Select Committee on Regulatory Reform Minutes of Evidence

Examination of Witnesses (Questions 1-19)


1 APRIL 2008

  Q1 Chairman: Welcome everyone and thank you for coming to give evidence today. I think you have had a good briefing on what we are seeking to do. It is four important organisations giving evidence today. I appreciate that some of the questions might be directed at one of you and others may think, "I would like to comment on that," and if there is time we will take comments from as many as possible, but if there are other things you want to supplement your comments with in writing after, please feel free so to do. There are a couple of other members who will be joining us who are detained at other events at the moment, but if you are happy we will get straight in. Perhaps for the record the four of you could formally introduce yourselves, starting with Ms Low.

  Ms Low: I am Sally Low and I am Director of Policy and External Affairs for the British Chambers of Commerce.

  Mr Fell: I am Matthew Fell, Head of Corporate Affairs at the CBI with responsibilities including the Better Regulation Agenda.

  Mr Ehmann: Alexander Ehmann, Head of Parliamentary Regulatory Affairs at the Institute of Directors.

  Mr Davenport: Clive Davenport, the Chair of Trade and Industry at the Federation of Small Businesses.

  Q2  Chairman: Thank you and welcome. Can I start off by asking all of you: do you believe that the BRE has a firm grip on its own objectives?

  Mr Fell: My take on that is the BRE in a sense has two key roles to play in this whole agenda. At a strategic level its job is to act as a champion of better regulation right across Whitehall, and I think it has put in place a number of processes and systems in order to help drive that agenda. Then, secondly, it has a more pragmatic role in a sense, which is working with colleagues across Whitehall to reach practical solutions on how we go about implementing or determining particular policies to achieve the correct outcomes. I would very much describe their role as a journey. I think there is a lot of effort and a lot of processes which have been put in place but, quite clearly, there is more to do on that agenda. From the CBI's perspective, I think we would see it as important that there is an increasing focus on the flow of new regulation. I think we need to better communicate changes which have been made to date on deregulatory measures. I think finally we would welcome an increasing focus on some of the real impacts on business that we might draw down to a little bit more this morning.

  Mr Ehmann: If I might add something to Matthew's comments. Broadly speaking, I think we would share the same view. I think it is important to point out that it is far easier to deconstruct a process than it is of course to create one, particularly in an area as difficult as deregulation, and I think we should acknowledge the effort that has been put in there. That said, if one takes a specific initiative of the BRE like the simplification plans and the Administrative Burdens Measurement exercise, which I am sure we will come on to later, one does get the instinct that the whole process is rather more driven by outputs than outcomes, and what I mean by that is that the target does seem to be the 25% empirical reduction rather than the shift in perceptions that the IoD would argue is absolutely critical to the process, so if there was an accusation I would float out there I would say where there is more effort that needs to be done is a recognition of this slightly more holistic necessity, which is to make sure that business, in this case, recognises it is different. The only other thing I would add is that there is perhaps a lack of clarity about what the Better Regulation Executive and the agenda more broadly is expected to achieve beyond 2010. I think the process up until 2010 may or may not yield results, but there is a question about whether that just sits within a vacuum or whether there is a wider strategic goal for the Government.

  Mr Davenport: I would certainly endorse my two colleagues' comments and there are two things I would add. The first is that my feeling is that when the BRE was brought into BERR as an organisation, it certainly made things more efficient, it was less confrontational for a start, which was certainly an advantage, and the other thing is that as far as the legislation is concerned, I think the focus needs to be much more on the problems that are encountered at the smaller end of the market. The larger end of the market can handle changes in legislation. The average proportion is that the small business has six times more load on its administrative time when it has an alteration in assessment, so that is the only addition I would put forward to you.

  Ms Low: Again, I would broadly endorse what my colleagues have said. If we are looking at the BRE as having two functions, the first to reduce the stock of regulation and the second to tackle flow, on the first part of that I think there has been success and things like the Hampton Review have brought about a new approach to risk-based enforcement which has been useful, and there have been a number of other positions that the BRE have adopted to address issues around the stock. With regard to the flow, when we look at a publication that you will be familiar with I am sure that the British Chambers of Commerce publish, which is the Burdens Barometer, in which we have been looking at impact assessments since 1998, what we have seen, and also endorsed in the report that we published yesterday, is that actually in the first four years from 1998, about 130 impact assessments per annum were coming through and this has now increased to 300 per annum, and I think that basically points to the fact that the BRE has to heighten its influence across Whitehall to bring to bear greater pressure to reduce that and tackle that flow of new regulations coming into being.

