My Lords, with the leave of the House, I will now repeat a Statement made by my right honourable friend the Secretary of State for the Environment, Food and Rural Affairs in the other place. The Statement is as follows:
“Mr Speaker, with your permission, I would like to make a statement about the significant flooding caused by the heavy rain and severe gale force winds brought by storm Ciara.
First and foremost, I want to extend my condolences on behalf of the whole House to the family and friends of the individual who lost his life in Hampshire earlier today; our thoughts are with you.
I would also like to express my support and sympathy to all those whose homes and businesses have been flooded over the weekend. For each individual affected, flooding can have appalling consequences and I want to provide the assurance today that the Environment Agency, local government and the emergency services are working hard to keep people safe in all of the areas affected by this devastating storm.
Storm Ciara brought rainfall ranging between 40 and 80 millimetres in 24 hours across much of northern England. The highest levels were recorded in Cumbria with 179.8 millimetres of rain over the course of the day.
Particularly severe impacts have been felt in Yorkshire along the River Calder; in Lancashire along the River Ribble; in Greater Manchester along the River Irwell; and in Appleby on the River Eden. Regrettably, four of these communities—the Calder Valley, Whalley and Ribchester, the Rossendale Valley and Appleby—were flooded in 2015.
The current estimate is that over 500 properties have been flooded but this number is expected to increase as further information is collected. The latest number of properties confirmed to have flooded are: 40 in Cumbria; 100 in Lancashire; 150 in Greater Manchester; and 260 in Yorkshire. Defences in Carlisle have held.
There is local road disruption across the affected areas and a shipping container is stuck under a bridge in Elland Bridge.
One severe flood warning was issued over the weekend to communicate a ‘risk to life’ along the River Nidd at Pateley Bridge. This has now been removed. Flood defences were not overtopped and no properties were flooded.
Our coastal communities have also been affected in parts of the south, west and north-east of England, where high tides, large waves and coastal gales have occurred. The weather is expected to remain unsettled and 97 flood warnings are currently still in place.
While river levels in West Yorkshire and Lancashire are now receding, we must expect high river levels further downstream in South Yorkshire over the next few days. We urge people in at-risk areas to remain vigilant, not to take unnecessary risks and to sign up to receive Environment Agency flood alerts. Some coastal flooding is also probable tomorrow.
There is extensive work taking place in the impacted areas, including clearing debris that can block up river flow. Environment Agency teams have been deploying temporary flood barriers where necessary. I pay tribute to all the dedicated professionals who are working so hard on the emergency response to this situation, operating flood defences, supporting communities and keeping people safe. That includes the hardworking staff of the Environment Agency, along with local authority staff and, of course, the police and fire services. I also thank all the volunteers who are part of the local flood action groups helping the response effort.
Every effort is being made to keep people safe and I can confirm this afternoon that the Government are today activating the Bellwin scheme. This will provide significant financial support to the local authorities in the areas affected by storm Ciara, helping them fund the costs of recovery. I would encourage councils in the areas affected to consider applications to the Bellwin fund.
In a changing climate, we all want our country and our communities to be better protected from flooding and more resilient when severe weather occurs. In the areas hit by flooding at the weekend, there are at least 25,000 properties and businesses which have been protected by flood defences.
But we know that more needs to be delivered and we are determined to do this. So, since the incidents of Boxing Day 2015, we have been taking action on a range of schemes to strengthen defences and improve resilience. We are investing more than ever before in these defences in a £2.6 billion programme up to 2021 to manage flood and coastal erosion risk. This will enable better protection of over 300,000 properties.
In early 2016, we committed an unprecedented £35 million to improve flood protection for homes and businesses in Mytholmroyd, Hebden Bridge and across Calderdale. Construction in Mytholmroyd is progressing and we expect the defences there to be completed in the summer. We have built 28 new flood defences in Cumbria and Lancashire protecting 23,100 homes, and 59 new flood defences in Yorkshire protecting 13,200 homes. In the autumn I announced an extra £60 million to boost flood schemes in the north, including £19 million for the Calder Valley. Our manifesto commits us to a further £4 billion of new funding in the five years up to 2026.
In 2016 we introduced the Flood Re scheme to make insurance cover for flooding more affordable and more accessible. Following the flooding in November, I announced an independent review of the data on insurance cover to ensure that the scheme is working as effectively as possible. Since the incidents of 2015, we have strengthened and improved our system of flood warnings, and we have established a flood recovery framework to prepare for and guide flood recovery schemes.
