Finance Committee

Meeting date: Wednesday, April 18, 2012

Official Report 448KB pdf

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Welfare Reform (Further Provision) (Scotland) Bill: Financial Memorandum

Item 3 is an evidence-taking session on the financial memorandum to the Welfare Reform (Further Provision) (Scotland) Bill. I welcome to the meeting a number of Scottish Government officials—Chris Boyland, bill manager, welfare division; Scott Mackay; Ann McVie; and Susan Anton—and invite one of them to make a short opening statement.

Thank you, convener. First of all, I thank the committee for inviting us to speak to you.

From a policy perspective, the bill does nothing more and nothing less than reflect the relevant sections in the UK Welfare Reform Bill—or what is now the Welfare Reform Act 2012—to which the Scottish Parliament refused legislative consent last December. Scottish ministers intend to use the powers enabled by this bill to make changes to the primary and secondary legislation that currently links eligibility for devolved passported benefits to UK benefits such as income-based jobseekers allowance that the 2012 act will abolish.

Passported benefits can be loosely divided into continuing benefits such as free school lunches or free NHS dental care and one-off benefits such as legal aid. They can be paid in cash, as is the case with the education maintenance allowance, or in kind through, say, optical vouchers. When the existing UK benefits are abolished, so, too, will be the associated eligibility hooks and the Scottish Government now has to amend devolved legislation in order to replace them.

That cannot be a simple, like-for-like replacement; we cannot, for example, just replace the phrase “jobseekers allowance” with “universal credit”. Given that universal credit incorporates in-work and out-of-work support, it will have a much broader recipient group than the benefits that it will replace. Crucially, receipt of universal credit will not, in and of itself, provide the same evidence of low income as the existing benefits and will not, in and of itself, serve as a means of determining entitlement to passported benefits as it will be awarded to a much larger group of people.

By April 2013, we need to complete a process that takes in primary legislation, followed by operational adjustments to be made by subordinate legislation. The timetable is not of our making; instead, it is being driven by the pace of the UK Government’s changes and the fact that many of the practical details about how the new UK welfare reforms will operate—for example, conditions for entitlement to universal credit and the personal independence payment—remain to be set out in UK subordinate legislation. At the moment, the Scottish Government does not expect the UK Government to be in a position to convey that essential detail to us before June.

As we are here to talk about the financial implications of the process, we would like to frame the discussion under four key headings: the current spending context; smoothing transition and ensuring continuing access; the information that is currently available; and the further information that we expect to provide.

On the current spending context, the financial memorandum sets out the costs of devolved passported benefits based on current provision and the existing associated costs, on the basis that provision of those benefits will be retained at the current level and that the on-going costs will be met from within existing budgets—although I stress that that is still subject to a final decision by ministers. Existing provision should also be seen in the overall context of the spending review, which has set the budget envelope within which we expect these changes to be considered.

With regard to smoothing transition, the bill’s intention is to ensure a safe transition for passported benefits into the new UK welfare structure. It is not intended to materially reconfigure any of those benefits and, at this time, we are not aware of any plans in that respect. As things stand, we expect that, if they are made, any such plans will be made separately as part of the normal policy development process.

As for the information that is currently available, I am afraid to say that there are necessarily some limits to the information that we are able to produce on the financial implications of some of the changes. For example, although we are able to specify the number of people receiving legal aid as a result of their entitlement to an existing UK benefit, we have not been able to disaggregate fully the cost of that provision from the overall cost of legal aid because the individual cost varies significantly from case to case.

We appreciate the committee’s desire to have as much detail as possible and we will do our best to provide what we can as early as we can. Just to assure members, I point out that, as the committee will be aware, the Cabinet Secretary for Health, Wellbeing and Cities Strategy has given an undertaking to the convener of the Welfare Reform Committee that we will make available to that committee all material on the relevant subordinate legislation at our disposal.

Finally, with regard to further information that we expect to be able to provide, when the necessary subordinate legislation is introduced later this year we will set out details of how passported benefits will be modified to operate under the new UK system and provide an assessment of the financial impact of the changes. That assessment is likely to be based on modelling that we will undertake to identify the optimum eligibility trigger or triggers that will ensure that our existing recipient base has a smooth transition into the new regime. We will also provide information on expected transition costs.

That is all I have to say by way of introduction. We are happy to take committee members’ questions.

