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Committee for Regional Development

Inquiry into the Better Use of Public and Community Sector Funds for the Delivery of Bus Transport in Northern Ireland: DRD Briefing

The Chairperson: I welcome Ciaran Doran, director of transport, finance and governance with the Department.  Ciaran, you are no stranger to the Committee.  I also welcome Stephen McKillop, head of the operational delivery branch, and Sean Johnston.  Sean, I am not sure what your position is.

Mr Sean Johnston (Department for Regional Development): I am from the transport projects division.

The Chairperson: OK.  You are all very welcome, gentlemen.  As usual, please go ahead and give your briefing to the Committee.

Mr Ciaran Doran (Department for Regional Development): Thank you for the opportunity to talk directly to the Committee.  Hopefully, you will have received a full written submission from the Department for Regional Development, so we do not intend to go into the detail of that today.  What we would like to try to do, spread across the three individuals here, is address the five items in the terms of reference for the review.

I will say at the outset that the Department is open to any suggestions from the Committee about how improvements to public transport can be made, but I will also try to set a bit of context from the Department's point of view, in assessing how public and community bus transport requirements are currently met.  It is important at the outset to distinguish the concept of public transport from that of community transport.  Public transport is available to anybody who wants to use it — for example, as provided by Translink — as opposed to accessible transport schemes that we fund through the community transport partnerships or under the Door-2-Door arrangements.  That distinction between community and public transport actually mirrors the Department of the Environment's (DOE) licensing arrangements as they currently exist:  full bus operator licences as opposed to the 10B permit regime that operates for the rural transport partnerships.

The other point I will make in introduction is that the Transport Acts of 1967 and 2011 are certainly key constraints and key drivers for the Department for Regional Development in terms of how it would address public transport.  In the establishment of Transport Northern Ireland, on which I know the Committee received some briefing, we should say at the outset that that is primarily driven by EU rules about the need for contracts to be put in place with the main public transport provider in Northern Ireland, Translink, along with some additional aspects.  That is essentially the context as it stands at the moment.

I will make a couple of points on the second aspect of the terms of reference, which relates to assessing current public and community bus transport options.  From the Department's point of view, they are not necessarily comparable, certainly when you are talking about cost comparisons, because they operate under a different licensing regime and are for different purposes.  To put it in statistical terms, Translink currently provides 68 million journeys on buses each year, including school transport, concessionary travel, and so on.  Community journeys currently make up less than 1% of that total.  If you then take that information and look at the overall cost or how much government subsidy is going into those areas, you can see that community transport or accessible transport is actually substantially more expensive, as you would expect it to be, because those services are targeted at the most vulnerable people, whether they are elderly, people who are living in rural areas, or disabled people.  By their nature, they are likely to be more expensive than a mass transit system.

Having said all of those things, the Department for Regional Development would make the point that we have proactively tried to engage with other Departments in finding practical and — an important point that I emphasise — locally based solutions or improvements to public transport, working with the Departments of Health and of Education.  That is something that Sean will talk about when we come to the pilot.  Stephen will briefly take you through some of the statistics and policy around community transport.

Mr Stephen McKillop (Department for Regional Development): Turning to the third point in the terms of reference about assessing current interrelations in the delivery of public and community bus services, I would emphasise that rural community transport partnerships provide a kind of a safety net and are focused on only certain groups and individuals, and those people are members of those schemes, rather than something that is open to the general public, like Translink.  It is not a substitute for public transport.  Rather, it is complementary to it and, as far as possible, should link in to the existing public transport network.

The 10B licence exemptions mean that services should be used primarily for educational, religious and social purposes.  Obviously, as you know, they are not used for home-to-school transport, which is the Department of Education's responsibility, or for transport services that the Health Department would be responsible for.  They are not intended to be in direct competition with private bus operators.

As Ciaran said, the services are locally based and, in respect of the road transport fund, it is because the key policy objective is to improve rural accessibility.  On a practical level, we have encouraged the rural community transport partnerships to link into Translink routes as far as possible.  A good example of that would be the pilot between Enniskillen bus station and Altnagelvin Hospital that we are trying to promote.  We have encouraged the community transport partnerships to pick people up in rural parts of Fermanagh and transport them to the bus station to link in with the new Translink pilot service.

