Examination of Witnesses (Questions 380
- 398)
TUESDAY 20 MARCH 2007
MR ANTHONY
HOBLEY AND
MR MITCHELL
FEIERSTEIN
Q380 Chairman: Those of us who have
a concern about the level of carbon concentration in the atmosphere
would like to see as much offsetting take place as possible, as
long as it is genuine, meeting some of the concerns that you expressed.
I am interested in whether there is almost an analogy with what
is happening on stock exchanges. London has a very successful
A market. It is causing some angst in New York, that we are getting
a lot of business here, but of course it is good for people trying
to raise capital. If we want to encourage offsetting, we want
a regulatory regime which is sufficient to boost the confidence
of the purchaser but not so bureaucratic that it inhibits the
provider of schemes. One of the criticisms I have heard of the
CDM process is that it is rather bureaucratic and expensive, and
a lot of small schemes will struggle to qualify under the CDM
so they might be a natural for a thriving voluntary market. Obviously
we need things like a verifiable registry—that seems to
me a sine qua non—but there is a careful balance
to be struck within a level of regulation which does not inhibit
the market, is there not?
Mr Feierstein: Absolutely. I make
the strong case that if you look at HFC-23, which is 58% of all
registered credits right now, it is not the least-cost option
and it is a valid CDM programme, but you are paying pence on the
pound to destroy one of the world's most potent greenhouse gases,
11,700 tonnes to one tonne of CO2. And those are CERs. Someone
is paying pence on the pound and they are selling them for up
to €30 last May. That is not driving new technologies and
most of those are generated in China. A VER programme where you
are investing money until it could become a CER project—those
where you are investing in new technology, like a wind farm, a
renewable energy project—are going to be more robust than
HFC-23, for one specific example, which would be not included
under the current scheme.
Mr Hobley: I think that is right.
In my day job as General Counsel to the Carbon Funds at Climate
Change Capital, we did two of the biggest HFC-23 deals last year:
a 20 million tonne deal and a 30 million tonne deal. The cost
per tonne to generate CER from an HFC-23 project is well under
one euro a tonne. In the Defra paper I think there is a bit of
a misleading statement, where they talk about the fact that CERs
and EUAs regulatory units cost more than VERs. The correct analysis
is how much it costs to reduce a tonne rather than how much they
are trading at. Of course, a CER is going to trade at a higher
value than a VER because there is a regulatory mandated need for
it: compliant buyers have to have it or they face heavy penalties.
So that is all a bit misleading in the paper. Quite a lot of VER
projects may cost more per tonne than it will for many CDM projects
and you get a lot of associated benefits over and above those
you get from an agency HFC-23 project—although I will correct
one issue. We have not done any HFC-23 projects outside of China.
In China, 65% of the revenues are going into a renewable energy
fund and a fund for poverty in Northern China, so Chinese HFC-23
projects have an awful lot of added benefit because the Chinese
government have mandated that they do. That is not necessarily
the case in places like India. In terms of pricing, the correct
analysis is: How much do you spend per tonne? rather than how
much you can sell the credits for.
Q381 Mr Caton: You do get the impression,
looking at Defra's proposals, that CER is good, VER is bad. Which
aspect is worse: the fact that they are putting down VERs or the
fact that they are giving too much faith to CERs and EUAs?
Mr Feierstein: The problem with
the basic tenet they have is a miscommunication in the document.
The document says it is the definitive standard for voluntary
carbon offsetting but their definitions of VERs and CERs are not
100% correct. They lead you to believe that a VER is something
that cannot be certified. I think there is a lot of confusion
in their definitions. All certification means is that a credit
has been certified under a protocol. A VER can be certified. The
typical definition in the market of a VER is not a voluntary emission
reduction; it is a verified emission reduction. In all the documentation
I have from every verifier, the DOEs, they refer to VERs as "verified
emission reductions" not "voluntary". You can have
a voluntary credit that is verified and certified, which is what
we purchase and put in the Bank of New York registry, or you can
have a CER that is verified and certified under the CDM mechanism.
There is a big misunderstanding in the drafting that needs to
be addressed.
Mr Hobley: I think that is right.
The fund that I work for and the funds of other members of LCCS
are predominantly at this stage focused on the regulatory market,
but we can spend a significant proportion of the money we have
under management in the VER market and we are looking at VER projects.
