Environmental Law Podcast – August 2018

The latest monthly environmental law podcast presented by Christopher Badger and Mark Davies, in association with LexisPSL, is now available.

This short update focuses on August’s key legal developments, which, this month include responses to Environmental Principles and Governance Bill consultation, FRC strategic report guidance and GMO directive developments.

Please find August’s podcast below.



Environmental Law News Update

In this latest Environmental Law News Update, Nicholas Ostrowski, Natasha Hausdorff and Angelica Rokad consider a recent authority on the status of supplementary badger culling, further legal action against Heathrow expansion from environmental NGOs and a recent fine imposed on a water company for poor water quality.


Badger culling

Badger culling was back in the news this week, in a judgment that is not only important to badgers but also to the scope of consultation and the Habitat Regulations.

Natural England has been issuing annual licences to cull badgers, up to a maximum longstop period of four years, since the government permitted the licensed culling of badgers as part of its strategy for achieving a bovine tuberculosis (“bTB”) free status for England. Following further consultation, Defra’s Guidance was re-issued in 2017. This extended Natural England’s powers by authorising it to provide supplementary licences which permitted the culling of badgers beyond a period of four years in areas which have already been subject to the standard licence periods.

Tom Langton, an independent ecologist, challenged this policy to allow the supplementary culling of badgers. Langton’s argument with respect to the policy centred essentially on DEFRA’s failure to consult, at a formative stage, on the principle of supplementary culling and properly consider whether there was an alternative approach – even if that meant, for example, doing nothing.

Mr Justice Cranston considered the consultation document to be, in many ways, both “unimpressive” and “not ideal”. However, it did not, in his view meet the high thresholds of procedural unfairness or irrationality to render it unlawful. He considered that DEFRA was entitled to issue the 2017 Guidance on the basis that the principle of supplementary badger culling had already been satisfied.

The importance of the statutory context in judicial review challenges based on unlawful consultations was emphasised by the Court. This has been raised in recent judicial reviews spanning the fields of heath, planning and most notably, challenges to local Government budget cuts. The Court considered that decision makers should be afforded a broader discretion than that which appeared on the face of the statute. If the “logic” of the statute did not compel it to take into account certain considerations, then the decision maker has a discretion to judge what it considered relevant in the particular circumstances. The Court also accepted that there was no need for a decision maker to refer explicitly to discarded alternatives on the face of the consultation. Rather, that requirement only arose in a limited number of cases, where “special circumstances” existed.

Langton also challenged the evidence, regarding whether in granting licences in particular areas Natural England had conducted adequate assessments under the Habitats Regulations. In one of those classic JR turns of phrase, the judge held that Natural England was “rationally entitled to conclude” that it could exclude the possibility of a significant disturbance effect in these areas, notwithstanding the precautionary principle. The court also took into account the licence conditions as integral features of the project which Natural England needed to assess under the Habitats Regulations. Whilst this may seem to contradict the recent People Over Wind ruling, this is actually a common sense approach. It would be odd indeed for Natural England to have to assume that culling was going to take place at times and places where the applicants did not propose to do so.

The Government’s Statutory Guidance on bBT can be found here.


Friends of the Earth and Plan B challenge Heathrow Expansion in the High Court

The Government’s decision to designate the Airports National Policy Statement (NPS), which gives the go-ahead to a third runway at Heathrow, has recently prompted legal action in the High Court by two environmental NGOs.

The policy framework for expansion at Heathrow Airport, devised by the Transport Secretary Chris Grayling, has been challenged by Plan B with a claim for judicial review focusing exclusively on climate change impact. Previous challenges by other organisations, including Greenpeace and a number of councils, have focused on noise or air pollution. Plan B maintain that the proposal breaches legal obligations in the Planning Act to alleviate the impact of climate change and promote sustainable development. The organisation argues that the NPS designated by Chris Grayling does not consider the Government’s obligations under the Paris Agreement on Climate Change.

