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Chamber and committees

Subordinate Legislation Committee,

Meeting date: Tuesday, May 24, 2005


Contents


Instruments Subject to Annulment


Instruments Subject <br />to Annulment


Common Agricultural Policy Single<br />Farm Payment and Support Schemes (Scotland) Amendment Regulations 2005 (SSI 2005/257)

The Convener:

The regulations breach the 21-day rule. Committee members might remember that we agreed recently to send a letter asking about liaison between the Scottish Parliament and the Westminster Government on European Union directives. We have not yet had a response to that letter, so the matter will arise at a later meeting. On this occasion, the Executive states that, "due to an oversight", the adoption and publication of European Commission regulation 606/2005, which entered into force on 20 April 2005, did not come to light until 9 May 2005.

The fact that the regulations breach the 21-day rule means that the usual sufficient time will not be available for representations to be made on the changes that they introduce. One or two committee members might be aware that constituents have raised concerns about that, so perhaps we should write to the Executive to ask a little more about what "due to an oversight" means.

Christine May:

We should write. My understanding is that, although farmers generally welcome the flexibility that the regulations provide, those who might lose money or not be paid as much as they were previously are very concerned, as they had no time to make representations. We learned of those concerns only through media reports in the past few days and, given the level of concern, it is appropriate that the committee ask further questions.

I agree. Farmers have approached MSPs on the issue, so there is obviously strong feeling on it.

Is it agreed that we ask for further information?

Members indicated agreement.


Mental Welfare Commission for Scotland (Appointment of Medical Commissioners) Regulations 2005 (SSI 2005/261)

No points arise on the regulations.


Mental Health (Conflict of Interest) (Scotland) Regulations 2005 (SSI 2005/262)

No points arise on the regulations.


Additional Support for Learning (Appropriate Agency Request Period and Exceptions) (Scotland) Regulations 2005 (SSI 2005/264)

The Convener:

The meaning and practical effect of regulation 2 may be unclear. It provides that an appropriate agency must comply with a request

"within a period 10 weeks starting on the date when the request was made by the authority".

A "request" is defined in section 28(1) of the Education (Additional Support for Learning) (Scotland) Act 2004 as a request that is in writing and which

"contains a statement of the reasons for making the request."

It is not clear what "made" means in that context: it is not clear whether the 10-week period will commence only when the appropriate authority receives the request or, alternatively, as soon as the written request is signed or posted.

Christine May:

Given the fairly well-publicised Royal Mail delivery results, it might be important for recipients to know whether the date on which a request became effective was the date on the postmark or the date when they received the letter. Clarification would be welcome.

Mr Maxwell:

I would think that the relevant date would be the date on which the request was received. That would be in line with the Freedom of Information (Scotland) Act 2002, under which time limits apply from the date on which an authority receives a freedom of information request. As the point is not absolutely clear, we should seek clarification on it, but the relevant day must be the day that the request is received; I cannot imagine that it would be the day on which it was posted in the high street.

I hope that that is the case.

Should there not be standard practice throughout the governmental machinery and ought the same rule not to apply in every circumstance?

No. I can think of some emergency situations—perhaps the closure of a dangerous operation—in which an order becomes effective as soon as it is made, regardless of whether the subject of that order has received the paperwork.

Murray Tosh:

In that case, there might be a graded policy that provides for the date of issue to be the relevant date, but there ought to be a presumption that the date of receipt is the relevant date unless there is a justifiable reason for treating some circumstances differently.

We will write to the Executive to ask for clarification on that point. I gather that the same issue arises in regulation 3(3). In addition, we will ask what the standard practice is.

If there is one.

Indeed. We will also ask what exemptions there might be from that standard practice, as we accept that there may be exemptions. Is that agreed?

Members indicated agreement.


Additional Support for Learning<br />(Changes in School Education) (Scotland) Regulations 2005 (SSI 2005/265)

The Convener:

The regulations set out actions that education authorities must take when changes occur in the school education of children and young persons who have additional support needs. The introductory wording to regulation 3(2)(b) includes the words:

"where the authority seek advice and information under paragraph (a)".

That appears to amount to a qualification that an authority will be required to seek and take account of the views of children as set out in subparagraph (b) only when it seeks such advice and assistance under subparagraph (a). It is not clear why that wording was added.

Do we agree to seek clarification on regulation 3(2)(b)?

Members indicated agreement.


Additional Support for Learning<br />(Co-ordinated Support Plan) (Scotland) Regulations 2005 (SSI 2005/266)

The Convener:

Regulation 3(1)(b)(iv) specifies that the matters that are contained in section 9(2)(a) to (d) of the Education (Additional Support for Learning) (Scotland) Act 2004—the parent act—must be included in a plan. However, under section 9(2) of that act, it is already required that such information be included in a plan. Do we agree to ask for further clarification on that point?

Members indicated agreement.

The Convener:

Regulation 5 provides for the time limit for reviews of a plan under section 10 of the 2004 act, and includes several cross-references to sections 10 and 11 of the parent act. Regulation 5(a) provides that, where an education authority completes a review of the plan, the copy of the plan, as amended, must be given to the persons mentioned in

"subsection 5(a) of that section".

The reference to "that section" is not clear, because the preceding wording refers to both section 10 and section 11 of the parent act.

Christine May:

I agree that that is unclear. I also have a question. The legal briefing notes:

"there are 5 separate cross references in this regulation".

For the sake of good practice, is there an alternative way of drafting that to make the regulations clearer and easier to use? The wording seems unnecessarily complicated.

We can ask about both those points. We will write to the Executive. Is that agreed?

Members indicated agreement.


Additional Support for Learning (Publication of Information) (Scotland) Regulations 2005 (SSI 2005/267)<br />St Mary's Music School (Aided Places) (Scotland) Amendment Regulations 2005 (SSI 2005/269)


Education (Assisted Places) (Scotland) Amendment Regulations 2005<br />(SSI 2005/270)

No substantive points arise on the regulations.