Genetic Technology (Precision Breeding) Bill

Baroness Hayman of Ullock Excerpts

Committee stage
Wednesday 14th December 2022 Lords Chamber

[Baroness Parminter (LD)]

My Lords, I did not mean to speak on this group, but it deals with delegated powers and the powers the Government take upon themselves in relation to other bodies—in this case the national Parliament.

Since we met on Monday, there has been a development concerning the state of the Bill in the country more broadly about which I wanted to ask the Minister, and I think this is the best place to do it. Since Monday, when the Minister referred to the ongoing discussions with Scotland, Scotland has tabled a memorandum to withhold consent to this Bill when it becomes an Act. Although it has only so far been tabled, clearly, with the SNP in a majority in the Scottish Parliament, it will pass. The Minister talked about ongoing discussions. Can he tell the Committee what the Government’s strategy is with regard to Scotland? Do they intend to try to reach consensus through the common framework, or to force the Bill through using the internal market Act?

[Baroness Hayman of Ullock (Lab)]

My Lords, I am grateful to the noble Baroness, Lady Bakewell, for tabling her amendments in this group. They all seek to upgrade certain regulation-making powers in the Bill from the negative procedure to the affirmative. I am also grateful to the noble Baroness, Lady Bennett, for bringing forward her concerns about the Henry VIII powers which could be used in this Bill and to which other noble Lords have referred during our discussions.

The main thing for us to raise here is that, once again, we are concerned about the sheer amount of work being left for the months and years after the Bill makes it on to the statute book, and the lack of parliamentary involvement when these instruments are eventually brought forward. During Monday’s debate, the Minister made it clear that it would take years to put the core regulatory structures in place and extend the regime beyond its original focus on crop plants. During this time, there could be significant changes such as new scientific analysis, changes in market conditions, developments in other jurisdictions and shifts in public perception.

The noble Baroness, Lady Bakewell, talked about the use of the negative procedure. The question then is, would making certain regulations subject to the affirmative procedure guard against all possibilities? It would not, but it would at least provide MPs and Peers with regular opportunities to share their views.

We have already had discussions about the welfare advisory body, including the form it may take and the functions it will fulfil. We know that colleagues across the Committee are understandably anxious about getting this right, yet the proposal is for the Secretary of State to designate key animal welfare responsibilities to an as yet unidentified committee or body through a negative SI.

I will listen to the Minister’s response to these amendments with great interest and hope that, at the very least, we can have more information about this ahead of Report. The power to make consequential provision is a standard inclusion in legislation, but we also accept that drafting often makes the power appear unnecessarily broad. It would be helpful if the Minister could provide any examples of what would or would not be permitted.

[The Minister of State, Department for Environment, Food and Rural Affairs (Lord Benyon) (Con)]

My Lords, I am grateful to those who have tabled these amendments. Before I reply to them, may I clarify a point I made earlier, as the noble Lord, Lord Winston, is in his place? When referring to CRISPR-Cas9, I was trying to respond to a point the noble Lord, Lord Cameron, made. That technology is fundamental to this Bill, and he was referring to where it took place. Of course, I meant to say that CRISPR will not be used on the farm. It is important to this Bill and will be used in laboratories that will have to be licensed under this mechanism.

Turning to the amendments tabled concerning changes to the parliamentary procedure for making regulations under certain powers in this Bill, I thank the noble Baroness, Lady Bakewell of Hardington Mandeville, for them, and I reassure her that these powers are administrative in nature and therefore do not require an increased level of parliamentary scrutiny.

Taking Amendment 26 first, the intended purpose of the power in Clause 4 is to prescribe details which are administrative in nature—for example, the types of persons who can be specified in a release notice, or the form such a notice needs to be given in. This is an important function as it will allow the Bill to operate as intended. Unnecessary scrutiny being applied to these administrative regulations through an affirmative procedure could delay the implementation of the Bill and reduce our ability to move quickly towards gaining the significant benefits the Bill has to offer. It would also make it more cumbersome for us to make technical adjustments to the requirements as to the form and content of the release notice and any accompanying information, to reflect developments in technology and industry practice. We do not believe that debating such technical and administrative details would be a beneficial use of parliamentary time.

Turning to Amendment 33, Clause 11 is clear that an application will be required to include

“a declaration that the notifier does not expect the health or welfare of the relevant animal or its qualifying progeny to be adversely affected … by any precision bred trait”.

