Oireachtas Joint and Select Committees
Tuesday, 16 December 2014
Joint Oireachtas Committee on Agriculture, Food and the Marine
State Aid to Fishery and Aquaculture Sector: Department of Agriculture, Food and the Marine
I welcome Mr. Paschal Hayes, principal officer, and Mr. Damien Clarke, assistant principal officer from the marine agencies and programmes division at the Department of Agriculture, Food and the Marine. I thank them for coming before the committee today to brief it on the new guidelines for examination of state aid to the fishery and aquaculture sector. I apologise for the delay. Unfortunately, a vote was called in the Seanad and a quorum requires at least one Member from each House so we could not commence the meeting at 2 p.m. as planned.
I remind witnesses that by virtue of section 17(2)(l) of the Defamation Act 2009, they are protected by absolute privilege in respect of the evidence they give to the committee. However, if they are directed by the committee to cease giving evidence in regard to a particular matter and they continue to do so, they are entitled thereafter to only qualified privileged in respect of the evidence they give. Witnesses are further directed that only evidence connected with the subject matter of today's proceedings is to be given and are asked to respect the parliamentary practice to the effect that, where possible, they should not criticise or make charges against a person or entity either by name or in such a way as to make him, her or it identifiable. I remind members of the long-standing parliamentary practice to the effect that they should not comment on, criticise or make charges against a person outside the House or an official either by name or in such a way as to make him or her identifiable. I now invite Mr. Hayes to make his opening statement.
Mr. Paschal Hayes:
As members know, the European Commission, DG MARE, has launched a public consultation on its draft new guidelines for the examination of state aid to the fishery and aquaculture sector. The consultation runs until 20 January 2015. The objective of the consultation is to collect stakeholder views on the draft guidelines. The Commission has previously sought member states' views on state aid earlier this autumn through its advisory committee, on which the Department of Agriculture, Food and Marine was represented.
The new guidelines are intended to replace the present guidelines of the same title, which have been in force since 2007. Under the treaties, the Commission is responsible for considering state aid notifications and, as such, the Commission will make the final decision on the wording of these guidelines and on how they will perform that task. The new guidelines will set out the principles that the Commission will apply when assessing whether proposed aid to the fishery and aquaculture sector can be considered to be compatible with the internal market. The guidelines apply to all state aid granted by member states to the fishery and aquaculture sector that has been notified, or should have been notified, to the Commission in accordance with the treaties. The Commission is moving to update the current guidelines in order to regularise references to legal acts mentioned in the guidelines, thereby aligning them with the Commission's state aid modernisation initiative, the reformed Common Fisheries Policy and the European Maritime and Fisheries Fund regulation.
State aid rules for the fisheries and aquaculture sector differ from the rules applying generally to other areas of the food industry. The Commission's proposed new guidelines should be viewed as part of a broader legal framework for state aid to the fisheries and aquaculture sector. That broader legal framework includes four elements: the European Maritime and Fisheries Fund regulation; the de minimisregulation for the fisheries and aquaculture sector; the fisheries block exemption regulation; and these guidelines for the examination of state aid to the fishery and aquaculture sector. It is important to note that these are essentially a form of cascade where a proposed support measures for the seafood sector will generally only be notified to the Commission through a state aid notification if it is not possible legally to implement that measure through one of the other three options.By way of example, during the last EU funding round from 2007 to the present, it has not been necessary to submit a state aid notification to the Commission for any of the many schemes implemented in Ireland to support the development of the seafood sector. The guidelines come into play only when it is necessary to submit a state aid notification.
I will very briefly explain the nature of each of the four instruments. The European Maritime and Fisheries Fund, EMFF, regulation is undoubtedly the most important. The EMFF is one of the four European structural and investment funds together with the European Regional Development Fund, the European Social Fund and the European Agricultural Fund for Rural Development. Together, these European Structural and Investment Funds are intended to support measures to address the EU 2020 strategy. The EMFF is intended in particular to support the new Common Fisheries Policy, CFP, and is considered the financial instrument of the CFP.
The EMFF is solely concerned with measures that are co-funded by the EU. It does not have anything to say about measures funded solely by the Irish Exchequer. The majority of measures implemented through the EMFF do not require state aid notification. They are considered to automatically comply with state aid rules. There are two exceptions which are not covered by this exemption: support to fishery local action groups and supports under the Integrated Maritime Policy both of which are provided for in the EMFF regulation. These two measures are excluded from the state aid notification exemption that generally applies to EMFF measures as they are outside the CFP. However, they may potentially be covered by non-fisheries block exemptions. That remains to be examined but in any case those measures are also outside the scope of these guidelines, again for the same reason they are not covered by the CFP.