  Q3  Chairman: In your note to us you suggested that it was a mistake for the BRE to withdraw from detailed scrutiny of impact assessments. Following on from that, what exactly do you think their role should be: policeman; think-tank; deliverer; teacher? Can it take on the role of deliverer of the kind of joined-up government that we would all like to see and, in your judgment, is it using its resources efficiently if it examines every impact assessment?

  Ms Low: I certainly think there is a strong case to be made for the BRE to adopt, as I have said, a much more robust stance with regard to its policing of departments across Whitehall through the impact assessment mechanism, and whilst we see the production of a top sheet as being fine in its way, it does not really address the fundamental issue. We have devoted an enormous amount of time to studying the analysis of impacts and for example, when looking at the disproportionate impact of regulation burden on small firms, you see that only 1% of impact assessments quantified in the last 2006-07 year quantified the additional costs of regulation for small firms in those impact assessments, and we believe on behalf of the network of chambers of commerce, 100,000 businesses, that whilst culture change is important—and I think the top sheet is a way of bringing about some culture change—fundamentally the measurement and analysis of impacts of the burdens on whatever is the recipient or whoever is having to carry out the regulation, namely business in our case, is absolutely vital to the process, and so in response I do not think that that is an inappropriate use of resources for BRE to carry out that role across Whitehall.

  Mr Fell: Just to pick apart the two elements of your question, as I said at the outset, I think the chief role of the BRE is to act both as champion and then pragmatic helper, if you like, with other government departments. In terms of scrutiny of impact assessments and how good and robust they are, I again think that is a journey where there has been progress. I think if you look at impact assessments today, they are better than they were, say, five years ago but, quite clearly, there is more to do. Where I think they are useful is to provide an indication of cost/benefit analysis, and for that to be helpful, quite clearly, there needs to be good quality scrutiny of those if they are to be robust and to be useful as a policy tool. In addition to that robustness, the other issue that is particularly important for impact assessments is their timeliness. I see a number of colleagues getting quite frustrated when impact assessments come out at the point of consultation, thinking particularly in the tax arena for example, HM Treasury, where it would be useful to have more dialogue before we reach formal consultation stage to say "are the figures and the assumptions that you have built into your impact assessments correct?"I think more emphasis on that informal dialogue before we get to the proper consultation stage, to understand the different factors that go into impact assessments, will be just as useful as the BRE taking on a greater scrutiny role.

  Q4  Gordon Banks: I suppose I should declare that I am a Member of Federation of Small Businesses before we start. I wonder how good the BRE at getting their objectives across to organisations and especially small companies which are not represented by people in your organisations, et cetera, because the majority of small businesses are not represented by anybody other than the people who are running the small businesses? Do we fail to get the message across to these small businesses?

  Mr Fell: Perhaps if I just carry on on that theme for a moment. I think the importance of using intermediaries is quite a good example. I see the Department for Business this morning has issued a notice that it is contacting 20,000 accountants and solicitors to set out the changes on the Companies Act that are coming into force. I think the greater use of intermediaries that small firms will typically turn to—their solicitors and accountants—for advice and guidance is perhaps the best way to reach that audience that you are talking about.

  Mr Davenport: I would say that as far as small businesses are concerned, the biggest problem we have is that the information does not get fed down, and whatever information does get fed down tends to be in, shall we say, "Whitehall speak" and the average business does not really understand it, so it gets filed in the bin fairly quickly and forgotten about. That is not what it is about. The whole thing is about informing people. If I can just give you one example. The Ministerial Challenge Panel did an enormous amount of work to promote the Local Better Regulation Office. The idea of that office was to produce a more even standard for councils throughout England and Wales. I have seen one document from the LBRO. I think if I can get the chief executive to sign it, it would be quite good because it would be worth quite a bit of money! I have not seen it anywhere delivered to any business at all. How on earth the LBRO can be expected to glean information to produce better performance if it does not inform the people that are its customers effectively I am not quite sure. The whole of the government system needs to get its communications act together a lot better than it does. One of the comments I would also like to make is about the HMRC. I am not quite sure whether the HMRC is included in the BRE reviews and, if it is not, I am quite intrigued to know as to why not; it is a department the same as any other.