Thank you, Mr Boyland. I find it interesting that, as you suggested in your opening statement and as the financial memorandum makes clear, there are many questions that you are probably unable to respond to at this time. Indeed, paragraph 32 of the financial memorandum says,

“The Scottish Government does not expect the UK Government to be in a position to convey the essential detail of its new benefits to it before June of this year”,

and paragraph 33 says,

“It is not possible to set out the detail of the likely financial impact of future plans to modify entitlement to passported benefits until the operational detail of the UK Government‘s welfare reforms is available.”

How much is the fact that you are operating almost in a vacuum hampering your work?

The simple answer to that is quite significantly. At the moment, our focus is on trying to map all the passported benefits for which the Scottish Government is responsible and, as you can see from the list, they are not a homogeneous group. We have never tried to look at these things in the round and, given that they are specific policy interventions that have been developed independently for a specific purpose, it has been quite a task to pull them all together into one place and to start to understand in a bit more detail the various eligibility criteria for individual passported benefits.

We are pretty much clear about the passported benefits and the current eligibility criteria, but in order to take things to the next stage we need a much better understanding of what the levels of universal credit will be and the detailed assessment criteria for personal independence payments. As members know, universal credit will be a much broader benefit and will cover people in and out of work. We understand, for example, that the minimum universal credit payment will be 10p, so it is quite different from the benefits that it is replacing such as income support and jobseekers allowance. However, we are very much working in a vacuum with regard to what the levels will be.

We do not know how detailed the award notification notice for universal credit will be and whether it will show, for example, that people are receiving the benefit because they have children, what the housing element is and so on. Given that we do not have a substantial amount of detail, it is difficult for us to develop new eligibility criteria for the passported benefits for which the Scottish Government is responsible.

Is it your understanding that the delegated powers could in theory be used to extend eligibility? I have another question, but whether I ask it depends on what your answer to that question is.

I do not quite understand what you mean by extending eligibility. It will be up to Scottish ministers to determine the new eligibility criteria for passported benefits, whether against universal credit or something else. For example, we could set our own income threshold for receipt of individual passported benefits.

Yes; I was asking whether you could make such changes. Perhaps I did not put my question quite as succinctly as I should have done.

Is the list of benefits in table 1 of the financial memorandum exhaustive or are there any others that have not been included?

I would not like to say that nothing else will come forward but, at this stage, we are as sure as we can be that that is the list of all the passported benefits that have—

Costs.

Thank you—that is the word that I was looking for. Those are the passported benefits that have costs associated with them. Blue badge parking discs are missing from the list. In addition, someone who is in receipt of a certain disability benefit and who has been treated as being incapable of work is not obliged to repay a student loan. Those benefits are not listed in the table in the financial memorandum because they are passported benefits that do not have costs directly associated with them.

It is worth noting that, although the bill’s primary policy objective is to ensure a smooth transition for passported benefits, we expect that Scottish ministers will use the powers that the bill delegates to them to make changes to Scottish primary and secondary legislation, which are required because they amend references to existing UK benefits. However, those references do not necessarily underpin a passported benefit. An example that is given in the delegated powers memorandum relates to a landlord’s requirement to have regard to a tenant’s eligibility for housing benefit before beginning proceedings to put them out of their flat. I am sorry, but I have forgotten the word for that.

Eviction.

Yes. That is not a benefit per se; it is something in legislation that will need to be changed.

We have received a number of submissions. One of the questions that we asked was:

“Does the Financial Memorandum accurately reflect the margins of uncertainty associated with the estimates and the timescales over which such costs would be expected to arise?”

Clackmannanshire Council’s answer was no. The additional costs that it thought it would face as a result of all the proposed changes included increased staff and transaction costs. How would you respond to what the local authorities perceive to be difficulties with the way in which the financial memorandum has been put together?

The difficulty relates to our inability to frame the successor arrangements precisely until we have the necessary detail. When that detail is available, we will attempt to estimate more accurately the transition costs and what the impact on administration will be. If we pre-empt our receiving the detail from the UK Government, any estimates of costs will be speculative. Therefore, we will refrain from making such estimates until we have the detail.

Yes. Some of the other organisations that sent in submissions gave exactly the opposite answer. It is as if the committee is asking questions in a vacuum.

I open up the discussion to other members of the committee.

