§ Mr. Albert Booth (Barrow-in-Furness)
I beg to move Amendment No. 4, in page 7, line 2, leave out from 'by' to end of line 17 and insert :' or under the authority of the Government of any Convention country '.
§ Mr. Deputy Speaker (Sir Robert Grant-Ferris)
I think that it will be convenient if, with this Amendment, we discuss Amendment No. 5, in page 7, line 6, leave out subsection (4).
§ Mr. Booth
If the Clause were to go through unamended, the legal position would be that ships sailing into and out of United Kingdom ports would do so under insurance requirements which could fall into one of three categories. If they were United Kingdom ships, they would be required to carry a certificate of insurance against oil pollution damage which they may cause issued by the Secretary of State of this country. If they were ships registered in a Convention country other than the United Kingdom, they would be required to carry a certificate of insurance issued by the Secretary of State for the country in which they were registered. If they were ships registered in a country other than a Convention country, they would be required to carry 113 a certificate issued by the Secretary of State, or a certificate meeting requirements defined in a regulation, that is to say a certificate which met the requirements laid down by the Secretary of State, presumably of this country.
The effect of Amendment No. 4 would be to simplify the position considerably, and to take away the right to sail a ship without a certificate issued by the Secretary of State of a Convention country. The Amendment is necessary in part because of the difficulty of defining, by regulation issued by the Secretary of State, and approved by the United Kingdom Parliament, a requirement of insurance which would have effect over all the conditions laid down by the country, not being a Convention country, which registers the ship.
One could well imagine the insurer of a vessel, having made the translation into his own language of one of our regulations, putting upon that translation an interpretation of the insurance requirement which was different from that which the Secretary of State intended, and which he would effect when he issued a certificate of insurance to a United Kingdom-registered ship.
Knowing the complexity of legal language a little better than when I first entered the House, I suggest that even English insurers reading some of the regulations issued—if our insurance could be effected in that way—could produce different types of insurance. Therefore, some difficulties of definition are bound to arise if we provide that it will be legal and acceptable for a ship registered in Liberia—or in any other non-Convention country—to enter one of our ports if it can be contended that the certificate of insurance that it is carrying against oil pollution damage claims meets the requirements of the regulations issued by our Secretary of State.
A further objection to the form of the Clause—an objection that is covered by the Amendments—is that it places those who operate ships under flags of convenience countries in a position different from that of those who operate under flags of Convention countries. That is highly undesirable. One might argue the reasons which still cause owners to choose to sail under flags of convenience. However, for the purpose of this legisla- 114 tion we would not wish to discriminate between ships registered in Convention countries and ships registered in non-Convention countries in respect of insurance requirements for damage against oil pollution; we would want all ships that sailed into United Kingdom ports, or sailed in a way that put at hazard any of our constituents for oil pollution purposes—or any of the peoples of a Convention country—to be in an identical position in respect of the safeguards provided by insurance, whether the ship that brought about the hazard was registered in a Convention or a non-Convention country.
With the best will in the world, a Secretary of State would find it very difficult, if not impossible, to achieve that desirable aim if he had to operate the Clause as it stands.
A further practical problem arises on the Clause. The certificates of insurance which will have to be produced to meet the requirements of the regulation would not necessarily be examined until such time as the ship concerned came into a Convention country's port—and there is no guarantee that even then the certificate would be examined—whereas the certificates carried by ships registered in Convention countries would be issued by the Secretaries of State in those countries in every case, and therefore they would require the prior examination of those Secretaries of State and to that extent would provide the safeguard entailed in the examination and issue of a certificate, which could not be said to exist in the case of non-Convention countries which provided certificate of insurance under subsection (3)(c) and (4) of the Clause.
We hope that this legislation will be one of the factors that will bring about the reduction in oil pollution damage and consequent claims. In spite of that, we must examine how effective the legislation will be in dealing with those cases where oil pollution takes place and claims arise, if the Clause is unamended it would seem to provide a defence to a person whose insurance is defective—a defence that the insurance certificate carried complied with the requirements of the regulation. That defence would be open only to those who sailed under flags of convenience countries which were covered by regulations in such a way as to enable them to issue these certificates.
