25
Examination of witnesses
John Curtin, Jennie Donovan and Tony Grayling.
The Chair: Welcome to this meeting of the House of Lords Built Environment Select Committee. This is a further evidence session in our inquiry on the impact of environmental regulations on development and the promotion of infrastructure. Our witnesses today are from the Environment Agency: John Curtin, Jennie Donovan and Dr Tony Grayling.
We will ask a series of questions. Could members and witnesses please keep the questions and the answers fairly brief? Especially with three witnesses, sometimes the answers can be quite long. It would help us move along if you could try to keep your answers brief. That will give us the chance to hear from all three of you on most questions. That is what we are aiming at. We have a number of questions to put to you, and supplementaries will flow from them as well. Our first question is from Lord Greenhalgh.
Q162 Lord Greenhalgh: To what extent is the Environment Agency a regulatory body as opposed to a problem-solving body?
John Curtin: First, it is a great pleasure to be here and to be invited to give evidence to what is a really important inquiry at an important time.
I see the Environment Agency’s role primarily as a problem-solver. Although we are a big and complex organisation, we have three strategic objectives. The first is to help make the nation more resilient to climate. The second is healthy air, land and water. Thirdly, importantly for this discussion, we want to support green growth and a sustainable future.
Supporting sustainable growth is important on many levels, not least for society. We all benefit from the benefits that development and growth bring. If I look at the challenges the nation faces in reaching its environmental goals and regaining the biodiversity we need, that is going to happen only through good development. We need to help, support and unlock development to meet the goals this nation has for environment and biodiversity. The EA cannot do it on its own.
Where should we place ourselves to become that problem-solver? We try, as much as possible, to go right up the chain of decision-making so that we can help, influence, advise and support, because that is where we see multiple benefits. We try to be in the conversations early to help development and planning, because we usually find that some of the decisions that turn out to be less good, which we have to deal with from a regulatory point of view, are usually seeded in bad decisions early on in the policy-making process.
Primarily, we see ourselves as a problem-solver, but, importantly, as well as being a problem-solver we are a regulator. The way I see that role is as a safety net for communities and the environment if things go awry. I have seen some of the written evidence. People sometimes see the Environment Agency not as a problem-solver when they are facing that more regulatory arm of our role.
To be clear, I would much rather we were at the problem-solving end. The more we can iron out any issues early on in the process, the less we will have to use our regulatory stick. I would much rather that we were not using our regulatory stick and that we were influencing things through planning.
I would also highlight one other feature of the EA. Although we are a fairly big national organisation, the vast majority of Environment Agency staff live and work in communities across England. They have close connections to the places they advise, and they bring their input into local authorities and planning decisions. A vast amount of Environment Agency staff are not London-based; they are out in all parts of England. They work and live in the communities they support.
I suspect through this session we will come up with lots of different examples to give you of how we have tried to embed ourselves strategically. I will just give one now and then we can explore others as we go through. You will be aware that one of the biggest strategic developments happening at the moment is the arc from Oxford to Cambridge. It is huge. It is about 7% of England’s land mass. To show how we have long strategic relationships on these plans, we have had a team in there since 2018. We have eight full-time dedicated staff in that Oxford-to-Cambridge development. Those eight can tap into the whole breadth of experience from the Environment Agency.
As well as all of the housing benefits and infrastructure benefits that will bring, we have identified that we are probably unlocking about £2 billion of natural capital by being involved early on in the process and supporting what is a really fundamental part of infrastructure development in this country.
In summary, I see us as a problem-maker—
The Chair: I think you mean problem-solver.
John Curtin: What did I say?
The Chair: Problem-maker.
John Curtin: That is a slip! Let us try that one more time. I see us as a problem-solver. To do that, we need to be much further up in the planning process, but we do have a regulatory arm and we are not afraid to use it. That is probably when people see us more as a problem-maker than a problem-solver.
Lord Greenhalgh: To what extent are you successful in getting more upstream? A lot of the evidence has been that you are seen very much as a regulator, to be honest with you. You have probably seen that in the transcripts. What is stopping you getting more upstream, if anything, if that is your key ambition?
John Curtin: I have seen some of the evidence. There is an important distinction here that we might explore. We have been very successful in engaging with the big strategic developments.
I will give you a couple of examples that I have worked on myself. I used to be one of our area directors in the Midlands and I worked with Derby on a scheme they have there, Our City Our River, which really embraced the River Derwent in Derby and unlocked a huge amount of development. It also protected, through the guidance of the Environment Agency, about £230 million of assets from flood risk.
There is a lot of discussion about whether you build in a flood plain. A lot of our cities are built around rivers or estuaries, including this one. You cannot not build in flood plains. It is how you build in them that is important. The EA gave advice about how to regenerate Derby. You had car parks on the ground floor and emergency exit routes on the top. There were also very subtle things. Upstream, the buildings were curved so that, if there were a flood and debris was coming downstream, it would be pushed away from the building and not cause any risk of damage. Again, that is a long-term partnership we have had with Derby.
I am going to Mayfield in Manchester on Friday, which is the first park created in Manchester for 100 years. That is probably going to unlock about 1.5 million square metres of office space and 1,500 homes, but it is also regenerating some of the rivers that have been industrialised and urbanised for generations. Under the advice of the EA, they have opened up that green space to be usable alongside all the developments of housing and businesses.
We have lots of strategic examples. When you have finite resources, the difficult element is how you provide that guidance to smaller developers. We have had some innovations to maximise our impact by helping with guidance manuals and training schemes, which I am sure Jennie and Tony can talk to you about. We have lots of examples of the big ones. As I say, what is really important is being up front and avoiding bad decisions so that we do not have to use our regulatory arm at the end.
Q163 Baroness Cohen of Pimlico: I have a supplementary on this. When I read your written evidence to the committee, I hit a paragraph on page 29, which begins, “Our focus and expertise is on protecting and enhancing the water environment, including river and wetlands habitats”. Indeed, why not? If that is front and centre, I would like to hear more about it.
John Curtin: Do you mean our protection of water environments or other facets as well?
Baroness Cohen of Pimlico: I mean water environments, including rivers and wetland habitats. I live in Cambridge, where we have nothing but rivers and flood plains and water-borne things, and lots of proposals for building on them. It just struck me as interesting that this turned up in the Environment Agency’s upfront statement about what it wanted to do.
