60.As we noted in Chapter 1, if the Commission’s proposal is eventually agreed, this is highly likely to be after the post-Brexit transition period, and EU law will no longer apply to the UK (see paragraph 20). If the Government chose to retain clock changes in the UK, there would be variable time differences between the UK and its EU neighbours during the year. This chapter considers some of the implications of such non-alignment.
61.Dr Heather Rolfe, Head of Research, Demos, argued that the implications of non-alignment could be of a different order of magnitude to those of existing time zone differences: “If there is non-alignment all year round”, as with existing time zones, “it is predictable”, but “if for half the year there is alignment and for the other half there is not, that is when complexity is added.” She suggested that non-alignment could affect externally facing sectors of the UK economy such as “transport, tourism and trade” and “add cost at a time when businesses will be under more strain because of Brexit”.
62.The Scottish Government also recognised the implications for “sectors and companies involved in export markets” in the form of “additional administrative activity”. According to Dr Katy Hayward, Reader, Queen’s University Belfast, and Senior Fellow, The UK in a Changing Europe, non-alignment would “affect predictability” for firms, which she described as “one of the key concerns in trade”. Duncan Edelsten, a private individual, also argued that non-alignment on clock changes could make UK-EU trade “more inconvenient”.
63.UKTPO could not identify any study on the implications of clock changes arrangements for inter-country trade. It noted, however, that academic literature on time zones pointed towards “the desirability of minimizing time differences between trading partners, in particular where these differences are above 1.5–2 hours”. It therefore suggested that the potential three-hour time difference that could arise between the UK and EU countries in the Eastern European Time Zone (such as Finland), if the former retained clock changes and the latter adopted permanent summer-time, could negatively affect UK trade with these countries. They told us that the manufacturing sector was likely to be hit the hardest, through “higher communication costs and non-overlapping working hours”, with services that “require real time interaction for delivery” also affected.
64.Ofgem provided an “initial assessment” of the implications of the proposal to end clock changes in the EU on Great Britain’s gas and electricity market. Great Britain’s gas and electricity markets are connected to EU markets through interconnectors, which allow energy to be imported and exported according to market signals. Great Britain tends to import energy when GB prices are high, such as when it is cold, and exports when GB prices are “lower compared to other markets”. Thus, the benefits of interconnectors derive, at least in part, from non-coincident peaks in demand.
65.There are currently three electricity interconnectors between Great Britain and Belgium, France and The Netherlands respectively, and two with Ireland. All operate in both directions. Plans are also underway to create “a pipeline of new interconnectors that could increase total GB electricity interconnector capacity from 5 GW to 16 GW”. Gas interconnectors are also in place between Great Britain and Belgium, The Netherlands and Ireland.
66.Ofgem explained that its economic analysis of the new planned electricity interconnectors was based on the “current seasonal time changes”, which give rise to “consistent differences … between Great Britain and continental electricity markets”. If Great Britain’s “peak times” “aligned with other markets, this would impact interconnector flows”, possibly “reduc[ing] the potential benefits of new projects”. In contrast, Dr Justin Andrews, Head of Design Authority, ELEXON, told us that peak times could play a less significant role for the operation of interconnectors in future: “The aim of the energy industry in future is to … remove peaks, using things like batteries and storage to try to smooth off.” He said that non-alignment between the UK and the EU would require “a fringe change to the computer systems of people who are either operating the electricity interconnectors or trading over them”.
67.Ofgem said that a more detailed assessment of the economic effects of the proposal would be required when “the final arrangements [were] clearer”, but it considered that the abolition of seasonal changes of time in either the UK, EU, or both, would not “fundamentally change supply and demand levels” of gas and electricity in Great Britain. It expected no “material impact on wholesale gas and electricity prices”.
68.Mr Ireland of IATA highlighted that, even if the UK retained clock changes after leaving the EU, airlines flying between slot-coordinated airports in the UK and EU would need to review their schedules to accommodate the new time arrangements of EU Member States. He told us that EU routes represented 50% of traffic at Heathrow and between 70% and 87% in the other six UK airports classified by IATA as Level 3, that is, with high congestion levels.
69.The Government stated that it had “no plans to implement this proposal” after the UK’s withdrawal from the EU. The Minister reiterated the Government’s opposition to the proposal in oral evidence, but recognised that the Government would “need to go away and consider [its] response” if the proposal were to become EU law.
