UNIFORM FORMAT FOR RESIDENCE PERMITS FOR
THIRD-COUNTRY NATIONALS (7298/06)
Letter from the Chairman to Liam Byrne
MP, Minister of State, Home Office
Sub-Committee F (Home Affairs) of the House
of Lords Select Committee on the European Union considered this
document at a meeting on 7 June.
The Explanatory Memorandum signed by your predecessor
stated that "the Government is considering its position on
participation in this proposal". We were unable to understand
why the Government, having decided to opt into the first proposal
for an amending Regulation, was having doubts about opting into
the second proposal; nor could we understand how it would be possible
for the principal Regulation to apply unamended in the UK, but
amended in the rest of the EU. However we now understand that
the Government is planning to opt in.
We are also concerned about the huge increase
in the cost. We understand that the estimated start-up costs have
increased from £24 million to something in the region of
£60 million; and the running costs, initially estimated at
£15 million per annum, are now estimated to be £56 million.
We would be grateful if you would detail under the relevant headings
the items covered by both sets of costs, and precisely why there
has been such a steep escalation.
In the meantime we are keeping the document
7 June 2006
Letter from Liam Byrne MP to the Chairman
Thank you for your correspondence of 7 June
2006, in which the Committee asked for further information on
the cost of implementing this proposal.
In 2004, the Government's figures were a broad
estimate based on implementation of the Regulation. My predecessor's
letter of 16 May 2006, to Jimmy Hood MP, explained that our new
estimate of running costs, A) is a 10 year average figure, taking
inflation into account, B) incorporates a larger contingency element,
in line with Treasury best practice, and C) was necessary in the
light of a better understanding of the technical specifications.
We have therefore had to revise upwards our estimate of the unit
costs. The objective will be to recover these running costs through
charges levied on those who apply for the service.
The same letter also explained that the increase
of £36 million in estimated start-up costs between 2004 and
today reflects an increase in programme management costs, contingency
and the costs of additional features to help ensure that the process
for issuing biometric residence permits (BRPs) is secure.
A BRP solution that implements only the minimum
required to meet the EU Regulation ("BRP Minimum" option)
would now have start-up costs of approximately £36 million.
However, our preferred solution for BRP that includes additional
features over and above those required to meet the EU Regulation
("BRP Incremental" option), has estimated set-up costs
of approximately £60 million (ie a £24 million increase
over the BRP Minimum option).
We have identified the benefits for both the
BRP Minimum and BRP Incremental options. Items covered by the
two sets of costs are set out in the table annexed to this letter.
The table illustrates clearly that the BRP Incremental solution
will deliver more benefit than can be realised through the BRP
The identified benefits of the BRP incremental
programme fall under three main headings, in-line with the objectives
of the project:
Benefit 1Contribution to the wider National
Identity Scheme: The BRP project forms an integral part of the
UK's wider National Identity Scheme, comprised also of IND's UKvisas
Biometrics, e-Borders and Immigration Asylum Fingerprint System+
(IAFS+) projects, and Identity and Passport Service (IPS). Together,
these initiatives will ensure that all UK residents (and anyone
requiring a visa) will have some form of recorded biometrics linked
to their identity, providing significant benefits in terms of
reduced identity fraud, immigration offences and threats to public
safety. The additional benefits stem mainly from the increased
assurance that biometrics are uniquely associated with an identity,
through capabilities that are unique to the BRP Incremental option.
Benefit 2Improvement to immigration control:
Whilst the EU proposal for a uniform format biometric residence
permit will help simplify immigration control within the wider
UK society, including for employers and public offices; the EU
Regulation does not stipulate any controls related to ensuring
that recorded biometrics are unique. There is also no obligation
to ensure that checks are carried out to ensure that biometrics
are attached to the correct identity. As such, issues regarding
counterfeiting and falsification are only addressed through the
introduction of a product that is physically more difficult to
counterfeit. The BRP Incremental option has been designed to include
additional features that will help to control fraud and abuse,
thereby improving immigration control.
Benefit 3Compliance with EU legislation:
The UK's opt-in to the 2003 version of this proposal remains valid,
and we are therefore bound to participate in, and implement this
new proposal. Whilst compliance with this Regulation would be
achieved through the BRP Minimum option, we consider, as noted
above, that there are significant benefits in going beyond the
requirements of the draft Regulation.
Finally, it is important to emphasise that these
cost estimates remain subject to departmental approval. You should
also be aware that I am in the process of conducting a review
of IND. The information provided in this letter is subject to
the outcome of this review. I have also written in similar terms
to Jimmy Hood MP, in response to similar questions raised by the
Commons European Scrutiny Committee on costs.
11 July 2006
Benefits by BRP Minimum and BRP Incremental