John Curtin: The agency’s primary role is on the water environment, but there are some land and air elements that we can explore. Maybe later we will talk about the multifaceted challenges on the water environment because here, of course, we are looking at development. I am acutely aware that there are a vast number of elements and challenges around water quality. We need to have an overview of all of them.
Government published a really important plan just a few months ago, the integrated plan for water. That is a fantastic opportunity to make sure that there is a more unified approach to all of the challenges. As we speak, for example, one of the biggest challenges the Environment Agency is facing in water at the moment is the weather we have been experiencing. We have had a very long and dry warm spell, which is lowering dissolved oxygen in our rivers. If you have storms coming straight after, you have urban run-off and run-off from roads, which adds load into the rivers and takes even more oxygen out. We have seen about 250 fish rescues by the Environment Agency just this month so far.
We know we have to look at all the different facets. It is not just farming, development and water companies. There are also the storm issues and run-offs from cities and roads, et cetera.
Baroness Warwick of Undercliffe: I just wanted to pursue the point you made a few moments ago about small and medium-sized enterprises. They are a major part of the development process, and yet it is from those very SMEs that we have been receiving the most criticism. That is not just about the regulatory role but the role of the agency in making its decisions and in almost stalling development because nobody quite knows what the best way to handle it is or where to move.
That comes through so regularly. It is something you are very aware of. How have you responded to that? Can you give us some examples where it has improved or where you have been able to produce plans that will change things?
Q164 The Chair: Just to summarise, we have heard evidence that you are difficult to get hold of and slow to respond; that, being a large organisation, you have multiple branches that have different interests in particular projects; and that contradictory answers are delivered by the Environment Agency so that applicants do not know where they stand. That is the character of the complaints that we have heard. That is a fair summary.
John Curtin: I will talk about the scale of the advice, and then perhaps Jennie can talk a little about what we are trying to do to help small developers. When we help small developers, they may not even know it is our help. We are working with associations, giving training advice and training packages that they may not even know are badged by the Environment Agency. Although we are helping them, from the product they receive they may not know that that is the case. I am sure Jennie can talk about that.
On the scale of our planning advice, in 2021-22, we had over 13,600 consultation responses. We did 89% of those within 17 days, which was our target. There are many other people who are receiving a positive experience from us. As I say, some of the small developers may not know that we are the provider. Jennie, I do not know whether you want to talk through some of the work we have done with planning associations.
Jennie Donovan: I am happy to, but I am also happy to hear examples of where that is not working. My role in the Environment Agency is to work with our local sustainable places teams. As John mentioned, we have people all across England working with local authorities, local developers and local communities. I am happy to hear examples.
Within those sustainable places teams, our role is to pull together that integrated advice to local planning applications. As a planning adviser, we offer advice on flood risk, water quality, water resources and land contamination and its impacts in association with groundwater. We have put that distinction about the water environment into our written advice probably because that is primarily where biodiversity comes into play in the aquatic environment.
The sustainable places teams are the teams that bring together that technical advice and offer it in planning applications. As John has said, because we are getting those only at the statutory end of the application, we have not had earlier conversations. We also offer a cost-recoverable service at the pre-app stage where there are often a lot more opportunities to resolve some of the issues that might be there from a flood-risk or groundwater perspective. We can offer that preliminary advice about what the issues might be. On a cost-recoverable basis, we offer technical advice about how to overcome them. That is a service we offer across the board to both SMEs and large developers.
We also work with the Planning Advisory Service. We have done a number of training modules on the new biodiversity net gain mandatory requirement that has just been issued. We have done some work on that. We have done several with the Planning Advisory Service and the Town and Country Planning Association on flood risk, because flood risk is probably the thing we most get involved in at the planning stage. We have done a lot of work with trade bodies on how you can deal with flood risk.
Baroness Warwick of Undercliffe: How do you judge the success of what you are doing? Are you aware of just how many people take advantage of either the training or the opportunities for upfront advice early on? There is clearly a mismatch between the service you believe you are providing and the service these small and medium-sized enterprises believe they are getting.
Jennie Donovan: Yes, we could certainly provide figures on the uptake of our pre-app advice. I would have to go away and look at the uptake of our modules of training. We do use those trade bodies. It is the trade bodies that have the most access to SMEs. We also work with some of the housebuilding federations to offer that advice, and we work with Natural England and the development industry group. They have a better route into that industry than we do. We try to get our reach as extensive as it can be.
Q165 Lord Mawson: I am always fascinated by government bodies that seem to get bigger and bigger, and that produce all the right words, the right phrases and all the rest of it. When you look at the real granular micro-detail in one place and you really talk to people about what is going on in one place, it is a bit like we are hearing—you hear a very different description.
I wonder whether there is one place you could mention and give us a taste of what that granular detail looks like with your interaction with SMEs and the local community context there. Is there a place where you have been involved in that micro-detail? Can you tell us what it looks like? Can you give us a feel for that?
Jennie Donovan: Before I moved into the role I am in now, I was in one of those area teams. I was in our Kent and south London area team. I worked on a number of developments there. For example, it is not even just with SMEs; it is trying to unlock economic growth in that place so that SMEs benefit.
A lot of what we have done over the last couple of years has been to work with other government departments on unlocking—
Lord Mawson: What is the place, though?
Jennie Donovan: Take Manston, for example. Manston is a tricky location because the groundwater there supplies a lot of the people across Kent. It is their public water supply. There was contamination above it. We needed to create a lorry park so that, as we went through the EU exit, we had somewhere for lorries to park while we waited for the paperwork to pass through.
We were on-site with the developer and with government, coming up with solutions to make sure that the contamination did not seep through into the groundwater or pollute the water supply, so that the people of Kent could still access their water. We were also able to develop there at pace. That was a cost-recoverable service. We went out and we had people on site to help come up with those solutions.
John Curtin: I would just go back to the point I made at the beginning. We want to explore where there are mismatches between what you are hearing and what we are experiencing. As I said, one of our three major strategic objectives is to get green and prosperous growth. It is the only way we are going to unlock the potential for nature, biodiversity and environmental recovery. We do not want this mismatch. I do not want to sit here trying to defend it away, although there are fantastic examples of the work our teams do every day. We want to understand and explore it as well.
Q166 The Chair: Before we come to the next question, I just want to explore something and take a slightly contrarian view for the sake of provoking an answer. You describe a development—it might be Derby or somewhere else; it could be a housing development, a commercial development or mixed use, but it is a substantial development—and say that there are all sorts of environmental benefits that come along alongside it. That looks like a win-win, but it could easily be presented as a large amount of cost being loaded on to development, and not only cost but delay.
