Draft Tax Credits (Income Thresholds and Determination of Rates) (Amendment) 2015; Prison and Young Offender Institution (Amendment) 2015; Social Social Security (Housing Costs Amendments) 2015; Feed-in Tariffs (Amendment) (No. 2) 2015 - Secondary Legislation Scrutiny Committee Contents

Ninth Report

Instruments Drawn to the Special Attention of the House

Draft Tax Credits (Income Thresholds and Determination of Rates) (Amendment) Regulations 2015

Date laid: 7 September 2015

Parliamentary procedure: affirmative

Summary: These Regulations propose that, from April 2016, the income threshold for Working Tax Credit (WTC) should be reduced to £3,850; and the income threshold for Child Tax Credit (CTC) to £12,125. They also propose that the income rise disregard should be reduced to £2,500; and that the taper rate should be increased to 48%.

In response to questions which we raised about the Explanatory Memorandum laid in September, we have received a letter, of 12 October 2015, from the Chancellor of the Exchequer enclosing an Impact Assessment: this sheds more light on the effects of the proposed changes than was provided by the Explanatory Memorandum. When it considers the draft Regulations, the House will wish to reach a view on the adequacy of the information about their impact with which we have been provided.

We draw these Regulations to the special attention of the House on the ground that they are politically important and give rise to issues of public policy likely to be of interest.

1.  HM Revenue and Customs (HMRC) laid these draft Regulations with an Explanatory Memorandum (EM) on 7 September 2015. The instrument proposes that, from April 2016, the income threshold for Working Tax Credit (WTC) should be reduced from £6,420 to £3,850; and that the income threshold for Child Tax Credit (CTC) should be reduced from £16,105 to £12,125. It also proposes that the income rise disregard should be reduced from £5,000 to £2,500; and that the taper rate should be increased from 41% to 48%. HMRC states that this means that, once a household's earnings reach the new income threshold of £3,850, its tax credit award will be gradually removed at a faster rate than before, namely, 48p for each pound of income above the threshold.

2.  In the EM as laid, HMRC offered little explanation of the policy background, save to state that the Regulations changed certain income thresholds, the income rise disregard and taper rate of tax credits that the Chancellor of the Exchequer announced in the Summer Budget on 8 July 2015 and were in the package of welfare reforms that were part of the Government's election manifesto. In announcing that Budget, the Chancellor said that "the whole working-age benefit system has to be put on a more sustainable footing. In 1980, working-age welfare accounted for 8% of all public spending. Today it is 13%". In referring to the changes proposed in these draft Regulations, he said: "We also need to focus tax credits and universal credit on those on lower incomes, if we are to keep the whole system affordable and support those most in need."[1] HMRC also stated in the EM that an impact assessment had not been prepared for the instrument.

3.  The proposed changes have attracted a good deal of interest. The Social Security Advisory Committee (SSAC) has published on its website a letter of 9 September 2015 to the Financial Secretary to the Treasury, which, in referring to its consideration of the Regulations, expressed disappointment at the lack of information about the effects of the changes.[2] On 14 September, Lord Dubs asked a question about what assessment the Government had made of the impact of the proposed reductions in tax credits, and sought confirmation that they would mean that "three million of the poorest families will be worse off."[3] In replying to the question, Lord Ashton said that, if the welfare changes in the Budget were considered together with increases in the income tax personal allowance and the introduction of the national living wage, "eight out of ten working households will be better off in 2017-18".[4]

4.  In our view, the EM laid in September by HMRC contained minimal information, given our general expectation that an EM should provide members of Parliament and the public with an adequate explanation of the effect of the instrument which it accompanies, and why it is necessary. Soon after the draft Regulations were laid, we requested additional information from HMRC, about why the Government had not published an impact assessment, and whether the Government had prepared some other assessment of the effect of the changes proposed.

5.  On 12 October, the Chancellor of the Exchequer wrote in response to our request, enclosing an Impact Assessment (IA) for the Regulations. We are publishing the correspondence as Appendix 1 to this report, and placing the IA on the Committee's website.[5] In his letter, Mr Osborne makes the point that, alongside the changes to tax credits, the Government are introducing the National Living Wage and increasing the personal tax allowance: "Taking tax and benefit changes into account, it means a renting family with two children where both parents work 35 hours a week on the minimum wage will see their income increase in cash terms by more than £5,500".

