UK access to EU funds

67. The debate on access to EU funds has been academic in this context following the decision by the Council of Ministers in 1990 that construction grants would not be payable until a Member State had met its MAGP targets. In the case of the UK this has led to greater resentment on the part of the industry who view the purchase of licences by Spanish and Dutch companies registered in the UK as a means of reducing their own fleets to meet MAGP targets, whilst putting a further obstacle in the way of the UK meeting its own obligations.[234] Whatever the facts behind this accusation, the UK is now moving into a new stage as regards construction grants. DGXIV of the Commission categorically told us that the MAGP rules required a Member State to meet its overall target and the individual target for any particular segment it wished to support. Hence, under the current figures, the UK is effectively at the stage where it could provide grants to most sectors, with the principal exception of the pelagic and beam trawl fleets. This removes one obstacle but there is another in the cost to the UK of taking up grants from the EU. Under the terms of the Fontainebleau agreement, the UK receives a budget rebate on its contribution to the EU. In return, it agreed to pay an abatement on any additional funding taken up which means that for every pound the UK receives from EU grant schemes, the UK Treasury returns 71 pence. This applies across the board, not just to the fishing industry and we have commented before on its impact in agriculture.[235] The Minister admitted that this was a consideration in not taking up the money available for fisheries.[236] It is a factor unique to the UK and is therefore a clear disincentive to apply for EU grants other EU fleets receive.

68. EU structural aid to the fishing industry is available under the Financial Instrument for Fisheries Guidance (FIFG) which covers all areas of the EU. It aims to contribute to achieving a sustainable balance between fisheries resources and their exploitation; to strengthen the competitiveness of structures and the development of economically viable enterprises in the sector; and to improve the market supply of and the value added to fisheries and acquaculture products.[237] It therefore applies to the whole industry and not just to decommissioning or renewal of the fleet. For the current period, the regulation required each Member State to present a sectoral plan in the form of a single programming document for the fishing industry from 1994 to 1999, which took particular account of MAGP targets. The UK was awarded FIFG assistance of E123.62m towards a total spend of over E300m, of which E19.8 was earmarked for the Highlands and Islands and E15.1m for Northern Ireland. The EC described take up of FIFG funds in England and Wales as poor at around 55%, meaning that "there will be a significant underspend of the funds available".[238] It attributed this to the cutbacks in public expenditure, lack of funding for aquaculture and "limitations to the vessel modernisations scheme". EU money is also available through the Pesca initiative under which the UK may receive E37.4m between 1995 and 1999 "to assist areas

dependent on fisheries to cope with the social and economic consequences of structural changes in the fishing sector".[239] This is heavily oversubscribed.

69. The future shape of FIFG is under discussion in consequence of the Agenda 2000 changes to the structural funds. The Minister told us that the negotiations were not likely to be completed until October.[240] His main objectives for the negotiations were "to support the Commission's proposal for an aggregation penalty, if there are public funds being used for rebuilding; and also to make sure that there is proper use of Community funds."[241] Reform of EU structural aid does not fall within our terms of reference but we note the wishes of the SFF that assistance to the fishing industry should continue to be made on a sectoral basis, rather than a regional one,[242] and the belief of the RSPB that the FIFG "should be directed at, and only at, activities compatible with sustainable development of the [inshore] sector".[243] We look forward to the outcome of the negotiations and hope that the Government's objectives will be informed by a new vision of the shape of the industry.

70. The Anglo-North Irish Fishermen's Organisation indicated what could be achieved with FIFG assistance. It described the modernisation scheme for local vessels as "a tremendous success", stating that "since 1996 over 130 local fishing vessels have benefited from European and national grant assistance".[244] This had helped improve safety on vessels and created jobs onshore, for example among marine engineers. Although Northern Ireland is a special case as it has Objective 1 status, this indicates the real benefits of assistance for modernisation and the knock-on effects of grants to the fishing industry. We are concerned therefore about the abrupt closure of certain fisheries grant schemes under the FIFG as a result of the change in MAFF's spending priorities announced on 21 May 1999. These included the marketing, processing and port facility grant scheme and the vessel safety equipment grant scheme. The Minister told us that in relation to the former "there might be an opportunity to return to that, as part of the Agenda 2000 structural funds"[245], but such sudden and unpredicted changes make it impossible for the industry to plan or even think ahead and these have come at a particularly difficult time when the processing side needs to invest to offset the heavy increases in effluent charges under the Waste Water Directive.