115 That position must be suspect because of the limitations of the Convention. If every country took as serious a view of the risks involved to international shipping as do the Convention countries, many more countries would be party to the Convention and, secondly, many more countries would be ready immediately to co-operate in framing legislation to match that of Convention countries. Since that is not the case, that aspect of the Clause must be suspect.
There is also the difficulty of the financial incentive to produce a cheaper insurance if a way of doing so can be found under the provisions of the regulations. Having seen an insurance company crash and many people being left without insurance, this Parliament should be very careful in considering Clauses that allow for different types of insurance to cover basically the same risk. If anything, the risk may be higher when a ship sails into our waters if that ship is not a United Kingdom-registered ship or the ship of another Convention country.
§ The Clause undoubtedly makes provision for regulations to be different for different countries. That is the only sense that we can make of subsection (4)(a) and (b), which allows regulations to provide that a certificate may be recognised if it is issued in a country in which the ship is registered—but insured, presumably, outside the country in which it is registered—if it is a ship registered outside the Convention countries. That lends itself to difficulties and to a multiplicity of forms of insurance.
§ The gist of my argument is that the Clause is risky, and makes for tremendous complication. The Minister wants to reduce the risk, and I am sure that he wants to get away from complication and would like to see an equal position apply—a position of absolute parity between all ships which sail into Convention countries' ports, be they registered there or not, and having the sole requirement that they carry a certificate of insurance issued by the Secretary of State of a Convention country. It is in order to achieve that aim, in the interest of achieving a higher measure of safety against the pollution of our waters and the pollution risks which can fall to 116 those whom we represent, that I move the Amendment.
§ Mr. Anthony Grant
The hon. Member for Barrow-in-Furness (Mr. Booth) is trying to do something with which I sympathise, but I do not think that I can accept the Amendment. He wants to increase safety generally, raise standards of insurance and encourage as many Governments as possible to join the Convention. But the provisions relating to insurance certificates are not necessarily the right vehicle for this purpose.
A ship which is registered in a non-Convention country may well be properly and adequately insured by a United Kingdom insurer, in which case a certificate issued by the Secretary of State would be applicable, or by a suitable insurer in a third country where the supervision of insurance was known to be satisfactory. In this case, a certificate recognised for this purpose by regulations made by the Secretary of State would be acceptable. Insurance, particularly marine insurance, is essentially an international operation and it would not in our view be appropriate to insist that the issue certificate should be confined to Convention States.
We are looking forward to another conference in Brussels in November to negotiate the setting up of an international compensation fund for oil pollution damage. The fund Convention will be based on the 1969 Convention, and Slates will not be able to ratify the former without ratifying the latter. This will be the stimulus for them to come within the Convention.
If claimants are successful, they will be able to look to oil interests as well as to shipowners and their insurers for compensation up to a very high amount. We cannot tell what the agreed limits will be, but I am sure that hon. Members will agree that we aim for limits which are high enough to cover the worst possible catastrophe to this country and not so high as to encourage inefficient cleaning up of the mess. In the meantime, we rely on the cover of the voluntary schemes of TOVALOP and CRISTAL.
At the end of the subsection it says in effect that the countries nominated as acceptable certified authorities need not necessarily be nominated solely as certifying authorities for tankers registered in 117 their own countries. In this connection, we envisage that the main factor influencing the recognition of countries for this purpose—it should be noted that such countries would be Convention countries or non-Convention countries—would be the Secretary of State of this country assessing the reliability and the quality of the countries' insurers.
I hope that the hon. Member will agree that it is desirable that the Bill should spell out who can make the regulations and without fettering unduly the discretion of the Secretary of State as to what those regulations should contain. I entirely appreciate the hon. Gentleman's motives, but they are misconceived in the sense of the Convention as a whole. I believe that it is better to deal with the matter as we have done in the Bill, by allowing the Secretary of State to make regulations in this respect. The House may rest assured that the Secretary of State will ensure that the highest standard of insurance is applicable in these cases.
§ Mr. James Johnson (Kingston upon Hull, West)
I take it then that this will be a selective list, that the Secretary of State will, at his own discretion, black list or eliminate some countries which he deems not to be worthy of being on the list.
§ Mr. Grant
That does not quite put the position correctly. It is not the countries : it is for the Secretary of State to determine the quality of the insurance. There might be a country of which someone disapproved, but that is not the point. We cannot leave a situation whereby lay magistrates may have to determine this question by going through the complexities of international insurance. Although I appreciate the motives, I cannot accept the Amendment.
