 Hi, Sarah Hindmarsh here from the Office of the Great Barrier Reef. I'm just checking in to see if everybody's on the line or you're on the line. Can anybody hear me? Okay, all right. Hi, my name's Sarah Hindmarsh as I said. I'm from the Office of the Great Barrier Reef within the Department of Environment and Heritage Protection. I'm going to be giving the webinar presentation today which will hopefully last for about half an hour, which will give us about half an hour to respond to questions and answers that you will probably have on the regulatory impact statement. So before we get started, I'd just like to talk to you about a few housekeeping matters. So you will be muted for the duration of this presentation due to the number of participants we're expecting. However, you can ask questions by using the Questions tab to type your questions. And this is located on the right-hand side of your go-to webinar window. At the end of the presentation, we will answer your questions verbally where we can. We have a number of questions to answer. So if we can't answer them all in time, we'll endeavour to follow up and send you written responses. Any questions that are highly technical, we'll take them on notice and again, we'll provide a written response to you. So we are recording the webinar and we will make this available to all participants. If you are having problems with the software or you know others are having problems, can you please contact your local IP provider in the first instance. And you're welcome to provide feedback by emailing officeofaGBR at EHP.qld.gov.au. Okay, so I'll start the presentation. Okay, in terms of the overall presentation, these are the areas that I'm going to touch on. So why is the government looking at or considering regulation what the current regulatory environment is? Just a bit of a quick overview summary of the feedback that we received on the March discussion paper that some of you may have contributed to in terms of providing submissions. The regulatory proposals themselves, the regulatory impact statement in terms of the costs and benefits and the water quality benefits from the proposals and what's happening next. So in terms of the actual purpose of this presentation, it's to obviously provide an overview of the proposal being considered by the government under specifically the Environmental Protection Act and to provide you with support if you choose to provide a submission on the RIS or not. So the regulatory impact statement was released in September with submissions invited until the 3rd of November and this feedback will help inform the decision in terms of whether we keep going with regulation or not. The RIS has been prepared by the Office of the Great Barrier Reef with technical assistance from a senior economist within the Department of Science, Information Technology and Innovation and it's been prepared in accordance with the Queensland Treasury Guidelines and was independently assessed against these guidelines by the Office of Best Practice Regulation within the Queensland Productivity Commission. Okay, so why is the government considering regulation? Well, protecting the Great Barrier Reef is a priority for the Queensland and Australian government and this is because the reef is a highly valued national and international icon. The reef receives runoff from around 400 square kilometres of coastal Queensland with the greatest water quality risks coming from nutrients, fine sediments and pesticides from land-based activities and in adjacent catchments. The regulatory proposals are in direct response to the recommendations made by the Water Science Task Force that provided advice to the government last year on how best to meet Queensland's water quality targets for nutrient and sediment reduction to support the health and resilience of the reef to respond to and recover from multiple pressures such as a change in climate. While pesticides pose a risk to freshwater ecosystems, they are outside scope of the regulatory package. The Task Force made 10 recommendations. Enhanced regulation was one of them and seen as an important component within a mix of tools to meet the reef water quality targets. The Task Force also recommended addressing all key pollutant source as the problem is accumulative impact one. However, other tools are also being looked at and enhanced regulations such as extension support, funding for rehabilitation projects and development of new innovative solutions such as water treatment systems. The recent science in terms of the science consensus statement also confirms that progress towards the targets is actually quite slow and not widespread enough and we won't meet the targets in terms of the present initiatives that we're taking. Okay, so just a quick overview of the discussion paper feedback. A discussion paper was released in March this year for a nine-week computation period. We got 48 submissions. The general feedback from the agricultural sector was mixed with an overall preference for a voluntary approach with incentives. There was some acknowledgment that the government is considering regulation and the current southern reef catchments are actually quite strongly opposed to regulation. If there is further regulation it was agreed that all industries not just agriculture should be targeted. In terms of the conservation sector, they obviously support a regulatory approach underpinned by stronger and faster action across all industries. So that's agriculture, urban and industrial sectors. They'd like the immediate implementation of best management practices and they do support the delivery of these practices through BMP programs, best management practice programs. Urban and industrial stakeholders believe they're already heavily regulated and that we should be targeting the highest polluting contributors in terms of the agricultural sector. In terms of the general public and other stakeholders, they support efforts to protect the reef. They have strong views about using regulation as an additional measure, but there's equally strong views against using regulation. They were supportive of using a locally tailored solution. Okay, so I just thought we touched base on the existing regulatory framework because