Written submission from Daniel Schofield (PSC0002)

I provide this written submission of evidence in regards to the above inquiry. I will be submitting this as an individual. I have several years’ experience in law enforcement in a variety of roles, including volunteering as a Special Constable, a civilian duty planner with the British transport police to having been an officer with the Metropolitan Police.

 

  1. Firstly, its worth reviewing the current security arrangements at air, rail and sea ports. At airports, due to the high level of terrorism threat, there are many layers of security. Local police forces provide armed and unarmed officers, along with counter terrorism detectives. Airport security including searching and screening of passengers on departure is provided by the airport authority and UK Border force undertake Immigration and Customs functions. I must confess Airport security isn’t 100% effectively after a couple of times forgetting that I had larger than 100ml liquids in my carry on that wasn’t detected.

 

  1. At Railway ports of entry, UK Border force are deployed at juxtaposition controls for boarding passengers. Border force staff at these controls often live in the UK and are deployed to other countries daily, which can be very ineffective and tiring for staff. Railway stations in the UK aren’t staffed by Border force. However, staff in juxtaposition controls only carry out immigration controls only, not customs controls.

 

  1. Customs controls can only be carried out at Coquelles, or the UK. It is unclear if this is being done, or if Border Force is knowingly or unknowingly taking an organisational risk by carrying out customs controls at other Juxtaposition controls except Coquelles. If Border Force wished to extend this they would need agreements with EU States.

 

  1. There is also the ‘Lille loophole’ which is unresolved and previous attempts to tackle this were met by threats of arrest from Belgian federal police to Border Force officers. This issue it likely to have an impact on future policing and security arrangements and relationships.

 

  1. As for policing, Eurostar is policed by British Transport Police. However, there’s a very strange arrangement where it appears only Kent police have a police station in Coquelles, not BTP, despite the fact it was BTP that travelled across the channel with Euro 2016 football fans, not Kent police. The onus on policing the tunnel seems to be on Kent police, not BTP. BTP isn’t part of the Cross-Channel Intelligence Community either, but Essex police are, again curious considering its BTP that police the actual railway itself and the stations on the UK side. It also doesn’t involve Sussex, Suffolk or Hampshire that could also benefit from being members.

 

  1. At Sea ports, the picture becomes even more complicated. All ports have security provided by the private port authority, but some, around 10 ports have a private independent port police. Some of these police forces are used as simply security, others used as full-blown police forces, supporting the security officers at the port, local police and attending port emergencies as well as preventing and detecting port crime, such as recovering stolen cars about to exported, etc. Some ports use security officer to carry out Maritime security checks for embarking passengers, some use private police. However, each of these private forces are individual to each port. Its not clear what intelligence they share amongst themselves or whether they work together on cases, particularly cases where organised criminals target several ports to move stolen goods abroad.

 

  1. Local police forces provide counter terrorism officers like at airports. UK Border force are responsible for immigration and customs functions at all ports and marinas, however their presence at sea ports, especially those that don’t have commercial passengers arriving, is patchy, which I will now come onto.

 

  1. The Home office state that UK Border force are currently responsible for immigrations and customs provision at around 140 ports of entry to the UK. Just under half of these 140 currently have a permanent body of staff stationed there. 77 in fact are listed by UK Border force as “unstaffed” meaning in actual fact, 63 ports are staffed by Border force. The majority of these unstaffed ports are in the North of England and Scotland, although there are several in Southern England. In addition to this there are thousands of smaller ports, marinas and air strips which UK Border force are responsible for.

 

  1. We have seen report after report for years that Border force can’t cope with what it is being expected to do through a lack of resources and staff. Border force appears to not have enough posts, let alone staff, with the budget being cut by 15% between 2011 and 2015, despite passenger numbers rising by 20% since 2010 and expected to continue rising by 2% a year. There may well be a rise above that 2% if we experience a “last minute rush” of people who want to move to the UK before Brexit.

 

  1. The Home office appears to have made Border Force a hellish organisation to work for with constant targets, inept leadership, re-brand and re-organisation one after the other and cut after cut or experienced staff and resource. Imagine having worked there since 2005! Staff are extremely stressed and therefore less likely to do their jobs effectively, or come to work at all, through sickness. All of this means that there is no resilience or goodwill left in the organisation. Brexit will be the rod that smashes the camel’s back.

