Scotland: Devolution
Lord Greaves Excerpts(10 years ago)
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Lord Greaves (LD)
My Lords, I am sure the whole House regrets that the noble Lord, Lord Barnett, cannot be here today to reply to all the comments about his formula. We all hope he is keeping well. I remind the House of my current interests in English local government. I wish to associate myself fully with the remarks of my noble friend Lord Tyler. I found myself cheering on the noble Lord, Lord Prescott, for his advocacy for devolution in the north of England.
To the surprise of many, certainly in this part of the kingdom, the Scottish referendum showed the intense feelings that people had about the dominance—I will try to use not very emotional words—of London and south-east England in the economy of this country, in investment, the financial sector, political power, government, media and culture. Watching all this on television, it came across to me that the degree of dominance is even greater if you just take England, because Scotland already has a substantial amount of political and financial power based in Edinburgh. This dominance is clearly linked to the distribution of wealth, incomes and influence; it is what people used to call the class system. Nowadays we are supposed to talk about social inequalities and not use the word class. However, it is not just social inequalities; the linked and closely related geographical inequalities are part and parcel of it. People are beginning to understand this much better now.
In the later stages of the referendum, the Deputy Prime Minister led calls for devolution, decentralisation, even a degree of federalism, in England as well as in other parts of the kingdom. To our surprise and horror, at the same time, we suddenly had calls at 7 am. I agree entirely with my noble friend Lord Steel about the nonsense of making announcements at this time but it is all to do with 24-hour rolling news. Top politicians nowadays think they have to dominate the day’s news agenda and hope to get through to the next day when something else will have taken over as the latest media fad. However, we had the attempt to resolve the West Lothian question by the introduction of English votes for English laws or, to use its appropriate acronym, EVEL.
Therefore, we are presented with a choice: that is, devolution to England and EVEL, however it may be carried out, or devolution within England to the regions—the towns, cities and localities of England. To pick up a point made by my noble friend Lord Thomas of Gresford, when the Prime Minister and similar people talk about England, it is not entirely clear whether they are talking about England or England and Wales. In terms of legislation, it is nonsense just to talk about England. Perhaps, instead of EVEL, we should talk about “EWVEWL” or something like that.
You only have to look at a typical Bill, especially a longer one, that comes to your Lordships’ House to see that towards the end there is a clause entitled “Extent”. Most noble Lords probably do not notice it. It states which clauses will apply to the different areas when the Bill passes into legislation. It is always extraordinarily complicated. When we were in opposition and I was responsible for overseeing the Marine and Coastal Access Bill from the Liberal Democrat Benches, I had the help of my noble and learned friend Lord Wallace of Tankerness to deal with the Scottish clauses. That was all built into the Bill and extremely complex. A lot of a typical Bill applies to England and Wales. Sometimes it applies to the Welsh Office directly and sometimes it applies to permissive powers to the Welsh Assembly and Welsh Ministers. Some of it applies to England, Scotland and Wales; to England, Northern Ireland and Wales; or to the whole of the UK. It is always complicated. If there is a serious attempt to deal with English votes for English laws, the whole way in which legislation is dealt with will have to be reorganised substantially. I suspect that often we could end up with three or four Bills instead of one.
When we were writing the constitution for the new party on the merger of the Liberals and the Social Democrats, my noble friend Lord Steel once accused me of being a north of England nationalist. I am not a nationalist; I am a north of England home ruler. I want as much local decision-making in the north of England as we can get. The problem is that throughout England, including the north of England, there is absolutely no consensus about the direction in which we want to go. My noble friend Lord Steel reminded us that it took nearly 10 years for the Scottish convention to get to the point where the Scottish Parliament was set up. At the beginning, the parties taking part all had a general consensus of the general direction in which they wanted to go; namely, home rule of some sort for Scotland.
There is no consensus in the north of England. We talk about city regions, which are a blind alley in many places because huge areas of the north of England are not in city regions. Some people talk about local authorities having more powers, which is a good thing in the short term, and some talk about regional bodies for the north-west, the north-east or for Yorkshire. I would like to see one for the whole of the north of England. Bodies such as One North, which was set up by some of the big cities to look at the transport links, lead us in that direction. However, there is no consensus. Before we can start talking about what we want, we must have debate and discussion in the north of England and, I suspect, in other regions of England to get some consensus of where we are going and what we want before we can stand up and say, “Home rule for the north of England”, which is what I should like to campaign on.
