Saying "Thank you"......

The Clarence Valley Independent, 2 May 2018:

A letter from mum and dad

Ed,

We will never forget certain things from this journey ever in our lives. On March 22, 2018 our lives changed forever.

Watching our baby Emerald (7 months old) go into cardiac arrest and multi organ failure one hour after arriving at our local hospital, me just taking her because I thought she was sick, then it all went downhill from there. The NETs retrieval team was called in to take us to Westmead; Emerald suffered a seizure in Grafton from low blood sugar that resulted in a brain injury and fluid on her brain, needing life support. It took NETS another six hours to stabilise her to get on the plane. Emerald was blue and lifeless and no one thought she would make it; in that moment I thought my baby had died, then the next day eight hours after arrival at the children’s hospital, we had a diagnosis of a very rare CHD called ALCAPA that Emerald had been silently fighting for seven months and was never picked up. They took her for major open heart surgery at 8am on March 23; the longest day of my life. They told me to be prepared for the worst as they expected Emerald to come back on the ECMO (the double bypass machine for lungs and heart).

3pm came and Emmy was about to come out of surgery and she wasn’t on the machine! When the head surgeon sat me down and pretty much told me no one told him about her low blood sugar and Emerald suffered another seizure creating a complication for the surgery, yet she still didn’t come back on that machine, they kept telling me that she would end up on it to give her heart a rest; the next week was very touch and go, we almost lost our girl three more times but still no ECMO; Emerald was fighting so hard
And the doctors telling me that her liver and kidneys won’t make it; she was so puffed up with fluid and so yellow from the jaundice and that they thought she had more seizures, but couldn’t tell because she was on the muscle relaxant, the only thought in my head was if she was going to be ok. I didn’t care if her brain injury resulted in her being a little more special, I just wanted to know she was ok – they couldn’t guarantee us anything and they still can’t. Emerald also contacted two blood infections, pneumonia from being on the life support and a collapsed lung.

This experience has been very trying and testing and very traumatising and we feel so out of our comfort zone being here and almost 700km away from home.

A few anxiety attacks from mum and dad over the last 5 weeks
Some very touch and go moments I will never forget.
We are slowly on the road to recovery, Emerald has astounded all her doctors with how far she has come and that she ever once stopped fighting.

Emerald is a miracle five weeks post op and she is saying mum, hi, can do high 5; eating solids again and rolling over from side to side!

I could not be standing here today beside my heart warrior if it wasn’t for the support from my family and friends and the entire community who has rallied around my daughter to help us. Thank you for all the donations and the prayers; we are truly blessed to have such caring kind hearted people in our lives and our little gem is fighting to get back to our little community so we can say thank you to everyone that has helped us.
Thank you from the bottom of my heart.

I know this journey still has a long, long way to go and the shock has worn off finally and is only just hitting me now, but every day is a step closer to home and Emmy is improving every single day.
And I appreciate everything you all have done – Thank you.

Thank you for never leaving Emerald in the dark.

Jess and Kev – Emerald’s parents

Heard Budget Speech 2018, read this morning's headlines? Now hunt the dollars using this cheat sheet

Because there is a great deal of sleight of hand in federal government annual budget announcements, to be sure that what the Turnbull Government is planning doesn't make life harder for you, your family and community everyone needs to read the fine print.

Budget Paper No. 1: Budget Strategy and Outlook - provides:

* information about the international and domestic economic outlook, including numerical estimates of key parameters such as gross domestic product (GDP) growth, employment, and the consumer price index (CPI)

* a statement of the Government’s fiscal strategy and the fiscal outlook of the Commonwealth (that is, the Government’s outlook and strategy for revenue, notably taxes)

* estimates of the revenues and expenditures of the Commonwealth, and their composition

* information on the proposed capital investment of the Commonwealth • information on the assets, liabilities—including contingent liabilities, or ‘risks’—and debt held or owed by the Commonwealth, and

* historical information about the Commonwealth’s fiscal and debt position. 

Go to: 

https://www.budget.gov.au/2018-19/content/bp1/download/BP1_full.pdf

Budget Paper No. 2: Budget Measures - contains information about the budget measures/policies Government intends to pursue and each measure will have a costing attached to it.

