2 The Creation of New Local Enterprise
Partnerships
The record of the RDAs
13. The new Local Enterprise Partnerships will replace
the existing Regional Development Agencies. The RDAs came into
existence in 1999, bringing together a number of structures and
funding streams which had focused on regeneration, including English
Partnerships, the Rural Development Commission, regional inward
investment organisations, regional supply chain offices, single
regeneration budget teams and innovation and enterprise teams
(in Government Offices). The original statutory remits of the
RDAs were (for each of their respective areas):
(a) to further economic development and regeneration;
(b) to promote business efficiency, investment
and competitiveness;
(c) to promote employment;
(d) to enhance the development and application
of skills relevant to employment; and
(e) to contribute to the achievement of sustainable
development in the United Kingdom where it is relevant to [their]
area to do so. [11]
They were also obliged to prepare and keep under
review a regional economic strategy for their area.[12]
14. However, over time the RDAs' functions expanded
to include innovation, sectoral development, tourism, implementation
of digital access, transport infrastructure, resource efficiency,
social exclusion and response to economic shocks.[13]
In addition, in 2006 they acquired a PSA (public service agreement)
target to "[m]ake sustainable improvements in the economic
performance of all English regions and over the long term reduce
the persistent gap in growth rates between the regions, defining
measures to improve performance and reporting progress against
these measures by 2006".[14]
15. In some activities, for example economic shocks,
there was evidence of effective intervention. EEF asserted that
"RDAs played a very important role in gathering good quality
economic intelligence based on their understanding of the area
and preparing areas very well for when they encountered economic
shocks".[15]
16. The TUC agreed:
We think the RDAs have been very important in
providing adequate co-ordinated responses to economic shocks and…the
committee heard before about the Rover taskforce, but I think
maybe an even more current example is the Corus situation in the
North East, where the Regional Development Agency worked closely
with local councils and local businesses, with Jobcentre Plus
and others, including trade unions, to put in place a package
of support, including support, for example, for apprentices whose
contracts came to an end with the closure of the Corus plant.[16]
17. Other RDA functions, however, were considered
to have been distractions from their principal objectives. John
Cridland of the CBI put it in this way:
Arguably, what we got wrong with RDAs is that,
when they began to succeed, as so often happens, we became excited
and we said, "If they can do that, why do they not do x,
y and z as well?" We gave too many things to RDAs, so they
almost became the only game in town rather than differentiating
where region was the main issue because of an economic zone or
where local was the main issue because of a travel to work area.
On some issues, such as I have illustrated with the national
innovation policy, when we are on a relatively small island with
modest resources, greater national drive would work. There is
room for each.[17]
18. RDAs also suffered from a perceived deficit in
accountability as a result of the failure of the policy for elected
regional assemblies. As Tom Riordan of Leeds City Council told
us, "one of the problems with the RDAs was that they never
managed to become creatures of our regions enough, because of
the lack of democratic accountability and despite lots of efforts
by people and good working relationships with local government."[18]
19. As non-departmental public bodies, RDAs were
directly accountable to central Government through the Department
and RDA board members were appointed by the Secretary of State.
A majority of the board members had business backgrounds, but
each board also included four local authority appointees as well
as members from trade unions, the third sector, and usually education.
RDAs therefore appeared to provide a forum in which business and
local government were able to decide jointly on strategy. However,
British Chambers of Commerce told us:
RDAs had business-led boards, but very many of
our business members in the Chambers and probably some of the
other business organisations as well often felt frustrated that
they weren't strong representatives of the business community's
voice as a whole or that they only represented a business that
actually was involved in public sector contracting, etc. There
were always some frustrations around that.[19]
20. There was also criticism that RDAs did not achieve
the level of private sector leverage seen with the Single Regeneration
Budget which had preceded them.[20]
21. EEF gave the following appraisal of the RDAs:
The RDA network chalked up both successes and
failures in its 12 year history. It is therefore important to
look at the strengths and weaknesses of the RDAs as we move towards
a new system of sub-national governance.
RDAs improved the understanding of local economies
and their connections with businesses and helped to identify and
deal with the consequences of economic shocks. They were also
able to catalyse delivery of infrastructure that would have economic
benefits beyond Local Authority boundaries and took a strategic
approach to planning decisions.[21]
22. It is clear that while RDAs provided many
benefits to their regions, mission creep and the lack of a clearly
defined strategy undermined their success. Furthermore, they suffered
from a democratic deficit. A key test of the new Local Enterprise
Partnerships will be the extent to which they learn from both
the successes and the failures of the RDAs.
