Wednesday 23 January 2019

Technical submission to DCO Examination



Manston Airport

A Nationally insignificant Infrastructure Project

Barry James | NSIP | 23/1/2019




Foreword


As we wrote this and read all the reports that dealt with Aviation connected with Manston is became apparent that “experts” had a different way of interpreting the many statistics involved. It also became clear that even the same statistics had different interpretations dependent on whether the information was being used to defend or attack aviation use at Manston. It is hoped that we have tried to remain neutral in our report.

Even when the same report was used to back the claim that Manston was viable important statistics have been selectively interpreted to benefit that viability. As an example Boeing wrote a report stated worldwide aviation would (in their opinion) grow by 6%. What was ignored was this applies to passenger growth and the Manston DCO is for a Cargo Hub using cargo freighters and not passenger planes with bellyhold cargo.

Executive Summary


To be a Nationally Significant Infrastructure Project (NSIP) Riveroak Strategic Partners (RSP) have to show that the UK would benefit from the reinstatement of Manston Airport and that taking the land from the legal owners would benefit the greater need of the population at large. The case for this they have failed to do simply because that need (for a cargo hub handling air freighters only) is simply not required in the United Kingdom and that current capacity restraints will not be reached until 2050 at the earliest if at all. *2

       • There is no overall shortage of freight capacity in the UK or South East specifically. While Heathrow is constrained, there is significant spare freight capacity at the established dedicated freighter hubs at Stansted and East Midlands.*1 Exec summary

       • Cargo activity in the UK has become much consolidated on the 3 cargo hubs (Heathrow, Stansted and East Midlands). All three of these airports have plans to significantly expand cargo capacity, and they forecast strong growth in cargo tonnage. Furthermore, other established passenger airports have the capability of handling much higher cargo volumes if demand existed. *1 exec summary

       • There has been a strong trend towards bellyhold freight, with the role of dedicated freighters diminishing. The most recent (2017) Department for Transport (“DfT”) forecasts to 2050 assume the number of freighter flights in the UK will remain flat at 2016 levels.*1 exec summary

            • Trucking is a highly integrated component of the air freight business model, and not merely a substitute for air freighter flights when airport capacity is constrained. The increasing use of truck feeder services is due to cost efficiencies and is not restricted to the UK. *1 exec summary

       • Manston is in a poor location to serve the wider South East or UK market. Other structural disadvantages include lack of critical mass, lack of a passenger hub, and night flight restrictions. These factors have limited Manston’s role to that of a niche freight airport. *1 exec summary

This is analysed under the heading freight market

       Further there are the following reasons to worry about the submission as follows

       2.         Why would the Planning Inspectorate grant a DCO to a UK shell Company with control hidden behind an offshore corporate veil in a Belizean Tax Haven, and especially one that is depending on raising the finance AFTER the DCO is granted? (RSP seem not to have any income unlike many infrastructure companies)

       3.   Without a cap on ATMs why hasn’t RSP considered a Public Safety Zone (PSZ) at each end of the runway?

       4.   It seems from the submission that the Northern Grass zone isn’t needed as it isn’t fundamental to the operation of a cargo hub so why is it included in the CPO powers asked for?

       5.   Why are the (only) two noise monitors positioned 6.5km from the runway (placing the Ramsgate one in the sea) when Central Ramsgate is 3.2KM from the runway?

       6.   Why have RSP reversed the conventional wisdom of landing and taking off INTO the wind? 20 years of commercial aircraft flying dictates the predominant wind is from the South West over the UK which would mean that 70% of cargo flights would overfly Ramsgate on landing and take-off over Herne Bay.

7.   How have RSP come to the conclusion that the Manston site is worth £7.5M when “In Spring 2006 Kent County Council acquired the undeveloped area of Manston Business Park, amounting to some 40 acres of developable land, from the Administrator of Planestation plc for £5.35 million”? (*5 KCC-Position-Statement-on-Manston-Airport page 7)

8. Justification for NSIP, We would like the Tribunal to ask RSP why they haven’t considered any of the surplus airfields in the middle of the country. For instance both Mildenhall and Lakenheath are looking for buyers and have far better motorway connections without a town of 40000 inhabitants at the end of the runway.

