Peanut Allergies (Announcements on UK Flights)

Ian Paisley Excerpts

Monday 9th February 2015 Commons Chamber

[Ian Paisley (North Antrim) (DUP)]

A few months ago, my constituent Helena Erwin and her young daughter Emily visited me at my constituency advice centre in Ballymena. Helena told me of her desire as a mother to ensure that her child was kept safe while travelling. Emily has a very severe peanut allergy that requires her to be kept away from contact with peanuts for fear of anaphylactic attack, which could be deadly.

The family only became aware of this condition when they were on a family holiday and Emily was taken seriously ill. Subsequently, her consultant reported that she has

“an instant and extreme allergic reaction.”

Any parent of a child who requires special attention or care knows that that means constant care and attention daily, which has a broad impact. That is the case with this child, Emily. Her GP told her mother that in future, for all air travel, she will need to inform the carrier of her daughter’s condition. Her older sister has been taught how to recognise signs of anaphylaxis and what to do in an emergency, and her contemporaries—cousins, family and school friends—have had to be told what consumables Emily cannot be exposed to. The adult members of her family have each been trained to use an EpiPen and know how to administer her medication, which must accompany her at all times.

The Erwins go abroad for work and recreation, and as a result of their travel experiences, Helena contacted me to raise awareness of the needs, particularly when travelling, of the many people who, like her precious daughter, suffer from anaphylaxis and could be helped by greater awareness and safety announcements, particularly onboard aeroplanes.

It is important to put things in perspective. In 2013, there were 1,300 emergency admissions to A and E units in English hospitals following adverse food reactions and shock, and there have been six deaths in the past 13 months across the UK from anaphylaxis caused by food. Today, when we board a flight, we hear several standardised announcements, all of which we are very familiar with and are designed for our own safety: “Fasten your seatbelts”, “Put your folding table away”, “Stow your baggage”, “Keep window blinds up for take-off and landing”, and “Put down your seat’s arm rest”. There are also announcements about when and where smoking is permitted, and where and when a passenger can use a telephone or computer. We are well used to these announcements; those are just seven that I, as a regular commuter to Parliament, hear each week while flying.

From time to time, but randomly—the crux of the issue—I hear allergy announcements. When I do, I accept that they are made for my safety and that of fellow travellers, and that they should be obeyed. However, it is the random nature of the peanut allergy announcements that has prompted this debate. The Minister and his Government can do something practical and positive to help. He can ensure that tonight we begin a process to achieve a consistent style of announcement on all flights, so that public safety is increased. I am not campaigning for prohibitions; I am championing the case for consistent safety announcements when required or requested by a traveller.

Let me tell the House about the current inconsistent state of affairs. I have with me a report on 36 air carriers that fly to the United Kingdom and their policies on food allergies and announcements. Is there one consistent approach? No, there are 36 different approaches. To be fair, some airlines are doing their best, but a consistent, universal approach would actually be welcomed by the airlines as a beneficial starting point.

I want to tell the House a little about what Emily experienced on a recent flight. I asked her mother to write out the details, and it is important that they be put on the record:

“We incurred a 6 hour delay. An aircraft and crew were flown in from Paris to take us home. It was very obvious from when we stepped onto the flight that the crew were not happy at being there. We spoke to the crew member who knew nothing about us and didn’t even understand what a nut allergy was due to the language barrier. I do carry a translation card but this was in Spanish and not French.

Eventually with much explaining from ourselves and some other passengers seated around us, the crew understood what we meant but refused to make an announcement. Their reason being simply they didn’t have to. My husband and I were by now beginning to get distressed as was our 6 year old daughter Lucy. We repeatedly asked and asked for the announcement to made, eventually we were told in a minute, other passengers were now starting to pass the information back and shouting at the crew on our behalf. The doors of the aircraft had been closed and my husband and I were now thinking about asking to get off the flight rather than take the chance. At this point the crew member agreed to make the announcement and when he made it was given a round of applause by all the passengers. As a family this was a very humiliating situation to be in and very upsetting for Lucy. About 2 hours into the flight the crew member actually apologised to us but we did not get an explanation why he wouldn’t announce it to begin with.

On returning home I...called the CAA and got speaking to a Doctor from the medical department. He gave me a few pieces of advice. He felt any risk posed to my daughter would be from 3-4 rows in front or behind me and had I considered policing these rows myself to see what people are eating? All this while I am responsible for 2 small children and also adhering to the seatbelt signs. Another suggestion was just don't fly. Take a boat!”

I think that tells its own story about the inconsistency, and shows that airlines require what I am suggesting. They probably need an impetus to drive them to come up with a policy that will work.

Since I secured this Adjournment debate, I have been inundated with calls and e-mails from people across the United Kingdom. The story of Andy Hyams is well documented. He and his suffering daughter were alleged to have been bullied off a flight because no announcement was made. It is easy to understand why a parent would not want their child to stay on a flight in those circumstances; they could not move away if there was a problem. If the issue arises in a hotel or in public, people can at least leave, but they cannot get off an aeroplane when it is in flight.

Another constituent, Francis, wrote to me to say that

“unless you actually go through the stages of death by anaphylactic shock until you are left with your lifeless child in your arms it is very hard to imagine what happens.”

Frank had that experience, and said that it was only when people saw it happening that they realised the huge need address this issue.

Another lady, Danielle Toner, wrote to me to say of airlines that

“yes some will make an announcement, others will not. When you have a child in a confined space with a life threatening condition I feel it is a must that airlines should be accountable for all passengers on their flights.”

I think she makes a very good point on behalf of her little six-year-old boy, who suffers from this condition.

These allergic reactions affect one in 50 children in the United Kingdom, and I think the Minister knows that something needs to be done about this now. Putting in place a requirement that a consistent announcement, agreed with the Civil Aviation Authority, be made on a passenger’s request should not be beyond the scope of this House, or the care of this Government.

I do not believe that new legislation is necessary, but if it is, there is an opportunity to make the Consumer Rights Bill, currently in the other place, the legislative vehicle to get this job done. I appeal to the Minister to put Emily’s law in place. Let us do something to make the airlines announce consistent messages on peanut and other food allergies, so that people can travel in safety and feel that they are not being hindered in any way or having their rights taken away from them. I appeal to the Minister to do something about this.

