Examination of Witnesses (Questions 60-79)
EQUAL OPPORTUNITIES
COMMISSION (EOC)
25 APRIL 2007
Q60 Roger Berry: Good morning. What
is your reaction to the Government's action plan?
Ms Ariss: We welcomed the action
plan because it did take forward many of the recommendations in
the report and we are pleased to see that in the follow-up report
that came out last month reporting on what has happened since
the original recommendations were published last year there is
some good progress that has been made. Childcare is an example
of an area where the Government for a number of years, not just
in response to the Women and Work Commission, has been making
real and sustained progress and we were very pleased to see things
like the Women's Enterprise Task Force proposal. It is early days
but we have seen some very good stuff there. We are warm towards
what has happened but we do think more is needed. We have already
said we were disappointed that the level of investment that the
Women and Work Commission called for in supporting change has
not come through in all areas, and although there has been a flurry
of activity since the report's recommendations were made just
over a year ago, we were not convinced that what is going on is
sufficiently strategic. If you go back and look at the Women and
Work Commission recommendations, although there were some things
that we would have liked to see that were not there, taken together,
it is a really strong package and it hangs together as a package.
We are not quite persuaded yet that the Government's approach
to taking it forward has been as strategic as the Women and Work
Commission was itself and we would like to see some clearer and
more high-profile leadership. It is very difficult to get all
of the actors concerned working together. It is about joining
up what a number of government departments are doing, and indeed
what different bits of the same department doing, joining that
up with what employers are doing, with what trade unions are doing
and indeed with what organisations such as our own are doing.
That does not happen. Joining up government is tricky, is it not?
It is easy to say and hard to do, but it does not happen without
some really strong, determined leadership and without there being
some resources put into that strategic co-ordination. I think
we would say some good things have happened but a lot more could
be done with a clearer, stronger and better resourced leadership.
Q61 Roger Berry: How do you respond
to the observation that, in addition to what you have said, one
thing about the action plan is that finding timescales is impossible.
If this were a gender equality action plan or for that matter
a disability equality action plan or a race equality action plan
produced by a public authority, would you not be expecting timescales,
rather than just ticking "Yes, we accept" or perhaps
"We do not"?
Ms Ariss: Yes, indeed we would.
Q62 Roger Berry: Does that cause
concerns? I do not mean to lead the question. Yes, I do actually.
Ms Ariss: As you rightly say,
in other areas people have had to produce plans that have deadlines
and timescales, and we know that, at the current rate of progress,
the pay gap is not expected to be eliminated until 2085, when
I suspect very few of us will be around to celebrate the event.
We would see it as really important that there are clearer targets
in place about what impact government expects the action it has
in train to have. When do they think there will be faster progress
than there is now? There are a number of frameworks that government
produce to do that. The Public Service Agreement framework is
one and we are talking to the Department for Communities and Local
Government and indeed the Treasury in its overall role in relation
to that to press them on this question and we hope that the fact
that the proposal is to replace the gender PSA with an equalities
PSA will not lead to any dilution. There is always a danger, I
think, that if you have a PSA that is about equality as a whole
it gets reduced down to a "The government will be nice to
everybody" sort of level, which has no real bite to it and
does not lead to and stimulate action by departments. We do want
to see some proper timescales attached to this because progress
at the moment just is not good enough. We cannot wait until 2085.
Q63 Roger Berry: You have talked
about possible priorities and easy wins and the importance of
easy wins to send the message and get things moving. Have you
been suggesting possible timescales for some of these recommendations?
Waiting for others to give the timescale is often a long wait
and I wonder, given the importance of the recommendations from
the Commission, whether you feel the EOC has a view about the
timescales that could be attached to some of those recommendations.
Ms Ariss: We have not gone through
and said, "We want that one done by X and that one done by
Y." We would like them all done immediately really but that
is obviously unrealistic.
Q64 Roger Berry: Yes, but suggesting
"reasonable" timescales might be a way of trying to
encourage others to go down that road.
Ms Ariss: We have done that in
some areas but we have not done it across every single one of
the recommendations. Our view is that within 10 years it should
be really clear that the pay gap is genuinely on course to be
closed in this generation of working women. We would like to see
it closed by then but, given the current scale progress, we think
it unlikely that in ten years' time it will be completely closed.
