1
Presentations on:
Proposed Changes to 2007 RulesPreliminary 2007 Stewards’ Fees
Revising the Blue Box Program Plan
August 31, 2006
2
Welcome!Welcome!
In person (50+)In person (50+)
Webcast audience (80+)Webcast audience (80+) slides advance automaticallyslides advance automatically enlarge slideenlarge slide email box for questions/comments on email box for questions/comments on
left-hand side of webcast consoleleft-hand side of webcast console use any timeuse any time
please include name & affiliationplease include name & affiliation
Archived webcast available for 180 daysArchived webcast available for 180 days
3
Today’s TopicsToday’s Topics
Proposed Changes to 2007 RulesProposed Changes to 2007 Rules
Preliminary 2007 Stewards’ FeesPreliminary 2007 Stewards’ Fees
Revising the Blue Box Program Plan Revising the Blue Box Program Plan (BBPP)(BBPP)
5
Summary CommentsSummary Comments
Rules reviewed each year to:Rules reviewed each year to: clarify language (e.g. co-branding 2[5])clarify language (e.g. co-branding 2[5]) address annual changes (e.g. dates) address annual changes (e.g. dates) ““house clean” (e.g. numbering)house clean” (e.g. numbering)
After this year’s court case, address After this year’s court case, address areas raised by legal counsel areas raised by legal counsel
6
Key Changes Key Changes
Key changes for 2007 Rules:Key changes for 2007 Rules: change in data reporting yearchange in data reporting year file Steward’s Report on behalf of delinquent file Steward’s Report on behalf of delinquent
stewardsstewards penalties for non-reportingpenalties for non-reporting
7
Change of YearChange of Year
Change addressed in sections:Change addressed in sections: section 1 – defines year for basis of Steward’s section 1 – defines year for basis of Steward’s
ReportReport 3(2) – describes reconciliation process3(2) – describes reconciliation process 6(4) – exemption process for stewards above 6(4) – exemption process for stewards above
& below $2M& below $2M Appendix A – Steward’s Report FormAppendix A – Steward’s Report Form
8
Delinquent Steward’s ReportsDelinquent Steward’s Reports
350 stewards filed in 2005; have not 350 stewards filed in 2005; have not reported in 2006reported in 2006
Would allow Stewardship Ontario to file on Would allow Stewardship Ontario to file on behalf of stewards:behalf of stewards: 4(3) – allows Stewardship Ontario to file 4(3) – allows Stewardship Ontario to file
Steward’s Report, if delinquent (after July 31)Steward’s Report, if delinquent (after July 31)
9
Penalties for Non-ReportingPenalties for Non-Reporting
Create penalties for non-reporting Create penalties for non-reporting 5(3) – 10% penalty based on 2006 5(3) – 10% penalty based on 2006 5(4) – additional 20% if report filed5(4) – additional 20% if report filed
Provide incentive for filing actual dataProvide incentive for filing actual data 5(5) – reduce penalty to 10%5(5) – reduce penalty to 10%
Flat fee penalty for stewards <15 tonnesFlat fee penalty for stewards <15 tonnes 5(6) - flat $700 fee for non-reporting for 5(6) - flat $700 fee for non-reporting for
stewards between 0 &15 tonnesstewards between 0 &15 tonnes
10
Comment PeriodComment Period
Please review draft 2007 RulesPlease review draft 2007 Rules comment on additionscomment on additions questions on proposed changesquestions on proposed changes
Comments due September 14Comments due September 14 put “RULES” in subject field & email to: put “RULES” in subject field & email to:
[email protected]@stewardshipontario.ca
13
OverviewOverview
Status of fee-setting methodologyStatus of fee-setting methodology
Key components of 2007 feesKey components of 2007 fees
Net Blue Box (BB) system costNet Blue Box (BB) system cost
Update on generation & recoveryUpdate on generation & recovery
Base fee ratesBase fee rates
Input requested by boardInput requested by board
14
Status of Fee-Setting MethodologyStatus of Fee-Setting Methodology
Review process - began October 2005Review process - began October 2005 meetings: 3 Advisory Committee; 2 public stakeholdermeetings: 3 Advisory Committee; 2 public stakeholder initial recommendations modified, based on initial recommendations modified, based on