[The Parliamentary Under-Secretary of State for Transport (Mr Robert Goodwill)]

I congratulate the hon. Member for North Antrim (Ian Paisley) on securing this debate about announcements relating to peanut allergies on flights entering and leaving the UK. I genuinely thank him for raising this topic, which is an important one. The responses he has had from his constituents and others show that many people around the country have been affected and have real concerns about their own or their families’ health.

The Government take the health and safety of air passengers and crew extremely seriously. The UK is recognised throughout the global aviation community for its high standards and excellent record of safety in commercial aviation. Severe allergic reactions, such as those that may be associated with peanut allergy, can be frightening for those who experience them at any time, and particularly for parents and carers of babies and infants. Within the confines of an aircraft cabin, there are few options for relief. The distress can be particularly acute.

We have the greatest sympathy for those who suffer—or who witness the suffering of their loved ones—as a result of such extreme reactions, wherever they occur, but we must have regard to evidence relating to the incidence and cause of such reactions. There is little published scientific evidence concerning the risks of exposure during travel and the efficacy of any mitigating measures. The risk of nut or peanut allergy, including anaphylaxis, as a result of consumption by mouth is well documented, but evidence of allergic reactions resulting from the inhaling of the allergen is mainly confined to anecdotal case reports. However, I know that airlines try to reduce the risk of serious medical incidents, including allergic reactions, while people are on board their aircraft. It is already standard practice for carriers to request passengers to notify them before travelling if they have any medical conditions, including allergies, so that they can take appropriate action, such as ensuring that wheelchairs and other assistance are available.

Most airlines carry information on their websites which outlines their policy in relation to passengers with allergies. Some have taken additional measures, such as removing peanuts from their in-flight snacks—that has been done by British Airways, among others—or offering to broadcast requests to other passengers not to consume nuts that they have brought on board with them. EasyJet and Norwegian already deploy that strategy. However, few airlines are able to offer or guarantee peanut or nut-free meals. The Daily Mail website today draws attention to my hon. Friend’s constituents the Levitan family, and the problems that they experienced. There is a very fetching picture of the hon. Gentleman and me—and, on the same page, Madonna, who was attending the Grammys.

The International Air Transport Association, a trade body for airlines, has also published detailed information for allergen-sensitive passengers. It includes guidance on the applicable regulations, such as the requirements for aircraft to carry first aid and emergency medical kits, and for cabin crew to be trained in first aid. However, the guidance acknowledges that the detailed regulations are the responsibility of each country, and that there may be variations in the extent of the medical equipment that is carried or the training of cabin crew. Its advice to passengers includes recommendations that they contact a physician before travelling to discuss any related risks, contact the airline once the booking has been made, ensure that prescribed medication is carried in hand baggage, and arrive early at the airport to re-confirm any specific requirements that they have made. Comprehensive advice is also available on the Anaphylaxis Campaign and Allergy UK websites. The Government commend those organisations for their work, which supports the range of other practical help and advice that is available.

We recognise—and we have heard again tonight—that passengers sometimes face inconsistent responses from airlines when they notify them of their history of allergy, and we understand that that can lead to pressure to require all airlines to meet certain minimum standards of support. However, there is a very limited amount of evidence relating to the risk, and the efficacy of any specific mitigation measures. The Government would need to be certain that the benefits of introducing any new regulation, such as a requirement for airlines to make a pre-flight announcement, was proportionate, and would have a significant impact in terms of risk reduction.

I accept that air travel is qualitatively different from other modes of transport, in that there is less opportunity to seek respite from environmental factors by moving. However, aviation competes with other modes on some routes. The measures proposed by the hon. Gentleman would place a duty on one mode of transport—aviation—but not on others, such as ferries and international rail, which compete with it. We should also have regard to the extent to which any actions requested in an on-board announcement might unreasonably limit the freedom of other passengers. For example, a family might have brought their own food—such as peanut butter sandwiches —on to an aircraft, and might have no alternative food to give their children during the flight.

[Ian Paisley]

I am, of course, very aware of the issue of freedom. I do not think that anyone is campaigning for a prohibition, which is an important point. However, I have not once met a family who, having been told by others, “One of our children suffers from peanut allergies—please do not eat those peanuts,” would wilfully want to eat peanuts in front of them, I think that most people would comply with such a request if they knew that the health of someone who was exposed to peanuts would be at risk.

[Mr Goodwill]

I am sure the hon. Gentleman is right. Indeed, the way ventilation works on aircraft may mean that a person who is seated well to the back of a plane and well away from the person with the allergy problem will not pose a risk. There is also interesting information about the effect on people when they smell peanuts. Their reaction may not be entirely an allergic reaction; if a person has had a bad experience before, they would certainly be feeling a degree of stress, which could be a risk to them. We should also not forget situations when peanuts have been served on a previous flight or people have had peanuts on a previous flight. Parents might sometimes want to check the seat so a toddler cannot find peanuts in between the upholstery and then consume it, thereby causing a problem.

We should not impose restrictions on other passengers without evidence that this would be necessary and effective. We should also consider that a carrier is unlikely to be able to guarantee an environment totally free of the trigger substance. For example, an aircraft may have had only superficial “turnaround” cleaning following a previous flight that day, possibly operated by a different airline, and a passenger on the previous flight might have consumed a product containing the allergen as other passengers may bring their own food with them which can contain the allergen.

Furthermore, the effect of such an announcement may be limited. I am slightly ashamed of this, but I am sure that I am not the only airline passenger not to devote my entire attention to each part of the announcements made every time I fly. In some cases language difficulties may also mean that some passengers do not understand the announcements.

Another issue is that if an announcement was to be made in relation to peanuts without clear evidence that the action sought reduced a real risk, there could be pressure to make announcements on other topics, for example other foodstuffs such as cooked fish and chickpeas, which have been linked to severe allergic reactions, or dog hairs which may be present on the clothing of passengers, or indeed an assistance-dog on the flight. The list of substances potentially causing an allergic reaction is long and includes strawberries, eggs, soya, milk and sesame seeds. Also, photosensitive epileptic reactions could be linked to some movies or video games that could be played by a passenger on a device during a flight in the vicinity of a person subject to such attacks.

Where action is to be required by regulation there needs to be an evidence base that it is necessary. I have today asked officials to write to the British Air Transport Association, which represents 80% of UK carriers, asking what its current policy is: whether the declaration should be made as a ticket is booked, which is the current situation; whether carriers should ban nuts from the foods they provide on their flights; and what type of announcement they should make and the practicality of that on some aircraft where the announcements are made via a drop-down video screen rather than by cabin crew over a microphone. I have asked my officials to try and get that information from BATA as a direct result of this debate.

