Select Committee on Environmental Audit Minutes of Evidence


Examination of witnesses (Questions 120 - 139)

TUESDAY 31 MARCH 1998

MR JEFF ROOKER, MP AND MR DUDLEY COATES

Chairman

  120.  Going back to the point Mr Dafis made earlier about the CAP regime, we were talking in terms of abolishing it but it exists and it is going to be there for some time. Given that constraint and the severity of that, which you have emphasised, what is the scope for greening agricultural support programmes realistically at the moment? For example, I note that the agri-environment scheme budgets are only three per cent of total UK CAP budget and yet you have a lot of enthusiasm there. 700 farmers attended the launch of arable stewardship, a very encouraging thing, but you only have enough money to fund 150 of them. To what extent can you and will you push forward programmes of this kind?
  (Mr Rooker)  We are certainly pushing them forward but we have to do it within the constraints of our overall budget, in any event. We have to look at the criteria and the balance. We put schemes up, some of which may be not acceptable to everyone. Farmers may turn up but they may not all want to join. I visited a 1500 acre LEAF (Linking Environment and Farming) farm in the Gloucester area about a month ago where I saw what I thought should be quite normal farming practices with planted and seeded strips around the fields. In fact, one area I saw was where I was told, "there are enough bugs in that strip in the summer to nip out of the strip, into the field, eat all the aphids off the crop and go back again", and no pesticides have been used on that crop in that field for four years. They have deliberately done this. This was in an Environmentally Sensitive Area. It was at Guiting Power; there is no secret about it. A third of the visitors are farmers from all over the country. They come and have a look at practices that could be used on their own farms. I suspect they cannot all be paid and subsidised, particularly probably if they are outside the Environmentally Sensitive Areas, but they are good farming practices. Farmers can see them first-hand in these experimental farms, if I can call them that. They can deploy them on their own farm without necessarily looking for CAP handouts because they are good things to do in themselves.

  121.  You must have got some impression from your discussions under the Comprehensive Spending Review etc., of the scope that exists to push these sorts of programmes forward. Is it a very, very limited scope?
  (Mr Rooker)  Yes, it is. It is minimal because the arguments about cross-compliance within the CAP—we are intrinsically opposed to the production subsidies. We want to stop somehow having the production subsidies. It does not make sense for us to build an edifice of——

  122.  Does that mean you are against cross-compliance?
  (Mr Rooker)  In so far as where it does work we will keep it but we are not pushing for it. If we push for further cross-compliance based on existing production subsidies, it will undermine—it is more important for us, as we see it, to get rid of production subsidies and dislocate that link, than it is to build on an edifice, that we wish to see go away, for the sake of a bit more cross-compliance. If there is a scale of priorities, that is where the priority lies.

Chairman:   There is also a potential conflict in MAFF between sponsorship and responsibility to protect the environment. I know Mr Baker wants to come in on this subject.

Mr Baker

  123.  Could I turn to the subject of genetic engineering which I have discussed with you, Minister, across the floor of the House? Given the potential revolution that is occurring in agriculture with genetic engineering, what is your department's strategic view of the place of genetic engineering in agriculture, say, in five years' time? How are you forming that strategic view and how are you coordinating your view with that of other colleagues in government who equally have responsibility for genetic engineering in other senses?
  (Mr Rooker)  It is a very important issue, as you are aware. There is public interest in genetic engineering. In terms of UK science, we certainly lead Europe on this issue. I do not think it is something that we take a view the United Kingdom can opt out of, for a start. It just is not possible for us to put up the shutters and say, "We are not interested in this advance of science". That presupposes all advances in science are bad. I do not subscribe to that view. In terms of driving it forward in the way you put it, I am not sure we are in the driving seat. We have our science and our laboratories. Industry itself is applying that science and it is our job to regulate their outturn, their products, and to make sure that every conceivable check and balance and a very stiff regulatory approval process is in place for these new products that come along. In five years' time, I cannot say—simply on the scale of change in the last five years, for a start, things are moving very fast, as you appreciate, and I do not think I can forecast where we will be in five years' time. What I can say is that, operating as we are at the moment, we are having for example a very thorough examination across Whitehall of the genetically modified herbicide-tolerant crops on which we had a consultation paper out last summer. For the uninitiated, these are crops that are not subject to the use of extra weed killers. What we do not want to do is to have problems caused if those crops come on to the market. We are still considering at the moment our decision. We cannot stop, as a UK government, those crops that have been already approved in the European Union from being planted. What we can do of course is influence industry in its code of practice as to how they will be managed and used. This is a matter not just for MAFF, for the Advisory Committee on Novel Foods; it is a matter for the committee on toxicity; it is a matter for the committee on releases into the environment; it is a matter for the Health and Safety Executive because of the actual buildings where the work takes place. There is a whole series of regulatory authorities involved in looking at what changes are being made and, as you appreciate, the benefits that can be obtained from genetic modification could be very substantial. It is not just a question of making things taste better or last a bit longer. It may be that we can develop crops—maybe grow soya in Europe or maybe enable the Third World, which is drought-stricken, to grow crops that do not require so much water. This is using science for the greater good of humankind.

