National Preventive Mechanism Fifth Annual Report 2013–14 Mousa Inquiry, was no longer necessary. Referring to existing inspections by the Army’s Provost Marshal and own Inspector, as well as visits by the International Committee of the Red Cross (ICRC), the Minister of Defence announced that the existing ‘triple’ inspection regime was ‘already fit for purpose and does not require further amendment’. This decision is in contrast to the very positive indications received by HMI Prisons when preparatory work for such an inspection was undertaken in 2011, in response to a request by the Ministry of Defence and successive Ministers of State for the Armed Forces. HM Chief Inspector of Prisons raised concerns about this decision, which he considers to be contrary to OPCAT Article 4(1) and the need to prevent any reoccurrence of the human rights violations suffered by Baha Mousa. Submitting proposals and observations on legislation (OPCAT Art.19c) Across the NPM, members commented on draft legislation and policy as a means of strengthening protections for those in custody and preventing ill-treatment. Given the breadth of the UK NPM’s membership, and the devolved nature of some areas of policy and legislation in the UK, NPM members often collaborate in providing responses. Where appropriate, NPM members also respond to each others’ consultations, such as around new inspection standards, and this is one of the means by which the various inspectorates and monitoring bodies share good practice and promote complementary approaches. Some of the main policy consultations and legislative processes to which NPM members 26 have submitted proposals and observations include: • A joint NPM response submitted to the February 2013 'Transforming Youth Custody' consultation on the government’s plans to introduce secure colleges in England and Wales. The government’s proposals cited the need to reduce reoffending, cut costs through competition and improve education provision to children in custody as its rationale for change. Subsequent government announcements set out that the first secure college would be opened in 2017, and would hold up to 320 girls and boys aged between 12 and 17 (see also section 2, Thematic areas (iii)) • OCC and HMI Prisons both responded to the government’s proposals for legal aid reform, as well as a review of these proposals by Parliament’s Joint Committee on Human Rights. The proposals regarding prison law, which are now implemented, restrict criminal legal aid in some prison law matters. • HMIPS submitted evidence to the Justice Committee of the Scottish Parliament on alternatives to custody, including for women offenders, and also on the Public Service Reform (Prison Visiting Committees) (Scotland) order 2014. • HMIC and HMI Prisons responded to a Home Office consultation on the treatment of 17-year-olds in police custody in September 2013, providing evidence from custody inspections to call for the provision of an ‘appropriate adult’ to 17-year-olds in police custody in both law and practice. Under the Police and Criminal Evidence Act 198435 (PACE), 17-year-olds could be treated by the police as adults and their entitlement to