Considered in Grand Committee
My Lords, the House may be aware that in October 2020 the Government consulted on the proposed one-year extension of the warm home discount scheme. The changes proposed were broadly welcomed and it is the regulations implementing those changes that we are debating.
The Government are committed to alleviating fuel poverty. In the sustainable warmth strategy, published in February, the Government restated our commitment to our statutory target to upgrade as many fuel-poor homes as is reasonably practicable to an energy efficiency rating of at least band C by the end of 2030. The best long-term solution is to improve the energy efficiency of a home, bringing down the cost of heating it, but this takes time, and some, especially those that are harder to treat, may be left behind. As well as reaching millions of people each year, energy bill rebates are simple to deliver and consumer-friendly. The warm home discount is therefore a key policy in our policy mix to help alleviate fuel poverty.
Since 2011, the warm home discount has helped more than 2 million low-income and vulnerable households each year by reducing their energy bills at the time of year when it is most needed. Under the current scheme, around 1 million low-income pensioners in receipt of pension credit guarantee credit receive the £140 warm home discount as an automatic rebate on their energy bills and more than 1.2 million low-income and vulnerable households receive the rebate following an application to their participating energy supplier. Building on the success of the scheme, the energy White Paper committed to extending the scheme to at least 2025-26, expanding the overall spending envelope to £475 million per year from 2022, and consulting on reforms to improve the fuel poverty targeting rate. We intend to consult on the future scheme later this year.
Reforming the scheme has long lead-in times, however, and this winter we want to prioritise the safe and timely delivery of rebates to ensure that those in need continue to receive this vital support, particularly given the continuing impacts of Covid-19. It is therefore important that minimal changes are made to the scheme for next winter. This will mean that the scheme will be worth £354 million and that eligible pensioners on pension credit guarantee credit, as well as eligible vulnerable households supported through the broader group, can continue to receive a £140 reduction on their energy bills.
We will also not be amending the current energy supplier participation thresholds, as any change now, with such limited time for implementation, could cause significant, and potentially damaging, administrative and financial challenges for smaller energy suppliers. We intend to review this for the future reform. We are, however, making some improvements to the industry initiatives part of the scheme. This includes lifting the restriction on providing financial assistance under industry initiatives to those eligible for a rebate, which will create greater flexibility and help more people during the Covid-19 pandemic. We will keep the current overall cap of £6 million for the energy debt write-off mechanism, but we will also introduce a new individual cap of £2,000, enabling support to reach a greater number of households in need.
We will also be making changes so that proposed industry initiatives and specified activities will ensure—so far as reasonably practicable—that advice on the benefits of smart meters is provided to households benefiting from the industry initiative or specified activity. During the Covid-19 pandemic, smart meters have been invaluable for energy consumers, allowing prepayment customers to top up remotely from home, while also enabling suppliers to offer timely support to vulnerable consumers. We are also introducing greater consumer protections for boiler and central heating system installations and repairs carried out under the scheme.
Finally, we are proposing to make some further operational changes this year. This includes introducing a requirement for the Gas and Electricity Markets Authority to inform the Secretary of State if an electricity supplier which becomes a supplier of last resort notifies the authority of its intention to meet all or part of a failed supplier’s non-core spending obligation. This additionally includes making changes to clarify the full extent of a smaller supplier’s scheme obligations when it passes the relevant threshold and becomes newly subject to the non-core spending obligation.
In conclusion, the regulations extend the warm home discount until March 2022, which will help more than 2.2 million households next winter. These regulations will provide vital support for low-income and vulnerable customers to keep warm, in advance of consulting on wider scheme reform from 2022. I commend these regulations to the Committee.
My Lords, I am delighted to speak in support of the regulations before us and thank my noble friend for setting them out so clearly. I have a number of technical questions and, as I have not been able to give advance notice, if my noble friend cannot reply in full, I would very much welcome a written response, if that is in order.
I particularly welcome the Government’s commitment to ending fuel poverty and declare my interest as president of National Energy Action. I pay tribute to NEA, which works across England, Wales and Northern Ireland to ensure that everyone in the UK can afford to live in a warm, safe home. NEA both promotes the warm home discount rebate scheme to its clients, ensuring that those who are most in need can access it, and delivers broader support as part of the industry initiative portion of the warm home discount. My noble friend has accurately set out why this scheme is so important, and I echo that NEA strongly supports passing these regulations exactly as they are set out before us.