The record of other existing economic
partnerships
23. Running alongside the RDAs were a series of ad
hoc economic partnerships between business and local government.
Several LEP bids have been based on those networks or partnerships
between business and local government, including those from Greater
Manchester, Leeds City Region, Coventry and Warwickshire, Thames
Valley Berkshire, and West of England. There are other such partnerships,
both at higher and lower levels than that of LEPs, among them
Furness Enterprise, Central Bedfordshire Strategic Partnership,
Gatwick Diamond, South East Economic Partnerships, South East
Diamonds for Investment and Growth and the Northern Way.
24. The overall impression given by the persistence
of these partnerships and the quality of some of their submissions,
both to the inquiry and as bids for LEP status, is that they offer
a track record of successful co-working between local authorities
and businesses. What is perhaps regrettable is that the decision
to move forward to LEP bid invitations was not made in the light
of at least some transparent review of the relative successes
of these bodies, and of the lessons to be learned from them, particularly
those operating at the same functional economic level as LEPs.
A proper evidence base for the policy decision would have included
such a study, with consideration of the merits of such proto-LEPs
against the merits of retaining an 'RDA lite' structure; that
is, a retained RDA system but with a slimming back down of RDA
functions to those originally envisaged.
25. LEP policy is already being implemented, but
it could be proceeded with alongside an examination of the record
of some forerunners to LEPs, so that lessons could be learned
from their performance and from any failings. The learning curve
of the initially successful 24 bidding organisations is one that
could also contribute to the success of other, following, LEPs
and help to even out performance. Given the important part that
LEPs will play in recovery, we recommend that the Government undertake
a rolling review of the first tranche of LEPs.
LEPs as an opportunity for culture
change
26. The evidence submitted to us indicated broad
support in principle for the move to LEPs. That support represented
a reasonable cross-section of bodies such as Centre for Cities,
University of Plymouth, Pennine Lancashire Chief Executives, Yorkshire
and Humber Stakeholders Group, and the Greater Manchester Chamber
of Commerce. Of the 131 submissions to us, very few, if any, were
entirely opposed to the idea of LEPs, although many had reservations
about certain aspects of how they would work. John Cridland of
the CBI said, "what is encouraging [...] is that everybody,
all key stakeholders and existing bodies, is accepting the principle
of change. Nobody is trying to swim against the tide."[22]
Chris Fletcher of Greater Manchester Chamber of Commerce commented
that: "businesses are very interested in this; there's a
great deal of interest out there—a surprising amount of
interest out there."[23]
27. The positive reaction appears to be based on
the scope for LEPs to facilitate better cooperation between business
and local government (flowing from the inherently smaller geographies
of functional economic areas, compared with regions), provided
there is proper business engagement.
Scope for better business and
local government cooperation
28. Louise Bennett of Coventry and Warwickshire Chamber
of Commerce, itself a signatory to the Coventry and Warwickshire
LEP bid, set out the advantages of LEPs to the partnership between
business and local government, saying:
I think that having the private sector at the
table gives you a stronger barometer of what's going on in the
economy, both locally and globally, and I think it gives us a
real opportunity to have very much demand-led local economies.[24]
29. The CBI highlighted the importance of dialogue
between local authorities and business. It argued that "too
often, the business community and the local authority world are
not sufficiently involved with each other. It is clear to us that
there are some sub-national issues for the business community
which are of great importance, where business is an absolutely
key stakeholder."[25]
This point was reiterated by the Institute of Directors who described
the interaction between the two in the following terms "in
our experience, they are not sour; they are not bad; but there
is a lot of misunderstanding between the two. LEPs present an
opportunity for us to address that".[26]
30. Among our first panel of LEP witnesses, Alex
Plant of Greater Cambridge and Greater Peterborough saw LEPs as
an opportunity to improve on this. He believed that LEPs had the
potential to be "truly business led" and have a "genuine
local focus and differentiation".[27]
Paul Gresham of Gatwick Diamond Initiative added: "Absolutely,
the business focus is important. SEEDA, which was our RDA, was
very supportive, but it did have a large geographical patch."[28]
Geoff French of the Enterprise M3 bid commented: "LEPs give
you the opportunity to look at the geographic areas and have logical
areas for each LEP, rather than areas that are dictated by historic
boundaries, which are really no longer applicable in many instances."[29]
31. The need for real business commitment and involvement
was highlighted both as an opportunity and a challenge. The Local
Government Association believed that:
"unless you have everybody in an area signing
up to what's on offer, you are not going to get the passion. That
was the disadvantage that some RDAs had [...] Now, if you have
a group of people—local authorities and businesses—who
go to the trouble to come forward with a proposal, and they have
the passion about that proposal, then that has to be the right
way forward."[30]
32. In a later session, Geoff French of Enterprise
M3 referred back to this, saying:
I was looking at the evidence given by the Local
Government Association, [who] spoke about having areas that were
small enough or appropriate enough that you could have a passion
for them—that was the word he used—or an affinity
for them. I think that's very much the case. I can have an affinity
for North Hampshire and the M3 corridor, because that's where
I spent all of my working life, but not for some larger amorphous
mass.[31]
Barrie Williams of Business Voice West Midlands put
it in this way:
I think that, as a previous speaker said, it's
about areas of business that have an affinity with each other.
