Apologies have been received by the Cathaoirleach of the committee. Today's meeting will be split into two sessions. The first will consider matters relevant to the EU emissions trading system, ETS. In the second session there will be discussion of social policy issues relevant to the Irish Presidency of the Council of the European Union.

The purpose of the first session is to consider two elements of the EU emissions trading scheme, namely, the carbon offsetting and reduction scheme for international aviation and carbon dioxide removal. The EU ETS is important in the context of climate adaptation and of course in the context of the Irish Presidency of the Council of the European Union. We are joined by representatives of Phillip Lee LLP, Mr. Lev Gantly, partner, and Mr. Max Loughrey, senior associate. You are both very welcome to the committee.

Before beginning I must read a note on privilege and deal with some housekeeping matters. Witnesses are reminded of the long-standing parliamentary practice that they should not criticise or make charges against any person or entity by name or in such a way as to make him, her or it identifiable or otherwise engage in speech that might be regarded as damaging to the good name of the person or entity. Therefore, if their statements are potentially defamatory in relation to an identifiable person or entity, they will be directed to discontinue their remarks.

Members are reminded of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the Houses or an official either by name or in such a way as to make him or her identifiable. I remind members of the constitutional requirement that they must be physically present within the confines of the Leinster House complex in order to participate in public meetings. I will not permit a member to participate where they are not adhering to this constitutional requirement. Therefore, any member who attempts to participate from outside the precincts will be asked to leave the meeting. In this regard, I ask any member partaking via MS Teams that, prior to making their contribution to the meeting, they confirm that they are on the grounds of the Leinster House campus.

Our opening statements are usually five minutes but we are going to be a little lenient on this occasion and have eight minutes for the opening statement from Mr. Gantly. I would appreciate it if every could try to stick to our time limits because we have quite a schedule of work on today.

A Leas-Chathaoirligh and Deputies and Senators, thank you for the invitation to appear before the joint committee. We welcome the opportunity to contribute to the committee's deliberations on two matters of significant importance for Irish and European climate policy. Phillip Lee LLP is a leading Irish law firm with offices in Dublin, Cork, London and New York and our international climate projects practice advises clients across the full spectrum of emissions trading regulation and carbon markets. Our team works at the intersection of EU and international climate law to advise governments, airlines, climate charities, project developers and financial institutions. With four partners and five senior supporting lawyers, ours is the largest private practice team of its kind globally.

Ireland assumed the Presidency of the Council of the European Union on 1 July at a significant inflection point for international climate policy. The European Commission is mandated to propose amendments to the EU emissions trading system directive, including as applied to aviation and the integration of carbon dioxide removals, with the draft proposal due on 17 July. Ireland will chair negotiations on this file and the decisions taken will shape global aviation emissions governance, and the investment thesis for carbon dioxide removal activities, for a generation.

Aviation was first brought within the scope of the ETS through Directive 2008/101/EC which originally envisaged coverage of all flights arriving at or departing from EU airports, including those operated by carriers from third countries. Coverage commenced from 2012, with airlines legally required to surrender emissions allowances to cover carbon dioxide generated by covered flights. This year is the first year European airlines will carry the full cost burden of the ETS for flights within the European Economic Area, EEA, as free allocation of emissions allowances for intra-EEA aviation has been completely phased out. The extraterritorial application of the ETS to flights beyond the EEA provoked immediate and sustained international opposition from the United States, China, India and others, including explicit and credible threats of trade retaliation. In response, the EU adopted a "stop the clock" decision in 2012, which suspended the application of the ETS to extra-EEA flights. This suspension was subsequently extended several times through to the end of this year to allow for the development of a global mechanism and the current review is the culmination of that process.

In 2016, the International Civil Aviation Organisation, ICAO, adopted the carbon offsetting and reduction scheme for international aviation, CORSIA, to address any annual increase in international aviation carbon emissions above a baseline set at 85% of 2019 emissions. CORSIA operates in three phases, namely the pilot phase that ran from 2021 to 2023, the first phase from 2024 to 2026, in which participation by states is voluntary, and a second mandatory phase that will commence in January. We are in the final year of the voluntary first phase. The deadline for operators to have purchased and cancelled CORSIA eligible emissions units, CEEUs, equal to their final obligations for the first phase is 31 January 2028.

