Reform of Legal Aid in England and Wales: the Government Response Part 46
Posted by admin
This is Part 46 of the government response to Reform of Legal Aid in England and Wales. Please read the other parts for a full picture. Used under the terms of the Open Government Licence http://www.justice.gov.uk/downloads/consultations/legal-aid-reform-government-response.pdf.
266 Reform of Legal Aid in England and Wales Government Response
Table 2: Schedule of alternative proposals submitted by the Law
Society
Quantified Law Society savings proposals
Law Society proposed saving MoJ comments on figures
1. More efficient prosecutions/
reimbursement of legal aid fund
In 2010, 9.5% of Magistrates’ Court cases
(almost 81,000 cases) and 12.6% of Crown
Court cases (14,745 cases) resulted in a
dropped prosecution or a judge-directed
acquittal. The legal aid fund should not
have to pay for these cases. They should
be much fewer in number, and the CPS
should bear the costs of the defence when
they do arise.
Assuming the cost of these cases is
proportionate to the whole legal aid spend
excluding AGFS, and assuming the
numbers could be halved, there could be a
significant saving to the legal aid fund.
Further assumptions are that all cases in
the Crown Court would have representation
and half of the cases in the Magistrates’
Court.
The cost to the CPS of having to meet the
defence costs in the remaining cases would
be offset from the saved resources in the
non-continuation or earlier discontinuance
of these bad cases.
Mags Court savings: 40,000 cases @ £475
per case (average case cost from LSC
Stats Pack 2009-10): £19 million
Crown Court savings: 14,745 cases @
£4,069 per case (average LGFS claim per
case from LSC Stats Pack 2009-10): £60
million
Total: £79m
This proposal would transfer
costs to another part of the
Government rather than cutting
total spending.
Total costs would only be cut if
dropped prosecutions and
judge-directed acquittals were
the responsibility of the CPS
and if the proposal provided the
CPS with an increased incentive
to avoid these. It is unclear to
what extent this is so.
The costing assumes that this
would be the case in 50% of
Magistrates’ Court and to 100%
of Crown Court dropped
prosecutions and judge-directed
acquittals.
These are very high
assumptions and no evidence is
provided to support them.
The costing also assumes that
all such cases would simply not
be brought in future by the CPS.
Instead the CPS might adopt a
different approach and these
cases might divert into cases
which proceed to a full hearing.
In which cases total legal aid
costs might rise as might costs
to the CPS.
267 Reform of Legal Aid in England and Wales Government Response
Law Society proposed saving MoJ comments on figures
2. Consideration of more cases being
dealt with in the Magistrates’ Courts
rather than the Crown Court provided
that there are safeguards to preserve
right to trial by jury.
A pending amendment to Section 20(3) of
the Magistrates Courts Act 1980, by
Paragraph 6 of Part 1 of Schedule 3 to the
Criminal Justice Act 2003, would allow for
an indication of whether a custodial or noncustodial sentence would be imposed on a
plea of guilty. This could encourage early
guilty pleas in the Magistrates’ Courts.
The number of either way cases heard in
the Crown Court in 2009 was 68,500, a rise
of 20% on 2008. For the purposes of this
calculation, we assume that this figure
could be reduced back down to the 2008
figure of approximately 57,000, and that
these cases would be average costs in
each court.
2009/10 average crime lower bill where
representation order granted: £475
2009/10 average crown court bill: £4,069
11500 cases at £3594 less per case,
rounded
Total: £41m
The costing assumes that 20%
of cases could be moved from
the Crown Court to the
Magistrates’ Court. There is no
evidential backing for this
assumption, which seems very
high.
The MoJ’s legal aid reform
package already includes
reforms which respond to
concerns that the current fee
system does not sufficiently
support the aim of speedy and
efficient justice and may
discourage early resolution of
cases. Non-election either-way
cases involve Magistrates rather
than defendants passing the
case to the Crown Court due to
the nature of the case.
3. Single fee for Crown Court
Over a relatively short time we believe that
the administrative savings for both
practitioners and the LSC from having a
single fee would reduce the cost of
delivering services in a way that would
enable significant financial savings to be
made.
Total: £30m
No derivation for this saving has
been provided.
268 Reform of Legal Aid in England and Wales Government Response
Law Society proposed saving MoJ comments on figures
4. More robust enforcement of merits
test for private law family contact
disputes
Based on anecdotal evidence, we believe
that a more effective application of the
current means test could reduce the volume
of contact cases by between 20 and 30%.
