Business Consultancy Services Ltd
Rt Hon Danny Alexander MP
Chief Secretary to the Treasury
1 Horse Guards Rd
London SW1A 2HQ
17 August 2010
Dear Chief Secretary
Passport fees – the case for a £23 ten-year adult passport
The Identity & Passport Service say<![if !supportFootnotes]><![endif]> that “the passport fee is reviewed by HM Treasury to ensure that there is no cross subsidisation between Identity and Passport Service activities”. Thus this approach to you. Since 1997, the price of a ten-year adult passport has quadrupled from £18 to £72. Your Treasury review could and should let a lot of hot air out of the price.
For some time it has been said<![if !supportFootnotes]><![endif]> that 70% of the passport fee is in respect of passports and the balance is in respect of ID cards and the National Identity Register. The Identity Documents Bill<![if !supportFootnotes]><![endif]> should be enacted by Christmas. Now that we are not going to have ID cards and now that the National Identity Register is to be destroyed, presumably this cross-subsidisation can cease and passport fees can be reduced by at least 30%.
The price of a ten-year adult passport is incredibly due to rise on 3 September 2010<![if !supportFootnotes]><![endif]> to £77.50. A 30% reduction would see that figure come down by £23.25 to £54.25.
Time was when the Identity & Passport Service planned to include flat print fingerprints on passports by 2012. That plan has now been dropped. The Identity & Passport Service say that “passport fees only recover the operational costs incurred in processing passport applications”. With no flat print fingerprints to process, it must be possible to reduce the price below £54.25.
How far below £54.25?
Consider. In 1997, a ten-year adult passport cost only £18. RPI inflation between May 1997 and May 2010 was 42.5%. If the price of a passport had only kept pace with RPI inflation, it would now be £25.65.
Technology costs have fallen in the past 13 years. There have been several efficiency reviews of the civil service during that time. The Home Office have the constant benefit of private sector consultants<![if !supportFootnotes]><![endif]>. Open competition for government contracts has been introduced. If the combined effect of all those factors is to improve efficiency by 10%, say, then the price of a passport now should be more like £23. (If that isn’t the effect, then why are we spending hundreds of millions on consultants?)
The gap between £23 and £54.25 is occupied, according to the Identity & Passport Service, by consular premiums and security enhancements:
Security enhancements include the introduction of: ePassports, with an electronic chip; interviews for first time adult passport applicants; secure passport delivery and; a number of other anti-fraud initiatives. The introduction of these security enhancements has been in line with international travel document regulations and entirely separate from the introduction of identity cards.
The UK is, indeed, a signatory to the Berlin Resolution of the International Civil Aviation Organization and we must abide by it. Which means that we must have a machine-readable digital photograph of the bearer stored on a chip in the ePassport<![if !supportFootnotes]><![endif]>. That is all we are bound to do.
The Berlin Resolution states that facial recognition was chosen specifically since the image “can be captured from an endorsed photograph, not requiring the person to be physically present”. There is no international regulation requiring first time adult applicants to attend an interview in person. That is a decision of the Identity & Passport Service’s and HM Treasury may care to review it, it may be a waste of money.
Similarly, the proposed introduction of flat print fingerprints was not a matter of obeying international regulations. European Council regulations 1030/2002<![if !supportFootnotes]><![endif]>, 2252/2004<![if !supportFootnotes]><![endif]> and 380/2008<![if !supportFootnotes]><![endif]> all specifically exclude the UK. The National Audit Office say<![if !supportFootnotes]><![endif]> that adding flat print fingerprints to passports is something the UK volunteered for. Under the coalition government, it seems that we can now very sensibly unvolunteer.
Very sensibly, because the National Audit Office reviewed the introduction of ePassports and could find no evidence<![if !supportFootnotes]><![endif]> that they increase our security. The history of biometrics based on facial geometry is a story of uninterrupted failure<![if !supportFootnotes]><![endif]>. The credulous belief that mass consumer biometrics have suddenly become reliable seems to be a global delusion<![if !supportFootnotes]><![endif]>, <![if !supportFootnotes]><![endif]>. Again, HM Treasury may care to review the matter to make sure money is not being wasted.
The crucial question is whether biometrics based on facial geometry are reliable enough to improve our security. When members of the public ask the Home Office to provide that evidence, they refuse<![if !supportFootnotes]><![endif]>. HM Treasury may have more luck.
The only evidence that can be persuasive, in the view of the House of Commons Science and Technology Committee, is a large-scale field trial<![if !supportFootnotes]><![endif]>. Computerised simulations of the sort favoured by the US National Institute of Standards and Technology tell us nothing<![if !supportFootnotes]><![endif]>. There is a lot of evidence that biometrics based on facial geometry aren’t reliable enough and no evidence that they are. The same is true of biometrics based on flat print fingerprints.