The Minister is preparing a new seafood development programme, SDP, for the period 2014 to 2020 to implement investment in the seafood sector with co-funding from the EMFF. The committee will have seen previous announcements from the Minister as part of budget 2015 announcing that the new SDP will have total funds of €241 million, of which €146.7 million is from EU funds and €93.9 million is from the Irish Exchequer. The new SDP will include a range of investment measures to encourage and foster the further sustainable development and growth of our seafood industry, including aquaculture, processing, the fishing fleet and coastal communities. Some €142 million of the SDP funds will go towards this core sectoral development purpose, which is more than twice the €66 million available under the previous programme, which was the European Fisheries Fund. The SDP will also directly fund €46 million in new investments to support our capacity to enforce the rules of the CFP and a further €41 million to fund the science that supports our fisheries management together with €11 million for implementation of the new EU Integrated Maritime Policy and €1.3 million for storage aid supports. The Government has made available €15 million in 2015 to commence investment measures under the new SDP and this will rise significantly in following years as the programme is fully rolled out.
The second measure is the de minimisregulation. A new de minimisregulation for the seafood sector was adopted by the Commission in June 2014. The so-called fisheries de minimisregulation is concerned solely with measures funded by the Exchequer. Measures implemented through de minimisare not considered state aid. The fisheries de minimisregulation provides wide scope to member states to provide nationally funded supports to enterprises in the seafood sector up to a maximum of €30,000 per beneficiary and up to €20.8 million nationally over a rolling three-year period and subject to certain exclusions specified in the regulation. While the €30,000 cap restricts its usefulness somewhat, it is a very useful instrument for smaller interventions that are not permitted under instruments such as the EMFF or the fisheries block exemption regulation.
BIM implements its fleet safety grants through de minimisas these are not eligible under the EMFF or its predecessor, the European Fisheries Fund, nor under the block exemption. BIM also implemented the pot replacement scheme earlier this year through de minimis, while Enterprise Ireland uses it to implement its marketing assistance programme for seafood companies. A separate general de minimisregulation applies to the food sector generally, excluding seafood, and this has a significantly higher cap of €200,000 per beneficiary. The significant difference in the cap applying to food companies in different sectors has been highlighted by Enterprise Ireland and Bord Bia as a difficulty. However, the Commission is not open to increases in the cap on the fisheries de minimis.
The third regulation is the fisheries block exemption regulation. The fisheries block exemption regulation or so-called FIBER is concerned solely with measures funded by the Exchequer.
Like the guidelines at present and the fisheries de minimisregulation earlier this year, the fisheries block exemption regulation, FIBER, is being revised by the Commission and the new instrument is expected to be adopted before the end of 2014. The new FIBER closely mirrors the European maritime and fisheries fund, EMFF, regulation. It allows member states to provide supports to the seafood sector based on the measures included in the EMFF and subject to the rules specified in the EMFF, without EU co-funding. This is useful where a member state wishes to implement particular EMFF measures, but has insufficient EU co-funding to cover all of the measures it may wish to implement. Measures implemented through FIBER generally do not require state aid notification. I say generally because there is an exception where aid exceeds €1 million to an individual beneficiary.
In a departure from the previous FIBER, the draft new FIBER allows block exemption of measures to assist the seafood sector with the impacts of natural disasters. The draft regulation defines "natural disaster", inter alia, as floods, tornadoes and hurricanes. The Commission’s definition is taken from the existing EU legal definition of natural disasters, so while it is a useful addition, it is questionable whether it would have applied to the storm events we experienced earlier this year.However, the draft FIBER mirrors the EMFF provision which allows for a state contribution to a mutual fund for adverse climatic events. That provision is broad in nature and would cover similar storm events as we experienced this year.