For the purposes of this estimate, we have
assumed a 25% reduction in volumes. The
new fee scheme is designed to be cost
neutral as against 2008-9 fees, so we have
applied the average cost per case from
2008-9 for Children Act only cases.
Published LSC figures do not distinguish
between contact disputes and residence
disputes. We have assumed that contact
disputes account for 85% of the 46,000
private law children certificates (2008-9
figures)
Reduction of 9,775 cases @ £3,002 per
case, rounded.
Total: £29m
It is unclear how deliverable and
enforceable these savings
would be in practice, and what
the enforcement costs might be.
The saving assumes that 85%
of ‘private law children cases’
are contact cases and that 25%
of those could be averted by
applying means test more
strictly. No evidence has been
provided for these assumptions,
which seem high.
5. Capping fees so no individual can
earn a personal income of more than
£250,000 in a year from legal aid
Based on statistics for payment to
advocates published by MoJ in March 2010
Mechanisms for achieving this could
include:
Aligning QCs’ and Leading Juniors’ fees at
the latter rate
Reducing the “event rate” for QCs in family
cases from £2310 per event, and ensuring
that a substantially reduced event fee is
paid for events lasting less than half a day.
Total: £16m
The derivation of this saving is
unclear. A simple cap might just
allocate current spending more
evenly amongst recipients.
There might also be risks
concerning the quality of advice
and service.
The other proposals seem to
relate to fee reductions. There is
potentially some double
counting with the savings
highlighted elsewhere.
The MoJ’s reform package
already includes savings from
fee reductions.
269 Reform of Legal Aid in England and Wales Government Response
Law Society proposed saving MoJ comments on figures
6. Review of approach to prosecutions in
VHCCs
CPS could be more selective about the
number of charges brought, the number of
individual defendants prosecuted and the
volume of evidence produced.
Such an approach could generate a saving
in the cost of VHCCs of 10-20%. For this
calculation, we have assumed savings of
15%.
15% of £95m
Total: £14m
The saving assumes a 15%
reduction in VHCC costs as a
result of the CPS operating in a
more selective manner. This
seems to double count the
savings from item 1.
There is no source or detailed
explanation for the 15% figure or
evidence of CPS inefficiency to
indicate this is plausible.
7. Limit all but essential advocates’
travel to court and hotel expenses and
no longer pay for first class travel.
In 2011 there is likely ample local coverage
by Advocates of almost all Crown Court
centres, thereby reducing the need for
travel & hotel expenses. These expenses
(under code THE), according to MoJ data,
amounted to over £11m in 2009-10.
Allowing for some exceptional travel, £10m
could be saved.
Total: £10m
The saving assumes a 90%
reduction in advocate travel and
subsistence costs based on
cases being allocated on the
basis of geographical proximity
and reductions in the quality of
travel and hotels. This
assumption appears quite
speculative and there might be
costs associated with the
implied different system for
advocate allocation.
270 Reform of Legal Aid in England and Wales Government Response
Law Society proposed saving MoJ comments on figures
8. Reduce waste
Mechanisms will include
Increase efficiency of Court Service by
improving listings systems, case
management and implementing Jackson
proposal for ‘ticketing’ of judges to ensure
that cases are heard by judges with the
appropriate expertise.
Increase use of wasted costs orders. In the
short term, this would cause an increased
cost to other public bodies, but only to the
extent that they were the cause of
inefficiency in the Court system. In the
longer term, the penalty of such orders
should reduce the amount of waste in the
system, generating savings for the public
purse across a number of budgets,
including Courts, prison delivery and CPS
as well as legal aid.
Review use of Associate Prosecutors.
APs are in practice often reluctant to make
decisions on cases leading to costs of
unnecessary delays and adjournments.
For the purposes of this calculation we have
assumed that there is one unnecessary
delay or adjournment caused by failures in
the system other than on the defence side
for every two representation orders, and
that each hearing adds £40 to the costs of
the case on average.
450,000 Representation orders x one half
@ £40 each.
Total: £9m
The saving assumes a 50%
reduction in representation
orders and assumes that each
hearing costs £40 in legal aid.
No evidence for these
assumptions has been provided.
The savings also does not seem
to relate to other aspects of the
proposal.
