Official Report: Minutes of Evidence

The Deputy Chairperson (Mr Beattie): I welcome from the Executive Office Andrew McCormick, who is general director of international relations; Lorraine Lynas, who is from the EU future relations division; and Michael Williamson, who is from the common frameworks programme team. I advise the officials that this session is being recorded by Hansard, and the transcript will be published on the Committee website. It is good to have you here to provide us with the fundamental information that we need to be able to do our job. Thank you very much for coming along. Andrew, I will hand over to you.

Dr Andrew McCormick (The Executive Office): Thank you very much, Deputy Chair. I will keep my opening remarks brief to allow you to get into any areas that you want to probe in more detail.

Work has been progressing on the common frameworks. The project began a long time ago, soon after the referendum. The eighth report on 'The European Union (Withdrawal) Act and Common Frameworks', which details the progress on the development of common frameworks was published on 24 September, and it has the most recent analysis of progress. Forty frameworks that relate to Northern Ireland are being worked on: 22 may require a non-legislative framework such as a memorandum of understanding (MOU); there are 18 where the advice is that a legislative framework may be required. In 2018, a further 115 policy areas were identified as potentially requiring a common framework arrangement, but they have been reclassified as not requiring further action because there are already sufficient working arrangements among the four jurisdictions. The 40 frameworks are set out in the briefing paper, with particular progress being made on a few of them.

Work has been held up a bit. Many staff who worked on these issues, across all four jurisdictions, had to be redeployed to COVID work. So, that is understandable.

The briefing paper sets out the five frameworks that there is the potential to implement before the end of the transition period: hazardous substances planning; nutrition labelling, composition and standards; emissions trading scheme; food and feed safety and hygiene; and radioactive substances. As previously advised, those are on the list. They, and several more, were regarded as essential. It may no longer be possible to implement the fifth one in line with the timetable. That is being kept under review by the four jurisdictions, with the Cabinet Office in the lead. The hazardous substances, planning and nutrition framework received provisional confirmation at a meeting of the Joint Ministerial Committee (European Negotiations) (JMCEN) on 3 September. The next stage of the process is that the frameworks will be submitted to the relevant Assembly Committee with a view to formal confirmation.

There is a lot of interaction between this work and the other areas of work, such as the negotiations, work on the UK Internal Market (UKIM) Bill and the outworkings of the protocol. Lorraine, Michael and others in the team work closely with the Cabinet Office and the other jurisdictions to make sure that this is all being worked out, especially some of the key areas of work, such as the issue of unfettered access from NI to GB as part of the outcome of the negotiations. Work is continuing on the development of those frameworks that it is not considered possible to implement by the end of the year. We are keeping that work under review and engaging with stakeholders where necessary and appropriate. Of course, further progress reports will be considered by JMCEN between now and then.

Monitoring of the project is handled by a project board, which has representatives from our team in the Executive Office, the Cabinet Office and the Scottish and Welsh Governments at senior official level. That meets at least monthly. Subgroups are dealing with the more detailed aspects. Within our system, we chair, through Lorraine, the Northern Ireland Civil Service (NICS) common frameworks forum, which makes sure that progress is being made. It looks for any blockages or barriers and tries to overcome those and make sure that progress is being made towards getting workable, practical arrangements for all these areas of policy work once the transition period comes to an end so that we get as smooth an outcome as possible. It keeps Ministers informed of progress and makes sure that, where completion is not possible, effective interim arrangements are at least in place. That is all progressing. It is about trying to keep the policy areas manageable, given that a very substantial body of responsibility comes back as a result of EU exit.

Lorraine, is there anything that you would like to add before we go to questions?

Mrs Lorraine Lynas (The Executive Office): No. I am happy enough to take questions on the programme itself.

The Deputy Chairperson (Mr Beattie): OK. Thank you, Andrew. It can be a complicated area and a little dry at times. I get that; it is just the way it is.

The common frameworks allow for intra-UK policy divergence. What mechanisms are in place to ensure that any such divergence does not affect another portion of the nation? If we diverge slightly here in Northern Ireland, what mechanisms are in place to make sure that our divergence does not affect one of the other constituent areas?

Dr McCormick: The key word is "framework": it is not a rigid common policy; it is a framework for a policy. Do you want to expand on that, Lorraine?

