DEED, Mr Tonami, Senior Policy Officer, Natural Resource Management, National Farmers' Federation RAGG, Mr Warwick, General Manager, Natural Resource Management, National Farmers' Federation RASHEED, Ms Fiona, Senior Policy Officer, Primary Producers South Australia [by video link] Committee met at 09:00 CHAIR ( Ms Swanson ): Welcome. I declare open the public hearing of the Standing Committee on Primary Industries inquiry into factors shaping social licence and economic development outcomes in critical minerals projects across Australia. I acknowledge the traditional custodians of the lands from which we meet today and pay respect to the elders past and present and the Indigenous peoples all across Australia. This hearing will be audio-broadcast and the transcript of the proceedings will be published on the parliament's website. Although the committee does not require you to give evidence under oath, I should advise you that this hearing is a legal proceeding of the parliament and therefore has the same standing as the proceedings of the House. The giving of false or misleading evidence is a serious matter and may be regarded as a contempt of parliament. The evidence given today will be recorded by Hansard and attracts parliamentary privilege. I now invite you to make a brief opening statement before we proceed to discussions. Mr Ragg : I'll rely on the opening statement we made in round 1. CHAIR: Which we do have on the Hansard record, thank you. I should also add that the committee thanks you very much, Warwick, Tonami and Fiona, for coming back on a Friday, because our last hearing was rudely interrupted by divisions and pesky democracy. I say that with tongue fully in cheek. Mr Ragg : I now have a couple of further pieces of information to hand, which I'm happy to table. I've got a couple of copies for you to share and I've also provided it to the secretariat and emailed them to you this morning. I just might spend a couple of moments talking to those. CHAIR: Yes, please speak to those, just for those listening online that don't see what you've given us. Mr Ragg : The first one is the Victorian Farmland Protection Plan. This is a document released by our Victorian member in response to a range of land use things. There are a couple of pages I'll draw your attention to. There's a commentary in there about rehabilitation and decommissioning. I'm not going to read all that to you, but just the high-level principles are that the rehabilitation requirements have to be binding, that there needs to be adequate investment from government in science, that no farmer should be left behind, and that the true cost of a project needs to be properly accounted for, including the community cost. They've really tried to frame the process which people need to go through to satisfy communities. Related to that is some commentary that VFF have provided me about a mine—I think it's called the Fingerboards Mine, in East Gippsland, Victoria—which has taken some time to approve. In fact, it was not approved and then they started the whole process again, but it's not an appropriate place for it because it's one of the highest-value areas for fresh produce in the state. I don't really want to go into data centres, but there are also some data centre discussions going on, partly about where they're going to be but more about the resources they need. Clearly they need access to the grid electricity. They're pretty heavy users of electricity. They also need water, and water is pretty contested in critical areas of Australia for agriculture, so we would be unlikely to be happy with is dumping data centres in or near the Murray-Darling Basin, for example, where it's already highly contested. That's the Victorian example. I'm happy to come back to interrogate that a bit more with you, to the extent I can. This other one is just a media release, but there's more detail behind it that we can get if necessary. There are two critical things I'll talk about there. This was in relation to coal seam gas development in the Condamine Alluvium. I'm sure Michelle Landry will be quite familiar with that. Legislation has passed the parliament to ensure that the prime agricultural land is able to be protected. There are a couple of key things in there. They have this thing called a regional interest development approval framework, which is a protection mechanism for the farm sector—so there actually has to be some process around it. You can't just go out and do this; we need some process. By way of further explanation, RIDA provides farmers with an important negotiation tool when resource development is proposed, and retention of the framework in this amended legislation was a key ask from QFF and our peak body members through the parliamentary committee process. Those are just a couple of comments. Broadly I would say—and I've probably said this in my earlier opening statements—any of these need to be done carefully, with the community, with respect to the resources, with respect to the wind-down and rehabilitation and making sure they're appropriately funded. We are happy to take your questions. CHAIR: That is really interesting. I'd like to unpack the RIDA you mentioned—the Regional Interest Development Approval framework. If I'm hearing you correctly, basically, in Queensland they've put that into legislation. Mr Ragg : Into law, yes. CHAIR: We don't need to do this straight away but, if you are able to, I wouldn't mind unpacking that in a few minutes, because I think that this could potentially form a recommendation of ours as well. We're constantly asking how we can come up with processes that have your members feeling as though they do have that social licence—basically, that they have equity in the conversation. I think I read in your submission that farmers want to feel as though they actually have some power in the decision-making process, rather than feeling that, for whatever reason, they've been run roughshod over and the decisions taken don't really take their considerations into account. I'm probably paraphrasing you there, but that was my takeaway from it. Mr Ragg : That's accurate. I think we now have an increasing body of evidence where our state members—because most of the interaction is through state legislation—are engaging with government in a proactive manner to rebalance how these things are dealt with. I've talked about information asymmetry before. 