This Government are determined to maintain and enhance our readiness to respond when extreme weather hits our country. Our swift activation of the Bellwin scheme today and our investment in the biggest ever programme of flood defence improvements illustrate that commitment. We stand ready to help communities recover from flooding. We are investing in the defences needed in the warmer, wetter, less predictable climate that scientists tell us we must expect in the years to come. I commend this statement to the House.”
My Lords, that concludes the Statement.
My Lords, I thank the Minister for repeating the Statement and I join with him in paying tribute to the emergency services and the Environment Agency for their prompt response to the threat of flooding in so many communities around the country. We echo the thoughts for the family of the man who died and send our condolences.
Yesterday, storm Ciara brought the most severe winds and heavy rain seen by many parts of the country for several years. It is heartbreaking to see local communities which endured so much in previous floods having to relive the experience. As the noble Lord said, a number of communities in the north of England were hit again, including Appleby, Bury and the Calder Valley, and there were further incidents in Scotland and Wales as well. There will be more frequent occurrences as we battle the extreme weather incidents that arise from the climate emergency. Once again, this is a huge wake-up call to the Government to act more quickly and decisively to stop global warming and the havoc caused by warmer, wetter winters and warmer, dryer summers, both of which increase the likelihood of intense rainfall events and flooding.
This is why we are critical of the Government’s net zero emissions target of 2050, when urgent action is needed now, not in the future. According to the Committee on Climate Change, there are 1.8 million homes at significant flood risk in England, and the number will rise unless we hit net zero in the next 10 years. Can the Minister confirm that the UK plan to be put before COP 26 in Glasgow will be more ambitious than the current plan and have more ambitious timelines? Does he accept that, as well as being more proactive on halting rising temperatures, the Government should also be more proactive on the practical mitigation of flood risk?
Sadly, action to prevent flooding has been hit by years of Conservative cuts to the Environment Agency, emergency services and local authorities, which all play a significant role in managing and responding to flood risk. The Minister will know that only last year the Environment Agency said it needed an extra £1 billion a year to provide an effective response to flood risk. Can he clarify whether that money has now been made available? Can he explain what extra funding is being provided—in addition to funding for specific flood barriers, which is very welcome—to emergency services on the ground? Can he explain why the money provided to South Yorkshire after the floods last November was made on the basis of match funding? Is there not a danger that that will penalise poorer communities even more? Will he clarify whether the same principle is going to be applied to any assistance provided after these storms?
This is about more than erecting higher barriers. As people said on the news last night, water will always find a way around those barriers. There is a great deal more that can be done through habitat restoration and better use of flood plains. Does the Minister accept that there is a need for a more comprehensive rethink of land use combined with a comprehensive plan for flooding that crosses communities and authorities? Where do environmental land management schemes fit with this? What are the Government’s plans for the co-ordination of schemes if they will be the basis of flood relief in future?
We welcomed the Flood Re scheme introduced in 2016 to provide flood insurance for those in high-risk areas, but there are still many businesses that cannot get insurance. This was again highlighted on the news last night. If we cannot help those businesses out, they will be forced to close and that will create ghost towns where there were once thriving communities. Can the Minister clarify what support is being given to small businesses to ensure that they continue to be economic and to keep their neighbourhoods alive? I hope when the Minister replies he will be able to assure this House that, for once, the Government have a comprehensive response to the rising tide of floods together with an urgent action plan to turn the tide of global warming that lies at the heart of the problem.
My Lords, I thank the Minister for repeating the Statement and draw the attention of the House to my interests as set out in the register, which include being a councillor in Kirklees in West Yorkshire.
Yesterday I spent several hours visiting flood-affected neighbourhoods in my town. Businesses, which are often located on the flatter land that is close to watercourses, found torrents of water rushing through their premises. Anxious residents were out in the appalling weather watching the levels rise, fearful that flooded cellars would lead to something even worse. In the face of the overwhelming nature of what happened, local emergency services were able to help only the very worst affected, and I thank them and all those in the local authorities, the Environment Agency and the energy supply companies who sought to keep people safe.