Fourth, I will deal with the guidelines for the examination of state aid to the fishery and the aquaculture sector. It is when a proposed measure is not covered by the other three instruments that a state aid notification is required. Only in that situation do we need to have regard to the new proposed Commission guidelines in designing a proposed new scheme and in drafting the state aid notification for it. The guidelines set out the principles by which the Commission will assess such state aid notifications. While the guidelines are quite detailed, they can be summarised as setting out certain principles that are common to all economic sectors and additional principles that are specific to the seafood sector. The general principles common to all sectors include: contribution to a well-defined objective of common interest; need for state intervention; appropriateness of the aid measure; incentive effect; proportionality of the aid; avoidance of undue negative effects on competition and trade between member states; and transparency of the aid. The additional principles specific to the seafood sector relate to the Common Fisheries Policy and the EMFF. These include: exclusion of operators who have infringed CFP rules, a similar rule exists in the EMFF regulation; a Commission delegated act will specify the waiting periods appropriate to particular types of infringements; a requirement to repay aid if an infringement of the Common Fisheries Policy rules happens after payment of aid; any aid measure similar to one described in the EMFF regulation must comply with the rules applying under the EMFF; measures ineligible under the EMFF regulation will not be permitted; and a proposed aid measure must identify how exactly it will contribute to the general and specific objectives of the Common Fisheries Policy.
Aside from these principles, which are the core of the guidelines document, the remaining notable element of the proposed new guidelines is the specific recognition they give to natural disasters, to so-called "exceptional occurrences" and to so-called "adverse climatic events". Natural disasters or exceptional occurrences must have been formally recognised as such by the member state. Natural disasters are defined somewhat to include exceptionally severe storms and floods, tornadoes and hurricanes among other things. Exceptional occurrences are defined somewhat to include war, internal disturbances, strikes, major industrial and nuclear accidents, and fires resulting in widespread loss. A very widespread outbreak of a new animal disease may be accepted by the Commission as an exceptional occurrence. Aid related to these natural disasters or exceptional occurrences must relate to the costs of the damage incurred to assets or loss of income arising from destruction of production or means of production. Separately, the guidelines indicate that the Commission may accept as compatible with the treaties aid to make good the damage caused by "adverse climatic events". This separate classification is somewhat defined as including storms, gusts of wind causing exceptionally high waves, heavy and persistent rainfall, floods, and elevated water temperatures over a long period. The bar is set higher in relation to these types of events in terms of eligible costs. The damage caused must amount to more than 30% of the average annual turnover of the operator concerned in the preceding three years. These provisions appear to be useful, particularlythose relating to adverse climatic events. Given our experiences earlier this year with a series of exceptionally severe storms, we may potentially need to make use of them in the future.
With regard to the next steps, the Commission proposes to apply the new guidelines from 1 April 2015. The Commission will be requesting that each member state adapt its existing aid schemes to these guidelines by 30 September 2015 and to give its agreement to this adaptation process within two months of the publication of these guidelines. At present we cannot foresee any difficulty with giving such an agreement, or in adapting our schemes to the guidelines. All existing measures are covered by either the European fisheries fund regulation, the fisheries de minimisregulation or the FIBER. The EMFF, de minimisand FIBER regulations provide sufficient scope for foreseen future measures, with the exception of the measures concerning fisheries local action groups, FLAGs, and the integrated maritime policy, IMP, to which I alluded earlier. We will be examining the state aid situations of measures relating to the FLAGs and the IMP in the coming months with regard to other non-fisheries block exemptions and, if necessary, we will submit a state aid notification. We do not foresee those measures having any difficulty in securing Commission state aid approval, given that they are provided for in the EMFF regulation and will likely be implemented in all member states.
I thank Mr. Hayes for his presentation. He mentioned that 20 January is the deadline for submissions from stakeholders. I presume the Department has made a submission based on what he said when it was asked for its views from the Commission in the autumn. Can Mr. Hayes share with us what was the Department's opinion? Are the submissions from the stakeholders, who would include more than likely those in the industry, being made via the Department or directly to the Commission? Has Mr. Hayes any idea of the number of submissions made and what they may reflect? Obviously, they would relate to the de minimis regulation and that affects every element of state aid rules, whether it be funding through the IDA, Enterprise Ireland or any of the funding streams from Europe, and there is nothing new in that. The new element is the increase in funding from Europe under the seafood development fund and there will be a knock-on consequence to have an increased fund available from the Department as well. In terms of the economic benefit of the fund over the lifetime of the programme, has any analysis been done of a breakdown of where the money will be spent, in other words, the sectoral elements of spend and the beneficial consequences of it in terms of the growth of the industry?