The submissions that we have received include one from the Convention of Scottish Local Authorities, which talks about the need to have parallel systems of entitlement. That is because, as I understand it, the change that we are talking about will not take place overnight—it will take place over the period 2013 to 2017. It sounds as if the local authorities will have to run two systems, which will be quite expensive. Have you looked at that? Is it possible to estimate what the cost will be?

No. We cannot estimate those things until we know what the successor arrangements will be, as my colleague said. We are alert to the fact that one of the advantages of a passported benefits system is that it reduces the need to set up an independent assessment process. We will have very much in our sights the need to come up with a system that is as efficient as possible for both the Scottish Government and local authorities and which avoids the need for overly complex assessments for such benefits in the future.

11:30

Are there bound to be extra costs in the interim or changeover period whatever the system is, because there will need to be two systems?

It depends, but yes, that would follow. We will have to look at that.

I think that Glasgow City Council raised the issue of data sharing. Are we clear, for example, that the Department for Work and Pensions will be willing to share data with the Scottish Government or local authorities? What stage are we at in knowing that?

That is very much a live issue, which we are having discussions with the DWP about at the moment.

So we do not know where we are.

We are at the early stages of the process, and we have quite a long list of things to do. Data sharing is definitely quite high up the list of things on which we need to engage with the DWP.

I would think that data sharing is crucial. If local authorities do not have to do that or the Scottish Government does not have access to data and has to start again, that will inevitably make the costs higher.

Absolutely.

NHS Lanarkshire has said:

“If additional costs are incurred, it would seem reasonable to expect that these costs are met by the Scottish Government”,

although, of course, the bill is based on United Kingdom Government legislation and is the result of UK Government changes. What is your view on that?

The Treasury’s “Funding the Scottish Parliament, National Assembly for Wales and Northern Ireland Assembly: Statement of Funding Policy” is clear that where

“decisions of United Kingdom departments or agencies lead to additional costs for any of the devolved administrations, where other arrangements do not exist automatically to adjust for such extra costs, the body whose decision leads to the additional cost will meet that cost”.

We would expect to pursue the budget cover for additional costs.

Indeed, but would the DWP pursue that right through the process, or do you believe that it will provide only limited support? Does it accept that argument?

We have made clear our expectation that we will pursue the funding under the arrangements in the statement of funding policy. Obviously, there will be some negotiation on the extent of budget cover that will be provided, but our starting point will be that we will expect full cover for all the additional costs that arise from the legislation.

A local authority might say to you that the additional costs are £300,000 and a similar-sized local authority might say that they are £1 million. Who would say, “Hold on a second. Why is a local authority saying that?”? The situation is horrendous. Who would decide which authority was incurring the costs that it said that it was and how they were being incurred? What is the likelihood that the DWP would basically say, “Well, yeah, you’ve said it’s going to cost £8 million or £22 million”—whatever the cost ultimately is—and that it would then be paid? Would they be long-term costs or one-off DWP payments?

The committee has already referred to two elements of that. There will be transition costs.

Yes.

As more detail becomes available, the question for us to assess is the extent to which additional costs will arise as a result of the legislative changes. We would seek to negotiate an appropriate settlement on the basis of both of those elements once we have a sufficiently robust analysis of the financial impact.

Obviously, there would be a negotiation with the DWP on guarantees on what the final level of any budget transfer would be. We would start from the position that we would expect full cover for the robust analysis that we will develop when sufficient information is available to us to do so.

You would expect the organisations on which there will be an impact, such as the NHS and local authorities, to tell you what they expect the costs to be, and you would then advise the DWP appropriately.

We would work with them to ensure that we had a robust assessment of the costs that will arise from the changes.

Yes. Okay.

As the convener said, everyone here seems to be struggling in the dark, as we simply do not have enough information. To be honest, it strikes me that the UK Government has not really considered some of the effects on other organisations. What consultation was there with the devolved Administrations and local government, for example, on how this major change in benefits legislation would affect others?

That consultation would have been rolled up with consultation on the UK Welfare Reform Bill. The committee will be aware that that bill was brought forward at a considerable pace, given the widespread, sweeping and systemic change to the UK welfare system that it represents.

The issue of passported benefits is clearly not unique to Scotland—England and Wales have the same job as we have in making adjustments to the passported benefits for which they have responsibility. They are in the same position as we are, in that those adjustments must necessarily follow the full working-out of the regulatory framework that the legislation will put in place, which is complex and is being battered through at considerable speed.