 

  1. Although customs and immigration merged nearly a decade ago, we still see that Border force separates officers into Customs and immigration teams, something that is detrimental to officers training, development and morale and defeats the point of a unified Border force. We have also seen experienced staff with specialist skills leaving the organisation not being replaced.

 

  1. One gap with current cooperation between government departments we can see from a number of the independent chief inspector of borders and immigration reports and also from my own experience we have a problem where the National crime agency are only taking on the most serious and highest level of cases in relation to border crime and seizures, leaving for the first time in this country a sizeable gap of offences deemed as "low level, easy wins" that will not be investigated. Essentially, they are “cherry picking” cases. From these inspections and cases, it appears that for whatever reason these investigations, although mainly ones of post seizures are being left to the local police to take on if they wish to. That is having an effect on the confidence of both Border force and police officers.

 

  1. It also raises the question of what happens to seizure cases that aren’t involving post. Are they simply left?

 

  1. This is also an issue of EU cooperation. Who do EU agencies cooperate with in future, especially if the seizure they require information on is not being actively investigated?

 

  1. All seizures at the border should be investigated by the National Crime Agency Border Command from current policy. This is quite simply not being done, and intelligence is passed to local neighbourhood teams (Not Squads or CID as they are under so much pressure they can't take on these proactive investigations). I can tell you first hand due that due to the pressures on the police and the sheer number of intelligence reports coming in these cases were often not auctioned upon.

 

  1. On very rare occasions, a local team will be tasked directly by the local intelligence team to the report from the NCA and told to investigate or develop with the view of applying for a warrant. However, 99% of the time it would rely on a proactive member of the team frequently monitoring the local reports on the intelligence database, something most officers don't have time for.

 

  1. Where the Police do take on these very complex investigations (a fact that is often off putting to busy officers itself) they often face problems obtaining warrants from Magistrates courts. The courts argue that if the prohibited items have already been intercepted then what would the officers would expect to find at the premises where it would be delivered to? This puts officers off further from pursuing these cases as a waste of time and effort, particularly given the cuts of previous years.

 

  1. The answer to these questions from Magistrates is that other packages that haven't been intercepted could be found (a fact that isn't strong enough on its own for most courts in most cases to grant a warrant) as well as documents to assist an investigation. The application has to include the fact that with the monopoly of Royal mail coming to an end and several couriers now operating and with no watch list of addresses of previous seizures kept, there is no current way of ensuring that seized post are all of the parcels that were sent. The key is there is no way to guarantee all parcels to suspect addresses are inspected.
  2. However, this answer and argument to use on an application isn't in any guidance. It's an answer I had to come up with myself and confirmed to be the case with the NCA after I rang them and asked. In fact, the magistrates remarked to me that it was strange the NCA weren't investigating and were astonished it was being left to local officers and there was no central intelligence database of checking post to addresses. These problems show why dedicated investigators are needed.

 

  1. It is alarming that for the first time in this country we now have a situation where the majority of seizures at the border aren't investigated or followed up. That can only be a good thing for criminals (especially those that send a large number of small consignments) and a bad thing for Border force and national security. We have already seen from the independent Chief Inspectors reports so far that its having a bad effect on border force staff. The reports have a common theme of officers no longer reporting what the NCA term "low level easy wins" or pieces of intelligence any more as they know the NCA won’t take it on and nothing will be done. This has a subsequent effect on morale.

 

  1. In 2016-17, the Border Force seized a record 4,503 kilos of cocaine from 6,672 separate seizures. Yet in 2008-9, there were around a thousand more seizures (7,680) which suggests more smugglers are getting away with it. Even more worrying is that in 2008/9 we weren’t seeing an increase in this trend of sending lots of smaller packages to ‘Grapeshot’ the system, which we are today.

 

  1. We needed to get our own house in order to make things simpler and clearer for cooperating with the EU after Brexit.

 

  1. Brexit is also an opportunity for organised crime and a risk for law enforcement and policing. Trusted trader schemes for both customs and immigration will be exploited at some point by either an individual working for a trusted company being bribed to turn a blind eye to “extra goods” in a shipment, criminals infiltrating companies themselves, becoming employees and falsifying customs declarations or at the highest level, setting up companies that become trusted and then using them to routinely smuggle goods. The same will go for people trafficking and modern slavery in both customs and immigration schemes along with whatever other changes are made. New ways will be found to exploit them.