It is also clear in this clause that the application will have to be accompanied by

“an assessment of the risks to the health or welfare of the relevant animal or its qualifying progeny”

and an explanation of the steps taken to identify these risks. These key requirements are set out on the face of the Bill. The delegated powers merely allow Ministers to prescribe further details in relation to these applications, which will be more administrative or technical in nature.

Regarding the amendment to Clause 18, I reassure the noble Baroness that a list of matters which could be included on the register is set out in the Bill. This list includes, but is not limited to, information relating to the release and marketing notices, reports from the advisory committees and enforcement notices.

This clause therefore enables information on a wide range of matters relating to precision-bred organisms to be made public, in the interest of transparency and public reassurance. Specific details of the information to be entered in the register are an administrative matter.

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Moved by

[Baroness Hayman of Ullock]

56: After Clause 25, insert the following new Clause—
“Release and marketing of precision bred animalsA person may not give a release notice to the Secretary of State in relation to the release of a precision bred animal (see section 4(1)(a)), and no precision bred animal marketing authorisation may be issued (see section 13(1)), until—(a) 12 months have passed since the date of the establishment of the Animal Sentience Committee under section 1 of the Animal Welfare (Sentience) Act 2022, and(b) 6 months have passed since the date on which the Animal Sentience Committee has made to the Secretary of State a report on the provisions of this Act.”Member's explanatory statement
This new Clause would delay the release of precision bred animals for at least 12 months after the Animal Sentience Committee established under the Animal Welfare (Sentience) Act 2022 has been established and at least 6 months after the Committee has reported on the impact of the Act on animal welfare.

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[Baroness Hayman of Ullock (Lab)]

My Lords, I have two amendments that make up this group. First, I will look at Amendment 56. Clause 10 defines a relevant animal as a vertebrate for the purposes of the welfare protection measures in Clauses 11 to 15. This is in line with the definition of an animal in the Animal Welfare Act 2006. With Amendment 56, I am interested in looking at the relationship between the Bill and the Animal Welfare (Sentience) Act 2022, which some of us were involved with. I thank my noble friend Lady Jones of Whitchurch for her support in this. That Act defines an animal as

“any vertebrate other than homo sapiens … any cephalopod mollusc, and … any decapod crustacean.”

Noble Lords may remember that during the passage of that Act, we debated the definition, particularly regarding the scientific evidence for the sentience of cephalopod molluscs and decapod crustaceans, and eventually they were included in that definition. Our concern is that, despite that, Clause 10 continues to define animals only as vertebrates. We also note that the clause does not exclude Homo sapiens explicitly: my noble friend Lord Winston has previously made that point. Basically, what we are trying to achieve here is to align the definitions in the Bill with the most recent piece of relevant legislation that has gone through the House.

The clause also makes provision for the Bill’s definition to be extended to include invertebrates if the Animal Welfare Act 2006 is extended to include them. Therefore, we have a rather confusing situation where we have two different definitions of animal in law, one from the 2006 legislation and one from the very recent legislation. As an aside, given that the Government’s aim with the Animal Welfare (Sentience) Act is to recognise the sentience of animals in law, it is kind of surprising that the Animal Welfare Act has not been extended to reflect the Government’s latest position on this. Regardless of that, we think that the Bill should use the most up-to-date definitions and allow for any new legislation to be properly established in this area.

My noble friend Lady Jones of Whitchurch mentioned at an earlier date the situation regarding the animal sentience committee. The Minister confirmed that it does have a chair, but it is not yet fully established, and the Minister did not adequately answer the question as to when we are likely to see it up and running. What is the point in having a chair if you have no committee?

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[Lord Harlech (Con)]

All I can say at this stage is that it will be as soon as possible.

[Baroness Hayman of Ullock (Lab)]

I thank the noble Lord for ploughing through that. I want to make the same kind of point the noble Baroness, Lady Parminter, made. All the while we do not have anything published and we do not know about implementation periods, the whole thing is a bit pointless. How can you have “due regard” to something you do not have in front of you, and if you do not know the timescales? It is quite frustrating. The sooner we can get all of this sorted and the Minister can give us some more timescales and dates, so we know what is going on, the better. I am sure we will be returning to these issues on Report, but in the meantime, I beg leave to withdraw the amendment.

Amendment 56 withdrawn.