Finally, it is only practical for any requirement to make such an announcement, if introduced under UK domestic legislation, to apply to UK airlines. As a result significant numbers of passengers flying in and out of the UK on foreign-owner carriers would not be covered by such a provision.

[Ian Paisley]

I welcome the fact that the Minister has been prompt in deciding to call for the gathering of that information. Will he go a bit further and give me a commitment that when he has that information he will turn that research into some serious policy that will allow for a change, if the evidence is there—I accept that the evidence must always be there to make a decision?

[Mr Goodwill]

I hope we might not have to introduce legislation. I get the impression that, given the sensitivity surrounding this subject and the publicity it has received as a result of the hon. Gentleman’s actions, many airlines in this country, and indeed around the world, are looking at this and looking at what standardised announcement might be made. I therefore hope we can make progress without the need for legislation, but we will keep all options open, of course. Several of the cases that have received recent media attention and been the subject of correspondence with the Department for Transport have concerned foreign-owned airlines.

I mentioned earlier that the Government take passenger health and safety very seriously. We are aware of the concerns expressed in Parliament on this matter. When it was discussed in another place at the end of last year, I had the pleasure of meeting the noble Lord Mendelsohn and the noble Baroness Kennedy of Cradley on 18 November to discuss and, I hope, allay some of their concerns.

In order to inform this debate, the Department for Transport and the aviation health unit of the Civil Aviation Authority have committed to work with medical specialists in allergies to develop evidence-based guidance for airlines. As a first step, it is intended to commission a review of the scientific literature to evaluate the evidence for a link between environmental exposure to aerosolised food particles and serious allergic reactions, including anaphylaxis, in subjects who have been diagnosed with a food allergy.

The objective of the scientific review will be to identify what, if any, steps could be recommended on the basis of the existing evidence and to identify the need for any further research. In that way, the industry could not reasonably object that the regulation was arbitrary or unwarranted. The regulation would have clear benefits in terms of reducing risk, and it would be easier to secure consensus on any international action necessary to offer protection to those at risk. Once again, I thank the hon. Gentleman for securing this debate and for providing the opportunity to bring this issue to the attention of the House.

Question put and agreed to.

Oral Answers to Questions

Ian Paisley Excerpts

Thursday 12th September 2013 Commons Chamber

[The Parliamentary Under-Secretary of State for Transport (Stephen Hammond)]

My hon. Friend refers to applications that were centralised at the DVLA in Swansea in July. There were initially some delays, but on 9 August a special team was created to deal with the more complex applications, and I think that that is now beginning to resolve the situation. However, I would of course be happy to meet him and his constituents.

[Ian Paisley (North Antrim) (DUP)]

The consultation on the potential closure of the Driver and Vehicle Agency office in Coleraine and the moving of 300 jobs to Swansea closed this morning. Although I do not expect the Minister to have the answers to the consultation yet, will he agree to meet me, my hon. Friend the Member for East Londonderry (Mr Campbell) and a small delegation of workers who would be affected by the closure? More importantly, will he take this opportunity to remove the smear levelled at workers that there were sectarian issues that would lead to the closure of the office when none has ever been reported?

[Stephen Hammond]

The hon. Gentleman is, of course, right that I will not comment on the result of the consultation. He is referring to the package of documents that were published as part of the consultation, including an equality assessment. I apologise for any offence that was inadvertently caused and accept that the wording could have been clearer. I must stress that there was no intention to imply that any of the staff at the DVA might be biased in any way. Indeed, the equality assessment concludes that there is nothing in the proposal on the centralisation plans that would give rise to any bias or any perception of bias. Finally, I would, of course, be delighted to meet him, the hon. Member for East Londonderry (Mr Campbell) and a group of their constituents.

Lowestoft Train Station

Ian Paisley Excerpts

Tuesday 15th May 2012 Commons Chamber

[Peter Aldous]

I thank the hon. Gentleman for that contribution. In an effort to rebalance the economy, the seaside and the seaside towns—the marine economy—is in many respects the hidden jewel of the British economy and we do not make enough of it. Therefore any initiatives that help us to realise the marine economy’s full potential are to be welcomed.

As well as helping the town centre, a redeveloped railway station can play an important part in supporting other industries that are important to Lowestoft’s future— tourism and energy. Lowestoft Central station is within walking distance of the town’s two beaches, which have just had their Blue Flag status reconfirmed. Inland are the Norfolk and Suffolk broads. The two railway lines serving Lowestoft, the East Suffolk line from Ipswich and the Wherry line from Norwich, are themselves tourist attractions passing through attractive countryside, along the Suffolk coast, through the water meadows and alongside the waterways of the broads. It is so important that the journey’s end should be in keeping with the rest of these special journeys.

The station is also close to two of the areas that form part of the Lowestoft and Great Yarmouth enterprise zone, which came into operation on 1 April. The enterprise zone is focused on the energy sector, both oil and gas and offshore renewables. In the case of the latter, Lowestoft occupies an important strategic location as the port that is closest to some of the largest proposed offshore wind farms—SSE’s Galloper and Gabbard development and Scottish Power’s and Vattenfall’s East Anglian Array. Already wind farm developers and supply chain companies are looking either to increase their presence in the area or to move into the town. A smart station as part of a good rail service will play an important role in attracting them and jobs to the area. The station in its current form and appearance provides no help in attracting such inward investment.

Significant improvements to the local rail network are now taking place, and if they are to realise their full potential, it is important that we have stations that are attractive in appearance and provide customers with the facilities they need. Work is currently taking place on the Beccles loop on the East Suffolk line which will lead later this year to a resumption of an hourly service from Lowestoft to Ipswich; indeed, I understand that the construction of the loop was completed this past weekend. That work is welcome and the service should prove popular, but Lowestoft Central in its current state will be a let-down to many passengers, and I fear that at present it does not pass the test in terms of appearance, facilities and services on offer.

Other improvements have taken place as well, including the new passenger lift at Ipswich station, which will make it easier for travellers to connect with ongoing services to and from London Liverpool Street and further afield on Crossrail, which will improve access in and around London and to Heathrow, thereby helping to address the challenge of physical isolation that has held back the Lowestoft economy in recent years. In due course it is important that the through service from Lowestoft to Liverpool Street is resumed, but that is another debate for another day.