70.Dr Andrews asked whether any lessons could be learned from the period until 1995 when the UK and Ireland switched to winter-time one month later than other EU Member States. The Minister told us that there had been no analysis of the economic evidence from those years. In proposing full harmonisation of the dates of clock changes in 1993, the Commission cited a “study” highlighting “numerous drawbacks for consumers and … sectors” as a result of non-alignment, but that study does not seem to be publicly available.
71.A more recent example of non-alignment within Europe is provided by Turkey, where clock changes have been discontinued and permanent summer-time applied since 2016. As a result, the time difference between Turkey and EU countries has increased by one hour during winter-time, reducing the number of common operating hours between Turkish and EU businesses. The Turkish Industry & Business Association (TÜSİAD) told us that, in the experience of its members, this was “an indirect barrier to trade in goods and service alike”. TÜSİAD noted the three-hour difference between Turkey and the UK, which means that, “when the UK reaches early afternoon, Turkey is fast approaching close of business”. On the other hand, the Turkish government had received “no negative feedback” about the change, including “from the Turkish Airlines and financial institutions which were expected to be affected the most from the transition”. Mr Ireland, however, told us that one airline operating in Turkey did experience connectivity impacts because of its decision to maintain its schedules in Coordinated Universal Time (UTC), rather than making changes according to the new local time, which meant it could no longer offer “preferred times” to consumers.
72.Dr Prerau pointed to examples of non-alignment in the Americas, such as the province of Saskatchewan, Canada, which had “followed year-round standard time for many years”, despite neighbouring provinces observing clock changes, and the US state of Arizona, which experiences non-alignment both within and without:
“During each summer the following occurs: the semi-autonomous Hopi Native American Reservation follows standard time. The Hopi Reservation is surrounded by the Navajo Reservation, which follows [Daylight Saving Time (DST)]. The Navajo are surrounded in Arizona by the rest of the state, which uses standard time. And the state of Arizona is surrounded in the US by all its neighboring states, which follow DST.”
73.Some witnesses also referred to the patchwork of time arrangements existing in Australia. As Dr Prerau put it:
“Some provinces utilize DST, and some, in the same time zone, do not. This, combined with Australia’s three time zones, yields a yearly summer situation where there are five different times in Australia for all the summer months, while only three different times (following the time zones) in winter.”
74.Chris Pearce, a historian of seasonal time arrangements in Australia, focused on Queensland, which, unlike neighbours to the south, does not observe clock changes. He told us that there was much public debate about whether Queensland should align to its neighbours’ time arrangements, with southern parts of the state supporting alignment and northern regions emphasising the incompatibility of clock changes with the local climate. He noted that non-alignment tended to “cause a lot of inconvenience” to people regularly crossing the border (such as for work or study), but also to businesses and government because of the reduced number of common working hours. A 2013 survey conducted among 2,300 Queensland businesses by the Chamber of Commerce & Industry Queensland had estimated the cost of non-alignment at $4.35 billion a year, although Mr Pearce cautioned that this figure was based on “information given by only a little over a quarter” of respondents.
75.We heard general concern that variations in the time differences between the UK and its EU neighbours might add complexity for UK businesses trading with the EU. Evidence on this point was, however, far from detailed or conclusive.
76.We are surprised that the available evidence regarding the consequences of non-alignment is relatively scant. Further research is needed into the general effects of clock changes, as well as the specific impacts for people and businesses of non-alignment of seasonal changes of time, for example as experienced in Australia and North America.
77.From the evidence we heard, it was clear that non-alignment could lead to an increase in the time differences between the UK and its EU trading partners, reducing the number of common operating hours for businesses. Academic studies, and anecdotal evidence from Turkey and the Australian State of Queensland, suggest that this could pose an obstacle to trade in some sectors. Moreover, any change to the time differences between the UK and EU could alter the economic benefits of gas and electricity interconnectors.
78.Considerably more evidence is also required to understand the implications of the Government’s current plans to retain clock changes even if the EU abolishes them. A starting point could be provided by evidence from the pre-1996 period, when the timing of the autumn clock change was not fully harmonised across the European Economic Community.
79.If Ireland discontinued clock changes while the UK retained them, Ireland and Northern Ireland could find themselves on different times for five or seven months a year, depending on the permanent time zone chosen by Ireland.
