--- leaked document 2019-08-18
--- document released 2019-09-12
HMG Reasonable Worst Case Planning Assumptions
As of August 2019
* When the UK ceases to be a member of the European Union EU in October 2019, all rights and reciprocal arrangements with the EU end.
* The UK reverts fully to “ ‘third country”’ status. The relationship between the UK and the European Union EU as a whole is unsympathetic, with many MS [Member States] (under pressure from the European Commission) unwilling to engage bilaterally and implementing protections unilaterally, though some member states MS may be more understanding.
* No bilateral deals have been concluded with individual member states, with the exception of the reciprocal agreement on social security co-ordination coordination with the Republic of Ireland. EU Citizens living in the UK can retain broadly all rights and status that they were entitled before the UK’s to prior to exit from the EU, at the point of exit.
* Public and business readiness for a no-deal will remain at a low level, and will decrease to lower levels, because the absence of a clear decision on the form of EU Exit (customs union, no deal etc) does not provide a concrete situation for third parties to prepare for. Readiness will be further limited by increasing EU Exit fatigue caused by, due to the second extension of Article 50, which will limit the effective impact of current preparedness communication. (To be reviewed)
* Business readiness will not be uniform – — in general large larger businesses that work across sectors are more likely to have better developed counting contingency plans than small and medium-size sized businesses. Business readiness will be compounded by seasonal effects and, impacting on factors such as warehouse availability.
* Concurrent risks associated with autumn and winter, such as severe weather, flooding and seasonal flu, could exacerbate any effects a number of impacts and stretch the resources of partners and responders.
* Private sector companies’ behaviour will be governed by commercial considerations, unless they are influenced otherwise.
* Her Majesty’s government HMG will act lawfully and in accordance with the rule of law, including by identifying the powers it is using to take specific actions.
Key planning assumptions
1. Exit day
For the purpose of freight flow and traffic management, as October 31 October is a Thursday, day 1 of exit is now on a Friday rather than the weekend, which is not to our advantage. Exit day may coincide with the end of October half-term holiday school holidays, which varies vary across the UK. (CCS/DExEU)
2. Member states
In a small number of instances where the impacts of Brexit would be felt negatively in the EU as well as in the UK, Member States may act in a way that which could also benefit the UK (e.g. energy for Ireland). (CCS/DExEU)
3. Channel ports
France will impose EU mandatory controls on UK goods on Day 1 of No Deal (D1 ND) and has have built infrastructure and IT systems system to manage and process customs declarations and to support a risk-based control regime. On Day 1 of No Deal D1 ND, between 50%-85% of HGVs travelling via the short Channel Straits may not be ready for French customs. The lack of trader readiness combined with limited space in French ports to hold “unready” HGVs could reduce the flow rate to 40%-60% of current levels within one day as unready HGVs will fill the ports and block flow. The worst disruption to the short Channel crossings Straits might last for up to 3 months before flow rates rise it improves by a significant level to about around 50%-70% (asdue to more traders get getting prepared), although disruption there could continue much to be some disruption for significantly longer. In the event of serious disruption, the French might act to ensure some flow through the short Channel crossings. Disruption to Channel flow across the short Channel Straits would also cause significant queues in Kent and delays to HGVs attempting to use the routes to travel to France. In a reasonable worst-case scenario, HGVs could face a maximum delay delays of 1½ 1.5-2½2.5 days before being able to cross the border. HGVs that are caught up in congestion in the UK will be unable to return to the EU to collect another load and some a proportion of logistics firms may decide to avoid the route should there be significant and prolonged disruption. Analysis to date has suggested a low risk of significant sustained queues at ports outside of Kent that which have high volumes of EU traffic, but the Border Delivery Group BDG will continue to work directly with stakeholders at those ports to support planning readiness. (BDG/DfT)
4. Border checks
UK citizens travelling to and from the EU may be subject to increased immigration checks at EU border posts. This may lead to passenger delays at St Pancras, Cheriton (Channel Tunnel) and Dover, where border juxtaposed controls are juxtaposed in place. Depending Dependent on what the plans EU Member States put in place to cope with these increased immigration checks, it is likely that delays will occur for UK arrivals and departures at EU airports and ports. This could cause some disruption on transport services. Travellers may decide to use alternative routes to complete their journey. (BDG/FCO/HO/DfT)
5. Energy supplies
Demand for energy will be met, and there will be no disruption to electricity or gas interconnectors. In Northern Ireland NI there will be not be immediate disruption to electricity supply on Day 1. A rapid split of SEM [Single Electricity Market] split could occur months or years after the EU Exit. In this event, there would not be issues about security of supply issues. However, there will probably likely be marked significant electricity price rises increases for electricity customers consumers (business and domestic), with associated wider economic and political effects impacts. Some participants could exit the market, thereby exacerbating the economic and political effects impacts. (BEIS)
6. Drugs and disease
i) The BDG [Border Delivery Group]/DfT [Department for Transport] planning assumption on reduced flow rates describes a pre-mitigation reasonable worst-case flow rate that could be as low as 40% on Day 1 of No Deal D1 ND via the short straits [main Channel crossings] Straits, with significant disruption lasting up to six months. Unmitigated, this will have an impact on the supply of medicines and medical supplies. The reliance of