  124.  Thank you for that answer. I will come back to one point in a second. You were very firm in the House on the question of beef on the bone, for example, when you said that even if the risks may be minuscule you were not prepared to let the public have that risk and you took action at that point. Equally, I have a quote here from Frank Dobson who was concerned about the theoretical risk from UK blood products. I will just read it to you. He said, "We have no evidence to show that the new variant CJD can be transmitted via blood products or blood. The risk remains only hypothetical but we must proceed on the principle that it is better to be safe than sorry." On that basis, with those two examples, are you concerned that the risk to biotechnology is not of that same ilk which should have action taken on the same basis? In other words, do you feel that the risk presented by genetically engineering crops to the environment, and indeed possibly to food, is less of a risk than beef on the bone, in which case it is okay for it to proceed as it is, or is it more of a risk and it is simply that you are not, to use your own words, in the driving seat?
  (Mr Rooker)  That is a very fair question but I do not think the comparisons are fair. To come back to beef on the bone, that was a question of not knowingly allowing infectivity into the food chain, even though it was a very small amount. We are dealing here with perceptions. We still have the problems of our European farmers having imposed the ban on beef and we are not prepared to knowingly allow even the tiniest amount of infectivity into the food chain. Therefore, that is why we took that precautionary view. We would say that is consistent with the precautionary principle, as I believe Frank Dobson's view was. Coming to the issue of genetic modification, this is not an issue where Britain stands alone. Our regulatory approval system for genetic modification in this country has had the seal of approval from the World Health Organisation. It is not something where we have a few scientists in a cupboard, doing a bit of work and then letting all these products loose on a public that is not defended, and where the regulatory process has not been quite hard. The one point that I will concede—and I freely do this because I am responsible for the initiation of it—is that I need to know that our regulatory authorities, independent advisory committees etc., are going to have a mechanism for monitoring for the future the changes in food that come about from genetic modification. Therefore, it is not a question of approving a product, allowing it on to the market and never looking at it again. I want a mechanism whereby the issue can be visited, if you like, on a regular and constant basis. Now, at the present time, both officials and members of the Advisory Food on Novel Foods are actually discussing this, and indeed there was the first meeting of the Advisory Committee on Novel Foods the other week on this where we, as Ministers, have encouraged them to have open meetings, where outsiders were able to listen to the discussion as to how a mechanism can be set up for the monitoring and the surveillance of these foods. It is not easy simply because the checking of whether GMOs are in some foods is not an easy thing to do, although I have to say that when I visited the Central Science Laboratory some weeks ago, the food side of the laboratory, work was already taking place by our own scientists before anything had been commissioned, using their own seedcorn money, on methods of checking all the made-up foods, the supermarket foods, as to how checks could be made as to whether or not there were products in there with genetic modification going down the DNA route, and I was very gratified to see that our own scientists were doing that, using their own seedcorn money, in advance of knowing they would be asked in due course to bid for such work and surveillance, so there is work going on. I have asked, I do not say all the questions because I will never be in the position of having asked all the questions, but I have been asking the questions to make sure that I have got the comfort myself of knowing that we are checking this and that there is a constant system of monitoring. Now, at the moment we are looking at how that can be set up and I will report on that in due course.

  125.  You have said you are committed to the precautionary principle, Minister, as indeed is your Department. I wonder if you have seen this NFU document, the report of the Biotechnology Working Group.
  (Mr Rooker)  No, I have not.

