Justice CommitteeWritten evidence from Kasia Beresford
1. Introduction
This submission is being made in a personal capacity. I am a practicing interpreter and have broad experience of management, finance and IT in large British corporates from my previous career.
I am going to address each of the six areas specified by the Justice Committee in turn. I am attaching two articles I have written, which explore in detail the statistics released by the Ministry of Justice (MOJ) and the misleading information provided to the Justice Committee about the number of interpreters currently working under the Framework Agreement (FWA). I will summarise the key points, but please refer to the articles for a fuller explanation.
2. The Rationale for Changing Arrangements for the Provision of Interpreter Services
The Parliamentary Under-Secretary of State for Justice, Mr Crispin Blunt, said repeatedly that the rationale for the changes was “to cut the cost and make more efficient provision while safeguarding quality”. In fact the implementation has focused solely on cutting costs and convenience for the MOJ, with no real overall efficiency gain and no regard for quality.
Another reason given for the changes was “anecdotal evidence” regarding the professionalism and quality of certain interpreters. As well as booking individual interpreters from the National Register of Public Service Interpreters (NRPSI), certain courts were regularly using various agencies which sent unqualified and unregistered persons to interpret in court. So, I agree change was required—but changes to check that interpreters were registered on the NRPSI or otherwise qualified and security-vetted, ie strengthening the regulatory function, not passing it to a commercial agency, which benefits financially by ignoring quality and sending the cheapest person available.
Lack of compulsory Continuing Professional Development was also quoted. If this is a real concern, it should be addressed through professional and regulatory bodies i.e. the NRPSI, or by direct provision by Her Majesty’s Courts and Tribunals Service (HMCTS), it is not a reason to make wholesale changes to the framework.
A perception that interpreters were overpaid. The discussion around this subject has been characterised by ignorance of the practical realities of a career as an interpreter and by blatant misinformation. Crispin Blunt told both the House of Commons (13 March 2012) and Radio 4 Today programme listeners that interpreters were earning six-figure salaries. It was impossible to earn a six-figure salary as a public service interpreter, other than by fraudulent means. In my experience the real remuneration an interpreter working full time in an in-demand language and available 24 x 7 could earn was at the £15,000–£30,000 p.a. level. That is not attractive remuneration for graduates with additional specialist qualifications, taking on all the risks of self-employment and working unsociable hours. It is certainly not excessive.
An assumption that low-level language skills are sufficient for court interpreting and that there are “untapped” interpreting skills in the UK’s immigrant communities—a local and unskilled labour force to be exploited. The two interrelated elements of this cheap and cheerful proposition are the assumption that court interpreting is low-skill and that, as the FWA stipulates, interpreters will be available within 25 miles of all locations for all languages. The first assumption is false, as the ALS debacle has shown, and the second is completely impractical as there is not the workload to justify that many individuals training to be interpreters. Clearly demand and supply for interpreting varies by language and location and for many professional interpreters a significant element of travel is inevitable.
A view that telephoning individual interpreters to arrange attendance is somehow “inefficient”. This argument is completely specious. There is not a sufficiently regular workload to justify employing interpreters on full-time contracts, so it is cost-effective to employ individuals on an as and when basis and therefore someone somewhere in the chain has to contact the individual interpreters to make bookings. ALS’s idea that interpreters would just pick up bookings from a website without human intervention proved to be a disaster. It is just a question of whether the individual court undertakes the activity, or a booking centre such as the Tribunals Service had at Loughborough, or an agency or an interpreter-run call centre. Claims of enhanced efficiency because the courts do not have to ring individual interpreters are completely spurious—the costs of that process have to be covered.
Reluctance to deal with individual freelancers and a view that the administrative burden of invoice processing etc is best handled by a commercial intermediary. In my experience the court administration was generally not impressive (e.g. payment only by cheque, which is an expensive method), although it was improving: in Greater Manchester a regional payment centre was introduced and the Tribunals Service had a more organised system than most individual courts. However, there is a clear line to be drawn between the outsourcing of the administrative function and outsourcing both the selection and remuneration of interpreters.
