With respect, sir, I don't think that's a fair comparison. The legislation in the U.S. is a set of regulations that covers the whole suite of offset tools and principles. It includes administration of in-lieu fees, proponent-led banking and so on, and a fair number of those 100 pages are commentary from the corps of engineers and from the Environmental Protection Agency on how it might be implemented.
The actual substance of the American system is—and I say this somewhat guardedly—reasonably streamlined, in that a party that wishes to sponsor a habitat bank makes an initial proposal to the corps of engineers outlining what they had in mind and where they intend to do it, including a budget and a business plan. That is reviewed by a multi-party committee. The committee—I forget the particular acronym—is a combination of the different agencies that may be impacted by the project.
There's essentially approval in principle given at that stage. A more detailed plan is called for, and then the implementation of that plan is monitored, with approval and accreditation given as different thresholds are met and different stages completed.
It's a system that seems to work. There are literally hundreds and hundreds of habitat banks under the U.S. fishery system, and they are selling credits on an ongoing basis. It does seem to work.