Select Committee on European Union Fortieth Report


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 under scrutiny.

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.

INCREASE IN COSTS

  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 Minimum option.

  The identified benefits of the BRP incremental programme fall under three main headings, in-line with the objectives of the project:

  Benefit 1—Contribution 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 2—Improvement 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 3—Compliance 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

Annex A

Benefits by BRP Minimum and BRP Incremental Options





 
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