We also work closely with the Department of Agriculture and Rural Development in developing a dial-a-lift scheme.  We operate an assisted rural transport scheme that they help by providing subsidy — in effect, a concessionary fare scheme for some of the members of the rural transport partnership.

In relation to health and hospital appointments, the rural transport fund is focused on delivering services to its members in the local areas, rather than long trips outside the area to hospitals.  It can facilitate people who want to go to their local GP or for local appointments but, given the current budgetary constraints, it is not practical to undertake work that the health sector is supposed to provide.

Mr Johnston: My team is responsible for the pilot in Dungannon, so I will give you an update on it.  I mentioned this when I was last with the Committee in November.  We have agreement now from all the Departments and the participating organisations to participate in the pilot.  We had the first meeting of the working group on 19 December in Loughry College, Cookstown.  The organisations taking part are ourselves, Translink, the Southern Education and Library Board, various representatives from the health service — somebody will join us from the Southern Health and Social Care Trust at our next session — as well as the community transport partnerships.

In relation to some of the discussion earlier on, we have no expectation that we would take on the policy responsibilities of the Department of Education or the Department of Health.  They will still have their own particular needs and will want to retain that.  I do not know that we would want to have any jurisdiction over that because that is their business, so we have got to be flexible enough to respond to the policy needs as they evolve.

At the first meeting, we agreed some key principles.  Among those, hopefully you will be glad to hear, was that the focus of our work should be on meeting customer need and value for money.  We can have debates about how we assess that, given the rurality of Northern Ireland and the particular terrain we are dealing with, but that was a key element of the working group's focus and will be on an ongoing basis.

We agreed some of the early tasks that we need to carry out.  We are trying to establish what services are out there, because there is confusion.  Who runs what?  Who does what?  What volume of usage is made of the services?  We made a good start in that Translink and the Southern Education and Library Board brought along details of their services.  We do not have the volumes of passengers on those yet, but that is in the next stage.  A key element is to know what is out there, and the gaps and overlaps, if any.  As I said, we agreed the outline of a plan, which our Department is now trying to work up into a project initiation document.  Later this month, we will establish a cross-departmental project board to oversee the work and also to get buy-in from the various organisations for their participation.  You will have sensed, as will the Audit Office, the complexity and the obstacles that exist, so I suspect that we will need ongoing buy-in and support from everybody to make a success of it.  We will also want to engage with local stakeholders, including the councils and others.

Some of the improvements will be easier to resolve and implement than others, so we may have to have a phased delivery.  We hope that some of the obvious changes, if there are any, could be implemented later this year, and then we will begin the evaluation to see what works and what does not in practical terms.  As Ciaran said, every area will be slightly different, but, hopefully, the lessons that we learn from Dungannon and Cookstown can be replicated in other areas across the Province.  We will want to evaluate that and see how it goes. 

One of the other areas that was identified at the group in December was that passenger information was felt to be an area of confusion.  A great deal of work is going on in Translink to improve passenger information, but that is for Translink services; it does not cover the totality of the services.  It would be neat if we could get better information out about what is available to people.  Inevitably, in rural areas, you will have to join up.  You will have to be taken to a transport hub that will take you on to your final destination for long-distance journeys, but it is not always easy for people to find that out.  In the pilot, we want to tackle the question of whether we can improve it, so that is another task.

We have not talked much about the procurement issues, which you raised earlier.  I suspect that, as we get into it, we will want to tease out that area to see whether it is feasible and consider how similar or different the vehicles are.  At this stage, I do not think that we know.  If you were doing procurement, issues such as petrol and diesel would be considered.  Perhaps that can be procured, but we have not tackled that issue so far or started to look at it.

The Chairperson: I am shocked that that is not already taking place between Departments.

Mr Doran: This issue came up in a couple of previous sessions.  There have been discussions between Departments under the remit of the Central Procurement Directorate and about ways in which efficiency can be delivered on procurement, and that covered Translink, as well as school transport and health.  As you might expect, Translink is by far the largest purchaser of fuel in Northern Ireland compared with education or health, but it has a very specific requirement because of the need for buses to be on the road essentially all the time.  It has looked at fuel, and Translink has been in contact with the Department of Education about engineering or bus maintenance.  There are options for improvements to be made, and I am aware that some discussions have been taking place on those issues.  The Central Procurement Directorate of the Department of Finance and Personnel obliges all Departments to look at such things, and that has happened.

