Select Committee on Trade and Industry Second Report


IV ADMINISTRATION OF SYSTEM


Departmental responsibility

56. The DTI's particular responsibility in strategic export licensing is for the integrity of the system, as the Minister responsible emphasised to us in oral evidence.[121] Other Government departments, principally FCO, MOD and DFID, but also the intelligence and security agencies and others with technical expertise, have advice to offer on specific applications: it is DTI who hold the ring, and issue licences. The system is administered by the Export Control Organisation, consisting of around 135 staff, over half of whom are in the Licensing Group devoted to processing applications and providing technical advice.[122] The ECO is located in the DTI office in Kingsgate House, Victoria Street. Members of the Committee paid a most instructive informal visit there in early November 1998, and were able to see the practicalities of licence processing.

57. The Scott Report raised the question as to where in Government responsibility for administration of export licensing should lie, expressing the view that administration of controls ran counter to a principal departmental interest of DTI in promoting exports. In their BMARC Report, our predecessors also recommended a review of current export licensing responsibilities, in particular as to which department should have the lead responsibility.[123] The 1996 Green Paper sought views on this matter.[124] The responses favoured either an independent authority or body giving an "extra degree of objectivity" or maintenance of the status quo but with an enhanced status and closer cooperation between the various players.[125] The 1998 White Paper announced the Government's conclusion that "the licensing authority should remain with the DTI",[126] a conclusion which has naturally disappointed those seeking change.

58. It is for general convenience that there should be some form of central point to which all licence applications can be made, whether covering military or dual - use goods. There is something to be said for it covering all export licensing, including works of art and animal products, with advice being sought in each case from expert departments. Those processing the application within the Government structure should be able to have access to the full range of expert advice. Those providing such advice are only able to do so authoritatively and with a degree of independence because of their daily involvement with work other than export licensing. The strength of the present system lies in its access to, for example, FCO Desk Officers profoundly familiar with a particular country and MOD technical experts on a relatively narrow area of technology. No independent authority could match that, without an absurd waste of resources. There is also a requirement for Ministerial involvement across departments, and for one identifiable Minister to take responsibility for decisions reached. Although we heard that only about 3 per cent of applications reach Ministers, and that only a handful of those few hundred lead to active inter - Ministerial discussion[127] this involvement is the necessary keystone of the system. Licensing of strategic exports is as much a matter of political judgement of risk as of technical assessment. It is logical to retain the central processing unit in that Minister's department.

59. We concur with the conclusion of the White Paper that the DTI is indeed the appropriate department. We have detected no excessive championing of intending exporters by the ECO: such is certainly not the impression given by their representatives. Transfer to the FCO, or separation from the DTI, might lead to an excessively negative regime of licensing. There are some grounds for seeking greater institutional recognition of the special nature of the ECO within DTI, and closer integration at a working level with HM Customs and Excise. The priority at present is however not to jiggle around with allocation of Ministerial responsibility for the licensing process, but to raise further its quality and speed.

Work of the ECO

General

60. It should be recorded at the outset that the ECO is praised as well as criticised for its performance.[128] One company responding to the 1998 White Paper stated that most of the officials were "courteous and helpful but like ourselves prisoners of a bureaucracy which is cumbersome and overly secretive". The management of ECO has shown an admirable recognition of the need for improvement in some areas. It must also be recorded that applicants do not always do themselves any favours in the way in which applications are submitted with evidently incomplete supporting material. The relationship between applicants and a licensing authority is not and should not be stress - free. The ECO is engaged in a formal process, ultimately subject to judicial review. We are encouraged by the prospect of closer liaison between the ECO and its clients, and of constructive co - operation in improving current weaknesses.[129]