  126.  The NFU, who perhaps could never be presented as the loony left by any stretch of the imagination, list a whole range of concerns about biotechnology in genetically-engineered crops and they say that these lead to a profound or complete misunderstanding of the natural ecosystems, insufficient requirements for monitoring produce sent to market, potential reduction in natural biodiversity, and so it goes on. Others of course, such as Greenpeace, have listed their more stringent concerns, such as their concern, for example, that once you have a GM crop out there, it is uncontrollable in terms of what may or may not happen to it in the same way that once you release rabbits into the environment, you cannot then suddenly get rid of the rabbits, they are there for ever, and there are unwanted effects which may take a long time to show up and so on. There is a whole range of concerns which people have. Surely the precautionary principle means that if we are to apply that properly in the same way that you have for beef on the bone and everything else, if we apply that principle properly, there should be a moratorium on the use of GM crops being planted in this country, and English Nature have requested a three-year moratorium and I wonder if you are happy with that moratorium, and, secondly, there should be a ban on the use of genetically-modified material in food in this country.
  (Mr Rooker)  Well, I honestly do not accept those claims. I am as sceptical, I have to say, as anybody else. I am an engineer by background, but I am sceptical and I genuinely try and put myself in the position, if you like, of a reasonably informed, alert person, naturally suspicious of being fed the line by Ministers, scientists or officials, and that is the way I try to approach my task in some ways as a Minister. I am as satisfied as I can be that the precautionary principle has been applied in this case in the same way as beef on the bone. It is a fair question, but, as I say, it is not a fair comparison. We, by the way, coming to your other specific question, are in no position, as I understand it from legal advice and we have asked about this, actually to insist on a moratorium of the planting of these crops. They have received approval within the Member States of the European Union and, as such, we are in no position. What we can do and what we are actively doing in Whitehall at the moment is making sure that the industry, including the NFU of course, have got a very robust code of practice about the way these crops are handled and dealt with and I can tell you now, and I can tell everyone, that MAFF will not be prepared to put its imprimatur on the industry code of practice on this unless we are satisfied that it is wrapped up, watertight. Now, at the present time I have not seen the draft industry code of practice on this. We have put to the industry a series of questions about the issues that we want that code to deal with and answer to our satisfaction, otherwise, we will not be able, as Ministers, to say, "Yes, MAFF agrees to this industry code of practice". Now, they may not like the tone of the questions and they may not be able to answer them all, in which case we may have to take a more robust line, but it cannot be a line, I am afraid, that insists on a moratorium on the crops. We may be able to request it if we are not satisfied with the code of practice, but we cannot insist on it. Before I conclude on this, because this is not an unimportant point, I would like to say that it has also been decided that every single pesticide that is used on these crops has got to go from the beginning right through the pesticide regulatory process. We are not going to allow pesticides that are used for a particular crop simply to be okayed on a genetically-modified version of that crop. We are going to require thorough regulatory approval, which could take a considerable amount of time, it is not done for delay, but it is done because we are applying the precautionary principle.

Dr Iddon

  127.  Can I refer to the DoE guidance policy document, Policy Appraisal and the Environment, published in 1991 and ask you how widely has that been circulated in MAFF?
  (Mr Rooker)  It has gone down, and I say "gone down", but I should not use terms like that, it has gone around officials and, to the best of my knowledge, it has been widely circulated throughout the Department.

  128.  So most of your staff would be aware that there is great pressure now to deal with environmental appraisals within the Ministry?
  (Mr Rooker)  Yes. It did not include of course notes on submissions to Ministers. We are ourselves putting further instructions to take account of these considerations to require submissions that come up to Ministers to state specifically whether the policy proposals have gone through an impact assessment in respect of the environment. To that extent, we are going to do things which have not been done in the past and I think that, if you like, is a point where we are going to get revised guidance on this in the near future, but we do not have to wait for that and we are taking action within the Department already. We are going to create for our own officials a presumption that a new environmental appraisal will be published and will require justification in submission to Ministers on points regarding the environment, so that there is a separate paragraph and I would hope that it would be up at the front and not put in the back so that it is up there at the front. I did ask earlier on, I have to say, when I had submissions and I went on some visits and talked to some of our scientists out in the countryside and I was concerned that not all of the submissions I was getting had gone through, if you like, some of our own scientists in terms of areas of the Department and I asked whether I could have a CSL, Central Science Laboratory, impact study and I was assured that everything had been gone through and I am amazed by the Whitehall machine now where everybody sees everything, it is amazing, even sometimes when they are not supposed to. The environment thing I think is important and to have that statement in submissions, to give that extra comfort to Ministers to know that this assessment has been done I think is important and, as I say, I would want it up front at the beginning of the submission and not at the end.