The Chairperson: I am shocked that it is not already happening, because —

Mr Doran: That is what I am saying —

The Chairperson: Sorry, Ciaran; let me finish.  It is already happening in local government; some councils pull together to buy their energy, whether that is gas or whatever.  Given the buying power of all the stuff that we are talking about today, it seems shocking that that is not already happening in government.  Is it down to Departments working in silos?

Mr Doran: Silos may be a factor, but, genuinely, from my knowledge, fuel for buses has been considered across the different areas.  I am aware of this because Translink is essentially in the lead on fuel purchases in Northern Ireland because it purchases so much.  Translink has a massive contract for that.  Therefore, the option of school buses, for example, using the Translink contract has been looked at.  However, I think that it was found that, technically, it is difficult to merge the two.  Dale Hanna from the Southern Education and Library Board said that buses in the western area tend to be based at the bus driver's home, whereas Translink's fleet will be refuelled at depots in certain locations, so there is a cost factor.  I am the first to admit that I am not an expert on fuel, but I can give you assurances that that has been considered.  I am not trying to suggest that there are not other areas where further work could be done.

The Chairperson: OK.  Why is the Department planning to introduce transport modelling only now, given the significant investment in roads and transport that it has already made?  The recent Transport Act (Northern Ireland) 2011 specifically provides the Department for Regional Development with powers to:

"secure the provision of public passenger transport services...enter into contractual agreements",

and to regulate services through the award of service permits.  However, "integrated transport" implies that this must be cross-cutting across Departments.  Is the new legislation fit for purpose?

Mr Johnston: When we started on the consultations and on drafting the proposals on the 2011 Transport Act, it was obvious to us, which is why we included the requirement to start doing local transport plans.  I do not think that anyone really understands as yet the scope for more integration of services, but when we issued the consultation document that was one of the areas that we put forward.  We got widespread support for that in the responses to the consultation, and that is why our Department is keen that we move forward on a pilot to see what could be achieved.  That was the catalyst for us trying to press for this to happen.  We are glad that it has happened.  You might ask why it did not happen before.  I do not know; I was not in the Department at that stage.

Mr Doran: I am genuinely not trying to sound negative, but local government in England is very different from the situation in Northern Ireland.  However, it may be difficult to take school or even health transport out of two Departments and put them into, say, Transport NI, without policy on school and health transport following.  That is a much more complex area. 

That is the advantage that local government in England has:  Devon County Council is responsible for school policy, as well as for social services and the equivalent of what the Department for Regional Development does here, even with roads to some extent.  The difficulty is in transplanting that here.  Merging all the transport budgets would have to be an Executive decision, because you are talking about substantial transfers of budgets from the Department of Education and the Department of Health into the regional development budget.

As officials, all we can say is that the Transport Act (Northern Ireland) 2011 works within those budgetary and legal constraints.  That does not mean that we would not be open to change; in fact, we are actively trying to find ways of better integration.  It is one thing to say that; it is another to suggest that all transport budgets should be merged into one.   We are not against better working across Departments.  However, we need to be careful about what is feasible in the current —

The Chairperson: It is all about what is best value for the public purse, Ciaran, at the end of the day —

Mr Doran: Absolutely.

The Chairperson: — and for taxpayers and for everybody.  I assume that the Executive will be very interested in that.  At the end of the day, there is one pot of money.  Perhaps we can do things better, as they have done across the water.  I appreciate what you said about local authorities.

I am glad that you are being positive and that you do not want to sound negative.  You heard some of the earlier negativity in people's mentality.  People threw up issues such as TUPE rules and child protection when the vast majority of people travel with members of the public on Translink buses every day.  All those are smokescreens to keep the silo and jobs intact.  At the end of the day, we have to learn to do things better, and it may be that fewer people are needed to do it.  Has the Department done anything to look at the electronic stuff that many councils are using across the water?