Go to: 

https://www.budget.gov.au/2018-19/content/bp2/download/bp2_combined.pdf

Budget Paper No. 3: Federal Financial Relations -  contains information about financial assistance grants made by the Commonwealth to States and Territories. Includes specific purpose payments for health, education, roads, local government.  Also provides estimates of the amount of GST revenue that will be collected, and estimates of how much each state and territory will receive from the GST.

Go to:

https://www.budget.gov.au/2018-19/content/bp3/download/Budget%20Paper%203.pdf

Budget Paper No. 4: Agency Resourcing - deals with various types of appropriations that are used by the Government to fund entities and activities. Shows the amounts and types of appropriation that are expected to be utilised in the forthcoming year.

Go to: 

https://www.budget.gov.au/2018-19/content/bp4/download/BP4_full.pdf

[Sources http://parlinfo.aph.gov.au/parlInfo/download/library/prspub/4523572/upload_binary/4523572.pdf & https://www.budget.gov.au/2018-19/content/documents.html]

Lock The Gate back in court asking questions about "secretive deals" between NSW Coalition Government and Shenhua mining group

NSW Environmental Defender’s Office (EDO):

Lock the Gate Alliance v Dept of Planning & Environment / Dept of Premier & Cabinet

Our client Lock the Gate is seeking access to information held by the NSW Government about secretive deals relating to the “buy-back” of the coal exploration licence for Shenhua Watermark Coal Pty Limited’s (Shenhua) controversial Shenhua Watermark Coal Mine in the Liverpool Plains in north central NSW, one of the nation’s most productive agricultural regions.

Lock the Gate argues that the public has a right to know about deals made behind closed doors in relation to the exploration and development of the proposed Watermark coal mine. Lock the Gate argues that accountability and transparency in this case are essential given the significant predicted impacts of the Watermark mine on the Liverpool Plains, the nation’s agricultural industry, local communities and the environment.

On behalf of Lock the Gate, we are asking the NSW Civil and Administrative Tribunal to decide that the release of this information is in the public interest.

Farmland on the Liverpool Plains. Photo: Lock the Gate Alliance.

Background

In July and September 2017, respectively, Lock the Gate made applications to the NSW Department of Planning and Environment and the NSW Department of Premier and Cabinet for information about Shenhua’s application to renew its exploration licence for the Watermark mine. That information encompasses secretive dealings between Shenhua and the NSW Government that resulted in the buy-back of around 51% of the exploration licence, which covered the highly fertile “black soils” of the Liverpool Plains, at the cost of $262 million to the public.

Whilst the NSW Government claims that the buy-back was necessary to protect the black soils from mining, and thereby the agricultural industry of the Liverpool Plains, Lock the Gate contends that the buy-back will do nothing to lessen the expected impacts of the mine. Furthermore, Lock the Gate argues that the buy-back was completely unnecessary. The NSW Government could have used its powers under the Mining Act to reduce the size of the exploration licence by 50% upon its renewal without the payment of any compensation to Shenhua.The NSW Government could also have cancelled the exploration licence outright given that Shenhua had allegedly failed to comply with a condition of the licence that required substantial development of the Watermark mine to have commenced by October 2016, eight years after the initial grant of the licence in 2008.

The information sought by Lock the Gate includes Shenhua’s submissions on the licence renewal application, its request for the abovementioned licence condition to be suspended, Ministerial briefings and draft deeds of agreement about coal exploration and mining titles. The NSW Government has withheld this information on the basis that, amongst other things, it contains Cabinet information, was provided in confidence, or that its release may be prejudicial to Shenhua’s business interests – and therefore that there is an overriding public interest against its disclosure.

On the contrary, Lock the Gate argues that the overwhelming public interest in the release of the information is clear.

Access to this information will increase the accountability and transparency of the NSW Government in relation to the exploration and development of coal in the Liverpool Plains. This is particularly important in these circumstances where the Government has done deals with a private, foreign-owned, coal mining company behind closed doors and these have resulted in the expenditure of vast amounts of public funds without clear justification.

Access to this information is also vital for the public to have confidence in the decision-making processes of the NSW Government in relation to dealings about coal mining and exploration projects. This is essential where these dealings involve projects that are likely to have significant economic, social and environmental impacts and in which a number of stakeholders have expressed competing views. 

The more transparency around those deliberative processes, the more likely it is that they will be of high quality and will serve the public interest.