There are natural communities of businesses that work around
specific industries very often, and whether they cross borders
or are on the borders or not, that's the group of people that
want to come together, because they are the people who can really
make the thing work.[32]
33. Yorkshire and Humber Chambers of Commerce rightly
set the bar very high for LEP aspirations. It said that "LEPs
had to 'ramp up' business involvement way above what has been
done in most LSPs[33]
in the region and in the Leeds City Region pilot". [34]
It also argued that Government should reject proposals which did
not demonstrate a true partnership with business. It concluded
that "businesses need to be directly involved in the formative
stages of the LEPs, not asked to sign up to a pre-defined structure
and plan".[35]
34. It is clear that there is a significant level
of enthusiasm for a fresh approach to partnerships between business
and local government; and one which is based on a greater affinity
for local economies among those participating. We conclude that
LEPs have the potential to offer a more dynamic approach to enterprise
through local businesses and local government. LEPs may also provide
an enhanced opportunity for small and medium sized businesses
to have a greater say in local development priorities. The opportunity
for greater business command represents, however, a challenge
both to business communities and to local government to be yet
more proactive and creative.
Functional economic geography
and critical mass
35. The joint BIS and CLG letter of 29 June 2010[36]
indicated that LEPs should reflect "functional economic areas";
in other words, areas that are reasonably self-contained and coherent
in terms of their travel-to-work pattern or economic homogeneity,
also taking into account matters such as extent of supply chain
or transport infrastructure. Working with such areas has the advantage
that they are more likely to deliver business engagement.
36. It is clear that some RDA regions were simply
too big to profit from that kind of local empathy. Examples frequently
cited include the distance of Cornwall from Bristol, or the arbitrary
separation of counties such as Hertfordshire (which fell into
the South East England Development Agency's area) from its neighbour
Bedfordshire (which came within East of England Development Agency
territory) notwithstanding that the considerably more distant
Sussex was still counted within the South East, and the totally
different nature of the Manchester economy from that of Cumbria.
37. It is worth noting, however, that RDAs' policies
were far from being applied on a blanket basis within regions,
and were capable of nuance toward local needs; merely because
the SWRDA counted both upland Devon and Bristol within its geographical
remit did not mean that it lacked the sophistication to apply
different considerations to them.[37]
However, it is also true that there was dissatisfaction with RDA
procedures: in its evidence, the Regional Studies Association
said "The Local Enterprise Partnership [...] proposals are
welcome in the sense that they may free localities from top-down
national control through literally volumes of guidance and regulation
that characterised the functioning of the [English] RDAs".[38]
38. On the question of whether local authority boundaries
fit the bill for deciding what is a functional economic area,
the Centre for Cities publication Beyond the Boundaries: Why
cross-boundary collaboration matters and what this means for local
enterprise partnerships[39]
highlighted the distinction between such boundaries and real economies,
observing that many UK cities are "'under-bounded' with administrative
geographies that captured only part of their real economic areas,
including "the area where people commute, shop and do business."[40]
Examples cited include Leicester, with only 51% of Leicester's
jobs taken by Leicester residents, and Sunderland, where the Nissan
supply chains extended substantially beyond the local authority
area of Sunderland.