comments receivedcomments received approved by WDO Board March 22, 2006 approved by WDO Board March 22, 2006 posted on Environmental Registry July 5 for 30 daysposted on Environmental Registry July 5 for 30 days
Currently before Minister for approvalCurrently before Minister for approval
Today - presenting 2 sets of fees for 2007Today - presenting 2 sets of fees for 2007 revised & previousrevised & previous
15
Key Components of FeesKey Components of Fees
Base steward fees composed of:Base steward fees composed of: payments to municipalities (93%)payments to municipalities (93%) program delivery & administration (6%)program delivery & administration (6%) Waste Diversion Ontario (WDO) charges (1%)Waste Diversion Ontario (WDO) charges (1%)
Additional elementsAdditional elements adjustments for shortfall or surplusadjustments for shortfall or surplus discretionary market development feesdiscretionary market development fees
16
Key Components of Base FeesKey Components of Base Fees
Municipal Payments
93.3%
Stewardship OntarioProgram Delivery 3.6%
Stewardship Ontario Administration 1.9%
WDO Program Delivery & Administration 1.3%
17
2005 Net Blue Box System Cost2005 Net Blue Box System Cost
$138M for 2005; verified by WDO$138M for 2005; verified by WDO up from $113M for 2004 up from $113M for 2004 22% increase 22% increase
Net cost up due to:Net cost up due to: increase in tonnes recovered (8.6%)increase in tonnes recovered (8.6%) previously approved revision of factor for previously approved revision of factor for
administration (3.6%)administration (3.6%) cost of living & fuel surcharges (3.7%)cost of living & fuel surcharges (3.7%) new capital (2.4%)new capital (2.4%) adjustments to prior year costs (2.2%)adjustments to prior year costs (2.2%) other factors, e.g. contract renewal under revised other factors, e.g. contract renewal under revised
terms & lower commodity prices (1.8%)terms & lower commodity prices (1.8%)
182005 Net BB System Cost 2005 Net BB System Cost for Setting Feesfor Setting Fees
Net system cost offset by:Net system cost offset by: lag from 3-year average of material priceslag from 3-year average of material prices cost band of $14Mcost band of $14M
Approved net cost for setting fees of $124MApproved net cost for setting fees of $124M
Stewardship Ontario ObligationStewardship Ontario Obligation 50% of net cost50% of net cost $62,017,482$62,017,482
19
Blue Box Waste GenerationBlue Box Waste Generation
Extensive new waste audit dataExtensive new waste audit data
Improved methodologyImproved methodology
Results in more reliable generation Results in more reliable generation estimatesestimates
1,494,000 tonnes for 2005 (2007 fees)1,494,000 tonnes for 2005 (2007 fees) compared to estimated 1,501,000 tonnes for compared to estimated 1,501,000 tonnes for
2004 (2006 fees)2004 (2006 fees)
20
Blue Box Waste RecoveredBlue Box Waste Recovered
Reported data verified & approved Reported data verified & approved by WDOby WDO
861,000 tonnes for 2005861,000 tonnes for 2005 compared to 820,000 tonnes for 2004compared to 820,000 tonnes for 2004 increase of 5.1%increase of 5.1%
Overall BB recovery rate Overall BB recovery rate 57.6% 57.6%
2005 2005 Generation & Generation & RecoveryRecovery
Material
Quantity Generated (tonnes)
Quantity Recovered
(tonnes)Recovery
RateCNA/OCNA News 268,224 215,716 80.4%Other News 128,557 103,390 80.4%OMB 97,267 73,043 75.1%OTB 21,121 16,986 80.4%Other Printed Paper 122,082 47,383 38.8%Total Printed Paper 637,251 456,519 71.6%
OCC 166,137 115,442 69.5%Gabletop 15,145 2,110 13.9%Paper Laminants 37,673 377 1.0%Aseptic Containers 3,589 458 12.8%OBB 127,388 67,799 53.2%Total: Other Paper Pckg 349,932 186,185 53.2%
PET bottles 46,004 23,515 51.1%HDPE bottles 25,689 13,328 51.9%Plastic Film 61,616 4,995 8.1%Plastic Laminants 25,613 256 1.0%Polystyrene 22,544 394 1.7%Other Plastics 44,939 3,594 8.0%Total: Plastics 226,404 46,083 20.4%
Food & Beverage Cans 47,668 31,434 65.9%Aerosols 3,957 1,040 26.3%Paint Cans 6,762 1,164 17.2%Total: Steel 58,387 33,638 57.6%
Al Food & Beverage Cans 22,890 10,842 47.4%Other Aluminum Packaging 3,648 310 8.5%Total: Aluminum 26,538 11,152 42.0%
Food and Beverage - Flint 124,073 80,949 65.2%Food and Beverage - Coloured 71,712 46,787 65.2%Total: Glass 195,785 127,736 65.2%
Total Packaging 507,114 218,610 43.1%