6.  The Chancellor's letter of 12 October 2015 and the enclosed Impact Assessment shed more light on the effects of the proposed changes than was provided by the Explanatory Memorandum laid on 7 September. When it considers the draft Regulations, the House will wish to reach a view on the adequacy of the information about their impact with which we have been provided.

Prison and Young Offender Institution (Amendment) Rules 2015 (SI 2015/1638)

Date laid: 3 September 2015

Parliamentary procedure: negative

Summary: The Prison Rules are being amended following the Supreme Court judgment in the case of Bourgass which held that arrangements that allowed Prison Governors within a prison to authorise segregation for periods longer than 72 hours were unlawful because Rule 45(2) of the Prison Rules required such decisions to be taken under the authority of the Secretary of State (in practice by officials from outside the prison). The instrument revises the Rule to allow the Governor to authorise segregation for repeated periods of up to 14 days subject to additional safeguards, for example, an external review must take place after 42 days for an adult.

This instrument is drawn to the special attention of the House on the ground that it gives rise to issues of public policy likely to be of interest to the House.

7.  This instrument was laid by the Ministry of Justice (MoJ) under section 47(1) of the Prison Act 1952 along with an Explanatory Memorandum (EM). It amends Prison Rules with immediate effect from 4 September. It responds to the findings of the Supreme Court, on 29 July 2015, in the case of Bourgass[6] on arrangements for segregating prisoners. The Howard League for Penal Reform has written to the Committee with objections to the instrument and their letter is published on our website.[7]


8.  The long-established Prison Rule 45(2) required segregation beyond 72 hours to be authorised by the Secretary of State. In practice, this authority has for some time been provided by the Prison Governor, subject to the advice of a Segregation Review Board. The National Offender Management Service ("NOMS") took the view that the Governor could act on behalf of the Secretary of State in granting this authority by virtue of the legal principle of Carltona, which allows a senior official within a department, where authorised to do so, to take decisions on behalf of the Secretary of State.

9.  Segregation is the removal of a prisoner from normal association with his or her peers. Under Rule 45 segregation can be authorised for two reasons: first, where prisoners are at risk from others in the prison and alternative accommodation, possibly in another prison, has yet to be found; and, secondly, where the prisoner presents a risk to others or to the order and control of an establishment. The MoJ states that segregation is not the same as solitary confinement which is never used in prisons in England and Wales. Prisoners located on the segregation wing are usually able to associate with other prisoners on that wing providing it is safe for them to do so. In addition, prisoners are visited daily by Healthcare, Segregation Unit staff and Chaplaincy and at regular intervals by the Independent Monitoring Board, the Governor and a doctor. Segregated prisoners also continue to have social and legal visits in line with prison visits policy.


10.  A judicial review was brought by Kamal Bourgass and Tanvir Hussain, high profile Category A prisoners serving life sentences for offences related to terrorism, who had been placed in segregation at their respective prisons following concerns about their involvement in serious assaults on other prisoners. They both remained in segregation for lengthy periods (10 months and 6 months respectively) during which they claimed they had not been given sufficient information to enable them to appeal. The Secretary of State was successful in the High Court and in the Court of Appeal. The argument that a Governor could not authorise segregation beyond 72 hours emerged in the Supreme Court judgment.

11.  The Supreme Court held that as a matter of statutory interpretation the words "the Secretary of State" in Rule 45 of the Prison Rules 1999 (and equivalent provisions in the Young Offender Institution Rules) could not have been intended to include the Governor or someone within the prison and must have meant an official located outside the prison establishment. The effect of the judgment was that from the date of the judgement Governors could not lawfully authorise removal from association (known as segregation) for more than 72 hours and the lawfulness of decisions taken prior to that date were called into question.

12.  In response the Secretary of State considered a range of options (described in the EM) and decided to amend the terms of the Rules to allow the Governor to authorise segregation for longer periods but, in parallel with this change, to introduce additional safeguards, including greater independent oversight of the process.

13.  Under the revised system introduced by this instrument:

·  from 4 September 2015 segregation for a period of more than 72 hours can be authorised by the Governor for a period of up to 14 days (authority for which may be renewed for subsequent periods of up to 14 days). Revised guidance, "Reviewing and Authorising Continuing Segregation & Temporary Confinement in Special Accommodation: Amendment to Policy set out in PSO 1700", was also issued; and

·  from 16 October 2015 the Governor must obtain leave in writing from the Secretary of State to authorise segregation for a period of more than 42 days and written leave must also be given at each subsequent 42 day interval. These reviews will be carried out by a Deputy Director of Custody ("DDC"), who is in charge of a group of prisons. At the six month point a further review will be carried out by the Director.