There is a linkage between CEEUs and Article 6 of the Paris Agreement that goes directly to availability of supply. Article 6 of the Paris Agreement governs the use of internationally transferred mitigation outcomes, ITMOs. An ITMO is a formally authorised carbon credit that represents a tonne of CO2 reduced or removed by an underlying project activity. Once authorised, the country that hosts the project is required to apply corresponding adjustments to the emissions balance within its national greenhouse gas inventory. This is to prevent the double counting of emission reductions or removals between the host country and whoever uses the ITMO. Considering both past experience and the current geopolitical moment, developing countries are acutely aware that affordable climate finance is in extremely short supply. This is why many such countries have placed great emphasis on ITMO-related revenue generation through the Article 6 mechanism within their most recent nationally determined contributions, NDCs, submitted to the UNFCCC's secretariat at or about last year’s UN Climate Change Conference, COP, in Belém. However, the detailed rules for Article 6, at UNFCCC level, were finalised at COP29 in Baku less than two years ago. As a result, most countries are still finalising domestic implementation of those rules and are increasingly aware of CORSIA as a critical demand node for their ITMOs. Derailing the unconditional application of CORSIA on international routes by the EU at this time would have the effect of derailing the ITMO export-related revenue expectations of many developing economies.

There are other risks associated with unilateral EU action on this matter. As noted in our written submission, the threats of trade retaliation that led to the stop-the-clock decision have not dissipated. In the current geopolitical climate, those threats are considerably more severe. Industry opposition is significant. The International Air Transport Association has publicly stated the opposition of its airline members to any extension of the emissions trading system, ETS, to international routes on the basis that it would distort competition between EU and non-EU carriers. Jet fuel prices and other increased costs are undoubtedly contributing to this sentiment. Over recent weeks, Airlines for Europe, the president of the ICAO Council and the ICAO secretary general, have written to President von der Leyen warning that extending the ETS to international routes would undermine CORSIA and impose duplicative carbon charges on the same emissions.

CORSIA has the potential to function well if all contracting states comply. The EU should use its diplomatic influence to apply pressure on key contracting states in order to ensure that the scheme is transposed into law and imposed on all airlines on and from the commencement of the mandatory phase next year. A failed CORSIA means a failed attempt to cap emissions. A failed attempt to cap emissions, eradicates hope for net zero in aviation.

The scientific case for carbon dioxide removal, CDR, is set out comprehensively in the European Scientific Advisory Board on Climate Change's February 2025 report Scaling up carbon dioxide removals - Recommendations for navigating opportunities and risks in the EU. The advisory board is the independent scientific advisory body established under the European Climate Law of 2021, mandated to serve as a point of reference for the EU on scientific knowledge relating to climate change. The advisory board has concluded that the EU must rapidly accelerate CDR deployment alongside deep emissions cuts if it is to achieve its legally binding climate neutrality obligations. Removals are already recognised in Ireland's climate Act and in the EU’s most recent nationally determined contribution.

The EU's carbon removals and carbon farming, CRCF, regulation is the first legislative framework of its kind. It has been established to certify carbon removals, including in respect of engineered and nature-based projects. In February, the European Commission adopted the first set of methodologies for permanent carbon removals through delegated acts, covering bioenergy, carbon capture and storage, BECCS, direct air carbon capture and storage, DACCS, and biochar. The Commission is expected to adopt certification methodologies for carbon farming activities, including agroforestry and peatland restoration, this summer. At present, however, there are no clear demand signals for CRCF-certified removals in EU climate legislation.

The integration of certified permanent removals into the ETS was expressly referred to in the European Climate Law, which, as recently amended, sets a binding 2040 target of a 90% reduction in net greenhouse gas emissions and explicitly foresees domestic permanent removals under the ETS contributing to that target. The advisory board has recommended a progressive integration of permanent removals into the ETS, subject to strict conditions to prevent mitigation deterrence and address environmental risks.

The economics of CDR integration into the ETS depend critically on the amendments to the linear reduction factor, LRF, that are due as part of a 17 July review. A reduced LRF would suppress ETS allowance prices, posing economic challenges to CDR projects. If the ETS price falls below the cost of delivering permanent removals, a private investment case for these technologies will become challenging.