Mr Johnston: We, on the passenger information side, are actively looking at how we can use that.  There is stuff on NI Direct that is not terribly useful.  Translink is working to upgrade the passenger information and journey planner.  It is like everything else:  when things are in silos, any repairs or improvements tend to stay in the silos too.  However, the customer does not understand the silos.  We are trying to design information so that it is more accessible and ignores the silos.  I do not know how difficult that will be, but it is one of the things that we would like to try out in Dungannon to see what is possible and what would work.  We assume that nobody will decide to change the rules on policy and budgets any time soon, so we have to work within the constraints and see what improvements can practically be implemented.  Sometimes, there will be constraints.  Stewart referred to licensing.  That can be changed; I do not see that as a block.  It can be worked around for the purposes of the pilot.  We may have to get ministerial agreement to do that.  If we want the Southern Education and Library Board to lift people on its way back with an empty bus, we may have to get it a licence or permission from the DOE to allow it to do that.  We may have to have workarounds, which can lead to legislative change, subject to the Assembly's agreement.  I cannot imagine that it would not agree to amend the rules in those circumstances.

There are all sorts of barriers, some of which may be easy to overcome, although I suspect that we will struggle to find a sensible answer for others.  It will probably take a fair bit of sorting through to get —

The Chairperson: Does the Department have transport planners?

Mr Johnston: We will recruit a temporary transport planner very shortly.  Eventually, we will recruit somebody long term.

Mr Doran: My division is moving into Transport NI.  Up to now, the Department and departmental officials have not been experts in operational transport issues.  We will have to develop better knowledge.  The pilot is seen as one way of trying to do that.  We will have to consider that.

This might seem like a strange point, but, in Northern Ireland, the integration of public transport is, in some respects, very different from England.  However, Northern Ireland has an integrated bus and rail network under Translink, which is a major advantage that does not exist in England.  It is something to bear in mind.

Mr Dickson: You may say that we have an integrated transport system, but the timetable specifically gives a public warning that there is no integration between bus and rail in Northern Ireland.  That is a misnomer, and I am disappointed to hear a departmental official state that we have an integrated service when the company that delivers it specifically says on its publications that we do not.

Mr Johnston: That is true, but it tries to design it so that it is as integrated as possible.  That is a get-out clause; it is not always integrated.

The Chairperson: OK.  I want to bring members in now because time is of the essence.

Mr McNarry: Did officials from the Department sit down with Translink for a pre-agreement negotiation prior to the latest contract being signed?

Mr Doran: There is no formal contract between the Department and Translink at this stage.  The intention is that, from April 2014, a formal contract will be in place, but discussions happen each year with Translink about its financial plans.  In broad terms, the Department discusses with Translink the level of fares and the targets that we expect it to achieve on passenger journeys.

Mr McNarry: Does it have a fairly good idea of what it is contracting to and what your expectations are?

Mr Doran: Yes.  Translink sets its own timetable and network; historically, that is how it has happened.  Under Transport NI, the intention is that, eventually, the Department will be more active in specifying services to be provided.  At the minute, it is more along the lines that we expect it to achieve certain targets.

Mr McNarry: It seems a very loose arrangement, and that is part of the problem.  Is the facility of sitting down and discussing things open to somebody who wants to compete for the Translink operation in Northern Ireland?

Mr Doran: I refer to the Transport Act 2011.  Sean is more au fait with that than I am, but there was a debate about the type of public transport system to operate in the future, and that legislation, which has gone through the Assembly and obtained Royal Assent, specifies that Translink is to be the lead public transport operator, subject to compliance with EU rules.  That is the policy that we operate.

Mr McNarry: I accept that.  You will accept that somebody like me does not agree with that because it is closed competition, is very wrong and is against all the European rules — not that I have much faith in any European rulebook.  However, because of the legislation and the legislative requirement on Translink to act in a commercial sense, it can exempt itself from scrutiny.  Can it exempt itself from the scrutiny of the Minister?

Mr Doran: I do not believe that Translink is exempt from ministerial or departmental scrutiny.  It is a public corporation and part of the public sector; it is an arm's-length body for the Minister.

Mr McNarry: That is good to hear.  I know that it does not plead the fifth amendment, but when Translink comes to the Committee, it exempts itself from giving answers.  So, why —

Mr Doran: I think that, where it is coming from —

Mr McNarry: May I finish?  I accept what you say.  Why is it that, if it is not exempt from scrutiny by the Minister or his officials, it feels that it can be exempt when it comes before an Assembly Committee such as this one?

Mr Doran: I cannot comment on behalf of Translink, but I understand that Translink —

Mr McNarry: I am trying to figure out what is in the rules of exemption.  It would help us if we knew what it could and could not hide behind.