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In the past, we have had lots of problems of misusing feed. We are waiting for another crisis—and then of course people will take an interest. The reason why the FSA was set up is that there was a crisis that was not dealt with because the department was too involved in providing benefits to the producers and forgetting the consumers. In this case, consumers are entitled to know and trust that the food and feed produced from precision-bred organisms is safe, but how can they if we are just dealing with skeleton clauses and we have government by diktat? Of course, that was the title of a report last year and it is what we have—Government by Diktat. Could the Minister explain to us why they have decided to introduce skeleton clauses but not admit in the delegated powers memorandum that those clauses are in the Bill?

[Baroness Hayman of Ullock (Lab)]

My Lords, much has been said during our debates about the strength of the food and public health measures in the Bill but also about the fact that the Food Standards Agency is going to have a role to play in ensuring that any precision-bred organisms that reach our supermarket shelves are adequately regulated.

Our concern is about the wording as it currently stands because, although it confers on the Government the option to create a provision for regulating the placing on the market of food and feed produced from precision-bred organisms, it does not make that mandatory. In other words, although the Bill makes the regulation of precision-bred food and feed a possibility, it leaves it open to the Government not to take up that power should they not desire to do so.

That is why I have added my name to Amendment 57, of the noble Baroness, Lady Bennett, which would change that subsection’s language from “may” to “must” so that the Government would be mandated to take up the power; it would not be an option—and likewise with her Amendment 58. I thank her for her thorough introduction to her amendments.

We also support Amendment 60, in the name of my noble friend Lady Jones of Whitchurch. This part of the Bill proposes to introduce powers that will empower the FSA to create a proportionate framework for regulating precision-bred organisms. If approved, the framework will form the basis upon which precision-bred food and feed products are to be authorised and placed on the market in England. That is one reason why I tabled Amendment 63; I felt it was important that we understand what preparatory work has been undertaken on the planned food and feed register and whether there is likely to be any further consultation on it.

As my noble friend Lady Jones has said, the FSA is already under financial and resource pressures. The noble Lord, Lord Krebs, asked an important question: what happens, what are the implications, if there are no new resources for the FSA? My noble friend Lord Rooker raised some serious and important points and questions that need to be answered. I will be interested to hear the Minister’s response to those points.

[Lord Benyon (Con)]

I am grateful to noble Lords and I will start by answering some of the points that were raised. First, I make it clear to the noble Baroness, Lady Bennett, and all noble Lords—I think we are all interested in this—that the precautionary principle is at the heart of the Environment Act and our desire to reverse the decline in biodiversity and the tragic loss of species, with no net loss by 2030, and our provisions in the 25-year environment plan. I am not sure that the precautionary principle in recent decades has been particularly well used in relation to what it was originally defined as, and we want to get back to making sure that we are committed to a proportionate, science- based regulation that protects people, animals and the environment.

On the question of the Food Standards Agency and its resourcing, I have had regular meetings with the chair of the FSA and other senior officials as we have progressed this Bill through both Houses, and I have been assured that precision breeding will remain an important area of work now and in future and, as such, the need to meet continuing resource requirements to support that work will be taken fully into account in future spending review bids.

On the point that the noble Lord, Lord Rooker, raised about a skeleton Bill, I fear that I may excite him again, but I shall say what I believe to be the case. The delegated powers are quite specific and technical in how they are intended to be used, so I would say that this is not a skeleton Bill. It has powers to supplement the principal policy measures that are set out in the Bill. I have some experience in the other place, and in my short time here, of legislation and how it can be Christmas-treed by MPs and others. I want to make sure that this is a precise piece of legislation, with as much in the Bill as can be, and that the powers that lie within it are technical and administrative.

I turn, first, to Amendment 57. As it stands, the Bill grants the necessary power to put in place a new regulatory framework for food and feed produced from precision-bred plants and animals. This will allow the FSA to continue to ensure that the food that we eat is food that we can trust. Until this new regulatory framework is in place, food and feed produced from precision-bred plants and animals will continue to be regulated under the regulatory regime for GM food and feed. So I can assure noble Lords there would not be a regulatory gap in relation to these products as a result of this Bill.

