Exiting the European Union (Environmental Protection)

Luke Pollard Excerpts

Tuesday 8th October 2019 Commons Chamber

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

I am afraid we are here again, for the second SI in a row, correcting mistakes in previous statutory instruments that the Government rushed through. Just as before, the Opposition will not oppose this SI, because there was a mistake in a previous SI that the Government pushed through, but we did at the time highlight that there could be errors, given the speed.

I welcome the new Minister to his place in the main Chamber, having already done so in a debate in Westminster Hall. I am grateful to him for setting out that this SI corrects the drafting in a previous SI. The rest of his speech was very nice, but it concerned an SI we have already passed. The only thing this SI does is allow the Minister to make regulations. In error, the previous SI said he could only make them in writing, which meant administrative actions which do not carry the same weight as regulatory actions in relation to CITES and other wildlife protection legislation.

There is cross-party agreement that that legislation is very important, and some of the interventions the Minister took were on topics that were also very important, if nothing to do with the SI. The only thing this SI does is correct the mistake of the Minister’s predecessor. I do feel for him a wee bit in that respect because he had to say a lot of nice words before he got to the meat of it, which was: “Here’s another mistake we’ve made, and we’re going to correct it.”

I am grateful to the Whips for putting this in the main Chamber, rather than a Committee. Had it been in Committee, no one would have known that the Government had yet again made a mistake in their statutory instruments. Instead, they have given us a platform for all the countless people who like watching SIs on parliamentlive.tv to watch one in the Chamber.

I have high hopes for the Minister. I hope that his insurgent and provocative manner on the Back Benches to drive change from the Government on animal welfare in particular will pay dividends. In the past, we have had lots of soundbites, promises and consultations, but very little action—[Interruption.] And many Ministers, as my hon. Friend the Member for Ipswich (Sandy Martin) says. I have high hopes that he will not accept the rum deal that his predecessors were putting out.

As with the Minister in the previous debate, I know that this Minister will be robust in this regard, and I hope this will be the last time that either has to come to the House to correct an SI that has been pushed through too fast without proper scrutiny or work. I suspect other errors will be found, however, particularly in the surge of SIs around February and March. This is not the first, the second or the third time the House has had to correct a drafting error in an SI.

I politely say to the Minister that a piece of work could usefully be done by DEFRA officials, who, to be fair, have had the most SIs to get through. Though no blame is being attached to them, the speed at which the SIs were reviewed will inevitably have let through some gremlins, such as this one. This was an important one to catch because the powers in article 7 that he set out are important. We need to make sure the Secretary of State has the ability to correct and make regulations, rather than just make administrative pronouncements.

I encourage the Minister not to accept any such errors and to make sure there is a robust process in place, because I suspect that this will not be the last time he has to stand at the Dispatch Box to correct an SI that has gone wrong. That said, I also encourage him to carry on fighting the good fight, because there is lots to be done on animal welfare and climate change in his Department. The Opposition wish him well in that. There is cross-party support for more robust animal welfare action, and, as we have seen from the protesters outside, more robust action on climate change.

Trophy Hunting Imports

Luke Pollard Excerpts

Wednesday 2nd October 2019 Westminster Hall

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

I congratulate the hon. Member for Mid Derbyshire (Mrs Latham) on initiating this very good debate, in which good points have been made by a number of speakers. It is a shame that it clashes with Second Reading of the Domestic Abuse Bill, because I know many of my hon. Friends wanted to speak in this debate. I imagine that, had they been here, they would have said much the same as has been said by others in the debate, but the Minister would have heard it from a few more voices.

I welcome the Minister to his place. It may not be fashionable—or productive for my future career—to say this, but I am excited about the hon. Member for Richmond Park (Zac Goldsmith) becoming a Minister. His championing from the Back Benches of causes and views that I believe many Members share has been really powerful. At the risk of injecting a partisan flavour into the debate, I have to say that sometimes we have heard the soundbite from Ministers but not seen the action that goes with it. I am certain that the hon. Gentleman will not fall for any press release camouflage on inaction. This is an area where there is a real opportunity to stop the long-grassing of policies where there is clear cross-party support, and to get on with it. I hope that when he gets to his feet in a moment, he will say exactly the same things.

We have heard some good contributions. The hon. Member for East Kilbride, Strathaven and Lesmahagow (Dr Cameron) mentioned a few but I will add a few more. The phrase of the right hon. Member for East Yorkshire (Sir Greg Knight), that trophy hunting is “nauseating and revolting”, cut through and adequately described what is going on. The hon. Member for Crawley (Henry Smith) rightly said that a ban on trophy hunting is backed by 86% of the British public. The hon. Member for Ayr, Carrick and Cumnock (Bill Grant) spoke passionately about the fact that it is not something that only happens abroad. We should recognise that and ensure that any ban takes adequate notice of that, so that it covers not just imports but exports of trophies from UK wildlife.

The hon. Member for Strangford (Jim Shannon) used “yellowhammer” correctly—it is good to hear the yellowhammer bird getting due attention after its name has been borrowed for so many things. We all share the complete puzzlement implied by his question, “Who on earth would want to shoot a zebra?” I agree with the hon. Member for Southend West (Sir David Amess), who was clear when he said it was a wicked, evil practice. We should not mince our words about people who go and shoot.

I am glad that it is not just parliamentarians who have encouraged this debate; people have used their fame and celebrity to endorse it too. Ricky Gervais does not mince his words on social media when it comes to this subject. I especially like his tweet from a few years ago, which says:

“The trophies I’m proudest of are the memories of all those times I didn’t kill a beautiful, majestic, endangered species for no reason.”

Although he may choose more powerful language to describe some of the people who are engaged in trophy hunting, his leadership on social media has highlighted a cruel and inhumane practice to many people who might not otherwise have appreciated its barbarity.

Ricky Gervais and the Minister are not alone, however, and have been in good company in championing the cause. Joanna Lumley correctly said that trophy hunting is “cruel, immoral…and unjustifiable”. Bill Bailey said:

“I can’t get my head round why anyone would want to kill a beautiful creature for fun. With the dwindling numbers of species, it’s time to halt this cruel and unnecessary practice.”

He is right, as are the speeches that we have heard today.