  129.  Your estate, as you have already stated, is very widely spread across these 240 locations and across the entire length and breadth of the country.
  (Mr Rooker)  Yes.

  130.  How do you communicate policy with the people at the chalk-face?
  (Mr Rooker)  Well, of the 240, some of them, I will not exaggerate, are very tiny and some of them are an office with a couple of people, maybe plant inspectors, in some location in the country. Others of course are our agencies. I am not sure how they go in ascending order, but certainly in terms of actually looking at an environmental assessment, to make it meaningful we have selected 24 sites which are essentially laboratories and of those 24, 14 of them are the veterinary investigation centres around the country. Weybridge counts as one site. Now, Weybridge has probably got 60 laboratory buildings on it and it is a huge complex for the veterinary laboratory. In terms of communication, the chief executives of the agencies obviously have operational freedom, but I have to say that in MAFF we have got, if you like, how can I put it, I am sure I shall say this wrong and have the people sitting behind me cringe, but we have policy people concerned with that area of policy who seem to have a very hands-on approach, if you know what I mean. In other words, I do not have to have the discussions with the chief executive of the agency, but with the policy lead officer in MAFF it is almost as good as. In other words, you can make things happen in the agency by discussions with the policy lead officers in MAFF, and I have not used the correct title and I regret that, but that applies as much for the Meat Hygiene Service as it does in the other areas, so I do not think there is any difficulty. When I have gone round in my own areas of responsibility to try and get around the MAFF estate, I have not had the slightest doubt that the agency chief executives and the heads of departments I have been with were not fully on board with exactly what had been said by Ministers and which had been decided in head office.

  131.  That brings me to my next point. In your memorandum you make no mention of training with respect to environmental appraisal techniques.
  (Mr Rooker)  I thought we did.

  132.  Could you perhaps elaborate on that and assure us that the whole of the estate is aware of what the Government's intentions are?
  (Mr Rooker)  Far be it for me to contradict you, but I thought we had because I have seen the issue of training because we actually include it in our induction for new staff, the environmental aspects, and if that is not in the memo, it is certainly in my brief here.

Chairman

  133.  We do not think it is in the memorandum, no.
  (Mr Rooker)  In that case, I would be happy to do you a separate paragraph on this, but I can assure you that in terms of induction of new staff and in terms of training on environmental aspects, we do cover that. I am not sure if we do it enough, but it is certainly a part of our induction process for new staff and that I do know.

Dr Iddon

  134.  You mention something about the publication of environmental appraisals. Are you able to say whether this will be a separate document at the moment or will it be included in some other document that you publish, and perhaps you could tell us when we will see the first environmental appraisals published by MAFF?
  (Mr Rooker)  Well, what I have just been discussing, in terms of that, we will only get environmental appraisals, if you like, as part and parcel of submissions to Ministers and of course we would not be publishing submissions to Ministers, so in that respect I do not think that area would be. The environmental appraisals we will do in respect of public policy when we make policy announcements and Bills and all that, we will make sure that those are published documents, and I make no bones about that, and we will presume that these will be published because, as far as we are concerned, the presumption is that there will not be anything secret and if there is something wrong with our environmental appraisal, we need to be addressing it and actually letting people know why we are addressing it. My original point was the fact that in the submissions to Ministers, we would check that this issue, whatever it may be, had been subject to environmental appraisal without us necessarily asking about it.