Transparency of Lobbying, Non-Party Campaigning and Trade Union Administration Bill
Lord Greaves Excerpts(10 years, 11 months ago)
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The Earl of Sandwich (CB)
My Lords, I first congratulate the noble and learned Lord, Lord Hardie, on the amendment, and my noble and right reverend friend Lord Harries for the work of his outstanding commission; I do not think that anyone has seen such a piece of work from the charity.
Having not spoken at Second Reading, I will beg for just a couple of minutes to put one point to the Minister. These are the most critical of the amendments. They convey the fundamental problem, which is that while the Bill and its predecessor are trying to regulate electioneering, they are actually hitting a whole range of legitimate charitable activities. The Government may not even guess at the damage that will be caused by this, all the way up to the review—which is of course welcome.
I have spent nearly 40 years working with aid organisations, personally assisting in the development of advocacy. It is a vital part of their work, bringing issues of poverty reduction to the attention of the public during an election campaign. Mr Brake told MPs that charities would not be caught by controlled expenditure. I am not sure that the Government yet appreciate that with national, European and local elections, and possibly referendums, all at different times, the Bill will or could hurt charities throughout the five-year period, not just leading up to the election—although we are going to discuss that period.
As the noble and learned Lord, Lord Hardie, demonstrated, there are grey areas everywhere in the Bill, even if we accept the Government’s undertakings in the Commons on definition. I have much sympathy with the Liberal Amendment 160, which is coming up and attempts to exclude charities altogether; however, it may already be too late for that, as they are already regulated under PPERA and the Charities Act. The amendment should attract the Minister, since it makes the point that if the campaign is not specifically related to a manifesto or proposed legislation, it should not be counted at all. It will be difficult enough making the calculation, but at least the Minister should see the point of the amendment. It is much narrower than subsequent amendments and should be easier for him to accept.
On smaller charities, there is a myth that Clauses 26 and 27 would not have an impact on them. As we know from coalitions, there is a close relationship between the larger charities, such as Oxfam and Christian Aid, and the many smaller ones which they themselves have sponsored. However, these may now be more independent and in some cases have grown much larger. So the smaller, specialist agencies are often concerned with single issues such as appropriate technology, fair trade, anti-slavery or other aspects of human rights in Burma, Tibet or Sudan.
Some of the issues are highly political. The noble Lord, Lord Walton, mentioned all-party groups; there are many active all-party groups on specific subjects. These might well be brought to the attention of campaigning politicians. At the same time, the size of these charities, while in some cases bringing them over the proposed threshold—I welcome the Minister’s assurances about the threshold—is not sufficient to justify the added expense and work involved in what I call selective accountability and monitoring in relation to the Bill.
The point about counting volunteers has already been made. It is often the smaller charities that depend on volunteers, especially in times of emergencies. We have also heard about coalitions. In spite of what the Minister said, I feel that they could also be caught by the Bill quite unnecessarily—as the noble and right reverend Lord, Lord Harries, pointed out. I therefore urge the Minister to consider accepting the amendment on Report.
Lord Greaves (LD)
My Lords, I think that this is the first time I have spoken in Committee, so I remind the House of my various interests with campaigning groups and charities set out in the register of interests, and also declare my lifelong activity as an election agent, which, I have no doubt, will continue.
I, too, thank the noble and right reverend Lord, Lord Harries of Pentregarth, and his commission for the outstanding body of work they carried out in a limited time and for the reports they have produced. This is only to the good as we look at the Bill in detail. I also thank the Government for the large amount of activity which has taken place. For example, my noble friend Lord Wallace of Saltaire has met something like 40 representatives of separate organisations to discuss their concerns about the Bill, and we had a letter this weekend from my noble and learned friend Lord Wallace of Tankerness making it absolutely clear that the Government are in listening mode. I hope that noble Lords will not get too tied up in whether this is consultation or not. The fact is that we are scrutinising legislation and that the Government are listening to that scrutiny. We do not always get that in Committee in the House of Lords, from different Governments, and we should make it very clear that it is welcome.
Much discussion is still taking place within coalition circles, within the Government and between the Government and other organisations, not least the noble and right reverend Lord’s commission. That discussion must continue and we must continue to do what I believe the Government, or at least substantial parts of the Government, are now doing, which is to seek a consensus on the Bill that will achieve the objectives behind it and will not have the damaging, chilling effects that are feared by so much of civil society.