the proposed package is looking at making amendments to the Environmental Protection Act. For agriculture, there's existing regulations under Chapter 4A of the Environmental Protection Act, and these specifically refer to cane and grazing activities. So there's nutrient application standards that limits the amount of fertilizers that can be applied using a prescribed methodology. There's the requirement to keep records for nutrients and chemicals that are applied. We have an environmental risk management plan approach for larger operators, which isn't currently enforced, by the way, and the regulations are limited to the wet tropics, Burtican and Mackay with Sunday areas. In terms of industrial point source activities, which we're also targeting in terms of the regulatory proposal, these are regulated under the Environmental Protection Act. These activities require an environmental authority before they can undertake their activities. Examples of these activities include sewage treatment, wastewater treatment, aquaculture, intensive animal industries such as poultry farming and some extractives and petroleum activities such as mining and quarrying. And when you make an application for an environmental authority, you're assessed against the Environmental Protection Water Policy, which guides decision-making related to water quality pollutants, which includes nutrients and sediments. We are also looking at other sectors besides agriculture and industrial activities such as urban development and stormwater management and the role that they play in reef water quality. However, these proposals, the current proposals on the table, will not seek to further regulate diffuse pollution from urban development. And this is because the recently amended planning framework, which came into effect in July 2017, includes new policy to achieve best management practice for erosion, sediments and stormwater management in urban areas, including the prevention of water pollution during the construction phase of urban development. Okay, in terms of the new regulatory proposals, these will apply across a broader range of key industries to better address the cumulative impacts of multiple pollutant sources on reef water quality. And this is in alignment with the task force recommendation to implement broader measures for key pollutants. Before proposals on the table are setting catchment pollution loads for each reef catchment to target responses for managing risk to water quality, setting or improving minimum practice standards for key agricultural industries, requiring fertiliser resellers to keep and produce records on requests. And this is about nutrient application advice to help improve nutrient management outcome and establish a water quality offset framework. And this is to manage water quality from new developments in the context of the load limits, so that we're not increasing our overall load from new developments. So the purpose of the regulations is to set minimum standards to bring all operators up to an acceptable baseline. And this is in alignment with the standard approach for other industries that release pollutants to the environment. And also, as I said, with water quality offsets to address additional pollution loads from new developments so that our current efforts aren't compromised by new developments. And just like to say that the great work of business landholders and industry in moving away from high risk practices is acknowledged. However, the latest science does show that progress towards the targets, the water quality targets for a healthy reef is too slow. All right. So moving on to catchment load limits. So catchment load limits applies to all sectors. So we're looking to put the new river basin targets that will be in the Reef Water Quality Protection Plan, the updated plan, into legislation as catchment load limits. And the reason we're doing this is to provide a driver or a trigger for existing activities to meet minimum regulatory standards. And then as a direct link for new industrial activities to consider these load limits when they're actually conditioned under an environmental authority. And this is in relation to avoiding mitigating and offsetting significant residual load. And the load limits will be updated as the targets are updated. Okay. So we're just moving on to existing productions for agriculture. So in terms of minimum standards, the minimum standards will apply to commercial cane, grazing, bananas, grain, and horticultural producers in all castments. So the current practices for cane will be improved. There will be new standards for grazing, bananas, grains, and horticulture. The current package is just about cane, grazing, and bananas. Horticulture and grains will be addressed at a later date in terms of the actual standards that will apply. The standards themselves are based on reducing sediment and nutrient runoff related to the reef water quality risk management framework as well as industry standards in the BNP program. They look at practices such as fertiliser application, maintaining ground cover, irrigation efficiency, and record keeping. We're putting timeframes in legislation about when those standards would start. So we'd have a revised standard for cane starting within 12 months of the legislation being approved. And then within two years for grazing and bananas. There's also an additional, I suppose, a stage two for cane, which would come online within two years. And then we also have review processes embedded in legislation to improve these standards over time. Okay, so the next slide is about recognising good performers, and this is about supporting our existing best management practice programs that are in place. So we're looking into or we would like to recognise BNP programs or like programs that allow growers to meet the minimum regulatory standard. So growers that are accredited under these recognised programs would be deemed as meeting the requirements, the standard, and they wouldn't need to do any additional measures. There are voluntary programs that are already in place, and there's others that are being developed. And this includes some components of those programs, such as the accreditation component, and we're developing