Ms Mary Heavey:

I will make one final point. We believe the general scheme, as currently drafted, does not include a full list of the people who have an entitlement to be here and have a long-term right to reside here. There are people who have arrived to reside here under other European case law, and they have derivative rights. We believe that the list is not full or complete. That is another part of the general scheme that we believe may be incompatible with EU law.