The towns affected by flooding yesterday were also the ones that were hit hard previously. Flooding does long-term damage to homes and businesses that can be very difficult to overcome. The immediate concern is the cost of the clear-up and the damage to homes and businesses. As the Minister said, the Government have activated the Bellwin scheme, which enables local authorities to claim some of the costs of the flooding. However, the scheme’s criteria state that a local authority has to fund the first 0.2% of its revenue budget before qualifying. No doubt that appeared generous when the scheme was drawn up before the 40% cuts to local government funding were imposed. Now with council budgets so squeezed, it is not approaching anywhere near generous. It puts enormous pressure on local authorities. On top of that, the same councils have had to fund clear-up costs from earlier flooding events, which, when they occur year-on-year, as they do, take a toll on council reserves set aside for such risks. Will the Government consider changes to the criteria to take these factors into account so that local authorities can have a more generous Bellwin scheme for areas that are affected time and again?
Obviously, insurance costs for residents and businesses often become prohibitive, especially for residents who already struggle to fund such costs. In my area, lower-value homes are often those most likely to flood; their owners or tenants are also the ones who struggle to pay for insurance costs. Can the Minister provide any comfort to such people and offer a more generous contribution towards these insurance costs?
One factor that constantly rises to the surface following flooding is that of drainage. One difficulty is that several different organisations are responsible for effective water drainage: the local authority, riparian owners, the water company and the Environment Agency. Can the Minister tell us whether the Government are thinking about how drainage systems can be better co-ordinated so that management and responsibility become more transparent?
Finally, there is the question of the consequences of ill-thought-through development. The Government are keen to accelerate planning application decisions and even, perhaps, to remove some of the detailed responsibilities of local planning authorities. This approach could well result in worsening the flood risk for a neighbourhood, with all the long-term consequences that follow. Will the Minister, through national planning guidance, consider putting a requirement on planning authorities to fully consider flooding risk, its mitigations and the responsibility of developers to fully fund such mitigations? Further mitigations could be made, for example, via the requirement of developers to restrict hard, impermeable surfaces and to set aside sufficient land for tree planting.
Of course, there is much more that can and should be done, such as, in my area, restoring the capacity of the peat uplands—something that in Yorkshire the water company is already beginning to do. I appreciate that I have asked a number of questions which may be outside the scope of the Minister’s portfolio. If that is the case, will he undertake to provide a written response?
My Lords, I am most grateful to the noble Baronesses for posing a number of questions. If any further details are needed on any of the questions, I will write to them.
I open by saying that, between 2010 and 2015, £1.7 billion was spent on flood defences. Between 2015 and 2021, that figure will be £2.6 billion. That is a record amount, and the manifesto commitment of my party is £4 billion for five years from 2020. I can say that this Government, and indeed the coalition Government before, invested very considerable sums, but it is clear that we will need to do ever more. I agree with the noble Baronesses that we will have to use a mix of conventional flood defences and natural capital; that is clearly the way to work on this, particularly in the uplands.
When we come to deliberations on the Agriculture Bill, one element of Clause 1—if I remember rightly; I cannot remember the number—refers to financial assistance and, indeed, the importance of tree planting. This is not a partisan matter—although we might vie for the number of trees we would plant—but a matter that we need to move forward. I say to the noble Baroness, Lady Jones of Whitchurch, that, on both mitigation and adaptation, we are fully seized that global warming must be addressed, not only in this country but across the world. We are the world leader on this and the G7 economy that has been decarbonising the fastest. We absolutely recognise the importance of this issue; that is why I am looking to great success for our country and its reputation at COP in Glasgow, with all of us working together.
I am also very conscious, having visited flood victims in Swaledale last year, of what it must be like not only to have been flooded, but to have been flooded again. Having seen what people endured, I am sure that all your Lordships will agree that it is impossible to ask people to withstand that. This is why I said what I said about the emergency services and our gratitude to them, and why I take seriously the accusations made about resources. I will take away the points that have been made about Bellwin. However, under this long-standing scheme for emergencies, we have said that we will reimburse 100% of the eligible costs incurred by local authorities, precisely to deal with this storm. This has been announced in what is probably record time because we understand the severity of the situation.