A further consideration to have in mind is that bus services in and around Lowestoft are being improved. Suffolk county council, with sustainable transport fund finance, is putting on a new circular bus route, serving the main employment areas and tourist destinations. The bus will stop at the station, as does the 601 service that runs down the coast to Kessingland and Southwold. To ensure that the investment in these services is successful the area around the station needs to be looked at closely to ensure that it is laid out in a way that enables the station to play a full role as a transport interchange and hub, not only for buses but also for taxis, and with the necessary facilities for the disabled, the elderly and the infirm.

The case for redeveloping Lowestoft station is a strong one that satisfies the most rigorous of cost-benefit analysis. I anticipate that the feedback I may get from the Minister, although I do not wish to prejudge his response, is that this is a good idea but there is no money available and I will need to take my place in that good old British institution of the queue. I shall now set out a suggested way forward and the support that I would like the Government to provide.

First, we need to consider future franchising arrangements. Abellio, which is now operating as Greater Anglia, took on a 29-month franchise in February of this year. That runs until July 2014. The new franchise needs to be in a form and of a nature that encourages both good management of the property and investment in it. A longer-term franchise would help secure this investment from the operator, who should also be given full control and responsibility for the management of the whole station and all its surrounds.

As I mentioned earlier, much of the surrounds of Lowestoft station are at present untidy and strewn with litter. Part of the problem is that no one party, neither Network Rail nor Greater Anglia, is ultimately responsible for its upkeep; it is a shared liability. The result is that no one takes full responsibility. There is nowhere for the buck to stop. In essence, a full repairing lease needs to be granted to the rail operator so that it is fully responsible for keeping the station and its surrounds in both good repair and tidy in appearance. This is a role for the train company and not Network Rail, which should concentrate its efforts on its core activity of being responsible for the track and larger category A stations, such as King’s Cross and Birmingham New Street. Smaller stations, such as Lowestoft, should be the responsibility of train operators, which are better attuned to local needs and demands and will have more of an incentive to provide a smart station that will help attract customers.

[Ian Paisley (North Antrim) (DUP)]

I commend the hon. Gentleman on raising this matter. As he knows, I have a twin brother who lives in Lowestoft and has lived there for 25 years. He constantly makes the case for having a station that has connectivity to the rest of Britain, and it is a case that could be made throughout the United Kingdom, especially in our rural parts. We must have this connectivity to enliven our rural parts of Britain.

[Peter Aldous]

I wholeheartedly endorse the hon. Gentleman’s sentiments. He is quite correct. As I said, railways have a key role to play in reinvigorating the parts that perhaps other means of transport do not get to.

Secondly, I would look to all interested parties to get together as a local delivery group to produce a blueprint of how the station should be redeveloped. I have in mind not only Greater Anglia and Network Rail, but Suffolk county council and Waveney district council. The latter has just appointed two project managers to help promote regeneration of this area of Lowestoft and they can take the lead in this work. The chamber of commerce, the new Anglia local enterprise partnership and the town centre partnership, which recently submitted the Portas pilot bid, should also be involved, and there should be an opportunity for the public to have their say. I would welcome the Minister’s support for such an initiative and confirmation that he will encourage Network Rail to participate fully and proactively.

Once it has been agreed how the station should be redeveloped, we need to think creatively about funding. The national stations improvement programme has had great success in completing projects, leveraging in private funding and delivering schemes that provide a real dividend for local communities. It has been such a success that all the funds for the period to 2014 have been spent. Given that success, I ask the Minister to lobby the Treasury for additional funds in the autumn statement and next year’s Budget for the continuation of the scheme.

We also need to consider other sources of funding, such as the coastal communities fund and the regional growth fund, and how best to leverage in private investment. A possible way forward with the latter might be the granting of sub-leases to restaurants, newsagents and other shops, for example, which as part of their financial commitment would pay rent at a lower level and agree to carry out capital improvements to a particular part of the property.

As a chartered surveyor, I was taught at a very early stage in my career that there are three factors that determine the success or failure of a redevelopment scheme: location, location and location. Lowestoft Central station occupies a unique location; it is the most easterly station in Britain, at the heart of the town’s main trading and retailing area and situated close to two of its most important industries—energy and tourism. I believe that the scheme could produce an attractive return, by bringing more people into Lowestoft, creating a feel-good factor and helping to provide and underpin jobs. I hope that the Minister and the Government will work with the people of Lowestoft to achieve that goal at the earliest possible opportunity.

DVLA Closures (Scotland)

Ian Paisley Excerpts

Wednesday 7th March 2012 Westminster Hall

[Mr Doran]

Indeed, it is. Motor dealers who have sold a car want it to be registered as quickly as possible. Registration is one of the largest components of the work of the office in my constituency. A significant number of objections or letters of complaint from the motor trade have been sent to the DVLA as part of the consultation. The motor trade will be damaged substantially by the local closures.

Another option is to replace the local offices with the Post Office. I have no objection to business going to the Post Office—we all want our local post offices to improve their businesses—but no one in that organisation can provide the technical help and support that the local DVLA offices provide. The other option is to go online. I am happy that the DVLA have made significant progress in this area. I have re-registered my car simply online: it works well and I am pleased about that.

[Ian Paisley (North Antrim) (DUP)]

There are DVLA offices in Coleraine, Londonderry and Ballymena. Going online also jeopardises those jobs. Does the hon. Gentleman agree that going online is not necessarily the best way to save those jobs?

[Mr Doran]

The jobs have not really been considered in the consultation document. I understand that 1,200 jobs are at risk and some of those—200 or 300—will be moved to Swansea, if people are prepared to move. The hon. Gentleman is right. Despite the progress made by the DVLA in going online and its digital technology, I understand that there is a huge gap in the technology. The trade unions’ assessment is that it will take at least four or five years to fill that gap. That will add to the problem.

The other route being offered to customers is the post. We are talking about 2.4 million new transactions shifting from local offices to the centre in Swansea. A pilot test run a year or two ago, looking at postal loss—envelopes that go missing between the DVLA and its customers—showed that some 0.9% of post was lost. That does not sound like a lot and I am told that the DVLA has got that figure down to 0.5%, but with the number of transactions that will transfer to Swansea the potential loss is huge: almost 120,000 of 2.4 million letters will potentially be lost.

