Ministers quizzed over plans to “streamline” fracking decisions

sc perry raab

Planning guidance on fracking inquiry. Photo: Parliament TV

Government ministers were questioned by MPs last night about their proposals to take fracking decisions out of local control and scrap the need for planning applications for exploration sites.

Energy Minister, Claire Perry, and Local Government Minister, Dominic Raab, appeared last night before the Housing, Communities and Local Government Committee which is investigating planning guidance on fracking.

They were questioned on a written ministerial statement, issued last week, which announced a consultation on classifying fracking applications as Nationally Significant Infrastructure Projects (NSIP). This would mean proposals would be decided by a government-appointed planning inspector, rather than the local authority.

The written ministerial statement (WMS) also proposed making non-fracking applications permitted development so that developers would not need to apply for planning permission. The government additionally announced a planning application brokerage service and a consultation on a single shale gas regulator.

The ministers said the proposals would “streamline” decisions on fracking schemes. But Claire Perry denied they would relax regulations:


Claire Perry, MP Source: Parliament TV

“There has been a highly complex interplay between regulations and planning which means that the applications are taking a long time and creating uncertainty for local authorities and for developers.

“But I’ve had no sense whatsoever that there is a desire to lighten the regulatory burden.”

Key points

  • Only production applications would be decided as Nationally-significant Infrastructure Projects
  • Only exploration applications could be decided under permitted development
  • No current definition of exploration or whether shale gas well sites would qualify for permitted development
  • No current criteria on the scale of plans to qualify for the NSIP regime
  • Brokerage service would work with local authorities and companies but opponents don’t need support
  • No plans to consolidate planning guidance documents
  • No need for a new definition on fracking but no response on whether the use of CO2 or acid qualified as fracking
  • No comment on specific applications, local plans or a new report on seismic risks of fracking in coal mining areas
  • “No contradiction” between a 2015 WMS on national importance of shale gas and the government’s Clean Growth Strategy
  • “No desire to lighten the regulatory burden”
  • Oil and gas licensing would stay with the Oil and Gas Authority
  • No comment on which applications have been “disappointingly slow”
  • Confusion over what legislation is needed for the changes
  • Consultations expected before the summer recess but no timeframe for implementation of proposals


Permitted development

Housing minister, Dominic Raab, was asked whether the permitted development proposals went against the concept of localism. He said:

dominic raab

Dominic Raab, MP Source: Parliament TV

“There are still opportunities for local consultation and local buy-in particularly if you have a pre-condition as part of that process.”

He said the proposal was “at the formative stage”.

Developments that needed an Environmental Impact Assessment could not be treated as permitted development, he said.

Energy Minister, Claire Perry, said local authorities had the power to remove permitted development rights. She said:

“Exploration is temporary and it is subject to pre-conditions. Why would local authorities not want to go through that process to see if there is a valuable resource which could benefit their local communities, both in terms of jobs and economic impact?”

Thirsk and Malton MP, Kevin Hollinrake, whose constituency includes Third Energy’s fracking site at Kirby Misperton, asked whether permitted development would include well pad construction.

Dominic Raab replied

“The principle is that it is only in relation to the exploration phase. One of the things we will want to look at very carefully is the definition around that.”

Kevin Hollinrake said:


Kevin Hollinrake, MP Source: Parliament TV

“These well pads are significant pieces of infrastructure. If you can simply put one anywhere on a permitted development basis – that will cause real concerns”.

Dominic Raab said he would feed in these concerns.

Kevin Hollinrake asked:

“Would a test frack be considered under permitted development?”

Dominic Raab replied:

“The key distinction is between exploratory operations and ones for production. But which side of the line that would fall on I am afraid I am not the expert and we shall …

Claire Perry intervened:

“We do need to set quite clear guidelines. PD [permitted development] will need to have very clear guidelines. If it is to be successful.

perry and raab

Claire Perry and Dominic Raab Source: Parliament TV

Nationally significant infrastructure projects

Dominic Rabb said NSIP was a “tried and tested” system in the transport sector and was used for the Hinkley Point nuclear power station.

The ministers were asked if the NSIP proposal was just about speed. Claire Perry said:

“It is a predictability question. You have a one-year statutory time frame. You have national policy statements that establish a need for that particular investment and provide the basis for the decision. It does bring together this one-stop shop for planning and consents and representation.”