The amount of work you have to do as an investor to ensure they
are verified and so on can be more because you, as a buyer of
VERs, want to be very sure of their integrity. We are looking
at some small projects in Africa, for example, which, because
of the CDM infrastructure not necessarily being in place yet and
ownership rights around VERs and CERs being more confusing, it
is better for us to do as VER projects than as CDM projects. It
is just a cost issue, because the bureaucracy to go for the whole
CDM process can be daunting. It is also that some of the rules
in the CDM process at the moment favour bigger projects. With
some of the smaller projects—the common one is the heating
stoves or the solar stoves, projects like that in small villages—to
make it financially viable you have to aggregate lots of small
households and villages and so forth, which is very difficult
to do under the rules of CDM but you have more flexibility in
the VER market to do that. It is still absolutely critical, as
an investor in those projects, to ensure that they are verified
and there are real reductions; otherwise you are throwing your
investor's money away. Talking as an investor, it would be good
to see a bit more harmony in international standards. Again, I
come back to the point that the UK Government has an amazing opportunity
here to set the benchmark, to catalyse those standards going to
the next level so that you have global confidence in them.
Q382 Mr Caton: You have already mentioned
the problem with phase 1 of the EU ETS. We have been told that,
on the back of the Government's proposed code, retailers are already
offering EUAs on the market, which really is equivalent to "hot
air". Do you think there is going to be a backlash against
Defra's code, when people realise they might be buying something
that has a market value but it is not reducing emissions at all?
Mr Feierstein: You have hit the
nail on the head there. I think that could be a big problem. If
that comes out to be the case, I think it could be extremely damaging.
This is, in essence, an emerging market. When you have an emerging
market, it is extremely fragile and anything could set it back
quite a way; for example, if you have credits in there that are
not 100% robust. I can also refer again to this advertisement
for Pure. They talk, in terms of the projects that they have,
about a bunch of them, and I know they did have some Chicago Climate
Exchange credits. Chicago Climate Exchange has some credits that
are "business as usual" and that gets into a whole different
round. You have business as usual credits that are not additional;
that is, they would have happened in the normal course of business.
But Pure may have CERs but they also have credits that they have
purchased from other programmes and I notice they word it very
carefully on the website by saying that they only buy credits
from "100% legally binding programmes". That is the
exact terminology that they use for CCX, that it is a "legally
binding programme". All that means is that the people who
sign up say, "Okay, I agree to offset [x] amount"
but it does not talk about the quality and it does not quantify
the reductions that go in that programme. A lot of people have
issue with the transparency and methodology behind verification
in that programme, CCX, specifically. If, indeed, they are still
purchasing those credits, it would not be good for that programme,
and it would really speak poorly for the entire 56-page document
because they are endorsing that programme.
Mr Hobley: I have two points on
that. Certainly from questions that were asked at their workshop
yesterday, Defra have woken up to that issue. I think they are
going to address that by timing, in that they are now talking
about the standard not being in place until the end of 2007/beginning
of 2008. They neatly side-step the issue of having phase 1 EUAs
being used in the offset scheme because they recognise now that
that could discredit the proposal and weaken their arguments around
the regulatory units. It may be something you would want to ask
them when they come in later, but if they were to use phase 1EUAs
I think that would be an issue. We are all reasonably confident
that phase 2, the cap and trade scheme, is going to be more robust,
but it is still not completely transparent that the allocations
will be as robust as they need to be and it may still be that
one phase 2 EUA does not really account for the same reductions
as, say, a VER from a properly verified voluntary project.
Q383 Mr Stuart: I am sure it is clear
from what you have said already but do you think that if Defra
did not go ahead and there was not intervention by Government
that the voluntary market would regulate itself? Would the cream
rise to the top and would we have, in a few years' time, a robust
system based on market pressures?
Mr Hobley: I think we will. The
VER market is growing very rapidly. It allows you to deploy capital
in a more flexible way alongside the CDM market. There will probably
be some backlash against the poor quality end of the market—and,
undoubtedly, there is a poor quality end, there is the cowboy
end of the market. That backlash will result in the market coming
together with all of these different standards, realising they
probably should have one standard. Defra have an opportunity to
avoid that dip and that backlash and to catalyse that progression
much more quickly, and that is what they should do. They have
done it already in other climate change policy measures; hence
London and the UK has the greatest concentration of expertise
and the most successful business sector in this market. They have
an opportunity to do that again and therefore influence what happens
in North America and other parts of the world where VERs will
be an incredibly important part of the market.