271 Reform of Legal Aid in England and Wales Government Response
Law Society proposed saving MoJ comments on figures
9. Funding from seized assets of
defendants
The SOCA Annual Report 2009-10 states
that assets denied to criminals totalled £238
million. SOCA spent over £8.5 million on
professional services and fees; and it is
likely that a proportion of staff costs were
also dedicated to asset recovery. For the
purposes of this calculation, and in the
absence of data from the LSC, we have
assumed that a similar sum was spent on
behalf of those whose assets were being
pursued. This may be a significant
underestimate.
Total: £9m
The saving relates to SOCA’s
spending on their own legal
services. There is no particular
basis for assuming that this
would equate to the legal aid
savings of the proposal. The
savings to the legal aid fund
might not be savings for the
Government overall as if the
defendant is found guilty the
funds would be seized by the
Government. In which case the
gain to the legal aid fund would
relate to a loss to other parts of
the Government.
10. Remove hearsay and bad character
provisions
There are no reliable figures for what this
proposal might save. We do not know in
how many cases such applications are
made; in how many they directly cause a
need for an additional hearing; or what
impact that has overall on the fees paid
under the Standard or Graduated Fee
Schemes
For the purposes of this estimate, we have
assumed that an extra hearing is required in
25-40% of prosecutions where a
Representation Order is granted, and that
on average, it increases the costs claimed
on the case by £40.
450,000 Representation orders x 25% x
£40 = £4.5 million
450,000 Representation orders x 40% x
£40 = £7.2 million
Best estimate – mid point, rounded.
Total: £6m
The saving assumes a 32%
reduction in representation
orders. There is no basis or
evidence behind this
assumption.
272 Reform of Legal Aid in England and Wales Government Response
Law Society proposed saving MoJ comments on figures
11. Single fee for family
This could save an estimated 2.5% on the
total spent on advocacy fees for family.
Counsel’s fees total £124 million. We do not
have at this stage an accurate figure for
solicitor advocacy in family cases, so we
have based the calculation just on
Counsel’s fees.
Total: £3m
The saving assumes a 2.5%
reduction in advocacy costs.
This assumption is unexplained.
It is unclear how this relates to
the other single fee saving.
12. Family mediated settlements should
become subject to the legal aid statutory
charge subject to a 50% discount.
In a mediation briefing for the judiciary, the
LSC stated that in 2008-9 they spent £13.8
million on publicly funded mediation. 68% of
cases resulted in an agreement of which an
estimated one half produced a financial
settlement.
50% of half of 68% of £13.8 million,
rounded.
Total: £2m
The saving assumes 50% of
legal aid costs can be recovered
from mediations which produce
a financial settlement. This
seems a very high percentage
with no assessment of time
profile, admin costs, or bad debt
rates. People might also move
away from mediation if a
statutory charge applies,
reducing any savings and
possibly generating increased
costs of this resulted in more
cases going to court instead of
mediation.
13. Reduce need to produce prisoners
on Governor’s warrant
This would reduce the number of interim
hearing and thus produce savings for legal
aid, the Court Service and the Prison
Service. The Crown Court remands
approximately 35,000 prisoners per year,
who spend on average 13 weeks in
custody. Figures do not appear to be
available for the number of hearings that
serve no purpose other than producing the
prisoner. For the purposes of this
calculation, we have assumed that there is
on average two such hearings for every
three remand prisoners, and that each such
hearing increases the legal aid costs by £40
on average, rounded.
Total: £1m
The saving assumes each
Crown Court prisoner on
remand has an interim hearing
and 67% of these serve no
purpose at all. No evidential
basis for these assumptions is
provided.
Total Law Society proposed savings: £249 million
273 Reform of Legal Aid in England and Wales Government Response
Law Society proposals for wider savings
Law Society proposed saving MoJ comments on figures
14. Make the financial sector pay for its
own fraud cases
Total fraud costs, per LSC estimate:
£148m
Assume 50% relates to the financial
services sector – LSC has no accurate
figures:
£74m
Note: some potential overlap with £250,000
cap and with review of approach to VHCCs
Additional saving: £63m
The saving assumes 50% of
fraud cases relate to the
financial services sector. There
is no bass for this assumption.
The derivation of the saving
reduction relating to double
counting is undefined.
