Question for Short Debate
My Lords, I am grateful for the opportunity to have this debate on Channel Tunnel security. I make no apology for it. Although subjects such as the threats and other security issues should probably be confidential, the issues of implementation, proportionality and others that I shall speak about can benefit from some debate. As background, I declare an interest as chairman of the Rail Freight Group and I worked on the development and construction of the Channel Tunnel. It opened 20 years with airline-type security arrangements, which at the time was probably the only model around. Now is the appropriate time to review this, because new operators and services want to start but are often held up because of security, immigration or technical issues. All these need discussing, but I shall concentrate today on security.
I welcome the fact that the UK and French Governments recognise the need to formalise the security arrangements so that all operators know what to expect. I was pleased to attend a meeting in Paris two weeks ago to discuss this idea with the two Governments’ representatives, who were about to publish something called a declaration of intent. It is useful that they are consulting the industry but they are not really looking at change. They are seeking views on whether they should carry on with the same thing they have done for 20 years and although they talk about proportionality and necessity, they do not always get there.
For background, the traffic through the tunnel comprises: Eurotunnel’s own shuttle services for cars, lorries and coaches; rail freight, with two operators at present; and through passenger trains by Eurostar, with planned services by the London Sleeper Company and German Railways. The two Governments state in their presentation of this declaration of intent that security measures must be practical, proportionate, effective and sustainable. I would agree with them on that but when you get into the detail, it is not what is happening at the moment and I do not think that it is what they intend to happen in future. They are rightly seeking to protect the infrastructure of the tunnel and the people using it but seem to be ignoring proportionality as well as the commercial reality for operators which, faced with very high costs, often decide that they are not going to try to run services at all—because they are just not viable with these costs.
The declaration of intent discussed various threats, and I shall concentrate on two—bombings and what they are pleased to call “marauding active shooters”, meaning people with guns. Some of these affect infrastructure, some people, and some both. I suggest that the level of checks between the different modes of transport through the tunnel, and compared with other rail tunnels, is very inconsistent and certainly not proportionate.
Regarding damage to the infrastructure, when I was helping to build the Channel Tunnel we worked out that it would need a 40-tonne bomb to make a hole big enough to get the sea in. You cannot carry that in a suitcase. If that is what they are trying to protect, there is no point in checking every suitcase because you are not going to catch that bomb. That kind of a bomb would have to go in a lorry shuttle or a freight train. So it is odd that only one in three lorries are checked before they get in the tunnel, whereas freight trains at the moment have 100% checks twice—that is, six times more checking than lorries get. What is the justification for the difference? I think we should be told. We then move on to people—or small bombs and shooters, as they call them. Why are 100% checks done on all the passengers and luggage on Eurostar, when one car in five is given a cursory check on the shuttle? Do we really believe that Eurostar passengers are more likely to have a shoot-out than those on a car shuttle?
I would look at proportionality even more closely in comparing the Channel Tunnel with the trains on the Métro and Underground. We were told in Paris that there was a big difference between trying to shoot one coach full of Eurostar passengers and one coach full of shuttle passengers. That seems pathetic to me; it is the same nasty result. But when you compare it with the Underground or the Métro, when was the last shooting on either of those? There was a shooting incident on the Paris Métro on 20 July, when the police chased somebody. In the UK, there was that very nasty incident when the Metropolitan policemen shot a Brazilian in the Tube. We have not had any in the Channel Tunnel. We could be told that that is because of security, but should we really accept that? The logical consequence is that everyone on the Underground should be checked 100%. Of course, we are told that it is not practicable to do it on the Métro, because it would stop people using it, but that it does not affect passengers much on the Channel Tunnel so we will do it anyway. That is the problem: it does affect passengers and the economy of the businesses. I have not had an answer as to why passengers in the car shuttles should be treated differently from Eurostar passengers. If you carry a gun in a car shuttle, presumably you will not be checked.
The key for me is the viability of the longer distance services, with German Railways coming from Frankfurt—I have talked to them often—as well as the Eurostar from Amsterdam and Marseille. The London Sleeper Company is planning to go to Frankfurt, Zurich or Milan overnight, with a high-speed, double-deck sleeper. However, you cannot introduce those security regimes for people coming back into the UK at every one of the stations that the trains might stop at. The solution adopted so far is that when you are going out to Marseille or Amsterdam, or wherever, you get checked at London and that is no problem. But coming back in, at the moment, the only solution is for everyone to get out of the train at Lille or Brussels. They hump their suitcases upstairs through security and board another train one and a half hours later. All that time is lost in their journey, which results in many more people booking tickets going out than coming back, but that is not the answer. For rail freight, additional stopping at + for a second check probably costs well over £1,000. That is disproportionate.
