103. It has long been recognised that marine science is not well-served by the current complexity of organisations involved in co-ordinating and funding research in this area. The Lords Science and Technology Committee Report of 1986 concluded that UK marine science was fragmented and underfunded, despite being technically excellent, and that the UK was suffering through the lack of an overall strategy for marine research. In 1990 the Co-ordinating Committee on Marine Science and Technology (CCMST), established in response to the Lords Report, produced its own report which set out a marine strategy for the UK, and recommended that a co-ordinating body of representatives from these areas, including the public, private and university sectors, should be made responsible for co-ordinating, monitoring, advising, supporting and promoting marine science and technology. This proposal was regarded by some observers as "laying the foundations of a comprehensive and co-ordinated approach to MS&T in the UK that would bring together government, academia and industry".[187] However, while accepting the need for some form of overall co-ordination, the Government rejected the recommendation for such a broad-based and central body in favour of a committee composed of members of relevant Government departments and Research Councils: the Inter-Agency Committee for Marine Science and Technology (IACMST).

Inter-Agency Committee for Marine Science and Technology (IACMST)

104. The objectives of the IACMST are to ensure arrangements for information exchange between all the publicly-funded bodies in marine science and technology, and to maintain an overview of national and international activities. Its primary responsibilities are the broad oversight of marine science research and technology activities within and beyond government agencies and to ensure the existence of adequate co-ordination mechanisms.[188] Its terms of reference are to:

• maintain an overview of national and international activities in marine science and technology.
• ensure that there are satisfactory arrangements for the co-ordination of national and international marine science and technology activities;
• encourage the optimum use of major UK facilities for marine science and technology;
• enhance wealth creation and the quality of life through targeted interaction between science and industrial and other user interests in marine science and technology;
• encourage training and education in marine science and technology; and
• report on IACMST activities and the broad scope of all Departmental marine science and technology activities to the Chief Scientific Adviser annually, and to other member agencies as and when appropriate.

105. The IACMST membership is drawn mainly from Government departments and agencies, with the addition of a small number of independent members and, since May 2006, IMarEST, representing the private sector. The current membership is:

• Centre for Environment, Fisheries and Aquaculture Science
• Department for Environment, Food & Rural Affairs
• Department for International Development
• Department for Transport
• Department of Trade and Industry
• Environment Agency
• Engineering and Physical Sciences Research Council
• Fisheries Research Services
• Foreign and Commonwealth Office
• Institute of Marine Engineering, Science and Technology
• Meteorological Office
• Ministry of Defence
• Natural Environment Research Council
• Northern Ireland Office
• Office of Science and Innovation
• UK Hydrographic Office
• Welsh Assembly Government
• Professor Peter Liss (President, the Challenger Society)
• Mr Ian Townend
• Professor Graham Shimmield (Director, SAMS)

We assume that the successor departments to DTI and OSI (Department for Business, Enterprise and Regulatory Reform and Department for Innovation, Universities and Skills, respectively) will take their places on the Committee. The IACMST was initially chaired by an independent industry representative, and it reverted to an independent chairmanship with the resignation of its current chairman, Professor Sir Howard Dalton, from his position as Chief Scientific Adviser at Defra since he is to continue as IACMST chairman for at least a year.[189] The IACMST secretariat is based at NOCS.

106. The IACMST stressed to us that its remit was "to ensure that there are satisfactory arrangements for the coordination of national and international MST activities" and not necessarily to do that co-ordination itself.[190] However, the IACMST has established several initiatives to improve the co-ordination of UK marine research. These include a horizon scanning capability for new policy-related research areas (for example, the effect of sound on marine mammals) and action groups which focus on global observing systems and data issues. Of these, the GOOS AG (Global Ocean Observing System Action Group) works to co-ordinate marine observation programmes operated by the UK, to improve the co-ordination, development and application of operational models of the shelf seas around the UK and to improve co-ordination of UK input to the GOOS programme. The MED AG (Marine Environmental Action Group) focuses on improving access to marine environmental data, including through its oceannet website. These arrangements are likely to change. The IACMST told us that "discussions are underway exploring the transfer of some of these responsibilities to a new body arising from the Government's marine stewardship commitments [the Marine Assessment Policy Committee]; the organisation of marine science in the UK is not static."[191]

107. The IACMST also runs the Marine Data and Information Partnership, which provides a co-ordinating framework for managing marine data and information to facilitate improved management of the UK seas (see paragraph 192 below).

