Written evidence submitted by Heriot-Watt
1. Heriot-Watt University (HWU) is one of the
most culturally diverse centres of study in the UK. We have a
long tradition of welcoming students from all over the world,
and 35% of our students studying in Scotland come from outside
the UK. We also have an unsurpassed international in-country presence,
delivering degree programmes to 11,800 students in 150 countries
around the world. HWU is therefore particularly concerned regarding
the proposed changes to the UK's visa regulations as outlined
in the recent UKBA consultation document.
2. HWU welcomes the UKBA's consulation on reforming
the provision of private sector sub-degree provision and understands
that the current abuses of the PBIS system require further revision
of existing regulations.
3. We are deeply concerned, however, that the
proposed changes will impact severely on the University's ability
to recruit suitably qualified international students. Fee income
from international students studying in our Scottish campuses
accounted for approximately £19 million to Heriot-Watt in
2010-11. With an overall institutional turnover of £147.6
million in 2010-11, this income stream therefore plays a central
role in institutional strategy for growth in the face of reductions
in public-sector spending and cuts to funding. Furthermore, a
significant proportion of the University's international students
are recruited from within the UK. UK-based Further Education and
private-sector institutions offer valuable and legitimate sub-degree
level provision to students who intend to come to the UK in order
to progress into Higher Education.
4. As requested by the Scottish Affairs Committee,
the key issues relating to impact on the University and more broadly
Scottish economy and society are discussed below.
1. How the proposal to reduce the number of
international students might impact upon Universities in Scotland
1.1 The announcement of proposed tighter regulation
is already being perceived negatively overseas in key markets
such as China and India. The University is very concerned about
the adverse impact of proposed immigration policy changes on the
reputation and image of Scotland and the UK as a preferred destination
for high quality education provision, particularly in an increasingly
competitive global market. The consultation's proposals appear
to be focused on correcting problems centred on provision in the
private, sub-degree sector. However, it is of great concern that
remedial measures may have a significant and adverse impact on
the whole of the UK's Further and Higher Education capacity to
recruit international students and operate successfully internationally.
HWU has a wide range of international teaching and research initiatives
and has developed a global presence as a transnational provider
of UK HE through collaborative activities, research and teaching
partnerships and its branch campus in Dubai. Such activities are
of economic and political value, supporting government policy
for international development with key global markets.
1.2 HWU supports the assertion made by Universities
Scotland that "the successful recruitment of international
students is integral to Scottish Universities' contribution to
Scotland's international profile and to the Scottish economy."
(U.S. Circular 02/11, p2). It is worth noting that Universities
Scotland also quoted a 2009 University of Strathclyde report on
the economic impact of Scottish Universities which estimated that
overseas students generated £516 million of export earnings,
including off-campus expenditure of £231 million.
1.3 Whilst HWU supports changes to UKBA policy
designed to deter the operation of "bogus colleges"
offering programmes at sub-degree level, we are concerned about
the way in which such provision is defined. In particular, our
concern is that the proposed changes may severely impact on legitimate
private and public providers which offer sub-degree level programmes
to students who intend to progress to degree level programmes.
These providers offer important progression routes into Scottish
1.4 As an example, HWU admitted 39% of its non-EU
undergraduate intake in 2010 from other UK institutions and the
impact of limiting legitimate UK providers in this sector could
have severe financial consequences for HWU, particularly given
the comparatively longer time that undergraduate students spend
at the University compared to those registering at posgraduate
1.5 For reference, during the academic cycle
2009-10 HWU attracted 871 applications from non-EU students at
undergraduate level with 194 new entrants. At postgraduate level,
HWU received 8,133 applications and admitted 781 new non-EU students.
2. Broader impact on Scotland's economy and
2.1 The benefits of allowing suitably qualified
international graduates "leave to remain" for work purposes
should also be considered. Heriot-Watt's portfolio is specifically
focused on business and industry-relevant qualifications and centres
on STEM disciplines (identified as a priority by the UK and Scottish
Governments), Business, Textiles and Languages.
2.2 Our international graduates are actively
sought after, notably in specialist and economically vital disciplines
such as Petroleum Engineering, Actuarial Science and Logistics
& Supply Chain Management.