On Flood Re, it was very important that—as was said in the Statement—the Secretary of State announced a review of insurance cover at the end of last year following the November 2019 flooding. I am very conscious that, in many instances, Flood Re has been remarkably successful. It has meant that many property owners have been able to go to a number of insurance companies for their insurance cover; that has been successful. However, we recognise that, as some noble Lords have raised before, there are other areas that this review should look into; it will investigate these areas to help identify any implications for future flood events and see what more can be done. I should say that Defra officials have been in touch with the Association of British Insurers to ensure that insurers are doing all they can to support those affected.
I come to sustainable drainage. I understand that we will have to build more houses for our growing population. Sustainable drainage presupposes that we need to build them in a manner that allows the reuse of water—grey water. We need to work on all this; I have taken back what the noble Baronesses have said. I agree, for instance, particularly in relation to rainfall in the uplands, that we need to look at how we work with hill farmers, landowners and managers to ensure that we can retain water. This is, once again, part of what we will discuss in both the Environment Bill and the Agriculture Bill. Working with the deep grain of our contours, how do we plant trees in the right places?
I am most grateful to the noble Baronesses. I agree that we need to review Flood Re, and that is taking place. I accept that there is damage to communities. That is why I have outlined, and the Statement outlines, some of the schemes already in place following the investments over the last decade relating to those parts, particularly in the north, that have traditionally had very high rainfall and are now experiencing even more. All of that is why our energies in this new phase are about getting the balance right between hard defences and natural capital. I remember being told the rainfall in Cumbria at the time of the last floods. We would have had to have walls going through some towns there that were so high that it was almost impossible. It is unrealistic to have barriers of that sort going through towns. We need to look at how we slow the flow and at any means to assist people who, I am afraid, are going through great difficulty at the moment.
My Lords, I echo my noble friend’s comments about sympathy, condolence and thanks to the emergency services. Does he agree that many livestock will have been lost? I wonder what the position is and whether any support, as has been given to farmers in the past in that regard, will be thought of.
Properties built after 1 January 2009 are not covered, yet we are continuing to build in inappropriate places, so I hope that the review of Flood Re will have regard to that, along with the fact that businesses and farms are not covered and nor are flats in whole blocks.
My noble friend referred to the Bellwin scheme. Of course, what is exercising a lot of local councils is that many businesses have been given an exemption to business rates because times are hard. How will that shortfall be made up to local councils to ensure that they have the wherewithal to do what we are asking of them under the Bellwin scheme?
My noble friend will be aware of the Slowing the Flow at Pickering scheme because I never miss an opportunity to mention it. That was entirely a public partnership. I know the Government are very much minded to have private involvement in these partnerships. Could he update the House on progress in that regard?
My Lords, we will be assessing vis-à-vis farmers and the impact on them. The investment of £2.6 billion that I outlined is also designed to protect an additional 700,000 acres of agricultural land, but we will certainly be assessing what the situation is for farmers following Storm Ciara. On Flood Re, as I said, we are undertaking a review. I cannot pre-empt that but I have taken all the points that have been made.
On Bellwin, my right honourable friend the Secretary of State for MHCLG has announced that. I will pass back the points made about Bellwin but I think it indicates that we recognise that the parts of the country that have had these terrible floods and that impact need assistance, and our intention is to help them.
My Lords, I would like to take the Minister back to the question just asked by the noble Baroness, Lady McIntosh, about Flood Re. He is not being drawn on three critical areas that she mentioned: private rented property cover, commercial buildings cover and post-2009 developments. These are critical areas that have to be considered by the review. The Minister could at least give us an assurance that those three specific areas will be a subject of the review so that we can further consider them when the review is published.
My Lords, the whole point of a review is to review all matters arising from this. Obviously, I cannot pre-empt the result of the review, but it is helpful that the points that my noble friend and the noble Lord have raised are precisely the sorts of areas that we need to look into. As the noble Lord has mentioned to me, in parts of Cumbria there have been leaseholders for whom this has been a problem. I assure your Lordships that I will take back the points made about the review, and we will be reviewing insurance cover with those points in mind.
My Lords, I declare the interest that I live in Greetland in the Blackburn Valley, less than a mile from the confluence with the Calder Valley. I saw the floods yesterday; I saw the Black Brook rise and come over its banks, and I saw it flood into several fields in front of my house from my own front window. I saw the same thing on Boxing Day in 2015. I am well aware of how those floods seriously affected Sowerby Bridge, Mytholmroyd, Hebden Bridge and Todmorden, and that has happened again this time. A mere 38 years ago, when I happened to be mayor, I had to visit various people, while wearing my chain, who had been flooded, so it is nothing new that we have floods in the Calder Valley, particularly the upper Calder Valley.