In the same week, Friends of the Earth has asked for the Airports NPS to be quashed, on the basis that it fails to address the UK’s climate change obligations. In particular, the environmental organisation claims that the NPS fails to account for all the impacts on future generations, who will be left with the adverse consequences of growth from aviation-increasing climate impacts, in the following way it does not explain how it takes account of domestic targets for greenhouse gas emission reduction under the Climate Change Act 2008;

i) it does not explain how it takes account of domestic targets for greenhouse gas emission reduction under the
Climate Change Act 2008;
ii) it does not factor in the Paris Agreement, which aims to limit global warming to well below 2°C and to pursue
efforts to limit it to 1.5°C;
iii) it fails to factor in the non-CO2 climate impacts of a third runway, such as the emission of nitrogen oxides,
which generate warming effects of a similar magnitude to CO2 emissions; and
iv) it does not lawfully and fully consider the likely impact on future generations of a third runway, who will be
stranded with the climate-damaging infrastructure.

The Department for Transport’s analysis of the measure indicated there was a risk that expansion would delay compliance with air quality laws. Nevertheless, many have emphasised that the plans will create 114,000 extra jobs by 2030, with the potential for an extra 16 million long-haul seats by 2040.

A decision on whether there will be a full hearing about these issues is expected to be made this Autumn.


Southern Water fined over water quality

The Drinking Water Inspectorate (‘DWI’), which focuses solely on the regulation of drinking water, is a comparatively small regulator within the ‘Defra family’ (as they like to refer to themselves these days). It typically brings only a handful of prosecutions each year, which is reflective, perhaps, of the UK’s generally high standards of drinking water. This case follows further prosecutions brought against United Utilities (who were sentenced for a similar offence in June 2018 and October 2017) and Southern Water who were sentenced in August 2017 for another offence under Section 70 of the Water Industry Act 1991. Section 70 creates an offence of allowing water to enter the supply system which is unfit for human consumption.

The DWI brought proceedings when discoloured and highly turbid water entered the supply system from the Cooks Castle Shanklin reservoir on the Isle of Wight, which supplied approximately 17,000 customers, back in 2013. The offence occurred when the outlet main was ruptured by a drilling rig during site investigation work which allowed soil and other debris to enter the network. On 10 August 2018 Southern Water were fined £65,000 and ordered to pay £44,620 in costs after supplying water which was unfit for human consumption. The time since the offence appears to have been put to effective use by Southern Water – in summing up, the judge noted that the company had made substantial changes to its operation since the incident, and that “It is clear this is a very different company now.”

The European Court of Justice has just accepted a major new people’s climate case challenging the EU’s targets to 2030. Read the story in full on our International Climate Change blog

**Please note there will be no update next week – the next Environmental Law News Update will be sent out on Monday 3rd September 2018**

Europe to see its very own ‘People’s Climate Case’ before the CJEU

Posted by: Frances Lawson

Following the somewhat unlikely example of the US leading the way in ‘People’s’ climate litigation, a similar action in Europe has just received the green light from Europe’s highest court. In this latest case, families from a number of European countries, as well as from countries far afield who are set to experience ever worsening climate impacts, are taking two of the EU’s three main institutions – the European Parliament and the Council of the European Union – to court over the alleged inadequacy of the EU’s climate targets to 2030.

Specifically, the Claimants – led by a Portuguese family and a legal team comprising Professor Gerd Winters – are asking the court to:

(1) declare the relevant EU legislation unlawful insofar as it allows the emission between 2021 and 2030 of a quantity of greenhouse gases corresponding to 80 % of the 1990 emissions in 2021 and decreasing to 60 % of the 1990 emissions in 2030;

(2) annul the relevant EU legislation insofar as it sets targets to reduce GHG emissions by 2030 by 40 % of 1990 levels; and

(3) order the defendants to adopt measures under the relevant legislation requiring a reduction in greenhouse gas emissions by 2030 by 50 %-60 % of 1990 levels, or such higher level of reduction as the Court thinks fit.

The Claimants’ arguments rely heavily on the customary international law principle not to cause harm to other States, as well as the environmental principles enshrined in Article 191 of the Treaty on the Functioning of the European Union (‘TFEU’). The Claimants’ additionally place weight upon the EU’s Charter of Fundamental Rights and contend that the current emissions reduction targets will result in the EU infringing a number of the rights protected by the Charter. Reliance is also made on the Paris Agreement, with the Claimants asserting that the EU’s targets are unlawful as they exceed the EU’s ‘equitable share of the carbon budget’ available to meet the 2 degrees target in the Paris Agreement.