I will ask the Minister a few questions to try to understand the detail of the proposed ban. He has been clear that we should ban trophy hunting, but Ministers in the past have not been clear about what that ban comprises in detail, as the hon. Member for Mid Derbyshire hinted in her opening speech. The thread of Ministers to date was that the Government’s proposed ban would affect just threatened species, by taking that international classification and banning the imports of trophies in relation to them. I would like us to go much further. Labour’s position is that the ban should be for every species above least concern. That would effectively capture many more species, not just the most endangered.

Looking around the room, I see that many hon. Members served on the Committee for the Ivory Act 2018 to support the introduction of a ban on elephant ivory. Since that ban has come into place, as expected, and as mentioned in Committee, we have seen the trade move from elephant ivory to other ivory-bearing species, such as the rhino, which has experienced additional hunting since the ban on elephant ivory came in. We knew that at the time and we must not make the same mistake with the trophy hunting ban by banning it for the most endangered and allowing it to slip down to those that are just below the most endangered. The Minister will be well aware of that and, hopefully, with his power, he can make sure that it does not happen.

We need to recognise that trophy hunting, as well as being cruel and unjustifiable, can act as a cover for illegal poaching, which was the sentiment of the intervention of the hon. Member for North Herefordshire (Bill Wiggin). The proposed ban that we would like the Government to adopt would cover all species above least concern on the International Union for Conservation of Nature and Natural Resources red list, which would include species classed as vulnerable, endangered, critically endangered and extinct in the wild.

Sustainable alternatives to trophy hunting, such as eco-tourism and photographic safaris, are generating revenues that cover the real costs of conservation and effective anti-poaching work, as well as providing well-paying permanent jobs for local people. Shooting a lion such as Cecil can generate a one-off trophy fee of around $15,000. There is no evidence that that goes toward conservation, no evidence that it goes toward the local community, and no evidence that it goes toward the protection of other animals. Nature tourism, on the other hand, can generate money from the protection and valuing of those wild animals.

There is an opportunity, which has been mentioned a few times, through Brexit to come together. What Brexit has done for DEFRA debates is to open space in the Government’s legislative agenda for issues that might not otherwise have got the airtime they deserved. If we think about what has been passed by this House in recent months, on a cross-party basis, with the Brexit malaise and chaos going on around us, we will realise that many of the same faces in this Chamber have been working together on banning wild animals in circuses, banning the trade in elephant ivory and tightening up regulations across the board.

That work might not have attracted the attention of many people outside Parliament, and certainly it has not troubled some of our friends in the media, but it has been worthwhile. We should continue that spirit, whatever is happening with Brexit or outside, because there is something here that could make a real difference to the species involved.

[Carol Monaghan (Glasgow North West) (SNP)]

The hon. Gentleman is speaking very eloquently about the issue and the potential opportunities of eco-tourism. He will know that last year in Scotland, as my hon. Friend the Member for East Kilbride, Strathaven and Lesmahagow (Dr Cameron) has mentioned, the shooting of a wild goat on Islay caused a huge upset among people in Scotland and much further afield. What is most upsetting is that tourism companies are promoting Scotland as a place to come and trophy-shoot. Surely we should be clamping down on that. Companies are not just offering places in Africa as destinations; that is also happening here in the UK.

[Luke Pollard]

The hon. Lady makes a very sound point, on a common theme with the hon. Member for Southend West (Sir David Amess), who voiced a concern about what powers the Government have over the advertising of those tourism products. I spent five years working for the Association of British Travel Agents, and in that role I supported the animal welfare guidelines that encouraged ABTA members to ensure that animals are used sustainably and without endangering them, their habitats or their handlers. There are opportunities to ensure that those principles, which are good and strong, are spread across not only ABTA members, but the entire tourism industry. I am sure that the Minister is familiar with those guidelines; if he is not, I encourage him to look at them next time he needs some bedtime reading, because there is some real strength there and some real opportunities to do the right thing. The market does not correct all ills, and in this case there is a role for real moral leadership from the Government.

I hope that the Minister will be as strong and forthright in his new role as he has been in campaigning to date. I was pleased to see a letter that he co-signed in The Guardian in April with a series of high-profile supporters, which said:

“Banning the import of hunting trophies will send a clear message to the international community that there is no place for trophy hunting in this day and age.”

We must be clear that the continuation of that colonial and neo-colonial practice of rich people descending on communities, for whom that extra money can have a positive impact on their lives, to do something that is abhorrent, is something that we should not accept any more.

The Minister was in good company in signing that letter. It was signed not only by the Prime Minister’s father and his partner, but by Michael Palin, Captain Kirk—William Shatner, that is—Matt Lucas, Will Travers of Born Free, by my right hon. Friend the Member for Leeds Central (Hilary Benn), my hon. Friends the Members for Sheffield South East (Mr Betts), for West Lancashire (Rosie Cooper), for Kensington (Emma Dent Coad), for Stroud (Dr Drew) and for Makerfield (Yvonne Fovargue), and many others besides.

As my final remark, I encourage the Minister not to allow his passion for these topics to be diluted by the sense, which there sometimes is within Government, that animal welfare legislation can be cut up and parcelled in different parts, as happened with the Ivory Act. The Ivory Act should have been a comprehensive ban on ivory—I believe that is something the Minister himself supported from the Back Benches—but it was allowed to be parcelled up into smaller bits. I hope that the new Administration will move away from that parcelling up of animal welfare opportunities.

There is a real opportunity here for people who may be bitterly divided on Brexit and other matters to come together, on a cross-party basis, around animal welfare. I encourage the Minister to be as bold as he can be, because in these times animals do not have a voice, and every animal matters. We must ensure that we are their voice. The Minister has the opportunity to be a bull in a china shop on the previous behaviour of the right soundbite but the wrong action, and to ensure that we have the comprehensive trophy hunting ban that we deserve, which animals both in the wild and in the canned lion industry that the hon. Member for Mid Derbyshire spoke about can really benefit from.

Draft Environment (Legislative Functions from Directives) (EU Exit) Regulations 2019

Luke Pollard Excerpts

Wednesday 17th July 2019 General Committees

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

It is good to see you back in the Chair, Mr Hanson. I will use my remarks to raise a number of concerns on behalf of the Opposition about the regulations and the way in which they have been put together. They seem a little like the pile of vomit we sometimes see on the street after a night out. With a cursory glance, we wonder, “Why are all those bits in there, and where does the carrot come from?” [Hon. Members: “It’s too early!”] No, no. Everyone needs to be awake on this. When we see the broad range of topics included in the regulations and the Minister’s statement that they were held back before exit day, we must consider why all these measures are being included together. The only contingent stream seems to be that they all under the responsibility of the Department for Environment, Food and Rural Affairs.