  135.  Can I be a little specific finally? You are probably not aware, but I am from the farming and market gardening industry and I was born, bred and worked in it in my youth and then became a chemist and when I became a chemist, I was horrified at the number of chemicals and the consequences of handling them which I had been involved in, such as formaldehyde and methyl bromide to sterilise soil, for example, without any precautions taken within greenhouses in a closed environment and all kinds of sprays for greenfly on tomatoes and lettuces and even burning nicotine openly in the greenhouses. I have done all of that without any health warnings given and when I became a chemist, I got rather alarmed, so could you say something about the monitoring of these chemicals, the environmental appraisal and monitoring of the use of chemicals, and I am talking, for example, about sheep dips, which are very controversial at the moment, the wide use of pesticides, to which you have referred already, particularly things like the organophosphates, as distinct from biodegradable pesticides like pyrethrins of which I am very much in favour, and about the over-use of nitrates to which you have already referred, all of which of course affect the biodiversity within the environment? Perhaps you could also say something about the way that your Department is monitoring biodiversity and with regard to Norman Baker's point on genetically-modified organisms and crops, we believe that these might affect biodiversity in that insects that feed on crops at the moment will not be able to feed on genetically-modified crops. Who knows? We do not know and not enough research has been done, but perhaps you could just open up and say how you are appraising all of these things in the environment.
  (Mr Rooker)  I think you touch on some really important points. Going back to what I said about the CAP, the one thing I have found which has been good as a consequence of a CAP policy, which has been phased out now of course, was set-aside where there was an incredible re-emergence of some bugs and wildlife on set-aside land. It is a very important aspect and it is a positive aspect that we need to keep, if you like, and nurture. So far as your specific point about sheep dips is concerned, there are two aspects in a way: the use; and then the disposal. Now, there is a lot of concern regarding organophosphates (OPs) and I freely admit that and indeed I suppose in some ways we shared it as a group of Ministers when we entered MAFF. All four of us were asking questions about OPs and we were saying that we should see the manufacturers of these and have a chat about it and the use of it, but we were told that it was nothing to do with us, that they are regulated, they are lawful products, they have gone through the legal process and we have no right to do this, so there is a legal constraint in some ways. This is very early days and we have moved on a bit since then, but I am just putting to you the kind of approach that we took. Since then of course there are at least three separate—I am not supposed to use the word "review"—but review discussions, I suppose is the term, on OPs, two being done outside government and one inside by officials which is due to report to Ministers quite soon which is a review of the current system really, security and everything else. In terms of the alternatives, I know that synthetic pyrethroids offer this great alternative, but it turns out of course that they are 100 times more toxic to the bugs in the watercourses than organophosphates, so we have got a real problem here. If they are not disposed of properly, we have real problems, and if the OPs are not used properly, we have got damage of course to the individual. If we look at the other alternatives, the injectables, we have got the problem of people wrongly, by mistake, injecting themselves, so we have got the problem of operator-safety. There are some real dilemmas and at the same time of course we have to get the bugs off the sheep. We have just reissued our guidance booklet for the use of sheep dips as the dipping season starts—I am told it never ends—to encourage sheep dippers to use and follow the instructions. Now, I know that there is some anecdotal evidence, but the instructions are virtually impossible to follow, particularly in high summer when you have got to dress yourself up in a rubber suit, with goggles, a mask, the lot; people do not do it. There is the disposal then of the containers, the disposal of the dip itself. I cannot even tell you that we know where all the dips are; we do not. It is amazing, but we do not know where the dips are. We are taking steps of course along with DETR actually to do some work on this so that we know where the dips are. Obviously our vets who visit farms and other people who visit farms are aware of dips, but there is no central register of where dips are, and some farmers these days use portable dips as well, but we have got a model, we have sketches and leaflets for the design of dips so that they can be used in the most safe way for the operators and for the disposal of both the products and the containers. We will be meeting the manufacturers quite shortly and one of the issues we will be putting to them is the design of the containers and canisters, but we do have some serious issues to face up to and we have to make the system as safe as possible. However, as I say, the alternative product which looks okay, which was regulated, which went through the Veterinary Products Committee, the synthetic pyrethroid if misused is more damaging to the environment than OPs, so we have to face this as well. So far as the point you make about pesticides is concerned, I have visited and sat in on meetings of both the Veterinary Products Committee and the Advisory Committee on Pesticides as well—not by way of intimidation, that would be wrong but basically these are independent experts who come from a variety of backgrounds, and they are not Ministry scientists in that we do not pay them, though they get their expenses, but they do not get paid—but by way of saying thank you to them and also to explain MAFF's new policy of openness, to explain why we are asking them to publish more information about their work as a committee, to publish their agenda, their minutes, to explain why we are placing lay persons on each of these committees. We are virtually within days of being able to say that every single independent scientific committee that advises MAFF, which must run into double figures, nine or ten, will have independent lay persons on them and the latest one will probably be the Veterinary Products Committee on which we will also have someone there who is a specialist in occupational health or hygiene and so there is a new post on that committee. I have gone to the committees and have gone there also, as far as I am able as a lay person, to look at their regulatory process which can take a long time before these products are allowed on the market. I will also add, and I speak from memory now, that something like 200 pesticides have been taken off the market since last May, not because I struck them off, and I think about half a dozen have been brought to my attention, but as part and parcel of our normal process of products that have reached the end of their life, products which are no longer on the market for the producer, so the licence has been withdrawn, or products that our officials and, if you like, the police people of the system have said, "No, that should not any longer be used". It is never perfect, but I assure you that it is something, it is a part of my responsibility as a departmental Minister, which I take damn seriously and I am convinced also that our officials do as well and also the independent scientists on the committees take very seriously and the practices that you were doing as an amateur gardener really are very dangerous, and look at what happened to you.