Delays

61. The principal complaint about the licensing system is the inordinate length of time it can take to get a licence. Very few are refused: there were 89 refusals of basic Standard Individual Export Licences (SIELs) between August 1997 and August 1998.[130] This of course understates the real effect of controls, since some proposed exports will be turned down on the basis of a Form 680 rejection and others will simply not be sought in the first place. On 24 June 1998, however, there were at least 450 SIELs which had been awaiting decision for at least 2 months.[131] The ECO does not at present maintain details of what has been described as the "tail" of undecided applications, so that it cannot easily be discovered how many in this waiting list have been there for many months. The annual rate achieved hovers around 50 per cent, with a severe recent dip in performance attributable to uncertainty and the subsequent introduction of tighter controls in July 1998 following the nuclear tests conducted by India and Pakistan. Some 15 per cent of circulated applications in October 1998 were for exports to India or Pakistan; staff time devoted to these apparently had an unquantifiable knock - on effect on the processing of other licences.[132] Performance in 1997 was also affected by the need to adapt to the new July 1997 criteria, leading to a very high rate of referrals to Ministers of doubtful cases.[133] The target of 70 per cent achievement of 10 working days (2 weeks) for non - circulated applications has now been reached. Given the circumstances, it is perhaps disappointing that any non - circulated applications should still take more than 2 weeks. The ECO fails by some distance to meet its own target of processing within 20 working days 70 per cent of those applications requiring circulation to other departments: this covers most applications received.[134] It is possible to gain a snapshot view of how long licence applications have been waiting on a specified date: but DTI are "seriously considering whether we cannot find a means of recording timings in every case in order to be able to give a better more easily recoverable, picture of how long licence applications take to process."[135] We recommend that vigorous steps be taken to give a rounded picture of the ECO's performance not only in relation to its own targets, but showing the full extent and nature of the waiting - list of applications.

62. We received anecdotal but compelling evidence from witnesses of the reality behind the figures. Mr Douglas Garland, Managing Director of RBR International, a leading manufacturer of personal protection equipment (body armour, helmets, shields etc) had received only one licence within the 20 day target out of 9 applications made in the past year.[136] The Minister has accepted in subsequent evidence to us that a decision on a May 1997 application to supply helmets to UNHCR in Afghanistan had indeed taken too long: no decision had been made by the time the order was cancelled in July 1997.[137]Mr David Evans, Managing Director of Chemring plc, manufacturers of military pyrotechnics and other products, told us that, of 140 licences sought since January 1998, 40 per cent had taken over 50 days and 14 per cent over 100. One, for the export of stun grenades to Colombia, had been given provisional clearance through the Form 680 procedure, and a licence was submitted on 29 October 1997; it still awaits a decision, although the order has now been lost.[138] From subsequent evidence forwarded, it would seem that after several months consideration the FCO recommended refusal and that other departments, including MOD, sought a review of this decision. Other applications seem to have taken equally long. Some were for CS gas to understandably sensitive destinations.[139] Others included an application to export one 30 mm multi - purpose gun to a laboratory in an EU/NATO country for use in testing; this took almost a year. An application to export passive air defence countermeasures to another EU/NATO nation took 6 months. Mr Evans described the length of time for most of his company's applications as "unacceptable".[140] A company responding to the White Paper recorded an average time of 84 days for applications to be decided, and 3 applications taking between 18 and 23 months. These were for rifle and mortar parts to a South Asian country, including a safety device for the extraction of jammed mortar rounds. We can only hope that these examples are not typical.

63. The Scott Report proposed that the target time limits used should be formalised, and specifically that there should in effect be licensing by default in the absence of a decision within a prescribed time limit. The 1996 Green Paper sought views as to whether there should be such limits and if so how they might operate.[141] The 1998 White Paper turned down the idea of licensing by default, given the self - evident risk that licences might as a result be granted "contrary to the UK's international obligations or the Government's own policy", and set out steps being taken to improve the speed and efficiency of processing for decision.[142] The DMA felt that its arguments in favour of licensing by default had been unduly summarily dismissed.[143] While that may be the case, we can see little merit in it. It is clearly important to avoid creating a system which would artificially encourage a refusal, as a means of reaching a decision. We could not accept a system which carried with it the inherent risk of inappropriate export.