Mr Doran: There is no exemption for Translink.  However, we need to be conscious of the fact that Translink, under its constitution and under the law, has to operate commercially.  The sensitivity arises when information is requested that it might consider to be commercially in confidence.

Mr McNarry: Is it Translink having to — using your words — operate under the law, or is it the holding company having to operate under the law?  Is there not a gap there?  Do you see them both as one?

Mr Doran: Technically, it is the Northern Ireland Transport Holding Company, which has a number of subsidiary companies, including Ulsterbus, Metro and Northern Ireland Railways.  For shorthand, they have used the brand name of Translink.  Therefore, it is formally the holding company, but the holding company encompasses —

Mr McNarry: So in future should we talk to the holding company and not Translink?

Mr Doran: I think that they are the same thing in terms of the officials —

Mr McNarry: They cannot be the same thing, because they send different people.

Mr Doran: I am not sure what you mean by different people.  There is a group chief executive.

Mr McNarry: Who is that?

Mr Doran: Catherine Mason.

Mr McNarry: Therefore, she is Translink's chief executive, too?

Mr Doran: She is effectively the chief executive for the holding company and the group incorporating all elements of Translink.  That is the position.  I do not know where —

Mr McNarry: I am just convinced — I had better not swear in front of the Committee.

Mr Doran: My division has been the sponsorship division for a few years.  I have been at the Committee before, but we would be more than happy to come down as departmental officials to explain to the Committee the sort of information that we receive from Translink.

Mr McNarry: Would you mind just answering this one question:  are you content with Translink's performance?

The Chairperson: I think that is us now.

Mr Doran: I am a great believer in continuous improvement  [Laughter.]

The Chairperson: Ciaran, that was a very good, polite, legal answer.

Mr McNarry: 'Yes, Minister' is back on TV, is it not?

Mr Doran: Genuinely, in my time in charge of the division, we have set targets for Translink on passenger journeys and accessibility, and, in general terms, Translink has delivered on those targets, even though they have not always been easy to deliver on.  During the middle of a recession, most other transport companies did not increase the number of passenger journeys.  To be fair, you have to assess it that way.

Mr McNarry: You would say that.  If you sit down prior to negotiations and contracts and tell them what they need to sign up to, which is effectively what you told me, then you would look after them.  Enough said.

The Chairperson: OK.  You got the message there.

Mr Ó hOisín: On the issue of room for improvement, you might not be able to comment, and it was a very diplomatic answer, but we can comment on it.  We have spent all morning here.  It is like pulling teeth, and I am just rather frustrated by it.

The Chairperson: I am thinking of taking up dentistry.

Mr Ó hOisín: I think that we are fully qualified.

Mr McNarry: We are going into the transport business.

Mr Ó hOisín: We are talking about integrated transport systems, but, at the end of the day, we are not going to have that under the current system because of the commercial sensitivity that Translink exercises over parts of the system.  Surely, in real terms, unless we address that we will have cherry-picking of the more profitable routes, we will see the demise or running down of less profitable rural routes and see them pass into the community transport sector, which makes up only 1% of that.

One of the big worries that community transport networks have is the proposed new legislation on licensing, which will affect them hugely.  What has the Department done in respect of discussions with the Department of the Environment on the implications that that new legislation will have across the community sector?

Mr Johnston: We have had discussions with the DOE.  The proposals are still under discussion and keep moving, so they are not finalised by a long shot.  From my discussions with the DOE in the context of the pilot, I do not think that the changes will have come in by the time we are introducing the pilot.  It will probably take longer, so we are probably within the rules as they stand.  Perhaps they will have introduced the changes by the time we ever get to roll it out more widely.  These are only regulations; they can be changed.  I have seen nothing to convince me that the proposed regulations will not  be suitable.  However, even if the changes that they are proposing go ahead, as they stand, I do not think that it would stop us making the improvements.  I do not think that it is a big deal.

Mr Doran: We have had discussions with the Department of the Environment.  We are sympathetic to the special category of licence that the community transport partnerships operate.  That is essentially the argument at the minute, because the Department of the Environment had taken the view that there should not be a distinction between a private bus operator, for instance, and community transport.  However, I think that it is reconsidering that view.

The Chairperson: The DOE is coming to the Committee on 27 February.