The action that is needed is going to need to be taken over a
number of years. We are not going to get rid of occupational segregation
overnight, clearly, so although we would like to see a target
of the pay gap being completely closed in ten years, we recognise
that is probably unrealistic but it is important to have a target
of that kind.
Ms Wild: I think this is one again
where the Commission for Equality on Human Rights needs to be
cut on the issue. The final report of the Equalities Review talks
a lot about the need for data and for management associated with
the data. From just the headline figures on the pay gap, it is
very clear that whatever progress is being made is being made
on the full-time pay gap and the part-time pay gap has not shifted
at all over a 30-year period. So you would need two different
periods of measurement for that one.
Q65 Roger Berry: At the One Year
On Conference, Bill Rammell on behalf of the DfES put forward
certain proposals for a variety of pilot schemes which seemed
to be well received. Do you have any information on progress with
those pilots to challenge segregation?
Ms Ariss: Our understanding is
that there has been some progress, particularly around careers
advice, and we were pleased to see that there has been a consultation
recently on standards around information, advice and guidance
in this area and we liked much of what we saw in that, although
we felt that it underplayed the role of work experience. Our own
research highlights work experience as highly significant for
young people in deciding where to go, particularly for young people
who are the least advantaged and who may have few other sources
of advice. We think the new guidelines on information and advice
and guidance are good but could be better. We are concerned about
whether some of the pilots that are under way are sufficiently
well resourced to allow them to be properly rolled out. There
is such a history in equality of good pilot things happening and
it stopping at that, that the pilot funding is time-limited, that
when it stops the organisations that were doing the pilot drop
whatever it was and it never does actually get rolled out. Until
we actually see some of these pilots becoming normal practice
and we get away from this model of equality being always some
add-on pilot that the enthusiasts do, we will not be satisfied
that we have really made the progress we need.
Q66 Miss Kirkbride: I was struck
by your answer to the last question because if pilots are taking
place and they are deemed to be successful but they do not happen
while the pilot funding or pilot exercises have been stopped then
that is a bit worrying, is it not? Why are employers not doing
it anyway? If they could see that they were getting value from
it because they witnessed it in the pilot, what is stopping them
from proceeding when the pilot has come to its official conclusion?
Ms Ariss: Often pilots tend to
have pump priming funding which eases the away and when that disappears,
especially if it disappears in one go rather than more steadily,
the easiest thing to do is to say "We cannot do that any
more" and you get a short-term loss, because sometimes the
benefits are quite long term and you are talking about the sort
of "invest to save" model, that you need to take action
now but the benefits may not accrue until two or three years'
time and it may be very difficult, whether it is an employer or
a public sector organisation, to sustain that initiative to get
those benefits further down the track when the costs of the changes
may be now and indeed when you are trying to struggle with all
kinds of other challenges and changes.
Q67 Miss Kirkbride: It is going to
make it very difficult to move on this if they can have in front
of their very eyes a pilot project that on the face of it is working
but they do not have the wit to realise that it is working over
the longer term.
Ms Wild: I think there maybe needs
to be some bridging between the pilot and what happens next because,
in addition to the money that comes for a pilot, you can tap into
advice and assistance from the Department that is delivering the
pilot, and so you lose two things: you lose the money and lose
that as well. Perhaps it could be tapered off rather than just
stopped dead. We also actually did some research into why it is
not being carried forward. I do not know why it does not get carried
through; we are just speculating at the moment, but it is worrying,
and we have seen it for so many years on equality issues. It happens
through the ESF funding, that you get fantastic initiatives taking
place while that funding is there and then the funding ceases
and things just fade away because there is not a handover. There
is a concept of mainstreaming, which means you pass on the learning
but who are you passing on the learning to and where is it going?
In a sense, projects ought to have built into them what happens
after the project, the next stage. What I am asking for is an
assumption of success in pilots and that you would then build
through that as part of the project itself.
Q68 Miss Kirkbride: Taking from there
the issue that has partly been touched upon already of gender
stereotyping and the kind of occupations that boys or girls go
into, how are we going to break that cycle? What do employers
and what do employees need to do? What is your view on where we
should be going on that?