Finally, I believe there were issues in working with the NRPSI in the past. Firstly, the NRPSI became independent of the Institute of Linguists in April 2011 and has strengthened its disciplinary activity and is becoming more responsive to feedback from its stakeholders. Secondly, the function of the NRPSI is sometimes misunderstood: it is a voluntary regulator, not a service provider. Its function includes providing access to the details of registrants and ensuring they are qualified, experienced, security-vetted and subject to a code of conduct and a disciplinary framework. Applied Language Solutions clearly pays only lip-service to the regulatory duties given to it in the FWA. It is highly inappropriate for a commercial entity with a direct conflict of interest to be the creator and keeper of a register of interpreters for the justice sector. Any such register should be publicly available and transparent.
3. The Nature and Appropriateness of the Procurement Process
I am a qualified accountant and I find it shocking that the MOJ can claim to have followed “a rigorous and robust procurement process” in the light of ALS’s poor financial track record (a £20,000 loss in 2010 and a £331,000 loss in 2011) and their inadequate size and experience in relation to the size and value of the FWA contract. They should have been rejected at an early stage of the selection process on that basis.
Any person with an ounce of common sense would have been alerted to the warning signs about the type of outfit ALS is, when its bid came in significantly lower than that of the next closest bidder. ALS’s pricing strategy clearly needed investigation and the MOJ showed no financial or business acumen in this respect.
In the long term paying decent rates is not financially sustainable for ALS and the absence of reasonable, guaranteed rates is unsustainable for qualified interpreters, who are being forced to leave this market. Put simply, the FWA has been completely mispriced both by ALS and the MOJ, so that ALS is not capable of delivering it fully even at additional cost in the short term, let alone the medium or long term.
The extensive input from the interpreting profession was ignored. Cost and convenience for the MOJ were the only criteria actually applied to the decision. The MOJ seemed to forget that although it could delegate execution of a contract, it cannot delegate ultimate responsibility.
4. The Experience of Courts and Prisons in Receiving Interpretation Services that meet their needs
The overall quality of the interpreters working in courts has plummeted:
(i)
(ii)
(iii)
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National Agreement: |
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3 hours minimum |
£85.00 |
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1 hr 15 minutes travel time |
£18.75 |
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Mileage |
£5 |
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Parking |
£5 |
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Total paid |
£113.75 |
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Income net of travel expenses |
£103.75 |
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Income/hour |
£24.41 |
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ALS: |
|
|
|
|
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Job lasts 1 hour |
|
|
Total paid |
£20 |
|
Income net of travel expenses |
£10 |
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Income/hour |
£4.44 |
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|
|
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Job lasts 3 hours |
|
|
Total paid |
£60 |
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Income net of travel expenses |
£50 |
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Income/hour |
£11.76 |
These figures speak for themselves. ALS rates do not even guarantee a rate equal to the National Minimum Wage! At best the net payment to the interpreter is reduced by 52%, even though the starting point is that the rates currently paid are barely sustainable and wholly incommensurate with the skills and abilities of a professional interpreter. Clearly ALS never intended to attract graduates with additional specialist qualifications such as the Diploma in Public Service Interpreting (DPSI).
(iv)
It has become evident that the FWA theory that interpreters can make a living at lower pay rates by fuller utilisation of their time, ie by accepting back-to-back assignments, has caused great inconvenience to courts. Courts need to have interpreters available in situ for significantly longer than the actual interpreting time in the court room. Firstly, due to the unpredictability of court room scheduling and secondly, because solicitors and barristers require the interpreters’ assistance outside the court room in consultations. By working to inadequate fixed time slots for interpreters the courts are wasting other more expensive court resources eg judges’ and lawyers’ time. It is very easy to blame the interpreter, but unless HMCTS pays the interpreter for the full time booked and books an adequate time slot to cover its requirements, it has only itself to blame. Expecting interpreters to be available for as long as required and not paying for the full time booked is not reasonable. This was less of a problem in the past with a three hour minimum guaranteed, but still a problem nevertheless. I personally would accept a lower minimum time if the assignment were guaranteed to finish and there was no expectation that I would stay beyond the booked time. This could be feasible for more predictable court hearings such as Social Security Tribunal hearings. However expecting a full day to be kept free for Crown Court but not paying for it, so that the interpreter cannot book work for the afternoon, but may well be free yet not paid for the reserved time, is not reasonable and has at times led to problems.