Grand Total 1,494,297 861,313 57.6%
21
22Proposed 2007 Program Proposed 2007 Program Delivery & Administration Costs (1)Delivery & Administration Costs (1)
Total of $3.6M (5.5%)Total of $3.6M (5.5%) program delivery $2.4Mprogram delivery $2.4M administration $1.2Madministration $1.2M
Increase of $0.5M (16%) over 2006Increase of $0.5M (16%) over 2006 subject to review & approval by boardsubject to review & approval by board
23Proposed 2007 Program Proposed 2007 Program Delivery & Administration Costs (2)Delivery & Administration Costs (2)
Increase primarily due to:Increase primarily due to: additional staffing requirementsadditional staffing requirements
Best Practice costs for fee settingBest Practice costs for fee setting
E&E Fund project managementE&E Fund project management
compliance & enforcementcompliance & enforcement
financial controlsfinancial controls
Ruling on removal of GST from feesRuling on removal of GST from fees removal of Input Tax Creditsremoval of Input Tax Credits
24
Proposed WDO Charges (1)Proposed WDO Charges (1)
Total of $832,000 (1.3%)Total of $832,000 (1.3%) WDO direct costsWDO direct costs common costs attributed to the Blue Box Programcommon costs attributed to the Blue Box Program
Includes:Includes: Datacall, including verification & financial auditsDatacall, including verification & financial audits board & committee support costsboard & committee support costs legal & accountinglegal & accounting
Subject to: Subject to: future WDO programsfuture WDO programs WDO Board review & approvalWDO Board review & approval
Effect of Revised MethodologyEffect of Revised Methodology2006 data2006 data for Illustration Onlyfor Illustration Only
Note: These are NOT 2007 fees, but are based on 2006 data for illustration purposes only. They do not include market development or shortfall recovery.
-40
-20
0
20
40
60
80
100
120
140
160
180
CNA/OCNA N
ews
Oth
er N
ews
OM
G
OTB
Oth
er P
rinte
d Pap
erO
CC & O
BB
Oth
er P
aper
Pck
gPET b
ottles
HDPE bottl
es
All O
ther
Pla
stic
s
Steel
Alum
inum
Gla
ss
To
tal
Fe
e R
ate
($
/to
nn
e)
2006 Fees
Projected Fees from Methodology Review
25
Preliminary Base 2007 Fee RatesPreliminary Base 2007 Fee RatesRevised MethodologyRevised Methodology
-40
-20
0
20
40
60
80
100
120
140
160
180
CNA/OCNA N
ews
Other
New
sOM
GOTB
Other
Prin
ted P
aper
OCC & O
BB
Other
Pap
er P
ckg
PET bottl
es
HDPE bottl
es
All Oth
er P
last
ics
Steel
Alum
inum
Glass
To
tal
Fee
Rat
e ($
/to
nn
e)
2006 Fees
Projected Fees from Methodology Review
2007 Fees using Revised Methodology
26
Preliminary Base 2007 Fee RatesPreliminary Base 2007 Fee RatesPrevious MethodologyPrevious Methodology
-20
0
20
40
60
80
100
120
140
160
180
CNA/OCNA N
ews
Other
New
sOM
GOTB
Other
Prin
ted P
aper
OCC & O
BB
Other
Pap
er P
ckg
PET bottl
es
HDPE bottl
es
All Oth
er P
last
ics
Steel
Alum
inum
Glass
To
tal
Fee
Rat
e ($
/to
nn
e)
2006 Fees
2007 Fees using Previous Methodology
27
Preliminary Base 2007 Fee RatesPreliminary Base 2007 Fee Rates
Material CategoriesBase 2007 Fees
(Revised) ($/tonne)
Base 2007 Fees (Previous) ($/tonne)
CNA/OCNA News 7.29 7.59Other News 7.04 6.91OMB 20.79 14.62OTB 20.79 13.21Other Printed Paper 20.79 70.13OCC & OBB 78.36 81.25Other Paper Packaging 111.22 81.25PET bottles 126.10 140.59HDPE bottles 108.60 140.59Other Plastics 162.89 140.59Steel 47.62 46.83Al Food & Beverage Cans -17.15 -6.42Other Aluminum Packaging 64.07 65.58Flint Glass 37.51 37.11Coloured Glass 39.53 39.68
28
29
Input Requested by BoardInput Requested by Board
Board requested stakeholders input on Board requested stakeholders input on additional elements of stewards’ feesadditional elements of stewards’ fees allocation of projected 2006 operating surplusallocation of projected 2006 operating surplus market development strategy & feesmarket development strategy & fees
29
30
Projected 2006 Operating SurplusProjected 2006 Operating Surplus
Projected operating surplus of $4.93MProjected operating surplus of $4.93M prior year feesprior year fees penalties & interestpenalties & interest savings in expendituressavings in expenditures
Board approved reserve of $3.5MBoard approved reserve of $3.5M unanticipated liabilities on revenue collectionunanticipated liabilities on revenue collection quick response to program improvement opportunitiesquick response to program improvement opportunities other contingenciesother contingencies