 

  1. One of the good things about Brexit though is with changes to customs and immigration that it is likely there will be more opportunities to detect these offences. Whilst this is good news on the surface, unfortunately its actually a risk to Border force and the police. If detection becomes more likely organised crime will respond one of two ways. Either bribery or violence, both of which could result in corruption. Recently, with terrorism rightly taking on the focus from police forces, the focus has moved away from organised crime. With the internet along with changes to police, criminal justice and the law, over the past 5-10 years more and more crime has become organised. We are becoming complacent and we need to be alive to this threat.

 

  1. On the point of corruption there isn’t a lot that I can say that wasn’t already said in the 1990’s and early 2000’s. Its alarming there currently are a lot of police officers and Border force officers unhappy with their pay as that is where the largest threat comes from. The average Border Force officer is paid between £23-6000 a year. Assistant officers are being paid around £18-19,000 a year and in a new role introduced by the government you can be an “apprentice assistant border force officer” working operationally, earning £15,000 a year! The average police officer now starts on £19,000. An NCA officer is paid around £24,000 a year, which won’t tempt any experienced professional into the NCA, especially one with the skills needed most currently. Low pay or the perception of low pay compared to duties breeds corruption.

 

  1. The Police Federation of England and Wales found in it pay and morale survey 2016 that Nationally, 74.4% of respondents said that they were not paid fairly for the responsibilities they have within their job and those who dissatisfied with their total remuneration package was 66.7%. That’s a huge corruption risk.

 

  1. Increased levels of corruption would affect our international partners sharing intelligence with us and compromise security and co-operation.

 

  1. If there are new duties and customs levied on some goods after Brexit, we will probably see a return to smuggling of goods that aren't prohibited or illegal, something that hasn't been seen since the UK joined the EEC. 

 

  1. This will require a significant increase of Border force staff to cover unstaffed ports and marinas. There will also be the question of who investigates these seizures too and how that process works between HMRC and Border Force. 

 

  1. The implications for cooperation will come because UK and many EU agencies haven’t had to deal with this 'new' smuggling since the 1970's. Agreements will have to be reviewed on intelligence sharing, joint operations and cooperation in regards to it and may have to be revised to include these issues. 

 

  1. As well as Co-operation with other agencies, Border Force will increasingly be cooperating with private companies. Developing new relationships will be important, especially with innovative firms.

 

  1. For instance, BlipSystems have developed a system called BlipTrack to monitor and analyse queues at airports by using the MAC address on mobile phones. This MAC address is solely to the Handset from the factory, and therefore no personal data on the phone is used. It can be used to display real-time demand to passengers on screens, giving estimates till they reach the front of immigration queues etc.

 

  1. The data is recorded, meaning Border force will be able to accurately analyse and predict future demand meaning it can have the right amount of resources in place.

 

  1. Recently, Birmingham airport has privately installed this system into their North Immigration hall and is sharing its data with Border force so they can predict demand and inform passengers better.

 

  1. Another issue is foreign national ACRO (criminal record) checks and providing advanced passenger information in origin countries for passengers. Recently these checks and advanced information have become critically important, especially for EU Nationals. What agreements are in place to provide these after Brexit with EU countries?

 

Recommendations

  1. I would urge you to consider the following proposals. The first would be for the committee to instruct Border Force to undertake a comprehensive review of every single entry point into the UK, including every single small port and marina, and assess the number of posts required to conduct both departure and arrival checks at each, including any future plans at that port, along with assessments for each Brexit scenario.

 

  1. I would recommend that to increase Security and simply co-operation, the Government should expand the British Transport Police’s remit to cover all UK commercial ports, ferry services and Airports covered by the National Aviation Security Plan, even those currently without a police presence, and to merge all current ports police and local police officers from local forces working at ports across the U.K, including those working in counter-terrorism, along with their estates into the BTP. This would include the Kent police station at Colloques.

 

  1. This would mean a single point of contact for Border force and all other UK and EU police Forces and a joined up approach to ports policing including all ports alerts. The BTP has policed ports previously and has significant experience of counter terrorism policing in a commercial environment with all the functions to support that, including armed protective policing where necessary. They also police by arrangements with private companies meaning the cost the tax payer would be reduced. The current funding model for BTP from the railways could be applied to airports and ports.

 

  1. Consolidation of these forces costs and procurement along with standardisation of armament and vehicles would save more money than complex collaboration arrangements between different organisations using different contracts, staffing arrangements, divisions and practices. Consolidation in contrast would allow for further cost saving and efficiencies, doing more for less. It would also reduce the number of current non-HO forces. 

