Child Performance Laws

[Ynot]

but its no big deal for a kid to be in a play/dance recital/ect for a few shows (some are up to 6-8 performances) after school. I performed way more than 6 times a year at 12-13 years old (going up from there as I got older) and there was never any silly forms for the government.

School shows and events produced AT school (and usually even in other venues) are in fact exempt from the CPS legislation. There is an assumption (not always correct, IMHO) that the teaching staff will have things like supervision etc covered.

[Junior8]

There is a grid here from where you can read off the precise needs that you have. Ir's worth remembering though that these regulations are pretty venerable, something like them has been around for years and are really designed to prevent exploitation and to control supervision of children in certain environments rather than for 'child protection' as we know it these days. It may seem odd that a group like this might need to apply for a licence but in most areas minors are simply not allowed to 'police themselves' legally anyway.

 

My advice is simple. Apply and if there is any difficulty remember Richie Benaud's counsel. Ask the council if they want to be sensible or famous? i.e. if refused go straight to the press with a story along the lines of barmy council refuses licence to (if I found the right news story searching the Lowestoft papers) award winning youth group!

[andrewg112]

Hello All,

Got a reply this afternoon after phoning up the County Council. Yes we do have to have them, because we are doing more than 4 performances, alot of work to do now I think!

 

The law on this is very over the top I believe. Personally, they should change it to only catch the ones out who are performing alot of the time and missing school. It really isn't encouraging to have obstacles like this in the way, especially if you've never dealt with performing licences before.

 

After this, we have to get our Chaperone's sorted. The young kids have to be escorted to the toilet like Paul says, but in reality its just not possible to do this all the time in the theatre environment. I also agree with what Paul says about the Choreographer shouting at the children, it is just what happens in shows, ive never known a kid to get upset over it (they just remember what to do next time!)

 

Its very difficult to organize a show as a Youth Theatre Group, we have to have Adults around us still, which is understandable, but its surprising how much the have to legally do with regards to us being a Youth Group. All 5 of us 16 year olds have had CRB checks, which is a bit over the top if you ask me! But hey we won a award as Junior8 says! Worth the work!

 

Andy,

[Ynot]

Is it all a bit OTT?

Yes.

 

Should you ignore what you've been told you should be doing?

Heck, no!

 

Trust me - there are moves to make changes to the regs regarding exactly what should and shouldn't be done/allowed with youngsters and performing, BUT don't expect it to be too sweeping a change.

[JohnA]

Assuming we are talking about children performing as part of say youth group, dance school or amateur dramatics i.e. not a paid or professional jobs, as this can involve far more serious regulations.

 

As far as licensing the children are concerned

 

1. Generally it is the ones that are under 16 that you need to concern yourself about. I say generally as it is possible depending upon the actual date of birth when compared to the school year (I am not sure if it is the start or the end), but it is possible to have a child that is actually 15 at the time of the performance that the local authority say that they don’t need licensing.

 

2. The rule is you may perform up to 4 days in any 6 month period (rolling 6 months) without licensing. It is not 4 performances it is 4 days. Also it is not just the performances your organisation are putting on, but if the child has performed in the last six months anywhere paid or unpaid. If so these days add to the total. Generally school and church performances don’t count towards this total.

 

3. If they require licensing generally it is a formality assuming the child is not playing truant, is keeping up with their education and has not missed to may days off school. Although the child’s school are asked if they want to object to the licence been given, it is not the schools decision it is the local authority that decides. I have heard of a case where the school objected, but the licence was still given, but I believe this was an exception

 

4. If a child is licensed by the local authority it is compulsory they are looked after by a registered chaperone (volunteer or professional chaperone, but the chaperone must be registered licensed chaperone) or the child’s parent.

 

5. There are restrictions as to how may children the chaperone can look after (my local authorities say recommended 8 but maximum 12). Considerations must be given to age and sex of the children under the chaperones care.

 

6. It is quite possible the performance may be made up of children that are licensed and ones that are not.

 

7. The children have to be licensed with the authority where they live, not the authority where they go to school or perform in.

 

8. The local authority have the power to carry out an inspection before during or after a performance to see if the regulations are been followed correctly (heavy penalties could apply for non compliance).

 

The best way is to licence the ones you know about that need licensing and give the local authority a list of the others you believe don’t need to be licensed. That way they acknowledge you list and it gives them the opportunity to come back to you is they think there is a mistake or error.