I have calculated that, if everyone in my area used the post—clearly they will not; this is just for illustration— over the past three years we would have lost 1,250 communications. Given that many of these communications will contain identification documents, such as passports, that is a serious problem. I should like the Minister to comment on that.

We are given three potential ways forward and there is a serious problem with each of them. More important, from my point of view as a former practising solicitor, are the legal consequences of another aspect of the DVLA’s work. The key responsibility in the local areas is enforcement.

Aviation Industry

Ian Paisley Excerpts

Tuesday 15th November 2011 Westminster Hall

[Mr Donohoe]

I want to make some progress because I know that there are a number of hon. Members who wish to speak. To give way again will impact on that wish, so I will, if I may, move on.

The London Mayor believes that London will become a destination on the end of a branch line unless a new international airport in the Thames Estuary is built. Quite a lot of work would have to be done for me and many in the industry to be convinced of the practicality of such an airport. It is fine putting concrete on the ground, but difficulties emerge when it comes to airspace. The situation in the south-east is among the most complex in the world. Such consideration is vital in assessing the needs of an estuary airport, as there are major structural airspace implications. Of course, we could carry out such work; we have never argued that we could not. However, the scale of the airspace structural change necessary to accommodate the proposal would be enormous and should never be underestimated.

In NATS’ expert view, a four-runway estuary airport could not operate in tandem with Heathrow if Heathrow were to remain the same size as it is today. Such an airport would need to be a replacement for Heathrow. There would be significant implications for other airports in the region, most notably for City airport, which I use weekly, Southend, Stansted and Biggin Hill. It is not simply a matter of shifting current traffic patterns to the east. The eastern boundary of UK airspace is an important factor. Belgian and Dutch airspace and the proximity of airports such as Schiphol and Brussels mean that climb and descent profiles would be affected, so international co-operation would be required.

With westerly winds in the UK prevailing for 70% of the time, westerly operations may increase departures over central London itself. Refining existing flight paths provides more certainty for people already living below them and would be better than blighting new areas, which is what could happen if Boris’s idea goes forward.

Airspace is a critical pillar of national transport infrastructure, yet it is too often the forgotten factor in the consideration of aviation expansion, particularly airport development. The UK has 11% of Europe’s airspace and 25% of its traffic. We are Europe’s transatlantic gateway, which is a strategically important industry underpinning economic growth.

Airports do not work without the airspace to feed them. The Civil Aviation Authority has set out a blueprint for future airspace strategy, and NATS and BAA are co-chairing a cross-industry group over the next 12 months to work out an implementation plan. A major review of airspace has already been started. It has to assume that the current infrastructure will be in place. This is a once-in-a-generation opportunity, so the Government’s policy framework needs to be able to stand the test of time. Fundamentally, if this opportunity is not to be lost, we need cross-party support, which the shadow Secretary of State has argued for for some time.

We face the possibility of being stacked in the air—it happened to me only yesterday. I believe that that is an inefficient way to operate, but some say that it is an extremely efficient means of maximising limited runway space. None the less, it is not very good for the passenger who is trying to get into London. NATS supports the provision of additional runway capacity in the south-east because that is where the demand is. That sounds like common sense.

Taxation is another important area. When I applied for this debate, I felt that somebody from the Treasury should be here with the Transport Minister. The industry is charged some £7.9 billion in tax. Tax is paid by aviation firms, and employees contribute around £6 billion. There is also the evil air passenger duty, which was introduced by a Labour Government. When it started, we had to pay £5 for short-haul flights and £10 for long-haul flights. Now, if a family of four want to go to Australia, they have to pay more than £700 in duty. I know families who now travel from Glasgow to Frankfurt, Charles de Gaulle or Schiphol. They then take their bags off the plane and get on to another plane to reach their destination just so that they can save themselves that exorbitant tax. We are one of very few countries in Europe to apply such a tax, and the Treasury needs to look at the matter. Without a doubt, we are haemorrhaging passengers who travel, connect and interconnect through Heathrow.

[Ian Paisley (North Antrim) (DUP)]

I welcome what the hon. Gentleman says about airport duty. Northern Ireland has successfully campaigned for a reduction in its duty and we thank the Government for recognising that. The other issue that I want him to address is the connectivity between the peoples of these islands. Does he agree that we must not sacrifice our internal links for the sake of the more lucrative external links out of the United Kingdom? I am particularly concerned about the potential sale of British Midland International. If it goes ahead, will we see a reduction in internal flights between Northern Ireland and London and between Scotland and London? That is a concern.

[Mr Donohoe]

I am grateful to the hon. Gentleman for that; I will come on to that matter. Suffice it to say that, only last week, there was an announcement that British Airways was to buy the BMI routes. I predict that those will be the ones that operate between Scotland and England. We have already lost the service from Glasgow. Ryanair’s winter programme is being implemented and there are no flights from Glasgow Prestwick to Stansted. Already we are seeing problems.

As the hon. Gentleman travels in planes as often as I do, he may have experienced similar problems. Any plane that I get on from Glasgow is always full, which shows that there needs to be further expansion in the number of domestic landings in central London. I will come back to that argument a little later.

Returning to APD itself, there is no doubt that that tax was introduced, like most taxes, at a minimal level, but it has become a significant factor in how, and from where, people travel long haul.

In the future, we need to have a joined-up approach on aviation policy and taxation, which of course would involve the Department for Transport and Her Majesty’s Treasury. Such an approach is required to ensure that the tax system and aviation policy are aligned and consistent. Unless they are, we will lose out; of that, there is no doubt. A joined-up approach is absolutely imperative to ensure a sustainable and competitive aviation sector.

Returning to infrastructure development, the Government have adopted an aviation policy that states that there will be no new runway capacity in the south-east, potentially up to 2050. That approach is flawed. As demand increases, there will be a need for new capacity.

Bletchley-Oxford Rail Link

Ian Paisley Excerpts

Tuesday 15th November 2011 Westminster Hall

[Iain Stewart]

I am grateful to my hon. Friend who illustrates the widespread support for this project. It cuts across both the public and private sector. I will come on to some of the benefits that I believe restoring this link will provide.

[Ian Paisley (North Antrim) (DUP)]

The hon. Gentleman has outlined a history of the railway being in and out of fashion, and then back in again because demand renews as population shifts. That is very telling, because it seems to be the history of our rail system. Indeed, it is similar to what has happened in Northern Ireland. Does he believe that one of the benefits of rail is to stimulate the local economy and that that is the best way to get the economic growth that we so desire?

