UNIFORM FORMAT FOR RESIDENCE PERMITS FOR
THIRD-COUNTRY NATIONALS (7298/06)
Letter from the Chairman to Liam Byrne
MP, Minister of State, Home Office
Thank you for your letter of 11 July 2006 in
reply to my letter of 7 June 2006[116].
Sub-Committee F (Home Affairs) of the House of Lords Select Committee
on the European Union considered it at a meeting on 25 October.
I have to say that your letter does nothing
to allay our concerns about the huge increases in the estimated
start-up and running costs. Given that these costs are to be recovered
"through charges levied on those who apply for the service",
it is all the more important that they should be fully quantified
and justified. We do not understand how the cost estimates "remain
subject to departmental approval", and would be glad if you
would clarify whose approval, and in which department, remains
to be sought.
The cost increases are said to be justified
by three benefits: "the additional benefits [stemming] mainly
from the increased assurance that biometrics are uniquely associated
with an identity"; "additional features that will help
to control fraud and abuse, thereby improving immigration control";
and, under "Compliance with EU legislation", further
"significant benefits in going beyond the requirements of
the draft Regulation"—though what these benefits might
be, your letter does not disclose.
Attached to your letter is a table showing the
basic and incremental benefits of biometric residence permits.
We do not understand how this explains or quantifies the cost
increases. We would be glad to see a detailed breakdown of the
figures which made up the original estimate in 2004, and now make
up the revised estimate. If, as you say, an element of the increase
is that the estimate is now 10-year average, incorporates a larger
contingency element, and is due to a better understanding of the
technical specifications, we would like to know how each of these
factors contributes to the total increase. We look forward to
receiving your reply. In the mean time we are keeping this document
under scrutiny.
Additionally, we understand that the Commons
European Scrutiny Committee, which shares many of our concerns,
has invited you to give oral evidence, and that this evidence
session is to take place on 22 November. We look forward to reading
a transcript of your evidence.
25 October 2006
Letter from Liam Byrne MP to the Chairman
Thank you for your letter of 25 October 2006,
in which you request further details of the costs and benefits
of the UK's biometric residence permit project— It was agreed
that I would respond to your letter after my appearance before
the House of Commons European Scrutiny Committee.
The questions set out in your letter were considered
at the evidence session. In answer to your questions therefore,
I would like to reiterate my responses to the Commons European
Scrutiny Committee. The revision in costs relate to the decision,
as part of the Government's National Identify Scheme, to go beyond
the minimum EU standard for the Biometric Residence Permit (BRP)
and incorporate additional features, which include the introduction
of a micro-chipped polycarbonate card and a central biometric
database to record fingerprints.
The additional benefits achievable by going
beyond the minimum EU requirements will enable the Home Office
to tie an individual to a single identity which will improve immigration
control, prevention in illegal working and fraudulent applications;
while improving the ability of genuine applicants to travel to
and from the UK.
I have noted the Committee's request for a detailed
breakdown of figures for both the original and revised estimate
of costs. I regret that I am not yet able to provide the full
costs and benefits at this stage as no decision has been made
in terms of assessing the numbers and classes of person who will
be affected by these proposals. As we intend capturing groups
on an incremental basis the costs and benefits will only become
quantifiable as soon as a particular group is identified.
I will be able to provide the Committee with
more quantified costs after the National Identity scheme has been
agreed later this month.
I apologise for not providing a more satisfactory
explanation of the phrase "departmental approval". We
are required to develop a robust business case for the BRP project
in accordance with Treasury and Home Office guidelines. The business
case requires approval from the Joint Approvals Committee in IND
and the Home Office Group Investment Board. This approval is required
by governance within IND & Home Office and Office of Government
Commerce practice. The process also helps to ensure the project
satisfies the approval criteria. These include value for money,
affordability, and capacity to deliver the project successfully.
No direct approval from the Treasury is required.
Please accept my apologies for not being able
to provide the Committee with a more detailed response at this
time. I remain committed to providing the Committee with the appropriate
information as soon as I am able to do so.
14 December 2006
Letter from the Chairman to Liam Byrne
MP
Thank you for your letter of 14 December 2006
in reply to my letter of 25 October. Sub-Committee F (Home Affairs)
of the House of Lords Select Committee on the European Union considered
it at a meeting on 31 January.
We have read with interest the transcript of
the evidence you gave to the Commons European Scrutiny Committee
on 6 December 2006. Plainly they share many of our concerns.
We note from your replies to a number of questions,
in particular questions 5-9, 13 and 26, that the estimates of
the costs may well yet change, and that you have yet to identify
the benefits which are expected to be derived from those costs.
You ended the evidence session by saying:
"But your [Mr Connarty's] fundamental point
about the need of the Government to demonstrate the cost-benefit
analysis is absolutely right. That is why my concern has been
to get a plan in place first, on which a business case can be
developed and a report then submitted to Parliament."
We look forward to seeing that report. We hope
that it will contain a detailed breakdown of these very large
costs, so that we can be certain that all of them are fully justified
by the benefits to be derived from them. In the mean time we are
keeping this document under scrutiny.
In my letter I said that we did not understand
how the cost estimates "remain subject to departmental approval".
You explain in your reply that "No direct approval from the
Treasury is required." However in your evidence you say (Q13):
"Those business cases then... will need to be cleared by
the Treasury". We do not see how these two statements can
be reconciled, and would be glad to have an explanation.
In your letter of 14 December you undertook
to provide us with "more quantified costs after the National
Identity scheme has been agreed later this month"—ie
December. We look forward to receiving them.
2 February 2007
Letter from Liam Byrne MP to the Chairman
Thank you for your letter of 2 February.
You asked for clarification around the issue
of Treasury approval referring to my letter to you of 14 December
2006 and comments I made during the evidence session on 6 December
2006.
The position stated in my letter is correct.
We do not require direct approval from the Treasury as the anticipated
set-up costs are within our delegated authority. However, all
business cases regardless of whether they fall within delegated
limits must comply with Treasury guidelines. This includes the
guidance laid down in the Green Book—Appraisal and Evaluation
in Central Government. Subject to resource availability, the Treasury
also reserves the right to scrutinise business cases which are
deemed to be novel and risky. In retrospect the word "compliance"
might have been a better choice than "cleared", but
I hope this is now clear.
I note that you are keeping the Regulation under
scrutiny until you have received further information relating
to the cost/benefit analysis. I will shortly be in a position
to let you have this.
27 February 2007
116 Correspondence with Ministers, 40th Report of Session
2006-07, HL Paper 187, pp458-460. Back
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