Mrs Lynas: Yes. Within each of the policy areas, that is what the framework is designed to do: to look at any existing processes. On an area such as fisheries, there will already have been very good mechanisms across the four areas of the UK for how they engage with each other through memorandums of understanding or concordats. That allows a little bit of flex within that sort of structure. The point of the common frameworks is to look within each policy area and, where there were existing structures, see how those could be used, and, where there were not existing structures, see what needs to be put in place to strengthen that to allow the four nations to work together on it. Fisheries is probably one of the better examples of where the nations have worked together, and there are other examples. However, there might be other difficult policy frameworks where the arrangements were not as good as they could have been.

The Deputy Chairperson (Mr Beattie): When I look at the fisheries framework, I see that they are trying to come up with how they intend that common framework to work. Are they stuck slightly, in the sense that they cannot put stuff in place until we see the outworkings of the protocol and the Internal Market Bill? Is it a circular process whereby one is stuck until the other moves, and the other cannot move until the first makes a decision? Is that the position?

Mrs Lynas: That is reflected in the delivery of the programme. While it moved through the various stages that it needed to, it was recognised that the internal market had been identified early on as a cross-cutting issue. It was taken outside the frameworks, and, in 2019, the Department for Business, Energy and Industrial Strategy (BEIS) and Treasury set up a separate group to look at the internal market and how it impacted on the frameworks. However, you are right to mention those other issues. A lot of the frameworks will be impacted by the outworkings of the negotiations with the EU — by what any deal will look like — and by the implementation of the protocol.

Those issues, and waiting for clarity, started to affect the delivery and slow down the development of some of the frameworks, which is why the frameworks programme had to be amended and adapted as we went through. It is like everything in the EU exit: all of these things are interlinked, and it is only at the end, when the pieces come together, that you can finalise these frameworks

Dr McCormick: Some frameworks more than others.

Mrs Lynas: Some more than others: those that are impacted by the protocol, of course.

Dr McCormick: It is a major difficulty.

The Deputy Chairperson (Mr Beattie): Yes, it is. Thank you. I will bring Colin in before I open up the meeting to members' questions.

Mr McGrath: Thank you for the presentation. As the Deputy Chair pointed out, trying to work out the details of the common frameworks is a bit complicated and dry. Somehow or other, I have in my head something like a Venn diagram, where the protocol is one circle, the Internal Market Bill another, and the little bit caught in between is us in the North. What will happen if there is a conflict between the Internal Market Bill and the protocol? Is that on somebody's desk to iron out or, when we come to 1 January 2021, will people, businesses and commerce be left looking in two directions, not knowing which to take?

Dr McCormick: The process has to be one that resolves, as much as possible, well before 1 January. Part of what has been said from London is that some of the controversial aspects of the Bill will be relevant only as a safety net; that is how they are described. If progress is made in the negotiations to resolve some of the difficult issues, some of the more controversial proposals will not be needed. That, I think, is the solution. The best way to avoid the hazard that you describe is to get resolution in the discussions. A good outcome from the main negotiations — a free trade agreement — would take away a lot of the pressure and remove some of the issues around the movement of goods from GB to NI. Some checks will be required, of course, on the sanitary and phytosanitary (SPS) front, but pressure on the tariff issue will be much reduced. We will still need to watch out for non-tariff barriers — the technical barriers to trade. All those things need to be looked at in detail to work out precisely how this will work. However, that would avoid some of the things that are most difficult in the Bill. Yes, the Venn diagram is a start, but there are several more shapes, circles and ellipses, with multiple overlaps and interactions. However, it is a good metaphor for seeing how this complicated work proceeds. What we need is to make progress in the negotiations and, therefore, avoid as many problems as possible.

Mr McGrath: This is where it might have been good to have your presentation before that of the First Minister and deputy First Minister. Your presentation highlights how critical it is to get a resolution to these matters, and the very perilous situation that we will be in if there is no deal. We were told by Boris Johnson that his deadline was 15 October. It looks likely that that will be pushed back until the beginning of November. It is unlikely that we will get a deal that covers everything. Northern Ireland will be left with about six weeks in which to try to assimilate all the decisions taken in early to mid-November.