  Mr Ehmann: If I might add a couple of extra points. I think all of the points my colleagues have made are absolutely right, but there are two examples I can give you of how the BRE is perhaps not getting the comms aspects of this agenda across as well as might be hoped. To echo the point about HMRC, and I would really emphasis that, we asked our members what was the last government agency or department they had physical interaction with or over the telephone, and for two-thirds of our members the most recent interaction was with HMRC. It seems therefore bizarre that that is the department that uses the least amount of leverage in this process. I would really echo that point. I think the other thing is if you look at some of the initiatives that have been announced, to pick just one, there is something which I think is now called a different name but it was the portal for simplification suggestions from business, the recognition levels in the NAO Report are incredibly low, and when we did some work on this in a report called Words or Deeds back last year, one of the proposals that we put forward was that purely on forms and administrative burdens, the Government might want to consider putting at the bottom: "If this irritated you, there is a place for you to go and make that representation", because at the moment there is a complete lack of join between the point of burden and reporting that burden to a government department or agency. To expect a business to think when they come across some kind of advertising, if they do, of this channel for communicating, "Oh yes, the burdens that bother me are ..." is frankly not going to happen.

  Ms Low: I would just like to say that I think the best way of communicating with business the benefit of what the BRE is achieving is by showing the proof of the pudding. We have measured in our Burdens Barometer a cumulative burden of cost on business of £66 billion this year; it was £10 billion when we first started the exercise in 2000. This year for the first time we actually saw some negative readings which showed that in three cases there were examples of regulations that had been the subject of regulatory reform orders. That amounted to £67 million-worth of reduction of savings, if you like, which admittedly is only one-tenth of 1% of the overall £66 billion figure, but that is important in that it starts to show impact, and we were happy to trumpet that fact. There are a number of issues that we have with legislation in this area because it is a very hard to actually redress the balance once something is in place. It is very, very difficult to turn the clock back. However, showing the proof in the pudding, showing to businesses what has happened by using hard figures is a very powerful way of communicating the benefit of the work being done within government.

  Q5  Chairman: Talking about the proof of the pudding, you have mentioned twice your Burdens Barometer; do you publish the methodology behind it? For example, is it measuring net burdens or simply new burdens? Does it take into account changes in a piece of legislation that are on the positive side of the equation or does it just add up all the negatives?

  Ms Low: It adds up the burden to business which comes from the impact assessment as recorded so we do not measure benefits in that way.

  Q6  Chairman: So it is not true to say that in net terms the Government has placed £66 billion-worth of new burdens on business this year?

  Ms Low: The main reason we do not measure benefits is that in hardly any cases are they actually quantified within the impact assessments.

  Q7  Chairman: Can I finish off this section by asking a very simple question: should the BRE concentrate on one major strategic vision or should it continue to pursue a number of goals based on what it is likely to get results on?

  Mr Davenport: I think from our point of view we are almost into a position of "if it isn't broke, don't fix it". Multi-visions can be confusing anyway. I think what it is doing at the moment is beginning to work. The problem we have is that it takes an inordinate amount of time for it to work and changing things dramatically now would be more confusing and would dissipate the energies that are already being directed in the areas that they are.

  Mr Ehmann: I think the initiatives in the areas of work of the BRE are broadly acceptable to the Institute of Directors. As I said earlier, I think there is a case for bringing those together under somewhat of a strategic aim, and I think the key component of that aim has to be about changing perceptions. If the BRE were a regulator, for the sake of argument, its role would be dictated by what you were hoping for it to achieve, so in the case of economic regulation it would be to create a market which operated effectively. I would say that the BRE's mandate should very much be to bring about a change in perceptions amongst the business community primarily but also amongst others to say that the regulatory environment in the last four years has improved, and tangibly.

  Q8  Chairman: Any counterviews?

  Mr Fell: I would underscore what I said . I think the BRE's primary function is to champion the Better Regulation agenda right across government. I think it has put in place a number of measures to do that and that journey is going in the right direction, and I think that the reform agenda would go at a slower pace without the role of the BRE doing its job as it is.

  Q9  Lorely Burt: My first question is directed mainly to the FSB. Clive, you said initially that there is a ratio of six to one in terms of the impact of regulation on small businesses. The Government has got this mantra of "think small first", so I am intrigued to know what you think of that. In your submission, you say that new legislation should specifically analyse the potential impact and costs to small businesses and adapt a proposed regulation accordingly. Could you elaborate a little bit on that and what specifically you think the Government should do to achieve that?