the criteria to do that, or we will be developing that criteria. The next component is about fertiliser resellers keeping records. So a fertiliser reseller is defined as a person or business that sells for commercial gain fertiliser containing nitrogen and or phosphorus to an operator of an agricultural ERA. So we're looking to request records about soil sampling and results, as well as sales and advice provided to provide a second line of evidence related to nutrient application. So the reason why we're doing this or looking into this is that producers talk to fertiliser resellers and get their advice, and we'd like this advice to be aligned with best practice or the management standards that are being promoted. It also allows for ongoing engagement with the fertiliser industry towards improved stewardship. Okay, regulating new developments. So this is about new agricultural production. We're talking about offsets here. So offsets are about offsetting additional nutrient and sediment loads from an activity where they can't otherwise be offset through your management practices. And offsets are about counterbalancing this pollution or reducing it through measures taken either on site or elsewhere, such as putting in riparian strips or treatment systems, water treatment systems. So new production is defined as new greenfield sites or the expansion and intensification of existing activity. And we're talking about agriculture that hasn't been undertaken before or recently undertaken or increased fertiliser application or increased irrigation or water use. The delivery of an offset will be a deans condition which would be included in the code, the commodity specific code where the standards are, and it would be delivered through something called an offset delivery arrangement which would need to be entered into prior to undertaking the new production. Okay, so in terms of new industrial activities, it's the same concept that applies. It's just delivered in a slightly different way. So because these activities are already regulated and they require a permit, the requirement for an offset would happen through an assessment process for that permit. And these activities would be required to offset significant residual load as part of their environmental authority. And again, the same condition would be required. Okay, in terms of doing a water quality offset framework, we know there's a lot of interest in this and there is just outlined a bit of a skeleton of how it might work. We know there's a lot more work to do on the detail. And unfortunately, we can't really speak to that detail except to say that before offsets are required, we would have to develop an offset policy and a calculator in consultation with stakeholders which would define what we mean by a significant residual pollution or load. And the calculator would allow for site-specific parameters to be inputted so that that load could be specific to an individual site. We are looking at putting the framework under the Environmental Protection Act. We know that there is the Environmental Offsets Act and this is a bit of a departure from that approach. The reason why we're looking at the Environmental Protection Act is that while the Offsets Act allows for other policies, it doesn't directly allow for the approach that we want to take with agriculture. So we think it would be less complex to set it up under the Environmental Protection Act. However, we obviously would use tools that are already in place and we would seek to complement other frameworks including that Act. So moving on to the Regulatory Impact Assessment. Okay, just a quick overview of the background to the assessment. So it's been done by senior economists within the city. The cost and benefits are estimates. They are indications. They do use the best available data. The figures that I've used may be over or under estimations. So in some cases you may think they're too high. In other cases you may think they're too low. It's very difficult to get perfect information that actually replicates every single scenario out there at the catchment scale and there are a lot of different scenarios for agriculture, for example. So we've used the best available information that we can find and one of the sources of this information is from the Alluvium Consultancy Report, which is a recent report that was done for the Great Barrier Reef Task Force about how much it would cost to meet the target and as part of that there were a number of different interventions that were costed and one of them was land practice change for cane and grazing. So we're using the figures and the data from that report for cane and grazing. For bananas we have less reliable information, so we've had to use some peer-reviewed papers and water quality offsets. The actual costs related to them, we've had to look at the Reef Trust Calculator, for example. So there's a number of different sources of information we've used. We've also talked to some industry people in terms of developing the Reef and staff economists as well. So in terms of the assessment it was done over a 10-year period because the regulation, that's a general assessment period for a costing exercise and the regulations will come in in different periods over that time and the cost and benefits are presented in different ways. So we have a total cost and benefit to society which just amalgamates all the cost and benefits to give you one figure for benefits and one figure for costs and then there's other cost and benefits that are broken down for each sector, so for example for government, for industry and then sectors within that agriculture, bananas, grazing and then we do have a sector cost that go down to a regional scale with an average sort of farm size which includes per hectare estimates, for example for minimum standards. Okay, so in terms of the sugarcane cost for minimum standards, cost and benefits, so there are large one-off estimated costs and this obviously depends on the region, so these costs and benefits are straight out of the ribs obviously and you can see the range there and there are savings as well. So in terms of cane growers, there's 3,007 cane growers across the Reef catchments the total one-off capital cost