15. A levy on the alcohol industry:
Alcohol is a significant factor in offences
and disputes requiring legal aid. Total
alcohol sales are in the region of £40bn
generating some £8.5bn in duty exclusive of
VAT. A 1% increase in duty would generate
additional revenue of £85 million per annum
towards for legal aid.
Total: £85m
The saving assumes a 1%
increase in duty on all alcoholic
products would yield income of
1% of current total duty. This
assumes no behavioural effects
or substitution effects.
16. Simplification of housing law along
the lines proposed by the Law
Commission report ‘Renting Homes’
(2006)
Current legal aid expenditure on housing is
around £50m. Implementing the
simplification proposals would reduce
spending by around 20%.
Total: £10m
The saving assumes a 20%
reduction in legal aid spending
on housing. No evidential basis
for this assumption has been
provided.
17. Increase use of legal expenses
insurance
No significant savings under current limited
scope of LEI. Possible savings if insurers
could be persuaded to increase scope and
if take of LEI could be increased
Not quantifiable
274 Reform of Legal Aid in England and Wales Government Response
275
Law Society proposed saving MoJ comments on figures
18. Compulsory legal insurance for
company directors for offences arising
from their office as director.
This would largely duplicate savings arising
from our proposed levy on the financial
services industry
Not quantifiable
Total Law Society proposed wider savings: £158m 276
Reform of Le
Annex M: Summary of responses to the consultation questions
Question Yes No Neither Total
Scope
1 Do you agree with the proposals to retain the types of case and proceedings listed in paragraphs
4.37 to 4.144 of the consultation document within the scope of the civil and family legal aid scheme –
Please give reasons.
1,584 217 227 2,028
2 Do you agree with the proposal to make changes to court powers in ancillary relief cases to enable
the Court to make interim lump sum orders against a party who has the means to fund the costs of
representation for the other party – Please give reasons.
1,090 265 62 1,417
3 Do you agree with the proposals to exclude the types of case and proceedings listed in paragraphs
4.148 to 4.245 from the scope of the civil and family legal aid scheme – Please give reasons.
103 3,380 266 3,749
4 Do you agree with the Government’s proposals to introduce a new scheme for funding individual
cases excluded from the proposed scope, which will only generally provide funding where the
provision of some level of legal aid is necessary to meet domestic and international legal obligations
(including those under the European Convention on Human Rights) or where there is a significant
wider public interest in funding Legal Representation for inquest cases – Please give reasons.
641 720 145 1,506
5 Do you agree with the Government’s proposal to amend the merits criteria for civil legal aid so that
funding can be refused in any individual civil case which is suitable for an alternative source of
funding, such as a Conditional Fee Arrangement – Please give reasons.
387 764 134 1,285
6 We would welcome views or evidence on the potential impact of the proposed reforms to the scope of
legal aid on litigants-in-person and the conduct of proceedings.
1,665
gal Aid in England and Wales: Government Response Question Yes No Neither Total
Reform of Legal Aid in England and Wales: Government Response
277
The Community Legal Advice Telephone Helpline
7 Do you agree that the Community Legal Advice helpline should be established as the single gateway
to access civil legal aid advice – Please give reasons.
69 1,690 197 1,956
8 Do you agree that specialist advice should be offered through the Community Legal Advice helpline in
all categories of law and that, in some categories, the majority of civil Legal Help clients and cases
can be dealt with through this channel – Please give reasons.
109 1,366 223 1,698
9 What factors should be taken into account when devising the criteria for determining when face-toface advice will be required –
1,365
10 Which organisations should work strategically with Community Legal Advice and what form should
this joint working take –
931
11 Do you agree that the Legal Services Commission should offer access to paid advice services for
ineligible clients through the Community Legal Advice helpline – Please give reasons.
473 848 124 1,445
Financial Eligibility
12 Do you agree with the proposal that applicants for legal aid who are in receipt of passporting benefits
should be subject to the same capital eligibility rules as other applicants – Please give reasons.
327 940 64 1,331
13 Do you agree with the proposal that clients with £1,000 or more disposable capital should be asked to
pay a £100 contribution – Please give reasons.
318 941 103 1,362
14 Do you agree with the proposals to abolish the equity and pensioner capital disregards for cases
other than contested property cases – Please give reasons.
