Select Committee on Environment, Transport and Regional Affairs Appendices to the Minutes of Evidence
Memorandum by NUMAST (FUS 1)
THE FUTURE OF THE UK SHIPPING INDUSTRY
— Britain's merchant navy has suffered an unparalleled decline during the past 20 years.
— The future supply of British maritime expertise is seriously jeopardised.
— The loss of British shipping and seafaring skills has profoundly adverse consequences for an island nation in which 95 per cent of trade goes by sea.
— There are strong economic, employment, environmental and strategic arguments to support action to end the decline.
— British shipping has immense potential to help achieve the objectives of the Transport White Paper.
— Clear consensus and unity exists within the industry on the measures required to end the decline.
— Most other major maritime nations have adopted packages to support their shipping industries, with tangible national benefits accruing as a result.
— International trends present important and potentially vast opportunities for the development of the British shipping industry and of UK maritime training.
NUMAST is the trade union and professional organisation representing more than 18,500 ship masters, officers, cadets and other professional staff in the shipping industry.
Over the past two decades, Britain has suffered a devastating decline in its merchant fleet. For more than a century, the British merchant navy was the world's largest and 50 years ago British-registered tonnage represented more than 22 per cent of the world total. Today, British owned and registered tonnage accounts for less than 0.3 per cent of the world total and the red ensign fleet has slumped to 30th place in the world league table.
Similarly, the past two decades have witnessed a drastic decline in British seafarer numbers. Total employment of British seafarers onboard British registered ships has fallen from 87,000 in 1975 to less than 17,000 in 1995.
For an island nation, that still relies on shipping to carry more than 94 per cent of its international trade, these statistics should be of the utmost public and political concern.
NUMAST therefore welcomes the Transport Sub-committee's decision to stage an inquiry into the future of the UK shipping industry at this crucial stage in the industry's long and proud history.
3. WHAT ACTION AND PARTNERSHIP IS REQUIRED OF THE INDUSTRY AND GOVERNMENT TO DEVELOP A SUSTAINABLE, INTERNATIONALLY COMPETITIVE SHIPPING INDUSTRY?
The decline of the British shipping industry stands in stark contrast to the state of the international industry. While the red ensign fleet has shrunk, in tonnage terms, by more than 95 per cent since 1976 the international merchant fleet has grown to a record level of more than 760 million dwt and over the last year alone registers such as Panama (up 7.8 per cent), Singapore (up 16 per cent), Bermuda (up 24 per cent) and Germany (up 35 per cent) have continued to record significant growth.
Shipping, therefore, is by no means a sunset industry. More than 95 per cent of world trade is moved by shipping and the volume of international seaborne trade has grown year-on-year by more than 22 per cent over the past decade. UNCTAD forecasts an average annual growth of 3.9 per cent in the coming decade.
At the same time, the international shipping industry is experiencing regulatory and commercial pressures to place a new emphasis on quality operations, creating substantial demand for well-run and efficient ships and highly trained and experienced seafarers. Britain—with its long maritime history, world-renowned maritime expertise and a small but specialist shipping fleet—could reap substantial benefits from these developments.
To secure a share of this global market, British ships and seafarers need to be able to compete on an equal footing with foreign counterparts. British shipping is squeezed on two sides: from other traditional maritime nations who provide varying levels of support for their shipping interests and from flag of convenience registers offering substantial savings through minimal adherence to international regulations and the use of low-cost labour from developing nations. Research conducted by the OECD on the latter shows that the operating practices permitted under such regimes can enable shipowners to more than halve their costs.
Over the past two decades, the vast majority of developed nations have adopted packages to promote their shipping industries and the employment of their seafarers. Measures adopted include: the reservation of certain trades to domestic-flagged ships; operating subsidies; investment incentives; preferential tax regimes; "second" registers; tax and social cost exemptions for seafarers; and training support for seafarers.
There are many examples to illustrate the success of such strategies, but perhaps the most relevant to the UK situation is the experience of the Netherlands. Until the early 1990s, the Dutch-flagged fleet had suffered a fairly severe decline. However, following research showing that the Dutch maritime sector generated some £5.2 billion a year (equivalent to 2.7 per cent of the country's GNP) and provided jobs for around 120,000 people, a support package was introduced in 1996 that attracted more than 110 ships to the register within 18 months and led to 40 companies either expanding or establishing their shipping activities in the Netherlands.
