My Lords, I would very much like to follow up on a number of the points that the noble Lord, Lord Hodgson, made so clearly. First, I welcome these regulations. Clearly, they are important pieces of secondary legislation. They are really important in terms of making sure that energy contributions, subsidies and public payments reach the people they need to reach. The questions I am going to ask are not a prosecution, if you like; I want to understand how some of this is going to work. I recognise fully the difficulty that the Government might have in finding a way to make this work.
First, what is the size of this problem? Does the Minister have any indication of the number of households that, in effect, have their landlords pay their electricity and energy bills? I do not know whether he has any idea what that is.
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The next question that tested my knowledge when I read through the instruments is how the domestic electricity retailer that feeds the landlord knows how many subtenancies or households there are to which that payment needs to be distributed. The gap in my knowledge came by taking the example of a mobile home park. I have done some casework in this sector; there are some not very good landlords in it. Those home parks are often not on direct supply; it goes through the landlord. So how does the electricity supplier, which is an intermediary for the Government, know how many units there are and what the payment to the landlord should be? I do not know how we have that information or who would have it. Surely the scheme should make sure that each of those home park owners receives the full amount of money. Many of those parks have 50 to 60 homes; are we going to divide £400 or whatever it is between 60 people? That is what I am trying to understand.
Thirdly—the Minister answered this to a degree—I found the instructions on how the payments are to be allocated or made impossible to understand, if I am honest. I understood the Minister to say that there would be straightforward communication with landlords. I do not know who knows who are landlords and who are not. That would be interesting to understand but I presume that there will be an easy, straightforward explanation of how this disbursement scheme should work.
Coming back to the area where the noble Lord, Lord Hodgson, started, how do we make sure that final consumers know that this scheme exists and that they are entitled to it? You have this asymmetric relationship between tenants, whether industrial or domestic, and landlords.
My final question comes down to how we are going to make sure that this is practically enforced. I come back to the mobile home park; in a certain part of that sector, landlords are very reluctant to pass anything on to their tenants. The history of that sector is not good for a number of landlord owners, some of which are national organisations. It is important that final consumers understand what they are entitled to. I would be interested to learn more about that communication system.
Again, coming back to what the noble Lord, Lord Hodgson, said, the fact is that, if they do not receive this—I read about a six-month time limit somewhere—they have to go through a debt procedure. Even if they win that, there is an interest rate of 2%, which is nothing really. To me, it ought to be a criminal offence if landlords wilfully avoid passing these payments on to their tenants. It is a form of fraud and I have no doubt whatever that there will be many examples of it. I understand the Government’s difficulty in delivering this but there needs to be a concentrated effort to make sure that people are aware of their rights and that it is clear how the system works.