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]
BACKGROUND
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.
THE RESPONSE TO JUDICIAL REVIEW
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.
THE HOWARD LEAGUE
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.
CONTINUING CONSULTATION
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.
A TEMPORARY MEASURE
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.
POLICY OBJECTIVE?
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."
IMPACT?
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."
REGIONAL VARIATION
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.
NO CONSULTATION
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.
CONCLUSION
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.
CONSULTATION
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".
CONCLUSION
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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