'Exemplars' may be putting it a bit high, but Queensland is certainly being very forward-thinking, not only with this particular legislation but also when some of the earlier Surat Basin gas fields development was done. There was the development of consultative mechanisms and, while there is not really a fidelity fund, there is a mechanism to ensure that rehabilitation is undertaken. Those are the sorts of examples that we think should be in the forefront of minds when these new proposals are being brought forward, whether they're data centres, whether they're critical minerals, whether they're renewables, or whether they're transmission lines. CHAIR: Basically anywhere where there's land use contestability for agricultural land. We're focused on critical minerals, as that's what we've been charged with, but I understand your general premise in terms of renewables or a mine. In fact, we can talk about a mine, which is what we're looking at here today. It's the life of mine. I think they call it the full picture accounting, so it's from concept to closure and beyond. It sounds to me like that other end of this is your big concern as well—so it's the rehabilitation back to what it was or at least back to something that's usable. Is that what you're contending? Mr Ragg : Yeah, and I think it's probably both ends. It's getting it right in the proposal development stage but it's also making sure that the proponents walk away having fulfilled their obligations for rehabilitation. I think I mentioned last time we met that we are concerned about poor corporate behaviour, such as transferring ownership and developing phoenix companies that all of a sudden don't exist anymore when you need them to be there doing the rehabilitation. There needs to be structures that don't allow that to happen—and the only way that we can see, in the current way the world operates in Australia, is that there is a commitment to make that investment in that fidelity-type rehabilitation fund. That takes off the table the capacity to disappear. CHAIR: I just noticed in your document the words I was looking for earlier, 'true cost accounting'. We will take that and have a look. The other aspect that occurs to me in relation to this is something that we covered off in food security, and it was the idea of natural capital accounting as well. On one end, you've got the true cost, which involves all of the development and the rehabilitation, but you've also got this idea of natural capital accounting, which is taking into full account and value what the land is actually capable of doing and the value of the water that it may have. Rather than just having a block of land and saying, 'This is worth X,' this approach asks what its actual productive value is in real dollars and figures as a productive accounting exercise. We had a couple of experts come and talk to us about that, and I thought that was a really interesting thing. You're really looking at that true cost, from productivity to repatriation, making it do what it did before, or at least somewhere close to that. Mr Ragg : Yes, that's important. Another thing that we are conscious of—and I alluded to it—is that I'm aware of a data centre proposal, I think between Geelong and Melbourne, which is competing for water that's currently being used for the food production bowl of Melbourne. That's kind of a problem, right? You need to think about where you're going to get some alternative convenient food sources. CHAIR: Of course. I can see that Fiona is now on the line again and we can see her, so I might take this opportunity to hear from her if the line is now clear. Did you want to make some remarks and just a contribution while we look as though we've got a decent connection, Fiona? Ms Rasheed : Yes, thank you. In terms of water, just going on from what Warwick was saying, communities that are reliant on water for their livelihoods are, by nature, going to be concerned if there is a development that comes in that is going to jeopardise that. In the south-east of South Australia, where there's a very strong reliance on the underground water, and critical mineral exploration is currently in process through the Koppamurra project, the concern from those in the community is that there isn't a clear pathway at the moment for how that project is going to access water. They have to buy a licence off the open market, but the water resource is already under stress. It's restricted, and there's a water allocation process underway that is potentially going to restrict allocations already. If you have a new, very large water user coming into the region, the concern is, 'We haven't got enough for the agricultural industry that's there as it is, so how are we going to then provide water for a significantly large new water user that comes in?' The other issue that concerns those in the region in regard to water is around the integrity of the aquifer. With some of these processes that are coming in, they are, let's say, still working out how they're going to undertake the mining activities and extract the minerals from the clay soils, so there are concerns around whether there's going to be use of acids that might leach into the aquifer. All of those