up in recent studies[3][4]. Neither should be a surprise. One concerns passengers and the other concerns the communities that will see flying taxies every day of the week.

Public and passenger safety is the number one concern. I know that’s easy to say and seems so obvious, but studies have show that people tend to take safety for granted. As if this will happen de-facto because people assume the authorities will not let air taxies fly if they are unsafe.

The other major factor is noise. This historically has prevented commercial public transport helicopter businesses taking-off. Strong objections come from neighbourhoods effected by aircraft constantly flying overhead. Occasional noise maybe acceptable but everyday operations, unless below strict thresholds, can provoke strong objections.

So, would you step into an air taxi with no pilot? People I have asked this question often react quickly with a firm – No. Then, after a conversation the answer softens to a – Maybe.


[1] https://www.ksta.de/koeln/innenstadt/ottoplatz-in-koeln-deutz-eroeffnet–das-muss-nicht-gruen-sein–2253900?cb=1665388649599&

[2] https://www.imdb.com/title/tt0119116/

[3] https://www.easa.europa.eu/en/newsroom-and-events/press-releases/easa-publishes-results-first-eu-study-citizens-acceptance-urban

[4] https://verticalmag.com/news/nasa-public-awareness-acceptance-of-aam-is-a-big-challenge/

Foot shooting

In the 1970s and 80s, Europe’s aviation industry strove to create common airworthiness codes. In 1983, a Memorandum of Understanding (MoU) was signed that bring together 11 national authorities, including the UK. These countries agreed to improve European safety regulation; develop common codes and common interpretation of those codes and extend cooperation.

Given the immense efforts the UK applied to creating the Joint Aviation Authorities (JAA) and subsequently the European Aviation Safety Agency (EASA) it is unsurprising the hope of continuing involvement remained until the EU-UK Trade and Cooperation Agreement (TCA) was signed.

Leaving the European system of aviation safety regulation is a consequence of the political choice of a hard Brexit. Exiting EASA membership was not accompanied by leaving other European institutions. However, the implications of no longer being an EU Member State have rippled through out the whole aviation system. As the UK becomes less Eurocentric so the rest of Europe becomes more Eurocentric. Yet, the UK will surely wish to continue to exercise influence within regional bodies. This is incongruous but it is a political choice, and such choices have consequences.

Another case of immense efforts, the UK applied, was to collaborative working in aerospace research. UK organisations and academic institutions benefited significantly from participation in the Horizon Europe project and its predecessors. This is being run down despite assurances given in the TCA. An impasse has arisen over the political shenanigans related to the Irish border.

Now, the lawyers have got involved there is surely nothing good that will come if it[1]. The overall message is negative. With Conservative leadership candidates stirring up anti-EU sentiment just to get votes, it’s hardly likely there will be a reconciliation any time soon.

Yet again, the UK is perfecting the art of shooting itself in the foot. A sad situation. By the way, I do think this situation will be resolved in the fullness of time. The EU published a Pact for Research and Innovation in Europe in November 2021. To quote:

(g) Global engagement: Develop a coherent global engagement strategy and common tools, promoting shared European values and principles for R&I in terms of international cooperation and capitalising on the attractiveness of research in the Union; ensure the Union’s scientific and innovation strategic autonomy while preserving an open economy; promote a level playing field and reciprocity based on fundamental values; enhance R&I partnerships and strengthen, broaden and deepen collaboration with third countries and regional organisations.

The last line ties in nicely with the TCA and creates a need to solve the issue of UK engagement. That would be wise for both parties in the end.

POST 1: The consequences are real Thanks to Brexit, I lost a €2.5m research grant. I fear for the future of UK science | José R Penadés | The Guardian

POST 2: Grants lost At least 115 UK researchers to lose their ERC grants – Research Professional News


[1] https://sciencebusiness.net/news/uk-launches-legal-case-against-eu-over-horizon-europe-association

FR4978

So, what’s the problem? A civil aircraft with passengers on-board, on a scheduled flight, flying over a sovereign State was diverted because of an alleged terrorist threat. Aircraft lands safely and in the end most of the passengers continue to their intended destinations.

Well, the case of the forced diversion of Ryanair flight #FR4978, a commercial passenger aircraft over Belarus on Sunday, 23 May 2021, is a matter for grave concern. The aircraft was carrying European citizens and residents between two European Union (EU) capitals.

