Member

Secondly, Clause 5 currently requires the Secretary of State to issue guidance to applicants to assist them in complying with requirements under Section 48 and best-practice guidance covering all aspects of pre-application preparation. This reflects the Government’s overarching objective to ensure that robust applications are prepared in a proportionate way. Amendment 36 would remove the provision relating to Section 48 guidance and seeks to narrow the scope of guidance to engagement alone, while including a list of suggestions for the guidance itself. This would be a step backwards. Introducing guidance solely on how to engage with stakeholders risks reintroducing the concerns regarding applicants gold-plating—something the Government are seeking to address. Instead, guidance should focus on the Government’s overall objectives, which are how to prepare robust applications in a proportionate way. That of course includes engagement, and its importance has been outlined by the Government. However, this guidance should not be restricted and risk the repeat of behaviours we are keen to avoid and the lack of flexibility within the system.