Tag: EU

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 and Aviation 35

The UK Government has published a round of aviation Technical Notices, laying out what the UK will do in the event of a “No Deal” Brexit.  No deal means no Withdrawal Agreement.  One thing I can do here is to highlight some of the responses to these “No Deal” papers.

ADS is a trade body for UK Aerospace, Defence, Security and Space companies[1].  They are trying to get the information out to the aviation and aerospace industries.  It really is a case of being prepared.

The airlines organisation, IATA warned on that the Government’s papers on a “No-Deal” exposed the “extreme seriousness” of what is at stake.  The UK would probably leave the European Common Aviation Area.  However, even if something is possible in theory, it doesn’t mean its going to happen.  So, the idea of all aircraft being grounded after Brexit day is more extremely improbable than unlikely.

Some commentators think that UK-EU flights and airport security may stay roughly the same in a “no deal” case, but this relies on the Government forming lots of mini mutual agreements with the EU to ensure continuity[2].  It’s a sort of let’s be good to each other even though we failed one negotiation and let’s do a “no deal” light.

Politically, the aviation papers reveal how much uncertainty remains just six months from Brexit day.  The result they have had not so much to provide guidance and public reassurance but to kick-off a stream of negative stories in the Press[3].

The professional aviation Press is none too complementary about the possibility of a “No Deal” outcome.  The Government papers seems to have confirmed theories that had already done the rounds[4].  Perhaps one is new and that concerns the Part-TCO safety authorisation.  Prior to being an EASA Member State, the UK did not have a Part-TCO regulation.  Now, the papers suggest that a new UK Part-TCO safety authorisation may be established.  No doubt that would be useful to bringing in much needed fees to fund all the new work coming the way of the UK CAA.

Several subjects have had no mention – yet.  Will aviation training schools have to change their workings?  Will cooperation on safety planning, occurrence reporting and accident investigation continue smoothly?  Will air traffic service providers continue to cooperate?

At the global level is likely that both EU and US will not want to change their current agreements.  Thus, the UK will need to fit in and prove that it’s effectively discharging its new responsibilities.  It’s evident that the UK CAA is recruiting staff and they will have much to do.

[1] https://www.adsgroup.org.uk/blog/aerospace/how-will-aerospace-be-affected-by-no-deal/

 

[2] https://fullfact.org/europe/no-deal-brexit-preparations-travel/

 

[3] https://www.politico.eu/article/brussels-isnt-buying-britains-no-deal-act/

 

[4] https://www.flightglobal.com/news/articles/uk-confirms-no-deal-brexit-would-limit-caa-certifica-452144/

 

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 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_brexitTuesday, 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

 

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

 

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:

  1. 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.
  2. 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

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.