At an earlier select committee hearing, Ineos said NSIP was not suitable for individual well applications, while campaigners and some local authorities regarded it as undemocratic

Kevin Hollinrake asked how NSIP would deal with the cumulative impact of shale gas, which concerned people:

“It has to be acceptable locally as well as nationally. And to have a social licence there’s a concern not just about one individual well pad but the ongoing cumulative impact of these developments.”

Claire Perry said:

“We would need to be clear about what the threshold was, whether it was an extraction volume, a number of wells.

“Understanding the cumulative impact and concerns of local communities in that would be a really important part of that process.

“We would need to provide a bespoke definition for trigger points.”

She rejected the suggestion that the government wanted to “turn out beautiful countryside into some scorched Texas”

Shale gas application brokerage service

Claire Perry said the brokerage service would “assist local authority decision-makers through the process so all sides are aware of what is happening”. But ministers did not appear to think it was for opponents.

Dominic Raab said:

“The brokerage service is there for the local authority and the developer and one of the things it will do is develop positive engagement with all the statutory consultees. If we weren’t doing this, your committee would be criticising us.”

Claire Perry said:

“If you’ve got 36,000 expressions of concern, most of which are not coming from the local area, there’s a suggestion that those who want to oppose these developments don’t need any more support than they’ve already got.”

Asked what evidence there was for a need for the service, Claire Perry said:

“The feedback from Departments is that there are various levels of planning policy and these are often decisions made that are extremely controversial in the local area, often by outside influences, and we need to make sure local authorities have all the support they need to work through them.”

Liz Twist put it to ministers:

Liz Twist

Liz Twist, MP Source: Parliament TV

“Some may see this as a way of pushing through contentious applications more quickly.”

Dominic Raab replied: “This is all about the process.”

“I think it is procedural and process learning.”

Claire Perry said:

“This is a very nefarious line of questioning.  We all face controversial planning decisions in our local authorities and this is meant to be helpful to incredibly hard-pressed councillors and officers.”

She added:

“The idea that somehow we want to set up and fund something to give people reason to get round legislation and planning guidance that we’re bringing in, I’m afraid that I completely reject that.”

Matt Western MP said:

Matt Weston

Matt Western, MP Source: Parliament TV

“Perception is a very important thing and how this will come across to communities is that it is very much a skew towards the applicant getting something through.”

Claire Perry replied:

“I think it behoves all of us to be responsible when we talk about this industry and the benefits it might bring to the local economies.”

Delays in decision-making

The Written Ministerial Statement said decisions on shale gas applications had been “disappointingly slow”. Dominic Raab said:

“We have had seven planning applications for shale gas so far and of those seven decisions that were taken by the local mineral planning authorities they took between 70 and 82 weeks to get to a decision when the statutory timeframe is 13 weeks from validation from application to decision, taking 16 weeks if there is an environmental impact assessment.”

But when pressed by the committee to name the authorities, he said:

“We are not going to start singling out individual local authorities. We are in the business of supporting them. As a general matter, …. We are not getting anywhere near overall to  the statutory timeframe.”

Claire Perry said:

“All of them were outside the statutory limits.”

An earlier committee hearing had evidence from Andrew Mullaney, the planning manager at Lancashire County Council. He denied that local authorities were slowing down the process.

Limits on shale gas development

The WMS said local minerals plans should not “set restrictions or thresholds” that “limit shale gas development without proper justification.” Kevin Hollinrake asked the ministers what this meant.

Dominic Raab said he was reluctant to be drawn into a hypothetical question. Kevin Hollinrake said:

 “It’s not hypothetical in that it is in your statement.  You must understand therefore what that sentence means…. What would be a proper justification?”

Dominic Raab said:

“We need to respect that ultimately it’s for the local authorities to make those determinations.  There’s a process, the integrity of which we want to preserve and ultimately if appealed it may come to us, in which case I don’t want to prejudice it.”

 Kevin Hollinrake asked:

“Would a proper justification be the protection of other parts of the economy in an area for example?”

 Dominic Raab replied:

“There will be further guidance in due course  but I’m not going to give edicts on what it might mean in individual cases.  The guidance needs to stand on its own two feet.”


Claire Perry said the government proposed to resolve the differences in the definitions of fracking the Infrastructure Act 2015, which is based on volume of fluid used, and the wider view in mineral planning guidance.