31
Allocation of Balance of SurplusAllocation of Balance of Surplus
Remaining projected 2006 surplus of Remaining projected 2006 surplus of $2.43M$2.43M
Initial staff recommendation:Initial staff recommendation: credit remaining surplus against 2007 feescredit remaining surplus against 2007 fees allocate based on relative reporting versus allocate based on relative reporting versus
target fees on material-specific basistarget fees on material-specific basis simple, but fairsimple, but fair
accounts for under- & over-reportingaccounts for under- & over-reporting
all materials receive benefitall materials receive benefit
32
Board Direction on SurplusBoard Direction on Surplus
Broader input on range of optionsBroader input on range of options simple:simple:
equally across material categoriesequally across material categories
based on relative tonnes reportedbased on relative tonnes reported
based on relative fees reportedbased on relative fees reported
same manner as common costssame manner as common costs
more sophisticated:more sophisticated: relative reporting versus target on by materialrelative reporting versus target on by material
actual over- & under-reporting versus target by materialactual over- & under-reporting versus target by material
Effect of Proposed Allocation of SurplusEffect of Proposed Allocation of SurplusRevised MethodologyRevised Methodology
-2
0
2
4
6
8
10
12
14
16
18
CNA/OCNA N
ews
Other
New
s
Other
Prin
ted P
aper
OCC & O
BB
Other
Pap
er P
ckg
PET bottl
es
HDPE bottl
es
Other
Pla
stic
sSte
el
Alum
inum
Glass
Cre
dit
Ag
ain
st F
ees
(¢/k
g)
Credit from Distibution of Surplus
Base Fee Using Revised Methodology
33
34
Market DevelopmentMarket Development
BBPP allows for material-specific market BBPP allows for material-specific market development fees to:development fees to: ensure capacity for recovered materialsensure capacity for recovered materials increase revenue for recovered materialsincrease revenue for recovered materials
Priority for first years Priority for first years mixed glass mixed glass successful investmentssuccessful investments
Now 2 priority areas:Now 2 priority areas: plastics #3 to #7 (not PET/HDPE)plastics #3 to #7 (not PET/HDPE) paper-based composite packagingpaper-based composite packaging
35
Priority 1: Plastics (1)Priority 1: Plastics (1)
Drivers:Drivers: WDO, AMO, MOE pressureWDO, AMO, MOE pressure WDO Board directed Stewardship Ontario to commit WDO Board directed Stewardship Ontario to commit
resources & report progress regularlyresources & report progress regularly high visibility in remaining waste streamhigh visibility in remaining waste stream
#3 to #7 grades#3 to #7 grades Current recovery < 6%Current recovery < 6%
compared to >50% for PET & HDPEcompared to >50% for PET & HDPE Toronto adding film & polystyreneToronto adding film & polystyrene
lack of facilities to processlack of facilities to process Potential for energy recovery optionPotential for energy recovery option
36
Priority 1: Plastics (2)Priority 1: Plastics (2)
Initial Staff recommendations:Initial Staff recommendations: Accelerate request for EOIAccelerate request for EOI 5,000 to 7,000 tonnes of # 3 to #7 plastics over 5,000 to 7,000 tonnes of # 3 to #7 plastics over
next 3 yearsnext 3 years Dedicated funding pool of $250,000Dedicated funding pool of $250,000
paid by stewards of these materialspaid by stewards of these materials
Plan for additional fees in 2008/2009Plan for additional fees in 2008/2009 Use reserve fund as necessary for quick responseUse reserve fund as necessary for quick response Promote Stewardship Ontario strategyPromote Stewardship Ontario strategy
37Priority 1: Plastics (3)Priority 1: Plastics (3)
Board direction to explore options:Board direction to explore options:1) Accelerate action-oriented investigation1) Accelerate action-oriented investigation
support EOI, preliminary planning & proposal evaluationsupport EOI, preliminary planning & proposal evaluation $250,000 for 2007 allocated to stewards of plastics #3 to #7$250,000 for 2007 allocated to stewards of plastics #3 to #7 anticipate possible additional fees in 2007 & 2008 to support anticipate possible additional fees in 2007 & 2008 to support