I will take this opportunity to look at some of the detail beyond the welcome single-year extension. NEA hopes that the regulations will take effect as soon as possible—the scheme effectively came into force on 1 April 2021; I think my noble friend will confirm this—and I echo its concern that the new regulations are urgently required to give immediate clarity to vulnerable energy consumers and industry participants on the shape of this scheme year.
I also welcome the commitments made in the energy White Paper, which has pledged to extend and expand the warm home discount scheme, after the one-year extension, from April 2022 to the end of March 2026 with an expanded scheme envelope. I hope that this debate enables us to look at the opportunities that these future developments will provide, and I take this opportunity to seek early clarity on the longer-term scheme.
It is particularly welcome that, while the White Paper does not set out too much detail, it makes a number of commitments that are to be noted and welcomed. These are a significant increase in the scheme envelope to £475 million a year from the current £350 million a year, and an increase in the rebate from £140 to £150. I also welcome consulting on reforms to improve fuel poverty targeting; for example, using government data to provide automatic rebates to most recipients.
There are some concerns expressed by NEA about the detail, which I hope can be resolved at the earliest opportunity, certainly before the end of this one-year extension and forthcoming consultation. The only clarity over the future of the industry initiative portion of the scheme was a commitment from the Minister in the corresponding debate to today when these regulations were raised in the Commons:
“The reform consultations later this year will include industry initiatives.”—[Official Report, Commons, 27/4/21; col. 315.]
Industry initiatives are particularly important to deliver significant value for the most vulnerable households. It is argued that they must be retained for the current level of energy advice, income advice and fuel vouchers to be preserved. Therefore, I hope that, as part of this debate, my noble friend is able to confirm and agree that the industry initiative scheme is of significant value and that, as far as the Government are concerned, this vital element will continue or be further expanded.
I want to raise on behalf of National Energy Action its concern about the intention to improve fuel poverty targeting. In the impact assessment for the recent consultation on the one-year extension of the scheme before us today, BEIS set out the fuel poverty hit rate for the current core group and the broader group based on the England-only fuel poverty “low income high costs” definition, which has been recently adjusted. While it is important that the poorest fuel-poor households can access future warm home discount rebates, this analysis implies the possibility of withdrawing support from the current core group and the broader group recipients. If that is the case, it could prove detrimental to households that currently receive the rebate, in particular current core group pensioner recipients or low-income-household recipients who require support with their energy bills via the broader group but who do not fall within the new fuel poverty metric for England: those with income less than 60% of the median living in poverty with an EPC of D, E, F or G.
Taking rebates away from the core group would remove support from the poorest pensioners, which I am sure is not the Government’s intention. Whether captured within the England-only fuel poverty metric or not, poorer recipients within the broader group could also face significant health risks when living in cold homes. The current discount doubtless helps mitigate such risks. I therefore request on behalf of NEA that the Minister share with us how these potential risks will be mitigated and how the department expects to do so.
While it is important that we value the contribution that the warm home discount scheme makes in supporting the Government’s wider fuel poverty commitments, the NEA specifically does not support one-off energy rebates counting towards progress to meet statutory energy-efficient fuel poverty targets. The current approach considers whether a household receives the warm home discount and, if so, treats the rebate as an energy-saving measure. This means that the energy-efficient fuel poverty target can be reached in part through giving rebates to households. As rebates do not necessarily deliver the same lasting benefits as energy-efficiency improvements, NEA believes it important that the warm home discount scheme does not potentially mask a lack of progress in increasing levels of domestic energy efficiency in fuel-poor homes.
While we accept and welcome the safe passage of a one-year extension, which will be secured through the regulations before us today, these issues should be addressed to ensure the future of the scheme. I welcome the regulations. I congratulate the Government on their ambitions, and hope that my concerns will be heard.
My Lords, I thank the Minister for her introduction to the regulations. It is always a pleasure to follow the noble Baroness, Lady McIntosh of Pickering, who raised a number of very important questions. If the Minister is unable to answer them immediately, I hope that any answers in writing will be copied to the Committee, in particular in relation to the rebate being covered as an energy-saving measure, which is clearly a counterproductive approach.