DEPARTMENTAL RESPONSIBILITY

108. There is confusion over departmental responsibility for the IACMST. When the Committee was first established, it was formally responsible to the Office of Science and Technology and from an early stage was chaired by an OST representative. In 2003, funding for the IACMST was transferred to Defra and Professor Sir Howard Dalton, Defra's CSA, took over as Chairman. The OST/OSI retained formal membership of the Committee. The OSI explained that the change was made because the creation of Defra "created a focus for marine policy and science in Whitehall that had not existed previously".[192] The OSI clearly regarded its responsibility for IACMST as ending at this point. However, the IACMST still considers itself as reporting to the OSI, and indeed its letterheads and all publications describe it as "a Government Committee reporting to the Office of Science and Innovation". The IACMST secretary told us that his understanding, at the time of taking up his post in 2003 and since, was that despite the changes, "IACMST continued formally to report to OST and I have been able to find no record of any change to this".[193] The IACMST Chairman, Professor Sir Howard Dalton, also assured us that "we report to the OSI",[194] although DIUS claimed not to have received an annual report, as required by the terms of reference of the IACMST, since the transfer of the IACMST to Defra.[195]

109. It is important to determine which department is in charge of the IACMST and of overall co-ordination on marine science. The GCSA, Professor Sir David King, accepted that "we need to go away and make sure that the reporting lines are clear".[196] At the moment there are no reporting lines at all, since the IACMST is not reporting to either DIUS or Defra in any active sense. It is unacceptable for a Government-funded body chaired by a Chief Scientific Adviser to be ignorant of its formal reporting responsibilities. We recommend that reporting lines for the IACMST be clarified without delay. Defra and DIUS, including the Government Office for Science, need to discuss lines of responsibility and what reporting procedures are required and communicate the results clearly to the IACMST.

110. We have not attempted to apportion blame for the failure to transfer responsibility from the OSI to Defra, but the relationship between the OSI and the IACMST following the transfer has certainly been inadequate. The OSI told us that it was still a member of IACMST and received circulated papers.[197] This transpires to be a euphemism for non-attendance at plenary meetings where such papers are discussed, since the OSI has not been represented at such a meeting since January 2004. Such neglect makes it less surprising that the OSI was the only witness to offer the opinion that "If IACMST members had doubts about the effectiveness of the body [as a co-ordinating mechanism] we would expect them, or the IACMST Chair, to draw these to OSI's attention", adding that "This has not so far occurred".[198] We also note Professor Sir David King's dismissive attitude towards the IACMST in oral evidence when he suggested that "I personally think that we have rather over stressed the Inter-Agency Committee and its position in the discussion" on co-ordination.[199] We are not satisfied with the attitude of OSI/DIUS towards attendance at meetings of the IACMST or towards the organisation in general. We recommend that DIUS play a more active part in the successor body to the IACMST which we recommend later in this Report.

EFFECTIVENESS OF THE IACMST

111. The IACMST has had some success, such as its work on marine noise and in establishing the MDIP. Its website lists several useful publications of its own, including the Pugh and Skinner report and work on monitoring, and it effectively co-ordinates links to funders and education providers, for example. The Committee also plays a valuable role as a forum in which different stakeholders can discuss important issues. IMarEST told us that "The Interagency Committee for Marine Science and Technology (IACMST) provides a vital role in bringing together the departments."[200] In addition, it is not a bureaucratic organisation, avoiding the danger of merely adding another layer of officialdom to the already complex structure of organisations and co-ordinating bodies.

112. However, the fatal flaw of IACMST is that it has not provided the central focus on marine research for which the community is looking and which was identified as missing as long ago as 1986. Dr Horwood of Cefas told us rather sadly "I do not believe IACMST has worked but I do not know why."[201] Other witnesses attributed its failure to lack of powers to compel its membership to take a wider view or to contribute to its work. The strongest critic was the IACMST chairman who told us:

We do not have enough teeth, in IACMST, to bring about many of the changes which…need to be brought about. We do not have resource, we act there in just an advisory role; we are a catalyst, to try to bring people together, and all that we can do is try to bring people together, tell them what the problems are, tell them what the issues are and rely very much upon them to try to sort it out. I think there are a lot of issues which really we do need to address properly, in terms of co ordinating and developing the science, and in some areas I think it is going very well, in other areas not so well.[202]