REGIONAL VARIATIONS
39. Different parts of England will face different
challenges, and the critical mass and degree of regional coordination
necessary for LEPs will vary between different parts of the country.
Tom Riordan of Leeds City Council believed that this was reflected
in the North of England:
I think the further away from London you are,
the more critical mass you need, from my experience of the last
few years in the RDA. Particularly in the North, we need significance
to catch the eye of those national agencies and policymakers who
sometimes find it quite hard to get their heads around the geography
of the country."[41]
40. The CBI, a survey of whose members had produced
some 66% support for a continued level of regional coordination,
noted that requirements differed across the country but that support
was far stronger in the North and the Midlands, where regional
identity is stronger, than in the East and the South, where it
was not as strong. John Cridland argued that:
You see in a number of those Northern and Midland
regions that business groups have said that, even if there are
a number of LEPs, there may be a need for an overarching body
that can deal with some of the bigger ticket infrastructure issues,
which a number of us have said is a prime purpose of business
engagement with local authorities across boundaries.[42]
41. Speaking of the six West Midlands LEP bids, Sir
Roy McNulty of Advantage West Midlands believed that a level of
regional coordination in the West Midlands would be necessary:
It would be very difficult for six LEPs separately
to address either of [the] issues [of supply chain and international
competitive advantage. A shock as big as the Rover collapse spread
right across the West Midlands. Major industries like automotive
and aerospace, which again spread right across the West Midlands,
would not wish to deal six times with different bodies to address
the macro issues that concern them. That point has been made very
forcibly to me by people from the automotive sector and the aerospace
sector. I think all of that points to the need…for some form
of coordinating body.[43]
42. The North East Economic Partnership[44]
submitted a proposal whereby LEPs in the North East would collaborate
on a wide range of issues including legacy projects of One North
East, carbon capture and provision of expertise for developing
the low carbon economy, inward investment, sectoral support and
applying for EU funding. We understand that the Government intends
to recognise and work with the North East Economic Partnership,
albeit the details are presumably still being worked on, and we
welcome that willingness. There appears also to be a strong wish
to establish a body to represent the views of Yorkshire LEPs.[45]
Other such partnerships may emerge, for example in the West Midlands.
43. A consistent theme in the evidence we heard was
that such partnerships should be allowed to emerge and evolve
organically within the relevant areas based on what local bodies
agree is needed.[46]
The County Councils Network described these as "coalitions
of the willing."[47]
Chris Fletcher of Manchester Chamber of Commerce believed that
the vital factor in establishing such partnerships was that they
were "a product of the LEPs, not the other way around."
If they were not, he warned that RDAs would merely be reinvented.[48]
Barrie Williams of Business Voice West Midlands agreed, though
he raised the concern that should evolution not start "on
day one" then services such as the Manufacturing Advisory
Service could be lost.[49]
44. The need for well-constructed coordination was
put forward in the Centre for Cities paper Beyond the boundaries.
Taking the example of the Birmingham city region it found that
manufacturing firms in that area could choose "between 55
different support initiatives, provided by at least 29 separate
delivery bodies and portals". It observed that this was confusing,
ineffective and inefficient and that:
[c]oordinating activities across the real economic
area increased the opportunities to reduce confusion, rationalise
service provision and realise economies of scale and scope—as
well as improve relationships with business who can then have
just one main point of contact.[50]
45. We believe that regional groupings should
be recognised where there is a wish for them and the Government
should be prepared to fully engage with such bodies where they
have clear local business support. Where a minority of business
community members in an area disagrees with the need for a regional
grouping, that minority should be willing to show flexibility
in accommodating the majority wishes of members who want to maintain
an element of regional coordination. Regional groupings should
also be recognised where LEPs believe it is appropriate to have
an overarching body dealing with matters such as transport, infrastructure
or EU funding.
THE POSITION IN COMPARISON WITH SCOTLAND
AND WALES
46. Both Scotland and Wales have their own development
agencies, which have dedicated budgets and impressive one-stop
shop websites that incorporate clear information for investors
on areas such as start-ups and international trade. When we asked
the Minister whether he agreed that it would be "bad news"
if the English regions were to lose out in comparison with these
well focused and well resourced national development bodies, he
replied, "it would, but they won't".[51]
47. We are not sure whether to be reassured by the
Minister's confidence or concerned. Certainly, Dr. Brian Gibbons,
a Welsh Assembly Member, saw the demise of the RDAs as an opportunity
for Wales:
One good thing that the Westminster Government
has done is to abolish regional development agencies in England.