64. The time taken to process applications circulated to other departments depends to a significant degree on the speed with which those departments respond. Within MOD, applications are circulated by the Defence Export Services Secretariat to a range of expert advisers "in order to produce the agreed MOD recommendations". Within FCO, the Non - Proliferation Department is similarly tasked.[144] There is apparently an "informal" target of 10 working days for these departments to reach an agreed departmental view.[145] The extent to which they achieve that target has not hitherto been published.[146] The DMA and others have the strong impression that it is to consideration of licences by the FCO that most of the delay can be attributed.[147] If so that may well be for good reason, such as the need to seek information and advice from overseas posts on the end - user.[148] Annex E to the 1997 Guidance for FCO desk officers noted that 10 days is "a target, not a deadline" and that "speed is not the same as efficiency": it also acknowledged that "unnecessary delays in processing an ELA can lose the applicant company money or even a contract. Unexplained delays in the FCO damage our reputation." It would be pointless for DTI to take steps to speed up that part of the process for which it bears direct responsibility only to find that applications linger in other Whitehall in - trays. We recommend that some analysis be carried out and published of the reasons for other Government departments failing to meet a 10 working day target on export licence applications, and of steps which could be taken to improve performance.

65. In addition to delays, evidence from those doing business with the ECO has in the past expressed frustration with various bureaucratic problems —

  • The absence of reliable information as to the stage in the system which an individual application has reached, leading some applicants to believe that their application had been in effect lost in what one company described as "a black hole";
  • The onus being put on the applicant to chase up progress, rather than the officials concerned taking steps to hasten matters;
  • The inaccessibility for informal discussion or explanation of those in other departments — primarily FCO and MOD — engaged in reviewing applications;
  • Officials from different departments, or different divisions of the same department, seeking additional information which is unnecessary or which has already been provided, or failing to understand that which has been provided.

From our visit to the ECO and other sources, we are satisfied that some steps are being taken to address these matters. Applicants should be informed what is happening to an application which will not be decided within the time limit: be offered the opportunity to make direct representations in response to objections raised: and be assured of a decision one way or the other within an agreed further timescale

Appeals

66. There are relatively few appeals against refusals of licences: 15 in the most recent 12 - month period.[149] Following a recommendation in the Scott Report, the 1996 Green Paper sought views on the creation of a formal appeals procedure against export licensing decisions.[150] In response, the 1998 White Paper proposes a statutorily established formal system of appeals, not however independent as sought by the DMA and others but comprising senior expert officials.[151] Where a decision — primarily a refusal — has been taken by a Minister, the appeal would also be at Ministerial level. The right sought by some voluntary bodies for third parties to be able to appeal against grant of a licence has not been ceded, to their chagrin: but, as the 1998 White Paper observes, there is always the possibility of seeking judicial review of export licensing decisions.[152] There should be a time limit for determination of appeals as there is for giving notice of appeal. It is also our intention to ensure that appeals are subject to a degree of subsequent parliamentary scrutiny by select committee.

Judicial review

67. The system of export licensing has always been subject to judicial review. The Scott Report records the sobering effect on the DTI of the eventually unsuccessful case brought in 1983 by Chris International Foods Ltd of a refusal by the Secretary of State to licence the import of 200 tons of bananas from dollar area countries.[153] It was noted by several respondents to the 1996 Green Paper that the introduction of formal statutory purposes would make judicial review a livelier prospect, not only of refusals and grants of licences, but also of other stages in the process. The 1998 White Paper notes explicitly that making preliminary advice that no licence is required (NLR decisions) legally binding would have the effect of making "licence required" decisions subject to judicial review.[154] The proposal to set out some of the procedures in primary or secondary legislation, or even in statutory guidance, does in our view raise the spectre of judicial review to an as yet unappreciated degree. The DMA accepted that there was some prospect of a more litigious approach.[155] At least one company responding to the 1998 White Paper actively sought judicial review as an option. We understand that there has been a recent successful challenge in the German courts to the refusal by the authorities there of an export licence.

