Appendix 8: Letter from Mr Tim Otter,
NBC UK, to the Clerk of the Committee
Thank you for your letter of 22 October 2003.
I write, as I gave evidence, in my capacity as both a representative
of Smiths Detection and as Chairman of NBC UK, the trade interest
group of the NBC Defence Industry within the DMA.
The central point of my evidence was that proliferators
do not apply for licences. I do not believe that any of the legislation
is going to change this situation. It will merely prove to be
a considerable burden on industry; some estimates have placed
this burden for training alone as high as £2.4 billion in
the first year with a follow on cost of £1.2 billion per
year thereafter. Once the bureaucratic costs are considered the
impact will be far greater.
My second point concerns support to UK forces
deployed overseas. I note with interest and gratitude that open
licences would be granted to allow support to continue to UK forces
on operations. I do believe that this needs careful consideration
because there are many elements of the force that may not actually
be committed to the operation but are involved in the support
of it and the structure of this licence therefore needs considerable
thought and consultation. The licence also needs to be opened
some months in advance of the troops being committed to the operation
to allow industry to respond in time. However, this does not address
the fundamental problem of coalition warfare and UK forces involvement
in it. Coalition operations are the modern and preferred deployment
option for British forces. Unless our allies are granted the same
rights as the UK to receive equipment and product support, there
will be a serious risk of British forces, our allies and the indigenous
population coming to unnecessary, and preventable, harm.
Not considered in the evidence that I gave was
the issue of open individual and open general licences for NBC
defence products, especially those involved in detection and identification.
The additional burden that having to apply for licences in each
instance will impose on industry will be dramatic. I know some
committee members and government officials believe that this is
not the case; however I suspect they have not had to apply for
licences whist at the same time trying to fend off angry allied
governments and overseas prime contractors, whereas my members
have.
I hope that this is of use to the committee
in its deliberations. There are many other points that we would
wish to bring to the committee's attention and are we working
with the DTI to try to resolve these. However, it is our contention
that the new regulations, as currently perceived to be the case,
will prove to be a burden that has not been thought through. If
it has, insufficient attention has been paid to its impact on
the UK well being and that of its industry and armed forces. In
the meantime the proliferators will continue to proliferate with
little or no impact on them from this regulatory regime.
November 2003
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