The consultation on the bill as it was going through the Westminster parliamentary process involved the normal Westminster public bill committee stages and so on. The Scottish Government contributed to that process in a number of different ways, at ministerial and official level. We ensured that our views and concerns were known. There is a question about the extent to which the UK Government heard those views and acted on what it heard. However, we took whatever opportunities were available to us to make our concerns known.

With regard to the 10 per cent reduction in council tax benefit, we have heard evidence from Children 1st and others that people are not taking up their current entitlement, yet we are likely to see a 10 per cent reduction in the budget that is devolved to us. It has been suggested that, if we had a campaign in the next 12 months to encourage uptake, we might get a bit more devolved to us. I do not know whether that is the case, but there is concern that, as a considerable number of the passported benefits are not being taken up anyway, the budget will not be available to support them, even if we were to be able to translate the entitlement to the new system.

You have to look at it on a benefit-by-benefit basis. Different passported benefits are awarded in different ways. As we said, some of them are continuing. For example, a family would expect their child to receive free school meals for the whole time that their child is at school. On the other hand, a person might never apply for or receive legal aid, but they would hope that it would be available to them if they needed it and qualified for it.

I imagine that the question about money running out is not unique to the provision of these benefits. We would have to go back and consider it in the context of the spending review, which is what all such matters are framed by. That has set the budget envelope with regard to our consideration of the entitlement changes that we need to make.

So it will be difficult to promise that we could keep the entitlements the same. That is almost a promise that we cannot make.

We are proceeding on the basis that we will consider the changes to entitlement with a view to maintaining provision to roughly the recipient group that exists at the moment. As things stand, we have no reason to consider the matter in any other way—either increasing or decreasing. Until there is a final ministerial decision, we will continue to consider what we need to do in order to maintain provision to the people who are currently receiving those benefits.

Dr Murray mentioned the issue of council tax benefits, so I will not ask about that—I had a list of four issues, so that has narrowed it down for me.

Children 1st raised the fact that the Welfare Reform Act 2012 has effectively abolished aspects of the social fund and it is making recommendations that there might be a need for primary or secondary legislation at some point in the future to recreate those aspects that have been lost. I know a family who needed urgent help with funeral expenses because they unexpectedly lost their teenage son in a tragedy. What steps might be taken to provide crisis loans in that sort of situation?

Successor arrangements for the social fund are being dealt with as a completely separate strand of work. We are still at quite an early stage of developing them. Ministers have agreed that we should work with local authorities to put in place a successor scheme from April 2013. To help us with that, we have set up a joint COSLA and Scottish Government design group with representatives from local authorities and Scottish Government policy interests to discuss the mechanics of how that will happen. The first meeting of the group will take place next week on 26 April.

I will trust that you have that one in hand.

The evidence that was provided by Highland Council asked whether there would be any coverage for school clothing grants. A free school meal entitlement is being looked at, and I wondered whether school clothing grants should be addressed.

We are not treating school clothing grants as a passported benefit per se. Local authorities have the discretion to offer those grants, but there is no automatic entitlement with eligibility hooked into a current benefit. Provision of such grants is very much a matter for local authorities rather than the Scottish Government.

Hopefully the Scottish Government has noted that evidence.

Table 1 in the financial memorandum, which sets out the detail of the projected spend on each of the passported benefits, is helpful. Earlier you mentioned that there was a change in the criteria for the universal credit and that the existing passported benefits might be impacted upon by that change. Is that likely to have any geographical effect that we need to take into account? We might assume that the spend will happen in the same pattern around the country as it is happening now, but perhaps the change in universal credit will impact on the spread of benefit spend across the country.

I cannot imagine that there will be a geographical impact. Beyond existing demographic factors, I cannot see that the changes to entitlement will have a geographical bias one way or another.

This is my final question, convener. I have just asked a series of quick ones this time.

Hear, hear.

Thank you, Mr Mason.

A different set of criteria will apply here than will apply in the rest of the UK, and there will not be the benefit of having standardised materials to train people in what to use as eligibility criteria. Do you have any view about the representations that have been made in the written evidence about the costs to train staff of different organisations at a local level to advise individuals about their eligibility? Do you have a good handle on the likely costs?