things are still being worked through. For the community that is reliant on water for their livelihoods, those things still having question marks next to them is what raises uncertainty and concern for them. They are concerned about, first, where they are going to get the water from. Second, even if they do get the water, some of these mining processes that jeopardise the aquifers—and there aren't clear answers to those questions yet—obviously raise uncertainty over the project. CHAIR: I guess that really then calls into question the whole idea of social licence, and we're asking how we can better get social licence? Of course, water is a highly contested resource, particularly in South Australia. You raise valid points, and we do have a tension with wanting to stand up these projects, which are incredibly important from a geopolitical and strategic point of view, but we also need to make sure that we can feed our country and do all the things that are of utmost importance. They're points that are well made. Ms Rasheed : Absolutely. It's a balance, I suppose, with regard to coming in and consulting early. We want early engagement from companies and we want them to be bringing the community along in terms of their processes and what they're working through, but the flip side of that is that, because there is still uncertainty about how they are going to undertake some of these activities, that undermines some of the trust. The community thinks, 'If you're still working it out, then you're kind experimenting with us.' We're the guinea pig and, if things do go wrong, then it's whole industries and regions and communities that rely on the water that are then at risk. CHAIR: There's a question here in my notes that probably works well within this framework. It is: should we as a government be developing comprehensive guidance for obtaining social licence in these projects? Most definitely there is a role for us here. Mr Ragg : Yes, I think so. I would characterise it this way: we need to recognise the subtle yet probably significant differences in how each jurisdiction addresses these issues. We've talked about the Queensland approach. I think there needs to be a coordination of comfort, making sure that there are some broad guidelines where thresholds can be tested in each jurisdiction to make sure they're met. I've been around trying to harmonise things with states and territories for far too long, but I would strongly encourage the Commonwealth to map expectations and, to the degree that can be aligned with where states are going, that would be good—but, as is always the case in this federation, some states are at different levels of progress than others. I've talked about how I think Queensland is leading on that. New South Wales, for example, has just brought in right to farm legislation. The Victorian document contemplates. I don't think that's in South Australia yet—Fiona might have a better idea than me—but certainly we could have a set of principles that we could then, collectively, go to jurisdictions with and say, 'Here are some threshold issues.' I haven't thought this through, but you may even have the power to tie that to some of the development things, because some of the development consents will have to come through a Commonwealth process. CHAIR: Enforceable standards is something that has been thrown around as well. Ms TRISH COOK: I'm taking a step back and thinking: is there a system that we already have where perhaps the prime agricultural land is already mapped? I see your natural resource management, and there's that actual group called Natural Resource Management—because I have the wheat belt, Natural Resource Management—and they basically have mapped all the areas. They know all the very sensitive environmental native areas that need to be carefully managed, and presumably they would know the prime agricultural land. At the moment, how does it work? Is it just that, if a farmer wants to sell up, they sell up, if they're approached? Is that how it works? Mr Ragg : Let me answer the first question before the second question. Broadly, you would expect so, but there are a couple of problems, and let me draw back on 30 years experience in this space. Beauty is in the eye of the beholder. Mapping prime agricultural land is one thing, and there are capability maps, which is kind of what you're referring to. Not surprisingly, they differ in how they're developed and how they're defined across jurisdictions, so you don't have a national map of soil capability. There is that problem, and that may begin to resolve itself. Frankly, a number of farmers have different views about what prime agricultural land is. Most of them think their land is prime agricultural land. It's not clearly defined anywhere. By way of example, I participated, and still do participate, in a process led by Melbourne University and former Chief Scientist Robin Batterham on scenario planning for Net Zero Australia. One of the discussions we had was where would be a really smart place not to put solar and wind, but particularly solar, and that is on flood plains—not only because it's high-performing agricultural land but also because, really, water and electricity don't go that well together. There's some logic there. On your second question, we absolutely argue for the right of volunteerism in this. One of the reasons transmission lines are so controversial is that they just say, 'We're going that way. Here's a bucket of money. Best of luck, guys.' Renewables and batteries et cetera are different because it is a choice a farmer can make to engage in that. Within the context of this inquiry, though, because critical mineral rights have a power, it's likely that there could be some compulsory acquisition. That's a concern for us. We'd much rather that it be done