Q384 Mr Stuart: If you believe the
market will sort itself out anyway then government regulation
is always a large, clumsy thumb and will necessarily lead to some
distortions. If you believe genuinely they will change, why have
it? Why not dissuade them?
Mr Feierstein: Why do I think
it is going to be efficient market theory? Efficient market theory
will govern where it is going to go. New York has seen, because
we have been looking at this for quite a while, a tiering process
go on. Premium and different credits are being traded at discount
and the market is going to recognise that. It is going to be an
efficient market. Right now it is an emerging market. Emerging
markets, by definition, have extremely high volatility. That is
why we saw a 71% drop in the CER prices in one day back in May,
so it is still very, very, very new. In coming up with a government
policy that is robust, I cannot add enough that developing a broad-based
global policy consensus through the creation of a benchmark standard
for VERs as well as CERs is a good thing. The reason for that
being the leadership position: you define it and basically you
are paving the way to move forward. There is an important difference
here out there. With the carbon cowboys, the 87 of them—once
again I will bring up the example—CO2 mitigation is business.
I do not know if you have seen the Lehman Brothers report by John
Llewellyn the economist. There are business opportunities out
there and they make a strong business case for CO2 mitigation.
There is a charity component to this. Sustainable development
is an aspect that we look at in all the credits that we will purchase
but you have to differentiate between CO2 mitigation and charitable
contributions. There are people on the websites and people out
there who try to "guilt" people into buying credits.
They say, "You have to support this tiny little project"
but, unfortunately, if those projects are not verified and certified
you are then into the problem where it could be a fraud and somebody
could be stealing the money and it has never happened. To add
assurances that it has happened, we use DOEs. We send somebody
in. We want a verification report and we want to see the monitoring
report, the baseline studies—we want to see everything to
authenticate it.
Q385 Mr Stuart: The point is about
the Government. You have misgivings about Defra's policy but are
you both saying that you think the UK Government coming in and
setting a standard is the right thing to do but it is just that
this particular intervention is not the right one? You do not
want to leave it to the market; you believe there is a role for
the UK Government and that they can then help market, if you like,
to cohere around standards.
Mr Feierstein: They could, but
they would need to acknowledge that there are some pretty good
standards out there which exist. I think they should have had
a look at those before they came out with yet another one.
Mr Hobley: The offset proposal
is not another standard, in terms of the standards that are out
there of the specific projects that create VERs, whereas the offset
standard is for an offset product for a company that provides.
They are different. I think this is a good thing, provided it
is written well. We say, as LCCS, that it is not Government's
job to write another standard for individual projects or to pick
one standard over another, but they can say—which I think
is good governance—"These are the integrity concerns
we have over the market. If you bring projects to us that meet
these standards ..." They tell industry what they have to
achieve, then industry can come up with the standards and industry
has something to aim for. It is not trying to create a standard
for individual projects in a vacuum; it is being given a goal
or a baseline that has to be achieved. I think that is what governments
do all the time. They say: "This is the minimum integrity
that has to be achieved. You, the private sector, now go away
and do that because that is what you are good at."
Q386 Mr Stuart: In terms of the Government
acting to promote the voluntary sector, is that the single most
important thing it can do? Is there anything else it should be
doing?
Mr Hobley: From our perspective,
that is the single most important thing it can do: to galvanise
and take the voluntary market to the next level. One of LCCS's
objectives is to promote the UK and UK industry in this area,
yet again to give the UK and London as the global centre of the
carbon market another advantage, which it has done by early regulation
to-date.
Mr Feierstein: I think the impact
of a good policy is important. Whether it is the role of the Government
to come in and do that is another question. And how long it will
take to review this properly is a third question that we need
to examine carefully. I think there are a lot of people who have
been involved. We were the first ones to get involved in August
2005 in creating what we felt was a robust and credible programme
to bring to market. If you can get the United States on board,
that is fantastic. If the UK Government can come out with something,
then that is fantastic as well. But another consideration is that
the EU ETS framework was not considered by Australia or the United
States and, considering the scale and magnitude of the problem
in the US that is not being addressed, if something can be in
neutral ground—not saying, "Well, only the EU ETS credits"—it
offers a compromise for people in the US to adapt or adopt, and
the possibility that these can be used in any future regulatory
scheme is their entitlement. So if you set the bar high enough,
they could be incorporated in any new regulatory scheme that is
set up. That is why I think it is a leadership role and you guys
can set a great example by doing it correctly.