Suffice to say that just for such a groundbreaking case to have received permission from the General Court speaks volumes about courts unprecedented willingness to entertain climate litigation. Should the case succeed, climate law and policy across the EU-28 will be forced into a major, and much-needed, gear shift.

The next step in the proceedings will be for the Parliament and Council to submit their Defence, which is expected within the next two months.

Further details about the Claimants arguments in law can be found from page 40 onwards in the Official Journal here

Environmental Law News Update

In this latest Environmental Law News Update, Gordon Wignall, Christopher Badger and Mark Davies consider an ECJ ruling on the treatment of gene editing, new guidance from the Financial Reporting Council on strategic reports and the decision to allow Cuadrilla to proceed with Hydraulic Fracturing at Preston New Road.


Gene editing and current EU legislation; case C-528/16

For centuries plant breeders have striven to improve crop traits by scientific methods for the general benefit. Mutations by the process of traditional plant-breeding techniques have sought to improve yields, to produce better flavour or to allow crops to be better harvested.

Traditional techniques have been supplemented more recently by GM methods, and over the last 20 years by the process of gene editing.

On 25 July 2018 the ECJ delivered its ruling as to whether gene editing should be considered a process akin to traditional plant breeding, or whether it is caught by EU legislation dated 2001/2002 which heavily restricts the promotion and marketing of GM materials. The case is C-528/16 Confédération paysanne et al v. Premier ministre.

The battleground was ultimately the ‘GMO Directive’ 2001/18/EEC, which regulates the release of GM organisms into the environment. Organisms covered by the directive can only be authorised after an environmental risk assessment and are subject to rules as to traceability, labelling and monitoring.

It has been said, put very simply, that GM technology introduces genes from other species into the genome of target cells (transgenesis), whilst GE uses cells from the same species to create the desired traits (mutagenesis, involving the alteration of the genome of a living species).

Scientists, whether they use the traditional plant breeding model, GM or GE, are ultimately interested in achieving the same aims. Traditional breeding methods have intentionally mutated crop species to make them tolerant to herbicides. They have also resulted in fruit and vegetables which have traded improvements in shelf-life and shipping quality at the expense of flavour. These are all consequences which are often attributed to the effects of GM techniques.

Annexes to directive 2001/18/EEC contain ‘positive’ and ‘negative’ lists of processes. The positive list describes techniques which must be considered to be techniques of genetic modification and which are caught by the directive. This does not extend to GE methods.

The negative list contains processes which are altogether exempt from the ambit of the directive. The negative list itself, however, prohibits any form of genetic modification which has employed a technique which carries the label “mutagenesis”. This wording is contrary to the contemporary French regulation in issue, which expressly excludes “mutagenesis” from the definition of techniques constituting genetic modification, and which therefore accommodates scientific developments derived from GE.

Whilst Advocate General Bobek had delivered an opinion which was not ultimately more favourable than the judgment of the ECJ (18 January 2018), his opinion is rich with various legal reflections, including the existence of a duty on the part of a legislative body to update its legislation in order to accommodate new developments and the requirement to keep the precautionary principle within proper bounds. The ECJ’s ruling is an interpretation of the strict wording of the directive. Since GE is a form of mutagenesis, it is necessarily caught by the directive.

Indeed, the ECJ’s ruling can be said to contain a ‘double whammy’. Not only does it demonstrate that GE is caught by the restraints of the directive, but it also makes it clear that even if a product is exempt from the directive by reason of the application of the criteria contained in the negative list, that does not mean that a Member State cannot establish its own rules intended to deal with its views as to what is and what is not safe from undue risks to the environment. That said, the primary laws of the EU will apply, in particular those concerning the free movement of goods and services. These are additional circumstances in which environmental regulation may end up being determined by trade laws.

The ECJ’s decision has dismayed many, who see its ruling as both a retrograde and outdated application of the precautionary principle to agricultural products which have more in common with traditional plant breeding techniques than with GM and transgenesis.

The United Kingdom government put in a response which, broadly, could be seen as a basis for future support for the development of GE. The ECJ ruling, assuming that it becomes part of the environmental acquis inherited after Brexit, can properly be seen as an unintended consequence of the adoption of the acquis. It will restrict the competitiveness of UK agriculture in a wider global marketplace.