71. There has been some confusion over the status of the fishing vessel safety equipment scheme. Immediately its suspension was announced the Deputy Prime Minister made it clear that it should be reinstated, though not who was to pay for it,[246] and Mr Morley assured us that all applications already submitted would be considered and that discussions were still continuing on the future of the scheme.[247] This situation is further muddled by the fact that there are two safety schemes, one funded by the FIFG and one by the UK. We received a memorandum from MAFF indicating that the former had already been closed in Scotland and Northern Ireland because the funding had been fully committed in those countries.[248] Yet Mr Morley claimed that the EU scheme had been "closed in all the countries" of the UK [our emphasis] so the only real impact of the announcement was the closure of the UK-financed Fishing Vessels (Safety Improvements) (Grants) Scheme 1995 to applications throughout the UK.[249] The Minister accepted that "there is a case for safety grants".[250] However, his Department had no plans and "no provision for any new EU schemes" for safety equipment even when new FIFG funds become available.[251] It will be the responsibility of the Scottish Parliament and the Northern Ireland Assembly to decide if they wish to reintroduce such schemes for their respective countries.[252] We are disturbed by the confusion surrounding grants for a matter as important as safety. It is not clear what assessment was made of the impact of the loss of this scheme, although we note that MAFF had already fought to keep it when it had previously been under threat from the Treasury.[253] We are also concerned that fishermen in England and Wales may not receive help in this area that is available to their counterparts in other parts of the United Kingdom. We recognise that in other industries it is the responsibility of the owner to meet safety obligations. However, we note the inequity of the funding position in the UK and between the UK and other EU states and therefore we recommend that the vessel safety equipment grant scheme be reinstated.

Scrap and build

72. Although some fishermen's organisations called simply for Government aid for new vessels,[254] there was general recognition that this should take the form of a scrap and build scheme in order to overcome the problem of technological creep.[255] Since newer vessels are likely to catch more fish, this has to be taken into account to avoid introducing extra capacity into the fleet, one of the main objections raised by opponents to grants for modernisation or new build.[256] The SFIA undertook some preliminary work during MAGP III to see if a scrap and build scheme could meet with EU approval, with some indications of success.[257] It submitted to our inquiry further details of the scheme, which was based on "the concept of basing the level of subvention offered on the difference in capacity and/or effort between the newly built vessel and the vessel(s) to be withdrawn from service".[258] A less complicated proposal for "a sensible scrap and build scheme" was put forward by the NFFO which involved "an appropriate replacement ratio ... say a two for one ratio".[259] In addition, the CFPO argued that a scrap and build scheme could be cost-effective if it allowed the fishermen to scrap their vessel and retain their licence VCUs and track record; it considered a 10 per cent reduction in capacity appropriate if further reductions were needed in a particular segment.[260]

73. As the North Sea Fishermen's Organisation advised us, "scrap and build policies, or indeed any assistance in restructuring the fleet, is a thorny subject."[261] Supporters among the industry were convinced that "we do need support to rebuild and modernise the fleet".[262] They were backed by the SFIA which believed "public aid for fleet renewal is essential" because this was the only way "to persuade vessel owners to make individual investment decisions which reduce their fishing capability (which in turn reduces their potential to generate income)".[263] Furthermore, the SFIA argued that scrap and build would "contribute to an overall reduction in capacity and improvement in the fleet age profile".[264] These arguments address one objection to the proposal but there is still a matter of principle. Mr Morley gave two reasons for not using public funds for reconstruction. First, "we used public funds to modernise and expand the fishing fleet in the 1980s, quite a lot of money; in the 1990s we used public funds to decommission and reduce the fleet".[265] He described this alternation as "madness". He was supported in this by economists from the University of Portsmouth who considered that "the wisdom of providing public money for fleet investments, while at the same time implementing programmes of capacity reduction (again with public money) because levels of fishing mortality are excessive is highly questionable".[266] Secondly, the Minister argued that it "is not good for sustainability, it is not good in relation to business practice, and, in the end, it is not good for fishermen themselves if you are artificially ... through public funds, increasing capacity which cannot be sustained".[267] The pressure to finance and maintain new vessels built with the aid of public money without the constraint of market forces could lead to the landing of blackfish in order to meet bills.[268] This is, of course, true of any investment in new vessels, however funded. More realistic is the verdict of the Highland and Islands Fishermen's Association which concluded that, while government assistance was of value, "real progress in both vessel and gear quality will only come from an internally well-funded annual production cycle where sound and sufficient earnings will put a confidence in place for future years".[269] This is easier to achieve in the Highlands and Islands given the substantial funding they have had than it is for sections of the English industry but we strongly endorse this view.