Stakeholders have raised concerns with the Opposition on which I will provide some detail. The Minister tried to head off some of the concerns raised already, but I would like to put a few questions on the record that perhaps she can answer. I warn her that our concerns are substantial, so she cannot be assured of the Opposition’s support; it will depend on the answers she gives.

We are concerned that the regulations represent a power grab by Ministers, potentially enabling them to reduce current EU environmental protections by amending their own duties, standards and monitoring requirements, in particular for toxic emissions. The withdrawal agreement and the draft Environment Bill do not maintain the current EU protections or keep us in step with improvements. Indeed, we have not yet really seen the full extent of the Bill. These regulations need to fit with the other jigsaw pieces the Minister alluded to that we passed before 29 March. Hon. Members who have sat on Delegated Legislation Committees on such topics will note that air quality, marine management, water and water resources are the subjects of many of the statutory instruments that we have passed.

I say gently to the Minister that there is utility in mentioning how related instruments will fit together in the first and second stages when one statutory instrument is considered while others are held for future consideration. That will help scrutiny of those SIs; otherwise, all we have is random bits of legislation that do not seem to fit together. I am sure there is a method in the tactics that are being pursued, but it makes scrutiny much harder.

A key concern is the governance gap between leaving the EU and the date when the Government’s proposed environmental watchdog starts to function. The public cannot have confidence in it if it is appointed by and reports to DEFRA. Some of the watchdog’s powers relate directly to the areas that the SI covers, so they are connected. We are concerned that the Brexit legislation is being used as an opportunity for the Government to take on additional powers, but not with the same level of scrutiny as we had before, and that the new environmental watchdog does not strengthen the protections that we have together.

We have concerns about how the SI’s provisions fit together with the overall Government strategy on air quality. We know that the Government’s plans have been ruled unlawful numerous times by the High Court. The clean air strategy was a disappointment with vague targets. Responsibility was shoved to some local authorities with a degree of power, but some of their resources were taken away. Stakeholders have raised concerns about how powers will be exercised in relation to air quality, so will the Minister set out any additional powers and the level of consultation? The key thing for lots of stakeholders is that if the Government change any of the powers, will the stakeholders be consulted and will the consultation be done in a meaningful way?

On environmental noise, the current proposals are not good enough. They do not cover noise from domestic activities and noise created by neighbours, noise in workplaces and noise from transport. The Minister mentioned stakeholder concerns and she is right to highlight the concerns flagged by Greener UK, but other organisations have also flagged concerns. They are concerned that the SI establishes broad powers for the relevant competent authority, usually the Secretary of State, to make amendments, by regulation, to a wide variety of significant legislation, which potentially has important implications for the environment. Although some of the powers are limited in that the powers may be exercised only to the extent that the Secretary of State considers it is appropriate to do so as a result of scientific and technical knowledge, the requirement does not apply to all of the powers in this SI. Indeed, it provides no clarity as to what

“appropriate...as a result of scientific and technical progress”,

actually means. That is a broad statement, so will the Minister clarify what considerations and technical tests she will apply in defining what scientific and technical knowledge means in relation to this measure? Simply being really good at science and sitting in a Government Department might not qualify, so it is important to have some external scrutiny of what that definition actually means.

All the regulations that can be made by the competent authority under the SI are, pursuant to regulation 47, subject to the negative procedure of scrutiny, which means that the regulations become law on the day they are signed by the relevant Minister and will remain so unless Parliament agrees a motion to reject the relevant regulation. In SIs in the past, the Opposition have raised concerns about how many of the additional powers the Government are taking for themselves and applying via the negative procedure, potentially limiting scrutiny. We know that many of these powers are exercised by European authorities at the moment, who have a wide range of scrutiny functions derived from the European Commission and the European Parliament, and we need to look at the transfer of such scrutiny powers to the United Kingdom and how they can be properly reviewed, so will the Minister set out why she feels powers in negative SIs, and not affirmative ones, are the right ones to take?

Key to many of the concerns is the lack of scrutiny. Will the Minister confirm for the record that the SI has been in the reading room and has had stakeholder feedback on its production? What changes, if any, have been made? The Minister knows that a pet hobby-horse of mine is impact assessments, and I am afraid this SI prompts the same critique as the others, which I have mentioned in this place many times before. Page 11 of the explanatory notes, under the section on “Impact”, states:

“There is no, or no significant, impact on business, charities or voluntary bodies”

or the public sector, and therefore:

“An Impact Assessment has not been prepared for this instrument because it creates regulation-making powers rather than changing any policy.”

I am concerned that the difference between “no impact” and “no significant impact” is an impact, and an impact assessment of the difference between “no impact” and “no significant impact” would be required. I know that Minister’s officials normally have to prepare lines to rebut my saying these things, and I wonder whether we can find a way to avoid that dance each time and have a mini impact assessment or a form of words that enable the time that officials spend rebutting my concerns about the impact assessment to be spent on applying some of these elements.

Now that we have got through the glut of DEFRA SIs ahead of the proposed exit day on 29 March, I wonder whether Government Ministers could persuade the House authorities through the usual channels to slightly adjust the set wording on the explanatory notes, to clarify whether there is “no impact” or “some impact”, so that we have those as two very different statements. These regulations could have some impact, but it has not been assessed. The Minister is probably correct that they take a lot of powers but might not necessarily change any policies. Given that there might be no change in the powers but that they could bring significant change when used, and that there is not always the same scrutiny of the exercise of those powers, I would be grateful if the Minister could set out her view on that.

The Opposition have some concerns about the environmental noise area. On the INSPIRE side, we are concerned about the devolution agenda and how different levels of devolution can ensure consistent application. If there is a difference between the devolution of INSPIRE in Scotland and in England, Wales and Northern Ireland, how would that be resolved? If they are applied in different ways, would the Minister be concerned about that? Has any consideration been given to how that spatial data can work together to ensure that we get the right stuff?