Ms Ariss: I think we would argue
that the approach needs to go beyond employers and employees because
the schools and the careers advisory structure and the training
structure around the Learning and Skills Councils and Sector Skills
Councils and so on is really fundamental. Our research into occupational
segregation identified very strongly that employers cannot do
this unless the education and training system is acting too, that
although young people, when you ask them, quite a high proportion
expressed interest in pursuing non-traditional careers, particularly
high proportions of girls but pretty high proportions of boys
too, almost nothing happens in school and in careers advice to
take advantage of that interest. The whole system operates now
to just carry on doing what we do now; the default position is
you just leave people to do the traditional things, and the way
in which things like careers advice and guidance and work experience
are organised do not make any active attempt as yet to encourage
people into non-traditional roles. That is starting to change.
I mentioned that the DfES had consulted on some revised guidance
on information and advice in this area which is improved, but
work experience has not been touched and that is really fundamental.
We know that a lot of young people's career choices are strongly
influenced by their work experience but often young people are
left to organise for themselves what kind of work experience placement
they will have and that means they often fall back on family and
family friends and they often therefore go and do very gender-typical
things, and that forms a lot of their views about what to do next.
We have also found that young women in particular do not know
that jobs typically done by women tend to be less well-paid than
the jobs typically done by men. When you say, "If you had
known that, would it have made a difference to the choices you
would have made at 16 or 18?" they say, "Yes, it would
and I'm really not very happy that nobody told me this, that if
I went down this route I would be a lot less well paid than if
I went down that route." We are not arguing of course that
young people are only motivated by money. People might still want
to do something because they really want to do it but we do think
they should know what the likely consequences are for their future
pay and prospects of those choices. So there is a huge amount
that needs to happen in schools, that needs to happen in the careers
infrastructure, with Connections, that needs to happen in the
training area before employers come into the frame, because it
is very easy to say this is all employers' fault and it is not;
many of the causes of occupational segregation are not what employers
are doing but what they are working with, if you like. Having
said that, there are of course things that employers can and should
be doing to encourage people into atypical jobs. We have just
published the results of an investigation we have done looking
at, particularly in this case, British black Caribbean and British
Pakistani and Bangladeshi women and their experience in the labour
market. We found some of the things that we would like to see
employers doing to encourage atypical recruits into their organisations,
not to sit there and wait for people to come and bang on their
doors but to get out there into communities, to communicate with
prospective employees about what kind of organisation they are,
to sell themselves a bit more, to encourage people in, really
actively to give people the confidence that "If you apply
in my organisation, you might not a typical recruit but if you
apply, we will welcome you and treat you fairly." So there
is a lot that employers could do but we do not want to see employers
being seen as the answer to the problem on occupational segregation
because there is so much that needs to be done by others as well.
Q69 Chairman: Can I come in on this?
You were talking about the problem about careers advice and young
women not knowing what the options were and not knowing the implications
for future earnings. This is something that we identified in the
report of our previous Committee. Who would you pin the responsibility
for dealing with that on? Clearly, there is an overall responsibility
with the DfES but you have a number of ranges of different organisations.
How do you think we can operate to make it happen in schools and
in the places that young people are at to get that information
and that advice?
Ms Ariss: The Connections service
has a key role, whatever it turns into. Schools themselves. Clearly,
they do need some help with the information that we would like
them to use because schools may well not be aware themselves of
the difference in pay that exists between typically female and
typically male jobs. So there is a role there for other players,
for people like some of the regional players, like regional development
agencies, in making sure that people in their area have that kind
of information about opportunities and about pay rates. Ultimately
DfES needs to take a lead even if the action is needed at local
level but it is something we would like to see schools being much
more active about. We think they are missing an opportunity, that
young people do want to be more innovative and schools are tending
a bit to assume that young people are more conservative than they
in fact are.
Ms Wild: It is a different discussion
that needs to be had. It is not one about getting a job; it is
one about a career and how your earning capacity is going to pan
out over your lifetime if you go this route as opposed to that
route, and I suspect that that kind of conversation is rather
rare.
Q70 Miss Kirkbride: I was quite shocked
when Baroness Prosser told us that after three years of leaving
university the income of women was already 15 per cent lower than
that of men, which is one of those figures that hit home. You
just mentioned ethnic minority women and the segregation, sadly,
in that respect. What did you think of the Women and Work Commission's
proposal? You have already mentioned something that you might
do but would you add anything else to those ideas?
