Mr. Greg Ennis:

I understand that there are only three or four barristers who are on top of this business. To get opinions on five or six issues could cost €10,000. It depends on the consultations. The point about the length of a piece of string is correct. As to scoping out, there are a number of things we would look for. We would look for the contribution rates and the statutory instruments governing the schemes, the legality of the CIÉ pensions rationalisation agreement of 1994, the legal significance of the Omega Pharma case and its potential implications on this, potential conflicts of interest, and the 2009 document contained in appendix 1 of my submission. We would like to have all of those perused. That is by way of starters and my colleagues may have other issues they would want to add to the list, but they are, at least, core issues.

This is a situation in which, without a by your leave to the trade union group, proposals were put to the Pensions Authority in 2013 which do not include pay increases. As such, this problem is going to get worse. The second point is that for some reason which is unknown to us, the 2009 recommendations of the actuary with regard to what was needed were not delivered on. We argue that they were in compliance from 1994 right up to 2009 and then, all of a sudden, they said they would not put in the amount of money the actuary recommended was required. We have now been ten years without that contribution and the hole is getting bigger. Pensioners have a legitimate and reasonable expectation according to CIÉ itself, as in my appendix 1, to see pay parity and pensions in payment increase over time. They have not had that for ten years. We have the 900 or so people in the 1951 scheme who have no other income on retirement except this. It is a critical issue.