for the sector is 142 million and 14 million per annum as an ongoing cost and this is for implementing the nutrient management, the finer scale nutrient management approach but there's also a return on investment of 54 million per year in estimated profits and the profit range is between 7,844 in the Burtican, 9,000 in the Reptropics 44,000 in Mackay with Sundays and 49,000 in the Burnett Mary. So we acknowledge that there are obviously upfront costs in terms of implementing the management practices and we are looking into support packages related to this based on the highly successful Burtican farm trials for improved nutrient use efficiency and profitability and this is where growers aren't otherwise engaged in incentive programs. There will be some additional costs associated with the proposed farm design standards for new sugarcane production but these are expected to be quite low and this is because we expect that those sorts of practices would be covered by other regulations such as clearing native vegetation requirements, the requirements for protecting wetlands for example and that if people are starting a new business they would probably be seeking to use the latest best management practices and technologies from an economic financial profitability perspective. Okay in terms of the grazing sector, again this is just a high level snapshot of the costs and benefits that are in the risk. So there's approximately 8,500 graziers in the risk catchments. We acknowledge that there is a large one-off capital cost across the sector of $148 million with ongoing costs estimated at $32 million per year and these costs are high due to the large area of land subject to grazing. We do however assume that there'll be increased profitability from these improved practices in terms of land conditions which has generally seen to be in the long term in the risk of greater than 15 years however there are studies that show a return on investment within 5 to 10 years in terms of the cost calculations they're based on the value of stock removed to reduce grazing pressure and there is strong evidence from a number of different studies that doing this does improve ground cover water quality and does have long term profitability and sustainability outcomes. However this is a low historical low margin in the grazing sector this is probably a disincentive to using these sorts of practices. We are investigating support packages for graziers in relation to these costs and to give you a better idea of the costs at a per hectare scale they range from about $5 to $7 depending on the catchment. The banana sector, less economic analysis as I've said for the banana sector on best management practice programs those estimates aren't actually as readily available as they are for cane and grazing but we would expect that using the management practices that are proposed for fertiliser application for example would produce a net financial benefit. So in terms of the cost for the water quality of the agricultural sector so these are based on estimating the cumulative area of expansion each year over the 10 year assessment period. The associated amount of residual nutrient and sediment load on a per tonne per hectare basis as an average for cane and grazing operating at B practice and the cost per tonne of averting nutrients and sediments from the offset. So in terms of the actual area of expansion this is actually quite low so we're not expecting offsets to be a big requirement or a big impulse. In terms of the area of expansion for cane it's estimated that it'll be about 1% in the area per year and for grazing about 0.1%. For horticulture it's also about 0.1% so that relates to bananas. In terms of the actual offset sorry the load itself this will be determined like the significant residual load will be determined by the calculator but we have actually tried to get an estimate of the load so the costings exercise and again this is a sort of an average for cane and grazing and that load was the export load so the actual load that goes into the reef rather than the inputs that go onto the farm for example from Fertiliser and in terms of the cost per tonne the most recent information has come from the reef trust calculator. The cost is quite high but this is the only reliable information that we have at the moment in terms of the cost after a big level practice is met and it ranges between $150,000 to $232,000 for nutrients and it's actually quite less for sediments which is about $230. So in terms of the offset you can see the sector cost so to cane it's up to $6 million per year and for grazing it's about $1 million per year. Again we're not expecting there to be a lot of offsets because of the low predicted increase in the production area for cane grazing as well as bananas and the cost is probably an overestimate because we haven't factored in the farm design requirement and we also have to remember that offsets can be a driver for innovation in terms of avoiding offsets to look at other ways of minimising nutrient and sediment releases. In terms of industrial activity the cost and benefits for this were limited to sewage treatment operators and this is because we don't expect to see a significant increase in other industrial activities in the reef catchments over the 10 year assessment period in terms of those activities that release nutrients and sediments to land in waters. So the estimated cost is about $2 million per year based on a 1% population increase where the sewage treatment is using less practice activities and again the cost is based on an additional load per year and this is generated by increased population growth and then the abatement costs per tonne and again using the reef trust calculator cost of the maximum cost for nutrient at $232,000 solid. Okay so that's all the cost and benefits, financial benefits in terms of return on investment from a profitability perspective in terms of the actual water quality benefits to the reef and why we think this helps achieve the targets and is a good idea. These are the range of benefits across the catchments in relation to nutrient and sediment reduction. So you can see that there's a range between 13% and 48% for nutrients and the range for sediments is