I wonder if the Minister could tell us a little, first, about the way in which this statutory instrument has been dealt with. My understanding is that these measures have come into force already; I think they did so on 31 March. It is obviously slightly concerning that we are debating issues which are already in operation. Secondly, in her response can she explain to me, in a way that I did not quite gather from the Explanatory Memorandum, what happens where the supplier of last resort does not take on the obligations? I understand that part of the purpose of these regulations is to try to encourage that, but what happens in those circumstances?
As noble Lords will know, the warm homes discount was introduced in 2011, during the coalition Government, to help tackle fuel poverty by placing obligations on energy suppliers. But in the 10 years since then, significant costs have been placed on bills because the cost of power sector decarbonisation has been funded pretty much entirely through them. This is obviously a highly regressive way of addressing the problems of climate change—an issue that is, after all, critical to us all and to which the wealthiest, in fact, contribute the most in emissions. The fact that those on low incomes are having to pay a disproportionate share of that burden seems the wrong starting point.
Not only that, but the impact assessment states that the cost of the warm homes discount is met by energy suppliers. Of course, that is not really correct: it is met by energy consumers, because those costs are passed on by the suppliers to the consumers. This means that it is, again, an extremely regressive—and in my view inappropriate—way of paying to tackle fuel poverty if it burdens costs in a disproportionate way on others who may find them difficult to pay. We have to look again at the whole way in which we share fairly the burden of decarbonisation and how we support those in fuel poverty out of it.
The most sustainable way of addressing fuel poverty—the noble Baroness, Lady McIntosh, touched on this—is to ensure that everybody lives in the most energy-efficient buildings. We are otherwise literally letting our money go up in smoke, which is why it is particularly unfortunate if the rebate is treated as an energy-saving measure. Again, the impact assessment gives an indication of the increased emissions as a result of these measures.
Can the Minister give us in her response, or else put it in writing, a breakdown of the EPC rating of all the homes where households are in receipt of the warm homes discount? She reminded us that the Government have committed to improving the homes of those in fuel poverty to EPC band C by 2030, while the Explanatory Memorandum reminds us that the Energy White Paper committed to all homes reaching band C by 2035. That is an incredibly unambitious target. The Liberal Democrats have set out a target that we should reach that point by 2025, but we should note also that even the unambitious target set by the Government is caveated by the words
“where practical, cost-effective and affordable”.
At some point, the Government will have to recognise that there is no point setting the highly ambitious targets that they have—a 68% reduction in emissions of greenhouse gases on 1990 levels by 2030, or the 78% reduction by 2035, or achieving net zero by 2050— if they will not match those targets with ambitious actions. The Minister knows that the one cannot be achieved without the other. She also knows that these targets of 68%, 78% and net zero are absolute targets and commitments; they are not caveated in the way that the Energy White Paper caveated the energy efficiency ambition.
I ask the Minister in her reply to confirm specifically that those targets are not subject to those sorts of caveats but absolute targets, and to recognise that if we are to have any hope of meeting them, our actions have to be much more ambitious. That has got to start with the energy efficiency of fuel-poor homes. We have to make much more rapid progress on that. All the time we fail to do that, we—the consumers—are having to pay out costs to support those in fuel poverty who continue to burn excess amounts of fuel in homes that are not properly insulated.
We have to recognise that the world has 79 months at the current rate, at the current burn level, before we have used up the carbon budget to keep us within the 1.5 degrees aim of the Paris agreement. We do not have the luxury of time. Much will rely on future technologies, but on the things that we know how to do we must act much more swiftly and ambitiously. As I say, our actions must be as ambitious as our targets.
Having said that, obviously we support the alleviation of fuel poverty and, in the absence of a more progressive scheme, welcome the renewal of the warm home discount and the increases in rebates. However, I urge the Minister and the Government to really get on to the issue of the energy efficiency of our buildings. We simply cannot proceed on the current timetable.
I thank the Minister for a clear explanation of the regulations before the Committee. From these Benches we are happy to approve the instrument, as it extends the warm home discount for another year. As it has been a successful scheme, what is there that we could not welcome in the extension for at least a further year, with a government commitment to continuing the scheme until 2026, albeit that new arrangements, with details and provisions as yet unknown, are envisaged to come into place from that point?