She said there was a risk that not setting a volume limit would mean the definition would “catch conventional drilling”.

But Kevin Hollinrake said many of his constituents were concerned that the industry wold use the volume definition as a loophole to start fracking in protected areas.

The North Yorkshire Minerals Plan has adopted a definition based on pressure needed to fracture rocks.

Dominic Raab declined to comment on this definition. The ministers were also unable to answer whether using carbon dioxide or acid to force out gas counted as fracking according to the Infrastructure Act.

Report on seismicity and fracking

A report by geologist, Professor Peter Styles, is due to be published this afternoon which warns about the risks of earthquakes caused by fracking in former mining areas. (See DrillOrDrop interview)

Mike Amesbury

Mike Amesbury, MP Source: Parliament TV

Mike Amesbury MP asked how scientific evidence like this was provided in the current or proposed guidance.

Dominic Raab sad the guidance was reviewed regularly and innovation was “going on all the time”

“We want to make sure that the guidance clearly reflects the national context as well as local circumstances to make sure it is fit for purpose and we do periodic reviews of guidance. But also we keep it up to date on a case by case basis where that is necessary.

“On the environmental side of it, that is regularly and persistently kept up to date.”

Claire Perry said the Oil and Gas Authority, which regulates seismicity, requires operators to stop activity if any seismicity is measured, “even as low as the tremors of a roller coaster”. She said:

“the monitoring regime is both robust and we have a very good regulator in the OGA who are prepared to stop if there is any sense of seismicity being a risk.”

Asked whether Professor Styles’ report should be taken into account when authorities consider planning applications, Dominic Raab said he didn’t want to prejudice current planning applications.

“Local authorities will take account of any guidance if there is lack of clarity.”

Claire Perry said:

“Of course there should always be scientific debate but we should be very careful not to single out any particular report and prejudice any individual application on that basis because we have had the world’s best scientists review this industry for many years.”

Asked again, Perry said authorities should take account of the ”overwhelming  bulk of academic and on the ground evidence”.

She said the risk was “very very low”.

Clean growth strategy

Jo Platt

Jo Platt, MP Source: Parliament TV

Jo Platt MP asked whether there was a contradiction between the 2015 WMS on the national importance of shale gas and the government’s Clean Growth Strategy, which did not refer to shale gas.

Claire Perry replied:

“Not at all”.

She said:

“I am extremely comfortable to be a world leader in setting our climate change ambitions and using gas, particularly gas sourced domestically.”

Asked by Jo Platt why it was harder to install a wind turbine than a fracking rig.

Claire Perry said:

“There was a political decision, put in the manifesto, that we would not bring forward large=scale onshore wind for England and that commitment still stands.”

47 replies »

  1. When will this Government start honouring the Paris Agreement and pursue and fund renewable energy. Their determination to assist the Oil and Shale Gas Industry. begs the question ‘how many in Government have financial interests in it?’ More scrutiny in this direction is definitely called for especially as Baroness Kremer (House of Lords) who proposed the Infrastructure Bill (which was passed) a couple of years ago, owns an infrastructure company.

    • It is most likely when the ‘infrastructure’ of electric vehicles is in place [battery storage] then more renewables will be deployed. At the moment traditional ‘oil and gas ‘ investors are afraid if the technology and have only quick returns on their minds. Oil and gas is a quick fix; they don’t care about the planet.
      The government are about to wriggle out of their climate targets by buying in LNG; this will be offset by carbon emission trading.

      • Shale gas is just a sideline; damned if you do [voters] and damned if you don’t [sponsors]; it’s a funny old world.

      • North sea supplies run out in 30-40 years. And onshore oil and gas is being fast tracked to ensure we have greater supply for the next 100 years. Wouldn’t say that’s a short term fix. Gas is a cleaner transition fuel over coal. If you don’t like LNG imports, then why are you so against the onshore oil and gas sector?

        • If we don’t keep to the Paris agreement then I doubt there will be a stable society to care about it in 100 years.

        • Greg or yyy; you really need to look beyond the oil and gas company websites for your information.

          There was no mention of liking LNG.

          • No you mentioned LNG Sher…

            Happy to offset your carbon footprint are you???

            You say we need gas in some of your posts… So where will you get it from???