between 12% and 36% in terms of moving towards the targets and in terms of low debatement that's outlined in the reef but it's 182 tons for averted nutrients from minimum practice standards for sugar cane about 1 million tons of averted sediment from grazing about 185 tons of averted nutrients and 25,000 tons of averted sediments from offsets for cane and 26,000 tons of averted sediments for offsets from grazing and about 70 tons of averted nutrients from offsets for treatment plants. And you'll notice that we haven't been able to monetize the water quality benefits in the reef so there is a gap between the quantified cost and benefits in the risk which is about 450 million in net present value but we consider this to be a small proportion in relation to the overall value of the reef which has recently been valued at 56 billion in terms of its values to the community as a whole. In terms of the next steps from here so submissions close on the regulatory impact statement on the 3rd of November which is two weeks from tomorrow. We'll analyze the submissions that have been received and the analysis of this will be put into a decision rinse and the decision rinse also talks about changes to proposals based on feedback that's received and other things and that'll be provided publicly when it's completed and being approved by Cabinet. If we go forward with regulatory changes a bill will be introduced into Parliament next year and we'll also have to do the supporting regulations for just about the detail. So right now we have the architecture and the framework and that would go into the Environmental Protection Act but the detail of how that works like the standards themselves would have to go into regulations that sit under that act and then from July 2018 we'd have staged implementation across industry sectors and this would begin with cane and then follow with grazing and bananas again if this is all passed by Parliament and that's it in terms of the webinar presentation. So we'll take questions now and before we take questions just let you know that we have a few people in the room. I'll just wait till we're unmuted so they can introduce themselves. So the people in the room are colleagues from the Office of the Great Barrier Reef and I'll just let them go around the room and introduce themselves. Hi, Chris Johnson here from the Office of the Great Barrier Reef. Hi, it's Louise Morse here. I'm Director for Reef Policy in the Office. Scott Robinson, Director of Reef Programs within IGBL Okay, so everybody's here to help answer questions. We've received two questions. So one question is how many recognised BMP programs are there currently? So at the moment there are BMP programs that are not formally recognised in terms of what we're proposing to do. So these programs were set up in response or under the previous LNP government. Under that government they chose not to directly enforce the regulations meaning they decided to switch them off and support BMP programs instead for cane and grazing. So we have those programs that are up and running. Under the regulatory proposals what we're proposing to do is to continue to support those programs by recognising them, where they can provide the ability for growers to meet our minimum standards. So in order for us to do that we have to develop that recognition criteria. We expect that the existing programs would pretty much meet that criteria straight away. There may be some tweaks obviously to that. But we're also opening it up to other programs that want to do that as well. So it's open to any program that wants to support producers to meet the regulatory requirements. Do you want to add anything to that? Anyone in the room? Okay, so the next question is how are the water quality benefits modelled and what other model inputs other than reduced nutrient application? What impacts are included in the model related to farm practice improvement? Okay, so at a really high level and we might have to get back to you with some more detail, the water quality benefits have been modelled through the alluvium costings report so under the alluvium report they did the cost and financial benefits and water quality benefits for cane and grazing in terms of moving from a D-class practice to a C-class practice to a B-class practice for example. So we've used those modelled results for our proposed standards because our proposed standards are speaking to shift growers from a C-class practice to a B-class practice over time. So those benefits that have been modelled in the alluvium report are directly related to the management practices. In terms of the benefits for offsets, we haven't, the water quality benefits for offsets, we haven't been able to directly include them in the rinse. So we'll have additional benefits from offsets that haven't been accounted for. And the farm practice improvement I'm interpreting is about the farm design for new agriculture and again we haven't been able to factor that improvement in but we don't think it would be substantial. Okay, the next question is about irrigation application efficiency. How will this be measured and what will be the minimum standards required? Sorry for the delay. I think getting back to you on the last question. We don't actually have any proposed standards related to irrigation application efficiency at this present time. However, there is a consultation document so if you think that this should be part of this particular regulatory response then by all means put that in as submission. So the next question is about soil testing for resellers. Will these soil tests be GPS reference? It's Chris here. At this point we're not proposing to make that a minimum requirement although that can form part of the soil testing regime but the minimum standards are still under development and we can certainly consider changes to those proposed minimum requirements to soil testing. Okay, the next question is how is the progress to the nutrient catchment load measured? Okay, so that question is about our Paddock to Reef monitoring and modelling program that's been in operation for about nine years now and it's used to monitor and model end of catchment loads related to land use practices, the dominant land use practices