Operation Yellowhammer

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HMG Reasonable Worst Case Planning Assumptions

As of 2 August 2019

When the UK ceases to be a member of the 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 EU as a whole is unsympathetic, with many MS (under
pressure from the Commission) unwilling to engage bilaterally and
implementing protections unilaterally, though some MS may be more

No bilateral deals have been concluded with individual member states with
the exception of the reciprocal agreement on social security coo-rdination
with Ireland. EU Citizens living in the UK can retain broadly all rights and
status that they were entitled 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, 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 larger businesses
across sectors are more likely to have better developed contingency plans
than small and medium sized businesses. Business readiness will be
compounded by seasonal effects, impacting on factors such as warehouse

Concurrent risks associated with autumn and winter such as severe
weather, flooding and seasonal flu could exacerbate a number of impacts
and stretch resources of partners and responders.

Private sector companies’ behaviour will be governed by commercial
considerations, unless influenced otherwise.

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. For the purpose of freight flow and traffic· management as 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 end of October half term school holidays,
which vary across the UK. (CCS/DExEU)

2. 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 way which could also benefit
the UK (e.g. energy for Ireland). (CCS/DExEU)

3. France will impose EU mandatory controls on UK goods on Day 1 No Deal (D1 ND)
and have built infrastructure and IT system to manage and process customs
declarations and support a risk based control regime. On 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 l.imited 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 Straits might last for up to 3 months before it improves by a significant
level to around 50-70% (due to more traders getting prepared), although there could
continue 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 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 maximum delays of
1.5-2.5 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 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 which have high volumes of EU traffic, but
BDG will continue to work directly with stakeholders at those ports to support
planning readiness (BDG/DfT)

4. 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 juxtaposed controls are in place.
Dependent on 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.
TraveUers may decide to use alternative routes to complete their journey.

5. Demand for energy will be met and there will be no disruption to electricity or gas
interconnectors. In NI there will be not be immediate disruption to electricity supply
on Day 1. A rapid SEM split could occur months or years after E Exit. In this event,
there would not be security of supply issues. However, there will likely be significant
electricity price increases for consumers (business and domestic), with associated
wider economic and political impacts. Some participants could exit the market,
thereby exacerbating the economic and political impacts. (BEIS)

6. The BDG/DfT planning assumption on reduced flow rates describes a pre-mitigation
reasonable worst case flow rate that could be as low as 40% D1 ND via the short
Channel 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 medicines and medical products’ supply chains on the short straits
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, or mean product must be transported under temperature
controlled conditions. Whilst some products can be stockpiled, others cannot due to
short shelf lives – it will also not be practical to stockpile products to cover expected
delays of up to six months. DHSC is developing a multi-layered approach to mitigate
these risks. (DHSC)

ii. Any disruption to reduce, delay or stop supply of medicines for UK veterinary use
would reduce our ability to prevent and control disease outbreaks, with potential
detrimental impacts for animal health and welfare, the environment, and wider food
safety/availability and zoonotic diseases which can directly impact human
health. Industry stockpiling will not be able to match the 4-12 weeks’ worth of
stockpiling which took place in March 2019. Air freight capacity and the special
import scheme is not a financially viable mitigation to fully close risks associated with
all UK veterinary medicine availability issues due to border disruption. (DEFRA)

7. Certain types of fresh food supply will decrease. Critical dependencies for the food
supply chain (such as key input ingredients, chemicals and packaging) may be in
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
price, which could impact vulnerable groups. The UK growing season will have come
to an end 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 potential impacts to the
agri-food supply chain. There is a risk that panic buying will cause or exacerbate food
supply disruption. (DEFRA)

li. Public water services are likely to remain largely unaffected due to actions now
being taken by water companies. The most significant single risk is a failure in the
chemical supply chain. The likelihood of this occurring is considered low and the
impact is likely to be localised, affecting up to 1 OO,OOO’s of people. Water companies
are well prepared for any disruption; they have significant stocks of all critical
chemicals, extensive monitoring of their chemical supply chains (including
transportation and all deliveries) and 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. Some cross-border UK financial services will be disrupted. (HMT)

9. 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.