            Norwegian piped gas reducing by 25% 2030 More requirement for gas Worldwide LNG twice as expensive as piped gas…

            You want it but don’t want it???

            You seem happy to have gas powered electricity pulsing through your plastic insulated electrical conductors in your walls to your plastic keyboard…

            You seem to be permanently tapping on your plastic keyboard, what would you do without gas???

            You have no answers but are happy to dumb down common sense…

            Don’t try and drag us back to the stone age…

            Grip that plastic mouse and click…

            • LNG from all sources far cheaper than UK shale.

              Norweign piped even cheaper.

              Indigenous North sea gas with 20 billion barre reserves cheaper than piped gas and a quarter the price of UK shale

              Government keen to expand UK LNG terminals

              Grip the plastic mouse and look it up.

              Could any pro fracker put forward the factual figures which show different?

              Que ‘we don’t know yet because we have not tested it’ which of course is nonsense.

              The maths have been done

              Statoil, Centrica, Bloomberg. OIES and EY say UK shale would be the dearest natural gas source.

              Doomed to failure but good for sucking mug punters dry for a while

            • hmmm .. Daily Mail .. that figures (in your case Kisheny). But actually the Tory (political class) obsession with GW has rotted their brains – they’re getting nearly everything wrong, and they’re a pushover for the fracking lobby. Very wrong!

              History is going to overtake all these events anyway. The effects of global warming are accelerating and will be completely unavoidable in the next few years. NASA puts our CO2 output into perspective on this long timeline (NB. Methane is 82x more powerful as a greenhouse gas than CO2 in its first 20 years):

    • I’d be more keen to see who is making the vast sums of money from the unicorn world of renewables.

      • LOL GottaBPeeny – people backing sustainable technology are going to make more than you with your AJ Lucas shares. Get used to it. Heck you could even sell your junk stock and join in!

      • Sorry, it’s no longer about money. In case you know something we don’t [and from your posts this seems unlikely] you cannot take it with you when you are dead; such a sobering thought, but one you need to get on board with.

      • The people you are talking about are a big Norwegian company installing offshore wind turbines that would take fifty years to pay off, scrap after twenty; how does that work??? Why do it well the good old British green energy subsidies, that’s 10% of our energy bill straight to Norway. Green gangsters in action… Total con… Looks good on the TV though… Public well and truly hoodwinked…

        More green gangsters

        Dispatches Channel 4 “The true cost of green energy” still available on catch up

        • You’re ignoring the fact that fuel is free for wind turbines and they’re offering the most competitive bang for buck out there. There’s something fishy about your sums Kisheny.

        • Denmark not yet sussed that wind turbines don’t run all the time. Like many pro frackers you would have thought wind power was pointless.


          That said most pro frackers state that shale gas could be a transitional fuel to a renewable future. Presumably they refer to a future with more wind and daylight than we have now.

          No really. They do actually say that.

          Pro frackers long range weather forecast

          2010 to 2030 mildly sunny with intermittent light winds

          Outlook for 2030 on wards. Exceptionally strong persistent winds with perpetual daylight.

          Why the fracking industry has not paid certain individuals to stop ‘promoting’ UK shale I do not know.

  2. Good observation by Kevin Hollinrake. I understand that it costs in the region of £12m to drill a shale well. I am sure the industry does not drill an exploratory well without careful consideration of the geology first and without the intention to frack. Constructing a well pad and drilling a well only leaves the actual frack. Given the pad and well are in situ that would make it difficult for the actual fracking itself to be refused planning consent. Do the government ministers not understand the scale the unconventional gas industry operates at, do they not understand the process? Or do they simply think it acceptable to deceive the public? This is not some small development that will hardly impact upon people. It really is astounding that they can even be considering permitted development rights. I would hope that even those that support fracking can see that this is not the way to proceed. This represents unrestricted industrial development with all the traffic and impacts associated with it. EA regulation is not adequate as that is concerned with activities on site only. It does not encompass the impacts this will have on communities, our landscape and natural environment.

  3. Innogy-to start with GBK.

    But of course, we are not intelligent enough to know that, and the antis think their “audience” isn’t either.