 

  1. A consolidated force would help with the sharing of intelligence with all sites that could be relevant, ensure a more joined up approach to policing nationally, such as detection of stolen vehicles by organised crime at ports, along with the CID Capability to investigate the groups behind it. It would mean a single point of contact for counter terrorism, rather than lots of different procedures and contacts for sharing and dissemination of information and intelligence between ports and forces.

 

  1. This issue was looked at by the Transport Committee in their inquiry into ‘Security on the railway’ In Paragraph 3.21 they state “There may be value in applying BTP's specialist approach to policing the railways to other transport modes, such as aviation. In particular, if the BTP's funding structure and close working relationship with transport providers were replicated at airports, it could minimise delays, maximise security and reduce the cost of policing for the taxpayer. The DfT should examine the case for expanding the remit of the BTP to include (a) aviation and (b) other modes of transport.”

 

  1. BTP’s remit could be increased by an act of parliament amending the Railways and Transport Safety Act 2003, each Chief constable requesting mutual aid from BTP for each of its ports (somewhat impractical) or by swearing in officers under s.57 Civil Aviation Act 1982 and s.79 Harbours, Docks and Piers Clauses Act 1847.

 

  1. In regards to UK-EU security co-operation and intelligence sharing after Brexit, the Cross Channel Intelligence community was set up in 1968, before the UK joined the EU. Perhaps this could be used as a vehicle to maintain our intelligence channels without being member of EURPOL, particularly if the countries most relevant and physically closest to us (Spain, Norway, Denmark) joined, along with BTP, Suffolk, Sussex and Hampshire police at least. The NCA and Home office are already members.

 

  1. Having mentioned the issue with border seizure investigations, I accept with finite resources, it is right the NCA focus on the highest level and most serious of cases. There could be a number of solutions to this problem for this problem. One could be for Border force to develop its own investigative capability to tackle these cases, akin to the old HMCE, just with the most serious cases handed over to the NCA. However, given the staffing and budget issues Border force faces, this would not be wise. Another possible solution would be IE's Criminal and financial investigation teams taking on these cases. However, it would be well outside their natural remit, I doubt they have the powers needed currently and they should remain focused on their immigration work, particularly proactively investigating modern slavery cases (a role I feel they should take on from the police in cases involving trafficked foreign nationals)

 

  1. HMRC would be in a unique and ideal position to take on this challenge. HMRC have a strong cadre of investigators in its Fraud Investigation Service and due to its previous border role which it had till very recently, until 2008. It would have the powers and capabilities to tackle drugs offences and organised crime, as well as other offences relating to tobacco and alcohol which are already in their remit. If HMRC were to take on cases where the NCA does not decide to investigate due to the size of seizure there would be several benefits.

 

  1. Firstly, it would mean these cases are dealt with rather than the current situation, where the cases are ignored, criminals gain and are consistently emboldened by no intervention. With HMRC having a national remit it would mean arguments about force areas are avoided. I can tell you if one part of an investigation for one of these offences related to another police division, let alone another force area, local police officers will told to ignore that part and focus on the part that relates to their force. In some cases it will even be a push to even deal with parts of a case on another part of the same division! This mainly due to the attitude that if it's not our beat then no one else would be covering our beat while doing something on someone else's. With HMRC this would be avoided.

 

  1. Secondly, HMRC will detect other revenue offences through seizure investigations, such as cases in the hidden economy or illegal tobacco or alcohol operations. In cases of cash seizures, this could be quite important and of particular interest to HMRC, especially the kind of sums that were detected in Operation Madam at Gatwick (9.21, p46 Independent Chief Inspector of Borders and Immigration (ICIBI) report on Border Force operations at Gatwick, July 2017).

 

  1. It would also be a more streamlined and obvious system of working for Border force to hand over cases of evaded duty on smuggled legitimate good with duties levied on after Brexit.

 

  1. As mentioned previously, there is no current "watch list" of UK addresses where parcels of prohibited goods could be being sent to. Previous addresses of interceptions, or intelligence suggest will be sent to could be held on HMRC's intelligence database to fulfil this purpose and possibly be linked into the new Customs declaration system if this scans incoming mail in order to alert officers to check it and search where grounds exist.

 

  1. It could also be a good way of dealing with some of the issues of planned cuts to HMRC. HMRC could deploy staff to Joint border intelligence units, further increasing the checks these units could carry out as they would have access to HMRC's systems for further research and intelligence development. HMRC could also base investigation teams alongside Border force officers. This would solve problems raised in the NAO report on HMRC workers having to travel hundreds of miles the new 13 central offices.