The bottom line is that it will create chaos, come January, and we will be playing catch-up to try to implement common frameworks or internal Bills. Everyone will be scrambling as we try to adjust. It means that we are heading for a car crash of an exit, in whatever shape it comes. Everybody seems to have their fingers crossed that there will be a good outcome from the negotiations. It is not a great situation to be in. I appreciate that you are doing the work in the background — this is not your fault — but you are reminding me, again, of the perilous situation that we are in.

Dr McCormick: A lot of people are doing a lot more than hoping or keeping their fingers crossed. A lot of detailed preparatory work is being done. I covered a fair bit of this last week. Project after project is being worked on across all Departments, and we in the Executive Office are drawing those together through the interdepartmental working group that we talked about last week. That is the process. It is designed to identify the biggest risk areas: the areas in which businesses, citizens or society might be adversely affected, especially bearing in mind that this will coincide with the difficulties through the winter as a result of the virus. Departments are looking at what will be a particularly challenging combination of events and asking, "In that context, where do we need to deploy resources? Where do we need to intervene most? How do we best manage this?" That information is brought to the Executive, and officials look at it. The apparatus exists to draw those threads together. Yes, a lot of things are still uncertain, but, as they become clearer, we will know where we stand, and there will be guidance for businesses. There is a lot of engagement with businesses. They have a lot of questions. The business working group, which has been here at the Committee, has done excellent work in analysing and presenting the issues that they are facing. They have big concerns, but we have to get through this, step by step, methodically identifying what needs to be done, and getting on and doing it.

Mr McGrath: I have another quick question. You say that a lot of work is going on. Is that work highlighting the problems, or is it highlighting the problems and putting a solution alongside them? If a problem is not sorted by 31 December, do you have in the next column a solution and a time frame in which that can be implemented? Are you identifying problems and solutions or just problems?

Dr McCormick: We are identifying solutions and what to do. Some of it is complicated because you have to allow for a range of scenarios. That is why we focus on the publicised reasonable worst-case scenario. There is also a central case. We have to look at those and, recognising a degree of uncertainty, hope for the best but plan for the worst — be ready for the worst and have some kind of interventions prepared. Some of this comes down to finance, as is so often the case. What can be done to help? That is being looked at. We are looking at what the right intervention will be for a reasonable worst case and for the other possible outcomes.

Mr McGrath: Thank you. Good luck.

Dr McCormick: We need it.

The Deputy Chairperson (Mr Beattie): We will go to Martina, and she will be followed by Trevor Lunn. Hello, Martina.

Mr Clarke: There she is.

The Deputy Chairperson (Mr Beattie): Do you hear us, Martina?

Ms Sheerin: She cannot unmute herself. I had that issue last week.

Ms Anderson: The gremlins were trying to keep me quiet. I could not unmute myself.

Mr Stalford: God bless them.

Mr Clarke: Unfortunately, it did not work.

Ms Anderson: Now, now. You behave yourself.

I acknowledge the work that you, Andrew, and your team are doing around all of this. However, I was somewhat disappointed when I received annex A of the outline briefing for this Committee meeting today. If I had the luxury of time in my life, which I know that many of us do not, I could have googled this and got the same information as has been provided to us today. We have a Civil Service form but, from speaking to colleagues on other Committees, I discovered that there are no standardised documents that go to the different Committees.

As the Deputy Chair said, the language of the common framework can seem like jargon to people, so we, as a Committee, need to "de-jargonise" it, if there is such a word. These common frameworks are about the 154 areas where EU law intersects with the North and therefore with the Assembly and the Committee. These are supposed to be our powers; they were to be transferred to us. The British Government are telling us that they will look at these powers before they hand them over to us. Who knows what they will do to them?

Andrew, you mentioned five areas that were supposed to be sorted out before the end of the transition period, and you then said that it may be only four. Which of the five in front of us may not make that deadline? Your paper says that 115 policy areas were identified in 2018 as potentially requiring a common framework arrangement but have since been reclassified as requiring no further action due to pre-existing work. With all due respect, this Committee is here to scrutinise, as are all Committees, and I see this as a democratic deficit in our ability, as MLAs, to do our job and look at these processes. We will not get a chance to do that if the frameworks are put into that kind of process. In the first instance, we need to better explain to people what this is all about. We also need to stand over, whatever position we are coming at this from, our ability and competence to scrutinise, as opposed to what is happening with those 115 areas.