9. Environment

RSP confirm within their documents that the effect of noise and pollution would have an adverse effect on the residents of Thanet “12.7.72 Considering the impact is permanent and a large number of dwellings…………….significant adverse effects…….Ramsgate, Manston, Wade and West Stourmouth” One has to consider that the possible benefit to the Community at large is outweighed by the detrimental effect on the Residents in the above towns. (Our emphasis) Further there is another potential environmental risk being glossed over, that is, the volume of heavy goods and fuel bowser vehicles proposed along the Thanet Way daily.

1.     FREIGHT MARKET


Overview of the UK Freight Market


In 2016 the total freight market in the UK amounted to 484 million tonnes which includes shipping, road haulage and air freight. The airfreight proportion of this market has averaged 2.3 million tonnes which equates to ½ of one percent. This is hardly surprising considering the relative cost of each element with shipping being the most cost effective followed by road haulage and airfreight being up to 4x the cost of shipping by sea.

What has also been a trend since 2004 is freight sharing with passenger flights. This is called bellyhold freight and significantly reduces the overall cost due to cross subsidies and makes up 95% of all freight tonnage at Heathrow the UK’s biggest freight airport.

Both these trends count against Manston because passenger numbers are constrained by the catchment area and the determination of RSP to state their preferred route is freighter only.

From 2006 to 2016 the study of the individual freight airports show that bellyhold freight has been increasing to the detriment of air cargo freighters. E.g. Heathrow has increased its total amount of freight handled by 17.5%. From 2006 to 2016 the total freight handled in the UK has increased by a paltry 2.58% (2.31 Million tonnes to 2.38 million tonnes over the same period). East Midlands increased by 9% and Stansted by 9.5%. Obviously with these taking more of a share other airports have gone backwards, Gatwick for instance has lost 50% of its airfreight business in the last 10 years.

However a cargo NSIP only has to prove that they will achieve 10000 ATM’s and not the freight tonnage which in theory could mean 5000 aircraft landing and taking off empty which would be hardly sustainable considering the capital expenditure needed to open the airport.

Overall, 29.7% of UK air freight in 2016 was carried on cargo only aircraft, with 70.3% carried in the bellyhold of passenger aircraft.

The Department of Transport (DfT) recently released a report “Moving Britain Forward” *2

The following is from the freight element of the report and clearly shows that the DfT believes that freighter only ATM’s are in decline and with the choosing of a 3rd runway at Heathrow this trend will almost certainly continue. With both Stansted and East Midlands both expanding capacity the chance of there being a market for Manston is receding every month it remains closed. Further recent (2016 and 2017) freight tonnage into and out of Gatwick show above average increases due to their management making increasing use of long haul bellyhold freight. They are still only 50% of the 2006 (CAA figures) so can still mop up any constraints found at Heathrow.
Manston Airport history

Manston has had a civilian conclave since 1959 but since 1989 after it changed the name to Kent International Airport it became dependent on passenger charters and freight however no matter what it renames itself it is only likely to be involved in a niche market because of its geographical position. At its closest it is an hour from the A2/M25 junction adding considerably to the costs of any freight forwarder.

Taking the Civil Aviation Authority (CAA) figures from 1990 to 2014 it is apparent that cargo has only ever been marginal compared to the rest of the freight airports such as Heathrow, East Midlands and Stansted however what it does show is that the average load per ATM during the 24 years of operation was 44 tonnes and this is not reflected in the forecasting by Dr. Dixon.

Several reports have stated the reasons why Manston would not succeed and these include the following points:-

“Note that at no time in the period since 1990 has Manston played a significant part in the UK air freight market. Its share peaked at 2.0% in 2003, and in the 5 full years prior to its closure in 2014 (2009-13), it had an average share of 1.3%. The number of cargo ATMs only exceeded 1,000/year on a single occasion since 2000 (1,081 in 2003), averaging 462/year in the 2009-13 period”

“Although there are no local airspace restrictions, Manston lies beneath some of the busiest cross channel airways giving access to Europe and so movements would need to share airspace capacity with heavy traffic flows to and from the main London airports.”

