Select Committee on Northern Ireland Affairs Minutes of Evidence

Examination of Witnesses (Questions 240 - 259)



Memorandum submitted by the Northern Ireland Office can be found at Appendix 1


240  All the witnesses are extremely welcome. There is a bit of ground clearing, which we need to do in a moment, to make certain that we know exactly who the witnesses are, because there are slightly more witnesses than we were expecting. We are particularly grateful to both the Ministers for coming and indeed for so organising it that they could come together. We are the more appreciative that Lord Dubs has come because this subject is not his direct subject. He is very kindly standing in for the Minister of State. This is very much appreciated by the Committee. We will follow the usual rules of this Committee which is that, first, if at any stage we ask you anything, or you give an answer which you wish subsequently to gloss, either at the time or in writing, we will be entirely happy for that to happen. Equally, if there is a question which we fail to ask during the session, which we need to ask in writing afterwards, we hope you will understand that we might do this. We will endeavour to follow a logical order of questions but we have a very full house in the Committee today—which is itself an index of the importance which the Committee attaches to this subject and constitutes a direct and warm welcome to you—but, because we follow a logical order, the questions may come from different parts of the horseshoe and not necessarily one after another. I do not know whether there is anything either of the Ministers would like to say, of a preparatory nature, before we start asking questions. It would be helpful if we could clarify that the names are in all the right places and we know who it is we are looking at.

  (Ms Hewitt) Chairman, thank you very much indeed for that welcome. I do have a few preparatory remarks that I would like to make in a minute, if I may. Perhaps I could first introduce my two officials: Heather Massie, who is not John Pavel, Head of the Excise Policy Group at Customs and Excise; and Steve Kelly, who is Head of the Oils Policy Branch at Customs and Excise.
  (Lord Dubs) Could I, first of all, apologise on Adam Ingram's behalf. He is very sorry that he is simply not able to be here. On my immediate right is David Gibson, who is Deputy Secretary at the Department of Economic Development in Northern Ireland; and on the far right is John Ritchie, who is a Director in the Department of the Environment, Northern Ireland.
  (Ms Hewitt) Thank you very much, Chairman, for giving me this opportunity to attend at the Committee. I am very grateful to you for rearranging dates and enabling both of us to be here. I know that you have heard about the concerns of petrol retailers, and the concerns particularly about smuggling, when you took evidence from the Petrol Retailers Association and the Legitimate Oil Pressure Group. Also, I understand you visited Northern Ireland and gathered evidence directly on the ground. I want to stress that we, as a Government, are also aware of the situation in Northern Ireland with regard to the smuggling of road fuels and, of course, we recognise the very real problems which this is causing, alongside legal cross-border trading to legitimate retailers. I have had the benefit myself of recently meeting two delegations from Northern Ireland, one of whom was led by one of your own members, Mr McGrady, who brought with him Tommy Gallagher and Joe Burn. The other, David Trimble, came to see me, accompanied by Danny Kennedy and his economic adviser, Dr Graham Gudgeon, so I have heard very directly of the situation, particularly in the border regions. Now I thought it would be helpful if I said a little about the smuggling issue and then a few introductory words about the broader policy context. As far as the smuggling is concerned, of course, Customs and Excise take the lead in measures to deal with the problem of smuggled fuel, but they are very much helped in their evidence by a number of other agencies, including the Royal Ulster Constabulary, Trading Standards, and the Revenue Commissioners in Dublin. They have appointed a senior official in Northern Ireland, Dick Kitchen, to co-ordinate the effort against smuggling, and I understand a number of workshops have taken place with the other interested party agencies. I believe you have seen for yourself some of that work which has been done on the ground to counteract the problem of smuggling. I hope that you would agree with myself and my Ministerial colleagues that Customs are really working immensely hard to try to contain the problem and identify the smugglers and take co-ordinated action against them. I am very happy to come back to that in more detail in response to questions. As far as the broader policy context goes, the road fuel duty escalator is the cornerstone of the Government's environmental policy in addressing global warming. It is vital, in our view, if we are to encourage a sensible and sustainable use of road fuels. It was introduced, of course, by the previous Government in March 1993 as a way of meeting our Rio commitments. We continued it as a very important part of our environmental but also our fiscal policy. By 2010, if the escalator is maintained at the current level until 2002, we expect to see a reduction in CO2 emissions of between 2 and 5 million tonnes—a very significant step towards meeting both our Kyoto commitments and our own domestic commitments to substantial cuts in CO2 emissions. As well as that, the revenue raised from fuel duties, as a whole, is some £21 billion a year. I think I have observed that the road fuel duty escalator is sometimes held out as the sole cause of the problems that have been experienced in Northern Ireland. I do want to stress that this is really not the case. The price differentials that have arisen in fuel—and, of course, which used to work the other way round—have certainly been exacerbated by the present exchange rate between the pound and the punt, and now the pound and the euro. Of course, that affects you in Northern Ireland, just as it does everybody in the whole of the United Kingdom. I do want to stress the centrality of the fuel duty escalator to our environmental policy as a whole. That policy, of course, works for the benefit of everybody in the United Kingdom but, more broadly, we hope for the benefit of the people across the globe. I know you will be looking at options to help ease the situation in Northern Ireland and we will look at your recommendations with great interest, but the more you can bear in mind this broader environmental context into which the policy fits, obviously we would be very grateful. I look forwards to your questions and to answering those in as much detail as I can.