113. Attendance records for plenary meetings show that many departments attend very infrequently, including the Department for Transport which is responsible for leading the UK response to the proposed EU maritime strategy, DfID, the DTI and the FCO, not to mention the OSI. This has a detrimental impact on the influence of the IACMST, which, lacking powers of compulsion, is reduced to a mere "talking-shop". The President of the Challenger Society argued that the IACMST had "been only partially successful in [its role of promoting co-ordination] because the component bodies are primarily focussed on their own (policy-driven) research agendas. They are often unwilling to contribute to the bigger picture—which may be more about new research ideas than immediate policy issues."[203] The Chief Executive of NERC agreed that the IACMST did not appear to have the necessary "strong feed into the policy and ministerial lead",[204] while from the industry point of view, Dr Rayner of IMarEST argued that the IACMST "needs to have more capacity to effect linkages, to enforce linkages … the problem at the moment is that it is representative of the different bodies in government but it has no ability to do anything other than talk about coordination as opposed to drive coordination".[205]

114. The Secretary of the IACMST suggested that "one useful thing which perhaps could be done is to have added to our terms of reference that the member departments and agencies should be required to report regularly to the Committee".[206] This would encourage attendance and attention from departments but would require a fundamental change in the terms of reference of the Committee. It is also unlikely to win favour from departments. There is also the question of resources. The IACMST has "a two-person secretariat funded by one member agency (NERC), a central government pot of ~£50K per annum and annual subscriptions for annually approved programmes from a few of the member agencies."[207] With such limited resources, it is commendable that the IACMST has been able to publish work of such a high standard or take any steps towards co-ordination, but it is clear that it is severely restricted in what more it could do. Granting additional funding for staff or activity, however, would be unwise before first determining what is needed in the way of co-ordination and how best this could be delivered. We do not believe that the IACMST as currently constituted is capable of fulfilling the role required of it by the challenges facing marine science. It is fundamentally flawed in its constitution, and minor amendments to its budget or resources will not transform the organisation of marine science in the UK.

Other initiatives

115. There have been a number of recent attempts to introduce better co-ordination of marine science. Cefas cited the Environment Research Funders Forum (ERFF) as an initiative which attempts "to join up the community effort."[208] In addition, Defra has made efforts to pull together marine research from different funding sources, particularly in the area of monitoring and climate change. The United Kingdom Marine Monitoring Assessment Strategy (UKMMAS) (see further below) has been welcomed by the community, although we were told by the IACMST that another recent initiative, the Office for Climate Change, "needs to give attention to integrating the contribution of the marine science community".[209] A third body, the Marine Climate Change Impact Partnership (MCCIP), aims to "provide a co-ordinating framework within the UK for the transfer of high-quality evidence on marine climate change impacts and advice to policy-advisers and decision-makers."[210] It has been generally welcomed by witnesses and held up as a good example of how work in this area should be co-ordinated. Natural England claimed that the MCCIP had "demonstrated in one process how to circumvent the lag time between science and policy, and how a framework can champion UK marine science excellence, where the sum is far more than the individual parts."[211] IMarEST called for greater support for such partnerships, particularly in areas where there is an urgent need to fill the scientific knowledge gaps.[212]

116. We asked witnesses whether there were too many co-ordinating organisations and therefore the danger of further fragmentation. Professor Shimmield of SAMS disagreed, arguing that the number of bodies showed "the breadth and pervasiveness of understanding climate change impact across the marine and terrestrial environment".[213] He felt that "they have been quite effective in producing some of the new status reports that are coming out".[214] Professor Watson countered that, from a university point of view, "many of these do not make a lot of difference at the practical level of the day-to-day doing of the research".[215] Dr Horwood of Cefas told us that "there is a huge amount of co-ordination that goes on".[216] However, he identified the existence of "the weak bit from our type of organisation to NERC, the research councils and the universities"[217], and in written evidence Cefas conceded that "the evidence of well-integrated programmes is sparse".[218]