I will close my speech by addressing marine strategy. The Opposition is very keen for the Government to have a more ambitious marine strategy for the protection of our oceans and seas. We are concerned about the application of the powers that are being transferred to the Secretary of State. I encourage the Minister to use the powers that she already has, as well as the powers that she is taking, to protect our environment in a faster, fuller way. We are very concerned about the state of our oceans and marine environment. Colleagues’ research on marine plastics and pollution, and the report on toxins and chemicals that was published yesterday by the Select Committee on Environmental Audit, should concern us. I would be grateful if the Minister could set out how she expects the powers in the marine section to be used. Simply transferring those powers is one thing, but their application is another.

There is plenty in the SI that looks like just a paragraph, which is our key concern. The consultation that needs to follow the powers does not always seem to apply as thoroughly as it should. I am concerned about how this fits with the other areas that we have already approved, and whether we should expect any other, related SIs. In her opening remarks, the Minister said that she chose not to bring forward this SI in the flood that we had leading up to 29 March, because it was not deemed critical. The powers that the Minister has taken are still substantial and I would be grateful if she could set out what other, non-critical powers she is expecting to transfer that relate to water, water resources, marine management, air quality and environmental protection, and which might not be included in this SI but will relate to the powers contained in it and in the others that we have passed in those areas. It is really hard to scrutinise the full regulatory and legislative impacts if the Minister keeps dripping different elements in at the same time, and if there are no aggregated or collated versions at the end that enable easy scrutiny, apart from trawling though the entire statute book—as we know, that is a much bigger challenge.

On that basis, the Opposition remain concerned about large chunks of this SI. We would be grateful if the Minister could respond to the concerns raised by stakeholders around the power grab, the additional powers and how any scrutiny functions will be applied in the use of the powers.

--- Later in debate ---

[Dr Thérèse Coffey]

In response to the hon. Member for Falkirk, I have been there once in my life, but I have not seen the Falkirk wheel. Perhaps I will add it to my summer list.

I object to the terminology used by the hon. Member for Plymouth, Sutton and Devonport at the opening of his speech. Our officials and lawyers have worked very hard on this legislation; it is not vomit. It is actually good, normal, sensible legislation being brought to this House for scrutiny.

Hon. Members will be aware that we had a huge number of statutory instruments to process into group areas, especially where they were small and similar, with the same approach of basically updating, in this case, technical powers. I thought it was appropriate to group together the different areas in order to undertake that. I also want to point out that I wrote to the shadow Secretary of State on 5 July, making her aware of this and inviting her to get in touch, if any discussion was wanted. I appreciate that the Government have the full benefit of the civil service behind them and the Opposition rely on Short money for that support to help on policy matters.

I want to assure the hon. Member for Plymouth, Sutton and Devonport that this statutory instrument was put in the reading room. No feedback was given to the Department at that point. There has been a subsequent briefing from Greener UK. I am not aware of contact from any other organisation on this and, as a consequence, no changes to the regulations were needed before formal tabling, which we are debating today.

The hon. Member for Plymouth, Sutton and Devonport is just going to have to join either the Procedure Committee or the Joint Committee on Statutory Instruments. I have made that appeal to him before. This is just the way that Parliament works, and it is not for the Government to change how Parliament decides that it wants statutory instruments to be written. We are following the conventions and rules set out by Parliament. I know that the hon. Gentleman is a champion for change on a number of matters. I encourage him to join the relevant Committees to make that change.

On the points that the hon. Gentleman made about air quality, regulation 15 provides that, before making any regulations under the part regarding air quality, there is a statutory duty to consult. Consultation will be carried out in accordance with our standard principles. On noise, the statutory instrument simply replicates the powers in the directive. It would be an inappropriate use of the European Union (Withdrawal) Act 2018 to do anything more than what is in the directive. If we want to make changes in the future, that will be a separate matter for us to consider through means other than this device.

On negative SIs, I repeat to the Committee that, at the moment, the Commission can exercise the powers without any scrutiny by this Parliament whatsoever. Today’s proceedings will at least give Parliament the chance to look at future regulations. We will have consultation where it is deemed necessary, and then Parliament can, even through the negative procedure, suggest that the regulations be stopped, debated and voted on. Parliament does not have those powers today.

Marine is an important issue, on which I think the House is united in wanting to do more. Again, the regulations are simply about powers to update technical matters. The hon. Gentleman mentioned how we know what will change, scientifically. As it stands, the Commission is regularly approached by scientists, academics and others in order to get such changes made, to update the technical progress. We would expect a similar situation to happen, whereby the Government would be approached by people saying, “We think you need to update these particular regulations,” or simply making a suggestion on how we monitor data.

A future marine strategy is an ongoing process within Government. The hon. Gentleman also talked about the INSPIRE regulation and metadata. That is a devolved matter. Usually, the UK Government work in great collaboration on matters that can be helpfully dealt with on a UK-wide basis—we have seen that as regards a series of processes. There is no reason why such ongoing co-operation cannot continue; however, the whole point of devolution is that, if a devolved Administration want to do something different, they do not have to remain in step with the rest of the UK.

[Luke Pollard]

In relation to scientists approaching the Department and asking for changes, one of the key things about our marine environment is that fish and other aspects of the marine environment do not respect national boundaries. Ensuring that regulations and standards in our marine environment, especially in areas that jut up against our EU neighbours’ marine environment, is really important. Does the Minister anticipate changes in the way that standard and monitoring assessments are made by our EU friends that she will need to carry over into UK law, or does she expect the two standards, which are currently the same, to diverge?

[Dr Coffey]

I am not expecting particular changes, but it is important to point out that we also have marine boundaries with non-EU countries. There is regular, ongoing co-operation through the regional management organisation for fishing. We also have the OSPAR commission, which covers the north-east Atlantic. Again, that has non-EU countries in it. We already have ongoing co-operation. It is important to state that one element of leaving the European Union is that it will be for Parliament to decide to make changes, rather than automatically agreeing with what the European Union decides is appropriate for its regulations. That is part of the effect of leaving the European Union.

I hope that I have answered the hon. Gentlemen’s concerns. This is a special day for me, because I have been doing this role for three years. I am very much looking forward to continuing for at least another week or—who knows?—for longer. With that, I hope that the Committee will support the motion.