241  Let me ask a very general and open-ended question, which I would like each of you in turn to answer. How serious do you actually regard the problem that we are investigating to your Department?

  (Ms Hewitt) In terms of the Treasury, there is, of course, a revenue loss as a result of both the legal cross-border shopping and the illegal smuggling. But in the context of the overall revenues from fuel duties, it is really relatively small.
  (Lord Dubs) We regard it as serious because we do not want to condone smuggling as an activity. Therefore, we are satisfied that we are doing a great deal to limit the amount of smuggling that goes on and to catch the people doing it.

242  This is really a question for Lord Dubs. How far was the management of the problem in Northern Ireland assisted (or the opposite) by the answer given officially from the Treasury at an earlier stage—and it was in line with what the Economic Secretary has just said—that really £100 million was a bagatelle from the Treasury's point of view and really does not matter or count in the great scheme of things.

  (Lord Dubs) I do not think our position has been made difficult. We believe the overall policy is important, both for Britain and for Northern Ireland, and there is sometimes a price to be paid for it. That price is that, because we have a land border, we have certain difficulties. I am concerned, on behalf of the business interests who are suffering, but we have had in the past situations where the movement has been the other way and people have found that things are much cheaper in the Republic and they have gone there. At times it has been cheaper in Northern Ireland. This changes from time to time.
  (Ms Hewitt) I would just want to stress that we in Treasury and the other Chancellor's Departments completely share the concern of Northern Ireland colleagues about the smuggling problem, as well as the problem for particularly rural retailers. In the case of the smuggling problem, we have put substantial additional resources into Customs and Excise. We have increased their staffing by some 13 officers this year, who are dedicated to the problem of combating oil smuggling, so we certainly do not regard that as a trivial issue in any sense at all.

243  My only other question is one for the Economic Secretary and arises out of the supplementary comments you have just made. In the context of the extra officers that have been put into Customs and Excise in Northern Ireland, have they been put in, in line with what I would describe as historic Customs and Excise/Treasury practice, in terms of measuring what return you are going to get from those extra people; or have they simply been put in because the smuggling issue is one which you are determined to defeat?

  (Ms Hewitt) We have put them in because we are determined to do everything we can to counter and to stop if possible—certainly to catch—illegal smuggling. I was not the Minister involved in the initial decision and I would just turn to Heather on the question of whether there was a statement to say that it was a spend-to-save investment.
  (Ms Massie) Across the board, the allocation of our resources is designed to focus operational resources on the areas of greatest risk. So, therefore, it is always a question of relativities. The fact that we have allocated additional staff to Northern Ireland reflects the view we take of the increasing risk from oil smuggling. I do not think it is a precise trade-off between resources and revenue. It is question of looking at risks across the board and allocating the resources to questions of highest risk.

Mr Robinson

244  Perhaps in helping to set the scene for colleagues, I could encourage you to give us something of a handle of the scale of the problem. We had a Mr Holloway of the Petroleum Retailers Association here, and he said that during the course of 1998 something in the region of a quarter of a million tonnes, which would be a loss of revenue to the Treasury of over £200 million, had been smuggled. Do you think he exaggerates the case? What is your best educated guess?