The scheme, now in its 11th year, will continue to provide a guaranteed £140 for to help those in fuel poverty and in vulnerable circumstances with their fuel bills. Before I challenge any assumptions or possible intentions of the Government in shaping the future scheme, let us recognise that these regulations maintain existing benefits with minor improvements in some respects. They maintain the overriding approach agreed by participants in the consultation: to allow as many eligible consumers as possible to receive support within the funding envelope. That this funding envelope has been increased to £354 million—the noble Baroness, Lady McIntosh, has a higher figure—in line with the rises in inflation is another important benefit. The regulations maintain the current £6 billion total debt write-off cap provision, while introducing a £2,000 cap for individual debt write-off—although how far that is used to write off historic bad debt from previous versions of the scheme with unfortunate outcomes is one for specific case-by-case analysis.
Nevertheless, I have some questions around this individual cap. How many individual cases of bad debt have been eliminated and from what total? Was there evidence of disparity in higher bands of debt across any analysis of banding debts with the number of individual cases? It would be interesting to understand whether the element of previous and new bad debts was being eliminated, with the stress for many vulnerable customers recognised and dealt with realistically. Further recognition can be given to the improvements in these regulations, removing restrictions on energy suppliers that prevented them providing additional financial assistance through industry initiatives to domestic consumers eligible in the core and broader groups—with rebates, advice and specified activities, including benefits for smart meters and consumer protection requirements for boiler installations to be provided under the TrustMark scheme.
It is also encouraging that the regulations include provisions such that when a voluntary or compulsory smaller electricity supplier grows to pass the relevant supplier threshold and becomes a larger energy supplier its core group rebates, undelivered previously, are utilised consistently with the fully obligated suppliers and that all funds for rebates are used to help those in need. However, some benefits and improvements, unfortunately, still need consideration and further development.
For example, when a supplier fails and its licence is revoked, the scheme’s obligations on that licence also fall, meaning that there is no obligation on whoever steps in as a supplier of last resort—or SoLR. If I understand the regulations correctly, if they had included provision that whoever this might be could deduct such a technical overspend from future scheme years, they could incentivise any supplier of last resort to take on the spending obligations of failed suppliers voluntarily. The provision would bring greater consistency with that regarding suppliers whose growth is allowed for, as I have mentioned. The scheme would be further improved. Can the Minister say whether I have this correct and see whether it could be addressed in future years?
It was also unfortunate that a consultation proved negative towards the proposal that supplier participation thresholds should be changed. While respecting the view that, given the pandemic and the disruptions it has caused throughout 2020, the main elements of the scheme should remain consistent in this one-year extension, it causes competitive issues and distortions. Some smaller energy suppliers can offer lower tariffs as they do not have to take part in a scheme. There are also consumer issues; a consumer may switch to a smaller supplier on price and then lose the benefit that he or she could be entitled to and receive with a larger supplier. Does the Minister have any figures or evidence on this latent cost?
The consultation also adjudges as unimplementable the proposal to require failing suppliers to provide data on unpaid rebates and industry initiative spending to TrustMark, to integrate it with its framework operating requirements. This can be extremely frustrating for participating consumers who miss out through no fault of their own. While we understand the practicality of the measures and the direction of travel for future regulations, will the Minister take the issue back to the department and can further consideration be given for future developments?
Many operability improvements also included in the measure could well be mentioned. All these measures will come with compliance costs and administrative burdens, which impacted businesses can recover under the scheme through charges to domestic consumers. The impact on the public sector is also discussed as very small—around £2 million for scheme year 11, in a total estimated cost of £10 million. However, the impact assessment fails to examine the added cost that will be passed on to consumers by energy suppliers. Can the Minister provide any details on the measure’s effect on consumer pricing? What is the status quo cost of the discount scheme on pricing and what may be the added cost specific to this extension?
I would like the Minister to address some other serious issues. The Energy White Paper of 2020 sets out the commitment to make and keep energy bills affordable, and to ensure that households in fuel poverty are not left behind in upgrading energy efficiency ratings on their homes, with the long-term reductions in energy costs this would bring.
One feature of the regulations is that they categorise one-off energy rebates to many vulnerable households as improvements in energy efficiency and progress towards reaching statutory energy efficiency targets. However, as has been stated by other contributors to this debate, rebates are not necessarily delivering lasting benefits in the same way as would be provided by energy efficiency improvements. The sustainable warmth part of the warm home scheme can mask a lack of progress on increasing levels of domestic energy efficiency in fuel-poor homes. The future design of the scheme must correct this interpretation. It is regretted that the green homes grant was such a dismal failure and had to be scrapped merely six months after its launch.
