Mr. Jeremy Godfrey:

In terms of powers, the most important thing is that there should be proper sanctions. It does not matter what the obligations are if there are no financially significant deterrents. That would be a much less effective regulatory regime.

At the moment, we investigate non-compliance. We have to go through due process, reach a preliminary conclusion and give the operator a chance to say what it thinks. We can then reach a final opinion of non-compliance. At that point, we have to go to the High Court and ask it to issue a declaration. We can suggest the financial penalty to the High Court and it can agree with us. It is a cumbersome process and is not frightening enough.

Rather than having to go to the High Court, we would like to be able to impose a fine. There would have to be an appeal mechanism.

If we can impose the fine directly, it means that we can apply discounts for co-operation with investigations and for fixing issues quickly. It is a powerful tool.