§ Mr. Booth
Thank you, Mr. Deputy Speaker.
If the aim of the Clause is to recognise the international character of marine insurance, and thereby enable the Secretary of State to frame regulations which will allow shipping companies to go to various shipowners to get their insurance, 118 why should not this apply to all Convention country ships? Why should not British companies go shopping around the world for insurance? Why not lay down a specific requirement that these certificates should be issued by our Secretary of State?
Are we supposed to read Clause 10(4) as superseding Clause 10(3)? May the regulations be drafted in a form which will override subsection (3) and allow the international character of marine insurance to operate freely across all Convention ships? This is a ridiculous position. That part of the Minister's reply will not stand up against what we were discussing in Committee or against the principal aim of requiring the certification by the Secretaries of State of Convention countries.
§ Mr. Anthony Grant
By leave of the House. I do not wish to make too heavy weather of this. Even looking at it as a layman, I do not believe that the drafting of subsection (4) which says that the Secretary of State may make these regulations, is inconsistent with subsection (3)(c), which merely refers to regulations.
§ The Amendment effectively would exclude non-Convention countries, but I could envisage a situation whereby a Convention country might well have very unsatisfactory insurance arrangements and a non-Convention country might provide a most excellent insurance. It would be a pity to exclude it in that way. It would probably be invidious if I gave examples to stand as the highest standards of insurance, but it may not be a Convention country. This would be invidious. This is why I urge the House not to accept the Amendment.
§ Amendment negatived.
§ 8.0 p.m.
§ Mr. Deputy Speaker (Sir Robert Grant-Ferris)
With this Amendment it is convenient to take also Amendments No. 7, in page 7, line 28, leave out ' £15,000 ' ind insert ' £35,000 ' ;
No. 8 in line 32, leave out ' £200 ' and insert :'£300 upon first conviction and for second or subsequent conviction to a fine not exceeding £1,000' ;119 No. 9, in line 32, leave out ' £200 ' and insert '£400'.
§ Mr. Mason
There are four Amendments grouped together here. It will be my intention to speak mainly on Amendment No. 6, and my hon. Friend the Member for Barrow-in-Furness (Mr. Booth), if he catches your eye, Mr. Deputy Speaker, will specifically deal with Amendment No. 8.
This fine of £15,000 proposed in the Bill is to be imposed on the evaders of compulsory insurance for liability for oil pollution. We believe that this is a derisory sum, that to evaders it is a farcical fine, especially if they decide to ignore the international Convention and will not bother to insure against oil pollution. Of course, the Under-Secretary and the House will know that I am speaking about a minority. We know that many of the oil companies and tanker owners treat oil pollution very seriously indeed. That is why TOVALOP and CRISTAL came about. They are treating this matter extremely seriously.
However, we have to be concerned about a minority, the minority who will not use load-on-top washing methods to avoid forming oil slicks in the sea when they wash out their tanks. These are the fly-by-night oil slickers who clean their tanks by night, discharge crude oil into the sea, and vanish by morning, leaving massive oil slicks behind, the ships having vanished without trace. This is the minority we think must be brought into line.
Progressive and good oil companies and tanker owners will not mind if we increase the fine to the evaders because the good companies will not be caught by it. Tanker owners who are not going to treat this international Convention and this new law of the sea seriously must be punished, and £15,000 is, to my mind, a derisory fine. The Under-Secretary will remember, and hon. Members present this evening will remember, that when we discussed the Oil in Navigable Waters Bill, dealing with the illegal discharge of oil, the penalty was made £50,000. Originally in the Bill it was £5,000, but the mood of the Committee on the Bill was such that both sides of the Committee joined hands and encouraged the Minister to write into the Bill 120 £50,000. Yet here, in this Bill, premeditated evasion of insurance against liability for oil pollution, with all its serious consequences, is to have a fine of only £15,000.
On the rare occasions the potential evader is caught he will pay; he will scoff; and he will move on. There are hundreds of oil tankers calling into our ports every year. We cannot examine them all, but when it is done, and they are found to be guilty of evasion, let us treat that seriously and make the illegal polluter pay. If he pollutes our coastline and is not insured against liability a long legal wrangle will follow and those claiming for damages are unlikely to be satisfied.