That was a pretty stupid decision from the point of view of regional
regeneration in England, because we know that the investment return
from those agencies, particularly the best-performing ones, was
quite substantial. However, it removes significant competitors
at a regional level from the market. That provides Wales with
a range of opportunities that would not have been available to
us previously. Therefore, we should be thankful for small mercies.[52]
48. Several organisations considered this to be a
risk, particularly if LEPs were not resourced as well as equivalent
bodies in Scotland and Wales. They included Leeds City Region,[53]
Cambridgeshire Horizons,[54]
Councillor David Sparkes for the LGA,[55]
and the North West Business Leadership Team.[56]
Alexander Ehmann of the IoD took the view that LEPs would not
be inherently disadvantaged when compared with equivalent bodies
in Scotland and Wales, but agreed that there might be a problem
if there is a disparity in resourcing.[57]
49. We note the Minister's confidence that LEPs
will not be overwhelmed by the Welsh and Scottish development
agencies, but we remain concerned that without a separate funding
stream LEPs could suffer. We recommend that the Government, in
its response to our Report, set out how those functions which
are being best performed in Scotland and Wales will be matched
by LEPs in England, in particular in light of the fact that the
Regional Growth Fund will not be available to support the ordinary
functions of an individual LEP or LEPs.
IS THERE A 'RIGHT' NUMBER OF LEPS?
50. The appropriate number of LEPs was considered
at some length by our witnesses. The Local Government Association's
opinion was that there were some 50 functional economic areas
in England; [58]
a figure that corresponded fairly closely to the 55 LEP proposals
submitted to the Government. However, British Chambers of Commerce
felt that upwards of 50 LEPs was too many, preferring between
35 and 40 on the basis of live and work criteria.[59]
The CBI would have preferred still fewer—of the order of
30[60]—while the
IoD wanted the minimum number commensurate with continued access
to EU funding.[61] EEF
argued that 12 to 15 LEPs would be more manageable.[62]
51. EEF and others among the principal business organisations[63]
highlighted the risk that undersized LEPs could lack the necessary
critical mass. Sir Roy McNulty of Advantage West Midlands believed
that a LEP with a population below 1 million would lack "sufficient
clout",[64] while
the TUC expressed concerns about the capacity of small LEPs,
the resources that would be available to them, and "in some
cases, we would be worried about their credibility with key partners,
including the private sector."[65]
Adam Marshall of the BCC put it more specifically, saying: "We
would want to see areas like Newcastle and Gateshead, and also
like Birmingham and Solihull, which is another one that is identified
in the Centre for Cities report[66]
as very under-bounded, working more closely with their neighbours
to try to get to a more sensible economic scale and geography."[67]
52. Many organisations told us that creating too
many LEPs risked creating a confusing and over-fragmented structure,
particularly with regard to delivery of LEP functions. Centre
for Cities[68] and One
Nucleus (a not-for-profit life science and healthcare cluster
based in Cambridge and London) were among those who voiced this
concern. The latter stated that "nothing frustrates One Nucleus
members more than fragmentation. They have neither the resource
nor the time to wade through potential 'mind spaghetti (as one
member described the potential scenario)'". [69]
The Institute of Directors was similarly concerned about LEPs
being "too parochial",[70]
adding, in oral evidence:
The Institute of Directors' general concern has
been about the LEP proposals that we have seen to date: they have
not had enough scale to them. Local authorities have not looked
beyond traditional relationships with other local authorities
that they felt comfortable with to wider bodies. The risk with
that is twofold. First, they are not strategic enough and will
not be able to deliver in the areas where we need them to deliver.