We have two main slates of amendments here which come through the different groups. One slate of amendments has come from the commission of the noble and right reverend Lord, Lord Harries, and we have another which my noble friend Lord Tyler has been working on with ferocious energy over the past few weeks. Together they add up, if not to a perfect answer, at least to a very satisfactory means of scrutinising the Bill, by putting forward a number of positive suggestions. I understand that the commission has said that it would like us to take its slate as a package. In practice, as the noble Baroness said, if we come up with something successful at the end of this process, we will end up with a series of compromises, as we always do, but the Bill will not be any the worse for that. There are various other amendments in this group, including three of mine that I will speak to briefly in a minute.
It is absolutely right that the commission chaired by the noble and right reverend Lord, Lord Harries, looked at all this from the point of view of campaigning groups and charities and of civil society. That is the purpose for which the commission was set up. But I hope that it will be recognised that that made the consultation that the commission carried out, and is still carrying out, incredibly valuable as it is, one-sided in one respect—that is, that people involved in fighting the elections, candidates and political parties, were not part of the consultation. When we scrutinise this legislation, we must find the right balance between protecting the interests not just of candidates but of the democratic process itself on the one hand, and preventing damage to civil society on the other.
The dangers that this legislation rightly sets out to prevent and challenge are, first, that at national level we do not see our national politics taken over by the super-PAC-type organisations that we see in the United States, and by what has been described as “big bucks from big boys”—usually boys, but perhaps sometimes girls as well. In other words, we should not allow money to dominate. That money is inevitably from large corporate interests, most if not all of them on the right. We should not allow them to take over politics in this country as has happened to a worrying degree across the Atlantic. Furthermore, we should not allow people to buy particular constituencies simply by throwing a large amount of money at them—far more than the candidates themselves are allowed to spend under the regulations. Those are issues that we will come to later, but that is the basic aim of Part 2, as I understand it. It is very important that we balance that against all the concerns and the proposals put forward to try to address those concerns.
I have three amendments. My Amendment 159C is similar to an amendment in the name of the noble and right reverend Lord, Lord Harries: Amendment 159B. It would exempt from controlled expenditure rules a range of activities related to legislation before Parliament —before devolved Parliaments and Assemblies—and proposals being actively put forward by local government, government agencies and so on. In other words, the normal campaigning and lobbying activities of charities and campaigning organisations ought not to be prevented during the period in which the expenditure is controlled.
Amendment 159D is another probing amendment, more probing than the previous one. It would exempt from controlled expenditure rules any campaigning that was not specifically related to the functions of the bodies being elected during the regulated period. There are obviously major holes in that amendment, and concerns with it, but there is a question as to how far the expenditure controlled by third-party organisations should relate specifically to the functions of the body that is being elected during the election period, and how far it is just general political activity, even if it is totally unrelated to the functions of the Scottish Parliament or whatever it might be.
Amendment 160A would exclude from controlled-expenditure arrangements,
“expenditure”,
that,
“is minor, insignificant, inconsequential or incidental”,
or any similar words that the Minister would like to consider. The question is to what extent there will be in practice a de minimis provision within the Bill and to what extent there will be a requirement to look at whether to some extent, even if it is a very small extent, it might be intended to affect electoral support, and how far it is absolute. It is a similar question to the questions put forward by the noble and learned Lord, Lord Hardie, but on a more de minimis basis.
Lord Greaves
I have listened with great interest to the noble Baroness, but it seems that all she is doing is repeating her Second Reading speech. What we have heard about so far, and what we have down for Committee, is a whole series of amendments probing particular parts of the Bill and putting forward very constructive and, in many cases, sensible proposals to improve it. Why is the noble Baroness still making a Second Reading speech, and why has the Labour Party not put down a single constructive amendment for discussion in Committee?
Baroness Hayter of Kentish Town
We have a clause stand part debate and the point is to argue that this increase in scope does not belong in the Bill. That is the purpose of this, and the clause stand part debate is in our name. It is absolutely because we do not accept the enormous expansion that this clause brings in. We had expected, at this stage, because of the pause, that the Government would give an indication, even if not through amendments, of their response to the dissatisfaction at Second Reading. Our surprise is that we meet today, five weeks later, and there is not a single indication that the worries raised either by the two reports from the noble and right reverend Lord, Lord Harries, or at Second Reading, find themselves in any way reflected, given that no government amendments have been tabled for today.