Of course, in this country we have a pressing need for housing that is produced at prices that people can afford but that still allow developers to make a reasonable margin on their investment in capital and risk. A large amount of cost is being loaded on this for the benefit of what the Environment Agency, in its sole discretion, I think it is fair to say, judges to be the right amount of natural improvement. At the same time, the Environment Agency, especially in riparian and coastal locations, is often the owner of existing infrastructure.
Is there a tension there? You have a role as an owner and manager of infrastructure, some of which is old and crumbling and needs investment. Are you seeing development as an opportunity to extract what is in fact a financial subvention for your own maintenance programme? Is that holding things up in some locations? Should that ownership relationship be separated from your planning consultancy role?
John Curtin: In the Environment Agency, there are a number of points where we are a regulator and an operator. Some of that is to do with planning, as you say. We also regulate all the reservoir safety stock in England and we maintain a number of reservoirs.
We are very clear on how we set ourselves up on two things. First, we do not apply a standard to the EA’s operational arm that is any different from what we expect from others. We are very clear on that principle. Secondly, we have a number of arrangements to ensure that there is clear separation between the decisions you have discussed. That includes our legal team being separated into two teams to make sure that our legal advisers are separate from the two elements of the organisation. We are very clear on the separation of operator and regulator. We ensure that we do not provide any advantage to ourselves that we would not provide to others.
On the cost issue, I maintain, from the examples I have worked with, that costs and delays usually come from when you are trying to retrofit decisions later on in the process. To be frank, many times we are trying to uphold the law and provide the safety net I mentioned. As I said in my opening, I would much rather we were not doing any retrofitting of decisions later on in the process and could advise and support beforehand.
There is a thirst from the public to have green development. I was struck by something recently. You are probably aware that the Office for National Statistics does a quarterly assessment of what the UK population hold dear. The last one was in May this year. The cost of living crisis is number one in the public’s mind at the moment, as you would probably expect. Fourth on that list of the most important things to the UK populace was climate and environment; it was above crime, education and even international conflict. The UK population has a thirst for environmental and climate improvement at the moment.
I do not want us to be dogmatic and do them for the sake of doing them. They add all sorts of benefits to development. As I say, we all benefit from the development that happens in this country, but there is a good balance here when it comes to the green environments that can be created if we advise, support and nurture partnerships further up the planning chain.
Jennie Donovan: There is also the element of costs avoided. I can give you a really simple example from the Humber. We received a planning application for a care home in the Humber. A small amount of it was at risk of flooding, although most of it was in what we call flood zone 1. We were able to advise on how to make it resilient to flooding. Just down the street, 10 cottages were developed that were only in flood zone 1. They flooded in 2013. We were able to talk to them about the impacts of climate change and the increased likelihood of flooding.
For every pound we spend on flood risk advice, that is £12 of flood damages averted. We are providing that advice in order to prevent costs to society. Similarly, for every pound we spend on contaminated land advice, we save £7 in damages averted.
We give that advice to local authorities, which then make the planning decision. We advise them on the risks of flooding and how that flooding needs to be dealt with, and they determine whether the application properly accounts for the risk of flooding, water supply, water quality, land contamination or biodiversity requirements. It is the local authority that makes the decision based on our advice. Primarily, local authorities support our advice.
Q167 Lord Best: We have explored quite a lot of the problems around nutrient neutrality. It has been a big issue for us. Natural England told us that nutrient pollution comes mostly from decades of unaddressed pollution by the farming industry: 96% of it is from farming. It appears to us that, if that is correct, it is not agriculture that you are concentrating on and that Natural England is taking a look at; it is construction. It is the housebuilder that is paying the price for us not addressing this problem in the farming community for possibly decades. Is this how you see it too?
John Curtin: This goes back to the point I made earlier. Water quality issues are multifaceted. We recognise that. I would stress the importance of the Government’s integrated plan for water, to which I will return. That recognises that all these elements need to be addressed together in an integrated catchment approach, rather than being segmented.
On agriculture, diffuse pollution is a serious issue across the nation’s rivers. First, we probably do not have the regulation for individual point source pollution, like you see at water companies, where we provide permits for particular treatment works. Wider diffuse pollution had less regulation, but the Government have provided us with a regulatory tool through the farming rules for water, which were introduced in 2018.
Secondly, the Government have invested in more people for us to go out and do inspections on farms. Last year, we had our largest farming inspection campaign. We had over 4,000 farming inspections, which we targeted to those we thought were probably causing the most problems. It showed that there is a problem. In those 4,000 inspections, we found 5,500 non-compliances.
The good news is that we did not go straight to enforcement. We sometimes get a lot of criticism for not taking farmers to court, but there is an important first stage, which is to explain to the farmer the effect of their practices on the water environment and to give them an opportunity to rectify it. Of the 5,500 interventions that we identified last year, almost half have already been completed by farmers.
Last month, I went out on a farm inspection in Dorset to a farmer who had his second inspection. He had a 550-head dairy herd producing 5 million litres of milk a year. He had a big contract with a clotted cream company that I will not advertise here. During his first inspection, he saw that there were a number of ways in which his business was causing pollution, and he has invested money to make all those corrections. He is addressing the diffuse pollution from his farms. That is what we want to do.
The farming rules for water give us the regulations, and now we have more resources to go and conduct targeted inspections of farms. As I said before, the influencing and problem-solving role is important—giving people the opportunity to make those corrections. After last year’s inspections, we still see some places where farmers are not making corrective action. We have about 140 enforcement elements in progress at the moment where people are not taking the action required. The way out of this is multifaceted. We recognise that. We are definitely doing a lot of work to rectify diffuse pollution from agriculture.
I will mention the integrated plan for water one more time. It is a fantastic opportunity to bring together all of the delivery bodies in Defra and across government to focus on catchments and make sure we have a glide path of improvement that does not punish one sector versus the others.
I should also highlight the use of innovation. Jennie might want to talk about Poole Harbour, which is one of the more sensitive areas we have seen for nutrient issues. There they are trialling quite an innovative approach of trading permits. That shows how you can explore more innovation in trying to get out of this nutrient fix, rather than just having the stick of regulation.