80.Time is a reserved matter for Scotland and Wales, but there is no equivalent exception or reservation for Northern Ireland. The Minister told us that the Northern Ireland Executive would have full discretion over its time arrangements and could choose between a time border with Ireland and one with Great Britain in the event of non-alignment. However, under the terms of the Withdrawal Agreement between the UK and the EU, and the Protocol on Ireland/Northern Ireland, Northern Ireland is required to maintain close alignment with the EU’s Single Market rules. Given the single-market legal basis of the proposal to abolish seasonal changes of time (as noted in paragraph 12), it is difficult to be clear whether Northern Ireland would be free to choose a time border with Ireland, should it so wish.
81.The Centre for Cross Border Studies noted that any time border would “offend either nationalist or unionist sensitivities” and “add to the stresses imposed on the [Good Friday] Agreement as a result of the wider context resulting from Brexit”. For the duration of our evidence-taking, the Northern Ireland Assembly and Executive were suspended, being restored in January 2020 after three years. This prevented us from seeking evidence directly from either the Northern Ireland Executive or Assembly members. However, Dr Hayward noted that the devolved institutions would have an important part to play in making decisions about time arrangements, and that the absence of those institutions would complicate the “decision-making for Northern Ireland in managing the working out of any time zone change”.
82.The depth of economic and social integration in the border region of Ireland/Northern Ireland is widely recognised. Data by the Northern Ireland Statistics and Research Agency (NISRA) shows that, in 2017, exports of goods and services from Northern Ireland to Ireland amounted to £3.9 billion (6% of Northern Ireland’s exports). Of these, 47% were attributable to 94% of Northern Ireland small and micro-businesses—those with fewer than 50 employees. Imports from Ireland to Northern Ireland were £2.2 billion. Dr Hayward highlighted to us that Northern Ireland’s exports to Ireland, while smaller in value than those to Great Britain, were not so in volumes.
83.Cross-border movements between Ireland and Northern Ireland are more difficult to quantify, owing to the lack of comprehensive, comparable statistics. A September 2017 study by the Office for National Statistics (ONS) estimated 110 million border crossings annually “for all reasons including work, business, trade, education, health and family reasons”. The 2011 censuses for Ireland and Northern Ireland found that 14,800 people regularly travelled across the land border for work or study, of which 6,500 travel from Ireland to Northern Ireland and 8,300 in the other direction. A 2016 report by the Centre for Cross Border Studies placed the total number of cross-border work commuters between 23,000 and 30,000.
84.Witnesses told us that non-alignment of time arrangements would be, in several respects, at odds with the organisation of life along the land border. Respondents to a 2019 survey in the Central Border Region, which Dr Hayward and Ben Rosher summarised in their written evidence, said that it would become much more difficult to coordinate within households or rely on facilities and services on the other side of the border. The Centre for Cross Border Studies agreed that different opening hours could be a barrier to accessing “essential services” such as “schools, colleges, health service providers, post offices and retail”, noting that cross-border workers “with childcare or other care responsibilities” would be especially affected.
85.In oral evidence, Dr Hayward focused on cross-border transport services and the complexity of adjusting to time differences for some of the year: “It would be a matter not just of changing schedules but of synchronising timetables so that you can make sure that a bus meets a particular train to get to a particular ferry, for example.” The Centre for Cross Border Studies noted that non-alignment for only part of the year would be particularly disruptive.
86.Dr Hayward told us that certain population groups in the border region were particularly reliant on public transport, such as commuting nurses, who formed “a substantial proportion of the cross-border workers”. She also gave the example of children from Northern Ireland attending school on the other side of the border, who could be further disadvantaged if the Irish Department for Education were to adjust school times in the event of Ireland adopting a year-round time zone.
87.The Royal Society for the Prevention of Accidents (RoSPA) told us that an asymmetry in time arrangements might exacerbate driver fatigue among “communities and those driving early and late in the day” in the Irish border region, so increasing the risk of road accidents.
88.The Centre for Cross Border Studies hinted at the possible loss of productivity across companies employing cross-border workforce. More broadly, the evidence we received indicates that a time border would pose various challenges to businesses in Northern Ireland. The Northern Ireland Chamber of Commerce and Industry (NI Chamber) referred to a 2017 study indicating that “each hour of time difference reduce[d] international goods trade by between 2% and 7%”. Dr Hayward agreed that “adding a time difference to trade” was “like adding distance to trade”. The UKTPO, on the other hand, concluded that “a time difference of one hour at the border with Ireland should not have a material impact on international trade”.