investment in new facilitiesinvestment in new facilities
2) Aggressive: 2) Aggressive: provide investment funds to accelerate immediate investment provide investment funds to accelerate immediate investment
in new facilitiesin new facilities significant additional fees for 2007 to offset risk for quick significant additional fees for 2007 to offset risk for quick
multi-million $ investments in new facilities multi-million $ investments in new facilities similar to previous investments for glass - $2Msimilar to previous investments for glass - $2M
3) Do nothing more (than current)3) Do nothing more (than current)
Fee Impacts in Addition to Fee Impacts in Addition to Base Plastics Fee RatesBase Plastics Fee Rates
Previous MethodologyRevised Methodology
0
2
4
6
8
10
12
14
16
18
20
PET bottles HDPE bottles Other Plastics
Revised Methodology
Incr
emen
tal F
ees
(¢/k
g)
Aggressive ($2,000,000)Recommended ($250,000)Base Fee
0
2
4
6
8
10
12
14
16
18
PET bottles HDPE bottles Other Plastics
Previous Methodology
Incr
emen
tal F
ees
(¢/k
g)
Aggressive ($2,000,000)Recommended ($250,000)Base Fee
38
39
Priority 2: Paper Composites (1)Priority 2: Paper Composites (1)
Drivers:Drivers: Collapse of Ontario marketsCollapse of Ontario markets LCBO TetraPak initiativeLCBO TetraPak initiative Current recovery rate <14%Current recovery rate <14%
compared to >60% for OCC & OBBcompared to >60% for OCC & OBB
Increasing generationIncreasing generation Steward (& supplier) demands for Steward (& supplier) demands for
recyclingrecycling
Priority 2: Paper Composites (2)Priority 2: Paper Composites (2)
Recommendations:Recommendations:
Establish focused task groupEstablish focused task group identify most cost effective optionsidentify most cost effective options
$100,000 funding pool in 2007 $100,000 funding pool in 2007 paid by stewards of these materialspaid by stewards of these materials assess alternative optionsassess alternative options develop detailed business case & initiate negotiationsdevelop detailed business case & initiate negotiations use reserve fund as necessary for quick responseuse reserve fund as necessary for quick response promote addition of these materials to existing promote addition of these materials to existing
programsprograms plan for possible additional fees in 2008 & 2009plan for possible additional fees in 2008 & 2009
40
Priority 2: Paper Composites (3)Priority 2: Paper Composites (3)
Board direction to explore options:Board direction to explore options:1) Accelerate action-oriented investigation1) Accelerate action-oriented investigation
establish task group to strengthen existing outlets & identify establish task group to strengthen existing outlets & identify cost-effective optionscost-effective options
$100,000 for 2007 allocated to stewards of these materials$100,000 for 2007 allocated to stewards of these materials anticipate possible additional fees in 2007 & 2008 to support anticipate possible additional fees in 2007 & 2008 to support
implementationimplementation
2) Aggressive2) Aggressive provide investment funds to accelerate immediate investment provide investment funds to accelerate immediate investment
in solutionsin solutions anticipate significant additional fees for 2007 to offset risk in anticipate significant additional fees for 2007 to offset risk in
multi-million $ investments in new facilities multi-million $ investments in new facilities possible investments of $500,000 in existing & new capacity possible investments of $500,000 in existing & new capacity
in millsin mills
3) Do nothing3) Do nothing
41
Fee Impacts in addition to Base Fee Impacts in addition to Base Paper Packaging Fee RatesPaper Packaging Fee Rates
0
2
4
6
8
10
12
14
OCC & OBB Other PaperPackaging
Revised Methodology
Incr
emen
tal F
ees
(¢/k
g)
Aggressive ($500,000)Recommended ($100,000)Base Fee
Previous MethodologyRevised Methodology
0
1
2
3
4
5
6
7
8
9
OCC & OBB Other PaperPackaging
Previous Methodology
Incr
emen
tal F
ees
(¢/k
g)
Aggressive ($500,000)
Recommended ($100,000)
Base Fee
42
Market Development Input Market Development Input Requested by BoardRequested by Board
Do you support?Do you support?