74. One PO, the North Sea Fishermen's Organisation based in Grimsby which was originally set up on behalf of Anglo-Dutch flag-ships, listed arguments for and against grants.[270] The most persuasive in favour was the knock-on effects of investments on the ancillary industries which could outweigh the initial support given to vessel owners. However, on balance, it proposed that "restructuring of the UK fleet occurs without such funds".[271] In the place of such schemes, limited funds should be used to help fishermen move away from high impact methods of fishing; for example, by assisting shrimp vessels to fish with more selective gear or to leave the industry. The Joint Nature Conservation Committee concurred with the use of support for the development of "inshore initiatives that promote small-scale fishing and simple fishing methods".[272] Other imaginative suggestions for the targeting of funds for restructuring the fleet included aid for marketing seafood[273] and early retirement.[274]

Conclusion

75. The economists referred to earlier also argued "that a profitable fishing industry should be capable of funding its own reinvestments - as is expected of many other industries - and that the priority should be to implement a management system that will ensure a profitable industry".[275] We agree that when an industry is efficient and profitable there is no case to be made for public subsidies and when it is not, public subsidies are equally hard to justify unless clearly identified substantial social goods are achieved. The amount of investment in some sectors of the fishing industry at the moment as we have seen on our visits and as the Minister observed at the Fisheries Exhibition[276] implies that there is sufficient profit in those segments to obviate the need for grants for new build or modernisation on a general basis. Indeed, Mr Wentworth of MAFF suggested that the industry was already operating its own version of a scrap and build scheme.[277] We are disappointed that the industry is quite so alarmist on this issue. For example, the SFF claimed that the failure to have access to EU funding made "this whole area ... perhaps the most depressing aspect of current fisheries policy" and asserted that "If it continues unchanged in a single continental market for fish and fish products, profitability levels will decay inexorably and the lethal combination of poor commercial returns and ageing tonnage will lead to increases in accidents with loss of life and vessels."[278] We are more inclined to agree with the Government that "the first priority for EU funding remains the reduction of excess capacity and that sustainable fishing means that fleets ought to be capable of generating sufficient returns from catch proceeds to justify investment in modernisation or renewal without the need for publicly funded subsidies."[279] We are also disappointed by the attitude of the industry in demanding subsidies without offering a properly worked-out proposal for a scheme. It is impossible that any Government would ever concede a demand for grants without knowing the extent or shape of what is requested. On the arguments put forward for funding for new build, we have sympathy with the complaints of the industry about the money received by their counterparts in other EU states. We support the Government in its attempts to tighten up the rules for such assistance. Nevertheless, we do not recommend that the Government adopt an industry-wide scheme to aid the construction of new fishing vessels, whether or not under a scrap and build approach.

76. We recognise, however, that a case may be made for assistance for other purposes. The Minister stressed that he was not saying that "we should not use public funds for the fishing industry", specifying a preference for "some element of modernisation, in terms of crew accommodation, ice facilities, things like that".[280] These issues are important as they affect the ability of the industry to attract new entrants. We were told by vessel owners that young men were deterred from becoming fishermen by the poor living conditions onboard vessels. We are acutely aware that some segments of the industry are not profitable and that they could be helped to become so through the judicious use of public funds. The criteria for such assistance must include the continual reduction of fishing capacity in line with the available fish stocks, safety, the sustainability of the fishing method, and that short-term targeted assistance would be effective. We recommend that any such grant scheme for vessels working within low-impact fisheries be based on these criteria.

