Response on behalf of Mark Prisk. Sort of.

July 20, 2012

You may remember that, on 26 June, I published an Open Letter To Mark Prisk about the small firms impact test, in which I wondered whether he actually knew that such a thing existed, and that he was the Minister responsible for it.  I suggested that he ask his officials to arrange for him to sit in on the next SFIT focus group that was organised, and that he might find it was a long time in coming.

Because I thought it was only polite, as well as publishing it as an open letter I also sent him a copy via his Department, BIS, the Department for Business, Innovation and Skills.  Here is the reply I received yesterday

Dear Ms Bradley

Thank you for your e-mail of 26 June to Mark Prisk about Impact Assessments and the Small Firms Impact Test. I have been asked to reply and I apologise for the delaying in replying to you.

I was very interested to read your perspectives on the SFIT – and indeed other aspects of regulatory and tax appraisal mentioned on your website. As you will be aware from your previous career, assessing the impact of new regulatory proposals on small firms is not straightforward, and we are always looking to improve our approach both domestically and in the EU. I am sure that the independent scrutiny of IAs through the Regulatory Policy Committee should in the medium term help drive up the quality of appraisal. We are of course always interested in new research or initiatives in this area that would be helpful in improving how things work in the future.

You’ll also be aware that aside from appraisal the Government has taken a number of other actions to minimise new regulatory burdens on small business, including the micro-business moratorium and parallel initiatives at the EU level.

Many thanks again for your email. I hope the new novel is also making good progress.

Yours Sincerely

Well, let’s look at the work of the Regulatory Policy Committee for a moment then.  Their latest report (which covers the calendar year 2011) is published here (although you may find that the link on their website doesn’t actually work but you can get at it via google).  And a quick word search of the document (no, I’m not claiming to have speed read all 63 pages, sorry) finds no entries for the terms “small firms impact”, “small firms” or “SFIT”.  The RPC’s own website explains that

The RPC assesses impact assessments against well established guidance set out by the BRE IA Guidance, IA Toolkit, One-in, One-out Methodology, and HM Treasury’s Green Book.

and we all know that the SFIT – the small firms impact test – is a mandatory part of the “well established guidance” – you can find it in the IA toolkit, with a link to the BIS page here.

Does the RPC think that checking whether impact assessments contain a reasonable assessment of the impact on small firms is part of their remit?  I’d be interested to know.


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