Joint Committee on Transport and Communications díospóireacht -
Wednesday, 12 Mar 2014

Commercial Vehicle Roadworthiness (Vehicles Testing) (No. 2) Regulations 2013: Discussion

Chairman

No. 8 on the agenda is a discussion with representatives of the Vintage Veteran Trucks Association in Ireland and the Irish Veteran and Vintage Car Club of the implications of the Commercial Vehicle Roadworthiness (Vehicles Testing) (No. 2) Regulations 2013 for vintage vehicles. On behalf of the joint committee, I welcome from the Irish Veteran and Vintage Car Club Ms Bernadette Wyer, president; Mr. Peadar Ward, director; and Mr. Michael Duff, honorary secretary; and from the Vintage Veteran Trucks Association Mr. Alan Doyle and Mr. Billy Kiely.

By virtue of section 17(2)(l) of the Defamation Act 2009, witnesses are protected by absolute privilege in respect of their evidence to the committee. However, if they are directed by it to cease giving evidence on a particular matter and continue to do so, they are entitled thereafter only to qualified privilege in respect of their evidence. They are directed that only evidence connected with the subject matter of these proceedings is to be given and asked to respect the parliamentary practice to the effect that, where possible, they should not criticise or make charges against a person or an entity by name or in such a way as to make him, her or it identifiable. The opening statements submitted to the committee will be published on its website after the meeting. Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official by name or in such a way as to make him or her identifiable.

Mr. Alan Doyle

I thank the Chairman and committee members for the invitation to address them. I represent the Vintage Veteran Trucks Association in Ireland which has a wide membership across the country. We are involved in the important restoration of vintage veteran trucks and trailers. We restore them to their original condition and participate in a number of social events throughout the year for the purpose of showing our restored vehicles and raising money for various charities. Our vehicles are restored to the highest standards with due care and attention to safety standards. They are only used for social and domestic purposes; they are not commercial vehicles. We enjoy reduced vintage insurance premia and our vehicles are classed as vintage veteran vehicles for the purposes of road tax at the reduced rate.

In 2012 we became aware that there was new legislation, the Road Safety Authority (Commercial Vehicle Roadworthiness) Act 2012, under which the Minister for Transport, Tourism and Sport could make regulations for the testing of vehicles and provide for exemptions from testing for certain vehicles. We wrote to the Minister, Deputy Leo Varadkar, in September 2012 requesting that when he made regulations, he exempt our vintage veteran vehicles from roadworthiness testing. We further became aware that he had made regulations, SI 347 of 2013, providing for an exemption for pre-1980 motor caravans, but he did not provide for the exemption of our vehicles, as requested. In January 2014 we again wrote to him requesting that he include our vehicles in the regulations. We received a reply from the Road Safety Authority stating that as these vehicles could be used for commercial purposes, they had to be tested. We again wrote to the Minister in February to point out that our vehicles were not commercial vehicles and that they were only used for social and domestic purposes. We provided him with a suggested text to amend the regulations to exclude pre-1980 vintage vehicles.

We received an acknowledgement stating a further reply would issue. We have not received a further update.

I also attach for the committee's information a submission made to the Minister which sets out the reasons we consider our vehicles should be exempt from roadworthiness testing. We ask the committee to request the Minister to amend the regulations to provide for the exemptions we require in order that our vehicles can be treated equally to other pre-1980 vintage vehicles in Ireland such as cars, motor caravans, tractors and motor cycles.

Committee members might note exemptions for vintage veteran vehicles are being discussed at EU level and included in the documentation provided for them is a paper provided for Irish Vintage and Veteran Car Club Limited by the Fédération Internationale des Véhicules Anciens, FIVA. This organisation represents and promotes the interests of historic vehicle owners throughout the European Union and the world and engages on policy issues at EU level. Also included with the documentation are sample photographs of our vintage veteran vehicles. I thank the committee for giving us this opportunity to address it.

Chairman

Mr. Doyle has presented the information clearly, with supporting documentation, for which I thank him. I now invite Mr. Ward to make his opening remarks on behalf of Irish Veteran and Vintage Car Club Limited.