“Rapid turnaround times that Manston has achieved when handling one or two planes a week. There is no evidence that this could be maintained at higher volumes – in fact, the longer turnaround times at other, busier, airports suggests that it cannot”

“With enough stands, and warehousing and terminal space, Manston could handle a lot of traffic, but that doesn’t mean that it will. In fact if it were this simple why didn’t Wiggins/Planestation and Infratil not build more stands instead of asking for night flights”

Even under previous configurations of the airport they should have been able to handle 21000 cargo ATM’s however because of the geography of the site few Cargo freight forwarders considered it a viable option. In point of fact Gatwick is considered too far south and since 2006 they have lost 50% of their freight tonnage.





Azimuth Associates


Dr. Dixon has written a report (https://infrastructure.planninginspectorate.gov.uk/wp-content/ipc/uploads/projects/TR020002/TR020002-002459-7.4%20-%20Azimuth%20Report.pdf to explain just why RSP believe Manston is an NSIP, however many more experts have repudiated all of her forecasts (this includes the figures in York Aviation’s reports that she quotes in her forecasts). It does seem rather strange that the only report in support of a Cargo Hub at Manston (and there have been a few) is the one written by Dr. Dixon.



Azimuth Associates (Dr. Dixon) has produced a series of forecasts with the intent of “proving” RSP’s contention that reopening Manston would be an NSIP (an NSIP in cargo aviation terms is 10000 air traffic movements (ATM’s)) however it is particularly noticeable that she has worked backwards to achieve this aim instead of looking at Manston’s past performance and working forward. Several reports have clearly stated that her forecasts are simply unrealistic. (Altitude Aviation and York Aviation’s (*3) reports)

We are, however, more concerned about the fundamentals of the way in which she approaches her forecasts. The NSIP requirement is for 10000 ATMs which historically Manston has never achieved. In fact from 1990 until 2012 (22 years) Manston failed to achieve 10000 ATMs at all and yet according to Dr. Dixon RSP will achieve that magic figure inside 7 years simply by increasing the number of aircraft stands from 2 to 19. Something is simply wrong.



From Dr. Dixon *4

With reference to the previous history of Manston, compiled over a 24 year period, it shows that every ATM averaged 44 tonnes of cargo which is an historical fact and should have been the basis for the forecast. Notwithstanding RSP have failed to produce a meaningful business plan breakdown it makes sense to look at where Manston’s niche market lay.



Using this as a basis and comparing it to the figures produced by Azimuth it becomes apparent Dr. Dixon has chosen to reduce the tonnage per ATM simply to ensure the 10000 ATM’s are reached.

Year
Azimuth ATM
Azimuth Tonnage
Average per ATM
Historical ATM
Tonnage
Average per ATM
2
5252
96553
18.38
2194
96553
44
5
9936
173741
17.48
3948
173741
44
10
11600
212351
18.30
4826
212351
44
15
14113
270579
19.17
6149
270579
44

Extrapolated from the CAA and Dr. Dixon’s report

Using the appropriate, more cost effective cargo tonnage it does show that even after 20 years the figure of 10000 will not be reached. It may be that RSP wants to attract far smaller freight planes however even then freight planes would on average carry far bigger loads than Dr. Dixon utilises.

Notwithstanding the above it is still our contention that even these figures will not be reached due to the previous reasons quoted.

2.    FUNDING


On the acceptance of the DCO the Planning Inspectorate wrote to RSP to advise them on the terms of them being accepted for Examination. This letter dated 14th August 2018 made it clear there were several areas that needed immediate work BEFORE examination. The Funding Statement (document 3.2) was clearly singled out as being subject to revision “As reflected in Box 30 of the Checklist, the Inspectorate considers that the Funding Statement poses substantial risk to the examination of the application.” We couldn’t agree more. Further it clearly want more information on the following:

·        In the generality, further evidence that adequate funds will be available to enable the Compulsory Acquisition of land and rights within the relevant time period.

·        Further information in respect of Riveroak Strategic Partner’s (RSP) accounts, shareholders, investors and proof of assets.

·        Further clarification in respect of the term “completion of the DCO” (Funding Statement para 12, 13, 27).

·        Further details of RSP’s Directors, staff, auditors etc.

·        Further details of the funders who have already expressed interest and others that are likely to come forward (Funding Statement, para 23).

·        Further justification as to why Article 9 of the draft DCO is appropriate and provides sufficient security for individuals in consideration of the provisions of the Human Rights Act 1998.

·        Further information on the sources and availability of funding for the Noise Mitigation Plan.

·        Further information on the joint venture agreement (Funding Statement, para 19 etc.).