14.  The Ministry of Justice states that at the 42 day point the prisoner will have had his or her segregation authorised by the Segregation Review Board at least twice and there will be a body of evidence about the prisoner's behaviour and any impact that segregation may be having on him or her to inform the DDC's review. DDCs are senior officials in NOMS based outside the prison, usually in a regional office. DDCs can decide to review cases earlier in the course of their regular visits to prisons or where there are particular circumstances that might indicate an earlier review is beneficial. DDCs have been carrying out reviews on the nearly 800 current cases with the aim that by 16 October none will be outstanding. MoJ state that in August 2015 only 27 prisoners had been held in segregation for more than six months.

15.  Similar changes are made to Rule 49 of the Young Offender Institution Rules by regulation 3. MoJ states that the 42 day rule will apply to Young Adults (age 18-21 years old) in detention. Decisions in respect of Young Offenders (under 18s) in segregation will be made and reviewed in a similar manner but will be reviewed by the relevant DDC at the 21 day point and by the Director at three months (MoJ state that at present no young offender has been in segregation for that long). It is felt that a shorter time is more appropriate to his vulnerable age group. The NOMS policy document Reviewing and Authorising Continuing Segregation and Temporary Confinement in Special Accommodation sets out specific procedures for the segregation of Young Adults in section 3 and for the under 18s in section 4.


16.  We have received a submission from the Howard League for Penal Reform who were involved in bringing the judicial review. The letter is published in full on our website. It expresses concern that by changing the legislation to fit the process, rather than changing the process to fit the law, the Government is acting contrary to the spirit of the Supreme Court judgment. The Howard League cites a number of studies about the irreversible risks to the health and mental health of prisoners from extended segregation and note the number of prisoners who commit suicide when held in segregation. The Howard League is particularly concerned by the delay in the requirement for external review of a segregation decision from 72 hours to 42 days, suggesting that 14 days is the maximum acceptable.


17.  The Ministry of Justice states that no external consultation was carried out prior to the introduction of this new system because of the need to react quickly to the judgment. However, NOMS began wider consultation immediately following introduction of the new legislation and policy and plans a review of the impact and success of the amended procedures early next year. As part of this review, a consultation document was sent to a range of interested parties, including the Howard League. Recipients have been asked to submit comments by the end of October.

18.  The new policy will be reviewed on conclusion of the consultation in November and the Ministry of Justice intends to publish a consolidated policy document in the New Year.

Social Security (Housing Costs Amendments) Regulations 2015 (SI 2015/1647)

Date laid: 10 September 2015

Parliamentary procedure: negative

Summary: From the start of the next financial year these Regulations will increase the waiting period before full housing costs (including help with mortgage interest) are met from benefits. The waiting period will change to 39 weeks (from 13 weeks) for certain benefits such as Jobseekers' Allowance, or nine assessment periods in Universal Credit (from three assessment periods). Six years ago, when considering the Regulations which this instrument amends, we asked for clear and specific evidence to be provided when the 39 week waiting period was reinstated and the DWP has failed to produce an Explanatory Memorandum (EM) that does that. We publish some additional material provided by the DWP in response to our questions but the House may wish to enquire why, if the DWP has relevant information, they did not see fit to provide it in the EM to assist the House in its scrutiny. A number of issues, for example the effect on claimants in the more expensive areas of the country and the potential impact on charities and local authorities, have not been satisfactorily explained.

These Regulations are drawn to the special attention of the House on the ground that the explanatory material laid in support provides insufficient information to gain a clear understanding about the instrument's policy objective and intended implementation.

19.  These Regulations were laid by the Department for Work and Pensions (DWP) under provisions of several Acts including the Welfare Reform Acts 2007 and 2012. They are laid with an Explanatory Memorandum (EM) and a Keeling Schedule.

20.  From the start of the next financial year, these Regulations will increase the waiting period before full housing costs (including help with mortgage interest) are met from benefits. The waiting period will change from 13 to 39 weeks for certain benefits such as Jobseekers' Allowance, or nine assessment periods in Universal Credit (from three assessment periods). The maximum amount of the qualifying loan is £200,000 on the basis that, according to Nationwide Building Society figures, the average home in the UK costs £194,000.