  Mr Davenport: That is a large question.

  Q10  Lorely Burt: It is, sorry.

  Mr Davenport: The problem for many years, probably 20 years, with government is that as small businesses have increased as a proportion of the total GDP of the nation, the perception in government of that proportion is not really taken account of. Government, by its very nature, tends to look at the large picture and at very large sweeping things to be able to create a result as fast as possible with a minimum amount of financial impact. The problem with small business is because of the disparate types of business that small businesses are, the Government cannot really get a handle on that situation, and that causes it a lot of heartache. They are aware of the situation but not quite sure, I do not think, how to handle it. Being engaged more with businesses directly would give them a big insight. I can remember the previous Director of the BRE, who was doing the Ministerial Challenge Panel, Mitchell Lehman(?), spent a week in Scotland and was absolutely mortified at the situation of the energies that had to be expended in small businesses. He came back and from the anecdotes screamed around the corridor for a week at the amount of work and effort that goes into a small business, and the amount of damage, effectively, that one small piece of legislation can create. I think that is a classic example of the way civil servants really ought to be involved more with small business and they would become more focused on what should happen to them.

  Q11  Lorely Burt: I would like to drag civil servants from behind their desks and send them to industry as part of their induction just to give them an idea of what is going on there.

  Mr Davenport: Indeed, that would not be a bad idea.

  Q12  Lorely Burt: There are moves afoot to do that. When we interviewed BERR, they were saying there was a senior civil servant induction process to do that but I think it has got to be a culture change right the way through really.

  Ms Low: I think it is a good idea of course for civil servants to spend time within businesses to understand the management issues that the burden of regulation imposes on a small business, the extra cost that it imposes, and all the other problems such as not being able to command economies of scale, etcetera, but I do think we have to be realistic about what sort of culture change a civil servant spending a week or so in a business is going to manage to achieve, because that particular gentleman has now moved on to a different department so all of that learning has effectively been lost. This is the problem. We facilitate via the chamber of commerce network lots of trips like this and they have always been valuable and they have been very good to show the host business that somebody cares, that somebody is listening, and that central government is awake and alert to the particular problems, but for us I would say that that is a limited benefit and I think that really there is no substitute for a much more robust and, as I set out, much more of a policing effect. If you look at the hard evidence, when we carried out our impact assessment report last year, which is the supporting report to the Burdens Barometer piece of work, it said that in 8% of the cases of impact assessments that were coming through they had quantified the additional costs of regulation for small firms and carried out a small firms impact test. The impact assessment report that we published yesterday recorded 1%, so it is actually going down, and that is a problem and that is something which needs addressing with much more hard-hitting measures I would suggest.

  Q13  Lorely Burt: Absolutely. Can I go on and talk mainly to the IoD about the perception of business on delivering results and how you feel that could be better improved. You say in your submission that 1% noted an improvement to the regulatory environment and 46% of your respondents felt that regulation had worsened over the past 12 months, and you go on to talk about investing more in communication with firms. Would you like to elaborate a bit more on that?

  Mr Ehmann: Yes I think delivery and communication are interlinked, so if you will excuse me I will touch briefly on delivery. If I contextualise the point that you have just made which is the 1% that recognised any change in the first year of the Administrative Burdens Reduction and the simplification plans, if you look at the two other countries—and we may come on to international comparisons—ahead of us in this process, the National Audit Office of Denmark remarked in their analysis of their process that from an examination conducted by the chamber of commerce in Denmark in December 2006 it happened that eight out of ten businesses were of the opinion that the administrative burden in 2006 had been largely the same as in 2004. The report goes on to give quite a mixed picture and a slightly negative one about what the process achieved. In this process, eight out of ten said it had not improved. Our analysis says that half of businesses were saying it has gotten worse, so I think the picture is more stark, and we must recognise that, otherwise we will end up with results similar to Denmark's, if not worse. I think the ways to fix that are very wide and the reason I touched on delivery as an important point is because, clearly, if delivery is not significant and is not targeted in the right areas that business would want to see it in, then communication by its very nature will never fix that problem. That would be propaganda of a sort so that would be very difficult to do. I think that more effort does need to be channelled into making sure, as I touched on earlier, that things like the Simplification Portal and much more of the work of the simplification plans and the agenda for reducing administrative burdens relates to genuine suggestions by businesses themselves. That would to some degree counter the problem that we face. I think the second point is about where there are areas of significant achievement making sure that that is communicated to the correct audiences. The point that I raised in our written submission was that whilst I do not expect, and certainly our members would not expect government to be able to communicate directly with every business in this country in an effective and bespoke way, there are business organisations like ourselves, and indeed many more out there, trade associations, and it would not be difficult to understand the demographics of their membership and to therefore create not perhaps completely bespoke packages of what had been delivered but something with a lot more resonance for their membership. I quoted in our written evidence that we have been given a document with about ten regulatory improvements, including the deregulation of beryllium injections. I am sure our members at some level are interested in that but I imagine less so professionally! I think the issue was it came with very little understanding of our overall membership, and more effort needs to go into that.

