The Role and Capabilities of the UK Armed Forces, in the Light of Global and Domestic Threats to Stability and Security
Lord Craig of Radley Excerpts(9 years, 10 months ago)
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Lord Craig of Radley (CB)
My Lords, I, too, thank the Minister for arranging this debate. I would like to follow on from the tour d’horizon of the noble Lord, Lord King, on one particular point—the number of platforms. I have expressed my concern on a number of previous occasions about the paucity of the number of platforms; by which I mean the airframes, ships and fighting vehicles that now form the front-line fighting strength of the three services.
I readily acknowledge that the striking power of individual platforms with modern, smart weapons provides a step change in hitting power and accuracy compared with previous generations. But that makes no allowance for the vulnerability of platforms themselves, nor of aircrew or other key sectors of manpower or logistics that support their use in combat. They are vulnerable to a variety of risks and not just those posed by an opponent. For example, there could be a hangar fire at an operational airfield that destroys a number of airframes; a loss of key components such as engines in a flood disaster; a damaging and fatal explosion in a crowded briefing room or on board a major warship; or a cyberattack on key intelligence or on equipment distribution. There could even be a tornado or other extreme weather event that causes physical damage. Any one of those risks and many more could deplete our already very limited front-line numerical striking strength, suddenly and unexpectedly. It is too easily forgotten that a freak hailstorm in Afghanistan in 2013 did more damage to front-line aircraft than the Taliban managed in the whole of the decade-long campaign in Helmand province. Is it a sensible policy that pays little or no heed to such potentially serious risks to combat capability?
Our complete mastery of the airspace in recent conflicts may also lure some into thinking that future operations will be just as loss-free from enemy action. But a better-resourced and capable opponent could in some future conflict readily inflict operational losses. Even against the less well-trained and equipped Argentinian forces in 1982, we lost half a dozen fighting ships with as many badly damaged, more than a third of our deployed fighter aircraft and numerous helicopters to Argentinian attacks. But we had sufficient strength in numbers to ride out those considerable setbacks. That strength had been procured many years previously and was operationally capable. Today, even small losses could greatly diminish our total combat ORBAT, which so lacks the numerical strength of earlier generations.
As has been mentioned, we pride ourselves that we punch above our weight, but the opposition, too, will doubtless mount some form of counterpunch. To succeed, we must have the resilience and firepower to overcome any form of counterpunch no matter how much damage or destruction it might inflict to our own front-line numbers. Let me say it again: we no longer have such resilience. That could be a critical factor between success and abject failure in future operations.
Even more critical so far as numerical platform strength is concerned is the vital contribution that conventional kinetic power has to play in sustaining and underwriting the credibility of our nuclear deterrent. Previous generations of the deterrent were procured when front-line conventional strength was orders of magnitude greater than what is available today, or likely on present plans to be available in the foreseeable future. Thus, it would have been possible, if faced with some gross threat to national survival, to mount a strong or even sustained conventional response, along with other non-military responses, to the aggressor. This would indicate national resolve and serve to underwrite the determination, if national survival were at stake, and ultimately, after all else had failed to deter or defeat the aggressor, to rely on the threat of a devastating nuclear strike. I fear today that the Government’s determination to remain a nuclear power, which I still support in principle, lacks adequate conventional muscle to underwrite and give a sure credibility to a nuclear deterrent strategy.
What in-depth analysis has been made of a minimum force mix—conventional force mix—that might be necessary to provide the Government of the day with the ability to indicate with strength their resolve to resist an aggressor? Otherwise, due to a paucity of conventional combat power, the Prime Minister could be faced with a most dreadful dilemma: a choice of the very starkest nature. It would be a choice between almost immediate use of a failed deterrent or surrender to the opponent. Does the Minister accept that current levels of conventional hitting power are not yet sufficient to give the deterrent truly believable credibility? Will this aspect of the renewal plan for the four new submarines be given the consideration that it merits in the SDSR work now in hand?
Finally, I return briefly to another issue that I raised, so far without success, in your Lordships’ House. Surely, it is time for the Armed Forces, so much reduced in numbers, to expect and look for some reduction in the number of Ministers with direct responsibility in the Ministry of Defence. I am not singling out personalities: all six of them are most diligent and hard-working, most notably the noble Earl himself. But it should be possible to reapportion responsibilities to have at most five rather than six Ministers on the payroll. Such a discipline has been applied repeatedly over many years within all three services. It would be an important signal to the forces. They have faced redundancies and other cuts. It is time that their Ministers shared in that downsizing burden, allowing the costs saved to be applied elsewhere in the defence budget. It is a reasonable reduction and it is long overdue.
