NORTHERN IRELAND ASSEMBLY

COMMITTEE FOR SOCIAL DEVELOPMENT

OFFICIAL REPORT
(Hansard)

Charities Bill
31 May 2007

Members present for all or part of the proceedings:
Mr Gregory Campbell (Chairperson)
Mr David Hilditch (Deputy Chairperson)
Mr Mickey Brady
Mr Thomas Burns
Mr Jonathan Craig
Ms Anna Lo
Mr Fra McCann
Mrs Claire McGill
Miss Michelle McIlveen
Mr Alban Maginness

Witnesses:
Mr Kieran Doyle (Department for Social Development)
Mr John McGrath (Department for Social Development)
Mr Seamus Murray (Department for Social Development)

The Chairperson (Mr Campbell):
Good morning, gentlemen. I welcome you to the Committee. I remind everyone that Hansard is recording the meeting. The normal precautionary note that mobile phones must be switched off applies. If they are not switched off, and they become active, their signal interferes with the Hansard recording equipment.

The Committee has met to consider the proposed charities Bill and its numerous clauses, of which the Bill Office has given us a general overview. I will pass over to you, gentlemen. The Committee would be grateful if you would be so kind as to take questions from members after your presentation.

Mr John McGrath (Department for Social Development):
Thank you, Chairman. We are pleased to be here. My colleagues are Mr Seamus Murray, who is acting director of the Voluntary and Community Unit, and Mr Kieran Doyle, who will cover most of the detail that may come up during the meeting and will certainly come up as the legislation proceeds.

The Department for Social Development is the main charity authority for Northern Ireland. It has responsibility for policy and most of the legislation that relates to charities.

At the minute we estimate that there are between 9,000 and 12,000 charities operating in Northern Ireland. In recent years we have been monitoring the need to change the legislation to take account of ongoing developments, governance arrangements and legislation in the rest of the United Kingdom and also in the Republic of Ireland. It must be decided which areas of existing legislation could usefully be amended to adopt the best of the new approaches to regulation and governance in the UK and to improve existing procedures.

As far back as 1996 an early review took place, but no consensus could be reached at that stage on what would be the most appropriate arrangements for Northern Ireland. The review was reopened in 2002 by the then Minister, Nigel Dodds. The proposals were then held again until the direction and shape of the new legislation, particularly in England, was clear, given the need for consistency across the UK. We are aware now, however, that Northern Ireland has fallen a bit out of step with the rest of the United Kingdom and will be out of step with the Republic of Ireland when the proposed legislation is enacted there.

We are also aware from discussions with the PSNI, the Independent Monitoring Commission (IMC) and HM Revenue and Customs (HMRC) that there is some evidence of charities having been established in Northern Ireland precisely to avoid the regulatory framework that exists elsewhere or will be brought in elsewhere. That was very much in the mind of the Northern Ireland Affairs Select Committee last year when carrying out its examination of organised crime. Some of us gave evidence to that Committee at Westminster.

Between 11 February and 3 June 2005, we carried out a public consultation on the range of proposals for changes in the legislation and the principles underlying the charity regulation proposals. We received a total of 106 responses from a wide range of bodies and individuals, with the majority being broadly favourable.

The key tenets, or the building blocks, of the Bill that will be coming forward largely follow the new definition of charities as set out in the Charities Act 2006, which covers England and Wales, the only addition being the promotion of peace and good community relations. Linked to that will be the Northern Ireland register of charities, with which all Northern Ireland charities should be registered. At present no formal register or record of charities exists in Northern Ireland or is required to exist.

A new charities commission for Northern Ireland will be established that will first and foremost seek to ensure compliance with the legislative requirements, monitor charities’ performance and provide public accountability and transparency for the funds given to charities. The charities commissioner will be the key regulator of the charity sector in Northern Ireland.

All charities to be registered will need to demonstrate that their objectives and their activities generate public benefit. There will also be requirements to make returns on both their finances and activities, and there will be new arrangements governing public collections involving a system of permits and licences.

Full consultation on the draft legislation took place from 17 July to 13 October 2006. Again the responses were overwhelmingly favourable. Two changes were made to the draft legislation subsequently, relating to audit levels and public collections. That legislation, which is largely the same now, was laid at Westminster on 29 January 2007; however, with the restoration of devolution it was not moved. Following Executive approval, which we expect shortly, we hope to bring it to the Assembly for consideration.