1) Recommended strategies for plastics & paper 1) Recommended strategies for plastics & paper composites market development involving:composites market development involving: modest investments for 2007 by stewards of materials modest investments for 2007 by stewards of materials
affected, as outlinedaffected, as outlined action-oriented investigation & likely leading to additional action-oriented investigation & likely leading to additional
material-specific fees to support investments as necessary material-specific fees to support investments as necessary in futurein future
2) A more aggressive approach involving committing 2) A more aggressive approach involving committing significant funds to support identification of significant funds to support identification of opportunities & immediate investment in solutionsopportunities & immediate investment in solutions
3) Do nothing more than current activities – involves 3) Do nothing more than current activities – involves support for very modest preliminary planning for support for very modest preliminary planning for plastics & nothing for paper composites.plastics & nothing for paper composites.
43
44Surplus Allocation Input Surplus Allocation Input Requested by BoardRequested by Board
Do you support?Do you support? Recommended distribution of projected Recommended distribution of projected
2006 operating surplus (above that 2006 operating surplus (above that allocated to the reserve fund) in 2007 feesallocated to the reserve fund) in 2007 fees
The recommended allocation method The recommended allocation method based on relative under- and over-based on relative under- and over-reporting by each materialreporting by each material
If not, what is your recommendation?If not, what is your recommendation?
Total Fee Rates with Total Fee Rates with Recommended FeesRecommended Fees
Material Categories2006 Fees ($/tonne)
2007 Fees (Revised) ($/tonne)
2007 Fees (Previous) ($/tonne)
CNA/OCNA News In-kind 5.47 3.41 6.05Cash 1.82 3.88 1.50
Other News 7.33 6.96 6.68OMG 14.81 19.20 14.21OTB 11.90 19.20 12.84Other Printed Paper 79.60 19.20 67.40OCC & OBB 76.73 75.35 78.56Other Paper Pckg 76.73 110.39 78.56PET bottles 135.56 120.91 136.75HDPE bottles 135.56 102.88 136.75Other Plastics 135.56 159.79 136.75Steel 46.01 45.31 44.51Al Food & Beverage Cans -4.76 -17.34 -6.62Other Aluminum Packaging 35.77 63.15 64.66Flint Glass 33.09 36.13 35.73Coloured Glass 36.02 38.29 38.44
45
Timeline for Comments & ApprovalTimeline for Comments & Approval
August 31August 31 Presentation of preliminary feesPresentation of preliminary fees
September 11September 11 Comments dueComments due
September 13September 13 Steward consultation meeting on market Steward consultation meeting on market developmentdevelopment
September 15September 15 Consultation: recommended market Consultation: recommended market development & allocation of surplus & development & allocation of surplus & presentation of revised preliminary feespresentation of revised preliminary fees
September 22September 22 Stewardship Ontario Board for ApprovalStewardship Ontario Board for Approval
October 2/3October 2/3 WDO Board for Approval of FeesWDO Board for Approval of Fees
Note: subject to Minister’s approval of revised fee-setting methodology
46
49BBPP Revision Consultation ScheduleBBPP Revision Consultation Schedule
Commences after 2007 fee setting process Commences after 2007 fee setting process completedcompleted largely to incorporate all WDO & Minister approved largely to incorporate all WDO & Minister approved
changeschanges Consider additional minor changes to program Consider additional minor changes to program
& Rules & Rules Release discussion paper in OctoberRelease discussion paper in October
include timelinesinclude timelines Undertake review of Undertake review of ActAct “within five years” “within five years”
(July 2007)(July 2007)