TRADE IN LICENCES AND QUOTAS

77. The greatest change in the fishing industry since the last Agriculture Committee Report has been the growth of trade in licences and quotas. All fishing vessels (with "one or two very minor limited exceptions")[281] have to obtain a licence issued at the discretion of Ministers before they can fish for profit for sea fish. There are different types of licences available according to the category of fish stock the vessel is permitted to catch and land, and each individual licence specifies the tonnage and power of the vessel to which it is attached. The current licensing schemes have applied to the over 10m fleet since 1984 and the under 10m fleet since 1993. A review of the licensing arrangements was ordered by the Government in December 1997. The joint departmental/industry working group entrusted with this task reported on 31 March this year. It concluded that "the overall structure of the present licensing regime should be retained",[282] although it made several recommendations for adjustments to the system. A second review on the management of the under 10m fleet is still underway and it is likely that this will lead to changes in the licensing arrangements for the vessels subject to this regime.[283]

78. The licensing scheme is closed to new applications in all sectors. To obtain a licence, therefore, it is necessary to have entitlement based on a licence already issued to a vessel. New vessels can only be introduced into the fleet if the fisherman obtains a licence, with sufficient capacity, from an existing vessel within the same sector of the fleet. In order to avoid technological creep and assist capacity reduction, such transfers are subject to a penalty of 10 per cent for single licence transfers, 20 per cent for aggregation of two licences and 30 per cent for three or more (these are general figures, discounting exceptions). All licences aggregated must be of the same type and no disaggregation is allowed. The previous Government allowed the transfer of licences in this way, rather than insisting that once detached from a vessel they should all be returned to the Minister who retains legal ownership, in order to free "ownership and fleet structure to develop in response to economic and other needs".[284] These other needs include the transfer of a licence within a family, the wish of a fisherman to leave the industry, the wish of new entrants to join the industry, the restructuring of existing fishing businesses and the modernisation or replacement of ageing fishing vessels.[285]

79. Licences are linked to the management arrangements for quota. The national quotas for each stock subject to a TAC are allocated within the UK on the basis of track record, ie the catch levels of each vessel over a certain period. Until this year the reference period was a rolling three-year one; since 1 January 1999 it has been fixed as the period 1994 to 1996, a system known as Fixed Quota Allocation (FQA). For management purposes, the allocations are made to three groups - individual POs on behalf of their members with vessels over 10m, the non-sector (vessels over 10m not belonging to a PO) and the under 10m's. The latter two groups are managed directly by UK Fisheries Departments. The non-sector receives a monthly catch limit which is incorporated into each vessel's licence, while the smaller boats have a collective quota and are allowed to fish until this is exhausted at which point they are prohibited either by means of licence changes or by statutory orders. When any of the three groups has taken its full allocation, its members are prohibited from landing any further catches of that stock or species.

80. POs are allowed to manage their quota allocation as they choose. Most that we spoke to operate a pool system, with the alternative being individual quotas. The Aberdeen Fish Producers' Organisation, for example, grouped all track records in a common pool and issued monthly or two monthly quotas.[286] However, members who had bought additional entitlement "are allowed to catch their own purchased fish when they want".[287] The Cornish Fish Producers' Organisation told us that "This PO is relatively unique in operating a pure pool system",[288] where all quota is distributed equally. This gives vessels flexibility to move between different sectors.[289] POs maintain their own records on landings from each vessel to ensure that quota limits are respected. Their ultimate sanction against a member who breaks the rules is to fine them.[290] However, the Chairman of the CFPO pointed out that this is against the spirit of cooperation between members: "We have to operate together or we fall to bits".[291] There is also close cooperation between most individual POs. The Chief Executive of the CFPO explained that "We have to swap quotas and all sorts of things on an almost daily basis and we all work as a team".[292] There have been difficulties over the admission of quota hoppers to some POs, specifically Fleetwood and the North Sea PO based in Grimsby which was formed by and for quota hoppers, but the industry has found a way to handle these developments in private, if not always in public.

81. As implied above, a growing issue for POs is how they handle additional quota purchased privately by their members. This is a question which is going to become even more pressing given the increase in trades between fishermen. Mr Deas of the NFFO dated this development to the decision to make licences transferable, thus making them tradeable.[293] Subsequent changes such as "liberalisation of swaps between producer organisations and attaching the track record on vessels, the quota entitlements, to the licence rather than the vessel ... made administration of the industry and the quota system more rational and more sensible, but they add up to a step by step movement towards trading in quota".[294] The Aberdeen Fish Producers' Organisation argued that the key change was the decision in 1995 to attach the track record to the licence which encouraged "the practice of vessels being sold with the licence being retained by the seller for track record purposes".[295] It saw the introduction of FQAs as contributing significantly to the increase in the trade of licences and quota entitlement.[296] A fixed share of the UK quota for a particular stock gives more stability to the system and hence adds to the value of the asset. FQAs were introduced and welcomed by fishermen as a means of removing the incentive for fishermen to catch as much as they could to maximise their quota allocation for the following year, by including "ghost fish" in their catching statistics if necessary to support their claims.[297] The fresh impetus FQAs have given to the growing market mechanisms in the industry was perhaps an unintended consequence.