·        Further details of how the costs set out in the Funding Statement at paragraph 15 have been estimated.

·        Further evidence to support various statements such as:

·        “The investors are willing to underwrite the cost of any blight claims or eventual claims in compensation […]” (Funding Statement, para 10).

·        “Riveroak anticipates that it will raise further equity and debt finance following the making of the DCO in order to develop the authorised development to completion” (Funding Statement, para 11).

·        “[Riveroak] have drawn down £500,000 from their investors” (Funding Statement, para 20).

Point 1 is the compensation to the owners in the event the DCO (and CPO) is granted and is based on a valuation by CBRE of £7.5M for the 720-800 acres. This valuation can only be derisory as based on previous valuations and purchases, notably the purchase in 2005 by KCC “In Spring 2006 Kent County Council acquired the undeveloped area of Manston Business Park, amounting to some 40 acres of developable land, from the Administrator of Planestation plc for £5.35 million” (*5 KCC-Position-Statement-on-Manston-Airport page 7)

Further in 2005 Infratil purchased the airport from the administrators of the defunct Planestation for a figure of £17M 



From KCC report (*5 KCC-Position-Statement-on-Manston-Airport )

From the 1st example and without inflation the developable land should be worth around £100M and from the second at least £25M (with inflation).

The whole structure has been designed to obfuscate the real ownership of RSP and to hide the source of funds and who controls the entity.

RSP is a series of shell companies registered in the UK but controlled by an entity, MIO Investments Limited, which is based in Belize. These UK registered companies include the following entities



It is understandable just why the Planning Inspectorate is concerned about “Further information in respect of Riveroak Strategic Partner’s (RSP) accounts, shareholders, investors and proof of assets.” As the ultimate control is masked within M.I.O. Investments Limited based in Belize.

Further RSP confirm that they do not have the funds to complete the DCO process only that they say “Riveroak anticipates that it will raise further equity and debt finance following the making of the DCO in order to develop the authorised development to completion” (Funding Statement, para 11).

The final point that the PI identify “[Riveroak] have drawn down £500,000 from their investors” (Funding Statement, para 20) is an oddity in itself seeing that this £½ million seems to have been placed in a separate legal entity “Freudmann Tipple International Limited (05429140)”





3. PUBLIC SAFETY ZONE


Our submission notwithstanding that 10000 ATM’s are unachievable RSP should have considered whether Manston Airport needs a PSZ because they state that the potential number of ATM’s is 83220 and they also state they will not cap the number of flights. The logic says that both 83220 and PSZ’s are potentially capable they should be considered together (worst case scenario)

The area of a Public Safety Zone corresponds to the 1 in 100,000 individual risk contour for an airport. These tend to be two triangular shapes extending out for 3-4 kilometers from either end of the runway. Whilst aircraft follow a number of routes surrounding an airport, it is statistically more likely for an airport-related aircraft incident to occur on landing rather than on take-off so the landing PSZ tends to be a longer triangle than the take-off triangle. 





The last Masterplan done for Manston in 2010 (*6 page 22) acknowledged that its PSZ should have been done in 2006. It was not. But by looking at other airports and knowing the pattern of aircraft take off and landings at Manston it is possible to gauge the likely shape of the PSZ that would affect Ramsgate.

The number of variables to be taken into consideration when determining the risk contours are:

           Annual traffic movements

           Maximum Take-off Weight Authorised (MTWA)

           The crash consequence model includes population density

           The number of crashes per million movements done by using crash rates for each aircraft class

           The crash location model for large and light aircraft

(2009-11-KIA-Master-Plan-Final-Infratil)

Aircraft landing at Manston used to line up at 300 metres above the harbour and descended across the most densely populated area of Ramsgate to the runway at the edge of town.



The 1 in 10,000 contour would most likely be a triangle extending a 1-1.5 km beyond the end of the runway. The 1 in 100,000 contour, and thus the PSZ, would extend approximately 3.5-4km from the end of the runway. It would cover a substantial area of Ramsgate right down to the harbour and including part of the town Centre. Three schools, Clarendon House Grammar School, Christ Church Primary School and Ellington Infant School, are within the 1 in 100,000 risk contour.