Defence: Budget
Lord Craig of Radley Excerpts(10 years, 1 month ago)
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Lord Craig of Radley (CB)
My Lords, we know that the Government have a long-term economic plan; is there a long-term foreign policy plan? I suspect that the Minister’s brief will advise, “Wait for the SDSR”.
Let us surmise what cannot be in future policy requiring action by the forces. We claim to punch above our weight, but that is reality only if we have the strength to ride out the opponent’s counterpunch and still fight on to win. Thirty-three years ago we punched hard against the Argentinians. In less than a month we lost to their counterpunch six fighting ships, with others badly damaged, more than a third of deployed fighter aircraft and numerous helicopters. But we had the strength to ride out these setbacks—strength that had been procured many years previously and was operationally capable—and we beat the counterpunch. Now we lack strength in numbers to fight back so successfully.
We fielded a divisional force with air power in the first Gulf War. More than 50,000 UK personnel were deployed. The Iraqi counterpunch failed to materialise, but we still lost six Tornados and other aircraft. Then, those losses could be quickly replaced; today, even though we could field only a fifth of the 1991 level, nothing is left in reserve to beat off a counterpunch. In Afghanistan there was no Taliban air power to face. More airframes were lost to a freak hailstorm in 2013 than to enemy action.
In the past three decades surface ship numbers have gone down from nearly 60 to just 19 and the RAF is down from three dozen combat squadrons to a mere half-dozen. Platform for platform, fighting capability improves, but there is no scope for sustained fighting against any counterpunch—even hailstones. We need hard power to underwrite the credibility of the nuclear deterrent. By no measure of past experience are today’s Armed Forces large or resilient enough to do that, let alone to defeat a conventional counterpunch. This must be corrected. Does the Minister agree?
Armed Forces: Airborne Maritime Patrol
Lord Craig of Radley Excerpts(10 years, 1 month ago)
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Earl Howe
My Lords, I emphasise again that this matter will be looked at very closely in the context of the SDSR—indeed, some preparatory work has already been done. I do not accept the noble Lord’s contention that we are without protection in this important area. We have the use of other military assets, as I said, including Type 23 frigates, submarines and Merlin anti-submarine warfare helicopters, and we rely on the assistance that we get from our allies and partners.
Lord Craig of Radley (CB)
My Lords, the Minister mentioned that some preparatory steps are being taken in the MoD. What date is the MoD planning for the introduction, assuming an agreement through the review that he mentioned?
Earl Howe
My Lords, I think that the noble and gallant Lord will accept that we must not leap ahead of ourselves too much. However, I can tell him that the capabilities required from a future maritime patrol aircraft have been studied by the MoD over the past two and a half years. The study has received representations from a number of defence industrial organisations, which have allowed us to understand better the nature of the platforms in existence, as well as the timeframe in which novel technologies are likely to mature.
Queen’s Speech
Lord Craig of Radley Excerpts(10 years, 1 month ago)
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Lord Craig of Radley (CB)
My Lords, I add my welcome to the noble Earl for his return to the Ministry of Defence, and congratulate him on his new responsibilities as Deputy Leader of your Lordships’ House. I will touch on two key defence issues: the nuclear deterrent and what has been characterised as combat lawfare.
During the election campaign, the importance of continuing to have a nuclear deterrent was briefly raised. Both major political parties, at the most senior level, stressed their commitment to Trident and to replacing the Vanguard boats at the end of their operational lives. The intention to maintain a continuous at-sea capability appears in the Tory manifesto:
“We will retain the Trident continuous at sea nuclear deterrent to provide the ultimate guarantee of our safety and build the new fleet of four Successor Ballistic Missile Submarines”.
However, possession is only a part of that ultimate guarantee. Deterrence is not just about capability—with a very high threshold of invulnerability—but also about political will. Does all a potential adversary can see or surmise indicate strong political determination about the nation’s deterrent posture?