I believe it might yield interesting information to look at the experience before and after implementation of the new arrangements for criminal courts and for the Tribunals Service separately. Each criminal court had its own interpreter booking process, whereas the Tribunals Service had a central booking centre in Loughborough, which has now been largely dismantled. The Tribunals Service had an efficient regional booking system and its own Panel of Interpreters, which included NRPSI interpreters and DPSI holders but with wider criteria for rare languages. It appeared to match interpreters to jobs fairly efficiently and provided a reasonable work flow for its regular interpreters. Why was this well functioning system dismantled for the sake of an unproven, politically driven mantra?
5. The Nature and Effectiveness of the Complaints Process
How can a complaints process be effective when the only route for complaints is to the Contractor who is the subject of the complaint? ALS has been designated judge and jury as well as being a party to the complaint—entirely absurd. Also there is no avenue for interpreters working for ALS to complain.
6. The Steps that have been taken to Rectify Under-performance and the Extent to which they have been Effective
ALS is paying certain individuals much higher rates than usual to fill the gaps that are most visible and embarrassing to it. A certain Russian lady reports being offered £700 for a day’s interpreting in Lithuanian in central London on her blog, while admitting she is not qualified for Lithuanian! Paying over the odds in such a way is not sustainable for the ALS long term.
Payment of travel time by ALS in order to reduce the problem of its under-provision of interpreters has had perverse results. I know interpreters on the NRPSI who do work for ALS and they travel far further to interpreting assignments than they ever did under the old arrangements. As only a one hour minimum is paid under the FWA, these interpreters do not accept any local bookings. It is unreasonable to expect a qualified interpreter to commit to a full day in court and face a high probability of earning only £20.00 gross for the day. This would also explain some previously unpopular remote locations getting an improved service.
The MOJ and ALS have been very reticent and evasive about the actual number of interpreters working under the FWA. I attach an article I have written on this subject entitled “Framework Fantasies: the number of interpreters working under the FWA”. The key points are:
(i)
(ii)
(iii)
7. The Appropriateness of Arrangements for Monitoring the Management of the Contract, including the Quality and the Cost-effectiveness of the Service Delivered
The FWA has not been effectively monitored at all. The contract could easily have been terminated for non-performance. The MOJ has chosen not to do so thus far. It has also not used the penalties available to it under the FWA contract. An inflexible mindset has led the MOJ to continue to rack up costs and turn a blind eye to inadequate justice for non-English speakers, rather than limiting the damage, which would entail losing face.
The attached article, “Lies, damned lies and statistics”, explains the major flaws in the statistics released by the MOJ for the first quarter of operation of the FWA. Please see the explanations in the article, but in brief:
(i)
(ii)
(iii)
(iv)
The MOJ has decided not to release statistics for Q2 of the FWA! The next publication is scheduled for 13 December to cover the first nine months of the FWA.
The MOJ seems to want to brush any inadequacies and additional costs under the carpet. It shows no signs of wanting to look at the real overall costs of its flawed policy, including those incurred by other public service budget holders eg the police for increased custody costs due to non-availability of interpreters. One hopes that the National Audit Office will prove more capable of reviewing the wider picture and calculating all the unnecessary costs being incurred due to the FWA.
The FWA is also building up liabilities for future costs, such as those of appeals where inadequate interpreting was provided. Similarly if the FWA is not reversed there will be significant legal costs incurred in explaining to the EU why the UK is non-compliant and took regressive action in the light of Directive 2010/64/EU on the right to interpretation and translation in criminal proceedings.
August 2012
Annex A
Lies, Damned Lies, and Statistics
The Ministry of Justice has recently released a report called “Statistics on the use of language services in courts and tribunals” (http://www.justice.gov.uk/statistics/courts-and-sentencing/language-services-in-use). This is the first set of statistics relating to the controversial Framework Agreement (FWA) between the Ministry of Justice (MOJ) and its contractor Applied Language Solutions (ALS), part of Capita Group plc. It covers the first three-month period during which ALS was charged with providing interpreting services for all courts and tribunals nationwide.
An Incomplete Picture
Despite the fact that nationwide implementation was made easier for the contractor by the Tribunals Service booking its own interpreters in advance for most jobs in February (only 1,711 service requests were made to ALS by Tribunals in February, as opposed to 4,711 in March), it failed to deliver so spectacularly that after two weeks the MOJ changed its initial stance of not allowing any bookings other than via the FWA.