Puffin Habitats

Luke Pollard Excerpts

Wednesday 26th June 2019 Westminster Hall

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

It is a pleasure to serve under your chairmanship, Mr Gapes. I congratulate my friend, the hon. Member for Berwick-upon-Tweed (Anne-Marie Trevelyan). We largely co-operate on defence matters, but we can now add puffins to our areas of co-operation. I suspect we will both be speaking in the combat air strategy debate tomorrow; I like her analogy of puffins as fighter jets and I look forward to hearing her mention puffins in the debate on the Tempest programme tomorrow.

It is true that every bird matters, but as we have heard, every puffin matters, too. Before I get into the detail, I would like to share my favourite puffin story. As we have heard, we all have our favourite. Mine relates to the puffins on the Skellig islands, off the west coast of Ireland. Sci-fi nerds may already know what I am about to talk about. The Skellig islands were used as a filming location for “Star Wars: The Last Jedi”. There were so many puffins as they were trying to film Luke Skywalker’s last hangout that they could not airbrush the puffins out of the movie, so they decided to turn them into their very own Star Wars species and the porgs were born. Watching “Star Wars: The Last Jedi”, Members will see plenty of porgs around Luke Skywalker’s coastal hut—and they are indeed puffins. That is a bit of bedtime watching for the hon. Lady.

It is true, as we have heard, that human activity is affecting the habitats of many of our planet’s valuable wildlife species. Through irreversible climate change, habitat destruction and biodiversity loss, we are making the survival of species that we love and appreciate increasingly difficult. In a debate last month, we heard about the cruel practice of the netting of bird nesting sites, preventing sea birds from nesting on some cliff faces. In that debate I made it clear that we must not keep squeezing nature into smaller and smaller spaces. Given what we have heard about puffin habitats, they are already in very small spaces geographically.

Britain is home to around 10% of the world’s puffin population, with nearly 600,000 breeding pairs, often found in clusters around the coastline of the British Isles. It is brilliant to hear of the experiences of various hon. Members with the puffin populations in their own part of the world. The right hon. Member for Preseli Pembrokeshire (Stephen Crabb) spoke about Skomer island. The hon. Member for Ayr, Carrick and Cumnock (Bill Grant) spoke about the west coast of Scotland. In the area that I represent, the south-west, we have puffin populations on Lundy island off the north coast and on the Isles of Scilly.

On Lundy we have had a similar experience to that mentioned by the hon. Member for Berwick-upon-Tweed in relation to tackling invasive species. On Lundy we are beginning to have a puffin comeback. After many years of puffins being on the brink of eradication, a programme to deal with the accidental introduction of rats from visiting boats has started showing good results. Thanks to the Lundy seabird recovery project, puffin numbers are now increasing. This is a great example of how targeted action can bring great results, correcting the damage that humans have done to these vital habitats.

Puffins are found in small clusters, which leaves them more susceptible to changes in local fish populations, as we heard from the SNP spokesperson, the hon. Member for Falkirk (John Mc Nally). Puffins are on the RSPB’s red list of conservation importance, which means that urgent action is needed to prevent their decline. In the Isles of Scilly, we have witnessed the success of the seabird recovery project—the hon. Member for St Ives (Derek Thomas) is not present today, but he asked me to mention that on his behalf. That EU-funded project has done some great work in removing items of rubbish and in eradicating invasive species on the islands, leading to the fast recovery of the populations of the Manx shearwater and the puffin. Will the Minister, in his remarks, set out what plans the Government have to replace specific EU-funded schemes, such as that one, which deal with rare bird habitat protection?

The RSPB describes the main threat to puffins as a change in the distribution and numbers of small fish. Drastic changes in the numbers of small fish in the local area around puffin habitats can occur if there is increased pollution, as we have heard in the debate, whether from plastic or other pollutants such as oil. Overfishing in those areas also poses a threat, with sustainable fishing paramount for the survival of seabird species.

The Minister will be aware that his Conservative colleague the hon. Member for Waveney (Peter Aldous) has tabled an amendment to the Fisheries Bill to ban sand eel fishing. As the hon. Member for Berwick-upon-Tweed noted, sand eels are a key part of a puffin’s diet, so I would be grateful if the Minister set out the Government’s position on sand eel fishing and on that amendment.

[Melanie Onn (Great Grimsby) (Lab)]

Does my hon. Friend have any thoughts about the additional assistance that inshore fishermen could provide in making the environment for puffins free from pollution, and in supporting their habitats?

[Luke Pollard]

Yes. Fishers have several important roles to play, one of which is dealing with ghost gear. Although puffins are small birds, they are susceptible to eating plastic. Dealing with ghost gear—discarded fishing gear—is an important part of addressing that problem; I know that fishers in my hon. Friend’s constituency and mine are taking steps to deal with it. Not only is it an expensive cost to the business, but it presents a real risk to wildlife and bird habitats. I urge my hon. Friend to keep encouraging fishers in her constituency to tackle plastic pollution, as I know she does already.

On the subject of plastic pollution, I must mention nurdles. Several hon. Members have noted incredibly worrying issues with puffins’ diet and their ability to survive in the long term. As well as eating sand eels and other fish, puffins also eat plastic. A variety of studies of dead puffins washed up on the beach have found that, when cut open, their stomachs prove to be full of nurdles. Nurdles are small pieces of plastic that can be melted together to make larger items, but they are also a consequence of macroplastics being broken down. Puffins’ stomachs, like those of other seabirds, are full of plastics, which prevent them from getting the necessary nutritional value from their food.

Just as we have a limited understanding of what puffins get up to at sea, we lack scientific knowledge about the effect of plastics on certain bird populations, of which puffins are a good example. I know that there has been much research in Scotland about seabirds and plastics, but I would be grateful if the Minister set out his vision for dealing with the scientific evidence base. If we had a true understanding of the effect of plastics on puffins and other seabirds, it would make it easier for the public to get behind action.

Seabirds are protected by a network of marine special protection areas, and I am pleased to hear that the Government have granted the application for such an area in the constituency of the hon. Member for Berwick-upon-Tweed. It is also good that the eider duck has been included among the protected bird species; I have heard the hon. Lady speak several times about its importance, and it should not be left out.

