Brexit – What is Wrong With The Border Operating Model?

Hello, it’s David here again. What is wrong with The Border Operating Model?  Lots.  That’s the simple answer.

I made a precis of the UK’s ‘Border Operating Model, a 206-page document which was released in July. Even the precis is thirteen pages long and highly technical.  I feel sure you probably can’t be bothered.   It is difficult to read even for the experienced.  More to the point, it’s riddled with holes and open questions.

So why bother? At least until those behind it wake up and smell the coffee. 

 We have created basic process maps from the Border Operating Model, for what they are worth.  Unfortunately, the Model displays such deficiencies that I was forced to use best guesses, the experience of my colleagues and myself and logic to try to plug the gaps. The trouble is, those advising the government don’t appear to be using a lot of logic.

Neither do they seem to be asking the people on the ground who have the right knowledge?

It is without surprise that it has emerged that version two of the Model will be released end of October, according to our sources. In other words, it’s a moving target.  I wonder how many versions will be needed?  Anybody been around long enough to remember ‘Dad, I think I got it wrong again’?

A flavour of some of the shortcomings in the current version:

  • No word on where import T forms will be discharged under the ‘Pre-lodgement Model’
  • No mention if T forms are needed under the Pre-lodgement Model
  • The assumption inland approved sites can cope with vast columns of uncleared import freight using the ‘Temporary Storage Model’.
  • I can answer this simply.  They can’t.  Warehouses don’t have elastic sides.  Control measures are draconian at best.  This model is unsuitable for full loads and large part loads.
  • Hauliers are expected to take responsibility for inputting multiple data elements in a new IT platform ‘GVMS’.
  • GVMS still not finalised.
  • Hauliers having to complete EU equivalent systems of GVMS such as the French ‘SI Brexit’; systems which do not talk to each other.
  • The possibility of ‘deferral’ of import entries for the first six months of 2021 via ‘CFSP’. Current regulations make this worse than useless – clunky and unyielding, actually increasing, rather than decreasing workload.
  • Import Safety & Security Declarations, required from 1.7.21.  There is no IT platform for these.  Why are they even necessary?
  • The haulier is responsible for Safety & Security Declarations – completely unworkable.
  • Hauliers having to use a second IT platform ‘SFS’, which is also still not available.
  • For exports, ‘Permission to Proceed’ status being required before loading – current regulations do not permit this unless the origin warehouse is specially approved.

I wonder how the border survived since 1993 – and continues to do so to this day – with trade between the UK and non-EU European countries?  Makes you wonder, doesn’t it?  I know – why not ask someone in Dover who makes this work?  No – that would be too obvious.  Let’s bury our heads in Whitehall; the inexperienced know best.  Am I alone in suspecting a ‘white noise’ Remainer plot to sabotage Brexit? 

A word to those who seem to know best.  Make version two work.

David

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