The worst thing is that this regime requires even catering trolleys on the train to be within a secure environment. But there is no secure environment for catering trolleys on First Great Western trains going through the Severn tunnel. They still go through a tunnel. I am sure that all operators look after these things but why do we have to have this enormous bureaucracy of checks? Is it proportionate? It is having serious and adverse effects on the provision of new and existing services, on the costs to the operator and on the hassle factor for passengers.
In commercially damaging the operators, we are cutting ourselves off from the kind of high-speed rail travel that is seamless across the rest of Europe. Governments, and this Government in particular, like high-speed rail—except, apparently, when they try to make it as inconvenient and difficult as possible through the tunnel. The bureaucracy is stopping competition and is anti-competitive. I hope that the Government will recognise that this is all a bit embarrassing for them. A sustainable expansion to the international rail market is not being supported. This raises questions about whether the precautions are proportionate and what can be done in the future. What new ideas are there?
The Channel Tunnel apparently is seen by the Government as of high value for terrorists. They cite loss of life and the economic damage that the tunnel closure would cause, as well as the PR value. But one must remember that the Channel Tunnel has been closed, either in part or fully, several times since it opened—not for terrorism but because of fires, breakdowns and so on. The sea will not come in, although there may be damage to the infrastructure from the kinds of bombs and things that we are talking about. But it would not be closed for more than a few days—not even for that long, I hope—which is the kind of thing that would happen if the Victoria line was closed.
In preparing for this debate, I talked to many experts in the industry. Their worries concern why the Government are engaging with them for new ideas as to what needs to be done and how. The general feeling is that the threat posed by terrorists to the infrastructure and rolling stock in the tunnel is much overstated. Therefore, it is reasonable to ask fairly basic questions. Are the current security measures really necessary and proportionate? Is it necessary for a regime to be as secure as it is? It is not in the long Swiss tunnels, some of which are even longer. Can the security measures, if needed for international rail, be achieved in a different way? There are many ways of doing it. Does the present regime provide a real-world security benefit? While agreeing that the regime needs to ensure passenger safety and the integrity of the tunnel, many in the industry believe that it has parts which are superfluous. There is a lack of critical assessment on the security regime from the industry, which questions its motives—so do I, as I hope that it is not jobs for the boys—and the impact on growth and on alternative proposals.
While the present declaration of intent is a good start, its vision is much too narrow. It does not involve the operators to any real extent; it just tells them what is to happen. It does not provide any justification for applying different rules, compared with metros, the Underground, Channel Tunnel shuttles and through services, or look separately at the threat to infrastructure and people. It does not really seek to justify its requirement; it just pays this lip service to proportionality to provide some justification for what it wants to do anyway.
The key must be to involve the industry in a meaningful way. You can hide behind the need for confidentiality; I said at the beginning of my speech that of course this is necessary for intelligence information. There is also a need for that to be assessed independently to avoid the criticism of creating policies for job creation. However, when it comes to dealing with the threats in different ways, the involvement of the industry is surely critical. The current regime adds costs and therefore makes the UK less competitive. This applies to passengers and freight traffic. It stops better high-speed connections for London and beyond and makes rail less competitive with road and air, which contravenes both government and EU policies.
In conclusion, I urge the UK Government, along with the French Government, to set up a joint independent inquiry into Channel Tunnel security to answer the questions that I have posed and assess the need for proportionality and the options for change, so that the UK economy is no longer adversely affected by unnecessary controls and costs. It should be independent of the current structure and involve operators, customers and others in its deliberations. Finally, it is worth reminding the French Government that the tunnel is very important for the UK economy—it is very much less important for the French economy—and that any issues to do with competition, anti-competitive practices or rules for the sake of reducing traffic should be avoided.
I am pleased to speak in support of the noble Lord, Lord Berkeley. I am very concerned about the competitive issues involved in this debate. I am not given to being anti-European or anti-French but it seems that this is one case where the British Government have tried to get some sort of inquiry going—one that I hope, as the noble Lord, Lord Berkeley, said, will take in industry views—but have been met with, shall we say, a slightly straight bat by the French to the extent that nothing is happening.