Although the 1992 Joint Working Party report "British Shipping: Challenges and Opportunities" described the industry as "a vital national asset", Britain—in contrast to most other major maritime nations—has for much of the past two decades adopted a largely "hands off" approach to its shipping industry. Indeed, during the 1980s certain support measures were actually removed. In an international industry, it is imperative that Britain—if it is to retain any significant presence—responds to the regimes adopted elsewhere and enables its ships and seafarers to compete on a reasonable basis.
Specifically, the UK shipping industry requires a fiscal regime that is at least comparable with major competitors. Evidence shows that the fiscal system in Britain is the least conducive to investment in shipping of nine other major European maritime nations. This is of particular concern now that the average age of the UK fleet is well above that of the world fleet and also because the volume of tonnage on order for UK registration now amounts to only 1.3 per cent of the world total, compared with 4.5 per cent in 1979. If British owners are not given the climate in which to invest in new, efficient and technologically advanced tonnage, the competitive disadvantage of the UK merchant fleet is likely to be further exacerbated and the decline will intensify.
All sides of the UK shipping industry are united behind a request for the introduction of the tonnage tax scheme, along the lines of those successfully operated in the Netherlands, Norway, Greece and Germany. Together with an improved depreciation regime for investment in new shipping, this would ensure a tax system that not only matches foreign competition but also better reflects the fiscal realities of the present-day shipping industry.
NUMAST considers it is very important that any initiatives have a direct and transparent linkage with employment and training. Proposals submitted to the government's shipping working group demonstrate the unity between employers and the maritime unions on this issue.
4. THE BENEFITS OF ENCOURAGING UK SHIP REGISTRATION, THE EXTENT AND IMPLICATIONS OF "FLAGGING OUT", AND THE SPECIFIC POSITION OF THE ISLE OF MAN REGISTRY
The benefits of encouraging UK ship registration are profound. Research by the business information group Douglas Westwood showed last year that UK marine industries have an annual turnover of £46 billion, generate exports worth £12 billion, and sustain more than 782,000 jobs. Just over 4.7 per cent of UK GDP comes from marine-related industries and services and maritime-related employment represents 3.6 per cent of the UK workforce. Marine industries and services—including shipping—make a bigger contribution to the national economy and employment than, for example, the financial sector.
However, as the UK shipping industry declines, so does the UK's international maritime status. Other countries provide evidence of the way in which shore-based maritime industries and services suffer as a result of a decline in national shipping activity, underlining the fact that domestic maritime infrastructures are inherently linked to the state of the national merchant fleet and maritime expertise.
With the development of new maritime centres, such as Hong Kong, Singapore, Cyprus and Vancouver, Britain's traditional leading role in the provision of such services as shipbroking, classification, insurance, management and equipment supply is becoming increasingly jeopardised through a challenge that must be fought off if we are to retain our international influence.
While shipping continues to make one of the largest sectoral contributions to the UK balance of payments, that contribution has been halved in real terms since 1980 and continued decline of the fleet at present trends (particularly in the high revenue earning ferry sector) could reduce earnings by around one-third, in real terms, over the next decade. The loss of City-based maritime services would add significant additional damage to the national economy.
The benefits of encouraging domestic shipping were underlined by US research in 1997, which showed that the cost of running the country's cargo preference scheme was more than offset by the increased revenue arising through employment and foreign exchange benefits. With less than 1.4 per cent of the world fleet, British-owned shipping still manages to account for around four per cent of global shipping earnings and even a marginal increase in this share (particularly at a time of increasing international seaborne trade) would have significant national economic impact. At present, just a one per cent increase in the UK's share of the world shipping market would add around £1 billion to gross invisible earnings.
However, with 78 per cent of British-owned shipping now operating under non-UK flags it is important to stress the value of maintaining an adequate domestic merchant fleet to offer full choice to domestic shippers, for security of trade, and to ensure a firm degree of domestic control over the shipping carrying our trade and passengers and operating in our waters. It should be of the utmost concern that the vast majority of British seaborne trade is now carried on foreign flagged shipping—with disturbingly high levels onboard flag of convenience tonnage, operated to minimal levels of safety and operational standards. While the UK fleet, despite its additional average age, continues to boast one of the world's best safety records, many of the ships operating in our waters sail under registers with tonnage-loss ratios as high as 40 times in excess of flags such as the UK. In recent years, around one in every 10 foreign ships checked in UK port state control inspections have been found to have so many defects that they have had to be detained. Disasters such as the Braer and the Sea Empress have highlighted the immense environmental and economic impact that may arise from maritime accidents and underline the need to promote the highest standards of safety through maintaining our own merchant fleet and a strong pool of domestic maritime expertise.