140 803 52 995
15 Do you agree with the proposals to retain the mortgage disregard, to remove the £100,000 limit, and
to have a gross capital limit of £200,000 in cases other than contested property cases (with a
£300,000 limit for pensioners with an assessed disposable income of £315 per month or less) –
Please give reasons.
346 550 68 964 278
Reform of Le
Question Yes No Neither Total
16 Do you agree with the proposal to introduce a discretionary waiver scheme for property capital limits
in certain circumstances – The Government would welcome views in particular on whether the
conditions listed in paragraphs 5.33 to 5.37 are the appropriate circumstances for exercising such a
waiver. Please give reasons.
485 336 84 905
17 Do you agree with the proposals to have conditions in respect of the waiver scheme so that costs are
repayable at the end of the case and, to that end, to place a charge on property similar to the existing
statutory charge scheme – Please give reasons. The Government would welcome views in particular
on the proposed interest rate scheme at paragraph 5.35 in relation to deferred charges.
363 395 125 883
18 Do you agree that the property eligibility waiver should be exercised automatically for Legal Help for
individuals in non-contested property cases with properties worth £200,000 or less (£300,000 in the
case of pensioners with disposable income of £315 per month or less) – Please give reasons.
312 433 118 863
19 Do you agree that we should retain the ‘subject matter of the dispute’ disregard for contested property
cases, capped at £100,000 for all levels of service – Please give reasons.
480 265 86 831
20 Do you agree that the equity and pensioner disregards should be abolished for contested property
cases – Please give reasons.
179 582 23 784
21 Do you agree that, for contested property cases, the mortgage disregard should be retained and
uncapped, and that there should be a gross capital limit of £500,000 for all clients – Please give
reasons.
475 236 60 771
22 Do you agree with the proposal to raise the levels of income-based contributions up to a maximum of
30% of monthly disposable income – Please give reasons.
96 881 88 1,065
Model 1 Model 2 Neither Total
23 Which of the two proposed models described at paragraphs 5.59 to 5.63 would represent the most
equitable means of implementing an increase in income-based contributions – Are there other
alternative models we should consider – Please give reasons.
117 21 530 668
gal Aid in England and Wales: Government Response Question Yes No Neither Total
Reform of Legal Aid in England and Wales: Government Response
279
Criminal Remuneration
24 Do you agree with the proposals to:
i) pay a single fixed fee of £565 for a guilty plea in an either way case which the magistrates’ court
has determined is suitable for summary trial;
136 681 817
ii) enhance the lower standard fee paid for cracked trials and guilty pleas under the magistrates’
courts scheme in either way cases; and
223 530 753
iii) remove the separate fee for committal hearings under the Litigators’ Graduated Fees Scheme to
pay for the enhanced guilty plea fee –
61 707 768
Please give reasons. 699
25 Do you agree with the proposal to harmonise the fee for a cracked trial in indictable only cases, and
either way cases committed by magistrates, and in particular that:
i) the proposal to enhance fees for a guilty plea in the Litigators’ Graduated Fees Scheme and the
Advocates’ Graduated Fees Scheme by 25% provides reasonable remuneration when averaged
across the full range of cases; and
65 558 623
ii) access to special preparation provides reasonable enhancement for the most complex cases – 118 517 635
Please give reasons. 483
26 Do you agree with the Government’s proposal to align fees paid for cases of murder and
manslaughter with those paid for cases of rape and other serious sexual offences – Please give
reasons.
123 592 38 753
27 Do you agree with the Government’s proposal to remove the distinction between cases of dishonesty
based on the value of the dishonest act(s) below £100,000 – Please give reasons.
290 375 49 714
28 Do you agree with the Government’s proposal to:
a) remove the premium paid for magistrates’ courts cases in London; and 156 473 629
b) reduce most ‘bolt on’ fees by 50% – 148 543 691
Please give reasons. 516 280
Reform of Le
Question Yes No Neither Total
29 Do you agree with the proposal to align the criteria for Very High Cost Criminal Cases for litigators so
that they are consistent with those now currently in place for advocates – Please give reasons.
285 250 81 616
30 Do you agree with the proposal to appoint an independent assessor for Very High Cost Criminal
Cases – It would be helpful to have your views on:
232 322 43 597
i) the proposed role of the assessor;
ii) the skills and experience that would be required for the post; and
iii) whether it would offer value for money.
Please give reasons.
31 Do you agree with the proposal to amend one of the criteria for the appointment of two counsel by
increasing the number of pages of prosecution evidence from 1,000 to 1,500 pages – Please give
reasons.