Self-organisation

117. The NERC marine directors pointed to a strong trend within marine science towards self-organisation. A good example of this in terms of the research centres is Oceans 2025. The Challenger Society also saw "signs that the recently reconfigured National Oceanography Centre (NOC) at Southampton is now beginning to take on a national leadership role", which had "not been forthcoming in the past."[219] This change arises from the bestowing on NOCS of "an explicit remit by NERC to act to facilitate coordination of marine science in an impartial and inclusive manner".[220] NOCS has established a National Marine Co-ordination Office, to assist the marine directors to deliver the national vision and the remit of the marine directors' forum. We note, however, that this mandate is ambiguous as NERC does not have any power outside its own institutional network: the universities in particular are very wary of this initiative and have not been consulted on the development. There are other examples of similar developments elsewhere in the sector, In Scotland there are moves to develop a "virtual" Scottish marine science group (Marine Science Scotland), involving the universities and the Fisheries Research Services.[221] We could also include here the formation of the National Centre for Ocean Forecasting (NCOF), a consortium of the Met Office, and four NERC-funded institutions, which seeks to develop more rapid uptake of ocean modelling advances into operational simulation systems.[222]

118.  Self-organisation can also be observed at the EU level. The European Science Foundation (ESF) Marine Board plays an important role in bringing together the marine community. The NERC centre directors considered that the ESF was "taking an increasingly proactive role in highlighting the contribution that marine sciences can make to the policy agenda".[223] NOCS described the ESF's November 2006 report, Navigating the Future III, as "an excellent synthesis of perspectives on marine science and technology in Europe".[224] In addition, the recent EurOCEAN conference in Aberdeen brought together 200 representatives of the European marine and maritime science and technology community, policy makers and non-governmental organisations from fifteen EU coastal states. The purpose of the conference was to comment on the EU maritime green paper and to issue a joint "Aberdeen declaration" on marine science and technology (see further below).

119. Moves towards self-organisation furnish a good example of grassroots action to adopt structures to meet their needs. The bottom-up approach is an effective mechanism for ensuring that the voice of scientists has a real influence in determining strategy. Nevertheless, there are limits to this approach in that it does not allow for a national strategic overview nor the inclusion of all players. It also limits the ability to change to those structures over which the grassroots have direct control. We note that NOCS argued that the drive towards self-organisation "perhaps points to a weakness in existing institutional structures for coordination".[225] We welcome the development of closer collaboration between scientists and institutions but individual arrangements are not an effective substitute for more cross-government organisation and national and international co-ordination.

Co-ordination in other countries

120. We have received evidence that co-ordination is more effective in other countries. For example, the Challenger Society cited France as an example of a country which appeared to have better arrangements for the co-ordination of their marine activities than exist in the UK.[226] We also had the opportunity to discuss co-ordination in the US and in Portugal. In the US, the National Oceanic and Atmospheric Administration (NOAA), which is embedded in the Department of Commerce, oversees the funding and co-ordination of the country's strategic marine science research. This has the advantage of tying together marine and atmospheric research. As an agency, NOAA has higher status and greater power than a committee. It also funds its own research and is a key player in the US oceans strategy for marine research (see paragraph 291 below).

121. Portugal is not a world leader in marine research, unlike the US, but it has addressed this under its reorganisation of its maritime policy and the priorities set for marine research within that structure. The resulting National Ocean Strategy is overseen by a Government Task Force for the Seas which brings together the major players in a much more dynamic form than the IACMST. Again, a task force of senior officials reporting to a Minister and with a clear remit and unifying strategy is a step-change from a committee.

Improving co-ordination of marine science and technology in the UK

122. There is a strong thread of dissatisfaction throughout the evidence to this inquiry with the effectiveness of co-ordination of marine science across all funding bodies. For example, the IACMST told us that

There is a need for continuing and strengthening coordination across all of the UK marine science community. Marine science and technology (MST) responsibilities are distributed widely across Government departments, agencies and NDPBs. Within any one of these, MST may be distributed across a number of different parts of the organisation. Several coordination mechanisms exist but many suffer from being identified too closely with individual departments.[227]

The Society for Underwater Technology argued that "Despite IACMST's best efforts there still appears to be a lack of co-ordination in marine matters between the Departments."[228] Similarly, the Biosciences Federation stated that "the UK's marine sciences remain seriously under-funded and surprisingly disconnected, reflecting a lack of overall co-ordination and an under-appreciation of our true depth of ignorance regarding the composition and dynamics of oceanic ecosystems."[229] The Challenger Society too were concerned at the "few mechanisms for integrating the activities of the many contributors.'[230] They reminded us that the universities are not represented on IACMST at all.[231] Neither of course is the private sector, with the exception of IMarEST.