The matter is listed for hearing on 9 May 2018.

Brendan Dobbie, solicitor for EDO NSW, has carriage of this matter for Lock the Gate and our Principal Solicitor, Elaine Johnson, is the solicitor on record.

We are grateful to barrister Scott Nash for his assistance in this matter.

'Surrounded by secrecy'

Link to this case summary.

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Is Telstra selling customer location data? Did it ever specifically request permission from account holders?

https://www.telstra.com.au/content/dam/tcom/personal/privacy/pdf/sample-data-oct-2015.pdf

The Sydney Morning Herald, 4 May 2018:

Telstra is making money by on-selling location data from its customers' mobile phones in similar deals to a partnership with the Bureau of Statistics that caused a public backlash last week.

The Australian Bureau of Statistics came under fire for partnering with the telco for a study in 2016, which used mobile phone data showing how many people were in particular suburbs hour by hour.

Similar data is now available for a fee, after the Location Insights program was quietly launched by the telco in July 2016. The Australian Bureau of Statistics was the first licensee under the program, but has not used Telstra's Location Insights since then.

Data available to Telstra's clients can be broken down into 15 minute increments, and demographics broken down by age groups and gender. The smallest geographic areas available for analysis are the same as the Australian Bureau of Statistics' smallest statistical area, which have an average population of 400 people and could have as few as 200 people.

In a video used to spruik the service by Telstra, potential customers are listed as local governments and transport companies. It’s not clear how many organisations have used the service, or what the price tag is for such information.

“Imagine if you could know what is happening in your community, region, or city hub, every 15 minutes,” a voiceover in the Youtube video promoting the program said.

“Telstra Location Insights builds industry-specific metrics where data sets are used for modelling purposes and then extrapolated to estimate for the entire population,” a Telstra spokesman said.

“These metrics are aggregated spatially and temporally before differential privacy and k-anonymisation are both applied to completely anonymise the data.”

This explanation is not accepted by senior lecturer at the University of Melbourne Vanessa Teague.

“In order to know whether those things actually work, we need to see what the parameters are and how they're applied to the data in order to be assured that they’re applied correctly and they work,” Dr Teague said.

Dr Teague is chair of the Cybersecurity and Democracy Network and was part of a team of researchers who re-identified patient health records from Pharmaceutical Benefits Scheme data that was released by the government.

“It's possible that [anonymising the data] has been done correctly, it's also possible that they think it’s been done correctly but they’re wrong. And really the only way to assess that is to get a clear and detailed technical description of what they've done,” Dr Teague said.

“If they've done it right then there's no reason to be secretive about the details of what they’ve done, if they’ve done it wrong then they are better off getting a genuine open assessment of it so they can find out sooner rather than later.”

Telstra said the use of the information was in line with its privacy statement, which states that customers’ information could be shared with “our dealers, our related entities or our business or commercial partners and other businesses we work with”.

Dr Teague is sceptical about that explanation. “Just because a company holds highly sensitive information about you doesn’t mean that that data is their property that they should then be able to turnaround and sell without asking you,” she said.

Now when I read Telstra's privacy statement I do not recall that it mentioned that it would be selling mobile phone location information in SA1 statistical level data bundles captured at 15 minute intervals (as mentioned in the news article) and, that those bundles could be used to create data sets which track an individual's movements over time in relatively fine detail.

Yamba in the Clarence Valley NSW is a quiet little town with a population of approx. 6,076 persons living in 3,820 dwellings spread across est. 16 SLA1 statistical levels and in over 100 even smaller statistical Mesh Blocks.

http://stat.abs.gov.au/itt/r.jsp?ABSMaps 

I suspect that many Yamba residents will not be happy with the idea that Telstra Corporation Limited will alllow their movements to be tracked and their daily habits predicted if an individual, private company, government agency or political party pays them for the town's mobile phone location data.

Gladstone Qld inherits serial fantacist

Still trying to sell 'the dream", former truck driver Des Euan has moved on from Port Of Yamba NSW to Gladstone in Queensland....

The Observer, 16 March 2018:

North Coast Voices readers may recall that he was touting both the Yamba 'mega port' and the Gladstone mega logistics hub to the Dept. of Infrastructure and Development in August last year.

Following in his previous footsteps Euan has created a shell company, set up a website and is apparently well into his patter.