Mr. Peadar Ward

I thank the joint committee for giving us this opportunity to address it on matters to do with historic vehicles. Irish Veteran and Vintage Car Club Limited, IVVCC, was formed in 1963 to cater for owners of veteran and vintage vehicles and enthusiasts who did not possess vehicles. We are happy to come before the committee to support the Vintage Veteran Trucks Association in Ireland, one of our affiliated clubs. The IVVCC's mission statement is to be the voice, custodian and facilitator of the historic vehicle movement in Ireland; to promote and facilitate the preservation, ownership, appreciation and use of historic vehicles; to promote public awareness of the historic vehicle movement; and to protect the regulatory environment affecting the use of historic vehicles.

In 2013 the Irish Veteran and Vintage Car Club celebrated 50 years, which is an achievement for any voluntary or community-based organisation. We now boast a membership of approximately 650, with more than 47 affiliated clubs nationwide. Most importantly, the IVVCC is the national representative of the Fédération Internationale des Véhicules Anciens, FIVA, which is a worldwide organisation. FIVA has more than 85 member organisations in 62 countries and represents more than 1.5 million historic vehicle enthusiasts. Its motto is "Yesterday's vehicles on tomorrow's roads". In January 2013 it enacted the Turin Charter, a policy paper designated to "preserve and safeguard the history of vehicles including their engineering, form, functions, and documented histories and their many and diverse relationships with society and social environments".

It is important to point to the history of self-propelled goods vehicles which dates back to Cugnot's steam dray of 1769 and which long pre-dates that of the passenger car. While the preservation of historic cars can be challenging and often expensive, the preservation of goods vehicles is far more challenging and expensive. Most goods vehicles clocked up considerably more mileage than private motor cars; consequently, few of them remain today. Many were on the road for ten or more hours a day during their business usage.

Apart from the greater use made of these vehicles in their day, the storage problem associated with their preservation is a major inhibiting factor in their preservation. It is imperative that an historic vehicle be kept under cover and protected from the elements, as otherwise they will deteriorate very quickly. This is particularly challenging in the case of larger vehicles such as those preserved by members of the Vintage Veteran Trucks Association in Ireland. It is important that these vehicles be preserved for posterity as they are a very important part of our social history. Many preserved goods vehicles are painted and display sign writing in the livery of the owner's business by way of advertisement which emphasises long-established businesses. Examples of such livery can be seen in the IVVCC centenary publication, Historic Motoring in Ireland, which was published last year.

The value of preserving goods vehicles can be seen in the social or industrial history these vehicles recall. Some have been restored in the livery of certain utilities, recalling projects such as rural electrification, the postal service of bygone decades, some of our defunct industries and agricultural infrastructure such as the old creamery network. Many are displayed at static shows where there is a charity fundraising dimension, while the heritage they recall has an educational value for adults and children.

I would like to address the definition of historic vehicles. The IVVCC and FIVA consider all mechanically propelled vehicles manufactured more than 30 years ago to be historic vehicles, the only exception being vehicles designed to run on tracks such as trains. This clearly includes cars, motorcycles, goods vehicles and passenger busses. FIVA's administration office is based in Brussels and iactively engaged in monitoring new regulations which might have an effect on the use of historic vehicles. In this context, it is relevant to bring to the attention of the committee the outcome of several months of discussions between FIVA and the relevant European institutions. At the end of December 2013 the European Council and the European Parliament reached agreement on the proposal to revise the roadworthiness testing directive. The committee should note the agreement text has yet to be formally adopted by the two institutions. This is scheduled to take place in the first quarter of 2014. FIVA understand the agreement will define vehicles of historic interest as any vehicle considered to be historic by the member state of registration or one of its appointed authorising bodies and which fulfils all of the following conditions: it was manufactured or registered for the first time at least 30 years ago; its specific type, as defined in national or EU law, is no longer in production; and it is historically preserved and maintained in its original state and has not sustained substantial changes in the technical characteristics of its main components. This definition clearly includes goods vehicles over 30 years old. It is the view of FIVA and the IVVCC that historic goods vehicles should be treated no differently from other historic vehicles in respect of roadworthiness testing.

I would like to provide the committee with some basic statistics for the use of historic vehicles. Historic vehicle-related activity is worth €16 billion to the European Union annually. More than 70% of historic vehicles travel less than 1,500 km per year and anecdotal evidence indicates historic goods vehicles are likely to travel less than half of this figure. A total of 29% of historic vehicle owners have a household income of less than €30,000 per year and 78% of historic vehicles are valued at less than €15,000. These statistics are derived from a 2006 survey conducted by FIVA in 11 EU countries, including Ireland. FIVA is undertaking a similar research project this year which will be launched on 26 March in 15 EU countries.