Not yet, but I refer to comments that were made about developing new eligibility criteria for the passported benefits. Taking account of efficiency in a broader sense will be part of that decision-making process, so factors such as training and guidance materials will be part of working up the most effective model.

Some of that will come under the consideration of transitional costs.

Absolutely. We will be looking to include that factor in the calculation of transition costs.

Thank you.

You have partly pre-empted my question by telling us about the group that has been set up with COSLA. I did not get the impression from the COSLA representatives who were at the Welfare Reform Committee yesterday that things are very far advanced—maybe we just did not get into that area and we will have to look a bit deeper into it. Are you entering into discussions with COSLA on the basis that there is an expectation that the Scottish Government will be meeting the costs 50:50 or 60:40? Is there any sort of prediction about how responsibility for dealing with the impact of the changes will be shared?

11:45

Do you mean in relation to the success of the arrangements for the social fund?

Yes.

The DWP has been clear that it will transfer to the Scottish Government the money that is spent on community care grants and crisis loans for living expenses in Scotland at the point of transfer, and our ministers have agreed that that money will be used for the same purposes. It will be put to supporting the successor arrangements. The funding for the successor arrangements will come from the DWP to Scottish ministers and then to local authorities.

The DWP has also accepted that there will be transitional arrangements with what it calls the new burdens agenda. Parallel discussions are happening in England, where the DWP is transferring responsibility for elements of the social fund to local authorities. It is expecting the Scottish Government, the Welsh Government and local authorities in England to present information about how much it will cost to operate the new scheme, so that it can take a view on how much it is going to give us to help us to run the successor arrangements. Again, that money will be transferred from the Scottish Government to local authorities.

I will be curious to see how the discussions on the share of that pan out.

I dropped a question on Mr Boyland at the Subordinate Legislation Committee about the vehicle that will be used for any legislation that is required to address changes to the council tax benefit system. Have you had an opportunity to consider that? Is it likely that the bill will be the vehicle, or is it more likely to come through in subordinate legislation or a separate bill?

As I recall from our conversation yesterday, we were talking about the possibility that council tax benefit could be used as an eligibility hook.

Exactly.

So your question is continuing on that point.

Yes.

We discussed the issue briefly on the way back up the hill from the Parliament yesterday. I certainly think that we will look at that as one of the possible mechanisms for replacing the eligibility links to the benefits that are being abolished. The question that we will have to answer is whether it would deliver the benefits to the recipient group that we wish to receive them.

Modelling will need to be done on whatever final mechanism is chosen to demonstrate that the people whom we want to get the benefits will get them. It might well be that we will want to put the use of council tax benefit as a hook through that modelling process to see what we end up with and whether it would do the job that we want it to do. If it does, we might well come back to the Parliament and say that we believe that it is an appropriate mechanism to replace the links to the existing benefits. If it does not, I do not see that we would have any reason not to say that it does not and that the mechanism that we have chosen serves our purpose better. However, that work will need to be done with the policy design work and the continuing analysis and modelling between now and, at the earliest, the end of the year.

That is helpful. Thank you.

Dr Murray stole my phrase to describe the issue. We are essentially fumbling around in the dark on it. I hasten to add that I do not consider that to be your fault. You are obviously being given limited, if any, information by the UK Government.

You talked about the speed at which the legislation is being put through, but it does not seem to be matched by the speed at which information is being trickled down to the devolved Administrations. What recent discussions have you had with the UK Government? Has it given you any indication as to when you might get some concrete financial data?

I am trying to remember the date when the Cabinet Secretary for Health, Wellbeing and Cities Strategy last met Iain Duncan Smith. It was definitely in the past month. I am sorry—I was there at the meeting, which was at 6.30 at night in the Parliament, but I cannot remember which day it was. There are on-going discussions between ministers and there are certainly on-going discussions at official level to try to get the information. The DWP has been willing to share information as soon as it has it, but it does not have much to share with us yet. As the financial memorandum and other accompanying documents set out, we expect the first set of regulations by June and further regulations in the autumn that lay out the detail of universal credit. However, as you rightly point out, we have not got those yet.

To be fair, one consequence of the pace at which the UK legislative process is moving is that the UK Government does not necessarily always have the information to provide. The UK Government has a series of complicated jobs to do, and the information that we are talking about will come out as a result of that. Therefore, we certainly would not want to suggest that anything is being withheld. The pace of change does not aid the early availability of that information.