A related news item is of interest concerning that other related environment bugbear, glyphosate (which the Commission authorised for a further five years from December 2017, after some torrid and controversial opposition from the European Parliament). Just before publication of this blog a jury in California is reported to have awarded a groundsman who contracted cancer almost $300m on the basis that Monsanto knew of the risks to health from its products containing glyphosate and that there was a causal connection between the cancer and those products. There are reportedly another 5,000 claimants intended to pursue similar claims. Monsanto intends to appeal.


Financial Reporting Council produces guidance on strategic reports

In July 2018 the Financial Reporting Council (“FRC”) published guidance on the content of corporate strategic reports.

The purpose of the strategic report is to provide information for shareholders and help them assess how the directors have performed their duty, under section 172 of the Companies Act 2006, to promote the success of the company and, in doing so, have regard to the specific factors set out in the legislation, which include disclosing information about environmental risks and uncertainties where they are material and the impact of the company’s operations on the environment.

The Guidance identifies that corporate transparency on broader matters is essential to enable shareholders to assess an entity’s ability to generate and preserve value over the long term, and to assess the management of risks which may impact the sustainability of the entity’s business or may affect society more broadly in ways which are not reflected in financial statements. Noting this, information on environmental matters, amongst others, should be integrated throughout the report where appropriate and, in particular considered when disclosing the entity’s strategy and business model, principal risks and uncertainties and KPIs.

Key questions that are raised include:

  • Is the entity’s business model reliant on natural resources such as water, land or minerals?
  • Does the use of these resources result in other secondary impacts on natural resources?
  • What is the entity’s impact on the environment?
  • What are the pollution risks from the entity’s activities?
  • Will the entity’s business be affected by climate change, either as a result of climate change of by climate change affecting how the business can operate?
  • What are the effects of an entity’s activities on climate change?

The Environmental Audit Committee, in its recommendations for mandatory climate risk reporting by 2022, recently highlighted the difficulties faced by companies in devising appropriate scenario analysis, to be able to assess the potential impact of climate change on any particular business going forwards (see here). However, irrespective of any potential difficulties, the need for comprehensive reporting on material risks is very current. ClientEarth has already referred three insurance companies, including the owners of Admiral and SunLife insurance brands, to the Financial Conduct Authority for failing to address the risks of climate change in their strategic reports. It is open to the FCA, depending on the results of any investigation, to issue a financial penalty or a public censure and to order that the reports are corrected.

The Guidance can be found here


Cuadrilla granted Hydraulic Fracturing Consent for Preston New Road

On 24 July 2018, Minister for Energy and Clean Growth Claire Perry granted Cuadrilla Bowland Ltd Hydraulic Fracturing Consent (“HFC”) for horizontal well PNR-1z at its Preston New Road site in Lancashire. The HFC is essentially the final consent Cuadrilla require in its long battle to extract shale gas from that specific well.

HFC was introduced by the Infrastructure Act 2015 as an additional step to the regulatory and permitting regime. Its purpose is to ensure that all necessary environmental and health and safety permits have been obtained, and that the Department of Business, Energy and Industrial Strategy (“BEIS”) is otherwise satisfied that it is appropriate to grant it.

As part of the process, Cuadrilla have been assessed as having adequate financial resilience to undertake work at Preston New Road but, interestingly, the decision letter for the HFC includes a condition in relation to one of the project’s backers, Spirit Energy Ltd; either its accounts must be submitted to BEIS for the last financial year or £557,000 must be transferred into an escrow account to hold said amount until the audited accounts are provided. Spirit Energy Ltd was only formed in 2017 following the merger of Centrica’s Exploration and Production business with Norway’s Bayerngas Norge, which may explain the concern.

In granting the HFC, BEIS has certified its satisfaction that the 13 technical requirements set out in section 4A of the Petroleum Act 1998 have been met. This includes as the first condition that the environmental impact of the development has been taken into account by the local planning authority.

It should be remembered that Friends of the Earth’s High Court challenge to the Environment Agency’s assessment of Cuadrilla’s techniques for the site is still outstanding, although this does not appear to have delayed Ms Perry’s decision. In her statement accompanying the decision she stated, “Shale gas has the potential to be a new domestic energy source, further enhancing our energy security and helping us with our continued transition to a lower-carbon economy.”

The Government’s announcement may be read here.