I have copies of that to make available to the committee.

In conclusion the IVVCC asks the committee to recommend that the legislation be amended to ensure that all historic vehicles be treated in the same manner in all respects including the exemption from roadworthiness testing.

Chairman

Mr. Ward has clearly outlined the case for support of his fellow colleagues. The public is aware of the activities that the vintage vehicles are involved in for charity. I see that vintage vehicle-related activities generate the staggering figure of €16 billion in the EU annually.

I can imagine that members will be supportive. I ask them to confine their remarks to three minutes so that we will get to put questions as quickly as possible. I do not wish to stunt the debate but I wish to conduct it efficiently.

Deputy Timmy Dooley

I welcome both groups and thank them for their communications, which I found helpful. I was not aware that the matter raised in the communications was an issue for vintage vehicles. I am familiar with the charitable work they do. I proposed that both groups would come before the committee to set out their stall, giving them an opportunity to present it in public. The Joint Committee on Transport and Communications is televised and it gives us an opportunity to highlight what has happened. If I were benign, I might say it was an oversight, but if it was not an oversight, I am concerned as to the reason this has been allowed to happen. The groups play a central role in public events in maintaining and preserving heritage. Their work feeds into education in terms of teaching the current generation about the practices and engineering of the past. They provide wonderful entertainment to so many people and they play an integral role in festivals which generate local economic activity. It is clear that they play a part in the domestic tourism sector. I hope that the exemption they are looking for will be extended. Quite clearly, the vehicles are used for social and domestic outings, largely for pleasure. Many of the vehicles that I am familiar with are taken on low loaders to events around the country, The vehicles are not driven for long distances, such is the interest in preserving them. They are not driven at high speeds or put through any work routine. I fail to see why the exemption cannot be extended. I will make a proposal that the committee encourages the Minister to put in place the appropriate exemption by way of statutory instrument to meet the needs of the Irish Veteran and Vintage Car Club and the Vintage Veteran Trucks Association. I know the Department has indicated that it will review of the statutory instrument. In my view that is too far down the road. It would be more appropriate to deal with it and have the vehicle class included in the overall exemption. When one considers that it includes motor caravans and tractors, I would have thought a logical extension would be the trucks that the VVTA so carefully maintain and protect for posterity. I thank the groups for their work.

I propose that the committee support the Chairman's recommendation to seek an exemption to include the vintage veteran trucks.

Deputy Noel Harrington

I too welcome both groups to the committee. I will be forgiven for singling out Mr. Ward, as it is a long time since he travelled the roads to west Cork and Castletownbere, in particular. It is good to see him again.

I fully support the objectives of the Irish Veteran Vintage Car Club and the Vintage Veteran Trucks Association in what they are trying to do. It would be unfair not to tease out some of the issues. We have a remit in respect of road safety.

I address this question to Mr. Alan Doyle. Is there a method of establishing that when a vintage truck is put on the road, the vehicle is safe? Who will certify or stand over the roadworthiness of a vintage truck, if it is to appear on the road? I think it is very important to put on record that road safety is an important element of what these groups are trying to achieve.

Could Mr. Ward set the context of the legislation in other countries that allows exemptions for vintage vehicles? That information would be helpful when we are discussing the issue with the Department. The Road Safety Authority wrote offering a review of the legislation in 2015. Why do they think that is too far down the road? Why would they prefer the Oireachtas to introduce a measure before 2015?

Chairman

I now call Deputy Colreavy. We will take the other members in the next tranche.

Deputy Michael Colreavy

I represent Sligo-North Leitrim. We depend on the members of the Irish Veteran Vintage Car Club and the Vintage Veteran Trucks Association to entertain us and show us the beauty of a bygone time. I know that people the length and breadth of Sligo and Leitrim love what they do. It adds a dimension to our lives, a look back through living history.

Normally my colleague, Deputy Dessie Ellis deals with transport but I think he would be as puzzled as I am as to the reasons these groups must make a presentation today. I do not know the reason that the proposal that was put by both groups to the Minister, which seems reasonable, was not accepted. I do not fully understand that. It seem that there was a difficulty with the way the legislation was shaped that the exemption could not be included. However, I cannot figure it out.