Carbon contracts for difference, CCDs, constitute a mechanism by means of which governments guarantee a strike price to CDR project developers. The lower the ETS price, the greater the difference between the strike price and the market price, and the greater the resulting cost to EU taxpayers. These contracts are similar in structure to the contracts for difference that have been successfully deployed across the EU to support the roll out of renewable energy.

Outside the ETS, Ireland has a significant and immediate opportunity. The CRCF creates the possibility for demand signals for non-permanent CDR pathways, including nature-based solutions such as carbon farming. Ireland can take a leadership role in creating such demand drivers domestically, thereby assisting with its obligations under the effort sharing regulation and the land use, land use change and forestry, LULUCF, regulation. Acting now would help Ireland to meet its climate targets, avoid fines and create carbon farming jobs.

I again thank the Leas-Chathaoirleach. I am happy to take any questions from members.

I thank Mr. Gantly. We appreciate all the details and specifics he has provided.

We all understand the large carbon footprint for which the aviation industry is responsible. We always talk in terms of sustainability and the fact that we have to have various methods to deal with emissions, including the single sky initiative, direct routes and sustainable aviation fuels. However, we are nowhere near where we are going to have to be. We are literally in the voluntary first phase. A huge lobby has been built up in relation to business and fairness. The fear is that CORSIA may die a death on this basis and that we would literally end up in a far worse situation. I am not wrong on any of this.

I thank the Deputy for the points he made. What he has said is exactly right. Part of the tension at the moment is around resurfacing some of the issues that caused the stop-the-clock measure to be applied back in 2012.

In the first place.

Exactly. That was when the EU sought to apply the ETS carbon price on emissions caused in international airspace.

If everything is applied as intended, how much would that impact on European airlines?

Does the Deputy mean CORSIA specifically?

Yes.

I will quote two data agencies, namely Morgan Stanley Capital International and Sylvera, from which I recently received data. For CORSIA phase 1, CP1, which is the current voluntary phase from 2024 to 2026, and for which the retirement date is January 2028, the cost, according to Morgan Stanley Capital International, is somewhere between €2 billion and €8 billion. According to Sylvera, it is somewhere between €5.8 billion and €7 billion. It is a lot greater across the second mandatory phase, which will run over an eight-year period from 2027 to 2035 and for which Morgan Stanley Capital International has estimated the cost to be somewhere between €23 billion and €120 billion.

I get that it is for eight years, but it would want to be. That is a significant amount of money. Has the aviation industry come forward with anything that is likely to mitigate the reason that this has been brought forward in terms of the high level of emissions generated by aviation? That is sometimes the lazy option whereby it is too hard to do anything, so science must step in and sort it. Again, there are alternatives, whether it is fuel, the way flights are operated operate flights or, as I mentioned, the single sky initiative, although that is not the correct term for it.

No, that is okay. The key point is as follows. What we do in the context of intra-EU flights is covered by the European ETS and the European sustainable aviation fuels, SAFs, mandate.

CORSIA specifically relates to emissions caused in international airspace. These are emissions between contracting states to the Chicago Convention, which is the convention that covers international aviation that was created after the Second World War. What CORSIA stands for again is the carbon offsetting and reduction scheme for international aviation. The R is CORSIA permits the factoring in of the use of what we call low carbon aviation fuels, LCAFs, and CORSIA eligible fuels, CEFS.

They probably do not mitigate to the amount people would want.

They absolutely do not; correct. Their overall emissions intensity reduction is probably about 10% or so against JET A kerosene. It is a pretty weak form of sustainable aviation fuel, using that term very generically, as opposed to somewhere in the range of 60% to 80% emission intensity reduction under the European SAF mandate. However, the European SAF mandate is a totally different thing that applies on European turf. This is specifically to do with how we manage in a cohesive internationally and multilaterally agreed way emissions that occur in a place that no one has jurisdiction over, which is international airspace.

At a time when an awful lot of the stakeholders do not want to pay that money and we are looking at a system that is currently under severe pressure of it being sustainable.

Yes, I agree with that. It is a good point. The other point I add is that CORSIA right now is still learning to crawl. I would be assessing for the effectiveness or otherwise of CORSIA probably two to three years into the mandatory phase. The big thing that needs to happen is the likes of China, the US, India and some of the countries that are currently not participating in the current voluntary phase and that have to participate, in theory, in the mandatory phase are actually transposing the CORSIA into national law and enforcing it. That is where we need to get to.