    Not a surprise is it? A few years ago worked with a lass from Yorkshire (farmer’s daughter). She met a new fella who ran several businesses, including placing wind turbines on landfill sites. She was not impressed with the impact of wind turbines in the countryside but was with the £150k/annum net profit EACH (four per site) whether they turned or not! So, she invested £150 in a set of undies (interesting industry-the more you pay the less you get) and I think they are married now with a bunch of kids. Of course, we all get a warm glow funding that. Just means, it’s only those riding the gravy train who can then afford to spend time in Paris for an “agreement”-one of the previous being in Rio!

  4. Refracktion returns!

    Wise words of “wisdom” there. However, shame about Mr. Musk’s situation putting a bit of a damper upon that generalisation! 15 years and still no profit-hardly a start up anymore. A $35k car that becomes a $70+k car, if it appears in any quantity. Goes well, shame about stopping it! Pretty alternative. Simples-just drive it up-hill and cycle back down. I should hold onto the diesel.

  5. Dominic Raab MP, “Developments that needed an Environmental Impact Assessment could not be treated as permitted development”, he said.

    Wonderful rubbish they all spout as NO “Environmental Impact Assessment’s” have been done or apparently needed as the areas concerned are deemed too small to need one !. HSE have decided also not to bother with drilling safety as there in no manpower available !.

    So opposition out of the area needs no help BUT if our water supplies are contaminated and we have health problems due to Fracking/methane leaks/subsidence/tremors/earthquakes NO PROBLEM for the Frackers or Government as we are out of the area !!!! WOW, how is that for a caring democracy ?.

  6. You can tell when an argument has been lost.

    Tax avoidance into tax evasion! Classical, but obvious. Profit is suddenly a dirty word-excite the anti-capitalists! (Just so happens that tax from company profits pays a heck of a lot into public services. How much does Shell pay out annually in dividends-much of it into Pension Funds? ) Russian oligarchs? Get a grip. You mean the same ones who control the Russian oil/gas resources and would just love the UK not to be secure in alternative gas/oil supplies? Working a treat so far, so much money and where to put it.
    And refracktion’s generalisation about returns from sustainable energy needs to be taken selectively! Err yes, I think that was the point being made.

    It’s not all about the money-sigh. No it isn’t, but strangely money has a big part to play in world economics and family budgets-sigh. I’m alright Jack may explain some of the one third, the majority two thirds do consider money. “Family budgets to be squeezed by rising fuel prices” was a headline yesterday that was conveniently ignored by some. Just hope the business you/family run is not one subject to discretionary expenditure.

    Good job Claire Perry is on the case. One of the more competent and practical souls in Westminster.

    • MARTIN ,

      The two thirds that are feeling the squeeze by rising fuel costs ,as you say, are doing so because of UK government taxation and an industry that has been eye wateringly slow and unwilling to pass on REAL FUEL PRICE REDUCTIONS ….

      With the price of world crude pegged to the US dollar, during the record lows of oil and gas, we should of seen a far greater cut in prices ..

      NOW, I know that your position has always been to champion the Oil and Gas industry , but HEY Martin , as a user of energy , I’M SURE YOU have also , like the rest of us, felt well and truly SHAFTED with these overinflated energy prices in the UK

      As far as Fracking goes, EVEN Lord Browne , who at the time of making this statement was one of the UKs most powerful energy figures, doesn’t think energy costs will come down as a result of fracking.


      Taking note of the above, do you really think energy prices will drop as a result of Fracking ????

      I don’t and neither does Lord Browne.

      • MARTIN

        As far as this Russia phobia is going by some in the mainstream media…… It really is becoming a source of great laughter to all with the brain capacity above your common garden earth worm ..

        It MAY or MAY NOT be a source of great amusement to Russia to watch the UK poison itself with toxic emissions from the burning of fosil fuels and the Oil and Gas industry production

        BUT there is a far greater chance that Russia would be saddened if the UK CLEANED UP ITS AIR and where possible went totally 100% carbon neutral with its energy production .

  7. Hello Jack.

    See, I can greet without shouting.

    Just a little reminder. It was one of your own anti buddies who raised the Russian issue. Rather spuriously, and inaccurately, but hey don’t hold it against him. He has been sent for re-education once, I’m not sure another go would have any better result.

    Over inflated energy prices? I think you need to research a bit wider what the situation is within the UK before you offer your input to us. Then you might just find the publication within the last few days regarding the shocking way the UK public are paying for energy produced by Innogy (a German company) from a large off-shore (Lincolnshire) wind turbine site.