Dr McCormick: The one with which the issue arose is radioactive substances. Recent work has shown that there is a bit of a delay on that one. It is being kept under review and is still being worked on. If it is not fully in place by the end of the transition period, it will be soon afterwards. Four of the list of five are still on track. The radioactive substances framework was recently reviewed as being not as far advanced.

Part of the point about the 115 policy areas is that there is no outstanding issue that keeps them together. The common frameworks approach implies a degree of working together among the four jurisdictions. In some cases, where there are already satisfactory arrangements, they are already sufficiently devolved. Part of the issue, and part of the controversy, over this whole topic was especially between London and Edinburgh, and that, in 2017, when this was first going around, gave rise to a big dispute over the Sewel convention. It seemed as though the UK Government were not moving forward to re-devolve powers. Powers were coming back from Brussels but stopping at Westminster, and the Scots were saying, "No. Those fall within the broad scope of devolution. They should automatically come to the devolved institutions".

The idea in the common frameworks is that, where the four jurisdictions identify a valid basis for working together, that maintains a way of working together that provides for that policy to be better than would otherwise be the case. We can provide any details that you need on the 115 that are mentioned. There is no difficulty in getting you whatever detail or scrutiny you want to undertake there, but the advice is that those are OK. Nobody is trying to take anything away from the Assembly or undermine the Assembly's role. There is no risk of controversy there. I hope that I am not overstating the case there.

Mrs Lynas: No, I point to the reclassification process. The reclassification was published at the same time as the quarterly report. There is a process that looks at each of the frameworks in the reclassification process across each of the four parts of the UK, so it goes through a standard process to assess whether an actual framework is required. Yes, you are right that 160 areas were identified that intersected, but that is not to say that a framework was needed in every single one of those areas. There was a certain amount of consolidation, so there were separate areas but a lot of them were grouped together, and the number of frameworks then reduced in size. There is a very clear reclassification process. As I said, the report has been published and laid in Parliament on that process as well.

I return to your other point about the jargon and the scrutiny by Committees. This maybe touches on Colin's previous question about how we manage the programme and how we have had to adapt. We started this programme before the protocol came into operation. As soon as the withdrawal agreement was agreed, we had to go back and look at all of the frameworks and where they intersected with the protocol and make sure that that was factored into any of the frameworks. The Internal Market Bill is now another area where there is a bit of work going on with the frameworks in looking at where they are market-orientated, where they are non-market-orientated or where they might fall into non-discrimination. As things change, we continually have to adapt the programme on that basis.

On the scrutiny, the first two that pass JMCEN will be coming to the Committees. It gives us an opportunity to review the processes, because this work is going to stretch way into June. We will be quite happy to take feedback from the Committees on how this works. Obviously, the frameworks will go in front of each of the Assemblies and Parliaments at the same time. The purpose of the cross-nation programme board that we have is to keep an eye on this, to work up joint procedures and to iron out things. We will be taking feedback from all and adjusting that process as we go. So, we are quite happy to take that feedback as we get to this critical stage, because getting confirmation of those first two was a key milestone in this programme, given how long it has been in operation.

Ms Anderson: What are the implications of the radioactive substances framework not being in place by the end of this year? We know that isotopes are very important, particularly for people who are getting cancer treatment. What happens until we get to that point?

Whilst I know that you are telling us with sincerity that it is all going to be OK and that the processes have been followed, I have been listening intently to what you have been saying about the four nations, as you call them. You will forgive me for not seeing the North as a nation. Whatever about the four areas in the agreement that has been taking place there, one of the guiding principles in the framework is to ensure the recognition of economic and social linkage between the North and the South, taking account of the Good Friday Agreement, obviously strand two of the Good Friday Agreement.

When I was going through the documents, I was looking at cross-border healthcare. Regardless of what tradition we come from, many of us know someone or know of someone who has gone to the South or elsewhere and availed themselves of cross-border healthcare. I know people who got hip replacements and others who were able to avail themselves of the opportunity to get cross-border healthcare. I do not hear you making a reference to that principle when you talk about either the 115 areas or the other areas. That concerns me. I am concerned about the importance of the common framework relating to cross-border threats to health, which is referenced in page 48 of the papers.

Will that common framework in any way negatively impact on cross-border cooperation? We have seen the need for that cooperation, particularly with COVID-19, but we are also aware of the areas of cooperation in the Good Friday Agreement, as well as the other 154 areas that we are dealing with here.