The track of the Ryanair flight FR4978 from Athens (ATH) to Vilnius (VNO) was posted on Twitter[1]. The Boeing 737-800 was diverted to Minsk in Belarus whilst it was about to start its approach to Vilnius airport in Lithuania.  The Ryanair flight maintained 39,000 ft toward Lithuania before beginning a diversion about 73km from VNO and only 30 km from border.  The Polish registered Boeing passenger aircraft (SP-RSM) was forced to land in Belarus.  

More than 5 hours after the landing of flight FR4978, the aircraft remained on the ground in Minsk.  Whilst the aircraft was on the ground the Belarusian authorities detained opposition activists, Raman Pratasevich and Sofia Sapega.

Was the aircraft hijacked to go to Minsk? Well, there’s no report of force being used on-board the aircraft, so strictly speaking this may not be a hijacking.  The mystery deepens when considering that if the alleged terrorist threat was credible, it would have been far safer to continuing into Lithuanian airspace and land at the intended destination. 

Also, there’s the Belarusian military fast-jet aircraft (MIG 29) that accompanied flight FR4978. This could be considered aggressive intimidation of the Ryanair flight crew.  It certainly limited their flight’s options in respect of the situation.  The military interception of a civil aircraft for political reasons is a serious act and one that can put the safety of passengers in peril. So, whether it’s called a “forced diversion” or a “State Hijacking” it could be in contravention of the Chicago Convention. That’s the basis on which international civil aviation is normally conducted. 

It’s now clear that the International Civil Aviation Organisation (ICAO)[2] will carry out an independent investigation into this Ryanair flight[3].   Strong condemnation has come from the European Union (EU)[4]. The aircraft operator, the State of Registry, and many of the passengers were from EU Member States. 

If the investigation concludes that officials in Belarus faked a bomb threat to divert this Ryanair flight for political purposes, then this is a gravely troubling act that has horrendous implications for international civil aviation.  No other authorities had knowledge of a bomb threat to this Ryanair Athens-Vilnius flight. The Greek Civil Aviation Authority, as the aircraft took-off from Athens, has stated that it received no bomb warning.

This event is an attack on European democracy, freedom of expression, freedom of movement and safety. The Belarus authorities need to immediately release Raman Pratasevich and Sofia Sapega.

Update 1: EASA issues Safety Directive calling on Member States to mandate avoidance of Belarus airspace.

Update 2: Simillar thoughts: The interception of #Ryanair Flight #FR4978 – legal or not, carriers have been put on notice.


[1] https://www.flightradar24.com/

[2] https://www.icao.int/Newsroom/Pages/ICAO-Council-agrees-to-pursue-fact-finding-investigation-into-Belarus-incident.aspx

[3] https://news.un.org/en/story/2021/05/1092812?123

[4] https://www.consilium.europa.eu/en/press/press-releases/2021/05/24/belarus-declaration-by-the-high-representative-on-behalf-of-the-eu-on-the-forced-diversion-of-ryanair-flight-fr4978-to-minsk-on-23-may-2021/

Flight, Risk & Reflections 13.

Last night, chatting about presentations and simple ways of making them better, I was reminded of: Ethos, Pathos, and Logos.  It’s ancient advice about how to persuade an audience of a point of view. The importance is to see a place for all three in a presentation. 

Looking at the day’s news, I see we are still on the brink of a deal. Negotiations drag on and on. Both EU and UK give the impression that they are stretching their negotiating mandates to try to come up with a good solution but time is ticking.

Outside of the negotiating room there remains the task of convincing different audiences that a deal is a good one. So, what of the classical three. In the UK, the media and politicians revel in Pathos. It’s almost as if the other two are consigned to be back seat drivers. For Ethos and Logos, objectivity is a must. Being honest means being factual. Arguing rationally means applying the facts.

Unfortunately, there are only a handful of places to go for that objectivity in the British media. So, it does make a difference to read the foreign media.  For some common sense, I recommend the thoughts of Julian King[1], the UK’s last European commissioner.  I agree that everybody stands to lose out with No-Deal.

This week we carry on with a multitude of unknowns. Only one thing is for sure. Life after 31st December will be different[2]

I do wish press articles would not say: “Otherwise, the U.K would have to strike individual agreements with EU countries to bypass these concerns, ……” Striking individual agreements with non-EU countries is what is happening. Striking individual agreements with EU countries will not happen. The reason for this is that for the major areas of interest the EU has competence[3].