Jennie Donovan: The other thing that sits beneath the integrated plan for water that we are leading on is understanding diffuse water management and the different contributions that are being made in a place from different sectors. That could be urban run-off, agriculture or sewage treatment works. That allows you to take a targeted approach. In the catchments that are experiencing nutrient neutrality, we are looking at those diffuse water management plans to understand the range of contributions.
Since 2013, because Poole Harbour is a highly designated area, we have been working with Natural England, water companies and agriculture to look at solutions that address their contribution to the nutrient issues. The water company has done what it has needed to do at the sewage treatment works. The local agriculture sector has identified the glide path it needs to work to in order to reduce its contribution. It is being done as a voluntary consortium. They are trading off different solutions so that they are able, as a consortium of farmers, to arrive at a nutrient improvement in that locality.
Lord Best: As those improvements come through in Dorset, are there corresponding opportunities for construction to come back into play again? How quick is this process? You are doing well in Dorset. Has that made a difference to the amount of construction we can see?
John Curtin: From my perspective, what we need next is the implementation of the integrated plan for water. I know I keep talking about it, but it is a really important tool. It has only just been launched three months ago.
I know that Defra colleagues are working hard on the implementation plan, but that is important because, as I say, it will look at all the different interventions in a catchment leading to the targeted improvements in the improvement plan, set out with government. We will be able to measure the reduction happening in sectors X, Y and Z and then set the target for that catchment to know where you can unlock or release development or other elements in the catchment. The implementation of the integrated plan for water is key to be able to do that.
Q168 The Chair: We are talking about decades of poor practice that has been allowed to continue. In the meantime, in 72 local planning authorities, 27 catchments, 14% of England’s land area, there is, in effect, a total stop on development. One of the things we are interested to know is how long it is going to take you to address these accumulated decades of bad practice before we can start proceeding with building the homes people want in large parts of the country?
John Curtin: The Government have set the targets for nutrient load across catchments. As I said, we now need the plan, and then we can work on the pace, including the innovation Jennie has talked about. The beauty of that plan is that you do not have to disrupt every business as you go through that glide path, because you can see where one area has capacity in nutrients that can be traded to another. The collective impact is what is important, from the glide path down. You do not have to have individual disruption to businesses. We need the implementation of the integrated plan for water to give us a real view of the timescale for change.
The Chair: The question then becomes about when we expect the plan. We have the integrated plan for water. You are saying that has been published.
John Curtin: Yes, it is now about the implementation, which Defra colleagues are working on at pace.
The Chair: That will be a plan for implementing the plan, but then somebody will have to implement the plan. Is that going to be the Environment Agency?
John Curtin: One of the things Defra colleagues need to look at is how the plan will be implemented. As I have said, it is critical to the Environment Agency, so we are more than ready to play our part. The other really important element in the plan is that it brings all the Defra bodies towards one ultimate goal. You can ensure that you are targeting your environmental land management farming schemes, alongside the regulation Natural England talked to you about and the Environment Agency’s regulation to one set of goals.
I am sure that the EA will play a part. I suspect it will be a coalition of the willing rather than one dominant force. It is a great opportunity to bring together all the regulation in place against a single plan.
The Chair: I am sure. Lord Best was driving in this direction; I am not moving away from it. I am not getting closer to a sense of what the timetable is.
Jennie Donovan: Each catchment will have its unique solution. In each catchment, these diffuse water management plans identify what the individual contributions are from different sectors. Let us remember that it is the sectors that are bringing—
The Chair: Defra has the responsibility for devising and implementing the plan, from what you say. It is not your responsibility at this stage. You will wait to hear what it has to say. As experienced managers of the environment, which you are, will it take a year, 10 years or 100 years to get this right for each catchment area? At what point are you able to say, “We can now resume housebuilding in this area”? That is what I am trying to come to. It might be that you do not want to answer it. I understand if you do not want to answer it. Can you give us your sense of how long this plan will take to produce results?
John Curtin: It would be really difficult for us to give you dates, because each catchment will have complex and different elements.
The Chair: Could you tell us whether it will be a year, 10 years or 100 years?
John Curtin: You could do it really quickly, but you would cripple all the other businesses. You could stop every farm in this country and you would reduce nutrients quite quickly. The real challenge will be in the integrated plan for water. Once we implement it, we will know the glide path and impact across all of those different sectors. We want them to have sustainable businesses that are still profitable. We need food in this country, and we need the environmental gain you can have from good farming alongside the development we need.
I cannot come up with a number because we want to see the challenges each industry will face to come back to compliance with where we are in the.
Q169 Lord Best: I just have a final question on this. Are you following the Dutch experience? A lot of this has emanated from there. They are taking a very proactive role in relation to farming communities. They are not regarding this as entirely to do with construction. There is even talk of buying 3,000 farms that are currently intensive farms that are creating a lot of pollution. They are getting on with the job. Are you following what is happening in Holland?
John Curtin: Yes, exactly, that is the principle. I am not trying to deflect from the pace at which the integrated plan for water will be implemented. It is just that you will have to talk to Defra officials. We can get them to write to you.
When that happens, that is the key opportunity to ask, “How bold will you be? Do you want to buy X or Y farms to really reduce the nutrient effect there so that you can unlock development? Do you want a glide path that is more equitable across all sectors?” That will allow you to make those strategic decisions. The pace will be based on the degree to which you implement those elements.
The Chair: It is perfectly fair of you to say that this is a question for Defra, and I understand that. There is no criticism involved in that.
John Curtin: It is a great opportunity.
The Chair: You have set it out for us very nicely. We are taking evidence from Defra Ministers in a couple of weeks. If I can summarise, you are saying that how you implement the plan will involve a lot of trade-offs between the different businesses and elements that bear the burden, and how quickly you achieve your goal will depend on how much pain you are willing to put on those various players, how quickly and with what compensation.
John Curtin: The single most important thing about the plan is the word “integrated” because it brings all the facets of a catchment that we have been touching on into one place and allows you to consider them together.
Jennie Donovan: As a final thing, Poole Harbour is a really nice example, but it probably has taken about 10 years for us to get to this point. It has targets for 2023-24, which are being overseen by an independent body. When those are reached, development should be unlocked.
That precedes the integrated plan for water. It has almost been a pathfinder. We could send you a YouTube link to a video about that, because it is a really interesting case study, looking at the different sectors and their contributions and how, voluntarily, those sectors can bring about improvements. We did not have the regulatory levers. Some 80% of that sector has signed up to that glide path.