229 437 30 696
Civil Remuneration
32 Do you agree with the proposal to reduce all fees paid in civil and family matters by 10%, rather than
undertake a more radical restructuring of civil and family legal aid fees – Please give reasons.
115 1,525 95 1,735
33 Do you agree with the proposal to cap and set criteria for enhancements to hourly rates payable to
solicitors in civil cases – If so, we would welcome views on the criteria which may be appropriate.
Please give reasons.
317 751 80 1,148
34 Do you agree with the proposal to codify the rates paid to barristers as set out in Table 5, subject to a
further 10% reduction – Please give reasons.
369 638 54 1,061
35 Do you agree with the proposals:
i) to apply ‘risk rates’ to every civil non-family case where costs may be ordered against the opponent;
and
81 585 666
ii) to apply ‘risk rates’ from the end of the investigative stage or once total costs reach £25,000, or
from the beginning of cases with no investigative stage –
84 583 667
Please give reasons.
gal Aid in England and Wales: Government Response Question Yes No Neither Total
Reform of Legal Aid in England and Wales: Government Response
281
36 The Government would also welcome views on whether there are types of civil non-family case (other
than those described in paragraphs 7.22 and 7.23) for which the application of ‘risk rates’ would not
be justifiable, for example, because there is less likelihood of cost recovery or ability to predict the
outcome.
346
37 Do you agree with the proposal to cap and set criteria for enhancements to hourly rates payable to
solicitors in family cases – If so, we would welcome views on the criteria which may be appropriate.
Please give reasons.
382 662 45 1,089
38 Do you agree with the proposals to restrict the use of Queen’s Counsel in family cases to cases
where provisions similar to those in criminal cases apply – Please give reasons.
459 592 65 1,116
Expert Remuneration
39 Do you agree that:
i) there should be a clear structure for the fees to be paid to experts from legal aid; 875 90 965
ii) in the short term, the current benchmark hourly rates, reduced by 10%, should be codified; 494 369 863
iii) in the longer term, the structure of experts’ fees should include both fixed and graduated fees and
a limited number of hourly rates;
639 220 859
iv) the categorisations of fixed and graduated fees shown in Annex J are appropriate; and 430 332 762
v) the proposed provisions for ‘exceptional’ cases set out at paragraph 8.16 are reasonable and
practicable –
478 288 766
Please give reasons. 282
Reform of Le
Question Yes No Neither Total
Alternative Sources of Funding
40 Do you think that there are any barriers to the introduction of a scheme to secure interest on client
accounts – Please give reasons.
578 189 130 897
Model A Model B Neither
41 Which model do you believe would be most effective. Please give reasons. 317 94 306
Model A Model B Model C None
42 Do you think that a scheme to secure interest on client accounts would be most effective if it were
based on:
216 102 47 292
Please give reasons.
43 Do you agree with the proposal to introduce a Supplementary Legal Aid Scheme – Please give
reasons.
176 273 173 622
44 Do you agree that the amount recovered should be set as a percentage of general damages – If so,
what should the percentage be –
259 182 124 565
Governance and Administration
45 The Government would welcome views on where regulators could play a more active role in quality
assurance, balanced against the continuing need to have in place and demonstrate robust central
financial and quality controls.
641
gal Aid in England and Wales: Government Response Reform of Legal Aid in England and Wales: Government Response
283
Question Yes No Neither Total
46 The Government would welcome views on the administration of legal aid, and in particular: 757
i) the application process for civil and criminal legal aid;
ii) applying for amendments, payments on account etc.;
iii) bill submission and final settlement of legal aid claims; and
iv) whether the system of Standard Monthly Payments should be retained or should there be a move
to payment as billed –
47 In light of the current programme of the Legal Services Commission to make greater use of electronic
working, legal aid practitioners are asked to give views on their readiness to work in this way.
840
48 Are there any other factors you think the Government should consider to improve the administration
of legal aid –
683
Impact Assessments
49 Do you agree that we have correctly identified the range of impacts under the proposals set out in this
consultation paper – Please give reasons.
88 1,104 169 1,361
50 Do you agree that we have correctly identified the extent of impacts under these proposals – Please
give reasons.
50 1,036 75 1,161
51 Are there forms of mitigation in relation to client impacts that we have not considered – 636