Mrs Lynas: I am happy to take that question. As you will be aware, centrally, the Executive Office has a role in trying to coordinate it. The policy areas all belong to individual Departments. As part of our oversight process, we were advised, just last week, that the DAERA/DEFRA discussions on radioactive substances have slipped slightly. Through our cross-departmental forum, our role will be to look at the impact of that slippage. That is one of the priority frameworks, and, if it slips, we need to understand what the impact might be. That is our role in that.

Michael, not to drop it on you, but can you add anything on the impact of the radioactive substances framework?

Mr Michael Williamson (The Executive Office): The intention is that it will still be considered by JMCEN for provisional confirmation before the end of December. It will then be scheduled for scrutiny by the Assembly in early 2021. It will be classed as a provisional framework from the end of the transition period at the end of December. Working arrangements will have been set out, but they will not have been fully implemented. The four Administrations will all have been working together on what they intend to do from 2021 onwards, so they will have plans in place on how to handle it. There should be no long- or short-term impact from its not being fully implemented by December.

Dr McCormick: In particular, anything to do with operational requirements will be managed as part of the operational planning. Making sure that there is a flow of important substances such as the isotopes that you mentioned, Martina — those practical realties — will be managed as an operational issue.

The frameworks are there to set the basis of engagement among the four jurisdictions for decision-making and policy going forward. They are designed to deal with how legislative and policymaking that previously involved being part of the EU will work in this exit mode. They are about providing an approach to managing and legislating for those issues and will not affect the operational side of the concern that you raised. That is an important point to make.

Mrs Lynas: The principles were agreed at JMCEN at the outset and the Executive signed up to those in June. In the absence of having an Assembly, officials did as much work as they could on the basis of those principles until the Executive could sign them off. They are front and centre in the development of the frameworks. All framework areas in all policy areas across all four areas across the UK and in all the individual Departments need to abide by those principles in the development of the frameworks.

Ms Anderson: I have outlined principle 3. You talk about the four jurisdictions working together, but why was health not one of the priority areas, particularly given our location on an island and our need to work together? We all know now that we need to ensure that not just animal welfare but human welfare is looked at on an all-Ireland basis, and that is particularly important in the context of the EU. What engagement is taking place with the Irish Government as you move through the process of working out how the common frameworks will be implemented here?

Dr McCormick: All those things are genuinely being treated according to what is practically possible and with a view to priorities. I am guessing that Health Departments everywhere were among those most affected by the pandemic and, therefore, were probably prioritising that work over the policy analysis and future planning that is inherent in this process in looking ahead at how to manage reciprocal and cross-border healthcare, as you pointed out, Martina, or public health. Rather than thinking about it in the abstract — this is technically abstract work — because they were having to manage the issues around COVID, I assume that that was where their energy was going. Therefore, they have had to work in the operational world, and that has probably meant that the longer term planning process has been delayed. There is no real-world detriment as a result of that; it is about making sure that there is the ability to deal with patients on a North/South basis and to maximise that cooperation. That is all continuing in the practical real world.

Mrs Lynas: At our level in the NICS, in the forum that we run, we keep an eye on all of the frameworks and the progress that they are making. It is not just up to us to make that progress. The progress has to be made equally across the UK on that basis. That is where the upper level of the board comes into play; that is where we can escalate the issues to say, "Why is this framework not progressing at the speed it needs to and what are impact and risk associated with that?". From our perspective, we feel that reasonably good processes are in place to keep an eye on that, to monitor it and to provide a little bit of scrutiny back down into individual Departments, which are responsible for the frameworks themselves.

Dr McCormick: Lorraine will correct me if I am wrong, but is it not a fact that when this emerged several years ago, during the period when we had no Ministers — it was long before the protocol as we now know it came into being — discussions were definitely going on about how we would be treated here as a result of exit? The backstop idea was around. My recollection is that we proposed the addition of that principle, recognising the need for it to be acknowledged that there was a likelihood that the outcome of the exit process would be some arrangement, even though we did not know what it would be at the time. Even then, there was a clear direction of travel that things would be, in some way, different here compared with across the water. Therefore, for us to be tied purely to an arrangement that ignored that dimension would have been unhelpful. That is why we proposed that principle.