The Chair: We had a Dutch witness who said that, as far as Rotterdam harbour was concerned, at minimum it would have to be a 10-year plan. You cannot do these things overnight. I understand that. That is why I was trying to get a sense of the timescale for implementation. Ten years for a harbour sounds perfectly reasonable. I can understand how you have landed there. You understand our interest in the timescales.
Lord Berkeley: I have one addition to the very interesting information we have been given. This phrase “glide path” sounds really nice and friendly. It sounds like something that will not upset the chicken farmers or anybody else, but it does not seem to have the same urgency as some of the needs from the housebuilding sector, which is saying, “Are we going to have to wait 10 years”—if that is the right figure—“to unlock some of these restrictions? Are we going to get the same support from Natural England as the farmers are getting from the Environment Agency?”
My worry is that the farmers are going to end up saying, “No, we are not going to do this”. In some places they probably will say yes, but in other places they will say, “No, we want massive compensation”, and it will probably stop there. I am very glad that everybody is working together now, but this does seem to be out of balance, in terms of the enforcement and the rules, between the Environment Agency and Natural England.
The Chair: You could regard that as a question.
Lord Berkeley: Thank you, Chair.
John Curtin: This reinforces two points I have been trying to make. First, we are regulating the farm sector. Of the 5,500 interventions we expected from farmers last year, half have already been completed. I suspect the rest will be, but there are a small number where we may need to take enforcement action. They will be playing their part.
These are trade-offs. These decisions—this is not about what trumps what; that is not what you are saying—about how much you push the pace of farming compliance, water company compliance or run-off from roads and development have to come from an integrated plan where all parties are together, describing what the plan for that catchment will be. Again, that is why the integrated plan for water is a fantastic opportunity, if we take it.
Q170 Lord Mawson: What is the process for the Environment Agency to contribute to policy development at Defra and DLUHC? I want to push a bit further on this question about how the micro experience at the front end influence the macro? I often find that in these government bodies there is all this talk at 60,000 feet, but when you introduce that it starts a very different conversation. The disconnects are often quite profound. I am just interested in how the on-the-ground stuff influences that.
Jennie Donovan: That is a really nice question because that is our unique role. The Environment Agency is an arm’s-length delivery body. We are a statutory consultee on planning applications and local plans. We have that operational experience of how planning, legislation and practice work on the ground. We absolutely draw on that in the conversations we then have with the Government.
In terms of process, we are responding to the various different pieces of planning reform that are coming through and the Levelling-up and Regeneration Bill. The Environment Agency makes responses to that, but we also work with Defra, Natural England and DLUHC on what those policies looks like.
Lord Mawson: You involve real people with names and addresses in that process, do you? It is not just process.
Jennie Donovan: We involve real experiences. For example, when DLUHC was updating its planning advice on flood risk, we used operational experience of where the sequential test was not working. That is one of the ways you manage flood risk in planning. That was not working locally. We used examples of how it was not working locally to update planning guidance and advice so that it was easier for developers to follow that. That is exactly how we would use it as different reforms come through.
The other thing we would do is, again, work with trade bodies. We work with sustainable urban drainage bodies on what good planning practice is—what works and what does not work—to help inform other SUDS schemes. We use examples, particularly when we are seeing it all across the country. The sequential test and SUDS are good examples that we are seeing across the country, where planning legislation is not necessarily easy to interpret. That is where we will step in and help think about how you interpret it.
Lord Mawson: There is lots of relying on bodies, processes and representatives. They have limitations. I am very interested in individuals, the real granularity of specific places and the specific experience on the ground. How does that percolate up into this wider conversation in government? I am never totally persuaded that these representative bodies have a contribution to make. Are they hands-on? Do they really understand the granular details? In my experience, there are often questions about that. How do you really get to the front end?
Jennie Donovan: Our officers on the ground will help developers or local authorities interpret flood risk guidance. From a flood risk perspective, planning says that you avoid areas of flood risk where you can. That is sequential. By exception you can develop in them, but you must not pass flood risk on to others and they must be resilient to flooding. We provide advice on different sites across the whole of the country looking at that.
It was fed back to us that the supporting advice notes that came with that planning reform did not allow people to work out what their modelling or their application needed to look like. We then helped rewrite those planning advice notes based on what developers were telling us was unclear to them.
John Curtin: More generally, to pick up on a point I made earlier, the vast majority of Environment Agency staff are on the ground doing things. The Environment Agency’s strength is in piping that practical experience up to Defra policy colleagues. Even in the example I gave you about farming, the farm inspections are pointing out where there are common themes in the irregularities in dairy farming, which potentially helps create regulations for future farm regs. There is a loop back in.
This is about the stories from people on the ground, which I go and experience. I go out and share my time with the people who do this job on the ground. The real strength of the Environment Agency is that it does a thousand things in a thousand places. That allows us to share that practical experience, whether it is about flood regulation or farm inspections, with policy colleagues to influence their policy.
When I spoke to the Secretary of State for Defra, I know she really valued that. She had seen that when she was in the Department for Work and Pensions. Her policy colleagues could experience how people were dealing with work and pensions issues only if they were grabbing the experience of the people at the front line giving out the claims.
That is the strength of this organisation. There are very few people sitting in London or appearing before Select Committees. They are out there doing stuff. We can collect that information and pass it through to those who are developing policy to help influence it.
Lord Mawson: In a week, how often are you out on the front line?
John Curtin: I confess that I enjoy that bit, so I probably try to maximise it. In the last month I have taken samples on a beach; I have then analysed those in a lab. I have been on a farm inspection. I am going to Manchester on Friday to see the new Mayfield development that we touched on. Last week I had the pleasure of going to one of our field teams in the Midlands that had sent a flood kit to Ukraine as part of its recovery. I thanked them and I saw the challenges they had working in temperatures above 30 degrees centigrade in PPE to send kit.
A big part of my role is to thank them for their work but also to experience what they experience, so that we are not removed from the front line and so I can use their stories in this type of debate or share them with Ministers. It is a big part of my working life.
Q171 The Chair: On a related matter, some people would say that this is quite a crowded field. There is the Environment Agency; there is Natural England; we now have the Office for Environmental Protection, about which we are going to learn more in an evidence session next week. Are you all out there tripping over each other’s feet the whole time? Would some rationalisation be sensible here?
Dr Tony Grayling: We all have quite distinct but complementary statutory remits. The Office for Environmental Protection, as you will discover and are no doubt aware anyway, is holding us, Natural England and the Government to account for the proper application of environmental law. That is quite a different role from the one we or Natural England would play.