89.The NI Chamber noted that firms that operated on both side of the border could experience difficulties with their “systems, communications, logistics which in turn could have costs implications at the very least in the short term”. Dr Hayward highlighted the importance of efficient logistics operations for the all-island economy: “We have very closely integrated supply chains, and a third of that trade is in agrifood, so we have just-in-time elements coming in there.” The Freight Transport Association (FTA) gave the example of a lorry leaving Newry in Northern Ireland at 7 am and arriving in Dundalk after 20 minutes: “In Irish/EU time it may only be 06.20 with the premises not opening until 07.00hrs therefore the driver is left sitting for 40 minutes to unload.” If, on the other hand, Ireland were one hour ahead, by the time the lorry arrived the deposit would have been “open for one hour and awaiting delivery of goods”. As a result, “the business in Northern Ireland would have to open earlier and pay extra costs to ensure their working timeline corresponded with businesses just over the border”.
90.Several witnesses emphasised the risks for smaller operators, which, as Dr Hayward told us, represent the vast majority of business in Northern Ireland. The Centre for Cross Border Studies observed that the burden resulting from a time border “may not be prohibitive” in absolute terms, but could become so for “smaller enterprises or those operating on already tight profit-margins, especially in the context of Brexit”. The NI Chamber raised similar concerns.
91.Finally, Ireland and Northern Ireland are both part of the Single Electricity Market (SEM). SONI Ltd, which operates the SEM’s transmission systems for Northern Ireland, told us that, while the SEM’s internal systems were set in UTC, and so would not be affected by non-alignment of clock changes, it would be necessary to retain a “common system wide” time for settlement and balancing reports exchanged between the SEM and market participants. Further, since the SEM was “legally designed to have one time corresponding to the time in Belfast”, it would “continue to operate according to the time requirements of Northern Ireland”.
92.We received substantive evidence that a time border between Ireland and Northern Ireland would have wide-ranging practical repercussions for individuals and businesses. A time difference for only some of the year, in a scenario where one part of the island of Ireland retains seasonal changes of time, would add greater complexity.
93.The implications of a time border between Northern Ireland and Great Britain received considerably less attention from our witnesses. IANA noted that, if Northern Ireland followed different time arrangements to Great Britain, “a new entry ‘Europe/Belfast’” would have to be created in IANA’s time zone database. Moreover, competent authorities would need to specify the official name and abbreviation to be used for identifying Northern Ireland’s time arrangements, “to avoid naming confusion in computer applications”.
94.The Government’s evidence made no reference to the specific implications of the Commission’s proposal for Northern Ireland. When asked, the Minister told us that the Government “completely [opposed] anything that would create a time border on the island of Ireland”. Asked whether the Government had assessed the implications of such a time border, she stated: “We are unclear whether this EU regulation will become law. We are waiting to see what the impacts are and we do not have a clear timetable.”
95.While reiterating that that it would be for a future Northern Ireland Executive to set its own time arrangements, the Minister told us that the Government would not favour a time border between Northern Ireland and Great Britain: “We want the whole of the UK and Northern Ireland to operate within the same timeframe.” Nevertheless, she said that the Government had not done any work on the implications of a domestic time border: “It would be very difficult to give an opinion if we had to decide what would be the best way forward.”
96.If the EU were to discontinue seasonal changes of time but the UK decided to retain them, a future Northern Ireland Executive would have to choose between having a one-hour time difference for part of the year either with the Republic of Ireland or with the rest of the UK.
97.Regions along the Ireland-Northern Ireland border share deep economic and social ties. Supply chains are closely integrated. It is normal to work or rely on public services, such as hospital and schools, on the other side of the border. There is no question that a time border would have enormous practical implications for firms and citizens in Northern Ireland, disrupting well-established ways of doing business and organising daily life.
98.We note that the Government has recently negotiated a Withdrawal Agreement with the EU that ties Northern Ireland closely to the rules of the EU’s Single Market. In evidence, the Minister repeatedly emphasised Northern Ireland’s autonomy to set its own time arrangements in the future. However, were this proposal to become EU law under its current single-market legal basis, Northern Ireland may be obliged under the terms of the Withdrawal Agreement and the Protocol on Ireland/Northern Ireland to align with the EU and thus institute a time border with Great Britain. We suggest that the Government should give urgent further consideration to the impact that the Withdrawal Agreement and its Protocol on Ireland/Northern Ireland will have on the ability of Northern Ireland to make its own arrangements in future.