The Channel Tunnel is now getting on in years, like me, and it is time that the operating regime, whatever it is, was reviewed. A number of people in the passenger and freight industry want to run trains to Europe. Unfortunately, France has created what one could almost call a cordon sanitaire or moat around their end of the tunnel, which makes it extraordinarily difficult to negotiate for the operation of the necessary through trains. Those of us in the industry who went to St Pancras about two years ago all saw a beautiful new German train that people in the industry wished to introduce into service from Frankfurt, Cologne and Amsterdam, et cetera. There is no doubt that there is a market there, but that market is being considerably obstructed.
Who is making that obstruction? I can say only that it is the Anglo-French bureaucracy. It is not, I believe, about valid security considerations; as the noble Lord, Lord Berkeley, has demonstrated quite cogently, those considerations are considerably overplayed. Eurotunnel, which I think is almost all French-owned now, seems to apply a different set of rules to the shuttle services that it operates, which convey lorries and people in their cars through the tunnel, from what is applied to railway services, which are mostly operated by other people but which the French could operate if they wished. They do not seem to have the commercial imperative to make the railway business in France competitive and are losing market share in many segments.
I am sorry to end on a slightly sour note about Anglo-French relations, but it really is time that someone did something about it. Let me make a suggestion that will be very unpopular. We are about to launch a franchise competition in this country in which Keolis, which is wholly owned by the French state, will bid to run one of our major passenger franchises. I do not see the logic of allowing free competition in that respect—although I actually support it—if there is no reciprocation on the part of Paris. It really is time that we got a move on.
My Lords, first, I thank my noble friend Lord Berkeley for providing this opportunity to discuss the Channel Tunnel security arrangements. My noble friend raised some serious issues about the balance between security needs and the need not to dampen the growth of traffic through the tunnel. I will refer to the issues that he raised, but I also want to take the opportunity to raise other issues concerning Channel Tunnel security with the Minister.
The Channel Tunnel’s current security arrangements are governed by the Channel Tunnel (Security) Order 1994. That requires passenger and infrastructure operators to put in place a security regime, including the searching of passenger and freight trains before they enter the tunnel, and it empowers the Secretary of State to order additional searches and checks. The operators are responsible for the day-to-day delivery of security, but the Department for Transport’s compliance officers ensure that the statutory security arrangements in place meet the statutory requirements and standards. They do that through regular monitoring and testing.
The current approach to land transport security in the UK as a whole is regarded as being risk-based, with any security measures deployed being proportionate to the current threats to which each transport sector is exposed. In evidence to the House of Commons Transport Committee, the Association of Train Operating Companies said that three factors needed to be balanced: cost versus benefits of security measures; the practicality of security measures that are both workable for the industry and acceptable to the travelling public; and the balance between technology and human activity. ATOC also said on assessing risks that, ultimately, the rail industry took its guidance from the security services on where the risks are greatest and what form they take. As I understand it, the risk-based approach also applies to the cross-border Eurostar and Eurotunnel operations and thus, presumably, in respect of the Channel Tunnel security regime. No doubt the Minister will clarify that point in his response, in the light of the comments made by my noble friend Lord Berkeley and the noble Lord, Lord Bradshaw.
The Channel Tunnel’s general security regulation is overseen by the Joint Security Committee of the Channel Tunnel Intergovernmental Commission, which is advised by the Channel Tunnel Safety Authority. The UK and France jointly nominate the members of all three bodies. Passengers travelling through the Channel Tunnel on Eurostar are currently subject to Home Office passport controls both in this country and at the start of their journey in France or Belgium. In 2011, the BBC, I think it was, reported that some passengers were exploiting a security flaw, which I think went under the name of the Lille loophole, whereby passengers could book a ticket from Brussels to Lille and then travel on to the UK without being subject to passport checks.
Passport checks were adversely commented on by the chief inspector responsible for border and security arrangements. He indicated that some progress was being made in dealing with this loophole. I believe—though I may be wrong—that we have now reached the situation where the Lille loophole has been plugged. Passengers travelling between Brussels and Lille now do so in a sealed carriage, I believe. I understand that this arrangement came in from the middle of this year—that is, about the present time. However, it would be extremely helpful if the Minister could confirm the situation about this loophole and whether it has been sealed. Even if this is the case, will the Minister explain why it apparently took the best part of three years to close it? What measures have been put in place to ensure that any similar loopholes can be dealt with more quickly once they are discovered?