It follows that there is no point wasting any more money than we have to on the Berlin Resolution. We’ve got the chips in the passports. Leave it at that. “Smart” electronic gates at airports, for example, designed to match people to their ePassports, are an unnecessary waste of money<![if !supportFootnotes]><![endif]>, <![if !supportFootnotes]><![endif]>. It follows also that, in giving up flat print fingerprints in passports and ID cards, we have given up nothing<![if !supportFootnotes]><![endif]>, they are too unreliable to make any contribution to national security.
It should be possible, with an ePassport, to prove that it is authentic, i.e. that it really was issued by the Identity & Passport Service and hasn’t subsequently been revoked. That proof would require use of the public key infrastructure. How much would that cost? How much, that is, would it cost to check the authenticity of all UK passports on entry and on exit at all border crossings? Does the UK Border Agency have the infrastructure<![if !supportFootnotes]><![endif]> to perform these checks? Do other countries take advantage of the public key infrastructure? If they’re not going to be used, either here in the UK or abroad, is there any point paying for these authentication facilities?
Take away the interviews for first time passport applicants, take away the expensive biometrics which are too unreliable to enhance our security, ignore the alleged international regulations from which it turns out on inspection the UK is expressly absolved, think hard about the unused authentication facilities in ePassports, note that now that there are no flat print fingerprints to process and there is no National Identity Register to maintain consular premiums can be reduced, and the result of your review of passport fees is likely to be a lot closer to £23 than £54.25.
cc Stephen Hammond MP
Damian Green MP, Minister of State (Immigration)
Amyas Morse, Comptroller and Auditor General, National Audit Office
Keith Vaz, Chair, Home Affairs Committee
Andrew Miller, Chair, House of Commons Science and Technology Committee
Sarah Rapson, Chief Executive, Identity & Passport Service
Alan Brown, Deputy Director, Policy, Identity & Passport Service
<![if !supportFootnotes]><![endif]> Please see copy letter attached from Alan Brown, Deputy Director, Policy, Identity & Passport Service or see http://forum.no2id.net/viewtopic.php?f=5&t=32949&p=120084#p120084
<![if !supportFootnotes]><![endif]> Please see for example http://webarchive.nationalarchives.gov.uk/+/http://www.number10.gov.uk/Page10364 and http://thescotsman.scotsman.com/letters/True-cost-of-card.5658700.jp. No evidence has ever been published, incidentally, to support this 70:30 split. A Treasury review may well discover that the proportions are quite different.
<![if !supportFootnotes]><![endif]> http://www.publications.parliament.uk/pa/cm201011/cmpublic/identity/memo/mid08.htm
<![if !supportFootnotes]><![endif]> http://www.paconsulting.com/our-experience/pa-wins-gold-at-the-2010-mca-awards/
<![if !supportFootnotes]><![endif]> http://dematerialisedid.com/PDFs/Biometrics%20deployment%20of%20Machine%20Readable%20Travel%20Documents.pdf, please see p.15
<![if !supportFootnotes]><![endif]> http://www.apply.eu/directives/format-for-residence-permits.pdf
<![if !supportFootnotes]><![endif]> http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:115:0001:01:EN:HTML
<![if !supportFootnotes]><![endif]> http://dematerialisedid.com/PDFs/0607152.pdf, please see para.1.7
<![if !supportFootnotes]><![endif]> Ibid., please see para.3.2. Indeed, the inclusion of RFID tags in ePassports may reduce our security since these devices can be induced to broadcast our personal details, please see http://www.cio.co.uk/news/910/uk-rfid-passport-chip-cracked
<![if !supportFootnotes]><![endif]> http://dematerialisedid.com/PDFs/1032.pdf, please see particularly para.83. The Home Office have ignored the Committee’s recommendation to publicise the results of their trials
<![if !supportFootnotes]><![endif]> http://dematerialisedid.com/Register/regBiometrics.pdf, please see particularly Notes 8 and 9. Even NIST don’t believe the results of their “chimera” trials
<![if !supportFootnotes]><![endif]> http://www.telegraph.co.uk/news/uknews/3136395/Security-fear-over-airport-face-scanners.html
<![if !supportFootnotes]><![endif]> http://www.telegraph.co.uk/news/newstopics/politics/lawandorder/5110402/Airport-face-scanners-cannot-tell-the-difference-between-Osama-bin-Laden-and-Winona-Ryder.html