I would like a network of national marine parks to be created around the UK, which would provide an opportunity to put our complex system of protected marine areas into plain English. We already have a network of marine conservation zones, designated European marine sites and sites of special scientific interest—the list goes on. However, there are so many forms and designations of marine protection that it makes it harder for the public to access those sites. The Government’s review of national parks gives us a real opportunity for the development of national marine parks. The Minister will know that Plymouth City Council is leading work, which enjoys cross-party support at a local level, to establish the first national marine park in Plymouth Sound. Protecting more marine areas would contribute to greater understanding and public awareness—the right hon. Member for Preseli Pembrokeshire mentioned the Puffarazzi project—and would underline the importance of taking care when visiting puffin habitats.

I am very pleased that the House recently agreed to Labour’s motion to declare a climate emergency, after an important debate that showed that this place is taking climate change seriously. I know that hon. Members from all parties will have visited climate change protesters at the Time Is Now climate protest today. Although we need to decarbonise our economy, we must not think of climate change as being only about carbon; we need to think equally about how to protect and conserve coastal habitats, bird nesting sites and feed, as we have heard today.

I am grateful to the hon. Member for Berwick-upon-Tweed for giving us a chance to tell our favourite puffin stories; I hope that more people will be able to do so over the weeks and months ahead. I know that the Minister has a full to-do list at his Department, but I hope that he will take seriously the concerns that have been voiced about our wonderful, brilliant, comical puffins, and take note that their decline is a sign of humanity’s intervention regarding our wildlife. We need to do more to protect puffins, which will also save and protect other important habitats and seabird populations.

Oral Answers to Questions

Luke Pollard Excerpts

Thursday 20th June 2019 Commons Chamber

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

I want to press the Minister on geographical indications, which are vital in our marketing of goods and products made across the country. In the event of a no deal, about which the frontrunner in the Tory leadership contest seems quite keen, protections for Cornish pasties, Buxton blue cheese, traditional Welsh perry, Cornish clotted cream and Whitstable oysters, to name but a few, will be at risk. What steps is DEFRA taking to ensure that those vital goods produced by our farmers and growers are protected come Halloween this year?

[Mr Goodwill]

In a no-deal situation, we would wish to set up our own scheme and to negotiate with our friends across the channel to ensure some degree of co-operation, but I stress that no deal is not an option I would want to support. We need to get a deal, and we need to get it over the line. If, like me, Opposition Members had voted for the deal on the three occasions it came before the House, we would have left the European Union on 29 March and we would be in a much better situation for UK producers.

Oral Answers to Questions

Luke Pollard Excerpts

Thursday 9th May 2019 Commons Chamber

[Michael Gove]

My hon. Friend is absolutely right and we are absolutely committed to supporting the work in St Fergus. Technological breakthroughs in institutions such as Robert Gordon University in Aberdeen are also precisely the sorts of work that we should be getting behind.

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

Today the Environment Agency announced that it is preparing for a catastrophic 4° rise in global temperatures and huge sea level rises. The EA says it needs £1 billion a year for coastal defences, but the Government have allocated only £2.6 billion over six years —less than half of what the EA says is needed. When should we expect the necessary increase in funding and a plan to protect our vulnerable coastal communities?

[Michael Gove]

The hon. Gentleman raises an important issue. First, I record my thanks to Emma Howard Boyd and Sir James Bevan, the chair and chief executive of the Environment Agency, for the leadership that they have shown on this issue. Under this Government, record amounts have been spent on flood defences and record efforts have been made to combat climate change. However, in both cases, more needs to be done. The national policy statement will be forthcoming shortly.

World Health: 25-Year Environment Plan

Luke Pollard Excerpts

Tuesday 9th April 2019 Westminster Hall

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

It is a pleasure to serve under your chairmanship, Mr Walker. I congratulate my fellow west country MP, the hon. Member for St Ives (Derek Thomas), on securing this important debate, and for introducing it so eloquently. I especially liked his phrase that we have to “up our game”. He rightly encouraged ministerial colleagues to do that. Our environment needs to be taken more seriously by all Members of Parliament and all those in public office if we are to meet the challenge that we face.

It has been a good debate. The Division has led to a slightly emptier Chamber than we had a moment ago, but we heard some fantastic contributions from speakers from right across the political spectrum. I especially pay tribute to my hon. Friends the Members for Great Grimsby (Melanie Onn) and for Bristol East (Kerry McCarthy), who spoke about the importance of bird nesting—a subject that now has media attention, not only because of the horrendous footage on social media today of sand martins trying to get through nets to get back to their nests.

There is also concern about the practice of developers netting trees to prevent birds from nesting, and the sense that that is being done against the best interests of our natural world. Hon. Members on both sides of the House feel aggrieved by that, but we have the powers in this place to do something about it. We must call out developers who use cruel, inhumane tactics against our wildlife and, if they persist in such behaviour, we must introduce regulation to prevent it.

I also pay tribute to the Chair of the Select Committee, my hon. Friend the Member for Wakefield (Mary Creagh), who spoke so eloquently about microplastics. We need Ministers to rise to the challenge of how we test for microplastics, ensure that we are using common science across all forms of testing and create a safe level and an action plan not only to reduce microplastics and microfibres but to tackle what is already in the natural world.

I pay tribute to those Members across the House who mentioned insect loss, a subject which my hon. Friend the Member for Leeds North West (Alex Sobel) led a good debate on only a few weeks ago. Despite many of us not being huge fans of creepy crawlies, we need to spend more time on that. We need to focus not only on bees but on a wide variety of insects that are vital to our natural world.

I pay tribute to the hon. Member for St Ives for talking about public engagement with nature. If we are truly to value and protect our natural habitat, we need to ensure that people visit it, understand the value of it, and get something from it. It is deeply disturbing how few people engage with our natural world. I am leading the campaign for Plymouth Sound to be designated the country’s first national marine park—the first, but I hope the first of many. Some 20% of our young people in Plymouth, Britain’s ocean city, have not even seen the sea, and 50% have not visited a beach. Those were the findings of the fairness commission that was run by Plymouth City Council. Those should be the type of statistics that scare us all. That is a city right on the coast, so much more needs to be done.