I will support Deputy Dooley's amendment. Far from relying on a review in 2013, if I were a vintage car, truck or commercial vehicle owner, I would be a little bit weary of what will come down the tracks in 2015. I do not understand the logic of treating trucks and commercial vehicles differently from vintage cars and I believe their request is reasonable. I will support it.

Finally, a question; are the witnesses aware of what is happening in other European Countries and, if so, will they give us a run down on it?

Chairman

Let us deal with these questions before I call the next tranche of members.

Mr. Peadar Ward

I thank the Deputies and the Chairman. As members will be aware many EU directives differ from country to country so one cannot say the same approach is taken in every country. For the most part there is no differentiation between goods vehicles and other historic vehicles in EU countries. They are not treated differently. For the most part, vehicles over 30 years old are not subjected to roadworthiness testing in most European countries. The current directive being discussed at EU level will propose that vehicles over 30 years old will not be subject to roadworthiness testing.

Having said that, this will be a directive rather than a regulation that each member state will decide how to implement.

Deputy Harrington asked about the vehicle safety and so on and I shall point out two particular things in that regard. First, the people who own an historic goods vehicle, motorbike or passenger car are enthusiasts who are interested in preserving the vehicle and its history for posterity. It is rare to ask an enthusiast what type of car or truck he or she owns because inevitably he or she will own more than one as. It is like a disease. People will want to collect more and become very enthusiastic about them.

My next point is particularly relevant to insurance. Mr. Kinneen referred to the fact that owners of these trucks can avail of special rates of insurance and the same applies to historic cars. The insurance rate is very competitive because the vehicles are a good risk for a couple of reasons. First, they are maintained to a very high standard. Second, the number of kilometres or hours that they spend on the road is limited. I have drawn attention to the fact that the last FIVA survey showed that 15,000 km was the average mileage for cars and all historical vehicles. In fact, it is considerably less for goods vehicles because they are not driven on the roads.

Chairman

Is Mr. Ward saying that there are no claims on them or a minimum number?

Mr. Peadar Ward

It is almost unknown. A number of insurance companies are now interested in entering the small Irish market and insure this type of vehicles because they are a good risk.

Chairman

I call Deputy O'Donovan, Deputy Tom Fleming and Senator Eamonn Coglan, in that order.

Deputy Patrick O'Donovan

I welcome the delegations. I must declare an interest in this matter. One of the speakers spoke about the delivery of vehicles and the way in which they turned out. My brother is actively involved in restoring the vehicles with one of the representatives present.

Under the regulations, the suggested changes intend to superimpose a modern standard on an old vehicle and, therefore, detract from the character of a vehicle. Let us contrast that with the manner in which the Department of Defence beautifully restored the armoured car called the Sliabh na mBan a couple of years ago. It is sent around the country and does a great deal of charity and community work on behalf of the Department. Let us consider the type of wing mirrors that the authorities want installed on some of the vehicles with what the gentleman and lady before us advocated as being suitable. It would detract from the character of the vehicle if, for argument's sake, the Department of Defence sought to have the standards associated with modern military vehicles imposed on the Sliabh na mBan. People would not be enthusiastic for something like that to happen.

Even though I have the details I would like the delegations to tell me what changes would be made to the vehicles if the regulations were left unchallenged.

I wish to point out another important matter. The associations have sought a meeting with the Minister and his officer is considering their offer. Deputy Dooley has recommended the best course of action. I urge that common sense should prevail. We are being asked to superimpose modern regulations on vehicles that were not designed for such a purpose. Pre-1980 cars are not required to have seatbelts on the back seat for the very good reason that such cars were not built with them and the same should apply to these vehicles. They are used primarily for social and leisure purposes. I am not aware of anybody hauling barrels of Guinness up and down the quays in Dublin in a 1940s truck and that is what this matter boils down to.

Deputy Tom Fleming

I welcome the delegations here today and thank them for their excellent presentations. We must recognise that vintage vehicle enthusiasts are custodians and provide the modern generation with an important link to the past which comes at a very high personal cost to the owners. A great debt is owed to them and to the companies who have invested in the preservation and exhibition of commercial goods vehicles that were used in the past. The vehicles will be very evident and visible in the coming week and on St. Patrick's weekend in the parades. They will be a highlight for many people.