It’s worth noting that the harmonisation of civil aviation requirements and procedures started a long time before the formation of European Union Aviation Safety Agency (EASA).


[1] https://www.irishtimes.com/opinion/brexit-the-uk-and-eu-both-need-to-put-aside-emotion-and-cut-a-deal-1.4425580

[2] https://www.politico.eu/article/5-things-to-know-about-post-brexit-aviation-airlines-eu-transition-cargo-travel-passengers/

[3] https://europa.eu/european-union/topics/transport_en

Flight, Risk & Reflections 8.

2-years ago I wrote: “Early in the year, prudently the EU published a series of notices concerning the “No Deal” outcome.  These were stark and based upon the UK becoming a “Third Country” with a blank sheet of paper in front of it.  That’s a Country with no special arrangements with the EU.” It seems that they (EU) were very prudent

That said, let’s be optimistic. News reports are that the UK and EU have transitioned into an intensive phase of negotiations with the aim of getting a much-cherished Free Trade Agreement (FTA)[1].  Here we are coming up to the last week of October 2020. 

Although the outcome remains unclear the wisdom of being prepared for the end of the Transition Period is unquestionable[2]. Aviation has been trying to get to grips with the ups and downs of Brexit for 4-years, but this is the real crunch time. 

As I’ve commented before, the departure of the UK from the European Union Aviation Safety Agency (EASA) was unexpected only a year ago but it’s going to happen on 1 January 2021. This will mean more “red tape” and regulatory costs for UK industry, but the UK Government is unmoved in its position. 

For aircraft design, UK based Design approval holders need to apply to the UK Civil Aviation Authority (CAA) for a UK Design Organisation Approval (DOA)[3]. The UK CAA will continue to apply the European rules as set out in Regulation EU No 748/2012 that determines the rules for the certification of design organisations. Part-21 subpart J of this Regulation concerns the Design of aircraft or the associated components.

For aircraft production, UK based production approval holders are advised to apply for an EASA Third Country Production Organisation Approval (POA)[4]. The same is true for those maintenance organisations who want to work on European Member State registered aircraft.  This is an administrative procedure within EASA and so certificates will only be issued to UK organisations, all being well, after the transition period has expired. 

A lot will depend on what’s in any EU-UK aviation agreements as to any mutual acceptance or recognition of approvals.  Now, no one is able to predict the outcome of negotiations. We all must rely on statements from the UK Government and EU Commission on the latest progress of negotiations. 

To me this is a mighty strange state of affairs. If I reflect on the detailed and thoughtful groundwork done for the creation of EASA back in 2002-3, it’s as if a everything has been thrown to the four winds.  


[1] https://www.bloomberg.com/news/articles/2020-10-25/brexit-talks-extended-to-oct-28-as-u-k-indicates-optimism

[2] https://www.adsgroup.org.uk/blog/prepare-for-the-end-of-the-transition-period-with-our-brexit-webinars/

[3] https://www.caa.co.uk/Commercial-industry/Aircraft/Airworthiness/Organisation-and-maintenance-programme-approvals/EASA-Part-21/Apply-for-a-Part-21-Subpart-J-approval/

[4] https://www.easa.europa.eu/brexit-early-applications#others

Flight, Risk & Reflections 4.

It’s under 100 days to go to the final, final, final Brexit exit. This Autumn flying faces the quadruple threats of rising Coronavirus numbers, diminishing Government support, implementation of erratic polices and the possibility of a disorderly end to the EU-UK Withdrawal Agreement transition period. The shining light is that everyone knew that this was coming, and adding up all the turmoil of the last 4-years it has at least given industry and institutions time to come to terms with the situation and prepare accordingly.  Yes, there are a bucket load of unknowns. 

On the plus side as soon as we get past 1 January 2021 there will be less constraints for either party. The European Union (EU) will be able to go ahead with actions once blocked by the UK. Vice-versa the UK will be able to develop its own unique set of policies, rules and regulations. 

If both parties don’t lose their basic common sense there ought to be a good degree of continuing communication, collaboration and cooperation.

I agree with the AIRBUS CEO: “Aviation, an irreplaceable force for good in the world, is today at risk as borders remain closed and influential voices in Europe call for permanent curbs on flying.”

Recently the British Business General Aviation Association (BBGA) hosted a webinar [1]dedicated to all matters Brexit. Good of them to make it available on-line to non-members.