The 1 in 10,000 risk contour would include a number of residential streets on the Nethercourt Estate, It also includes the, as yet unbuilt, estate to be named Manston Green. This new estate of some 785 dwellings, given planning permission prior to the consultations, isn’t even mentioned in the 10500 pages of the DCO submission and has not even been considered for compensation purposes but lies well within the PSZ for a busy airport. These residents would need to be moved and in the case of Manston Green the developer would need to be compensated for the loss of their development.



Position of Manston Green development.

4. NORTHERN GRASS


Without going into a great deal of detail it is apparent that much of the land north of the B2050 isn’t required by RSP in their pursuit of achieving 17000 ATM’s. To make it clear from section 3 we do not believe this number of ATM’s is achievable either however in the interest of fairness we will assess their needs notwithstanding.

There are other Aviation experts who will deal with the detail however just to be clear we reproduce a map of the area we believe isn’t required to run a cargo hub.



Reproduced from a report dated November 2017 York Aviation *7 SHP-York-Aviation-Summary-Report-Final pg 57

From the same report they believe that a cargo hub could be run perfectly well, notwithstanding the ATM’s aren’t possible, and they believe the surplus land would be used to cross subsidise a loss making cargo hub.

4.19 No other justification is given for the extent of the commercial development shown on the ‘Northern Grassland’ part of the site. In our view, it is certainly not ‘associated development ‘required to support the operational airport, other than in terms of providing a financial cross subsidy from rental income for general commercial buildings.” And further

4.24 We can see no justification for the inclusion of the ‘Northern Grasslands’ within the DCO as associated development as there will be little requirement for the relocation of freight forwarding activity from adjacent to the UK’s main cargo hub at Heathrow to Manston and any requirement could be accommodated south of the B2050. The development on the Northern Grasslands site appears to be speculative commercial development which, based on the precedent at East Midlands Airport – the UK’s principal airport for pure freighter operations – would be expected to be largely for non-aviation related uses.”

*7 SHP-York-Aviation-Summary-Report-Final pg 58

5. NOISE MONITORING


The DCO clearly states that they will be monitoring the noise from aircraft landing and taking off by positioning 2 noise monitors 6.5km from the runway. This, however, isn’t possible at the Ramsgate end of the runway. Ramsgate at its closest is 1.2KM and at the harbour is 4km and even allowing for where the aircraft starts rolling 6.5KM will terminate in the main shipping channel. Whoever wrote that statement obviously has no idea how close a town of 40000 people is from the end of the runway?
6. LANDING AND TAKE-OFF

20 years of commercial aircraft flying dictates the predominant wind is from the South West over the UK which would mean that 70% of cargo flights would overfly Ramsgate on landing and take-off over Herne Bay. Within the Environmental statements RSP seem to imply that this 20 years of practice will be changed to the complete opposite which is rather odd seeing as aircraft land into the wind for stability and also take-off into the wind to facilitate a smoother lift.

70% of all landings are over Ramsgate because of the wind and only 30% of take-offs are over Ramsgate. Clearly this will have to be examined but using conventional wisdom 7000 landings a year will be from the harbour to Manston and 3000 take-offs will be over Ramsgate generating the following noise contours.



Landings from the East Boeing 747



Take off to the East Boeing 747 noise contours at 85, 90, and 95 Db
7. VALUATION

See section 2

8. Justification for NSIP


We would like the Tribunal to ask RSP why they haven’t considered any of the surplus airfields in the middle of the country. For instance both Mildenhall and Lakenheath are looking for buyers and have far better motorway connections without a town of 40000 inhabitants at the end of the runway.

Nowhere in the document “TR020002-002382-2.3 - NSIP Justification” does it mention whether other surplus airfields have been assessed.

In the document “TR020002-002386-3.1 - Statement of Reasons” there is the following

“4.10 A cargo-focused airport at Manston Airport would meet that need as it has several advantages:

4.10.1 A long runway that can accommodate all types of aircraft;

4.10.2 Close to London but outside congested London airspace;

4.10.3 A focus on freight rather than passenger flights and significant airport capacity will provide a reliable and thus attractive service to freight companies; and

4.10.4 Dual carriageway or better access to the M25, London and the Channel.”

Nowhere however have RSP considered that Mildenhall or Lakenheath, both surplus and operational, could meet the needs of their cargo hub without the need for a DCO and CPO powers. Both airfields are more central, would meet the needs of a hub and are closer to the market. Being as they are both close to the A14 (access to the midlands and the seaport of Felixstowe) and M11 (access to the M25)

There, of course, maybe other surplus airfields as both the USAF and RAF continually review their requirements.