The aquaculture sector is one of the strands that can be funded from the programme. In light of some of the concerns of local communities around the country, how will they fit in with the funding mechanisms? If there are local concerns, they will have to feed into the mix of funding programmes based on business plans alone. Will a social cost benefit analysis be carried out on the unintended consequences, given that it is set out in the 2013 public spending code that social benefit analysis must be taken into consideration as well? Presumably, there would have to be some level of awareness and some way of building the social concerns of communities into whatever funding is made available.
For example, in Galway, Donegal and Mayo, where there are plans to develop salmon-farming facilities off the coast, there have been suggestions, whether scientifically proven or not, that these enterprises could be to the detriment of local communities. Will those types of social costs be taken into account when it comes to deciding how the funding should be used? Where investment comes from private sector interests, including multinational organisations, the main concern, at the end of the day, is their own stakeholders, who are the shareholders of the company. Their bottom line is profit.
There are issues to be addressed in terms of how these proposals can be implemented in a beneficial way while ensuring the concerns of local communities are not diminished. There are genuine concerns about how this money will be spent if it does go towards aquaculture. The State, which should have the best interests of citizens and local communities at heart, needs to be very much aware of this. There is a lot of money to be made in the sector. Salmon farming is one of the cornerstones of what the Minister is driving in terms of the seafood element of Food Harvest 2020 and his efforts to develop outputs. At the same time, we must be very much aware of the consequences that go along with that. I might be going off on a tangent, but it is very much related to how the money is spent. Europe will have an eye on that and we may well see complaints from local communities to the European Commission in regard to how the money is carved up. Perhaps the delegates might enlighten us as to whether there has been any discussion with the Commission on these matters, particularly regarding the aquaculture element of the seafood development programme.
I thank Mr. Hayes for his presentation. He indicated that the object of the consultation is to collect stakeholders' views on the draft guidelines. I assume, therefore, that the guidelines are not yet signed off and are still up for negotiation?
Are the submissions the delegates have received from the Department, the joint committee and other parties compatible with the new guidelines as recommended in this paper?
Will the delegates comment on the implications of these proposals for inshore fishermen? I am very concerned about the availability of funding for that sector.
Mr. Hayes referred to the pots replacement scheme. According to my information, that scheme turned out to be an absolute disaster because the criteria attaching to it were too strict. People were required, for example, to produce receipts for lost pots that may have been purchased several years previously, which was impossible for some to do. Applicants also had to produce evidence they were selling fish during the relevant period.
Mr. Hayes mentioned that in the case of damage caused by natural disasters, these provisions will apply only where the damage amounts to more than 30% of the average annual turnover of the operator concerned in the preceding three years. Do the delegates consider this a high threshold in order to claim any type of compensation or support? I know small operators who lost everything as a result of storm damage earlier this year. I am afraid 30% of their turnover for the previous three years would go no way toward getting them up and running again.
Mr. Hayes indicated that the proposal is for €142 million of the seafood development programme funds to go towards sectoral development, with €46 million going to new investments to support the enforcement of the rules. How is it envisaged that this funding will be allocated? Will an existing body such as the Sea-Fisheries Protection Authority be given a remit in this regard?
I thank Mr. Hayes for his presentation. I am trying to get my head around these guidelines in terms of how and to which types of funding they will apply. It seems from the presentation that anything under the European Maritime and Fisheries Fund and the fisheries block exemption regulation is not covered by these state aid guidelines. Therefore, I presume it is only state funding outside any of those regulations to which these particular proposals would apply. Under the previous guidelines, no applications were made by the State to waive the state aid rules in this regard. Do the delegates foresee any such applications being made in the future under these guidelines?
Deputy Ferris referred to compensation for operators impacted by storm damage. Mr. Hayes referred to various terms contained in the proposals such as "adverse climatic events", "natural disasters" and "exceptional occurrences". I understand that natural disasters are already mentioned in the treaties. Is the notion of "adverse climatic events"something new that is being added? I am wondering what is the rationale for setting two different qualifications separate from the treaty element. Does Mr. Hayes see an opening to ease these criteria in some way to make them more beneficial for fishermen? In the light of the effects of adverse weather earlier this year, it would be helpful if the State could make better provision for those affected rather than having to keep it under the de minimis rules.
Mr. Hayes also referred to "elevated water temperatures over a long period" in the context of the proposals regarding adverse climatic events. Might these provisions cover fish farmers whose stock is affected by amoebic gill disease, which is caused by high water temperatures, thereby making them eligible for some degree of state aid?