In addition, there’s a “Readiness for Brexit[2]” update from Tim Johnson, Strategy and Policy Director UK CAA now on-line. This is about the CAA’s readiness for what’s going to happen at the end of the transition period.  There’s a promise of continuity, at least for a while[3].

It saddens me greatly that the UK will no longer be part of the EU Aviation Safety Agency (EASA) system but that’s now a matter of fact. Who knows what the future may bring? It’s perfectly possible that the UK will be back in the system in the next decade.

There’s a lot of reasons why it’s going to be difficult for the UK to act entirely alone. For efficient and sustainable air traffic management the European Single European Sky (SES) project will continue to advance. It would be better for all if the UK was part of that advancement.

We need to concentrate on dealing with the present situation and maximising positive working with Europe. There are many areas of common interest. We remain a great European Country.


[1] https://www.avm-mag.com/bbga-to-conduct-brexit-info-webinar/

[2] https://www.caa.co.uk/Blog-Posts/Readiness-for-Brexit/

[3] https://publicapps.caa.co.uk/docs/33/UK%20Safety%20Regulation%20outside%20EASA%20(CAP1911)%20SEP%202020.pdf

Flying, Democracy and Safety 6.

space shuttle launch during nighttime
Photo by Edvin Richardson on Pexels.com

One of the News stories of the week was that of UK Prime Minster (PM) Johnson spending £900,000 to paint a RAF transport aircraft with Union flag colours. Red, white and blue. I imagine that money will be spent in the UK. It’s good to see that Marshall Aerospace and Defence Group in Cambridge has reduced the Carbon Dioxide (CO₂) emissions of its huge paint shop[1].

The effect of the COVID-19 pandemic and decline of air traffic on European aviation has got worse in recent weeks[2].  Rebuilding it will require new measures to be put in place. Now, the aviation industry is nervous that these will be imposed in an uncoordinated way. National quarantines are an example of such measures as they are an impediment to recovery especially when they are introduced on political grounds. There’s quite a lot of that going on at the moment.

UK PM Johnson and Ursula von der Leyen, the President of the European Commission, were in communication last Monday[3]. There was much talk of giving the on-going UK-EU negotiations new momentum. We are told, people are searching for agreeable compromises. The real possibility of a collapse in the talks remains, with some speculation that this would be exploited to distract from criticism over the UK Government’s handling of the COVID-19 pandemic.

As a taster of what the ratification of any new agreement might involve, a report has been published by the European Parliament (EP)[4] with recommendations on the negotiations for a new partnership with the UK.  This report does have a few mentions of civil aviation, notably:

  1. Considers that the envisaged partnership should include an ambitious and comprehensive chapter on air transport which ensures the EU’s strategic interests, and contains appropriate provisions, on market access, investment and operational and commercial flexibility (e.g. code sharing) in respect of balanced rights and obligations, and should include close cooperation in aviation safety and air traffic management;
  2. Stresses that any possible granting of some elements of the so-called ‘fifth freedom’ (freedom of the air) should be limited in scope and needs to include balanced and corresponding obligations in the interests of the EU.

Even though this has been rejected by UK Government Ministers, the EP continues to support the participation of the UK as a “third country” observer with no decision-making role in the EU’s Agencies, such as the European Aviation Safety Agency (EASA).

Also, the EP still wishes to see UK’s continued participation in the Single European Sky (SES) and technology initiatives like: Clean Sky I and II, Single European Sky ATM Research (SESAR), Galileo, Copernicus and the European Geostationary Navigation Overlay Service (EGNOS).

Today, the indications are that the UK Government has rejected such technical participation. However, it does seem that one or two plans are being changed as we go. It’s reported that the UK is scaling back plans for rival to Galileo satellite system[5]. Ambition is being shaped by practicalities.

Whatever is the case, it’s certain European civil aviation will use both Galileo and EGNOS in advanced forms of navigation and surveillance. The future is being made, tested, and put into service as we speak.

[1] https://marshalladg.com/insights-news/marshalls-clean-air-unit-paints-an-even-cleaner-picture

[2] https://aviationweek.com/air-transport/airlines-lessors/pandemic-impact-european-aviation-worsening-iata-says

[3] https://www.cer.eu/insights/eu-uk-negotiations-no-need-panic-yet

[4] https://www.europarl.europa.eu/doceo/document/A-9-2020-0117_EN.html

[5] https://www.ft.com/content/50c3b6dc-2d2f-4bb4-aa9b-b24493315140