Q387 Mr Stuart: I know you are opposed
to any future reductions as being allowable: they should all have
been verified and achieved. Given the capital investment that
is required and given the fact that it is a fledgling market,
could one have rules that allowed a timeframe of three- or four-years
ahead? Does one need to be as absolute as you appear to be in
your paper?
Mr Feierstein: I am not opposed
to it. I do not think it is a prudent investment at the current
time. I think that could be highly speculative. Responsibly speaking,
if I were to be investing in the market I would rather have something
that I could quantify. I am not saying, going forward, that we
cannot come up with some sort of insurance or reinsurance on that
reduction that would pay out should it fall down or be replaced
but that is not going to be the most cost-effective allocation
of resource to creating a scaleable production that is going to
come up with an expeditious, scaleable response to the problem
in a three- to five-year window as we seem to have necessary at
the present time.
Q388 Mr Stuart: Is that the view
of the LCCS?
Mr Hobley: I am sorry, could I
clarify the question?
Q389 Mr Stuart: Take forestation,
for instance, where there is a whole issue about some offsets
taking 100 years before you offset the carbon from your flight,
Mr Feierstein's view, very strongly, is that you should have achieved
the offset before you sell it, thus it is verifiable and bankable.
Does the LCCS see things in the same way?
Mr Hobley: The standard talks
about, if you are the seller of an offset you have to buy it within
six months, and, in terms of consumer confidence and business
confidence in what they are buying, yes, we would support that.
In my day job—and other members of LCCS do this all the
time—we are investing in CDM projects and now voluntary
projects and we are putting in place contracts for a five- or
seven- or ten-year timeframe. There is a bit of a difficulty for
anything post-2012 but I think we are fast approaching a point
where we will have some confidence around paying money and entering
into commitments for post-2012 as well. We say, "We will
buy these from you" and quite often we will provide significant
advance payments for credits that are not going to be produced
until 2008/2009/2010/2011/2012 because we know that there is a
market that goes forward until 2012 and so we are making assumptions
that there will be buyers and there will be demand for what we
are now committing to buy. If you put a voluntary code in place
and you know it is going to be in place for a reasonable period
of time, you then, as a market player, have funds, and banks will
provide liquidity and all the rest of it, to supply this into
the market. You can make legitimate assumptions around what the
demand will be and then take the business decision about whether
you are prepared to enter into a commitment—
Q390 Mr Stuart: Selling it to your
investors now on the basis that you will reap the crop later is
one thing. Selling it today to the consumer who thinks he has
bought an offset today when he has not is another. I wonder, are
you opposed to that?
Mr Hobley: We agree with that.
Providing there is a framework in place so that you as a buyer
can evaluate what the market will be in the future, then that
should not be detrimental to investing in those VER projects.
Mr Feierstein: I agree. Could
I clarify one thing which I may not have made clear in my answer?
I will buy forward credits if we have a project that I own but
I will not sell them forward until they have happened.
Mr Stuart: I am clear on that.
Q391 Mr Chaytor: Turning to the CDM,
do you think the CDM will continue as a highly bureaucratic or
highly regulated mechanism, or is it likely to soften as the years
go by and take on more of the characteristics of the voluntary
market, more flexibility and greater concern for wider sustainable
development issues?
Mr Feierstein: It is an emerging
market and it is the first programme that has gone out and said
that you could now buy and sell carbon. It is a guideline and
there are a lot of really notable things. It is a good thing,
it is healthy, but obviously there are going to be teething pains
in any programme that you set up that, going forward, people are
going to use the methodology more to try to correct.
Q392 Mr Chaytor: But you are optimistic
at the moment.
Mr Feierstein: I am very optimistic
about it but I think there is also such a need out there for some
much more scaleable programme right now. If you can create a voluntary
one, it could be integrated into the existing regulatory frameworks
out there part and parcel. I think if you make a good enough mousetrap
that is robust enough, it could be used everywhere.
Mr Hobley: I am optimistic. Again,
if you are asking me to bet, I think there will be a CDM post-2012
and over time it will get better. It will get better resource.