The lessons learnt from this affair should be applied to any future international services. In that regard, Deutsche Bahn has long-standing plans to run trains from St Pancras to Amsterdam and Frankfurt, which would give passengers a choice between two international passenger operators. Two years ago, the Government said that the UK and France were working well with Deutsche Bahn to ensure that comparable security measures would be in place in the Netherlands and Germany. Will the Minister indicate what has been achieved on this issue over the last two years?
The Land Transport Security Division of the Department for Transport is responsible for counterterrorist security in a number of areas, including the Channel Tunnel and international rail services. In its response last year to the House of Commons Transport Select Committee’s report on land transport security, the Department for Transport said that a new body, called the All States International Forum—ASIF—had been created to bring together ministries responsible for transport security from all states that already host Channel Tunnel services or are likely to in future. The purpose was to facilitate intergovernmental liaison on matters relating to the security of the Channel Tunnel and services that might operate through it.
As I understand it, ASIF met for the first time in March 2013 and included representation from the UK, France, Belgium, Germany and the Netherlands. Will the Minister give an update on what has been discussed and determined at ASIF meetings, indicate how many times it has met since last March and say what the value of our involvement has been to the UK? Does the Minister agree that one of the lessons from the Lille loophole is that close co-operation should be maintained with the police and immigration authorities of other nations, not just the transport operator? If he agrees, is the All States International Forum geared to delivering this?
Earlier, I referred to the Independent Chief Inspector of Borders and Immigration. He has been critical of the lack of fingerprinting of illegal immigrants in Calais, for example. The chief inspector said that he found it surprising that people caught attempting to enter the UK concealed in freight vehicles—the figure runs into thousands—were not fingerprinted by the Border Force, since gathering biometric information such as fingerprints could assist in the decision-making process if such individuals were ultimately successful in reaching the UK and went on to claim asylum. What is the Government’s position on the issue of fingerprinting in the light of the chief inspector’s comments?
In the coalition agreement, the Government committed themselves to introducing exit checks by the end of this Parliament through the e-Borders system. In April 2012, the then Policing Minister said that the system was very close to covering 100% of flights coming from outside the European Union. However, the head of the UK Border Force has now told the Home Affairs Select Committee that the project has been terminated. Can the Minister confirm whether that is the case and, if it is, say when the ministerial announcement was made to that effect, what the cost was of terminating the e-Borders project, how exit checks will now be implemented by the end of this Parliament and whether they will cover international rail passengers travelling through the Channel Tunnel?
As I understand it, freight is not planned to run on HS2, but the Government’s recent response to the HS2 growth report was to say that they had ensured that the design of HS2 does not exclude its use for freight traffic. If HS2 was adapted for carrying freight, have the Government given any consideration to what additional security measures would need to be put in place at depots if operators wished to run freight services via HS2 and then the Channel Tunnel?
In the Government’s response published on 31 March this year to the House of Commons Transport Committee’s report on land transport security, reference is made in paragraph 13 to a wider review of the national rail security regime. It appears that that wider review commenced in January of this year. It is not clear from the Government’s response to the Select Committee report whether this wider review is confined to the important issue of security training for staff or whether it covers all aspects of security and security regimes. Therefore, will the Minister say something about the review, its terms of reference, who is carrying it out and when it is expected to report? Is it looking at the issues and concerns raised by my noble friend Lord Berkeley? The Secretary of State has reportedly said that a decision on the inclusion of “international facilities” at HS2 stations has been postponed until the conclusion of the study into the options for improving the connections between HS2 and HS1. Will the Minister say whether that is the case, as it is obviously relevant to the points raised by my noble friend Lord Berkeley?
To conclude, the Channel Tunnel is an important national asset, but it remains underutilised. Two years ago, the Department for Transport said that it was essential that any security measures deployed across the transport sector were proportionate, practicable and sustainable. With that objective in mind, the Government need to ensure that existing security measures are effective and properly enforced and that there are no unnecessary or excessive barriers to the growth of passenger and freight traffic.