Open Licences

68. Whilst most licences granted are standard individual licences, much of the volume of trade in controlled goods is carried on under open licences. There are two types of open licences —

  • Open Individual Export Licences (OIELs) are specific to individual exporters, covering multiple shipments of specified goods to specified destinations: records have to be kept for 3 years (4 years for military list OIELs), open to inspection by ECO Compliance Officers.[156] There are currently around 1000 OIELs granted each year, valid for two years.
  • Open General Export Licences (OGELs) remove the requirement for licencing for specified goods to specified destinations, requiring only that the exporter register with the ECO its intention to make use of these derogations. There are 24 DTI OGELs in force; copies are publicly available.[157]

The system of open licensing grew in the late 1980s as a means of reducing the administrative burden on frequent exporters of making large numbers of "repeat" licence applications for export to standard destinations, and on the ECO in processing them.

69. The Scott Report noted that goods had been exported in the 1980s to, for example, Jordan under open licences, and had subsequently been diverted to Iraq, and concluded that "the grant of these OIELs left open a gaping hole in the procedural fences erected for the purpose of policing the Guidelines on defence - related exports to Iraq....".[158] Our predecessors' BMARC Report expressed concern at the use of open licences and recommended a review of their availability in view of possible diversion.[159] The system of compliance inspection has been substantially strengthened since the events on which earlier criticism was based. DTI told us indeed that "it may become increasingly appropriate to put more emphasis on self - regulation by making increasing use of OIELs ....", while accepting that it remained difficult to identify potential diversionary procurement routes at the moment of imposing an embargo.[160] OIELs are not exactly swift to procure. One company wrote that "we have found that DTI are keen to suggest that we apply for an Open Individual Export Licence in certain cases but that these have taken 6 - 12 months to be granted which somewhat nullifies the benefit of their offer."[161] Nor does the compliance record suggest that there are many breaches of the system.[162] It is obviously necessary to strike a balance between reducing the burden of unnecessary individual applications and retaining a degree of detailed control. We counsel caution in moving too rapidly towards yet greater use of open licences, and Open Individual Export Licences in particular: and look forward to detailed reporting of the nature of such licences granted in the Government's Annual Reports.

Electronic transfer

70. In its response to our predecessors Report on Exports to Iraq, the DTI announced that an integrated ECO - wide computer system was to be in place in 1993. It was in fact introduced in March 1995.[163] Our predecessors also noted that MOD had developed its own computer system incorporating data from ELAs, and that there was no mutual access between these departments. The Committee recommended that "the three departments (DTI, FCO, MOD) allow mutual access to their computerised information relating to export licensing and that the DTI export licensing database be developed for the benefit of all three departments."[164] The Government Reply accepted that there would be merit in more co - ordinated use of IT and reported that the scope for downloading licence data from the DTI's ECLIPS system was under consideration.[165] Such efforts were not however fruitful.[166] In addition to procedural difficulties, it became apparent in late 1997 that the ECLIPS database was in some respects seriously deficient.[167] Efforts are now therefore being concentrated on a new project, ELATE, designed to provide for —

  • submission of applications in electronic form, at first by posting a completed diskette, but eventually electronically[168]
  • transmission by DTI of this and associated data to other government departments, at first on diskette and, once a Government Secure Intranet is established, electronically
  • electronic transmission of completed licences to Customs and Excise, as well as to the applicant[169].

71. We have seen a hard copy and an electronic on - screen version of the proposed new application form, which should in theory save much time and repetitive work, as well as overriding the need for manual typewriters. Having been trialled it is due for introduction shortly.[170] Several of the companies in the trials are pressing for the introduction of down line transmission rather than postage of a diskette. Some notes of caution must be sounded. The past track - record does not give great cause for confidence that there will be a trouble - free introduction of ELATE. The associated material, notably end - user certificates provided from abroad and in particular technical documentation, may not be readily transmissible electronically, although applicant companies may already have digitalised versions of technical information. There are also issues of security between Government and applicant as well as within Government: of validation of electronic signatures: and of the requirement to keep records of transactions, not least for purposes of audit and parliamentary accountability. We are pleased to note the degree of progress made; the days of ever - thicker files of applications winding their weary way up and down Whitehall may be drawing to a close. We recommend vigorous pursuit of the programme of bringing the export licensing system into this decade before we embark on the next.