[Iain Stewart]

I am relieved that the hon. Gentleman is not calling for the line to be extended via a new tunnel under the Irish sea to Ballymena, which might be a little too ambitious. Nevertheless, he has made an important point. The country made a strategic mistake by closing so many railway lines in the ’60s, which we are now painfully and expensively trying to rectify. I will come on to the economic benefits that he has mentioned.

Search and Rescue Service

Ian Paisley Excerpts

Tuesday 1st March 2011 Westminster Hall

[Sir Alan Beith (Berwick-upon-Tweed) (LD)]

I am grateful for the opportunity to raise this extremely important matter, which has exercised the House for some time. I have raised it on several occasions, and it is time that we looked in detail at what the future holds for the search and rescue service, on which we all depend.

The search and rescue service covers 1.25 million nautical miles of sea and 10,000 nautical miles of coastline, as well as the entire land area of the United Kingdom. It is a joint service, which is operated by the RAF, the Royal Navy Fleet Air Arm and Her Majesty’s coastguard. It uses more than 40 helicopters from 12 bases around the UK.

HM coastguard uses Westland AW139s and Sikorsky S-92s, which are under contract to the Maritime and Coastguard Agency. The RAF and the Royal Navy use Sea Kings. The Sea King has four crew members—the pilot, the co-pilot, the winchman and the radar operator, who is also the winch operator. There are two versions of the Sea King: the Mk 3, which entered service in 1977, and the Mk 3A, which is slightly newer. The age of the aircraft has been causing significant technical problems, and they require constant maintenance to keep flying—a point to which I will return.

The RAF bases are RAF Boulmer, which is the headquarters of A flight and 202 Squadron; RAF Lossiemouth, on the Moray firth; RAF Valley in Anglesey, where Prince William is based; Leconfield, near Hull; Chivenor, in Devon; and Wattisham, in Suffolk. The Royal Navy bases are Culdrose in Cornwall and Prestwick in the west of Scotland. HM coastguard operates from Lee on Solent, Portland, Stornoway and Sumburgh in the Shetland islands.

The RAF has just celebrated 70 years of involvement in the search and rescue service. It has 16 Sea King Mk 3 and 3A helicopters in service, which are divided between 22 Squadron and 202 Squadron. Each squadron maintains a 15-minute readiness state during daylight hours and a 45-minute readiness state during the hours of darkness. 22 Squadron operates out of Chivenor, Wattisham and Valley, while 202 Squadron operates out of Boulmer, Lossiemouth and Leconfield. The training unit operates out of RAF Valley with three Griffin HT1 helicopters.

In Boulmer, which is in my constituency, the RAF search and rescue service is a source of enormous local pride and satisfaction. It is hugely respected and very involved in the local community, and the RAF helicopter is often to be seen not only engaged in operations or training, but supporting local community events. That, of course, is good public relations for the RAF and adds to its excellent reputation in my area. Indeed, such activities are such a prominent feature of the RAF’s work that they tend to distract attention from the fact that the vast majority of the work done at RAF Boulmer is in the very different field of monitoring and guarding our skies and training people. None the less, it is the familiar yellow helicopters going about their rescue and training work that enjoy the greatest and most immediate public awareness.

Under the previous Labour Government, a private finance initiative contract proposal was developed under the name of search and rescue harmonisation. Commonality of function between the MCA and Ministry of Defence helicopter forces, and similar time frames for the potential introduction of new aircraft fleets, led Ministers in the MOD and the Department for Transport in May 2006 to announce a cross-Government approach to the acquisition of a harmonised UK SAR helicopter service. A joint project team from the two Departments was tasked with running the project, which was essentially a Labour privatisation project. I say that not as a criticism, but simply to set out the context, because if this Government contemplate privatising anything, the Opposition tend to say that they would never consider such a thing. However, the previous Government did devise a privatisation project, and that was because they thought that such a project was essential to ensure that new helicopters could be provided relatively quickly to replace the Sea Kings. The total project contracts were worth £6 billion.

During discussions on the project, a number of concerns arose and were subject to quite a lot of public discussion. What aircraft would be used to replace the Sea King? How long would it take to get them into service? Which personnel would be required to operate the new service? Would they be drawn from the military, civilian life or a mixture of the two? If there were to be a mixture of military and civilian personnel, how would that work in practice, given that the civilians would be covered by the European working time directive, while the military personnel would not? That has already caused issues at the coastguard-operated bases in the Hebrides and the Shetlands. Consideration would also need to be given to the equalisation of pay and other conditions.

What training would air crew receive? At the moment, there is a fairly heavy dependence on experienced personnel with RAF training moving into other areas of search and rescue and other helicopter services. Of course, it is true that RAF training is heavily drawn on in aviation more widely. Furthermore, what arrangements would be provided for SAR cover in the Falkland islands under the SAR helicopter scheme? SAR in the south Atlantic is currently provided by the RAF, using the same crews who man our stations in the UK. That is done on a six to seven-week rolling rotation, with two crews of four personnel based in the Falklands at any one time. A normal feature of a career spent in a search and rescue aircrew will therefore be time spent in the Falklands.

Where do the prospects of a new helicopter with faster flying speeds and a longer range leave the existing basing pattern? What changes would be feasible under SAR? Linked to that, would 24-hour cover be provided by each base? An early answer to that question made it clear that there were proposals to reduce the cover at a number of bases to 12 hours, after which time the area for which the base was responsible would be covered by the base in the adjoining area. That raised great concern. In the Lake district, for example, rescue operations are often mounted by the RAF Boulmer helicopter, and there was particular concern that the area could not easily be served from other bases. Those bases would, like Boulmer, have extensive responsibilities for the North sea and the east coast, and their helicopters could easily be on a rescue operation and be unable to respond. Bases would be covering two huge areas—their own area and the neighbouring area—so there was a lot of concern about the idea of 12-hour operation. Following a number of meetings with Ministers and others, it was decided that RAF Boulmer would continue to provide 24-hour cover, at least until new helicopters with greater range and the ability to reach other areas at greater speed were introduced.

In the course of the project, bidders were identified, although some did not stay the course until the end. On 9 February 2010, the Soteria consortium was identified as the preferred bidder. The consortium was made up of CHC Helicopter, which is the largest global supplier of civilian helicopter services and the current provider of the MCA’s interim SAR service; the Royal Bank of Scotland, as a PFI equity investor; Thales UK, the well known defence contractor, which has been involved in a number of PFI and partnership projects; and Sikorsky, which has long experience in the design and manufacture of military and commercial helicopters.