 

My advice is be careful as more and more local authorise are looking into the licensing and chaperone procedures as time goes by. It is easy to assume you are okay, but assuming is no defence.

[Ynot]

1. Generally it is the ones that are under 16 that you need to concern yourself about. I say generally as it is possible depending upon the actual date of birth when compared to the school year (I am not sure if it is the start or the end), but it is possible to have a child that is actually 15 at the time of the performance that the local authority say that they don’t need licensing.

Incorrect - the rule is children must be licensed up to the age of 16 and still in full time statutory education. So, if like my daughters, your birthday is early in the school year, they need licensing up to the point that they officially leave that school at the end of year 11

2. The rule is you may perform up to 4 days in any 6 month period (rolling 6 months) without licensing. It is not 4 performances it is 4 days.

This is actually dependent on the interpretation of the relevant county council - some say it's 4 DAYS, others stipulate 4 PERFORMANCES, which means in the latter case a matinee and evening show counts as TWO.

4. If a child is licensed by the local authority it is compulsory they are looked after by a registered chaperone (volunteer or professional chaperone, but the chaperone must be registered licensed chaperone) or the child’s parent.

It should also be noted that unless the parent of a performer is also a) a registered chaperone and b) registered as chaperoning for THAT performance, then the parent may ONLY look after their own child - NO others.

6. It is quite possible the performance may be made up of children that are licensed and ones that are not.

True, though regardless of licensing, ALL children performing SHOULD be notified to the County Council CPS for records.

7. The children have to be licensed with the authority where they live, not the authority where they go to school or perform in.

Oh yes - which means that if your venue or performing group is on the border of more than one countyauthority, then licenses must be obtained from as many as you have kids from their jurisdiction!

8. The local authority have the power to carry out an inspection before during or after a performance to see if the regulations are been followed correctly (heavy penalties could apply for non compliance).

I don't believe it's the case in all locales, but certainly in Warwickshire, EVERY performance with children from WCC will be inspected.

The best way is to licence the ones you know about that need licensing and give the local authority a list of the others you believe don’t need to be licensed. That way they acknowledge you list and it gives them the opportunity to come back to you is they think there is a mistake or error.

Ah - yep - that reinforces my point above. :** laughs out loud **:

[JohnA]

Incorrect - the rule is children must be licensed up to the age of 16 and still in full time statutory education. So, if like my daughters, your birthday is early in the school year, they need licensing up to the point that they officially leave that school at the end of year 11

 

Ynot, Your comment above, it is you that is incorrect not me.

 

In October 1968 the Home Secretary made an order bringing Part II of the Children & Young Person Act 1963 into force. The Act and the Regulations constitute a comprehensive code governing the circumstances in which children under the upper limit of compulsory school age (section 58 1944 Education Act) may take part in performances of all kinds, and containing safeguards for the children (compulsory school age ends on the last Friday in June of a child's final GCSE year)

 

So a child who’s 15th birthday is say on 25th July and was also performing say on 15th July would technically be 15 years old at the time of the performance, but they would not be of compulsory school age and therefore out side the licensing requirement.

 

This is actually dependent on the interpretation of the relevant county council - some say it's 4 DAYS, others stipulate 4 PERFORMANCES, which means in the latter case a matinee and evening show counts as TWO.

 

You say “dependent on the interpretation of the relevant county council” there is no room for interpretation as far as the Act is concerned. Looking at the Act (as far as I am aware) it only talks about Days not Performances with regard to this issue. So which county council(s) is it that you referring too?

 

It should also be noted that unless the parent of a performer is also a) a registered chaperone and b) registered as chaperoning for THAT performance, then the parent may ONLY look after their own child - NO others.

 

Yes you quite right and that is why I said “or the child’s parent” and that is why I didn’t say “or the parent of another child”.

 

I don't believe it's the case in all locales, but certainly in Warwickshire, EVERY performance with children from WCC will be inspected.

 

Well what I said was “The local authority have the power to carry out an inspection before during or after a performance to see if the regulations are been followed correctly (heavy penalties could apply for non compliance)”.

 

The fact in your experience in Warwickshire, EVERY performance with children from WCC will be inspected. This is amazing?

 

I know from my own experience and talking to the Child protection officers in 4 local authorities around me, this just doesn’t happen. They would love this to happen, but they just don’t have the manpower to carry out an inspection for every child. It would be an impossible task considering budgeting and resource restraints councils have.