by consultation and engagement, but it's a bit hard to move where the minerals are, so then you have to have the discussion about what's the best way to utilise those. Ms AMBIHAIPAHAR: I am just looking at the document you've provided. I'm not sure what page that would be—maybe page 2. Mr Ragg : Page numbers would have been helpful. Ms AMBIHAIPAHAR: That's all right. Particularly on that shared prosperity bit, it says that communities hosting energy and mining projects should share in the wealth generated through a dedicated fund focused on enhancing agricultural productivity across the state. Can you just provide some reflections around an ideal model and, thinking nationally, what kind of considerations are there on how you're weighting on interests, particularly for farm owners and then, obviously, the local community? I think that feeds into getting that social licence from the community. What are we getting back can probably be said about anything really. Mr Ragg : That's difficult, and it's probably a PhD. The first thing I'd say is that I doubt we've got an ideal model and I doubt we ever will. It will depend on the various circumstances, such as land capability and community disposition—and that's a really difficult thing to do. I think I talked in the first hearing about how communities will react, depending on the intervention. Different parts of a single community will react differently. So some will say, 'That makes sense. That's good.' I think the core to your question, though, is: what do we need to start seeing out of these processes? We need to see that communities are more engaged and more vibrant. If there are things that need doing in communities, there are already models of co-investments for proponents in, for example—and this is trite—fixing up the local football field, or better change rooms or lights. That's community visibility on what this organisation is bringing to town. Where there are infrastructure impacts—a shared obligation to deal with the damaging of roads or whether they need to go around a town rather than straight down the main street—those things need to be worked through. With things like renewables—it won't work so much in critical minerals—there is the notion that, if the power's being generated within a community, do they get cheaper electricity? Where is the broader benefit to the community? It's being developed there. Someone's selling it somewhere—and there are some technical difficulties with this—but how do we make sure that there's a tangible community benefit to those sorts of things? They are the sorts of threshold issues that communities expect to be considered. They'll go to town hall meetings, they'll have chats and some will like it and some won't. They'll think someone's doing better out of it than others. That's life. That's democracy. CHAIR: It's human nature. Mr Ragg : Yes. CHAIR: It depends. Self-interest is always the best backed horse, so, if someone's got something to benefit from something, then they'll stick up for that, and if someone else has got another benefit they'll fight hammer and tong for that. Mr Ragg : There is an interesting model. Just out here there is a wind farm, and it's been there for quite some time. It will come to me where it's actually at. One of the models that was used there really satisfied a range of community concerns. The way renewables with wind farms work is that you get paid per wind farm on your property. I think it's an annual payment. What they were able to negotiate there was that some of that payment went to neighbours where their amenity might have been affected. So they felt included in the impact and were getting something out of that rather than it just being, 'My neighbour's getting all the benefit. I've got to look at this eyesore, and I get nothing out of this.' In regional and remote communities, anything you can do to remove disharmony is a really good thing, because there are surely other ways that disharmony exists anyway. So that was good. It isn't applying everywhere, but it's certainly been seen as an example. Fiona, I don't know whether you've got any experience down there with transmission lines and things yet? Ms Rasheed : Yes, more in the renewables space and also more in projects that are currently being developed. There aren't that many that are operating here in the southeast. There are some further south that have been going for about 20 years. I have an example similar to yours, Warwick, again in the renewables context, but there are applications across other land uses. This is where the landholder themselves, obviously, gets their annual lease payment, but then the developer or the project proponent puts an annual amount, rather than just one upfront payment, into a fund that can then provide grants to local sporting communities or organisations. There are two different models. One is that those grants are decided by the project proponents somehow, and another is to have a community committee or board that makes that decision so that, again, there's community engagement in terms of how the benefit is distributed across the community. One comment that I would make is that there needs to be caution in terms of those. Yes, we want community benefits, but there is also a perception that project developers and proponents are coming in and trying to buy off the community. While we definitely want community benefit out of any project, the underlying concern is to address those broader issues like water and soils. Unless they're addressed, there won't be a social licence. Once they have been addressed—and you can provide assurance to landholders that their own access to water will not be affected, or their soils, and that decommissioning and remediation are part of it, or the environmental sustainability side—yes, obviously