21.  The DWP states that this legislation reverts to the position prior to the temporary change introduced by the Social Security (Housing Costs Special Arrangement) (Amendment and Modification) Regulations 2008 (S.I.2008/3195).[8] Those Regulations were put in place at the start of the economic downturn and were intended as a temporary measure.

22.  When those Regulations were considered by the Committee in 2009, we were extremely critical of the lack of evidence provided by DWP to support its proposals, to the extent that we asked the Minister to give oral evidence. Our 5th Report of Session 2008-09 said:

    "We have concluded that these Regulations are, for the most part, beneficial and likely to achieve their intended policy objective, but only after we initiated a wide range of supplementary enquiries and pieced together data from a range of sources. The Department could not provide us with certain basic cost/benefit figures when we asked for them, and we are concerned that they were not available when the policy was being formulated. Their estimates of likely cost and effectiveness, however, are very approximate and the Department should devote thought to refining these estimates and how they will use them to decide when it is appropriate to bring the extension of [Support for Mortgage Interest] to an end."

23.  We are disappointed that, in respect of the current Regulations, the EM again lacks adequate supporting evidence.


24.  The EM provides no clear statement of the policy objective of the Regulations. We think that it is likely that the policy objective is saving money but there is no indication in the EM of the sum likely to be saved. In supplementary material DWP told us rather elliptically:

    "There are no savings from returning the waiting period to the baseline level of 39 weeks. However if the waiting period was held at 13 weeks, it would come at a cost of approximately £65m a year."


25.  Furthermore, no impact assessment is provided to indicate the costs and benefits of the change in practice. We note that the EM states that "based on the housing costs in respect of mortgage interest for working age claimants of £165 monthly, a claimant who made no mortgage payments whilst serving a waiting period would accrue around £1000 in mortgage arrears over a six month period. This level of arrears is similar to the arrears position in around 150,000 cases in the wider mortgage market." (paragraph 7.2). But no explanation is given of why those figures have been chosen: why, for example, is £165 a month relevant? And why does the statement refer to six months arrears when the new 39 week waiting period is closer to nine months?

26.  Paragraph 7.2 of the EM also includes the statement: "The Government believes that the 39 week waiting period will not have an impact on repossessions because it expects mortgage lenders to continue to exercise forbearance in the knowledge that housing costs will become payable." This is a strong assertion but no supporting evidence is set out in the EM. We therefore requested supplementary evidence. In response to this, DWP provided a published statement from the Council of Mortgage Lenders:

    "The summer Budget announced that, from April 2016, the waiting period for new claimants of Support for Mortgage Interest (SMI) would revert to 39 weeks and that future SMI payments would eventually be paid as a loan. The first of these changes will adversely affect new claimants at the margin, but the overall impact on possessions over the 2015-16 forecast period should be negligible.

    Our current judgment continues to be that the vast majority of households will cope with gentle and protracted interest rate rises. This has led us to materially revise down our arrears and possessions numbers for 2015 and 2016."[9]

27.  We asked DWP about the basis for stating that there will be no impact on business or charities from this change. DWP replied:

    "There is no evidence to suggest that any significant proportion of the 12,000 repossessions [expected in 2015 on the basis of current figures] are benefit claimants/SMI recipients. There may be a very small number of SMI claimants who are repossessed but this is likely to be because their mortgage account was in a perilous position before they made a claim for benefit. We have not been made aware of any SMI claimants being repossessed by MPs, Welfare Rights organisations or operational colleagues in the last 7 years.

Some claimants will have mortgage payment protection insurance which will pay their mortgage during the waiting period while other claimants will make arrangements with their lenders for payment holidays during a waiting period.

Therefore, we do not consider that the impact of a 39 week waiting period on lenders and charities will be significantly different from that under a 13 week waiting period."


28.  For the most part, DWP has been able to provide additional material where requested but the Department's response to the question what is being done to address the inequalities arising from the effect of this change on claimants in different parts of the country seems to us to be wholly unsatisfactory.

29.  Paragraph 8.2 of the EM states that the average home in the UK now costs £194,000. That is quite close to the £200,000 maximum set on loans, but, reasonably, assumes that a mortgage will not be for the full value of the house. However, this instrument makes no allowance for regional variation. The average price of a three-bedroom house in Durham or Birmingham will differ radically from the average price of a similar house in Surrey or central London. Figures from the Office of National Statistics, provided by DWP, clearly illustrate this variation.