Throughout the process of work that the Department has been engaged upon in recent years we sought to reassure all the charities, and the charity sector in Northern Ireland, that a new charities commission will aim, as part of its work, to support and assist organisations to ensure that they comply with regulation requirements. The commissioner will be expected to work with other charity regulators across the UK and Ireland on developing guidance and support.

In summary, therefore, this legislation is first and foremost about protecting the public who give to bodies purporting to be charities. The governance arrangements and the register will provide a framework within which bona fide charities will be able to receive greater public support and to give reassurance that their activities are appropriate and that they deserve fund-raising and donations.

The Chairperson:
You have estimated that there are between 9,000 and 12,000 charities in Northern Ireland. There is a considerable variation in those figures. Do you know the scale of each organisation?

Mr Seamus Murray (Department for Social Development):
The only reliable indicator as to the number of charities in Northern Ireland is the list held by HM Revenue and Customs. Coincidently, the Department had its annual meeting with HMRC yesterday. The list contains an estimated 5,000 charities with a Northern Ireland postcode, and that figure increases by around 300 each year. The list is limited in that it includes only organisations claiming tax benefits.

Northern Ireland differs from the rest of the UK in that it has few large charities — most are relatively small. The variation between the figures of 9,000 and 12,000 reflects the fact that many charities may be Church based. Some Northern Ireland-wide bodies, such as scouting organisations, have individual scout troops. Therefore, whether those scout troops register as a group, or as individuals, would impact on the overall number of charities.

The Chairperson:
HM Revenue and Customs lists 5,000 charities; where does the figure of 9,000 come from?

Mr Murray:
The Department also uses the Northern Ireland Council for Voluntary Action (NICVA) annual ‘State of the Sector’ report to estimate the number of charities that are operating. The current report puts the number of charities closer to 9,000. The potential addition to that figure due to charities run by Church bodies and the like, as I have mentioned, creates the difference between the figures of 9,000 and 12,000.

The Chairperson:
To clarify: 9,000 charities are included in the latest NICVA annual report and 5,000 have been listed by HM Revenue and Customs. Is it fair to assume that the remainder have not applied for tax benefits with HMRC, and are they likely to be much smaller charities?

Mr Murray:
Yes. Charities may not apply to HMRC for tax benefits for a variety of reasons: the benefits gained may not be worthwhile; the charities may not be interested in gift aid; or perhaps there would be a point of principle involved.

The Chairperson:
In general, is it accurate to say that half of the charities would be large enough to be involved with HM Revenue and Customs in order to gain charitable status and the other half would be too small to benefit from such a status?

Mr McGrath:
That is a fair reflection of the situation. One of the problems faced in Northern Ireland is that there is no register of charities.

Mr Craig:
I read with interest that there would be no exemptions from registration in Northern Ireland. In England and Wales some exemptions are being considered.

There is also the specific intention that Church-based charities should register. Perhaps that explains the confusion over the number of charities that exist. Some churches are centralised. For example, in the Baptist Church system, every church is an individual entity, therefore hundreds of churches would have to register individually. Could the validity of putting churches on the register be reconsidered, given the complexity that might result?

Mr Murray:
The view is that there should be a level playing field for all charities regardless of their nature or function. If there is the potential for exemptions as regards certain charities, there may be a grey area created in Northern Ireland, and the Department is seeking to avoid that situation. A record of all charities operating in Northern Ireland is required.

The scale is substantially different in England and Wales, where there are approximately 135,000 charities registered. In Scotland, all 23,000 charities, whether Church based or not, are expected to register. The view has been that Northern Ireland should seek to do likewise. The Republic of Ireland is also progressing legislation, and it has no exemptions for any body. The diocesan boundaries of some Church-based organisations mean that they operate across the border, and they could operate on an all-island basis. It is important that our approach is consistent.

Throughout the consultation process, the Department reassured the Church bodies that it will work with, and support, them. Church organisations that are structured around a central body must decide whether they wish to register as charities. Those bodies must ask themselves whether they want to do that, whether it is in their interests and whether it is valuable and beneficial. If they choose not to register as charities, they will not be entitled to call themselves charities and seek the benefits that charities may have.

The Chairperson:
The Electoral Commission examines political parties’ accounting units, which are quite small and equivalent in size to small charities, and deals with them much less rigorously because of their lack of activity. Might the Department insert a similar provision in the Bill so that small charities that have relatively less activity would be subject to a less rigorous registration process?