Critical to this, when faced with the most serious of threats, is the ability of government first to engage the enemy with all other non-nuclear means available to it, both military and non-military, and to be seen to act stoutly and with determination to defend an absolutely vital national interest. I do not consider that political will about intention regarding or use of nuclear weapons is believable if the choice that the Government of the day must make when faced with a critical national emergency is either virtually immediate use of their nuclear weapons, because they so lack conventional fire-power, or surrender.
Without further elaboration, my point is that national deterrence—the death sentence of a nuclear deterrent—lacks credibility unless there are available to the Government other military means of demonstrating determination and resolve in a worsening crisis. Robust kinetic action, short of a nuclear response, is required. But surely we need more—much more—non-nuclear capability than we could field today. Platform numbers are so low that even modest loss rates in the early stages might all too soon leave the Government conventionally impotent.
In years gone by, with troops and aircraft forward-based, with 30 or more combat air squadrons deployed on land or at sea and with the service fleet number treble that of today, different levels or degrees of conventional military response were available to the Government. Such serried steps are vital, visible indicators of a Government’s determination and that they will, if all else is failing, be strong-willed enough to threaten actual use of a nuclear weapon.
Therefore, I urge the Government to consider what more must be done as the economy improves to bolster and give credibility to their manifesto commitment to sustain continuous at-sea deterrents. I doubt that the pledged 1% increase in the equipment budget will suffice. This year’s SDSR should recommend what strengthening of our conventional offensive capabilities, both platforms and missiles, is essential to the nuclear deterrent posture, what additional protection for those more vulnerable platforms such as aircraft carriers, with dedicated surface and other units for them, must be acquired, and of course what protection is needed for our actual nuclear capability at its most vulnerable when entering or leaving UK coastal waters. If the Government’s manifesto commitment to mount continuous at-sea nuclear deterrence is to be credible, it must be partnered with greater non-nuclear conventional capability than is at present available. Surely it would be folly to spend billions on four successor ballistic missile submarines without providing the conventional contribution essential to sustain a credible nuclear deterrent.
I turn briefly to combat lawfare. There are growing and welcome signs that the uncertainties about the application of domestic or international law in complex scenarios are to be addressed. As the noble Earl mentioned, it is in the Tory manifesto, which states:
“We will ensure our Armed Forces overseas are not subject to persistent human rights claims that undermine their ability to do their job”.
I do not underrate the difficulties in honouring that pledge. I go back to the debates on the Human Rights Bill in 1998, when I foresaw difficulties—which were dismissed by the then Lord Chancellor, who was leading on the Bill—of incompatibilities between that Bill and Armed Forces legislation. Legislation about the International Criminal Court in 2001 and, more recently, concerning the handling of service complaints have all served to lessen the essential ethos of trust, both political and military, up and down the chain of command—a fundamental requirement of the Armed Forces. I wish the Government well in tackling those combat lawfare issues.
Now that there is likely to be a delay in bringing forward a British Bill of Rights, which might have been one vehicle for that legislation, I hope that the Government will consider dealing with the issue in the quinquennial Armed Forces Bill, which the noble Earl mentioned and which is due next year.
Falkland Islands Defence Review
Lord Craig of Radley Excerpts(10 years, 3 months ago)
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Lord Astor of Hever
My Lords, I can assure the noble and gallant Lord that the destroyers and frigates are within a certain number of days’ sailing distance from the Falkland Islands—we are very insistent on that. I think he will agree with me that sometimes an invisible deterrent is as effective.
Lord Craig of Radley (CB)
My Lords, the Minister has made an important Statement, but it really says, “We’re continuing as we are, doing some routine maintenance” —which after 30 years is hardly surprising—“and we’re sending a couple of Chinooks there next year”. That seems to beg the question: why has this become an Oral Statement rather than just a Written Statement?
Lord Astor of Hever
My Lords, I understand that it became an Oral Statement because the Opposition asked for that.
Armed Forces (Service Complaints and Financial Assistance) Bill [HL]
Lord Craig of Radley Excerpts(10 years, 4 months ago)
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Lord Thomas of Gresford (LD)
My Lords, I speak as chairman of the Association of Military Court Advocates—I declare an interest; I am not expressing the view of that association.