Both Resources and Northern Australia Minister and Liberal Senator for Queensland Matt Canavan and local state Labor MP for Gladstone Glen Butcher reportedly support Euan's scheme.

Perhaps the people Gladstone should ponder on the reasons why that ancient Roman maxim caveat emptor has lasted down the ages.

* Hat tip to Clarrie Rivers for supplying link the newspaper article.

Ballina not happy with second-rate NBN installation plans

The Northern Star, 4 May 2018:

BALLINA'S deputy mayor is calling on residents to speak out against about the NBNCo's plans to deliver "second class technology" to local residents.

Cr Keith Williams said he had been contacted by residents in East Ballina, Skennars Head and Lennox Head to say they would be getting "inferior" fibre to the node NBN connections.

But he said fibre to the kerb should be the minimum installation standard across the shire.

"We know that fibre to the node places more reliance on the copper network, limits potential speeds and is more expensive to upgrade," Cr Williams said.

"This places a real limit on the economic potential of the area, not just now, but potentially for years to come.

"It makes no sense whatsoever when you consider that all these areas are close to the coast and more exposed to the effects of salt water.

"This is precisely the areas where you want less reliance on copper."

Cr Williams said failure to oppose NBN rollout plans now, risked leaving residents in these areas with a second class NBN.

"NBN Co have insisted this is not second class technology, being essentially the same technology as fibre to the kerb," he said.

"In this they are correct, but they avoid the central point.

"The greater reliance on the old copper network means it is a second rate service, slower, more prone to dropouts and more expensive to upgrade.

"From my enquiries to date it seems there is no formal mechanism to seek a review of the NBN Co rollout plans.

"The only way these things change is by community pressure and adverse publicity.

"I'm asking everyone in the area to go to the NBN website, check what the rollout plans are for your house and if it says Fibre to the Node, let NBN Co know that it just isn't good enough.

"You deserve better."

Elder abuse and profit shifting go hand-in-hand in the age care sector?

Any regular reader of online news would have seen mentions of elder abuse, neglect and sub-standard health care over the years.

hellocaremail.com.au, 2017:

Elder abuse is a critical issue in aged care homes, with thousands of cases reported to the Health Department every year…. In 2016-2017, there were 2853 reports of “reportable assaults’’ and 2463 allegations of “unreasonable use of force”.

Australian Law Reform Commission, Elder Abuse (DP 83), Abuse and neglect in aged care, 12 December 2016:

1.34   Stakeholders reported many instances of abuse of people receiving aged care. These included reports of abuse by paid care workers[55] and other residents of care homes[56] as well as by family members and/or appointed decision makers of care recipients.[57] For example, Alzheimer’s Australia provided the following examples of physical and emotional abuse:

When working as a PCA [personal care assistant] in 2 high care units, I witnessed multiple, daily examples of residents who were unable to communicate being abused including: PCA telling resident to ‘die you f---ing old bitch!’ because she resisted being bed bathed. Hoist lifting was always done by one PCA on their own not 2 as per guidelines and time pressures meant PCAs often using considerable physical force to get resistive people into hoists; resident not secured in hoist dropped through and broke arm—died soon after; residents being slapped, forcibly restrained and force-fed or not fed at all; resident with no relatives never moved out of bed, frequently left alone for hours without attention; residents belongings being stolen and food brought in by relatives eaten by PCAs.[58]

1.35   The ALRC also received reports of other forms of abuse, including sexual[59] and financial abuse.[60] Restrictions on movement[61] and visitation[62] were also reported. Many submissions also identified neglect of care recipients.[63]

The Sydney Morning Herald, 15 October 2017:

Across NSW, 58 per cent of aged care workers surveyed said they have not been able to provide the level of care residents deserved because of budget cuts. Of those, 80 per cent said staff shortages were the main barrier to providing proper care.

The Courier-Mail, 19 April 2018: 

PROFIT-HUNGRY aged care companies are charging fat “administration fees” to skim up to 40 per cent of government payments for in-home nursing care.

More than 100,000 elderly Australians are on a waiting list to receive as much as $50,000 a year in a “homecare package” to pay for nursing, housekeeping or companionship at home. But an investigation by The Courier-Mail has revealed that some home-care companies are pocketing as much as $19,000 of the taxpayer cash through hefty “administration” or “case management” fees.