Secondly, they will not have the broad based support of business
in order to deliver. To give a specific example, in the South,
which has been referred to already, I believe there have been
17 proposals for Local Enterprise Partnerships. To garner the
amount of business support that is necessary for that, both in
terms of being able to go ahead but also the governance arrangements,
the way that organisations like ourselves, as national organisations,
will engage with those bodies and keep those people engaged is
a massive task. The jury is out on that.[71]
53. The Sector Skills Council for Science, Engineering
and Manufacturing Technologies (SEMTA) expressed similar worries
in its written evidence:
We have serious concerns that the proposed LEP
structure will compound complexity for companies, particularly
those with a geographical spread to their premises. It will also
increase administration costs.[72]
54. When we asked the Minister whether he believed
there was a "right" number of LEPs, he responded:
I have no intention of guessing a number. Although
we are quite rightly not trying to look at it from the centre,
what matters is having the number of LEPs that meet those criteria
that will make a difference to improving their local economy.
I do not mind how many that is. What I mind [about] is whether
they are going to be able to make that difference.
55. We conclude that, while there are clear merits
in founding local economic partnerships on strong local loyalties,
a structure consisting of significantly more than 40 bodies has
the potential to result in business confusion, lack of critical
mass and insufficient economies of scale. However, a structure
which produced 12 to 15 while delivering a simplified structure
might risk reimposing those arbitrary associations between areas
for which the RDAs were criticised.
56. It seems likely that, with 24 LEPs already
approved, the final number will rise to around 40. LEPs should
be approved on their business case rather than an artificial maximum
number, but the Department must be aware that too high a number
of LEPs runs the risk that they will not be effective.
11 Regional Development Agencies Act 1998, section
4(1). Back
12
See section 7 of the 1998 Act. Back
13
For a full list, see Ev 152. Back
14
http://webarchive.nationalarchives.gov.uk/+/http:/www.berr.gov.uk/aboutus/corporate/performance/performance_Framework/page14316.html Back
15
Q 72 [Radley] Back
16
Q 44 [Nowak]; Councillor Sparks also gave some favourable views
- see Q 49. Back
17
Q 84 [Cridland] Back
18
Q 125 Back
19
Q 79 [Marshall] Back
20
Ev 143 (Local Government Association), paragraph 6 Back
21
Ev 123 Back
22
Q 95 Back
23
Q 127 Back
24
Q 156 Back
25
Q 70 [Cridland] Back
26
Q 78 [Ehmann] Back
27
Q 118 Back
28
Ibid. Back
29
Ibid. Back
30
Q 59, Sparks Back
31
Q 120 Back
32
Q 158 Back
33
Local Strategic Partnerships Back
34
Ev w298, paragraph 4 Back
35
Ibid. Back
36
See Annex. Back
37
The Area Action Forces initiative is an example of tailoring approaches
to the needs of individual areas. Back
38
Ev w193, paragraph 22 Back
39
www.centreforcities.org/assets/files/10-09-07%20Beyond%20the%20Boundaries.pdf Back
40
Op. cit., Chapter 1, paragraph 2. Back
41
Q 119 Back
42
Q 74 Back
43
Q 3 Back
44
A consortium of the Association of North East Councils and the
Northern Business Forum, proposed to operate as a company limited
by guarantee. Members of the NBF include the North East Chamber
of Commerce, CBI North East, EEF Northern, the IoD and the FSB.
ANEC includes all 12 North East strategic councils. Back
45
See, for example, Ev w299, paragraph 10. Back
46
See, for example, evidence from: Devon and Cornwall Business Council,
East of England Business Group, Greater Manchester Chamber of
Commerce, CEDOS/ADEPT, and the Regional Studies Association. Back
47
Ev w64 Back
48
Q 132; and see also Qq 136 and 137 [French.] Back
49
Q 167 Back
50
Op. cit., page 7. Back
51
Q 219 Back
52
Welsh Assembly debates, 6 October 2010. Back
53
Q 139 [Riordan] Back
54
Ibid. [Plant] Back
55
Q 53 Back
56
Ev w157, paragraph 5 Back
57
Q 94 Back
58
Q 45 [Sparks] Back
59
Q 114 [Marshall] Back
60
Q 114 [Cridland] Back
61
Q 114 [Ehmann] Back
62
Q 114 [Radley] Back
63
For example, British Chambers of Commerce, Ev 100, paragraph 10;
CBI, Ev 113. Back
64
Q 10 Back
65
Q 45 [Nowak] Back
66
Beyond the boundaries; op. cit. Back
67
Q 78 Back
68
Ev w36, page 1 Back
69
Ev w167 Back
70
Ev 139, paragraph 1.12 Back
71
Q 75 [Ehmann] Back
72
Ev w212 Back
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