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Having spent the week digesting the AltArrange report a few observations. Not so much about the MaxFac practicalities but the thinking underpinning it.
1) There’s an important definition or redefinition. The 2017 EU-UK joint report said the UK committed to no physical infrastructure or related checks & controls. 
EU view was thus meant status quo must be maintained, no new procedures at all relating to the border. UK appeared to go along with this. AltArrange people say this is too restrictive and it should ‘properly’ mean no new checks & controls AT THE BORDER.
Makes sense from their perspective because the MaxFac they are proposing involves a whole range of new administrative & bureaucratic interventions. Which lead onto...
2) There’s an expectation that the Irish govt, political nationalism & NI businesses are going to have to take some pain in order that a proper Brexit can be delivered.
Irish govt would have to climb down on checks & controls, nationalism accept a new distinction between the two polities, NI traders accept new costs & frictions.
On the cost and frictions point, the use of transit procedures is a major part of this plan. But for many businesses that’s going to involve the use of a customs broker every time. As @ManufacturingNI pointed out at the report launch this is good for customs brokers not traders.
3) On SPS/ food standards there’s an acknowledgement that some system of shared rules is the best way to crack it. There is no pure tech solution.
The shared rules the AltArrange people alight on is a convoluted UK-Irish food standards zone which they say will be ‘difficult’ to negotiate. Well yes, as it starts to nudge Ireland out of the single market.
Having an all-island food standards zone, building on the all-island animal health zone is meanwhile described as not negotiable ‘at this time.’
At the launch I didn’t really get a convincing explanation of why the entirety novel UK-Ire food standards zone was judged to be merely difficult to negotiate while extending the existing all-island arrangement was not negotiable.
If a system of shared rules for SPS can’t be agreed the report floats the idea of checks away from the border (also mentioned in Nicky Morgan’s piece. ) When you look at EU law that’s extremely optimistic.
At the launch we were told this idea ‘goes with the grain’ of developing EU policy on borders. The grain is one thing but the regs say stuff needs to be checked at immediate vicinity of point of entry unless there is a geographic constraint.
Anyway the AltArrange people are quite properly doing presentations in Belfast & Dublin so you may get a chance to ask your own questions. prosperity-uk.com/wp-content/upl…