Ms Ariss: Subsequently to the
Women and Work Commission's report we have done a major piece
of work ourselves in this area which I think builds on what the
Women and Work Commission recommended. We have identified five
areas where currently there are barriers to ethnic minority women
either getting into work or, once they have got into work, getting
on in a way that allows them to use their skills. Those five areas
are participation; there are quite big differences in participation
in work between ethnic groups, and they are often not just the
result of people making a choice but they are actually the result
of barriers. There are gaps around unemployment and pay. Ethnic
minority women are likely to be even less well-paid than women
as a whole. There is an issue around progression and there is
an issue about segregation. Women as a whole tend to be concentrated
into a narrow range of jobs and ethnic minority women are even
more concentrated. Ethnic minority men are very concentrated in
particular ranges of jobs too. So there are five areas where we
think action is needed and we have recommended, three years after
our report which was published last month, that the Commission
on Equality and Human Rights should go back and look at whether
what we recommended has been done and whether it has made the
kind of difference that it should, but a lot of those recommendations
are in the sorts of areas that we have been talking about this
morning, about careers advice and guidance, about improving support
for women with family responsibilities, about workplace practice,
about providing the sort of information that employers need to
plan properly so that those who do not realise that they are missing
out at the moment by employing either no or few ethnic minority
women get the message. At the moment we think a lot of the policy
discussion in this area assumes that the problem here is the women
themselves, that they do not speak English, that they do not to
work, that, even if they want to work, someone else in their community
does not want them to work or that they do not have skills. We
think that idea that the problem is all about the women is really
out of date and that if you look particularly at the younger generation
of women coming through, most if not all born here, speaking English
as their first language, increasingly having very strong educational
qualifications, but finding that what happens to them at work
is that they cannot get the jobs that match their qualifications
and they cannot progress in the way that others can. That is a
huge loss not just to those women and their families but also
to the economy as a whole, and potentially is also an issue around
community cohesion: if those women are finding that, having invested
in education and training, still they get stuck in low-paid, dead-end
jobs, that does not help in terms of building cohesive communities
and having workplaces where people have equals from all sections
of the community.
Q71 Miss Kirkbride: Have you any
figures on that? I do find that genuinely surprising. I would
have expected women who were not born here to be stuck, so to
speak, but I would have thought those that were educated here
would have roughly the same chances as their white contemporaries.
Ms Ariss: That is what you would
expect, is it not? But we have found that it is not the case,
that there are higher unemployment rates, that compared to white
women, ethnic minority women with degree level qualifications
are more likely to be working in jobs that are below their qualification
level and that they have a higher pay gap. We have just published
a report that contains all of the evidence that we have been able
to gather. Some of it is quite groundbreaking evidence. This is
not a very well researched area, which is one of the reasons we
want to take a look, because we had a hunch that there was something
going on here, that there was a lost opportunity, which was what
caused us to launch the investigation and we would be very happy
to supply you with a copy of the report if you would find that
of interest.
Q72 Miss Kirkbride: What would you
hope employers and trade unions would now be doing as a result
of the Women and Work Commission's recommendations?
Ms Ariss: Lots! One of the big
things we would like employers to be doing, which some are but
nothing like enough, is we would like them all to be looking regularly
at whether there is a pay gap in their organisation and, if so,
what causes it. Is it to do with discrimination in the pay systems?
Is it to do with women and men in the organisation doing different
sorts of jobs? Is it to do with a lack of flexible working or
a lack of part-time opportunities further up in the organisation?
What is going on? Then taking action to tackle whatever the cause
is within their own particular workforce. If we were going to
pick one thing that we really want employers to do, it is that.
At the moment they are not required to do that in the private
sector. Effectively, public sector employers pretty much now are,
but we would like them all to be doing it, whether they are obliged
to or not, because we think that regular looking at "What
is going on in my organisation?" and "What can
we do to make a difference?" is one of the biggest
drivers of change for employers.
