My Lords, I have a few preliminary remarks. First, as I usually do, I find myself in almost total agreement with everything that the noble Baroness, Lady Finlay of Llandaff, had to say. I re-emphasise the importance of the whole issue of carbon monoxide poisoning. My second confession is that I returned to this country from abroad only this morning and I had not seen these regulations until my noble friend Lord Marlesford drew my attention to them. Thirdly, I think that I have to declare an interest in that I am a tenant of premises that fall within the definitions here. The new regulations may or may not apply to me. There are certainly carbon monoxide and fire alarms in the building and on the upper floor. I do not think that there is an installation on the ground floor that may come under the definition—although it is virtually never used. However, the regulations may not apply in my case because they will apply only to tenancies that come into effect after 1 October. I think that I will be renewing my lease within the next day or two because my landlord and I have already agreed the terms. However, I will hasten to tell my landlord that we may have such an appliance.
My anxieties are like those of my noble friend and I begin, as he did, with the recommendation of the Secondary Legislation Scrutiny Committee. I began to wonder exactly how far the consultation had advanced. The Minister referred to some initial consultations, which I think took place in general a year or so ago. We are informed in the Explanatory Memorandum that during those consultations, which took place between February and March 2014, there were 299 responses to the question on smoke alarms. “A regulatory approach”, we are told,
“was supported by Fire and Rescue Authorities, industry representatives and over 96% of landlords, agents and fire officials who responded to the paper”.
I am glad that they did respond to the paper, but quite clearly if only 299 responded, it does not necessarily indicate that there was—or even now is—a widespread awareness of what has happened in terms of consultation. I do not think that my noble friend the Minister gave us any real information about that.
The scrutiny committee did give us some quite useful information in an appendix. We were told in appendix 1 that the Department for Communities and Local Government,
“intend to update a core set of guidance documents”.
The guidance documents are listed: the How to Rent guide, the industry code of practice, the model tenancy agreement, and the Renting a Safe Home guide. We are entitled to know whether those have all been updated, when and in what way. I would certainly be grateful for that information.
The appendix goes on to say:
“In addition to updating current guidance, we plan to use our partners and the media to communicate the regulatory changes. We have already communicated the key message through press notices”.
I wonder how many people in the business world actually read the press notices on matters such as this, issued even by so great a department as the one in charge of these regulations. It says that we,
“are working with our partners: lettings agents, landlord representative bodies, local authorities, fire and rescue authorities and alarm manufacturers to publicise the requirements over the next 6 months”.
What we really are entitled to know—this is what the scrutiny committee really demanded—is exactly how far that consultation and dissemination of well-publicised advice has gone. I do not think we heard very much about that, with great respect to my noble friend the Minister, in her introduction.
Before we approve these very important regulations—even if it is only a first step, as the noble Baroness suggested—we should know exactly what has been done to ensure that they are widely understood. I am quite certain that my very nice landlord, who is currently renewing the lease of my property, has no idea about it. I am not criticising him for that because I had no idea at all about it until my noble friend Lord Marlesford spoke to me less than an hour ago. I suspect that that situation would be found up and down the country. If we are to approve regulations that are to come into effect in three weeks’ time or something, we should have rather better information than we have been given so far.
4.30 pm