The delegations made a logical request which the Government should co-operate and comply with. The amendment suggested by Deputy Dooley is an immediate amendment to SI 347 of 2013 and includes goods vehicles first registered on or after 1 January 1980 and used only for social and domestic purposes; and goods trailers first registered on or after 1January 1980 and used only for social and domestic purposes. It allows for a similar testing frequency for post-1980 veteran trucks and trailers as per the regulations for motor caravans. That is section 6, SI 347 of 2013, and that was from the Irish Vintage Veteran Trucks Association. We need to adapt and implement the amendment in order to move it forward. It is a very small request in view of the importance of such vehicles.

Senator Eamonn Coghlan

I welcome the delegations. I agree with Deputy Dooley and with some of the comments made in support of the organisations. I have a particular interest in cars and motorbikes, particularly now that my baby is 29 years old and next year will fit into the category of 30 years of age - a lovely little Alfa Romeo Spider Veloce.

Deputy Michael Healy-Rae

That is no Morris Minor.

Deputy Patrick O'Donovan

The Deputy may need two of them.

Senator Eamonn Coghlan

Dustin Hoffman is looking for mine.

Deputy Michael Healy-Rae

They have no room for guests.

Deputy Timmy Dooley

A four-wheel drive and Guinness on the back.

Senator Eamonn Coghlan

I have had an opportunity to meet the vintage vehicle owners of both the trucks and cars through my involvement in charity. Therefore, I can understand the pride, passion and enthusiasm that goes into sourcing, restoring and putting the vehicles on the street. I know for sure that vintage enthusiasts will not put a vehicle on the street that is not roadworthy because this is a hobby for them. It is like the Department of Health telling a sportsperson that he or she is not allowed to play a game unless he or she proves fitness. A coach will know whether the person is fit enough to play. The vehicles break down at times and the regulations are about health and safety in terms of putting cars on motorways and national roads. Do the delegations agree that they should provide some kind of regulation to ensure that a car is roadworthy, in some form or another, as opposed to a regular roadworthy test such as the NCT or whatever?

Deputy Paudie Coffey

I welcome the delegates and express my sympathy for the position in which they find themselves. I am aware that they are enthusiasts and of the work of the two associations. It is our responsibility to challenge the thinking. I feel a little like Senator Eamonn Coghlan that there was an element of self-certification. I am also aware that to be a member of the associations one has to be an enthusiast and totally committed to their work.

In regard to road safety, if there was a way of reassuring the public that the vehicles were roadworthy, even when put on public display, that would be enough. In this instance, I agree with colleagues that this is bureaucracy and regulation over-kill. I note with interest and thank the delegates for drawing to our attention the discussions they have had at EU level where a reasonable approach has been adopted. In Ireland we appear to have gone over the top. I am supportive of what the delegates have come here to achieve. Although I am not always supportive of what Deputy Timmy Dooley proposes, he made a reasonable proposal which I support. We will have a further discussion to see how we can help the delegation to achieve its objectives.

Deputy Helen McEntee

Most of the questions have been asked. I thank the delegates for their presentations and acknowledge their work. We have a vintage club in Nobber and much of the money raised throughout the year goes to local communities and local charities. However, road safety is an issue. Unfortunately, last year a young girl died during a vintage tractor run in my county. I appreciate this is separate from the associations' remit, but is there any chance there could be abuse in the system, not by members of the associations but by people outside their membership? Have the delegates come across this? I am supportive of their objectives and agree with Deputy Timmy Dooley's proposal.

Deputy Michael Healy-Rae

I, too, welcome the delegates and their supporters. The contribution that they and their fellow enthusiasts make is massive because if the work of restoring vehicles had not been done in the past, we would have lost a very valuable part of our heritage. In my area John Mitchell and his family have given a lifetime to restoring lorries, trucks, motorbikes and other vehicles which will be handed down to the children in the future