How will the Government align the warm home discount scheme with their legal commitment to net zero? What plans do they have to address the urgent problem of below EPC standard band C homes, especially those of the fuel poor with generally less available income? What is the Government’s view of Scotland’s wider interpretation of the 10% indicator in assessing fuel poverty? What are their plans and what thoughts do they have on reassessing and redesigning the scheme?
The Minister said in her introductory remarks that 1.2 million households received the £140 rebate. How many do the Government expect to receive the rebate in the next year? What will success look like to the Government in addressing the route to eliminating fuel poverty by 2035? What measures will the Government put in place to ensure that net zero is delivered fairly to those living in fuel poverty? When will the promised consultation start and when will the Government lay out their proposals?
Already there are concerns when the Government talk of refining the scheme towards better targeting of the fuel poor when the budget was already constrained from providing better financial assistance to more households that already miss out on their entitlements. This inevitably means that there will be some losers and that some households will receive less help than they currently do. Can the Minister confirm that industry initiatives will remain a key part of the current and future schemes? Will the department look at how the budget could be expanded for this element that seeks to help consumers understand and utilise their entitlements? It would provide a welcome boost of confidence to the industry to develop these initiatives.
There is much here for further consideration in my approval of the continuation of the warm home discount scheme.
My Lords, I thank all noble Lords for their valuable contributions to this debate, particularly coming from people whom, I know, have long been interested in this subject and have a greater degree of knowledge than often happens in these short debates.
The points made show the importance of extending the warm home discount scheme for a further year. The financial pressures that Covid-19 has imposed on households across the country has been challenging, particularly for low-income and vulnerable households. Extending the warm home discount will provide much-needed support for households in or at risk of fuel poverty, particularly during the pandemic. I am therefore pleased that there is agreement across this Committee that low-income and vulnerable households should continue to receive the valuable support provided by the warm home discount at the time when they need it most.
Over the 10 years of the discount scheme, more than £3 billion in direct assistance has been provided to low-income and vulnerable households. These regulations will enable the continuation of this support for another winter. This means that more than 1 million of the poorest pensioners and a further 1.2 million households in or at risk of fuel poverty will continue to receive £140 off their energy bills.
The regulations also allow for the continuation of a wide range of industry initiatives, including debt write-off, financial assistance and energy efficiency measures. These initiatives will be enhanced by the changes I have outlined, ensuring that we can better support households in need.
As outlined in the energy White Paper, we are committed to extending the scheme beyond this extension, from 2022 until at least 2025-26, expanding the spending envelope to £475 million to enable us to reach a further 750,000 households. We are also consulting on reform of the scheme to target fuel poverty better. This may be where the difference in numbers came from—the scheme has expanded from next year. We intend to consult later this year on the future scheme beyond 2022.
I pay tribute to the long-standing commitment of my noble friend Lady McIntosh of Pickering to this whole area of alleviating fuel poverty. I am very grateful for her support. She asked for confirmation of the industry initiatives—they are of significant value—and whether they will be continued or expanded under the reformed scheme. We recognise the value of industry initiatives, which is why we have expanded their potential use over time. We will consult on reforms later this year; that will include proposals on industry initiatives.
In response to my noble friend’s question about the future for vulnerable customers in relation to the new fuel poverty metric, we intend to reform the scheme to target those most likely to be in fuel poverty while continuing to protect the most vulnerable current recipients. Our proposals, which we are still finalising, will include options to mitigate the impact on households that may be disadvantaged by those reforms. My noble friend also asked about the rebate contributing to the Government’s fuel poverty and energy efficiency targets. We are increasing energy efficiency support for fuel-poor homes through the future expansion of the energy company obligation, as well as through recently introduced funding through local authority delivery.
We recognise that energy efficiency is the best long-term method of tackling fuel poverty, which is why in the past year we have increased government investment to make homes more energy efficient and committed to extending and expanding the energy company obligation. We should also recognise, however, that reducing bills through the warm home discount will continue to be a crucial tool in reducing fuel poverty until all homes reach the required energy efficiency standard. I know that this point was of particular concern to the noble Lord, Lord Oates. In response to his question on the timing of the regulations, they have not come into force; the rebates will be paid only from autumn this year, as is always the case. We have said that, if and when these regulations come into force, any industry initiatives that have already been funded from 1 April 2021 and are subsequently approved will count towards suppliers’ obligations.