Furthermore, as British shipyards and marine manufacturers rely on UK shipping for around 50 per cent of their business, the interdependence of the various sectors of the UK maritime economy must not be ignored.
The spectacular growth in recent years of the Isle of Man register makes an interesting contrast to the drastic decline of the UK mainland register. Indeed, in recent times it has actually overtaken the mainland register in tonnage terms as a result of concerted efforts to attract foreign shipowners. However, although the register has provided a degree of employment opportunities for British officers and ratings, the proportion of British seafarers employed is markedly less than on mainland registered ships and the UK training and employment links have been steadily diluted as increasing numbers of foreign owners have transferred tonnage to the register. It is, as the Chamber of Shipping has pointed out, the ships that are owned and operated in the UK that represent Britain's true shipping interest and which make the full contribution to employment and the UK economy. The closer those ships are to the UK, not least in terms of registration, the more direct the national benefits appear to be.
Although the Isle of Man has been viewed as a form of UK second register, there appears never to have been a conscious political programme to develop it as such. The initial development of the register came from British owners transferring from the mainland register and its genuine connections with the mainland are now often tenuous—with any accruing benefits to the overall UK maritime infrastructure falling short of those that would arise from mainland flag operation.
5. THE CONTRIBUTION THAT SHIPPING CAN MAKE TO ACHIEVING THE OBJECTIVES OF THE TRANSPORT WHITE PAPER
The role of shipping in delivering environmentally-sound transport policies has been seriously neglected over the past two decades. There has been a marked absence of policies to encourage the use of waterborne freight, so that the proportion of domestic trade being carried on water (just 7 per cent) lags well behind the levels attained in many comparable countries.
There are strong arguments in support of encouraging a transfer of freight from the roads to the sea—something that is increasingly reflected in the policies being pursued by the European Union and individual member states. Britain has an extensive coastline, with no major towns and cities being further than 75 miles from the sea and some 350 ports around its coastline. Shipping offers the potential to ease road congestion, reduce noise and atmospheric pollution, and curb the pressure for new road building programmes. Unlike the road system, it requires little in the way of infrastructure investment and maintenance and has enormous potential additional capacity. In total terms, UK commercial road transport consumes almost 10 times as much energy as domestic shipping to carry about twice the volume of freight. Overall, water transport is as much as twice as energy-efficient as rail, four to 10 times more energy-efficient than road and many times more energy-efficient than air transport. A single voyage by a coastal cargoship can carry as much cargo as 80 or more lorries, with one estimate showing that the 11 million tonnes of freight carried by water in London in 1990 amounted to some 10 million fewer lorry journeys.
The catastrophic decline of the British fleet has reduced the opportunities for domestic shipping to contribute to "greener" transportation policies and to benefit from EC initiatives in this area. The development of shipping as an alternative to rail freight has also been hampered by comparatively poor road and rail links to ports and, until recently, by the inadequacy of the freight facilities grant system for encouraging alternative transportation modes. In addition, there has been little consideration of the way in which new shipping technologies can be used to overcome old objections about the speed of shipping compared with land transport.
6. WHETHER ENOUGH UK REGISTERED SHIPPING IS AVAILABLE TO FULFIL THE COUNTRY'S STRATEGIC NEEDS AND INTERNATIONAL OBLIGATIONS
Concerns about the strategic impact of the loss of UK registered ships and seafarers has been articulated not only by NUMAST but by numerous Parliamentary defence committee inquiries during the past 15 years. In 1988 the defence committee stated: "The availability of merchant shipping for defence purposes is governed by three key factors: the number of UK flagged ships; their accessibility when they are needed; and the availability of a pool of British seafarers to man them. There are grounds for concern on all three counts." Since that warning was made, the number of British owned and registered ships has fallen by around two-thirds, from 685 to 231, which NUMAST believes makes a mockery of repeated government assurances that there are still sufficient ships to meet strategic needs.