10. Law enforcement data and information sharing between UK and EU will be disrupted.

11. 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 have now published legislative proposals, but not all
have passed legislation to secure all rights for UKNs. There is a mixed picture across
MS in terms of the level of generosity and detail in the legislation. In some MS, UKNs
need to take action now, whilst others they do not. Complex administrative
procedures within MS, language barriers and uncertainty regarding the UK political
situation are contributing to some UKNs being slow to take action. There will be gaps
in both substance and understanding. Demand for help from HMG will increase
significantly leading to an increase in consular enquiries and more complex and timeconsuming
consular assistance cases fqr vulnerable UKNs. Cross HMG support,
inclu ding continued close engagement and clear communications messaging from
UKG departments and the DAs will be needed to help manage the demand. (FCO)

ii. An EU Member State would continue to pay a pension it currently pays to a UK
national living in the EU. (DWP)

iii. The Commission and individual Member States do not agree to extend the current
healthcare arrangements for UK state pensioners and tourists beyond 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
other 3rd country nationals.

UK pensioners, workers, travellers and students will need to access healthcare in
different ways, depending on the country. Healthcare may require people to
demonstrate residency, current .or previous employment, enter a social insurance
scheme, or 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 the imposition of border checks at its border with Spain (and the
knock-on effect of delays from the UK to EU), will see disruption to supply of goods
(including food), mediCines, trans-frontier shipment of waste and delays of 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
adversely impact Gibraltar’s economy. Like the UK mainland, cross-border services
and data flow will also be disrupted. Despite the time extension to EU Exit, Gibraltar
has still not taken decisions to invest in contingency infrastructure (port adjustments;
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 our Yellowhammer scenario. Crown Dependencies
may be affected by supply chain disruption. (FCO/MoJ)

13. Protests and counter-protests wi ll take place across the UK and may absorb
significant amounts of police resource. There may also be a rise in publ ic disorder
and community tensions. (HO)

14. Regional traffic disruption caused by border delays could affect fuel distribution within
the local area, particularly if traffic queues in Kent block the Dartford crossing, which
would disrupt fuel supply in London and the South-East. Customer behaviour could
lead to local shortages in other parts of the country. (BEIS)


16. A small minority of insurance payments from UK insurers into the EU may be
delayed. (HMT)

17. Low income groups will be disproportionately affected by any price rises in food and
fuel. (HMT)

18. On 01 ND HMG will operationalise the “no new checks with limited exceptions”
model announced 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 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 country, the automatic
application of the EU tariff and regulatory requirements for goods entering Ireland will
severely disrupt trade. The expectation is some businesses will stop trade or relocate
to avoid paying the tariff which will make them uncompetitive or to avoid the risk of
trading illegally, while others will continue to trade, but experience higher costs which
may be passed on to consumers. The agri-food sector will be the hardest hit, given
its reliance on highly integrated cross border supply chains and high tariff and nontariff
barriers to trade. Disruption to key sectors and job losses are likely to result in
protests and direct action with road 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 threat and impunity. Given the tariff and non-tariff barriers to trade, there will
be significant pressure to agree new arrangements which supersede the day one
model within days or weeks. (NIO/NICS)

19. Up to 282 EU and EEA nations fishing vessels could enter illegally, or already be
fishing in UK waters (Up to 129 vessels in English waters, 100 vessels in Scottish
waters, 40 vessels in Welsh watets, 13 vessels 1n Northern Irish waters) on day one.
This is likely to cause anger and ftustration 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
agencies and their assets could put enforcement and response capabilities at risk,
especially in the event of concurr nt or cumulative incidents, which are likely to
include; illegal fishing, borders violations (smuggling and illegal migration), and any
disorder or criminality arising as a: result, e.g. violent disputes or blockading of ports.
(Defra, HO, and the DAs in respect of fisheries protection).

20. There is an assumption that there: will be no major change in adult social care on the
day after EU Exit. The adult socia’ care market is already fragile due to declining
financial viability of providers. An : increase in inflation following EU exit would
significantly impact adult social care providers due to in reasing staff and supply
costs, and may lead to provider failure, with smaller providers impacted within 2-3
months and larger providers 4-6 months after exit. There are also possible
concurrent localised risks: transp
<?rt or staff disruptionsevere winter weather or flu
that could exacerbate the existing market fragility
, and that cumulatively could stretch
resources of providers 
and LAsIntelligence will continue to be gathered to forewarn
/prepare for any impacts on the1sector including closure of services and handing
back of contracts which are not part of normal market 
function. In additionwe will
look at the status of preparations in four local authorities
which are identified as
priority concernsby mid-August. (DHSC)

Source Article from https://www.voltairenet.org/article207617.html

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