2.3 In the instance of the University's highly-rated
Institute for Petroleum Engineering, 109 of the 181 students registered
in 2010-11 are classified with non-EU status. These graduates
are in high demand in both the Scottis, British and International
Oil & Gas sector and preventing such well trained graduates
from accessing the Scottish & UK workforce will mean the loss
of highly valuable graduate-level knowledge and expertise. This
could result, for example, in non-EU graduates being employed
by multinational companies overseas rather than in North Sea Oil
& Gas to the detriment of the Scottish economy.
2.4 Indvidual examples of graduates of a non-EU
background include the following who have succesfully used the
Post-Study Work route:
PhD graduate in Computer Science who worked successfully for a
research spin-out company before returning to China as Heriot-Watt
University's in-country representative.
PhD Graduate in Built Environment who lectured in the University's
School of Built Environment before returning to Syria to participate
in the Syrian Higher Education Capacity Building Project.
PhD graduate in Translation & Interpreting who works for the
Scottish Government as a translator, recently supporting the Scottish
First Minister during the visit of a delegation led by the Chinese
2.5 As a Scottish institution, Heriot-Watt has
been an enthusiastic supporter of initiatives to address the demographic
problems of the reducing Scottish population (eg the Fresh Talent
initiative). The UK government's stated intention to reduce immigration
levels threatens to impact particularly on Scottish society given
the declining population (the number of births is projected to
fall from 60,000 in 2008 to 53,600 in 2033).
3. Specific concerns on proposed changes
3.1 HWU would oppose any proposed change to require
international students on student visitor visas to return home
to apply for a Tier 4 visa. International students at HTS institutions
should be permitted to apply from within the UK, thus removing
an impractical and expensive barrier to appropriate progression
of bona fide students.
3.2 Expecting students to return to their home
country to apply for their new visa is impractical for many students
as additional costs, disruption to both them and their dependants
and lead time for new visa to be processed will all impact on
study. There would also be adverse implications in terms of cost
and accommodation for the students concerned. Also, the gap between
students finishing summer pre-sessional or foundation study and
commencing degree programme can be less than three weeks, significantly
less than the targets currently being met by many Entry Clearance
managers. Disruption to continuing students (eg PhD students)
who need additional visa time to complete their studies would
be significant if they can not apply for this extension from within
3.3 Our HESA data shows that around 150 international
students progress each year between HWU's own programmes, which
includes progression from pre-sessional English courses and from
Undergraduate to Postgraduate level.
3.4 At undergraduate level HWU is particularly
concerned that sub-degree providers such as Scottish Further Education
Colleges and private sector partners such as Study Group are able
to maintain and develop their portfolio as they offer valuable
opportunities to international students and act as important feeder
institutions to HWU.
3.5 At postgraduate level, a key concern is the
impact that the proposed changes may have on the Post Study Work
route, as discussed below.
4. Protecting the Post Study Work Route
4.1 The post study work route is a valuable route
for international graduates who wish to build on their academic
experience through a period of work and it is a significant asset
in attracting international students to the UK for Higher Education.
Particularly in Scotland, we welcome high quality graduates contributing
to economic development and playing a valuable role in our universities.
4.2 The University wishes to highlight that doubts
about the future of PSW are already having a negative impact on
recruitment, based on feedback from our international representatives
in core markets such as India and China - both established as
significant markets for UK-international relations and business
development. The University is very concerned about the impact
of proposed immigration changes on its ability to achieve its
goals for international development. These include transnational
provision which may also be adversely affected in key markets
as a result of the negative perceptions being associated with
the UK through changes proposed to immigration policy.
4.3 The total closure of the PSW route would
impact negatively on international recruitment and send the wrong
message overseas (we believe that this would lead to the UK being
seen as unwelcoming). This is of particular concern to Heriot-Watt
as 48% of our postgraduate students come from outside the EU.
4.4 Therefore, restrictions to HTS graduates
or only postgraduate students would be preferable to a total closure
of this option. Also, a transitional arrangement should be in
place, at least for students who will be completing their studies
this academic year, otherwise this could cause severe damage to
the UK HE sector and our ability to operate successfully in international
5. Alternative approaches
5.1 As an institution with Highly Trusted Sponsor
status, HWU is of the view that changes to the system should further
develop the responsibilities given to "bona fide" HTS
institutions. Such development would allow Universities to continue
to make informed, professional decisions on both English and Academic
entry requirements, allow international students to progress to
new courses with minimum interference (with their dependents)
and allow well-qualified international graduates to pursue Post-Study