I was not suggesting that the UK Government is withholding information—I would not make that accusation. However, it strikes me as odd that scenario planning is not being done to show what we might expect to receive, although I guess that, as you say, the detail needs to be fleshed out. In the written responses that we have had, some people say that they can afford the changes, which strikes me as rather bizarre when we do not know what the changes will be; some people say that they just do not know, which is the most likely scenario; and others say that they definitely cannot afford it, which again strikes me as odd when we do not know what the implications will be. I note that you are having discussions with COSLA, but are you having discussions with other organisations, such as the NHS and third sector bodies? What discussions are you having with those organisations and what are they feeding into you?

We have on-going engagement with COSLA and a variety of stakeholder organisations. We have two external reference groups: the welfare reform scrutiny group, which we co-chair with COSLA; and the housing benefit stakeholder advisory group, whose interest in the issue might be slightly tangential, although it is an example of the net that we are casting. The welfare reform scrutiny group, which has discussed the issue of passported benefits previously and which I expect will continue to do so, has been meeting since the beginning of last year. We expect it to continue to meet throughout the process.

Michael McMahon asked whether council tax benefit could be tackled in the bill. I have a similar question in relation to the social fund. If I heard correctly, the social fund is being treated as a separate stream of work and has no part in the bill as it stands. Given that the bill will be enabling legislation, could the framework of the social fund be tackled in the bill and dealt with in regulations thereafter, or will that require a separate piece of legislation?

The bill will be a piece of enabling legislation. My understanding is that the social fund might be within the scope of the bill but, at present, the clear ministerial decision is that the bill does not include provisions in relation to the social fund and council tax benefit. The ministerial decision is that those provisions will be progressed separately.

I have a second question, which is a follow-up to the question about data sharing. I think that that was described as a “live issue”, so you obviously cannot say too much about it but, given that there must be protocols in place under the current set-up, do you have concerns about that live issue or is it something that has just not been thrashed out yet?

It is the latter. Everyone recognises that there will be a need for data sharing. The issue that has not as yet been sorted out is about the mechanics and the nitty-gritty of how we do that.

System requirements sit beneath any protocols to share data. That is where the complexities come in. The issue is not just about the agreement that we will share; it is about how we get potentially individual systems to speak together in a timely manner and in a way that delivers the service and support that we need.

I have a final question, which is just for clarity. I think that you are working under the assumption that, in relation to passported benefits, we will as far as possible end up with the same provision as at present, or thereabouts. However, you stressed that that is subject to final approval by ministers. Is that issue under active discussion, or did you simply stress the point to make it clear that ministers will take the ultimate decision? Are discussions taking place about whether we might not end up with the same provision?

As Ann McVie pointed out near the top of the session, nobody has ever considered the range of benefits holistically. I honestly could not say whether consideration is being given in individual policy areas to the possible future of individual benefits as part of a particular policy picture. However, we have not advised ministers on whether they should make material changes to the benefits, and I certainly do not expect us to do so.

As we said, we are still in the early days of the process. We are still a little in the dark about what universal credit will look like and what the eligibility hooks or criteria might be. We are just being naturally cautious civil servants and saying that those issues are subject to final discussion with ministers once we are a bit clearer about the options for the eligibility criteria.

I have a quick question on the principle, leaving aside the mechanics of the legislative process that we are having to go through. To pick up on a point to which Gavin Brown alluded, because we have to do something different we have an opportunity to reflect on Scotland’s particular needs and to amend where necessary. Obviously that would be up to ministers, rather than you. However, do we not have an opportunity to tailor benefit entitlements to better suit Scotland’s needs, rather than taking the one-size-fits-all approach that has been taken until now?

Yes, we do. I do not think that there is any intention to default to a one-size-fits-all approach. It is worth pointing out that, for example, free prescriptions are a passported benefit in England but are offered universally in Scotland, so variations already exist between the two systems.

So there might be scope in the process to tackle the needs of specific groups, such as armed forces veterans—I am a member of the cross-party group on them. The current opportunity might allow us to take a different approach in Scotland to issues for particular target groups.

Potentially, yes.

That appears to have exhausted our questions, given the fairly limited information that we have on which to base our questions and the limited answers that the witnesses can give. Do you have any further points to raise with the committee?

I do not believe so.

In that case, I thank you for your attendance.

11:58 Meeting continued in private until 12:06.