  (Ms Hewitt) Thank you for that question. Yes, I do think those numbers are an exaggeration. It is not possible—certainly has not been possible for us—to separate out the impact on revenue of legal cross-border shopping and illegal smuggling. We assess from the Customs' end that the revenue lost through both those activities, the legal and the illegal, was about £100 million in 1998. So that is our assessment of the revenue loss but it does come from the cross-border shopping as well as the smuggling.

245  From all the evidence that we have taken, the problem appears to be getting worse because of the greater duty differential. In your Department, has there been any assessment carried out as to what is the medium-term likelihood? For instance, the Irish media have been expressing concern—for them, not for us—that they may be forced, because of European controls, to increase duty on fuel. Would that reduce the differential or would it affect us as well?

  (Ms Hewitt) I am not aware that we have made any projections looking to the future because, of course, that would depend on a whole variety of factors: not only our policy but, as you have indicated, the policy of the Irish Government; and also the exchange rate, which, as I have said, is a rather important factor in all of this. Customs are certainly going to continue to try to update and refine their assessment but in terms of what might happen in the Republic, the European Union, as a whole, has signed up to Kyoto. Each of our European Union partners will have to concern themselves as to how they want to meet their share of the EU Kyoto targets and any domestic targets which they may have set themselves, but that is a matter for the Irish Government, as it is a matter for any other government within the European Union.

246  It seems to me there are only three directions in which the Treasury can move in order to alleviate the difficulty. One is either to get good co-operation from the Government of the Irish Republic, or alternatively they will be forced to increase their duty; or enforcement; or some form of reduction for stations around the border. Have you looked at those three? Which is the most appealing to the Treasury?

  (Ms Hewitt) On the issue of a Dutch style scheme of supporting petrol stations around the border, I will primarily get Alf Dubs to address that issue because it is really one for the Northern Irish Office, but on the first two, there is very close co-operation with the Irish authorities on the smuggling issue. There are certainly discussions in a European Union context about higher minimum rates, for instance, for oil duty. Clearly that would be very helpful. We continue to make the case for that, particularly on environmental grounds, although I do not think there is any immediate prospect of agreement on that. We look at the fuel duty escalator, as I have indicated, as a central part of our environmental policy. It is not possible under European Union law, nor would it be desirable, to try and have different fuel duty rates for different parts of the United Kingdom. One therefore looks at the possibility, which has been raised by several people, of a Dutch style subsidy scheme. Now because that is a subsidy and not a tax allowance or a differential duty rate, it is not particularly a matter for the Treasury. If, at the end of the day, Northern Irish Ministers—or, in future, the Assembly—were able to come up with a workable justified proposal for a subsidy of that kind, we would not stand in their way; but we do not, in general, favour the use of subsidies as a way of trying to deal with the problem. This is because we do recognise that within the European Union, within a single market, one is always going to have cross-border issues; and in an open economy—indeed, this goes beyond the European Union—people will increasingly travel or, in some cases, even use the internet, to buy their goods in different places from where they live. I think I am right in saying that people come from Ireland to Northern Ireland to visits Marks & Spencer. Certainly a lot of people come from France to visit Marks & Spencer in mainland Britain. So that is a feature of an open economy and a single market. It does create very real problems, as I have indicated, but it would be a matter for the Northern Ireland Office to decide whether or not a Dutch style subsidy scheme was a sensible way to go forward.
  (Lord Dubs) We have obviously considered the possibility of a subsidy scheme and we see a number of serious difficulties. Firstly, a scheme on the Dutch lines is very complex indeed. I think the amount of subsidy is related to the distance from the border in the Netherlands, and we find that this would be hard to do. It would be pretty costly. I think the difficulty affects the petrol trade all over Northern Ireland. We cannot confine the difficulty to the border, even in Northern Ireland, but it goes further than that. It would be a costly thing. I think also that it would be perceived to be unfair because there are many other industries and businesses that do say they are suffering from competition because of the exchange rate against the Irish currency, and it would be seen to be unfair to help one industry and not the others. Whether it would be effective enough in actually dealing with the difficulty, I suppose would depend on the scale of subsidy. I suspect that we might not be able to adjust it for that to be properly effective. Above all, it would be an administrative nightmare. We would have to set up a whole system to deal with the subsidy. We would have to work out some turnover figure for each petrol pump and so on. For all those reasons we feel that it is not the best way forward. Now, could I say on enforcement, if I could just endorse what has been said. We believe that there is very good co-operation indeed between the Customs and Excise people in Northern Ireland and our opposite numbers in the Republic, as there is as good a co-operation on this and other issues between the RUC and the Garda. We feel that co-operation is leading to a significant number of detections in smuggling activity.

