Ms Emma Kennedy:

The Senator asked where we got the data. Again, I do not know if she has received the information that we sent in advance. If so, she will be able to see the evidence for the three errors that we talked about and, indeed, all of our analysis. Our data is Irish Water's raw data, perhaps as much as 95%. Irish Water produced umbrella reports that are informed by underlying reports from various experts. The principal report is the Project Need 2015-2050 report. It was an umbrella report that was informed by two separate reports. One report was compiled by a company called Indecon, which was an independent economic adviser to Irish Water, and the second report was compiled by Jacobs-Tobin, which was the engineering adviser. The reports contained more technical data, and tables of numbers etc. That is where almost all of our data comes from and, to the extent that it is not, it is from other publicly available sources. None of it is data that we have generated ourselves. It is all data that is either out there or that Irish Water has put out there.

Senator McFadden made the point that there is more to the country than Dublin. Of course there is. Our focus is very much just this project. The key focus of this project is the greater Dublin water supply area. I think the Senator referred to the benefit corridor concept. This project has lasted for 22 years. In 2015, the time that the Project Need report was produced, the concept of a benefit corridor was introduced. The details provided at the time of the report on the benefit corridor were extremely scant and incomplete. At the time there were tabular statements provided that literally showed question marks or had the words "not yet available" written into the columns in the tabular statements. The details were inadequate. In our view, there were errors in the analysis that was undertaken for the benefit corridor. For example, a huge amount of work was undertaken to calculate the water deficit for the greater Dublin water supply area. They asked themselves how much water people in the area need, how much water is available for supply and what will be the deficit. On the other hand, the amount of analysis done on the benefit corridor was incredibly scant and literally amounted to a couple of pages. Instead of looking at a deficit the question asked was what will the total water demand be for the entire area. A number was produced, adding the demand number to the deficit number, which is like trying to add apples and pears. It is mathematically invalid to conclude that 330 million l of water per day is needed.

Interestingly, I wish to again refer to the two advisers, Indecon and Jacobs-Tobin, and how to handle the benefit corridor at that time was one of the issues on which they disagreed. Indecon believed that one needed to take account of water in the area. That, combined with their approach to non-domestic demand, resulted in two very different conclusions. Indecon concluded that the need for the greater Dublin water supply area, combined with the benefit corridor, on their base case scenario, was 207.5 million l per day. Jacobs-Tobin, for exactly the same area, concluded that it would be 330 million l per day. Let us compare the Indecon figure of 207.5 million l per day, having used the same data but looking at it differently, with the Jacobs-Tobin figure of 330 million l per day. A key driver was how can one analyse things connected with the benefit corridor.

I am certainly not Dublin-centric by any means. I am just looking at what this project is about and that has been my focus. Does that answer all of the Senator's questions?