My Lords, I am pleased to address this Question for Short Debate which the noble Lord, Lord Berkeley, has secured on whether the Government have plans to set up an independent review of the Channel Tunnel security regime to consider whether it is proportionate and appropriate to current threats and risks. I am grateful to him and to the noble Lords, Lord Bradshaw and Lord Rosser, for their thoughts on this very important issue.
Security is a delicate issue to debate, as there are matters touching on the precise nature of the security regime that covers the Channel Tunnel that cannot be discussed in too great detail for obvious reasons. It might be helpful, however, if I put into context, as far as I can, the very serious threat we continue to face in the UK and the West generally from international terrorism.
We know from sad experience through events such as the 9/11 attack on the World Trade Center in New York, the Madrid train bombings, the London Underground suicide attacks and the liquids plot associated with transatlantic flights, that terrorism exists not just in the UK but internationally. We know also that al-Qaeda and its affiliates have aspirations to cause mass casualties and economic damage that have political and psychological impact. We also know that transport systems are attractive targets for the terrorist because they fulfil those aspirations. As a result, Governments have had to make a variety of adjustments in transport security regimes to reduce the risks of attack and to protect the travelling public, but with each adjustment comes a desire from the terrorist to be ever more innovative. New methods of attack designed to circumvent the systems in place are clearly demonstrated, with the recent changes to aviation security. For example, in America there is now a requirement to see mobile phones as well as laptops.
Twenty years ago, when the Channel Tunnel, one of the most costly and ambitious civil engineering projects of the 20th century, was opened, the main terrorist threat came from the IRA, whereby we had to contend mainly with protecting against vehicle bombs and hidden devices. Islamist terrorism has since emerged, with perpetrators willing to die for their cause; hence we have seen suicide bombings on the London Underground and 9/11, where aircraft were used as missiles, as well as the marauding active shooters in Mumbai and Nairobi. We have also seen terrorists attempting to use more subtle and novel methodologies to achieve their aims, including by liquid explosives and the shoe bomber, to give a few examples.
The Government have to be able to counter in a proportionate way all relevant risks and attack methodologies. Hence we take intelligence-based advice and analysis from an independent body, the Joint Terrorism Analysis Centre, and tailor security regimes to address new and emerging risks, as well as making sure that existing risks are mitigated. The threat from international terrorism continues and currently the threat to the UK is assessed as substantial, meaning that an attack is a strong possibility. We, as a responsible Government, must take note of the intelligence picture, standing ready to protect our citizens and infrastructure.
The security measures in place are tailored to the mode of transport operating through the Channel Tunnel, which explains why there are differences between Eurostar, passenger and freight shuttles and rail freight. That requires balancing convenience to travellers and business against security. It is not an exact science but, as there have been no successful attacks associated with the Channel Tunnel, we can take that as an indication that the security regime is sufficiently robust to deter and prevent acts of violence. In view of that, the measures would seem to be proportionate and appropriate, but we cannot be complacent.
It has been argued by some that there is no difference between the Channel Tunnel and London Underground, where security is less pronounced. Contrary to that view, the Government believe that there are a number of significant differences. Following the 2005 attacks on the Underground, Government considered the introduction of security screening measures to protect the travelling public, but found it nearly impossible and impractical do so for mass transit networks. As we saw in 2005, there were many alternative routes and modes available for travellers. Furthermore, any incident in the Channel Tunnel could potentially be 25 kilometres from the exit, making quick assistance difficult in the event of a bomb attack. That is further complicated in the event of a hostage or firearms attack, when intervention would be necessary. Unfortunately we know from experience the impact and disruption a fire in the Channel Tunnel can cause—that was without any casualties—and the psychological trauma an incident underground and below the Channel would have.
I also remind the Committee that the matter of the Channel Tunnel’s security is not just a UK responsibility. The fixed link straddles British and French territory. For that reason, both countries share responsibility for its defence and security. We must work together to protect the fixed link and the measures should reflect the terrorist threats that are relevant to both our countries. In that pursuit, the two Governments liaise regularly on issues relating to its continued protection. The security regime cannot be effective without joint consideration and comparable security measures on either side of the tunnel.