The consortium proposed a fleet of 24 Sikorsky S-92 aircraft, with a top speed of 190 mph and a cruising speed of 167 mph. The S-92 would have been fitted with an internal fuel tank, increasing the aircraft’s flying radius to 310 statute miles. The aircraft would also have been fitted with the latest high-speed twin hoist, providing for the possibility of single-hoist failure. It would also have had a 300-foot hoist cable and a lift capacity of up to 600 lb at 350 feet per minute. It is hard to envisage being raised on a winch at 350 feet per minute, but such things are necessary in certain situations—for example, on the moving deck of a ship in rough seas. The aircraft cabin would be fitted out to allow paramedic medical care to be administered to a casualty. The ramp at the rear of the aircraft would provide access for loading and unloading stretchers, incubators and medical equipment and access for rescue teams and their equipment. The other major bidding consortium went under the name of AirKnight, but two further consortia pulled out at a relatively early stage in the process.

At some stage—I must confess I now forget when it was—responsibility for the future operation was transferred from the Ministry of Defence to the Department for Transport, which is why the Minister with whom I deal with all sorts of other transport issues is replying to the debate. All that I have described of course preceded the dramatic events of the suspension of the SAR-H scheme and its subsequent abandonment. The first stage of that was just part of the process of the incoming Government reviewing the spending commitments left to them by the previous Government. In June the Chief Secretary to the Treasury announced that the Government had identified several projects, some of which were dropped, while others were to be reviewed. SAR was one of the reviewed projects.

[Ian Paisley (North Antrim) (DUP)]

I understand that on average over the past five years there have been between 80 and 120 mountain rescues in the United Kingdom. Does the right hon. Gentleman think that such rescues could adequately be carried out using non-military personnel and equipment, in a way similar to what happens in France and the United States; or should they remain in the hands of the military?

[Sir Alan Beith]

Some of the rescues are done in that way even now. Not all SAR services are provided by military crew, but a high degree of training is required, and there must be consistent co-operation with local organisations such as mountain rescue teams. That depends on consistent good working relations. The military operators such as RAF Boulmer and 202 Squadron have done that particularly well. In general I think that most people feel more confidence about military crew, because they know the high standards of training that are involved. However, it is quite an expensive way to provide the service, and other options probably should be considered. Some of the training and experience that the military has, and some of its operational practices, would need to be transferred if there were any wider civilianisation of the service. The hon. Gentleman is right to raise that as a matter of concern.

The review announced by the Chief Secretary was about cost-effectiveness, against the background of a huge deficiency in defence capital programme funding. It was not about the issues that finally brought down the contract. Indeed, Ministers were on the point of announcing the final decision on the contract. Various other things had been going on, however. There were rumours that as part of the comprehensive spending review the Government had proposed that the project should be rewritten, so that an entirely civilian work force would operate the service, rather than a mixture of civilian and military personnel. Of course, if the Government had done that, it would have created a big saving, because it would have taken about 66 higher-paid military personnel out of the project, and probably created up to an additional £100 million over the lifetime of the project in personnel costs for the contractor. It also sidestepped the problem of some personnel being subject to European working time directive rules, while others were not. That issue was rumbling in the background.

On 16 December a dramatic announcement was made—I think that it was the very day on which we were to have heard the final decision about the contractor. The Secretary of State for Defence announced that information had come to light about the preferred bid in the search and rescue competition, which required clarification. The preferred bidder had informed the Government of irregularities in the conduct of the bid team, which had only recently come to light. The irregularities included access by one of the consortium members, CHC Helicopter, to commercially sensitive information about the joint Ministry of Defence and Department for Transport project team’s evaluations of industry bids, and evidence that a former member of that project team had assisted the consortium in its bid preparation, contrary to explicit assurances given to the project team at the time.

I believe that a considerable time previously a letter went to the Ministry of Defence warning it of potential irregularities of that nature. One of the matters that I hope is being investigated is why that warning was not heeded. Of course many other matters are being investigated as well, not just by the Ministry of Defence but by the police. A former member of the MOD team, subsequently employed in the industry, is, I believe, the subject of investigation. I do not know to what extent others are as well.

On that basis, we were told that

“the Government have sufficient information to enable them to conclude that the irregularities that have been identified were such that it would not be appropriate to proceed with either the preferred bid or with the current procurement process.”

The statement continued:

“The Department for Transport and the Ministry of Defence will now consider the potential procurement options to meet future requirements for search and rescue helicopters in the United Kingdom, including options to maintain continuity of search and rescue helicopter cover until new longer-term arrangements can be put in place.

We will make a further announcement once a way forward has been agreed.”—[Official Report, 10 February 2011; Vol. 523, c. 17WS.]

That brings me to the focus of today’s debate, which is what progress has been made in reaching those decisions and when we are likely to get a proper announcement about it. Other factors could be at work. There is the potential for legal action involving contractors. An unsuccessful contractor might want to pursue the successful one over bid costs incurred. There might be legal action between the Government and a contractor. The Minister may be inhibited in what he can say about that, but it could be going on at the same time.

What will happen next? The Sea Kings were due to be withdrawn by 2016 or 2017. They are ageing and they continue to need substantial levels of maintenance to keep them operating. Those of us who keep in close touch with the search and rescue service know that there are many occasions when the Sea Kings are not available to fly. I have seen that for myself. I was flying in a Sea King that returned to base because the radio system failed. The other aircraft was on land having returned from necessary maintenance work, and was not yet tested and available to take over. At that point therefore neither was available. There have been moments when no helicopter has been available at Leconfield, Lossiemouth or Boulmer at the same time. That clearly is a situation we cannot allow to continue.

Coastguard Service

Ian Paisley Excerpts

Wednesday 2nd February 2011 Westminster Hall

[Sarah Newton]

That is just the sort of point that I was hoping that hon. Members from all parties could make to the Minister today.

The MCA’s headquarters has not sent any formal training programme or competence framework to Falmouth. Instead, staff from the Falmouth station have used their own initiative to manage and adapt these functions and to tailor them to suit the needs of the mariners under their care. Years of dedication and experience have allowed the officers to develop and modify policies accordingly. Allowing these men and women to work out their own practices, rather than adhering to centrally controlled diktats has meant that Falmouth has developed best practice not only in the UK but across the globe. International partners will often look to Falmouth to see how they can better manage and co-ordinate their waters. It is not uncommon to visit the Falmouth station and find international delegations there learning how the station operates. When they want to see how the UK coastguard system works, they do not go to the MCA headquarters in Southampton; they go straight to Falmouth. A south American country’s coastguards are instructed, “When in doubt, call the Falmouth coastguards.”