Mr. Gantly thinks America is going to buy into this.

It is not clear if it is going to in the current Administration.

I could probably take a guess.

Indeed.

I thank Mr. Gantly.

I did not understand some of that, so I want to come back to ask. It is an area in which I am not particularly well versed. Who is Philip Lee?

We are a law firm.

What is the firm's interest in this?

My practice is in international climate law. We represent a lot of project developers around the world. We work with investors, financial institutions, project developers and charities developing projects in the global south that are relying on CORSIA as a revenue stream, as I mentioned in my opening statement. To clarify that, the jurisdictions that need to export the carbon credits under Article 6 of the Paris Agreement, which are the types of credits that qualify for use in CORSIA, have written their reliance on Article 6 into their nationally determined contributions, which is the document they submit to the UNFCCC every five years under the Paris Agreement. They are relying quite heavily, in the cases of certain countries, especially in Africa, on revenue streams associated with what we would colloquially refer to as carbon finance, namely, the export of carbon credits in exchange for revenue coming into the country.

Okay. Why is the firm here? How come Mr. Gantly is here?

There were views expressed in prior Commission sessions on the question of what ought to happen with the ETS and we thought it necessary to balance the field and offer what we think is an objective analysis of the situation.

If I understand it correctly, the firm's area of representation, being very general about it, would be countries which pollute the skies less than most and which can benefit from the fact that they do that less by trading their lack of emissions with other countries.

There is that element of it, and generating revenue though the export of those carbon credits. Then there is the second point, which is just as important. For example, there was an ICAO general assembly, which runs every two to three years every September-----

A what?

The International Civil Aviation Organization, ICAO, which is a United Nations body which administers CORSIA. It has a general assembly every two to three years. The last one was last September. Representatives from 52 African states in their submission noted unconditional support for the CORSIA scheme, wishing to avoid what would otherwise be a patchwork of approaches. If the EU takes a certain position on CORSIA, in other words lift the stop the clock and extend the emissions trading system, ETS, into international airspace, that means airlines coming in and out of Europe will have to pay different levels of carbon pricing depending on where they are flying to and from. They would have to purchase credits under the CORSIA scheme if they are flying, for example, from an African state to a South American state.

Let us tell this in stories. If the emissions trading system is expanded, we will say you are British Airways - we will leave an Irish company out of it - or KLM and you are operating an international flight from Dublin, what is the impact?

The impact is that those airlines would need to ultimately purchase emissions allowances under the emissions trading system, which are significantly more expensive for those airlines-----

From?

-----from whoever auctioned them within their member state. The way the emissions trading system operates is that there has been auctioning by designated authorities within each member state of emissions allowances up to a certain cap. At the moment, Aer Lingus has to buy emissions allowances in relation to emissions caused on flights from, for example, Dublin to Frankfurt or Dublin to Paris. For a flight from Dublin to New York, Aer Lingus, at the moment, would in theory have to purchase CORSIA eligible emissions units, CEUs, the price of which at the moment in the market is significantly lower than the emissions allowance price. If the ETS were extended into international aviation, Aer Lingus would need to purchase emissions allowances, which at the moment are-----

That is under the ETS as opposed to under CORSIA.

Correct.

All right. The impact on, we will say, developing countries is-----

The impact on developing countries would be that they would not be getting the revenue stream associated with the export of CORSIA eligible emissions units.

They would not be benefiting from the fact that they pollute the skies substantially less than others.

Correct. There is that point as well. Not only that but Kenyan Airways or any developing country airline that flies in and out of the EU would also need to pay the EU price.

How can Ireland best play a leadership role in the contest of the EU Presidency, particularly with phase 1 or CORSIA going into phase 2?

I thank the Deputy for the question. There are probably a few key points. The history of this needs to be understood. In 2012 or just before the stop the clock measure, the Obama Administration passed the emissions trading prohibition act as a retaliatory measure which prohibited US carriers from participating in the EU's carbon pricing. Where the EU was concerned, they were going to apply that price come hell or high water, but the Obama Administration at the that time effectively banned it through bipartisan support. That is the first point. If that happened during the Obama Administration, I wonder what will happen this time around. Second, I think Ireland has traditionally played a really important leadership role in multilateral negotiations, especially as they pertain to climate change. CORSIA is the product of probably ten or more years of multilateral negotiations and, as I mentioned, it is just learning to crawl now. The mandatory phase has not started yet. Our view is that it needs to be given a chance to breathe and function as intended. The other key point I would repeat is that the EU, perhaps through Ireland and the Irish Presidency, could use its diplomatic influence and negotiating power to help communicate the message to other large contracting states - the Chinas, the Indias and maybe in the next Administration in the US - that they will need to start taking CORSIA seriously.