82. The market for licences and quota has three elements which Mr Goodlad, Vice President of the SFF, explained with admirable clarity: "The first part is the authorisation to fish. You cannot go out and fish without the appropriate licence. The second part is that the licence is quantified in terms of its VCUs, its vessel capacity units. You will need a larger licence, a larger number of VCUs, to place on a larger trawler than you will need to place on a smaller trawler. These VCUs now have a value. If you were to build a new ship of a certain size, you would need so many VCUs. The more VCUs you need, the more you have to pay. The third element of the fishing licence value is the so-called track record, the fishing entitlement which comes with the licence ... Those are the three parts which are now bought and sold within the industry and fishermen recognise the value attached to all three parts of the licence."[298]

83. The extent of the trade is hard to quantify. It includes not just outright sales but leasing arrangements for quota either on a short-term or long-term basis. We accept Mr Goodlad's caution that "the vast majority of licences on fishing vessels in the UK have not changed hands"[299] but the number of fishermen involved in such transactions and the value of the trade is still substantial and growing. For example, one PO, the Scottish Fishermen's Organisation, told us that 120 of their 450 member vessels now have "some additional fish that they have bought, leased or whatever".[300] Mr Morley told us that the trade "has now become very big business ... it is calculated that the licences and quotas are worth probably over £1 billion to the industry, it is worth probably more than the total value of the fishing fleet, actually, in terms of the value of the vessels".[301] While all would agree with the latter half of this statement, the figure of £1bn is probably an underestimate: we heard a similar value put on the Scottish industry alone which represents around two thirds of the UK's catch.[302] The NFFO advised us that it was not straightforward to calculate the tonnage which had changed hands, although this information is held by the UK Fisheries Departments, because "licences can be transferred with the vessel more or less as a byproduct of the sale or transferred to a different vessel either as a straightforward transfer or as part of an aggregation exercise involving two or more licences".[303] It was able to tell us that as of February this year "whitefish licences are trading at around £500 [per] vessel capacity unit", depending on the specific quota entitlement attached to the licence. Prices for pelagic licences were much higher.[304] Two had recently changed hands in Scotland for £5m and £6m.[305] We heard informally that the price of quota had been subject to rapid inflation in the last few years. White fish quota used to cost £200-300 per tonne. It had now reached 150% of market value, which itself has increased, with the result that quota for cod was priced at £1,800-2,000 per tonne.[306] Finally, rental values for cod, haddock and saithe quotas were around £300 per tonne per year.[307]

84. Most representatives of the fishing industry voiced their strong disapproval of the trade but also their acknowledgment that it had now become "a recognised and accepted practice which cannot be stopped because of the amount of money which has changed hands".[308] The trade has had a profound impact on the structure of the industry. It has led to what the North East of Scotland Fishermen's Organisation described as "self- rationalisation" of the fleet,[309] a point also made by the individual fishermen we met in Cornwall.[310] The Minister believed this had caused the increased profitability the industry had experienced recently.[311] In particular, two witnesses attributed the generally accepted fall last year in the levels of blackfish to the trade. Mr Smith of the SFF simply pointed out that "the individuals who are catching more fish than others have bought extra quota so that if they do catch more fish then they have entitlement to land it legally."[312] Mr Gilland of the NESFO offered the more considered view that "if somebody has purchased a track record to legally land what he catches he is very quickly aware that he does not want anybody to be landing blackfish ... to undermine the value he is going to get for the additional fish he has bought".[313] This implies a new attitude among fishermen towards ownership of measures which restrict their activities and are primarily aimed at protecting stocks but which also protect their investments. Mr Couper of the Scottish Fish Merchants' Federation believed that "the perception of the fisherman is now changing from the hunter to harvester and he has got a vested interest in the fish and looking after it for the future" because of ownership and the sense of having "something to hand over to their sons".[314] Fishermen are therefore becoming "self-policing" and market mechanisms appear to be delivering conservation.[315]