The hon. and learned Member for Dover (Mr. Peter Rees) has the other two Amendments we are discussing with mine and he would increase the fine from £15,000 to £35,000. We will gladly give way to that if the Under-Secretary is willing to accept that. The hon. and learned Gentleman knows full well that his Amendment and ours were put down now because of the pressure which was applied to the Under-Secretary, who, to avoid the fine being increased in Committee, was forced to say that he would sympathetically consider a higher fine by this stage, so that we are anticipating that at least he will accept the £30,000 proposal which we make or, best, the £35,000 proposal by the hon. and learned Gentleman. Both on the Oil in Navigable Waters Bill and this Bill dealing with civil liability, the mood throughout has been that there must be high fines for oil polluters, and either the £30,000 or the £35,000 fine would be better than the small, derisory £15,000. In keeping with that mood I hope that the Under-Secretary of State will accept either the £30,000 or the £35,000. Those who attempt evasion of their liabilities, or pollute the sea and our shores, should not escape their financial responsibilities, and must be fined accordingly, and I hope that at the conclusion of this debate the Under-Secretary will accept either the £30,000 or the £35,000 fine proposed
§ Mr. Peter Rees (Dover)
I rise to draw the attention of the House to my Amendments No. 7 and No. 9 which, like the Amendments put down by the right hon. Gentleman the Member for Barnsley (Mr. Mason), are designed to stiffen the 121 penalties on shipowners who fail to insure their tankers against pollution, and against masters who fail to carry certificates of insurance.
My Amendments are purely designed to raise the maximum penalties. They are not fixed penalties. It will be at the discretion of the bench of magistrates whether to award the full penalty or, where there are mitigating circumstances, to award some lesser penalty.
I welcome the Bill and I congratulate the Government upon bringing it forward. This is the first Government to implement the Convention on which the Bill is based, and I think that that is greatly to the credit of this country and of this Government.
Of course, this particular provision, and my Amendments to it, are not aimed at reputable tanker companies, as the right hon. Gentleman opposite said. Indeed, I should like to pay tribute to B.P. for the very rapid and prompt assistance when the "Panther" grounded on the Goodwins. It set a very good example for other oil companies in similar situations. Unfortunately, there are less reputable companies, possibly registered in other countries, which may be tempted to chance their arm in falling foul of the law of this country and the premiums which, I have no doubt, insurers will exact. It is against those people my Amendments are particularly aimed.
There is certainly in East Kent widespread concern, which I share, on the question of oil pollution. It is not an academic problem. Indeed, having bathed or walked on the beaches I can personally testify to the horrible oil patches floating in the sea and to the filthy sight of it on our beaches. That is what has moved me and the people of East Kent to demand really stiff penalties for those people who are callous enough to damage them.
There is to this provision a very real parallel in the Road Traffic Acts. It is fair to observe that the penalties which can be imposed for failing to have third party insurance are comparable to but are a great deal more severe than those which can be imposed under this Bill, even if either the Amendments which I propose or those which the hon. Gentleman proposes are accepted. There is no question of barring absolutely from this 122 country's shores ships which are improperly insured.
What I want to see is this Bill given teeth, teeth which are both sharp and white. I hope it will have two consequences, not only of easing the task of those attempting to exact damages on those responsible for pollution, but also of raising standards of seamanship, because I am very certain that insurance companies and Lloyd's will take note of this and will raise the premiums for those companies which have a bad accident record.
The Minister was a little reluctant in Committee to acecpt this kind of Amendment, and was disposed to contrast the offence provided for in the Bill with that in the Oil in Navigable Waters Bill, and it is fair to observe that under the latter Bill the deliberate discharge of oil only carries a penalty of up to £50,000, and deliberate discharge is clearly an offence of far greater gravity than that of merely failing to insure against spillage. Nevertheless, I hope that my hon. Friend will recognise, particularly after the generous words used by the right hon. Gentleman the Member for Barnsley, that I here suggest a reasonable compromise, which I hope he will feel able to accept.
§ Mr. James Johnson
The Minister will accept that we all want the Bill, and welcome it. It is an all-party Bill. As we all love the Minister so much, it seems a pity that, like the boy who stood upon the burning deck, he should on this Bill, as in the case of the Oil in Navigable Waters Bill, find himself not being manœuvred, but by sheer dauntless will force into isolation. None of us likes that. We want to work as a team.