Ms Wild: It is easy to overestimate
the role of trade unions here in closing the gender pay gap. Where
unions have a very good relationship with the employer, where
they are recognised, they can achieve a lot but that may not necessarily
be the case and of course, they may not be recognised. There are
different scenarios. Also, looking specifically at equal pay and
pay discrimination, equal pay is an individual right and although
that right can be delivered through a collective agreement, the
collective agreement will not necessarily deliver it, and that
is why we are seeing the problems we are seeing in local government
at the moment around equal pay. Most trade union officers are
overworked and have far too much to do. Closing the gender pay
gap is quite a complex issue for them to deal with. We would certainly
welcome the creation of statutory equality reps to give some recognition
to the role of trade unions around equality, to put some power
behind that of recognition, but also to give people who move into
those roles the space to do it so that they can become fully conversant
with the issues, that they can become experts that people in the
workplace can tap into, so that they have time to get themselves
trained and to work on these issues. If you have somebody like
that in a workplace or in a sector, that is a resource not just
for the unions but also for the employer. Certainly, closing the
gender pay gap is a challenge for both parties and there are certainly
limits on what any trade union, no matter how good it is, can
do if it is trying to do it and the employer does not want it
to happen.
Q73 Miss Kirkbride: How do you see
quality part-time work progressing?
Ms Ariss: We have already said
that we think it needs to become a much bigger scale and that
the level of investment that the Women and Work Commission recommended
in this area is really what is needed, so we were very disappointed
to see that that is going forward on a much smaller scale. We
are glad it is going forward at all, because all the exhortation
in the world will not help if there are not initiatives going
on with employers to help them work out how to do this. We think
what is happening is just not enough to tackle how absolutely
fundamental this is. Almost half of women who are working work
part-time and the vast majority of them are stuck in low-grade,
poorly paid jobs with poor prospects. So this is not just one
element amongst many; it is an absolutely central element and
much more is needed in this area to persuade employers of the
case for change, to help them make those changes, to make sure
that managers are educated and trained to manage a much more flexible
workforce and that there are some role models of both sexes.
Ms Wild: There is a presentational
issue here. If a woman is in a senior position and she is working
part-time, she is working part-time in a senior position. If a
man in a senior position is working part-time, he has a portfolio
career. There is a big difference in the perception there and
we need to shift that. A woman too has a portfolio career but
it is never portrayed in that way.
Q74 Roger Berry: On the question
of training, you make the point in your submission to the Committee
that mainstream training tends to focus on people who have few
or low skills and that that is often no help for women who take
time out to raise a family. There have been some changes in the
approach to training recently. Do you see this as moving in the
right direction or is it still inappropriate training, from this
point of view?
Ms Wild: It is moving in the right
direction but there still needs to be much more dialogue between
the woman and whoever is providing the training, whether it is
job-based training or whether it is externally based training.
We are in a very fortunate position at the moment with the introduction
of new technology that the possibilities of different ways of
providing training have really opened up. There is a huge potential
is there to deliver, but it needs to fit in with women's other
commitments. It is not women being awkward if they have these
commitments. There needs to be a recognition that they do have
these commitments and they are real, and what actually do they
need? Again, what are their long-term aspirations? Again, that
conversation about if you follow this training route rather than
that training route, what is going to be the long-term implication
for your earnings? If you are training now, what is the implication
for childcare? If you have a higher earning potential at the end
of this training, is that going to open up more childcare possibilities
than you have at the moment? It is a complex conversation, and
to really make training take off and be appropriate and helpful,
not just for women but for the economy as well, those conversations
need to take place.
Q75 Roger Berry: On the key issue,
as many people would see it, of equal pay audits and reviews,
you do seem keener than the Women and Work Commission on compulsory
equal pay reviews. You do though mention alternatives, interesting,
the use of public procurement to spread best practice and so on.
My first question is: do you believe that there are alternatives
to equal pay audits that can do the job, or are you just offering
those as alternatives because you thought the struggle for compulsory
equal pay audits was ongoing?
Ms Ariss: Yes. This is not an
easy one. You are right that we are warmer towards compulsory,
mandatory pay reviews than the Women and Work Commission as a
whole. We like very much the model that is enshrined in the Gender
Equality Duty. When we first saw it we were not sure; it took
us a little while to work out what we thought of it but the reason
we have decided that we think it is potentially very powerful
is that it is challenging public bodies; it is effectively requiring
public bodies if they have the pay gap to look at all of the causes
of it and to tackle them, and if pay discrimination is one of
the causes, an equal pay review would be part of how they tackle
it, but if the primary cause of their pay gap is to do with lack
of access to flexible working and that is holding women back in
terms of getting promoted, we would be expecting to see them concentrate
their actions in that area. We remain of the view that, if you
have a pay discrimination problem in a workforce, an equal pay
review is much the best way to tackle it, and that is what our
statutory code of practice on equal pay says. But there are other
causes of the pay gap, and there are other actions that need to
be taken. Although we still think that pay reviews are tremendously
important in tackling pay discrimination and that pay discrimination
remains pretty widespread, and therefore our broad position on
pay reviews is unchanged, we do think that other things need to
be done to tackle the other causes. To an extent, of course, if
there is a lack of willingness to progress as quickly as we would
like with pay reviews, then we need to look at other routes but
those other routes are important in themselves and there are a
number of reasons why we would like to see public bodies integrating
equality into procurement that go beyond pay.