Lord Wallace of Tankerness
My Lords, I thank all noble Lords who have taken part in this important debate on the core definition. In particular, I thank the noble and learned Lord, Lord Hardie, for moving his amendment, which initiated the debate. The noble Baroness, Lady Hayter, indicated correctly that the stand part debate was part of this group. Actually, the next group also includes amendments relating to Clause 26.
Clause 26 seeks to amend the definition of what is regarded as controlled expenditure for recognised third parties. I want to be clear about what we are doing and what we are not doing. Yes, we are widening the range of activities for which campaign expenditure by a recognised third party will be treated as “controlled expenditure”. Schedule 3 inserts a new Schedule 8A into the Political Parties, Elections and Referendums Act 2000. The new Schedule 8A expands the activities that will count in a way that closely reflects the scope of the rules for political parties. That change means that not only will written “election material” be regulated but so will other events such as media work associated with an election campaign by a third party. The next group of amendments goes over these changes in some detail.
What we are not doing is widening what the spending must be about. Expenditure is only controlled expenditure if it,
“can reasonably be regarded as intended to promote or procure electoral success”
of a party or candidates. I am particularly grateful to my noble friend Lord Greaves—who I hope will continue to be an election agent for many elections to come—for summing it up. He said that in seeking the objectives of greater transparency, we should not have a chilling effect. That is an objective that we share and seek to implement in this Bill. We do not want our national politics taken over by super-PACs—as he said, “big bucks from big boys”—and we do not want a situation where it is possible for a third party organisation to spend more than the candidates can legitimately spend. I agree that what we are seeking to do is a listening exercise. The noble Lord, Lord Rooker, summed it up correctly. What Governments do in Committee is listen, get the mood of the House and reflect on what has been said, and that is certainly what we intend to do.
We are aware of the concerns expressed by charities and voluntary organisations that the proposed test will impact upon their normal day-to-day activities. The Government believe that, by not changing the existing test for controlled expenditure, charities, voluntary organisations and other campaigners should be reassured that their normal engagement with public policy will not be subject to regulation as long as it cannot,
“reasonably be regarded as intended to promote or procure electoral success”
of a party or candidate.
I will pick up two specific concerns that were expressed. The noble Earl, Lord Sandwich, expressed that concern about small charities—we will come on to the thresholds later—but he also mentioned the importance of volunteers working with small charities, which I certainly recognise. I can indicate to the noble Earl and to the House that volunteer costs will not have to be included in the calculation of staff costs because volunteers are excluded from the calculation of staff costs by virtue of Section 87(2)(b) of the 2000 Act.
My noble friend Lord Hodgson asked about hustings meetings if not all candidates are invited. My noble friend Lord Phillips made reference to Charity Commission guidance on this. My understanding is that the Electoral Commission has said that it expects non-party campaigners to apply a similar approach to current hustings guidance. Subject to any change of approach in that guidance as a result of the review that is taking place, this would mean that the costs of a hustings event involving political parties will be controlled spending under the non-party campaigning rules only if all the following conditions apply.
Those conditions are: the event features party spokespeople—hustings events that feature only local candidates will be covered by the candidate spending rules, as at present; that the event is open to the public, rather than just members of the organisation that is organising the hustings; that the event features party spokespeople and not all parties contesting the election are invited to attend; and that organisers cannot provide objective reasons for their decision as to which parties to invite, such as the parties’ prominence or track record in previous elections. I recognise that this is an issue and I will certainly write to the noble Lord and ensure that that letter is available, not only, I suspect, to Members of the House but to those who have a wider interest in this matter.
The test that I am referring to has been in existence since 2000 and was in place for the 2005 and 2010 general elections. These elections did not see charities and other campaigners being prevented from engaging in and influencing public policy, although I take the point that it is “other activities” and any possible changes to the threshold that are giving rise to concern.
The amendments in the name of the noble and learned Lord, Lord Hardie, would amend Clause 26 so that only activity that can reasonably be regarded as intended for the “principal purpose” of promoting or procuring the electoral success of a party or candidate is covered. However, we believe that the introduction of a “principal purpose” test could lead to greater regulatory uncertainty, as well as an obvious avenue for avoidance, which could undermine the rules as a whole.