Mr Murray:
That issue arose from our first consultation process. Several smaller charities, including the Church-based charities, were concerned about the threshold levels for reporting. The Department took that on board when the draft Bill was being finalised, and the threshold was raised to include organisations with a gross income of less than £100,000. Therefore, the reporting requirement level is much lower.

Mr Hilditch:
Some people have negative attitudes about quangos. In the light of that, what size will the commission be, and how will it be staffed?

Mr McGrath:
Depending on the size of the workload, the Department estimates that the commission will have a chairperson, a deputy chairperson and between three and five members. It would be a non-departmental public body (NDBP) and, therefore, a quango. The membership appointments would be treated as public appointments and overseen by the Office of the Commissioner for Public Appointments. It is estimated that the commission would have an initial staff of around 16. The annual running costs would be some £800,000. That was previously tested by at least one of the direct rule Ministers with responsibility for social development, and it was decided that if there were to be a commission, it would have to be effective. A critical mass of activity and expertise was needed. It was expected that the commission would be up and running earlier, so there is a budget provision for it in the Department’s baseline.

Mr F McCann:
How will the commission be made up, and how many staff will it have? Will there be winners and losers?

Mr McGrath:
As I said, there will be a chairperson, a deputy chairperson and between three and five members.

Mr F McCann:
From where will the membership come?

Mr McGrath:
They will be public appointments. The posts will be treated as significant appointments and will be overseen by the Office of the Commissioner for Public Appointments. All posts will be advertised. I suspect that the Department will want to bring in some expertise from charity commissions elsewhere to advise us on the appointment process.

Mr F McCann:
Will there be winners and losers? Will some charities lose out?

Mr Murray:
Some organisations were concerned that they would fall out of the process because of the public benefit test. The Department has reassured those organisations that the vast majority of charities that are currently perceived as being charitable organisations and have sought recognition by HM Revenue and Customs would have no problem in meeting the public benefit test. In many ways, the public-benefit aspect acts as a safeguard against difficult decisions or questions that the charity commission may face.

The short answer is that there should not be any losers; it is beneficial if charities publicly demonstrate the value that they give to the community and account for the money that they receive from the general public. That is quite clear. The charity commission is there to provide assurance to the public and to raise the level of confidence in charities so that the public is more likely to make donations — so there is a benefit all round. We cannot see any losers in the equation, but who knows what the future may hold?

Mr F McCann:
We have all come across major charities of which it is said that 80% of their money goes on administration; they are more like businesses than charities. Will this impact on them?

Mr Murray:
We propose that all charities will be required to make returns on their financial performance and activities over the financial year. One of the roles of the charity commission will be to carry out checks to see what proportion of the money actually goes on the service. Where the charity commission has a concern about the balance between running costs and the delivery of the service, it has the potential to examine further. In addition, the publication of the charity commission’s reports means members of the public will be able to see the facts and make their own decisions. If they see that 80% of the money that they have given has gone to the charity’s overhead costs, the next time that they want to give, they can raise a question about that, so there is a dual aspect to it.

Ms Lo:
I presume that the 5,000 charities currently registered with HM Revenue and Customs will register with the new commission. However, as was mentioned earlier, there is a number of organisations here that may not want to register with the commission because they are so small. I am thinking of small residents’ groups. Will they be very disadvantaged in future if they are not registered with the commission?

Mr Murray:
The only disadvantage will be that those organisations will not be able to call themselves a charity in Northern Ireland terms. Tax is a reserved matter. An organisation could still apply for recognition from HM Revenue and Customs if it desires, and HMRC may consider approving it. However, one would assume that if the charity commission in Northern Ireland did not consider a particular organisation to be a charity, there would be some read across because the Department and HMRC worked very closely on the drafting of the Bill.

The only disadvantage to small organisations that chose to opt out, for whatever reason, is simply that they could not call themselves a charity, and that may impact upon their ability to attract funding or grants.

Miss McIlveen:
With regard to the consultation last year, I note that there were only 97 responses, and yet there are about 9,000 to 12,000 charities. Just how broad was the consultation, and how many of the responses were taken on board?

When I looked through the comments on the results of the consultation, I saw a lot of phrases such as “We are not minded to do so”. There is very little there that the comments are actually positive about.

The Chairperson:
A 1% response rate does not seem very high.

Mr McGrath:
I have seen worse.