I agree with Deputy Timmy Dooley's suggestion. A strong message must be sent from this meeting to the Minister that we respect the work the Road Safety Authority and similar bodies have done. However, there is such a thing as going over the top and not having common sense and realising a vintage truck that has been restored should not have to comply with the same regulations as a truck that leaves Cork every day for Dublin with a full load and repeats the journey twice or three times daily. Where is the common sense in what the Minister has proposed? If a Minister does not have common sense, surely the officials in his or her Department have it. Somewhere along the line somebody has to realise it is not right to put the vehicles of the associations' members through the roadworthiness test. There are many individuals who have restored one or two vehicles who are not members of any club. We are here to speak on their behalf also because they will be adversely affected by what the Minister is proposing. Common sense will have to prevail. Of course, there would have to be an amendment to the legislation to provide for an exemption for trucks, cars, motorbikes and any other vintage vehicle. While we want all vehicles to be safe, at the same time one cannot ask people to ensure an old vehicle complies with the regulations of today. It just does not and cannot work. It is very important that the Chairman has invited the delegation to appear before the committee. The Minister and his officials will have to wake up and take note of the delegations' concerns.

Mr. Alan Doyle

Everybody knows when he or she steps outside the door that there is an issue with health and safety. Many of the events we attend are not necessarily organised by us, but we have a duty of care in arriving at somebody else's show and have a shared responsibility so far as health and safety issues are concerned. Historically, up until 1980, similar to cars and motorbikes, we always enjoyed an exemption from testing. From our point of view, there is no reason to change that exemption provision because nothing adverse has happened, although I know we hear about a tragedy here and there. The way some insurance companies approach the issue initially in respect of older vehicles is by asking for an engineer's report on a vehicle that has been restored. In other words, as this is the first time the vehicle has been insured and there is no history available, the insurance company will ask for an engineer's report. Prior to NCT-type testing an insurance company would have had an agent who would have tested the vehicle. There are still engineers available who could conduct such a test. It is more like a visual test, perhaps, involving a smoke test, but it does not carry the regulatory burden attached to a full DOE commercial test. I do not see why something along these lines could not done, say, every five years. When a vehicle was being put on the road initially, it would have to be certified. That would be reasonable.

Some issues arise from the point of view of health and safety. In modern trucks, as the tyres are nearest to the road, it is vital that they be correct, have the E mark and be stamp-dated. There are many tyres that were produced prior to the introduction of E-marking and date-stamping which are still perfectly good and serviceable. As responsible owners of vintage vehicles participating in runs, we are not going to put bad tyres on a vehicle, but at the same time we do not want to use ultra-modern tyres because many of them do not fit and do not look right. An insurance policy usually provides for limited mileage. That there is a reduced tax rate reflects the fact that they are rarely used. An engineer's report would address the health and safety issues.

Mr. Peadar Ward

One of the problems, if one submits vehicles to a testing regime, is the lack of flexibility to take account of vehicles built 30, 40, 50, 60, 80 or 90 years ago. Some members of the Irish Veteran Vintage Club have experienced difficulties. A number of them had vintage cars for hire for weddings. For that purpose they had to be licensed as either hackneys or limousines and were required to be submitted for annual testing. The difficulty was that facilities were not in place to test them. The type of test proposed initially could not be undertaken. For example, one of the tests carried out at an NCT centre on a modern car is carried out on the body. If the same test was conducted on a vehicle such as a 1920s or 1930s Rolls Royce, it would simply break it. The facilities to carry out that type of test are not in place. Many of these trucks might be on the road twice or three times a year and the fourth time they are put on the road it is to take them to have a test carried out.

There is a lack of logic in doing this.

The other issue concerns whether tests could be abused. It would make absolutely no commercial sense to use an historic truck for commercial purposes. Irrespective of the cost of maintenance and fuel, nobody would use one as one would be losing money.

Deputy Michael Healy-Rae mentioned Morris Minors. About 20 years ago there were those who were starting to use a vehicle such as a Morris Minor as a second car because they might have been able to tax it cheaply. This practice has declined completely because it makes no commercial sense. One can buy a 15 year old Nissan, Toyota or Ford that is perfectly good, costs a lot less to run and is much more reliable than a 40 year old Morris Minor. What has happened in the economy has ruled out the practice for cars and it has certainly been ruled out as a possibility in the case of trucks.

Chairman

I thank both delegates for their presentations. I have never noticed so much unity of purpose and support around the table.

Deputy Timmy Dooley

That is the only bit that worries me.

Chairman

I am sure it will be reflected in our representations to the Minister on the delegations' behalf. I thank the delegates for attending and highlighting the relevant issues.