247  I will not take any further the issue of subsidy. Colleagues will want to do that. On the issue of enforcement, how satisfied are you of the level of prosecution arising out of enforcement action? I have to say that I am not as convinced as you appear to be that a good job is being done here. The most significant prosecutions came just immediately prior to this Committee visiting Customs and Excise in Belfast. I am not sure whether there was any connection between those two events but I am wondering: is there not more that could be done as far as enforcement is concerned?

  (Ms Hewitt) Would it help if I gave some figures? I am sure Customs and Excise were pursuing active prosecutions anyway, but perhaps you are really illustrating the merits of Select Committees! Since the beginning of last year, Customs have seized 68 vehicles, something over 884,000 litres of fuel. They have had admissions of smuggling of a further 29.1 million litres. A total of 39 people have been arrested. Twenty-seven cases have been recommended for prosecution or compounding, and a total of seven compound penalties have been imposed, totalling £78,300. As far as the prosecutions themselves are concerned, there have been five successful prosecutions to date, one of which resulted in a 18-month sentence suspended for two years. Twelve further cases are with the Director of Public Prosecutions. Now it is perhaps hard to say whether the penalties that will be meted out by the courts (if those cases are successful in securing a conviction) will be enough to act as a deterrent to the smugglers but I think one does have to stress that the court action and the threat of punishment at the end of it is not the only deterrent. This is because people who are found smuggling fuel and selling smuggled fuel will also see their vehicles seized and not restored and, of course, they could face substantial fines. Customs also has the power to assess the smuggled fuel for duty in appropriate circumstances. So there is a variety of sanctions there which Customs is deploying and will continue to do so extremely assertively.

  Mr Robinson: The temptation to go on, Chairman, is huge but there is a large committee so I will pass the baton over.

Mr Salter

248  And I will happily pick it up. You are talking about enforcement action, but what you are actually saying is one 18-month sentence, suspended for two years. It is hardly going to put them off, is it, given that this is a multi-million pound racket. Quite frankly, what sort of deterrent do you think the current record of enforcement action is to the gangs and criminals behind the fuel smuggling between Northern Ireland and Southern Ireland?

  (Ms Hewitt) My understanding is that this is a relatively recent problem. The differential, having widened, and the exchange rate having had the impact I have described, has really created a problem—and it is hard, as I say, to assess exactly how much the problem is of smuggling—in the last 18 months or so. So there is a real problem there, but I think it would be unrealistic to expect that we would have them all behind bars in the first year or so. Now we have five successful prosecutions—one, as you say, resulting in a suspended prison sentence—but there is the pipeline of further cases that are with the Director of Public Prosecutions, or waiting to go to him, and some highly successful actions in terms of seizing vehicles. I would have thought that those were effective deterrents and that it is too early perhaps certainly to reach a conclusion that we are powerless in the fight against smugglers. I do not think that is true at all. Lord Dubs I do not know whether you want to add to that.
  (Lord Dubs) I cannot add very much. I think it is based partly on detection and partly on intelligence information. Therefore, the better the co-operation between Northern Ireland and the Customs and Excise and the Garda in the Republic, the more likely there is to be increased intelligence forthcoming, which will enable more of these people to be caught, as well as detection when they are simply driving along and stopped. So both come into play.

249  I would like to see that. You have said, that you think enforcement action taken thus far is an effective deterrent. That is what you have said for the record. What evidence have you, therefore, that illegal fuel smuggling is now reducing?

  (Ms Hewitt) I did start by saying that it is almost impossible to get an accurate estimate of the scale of the smuggling. That is in the nature of smuggling. But I do think that the numbers, in terms of vehicle seizures and admissions of smuggling that Customs have so far achieved, are impressive. I would also stress the fact that we have increased the Customs staffing in Northern Ireland by more than 50 per cent since the beginning of this year. So in the last six months Customs have had an extra 13 full-time staff to deal simply with this problem. We know—not from this situation but generally from what works as a deterrent to criminal activity—that the most effective deterrent is the fear of detection. The penalty you get if you are prosecuted and convicted is only part of the picture. The more people we have working on this problem and the more effective co-operation we have, as Lord Dubs has indicated, the more that people who have moved into this illegal smuggling business will decide that the risk of detection is simply too big a risk to run.

