Please confirm that the OPA will also differentiate projects, in the context of the Launch Criteria Score, and also credit projects that have achieved substantial completion under the old ESR process, without having achieved REA exemption, over and above projects that have not achieved substantial completion under the old ESR process. Otherwise as it stands, a project having achieved substantial completion under the old ESR process would be rated equally to a project that has had no environmental work undertaken to date and in the worst case possibly compared negatively in the event of a tie break - if the other project had happened to have an earlier Access Rights Date.

Given that that the currently proposed rules are clearly unacceptable as a measure of the seriousness of the two projects - how does the OPA intend to recognise the projects that have achieved substantial completion in terms of the existing ESR process.