Chairman

  136.  You did emphasise this question of openness in your remarks, Minister, and you did say that you will be publishing your environment appraisals. Could you let this Committee have an example of an environmental appraisal?
  (Mr Rooker)  I will do it as quickly as I can.

Mr Baker

  137.  Can I just follow up on the point Brian was making, and I think it was a very important point about pesticides and going back to the precautionary principle? It seems to me that if there is a significant doubt about the safety of anything, and I am thinking of lindane, for example, surely the benefit of the doubt must go to those who use it in the environment and that product should be withdrawn. Now, lindane has been withdrawn in other countries and I know you have had reviews or reassessments, but if there is significant doubt, at what point does your Ministry say, "Well, the doubt is such that really we have got to give the benefit of the doubt to the people that use it and withdraw it" rather than having to accumulate overwhelming proof that it is unsafe before it is withdrawn?
  (Mr Rooker)  I certainly do not take the view that we have to wait until there is massive evidence before something is withdrawn. To be honest, I will do you a note on that because I require notice of that particular product. There are products, particularly for the amateur gardener, where there has been a review of some products going back on the market, but I was not satisfied that the amateur gardener would be prepared to take all the necessary precautions that would be required to use the product safely, ie, the goggles, the mask, the gloves, and so I said no, I would not allow them back on the market. Now, that would be different for what I call the professionals. I have to expect that farmers and farm workers are professionals and they are trained to follow instructions, but I also accept the impracticalities sometimes of that and that is why I raised the issue about OPs and the sheep dips, so in terms of the precautionary principle, it will weigh heavier, or if you like, to a different degree, looking at the amateur gardener than it does the professional, and products would be allowed of course on a farm with someone who has got a certificate to use the product, but the amateur gardener would not need the certificate and I would be asked to expect people to use their common sense, but people do not do that in their own back garden and that is why I have said that the precautionary principle on this one is such that the answer is no, the product should not go back on the market. I will do you a separate note on lindane.

  138.  I think that is also in domestic products.
  (Mr Rooker)  I will do you a separate note on that.

Mr Dafis

  139.  I have something on the procurement policy and I was very interested to see in the paper that you have prepared for us that "the Government's current policy of not using procurement to achieve policy ends other than value for money limits the extent to which the Department may have recourse to contract compliance on environmental considerations". I was not aware, and I do not think perhaps the Committee was aware, that the Government had a policy of that kind, and perhaps it is not surprising, but it is certainly significant. Then I note in your second paragraph that there is a note currently being prepared by the Treasury and DETR on environmental issues in purchasing. You say that "The further incorporation of environmental consideration in the Department's costing strategies will be reviewed in the light of this guidance". Now, I was wondering whether you could tell us the extent to which the existing policy does constitute a constraint and does oblige you to procure in a way other than what you would like and what you are looking for in this reconsideration of procurement policy because I suppose that green principles oblige us to take into consideration far wider issues than value for money in the conventional sense when we are making purchasing decisions.
  (Mr Rooker)  Yes, I too was surprised to find that policy, one which has been around for quite a while. We have inherited that policy and, like in many other areas, you would expect us to be having a look at it. At the moment we are constrained. You have got to balance the criteria of course. It would not be green at any cost and there has to be a balance, but you also referred to the note by the Treasury and DETR on environment issues in purchasing and in preparation. Yesterday I actually asked where is it and how long has it been in preparation. You will be astonished to know that the answer I received was five years. You may wish to pursue that. I will.


 
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