Supply chains for medicines and medical products rely heavily’ supply chains on the short straits, which makes crossing make them particularly vulnerable to severe extended delays:; three-quarters of medicines come via the short straits. Supply chains are also highly regulated and require transportation that meets strict Good Distribution Practices. This can include limits on time of transit times and, or mean product must be transported under temperature-controlled conditions. While Whilst some products can be stockpiled, others cannot because of due to short shelf lives. – it will also not be practical to stockpile products to cover expected delays of up to six months’ supplies. The DHSC [Department for Health and Social Care] is developing a multi-layered approach to mitigate these risks. (DHSC
ii)ii. Any disruption that reduces to reduce, delays delay or stops the stop supply of medicines for UK veterinary use would reduce our ability to prevent and control disease outbreaks, with potential harm to detrimental impacts for animal health and welfare, the environment, and wider food safety and/availability, as well as, in the case of and zoonotic diseases, posing a risk to which can directly impact human health. Industry stockpiling will not be able to match the 4-12 weeks’ worth of stockpiling that which took place in March 2019. Air freight capacity and the special import scheme are is not a financially viable way mitigation to mitigate fully close risks associated with all UK veterinary medicine availability issues due to border disruption. (DEFRA)
7. Food and water
i) Certain types of fresh food supply will decrease. Critical elements of dependencies for the food supply chain (such as key input ingredients, chemicals and packaging) may be in short shorter supply. In combination, these two factors will not cause an overall shortage of food in the UK but will reduce availability and choice of products and will increase the price, which will affect could impact vulnerable groups. The UK growing season will have come to an end, so and the Agri-food supply chain will be under increased pressure at this time of year, due to preparations for Christmas, which is the busiest time of year for food retailers. Government will not be able to fully anticipate all effects on potential impacts to the agri-food supply chain. There is a risk that panic buying will disrupt cause or exacerbate food supplies supply disruption. (DEFRA
ii)ii. Public water services are likely to remain largely unaffected, thanks due to actions now being taken by water companies. The most significant single risk is a failure in the chemicals chemical supply chain. The likelihood of this occurring is considered low, and the impact is likely to be local localised, affecting only hundreds of thousands up to 100,000’s of people. Water companies are well prepared for any disruption:; they have significant stocks of all critical chemicals, extensive monitoring of their chemicals chemical supply chains (including transport transportation and all deliveries) and sharing mutual agreements in place. In the event of a supply chain failure, or the need to respond rapidly to other water supply incidents, urgent action may need to be taken to make sure people continue to have access to clean water. (DEFRA)
8. Financial services and insurance
Some cross-border UK financial services will be disrupted. (HMT)
The EU will not have made a data decision with regard to the UK before exit. This will disrupt the flow of personal data from the EU, where an alternative legal basis for transfer is not in place. In no-deal, an adequacy assessment could take years. (DCMS)
10. Law and order
Law enforcement data and information-sharing between the UK and the EU will be disrupted. (HO/NSS)
11. Brits in Europe
i) UK nationals will lose their EU citizenship and, as a result, can expect to lose associated rights and access to services over time, or be required to access them on a different basis to now. All MS [Member States] have now published legislative proposals, but not all have passed legislation to secure all rights for UKNs [UK Nationals]. There is a mixed picture across member states MS in terms of the level of generosity and detail in the legislation. In some member states MS, UK nationals UKNs need to take action now, whilst others they do not. Complex administrative procedures within member states MS, language barriers and uncertainty regarding the UK political situation are contributing to some UK nationals UKNs being slow to take action. Demands There will be gaps in both substance and understanding. Demand for help on Her Majesty’s government from HMG will increase significantly, including leading to an increase in consular inquiries enquiries and more complex and time-consuming consular assistance cases for vulnerable UK nationals UKNs. Cross-government HMG support, including continued close engagement and clear communications messaging from UK government UKG departments and the departmental agencies, DAs will be needed to help manage the demand. (FCO
ii)ii. An EU Member State would continue to pay a pension it currently pays to a UK national living in the EU. (DWP
iii)iii. The Commission and individual Member States do not agree to extend the current healthcare arrangements for UK state pensioners and tourists beyond October 31, October 2019, and refuse offers by the UK to fund treatments. Member States take no further action to guarantee healthcare for UK nationals and treat them in the same way as the other “third 3rd country” nationals. UK pensioners, workers, travellers and students will need to access healthcare in different ways, depending on the country. Healthcare systems may require people to demonstrate residency and, current or previous employment, to enter a social insurance scheme, or to purchase private insurance. Member States should treat people with urgent needs, but may require them to pay after the fact. There is a risk of disruption for patients, and a minority could face substantial costs. (DHSC)
12. Gibraltar, due to