The British merchant navy has long held a central role in our nation's defences and has traditionally been accepted as "the fourth arm" of the armed forces. In the present unsettled and constantly changing geopolitical situation, that role is perhaps more important than ever.
The Falklands War and the Gulf conflict are two recent and striking examples of the crucial contribution that merchant shipping and merchant seafarers can make at times of national emergency. Admiral Sir John Fieldhouse said after the Falklands conflict that "without the ships taken up from trade, the operation could not have been undertaken". Yet the UK fleet today is less than one-third the size it was at the time of the Falklands—when foreign ships had to be chartered by the government to make good critical shortages in key sectors. In the Gulf war only eight of the 143 ships chartered by the MoD flew the red ensign and a subsequent National Audit Office inquiry confirmed concerns that the UK had paid around £38 million in excess of market rates for foreign ships it chartered.
During the Gulf conflict, concerns were also raised by US forces that delays in shipping troops and equipment to the region had setback the combat readiness of the forces. At a time when the UK is making a significant contribution to the Joint Rapid Reaction Force, the need for adequate numbers of merchant ships and seafarers is of special significance. Whilst NUMAST welcomes the decision of the Strategic Defence Review obtain four new ro-ro containerships in addition to two new ro-ro vessels on bareboat charter to the Royal Fleet Auxiliary, we believe this falls far short of what is required to remedy the impact of the past two decades of decline.
The strategic concerns about the merchant fleet's decline are not a simple matter of numerical decline. Different ship types have particular strategic value—ro-ro ferries, product carriers and tankers, and large containerships are of particular importance. Reliance on foreign shipping is, as the Gulf experience showed potentially economically unwise, presents strategic sensitivities, and "potential legal and political difficulties" (as stated by the 1985 Defence Committee inquiry). The government has itself acknowledged these issues by deeming that certain ships of strategic significance should be required to have British nationals as their masters.
It is now more than a decade since the defence committee voiced its concern at the number of British seafarers available to serve on ships operating in support of the armed forces or strategic operations. Yet, since that time the number has continued to decline and, on present trends, is set to decline even more dramatically over the next decade. Reliance on foreign seafarers or even crews from NATO or other EU countries is strategically unwise. Not only do many of these countries also suffer from serious and growing shortfalls in maritime expertise, experience in the Falklands and the Gulf has shown that foreign seafarers may often be unwilling to serve on ships involved in third-party conflicts.
7. THE PRESENT LEVEL OF EMPLOYMENT OF UK SEAFARERS, THE EFFECTS OF ANY PRESENT AND FUTURE SHORTAGE OF SKILLED PERSONNEL IN THE SHIPPING INDUSTRY AND IN RELATED ON-SHORE INDUSTRIES, AND HOW THE TRAINING AND EMPLOYMENT OF UK SEAFARERS CAN BE PROMOTED
Just two decades ago, the British shipping industry employed 82,626 seafarers. In 1995, the year for which the most recent statistics are available, it employed just 31,392. Between 1978 and today, the total number of British seafarers has fallen from more than 65,000 to less than 25,000. Most alarmingly, more than 70 per cent of British officers and 53 per cent of British ratings are aged over 40. On current trends, this means that existing officer numbers are likely to decline by almost 30 per cent over the next five years.
This decline has very serious implications. It matters that Britain faces a growing shortage of skilled and experienced ships' officers and that we may soon be in a position where we will be reliant on international markets for meeting our needs.
British merchant navy officers are internationally renowned for their expertise and are among the most sought after by shipowners and crewing agencies on the international market, with around half the NUMAST membership employed on foreign flagged ships. With the pressure for safer shipping operations and the introduction of stricter regulatory regimes for shipping—including the International Safety Management Code and the revised Standards of Training, Certification and Watchkeeping Convention—the demand for such skills is intensifying.
However, not only is there a growing shortage of British officers, there is a growing international deficit of skilled officers that is certain to increase in the coming years—with worldwide cadet recruitment estimated to be barely 75 per cent of the level required to meet future needs and the new STCW Convention likely to lead to further reductions in the supply of officers. Research suggests that worldwide demand for skilled officers is already exceeding supply by as much as 50,000 and that the shortfall is likely to rise to around 350,000 within six years. Although the officer nationality requirements for British ships have, misguidedly, been diluted in recent years, NUMAST believes that efforts to promote the UK register could be constrained by a domestic seafaring skills shortage at a time of intense international demand.