At the last DEFRA questions on 28 March the shadow Environment Secretary, my hon. Friend the Member for Workington (Sue Hayman), declared a climate and environment emergency, on behalf of the Opposition, at column 534. She challenged the Minister to join us in cross-party working to jointly declare a climate crisis. Ministers did not agree to do that, but I hope that the Minister will recognise the importance of cross-party working in relation to declaring a climate crisis. In local government up and down the country, Conservative, Labour, Green and Liberal Democrat councillors, and others besides, have been working in collaboration to declare local climate crises. The public and the young people whom the right hon. Member for Newbury (Richard Benyon) spoke about expect politicians in this place to do something similar and declare a climate crisis at national level. We can then take cross-party action against it.

The 25-year environment plan is a good start, but we need much more besides. My hon. Friend the Member for Huddersfield (Mr Sheerman) spoke with passion about the need for action and that is something I want to impress on the Minister. Since the Environment Secretary took office there have been 76 DEFRA consultations, but only one piece of primary legislation. It is not good enough to be the Secretary of State for consultations. We need to tackle climate change properly, which means that we need proper action. I implore the Minister to tell the House when the Agriculture Bill and the Fisheries Bill will make a comeback, and when the environment Bill, for which the hon. Member for St Ives made a good case, will be seen. We need action, not just warm words.

[Mr Charles Walker (in the Chair)]

A beautifully timed speech from the shadow Minister.

Oral Answers to Questions

Luke Pollard Excerpts

Thursday 28th March 2019 Commons Chamber

[Michael Gove]

The fishermen of Strangford and the Ards peninsula are people close to my heart. It is absolutely right that since the recent actions we have been in touch with the Irish Government specifically in order to ensure that we can have a fair allocation of fishing opportunities across the island of Ireland and its waters. The Republic of Ireland Government know how seriously we take this issue, and how urgent it is to reform.

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

I was amazed and disappointed this week that the Government whipped their MPs to vote for a huge loophole in post-Brexit fishing rules that would allow a cruel and inhumane method of fishing to continue. The 5% loophole that allows electro pulse beam trawling is cruel and destructive. It destroys our seabeds and kills juvenile fish, and it is so intensely destructive that it breaks the vertebrae of cod. Will the Secretary of State now work with the Opposition to bring forward a brief statutory instrument to close this loophole that allows UK boats to use this cruel and inhumane fishing method?

[Michael Gove]

We always want to work with the Opposition to ensure that the highest standards of environmental and marine welfare are maintained, but I should say that it is one of the opportunities that leaving the European Union gives us to ensure that Dutch vessels that have been using pulse fishing in our waters end that cruel practice.

--- Later in debate ---

The right hon. Member for Carshalton and Wallington, representing the House of Commons Commission, was asked—

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

7. Whether the House of Commons plans to stock Plymouth Gin during the Mayflower 400 commemorations.

[Tom Brake (Carshalton and Wallington)]

The House of Commons catering service does not currently stock Plymouth Gin, but will seek to stock some for the Mayflower 400 commemorations.

[Luke Pollard]

I thank the right hon. Gentleman for that answer, which will warm the spirits of people in Plymouth. Plymouth Gin is a fantastic gin, and Mayflower 400, which marks the 400th anniversary of the sailing of the Mayflower from Plymouth to America, is a great opportunity. In these tough times, may I suggest to the right hon. Gentleman that we look not only at the standard-strength gin, but Plymouth Gin’s Navy strength as well? We could all do with a little bit extra in these tough times.

[Tom Brake]

I thank the hon. Gentleman for that. He may be aware of moves within the House to look at the availability of alcohol in this place; I am not sure whether the House will want to entertain the idea of double or triple-strength gins. However, he has put his point on the record and I will take it back to the catering services, including whether they want to stock the double or triple-strength gin that he proposes.

draft Common Organisation of the Markets in Agricultural Products Framework (miscellaneous amendments, etc.) (eu exit) Regulations 2019 Draft Common organisation of the markets in agricultural products and common agricultural policy (miscellaneous amendments) (eu exit) regulations 2019 Draft Agriculture (Legislative Fuctions) (EU Exit) (No. 2) Regulations 2019

Luke Pollard Excerpts

Tuesday 26th March 2019 General Committees

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

As the Minister is double acting with his former Minister, he will excuse me if the shadow team does the same. I have only a few technical questions.

In the draft Agriculture (Legislative Functions) (EU Exit) (No. 2) Regulations 2019, explanatory note 7.5 on page 4 states:

“The Secretary of State may also exercise the functions on behalf of a devolved administration, but only with their consent.”

Can the Minister provide clarification with regard to the concerns he raised earlier about the functions being used in relation to powers in Wales? What type of consent does the Minister need to seek? For the sake of clarity, can the Minister set out whether he can exercise those powers in Wales without the consent of the Welsh Assembly due to the devolution settlement being confused?

The Minister, and certainly his predecessor, will know that I have been critical about the wording of impact assessments throughout this entire process and the phraseology that said there is no or no significant impact was used in earlier statutory instruments. As we are coming to the end of these DEFRA SIs, I wish to put on record that impact assessment paragraph 12.3 on page 5 is significantly better than the wording when we started the process. I am grateful to officials for beefing that up. I am also especially grateful for the addition of the understanding about the financial threshold and the impact the instrument suggests. In this case, it states that

“the change in regulation falls below the £5m p.a. threshold for net direct costs to business.”

In my mind, £5 million seems to be a significant impact for businesses. I believe that threshold level is still too broad, but it is good to see that a threshold level is being inserted at all.

On the draft Common Organisation of the Markets in Agricultural Products Framework (Miscellaneous Amendments, etc.) (EU Exit) Regulations 2019, can the Minister explain the revocations in part 4? My understanding is that this SI revokes geographical indication protection for a series of incredibly posh wines that I have not been fortunate enough to try, including Bürgstadter Berg and Monzinger Niederberg, which according to my friends at Google is a wonderful Riesling. I would be grateful if the Minister set out whether those protections are replicated elsewhere, or whether what we are doing here is removing geographical indication protections. As the Minister will know, and the former Minister will certainly know, I am a big fan of keeping geographical indication protections so that the GI status of, for example, Cornish pasties can be protected after whatever form of Brexit we have. I am concerned that revoking protections on certain types of wine will be the start of a reduction in GI protections that could encourage our European friends to further remove protections on UK products.

Finally, in the explanatory memorandum for the draft Common Organisation of the Markets in Agricultural Products Framework (Miscellaneous Amendments, etc.) (EU Exit) Regulations 2019, paragraph 7.3 on page 4 states:

“With exit day less than one year away, and in the continued absence of a Northern Ireland Executive”.