Mr Murray:
I suppose that we were quite satisfied with our consultations — often the level of response to consultations is quite limited. We went through a process of sending out documentation to as wide a field as possible; importantly not just to the charitable and the voluntary and community sector, but also much more broadly than that. The charitable issue is much broader than simply the charitable or voluntary and community sector organisations, so we spread our consultation as far as possible.

We also engaged in a series of workshops across Northern Ireland, which were advertised and allowed people to come along, to raise questions and to talk through both the proposals. We then embarked on the same process of circulating information and running a series of workshops for the original draft Bill that went through to Westminster, addressing issues in the Bill itself. We had a number of meetings with individual organisations, and we were open to requests from any organisation that wished to meet with us. The churches in particular came along, and we met to talk through issues with a number of the senior Church bodies in Dublin and Belfast.

The Department tried to be as open and receptive to as many questions and issues as possible. We took on board two major issues. Major concerns were raised about the accounting issue; the other was the Church’s request for the continuation of exempt status. We discussed that and felt that a level playing field should be maintained. Many of the other issues raised were of a minor or technical nature, and some of the technical issues were useful in helping to finalise the original draft, but they were not substantive in the consultation process.

Miss McIlveen:
Will it cost anything to register?

Mr Murray:
No.

Mr McGrath:
The Department regards the Bill as being primarily about protecting the public, so the 9,000 organisations are not the only stakeholders. In certain cases the level of response suggested that, in general, the charity sector was signing up for this and expecting it to come. As Fra McCann said, it is important to remember that we are primarily trying to protect those who give money, and through that to protect the bona fide organisations.

The Chairperson:
Earlier you made reference to the Northern Ireland Affairs Select Committee’s concerns regarding the protection of the public. Will there be any preclusion of those with criminal or terrorist convictions from registering or being involved in charities?

Mr Murray:
In the draft Bill there are provisions that outline eligibility and disqualification criteria for trustees. Only those people convicted of financial irregularities are excluded; it does not preclude those who have committed other offences. During the consultation, the point was made that ex-prisoners are already involved in a number of charities, which would make it difficult to exclude them.

Mr Brady:
Under your proposals, an organisation will be defined as a charity if it:

“is established for charitable purposes only [and] is for the public benefit”.

Article 4 gives a list of charitable purposes, which presumably includes public benefit. Is that a finite list, or can it be added to? Legislation that has been passed is quite difficult to change.

There is also a proposal for a charity tribunal for Northern Ireland to be established to hear appeals against some types of decisions. Would that be an independent appeal system, or would it incorporate members of the commission?

Mr Murray:
Regarding the list, the Committee and the Assembly will obviously have the opportunity to debate the Bill. The list is an expanded and more detailed version of the original four headings that are in the existing charities legislation. Members will see that there is provision under sub-paragraph 4(2)(l) for “any other purposes within paragraph (4)”, which is a catch-all measure. It is fairly broad in its nature; we have sought to give a sense of types of organisations with which the person on the street can identify.

We have had ongoing discussions with the Northern Ireland Court Service about the tribunal. The Court Service is establishing a centralised process for tribunals, and it has given the charity commission the opportunity to work through that process once it has been established.

As a first step, the charity commission would consider any appeals of an administrative nature — if the proper administrative process has been applied, if a proper decision has been reached, and so on. Beyond that, it would go to the tribunal for consideration. It would be independent of the charity commission for Northern Ireland.

Ms Lo:
The smaller organisations may feel that it is not worth their while to register. Do you intend to help them with their constitutions, training, and governance so that they can register with the commission? Will the new commission advise and support staff of non-registered organisations so that they can register?

Mr McGrath:
Part of the commission’s job will be education facilitation to explain the requirements and perhaps have open discussions about the advantages or disadvantages of registration, so help and advice will be available. It is a watchdog — but a helpful one for small organisations that wish to go through the process.

Mr Murray:
The commission will have a role in providing guidance and advice. Once the legislation has been passed, the process will be incremental — registration will not be immediate but will work from the largest charities down to get the system up and running. The commission will provide advice, promotion and guidance to enable organisations. NICVA, the volunteer development agency — with which Anna will be familiar — and community change have roles in providing training, advice and guidance on governance and trusteeship to the sector organisations. Those bodies have a key role in helping people to set up organisations.

Ms Lo:
Insurance is a big problem for many smaller organisations; trustees’ indemnity insurance is very expensive. Will organisations have help with that?

Mr McGrath:
Not specifically. All organisations, once registered, must have proper governance and appropriate insurance cover. That is a separate issue.