 

So if I was to look at your statement “in Warwickshire, EVERY performance with children from WCC will be inspected” So if this is true, just taking an example, a child from WCC performs in say Buckinghamshire you are saying they get inspected. Who does it? Are you saying the Warwickshire child protection come down to Buckinghamshire to carry out their inspection? I know for a fact Buckinghamshire (I would have said all local authorities, but accepting your comment about Warwickshire I would therfore say 99% of local authorities) don’t have the resources to carry out a 100% check on all children.

 

Also just to confirm as I understand the way things work is:

 

The child (where licensing is required) is licensed by the local authority where the child lives (there are exceptions, but I won’t go into this now).

 

This may mean that a drama school could be based / resident in one local authority, has children requiring licensing from say 3 or 4 different local authorities and does there performing in a completely different local authority. If this is so the licenses are applied for and each respective local authority granting the licences asks where the performance is taking place. The resion for this is then each of the local authorities granting the licenses should notify (provides details to) the council where the performance is taking place. It is then the local authority where the performance is taking place that may or may not decide to carry out an inspection.

 

I speak not only from my experience, but having contacted several local child protection officers in different areas having children from several different local authorities and at the same time performing in another local authority area.

 

Another thing to consider, I haven’t mentioned it because it is just another exception, it is possible (in a very few cases) to have the venue licensed i.e. the venue takes the responsibility for a lot of the duties surrounding the chaperone and the licensing. I am not going to say any more here as it is (in at least one case I am aware of) a trial to help get around all this red tape.

 

Regards

 

P.S. I say I speak from experience - I am a trained registered chaperone and have licensed children from the point of view of the organisation putting on the performance and therefore dealing with all the different local authorities.

[Ynot]

Incorrect - the rule is children must be licensed up to the age of 16 and still in full time statutory education. So, if like my daughters, your birthday is early in the school year, they need licensing up to the point that they officially leave that school at the end of year 11

 

Ynot, Your comment above, it is you that is incorrect not me.

 

In October 1968 the Home Secretary made an order bringing Part II of the Children & Young Person Act 1963 into force. The Act and the Regulations constitute a comprehensive code governing the circumstances in which children under the upper limit of compulsory school age (section 58 1944 Education Act) may take part in performances of all kinds, and containing safeguards for the children (compulsory school age ends on the last Friday in June of a child's final GCSE year)

 

So a child who's 15th birthday is say on 25th July and was also performing say on 15th July would technically be 15 years old at the time of the performance, but they would not be of compulsory school age and therefore out side the licensing requirement.

Sorry, John, but I'm not quite sure where you're going with that one... Did you mean to use 15 as the age under discussion? ANY child under 16 (ie 15 or under) MUST still be in compulsory education.

 

But the essence of my statement is perfectly correct. Taken from page 3 of the WCC Guidance Document...

Does my child need a licence?

The law applies to all children from birth until completion of compulsory schooling (last Friday in June, during the school year in which the child attains the age of 16).

Now that ties up with your statement above, but you seem to be disagreeing with what that says at the same time...

Quite simply, whilst a child is still at normal secondary school, even if they're 16 and 8 months old, they will STILL need a licence to perform if they've racked up the 4 in 6 months tally.

 

This is actually dependent on the interpretation of the relevant county council - some say it's 4 DAYS, others stipulate 4 PERFORMANCES, which means in the latter case a matinee and evening show counts as TWO.

 

You say "dependent on the interpretation of the relevant county council" there is no room for interpretation as far as the Act is concerned. Looking at the Act (as far as I am aware) it only talks about Days not Performances with regard to this issue. So which county council(s) is it that you referring too?

I can't quote chapter and verse, but it was raised at one of the sessions we hosted for the CPS that other authorities were more stringent in their interpretation of this. However, if a CC did decide that they wished to treat 2 performances on the same day as 2 of the 4, then they're effectively erring on the side of caution.

 

I don't believe it's the case in all locales, but certainly in Warwickshire, EVERY performance with children from WCC will be inspected.

 

Well what I said was "The local authority have the power to carry out an inspection before during or after a performance to see if the regulations are been followed correctly (heavy penalties could apply for non compliance)".

 

The fact in your experience in Warwickshire, EVERY performance with children from WCC will be inspected. This is amazing?