The FSA has published key papers over the past few months, giving details of its proposals on how food and feed produced from precision-bred organisms will be regulated. Noble Lords will also be aware of the support from the FSA board for this Bill and the letters we have received from the chair of the FSA board on this matter. The FSA has commissioned independent scientific advice from the Advisory Committee for Novel Foods and Processes, the FSA’s independent scientific advisory committee, to determine the appropriate means of regulating precision-bred food and feed to ensure that measures are in place to safeguard consumers’ safety in relation to food that they eat. The advice will recommend the criteria for determining how food and feed produced from precision-bred organisms will be assessed. In addition, scientific advice will be provided on the technical information that developers will need to provide to enable assessment under the new framework by the FSA. The Bill should not pre-empt this advice or unduly restrict our ability to implement the most suitable regulatory framework for these products.

Regulations setting up the regime developed by the FSA will also be subject to the affirmative procedure and would therefore need to be debated and approved by both Houses of Parliament. The FSA is committed to food safety and to developing a system that would be put in place by the Secretary of State, using these powers in a proportionate way that both supports innovation and protects consumers. This will deliver a proportionate regulatory framework.

I turn to Amendment 58 and reassure noble Lords that there are already well-established provisions in existing general food law that secure the traceability of all food and feed throughout the supply chain and assist with its recall or withdrawal from the market when it may be proved unsafe. Businesses producing or marketing food and feed produced from precision-bred organisms will need to comply with this existing law. The Bill gives Ministers the option to impose, by regulations, specific requirements to enhance traceability of food and feed produced from precision-bred organisms beyond existing traceability requirements. This provides flexibility to make adjustments to meet any future needs that are not covered by general food law. The FSA will advise Ministers in this regard and ensure that proposals are subject to a public consultation before any such measures are implemented.

I also thank the noble Baroness, Lady Bennett of Manor Castle, for Amendment 59. The primary policy objective of the Bill is to ensure that plants and animals developed using precision breeding, and food and feed produced from them, are regulated proportionately to risk. To do this, the Bill and the regulations to be made under it would remove precision-bred plants and animals, and food and feed produced from them, from the regulatory requirements applicable to genetically modified organisms. However, I take on board the noble Baroness’s concerns around thorough risk assessment and reassure her that any risk-assessment framework will be based on robust scientific advice provided by the Advisory Committee on Novel Foods and Processes.

The provisions in Part 3 of the Bill will allow the FSA to design a framework that adequately responds to the risk profile of precision-bred organisms and provide consumers with food they can trust, based on independent scientific advice. Detailed proposals for the future framework will be subject to full public consultation, as is required under food law, and the detailed scrutiny of Parliament through the affirmative process.

I turn now to the additional amendment from the noble Baroness, Lady Jones—Amendment 60. Following the UK’s exit from the EU, the FSA has expanded the expertise of its independent scientific advisory committees to assist with considering the range of possible food safety risks posed by new and existing technologies. This is reflected in the composition of the ACNFP and a new subgroup of that committee, which was formed to consider these issues. This committee can bring in wider experience where specific issues arise.

The FSA is committed to food safety. We have two former chairs of it in this Chamber and they can assert this. It has been active in bolstering the resources of its scientific advisory committees and I am satisfied that they have sufficient resources and expertise to fulfil their intended functions in relation to regulating the placing on the market of food and feed produced from precision-bred organisms, including undertaking risk assessments of food and feed produced by precision-breeding technologies.

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[Baroness Bennett of Manor Castle (GP)]

My Lords, Amendment 61 is in my name and those of the noble Baronesses, Lady Jones of Whitchurch and Lady Parminter. I thank them for their support. Both the amendments in this group take on the issue of labelling. Traceability and labelling very much fit together. I will quote one sentence from the Soil Association’s briefing on the Bill, which makes a really important point:

“The objectives of the Bill could be achieved with the inclusion of labelling and traceability.”


It is crucial to say that these are amendments that, much as I might not like it, accept many other parts of the Bill but say that the public and industries have to be able to see what is going on.

I already referred to the FSA’s study of July 2021. To quote another of its findings:

“Most consumers felt labelling should always inform the consumer of the presence GE ingredients”.


I also note that the Nuffield Council on Bioethics, BBSRC and Sciencewise’s Public Dialogue on Genome Editing in Farmed Animals found that consumers

“wanted products from genome edited animals to be labelled as such.”

We have before us two amendments that are similar but slightly different; the second one, Amendment 62, being in the names of the noble Baronesses, Lady Hayman of Ullock and Lady Bakewell. Either amendment would very much do the job. My Amendment 61 aims to be really clear and simple. It would give consumers information at the point of purchase, and although I fully understand the desire of the noble Baroness, Lady Hayman, to add further information about nutritional content, allergens and environmental impact, I suspect that we should be seeing that kind of labelling on all food, rather than specifically precision-bred food.