The fees are billed on top of hourly charges for home help – leaving clients with less cash to spend on in-home care such as nursing. And if clients want to switch to a cheaper provider, they are being slugged up to $1000 in “exit fees”.

The Age, 3 May 2018:

Scandals, including a recent national audit showing 600 aged-care homes failed in the past five years to provide minimum standards, prompted a government review. The Coalition, accepting a key recommendation, has ended the ridiculous practice of alerting operators to spot checks. The review also urged the streamlining and strengthening of the regulator.

If one does a simple online search many of the big ‘for profit’ aged care providers are named in relation to such abuse, neglect and sub-standard health care allegations.

Now in May 2018 the Tax Justice Network^[1]  is looking at aged care provision from another angle. One which shows that the budgetary meanness which sees these big companies expect elderly residents to remain in sodden incontinence pads or live-off meagre meal rations occurs in spite of the millions in profit made on the back of billions in taxpayer funding of the age care sector.

It has released A Tax Justice Network – Australia Report, TAX AVOIDANCE BY FOR-PROFIT AGED CARE COMPANIES: PROFIT SHIFTING ON PUBLIC FUNDS.

Sadly, this report only confirms the fact that corporate greed runs rampant through all major aspects of Australian life, including aged care.

Executive Summary, Background, p.5:

Older people are a growing proportion of Australia’s population; in 2016, 15% (one in seven) Australians were aged 65 years or older. By 2056 this percentage is expected to grow to 22% (8.7 million).1 The need for aged care services is increasing. Between 2015– 2016 almost 214,000 people entered aged care in Australia. On average, older people in Australia spend three years in permanent residential care, just over two years in home care, and one and a half months in respite care.2 The Australian tax payer, via the Commonwealth Government contributes around 75% of the expenditure in aged care in Australia, which is around 96% of the total funding on aged care from Commonwealth and State Governments. Government recurrent spending on aged care services in Australia was $17.4 billion Australian dollars (AUD) in 2016- 2017, with residential aged care services accounting for 69.3% ($12.1 billion AUD).3 Some of this funding is provided as subsidies to aged care provider companies including those that operate for profit. In 2018 the Australian Nursing and Midwifery Federation (ANMF), Australia’s largest national professional and industrial nursing and midwifery organisation with over 268,500 members, commissioned the Tax Justice Network - Australia to analyse possible tax avoidance by for-profit aged care companies and to provide recommendations for improving transparency on Government spending on for-profit aged care.

Key points from the report

* By number of beds, not-for-profit providers are the largest aged care provider group in Australia (52% in 2013-2014), however there has been a rapid growth in the size and spread of for-profit companies; Bupa, Opal, Regis and Estia are the largest aged care providers nationally. If Japara and Allity are included, these 6 for-profit companies operate over 20% of residential aged care beds in Australia.

* In the most recent year (mostly the 2017 financial year) the six largest for-profit companies were given over $2.17 billion AUD via government subsidies. This was 72% of their total revenue of over $3 billion. These companies also reported profits of $210 million AUD (2016-2018).

* Companies can use various accounting methods to avoid paying tax. One method is when a company links (staples) two or more businesses (securities) they own together, each security is treated separately for tax purposes to reduce the amount of tax the company has to pay. Aged care companies are known to use this method as well as other tax avoiding practices. Another practice is by “renting” their aged care homes from themselves (one security rents to another) or by providing loans between securities and shareholders.

* The six largest for-profit aged care providers have enormous incomes and profits:

* The largest company, BUPA, had almost $7.5 billion in total income in Australia (2015-16) but paid only $105 million in tax on a taxable income of only $352 million.

* BUPA’s Australian aged care business made over $663 million in 2017 and over 70% ($468 million) of this was from government funding.

* Funding from government and resident fees increased in 2017, but BUPA paid almost $3 million less to their employees and suppliers.

* The second largest, Opal, had total income of $527.2 million in 2015-16 but paid only $2.4 million in tax on a taxable income of only $7.9 million.

* 76% ($441 million) was from government funding in 2016.

* Allity had total income of $315.6 million in 2015-16 and paid no tax.

* 67% ($224 million) of Allity’s revenue was from government funding in 2016-17.

* Regis, Estia, and Japara are listed on the Australian Securities Exchange (ASX) but appear to be using methods to reduce the amount of tax they pay while earning large profits from over $1 billion of government subsidies.