That is technically correct—three days is certainly less than one year away—but I wonder how long this SI has been sitting on the books. There is a point here about how late we are looking at so many of these SIs, ahead of what was previously exit day on 29 March. That sentence suggests to me that this SI has been sitting around for a long time.

[George Eustice]

Perhaps officials in the Department could foresee that Parliament would baulk at the idea of leaving without a deal. “One year” might be a reference to the extension.

[Luke Pollard]

I am grateful to the former Minister, who is again backseat driving the Minister’s role. I would like to think that officials are that prescient about the Government’s inability to bring forward a deal that they can get a parliamentary majority for, but I suspect the answer is that this SI has been sitting on a desk in DEFRA for some considerable time, and we are waiting until the last moment for these SIs to be given the scrutiny they deserve. As my hon. Friend the Member for Stroud said, driving through so many SIs means that the level of scrutiny that stakeholders and the Opposition can give them is more limited than if we had been given more time. However, I would be grateful if the Minister set out answers, particularly about the geographical indications and what they mean for the read-across of UK protections.

Draft Agriculture (Legislative Functions) (EU Exit) Regulations 2019 Draft Common Agricultural Policy (Financing, Management and Monitoring) (Miscellaneous Amendments) (EU Exit) Regulations 2019 Draft Common Agricultural Policy (Financing, Management and Monitoring Supplementary Provisions) (Miscellaneous Amendments) (EU Exit) Regulations 2019 Draft Common Agricultural Policy and Agriculture and Horticulture Development Board (Amendment etc.) (EU Exit) Regulations 2019

Luke Pollard Excerpts

Monday 25th March 2019 General Committees

[Luke Pollard (Plymouth, Sutton and Devonport) (Lab/Co-op)]

The Minister will be pleased to know that I have just a small number of technical questions. Before I turn to agriculture, I briefly want to mention fisheries. The explanatory memorandum for the Agriculture (Legislative Functions) (EU Exit) Regulations 2019 talks at the bottom of page 3 about the EMFF funding. It was asked during the passage of the Fisheries Bill what happens in the event that the powers jointly exercised by the Secretary of State and the devolved Administrations cannot be exercised with complete unanimity because one of the devolved Administrations object to the Secretary of State’s policy. That is referred to on page 3 of the explanatory memorandum. Page 16 states:

“Any changes as a result of the use of powers after EU Exit will only be carried out with the consent of the devolved administrations.”

The Opposition proposed an amendment that would have created a dispute mechanism to ensure that, if that happens, there will be a plan in place to resolve it. The Government disagreed with that dispute mechanism, but I note that there is no method of dealing with the issue in this instrument. I will be grateful if the Minister sets out how he intends to deal with it.

On the Agriculture (Legislative Functions) (EU Exit) Regulations 2019, I would be grateful if the Minister set out, in relation to financial discipline in England, the different thresholds specified in the regulations. I have two questions about the regulations. First, the SI suggests that the threshold for the financial year ending 31 March 2020 is £2.093 billion, and the financial threshold for the year ending 31 March 2021 is £2.095 billion. That is an increase of only £2 million. What calculation and rationale was there for that £2 million? Why is there no reference to any retail prices index or consumer prices index calculations?

Secondly, I want to press the Minister on the exchange rate used. Throughout the document, euros, rather than pounds, are used for financial payments. I could not see anything about the exchange rate. Any big fluctuations, such as the fall in the value of the pound after the 2016 referendum, could have a substantial effect on the exchange rate. Is there a mechanism to adjust that to ensure that our farmers do not lose out?

I am grateful that the Minister set out the gremlins that he discovered in the explanatory note. In a previous SI Committee, I asked him to assure us that there were no gremlins in the explanatory notes or the SIs, but one was pointed out in the very next SI Committee. I am glad that he spotted that one, but I wonder how many other gremlins in these SIs have not been spotted. I do not anticipate that the Minister has a list of how many have not been spotted; the point is that there could be others.

Finally, I want to ask the Minister about the agriculture support. The Government have committed to continue funding until the end of the Parliament, rather than a certain date. What happens to the funding if the Parliament ends before 2022, especially if there is a shortfall? My understanding from Ministers’ statements is that the post-CAP funding settlement is expected to lead to an above 40% reduction in the total value of agricultural support. If the Parliament ends before 2022, what measures are in place to provide the same timeframe for farmers and others in the agricultural sector, so they can adjust to what could be quite a substantial difference in agricultural subsidies?

--- Later in debate ---

[Mr Goodwill]

I thank the hon. Gentleman for that question. We are keen to make progress on the Agriculture Bill. We will get it on the statute book as soon as possible, and it will certainly be on the statute book as and when it is required.

I was asked about cross-compliance. The European Union (Withdrawal) Act 2018 does not give us the power to make wholesale policy changes, and we do not think it would be appropriate to use the powers in the Act to omit cross-compliance from retained CAP legislation. Instead, we have the flexibility to amend cross-compliance within the confines of the current legislative framework. Further substantive changes to cross-compliance will be able to be made through the Agriculture Bill.

I was also asked why the devolved Administrations have taken a different approach to agriculture. Agriculture is a devolved policy area, and the devolved Administrations are currently able to operate CAP schemes within the legislative framework. It is for each Administration to decide how these EU regulations should be made operable.

The hon. Member for Plymouth, Sutton and Devonport raised issues to do with EMFF funding and the Fisheries Bill. I had been doing so well, but that is one that I will need to write to him about, as it is quite a technical issue and I do not want to get it wrong—similarly with the dispute mechanism, although of course that is one of the things for the future. As I said, at the moment, we are keeping measures in place as they are; there is no change.

The hon. Gentleman mentioned the exchange rate. The exchange rate for payments is fixed in September. That has been the case for some time. He also mentioned fixed-term Parliaments. As I said, no Government can tie the hands of a future Government, and it will be up to the parties what they put in their manifestos.

[Luke Pollard]

On the technicalities of the two threshold levels, I would be grateful if, when the Minister prepares his note to me, he set out the thinking behind the €2 million mark, whether that is RPI or CPI-related, and what formula created those two levels.

[Mr Goodwill]

I will ’fess up: I was not aware of that difference. There may be a perfectly logical explanation that is not policy related.