Q76 Roger Berry: As far as public
bodies are concerned, you are suggesting that where it matters,
the Gender Equality Duty effectively would require an equal pay
review.
Ms Ariss: Yes, it does. Effectively
it does, yes, and that is what our statutory code of practice
on the Gender Equality Duty says to people, that if you have a
pay gap, you are going to have to have a very good reason for
not setting an objective to close it and for not taking action
and that is something we will be looking at very closely.
Q77 Chairman: That helpfully brings
us to the area we need to explore in our last few minutes, which
is that there seem to me to be three different areas that relate
to legislation and structural ways forward: the gender pay duty,
the discrimination law review and the Comprehensive Spending Review
and Public Service Agreements within that for departments, and
there are a number of questions around that. Are you saying that
you would like the Gender Equality Duty extended to the private
sector?
Ms Ariss: Yes, we do think a similar
approach would be appropriate—not necessarily exactly the
same in every last detail because clearly, the Gender Equality
Duty framework was designed with the public sector in mind and
it spreads well beyond pay; it covers every aspect of what public
bodies do. We are not advocating something exactly the same for
the private sector because the way forward needs to be tailored,
but we do think that there should be an onus on organisations
to eliminate discrimination and to tackle it effectively. At the
moment that onus is only there in the public sector.
Q78 Chairman: That seemed to be the
main point in your written evidence that you were putting in to
the section around discrimination law review and yet I think it
was when Sheila spoke earlier you made it broader than that. Was
that your main tenet of what should happen in terms of amending
the law? Can you say any more about what your proposals are in
relation to the discrimination law review? Also, we are a bit
unclear about where it has got to and I understand, Amanda, that
you are on the reference group for it, so could you clarify both
where you think it has got to, why it is not there yet and what
your views are about what should be being done on legislation
which clearly many people have said has come to the end of its
usefulness. Maybe you could expand on that and also how it ties
into the gender duty and whether you are saying that should be
a major part of that review.
Ms Ariss: What I think is happening
with the discrimination law review is that a Green Paper is due
out in May. The reference group is an advisory group rather than
one that has any decision-making power. That is my best information.
It has been delayed a number of times so I am not yet holding
my breath but we are expecting to see a Green Paper in May and
of course, there is a manifesto commitment to introduce a single
Equality Act in the lifetime of this Parliament. So that is what
we think is happening. Because there have already been a couple
of years of discussion around the discrimination law review, we
made a major submission a year ago now and we identified three
priorities in that submission, which remain really important for
us. One of those priorities was to improve the way in which the
law worked to speed up closing of the pay gap, and in that we
recommended that there should be an obligation on employers in
all sectors—the private sector, NGOs, et cetera—to
look at what the pay gap is in their workforce and to take action
to tackle the causes of that pay gap. That is still what we would
like to see happen. We are not very confident that that is what
will happen in the discrimination law review and we have a number
of other proposals that we would like to see taken forward in
terms of improving the way that the Equal Pay Act works as it
currently stands and we can say a little bit more about that if
you would like.
Q79 Chairman: Would you think the
Equal Pay Act should be abolished and subsumed within sex discrimination
legislation, and how does that then tie into a single Equality
Bill?
Ms Wild: That is one of the issues
that we are still working on because it is actually quite complicated,
not so much because of the two statutes but because of the whole
raft of regulations around equal value which attach to the Equal
Pay Act, and it is how you would actually take those into a single
Equality Act. We are talking to lawyers and to independent experts
and to the tribunal system as well at the moment about what the
best way forward is on equal pay. We will have sorted our position
out on that when we respond to the Green Paper but we did not
express a view on that in our original submission.
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