  Q14  Gordon Banks: I wanted to pick up on the point that you have just finished making. I come from a construction background and having run my own business for 19 years, there needs to be a much more focused approach to particular industrial sectors. In my business for instance, and the analogy I always use, I do not need to know how to dispose of fridges because of some new EU regulation but I need to know of the issues that are relevant to me in the construction sector, and that is the real challenge, and it probably goes back to what I was saying in the first part of the questions, yes, we can communicate through organisations like yourselves but how do we get this information through to the people who are not in organisations such as yourselves? In the government portal that we use—or some people use—do you not think it would be much better if there were industrial sectors within that portal so that there is a certain amount of regulation which is obviously relevant to everyone, health and safety stuff et cetera, but there is a lot of specific stuff, and would it not be better if there were sectors where the construction industry could go, where the motor retail industry could go, where the fridge disposer could go to look at particular regulations that are relevant to their individual businesses?

  Mr Fell: Jumping in slightly, I would say perhaps the portal is not the best place to do it but I absolutely endorse the sentiment about packaging up, if you like, deregulatory measures to say, "How should this make an impact for you? If I am in a given sector employing a certain amount of people then these are the things that should be making a difference to your lives and helping you out." If they communicated it in that way rather than a broad brush message that has some relevance to some people and not to others, I think that would be a much more effective way of getting across the messages and making sure that people actually take up the changes in a beneficial way.

  Mr Ehmann: I think that is absolutely correct. Whilst you are absolutely right in saying that there will be businesses out there that are not part of a membership organisation or do not have some kind of representative who you can channel communication through, if you look at some of the questions we asked back last year, apart from a general question about whether regulation is getting better or worse—we asked about three of the initiatives that the BRE seemed most proud about having achieved, and one which strikes me (it is quite wide ranging anyway) is the abolition of the requirement in certain circumstances for an annual general meeting. The recognition rate amongst our membership, of which 73% are SMEs, was only 43%. I agree there is a question about what you do about people who are not members of membership organisations, but there is still a problem with people who are members of membership organisations, so I would argue let us tackle that first because it is an easier one to win.

  Ms Low: Just a quick point to add about making the information more sectorally based, there is some best practice which came out of Hampton on things like the retail enforcement pilot and I think there could potentially be scope to develop that line of thinking where you have got the simplification of a process. In enforcement there is a communication job to be done in there as well and also cross-cutting across all local authority boundaries looking specifically at sectors.

  John Hemming: I will start with a declaration of interest. I have been in business on my own account for 24 years during which period I have in fact been a member of a chamber of commerce but I am not longer; I resigned a couple of years ago, but I am still, I believe, a member of the Federation of Small Business. That is I think I have sent off the cheque!

  Q15  Chairman: It is in the post.

  Mr Davenport: Let me just check that!

  Q16  John Hemming: I intend to be a member of the Federation of Small Businesses, let us put it that way. We have all encountered regulation generating organisations and you have that on one side and on the other side you have attempts going on to simplify regulation. One of the eternal problems of politics is measurement and how you measure what you are trying to achieve, so the question as to whether the chambers of commerce have another mechanism or whatever. We have the Standard Cost Model which focuses on the administrative burdens. Okay, it is an easy target but it does at least give you something definable. Shall we start with Matthew as he is nodding, what is your view in respect of the Standard Cost Model and whether it is worth looking beyond administrative cost or whether we should focus on administrative cost because although we have only hit one per cent so far it is a sort of deliverable?