The new guidance issued in mid-February stated: “With immediate effect HMCTS will revert to the previous arrangements for all bookings due within 24 hours at the Magistrates’ Courts. Magistrates’ Courts bookings should be made direct with the interpreter under the terms of the National Agreement. It has also been decided that we will revert to previous arrangements for urgent bookings required for bail applications, deports and fast track applications in the First Tier Tribunal Immigration and Asylum and urgent bookings in the Asylum Support Tribunal.”
Clearly a significant proportion of the total workload is not being handled under the FWA, yet the MOJ has presented a report based solely on the data in ALS’s web-based portal as at 8 May (p9 of the report). This report does not reflect the use of language services in courts and tribunals as a whole, only those requests processed by ALS.
Not revealing the total number of cases requiring interpreters makes a mockery of any claim to openness and transparency, as without figures for the courts’ total requirement the true picture of ALS’s underperformance on its nationwide contract is conveniently obscured.
Performance Well Below Target
The report includes findings, supporting tables and base data focusing on two sets of information:
Language service requests by outcome, by type of court, by month and by language and geographical region.
Complaints by reason for complaint, by type of court, analysed by region and separately by month (no base data provided).
Even within the limited parameters set by this report the contractor’s performance does not meet the criteria set out in the FWA.
The target for fulfilment of all assignments in the FWA is 98%. ALS’s “success rate” (more later) is 81% over the quarter. The actual fulfilment rate is only 72%… and neither of those percentages is actually based on the total requirement.
There were 2,232 complaints over the quarter of which 177 had not been resolved by 8 May (p7). The Key Performance Indicator in the FWA states that complaints should be resolved within three working days. Clearly the contractor clocked up another abject failure in terms of both the number of complaints and speed of resolution.
Interestingly there is no table showing total complaints. If you aggregate the tables provided you will find the total is 177 short of the quoted figure of 2,232. The figures given in the tables would be about 9% worse had they been included… so how valid are the rates shown?
One other obvious anomaly is that only 3% of the complaints actually included in the tables are categorised as relating to “Interpreter Quality”. Interestingly the MOJ’s Chief Statistician distances himself from the categorisations used in the report by saying (p9): “The classifications used in this bulletin… are taken directly from the management system [ie ALS’s system], and are decided according to the rules laid down by the contractor.” Perhaps that is why issues relating to the tier of interpreter are classified as “Operational issues”, which make up 21% of the complaints reported in the tables. This is rather convenient for the government minister Mr Crispin Blunt, who has recently quoted the 3% figure as evidence of lack of problems with quality.
Manipulation
The statistics have been manipulated to provide “improved” headline figures for the press and all those who may not have the time or inclination to examine them in detail. Let us examine one of the key statistics—the overall “success rate” of 81%.
The fulfilment rate is shown as 72%, so how does that become 81%? Well, you add 0.1% of requests when the ALS interpreter was present but the “Customer Did Not Attend” and then you take the 11% so-called “Customer Cancellations” out of the calculation. Well it’s not the contractor’s fault if the customer cancelled, is it? So, it wouldn’t be fair to include them in the total requests, would it?
The clue is on page 10 of the report: “Requests may also fail because… the supplier… does not attend (or arrives so late that the job is cancelled).” If the interpreter arrives so late that the court can no longer proceed, that is by any normal person’s standards a failure, hence those requests should be included in the total number of requests for interpreters when calculating the “success rate”.
I suspect that a large number of ALS failures are hidden in these so-called “Customer cancellations” because the rate of cancellation seems very high at 11%. In my experience the only type of court with a very high interpreter cancellation rate is an Employment Tribunal, as the parties often settle prior to a hearing. However, Employment Tribunal cancellations are only 3% of the total cancellations, so how does one explain the rest? Sometimes postponement of a hearing will lead to an interpreter cancellation in advance, but it does not happen that frequently. Certainly the cancellation rate of 17%, or 863 Immigration & Asylum Tribunals (IAT), appears extremely high. I have interpreted at quite a number of IAT cases and I can’t recall a single booking being cancelled in four years.
Clearly the real “success rate” should be closer to 72% than the 81% headline ie 26 percentage points short of the 98% target!
Obfuscation
There is a file of record-level data accompanying the report, which contains the data for the 26,059 language service requests on which all the tables and statistics are based… well, not quite.
The base data has been doctored to make independent analysis difficult: 4,446 records (17% of the total) have had the actual “Language” replaced by “Not disclosed”.