I very much welcome the extension of the role of the ombudsman to considering the merits of a particular issue. I approach it from the point of view of the complainant and the complainant’s family, and the importance of the confidence of the public in the system of justice in the Armed Forces. From the point of view of recruitment and retention of service personnel, it is very necessary that those who undertake the burdens of service life should feel that they have a fair and just system of complaint. As I expressed when the Bill went through this House, the weakness of simply looking at process was that a decision on process would not be satisfactory to the complainant and their family. They would want an ombudsman to act like an ombudsman and to look at the merits of a particular case. I am grateful that the Government have moved in that direction.
Lord Craig of Radley (CB)
My Lords, following the Government’s defeats on this Bill in the other place, their initial reaction was to consider how best to reverse them when the Commons amendments were considered in your Lordships’ House. I shared that reaction. Not to reverse the defeats would be a further withdrawal from the position adopted by the Government and reaffirmed in correspondence that I had with the Minister of State, Anna Soubry, following the Bill’s consideration in this House. She wrote to me:
“The bill as it currently stands”—
that was before the defeats in the Commons—
“gets the balance right between having a strong and independent Ombudsman and preserving the PRIMACY of the chain of command. It is that balance that I wish to maintain”.
We now have this run of government amendments reflecting their new position. No doubt this change of heart within government has been brought about in part by the imminence of Dissolution, in part by the weakness of their position in this House on this matter, and in part by the acceptance by the Chiefs of Staff, albeit on the basis of shotgun pressure upon them, that the Bill as amended is the least bad of the possibilities likely to be available. However, is not that latter acceptance itself due in part to the character of Nicola Williams, the nominee for the new post of ombudsman, and the position that she has adopted of recognising the ethos and value of the chain of command? Whether she accepts, as Anna Soubry stated, the primacy of preserving the chain of command remains to be judged.
However, in due time, will her replacement be as savvy? We are legislating about principles, not personalities. I am also concerned to learn that the ombudsman’s office may be 20-plus strong, not all of them lawyers, as will be the ombudsman, and so probably less qualified to undertake systemic examinations of complaints handlings, let alone of actual complaint topics.
Moreover, there seems to be no presumption of improvement in the working of the chain of command over time in dealing with complaints—in fact, the opposite. The default presumption is that complaints will continue to be subject to systemic and irreversible maladministration, as bad as or even worse than it is today. Once again, it is the unspoken but damaging inference that civil authority does not believe that the military chain of command is ever really competent or trustworthy, or is ever really worthy of being upheld or supported. Such an attitude would concern me very greatly.
The Human Rights Act 1998 flew in the face of and upturned long-standing Armed Forces legislation. It removed the majority of the Armed Forces’ legal processes from the chain of command and was damaging to the sense of trust. For example, the convening and review of courts martial are no longer exercised by the chain of command.
The Human Rights Act and other, more recent, statutes affecting the position of the chain of command have served to chip away at and undermine the essential and irreplaceable value of trust and support up and down the chain of command. Although each individual change may seem not to be too damaging or serious, it is the cumulative impact of a number of statutes on the values of the chain of command that worries me and that must be considered. Such values are vital to the use of armed forces in peace or war and to success in operations.
Will the Minister give an undertaking that, as and when there are significant improvements in dealing with complaints by the chain of command, the size and scope of the ombudsman’s team will be reviewed? Otherwise, and given those improvements, there will surely be a temptation to avoid idle hands and deploy the efforts of the 20-plus in systemic work which might, on balance, prove to be inimical to and derogatory of the standing and desired primacy of the chain of command. I look to the Minister for that assurance.
Defence Budget
Lord Craig of Radley Excerpts(10 years, 4 months ago)
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Lord Astor of Hever
My Lords, I will take the noble Lord’s suggestion back to my department and it will pass it on, but we will meet the 2% target this year and next. Decisions on defence spending will then be made in the next spending review. However, the Prime Minister is clear that there will be an annual 1% real terms increase in spending on defence equipment. We are committed to ensuring that Britain’s Armed Forces remain among the most advanced and capable, able to protect our security interests across the globe.
Lord Craig of Radley (CB)
My Lords, the Minister mentioned the Government’s commitment to a 1% increase on equipment, but he did not make it clear whether this would be a 1% increase on the defence budget. Perhaps he could do that now.
Russia: Armed Forces
Lord Craig of Radley Excerpts(10 years, 5 months ago)
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Lord Craig of Radley (CB)
My Lords, what was the Russian ambassador’s response to the Foreign Office when it called him in to complain about the transit of a Russian bomber aircraft along the Channel?