My final question concerns what will actually constitute the state aid. In the case, for instance, of studies that have taken place on the proposed fish farm off the Aran Islands, would that constitute state aid and would it come in under these guidelines?
Before calling Senator Ó Clochartaigh, a question occurs to me arising out of one of the points raised by Deputy Pringle. In the case of the exception concerning fishery local action groups and the integrated marine policy, does that apply only where there is a co-funding element as opposed to exclusively state-funded initiatives?
Most of the points I intended to raise have been already touched on by colleagues. Regarding the pots replacement scheme, could that scheme have gone further under the previous rules? Did the Government have scope, for example, to cover loss of earnings, damage to vessels and so on? Or is that what is envisaged under the new guidelines such that, if we had a similar occurrence this winter, a scheme could be put in place which would consider those elements?
A number of fishermen informed us that the replacement of pots was only one element of the support they required.
One of the sub-committees has been studying the potential for multitrophic aquaculture development, which involves shellfish, seaweed and fish farms working in tandem in an integrated manner. We have been told that while the technology required to achieve this type of set-up is still a little way off, it is a possibility. A pilot study on the issue has been mooted. How would multitrophic aquaculture sit within the draft guidelines, which appear to cover different types of investment from different areas?
There is a significant backlog in aquaculture license applications because the bays are still being surveyed. Notwithstanding the various regulations, resolving this backlog will be necessary before much of the potential investment in these areas can proceed. How do these two competing forces, which are stifling the development of the industry, sit together?
Mr. Paschal Hayes:
I will deal first with the question on fisheries local action groups, FLAGs, because it requires clarification. As the issue with FLAGs is not a Common Fisheries Policy initiative, it is not automatically exempt from state aid. That is not to say that we will need to make a notification or that there will be any difficulty in funding FLAGS. However, we must examine other regulations in place to ascertain whether FLAGs can be funded without a state aid notification. In the event that we find a difficulty in this respect, we will submit an application for state aid to funding FLAGs. We do not envisage any difficulty arising in allowing FLAGs to be funded.
The Department was involved in committees at which this draft was initially discussed. We have asked the agencies that deal with grant aid to the fishing industry, for example, Bord Iascaigh Mhara, BIM, and Enterprise Ireland, for their opinions on the draft and requested that they revert to us by early January. We will make a decision at that stage on whether the Department needs to make a submission as part of the consultation.
Senator Ó Domhnaill asked about stakeholder submissions. As the consultation is public, anyone can make a submission, including individual fishermen, producer organisations and anyone else. Everyone is entitled to make a submission on foot of the call for submissions made by the European Commission.
The Senator discussed the funding options in respect of the European Maritime and Fisheries Fund, EMFF. While that is probably a different discussion, I will provide an update on the EMFF programme and the process involved in it. We had a number of consultations with a broad range of stakeholders, namely, the stakeholders we had in place for the current programme, the European Fisheries Fund, with some additions. We also had a number of bilateral meetings with other State agencies on their requirements. An operational programme is being drafted and will set out priorities for spending this money and the measures that will be implemented under the programme. It must go through a series of steps, including a public consultation, which will take place early next year, at which point everyone will have an opportunity to feed into the process and make known their views.
Deputy Ferris asked about the recommendation of the committee in respect of his report. I hope my response on the FLAGs addressed his concern.
I will provide some figures on the pot replacement scheme which may not have been available heretofore. The current position is that a total of €308,000 has been paid to 128 claimants by Bord Iascaigh Mhara, the organisation administering the scheme. BIM has recognised there is a difficulty with people accessing funding to buy pots and is giving them an opportunity to get to that stage. It is anticipated that the number of pots replaced may increase, with an estimated 13,000 lobster and crab pots and 2,700 shrimp pots being replaced by the time the scheme finishes.
Mr. Paschal Hayes:
That is very difficult to determine because we do not know what was the loss, in other words, we do not know how many pots were lost in the storm events. The call was put out for applications from anyone who had suffered losses of pots in the adverse weather conditions. We can only assume that anyone who suffered losses submitted an application.
The threshold of 30% turnover seems to be causing a little confusion. This is a bar that applicants must get over, which means that losses must be greater than 30% of average turnover in the preceding three years. It does not mean that grant aid will be limited to 30% of their turnover in the past three years. The thinking behind the threshold is that the loss must be significant and preclude people from seeking compensation for a small loss suffered. The test for significant loss is that it should be greater than 30% of average turnover in the previous three years.