    Never mind. Looks like Drax will go from coal to gas. Hopefully, we can do it with our own production. Angela seems to want to do so with Russian gas. That should set her on course for problems with the Donald-and, she will not win that one, as she will not be allowed to sacrifice the German car and steel industries.

    Toxic emissions causing great amusement in Russia? Is that up-wind, or down-wind from Chernobyl?

    Must be NT time approaching. Look forward to our chats on that one!

  8. Lord Browne in 2013!!!!

    At least you are consistent. Really should take a look at something a bit more up to date. Fracking costs have dropped like a stone since 2013. Do you really not think that has not been noticed?

    Talking of BP (obliquely), notice they are pulling out of drilling a field in the N. Sea as the partner is Iranian! Looks as if we could do with some on-shore production to replace. Funny how John has not mentioned that.

    • MARTIN the points you should draw from my above statment is that the UK public are being well and truly shafted as far as energy prices go in general.

      How it is being generated is immaterial, the end product is sold in to the public at inflated prices …..

      I CAN’T AND I’M CERTAIN OTHERS WON’T be able to see how an extremely costly process of fossil fuel extraction ( fracking ) will have ANY impact downwards on our energy costs .

      • Yes MARTIN, you are correct, Lord Browne did make his statement regarding the validity of the fracking in 2013.

        BUT what he said is as valid today as it was back then ….

        YES , fracking costs can be cut …… BUT ONLY if you are willing to cut environmental safeguards and increase the risk to the public ….. Just look at the fracking mess in the USA.

        Lord Browne also points out that only complete , widespread , intensive fracking will have any meaningful effect on UK domestic supplies ….. Do you really want to see the complete destruction of our countryside Martin ??

        TO PUT THIS all in a nutshell Martin ,

        ( 1 ) The process of extraction is STILL remains costly .
        ( 2 ) The enviournmental risks and risks to the public still remain HIGH.
        ( 3 ) Only widespread intensive fracking will have any meaningful effect on the UK gas market ..
        ( 4 ) Opposition to fracking by the general public still remains HIGH .

        I would say little has changed since Lord Browne made that statement .

        • Good morning Martin ,

          Yes , I to , also look forward to our increased keyboard activity carefully dissecting any future developments regarding the National Trust and fracking .

          Regards for the day , Jack

    • Oil prices up North sea expands. Oil prices low North sea still operates but less expansion.


      Oil prices up UK shale cannot compete with North sea, Norway, LNG

      Oil prices down UK shale cannot compete with North sea, Norway,LNG

      Penny dropped yet?

      Still clinging onto the house prices will go up, 64,000 jobs, without it lights will go out, pensioners will freeze to death, big revenue for the country, cleaner than coal, Russia could turn the gas off, Ineos control piped gas, and the latest offering that a tropical disease will stop the rapid expansion of battery storage of renewable energy.

      8 years of waffle and it still keeps coming

      For clarification I was at the meeting when Mark Miller and Eric Vaugn stated that house prices would ‘go up’ near fracking sites.

      It was televised. You could hear a pin drop.

  9. Lord Browne was more of an expert than JR. He accurately saw the writing on the wall for shale in this country. As have the other big players – who would be very interested in UK shale gas production if they believed it was to be economical.

    JR is alone, but as a canny operator I expect he could leverage some advantage out of the Government and taxpayers, getting them (us) to underwrite all the infrastructure overheads – because fuel security is in the national interest of course – then collect gas revenues AND gets the byproducts (ethane etc) for his plastics plant.

  10. Ahh, you mean the same sort of big players who sold assets to Jim, who couldn’t get them to run economically, but then found Jim could?

    No. Lord Browne was talking in the past (hence your “was”)-as other “experts” were-about costs of shale production which are now historic. If you want to exercise a little, there are many references concerning the subject and how OPEC were expecting to force shale producers out of business with cheap oil prices. What happened? The shale producers made adjustments to their processes and reduced their costs of production dramatically, much to the annoyance of OPEC who then had to reduce output dramatically.

    It is all there for anyone interested to research. I suspect many of the two thirds will have bothered to do so. Indeed, I can’t even see too many of the one third being excited by fake news when it is so obvious.

    Think you have been reading a little around the Swansea Lagoon reference “leverage”, and have become confused. Although, I suspect “alternative” leverage is somehow different.

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