You will get better people in the senior executive board: international
negotiators and so on; it will become more professionalised; it
will build up a cache of knowledge and methodologies. The VER
market, if it is allowed to co-exist, can be a wonderful laboratory
with lower bureaucratic thresholds that can feed into that learning
process on the CDM. The only way you really learn resource projects
is by doing them. If the threshold for smaller projects in the
CDM is too high, you will not do them, so you will not learn important
lessons. The VER market can be a very important laboratory. It
can help inform and improve the CDM system.
Q393 Mr Chaytor: Do you think that
what we might call the HFC-23 programme is always going to be
a feature of CDM?
Mr Hobley: It is an international
political issue. I think the current feeling in the market is
that you probably will not have new HFC or big industrial gas
projects post-2012. My concern, if that happens, is that you do
not leave a vacuum, that you do not suddenly have all these incinerators
turned off because they are quite expensive to run. You will have
lots of HFC-23 in the atmosphere again, so maybe there will be
a big discount, but there will be something that will be done
to reduce the windfall you get from those huge projects and perhaps
create a bit more of a level playing field with the energy efficiency
projects and the CO2 projects.
Mr Feierstein: That speaks again
of price tiering. I think we have to look at the overall picture,
where you have six greenhouse gases and the high 70 percentile
for CO2. The three really big ones are CO2, nitrous oxide and
methane. That comprises up to almost 96% (though the numbers could
be a little bit off), but that is 96% of the problem, so let us
talk about proportionality and figuring out how to mitigate those
going forward, because that is the biggest part of the issue right
now.
Mr Feierstein: There is a lot
of criticism of the big industrial gas projects but I would say
several things in their defence. HFC-23, nitrous oxide, methane
are powerful global-warming gases and if there is not a mechanism
there to encourage and incentivise people to reduce those emissions,
to destroy those emissions, they will be in the atmosphere causing
global warming. If you are going to take them out of CDMs, it
is critical you do not leave a vacuum and they are still regulated
in some way and there is a heavy discount. Also, for many of us
in this market they have created early wins which have impressed
investors, which has allowed us to raise more money and given
us more room to do the harder projects: the energy efficiency
projects, the projects where you do not quite get those easy wins
but where you have to do quite a lot of work to make them happen,
even though do not produce as much CO2. So they have given the
financial community more room to manoeuvre and allowed it to raise
more capital as a result of those early wins. So those industrial
gas projects are not all bad, but in the long term it is probably
unsustainable for you to get that huge windfall on those projects
as against smaller CDM projects.
Q394 Mr Chaytor: As the voluntary
market develops, what do you think the balance will be between
investment in North America and Europe as against investment in
developed countries?
Mr Feierstein: The CO2 mitigation,
as I have said, would make a strong business case. You are going
to invest in technologies wherever you can best implement them.
But it is not really significant if you produce a tonne of carbon
in Central London or if you produce it in Delhi: taking a tonne
out, is taking a tonne out.
Q395 Mr Chaytor: The CDM finance
you to reduce it in Central London.
Mr Feierstein: Exactly but I think
you should be able to. That is why the two markets are separate.
If you can achieve something that is credible or viable, it does
not matter where it will be as long as you can come up with methodology
that you are comfortable with and have it verified and certified.
Q396 Mr Chaytor: Is it easier to
verify in North America and Europe than it is in central Africa?
Mr Feierstein: If you use a company
like SGS, which is a big verifier, they have over 45,000 employees
in over 1,000 offices around the world so they are pretty well
connected everywhere. They have the financial and legal accountability,
in that what they are verifying and what they tell you in the
documentation it is going to be able to get, and I have confidence
and we go with that.
Mr Hobley: It is also that there
are different tiers of developing countries in terms of how easy
it is to operate and verify. It is a lot easier to verify and
feel confident as an investor around projects in China, Brazil,
India than it is in maybe Tanzania, Uganda and so on. That is
where the VER market can have a much greater impact in these early
years, until those countries put in place the infrastructure that
they need to work within CDM. There are different figures from
Point Carbon and New Energy Finance and so on but I think there
is something like—depending on whose figures—€3.5
billion to €6 billion in funds that are being deployed mainly
in CDM, normally in JI but mainly in CDM, and that of course is
all going to development countries. Of the Climate Change Capital
Carbon Fund which is €800 million, we will probably deploy
at least €400 million in China, simply because it is easier
to do CDM projects and business in China, because of the way they
have regulated it, than it is in other countries. A great proportion
of the remainder of that will be in Brazil, India, Malaysia, Indonesia
and so on. We are looking at Africa, but that is more VER projects,
to be honest.