  SUMMARY OF RECOMMENDATIONS AND CONCLUSIONS

Legislation

(a) We note that the Queen's Speech makes no reference to the Bill. Given that almost 3 years have passed since all parties accepted the strong recommendation in the Scott Report that there should be a new legislative framework for strategic export controls, and that controls are still being operated under a barely refurbished piece of emergency legislation from 60 years ago, we hope that time can be found for such largely uncontroversial legislation. While it may be a nuisance to seek new legislative authority for other export (and import) controls, it can hardly come as a surprise to those concerned. We consider that it would in principle be desirable to repeal the 1939 Act and replace it with wholly new legislation, rather than seeking to amend it (paragraphs 3 and 9).

Annual Report and parliamentary scrutiny

(b) We hope that the Annual Report will include details of work underway within the Wassenaar Arrangement, including efforts to increase the number of participating states, and to pursue cases where there would seem to have been a failure of control by participating states. If, as we envisage, there develops a coherent form of UK parliamentary scrutiny of strategic exports, it will hopefully be possible to learn from overseas examples, and to develop a constructive relationship with similar bodies in other national parliaments (paragraphs 6 and 7).

Parliamentary scrutiny of secondary legislation

(c) The Scott Report devoted considerable space to criticising the absence of parliamentary scrutiny of the Orders made under the 1939 Act. The question of parliamentary scrutiny of Orders made under the 1939 Act and its eventual successor is therefore of central concern both because of a sorry history of 60 years of failure by Government and Parliament in this regard, and in the light of the attention devoted to it in the Scott Report. Parliament must be vigilant to ensure that new arrangements do not replicate the mistakes of the past. In order to ensure that significant changes are not slipped through Parliament without debate, we recommend that (a) drafts of Orders under the new Act be made available to this Committee in advance of their being made; and (b) that the Government undertake to find time for a debate on an Order if at least 6 Members so desire. On this basis, we consider that the negative procedure for orders laid under the new legislation will be found acceptable. We recommend that should Ministers wish to make any further Orders under the 1939 Act prior to the passage of new legislation, they give consideration to laying the relevant Order before the House (paragraphs 8 to 12).

Parliamentary scrutiny of primary purposes

(d) We welcome the opportunity to be provided soon for parliamentary scrutiny of the purposes of export controls, and urge Ministers to go the extra distance to provide an opportunity for proper examination and debate. We recommend that the principal list of purposes be set out in the primary legislation: and that power be given to Ministers to amend that list by secondary legislation subject to subsequent ratification by Parliament using the modified affirmative procedure as proposed in the White Paper for agreeing the original list (paragraph 15).

Parliamentary scrutiny of geographical application

(e) In seeking an appropriate degree of parliamentary scrutiny of secondary legislation on export controls, the absence of any equivalent level of scrutiny over the geographical application of controls comes sharply into focus . There are gaping holes in the system of parliamentary accountability governing the framework within which licences are granted, and in particular the geographical application of controls. Replacement of the 1939 Act will go only some way towards improving the situation (paragraph 17).

Parliamentary scrutiny of licences

(f) We are content at this stage to continue to leave individual decisions on export licences to Ministers who are accountable to Parliament, in accordance with constitutional conventions. Ministers can however only be properly held to account for their decisions if Parliament is in possession of the full facts, and has access on request to detailed casework on decisions taken by Ministers and those responsible to them. We cannot therefore accept the bald proposition advanced in the White Paper that there should be no parliamentary scrutiny of individual applications after a decision has been taken. What is required is a system of parliamentary scrutiny which combines the greatest possible access to the details of decisions taken — licences granted, refused and delayed — with safeguards to protect commercial confidentiality in the interests of individual exporters and customers legitimate demands for confidentiality. We share the view expressed that the existence of a robust system of parliamentary scrutiny can act as a useful prompt to officials and Ministers. We are confident that such a system can and will be developed (paragraphs 20 to 24).