 

I know from my own experience and talking to the Child protection officers in 4 local authorities around me, this just doesn't happen. They would love this to happen, but they just don't have the manpower to carry out an inspection for every child. It would be an impossible task considering budgeting and resource restraints councils have.

 

So if I was to look at your statement "in Warwickshire, EVERY performance with children from WCC will be inspected" So if this is true, just taking an example, a child from WCC performs in say Buckinghamshire you are saying they get inspected. Who does it? Are you saying the Warwickshire child protection come down to Buckinghamshire to carry out their inspection? I know for a fact Buckinghamshire (I would have said all local authorities, but accepting your comment about Warwickshire I would therfore say 99% of local authorities) don't have the resources to carry out a 100% check on all children.

OK - maybe saying EVERY was a little strong, but they most certainly do make the attempt to inspect every one that they are able to - which isn't necessarily as difficult as might be imagined. Not sure how many inspectors WCC have at the moment - there were 3 at one stage for our part of the county, and I know that just about every qualifying show in my venue HAS been done.

As for who inspects WCC children out of area, they would normally request the local CPS to do this on their behalf. And for those with kids from multiple areas, I'd expect them to co-ordinate who would be responsible.

 

Can't dispute the majority of your posts as you're obviously well informed. Like yourself, I've been registered as a chaperone since the new 'rules' came in some years ago, and am a signatory for approving others for my venue. We've hosted several sessions and seminars in conjunction with WCC, both for CPS legislation itself and guidance for chaperones. I have regular contact with our CPS team, and I personally know one of the regular inspectors.

[JohnA]

Sorry, John, but I'm not quite sure where you're going with that one... Did you mean to use 15 as the age under discussion? ANY child under 16 (ie 15 or under) MUST still be in compulsory education.

Sorry I made a typo.

 

My original comment was

 

As far as licensing the children are concerned

 

1. Generally it is the ones that are under 16 that you need to concern yourself about. I say generally as it is possible depending upon the actual date of birth when compared to the school year (I am not sure if it is the start or the end), but it is possible to have a child that is actually 15 at the time of the performance that the local authority say that they don’t need licensing.

 

Your reply was

 

Incorrect - the rule is children must be licensed up to the age of 16 and still in full time statutory education. So, if like my daughters, your birthday is early in the school year, they need licensing up to the point that they officially leave that school at the end of year 11

All that I said was it was “It is possible to have a child that is actually 15 at the time of the performance that the local authority say that they don’t need licensing.”

 

To explain and add some more detail to an example.

 

Take a child who was born on 25th July 1995.

 

At the present date (2nd December 2010) they would be 15 years 5 months.

 

In the school year ending on the last Friday in June 2011 (i.e. 24th July 2011) the child would still be 15 (i.e.15 years 10 months – well almost 11 months).

 

If there was a performance taking place say on 15th July 2011 and say the child because of the number of days they have already done in the last 6 month you would want to licence them. Well they would no longer need to have a licenced because although they are technically 15 years old they are classed as no loner of compulsory school age and therefore out side the licensing requirement. This is because the school year ending 2011 has already ended and by the time the next school year starts the child would already be 16 (16 on 25th July 2011).

 

 

I can't quote chapter and verse, but it was raised at one of the sessions we hosted for the CPS that other authorities were more stringent in their interpretation of this. However, if a CC did decide that they wished to treat 2 performances on the same day as 2 of the 4, then they're effectively erring on the side of caution.

 

Well not having experience of Warwickshire CC I have had a look at their website and they talk about days not performances. http://www.warwickshire.gov.uk/web/corpora...025709D0043BDC0

 

If Warwickshire CC decided that they wished to treat 2 performances on the same day as 2 of the 4 I would say they are exceeding their authority. It might be the person(s) didn’t really know the law.

 

As for erring on the side of caution, I don’t agree. Why....

 

1) There are enough people out there now only put on performances say at the end of term (outside school times) say 2 or 3 days across three terms and they are falling into the registration process and have to complete more forms. They still would (and most venues require you to have the chaperones) otherwise comply with the chaperone element, so why get tied up in more paper work just because some council employee wants to ignore the law and err on the side of caution.

I am not alone, I know some senior Child protection officers and their opinion of the 4 day rule in the previous 6 months (especially outside normal school terms) is a bit excessive. I would also say talking to lots of other groups putting on performance they would agree with this.