85. The sense of ownership resulting from the purchase of quota is somewhat misleading as the legal owner of licences and of quota remains the UK Government. There is naturally some unease among fishermen at the uncertain status of their agreements to buy or to lease from other vessel owners. At the moment, the UK Fisheries Departments have to approve and register changes in licences. The situation on quota is more complicated, particularly with the trend towards leasing. Although fishermen draw up legal agreements which are endorsed by the relevant POs and notified to the Government, what is being exchanged is not a property right. Mr MacSween of the SFO described this as "a very odd situation", adding "I keep saying to the lawyers who draw [the agreements] up 'How can you draw up a legal agreement to sell something that does not belong to you? How do you advise clients to buy something from somebody who has no proper legal title?'"[316] There is a genuine concern here. The fishermen who have invested so much capital in their business need to be certain that what they have bought is legally their own. The Government has recognised this anxiety in part by ratification of all the transactions undertaken in the last year at the end of 1998, a procedure it now intends to repeat on an annual basis.[317] It has also indicated that licences and quota entitlements are assets which could be accepted by banks as security for loans. Yet, as Mr Morley stressed, "in the end, the title does belong to the state."[318] This means, as the SFIA observed, that "there is the risk that the licence, will at some point, become valueless".[319]

86. The question of legal ownership must be resolved. The trade in licences and quota and the value it brings into the industry have reached such an extent that it is almost inconceivable that any Government could recall the title it theoretically retains without facing massive compensation claims. Yet it is being pushed into this position by market forces rather than by any strategic decision. We are not confident that the Government has adequately addressed the legal implications of the tradeability of quota and licences and we recommend that MAFF provide clear guidance on the legal title to licences and quota in the context of transactions between individuals and/or organisations.

235  Eg First Report from the Agriculture Committee, Session 1998-99, MAFF/IB Departmental Report 1998 and the Comprehensive Spending Review, (HC125), para 28.  Back

236  Q 1088. Back

237  Ev. p.326. Back

238  Ev. p.327. Back

239  Ev. p.327, 2.2. Back

240  Q 1090. Back

241  Q 1091. Back

242  Ev. p.294. Back

243  Ev. p.258, para 4.3.3. Back

244  Ev. p.249. Back

245  Q 980 Back

246  Q 985. Back

247  Qq 980-986. Back

248  Ev. p.355. Back

249  Q 986. Back

250  Q 981. Back

251  Ev. p.355. Back

252  Ibid. Back

253  Q 981. Back

254  Eg. Ev. p.313. Back

255  Eg. Ev. pp. 94, 155.  Back

256  Ev. p.257, para 3.1.1; Ev. p.274. Back

257  Ev. p. 66. Back

258  Ev. p.299. Back

259  Ev. p. 38. Back

260  Ev. p. 94. Back

261  Ev. p.311. Back

262  Q 173. Back

263  Ev. p.299. Back

264  Ibid. Back

265  Q 1053. Back

266  Ev. p.293. Back

267  Q 1053. Back

268  Q 1059. Back

269  Ev. p.290. Back

270  Ev. p.311. Back

271  Ibid. Back

272  Ev. p.275. Back

273  Ev. p.282. Back

274  Ev. p.274. Back

275  Ev. p.293. Back

276  Q 1059. Back

277  Q 64. Back

278  Ev. p. 53. Back

279  Ev. p.213, para 17. Back

280  Q 1053. Back

281  Ev. p. 21, Annex, para 2. Back

282  Review of the Licensing of UK Registered Fishing Vessels (March 1999), page 10. Back

283  MAFF PN 119/99, 31 March 1999. Back

284  Ev. p. 21, para 6. Back

285  Ibid. Back

286  Ev. p. 149. Back

287  Ibid.  Back

288  Q 432. Back

289  Q 427. Back

290  Q 442. Back

291  Ibid. Back

292  Q 434. Back

293  Q 150. Back

294  Q 152. Back

295  Ev. p. 148. Back

296  Ibid. Back

297  Q 99. Back

298  Q 188. Back

299  Ibid. Back

300  Q 786. Back

301  Q 1021. Back

302  Informal evidence. Back

303  Ev. p.296. Back

304  Ibid. Back

305  Q 183. Back

306  Private information. Back

307  Q 782. Back

308  Qq 151, 192; Ev. p.149.  Back

309  Ev. p. 156. Back

310  Q 397. Back

311  Q 1033. Back

312  Q 185. Back

313  Q 791. Back

314  Q 740. Back

315  Ibid. Back

316  Q 786. Back

317  Q 1028 Back

318  Q 1038 Back

319  Ev. p.301. Back