Mr Murray:
That would be beyond the remit of the new charity commission, although there have been discussions at a senior level in the UK Government about insurance for the voluntary and community sector. We have been feeding into that process, but the commission would have no remit for that.

The Chairperson:
NICVA has expressed concern about the possibility of conflict between the advisory and regulatory roles. How might that might be resolved or is NICVA mistaken?

Mr Murray:
It is a matter of how the “friend and policeman” roles rub along together. The first and foremost role of the charity commission will be as a regulator; that is its function and purpose. Its advice and guidance must be in its role as regulator, and it must be careful not to move beyond the role of advising on how to meet the requirements under the legislation or how to improve performance or governance.

NICVA is a support organisation, so its remit is much broader than that of the proposed charity commission. NICVA’s role is support rather than legislation, and we have discussed that with it.

Mr Burns:
It is interesting to talk of the charity commission and the Bill; I am just coming to understand it. My concept of a registered charity was of groups gathering money to give to a good cause, and that there were no tax implications. I believed that to be their main function, but much more is involved than raising money. Will community groups and other organisations be registered as charities for tax purposes? Are we going to close in on those groups? What is the real purpose of the Bill?

Mr McGrath:
The main purpose of the Bill is to protect the public, as there is no formal register of charities. At the moment, if someone is stopped in the street and asked to donate money to a small organisation, or one that is unknown, there is no “kitemark”, or indication as to whether the organisation is bona fide, or has been validated as doing good work, and entitled to seek public donations.

Many charitable organisations, such as Barnardo’s and the NSPCC, are known because they are large and reputable. However, many small organisations do very good work, but are not registered because no registration system is in place. Such a system is necessary, so that those organisations can be validated and given the strength to demonstrate that they are charities, that they are registered, and that they have a reference number that can be checked with a charity commission.

The purpose of a registration system is to safeguard the public and enable the smaller, less well-known organisations to raise funds in a more stable and secure way.

The Chairperson:
It is unfortunate that the vast majority of charities, which are law-abiding and engaged in worthwhile causes, as mentioned by Mr Burns, will be subject to the same regulatory regime as the very small number that, possibly, have abused their charitable status and broken the law.

Mr McGrath:
There may be bona fide charities that still do not have the right balance between administration costs and giving out money; such charities are worthy and well intentioned, but may need to be regulated.

Mr Burns:
People must register with their local council if they want to collect money for charity. To gain permission to hold a prize draw, for example, a charitable organisation must register that draw with the local council. Each ticket should state that the draw has been certified by the relevant council. Therefore, some regulations exist.

Mr McGrath:
That means only that the council has given permission for an organisation to collect money on a given day.

Mr Murray:
That is a separate legislation matter and relates to raffles. Raffles are governed by gaming and lottery legislation, which also covers tickets, ballots and, for example, the National Lottery. However, public collections, where someone stands in the street rattling a tin can or asking people to sign up for direct debits, fall within the ambit of the proposed legislation. Under the current system, charities apply to the PSNI for approval to collect money in a particular area, or they could apply to the Department for overall exemption.

Organisations, such as the British Red Cross, carry out an annual collection and are given overall approval by the Department.

The proposed legislation will provide for a system of permits whereby the charity commission will examine the bona fides of an organisation to see if it is fit to carry out a collection. In addition, a system of licences, initially applied for through the charity commission, will allow charities to collect money on particular days. The issue is important, because sometimes two or three charitable organisations may be collecting money in the same area. Therefore, there must be some kind of overarching view of the process.

The proposed legislation provides for councils, at a later stage, to issue licences to permit public collections. Importantly, those proposals will additionally cover “black-bag” collections. There has been a high level of media coverage concerning illegal “black-bag” collections. People have been asked for goods that, subsequently, have not been passed on to charities; instead, they have gone to private businesses. There is a genuine concern about that, and the charity commission will address it.

Mr F McCann:
Many community groups apply for charitable status to gain exemption from VAT. Will the proposed legislation impact on them?

Mr Murray:
VAT is a separate issue that has no bearing on an organisation’s charitable status. How an organisation is established, and whether it is VAT-exempt or VAT-discounted, is a separate issue. There is no relationship between the two.

With regard to community organisations, community development will be covered in the definition of charitable purpose in the Bill. A community group could apply for charitable recognition and could apply to HM Revenue and Customs for tax benefits.

Mr F McCann:
One usually led to the other. If people had been given a number for charitable status, they would be able to apply for exemption from VAT.

