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First, as @MatthewOToole2 says here, the absence of any acknowledgment of the impact of the NI Protocol. Many aspects of that but see here for a discussion of the State aid elements and the way in which they inevitably condition the UK’s options. uksala.org/paper-by-james…
Second, while lecturing the EU about the need to accept UK “independence” it fails to acknowledge, let alone try to address, the EU’s real and valid concerns.
In State aid, the concern is that the UK can cheerfully free ride on the EU’s State aid regime to protect it against subsidised EU competition while subsidising its own exports of goods and services to the EU.
Those who shout “but the EU can always use trade remedies” ignore the point that those remedies don’t apply to services at all and are complex and take time and resources: fire fighting rather than installing a smoke alarm.
For such a huge and close trading partner, the cry “you don’t ask this of Canada or South Korea” misses the point.
That said, it is also fair to ask the EU, as Frost does, hard questions about whether what it is demanding is too rigid to be workable. On State aid, I asked some questions along those lines here.
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