I note what the Statement said about the serious amount of money spent on flood protection, particularly in Mytholmroyd and Hebden Bridge. The upper Calder Valley is of course a place where we have steep valleys and no flood plains. Therefore, however good the work that will be done in the valley bottom, work has also to be done in the uplands. It seems to me that these things should go hand in hand, so we have to look very seriously at the uplands because the work that was done in the upper Calder Valley is seriously stressed now. I hope that is taken in.
Living in Calderdale now, we are at the latter part of the local plan preparation process. A revised draft has been produced, consultations are taking place and an inspector has been appointed. Can the Minister assure me that an inspector looking at a local plan will look at the issue of houses being built on a flood plain? Some 600 houses are proposed in the Blackburn Valley. Will that be looked at in the next few weeks?
My Lords, the noble Lord is of course right that all sorts of areas have been flooded over the centuries. I was only just discussing that happening in York, parts of which have flooded for centuries. Our purpose with the investment we are undertaking is to do everything we can to protect houses and businesses; that is why it is unprecedented. But we understand and accept that we are going through unprecedented times. The noble Lord is also right about steep valleys. I often think about this in terms of the upper reaches of, say, the Severn. We need to think about how we use natural capital. What are the ways in which we can slow the flow in those steep valleys, given that, as he said, very often there are no flood plains but there are traditional areas, which were used when we had those floods? My understanding about development on flood plains has always been that the Environment Agency has to be consulted about these matters as well. If the noble Lord would like to give me more detail on either the application or proposal, I would be very happy to ensure that the agency is consulted again.
My Lords, during the general election I recall seeing the Prime Minister on television, visiting a village that had been largely flooded; I think it was in Yorkshire. He promised £5,000 per household for each house that was flooded. I assume that has been honoured, but I heard a lady on the radio this morning from Hereford, a strong Conservative seat—the other seat was a marginal, by the way—who had applied for the same grant and been refused. Can the Minister explain this inconsistency?
My understanding is that the property flood resilience recovery fund was part of the package following November’s flooding. The grant allows eligible local authorities, with 25 or more properties flooded in this timeframe of flooding—as in South Yorkshire and the north Midlands—to run a local property flood resilience scheme. Each eligible property under it would be able to receive £5,000 to fund changes that would help it become more resilient to any future flooding. To my knowledge, a number of insurance companies will also assist with that resilience. Having been flooded, one thing to do is to move obvious things such as the electric points. Where are they and can they be further up, particularly in areas that traditionally flood? That is why the pub in York, for instance, has its bar on the first floor.
Does the Minister not agree that a good place to start would be to have a simple, blanket moratorium on constructing houses and other sorts of buildings in areas proven to flood? No ifs or buts; it should just be no.
My Lords, I think that would mean most of London could never have been constructed. I do not mean to be facetious by saying that, but the truth is that many parts of our towns would be so deemed now. That is why we have the Thames Barrier and the hard flood defences that we do, and the Environment Agency is absolutely key to this. While I do not have the statistics in front of me, I think that very few planning applications that would be in a flood plain are permitted, precisely because of the point that my noble friend has alluded to.
Can the Minister—
I have not finished yet. I say to my noble friend that the last thing we want to do, obviously, is to build houses which then get flooded. There needs to be an assurance that newly built houses will not then be flooded, with all the misery caused to their residents.
Can the Minister reassure the House that in preparation for events of this kind, which are likely to recur, enough is being done to involve the non-statutory bodies—the Red Cross and a range of other relevant bodies—in planning to meet the contingencies that may arise? Thanks to the Meteorological Office, we had lots of warning of what was to happen this weekend. Across the country, how far were planning arrangements put in place involving those non-statutory bodies, to work out exactly how everybody could make the best possible contribution?
I put one other point to the Minister. Is this whole episode not a stark reminder of the crucial importance of what will happen in Glasgow later this year? Are we really convinced that we have a streamlined approach across government, as a whole, to prepare for Glasgow and ensure that all relevant departments are playing into the plan? Are we absolutely clear what our priorities will be in that conference?