On the noble Lord’s question on the supplier of last resort process, the Office of Gas and Electricity Markets already has in place a process that ensures that customers have continuity of energy supply when an energy supplier fails. The competitive process is run by Ofgem and allows for the orderly transfer of the failing energy supplier’s customers to a different energy supplier. Warm home discount obligations are placed on the electricity supply licence and, when a supplier fails, it does not transfer to the new supplier. However, the warm home discount is taken into consideration when Ofgem appoints a supplier of last resort. In previous scheme years, suppliers of last resort who were themselves warm home discount participants have chosen voluntarily to honour the obligations to pay rebates of the failing energy supplier. This information requirement is intended to facilitate the potential to permit any notifying suppliers of last resort to deduct extra non-core overspend from their non-core spending obligation in future scheme years, which in turn would incentivise suppliers of last resort to take on the non-core spending obligations of failed suppliers voluntarily.
The noble Lord also asked about the funding of the scheme. Suppliers reducing their customers’ bills directly is a more effective way of tackling fuel poverty than increasing incomes because consumers are more likely to use the money to pay their energy bills. The same amount of money reduces energy bills by a greater proportion than it increases income. We also believe that it is more likely to result in households using more energy to keep warm in winter and reduces the risk of them rationing how much they heat their homes or self-disconnecting entirely.
In response to the noble Lord’s question on the EPC ratings of homes that have received the warm home discount, I am afraid that we do not have the data he requires. He also spoke in general terms about the Government’s ambitions on increasing the efficiency of homes and their heating. On this point, I should say that the heat and building strategy will be published imminently, setting out how we intend to meet our commitments and setting us on a path to decarbonising homes and buildings by 2050. When I say “imminently”, I know it is disappointing that we have not got it out already, but it is due to be published soon.
I suggest that I write to the noble Lord, Lord Grantchester, on the details of writing off bad debt as I do not have that data in my briefing pack or to hand. In response to his question on the supplier of last resort process, the obligation is tied to the supplier’s licence but, thus far, the new suppliers have voluntarily taken on these obligations.
In response to the noble Lord’s question on TrustMark, we are introducing new requirements for the installation and repair of boilers and central heating under industry initiatives. They are to be delivered by TrustMark-registered installers and lodged in TrustMark’s data warehouse. This will provide greater consumer protection for households. The cost for a company to register under TrustMark is minimal. TrustMark also has a fee for installers to lodge measures in their data warehouse. As with other government schemes, the fee is £30, which covers the costs associated with providing technical monitoring and quality assurance. Requiring TrustMark registration will ensure that boilers and central heating systems installed under the scheme are delivered to a high standard, providing households with security and a longer-term solution. The introduction of these standards is particularly beneficial for those who are particularly vulnerable to cold, such as individuals with a health condition.
On the noble Lord’s question about consumer costs, the expansion from 2022 is expected to add £5 to the average annual dual fuel bill, taking the total to £19 per annum.
The noble Lord asked about the definition of fuel poverty in Scotland. Fuel poverty is devolved and it is up to Scottish Ministers to set their definition of fuel poverty and targets. We believe that our definition is best suited to measuring the problem and progress against it in England. In the next scheme year, we expect around 2.2 million rebates to be provided.
The noble Lord also asked about the contribution of measures to eliminating fuel poverty by 2035. Our target is to improve as many fuel-poor homes as is reasonably practical to an energy efficiency rating of Band C by 2030. I can also confirm that we will publish our consultation on the future of the scheme soon. We will consult on the future of industry initiatives as part of this but, as I have already said, we value industry initiatives.
I think I missed out the green homes grant and local authority delivery. Last summer, the Chancellor announced an investment of up to £3 billion in decarbonising buildings, including investments towards the £9.2 billion of funding set out in our manifesto. We have made excellent progress across much of this investment, with substantial sums being invested in social housing, schools and hospitals as well as in homes through the green homes grant voucher scheme, particularly in partnership with local authorities and supporting local green jobs. I think the noble Lord, Lord Oates, asked about this.
I think that that completes the debate. I commend the regulations to the Committee.