This needs to be implemented and transposed into domestic law and enforced such that everyone is compliant. It is not good enough for CORSIA to exist and for everyone to say they back it and they want to comply with it yet not transpose legislation. Only a handful of states, apart from the EU, Japan, South Korea and Canada have actually transposed CORSIA in any great detail into domestic law. However, there is another point. In the case of the EU, apart from France and Austria, no member state has actually legislated for what penalty applies to a European airline. In the Aer Lingus example I gave earlier, we do not know the penalty that would apply to it would be because Ireland has not actually legislated for a penalty. Does that answer the question?

Yes. Has there been any engagement with the Irish Government or is there any likelihood?

I expect there will be on this topic. The question of the lifting of the "stop the clock" or some variant thereof in relation to what happens on this point will be proposed in a significant Commission proposal on revisions to the emissions trading system as a whole. This is one of the key elements. The other key element is carbon dioxide removals, and then there is the linear reduction factor. There is a whole bunch of things that will come as part of that draft Commission proposal. That will be subject to trilogue negotiations.

Out of curiosity, because it is my own constituency, I have a question about the Dublin Airport cap being removed. I take it this will not significantly increase operational costs for airlines unless they are flying internationally?

To go back to the two data points, on the effect on operating profits on airlines, in the first phase it will be somewhere between 2% and 4% according to MSCI. It is saying 5.6%.

I thank the witnesses for their presentation. What is the situation with Ryanair and Aer Lingus? Ryanair flies into Europe and Aer Lingus flies to the United States. Are they paying a voluntary amount or purchasing ETS?

I will zoom out and take a step back and repeat what I said earlier. On intra-EEA flights, that is flights between member states, the emissions trading system has applied for a long time. Up until three years ago there was free auctioning so airlines got emissions allowances for free. Last year, they reduced free auctioning by 50% and this year free auctioning has been completely removed. For emissions caused by Ryanair and Aer Lingus on intra-EEA flights, 100% of exposure for those emissions needs to be purchased through emissions allowances. Therefore they will have to carry that on their balance sheet when they go to do their calculations for 2026 next year. I believe the cancellation date is September 2027 for the 2026 calendar year. On Ryanair and Aer Lingus’s emissions in international airspace, it depends on whether they are flying between two contracting states. CORSIA only applies on routes between two contracting states to the Chicago Convention that in the current three-year voluntary phase have voluntarily opted in to participating. For example, the US has, in theory, voluntarily opted-in to participating.

I have to disrupt Mr. Gantly for a moment. Unfortunately, I have to go to a vote in the Seanad. Deputy Lahart will take the Chair and he will come in with a question afterwards. I am sorry to disrupt Mr. Gantly.

They have been assigned ETAs for free until now.

Until 2024. Last year there was 50% auctioning, so that half of the emissions caused by the EU would have had to have been purchased for 2026. For the current calendar year there are no more free allowances.

They would pay, or whatever they have to do would be due, in 2027.

Yes, for intra-EEA flights, not on international routes. When I say international routes, it is a subcategory of international routes. CORSIA, as I mentioned, only applies on routes between two contracting states that in the current three-year phase have voluntarily opted in to compliance. The US has opted into compliance even though it has not transposed it into law. In theory, Aer Lingus flying from Dublin to Washington DC would need to buy CORSIA-eligible emissions units.

Will Mr. Gantly give an idea of what cost it will add to tickets when they have to pay 100%.

Again, basing this on the data I have from the two organisations I mentioned earlier, it is about 70 cents to $2.20 for CORSIA phase 1, CP1, per ticket on average. When you take that across all the routes, that is the average mark-up on ticket price. It is about 0.2% from the other organisation. That is for the current phase so it is not that much at all. For the next mandatory phase, I expect it will be significantly more than that.

How much would it be?

I do not know. We do not have the figures. It is too early to say.