9. Environment


Within their documentation RSP state that there would be adverse effects on the Ramsgate population but they think that their uncosted (as in derisory payments without sufficient monies to pay for it) is sufficient to justify the 7000 landings and 3000 take-offs a year (notwithstanding our belief this is unachievable). In the last 20 years of Manston’s life they failed to achieve 10000 ATM’s so there is no one alive today living in Ramsgate that has lived through the number of ATM’s RSP propose and further this excessive disruption cannot be justified as RSP have yet to prove that a Cargo Hub is viable.

CONCLUSION


Finally it must be proven to the satisfaction of the Examiner that various criteria have been met. It is in our contention this is a resounding NO. The Planning Act 2008 makes things clear and it is also apparent that PINS isn’t convinced.

“Further justification as to why Article 9 of the draft DCO is appropriate and provides sufficient security for individuals in consideration of the provisions of the Human Rights Act 1998.”

Further consideration should be examined carefully:-

Guidance Related to Procedures for Compulsory Acquisition (DCLG February 2010) (issued under section 124 Planning Act 2008) sets out general considerations which are to be applied when considering whether compulsory acquisition is justified. The following guidance is given (at paragraph 24):

“The first criterion is that the land is required for the development to which the development consent relates. For this to be met, the promoter should be able to demonstrate to the satisfaction of the decision-maker that the land in question is needed for the development for which consent is sought. The decision-maker should be satisfied, in this regard, that the land to be acquired is no more than is reasonably required for the purposes of the development(our emphasis)

Further

“In practice it is necessary, when considering confirmation of any CPO, to address the question of whether there is a compelling case in the public interest (our emphasis), in order to address the policy in the Circular and in order to address considerations arising when Article 1 Protocol 1 and Article 8 (European Convention on Human Rights (“ECHR”)) rights are engaged. As a result the addition of a statutory test is unlikely to change the way in which confirmation of CPO’s (or in the case of DCO, inclusion of powers of compulsory acquisition) is likely to be approached.”

And

“The overarching public interest test is whether there is a compelling case in the public interest (our emphasis). As the Circular advises (17), an authority should be sure that the purposes for which it is making the CPO sufficiently justify interfering with the human rights of those with an interest in the land affected.” (Our emphasis)

And

Before proceeding to any CPO the Examining Authority should seek further information on their plans for the site from the new owners. The Examining Authority must be in a position to assess the degree of interference with the landowner’s human rights, and also, if appropriate, to consider the benefits of their alternative proposals for the site to strike the public interest balance. (Our emphasis)

In seeking to justify any CPO the Examining Authority would have to show that the benefits of what it proposed would be so extensive that (notwithstanding the merits of the new owners’ proposals) the public interest v human rights balance would still be in favour of the CPO. (f)

It should be remembered that a CPO is a last resort, Counsel would not advise against attempting to negotiate. Indeed, in order to strike the balancing exercise properly (and safely) it is in the Examining Authorities interest to understand the new owner’s position, and their intentions for the land. *Guy Williams, Landmark Chambers

What is clear is that nowhere in the DCO application is a comparison made with the existing owners plans either financially or which would benefit the wider (Thanet) community better. It should be part and parcel of the examining authority to look at both schemes and to assess whether there is a compelling case in the public interest. As the Circular advises (17), an authority should be sure that the purposes for which it is making the CPO sufficiently justify interfering with the human rights of those with an interest in the land affected.

References


*1 Altitude Aviation Report Web reference for original report. Attached as appendix 1


*2 (DfT “Moving Britain Ahead”) Web reference for original report. Attached as appendix 2


*3 York Aviation “Key Findings of York Aviation Report” Web reference for original report. Attached as appendix 3

http://www.stonehillpark.co.uk/images/uploads/documents/SHP-York-Aviation-Summary-Report-Final.pdf

*4 RSP Transport Assessment. Available on PINS


*5 KCC-Position-Statement-on-Manston-Airport. Attached as appendix 4

*6 2009-11-KIA-Master-Plan-Final-Infratil. Attached as appendix 5

*7 SHP-York-Aviation-Summary-Report-Final. Attached as appendix 6