National criteria and Code of Conduct

 (g) We welcome the publication of criteria for the grant of arms exports licences hitherto only technically accessible, providing the necessary yardstick against which to judge licences granted or refused. Comparison of the new criteria with their predecessors suggests however that the July 1997 criteria represent a rather less radical break with past policy than is sometimes represented to be the case. As before, Ministerial interpretation of the criteria in difficult cases is the touchstone of their real significance. We strongly favour the adoption of a slightly modified set of national criteria so long as it was clear that it was no more restrictive than the current set in its practical implementation. We would also welcome confirmation that any proposed changes to the EU Code of Conduct should be subjected to the new parliamentary scrutiny procedures for Common Foreign and Security Policy proposals (paragraphs 28 and 32).

Controls over weapons of mass destruction programmes

  

 (h) The legislation on extension of the scope of controls over participation in programmes of weapons of mass destruction could usefully be accompanied by clarification of the legal position under the Non Proliferation Treaty, and of the precise scope of the exemptions it is intended to permit by licence (paragraph 33).

Trafficking and brokering

(i) We welcome the limited proposals on trafficking and brokering, and recommend that their extension be considered only once experience has been gained of enforceability. We call on Ministers to explore further within the EU and the Wassenaar Arrangement the benefits and potential pitfalls of some multilaterally agreed form of licensing or registration of arms dealers (paragraphs 35 and 36).

Intangibles

(j) Grave doubts have been expressed as to the practicality of the proposals relating to transfer of technology by intangible means and fears raised as to their consequences if implemented. Given the degree of controversy raised over the proposals in the White Paper, there can be no question of the United Kingdom agreeing to an extension in the EU's dual - use regime, under whatever legal power, until a consensus has been arrived at on the way forward on controls of intangible transfer of technology generally. The Government should consider limiting the proposed extension of licensing requirements to electronic transfer of documentation to technology related to weapons of mass destruction (paragraphs 37 to 42).

Review of coverage

(k) The production of a unified list covering military and dual - use goods under the new Act and the revision within the EU of the basis for dual - use controls present an opportunity for review of the present coverage (paragraph 47).

Licensed production

(l)We recommend that the question of controls on licensed production of arms and dual - use goods be addressed within the Wassenaar Arrangement (paragraph 48).

End - use controls

(m) We share the sense of disappointment that there should as yet be nothing to show on the work done on creating a more effective end-use regime (paragraph 55).

Departmental responsibility

(n) There is something to be said for a central department to cover all export licensing, including works of art and animal products, with advice being sought in each case from expert departments. We concur with the conclusion of the White Paper that the DTI is indeed the appropriate department . The priority at present is not to jiggle around with allocation of Ministerial responsibility for the licensing process, but to raise further its quality and speed. The priority at present is not to jiggle around with allocation of Ministerial responsibility for the licensing process, but to raise further its quality and speed (paragraphs 58 and 59).

Administration and delays

(o) We are encouraged by the prospect of closer liaison between the ECO and its clients, and of constructive co-operation in improving current weaknesses.The principal complaint about the licensing system is the inordinate length of time it can take to get a licence. The ECO fails by some distance to meet its own target of processing within 20 working days 70 per cent of those applications requiring circulation to other departments. We recommend that vigorous steps be taken to give a rounded picture of the ECO's performance not only in relation to its own targets, but showing the full extent and nature of the waiting - list of applications. We recommend that some analysis be carried out and published of the reasons for other Government departments failing to meet a 10 working day target on export licence applications, and of steps which could be taken to improve performance. Applicants should be informed what is happening to an application which will not be decided within the time limit: be offered the opportunity to make direct representations in response to objections raised: and be assured of a decision one way or the other within an agreed further timescale (paragraphs 60 to 65).