Because of the imposition of border checks at its border with Spain (and the knock-on effect of delays from the UK to the EU), Gibraltar will see disruption to the supply of goods (including food and medicines) and to shipments, medicines, trans-frontier shipment of waste, plus and delays of four-plus 4+ hours for at least a few months in the movement of frontier workers, residents and tourists across the border. Prolonged border delays over the longer term are likely to harm adversely impact Gibraltar’s economy. As on Like the UK mainland, cross-border services and data flow will also be disrupted. Despite the time extension to the UK’s exit from the EU Exit, Gibraltar has still not taken the decisions to invest in contingency infrastructure (such as port adjustments and; waste management equipment) and there are still concerns that Gibraltar will not have passed all necessary legislation for No-Deal, opening up potential legal gaps/risks mainly for the Government of Gibraltar. Gibraltar continues to plan for less significant border delays than in our Yellowhammer scenario. Crown Dependencies may be affected by supply chain disruption. (FCO/MoJ)
13. Protests and police
Protests and counter-protests will take place across the UK, using up and may absorb significant amounts of police resources resource. There may also be a rise in public disorder and community tensions. (HO)
14. Fuel Regional traffic disruption caused by border delays could affect fuel distribution in within the local area, particularly if traffic queues in Kent block the Dartford crossing, which would disrupt fuel supply in London and the southeast South-East. Customer behaviour could lead to local shortages in other parts of the country.(BEIS)
Tariffs make UK petrol exports to the EU uncompetitive. Industry had plans to mitigate the impact on refinery margins and profitability, but UK government policy to set petrol import tariffs at 0% inadvertently undermines these plans. This leads to big financial losses and the closure of two refineries (which are converted to import terminals) with about 2,000 direct job losses. Resulting strike action at refineries would lead to disruptions to fuel availability for 1-2 weeks in the regions they directly supply. Government analysis of the impact of no-deal on refineries continues
16. A small minority of insurance payments from UK insurers into the EU may be delayed. (HMT)
17. The poor
Low-income groups will be disproportionately affected by any price rises in the price of food and fuel. (HMT)
18. Northern Ireland
On Day 1 of No Deal, Her Majesty’s government D1 ND HMG will activate operationalise the “no new checks with limited exceptions” model announced on March 13 March, establishing a legislative framework and essential operations and system on the ground, to avoid an immediate risk of a return to a hard border on the UK side. The model is likely to prove unsustainable because of due to significant economic, legal and biosecurity risks and no effective unilateral mitigations to address this will be available. With the UK becoming a “third [non-EU] country”, the automatic application of the EU tariffs tariff and regulatory requirements for goods entering Ireland will severely disrupt trade. The expectation is that some businesses will stop trading trade or relocate to avoid either paying tariffs that the tariff which will make them uncompetitive or to avoid the risk of trading illegally;, while others will continue to trade, but will experience higher costs that which may be passed on to consumers. The agri-food sector will be the hardest hit, given its reliance on complicated highly integrated cross-border supply chains and the high tariff and non-tariff barriers to trade. Disruption to key sectors and job losses are likely to result in protests and direct action with road blockades blockages. Price and other differentials are likely to lead to the growth of the illegitimate economy. This will be particularly severe in border communities where both criminal and dissident groups already operate with greater freedom threat and impunity. Given the tariff and non-tariff barriers to trade, there will be significant pressure to agree new arrangements to which supersede the day 1 one model within days or weeks. (NIO/NICS)
Up to 282 EU and European Economic Area EEA nations’ fishing vessels could enter illegally, or are already be fishing in UK waters: (Up to 129 vessels in English waters, 100 vessels in Scottish waters, 40 vessels in Welsh waters and, 13 vessels in Northern Irish waters) on day 1 one. This is likely to cause anger and frustration in the UK catching sector, which could lead to both clashes between fishing vessels and an increase in non-compliance in the domestic fleet. Competing demands on UK Government and DA maritime departmental agencies and their assets could put enforcement and response capabilities at risk, especially in the event of concurrent or cumulative incidents, which are likely to include; illegal fishing, border borders violations (smuggling and illegal migration), and any disorder or criminality arising as a result, eg e.g. violent disputes or blockading of ports. (Defra, HO, and the DAs in respect of fisheries protection).
20. Social care
There is an assumption that there will be no big changes major change in adult social care on the day after EU Exit. The adult social care market is already fragile because of the due to declining financial viability of providers. An increase in inflation after the UK’s following EU exit would affect providers of significantly impact adult social care through providers due to increasing staff and supply costs, and might may lead to provider failure, with smaller providers impacted within 2-3 months for smaller providers and larger providers 4-6 months for larger ones after exit. There are also local possible concurrent localised risks —: transport or staff disruption, severe winter weather or flu — that could exacerbate the existing market fragility, and that cumulatively could stretch the resources of providers and local authorities LAs. Intelligence will continue to be gathered to forewarn of/prepare for any effects impacts on the sector, including closure of services and handing-back of contracts that which are not part of the normal market function. In addition, by mid-August we will look at the status of preparations in four local authorities, which are identified as priority concerns, by mid-August. (DHSC)