123. The fragmented nature of oversight and responsibility for marine research by multiple organisations with different interests has led to criticism that UK marine research is unnecessarily complex. This has inevitable consequences. As Natural England explained, "It is still challenging for stakeholders to understand how the various elements integrate together, who is doing what, and therefore how to take advantage of the relevance and value of particular aspects of their work".[232] In oral evidence, Dr Tew of Natural England argued that the current lack of knowledge about the oceans is largely due to "the lack of structure, funding and integration" of marine research in the UK.[233]

124. These criticisms largely focus on co-ordination of strategy and research effort but there are also issues that arise over the lack of co-ordination of funding. Dr Rayner of IMarEST commented that "One of the problems you have is that, once you start talking about funding for marine science and technology, the beneficiaries of the funding are distributed and they are each vying for their individual sources of funds. There is no collective pot, either at a UK level or indeed at the European level, so there has always been this problem of the marine sector being very diffuse."[234] Scientists from the Marine Biological Association agreed that without an improved funding structure, the UK may be in danger of losing its leading position internationally, since "a more coherent approach to funding has led to countries such as Germany, France and the Netherlands challenging the UK's lead role in Europe in certain sectors".[235] This does not necessarily mean a single source of funding: the MBA also observed that "diversity of funding enables much applied research and knowledge transfer".[236] However, it does imply the need for greater co-ordination to ensure that public research funds are spent effectively and efficiently, whether in research institutes, universities or public laboratories.

125. The importance of greater co-ordination cannot be doubted, especially in the light of increasing efforts to develop holistic strategies that include all with an interest in the sea. The IACMST itself argued that "the brief of IACMST may need to be changed from one of co-ordination to actively drawing forward an updated version of the strategy first developed in CCMST 1990".[237] The Committee would also need powers to implement that strategy. It is interesting that the responsible Minister suggested that "the IACMST is the catalyst that identifies particular areas of research that are required".[238] At present, its performance of this role is limited by inadequate powers and resources but the Minister's answer implies government acceptance that there is a need for an organisation which does take a strategic approach to co-ordination of research needs.

AN AGENCY FOR MARINE SCIENCE

126. The Challenger Society suggested that "the merits of having a UK `Wet office' might usefully be considered".[239] It put forward two potential structures. One was to use the proposed Marine Management Organisation (MMO) as "the starting point for such an organisation" , but this found little support among witnesses and we consider that it would be insufficient to roll up this additional responsibility into the fledgling MMO which is already suffering from inter-agency turf issues. It would also mean delaying action until the implementation of an Act which currently exists only as a White Paper. The other possibility proposed was adopting the model of NOAA, the agency which is responsible for ocean and atmospheric monitoring and research in the US.[240]

127. We have looked closely at the recommendation that the UK needs an agency to co-ordinate marine research effectively. In general, witnesses were in favour of the idea. Asked if he supported a specific marine agency to co-ordinate research and to drive the science, Professor Sir Howard Dalton told us that "personally, I think that would make a lot of sense".[241] He added that "there is a whole series of activities … which, I think, if it were to come under some sort of agency operation, would make a lot of sense, in trying to bring about the co-ordination".[242] The three witnesses from industry who gave oral evidence all agreed that the equivalent of NOAA in the UK would be an advantage.[243]

128. Dr Thompson of EPSRC put two arguments against an agency: first, that it might be an unnecessary extra layer of bureaucracy ("people dread—and my own organisation is as guilty of this as anyone—getting entwined in lots of discussion meetings without seeing very positive forward action"; and second, that it might weaken the existing links between marine and terrestrial activities. [244] Dr Bell of the Met Office was not keen on the idea of an agency precisely because it could cut across the Office's work and break the synergy between weather forecasting and ocean forecasting.[245]  

129. Professor Thorpe of NERC suggested that "in many respects, of course, we have parts of NOAA already, and it is called the Met Office … One can see the Met Office as playing a key role in a UK analogue to NOAA".[246] Dr Bell, however, considered that this would give the Met Office responsibilities which it did not have the right expertise to take on in its current form: "The Met Office has a rather small group of people involved in marine research. That would not be an appropriate place to bring all the marine research institutes. Those need to be closer to the universities".[247] In addition, Dr Williamson from the UEA warned that "NOAA includes the fishery responsibility and management, so any UK equivalent of NOAA would then have to take under its umbrella the fishery laboratories in the UK and Scotland; and that is quite a major issue, bringing all of that under one area".[248] Fisheries would not be a natural fit with the Met Office.