Environmental Law News Update

In this latest Environmental Law News Update, Charles Morgan, Christopher Badger and Antony Bartholomeusz consider the Environment Agency’s response to the DEFRA consultation on environmental regulation after Brexit, an ECJ case concerning the interpretation of Article 6 of the Habitats Directive, and the continuing challenge obtaining authoritative end-of-waste guidance for the purposes of the Waste Framework Directive.


Environment Agency publishes response to DEFRA consultation on Environmental Principles and Governance after the UK leaves the European Union

The deadline has now passed for responses to be filed to DEFRA’s consultation on Environmental Principles and Governance after the UK leave the European Union, the results of which have the potential to definitively shape the future of environmental law in the UK for a generation.

The Environment Agency has published its response to the consultation. In it it states:

  • It agrees that the suite of principles set out in the Withdrawal Act 2018 are the correct principles;
  • It agrees with the suggestion of a statement of policy, but adds that, as it will be important to show that the environmental principles continue to have a real influence on the development of environmental policy and legislation, its subsequent interpretation in caselaw and to deliver important environmental outcomes, a further principle of high environmental protection could be added;
  • A non-regression clause should be included in the Bill;
  • That the Government should be required to publish appropriate reports, to reflect the EC’s role on reporting on the implementation of EU environmental law;
  • The EA supports the establishment of a new independent environmental body which should be able to scrutinise, advise and report on the delivery of key environmental policies, including the 25 Year Environmental Plan;
  • That the 25 Year Environmental Plan should be placed on a statutory footing, with progress reports similar to the architecture for carbon budgets and the National Adaptation Programme under the Climate Change Act;
  • That the new body should be able to respond to material public complaints;
  • That judicial review of the Government should be open to the new environmental body.

It is also of note that the Environment Agency state that “holding the national government to account is the right scope for the new body”. It refers to the fact that the Environment Agency is held to account by, amongst others, its sponsoring department DEFRA. This raises an interesting constitutional question. It is arguable that the new independent environmental body will not be truly independent of Government unless it is wholly accountable to and funded by Parliament, not by a sponsoring department of the Government. There is precedent – the National Audit Office, for example, had no sponsoring Government department.

It is no surprise to find that the response to the consultation states that, in its view, the new body should not replace or duplicate the roles of other existing bodies, including the Environment Agency.

The Environment Agency’s response can be found here


Case C-164/17 Grace and Sweetman

The Court of Justice of the European Union recently gave judgment in Case C-164/17 Grace and Sweetman v An Bord Pleanála concerning the interpretation of Article 6 of the Habitats Directive 92/43/EC, asking whether measures taken to mitigate the impact of a proposal on a protected species can be taken into account when assessing whether the proposal adversely affects the integrity of a special area of conservation.

The interested parties proposed to build a wind farm in a specially protected area (SPA) that is the natural habitat for the hen harrier – a species protected by Annex I of the Birds Directive 2009/147/EC. The hen harrier forages in open-canopy forest. As a result, the areas of the SPA in which the trees have matured to the point where there is a closed-canopy are felled and replanted. This is done in stages with the aim of maintaining a similar amount of open-canopy forest within the SPA. Accordingly, the parts of the SPA that are suitable habitat for hen harriers changes over time.

The proposal included a species and habitat management plan (‘the mitigation plan’) to address the effects of the wind farm on the hen harrier’s foraging habitat by ensuring that the amount of open-canopy forest remains the same as at present. Other measures included the restoration of planted areas adjacent to wind turbines to blanket bog, which is also a suitable habitat for hen harriers. Also, construction works would be scheduled to take place outside the hen harrier’s breeding season. It was claimed that the consequence of this plan was that the amount of the site suitable as habitat would not be reduced and may even be enhanced.

Article 7 of the Habitats Directive requires the procedure in Article 6 of that Directive to be followed in respect of proposed developments affecting SPAs under the Birds Directive. Article 6 sets out a two-stage procedure. Firstly, Article 6(3) provides that any plan that might have a significant effect on a special area of conservation must be assessed. The competent authorities may only agree to the plan only after having ascertained that it will not adversely affect the integrity of the site concerned. Secondly, Article 6(4) provides a derogation from Article 6(3) where a plan must be carried out “for imperative reasons of overriding public interest, including those of a social or economic nature”. In such cases, the member-state is obliged to take ‘compensatory measures’ and notify these to the European Commission.