On the point of regulatory uncertainty, the Electoral Commission has expressed concerns that we would be retaining a familiar test but introducing a new subjective element which could lead to significant regulatory difficulty. Determining the “principal purpose” of any expenditure adds a new layer of judgment and complexity to the test and therefore could complicate rather than clarify.
The test also creates an obvious avenue for avoidance; for example, a regulation campaign presented as mainly trying to recruit members and donors could clearly also be seen to be promoting electoral success, and in these circumstances might not be covered. Under the “principal purpose” test, the fact that there was a clear intention to support a party or candidates would therefore be immaterial and not subject to regulation.
This issue was looked at by the Committee on Standards in Public Life back in 1998, which led to the establishment of the 2000 legislation. Paragraph 10.78 of the committee’s report refers to activities in the 1959 general election—I can just about remember accompanying my parents to a polling station and having the day off school. It says that,
“a privately owned steel firm, Stewarts and Lloyds, ran a series of advertisements in daily and Sunday newspapers, most of which were thought to have large Labour readerships. The advertisements were clearly intended to discourage voters from voting Labour. That is not, however, what they said. On the contrary, the Stewarts and Lloyds slogan insisted: ‘It’s not your vote we ask for, it’s your voice. Speak up against state-owned steel’. In one advertisement, published in the pro-Labour Daily Herald, the firm stated baldly: ‘This advertisement is not trying to sway votes in any political election’”.
The committee goes on to say:
“It is clear to us that advertising of this kind … has as one of its objects or one of its foreseeable effects, though not necessarily the only one, promoting the electoral prospects of one or more political parties and damaging the electoral prospects of one or more others. It is simply naive to imagine that organisations that send out explicitly political messages in the midst of election campaigns, or shortly in advance of them, are engaged innocently in generalised, nonpartisan promotional propaganda”.
That is why there is concern about introducing a subjective element.
The first recommendation of the most recent report of the Commission on Civil Society and Democratic Engagement, on the definition of regulated non-party campaigning, says:
“PPERA and the Lobbying Bill include a definition of non-party campaigning that is both ambiguous in meaning and makes too many campaigning activities subject to regulation that are not intended to promote or procure the election of a registered party and its candidates”.
If the campaigning is not intended to procure that, by this very definition it will not be regulated or controlled expenditure. The only difference is whether there is a subjective test or an objective test. For reasons of trying to minimise avoidance, the objective test is the proper one. Amendment 159B tabled by the noble and right reverend Lord, Lord Harries, amends Clause 26 so that any campaign which can reasonably be regarded as intended to promote or procure electoral success involving legislation going through Parliament during the regulated period would not count as controlled expenditure. Again, to incur controlled expenditure a third party must be carrying out an activity that it would be reasonable to regard as intended to promote or procure the electoral success of a party or candidate.
I take issue with one thing that my noble friend Lord Greaves said relating to campaigning during a Scottish parliamentary election or a European election over issues in Parliament at Westminster. He said that he thought that normal campaigning activities ought not to be prevented. I am interested in the words he used: “ought not to be prevented”. There is nothing intentional here to prevent activities. If it is an activity which would pass the threshold and be seen as intended to promote or procure an electoral advantage for a party or for a candidate, then it is for registration for regulation. The purpose is not to prevent it. I understand why he said that; it is a common slip of the tongue. Indeed, the noble Baroness, Lady Hayter, asked how many of Beatrice Webb’s campaigns would be ruled out. There is nothing here that would rule them out unless they reached the spending limit, which the Green Party did not even reach at the last general election.
However, I take on board the perfectly legitimate concern that I have heard at a number of the meetings I have had about the possibilities of a chilling effect. That is why it is important that we look at these issues and try to ensure that we have proper transparency without introducing a chilling effect. I plead guilty at some of the meetings to a slip of the tongue that this will rule out a particular sort of campaigning. It is not surprising that some charities and third-party organisations get the impression that they will not be allowed to campaign, but that is neither the purpose nor the effect of this part of the Bill. If you are going to undertake campaigning activities which would procure or promote the electoral advantage of one party or a candidate, then if you reach a particular threshold you should be registered and there will be the transparency that goes beyond that. We can debate the size of the spending limit it would be subject to, but many of the charities which have expressed concerns would come nowhere near the top spending limit that has been suggested in their normal activities.