there needs to be benefits that flow to the community. Then it is about being transparent in terms of any royalties, whether they pass to the federal government or state government, and transparency in terms of what the benefits are to the state and to Australia, as well as making sure that they flow on to the community. Also, as Warwick said, you need to ensure that there aren't any unintended consequences that the community has to bear. For example, with things like road damage, you don't want a local government then having to increase their road maintenance or renewal budget because of a project in their area, particularly if there isn't going to be much that flows on to them. Local government rates is another aspect that I think needs consideration as well—how the local government and council are supported, because they obviously would have an increase in their activities through projects moving in. CHAIR: Thank you, Fiona. I think those are points well made and, whilst this inquiry is focused on social licence and economic development of critical minerals, there are lessons most definitely to be learned. Straight mining, coal mining, I can speak with a little bit of authority on the ways we've done that well in the Hunter and the ways that we could have really done it much better. Community benefit sharing is a really interesting beast because you do want the community to benefit but, in saying that, you don't want the community to feel as though it is, to use your language, being bought off or it's a tokenistic effort—that is, 'We're going to extract X billions of dollars of wealth out of the ground and we're going to sponsor a few football jerseys over a few years and everything will be sweet.' A lot like the world, and mining practices, things are more sophisticated and things need to be more sophisticated around that and there has to be greater understanding. Your point is well made. My mind keeps going to Royalties for the Regions, which was a program that was used whereby regions that were at the heart, basically, of the extractive industries—where there is more pressure on local infrastructure, whether it's roads, bridges, schools or hospitals—they needed to see real input and benefit. Again, when we were out in the west of New South Wales, local governments were at pains to say that often they are the sole entity responsible for housing, and for all of the things that come along with supporting these big industries, and it's very difficult for them to do it on their own. So I think your evidence is great. Ms AMBIHAIPAHAR: I just have one other question. I apologise because this is a very new area for me, given that I'm more from the city side, the metro side of Sydney. I know we talk a little bit more about physical infrastructure, and that's what I've been hearing, particularly through the inquiry. What about the sort of the softer services? I know a lot of things are expected of the respective state jurisdictions to provide those services. I'm thinking of health and education. What about that, in the sense that, if I was living in a community where I saw that kind of benefit, it might have a better role in that social licence rather than just the infrastructure piece? Could you maybe talk a little bit about that? Mr Ragg : There are probably a couple of aspects of that I could dwell on. My observation, and it's a distant one, is that the development of the new airport in Sydney has come with commensurate hard infrastructure, its rail lines and its new roads. I haven't got visibility, but I anticipate that the population explosion around Oran Park probably hasn't been fully met with social infrastructure—health, education, et cetera—to the degree it probably should have. Sure, there are new schools. If we think about Singleton, when I was up there all those years ago, Singleton town was kind of off the main thoroughfare. It's better now because you can go around Singleton. CHAIR: We are working on that. It's not quite open yet; we're getting there. Mr Ragg : And that's the point. Coal mining in Hunter Valley has been there forever, but there's a lag—and this is probably to your point—on public infrastructure with private investment. As to how we go about coordinating that, I know there's competition in budgets and everyone needs stuff, but major expansions will need major infrastructure, contiguous commitment, I guess, to just make sure that you're aligning those issues. The corollary is the water example in the Murray-Darling Basin, where one of the things that was being proposed in the face of buybacks was, 'We'll build a new hospital in Deniliquin.' We were asking, 'Why would you do that? Deniliquin is depopulating. In the main street a third of the shops are empty. No-one will want to go to the new hospital, but sure, thanks, build a new hospital because that's nice.' You just have to get the right infrastructure. Ms AMBIHAIPAHAR: You could have an increase. Mr Ragg : So yes, we do, but it's got to be the right infrastructure at the right time for the right purpose. Were you adding something to that? Mr Deed : No, I think that's correct. Just in terms of the funding, are you talking about royalties going into that? Ms AMBIHAIPAHAR: I guess it's more that, when you're thinking about what the community is getting back, we talk a lot about physical infrastructure, and rightfully so, and that might be just the needs base, right? Mr Ragg : Yes. Ms AMBIHAIPAHAR: But, if we want to also build a community, I think about the soft skills or training people or supporting that next generation. I'm just thinking of that sense, such as more in education or training nurses. Is there space for funding that? CHAIR: David, I can see that you've joined us online and you have your hand up. Did you have a question that you wanted to put to the