In 1991, a University of Warwick study predicted a shortfall of 12,600 in the international and national supply and demand relationship for UK officers by the end of the decade. A recent EC-commissioned report on European officer training suggested that the UK is presently short of around 850 officers, that this will rise to more than 3,100 by 2001 and could grow to more than 6,800 by 2006.
Such shortages present profound problems for the shore-based maritime infrastructure. Many leading institutions—including classification societies, marine insurers, the Baltic Exchange and the Salvage Association—have expressed their concern at the loss of seafaring skills for essential posts, such as pilotage, ship inspection and surveying, marine law and insurance, maritime training, ship management and harbour administration.
The demise of UK maritime expertise presents a serious threat to the future health of many maritime industries and services that provide significant economic and employment opportunities. The loss of merchant navy officers' skills also presents a serious threat to the safe operation of shipping in our waters, as well as to Britain's continued international pre-eminence in many maritime fields. While shipping companies may have been able to utilise low-cost foreign labour in many seagoing posts, it is unlikely that such a process can be applied to shore-based maritime services and industries. In the long-term, Britain's ability to influence global maritime policies and events will be jeopardised by the country's consequent marginalisation in worldwide shipping business and affairs.
Furthermore, the growing shortage of British officers is likely to result in a "feeding frenzy" among non-training employers, inflating pay and accelerating the flow of officers from the sea to shore-based employment.
The employment of British officers has, in the past 25 years, become increasingly threatened by the drift of British-owned tonnage to foreign registers, by the low level of wages that can be paid to seafarers from low-cost labour supplying countries, and by the progressive employment support measures adopted in many high-cost labour supplying countries—including special tax and social security regimes, the payment of training costs and innovative recruitment campaigns—than can halve the cost of employing national seafarers.
While the UK has in recent years attempted to offset the impact of such competition by introducing limited income tax concessions for seafarers and by increasing the size and scope of support for maritime training, it is fair to say that the overall regime falls far short of that enjoyed in many other countries and has failed to promote any significant increase in employment and training levels. Many measures have been introduced in a non-systematic manner—with the result that income tax and national insurance concessions, for example, are applied in a confused or complex process that may actually exacerbate problems by requiring employers to transfer contracts offshore or to require employees to serve on certain ship types or in certain trades. With the European Commission having explicitly stated the policies that member states may pursue to promote seafarer training and employment, it is now more essential than ever before that the regime in the UK matches that applied in comparable countries such as the Netherlands.
The annual intake of officer cadets—though now significantly up from the trough of less than 100 in 1986—is still barely one-third the level acknowledged as necessary for ensuring that future needs are met. While evidence shows that there is no shortage of well-qualified and committed young people applying for seagoing training opportunities, it is clear that the number of available cadetships is extremely limited.
Because the current international trends present significant opportunities for skilled British officers and offer young people potentially stimulating and high value career choices, the shipping industry could offer the government a valuable source of fulfilling its commitment to provide new and rewarding opportunities for youth employment.
NUMAST believes there is significant scope for further expansion of the SmarT training support scheme, to encourage more employed to contribute to the training process. The Union has for several years also argued strongly in favour of the creation of a national training fund scheme to co-ordinate all actual and potential sources of training funding, with the additional development of an industry "levy" scheme to end the present divisive and damaging structure in which many employers are content simply to "poach" from those who make the often considerable commitment of investment in recruitment and training. There are now firm and tangible signs of support within the industry for such a scheme and NUMAST believes the government must play a firm role in fostering its development.
8. WHAT THE UK CAN LEARN FROM THE EXPERIENCE OF OTHER COUNTRIES IN DEALING WITH SIMILAR PROBLEMS, AND THE ROLE OF THE EUROPEAN UNION
Virtually all major maritime nations have adopted some form of policy programme for supporting their merchant fleet and merchant seafarers. The measures utilised are varied and their impact has similarly varied, from slowing the rate of decline to generating a market revival in fleet size and seafarer employment.
Britain's failure to match such policies in a cohesive and planned strategy has undoubtedly resulted in its comparatively marked maritime decline—one of the most severe experienced by any country.