Currently it is 0.2%

It is something like that. It is approximately between 0.7%, so 70 US cents and $2.20 for the current phase, CP1. That is because the CORSIA eligible emissions unit price is at the moment significantly lower than the ETS price. If the ETS were to apply, the ticket price for consumers would be more than that.

I thank the Deputy. I find this fascinating. That is why I was asking those questions at the start. It seems to me, unless this has been done, that it would be useful to shake the tree in Government and the various Departments with a series of parliamentary questions on CORSIA and its adoption. Mr. Gantly may have already done that.

We have not done that, no.

Does he understand that process?

No.

That is whereby public representatives from whatever party - any of us here as TDs - can place parliamentary questions, in this case probably to the Minister for Transport but there could be a climate piece as well, such as some of the questions Mr. Gantly raised about communicating the advantages and the fact that it is a multilateral agreement, to see where the State sits on this. The beauty of a parliamentary question is whether you like the answer or not, it is a formal answer on the public record. Then you can see the State is aligned to our way of thinking on it, for example. I am not saying Mr. Gantly’s way of thinking is the right one but you get full view of where the State is on a particular position. That allows people like us to ask questions in Parliament on it. This is not an area I know a huge amount about but Mr. Gantly has certainly piqued my interest in it, particularly from the developing world point of view and because of its multilateral aspect. These are things we like to embrace in Ireland because they tend to be protective of us as a small country.

The witnesses can chat to any of our colleagues about parliamentary questions. It is a facility that is there for any member of the public and any organisation. The witnesses may have responsibilities as a corporate body to make some declarations or something like that but they have come in and set out their stall and exactly where they are on this. They are on the record and nothing is being hidden here. They have raised an angle on this that has not been raised at the committee before so I think it would be useful for them to consider.

The ETS review is not just about aviation. There is discussion around the linear reduction factor and other things that have a real impact on the cost of living. Our view would be there should be reforms to the EU ETS that uphold its climate ambition while also protecting families that are having it tough. It is not just to do with aviation. It is also related to the integration of carbon removals and other factors like that.

Does anyone want to come back?

Does this apply to the maritime sector as well?

At the moment, CORSIA does not. The Deputy raised a very good point. There is currently no law of any kind that covers emissions in international waters. As the Deputy might be aware, the International Maritime Organisation, IMO, has held meetings over the past several years, which were, frankly, jeopardised, let us say, by the US Administration in London in September of last year.

There is no multilateral equivalent.

No. Our hope is that if CORSIA can flourish and work in the context of emissions in international airspace, it could then be looked at as an example by the maritime sector in the context of emissions in international waters.

As the committee can imagine, we do not advise or engage with many people in the shipping space, just because of Ireland’s economy. We do a fair bit in the aviation space. My understanding is that there is some increasing integration of the EU emissions trading scheme on certain maritime routes. Is it 50%?

Yes. The ETS does apply to maritime journeys into or out of Europe, but only up to a 50% threshold. Part of the thinking in the Commission, as we understand it, is that it should do something similar in respect of aviation. This would be to apply the ETS on outbound international routes to sort of mimic what has been done in the maritime context, except this ignores the fact that CORSIA took ten-odd years to negotiate and put in place.

It was put in place because the EU pushed so hard. The EU has done what it said it would, but other actors have not necessarily done what they said they would do. These are the European values: say what you are going to do and then do it.

Has a difference been seen in the current make-up of the European Commission compared with the previous Commission?

The people working on this particular file and the draft coming through are pretty much the same people who have been working on it for quite some time.

Lovely.

There have been some changes regarding the stability reserve. Some changes are proposed at Commission level to try to stabilise the price a bit. There have been some more changes which, broadly, have been in the area of competitiveness. Generally, I think the approach has been pretty consistent, especially in the area of aviation.

All right. I thank Mr. Gantly and Mr. Loughrey.

That was really interesting. If Mr. Gantly and Mr. Loughrey want to follow up, I ask them to communicate with us. They raised some matters that are of interest to the committee and, I would say, to the wider Parliament as well in respect of this issue. I am sure there are players in the industry who will be listening intently. I thank Mr. Gantly and Mr. Loughrey for their engagement in respect of what has been an insightful discussion. We will suspend for a few minutes to allow for the changeover of witnesses. Is that agreed? Agreed.