On control and enforcement, the funding in this area is for our control and enforcement services, namely, the Sea-Fisheries Protection Authority, Naval Service and Air Corps. These are the agencies that already carry out this activity and it is not intended that a new organisation would be established. The funding is to finance the activities of the control and enforcement authorities.
I hope I answered Deputy Pringle's question on the 30% threshold.
As to whether we foresee any applications, while we do not expect applications at this stage, we are still in listening mode. As I indicated, we are consulting our agencies to ascertain whether they foresee any difficulties with it. As the Deputy correctly pointed out, we did not make an application under the previous programme, which ran from 2007 until the present day. At this point, we do not foresee circumstances arising in which we would have to make an application. That said, we are still open to any scenario that people may wish to highlight.
Mr. Damien Clarke:
I acknowledge that it is strange to have a number of different categories. One sees a pattern running through the different state aid instruments to which Mr. Hayes referred. The European Maritime and Fisheries Fund includes references to adverse climatic events and tools that are in place to deal with that specific scenario. Similarly, the block exemption includes both the adverse climatic events and natural disasters categories. The latter are defined by reference to existing instruments such as the general de minimusand block exemption regulations in which they are defined, as well as European Union case law. The adverse climatic events category is of much more interest to us as it is much more likely to be useful to us. Natural disasters refer to events such as tornados or hurricanes. God forbid, that we will ever have those types of events in Ireland. The adverse climatic events category is much more relevant, for example, in respect of the storms we experienced earlier this year. The Commission's thinking appears to be that because these types of climatic events are much more likely to occur, the bar should be set higher. The obvious reason for imposing a 30% loss threshold is that one cannot have claims being submitted annually or as a matter of routine because the intervention would cease to be for exceptional events.
It does seem to be a high loss threshold and it is an issue we raised ourselves in previous discussions with the Commission. Many member states would have liked to have seen it perhaps a little lower. However, the Commission's view on that was that it could not legislate or make new legislation. It is there to implement it. It is looking to what the co-legislators have already said in the EMMF, and that 30% threshold is built into the EMMF by the co-legislators. For that reason, the Commission is essentially implementing the same policy in these guidelines.
Mr. Damien Clarke:
I would not categorise it as that. It is there for when people suffer very significant losses. Our thinking is that we are much more likely to use the mutual fund approach, which is set out in the EMMF regulation. The Minister is already on record as being minded to make allowance for that in the new programme. It is a much more flexible instrument that could potentially deal with the kinds of storms we saw earlier this year.
Mr. Damien Clarke:
It is difficult to say. These are the Commission's guidelines so, like the committee, we are trying to interpret them. Potentially that is something at which it is aiming. There are also existing provisions in the EMMF for aquaculture stock insurance and so on - measures which are specifically designed to deal with disease outbreaks, compensation for bio-toxin outbreaks and so on. There are, therefore, a number of potential tools in the EMMF. It is probably unlikely, for that reason, that we would ever need to resort to the guidelines and a state aid notification for that kind of event.
Before we conclude, is the Department making a submission or is it just in negotiations? From the committee's point of view, we need to know whether we need to make a submission. The one that stands out is the differential and why the commission is not open to increasing the fisheries de minimiscap from €30,000 to €200,000. From a general perspective, would it be an addition if the committee were to make a separate submission? This would be one of the things we would highlight.
Mr. Paschal Hayes:
The current position on the consultation process is that we are still consulting with the relevant agencies and, hopefully, in early January, we will see if they have anything to bring forward. As things stand, we do not see a need to put in a submission. However, this will depend on what our agencies say to us. The €30,000 cap is in the de minimisregulation rather than in the one that is out for consultation at the moment. The de minimisregulation has been already adopted. Even though we put forward a case on behalf of Ireland, as did other member states, that the cap should be higher - that was in the spring of this year at the meetings on the de minimisrule - the Commission was not for moving on it. In answer to the Chairman's question on this particular consultation, the €30,000 de minimiscap would not be part of it.
Are the members satisfied? We will decide whether to make a submission. We will take a further look at the briefing note and consider the answers to the questions during this session. I thank the witnesses for coming today. I will suspend the meeting to allow the witnesses withdraw.