The measures adopted in countries such as Norway, Sweden, Denmark, Greece, Spain, Germany, the Netherlands and the United States have followed an assessment of the national value and importance of the country's maritime sector and have been introduced in a planned, strategic manner. In contrast, the UK's response to the decline of the merchant navy has until now failed to produce a comprehensive and co-ordinated strategy for the future.
The European Union has becoming increasingly aware of the decline of the Community's maritime industries and increasingly responsive to their needs. The EU guidelines on state aids for shipping adopted in July 1997 have signalled the endorsement of the progressive measures adopted by countries such as the Netherlands by accepting the fact that shipping presents a "special case" for support. The research has been conducted and the political arguments for measures to provide the environment for British shipping and maritime skills to be rejuvenated have been proven. Other countries have acted in response to these factors—Britain can no longer afford the time to go through the processes followed by these countries: in essence, there is no need to "reinvent the wheel".
It is now essential that Britain adopts a structured and strategic maritime policy in line with the EU guidelines and the measures adopted elsewhere. Unless this is done, the UK fleet and UK seafarers will become increasingly competitively disadvantaged.
9. THE ROLE AND IMPORTANCE OF ON-SHORE SHIPPING SERVICES PROVIDED IN THE UK, SUCH AS INSURANCE AND SHIP BROKING
In the past few years, a number of studies (including work undertaken by British Invisibles and the Maritime Panel of the Technology Foresight Programme) have demonstrated the immense national value of the UK maritime sector. Britain remains a global market leader in many maritime services—accounting for around 25 per cent of the marine insurance market, as much as 50 per cent of sections of the shipbroking market, classifying more than one-fifth of the world fleet and also acting as a leading international centre for maritime law, seafarer training, consultancy and publishing.
Underpinning NUMAST's evidence to this inquiry is the concern that the continued decline of the UK fleet and of UK seafarer numbers will jeopardise the future of such services in Britain. There is already evidence to show that maritime-related earnings in the City have declined by around one-third over the past decade and by more than 50 per cent in real terms since 1975. Shipping's unparalleled internationalism fosters the ready development of new centres of expertise and service—demonstrated by countries such as Singapore, Cyprus and Hong Kong—which many other governments around the world are consciously responding to.
In 1992 the EU's Maritime Industries Forum warned that "there is at all times the potential for outward movement towards operating bases where conditions are more favourable or where survival in this highly competitive global market is less difficult".
By failing to stem or reverse the loss of British registered ships and of British seafarers, the UK will lose the basic building blocks supporting the valuable ancillary maritime services and industries. In turn, Britain will face the gradual demise of its international maritime status and its ability to participate and influence global maritime policy. For an island nation, still highly dependent on the sea and shipping, that should be a deeply disturbing prospect and one that should be avoided at all costs.
10. CONCLUSIONS
The UK shipping industry has suffered a decline of almost unparalleled severity.
This decline presents alarming consequences for national security, employment, the environment and the economy.
A comprehensive package of measures must be introduced urgently to ensure a future for British shipping, UK seafarer employment and the wider UK maritime infrastructure.
Measures required include:
— The introduction of an optional tonnage tax system.
— The provision of an improved depreciation regime to encourage greater investment in new tonnage.
— Application of the measures permissible under the EU state aid guidelines for supporting shipping and seafarer employment.
— Increases in the scope and value of existing support for seafarer recruitment and training and their application to all employers recruiting British cadets and junior officers.
— The extension of existing UK seafarer income tax concessions to certificated UK officers and ratings in all sectors of the industry, irrespective of ship type or trading area.
— The abolition of employers' National Insurance contributions for British seafarers, with no loss of seafarers' individual entitlements.
— Improved incentives to encourage the transfer of freight to waterborne modes of transport.
— Concerted and strict application of international safety standards on foreign ships trading in UK waters.
In 1986, a similar inquiry by the House of Commons Transport Committee warned the government:
"It is a fact that in the real world there are only two alternatives for maritime governments—either to promote their country's shipping industry, or to see it obey market trends and ebb away to registers which have a competitive advantage even though their advantage may sometimes be artificial. There is no third option."
Twelve years on, NUMAST believes that stark warning is as real as it ever was—if not more so. We cannot wait a further 12 years. Today, more than ever before, we have to take the first option.
© Parliamentary copyright 1999
Prepared 8 June 1999