30.  In response to supplementary questions, DWP told us that data from the Council of Mortgage Lenders show that less than 3% of SMI claimants have outstanding loans of over £200,000. That is reassuring to a degree. However, the response continued: "Mortgages of more than £200,000 are concentrated in London and the South East, but the Government does not consider it fair that people have all the interest paid on a mortgage that is over 6 times larger than the median household income for the UK." This appears not to address the practicalities of those who are living in the South East and have a larger mortgage simply because of the difference in regional house prices. The House may wish to press the Minister further on what the effect of the changes on these people will be.


31.  We note that there has been no consultation on the issue since 2012. Given the significant changes in the economy and housing market since then, many of the comments made in 2012 will be out of date. The Department's assertions about the lack of impact on charities and claimants, particularly in the South East, would have been far more convincing had some more recent consultation taken place with charities, local authorities and representative groups.


32.  When the Committee considered the regulations that this instrument amends, we were very critical of the absence of supporting evidence, and in our report on those earlier regulations we asked for clear and specific evidence to be provided when the 39 week waiting period was reinstated. Regrettably, DWP has not produced an EM to meet that expectation.

33.  Once again, not only have we had to jigsaw together the evidence from material provided in response to our supplementary questions, but a number of issues (for example, the effect on claimants living in the more expensive areas of the country and the potential impact on charities and local authorities) remain inadequately explained. The House may wish to ask the Minister why the Explanatory Memorandum accompanying this instrument failed to fulfil its purpose by neglecting to provide an adequate account of the changes made by these new Regulations.

(See also the paragraph on the Universal Credit (Work Allowance) Amendment Regulations (SI 2015/1649) later in this Report)

Feed-in Tariffs (Amendment) (No. 2) Order 2015 (SI 2015/1659)

Date laid: 9 September 2015

Parliamentary procedure: negative

Summary: This Order removes pre-accreditation from the Feed-in Tariffs scheme, which, as described by the Department for Energy and Climate Change (DECC), is the Government's main policy measure to encourage the deployment of small-scale low-carbon electricity generation. DECC says that the change is being made to control costs and limit the impact on electricity bill-payers of surges in applications for pre-accreditation adding to deployment at current tariff rates.

DECC carried out consultation on this proposed change from 22 July to 19 August 2015, a period of four weeks. A significant number of respondents stated that the four-week period allowed for consultation, and the lack of an Impact Assessment to accompany the consultation document, adversely affected their ability to respond. DECC's dismissal of these criticisms gives the impression of a Department more concerned about its own needs than about those of interested parties.

We draw this instrument to the special attention of the House on the ground that there appear to be inadequacies in the consultation process which relates to the instrument.

34.  The Department for Energy and Climate Change (DECC) has laid this Order with an Explanatory Memorandum (EM). DECC explains that the Feed-in Tariffs scheme ("FIT scheme") is the Government's main policy measure to encourage the deployment of small-scale low-carbon electricity generation in Great Britain. It says that pre-accreditation (introduced under the FIT scheme as part of a 2011-12 review) gives generators a guaranteed tariff level in advance of commissioning their installation, provided a project is commissioned and full accreditation applied for within a specified period.

35.  The purpose of this Order is to remove pre-accreditation from the FIT scheme, in order, as DECC says, to control costs and limit the impact on electricity bill-payers of surges in applications for pre-accreditation adding to deployment at current tariff rates under the scheme, in particular those applications made in response to the tariff changes set out in the full FIT review. The Department states that the effect of this will be that new participants in the scheme will only receive the tariff rate as at the date they apply for full accreditation (i.e., after their installation is commissioned).

36.  By way of background, DECC says that both deployment and spending under the FIT scheme have outstripped expectations: original projections were for 750,000 installations by 2020, but by June 2015 over 700,000 installations had applied for accreditation. The FIT scheme has contributed to a projected overspend of around £1.5bn on the Levy Control Framework (LCF), which has a corresponding impact on electricity consumer bills. On 27 August the Government published a further consultation-the full FIT Review 2015 - which proposes more cost control measures-caps on entrants, reduced tariff levels and steeper degression of tariffs, to achieve better control of costs under the LCF and limit the resulting impact on consumer bills.