Lord Astor of Hever
My Lords, the Russian ambassador committed to giving a full explanation in writing of that long-range bomber activity.
Armed Forces (Service Complaints and Financial Assistance) Bill [HL]
Lord Craig of Radley Excerpts(11 years ago)
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Lord Boyce (CB)
My Lords, at Second Reading the Minister gave us reassuring words about the importance he attaches to the command chain, and that was good to hear. However, I believe that new Section 340K undermines this principle and could be seen to be violating the integrity of the command chain. I have particular difficulty with the argument that this power is necessary because ombudsmen in other organisations have it. The Armed Forces are different, and the Minister does not need reminding about the emphasis given to this in the Armed Forces covenant, especially because other organisations do not have an equivalent of the Armed Forces Act and its inherent disciplinary processes.
If the ombudsman detects obstruction, the Defence Council and the command chain on his or her instruction can issue an order to any person deemed to be obstructing to comply. The failure of that person to comply would be an offence. New Section 340K may be a safety net or a last resort in case such a procedure does not deliver what the ombudsman wants. If so, it might be helpful if that were stated. I welcome the Minister’s comments on this. I beg to move.
Lord Craig of Radley (CB)
My Lords, I have added my name to this amendment—as the noble and gallant Lord, Lord Boyce, has explained, it is a probing amendment—because of the importance that must be vested in, and allowed to, the chain of command. I do not need to rehearse in this Committee that importance. The chain must run, and be allowed to run, seamlessly from the highest legal authority, the Defence Council, down through the ranks to the most junior serviceperson.
Since the major part of this Bill is to amend the Armed Forces Act 2006, this should ensure that service personnel involved in a complaint are to be subject to a single disciplinary statute, and are not, as in matters considered to be human rights, dealt with by separate and potentially conflicting legislation. I welcome that.
However, my concern with new Section 340K is that it allows the ombudsman to opine that a serviceperson is in contempt for some obstruction or act, to certify the obstruction or act, and to refer the person directly to a civilian court for investigation. In other words, the ombudsman is given a power of command over the individual even though he—the ombudsman—is not, as the Minister stated, within and does not form any part of the chain of command. It is argued that this contempt-dealing power is normally vested in an ombudsman, although not invariably. Be that as it may, the Armed Forces are, as the noble and gallant Lord, Lord Boyce, has said, dealt with differently in legislation. No other public servant is treated in the same statutory way as are members of the Armed Forces.
Surely a better approach, which would cover the issue of contempt and retain the position of the chain of command, would be for the ombudsman to report the individual and the perceived contempt to the Defence Council. The council would then instruct the individual to comply with the ombudsman’s requirement and, if the individual did not, it would be a blatant case of failing to obey a lawful command and could be dealt with accordingly.
Allowing the issue of contempt to be taken direct to a civilian court could lead, because of the lack of detailed knowledge of the Armed Forces by the court, to protracted, time-consuming and more expensive consideration of the issue. Surely it is important to the legislation’s aim to speed up resolution of complaints that steps are taken, where possible, to avoid delay and not slavishly to insert and rely on drawn-out procedures, as would be the case with new Section 340K. Bearing in mind the authority invested by new Section 340M in the position of the Defence Council to an ombudsman’s report about a complaint, it would seem acceptable and a more timely solution to the problem faced by an ombudsman of a potential contempt of his authority if that contempt were dealt with through the Defence Council. I urge the Minister to consider this approach and be minded to offer an alternative to the current new Section 340K on Report along the lines that I and the noble and gallant Lord, Lord Boyce, are suggesting.
Lord Deben (Con)
My Lords, it will be within many of your Lordships’ memory that I take a particular interest in those occasions when we are discussing the particular interests of sections of the community. We very often have a discussion when the whole debate seems to be by lawyers about what should happen on the law. Similarly, I am concerned when the debate becomes a debate by members of the Armed Forces about what should happen in the Armed Forces. As a non-member of the Armed Forces I support the concern behind this, for two reasons.
The first is not a military reason at all. It is that I dislike very much the concept that, because somebody else has a power, it has automatically to be put into this legislation. That, of course, is an argument that has been used. It seems to me to be almost always a false argument. Indeed, if it is to be here it should be argued that it is right here, not that somebody else argued about it and said it was right somewhere else. There is much in our legislation which has got in because people have never really debated it but merely said, “Well, every time we have a Bill of this kind, we always put this in”. New Section 340K extends the way in which the ombudsman would work to an unacceptable extent.