I had a recent case were one child had done two performances with the group I was working with. When we checked with the girls monther it turned out she had als done two days of performance (in the last six months) with a local Bally school. So taking the two days she had done 4 months previously with the group and the 2 days with the Bally school she now had to be licenced for one days performance because she would be over the 4 day rule.

 

2) If Warwickshire CC want to err on the side of caution why not make licensing compulsory for all performances?

 

3) There are limited resources and personnel within the Child Protection teams in local authorities. They shouldn’t be tied up in paper work for the sake of paper work.

 

4) This is one reason why trials of licensing venues are taking place instead of licensing the children directly.

 

Regards

[paulears]

The thing that impacts on this bit

So a child who’s 15th birthday is say on 25th July and was also performing say on 15th July would technically be 15 years old at the time of the performance, but they would not be of compulsory school age and therefore out side the licensing requirement.

 

However, the would still need the license as a licensed child is the ONLY way anyone under 16 can work in a theatre - as it's one of the prohibited places. So for an open air event in a park, then the children's performance license would not be needed - but shift the venue to a theatre, then without the license, they cannot work - and performing is work in the eyes of the law, even if unpaid.

[RichardCaswell]

Sorry if I offend anyone, but this is madness. We are certainly not this crazy on the other side of the pond. I don't know the rules for paid acting roles, but its no big deal for a kid to be in a play/dance recital/ect for a few shows (some are up to 6-8 performances) after school. I performed way more than 6 times a year at 12-13 years old (going up from there as I got older) and there was never any silly forms for the government.

 

 

It is simply the utter madness of UK governing bodies.

There was a time (quite rightly) when kids performed 8 shows a week, they loved it, no harm done to anyone.

The UK and it's Health & Safety rules are NOTHING to do with either health or safety, they are only there to try and prevent legal action being taken, nothing more, nothing less.

They are, quite frankly, a damned disgrace and a pain in the butt.

[Ynot]

All that I said was it was "It is possible to have a child that is actually 15 at the time of the performance that the local authority say that they don't need licensing."

 

To explain and add some more detail to an example.

 

Take a child who was born on 25th July 1995.

 

At the present date (2nd December 2010) they would be 15 years 5 months.

 

In the school year ending on the last Friday in June 2011 (i.e. 24th July 2011) the child would still be 15 (i.e.15 years 10 months – well almost 11 months).

 

If there was a performance taking place say on 15th July 2011 and say the child because of the number of days they have already done in the last 6 month you would want to licence them. Well they would no longer need to have a licenced because although they are technically 15 years old they are classed as no loner of compulsory school age and therefore out side the licensing requirement. This is because the school year ending 2011 has already ended and by the time the next school year starts the child would already be 16 (16 on 25th July 2011).

John, sorry to be blunt but no, you are WRONG!

 

NO child of 15 can perform on stage for more than the prescribed number of days/shows without being licensed. In your example where said child's birthday falls after the June date of the end-of-year just doesn't qualify. I'll refer you to my previous quote from the WCC guidance:

The law applies to all children from birth until completion of compulsory schooling (last Friday in June, during the school year in which the child attains the age of 16)

which quite simply and clearly supports my argument. Please read it carefully and I think you'll see my point.

 

If Warwickshire CC decided that they wished to treat 2 performances on the same day as 2 of the 4 I would say they are exceeding their authority.

Er, di I say it was WCC? No. I said some authorities were apparently doing so due to their interpretation. I cannot comment on why and whether they are indeed exceeding their authority.

 

 

It is simply the utter madness of UK governing bodies.

There was a time (quite rightly) when kids performed 8 shows a week, they loved it, no harm done to anyone.

The UK and it's Health & Safety rules are NOTHING to do with either health or safety, they are only there to try and prevent legal action being taken, nothing more, nothing less.

They are, quite frankly, a damned disgrace and a pain in the butt.

 

And whilst I'd be amongst the first (and indeed have been) to rail against the over-zealous knee-jerk legislation that we have here, at the moment, unfortunately, it's all that we have to work with, and as such must be seen to be doing what's laid down.

Yes, there are areas where interpretation is possible which may cause extra issues, but most groups tend to go more overboard than they need to just so they can say they comply....

[JohnA]

I am sorry it is you that is wrong and if you follow the links below I will refer you to my sources.