Our role and Natural England’s role are quite distinct and complementary. We work quite closely with them at both national and local level to ensure that we can be as joined up as possible. For example, as Jennie was saying earlier, we participate in the developer industry group that Natural England convenes. We participate on its task force, which is devising the mitigation scheme in relation to nutrient neutrality. We are frequently comparing notes with it and trying to ensure that our complementary roles are as joined up as they can be.
The Chair: Who was holding the Environment Agency to account for compliance with the law before the Office for Environmental Protection was created in the last year or so?
Dr Tony Grayling: Of course, that was before we left the EU. The European Commission played the key role in holding the Government and its bodies to account in the implementation of environmental law, much of which was European.
Q172 Baroness Warwick of Undercliffe: I asked earlier about measuring impacts. Does the Environment Agency undertake impact assessments? Do you consult with Defra and DLUHC when you are issuing any advice, particularly when it impacts development?
Jennie Donovan: On a macro scale, it will be the Government themselves who do impact assessment for any new planning policy. They have introduced mandatory biodiversity net gain and local nature recovery strategies. That is government policy and legislation. The Government assess that. The Environment Agency is a statutory consultee for strategic environmental assessments and environmental impact assessments, so for large-scale developments. We are the statutory consultee. We are the people who respond to that.
One thing we really welcome in planning reform is the introduction of environmental outcome reports, which will replace strategic environmental assessments and environmental impact assessments. Those will look at the environment as a whole. They will look at the evidence and the mapping of what the environment looks like as a whole so you can consider strategically where you can make some net gain contributions to unlock the development.
As the Environment Agency, we also provide advice on Natural England’s licensing. Likewise, if any of our permitting impacts on its domain—the habitats regs—it will provide us with advice on our permitting decisions.
Baroness Warwick of Undercliffe: It works very efficiently, then, in your view.
The Chair: Just on permitting, we have heard evidence that quite a lot of the permitting undertaken by the Environment Agency replicates the types of inspection and standards that operate through the planning system, and that there really is no need for a large amount of it because it is duplication. Would you just like to comment on that?
Jennie Donovan: The gift of planning is that it thinks about the place. Is that the right place for that development or that industry to happen? Is it the right location? You need to factor in flood risk, water quality and water resources in that place. When you have introduced an industry, permitting controls the emissions. The decision has been made that that is the right place, but the permitting controls the emissions that go into the environment. They are quite distinct.
The Chair: I am very sorry, I anticipated Lady Thornhill’s question.
Q173 Baroness Thornhill: No problem, we can broaden this. My question was going to be about the overlap between your two roles of planning and permitting. How big is the issue of overlap and duplication, not just within your own organisation but between other agencies? If you want to add to that, please do.
Could I also push you a little more on capacity and resource? Do you feel you are tooled up to do the job? I also want to look at the extent to which value for money and eradicating these overlaps and duplications are part of your corporate objectives, for want of a better word, in terms of providing value for money to the taxpayer.
John Curtin: If I can just take the first point, I would reaffirm the point Jennie made. Planning sets out where you are going to do something. Permitting then sets the standards by which you can emit to the environment. The important thing about permitting is that you might have that farm, factory or whatever else in place for a very long time. The standards might change; the expectations might change. The permit allows you to review, adapt and change as and when the requirements change. The place or the factory might stay there for many generations, but environmental legislation might change. The permitting allows you to be dynamic against the decision that was originally made from the planning point of view.
Resources have been a challenge over the last decade, but you will not have many public sector organisations coming in and saying it has not been a challenge. I go back to the stats I mentioned before. The team have been quite imaginative in how they have used digital solutions, standing advice and others to try and improve the service. With that said, if there is a mismatch between what you are hearing and what we are trying to achieve, we want to explore that. The benefits of having successful, good development on the goals for the environment are really important to us as well as to people.
Resources have been a challenge over the last decade. Over the last couple of years, it has been difficult to sustain people with the skills we need. That will be the same for local authorities. If you are an environment officer in the Environment Agency in the south-east of this country, you start on £25,000. It is difficult to sustain the skills you need. Some of our planning people will not be on a huge amount more than that.
At some points in the last year and a half or two years, the planning teams have had 30% vacancies. We train good people up and they will leave to other employment to secure higher wages. We have had some really successful recruitment campaigns recently. We are nearly back to full complement, although it takes a while for people to gain the skills when they start and to get fully up to speed. A lot of people want to do the work we do to influence the environment, but sustaining the real specialist skills that we need, and that I am sure local authorities need, is a real challenge.
Baroness Thornhill: Do you have anything to say on the corporate drive to knock out these overlaps and duplication within the Environment Agency and with all the other agencies? That is where Lord Moylan came in. I did not hear anything about that being important to you. You made a big play of saying, “We want more integration”. If you are going to integrate, you need to know where those areas of overlap are, and you need to try to eradicate them and decide which body is more effective in doing what.
John Curtin: Yes, absolutely. I am going to sound like a broken record through this session, so I do apologise. The integrated plan for water is a great opportunity because it brings all those bodies together in one plan. We do quite a lot of work with Natural England. I meet the chief executive of Natural England, Marian Spain, and we work through some of the complementary challenges and look at where we are going to align our teams.
Our operational teams meet quite regularly to ensure that our complementary skills are giving similar and not contradictory advice and that we are trying to be responsive to the customers who we are trying to serve. There is a lot you can do, but framing this through the plan to give us a joint target is really effective as well.
The Environmental Agency does not have a God-given right to exist. We should always be looking at whether there are better models to deliver policy in the organisation, but we need to recognise the costs of change versus any mythical new structure that would provide great benefits. The real opportunity is to recognise the distinct skills and inputs that each organisation brings to the overall plan for reducing the challenges in the environment in a catchment and implementing them together.
Q174 Lord Carrington of Fulham: I really want to explore what has happened in the past. You read all those stories in the newspapers about Poole Harbour, to start with, and then the River Wye, the pollution levels in all our rivers, and Natural England stopping all housebuilding in the south-east because of the pollution run-offs and things like that. How did we get to this situation? What went wrong?
The Wye is a classic example. It used to be a wonderful chalk stream and river. It was a wonderful environmental location. People used to go there for their holidays. It is one of these places that has been gorgeous down the centuries, and yet somewhere something has completely fallen down.