Lord Greaves
I accept everything that my noble and learned friend said about the difficulty of getting absolutely clear in our minds what we are talking about. We are of course talking about whether expenditure comes within the regulation, not whether it is ruled out. However, let us imagine that during a UK general election the Scottish Parliament is considering a Bill that is highly controversial in Scotland and that is being promoted by the present SNP Scottish Government but opposed by everybody else. If organisations in Scotland lobby on that Bill during the regulated period running up to a UK general election, will they be caught or not? That is the question I am asking.
Lord Wallace of Tankerness
Our view is that if it could reasonably be seen that the purpose of that lobbying was to get the Scottish Government to change their mind, then no, the organisations would not be caught. However, if to further that campaign they were to say, “And by the way, in this general election don’t any of you vote SNP because that will only encourage them”, then I think that would cross the threshold. But if the focus and intention was to try to change the policies of the Scottish Government with a particular piece of legislation, it would not be a campaign that was intended to influence the outcome of the United Kingdom general election.
Lord Horam
My Lords, I add my voice in paying tribute to the commission chaired by the noble and right reverend Lord, Lord Harries, who very generously pointed out that it was a team effort. I am sure that it was, but it is remarkable that his report has been produced in only five weeks.
In the particular area that we are discussing on these amendments, it shows how, if the Government listen to the commission’s report and take account of it, there is a way forward whereby we can achieve what we are all looking for—to protect democracy but not see it overwhelmed by outside lobbying of a particular kind, although that lobbying may be worthy in its intention. I would slightly disagree with the noble Baroness, Lady Mallalieu. I am new to this House and may be misinterpreting things, but I do not think that we should always take a package as a whole—either the Government’s or the commission’s package. I do not think that that is the spirit of this House. What we can do, in reference to her view that we should have a view about the role of civil society, is to take into account the spirit of what lies behind the views expressed in detail, point by point, in the commission’s report. The Government would be well advised to do that.
I refer, too, to remarks made by my noble friend Lord Greaves. With regard to what he said on an earlier amendment, we are in some danger in looking just at charities and non-political party campaigners and forgetting the main body of people—the PBI, or poor bloody infantry of an election, the candidates and parties who have to go through the whole wretched business of fighting elections. That is something that we should not forget in concentrating, as we obviously are today, on the problems for charities in the electoral process. Let us not forget what a general election is all about. I know it very well, having fought 10 elections myself, with varied success.
To come to the point of the amendments, there is sense in exempting directly employed staff for the 2015 general election. It is true that the Electoral Commission has said in principle that party staff who are directly employed and full time should be included in election expenses; that would be something that it would want to press. But one accepts that in the context that we are now talking about, in the short time before the next general election, sorting all this out would be very difficult and would pose huge problems for many charities, which may have very large staffs. Most associations that fight general elections have extremely small staffs—almost no full-time staff, in many cases—and exist entirely on volunteers. We tend to forget that. I am not speaking on the Electoral Commission’s behalf, as I keep stressing, but that is something that it has wisely said.
I disagree with my noble friend Lord Tyler, in that I do not think that it would help to try to differentiate between the activities undertaken by paid staff; you either exempt them as a block or you include them. In the case of the next general election, as it says in the briefing from the Electoral Commission, they should be excluded temporarily, while the whole business of whether full-time staff should be included in future could be looked at in the review that the Government have promised for after the next general election.
Lord Greaves
I am grateful to my noble friend for giving way, and for his kind words. However, would he not agree that there is a difference between somebody who works for a charity or political party taking part in an election campaign as part of their normal job and somebody who is taken on to deliver leaflets? Political parties cannot take on people to canvass, because it is illegal to pay people to canvass, but a third-party organisation could do so. So if you pay people who normally do not work for you to deliver leaflets, surely that should be included.
Lord Horam
There is clearly a difference there, and I think that it probably should be reflected in the Bill. The fact is that the two situations are quite different.
The other issue is translation. Our noble friends from Wales put it very eloquently. It is almost an abuse to call this a translation, as though Welsh were a foreign language. This applies to other languages too. Then there is the question of making documents available to those with physical or learning disabilities and, as I mentioned in my remarks on Northern Ireland, exempting costs relating to safety or security measures. This is something which the Government have already implicitly begun to accept.
Therefore, I think this is an area where, prima facie, there can be some discussion and resolution which will be helpful to the charities, and I hope that the Government will consider this.