Mrs Lynas: That is right; that was put in at the time specifically to address our needs.

Ms Anderson: If I am following your responses correctly, no framework will break the alignment that is required in strand 2 of the Good Friday Agreement, for instance, on health, and that the frameworks will ensure that that alignment takes place even if the British Government diverge from that. Secondly, many of the frameworks relate to transport, drivers' licences and so on. Will the success or failure of those frameworks affect transport across this island?

Dr McCormick: I will go back to the Venn diagram that Colin mentioned. The frameworks have to have regard for and have to be subject to the regulatory obligations that arise from the protocol. There is a range of legislative obligations. Our participation as a region within the frameworks will be constrained by all the legislative obligations that arise from that and, indeed, by the practicalities of operating transport systems across the island. If you are going to have a railway system that crosses the border, having it working has to take primacy. Those obligations are there and they need to work practically. Anything that is agreed across the four jurisdictions has to leave us able to comply with what might be legal obligations under the protocol. It is a long yes, Martina, to your question. Is that bit OK?

Ms Anderson: Yes, I am satisfied with that.

I have other questions, Chair. I know that I could hog this meeting by talking about the EU, but I will resist. I have said enough.

Mr Lunn: I was with a conservation group this morning, and, by coincidence, they asked me to answer questions that I could not answer, but I am sure that you can. It is about the habitats and the birds directives under one of your categories. I forget which one — natural biodiversity or something. They made the point that, when EU law transfers to the UK, the UK could weaken those directives. At the moment, if the UK tried to do that, it would be subject to, perhaps, court action by the European Court of Justice, but that will not be the case any more, and they are hardly likely to fine themselves. The question that they asked me to ask you is this: can Northern Ireland ensure that there will be a legal commitment to the principle of non-regression of nature conservation laws? That is their interest, but I am sure that the question would apply to other interests.

Mrs Lynas: That probably sits within DAERA. We would probably have to take it away and check.

Dr McCormick: We may need to come back to you on that. That does not strike me as a protocol obligation, because it does not relate to trading and the main topics in the protocol, but it may be. Let us check out the facts and come back to you on that.

Part of the point of all this is that there should be respect for devolved functions. If Scotland, Wales or Northern Ireland wants to maintain a devolved divergence from what England or the UK Parliament might want, that is part of this. This is supposed to be agreeing to work together within a framework. If there is a desire to diverge from EU obligations or to uphold them, and those two points of view are in tension, there has to be a way to resolve them under this process and get an acceptable outcome.

Mrs Lynas: We probably need to take that question away and provide you with a written answer.

Mr Lunn: Fair enough. Are those devolved matters at the moment?

Dr McCormick: All of these are being considered because up to this point, because of EU membership, the powers lay with the EU. They were in devolved-type functions but, in reality, pooled by all, then 28, member states. With EU exit, this question arises: are they repatriated, so to speak — forgive me, Martina — to London or devolved back to Edinburgh, Cardiff and Belfast? That is the question.

Mr Lunn: Thanks for that. There is a UK Environment Bill that proposes an office for environmental protection. That appears to be one of the most useless organisations in prospect. It cannot investigate anything other than government operations, and it cannot impose sanctions, so what on earth use it is going to be is open to question. It is definitely going to be very weak. We do not have an independent environmental protection agency here, which could, perhaps, beef the thing up for Northern Ireland. That is a worry.

Dr McCormick: That is a long-term controversial issue on which I would hesitate to tread in this context. That is a matter for further debate. It is also a matter for DAERA as environmental policy. That is a matter for using the Assembly as to what is the right thing to do about environmental regulation. I do not think that that is going to be controlled by this process. That will be a matter for policy work led by DAERA.

Mr Lunn: I always seem to be asking you questions that are semi-political. I do not mean to.

Dr McCormick: That is OK.

Mr Lunn: You can come back to me on the first issue.

Dr McCormick: We will do our best on that and come back to you.

The Deputy Chairperson (Mr Beattie): George, can I confirm that you have no questions?

Mr Robinson: Nothing, Chair, no.

The Deputy Chairperson (Mr Beattie): And nobody else has.

Mr Stalford: I can see how this develops. [Laughter.]

The Deputy Chairperson (Mr Beattie): Andrew, thank you very much to you and your team. Giving of your time is important to us because it helps us to understand what are quite complicated issues.