I understand exactly what you are saying: that you are putting it right and that you have enforcement rights to change things. I quite understand that you are working with the other agencies, particularly Natural England, to make these things seamless and fitting together. I quite understand that we are waiting for a long-term strategic plan out of the ministry, which puts shivers down my spine, I have to say. What went wrong? We can look at a problem and say, “We have a problem. How are we going to solve it?” but the real question is about what we should have done in the past that we did not do. Should that be teaching us what we should be doing for the future?
We learn an awful lot more from what went wrong than we do from somebody sitting and doing a long-term plan uninformed by the errors of our past generations. Should it have been solved? Could it have been solved? How did we end up with all these chicken farms on the Wye?
John Curtin: The first thing is that we all eat chicken.
Lord Carrington of Fulham: Why should that be on the Wye?
John Curtin: The decision for placing a farm is a planning decision made by a local authority with our advice.
If I can just roll back on the overall challenge for water and maybe start with water companies, to be fair, we have talked about farming and about developers, but water companies are an important part that we should talk about. From my perspective, you need people to stop breaking the law. We often get criticised for not holding to account those who break the law. We have prosecuted water companies 58 times in the last few years and raised £147 million in prosecutions. I do not want to do that, because that wastes a lot of people’s time and resource in the courts, the Environment Agency and the water companies. First and foremost, people should know what the law is and adhere to it.
Looking at the water industry, we went on a basis of thinking that this was mature. Operator self-monitoring is a regulatory tool that has been driven through a number of cycles of reducing red tape and bureaucracy. In the last few decades, we have had a number of water companies that you would think should be professional; we have added monitors to the input to their sewage treatment works, and now the event duration monitors and CSOs, and clearly a number of companies are not complying with what they should be doing. As a result, last year we started Operation Standard, which is our largest investigation of water companies across this country. First and foremost, the heart of it is that people need to stop breaking environmental law.
Lord Carrington of Fulham: You—or somebody else—have clearly failed to stop them breaking environmental law. They have done it with all the sewage run-offs and the flooding of sewage into the sea and rivers, which is an outrage. You say you have taken prosecutions. I understand that and that is fine, but I am not quite sure whether fining a company does anything other than stop it investing in putting things right. Would sending some of the directors to prison not be better?
John Curtin: We have fined hundreds of millions of pounds, so we do need different action. I have to say that Water UK, under new leadership, has come forward and apologised, and put its hands up and said, “We have got this wrong”. Our role as a regulator is now to ensure that it takes the actions to move from where it has been in the past to going forward. Sending people to prison is not going to change the culture in some of these organisations. Making sure that they address the plan is.
Lord Carrington of Fulham: All those hundreds of years ago, Dr Johnson said that the prospect of being hanged in a fortnight concentrates the mind wonderfully. If you send these people to prison, there is the possibility of personal liability. That is what I am saying.
The Chair: To be fair, though, it is not the Environment Agency’s job to have a view. Of course, it can have a view, and you are welcome to have one, but a decision about sentencing policy is not under its remit.
Lord Carrington of Fulham: What I am trying to get at is whether, in the Environment Agency’s view, there should be stronger action to be taken against these companies that have been breaking the law, as you said. I am not saying you all should be policemen, but I am saying that something should have been done, something should now be done and something more forceful should be done in the future, should it not?
John Curtin: My view on this is twofold. First, the toxicity in the debate around water is not helping anyone. I have seen some fantastic examples of people working in partnership with trust. If you want a controversial view, some water companies are doing good things for the environment in some places.
On the River Ingol, a chalk stream in Norfolk, the Norfolk Rivers Trust is replacing a high-carbon, high-energy treatment works with a wetland that is removing nutrients. It is providing biodiversity and a fantastic environment for people to walk their dogs, with low energy. There are great solutions out there. Tossing around statements about whether we should send people to prison does not create the solution. It just creates more of this toxicity in the debate.
I was out with a young engineer from one of the water companies, fresh into the industry, showing me the fantastic work they were trying to do to correct poor decisions of investment from decades ago. I cannot defend what water companies were doing in the last few years. I am talking about now. This young individual was showing me what they were going to do, they were wearing their jacket and a member of the public spat on them. That person could walk away from this industry and not help any of us, so I want to move to a more nuanced debate about what the solution is.
It should not have been like this. I can keep prosecuting water companies and taking money and giving it to the Treasury, but the real important fact is that water companies show a cultural change to take responsibility for what they do, and we make sure that they do it. That is what I am about.
Baroness Cohen of Pimlico: I tend to view water companies as being wrongly constructed for the job, wrongly financed and wrongly a private sector idea. Their terms are too short; a five-year planning term is awfully short. Do you share the view that some restructuring of the way that water companies are run and financed is needed? I am not asking you to state exactly what. It is a huge subject, but I would like your view.
The Chair: That is quite a long way outside the remit of the Environment Agency, so feel free to comment as you would like.
John Curtin: I have a view on the second point about the short terms. In many places, we should start looking at these five-year regulatory investment cycles, so the price reviews for water companies, with a funnel that looks generations ahead, because the issues we face, both on tackling the climate adaptation issues and the environment we have today, is going to be a generation journey out. Price reviews being set knowing what you might be doing in your second and third price review ahead is really important, rather than it just being what the current one sets out.
Q175 The Chair: We are not quite making the progress that I had hoped, but it has been a very valuable and interesting session. I will ask one important question before we come to the last question, and then we will try to wrap up.
From a developer’s point of view, the primary contact is with the local planning authority, and you are an adviser to them. I would like a few brief comments on what you find the condition of local planning authorities to be today. Are you giving them the service they want in a timely fashion? Are they staffed up and capable of taking your advice and proposals and translating them into planning decisions in a timely fashion as well?
Jennie Donovan: As John mentioned, from our perspective, we have a statutory requirement to reply within 21 days. We are replying to the vast majority in 17 days. We are servicing our advice. We would much rather do that at the non-statutory stage where solutions are available, and offer that pre-app advice and that preliminary advice. Local authorities would like us to do that, and local authorities also offer that service. By local authorities offering that service, they can bring together a collection of statutory consultees as well.
The Levelling-up and Regeneration Bill recognises the undercapacity of the planning system, the need to invest in the planning system, and the need to look at it as a system in order to accelerate development. It is looking at how it can be a plan-led system, such that it is quite easy to understand that place and its requirements, and applications can move through the system much more quickly. The Levelling-up and Regeneration Bill offers that opportunity.
