Why are you proposing contingency measures for aviation but not for rail transport? Are you treating modes of transport differently in case of no deal?
“The withdrawal of the UK from the EU without a deal will cause disruption in all modes of transport, but to a different degree. In particular, some modes of transport benefit from an international system, which will remain in place in a no-deal scenario and provide limited, continued basic connectivity. Moreover, in many areas it is possible for economic operators to take preparedness actions. Contingency measures do not compensate for the lack of preparedness actions from stakeholders.
“In aviation, there is no existing regulatory fall-back option that would allow the continuation of basic connectivity for air transport services between the EU and the UK. In road transport, the existing fall-back options (European Conference of Minister of Transport’s quotas) is not sufficient to avoid major disruptions, which leads the Commission to propose a contingency measure to ensure some basic connectivity for road haulage.
“As regards the maritime sector, existing international rules will enable some basic connectivity. In general, EU rules already allow stakeholders and national authorities to prepare, before the withdrawal date, for a possible no-deal scenario by making sure that they obtain the relevant certificate from an EU27 Member State (e.g. railway undertakings can establish themselves in one of the EU27 Member States to obtain an operating licence or they can request safety certifications from EU27 authorities, airline pilots can apply for EU27 licences, seafarers can obtain recognition in the EU27 of the UK certificate, etc.)”.