We can imagine what a so-called precision-breeding label might look like: a sticker that says “PB” in large writing with a little explanation underneath. Keeping that separate from the nutrition and environmental impact labelling in the interests of simplicity is an argument. Plus, saying that this should be added specifically to precision-bred food items but not to others does not quite add up, as far as I can see. However, I am not hugely wedded to that position, and I will interested to hear what the noble Baroness, Lady Hayman, has to say in this regard.

If we were to do a survey on the public’s concerns about this Bill, labelling is probably the issue about which we would find the most concern, as is backed up by the research I have already quoted. It is very clear and understandable, and people just want to know what they are eating. That has always been true and is increasingly true, given, as the noble Lord, Lord Rooker, said, some of the many scandals, problems and issues we have had with our food supply over the years. I beg to move.

[Baroness Hayman of Ullock (Lab)]

My Lords, I think it would be helpful for me to introduce my Amendment 62 at this point. We know that the Bill is going to create a new type of food product on supermarket shelves, the precision-bred organism, and is also clear that there is a trend among consumers to want more information about their food, what it contains, where it comes from and its environmental impact. All these things are important, and the noble Baroness, Lady Bennett, talked about traceability as well, so it is important that we have a discussion about how we achieve this, what we label, how it needs to be labelled and the impact of precision-bred organisms on future labelling.

Our Amendment 62—I thank the noble Baroness, Lady Bakewell, for her support—would require the Government to introduce regulations to ensure that precision-bred food and feed is labelled to provide sufficient information in certain areas. As the noble Baroness, Lady Bennett, has already said, that includes nutritional content, the potential presence of allergens and the environmental impact of the product, but it would also require the Secretary of State to consult stakeholder groups before pursuing that and to seek the advice of the Food Standards Agency. The Government have already said that they support nutritional labelling to inform consumers of any allergens or if the nutritional content of the food has been changed from its natural state. This is something we need to address in the Bill.

We are aware of the issues of coexistence with other production systems, supply chain tracing and how the legislation might have an impact on the organic sector. The noble Baroness, Lady Bennett of Manor Castle, has talked about the organic sector, and I am not sure we have had sufficient discussion in Committee so far about the potential impacts on that sector.

We also believe it important to consult on this issue, so that whatever labelling regime the Government decide to introduce allows for different types of food production to coexist. In the impact assessment the Government state that they oppose labelling in this instance, based particularly, I think, on the costs it would incur for businesses. I am sure the Minister can confirm those points. The impact assessment has not calculated the costs or benefits of labelling, so it would be helpful if the Minister could let your Lordships know how that judgment was reached.

I would like to draw attention to a couple of points in the impact assessment. In paragraph 114, the Government note that

“maintaining a labelling and tracing system could also have wider benefits, most notably, improved consumer confidence in food products potentially adding value across the food supply chain.”

We spoke at Second Reading and earlier in Committee about the importance of consumer confidence. The impact assessment also states:

“Given uncertainties … we have not monetised the estimated annual cost of a labelling and tracing system to business.”


This was also identified by the Regulatory Policy Committee, which stated in its report:

“The traceability and labelling costs, the primary benefit for the preferred option and which differentiates the two regulatory options considered, is not quantified. As this is the main difference between the two regulatory options, the Department needs to provide some quantification of the scale of the potential impact from this change.”


I would be very grateful if the Minister could comment on this assessment. Further to that, in its written evidence to the committee, the Nuffield Council on Bioethics noted that the Government’s present stance on labelling

“runs contrary to the findings of many public engagement initiatives that have broached this question ... in this context, not labelling amounts to the withholding of information about consumer preferences”.

The question I would ask the Minister and the Committee more broadly is: where do we go with this? How do we best provide the information consumers want in order to produce confidence in the system? It is not an easy question; there are no easy answers. But I do think we need to make progress.

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[Baroness Bakewell of Hardington Mandeville (LD)]

My Lords, the noble Baroness, Lady Jones of Whitchurch, has tabled this group of amendments to set up a genetic technology authority. The amendments are detailed and intended to ensure that the GTA operates effectively and transparently, and brings some measurement of results to the Bill. The noble Baroness spoke very eloquently and in depth to this group and to its purpose. For the ethos of the Bill to operate effectively, it will need a robust genetic technology authority to see it through. We have not heard just where the animal sentience committee fits in with the welfare advisory body or with ACRE. Are they to be dovetailed together or completely separate? There is a need for a properly constructed body to ensure safety and progress in outcomes.