An Bord Pleanála, Ireland’s competent authority, approved the proposal under Article 6(3) on the basis that it would not adversely affect the integrity of the SPA. Ms Grace and Mr Sweetman brought a judicial review challenging this decision. The Supreme Court of Ireland made a reference to the CJEU under Article 267 TFEU, asking whether the mitigation plan could be taken into account when assessing the proposal under Article 6(3) (the view of An Bord), or whether it was in fact a ‘compensatory measure’ under Article 6(4) (the view of Ms Grace and Mr Sweetman.)

The Court of Justice sided with Ms Grace and Mr Sweetman and declared that the mitigation plan could only be taken into account under Article 6(4). The Court noted that some parts of the SPA would no longer provide a suitable habitat for the hen harrier. The Court questioned whether there was sufficient certainty that the mitigation plan would achieve its objectives. It would only be permissible for a mitigation strategy to be taken into account under Article 6(3) if the effects of the mitigation strategy could be foreseen with a high degree of certainty. The Court supported this approach by reference to the precautionary principle. Interestingly, the Court opined on the factual issue as to the degree of certainty as to the effect of the mitigation plan: in Article 267 proceedings, this is usually understood to be the task of the national court. In effect, the Court appeared to adopt a starting point that the effect of measures taken to create a new habitat are highly difficult to forecast. While the Court did not absolutely close the door to considering mitigation under Article 6(3), it is clear that the bar to doing so is very high indeed.


Waste: Will it Never End? And How Do We Know When it Does?

The “end of waste” would be a wonderful thing if ever it could be achieved. The more technical and circumscribed concept of “end of waste” for the purposes of the Waste Framework Directive has proved almost as elusive. In the wake of the Environment Agency’s recent resurrection of its Definition of Waste Panel (see our recent blog item) comes a decision of the Administrative Court on the subject, spawned of the original panel’s final decision and quite possibly instrumental in its renaissance. In R (Protreat Ltd.) v Environment Agency [2018] EWHC 1983 (Admin) Sir Wyn Williams considered a number of questions arising out of the activity of re-refining of waste oil for non-fuel purposes and the EA’s refusal to produce guidance as to whether the end product had ceased to be waste, leaving operators uncertain as to the regulatory environment within which they were operating. The judge held that the EA was not under any Directive duty to provide end-of-waste guidance in relation to the products of re-refining of oil (or indeed more generally) nor otherwise in breach of the Directive in its approach to regulation of the sector.

The judgment contains a very careful consideration of the proper application of the waste hierarchy in article 4 of the Directive and its inter-relationship with the requirement of delivery of the “best overall environmental outcome”. The judge held that this entitled a decision-maker to have regard to the costs of differing options – were that not so, one might scarcely ever be able to look below the highest-ranking option (prevention) and application of the hierarchy would become impracticable. Article 4 is to be construed ‘flexibly’ and consistently with the aim and scope of the Directive set out in Article 1. “It cannot be the case that whatever the circumstances a breach of the Article occurs if the hierarchy is not applied strictly in accordance with the descending order of priorities.”

The case is also of interest for its consideration of the extent to which an emanation of the state such as the EA is directly bound by the requirements of a Directive. The judge held that this was so only to the extent that such a body was exercising the functions conferred upon it by Parliament. Thus, by way of obvious illustration, no complaint could be made that the EA had not passed appropriate domestic legislation since it had no power to do so. Further, and of the most general application, “an obligation on the part of a public authority to produce guidance as to how it will operate in a particular context arises, rarely, if at all”.

It is interesting to speculate whether this litigation and the problems to industry which it highlighted were instrumental in the voluntary reintroduction by the EA of the Definition of Waste Panel. It plainly has a useful (if perhaps also thankless and endless) task to perform and its return is welcome.

The claimant was represented by Six Pump Court’s Gordon Wignall, led by Robert McCracken QC.


We published July’s Environmental Law Podcast last week – a monthly round-up of the latest developments in environmental law.

Environmental Law Podcast – July 2018

The latest monthly environmental law podcast presented by Mark Davies, in association with LexisPSL, is now available.

This short update focuses on July’s key legal developments, which, this month includes Network Rail Infrastructure Ltd v Williams and Waistell, the first enforcement undertaking for odour nuisance and the re-introduction of the Environment Agency’s Definition of Waste Service.

Please find July’s podcast below.