that release these loads which is mainly sugarcane and grazing however horticulture is captured bananas is captured and industrial activities and urban development is also captured and we report on this regularly through the Reef report cards. Okay, so the next question is there's 286 tons of din reduction flagged for the Burdekin by 2025. How does that relate to products that's applied? Yeah, I'll take that one to Chris. Sure, the answer is it doesn't but we don't know but the model reduction of 286 tons was done under the Aluvium report but the regulation the proposed minimum standard will have an impact on products applied and it's proposed under the Cain standard that that continues to an initial phase is aligned with the existing regulatory requirements which are based on six easy steps and then moving into years to a nutrient management planning approach which our intention is that may refine nutrient application but there's no detail around the nutrient management plan in the sense that it will require X amount of fertiliser to be applied so we're still working out I guess the detail around the nutrient management plan requirement which will come in under stage two of the minimum standard The geographical variability makes and the differences in practices makes that a very difficult thing to determine that relationship between loss versus what's applied. Okay the next question is what is the expectation for resellers if a cash customer walks off the street and buys 10 tons of fertiliser will the reseller be expected to capture details of the customer? Possibly. Yeah so Scott said possibly so you know we're refining I suppose looking into those record keeping requirements and getting feedback from resellers about how they do transactions so that feedback will help refine our approach. Okay the next question is fertiliser resellers often only sell fertiliser to farmers who have had soil testing carried out by independent agronomists they have no record of or control over where that fertiliser is applied. How are these records of fertiliser sales to be linked to farmers blocks or even different legal entities? Okay so the intention of record keeping for fertiliser resellers is to provide a second line of evidence around the advice that was provided and the product that was sold to a particular client. The onus is on the producer the grower to meet the regulatory requirements so there's no actual direct link between what was applied and what was sold because we do understand that there's multiple parties that can sell fertiliser to growers. This is to support us in terms of a compliance response around gathering additional information where we think that there might be over application of fertiliser going on. There is no I suppose repercussions for bad advice or how much is sold. The repercussions for fertiliser resellers is about not providing the records. Does anybody want to add to that? There's no additional questions. Does anybody have any additional, other additional questions? There's four coming. Four minutes left. Okay we've just received another question in terms of assistance packages. The question is the availability of extension resources is a constraint. Has this been taken into account in determining timelines for changes to minimum standards? So in terms of the time frames, the immediate time frame is for CAIM in terms of revised standards and those revised standards we're seeing as minimal really and that's why they'll switch on straight away. In terms of the nutrient management planning approach at a refined scale, we consider it two years to be an adequate amount of time to implement those requirements. However we do acknowledge that they will be support that's required in terms of agronomic support so we are looking into how we might provide that support. In terms of grazing and bananas because we haven't had minimum standards that apply across the board before we're providing extra time for this. However the standards that will need to be implemented will be available up front so people will know what they need to do and be given two years to do that. Again we acknowledge that costs and extension support for those practices could be required and quite a large scale so we are looking into what support we can provide in those areas. We've also attempted in creating the minimum standards to deliberately target practices that are a generally accepted industry standard and that are the practices that the industry largely view as outdated so we're expecting that the bar that we've set for a lot of growers shouldn't be a difficult hurdle to get over without that agronomic advice. And there are also incentive programs that are out there as well so in terms of those programs we'd be seeking to complement them. We just clarified too that for the Burnett Mary so those areas where we haven't had standards in place before they will have additional time to transition to the new minimum standards. Any other response? It's one o'clock. Does anybody have any further questions that they'd like to ask? Are any points of clarification in terms of the responses we've provided so far on the questions you've asked? Okay we'll wait another minute and then we'll finish off. Here's one. The last minute scraped in. If we can't lower our DIN levels with six easy steps will we have to go to lower standards or does it mean lower fertilizer rates? So that's really the intent behind the management plan process to find the opportunity where there are opportunities on farms to optimize fertilizer application and process and practices that might further enhance nutrient management beyond the 60 steps particularly the 60 steps district yield potential stage. Alright we might wrap it up there. Thanks for everybody who's participated in the webinar and if you do have any additional questions you're welcome to send them through to the office of the GBR email address which can we put that slide up? Oh okay so the address is in front of you so please if you have any additional questions please let us know and we'll go on to those questions. I hope this has been a useful exercise for you and just a reminder that submissions are invited on the res until the third of November. Okay thank you.