Ms Lo:
That is not the case.

Mr Murray:
The guidance on VAT is a minefield, but there is no direct read-across between VAT status and charitable status.

Ms Lo:
Many charities do not get exemption from VAT. The process is too complicated.

Mr Brady:
Apparently, professional fund-raisers are not closely regulated. For instance, the hospice in Newry has an in-house, professional, fund-raiser — a person who is employed specifically to raise funds. I have worked in the voluntary sector for several years, and I know that many organisations have wondered about employing people to raise funds. Those organisations constantly chase their tails as they try to raise the funds to keep going. I hope that a distinction will be made between in-house, professional, fund-raisers and external companies that undertake — for a fee, I presume — to raise funds for a particular charity. Such companies must be answerable to the charity for which they work at any given time.

Mr Murray:
You are correct in your presumption. The legislation seeks to provide regulations to cover individuals who are employed as professional fund-raisers. That is to protect the charities, because sometimes they might have to, or be encouraged to, employ someone to raise funds. At present, the guidance on that may not be clear, so the legislation covers the legal contract between the charity and the professional fund-raiser. In addition, the professional fund-raiser will be required, if asked, to state that he or she is a professional fund-raiser, employed by the charitable organisation, and what percentage of the money he or she will receive, so that the public is aware of that.

Mrs McGill:
I thank the witnesses for the briefing. As John McGrath said, the issue is about protecting the public. However, we do not want to smother the good work that many charities do. I am concerned, in particular, about smaller organisations that do occasional charity work.

John McGrath spoke about fund-raisers who approach people in the street. I take it that they have to wear an identity badge. The legislation may provide for that. However, to return to Fra McCann’s point, will those fund-raisers be required to state clearly that, for example, 80% of what we give them will go to the cause and 20% will go towards costs?

Mr McGrath:
We have not yet reached that level of detail; however, the proposed commission may give guidance on that point. Obviously, it is good practice for any organisation to reinforce the point that its administrative costs are kept to a minimum.

The Chairperson:
This concerns transparency. The public should know what percentage of its money will go to the charity.

Mrs McGill:
There is a gap. Charities are often organised like businesses, and some of us completely misunderstand how much money goes into their organisation. It is important that the public knows how much money goes directly to a charity’s cause.

Mr Doyle:
The Bill requires professional fund-raisers to indicate in any literature what percentage of the collection, or the funds raised, they will take.

That aspect of fund-raising will be reflected in a charity’s annual returns. Under the proposed legislation, those returns will be open to public inspection. When the annual return is published, the public will be able to see how much money goes to professional fund-raisers.

Mrs McGill:
That is all right. However, when people are approached in the street, they are unlikely to read the literature.

Mr McGrath:
That is an interesting point, which perhaps should be picked up if the Bill goes through. Fund-raisers for an organisation may be volunteers, rather than professionals.

Mr Craig:
On the matter of public charitable collections, it is proposed that the charities commission will issue permits, which the PSNI currently grants. I am aware of conflicts that have arisen at major events, because one organisation has been given permission to collect, when the organisation running the event wished to collect for the charity it supported. Those things happen and, when they do, it is very embarrassing. The intention is, in the long term, to transfer that responsibility to the councils, which — nine times out of 10 — are the organisers or sponsors of major events in their areas. Would it not be wiser to do that from day one?

Mr Murray:
As I outlined, the charity commission will issue the permit, which provides the authority to take up collections. The licence to perform the actual collections will, initially, be issued by the commission; however, there is provision in the legislation for councils to pick that up. We have left that door open, because we are currently engaged in the review of public administration (RPA). Given their local knowledge of what is happening, and of how collections should take place, councils have an important role. The opportunity for them to assume control is there, but how quickly the commission can move to that position will depend upon how it engages with the councils, and their appetite for such engagement. The presumption is that to indicate that councils should have responsibility from day one is to move too quickly.

Mr Craig:
There is no question that the timescale for the review of public administration will slip. Will the Department rethink its position in the light of that?

Mr McGrath:
The Bill will come through, and there will be opportunities for debate and discussion, particularly around this table. Given the time frame for the RPA, that is a fair point.

The Chairperson:
Thank you, Mr McGrath, Mr Murray and Mr Doyle. The Committee Stage of the Bill is likely to begin on 27 June 2007, and you are scheduled to give evidence to the Committee on 5 July. We look forward to seeing you then.