  Mr Fell: I think the Standard Cost Model on simplification plans was the original game in town, which was tackling that administrative burden, and clearly that was an important step. I think when we all gave a broad endorsement to that approach, we did so knowing that the Standard Cost Model did come with its faults but it was perhaps as good a tool as there was of providing an indicative cost about the areas to tackle. If you pick a department that we are pretty familiar with, the Department for Business, Enterprise and Regulatory Reform, and you look at their simplification plans, then the big ticket items that it flags up suggests that they sit in employment, in company law, and in consumer law, and for us at least that would feel about right, so I think it is a useful tool for pointing in the right direction and providing indicative costs of the problems to tackle. That gets at the administrative burden and where I think increasingly the focus should shift is on that whole policy burden and the flow of new regulation as opposed to chipping away at the stock. I think there is quite an exciting proposal that came out of the Budget to look at the notion of regulatory budgets, which might be more effective in looking at some of those flow issues, and on the policy burden not just the administrative side.

  Q17  John Hemming: You mention the issue of employment law and cases like Ivan v Wand (?) obviously have a substantial impact. Is that something that you have thought of?

  Mr Fell: I think at the end of the day these are all tools that we use to help us make informed decisions and I do not think that we should ever get to a situation where, whatever measurement tool we use or approach to costing, it completely overrides making an informed decision, but it helps us make decisions and then it is for the elected Government of the day to decide how they go on a particular policy choice. I think if there are more tools out there that help us make informed decisions—

  Mr Ehmann: I think Matthew is broadly correct. I think there is a question about whether we would, looking at it again, have chosen this process today? I am slightly undecided on that particular issue and I think again not to want to use our other European colleagues but the Dutch Audit Office said their government selection of reduction measures should concentrate on the legislation that creates the greatest burden, that is not perhaps surprising, but they found that information from the baseline measurements can distort the actual burden, since the measurements are based on a series of unrealistic assumptions. Enterprises find those laws and rules that they do not understand to be the most burdensome. It really goes back to the key point; the process is not fundamentally flawed but what needs to happen is a closer calibration between the process and genuine business suggestions for how to improve it. If I can briefly say, we submitted, through that same portal again, about 35 suggestions last year and from an IoD perspective, certainly wholeheartedly, none of those were adopted. It touches on Lorely's earlier comment which is when we confronted Government with this—and these were suggestions on behalf of small and medium-sized businesses, which was the purpose of the portal—one answer that was given to us was that GlaxoSmithKline had good success with this process. I think that shows perhaps a misunderstanding of the small business aspect but also about how we actually elicit genuine suggestions from members in an interesting and innovative way.

  Ms Low: From the outset, we have expressed reservations about the Standard Cost Model, particularly about the methodology.

  Q18  John Hemming: What aspects of the methodology?

  Ms Low: Yes and the way that it calculates cost.

  Q19  John Hemming: In particular, what is the reservation about the way it calculates cost?

  Ms Low: The Standard Cost Model essentially takes three different companies as examples, takes a median, and assesses the cost of the regulation from the data from three firms and, if it is 20% either way, it will measure that. It is unlikely that just three businesses are going to exhibit the sort of costs that meet that criteria. For example, in the UK you have got ten different sectors of industry, six different business size bands, and that would create about 60 cells of data to start to analyse. If you get into that kind of methodology then you are creating a flawed methodology for the future. One of the problems, and we have set all this out in Deregulation or Déjà Vu which we have sent to the Committee, is there was a rush to endorse the Dutch model as the Standard Cost Model and then various other mechanisms that have been deployed, without properly looking at other systems or bringing to bear more rigour, as we have said, in the impact assessment process that we already had going in the UK, so I think that was a mistake and, as we have said in a number of our reports and documents, that is one of the reasons we have problems with that and about the quality of UK impact assessments across the board.

  Mr Davenport: I fully endorse what Sally just said. The fundamental thing about Hampton was that the Dutch model was the model. Dutch structures internally are not the same as British structures, and yet we now seem to almost be in a position where Hampton is the mantra that we must not touch, when I think that really we should be looking at the whole Hampton principle in detail and examining where we can improve it and where we can actually deliver to the end user a more efficient and more concise process so that the end user can understand it more easily and use it more effectively. There is no point in having loads and loads of legislation if it is so complex and unwieldy that the end user cannot understand what he is supposed to be doing, and that is counterproductive in itself, and you end up with the end user disengaging completely and that has its own dangers. I think that is one of the foci that should be concentrated on. The detail is much more important than the overarching scheme.

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