 

  1. Its already been mooted that HMRC may take on the International trade detection role along with some other Border revenue functions from Border force as part of a joint "Singapore Style" approach, which will require staff to be based at the border anyway after Brexit, which would fit in with the above changes. I believe that should happen.
  2. If HMRC takes on Border revenue functions from Border force then I believe that the majority of staff currently deployed to carry out these functions from Border force should be redeployed in Customs and Immigration vacancies within Border force, not simply moved over to HMRC, further depleting Border Force.

 

  1. HMRC should bring in new staff, perhaps those redeployed from office moves, to carry out these functions, perhaps with a small amount of staff seconded from Border force to mentor the new HMRC staff in role until they are confident and competent.
  2. Although it's not ideal splitting Border force cases between three agencies (NCA, IE CFI, HMRC) to investigate, it would be good in that it spreads the workload, a key reason UKBA was broken up. As far as I am aware, it would only take a very simple government direction to the Commissioners of Revenue and Customs to allow Customs officers to deal with these offences and to make HMRC responsible for this area

 

  1. In order to address the vacancies and the "brain drain" at the same time, with minimal cost and in time for Brexit, I believe the government should write to and invite ex-border force and HMRC officers that have left voluntarily in the past 10 years with good discipline records and not suspected of corruption back to the nearest vacancies at their nearest current location. Inviting all border force and HMRC officers that have left in the past decade with good discipline and complaint records, no intelligence of them being corrupt and are before retirement age back, without an interview, just with new vetting and refresher training will go a long way to addressing border forces problems and vacancies in an effective way.

 

  1. Training for Border force officers should be standardised, meaning that all officers receive Core skills 1, 2 and 3 training as well as all being trained and appointed designated immigration officers. There should also be a national audit of training deficits for special skills, such as x-ray and cyclamen scanners and identify the number of staff and training courses needed to effectively operate and staff them. 

 

  1. To use those skills and maintain experience, Border force should come away from its operating model of separate customs and immigration teams. There should be one team for each port/terminal and staff rotated around roles on different days. This will boost staff morale, cohesion, enthusiasm, effectiveness and experience. 

 

  1. Those working operationally in Law enforcement agencies and the criminal justice system should start on around £25,000 a year with progression in pay at points, not necessarily every year, right up until retirement and without promotion. This pay should increase for investigators that could come into contact with organised crime. Non-operational staff should be paid less, but have pay points until retirement too.

 

  1. I believe that all of those involved in law enforcement such as police, prison, Border force officers, along with NCA, HMRC investigators should have their pay looked at together overall, to ensure there is no “weak link” – an organisation paying its staff much lower than others that criminals can exploit.

 

  1. We should also renew and update policies for if a team or officer are approached or whistle blow about corruption. Its vital to have protection in place and that supervisors take the threat seriously. The nightmare scenario is someone is approached with a bribe or a threat of violence or both, and they summon the courage to report it, but unknown to them the supervisor is already corrupt. As unlikely as it seems, it has happened with terrible consequences for that officer. We need to learn the lessons from what happened to DCI McKelvey and the Newham crime squad in 2007 and act. If the police or Border force won’t protect officers, then perhaps the CPS or IPCC can.

 

  1. We should also look at adopted law-enforcement aimed Developed vetting for some posts where contact with organised crime is likely. All officers should be re-vetted, and drug tested with every move within the organisation they make throughout their careers, rather than once in the beginning. Anyone failing vetting should be dismissed. A more in depth separate vetting system should be considered for law enforcement and criminal justice roles.

 

  1. The Home office should trial the use of BlipTrack in immigration halls and install it in all arrivals area of ports and airports before Brexit.

 

  1. Looking at Cooperation within government and as part of the One Government at the Border strategy, now would be the right time to look at UK Border Force taking on all UK fisheries enforcement allowing the Royal Navy to focus other tasks and on more high-end Fisheries Protection, keeping the peace around fishing fleets (think disputes like the cod wars, Scallop conflict, etc) supported by Border Force. There could still be a Fisheries Protection Squadron, and it could still make interceptions, just with them focusing more on the protection of fishing fleets and Border force having the lead on enforcement. These sorts of high-end disputes between fishing fleets, involving violence and force, will no doubt increase after Brexit.