130. An alternative to an agency would be to place greater responsibility for strategic oversight of marine science within a Government department. Professor Sir David King felt that it was better for Defra "to take on full responsibility for the marine environment", including co-ordination with other government departments.[249] However, Professor Sir Howard Dalton argued that, in view of the industries which are generating most of the economic output from the maritime sector, Defra might not be the natural home for responsibility for marine science and technology.[250] As mentioned previously, NOAA sits within the US Department of Commerce. Defra's lack of connections with other important sectors such as oil and gas, renewable energy and defence make it an unnatural home for the whole of marine science and technology, and there would also be the position of the Department for Transport as lead department on maritime strategy to consider.

131. We conclude that marine science and technology is a vitally important area, and one to which policy-makers are increasingly looking for solutions to crucial questions. It is not a niche area of interest, which can be shunted off to an obscure committee, but a central concern across Government which requires prominence and proper organisation. The current situation in which lack of effective co-ordination of effort and funding is hampering, rather than assisting, marine research cannot be allowed to continue. Strengthening the IACMST to encourage buy-in from Government departments and provide more resources to expand its activities would still leave a relatively weak body with little influence and few executive functions.

132. We believe that a stronger body than the IACMST is needed. The role of this new body would be to co-ordinate the activities of the funding bodies, to develop strategy (see below) and to enforce co-operation between the agencies involved. Clarity of purpose and buy-in from Government departments would be essential prerequisites of success. We recommend that a new co-ordinating body for marine science, reporting to Defra, be established. This body should bring together all public-sector funders of marine research, together with stakeholders such as the universities and end-users of marine science, and should be properly resourced to fulfil its functions. Because of the range of activities for which greater co-ordination is required at an executive level, our preference would be for this co-ordinating function to be placed with a new marine agency, which should be given executive powers and a budget to oversee operational observations (see further below). We attach two figures at Annex A, summarising the functions and key relationships which we propose for the new agency.

133. The question arises of how the new marine agency would relate to the new institutions to be established under the Marine Bill. It is essential that there is a defined relationship with the MMO which could address the challenges presented by devolutionary issues. The agency would also provide a natural focal point of international co-operation on marine issues. This proposal would create an agency with a wider remit than just marine science but we believe that it merits serious consideration. We believe that the transfer of functions to the new marine agency should provide an opportunity to reduce the number of co-ordinating bodies operating in this area and we recommend that the Government review the organisations, committees and other bodies co-ordinating marine-related activities with this aim in mind.

188   Ev 128 Back

189   Q 487 Back

190   Ev 128 Back

191   Ibid Back

192   Ev 235 Back

193   Ev 254 Back

194   Q 32 Back

195   Ev 262 Back

196   Q 484 Back

197   Ev 263 Back

198   Ev 237 Back

199   Q 505 Back

200   Ev 230 Back

201   Q 168 Back

202   Q 2 Back

203   Ev 121 Back

204   Q 577 Back

205   Q 276 Back

206   Q 6 Back

207   Ev 128 Back

208   Ev 99 Back

209   Ev 130 Back

210   www.mccip.org.uk/summaryaimshtml Back

211   Ev 211 Back

212   Ev 229 Back

213   Q 449 Back

214   Q 450 Back

215   Q 450 Back

216   Q 165 Back

217   Q 166 Back

218   Ev 99 Back

219   Ev 121 Back

220   Ev 168 Back

221   Ev 98 Back

222   Ev 173 Back

223   Ev 202 Back

224   Ev 170; www.esf.org/marineboard Back

225   Ev 173 Back

226   Ev 121 Back

227   Ev 128 Back

228   Ev 140 Back

229   Ev 141 Back

230   Ev 120 Back

231   Ev 121 Back

232   Ev 209 Back

233   Q 369 Back

234   Q 253 Back

235   Ev 168 Back

236   Ev 161 Back

237   Ev 128 Back

238   Q 480 Back

239   Ev 121 Back

240   Ev 122 Back

241   Q 32 Back

242   Ibid Back

243   Q 367 Back

244   Q 285 Back

245   Q 68 Back

246   Q 578 Back

247   Q 168 Back

248   Q 580 Back

249   Q 505 Back

250   Q 507 Back