The notes provided state that this has been done “to protect the privacy of individuals” for any instances where there is only one interpreting request for a single combination of court, month and language.
This “justification” doesn’t bear examination. First and foremost there is no data relating to individuals included in the data set. How does the fact that a specific court (or group of courts) had a language service request which was fulfilled, not fulfilled or cancelled in a particular month impact on any individual’s privacy? It should be borne in mind that the data is being provided from one to three months after the event. In any case, the interpreter’s identity in any specific case is not secret: the vast majority of court hearings are open to the public and the interpreter will commonly give his or her name to the judge in open court.
So what does this restriction achieve? It makes many additional analyses of the data either incomplete or impossible. In particular it would assist in covering up high failure rates in certain languages.
For example, say I wanted to calculate the “fulfilment rate” for Tamil, as opposed to the dubious “success rate” shown in Table 2. By summing data from Tables 8, 9 and 14, I can calculate that there were 621 requests for Tamil in total, but the record-level data contains only 541 records for Tamil ie 80 requests or 13% of the Tamil data is hidden in “Not disclosed”, so full analysis is impossible.
The situation for Lithuanian, Vietnamese and Latvian is even worse because these languages are not included in Table 14, so there is no way to calculate the total requests for each of these languages. Hence we don’t even know what % is hidden in “Not disclosed”.
Even for very frequently used languages such as Polish the “Not disclosed” category is problematic. I wanted to look at the figures for Polish for my region, the North-West, but the number of Polish records which can’t be allocated as they are concealed in “Not disclosed”—310—is greater than the 239 Polish requests definitely associated with the North-West!
I fail to see any justification whatsoever for restricting the record-level data in this fashion. The only individuals protected by this obfuscation are those who are desperate to fly in the face of the evidence and maintain that the FWA is a success.
Revealing Omissions
Finally, the most important thing about this report is all the statistics that are missing.
There is not a single figure giving information about the tiers of interpreters used, although the FWA clearly states this information is to be supplied. Perhaps it is now convenient to forget about quality in relation to the FWA? Perhaps this reflects the reality that there are no minimum standards for court interpreters any more? It is certainly noteworthy that the detailed criteria set out for each tier in the FWA have been diluted into “tier-based needs” in this report and contain no mention of any qualifications or experience at all.
Similarly, the number of available interpreters, gaps in availability of languages by region and all the other Key Performance Indicators listed in the FWA are conspicuous by their absence.
These statistics do not even address the limited scope set honestly. While the MOJ turns a blind eye and refuses to accept that the FWA is fundamentally flawed, the outlook remains bleak. Proper evaluation of the FWA would reveal very poor stewardship of both the public interest and the public purse.
Annex B
Framework Fantasies: The Number of Interpreters Working under the FWA
We are now over six months into the MOJ’s Framework Agreement (FWA) for interpreting in courts, and throughout, rather than treating interpreters as stakeholders in the judicial process, the politicians and officials at the MOJ have persisted in attempting to impose the Framework on interpreters in the delusion that they can force highly-qualified, intelligent, freelance professionals to work for them under clearly unacceptable arrangements.
One of the Framework Fantasies is that interpreters are low-skilled automatons, who just spurt out translations word for word, expendable Google Translate skivvies who can easily be replaced from amongst all the newcomers in this country and, if it weren’t for a few “militants”, the FWA would operate smoothly, everything would settle down and the “teething problems” could be forgotten.
The reality is that the professional interpreters, who are able to facilitate efficient and effective communication in court, are voting with their feet: refusing to work both for the chosen contractor and, in many cases, for any body which participates directly in the FWA. Good interpreters are intelligent individuals and well able to assess the current situation. We can see that there is no future at all in public service interpreting while this farcical FWA persists.
In fact, in a recent letter to John Leech, Crispin Blunt answered my MP’s question about how many ALS interpreters are registered on the National Register of Public Service Interpreters. Applied Language Solutions supplied the information that they had 301 NRPSI interpreters as at 6 July 2012. Unverified figures provided by ALS are known to be less than reliable and it is not in its interest to understate this number. So, at best, 13% of NRPSI interpreters might be available to work under the Framework Agreement and it is clear that at least 87% of NRPSI interpreters reject it outright.