Mr Doran: It would probably be in a better position to talk about it.  However, if that position holds and we stick with the current licensing regime, which is that the community transport partnerships have a separate licence, certain restrictions in respect of trying to compete with a private bus operator, for example, will be placed on the community transport partnerships.  We are sympathetic to that argument.

Mr Ó hOisín: Moving to another matter, how confident are you that everything will be in place for the pilot schemes when they are rolled out?  Sean, I think that you said that it would be April.

Mr Johnston: We have only kicked it off.  I think that it will take us a little bit of time to design it.  I think that we will be kicking it off later this year, but I do not see DOE having the changes implemented by then.  Therefore, it is probably existing rules.

Mr Ó hOisín: Is everything in place with other stakeholders?

Mr Johnston: As Ciaran said, if we wanted community transport to start competing, the existing arrangements would not quite suit them.  Who knows whether that is the model that we will operate with going forward?

Mr Ó hOisín: Therefore, it is all up in the air again.

Mr Johnston: If it does not work, we change it, surely.

Mr Doran: It is only a minor example, but in Enniskillen we connected a rural transport partnership with a Translink service that was put on to bring a small number of people to Altnagelvin Hospital.

Mr Ó hOisín: I do not know how many.

Mr Doran: I appreciate that that has taken time to settle, but that practical way of improving things at a local level might be productive.  That is our view, and that is why the pilot is based locally in Dungannon.  We want to build on that initiative.

Mr Ó hOisín: To be clear, it is not starting in April.

Mr Johnston: It is not.  We had the first meeting of the working group in the week before Christmas.  We will have several sessions before we are —

Mr Ó hOisín: You talked about April the last time.

Mr Dickson: We have heard much about the audit reports and concerns that the Department of Health and the Department of Education did not take things on board as seriously as they might have.  Is your role not one of banging heads together?  Why have you not been doing that since 1995?

Mr Doran: The Audit Office report, which I read in the past day, was the responsibility of the Department of Education and the Department of Health; that sounds like buck-passing, but that is the fact.  The report was the responsibility of Education and Health.  The recommendation was for Education and Health to get together to talk.  That said, this Department has been actively trying to engage with Education and Health, but it has to do so within its remit.  There is no point in my saying that I am responsible for school transport.

The Chairperson: However, you have a responsibility for the regional transport strategy, Ciaran.  Surely that should be cross-cutting.

Mr Doran: The regional transport strategy, which ran out at the end of 2012, looked at ways of improving; however, it was looking, primarily, at the position in the Department for Regional Development.  For example, it was out of the regional transport strategy that our Department started to focus resources on accessible transport and rural transport.  That was one of the concrete developments.  We have engaged with the Department of Health, and that is where the pilot in Dungannon is seen as a practical way forward.  That is what I have to say about the Audit Office report.  It makes some reference to the Department for Regional Development and the Department of the Environment, but it is pretty minor.

The Chairperson: It is 20 years later, is it not?

Mr Doran: It might be 20 years later, but I think that you asked that question of the relevant Departments earlier.  That is all I can say.

Mr McAleer: One of the objectives of the regional transport strategy is to meet the social objectives of the Programme for Government.  Since you have no transport planners at the minute, how can you achieve social inclusion objectives, particularly for rural areas, when you are deciding whether to reduce or withdraw routes and services?

Mr Doran: To a large extent, Translink has operational responsibility for decisions on routes.  However, for some years we have insisted that Translink consult locally where it is making significant changes to services, whether with stakeholders or local politicians, and we believe that that is happening.

In relation to other aspects of social need, our system using grant funding for rural transport partnerships throughout Northern Ireland, plus the door-to-door services in urban areas, which is under contract, gives a pretty good spread.  I think that the rural transport partnerships, in particular, where members join those organisations to receive services, are in a very good position to assess where the real need is.  There are many advantages in that arrangement.

The Chairperson: Ciaran, Sean, Stephen, thank you.  If I was marking the three Departments, I might say that our own Department won today, but I will not go down that route.

Mr Doran: Tell my boss that.  [Laughter.]

The Chairperson: We will be meeting him in the next 25 minutes or so.

Mr Doran: Fair enough.  Chair, we made an offer.  If you had a half-hour slot, Stephen and I, and some of the other people from our division, would be more than happy to talk about what the sponsor division in the Department does.  It might be helpful.

The Chairperson: OK.  I appreciate that.  Thank you very much.