250  Let us move on. For the record, what you are saying is that you are not sure whether it is getting worse or getting better.

  (Ms Hewitt) I do not have the evidence to tell you whether it is going to get worse or better just at the moment.

251  Our evidence certainly indicates that the problem is endemic and that there is a general feeling of the acceptability of smuggling. For many years it used to be smuggling butter and milk and cows and sometimes it went north and sometimes it went south. There is also significant evidence of paramilitary involvement in the illegal fuel racket. Is there not a compelling case to invest even more in Customs and Excise, in enforcement action, to stem the flow of funds into the coffers of paramilitaries, both on the Republican and the Loyalist sides who, from the evidence we have received, stand to benefit tremendously from the continuation of this particular activity?

  (Ms Hewitt) We have given Customs and Excise the resources that we believe they need to deal with the problem that they are facing. Certainly the view that Customs and Excise have given to Ministers is that they have now got the resources that they need to tackle this problem. If they decide that they need more resources, then I am sure they will come properly to Ministers and tell us so, and we will then have to make a judgment.
  (Lord Dubs) As far as the RUC are concerned, they are well aware of what is happening, and I am satisfied that they are doing everything they can to stem the flow, whether it is done in association with paramilitary organisations—it would be surprising if some time it were not—or whether it is done in terms of illegal activity for financial gain. As I say, I am reasonably satisfied that the RUC are doing what they can, that they have the resources with which to deal with it, and that they are getting good co-operation. In the end there are so many small roads, there are so many ways things can be taken across the border, that one cannot stop it all. One would be naive to suggest that. The thing is to stop the bulk of it and to catch the big operators who may be behind some of it.

252  Finally, Chairman, Members of the Committee would certainly encourage Ministers to take a look at the aerial photograph that we have seen. It does not appear to be an agricultural environment any longer.

  (Ms Hewitt) I am intrigued by that invitation.

Mr Donaldson

253  May I deal, first of all, with the role of the Northern Ireland Office in this issue. Lord Dubs spoke earlier about the seriousness with which the Northern Ireland Office treats this issue. May I ask: how long has Adam Ingram been the Minister responsible for the oil and petroleum smuggling issue in the Northern Ireland Office? Which Minister was responsible before Adam Ingram was appointed to that responsibility? Why did it take over a year before a Northern Ireland Office Minister was prepared to meet industry representatives, if you feel this is a serious problem?

  (Lord Dubs) Adam Ingram has been the Minister in charge of the Department of Economic Development since May 1997. He was appointed just after the election. Baroness Denton was the Minister who preceded him before the election. Adam Ingram met the industry just recently. The Secretary of State has met the haulage industry. Adam Ingram and I are both meeting the industry again next week or the week after. I think we are sensitive to the concerns and we are happy to meet the industry and discuss it further with them.

254  So what you are saying is that Adam Ingram has been dealing with this issue since he was appointed a Minister in the Northern Ireland Office over two years ago.

  (Lord Dubs) Yes. He has had responsibility for that and another department since the election.

255  With respect, Lord Dubs, there is a difference between having responsibility and dealing with an issue. The evidence I have is that the Northern Ireland Office has ignored this issue for some time. That whilst there has been responsibility as such, they have rather left it to Customs and Excise to get on with it, and that the Northern Ireland Office, at Ministerial level, has not really been engaged with this issue until recently.

  (Lord Dubs) I cannot speak for the details of Adam Ingram's workload over the last two years. It would be presumptuous of me to try. I believe we have been aware, as a Government, of the issue. However, it has hit the headlines only over the last few months in a big way. In one sense it is a recent issue, if one looks at the columns of the newspapers in Northern Ireland, and if one hears the representations made by the industry and by politicians. It has only stepped up greatly in the last two months compared with what it was before. I would be very surprised if Adam Ingram had not devoted himself to this issue ever since he was appointed after the election.

256  I will only comment, Chairman, that our Committee has been engaged in this inquiry a lot longer than two months. We, as a Committee, identified this as a serious problem some time ago. That is why we embarked upon this inquiry. Therefore, I am bound to say that your response does indicate that NIO has come late to the issue, but we will leave it at that.