37.  In the EM, DECC says that it carried out consultation on removing pre-accreditation from 22 July to 19 August 2015 (four weeks).[10] In total it received 2,370 responses, of which some 1987 were template letters organised by campaigning groups, and 383 unique responses. It published a Government response to the consultation in September 2015.[11]

38.  DECC acknowledges that its proposals were opposed by the majority of respondents. In the EM, it says that the main theme of responses was that removing pre-accreditation would undermine confidence in renewable energy, leading to a significant number of projects not deploying in the short term, as well as harming wider investor confidence in the long term. The majority of respondents also stated that the consultation had understated the impact of the proposed change, and had failed sufficiently to reflect the effects across different sectors and technologies, as well as on small and medium-sized businesses. The community energy sector was the most commonly cited area where the proposed change would have a disproportionate impact.

39.  In the September 2015 response, DECC states that, while it recognises that removing pre-accreditation will introduce considerable uncertainty in the short term, it considers it necessary to safeguard spending under the scheme while it carries out the FIT Review (on which consultation was launched on 27 August). It also states that, subject to the outcome of the FIT Review, if generation tariffs for new applicants remain available under the FIT scheme, it will consider reintroducing pre-accreditation either for all groups or on a more limited basis. It comments that pre-accreditation would be an appropriate means of enabling deployment under an effectively cost-controlled scheme.

40.  We note that, in the EM, DECC acknowledges that a large number of responses criticised the length of the consultation process and the lack of a separate accompanying Impact Assessment, and stated that these factors had adversely affected their ability to respond in full to the consultation. DECC says that, while Cabinet Office guidance advises against holding consultations over the August holiday period, this consultation proposed only one change to an established policy; the urgency of implementing these proposals to protect against rising costs justified holding the consultation over August.

41.  As for the absence of an accompanying Impact Assessment, DECC states in the EM that it judged that the information provided in the consultation document, and in particular the statement of impact in paragraphs 1.16-1.21, was adequate. We note, however, that these paragraphs, entitled "Impact of measures proposed", included the following: "Owing to this uncertainty around the exact effect this change would have on the rates of return required by developers, DECC has not attempted to estimate the likely impact of this change on deployment and therefore on potential savings".


42.  DECC makes it clear in the EM that it considers it necessary to remove pre-accreditation from the FIT scheme at this point, in order to prevent a surge in applications on to the current tariff before any cost control measures be implemented. It is clear that the Department held this view at the start of the consultation process this summer, and that its intention has not been swayed by the large number of consultation responses that opposed the change.

43.  We accept that Departments must ultimately make their own decisions on policy changes. However, we are equally clear that, if Departments seek views on their proposals for change before they are implemented, they should carry out consultation in a manner which respects the needs of potential respondents to formulate their own views. A four-week consultation period which takes place substantively in the holiday period of August seems likely to fall short, and the shortcoming is only exacerbated by a dismissal of complaints about lack of time. By the same token, we see it as incumbent upon Departments to include in any consultation paper sufficient detail for respondents. DECC made little effort to offer an assessment of the impacts of the proposed change in its July document, and in this respect as well its statement that it judged the information adequate gives the impression of a Department more concerned about its own needs than about those of interested parties.

1   HC Deb, 8 July 2015, col 333. Back

2   See: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/459498/ssac-letter-to_david-gauke-re-tax-credits-and-work-allowance.pdf Back

3   The Institute for Fiscal Studies (IFS), in commenting on the Summer Budget, said that three million families would be £1,000 a year worse off as a result of tax credit reductions. See: http://www.ft.com/cms/s/0/87b00b52-264e-11e5-9c4e-a775d2b173ca.html#axzz3m055nxJz Back

4   HL Deb, 14 September 2015, col 1640. Back

5   See: http://www.parliament.uk/documents/lords-committees/Secondary-Legislation-Scrutiny-Committee/DraftTaxCreditsRegs2015-ImpactAssessment.pdf  Back

6   R (on the application of Bourgass and another) (Appellants) v Secretary of State for Justice (Respondent) [2015] UKSC 54. Back

7   See: http://www.parliament.uk/documents/lords-committees/Secondary-Legislation-Scrutiny-Committee/Submission_from_the_Howard_League_for_Penal_Reform.pdf  Back

8   As amended by the Social Security (Housing Costs Special Arrangement) (Amendment) Regulations 2009 (SI 2009/3257). Back

9   CML market commentary July 2015 Back

10   See: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/447314/FITs_pre-accreditation.pdf Back

11   See: https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/459286/Government_response_to_FIT_pre-accreditation_consultation.pdf Back

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