I do not understand why it would be better to do it this way than in the way noble Lords opposite have put forward. The Government must explain why going through the Defence Council would not be just as good as doing this. If one went to the Defence Council, one would not open oneself to the concern that is here. It is not the most important thing in the world; the pillars of the temple will not come down if we do not make a change here. All the same, we ought to be very careful about making it difficult for the chain of command in the Armed Forces to be clearly a chain without any interference. There is a mechanism for avoiding that and I hope very much that the Government will look at it and see whether there is any real reason for insisting on this format, which may be all right somewhere else but is not necessarily right here. The only reason I intervene is that I think it is important for somebody who is not in the Armed Forces to say that they think this is valuable.
Armed Forces (Service Complaints and Financial Assistance) Bill [HL]
Lord Craig of Radley Excerpts(11 years ago)
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Lord Craig of Radley (CB)
My Lords, I welcome the Bill, but have some reservations about it. First, I am surprised—although maybe there is a simple explanation—that Clause 4 is not in a separate part. It does not seem to have anything in common with complaints or ombudsmen. Nevertheless, welcome support has already been given to service charities and others from the £35 million LIBOR funds that have been allocated. I welcome the Minister’s information about further funds being set aside for future years. What assurances can he give the House that these welcome funds will not be reduced or forgone, whether they come from LIBOR or from the defence budget?
I turn to the principal issue of the Bill. There has been systemic evidence that the complaints system has not moved with the times, and a commendable expectation that complaints about maladministration and issues such as bullying and sexual harassment should be dealt with fairly and in a timely manner. As the complaints commissioner’s annual reports make clear in citing examples of poor handling of complaints, much still needs to be done to improve the way in which the Army and the Royal Air Force deal with complaints. The Royal Navy seems to be showing the way, with a reasonable recent record. What is not clear—and maybe the Minister can help us on this—is how much of the difficulties being faced by the Army and Royal Air Force are due to a lack of adequate resources or to conflicting issues that make a quick and timely resolution of a complaint unachievable. Are there barriers to better performance that lie beyond the control or decision of the chain of command? The complaints commissioner herself has reported that more resources are required within the services. Is she right on this?
Unless these problems are tackled and resolved, the changes in this Bill—the substitution of an ombudsman figure for the complaints commissioner and the reduction in the appeals process from three levels to just two—will prove not to be the answer to the problem but more expensive than its predecessor. Will it turn out to be no more than costly cosmetics, because the practical difficulties faced within the services for dealing with complaints cannot be or have not been resolved?
As has been made clear by the Minister, the Government recognise the importance of retaining the responsibilities of the chain of command, even to the extent of not giving the ombudsman the final say in the outcome of his or her investigation and report. I welcome this approach because, as I have said on other occasions in this House, the whole ethos and trust between those in command and those they command are so essential to the operation, employment and day-to-day activity of the forces.
Much of the detail in the Bill will not emerge until the many regulations specified in it are published. One in particular about which it would be helpful to have further information is the reference on page 2, on lines 18 and 19, to matters of a description about which a complaint may not be made. The Minister has given the House some indication what those no-go areas might encompass, but more information would be helpful.
Another example that would benefit from further information is the procedure for the ombudsman investigations in new Section 340I on page 7. New subsection (2) states:
“The Secretary of State may make regulations about the procedure to be followed”,
but new subsections (3) and (4) seem to give the ombudsman freedom to make up his or her mind on how to proceed, albeit constrained by whatever the Secretary of State has set out in his regulation about procedure. It would be helpful to our understanding all the intricacies of the regulations referred to in this Bill if drafts for regulations for more major issues could be made available before we reached Committee. Would that be possible?
The Bill introduces arrangements that may help to speed up resolution of a complaint by reducing the number of levels of appeal and setting out timescales for the submission and discharge of appeals. I welcome the latter and the intention to have a cut-off point beyond which claims cannot be made or continued. The downside to this is that future claimants may feel that their rights have been eroded. Provided that the new arrangements—not only those covered by this Bill but, most importantly, the improvements in service procedures for dealing with complaints—are seen to work well, the reduction in appeal opportunities seems reasonable and I for one conditionally accept it.