Q397 Chairman: Just for clarification,
because of the emphasis which you put rightly, in my view, on
additionality, a tonne saved in London is not the same as a tonne
saved in Delhi, is it? Because Britain is a signatory to Kyoto
and therefore is obliged legally to make reductions. Those will
happen under business as usual without the purchase of offset.
Mr Hobley: I think you have raised
an important point but additionality will be measured or assessed
differently in those different places because of that. Additionality
may be easier to show in China or Malaysia or Tanzania, where
there is not as much regulation and there is not the same driver
at the government level to achieve reductions, so in many respects
it may be easier. You have a harder job to show additionality
in London because you then have to go through probably quite a
detailed regulatory analysis. But if that is an area of the economy
which the Government have not regulated, they have not spotted
that opportunity to reduce emissions—the Government is not
going to spot and regulate every opportunity; they create a framework
around that in which entrepreneurs can see the other opportunities
they have missed and reduce them—then that should be additional,
but you have to do a very careful regulatory analysis to see whether
that would happen. Then you have to work with the Government to
have that framework in place, because, as you know, each Kyoto
Annex B country has an assigned amount and that is measured in
these assigned amount units. Ideally, you want to tag that introduction
in London with an assigned amount unit so that then there is no
double counting, because, once you have spotted it and you reduce
the emissions on a voluntary basis, the Government may say, "That's
interesting, we should regulate that" and then you get a
double-counting issue. You probably need Government to put the
framework in place to allow you to do that. One of the things
I picked up on yesterday at the Defra workshop is that, apparently,
there is a lot of feedback coming in that as part of this offset
standard people want to see domestic projects, and that people
who offset quite like the fact that they are offsetting locally
rather than globally. That is probably an important issue to think
about.
Mr Hobley: I agree with the comments.
All I will say is that we believe there are things which certain
governments have not picked up on yet, there still are opportunities
for investment in those sectors, and that is where I would look.
It might take a little detail to come up with the project design
document but if you can recognise them then I think you would
be the first one to be involved in them.
Q398 Chairman: You have expressed
some doubt about the market growth assumptions in the Defra consultation
paper. If the code was implemented as it stands or if nothing
happens—the two different assumptions—what do you
think will happen to the voluntary market? Will it grow faster,
slower, disappear?
Mr Feierstein: I have not seen
anything to support an uptake increase of six% of the 30% number.
I was promised to get something on that but I have not received
it yet. I do not know what was used for that. I would like to
see the Regulatory Impact Analysis. I would like to see how price
impacts that study as well, if at some point I would get that
document.
Mr Hobley: I think the voluntary
market will still continue to grow alongside the standard. It
may inhibit the uptake of this standard, so it may be counterproductive
on the standard. If the door is left open to good quality VERs,
this standard may find it has a much bigger uptake and influences
similar standards globally and around the world. It may have a
smaller uptake. The VER market may grow more slowly than it would
if Defra took this opportunity to catalyse the development of
VER to the next stage. I think there is a lot at stake here.
Mr Feierstein: Finally, I would
like to elaborate one more time that getting the United States
on board I think is pretty critical. If you are just going to
say. "We are going to take the easy way out and say just
CERs, which is EU ETS, is going to be accepted" I think Washington
would look at that as saying "We have already turned that
down once, so do you have another idea?" I think it is important
to get broad-based international consensus on it. We have to look
at everything very carefully if we are going to set international
policy consensus.
Mr Hobley: Coming back to that
question of a UK and London perspective, if this opportunity is
not taken up I think it does not help. It will not damage overnight
the leading position that London is securing as the finance centre
for the carbon market, but it will not help either; whereas if
Defra does grab this opportunity yet again to put the UK in a
leading position in the development of the global carbon market,
it will be yet another important development in securing London
and the UK as the lead-in centre for the global carbon market
and help London stay ahead of New York. Competition is undoubtedly
going to come from New York and some of the other financial centres
in Asia, so it would be very helpful for UK plc to have this initiative.
Chairman: Thank you both very much indeed.
That has been a very interesting and useful session. We are grateful
to you for coming.
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