Both ALS-Capita and MOJ representatives have repeatedly maintained that properly qualified, experienced and vetted interpreters are signing up to work under the FWA in droves. They seem to think that by repeating it frequently, they can make it come true: that, if they can make interpreters believe it, they will follow like sheep.
We know that ALS/Capita has made many statements about the numbers of interpreters working under the new arrangements quoting wildly varying figures. The context always implies that the number relates to proper interpreters working under the FWA, but the words are always suitably vague, so that they cannot be pinned down.
The MOJ surely could be expected to do better? It wouldn’t be hard to be a touch more impartial, objective and reliable than Gavin Wheeldon’s creation.
In an article in the Independent on the 21 May 2012, the MOJ is quoted as follows: “Close to 3,000 interpreters are now working under this contract.”
In a letter dated 31 May 2012 to Sir Alan Beith, the Chief Executive of HM Courts & Tribunals Service, Peter Handcock, answers a question about how many interpreters are providing services via ALS (http://www.publications.parliament.uk/pa/cm201213/cmselect/cmjust/courtinterpreters.pdf).
He explains that each language for which an interpreter is qualified counts separately “as a single entity” giving “a figure of almost 3,000 interpreters (by language)”. The normal terminology for this is “3,000 language listings”, as saying “3,000 interpreters” lends itself to misleading quotes such as the one in the Independent mentioned above.
Mr Handcock continues: “This equates to around 1,500 individual interpreters providing services under the contract.” In actual fact it is extremely improbable that 3,000 language listings equates to 1,500 interpreters properly qualified in all their listed language pairs. Why could Mr Handcock not tell the Chair of the Justice Select Committee how many people were actually providing services as interpreters? Perhaps because the figure is substantially lower than 1,500? Or maybe the 3,000 figure is poppycock? Is disingenuous obfuscation a reasonable way to reply to the Chair of the Justice Select Committee? Or could it be possible that Mr Handcock really is blithely unaware of what is happening in the service for which he is responsible?
Similar information was conveyed to the House of Lords on 9 July 2012 during a debate instigated by Baroness Coussins. Lord McNally said: “At the moment there are about 1,500 interpreters under contract and they are equivalent to about 3,000 interpreter persons, which means that many of them speak two or more languages.”
Anyone knowledgeable about the realities of legal interpreting in the UK will instantly recognize this as twaddle, because the vast majority of legal interpreters work in only one language pair. There are some combinations of languages where it is more common to work in multiple language pairs eg Urdu<>English and Panjabi<>English or Cantonese<>English and Mandarin<>English, but most interpreters have only one pair for which they are properly qualified to intepret.
The proposition presented by Lord McNally and Peter Handcock might be taken at face value by those unfamiliar with the field because misconceptions about what is involved in interpreting are common.
The most high-profile type of interpreting is conference interpreting and people may be aware that it is common for a conference interpreter to work with multiple languages. However it is common only where the interpreting is in one direction ie the interpreter understands a number of languages, but speaks only in his or her native tongue. Court interpreting is bi-directional ie you interpret to and from both languages in the pair. Few interpreters are qualified or capable of interpreting bi-directionally between multiple pairs of languages to a high standard.
The second misconception is expressed in Baroness Sharples’ question: “how many languages each interpreter is expected to speak?” A legal interpreter doesn’t just have to “speak” a language—social chit-chat or getting by communicating in everyday situations—the interpreter has to interpret between two languages and needs specialised terminology in both, a huge breadth of vocabulary in both etc. I have degree-level French and Russian and “I speak” a bit of Spanish and Italian, but I only interpret professionally between Polish and English. If holiday-level language skills are included, then 1,500 interpreters could easily become 3,000, or far more, “interpreter-persons”.
My arguments above are confirmed by the actual figures provided to me by the National Register of Public Service Interpreters. Currently 86% of NRPSI interpreters are registered for one language pair only, 12% interpret in two language pairs and 3% in three language pairs. The ratio of language listings to interpreters is 1.17, which means you would expect to have 17% more language listings than interpreters—not 100% more as Lord McNally claimed!
It is a matter for embarrassment, to say the least, that this was presented as a serious proposition in the House of Lords and to the Chair of the Justice Committee. It points to dilution of standards and quality on a massive scale, which is wholly incompatible with complying with the EU Directive on the right to interpretation and translation in criminal proceedings, due to be fully operative in October 2013.