What is involved is not a matter of abstruse international law, or a labyrinth in which we all get lost and then come back again to find each other. The issue is just that there are these villains on the high seas who scatter filth about which often gets on our shores. Society today is more than keen, it is enthusiastic about eliminating pollution. We have this small minority of anti-social people, and the only issue is how to deter them from their practices.
The Oil in Navigable Waters Bill first proposed a penalty of £5,000, but the Minister, with dignity and good will, gave way to the Committee's demand and 123 agreed to increase the amount to £50,000. Lest he be forced again into isolation I urge him to follow his previous course. Henry Ford said that all history is bunk. I do not accept that view. Teachers sometimes tell us that history never repeats itself, but it can and should, and tonight I think that it will.
I agree with all that has been said by the hon. and learned Member for Dover (Mr. Peter Rees). It is good that on these matters we can both talk the same language for the sake of people on the high seas, and on the shores, too. The hon. and learned Gentleman talked about teeth. I do not want the Bill to have teeth. I want it to have big sharp spikes that we can stick into people who thwart society and behave like this. Let us have a deterrent. In terms of the amount of damage done and the amount of insurance involved. I suggest that a penalty of £35,000 is not out of way, especially when one thinks, too, of the enormous cargoes carried and the huge sums involved.
§ 8.15 p.m.
§ Mr. Booth
The hon. and learned Member for Dover (Mr. Peter Rees) and I have two things in common tonight. One is a concern that the penalties for sailing a ship uninsured should be adequate, and the other is our representation of constituencies with a considerable amount of coastline. My constituency, having some offshore islands, probably has a little more coastline than his, but I do not make any point about that.
The hon. and learned Gentleman and my right hon. Friend have fairly posed the need for a proper relationship between the penalty and the degree of offence resulting in a massive discharge of oil at sea. In post-war years the growth in this risk has been enormous : if ever there was a growth industry, it has been the conveying of oil by sea. In the immediate post-war years we regarded the mighty "Queens" as the monarchs of the sea, thinking of them in terms of size and opulence. But they are almost mini-boats compared with the sort of tankers we can foresee in the immediate future. We can talk seriously now of ½ million and even 1 million ton tankers. The risk of major oil pollution is therefore enormous, and the penalty 124 for failing to insure against claims for oil damage must be seen in that context.
Another factor is the international character of the oil-carrying industry. In connection with Amendment No. 4, the Minister fairly referred to the international character of insurance, and there is provision in the Bill for a person suffering damage to proceed directly against an insurer. This is a relatively new provision in our law, and one of the utmost importance in connection with the shipping industry. Those who in the past have had to proceed with claims against owners or masters of ships for damage caused by their vessels have frequently been involved in the most hideous complexities of law in connection with ship ownership. The practice of ships being owned by companies in one State and leased to subsidiaries in other States has become common. The practice of chartering ships to companies by subsidiaries of the owners is not uncommon, nor is the multi-national staffing of companies and ships. The labyrinth of international law involved in pursuing claims against masters or owners as a result of these practices has increased to alarming proportions. In the case of the "Torrey Canyon", when great legal expertise was brought to bear in connection with claims for damage, only 50 per cent. of the cost sustained was recovered.
I therefore take very seriously the provisions enabling anyone suffering damage to proceed directly against the insurer. It is an excellent proposal, and the Government are to be congratulated on it. But, as a corollary, the Government must realise that it is absolutely essential to enable the insurer to be identified, and also to make sure that the vessel is insured. It must therefore be considered to be a very serious offence not to have a certificate of insurance available on the ship for examination.
I agree with those who have congratulated the Government on being one of the first to bring in legislation necessary for the operation of the Convention, but that carries an additional responsibility, too. We are setting a precedent here, so we must make sure that we have the wording absolutely right. The Minister has hinted earlier tonight at some of the foreseeable difficulties in operating this when he mentioned the difficulty of 125 the salvor in obtaining insurance against the sort of claim he might have to meet if he were held to be responsible for pollution damage.