There is little that I can add which will bring anything additional to this debate. We support the noble Baroness, Lady Jones, in these excellent amendments. Should the Minister not give a favourable response, we would be prepared to support her again on Report, should she so wish.

[Baroness Hayman of Ullock (Lab)]

My Lords, I thank my noble friend Lady Jones of Whitchurch for introducing these amendments. We fully support these proposals.

I would also like to comment on the amendment to Amendment 67, in the name of the noble Baroness, Lady Bennett. What she has done with her Amendment 68 is to aid our discussion and broaden it out. That is an important thing and we should consider it, but, as my noble friend said in her introduction, her amendments would be pretty fundamental to how we move forward with the Bill if the Minister were to accept them. It also brings forward an important way in which the Bill could be improved, and the implementation of the new technologies managed and overseen.

We know that, as my noble friend said, the genetic technology authority that she proposes is modelled on the legislation introduced to establish the Human Fertilisation and Embryology Authority. We heard earlier from my noble friend Lord Winston how successful that has been, so we should consider this extremely seriously. We know that a number of organisations in this field have either argued for or alluded to the need for the establishment of such a body. They include the Nuffield Council on Bioethics, the Royal Society of Biology and the Royal Society, as well as Doctor Madeleine Campbell of the British Veterinary Association.

There is no need for me to go into the details of why such a body is important, or how it could be set up and operated, as my noble friend has clearly and persuasively laid that out. I say to the Minister that this really seems to be a sensible, proportionate approach that would genuinely strengthen the Bill. I urge him to give it serious consideration and discuss it with his colleagues in the department as we move towards Report on the Bill.

[Lord Benyon (Con)]

I thank the noble Baroness, Lady Jones, for her considered and detailed proposal. As she says, this was raised by her colleague Daniel Zeichner in the other place. I would like to go over some of the key points on why we do not think that a new independent body should be established in the Bill.

We set out our plans for wider reform of genetic technologies regulation in last year’s public consultation and in the subsequent government response. We are taking a stepwise approach to developing a more proportionate governance framework in this area. As part of this, we intend to review how we regulate a wider range of genetic technologies and applications. This wider review is a more appropriate context for discussions on an overarching body, such as a genetic technologies authority. It is also consistent with a recommendation made by the Regulatory Horizons Council.

The Bill has a narrower but important ambition, which is to address the pressing issue of introducing more proportionate regulations for PBOs, which are currently regulated as GMOs. Science is already at the heart of this policy and the Bill rightly requires the Secretary of State to make decisions based on the advice of expert committees. ACRE, the committee that will advise the Secretary of State on whether they should confirm the status of a PBO, is also the committee that currently advises on genetically modified organisms. ACRE has considerable scientific expertise on precision-breeding technologies; indeed, it first advised on these techniques in 2013. This formed the basis for our intervention in a pivotal European Court of Justice case in 2018, and for the consultation that we held on the regulation of genetic technologies last year.

More recently, ACRE published technical guidance on the distinction between genetic changes that could have occurred naturally, or through the use of traditional breeding methods, and those that could not. This was warmly received by its target audience—that is, those planning to carry out field trials with plants developed using these technologies.

The guidance supported an SI that came into force in April. This was the first step to making regulations in this area more proportionate. This guidance and the scientific rationale behind it will be directly relevant to the advice required by the Secretary of State to confirm the precision-bred status of an organism before it can be marketed in England as laid out in the Bill.

We anticipate that ACRE may need to appoint or co-opt new members to fulfil its additional responsibilities. However, it is already populated by many scientific experts in the relevant fields. The chair of ACRE, Professor Dunwell, works closely with Defra and with the devolved Administrations to ensure that the committee has the necessary expertise to deliver the highest quality advice and guidance. Noble Lords will also see in ACRE’s framework document that many of the criteria listed in the proposed new schedule are included in it. These include publishing annual reports, advice and guidance.

I thank noble Lords for their detailed considerations on this topic, but I hope I have convincingly set out that it is not appropriate to establish a new independent body in the Bill. I hope I have reassured the noble Baroness. I thank noble Lords for their persistence and the calibre of the debate we have had on these two days. I hope I can convince the noble Baroness to withdraw her amendment.