My Lords, the answer regarding the voluntary spirit is yes. That is an absolutely key part of resilience, and of how communities have got through many of the floods. When I went to Swaledale last year, the local community certainly came together with the Red Cross and all the local civic action. The communities in North Yorkshire were obviously working with the local authorities and the agencies, but what struck me most was how those communities worked together. They helped each other. There was not a resident who had been flooded who did not have two cooked meals a day. That is where we see that working of civic society: the volunteers with the agencies, backed up by support from local authorities and the emergency services.
Having the COP in our country gives us a great responsibility. We need to lead on that, and that is what the Government will do. People will obviously make their point but I think that during the COP in Glasgow we will see this country as a whole, and this Government, saying that this is the most serious enterprise and that it has to be addressed by all nations.
My Lords, the Minister talked about natural capital. Will he give an undertaking that the Environment Bill will look at catchment areas in the round? They were raised in the Water Act 2014, but dealing with the entire catchment area system is very complicated. I declare an interest as owning land in the upland areas. We have planted tress under higher-level stewardship, but it seems a disjointed event. Farmers are asked to plant trees, whereas, lower down, impermeable paving has been put in.
Those of us who know people who have been flooded know that it is not a short-term issue and that there is a massive cost to the health service. A recent report looking at the cost in mental health services from the previous flood talked about tens, if not hundreds, of millions of pounds being needed for those services over a long period. Is the Minister prepared to talk to those dealing with the National Health Service to make sure that the mental health budget is adequate to meet those needs?
Again, my experience is of how extraordinarily resilient communities are, but, very often, they will not admit that they are under great pressure. I went to see a number of farmers in Yorkshire last year. There was a facade of coping, but I was very struck by the powerful sense of devastation felt at losing livestock and all that went with it. I understand that and will pass it back.
On catchments, in both the Agriculture Bill and the Environment Bill the whole concept will be for the farmer to have an ELM, which we will bring forward, but some of the great advances have been seen where there are much wider clusters and you are thinking about how you manage that wider catchment area. A very good example is Slowing the Flow at Pickering, but there are other ways of getting ownership that goes much wider than a number of landowners or farmers, which gives you an advantage. The schemes will be trialled and co-designed with ranges of farmers and landowners so that we get that advantage of working with the countryside and with natural capital.
My Lords, perhaps I may take the Minister back to the response that he gave to the noble Lord, Lord Inglewood. The kind of building that goes on in towns and cities—this is particularly true in London—can exacerbate the risk of flooding. I give as an example the frequent removal of front gardens in densely populated urban areas and the substitution of hardstanding, which is usually to accommodate cars. When there is inundation, the effect is often not on the houseowner who has done that but on others. I am old enough to remember a serious example in London about 40 years ago when a very hot summer was followed by extreme rain, and the impact of water running off Hampstead Heath was that many houses at the bottom of that incline were flooded. As we know, that sort of thing is more likely to happen as extreme weather events become more common. Does the Minister think that it is time for planners to take a more active part in preventing that kind of low-level intervention by individual houseowners who exacerbate the risk of flooding?
My Lords, that is a very important point; we should all be playing our part. I would like to say to people who want to concrete-over or tarmac their front garden, “Think about it. It might even be your house that is inundated.”. It is important that we look much more at this. I shall pass it back to MHCLG, because I know that it has been considered in your Lordships’ House. Each of us can find ways of reducing run-off and having permeable surfaces. If we need to have hardstanding, how about using gravel or choosing other ways in which we might reduce flooding which might affect either our own house or, perhaps more worryingly, those of our neighbours’?
My Lords, my experience of flooding over the weekend was confined, I fear, to what for me were the unfortunate events at Murrayfield. My noble friend pointed out that the incidence of flooding is often greater in houses in less affluent parts of the community. Such households find it very difficult to meet the expense, not least because the cost of insurance is inevitably increased. Is there some way in which we can recognise that, so as to ensure that the burden of the consequences of flooding of the kind that we have been talking about is not felt disproportionately by a particular section of the community?
The noble Lord makes a very good point, and it is precisely why my predecessor, my noble friend Lord De Mauley, and others worked hard on Flood Re. The introduction of Flood Re has seen four out of five households with a previous flood claim get price reductions of more than 50% on their insurance. So we know that Flood Re has been a benefit, but, as a number of your Lordships have said, it is something that we need to review and come back on.