[Ian Paisley (North Antrim) (DUP)]

The hon. Lady talks about the local knowledge of the Falmouth coastguards, but that is something that can be lost across the entirety of our coastline. My constituency includes Rathlin island, the only inhabited island off the coast of Northern Ireland. If the skills of the coastguards there are lost, it will mean the loss of many more lives around our coast. I agree wholeheartedly with the hon. Lady. Does she not agree that the proposals to pass co-ordination on to a yet-to-be-developed IT system and software system pose genuine concerns for the future protection of lives on our coast?

[Sarah Newton]

I very much agree with the hon. Gentleman. I am very sceptical about the capabilities of some of the technology that is being advanced, and I will discuss that later. Even the MCA headquarters appreciates the best practice that has been worked out in Falmouth. It has published its work in the coastguard operations bulletin, which is a testament to its inventiveness, ingenuity and ability to solve problems quickly and efficiently.

Handing over the research and rescue co-ordination for such a large area to another marine operations centre will inevitably lead to a loss of efficiency, which will affect the outcomes of some incidents. Coastguards have expressed to me their grave concerns about the loss of local knowledge and the impact that that will have on the co-ordination of local coastal rescue.

I understand that, on his recent visit to Falmouth, Sir Alan Massey stated that the process of identifying the particular location of someone in distress and requiring urgent assistance will be longer than it is now, with a possible 10 minutes added to emergency response times.

--- Later in debate ---

[Ms Ritchie]

I thank the hon. Lady for her intervention. She is indeed correct.

The Northern Ireland coastguard service at Bangor provides a vital service to the fisheries and tourism sectors right from Lough Foyle to Carlingford lough. Axing such a service will put at risk not only livelihoods, but lives. The Government must not take for granted the courage of those who devote time to rescue efforts on our shores. Funding must be protected.

We must remember that the coastguard protects not only the coast, but, as the hon. Member for North Down has said, Lough Neagh, Lough Erne, inland fisheries and inland lakes. It also provides an inland mountain rescue service for the Mornes and the Sperrins, and it is the point of contact for all helicopter operations in Northern Ireland.

The current proposals will leave Northern Ireland without a full-time coastguard station. This front-line emergency service has saved countless lives since its establishment. In the past year alone, the Northern Ireland team has dealt with more than 700 incidents. For me, my constituents and all my colleagues in Northern Ireland, saving lives is paramount.

The document that has gone out to consultation proposes that the Belfast Lough station, which is based at Bangor, might become a part-time station or that it might close, in which case our nearest coastguard would be the part-time station in Liverpool. The nearest full-time station would be at Aberdeen, on the east coast of Scotland. Co-operation is certainly important. Our co-ordination with Scotland and the south of Ireland has been invaluable in saving lives in previous rescue missions. I support north-south co-operation.

[Ian Paisley]

rose—

[Ms Ritchie]

I will give way to the hon. Gentleman.

[Mr Mike Hancock (in the Chair)]

Order. We do not want a long debate about co-operation.

[Ian Paisley]

What an opportune time to get an intervention. In 1989, I was involved in an attempt to rescue two drowning children off the coast of Northern Ireland. They had been holidaying there, but, unfortunately, one of them died. However, if it had not been for the co-ordination that the hon. Lady has mentioned, there would have been a double tragedy. It is essential that people recognise and get to grips with the fact that Northern Ireland will be naked to the ravages of the sea if we do not properly protect our coastguard.

[Ms Ritchie]

The hon. Gentleman is absolutely correct. Co-ordination and co-operation are vital, particularly on the island of Ireland. Closing the coastguard station in Northern Ireland is foolhardy, because there is a need for both coastguard services on the island of Ireland to work together and to co-operate.

The chief executive of the Maritime and Coastguard Agency, Sir Alan Massey, has indicated that the closures can be offset by the introduction of new technologies, such as Google Earth. Although I support the introduction of such measures, which can help to save lives, they must supplement, rather than replace, existing provisions. Nothing can replace local knowledge of the waterways or, in the case of Northern Ireland, the mountainous regions. That knowledge has been built up by generations of people living in the local communities.

--- Later in debate ---

[Mike Penning]

I gave way previously because I specifically referred to Falmouth. If we are to go forward, we have to be honest with our constituents about what is going on. Let me just touch on some of the points and some of the things I have heard on the airwaves and read in the paper.

There will be no reduction in the cover provided to rescue people. The service provided by those fantastic almost completely voluntary people who give up their time to go out will be enhanced and invested in. That service will not under any circumstances be touched. We will invest and go forward. They know that. We worked with the unions very early on and we talked to them all the way through. It is wrong—really wrong—to use emotive language and say that people would die if these changes take place because there is no evidence for that. I listened to the hon. Member for Ynys Môn (Albert Owen) earlier talking about such things. I have been at incidents where people have died. I have gone in and done everything possible, like the people in the crew that was mentioned. We do not know whether that crew would have got there any quicker under a new or existing system. What I will do—this has been touched on several times in the past few minutes—is publish the risk assessment next week; not at the end of the consultation, but next week. That will mean that everyone, including hon. Members’ constituents, can look at it. I have been accused of not publishing it and not acting. It will be published next week and it can be part of the consultation as we go forward.

[Ian Paisley]

Will the Minister give way?

[Mike Penning]

The hon. Gentleman will have to bear with me because I have two minutes left.

We should not sit back and, on behalf of our constituents, say that we think all stations can stay open and that everything is fine. I know that the previous Government looked at the matter because it was on the table when I was appointed. My hon. Friend the Member for Poplar and Limehouse (Jim Fitzpatrick)—I call him my hon. Friend because we have been friends for many years—has been sensible and this has been quite a sensible debate. What worries me is that, when hon. Members go home, they will say to their local papers tonight—I have seen such things in the papers that land on my desk in the morning—that lives are at risk and are going to be lost. The headlines will be : “Cuts to your service,” “Cuts to the frontline,” “Cuts to this.” That is not going to happen. There will be job losses. Some will be voluntary and some will be compulsory.