 

  1. Current Inshore Fisheries and Conservation Authorities and Marine Management Organisation enforcement officers who already know their "patch" of the coast could move into Border force, boosting Border forces resources, and be trained and sworn in as Border force officers. I would suggest all Border force customs trained officers are also trained in fisheries enforcement. Experienced border officers from general maritime and aviation teams should merge with ex IFCA and MMO teams to support each other at their current locations and that team still patrol within the current IFCA areas, integrating teams and roles both on and offshore. This will increase Border force coverage of smaller ports and marinas, a massive current security risk, highlighted by many officers and experts.

 

  1. These teams covering smaller marinas for customs, immigration and fisheries enforcement, would go a significant way to establishing some presence in these widespread patches of gaps in our security as well as gathering intelligence from the relationships they build with people in the fishing industry and marinas. It would also be a good way of tackling modern slavery in the fishing industry.

 

  1. This would add around 33 IFCA vessels of all types from RHIB's to Larger survey vessels and purpose-built patrol vessels to the Border Protection Squadron for customs and immigration work as well as an extra 9 current Border force cutters to fisheries protection. It would also extend the current fisheries vessels to all fisheries enforcement throughout the EEZ, not just inshore. All these vessels are already in government service, crewed and paid for.

 

  1. I think the government should also include Marine Scotland Compliance along with the Welsh and NI fisheries compliance departments to this, adding around 7 more vessels and more teams. Fisheries policy could still be a devolved matter, just enforced by a UK agency that can have central co-ordination. It will also mean fishery assists like aircraft and satellite monitoring can be increasing used for customs and immigration control.

 

  1. Current non-enforcement work carried out by IFCA’s could be transferred to the MMO. A small number of suitable staff could be kept in order to do this. If this happened the government should consider merging the Maritime and Coastguard agency with the Marine Management Organisation.

 

  1. These changes could be made under the Fisheries bill introduced into Parliament. Perhaps long-term or in this bill, if these proposals were to be taken up, the powers of Maritime enforcement officers, British Sea fisheries officers and IFCA officers could be incorporated or extended to all Customs officers.

 

  1. If the Government was looking to increase the number of larger patrol vessels to patrol the EEZ after Brexit, for sale at the moment in other countries are 3 Damen Stan 4207's (same class as the majority of the cutters) from the Jamaican defence forces available with Damen Trading and 2 of the same class as HMC Protector from Finland.

 

  1. Larger cutters could be “forward deployed” in places like the Isles of Scilly, Alderney and the Outer Hebrides. Basing cutters here would support the local economy, as well as meaning cutters have less distance to travel to busy patrol areas and building relationship with costal and Island communities.

 

  1. There could be an increased cost of logistics, at least initially, but these should be done to support and develop those communities. In future the Home office could look to provide those logistics locally, or ways round it developed. For instance, on some occasions a cutter based in the Isles of Scilly, depending on where they will patrol could be required to pick up fuel and supplies in Cornwall, rather than taking it out the Isles of Scilly.

 

  1. As a part of this streamlined joined-up approach, we should look at including biosecurity for humans, animals and plants into Border force. Currently, this is covered by a whole myriad of different agencies from Port health authorities, Public Health England and the devolved versions, DEFRA, forestry commission. This is very frustrating for imports that so many different organisations involved. It also sometimes complicates the response to Biosecurity risks. New Zealand has a single agency for bio-security held under the ministry for primary industries.

 

  1. We should follow Canada's model, where they are integrated their bio-security agencies relevant staff into one Border force with a specialist division for Biosecurity.  The UK could have a central border Biosecurity unit with some specialist officers that have been moved over from Port health authorities based on ports and airports integrated into the customs teams. Customs teams could then cover biosecurity and customs meaning these Biosecurity questions and declarations can be covered together. This would make co-operation with EU agencies easier, as well as making things simpler for traders from the EU.

 

  1. If fisheries were moved over in addition to this in the way previously described, that would become joined up with the shellfish role that Port health authorities currently cover.

 

  1. Any other roles that don't strictly relate to the port environment, for instance, noise control over a river could be moved to local authority environmental health teams. Obliviously, internal bio-security and other work would remain the same and with the current agencies that deal with them. This would just relate to the border.

These streamlined approaches, if sufficiently resourced, will provide a more effective, joined-up Border Force.

I hope this will be considered and recommendations on this issue devised. Please feel free to forward on this proposal onto those who would be interested or have responsibility for this.

 

January 2018