99.The implications of a time border between Northern Ireland and Great Britain have attracted less attention and are therefore not well-understood, but in addressing the question of the ability of Northern Ireland to make its own arrangements in the future, we also ask the Government to assess the likely economic impact on Northern Ireland/GB trade of different time zones within the UK as a result of the obligations set out in the Withdrawal Agreement.
63 For example, if clock changes were abolished in the EU, France might decide to apply its winter-time (equivalent to GMT+1) year-round. If the UK retained its seasonal changes of time, it would continue to be one hour behind France in the winter months but move into France’s time zone during spring and summer. Conversely, if France had opted for permanent summer-time (GMT+2), the UK would be two hours behind France during winter and one hour behind it for the rest of the year.
64 (Dr Heather Rolfe)
65 Written evidence from the Scottish Government ()
66 (Dr Katy Hayward)
67 Written evidence from Duncan Edelsten ()
68 Written evidence from UK Trade Policy Observatory ()
69 Written evidence from Ofgem (). Ofgem has responsibility for gas and electricity markets in Great Britain, but not Northern Ireland.
73 (Dr Justin Andrews)
74 Written evidence from Ofgem ()
75 Level 3 airports, or slot-coordinated airports, are those where the transport demand of airlines exceeds the airport capacity for significant periods and all airlines must be allocated a slot, authorised by a coordinator, in order to land or take off. They are also called “fully coordinated airports”.
76 (Philip Ireland)
77 Written evidence from Department for Business, Energy & Industrial Strategy ()
78 (Kelly Tolhurst MP)
79 (Dr Justin Andrews)
80 (Kelly Tolhurst MP)
81 Proposal for a Seventh Council Directive on summer-time arrangements, , p 1
82 Written evidence from the Turkish Industry & Business Association ()
83 (Philip Ireland)
84 Written evidence from Dr David Prerau ()
86 Written evidence from Chris Pearce ()
87 (Kelly Tolhurst MP)
88 Revised Protocol on Ireland/Northern Ireland (17 October 2019): [accessed 30 January 2020]
89 See further discussion of the terms of the Withdrawal Agreement in European Union Select Committee, (1st Report, Session 2019–20, HL Paper 4), paras 129 to 171
90 Written evidence from the Centre for Cross Border Studies ()
91 (Dr Katy Hayward)
92 Northern Ireland Statistics and Research Agency, Northern Ireland Trade 2017/2018 (March 2019): [accessed 28 November 2019]
93 (Dr Katy Hayward)
94 Centre for Cross Border Studies, Border people briefing (May 2016): [accessed 28 November 2019]
95 Office for National Statistics , ‘Living abroad: dynamics of migration between the UK and Ireland’ (21 September 2017): [accessed 28 November 2019]
96 Northern Ireland Statistics & Research agency ,Census 2011 Ireland and Northern Ireland (June 2014) [accessed 28 November 2019]
97 Centre for Cross Border Studies, Border people briefing
98 Written evidence from Dr Katy Hayward and Ben Rosher ()
99 Written evidence from the Centre for Cross Border Studies ()
100 (Dr Katy Hayward)
101 Written evidence from the Centre for Cross Border Studies ()
102 (Dr Katy Hayward)
103 (Dr Katy Hayward)
104 Written evidence from the Royal Society for the Prevention of Accidents ()
105 Written evidence from the Centre for Cross Border Studies ()
106 Written evidence from Northern Ireland Chamber of Commerce and Industry ()
107 (Dr Katy Hayward)
108 Written evidence from UK Trade Policy Observatory ()
109 Written evidence from Northern Ireland Chamber of Commerce and Industry ()
110 (Dr Katy Hayward)
111 Written evidence from the Freight Transport Association ()
112 (Dr Katy Hayward)
113 Written evidence from the Centre for Cross Border Studies ()
114 Written evidence from Northern Ireland Chamber of Commerce and Industry ()
115 Written evidence from SONI Ltd ()
116 Written evidence from the Internet Assigned Numbers Authority ()
117 (Kelly Tolhurst MP)