As a result of the bad operating practices of some companies, which the hon. and learned Member for Dover mentioned, we foresee the possibilities being examined by insurers. What is the insurer to think of some of the reports that have been made as a result of inquiries into accidents which have resulted in massive pollution damage? For instance, there has been a report that a vessel carrying many thousands of tons of oil did not have its navigational equipment working properly, and a report to the effect that there was not a qualified man upon the bridge. Surely, any objective assessment of insurance risk against major oil pollution must take these factors into account. If the penalties do no more than induce tanker owners to ensure that their ships have proper navigational equipment and that their bridges are properly manned, they will have done a great deal to achieve the end desired by all those who have welcomed the Bill.
§ Mr. Anthony Grant
I hasten to assure the hon. Member for Kingston upon Hull, West (Mr. James Johnson) that the last thing I ever wish to be is in a state of total isolation. I have listened very carefully to the speeches made tonight, as I did to the debate in Committee.
The right hon. Member for Barnsley (Mr. Mason) recalled to the attention of the House that the Government decided, as a result of strong expressions of opinion from both sides of the House on the Oil in Navigable Waters Act, as it now is, to raise the maximum penalty for illegal discharge of oil, and other related offences in that Act, from £5,000 to £50,000. It has been argued, in previous consideration of the Bill, that the penalties of £15,000 for failure to have the requisite certificate of insurance and of £200 for failure to produce that certificate were inadequate, and we had a very full and careful debate in Committee on this subject. I listened very carefully to the views expressed on both sides. Since the Committee Stage, I have looked at this question again in the light of penalties relating to other offences over a wide 126 area. I still contend, as I did in Committee, and it should be made perfectly clear, that the offence with which we are dealing here, the failure to have insurance cover, must be distinct from the offence under the Oil in Navigable Waters Act of deliberately discharging oil into the sea. Therefore, a distinction must be preserved. Nevertheless, I recognise fully the arguments urged on me by my hon. and learned Friend the Member for Dover (Mr. Peter Rees), who keeps at me very vigorously on this point, and the arguments of the Opposition, too.
As I am in a generous mood, I can tell the right hon. Member for Barnsley that I am prepared to accept the higher figures now proposed by my hon. and learned Friend, the £35,000 figure and the £400 figure for the lesser offence, instead of £15,000 and £200. These higher figures entirely meet the spirit of the similar Amendments put down by the right hon. Gentleman and his hon. Friends, so we are at one in that respect.
As to the proposal of the hon. Member for Barrow-in-Furness (Mr. Booth) that the £300 should only apply to a first conviction and that for subsequent convictions the fine should be £1,000, I am afraid that I cannot accept that proposal. We should be satisfied with a maximum penalty of £400 for failure to carry or produce an existing certificate, which would be more than sufficient to discourage repetition of the offence.
I make these concessions having regard to the strength of feelings expressed on both sides of the House. After all, that is what Parliament is all about. I want to make it clear that the Amendments maintain the distinction between these offences and the offence in the Oil in Navigable Waters Act. I reiterate what my hon. and learned Friend has said for the benefit of magistrates, who will have to have these very considerable powers at their disposal, that these limitations are definitely maximum limits which obviously would only be used in the most extreme case.
I am prepared, therefore, to accept Amendments Nos. 7 and 9.
§ Mr. Mason
On behalf of Her Majesty's Opposition, I thank the hon. Gentleman for being so forthcoming and for recognising the need to increase the fines against those who may be willing to 127 evade their responsibilities and may, thereby, be likely to pollute the seas and the coastline, and possibly escape their financial liabilities.
The hon. Gentleman knows, as do all of us who have sat through the Oil in Navigable Waters Bill and now this Bill, that during the course of the proceedings on both Bills we have been creating a precedent for many of the major maritime nations of the world. We can be proud that we have been in the forefront and that we have bettered both Bills during their Committee stages. But, above all, we can be proud that we are keen to make the polluter pay. The serious consequences that can flow from oil pollution will be punished, and we shall curb oil pollution as quickly as we can.
§ Amendment negatived.
§ Amendments made : No. 7, in page 7, line 28 leave out '£15,000' and insert ' £35,000 '.
§ No. 9, in line 32, leave out ' £200 ' and insert ' £400'.—[Mr. Peter Rees.]
§ Motion made, That the Bill be now read the Third time.
§ [Queen's Consent, on behalf of the Crown, signified.]
§ Question put forthwith pursuant to Standing Order No. 56 (Third Reading), and agreed to.
§ Bill accordingly read the Third time and passed, with Amendments.