As I have mentioned, we have also, with local authorities, been trying to invest in digital, so that we can increase the pace there. We have been trying to increase standing advice, so that we can increase the pace there. We have been trying to provide capacity-building training for local authorities, through the Planning Advisory Service but also direct to local authorities. There is an underinvestment and the system is not fully working, but there are a number of things that are in train to help it.
At the other end of the spectrum is something that I wanted to say in answer to your earlier question. When we did a survey probably about eight or nine years ago, the actual overlap between us and Natural England was something like 7%. We have different responsibilities, so we advise on different things. Sometimes those come together on the nationally significant infrastructure projects. The Government have looked at a national infrastructure acceleration programme and what pilots can come through and test that planning system, to halve the permission period and the development period, both of which the Environment Agency is involved in.
The Environment Agency has also been given money, under the umbrella of Project Speed, to create a team dedicated to those nationally significant infrastructure projects. We are able to offer that advice to help with that acceleration agenda to the developers coming through that pipeline of what are called NSIPs, but we do it in a way that also ensures that we are creating those greener infrastructure projects that we know people and communities want.
That Oxford-to-Cambridge arc is a really good example of where we, Natural England and others have come together, and people are interested. They are another part of this planning system. People are interested in the environment that they are going to live in, and some of the delays in the planning process are where people are not happy that developments are going to happen, but they become more at ease with it when they can see that the environment is considered in those applications.
The Chair: Our last question is from Lord Faulkner of Worcester.
Q176 Lord Faulkner of Worcester: Will the increase in environmental regulatory developments, such as biodiversity net gain and the measures to address sewage pollution, have a deleterious effect on construction and infrastructure development? Is there a risk that these projects could grind to a halt because of the new regulations?
John Curtin: We touched on some of these in the answer on water. There are a couple of challenges. One is that the scale of environmental improvements needed from the water sector will affect the supply chain that can deliver them, and that supply chain will be used by other developments in this country, so we need to be mindful of that.
The one concern I have is that, if we are overreactive, we could force conventional solutions to some of the challenges at water treatment works and CSOs. They need to be corrected but, if we default to heavily concreted and high-energy, high-carbon solutions, we are losing out on the sort of example that I mentioned of the chalk stream in Norfolk, where wetlands are being used to treat phosphate and ammonia removal rather than an expensive chemical treatment works.
The key in this is not to see it as a negative. Nature-based solutions could be a fantastic solution to some of these challenges that provide multiple benefits and potentially grab more of the nutrients that are causing some of the discussions that we had earlier. I can see it as quite positive, but there may be some supply chain issues to getting some of these solutions, given the scale of what people want to achieve in the next price review and other development demands in this country.
Lord Faulkner of Worcester: What about the efforts to reduce nutrient and pesticide pollution? What effect will those have?
The Chair: There is a target to reduce it by 50% by 2030.
Dr Tony Grayling: That is a challenging target and requires a concerted effort. It goes back to that word “integration”, which John has used rightly throughout these questions and answers. It is about having a mixture of the right planning measures, regulation and incentives. At a strategic level, we see those brought together in the environmental improvement plan and in the plan for water.
It is about a concerted effort to implement the proposals and plans set out there. Part of it is not just planning and regulation. It is those incentives. For example, one of the new standards in the sustainable farming incentive is about the management of pesticides, so if a large proportion of farmers were to sign up to that, that would have a big impact. In the end, it is not any one measure; it is a combination of measures that are designed for the locality where they are being implemented that will deliver that ambitious target.
John Curtin: I can answer this using your challenge about seeing actual things on the ground. There are some great partnerships in Warwickshire, where it is quite expensive for Severn Trent Water to take pesticides out of the drinking water process at the end. It has invested in farming technology, which I have been out to see myself on the farms, with tech on tractors that guides them to make sure that they stay in their lanes and really measure the amount of pesticides that is required, so that it is not lost and it is turned down when the wind direction changes. That is a water company investing in real high-tech farm gear to reduce the amount of pesticides that leaches into the public waterpipe system, and it has an expensive treatment process. Again, that is an innovation bringing all the sectors together for the overall solution, rather than being segmented. We can show you the farm in Warwickshire if you want to come out and see it.
Baroness Warwick of Undercliffe: Just to follow up, 2030 is only seven years away. You have been quite optimistic that all this co-operation and collaboration, which has not existed tremendously well before, will now work very effectively in order to achieve, in seven years, the very challenging targets, as you have admitted. What are the barriers and what is your best guess?
Dr Tony Grayling: That is a hard question. Some of it is quite hard regulation. The requirement on water companies to use the best available techniques at their sewage treatment works is hard regulation, so it ought to be delivered for certain.
As John was saying, some of the best solutions require proper collaboration between the different sectors and the use of nature-based solutions and behaviour change among farmers. The environmental land management schemes are really important in that respect—learning from them as we implement them and adjusting as we go to make sure that those incentives are pitched correctly.
There is the prospect of significant progress. It is an ambitious target, but there is the prospect of getting on a par to it if we implement the integrated plan for water and the environmental improvement plan.
Baroness Warwick of Undercliffe: Do we need more incentives—or, indeed, more sticks—than we have at the moment?
Dr Tony Grayling: The short answer is that I do not know the answer to that question. The longer answer is that it is very important that you look at how public policy is being implemented and what effect it is having, learn from that and then go back and adjust it. It may be possible that there are different incentives and different regulations.
John Curtin: You need incentives alongside the regulations. I was also struck, in the Warwick example I gave, by the actual savings in pesticides and the cost savings on that farm. They did not realise the wasted money that was going into that. It was about sharing that story: “You have the opportunity to make savings in your business as well as reducing your environmental impacts”.
Lord Faulkner of Worcester: What about the local nature recovery strategies? Will they help supplement the planning system?
The Chair: Or are they just another local plan?
Jennie Donovan: I think they will help, because we will have an understanding of the condition of nature now within that local authority, with the opportunities to invest in it, alongside some incentives to invest in it through things such as ELMS. That is bringing together a better understanding of what needs to happen spatially.
It would be great if local authorities had to give material consideration to them in their planning decisions as well, so that you have created that regulation framework as well as that incentive framework. Just understanding what we have there now, and what we need to invest in, will be really helpful as well.
The Chair: I thank our guests for the time they have given us today and for their very informative and helpful answers. I certainly feel better informed at the end of this. I draw the session to a close.