To explain..

 

As part of my training to become a chaperone I was told

 

“In October 1968 the Home Secretary made an order bringing Part II of the Children & Young Person Act 1963 into force. The Act and the Regulations constitute a comprehensive code governing the circumstances in which children under the upper limit of compulsory school age (section 58 1944 Education Act) may take part in performances of all kinds, and containing safeguards for the children (compulsory school age ends on the last Friday in June of a child's final GCSE year)”

 

Now I could write to the Child Protection teams in different areas and ask them what the law says - Westminster would probably be a good one to contact as they have a lot more responsibilities.

 

However before I do that I have taken a look at the relevant ACTs.

 

Have any of you done so? Maybe I am reading the Act(s) wrong, but I am sure you will tell me if I am.

 

So if you go to the "Children and Young Persons Act 1933 (c.12)"

 

http://www.statutelaw.gov.uk/content.aspx?...;filesize=31372

 

Look 2/3 of the way down the page

 

Interpretation of Part II.

— [F14 (1)] For the purposes of this Part of this Act and of any byelaws [F15 or regulations] made thereunder—

[F16 The expression “child” means—

(a) in relation to England and Wales, a person who is not [F17 over compulsory school age (construed in accordance with section 8 of the Education Act 1996)]

 

So a ‘Child’ is one who is NOT over the compulsory school age. What is the ‘compulsory school age’?

 

Then look at section 8 of the Education Act 1996 for the definition of compulsory school age.

 

http://www.legislation.gov.uk/ukpga/1996/56/section/8

 

Compulsory school age.

 

(3)A person ceases to be of compulsory school age at the end of the day which is the school leaving date for any calendar year—

 

(a)if he attains the age of 16 after that day but before the beginning of the school year next following,

 

So in my example (sorry to go back to it)

 

"Take a child who was born on 25th July 1995.

 

At the present date (2nd December 2010) they would be 15 years 5 months.

 

In the school year ending on the last Friday in June 2011 (i.e. 24th July 2011) the child would still be 15 (i.e.15 years 10 months – well almost 11 months).

 

If there was a performance taking place say on 15th July 2011 and say the child because of the number of days they have already done in the last 6 month you would want to licence them. Well they would no longer need to have a licenced because although they are technically 15 years old they are classed as no loner of compulsory school age and therefore out side the licensing requirement. This is because the school year ending 2011 has already ended and by the time the next school year starts the child would already be 16 (16 on 25th July 2011)".

 

Regards

 

P.S. Sorry Ynot, no you didn’t say WCC,

 

 

=====================================

 

 

 

Paulears - I feel another long drawn out discussion coming on here (please, please let me be wrong).

 

You say

 

However, the would still need the license as a licensed child is the ONLY way anyone under 16 can work in a theatre - as it's one of the prohibited places. So for an open air event in a park, then the children's performance license would not be needed - but shift the venue to a theatre, then without the license, they cannot work - and performing is work in the eyes of the law, even if unpaid.

 

As far as I am aware, ‘yes’ under 16's generally working in a theatre comes under prohibited places.

 

I also agree “performing is work in the eyes of the law, even if unpaid”.

 

However the law specifically covers “performing” separately as opposed to say operating the lighting desk or acting as an usher.

 

Under the “performing” heading there are exceptions, part of which is the 4 day rule. There are other qualifying requirements that you have to comply with, just one of which for example is unpaid work, but I won’t list out all the other requirements and exceptions.

 

As a matter of procedure, if I am ever helping with the licensing applications, I also include a separate list to the local authorities of the children I believe come into the 4 day rule so they can check and add to their records.

 

In return, if all is okay, I get a letter of acknowledgement and confirming to the best of their knowledge these children don’t need licensing.

 

If you are referring to something else, I am unsure as to what you are getting at?

 

Regards

[paulears]

No it's fine - my point was that the only legal way to get kids under 16 working in a prohibited place is via the licensing system - BUT if the licensing system cannot license them because they are too old - then any kid in this difficult age range can't work, can they? Too young to work in a prohibited place, but outside the scope of licensing? I'm not suggesting anyone is wrong, perhaps other than the people who mis-designed the legislation.

[JohnA]

Yes Paulears, I see your point, and a good one that is. I hadn’t thought of it other than from the performance point of view.

 

I would agree it looks like mis-designed of the legislation.