I am conscious that the noble Lord has an ambition for the tunnel to be utilised to its full potential and to make sure that our security is proportionate. We do not see security as a barrier to having other operatives operate within the Channel Tunnel. If we look at the figures, they do not support an argument for a review of the security. With traffic numbers on the increase, the Government recognise that economically, growth in this area is very important to the UK. We keep security measures under constant review to ensure that they remain proportionate and encourage growth. We have actively engaged with new operators on security to ensure that they understand what is expected of them. In those discussions, we have recognised the need for a flexible approach in the security requirements but they must be able to offer a similar level of protection as exists now.
The noble Lord, Lord Bradshaw, spoke about Anglo-French relations. I am pleased to say that we have regular discussions with our French colleagues and operators. Earlier this month, through the Channel Tunnel joint security committee, the UK and French Governments invited stakeholders—including the noble Lord, Lord Berkeley, in his capacity as chairman of the Rail Freight Group—to preview a joint document that updates previous guidance on security and is referred to as the declaration of intent. This sets out the security requirements considered necessary by both Governments to protect the Channel Tunnel and those using it. It is an important document which recognises the need to be flexible in future, with the potential expansion of the rail passenger network beyond France. It would not be appropriate, for instance, with single services per day, to insist that permanent infrastructure be provided or that specific security equipment be used. We support proposals to use new technology that can improve the passenger experience and provide similar levels of security. At the meeting, stakeholders were given an opportunity to make some initial comments about the declaration of intent and the plan is to issue the joint document for formal consultation. The two Governments will of course make adjustments to it, where they see that there is merit to do so.
The Government must take security very seriously: this includes any terrorist threat to transport, including the Channel Tunnel. By keeping the threat and security measures under review, and planning jointly to consult stakeholders on revised guidance later in the year, the Government’s view is that the security regime in place is both appropriate and proportionate, providing the correct balance between protection and ease of use. The Government therefore see no need to carry out an independent review of the Channel Tunnel security regime.
A number of questions were raised during the debate. Let me first cover the issue raised by the noble Lord, Lord Berkeley, on whether the security measures are proportionate, practical and necessary and about the options for change, since nothing has really happened in the last 20 years. I say to the noble Lord that the requirement for passengers’ vehicles and goods to be subject to security and screening measures is an appropriate and proportionate response to the nature of the threat. The noble Lord, Lord Rosser, also raised the issue of balancing the inconvenience to travellers and business against security and costs. The current measures are necessary to ensure the safety and security of the travelling public and to provide an effective deterrent, together with other safety and security measures, to those who may seek to undertake an attack against passengers or infrastructure. The terrorist threat levelled at all modes of transport infrastructure remains under regular review. We review that on a regular basis and have discussions with our French colleagues.
The noble Lord, Lord Rosser, raised the risk-based approach as applied to Channel Tunnel services. It is best if I write to him. He raised a number of issues, including trains to Amsterdam and the security measures that there will be, and co-operation between the police and immigration officers.
I will certainly be happy to write to the noble Lord on a number of his concerns, including, in the light of the police commissioner’s comment, what the Government are doing about fingerprinting. We should take that seriously, although it is an issue for the Home Office rather than for the Department for Transport. I will ask officials to take this matter to the Home Office, which will give an appropriate response.
HS2 is an exciting project for the whole Government and the whole country. The noble Lord, Lord Rosser, referred to freight traffic tracks and I will address that. Freight traffic is an expanding business and we want to make sure that we have the right capacity to help to have increased freight traffic.
I thank the Minister for his comments. Perhaps he would also write to me in response to some of my questions. He compared an incident in the tunnel with an incident on the London Underground, as well as the fear of passengers in the tunnel compared with the fear of those on the Underground. The Channel Tunnel Safety Authority is looking at evacuation from the Channel Tunnel into a separate service area. When considering people in the deep Tube having to get out one by one and climbing down into a dark tunnel and onto the track with four rails, I suggest the Channel Tunnel is a great deal safer than the Underground. I do not think that that is an argument for saying that there should be a different regime. Perhaps the Minister will write to me on that.
Certainly, I will write to the noble Lord, Lord Berkeley. We cannot compare the Channel Tunnel with the Underground, other than that they both take passengers. Where the security threat level is raised, the security response can be increased. With the number of people using the Underground, it is very difficult to set the security standard that is necessary. Current security measures for the Channel Tunnel are considered to be proper and proportionate, so the Government see no need to have an independent review. Having said that, I certainly will take the noble Lord’s questions into account and will give an appropriate response.