Appeals

(p) There should be a time limit for determination of appeals as there is for giving notice of appeal. It is also our intention to ensure that appeals are subject to a degree of subsequent parliamentary scrutiny by select committee (paragraph 66).

Open licences

(q) We counsel caution in moving too rapidly towards yet greater use of open licences, and Open Individual Export Licences in particular: and look forward to detailed reporting of the nature of such licences granted in the Government's Annual Reports (paragraph 69).

Electronic transfer

(r) We are pleased to note the degree of progress made [in the introduction of electronic document transfer]; the days of ever - thicker files of applications winding their weary way up and down Whitehall may be drawing to a close. We recommend vigorous pursuit of the programme of bringing the export licensing system into this decade before we embark on the next (paragraph 71).

  


121  Qq 109 - 110 Back

122  See Ev, p72, Annex C Back

123  BMARC Report, paras 91 - 93 Back

124  Cm 3349, 2.7.1 - 2.7.3 Back

125  Eg Q29: Ev, p13 Back

126  Cm 3989, 5.3.3 Back

127  Qq 112 - 3 Back

128  Qq 103 - 6 and Ev, Appendix 21: see eg Q38 Back

129  See eg Ev, p32 Back

130  Ev, p65, paras 3.2.7 & 3.2.9 Back

131  HC Deb, 24 July 1998, col 741Back

132  Ev, p151, A4 Back

133  Ev, p65, para 3.2.12: Qq 101,103 Back

134  Ev, p65, 3.2.10 and p74, Annex E Back

135  Ev, p151, A5 Back

136  Q46 Back

137  Ev, Appendix 21 Back

138  Qq 33ff: Ev, Appendix 20 Back

139  Eg Qq55 - 6: and for use of CS gas in Kenya, Ev, p14, fn15 Back

140  Q40 Back

141  Cm 3349, 2.4.9 - 10 Back

142  Cm 3989, 4.4.1 - 2 Back

143  Q32 & Ev, pp42 - 3 Back

144  Ev, pp66 - 67, paras 4.2.1 & 5.2.3 Back

145  Qq 102, 114 - 5: Appendices 22 etc. Back

146  MOD show an average of 77 per cent cleared within 10 working days over the past 12 months: Ev, Appendix 22. FCO have an average of 70 per cent: Ev, Appendix 23. DFID does not keep detailed figures but "all applications received are replied to within 10 working days": Ev, Appendix 24  Back

147  Qq34, 37: Ev, Appendix 25 Back

148  Ev, p67, para 5.3.1 Back

149  Ev, p65, 3.2.9 Back

150  Cm 3349, 2.5.1 - 2.5.3 Back

151  Cm 3989, 4.6.2; Ev, p44 Back

152  Cm 3989, 4.6.1 Back

153  Scott Report, C l. 50ff Back

154  Cm 3989, 4.2.1 Back

155  Qq 48 - 9: see also Ev, p102, paras 16 - 17 Back

156  Ev, p63, paras 2.3 - 2.4 Back

157  Ev, p67, para 2.5 and p71 Back

158  E 8.3 Back

159  HC 87 of 1995 - 96, para 67 Back

160  Ev, p69: p63, para 2.7 Back

161  Ev, p89 (EEV Ltd): also Ev, Appendix 25 Back

162  Ev, p150, A2 Back

163  BMARC Report, para 73  Back

164  Ibid, para 75 Back

165  HC 713 of 1995 - 96, pvii Back

166  Ev, p75, para 3 Back

167  HC Deb, 30 October 1997, cols 870 - 1w: ibid, para 4 Back

168  Ev, p68 Back

169  For details, see Ev, pp75 - 6 Back

170  Cm 3989, 4.4.2:Ev, p , para 6 Back


 
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Prepared 10 December 1998