  (Lord Dubs) However, may I say, we treat it very seriously and, as I said, the Secretary of State has had meetings with a sector of industry. Adam Ingram has. We are both having a further meeting with the industry, as well as dealing with numerous representations from politicians and other people. We treat this as serious and I believe we have always done so.

257  I welcome that, Chairman. My colleague, Mr Salter, was probing in terms of whether this problem is increasing or decreasing. Are you aware, for example, that in the last two weeks alone complete tanker loads of diesel, smuggled from Ireland, have been offered to retail filling stations in London, and that the profit margin on each tanker load is £8,000 in cash? Is it not the case that this problem is, in fact, extending now beyond the confines of the Island of Ireland? There is evidence of the smuggling having reached Scotland and now we have evidence that it has reached London. Is it not the case that the problem is increasing, and not just increasing in terms of Northern Ireland but indeed throughout the United Kingdom?

  (Ms Hewitt) There are reports—and Customs and Excise have made me aware of them—of cheap fuel being offered to retailers in the London area. There was certainly a case in Liverpool of the smuggling of Irish green diesel by ferry from Dublin by a haulier based in Liverpool. That was between August 1997 and June 1998. In June 1998 Customs staff arrested the participants and seized a number of vehicles and green diesel. The green diesel was described in the shipping documents as cream or tallow and the case is currently awaiting court proceedings. But it is very difficult to envisage a wholesale smuggling of fuel into Great Britain from the Republic of Ireland. This is because there are relatively few entry points into the mainland and, of course, those are capable of much closer control than the long land border between the Republic and Northern Ireland. That control is particularly easy to achieve when you are talking about commercial movements by tanker. It is, as I say, a very different matter with respect to the land border with Northern Ireland, where you have small roads and large numbers of crossing points. There is no complacency at all, either amongst Ministers or Customs and Excise, about this threat; and the entry points at ports are aware of that risk and are looking at that route.

258  You referred, in your opening remarks, to meetings you had had with political representatives from Northern Ireland, and I am sure that has been valuable. Could you confirm whether, in fact, you have had any meetings with industry representatives on this issue? If not, is it your intention to have meetings with industry representatives to hear, at first hand, the problems they are facing?

  (Ms Hewitt) Following representations to the Government generally from, for instance, the Road Haulage Association, we made the decision to establish the Road Haulage Industry Forum, which was formerly chaired by John Green and is now chaired by Helen Liddell, as Minister of Transport, and of which I am also a member. So we now have a forum for Ministerial contact with the industry. I think that has been welcomed by the industry—certainly by the Ministers—as it is an extremely useful forum in which to engage in debate on these issues.

259  Therefore, you have no plans yourself, at this stage, representing the Treasury, to meet with industry representatives to hear, at first hand, their concerns about the problems that they are facing; and to hear some of the suggestions that they have to make?

  (Ms Hewitt) If you are talking generally about the problems facing the road haulage industry, specifically the petrol industry, I am pretty certain, (and I will double check for the record), but I do not think that I have been asked for a meeting[1] I have explained to the political representatives—and indeed in Parliament—the situation; the reason why we have the fuel duty escalator. I have also explained the steps that have been taken, in terms of strengthening Customs and Excise against the smuggling, but I suspect that a discussion with the petrol retailers—and particularly a discussion around the subsidy Dutch style of proposal—would really be one for my Northern Irish colleagues rather than me.

  (Lord Dubs) Of course, as I indicated, we do have such meetings and we are going to go on having such meetings, but the point we must make is that any points which are made to us in those meetings are certainly communicated to the Treasury or DETR as appropriate: so that Patricia and her Treasury colleagues will be aware of what is said to us by the Northern Ireland industry.
  (Ms Massie) In Customs and Excise, both at an operational and at a policy level, we have had long contact with the Petrol Retailers Association in Northern Ireland. We have had meetings going back over several years. We have always reported the outcome of those meetings and those concerns obviously to Treasury Ministers.

1   Note by witness: Both the Paymaster General in July 1998 and the Economic Secretary in October 1998 were approached for meetings by lobbyists on behalf of petrol retailing associations. Ministers receive many requests for meetings than they can accept and in both these instances Ministers were fully aware of the PRA case from their contacts and meetings with Customs and Excise and felt that a personal meeting was not necessary. Back

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