National Farmers' Federation? Mr FARLEY: Yes, I do, and thank you. I've been online since the start of the meeting via the phone. CHAIR: Oh, I apologise, David. I've only just got a visual on you, so I'll give you the opportunity to introduce yourself to our witnesses, please. Mr FARLEY: Thank you. Good morning. I'm David Farley, the federal Member for Farrer. Have I got an interest in this area? Yes, I have, and I'd like to contribute, so when the opportunity arises, Chair, I would like to contribute some questions. CHAIR: This is that time now, David, so please feel free. Mr FARLEY: I've been listening to the conversation to date and reminisce across my experiences in the Murray-Darling Basin debate, especially over the retraction and take-back of water and what it's done to our communities. I also listen intently in watching residential developments in our larger areas in Farrer, and how they're being interfered with constant rural change. I would like to share some of my experiences that I got out of California, Arizona and New Mexico in regard to this as well. I think the most important thing that I've learned over the years in regard to both the impact of mining and the impact of the buyback of water and the water debates generally, not only in Australia but around the world, relates to the words 'social value,' which we've heard about today, and this is always very hard to put a value on. When you actually look at the value that we should be looking at, it is intrinsic value to communities, and that intrinsic value is quantifiable and does have valuation models that go around it, which are principally developed from the Black-Scholes option modellings that take into account the five important risk measures named after the Greek letters delta, gamma, theta, vega and rho. I refer back the question on Deniliquin: why would you put a hospital there when the population is retracting because of water buybacks? The reality is that the population is retracting because the intrinsic value of water has been removed from the Deniliquin community. The intrinsic value of water was that it created jobs and service industries to the primary industries that were using water. So I think we—and when I say 'we,' I mean the collective around the table—should be thinking beyond social value, which is always very difficult to quantify into dollars, and going back to the capital markets, because that's what's driving these developments of critical minerals, and starting to use the formulas that they use to create their short-term and long-term values attached to it, and then understanding intrinsic value of the community. I am keen to put it on the record that our valuation models on community, in particular, need to be at least understandable in the languages of the capital market and the investment market. Social value isn't one that actually sits inside prospectuses when you read them, but people really understand intrinsic value in the world of capital markets. That's one of my points. CHAIR: David, now that I know you're there online, I again apologise. I didn't realise you were there, but we'll have a chance as a committee to really unpack some of that and explore that in greater detail as a committee when we're formulating our recommendations and finalising the report. We will get a chance to get together, but while we have witnesses today, do you have any other specific questions, because we will have to draw to a close with the NFF at 9.40 am? Now I know you're there, I'll definitely come to you for some questions for our next set of guests who are joining us. Mr FARLEY: Can I squeeze in one last question to the NFF, please? CHAIR: Yes, please. Mr FARLEY: That last question is: we need to have consideration for the landholder, in that they will be incurring expenses on this, whether they've got to get independent consultants in or whether they've got to go to their solicitors and get caveats registered on their title to protect their asset. Any of these applications need to be mindful of the capital investment that the farmer's got to make going forward. Therefore, he should be able to be compensated so that it protects his title into the future. Mr Ragg : Thanks, David. We would agree with that. I'm not sure whether you were online when we talked about, particularly, information asymmetry and ensuring that the individual farmer is as empowered as the proponents to make informed decisions. If that requires co-investment in technical, legal and accounting advice, then that should be the case. CHAIR: I'm just going to intercede here. David wasn't a part of that last hearing. He's only just joined the committee at the last meeting, so he didn't get to hear that evidence. So we can bring you up to speed with some of that evidence as well, David. I know it's very difficult when you come into something a little bit behind. You can't help the fact that you were appointed to the committee yesterday, so you're doing well so far. Thank you very much for that. I would like to thank our witnesses for their attendance today. You haven't been asked to provide any additional information, but you'll be sent a copy of the transcript of the evidence so you can have the opportunity to request corrections to any transcription errors. Thank you sincerely for your time and energy and effort and your submission. I know a lot of effort and resourcing goes into these things, and we do take them seriously, as we also take your evidence and suggestions seriously when we formulate the reports and make recommendations in the hope that they can shape legislation and guidance and regulations moving forward. Mr Ragg : We're available as you get into the nuts and bolts of this. If you want to come back and clarify, we're very happy to have that discussion. We appreciate your time..