* Family owned aged care companies (Arcare, TriCare, and Signature) receive between $42-$160 million each in annual government subsidies but provide very little public information on their operations and financial performance and may use accounting methods to avoid paying tax.

 * (All figures quoted above are in AUD)

* The Australian Government and the Federal Opposition (the Australian Labor Party) have proposed several ways to fix the problems with companies avoiding tax by using trust structures and other methods but there are still loopholes.

* It is difficult to get a detailed and complete picture of the full extent to which these heavily subsidised aged care companies are avoiding paying as much tax as they should, because Australian law is not currently strong enough to ensure that their financial records and accounting practices are publicly available and fully transparent.

Conclusion

The six largest for-profit aged care providers in Australia received over $2.17 billion AUD in annual tax payer funded subsidies which provided after tax profits of $210 million AUD. The actual operating profits were much larger. These providers only paid around $154 million AUD in tax in 2015-16. Companies that receive millions of tax payer dollars via Australian government subsidies must be required by law to meet higher standards of transparency in financial reports and be publicly accountable. The report calls upon the Government, Opposition, and cross-bench Senators to work together to make laws to stop aged care providers from avoiding the taxes they should pay and provide clear records of their business dealings.

The Tax Justice Network – Australia strongly supports recent government legislation that has been introduced to close loopholes in the Multinational Anti-Avoidance Law and government reforms to stapled structures. However, there is still a need for additional transparency measures. The Tax Justice Network – Australia also strongly supports a policy proposed by the Australian Labor Party to introduce minimum taxation of discretionary trusts. These reform measures are examined in more detail by this report in the section: Current Reform Measures.

This analysis of tax payments and corporate structures of the largest for-profit aged care companies provides clear evidence that simple common-sense reforms are needed immediately to restore integrity to the tax system and to ensure public accountability on billions of dollars in government spending.

RECOMMENDATIONS FROM THE REPORT

Any company that receives Commonwealth funds over $10 million in any year must file complete audited annual financial statements with Australian Securities and Investments Commission (ASIC) in full compliance with all Australian Accounting Standards and not be eligible for Reduced Disclosure Requirements. Public and private companies must fully disclose all transactions between trusts or similar parties that are part of stapled structures or similar corporate structures where most or all income is earned from a related party and where operating income is substantially reduced by lease and/or finance payments to related parties with beneficial tax treatment.

Australia’s Largest For-Profit Aged Care Companies

In Australia, non-profit providers collectively operate a majority of residential aged care beds. However, the market share of large for-profit providers continues to grow rapidly. Likewise, the influence of for profit providers on shaping government policy and influencing broader trends in the aged care sector has never been greater. Ranked by the number of government allocated residential aged care places (beds) in 2017, the six largest for-profit aged care companies in Australia are; Bupa, Opal, Regis, Estia, Japara, and Allity. Combined, they operate over 20% of all residential aged care beds in the country. These companies continue to expand market share through new developments and acquisitions. These companies are also expanding to provide more retirement living and home care services, which allow access to additional government funding. In the most recent financial year (2016-2017), these six for-profit aged care companies combined received over $2.17 billion in government subsidies.4 This made up 72% of their combined total revenue of over $3 billion.5……

COMPANY SNAPSHOT

Bupa: A United Kingdom-based mutual insurance company with global operations including aged care services. Australia is Bupa’s largest and most profitable market.

Regis, Estia, and Japara: Public aged care companies listed on the ASX.

Opal: A private aged care company owned by subsidiaries of two listed companies, AMP Capital and Singapore-based G.K. Goh.

Allity: controlled by Archer Capital, an Australian private equity firm with large foreign pension fund investors.

Arcare, TriCare and Signature (formerly Innovative Care): three family-owned, for-profit aged care companies.

NOTE:

1. The Tax Justice Network - Australia is the Australian branch of the Tax Justice Network (TJN) and the Global Alliance for Tax Justice. TJN is an independent organisation launched in the British Houses of Parliament in March 2003. It is dedicated to high-level research, analysis and advocacy in the field of tax and regulation. TJN works to map, analyse and explain the role of taxation and the harmful impacts of tax evasion, tax avoidance, tax competition and tax havens. TJN’s objective is to encourage reform at the global and national levels.

Membership of the Network can be found here.