AUSTRALIAN RADIATION PROTECTION AND NUCLEAR SAFETY BILL 1998
AUSTRALIAN RADIATION PROTECTION AND NUCLEAR SAFETY (LICENCE CHARGES) BILL 1998
AUSTRALIAN RADIATION PROTECTION AND NUCLEAR SAFETY (CONSEQUENTIAL AMENDMENTS) BILL 1998
DECEMBER 1998
© Commonwealth of Australia 1997
ISBN 1440-2572 |
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Committee Secretary
Senate Standing Committees on Community Affairs
PO Box 6100
Parliament House
Canberra ACT 2600
Australia
MEMBERSHIP OF THE COMMITTEE
Members
| Senator Sue Knowles, Chairman |
LP, Western Australia |
| Senator Andrew Bartlett, Deputy Chair |
AD, Queensland |
| Senator Kay Denman |
ALP, Tasmania |
| Senator Alan Eggleston |
LP, Western Australia |
| Senator Chris Evans |
ALP, Western Australia |
| Senator Ross Lightfoot |
LP, Western Australia |
| Substitute Members |
|
| Senator Forshaw for Senator Evansfor the Committee's
inquiry |
ALP, NSW |
| Senator Stott Despoja for SenatorBartlett for the Committee's
inquiry |
AD, SA |
Participating Members
| Senator Eric Abetz |
Tas, LP |
| Senator Bob Brown |
Greens, Tasmania |
| Senator Mal Colston |
Ind, Qld |
| Senator Brenda Gibbs |
ALP, Qld |
| Senator Brian Harradine |
Ind, Tasmania |
| Senator Meg Lees |
AD, South Australia |
| Senator Dee Margetts |
GWA, Western Australia |
| Senator John Woodley |
AD, Queensland |
1. THE INQUIRY
1.1 The Australian Radiation Protection and Nuclear Safety Bill 1998
and associated Bills were introduced into the House of Representatives
on 8 April 1998 and into the Senate on 23 November 1998. On
26 November 1998, the Senate, on the recommendation of the Selection of
Bills Committee (Report No. 11 of 1998), referred the Bills to the
Committee for report by 1 December 1998. The reporting date was subsequently
extended to 2 December 1998.
1.2 The Committee considered the Bills at a public hearing on 30 November
1998. Details of the public hearing are referred to in Appendix 2. The
Committee received seven submissions relating to the Bills and these are
listed at Appendix 1.
2. THE BILLS
Australian Radiation Protection and Nuclear Safety Bill 1998
2.1 The Australian Radiation Protection and Nuclear Safety Bill 1998
(ARPANS Bill) proposes to establish a scheme to regulate the operation
of nuclear installations and the management of radiation sources, including
ionizing material and apparatus and non-ionizing apparatus, where these
activities are undertaken by Commonwealth entities. [1]
2.2 The Minister in the Second Reading Speech stated that:
This Bill is a critical piece of legislation which introduces, for the
first time in Australia, a comprehensive regulatory framework for all
Commonwealth radiation and nuclear activities. The ARPANS Bill closes
a current gap in regulation where State and Territory Government activities,
and private undertakings are regulated by State and Territory radiation
laws, but Commonwealth agencies have operated without corresponding Commonwealth
oversight and regulation. [2]
2.3 The Bill gives effect to the Government's commitment to comprehensive
Commonwealth legislation in this area and to the establishment of a national
regulatory body. The Bill also incorporates many of the recommendations
of the report of the Senate Select Committee on the Dangers of Radioactive
Waste, which called for an improved regulatory framework. [3]
2.4 The Minister in the Second Reading Speech stated that `regulation
of Commonwealth activities is also strongly supported by all State and
Territory Governments and the Bill has been crafted following consultation
with States and Territories'. [4]
2.5 The object of the Bill is to protect the health and safety of people,
and to protect the environment, from the harmful effects of radiation.
For this purpose, the Bill:
- establishes a statutory officer, to be known as the Chief Executive
Officer (CEO) of the Australian Radiation Protection and Nuclear Safety
Agency (ARPANSA). The functions of the CEO will include regulating Commonwealth
radiation and nuclear activities; working with the States and Territories
to develop uniform regulatory controls; informing and advising the Government
and the public on radiation protection and nuclear safety; and undertaking
research and providing services to ensure radiation protection and nuclear
safety.
- establishes a licensing scheme for the regulation of nuclear installations
operated by the Commonwealth or Commonwealth entities, from the time
at which plans are drawn up to construct an installation through all
its stages of operation until it is decommissioned.
- establishes a licensing scheme for the regulation of ionizing sources
and certain non-ionizing sources where these are dealt with by Commonwealth
entities.
- establishes a Radiation Health and Safety Advisory Council (and two
supporting Committees – the Radiation Health Committee and the
Nuclear Safety Committee), with members to include State/Territory radiation
control officers, relevant scientific and technical experts and representatives
from the community. The Council will have functions including advising
the CEO on matters relating to radiation protection and nuclear safety,
the development of uniform standards and codes of practice and examining
matters of major concern to the community in relation to radiation protection
and nuclear safety. [5]
Australian Radiation Protection and Nuclear Safety (Licence Charges)
Bill 1998
Australian Radiation Protection and Nuclear Safety (Consequential Amendments)
Bill 1998
2.6 The Australian Radiation Protection and Nuclear Safety (Licence Charges)
Bill 1998 provides a capacity for annual charges to be made for licences
issued under the ARPANS Bill. The Australian Radiation Protection and
Nuclear Safety (Consequential Amendments) Bill 1998 makes consequential
changes to the Australian Nuclear Science and Technology Organisation
Act 1987 and provides for transitional arrangements in relation to
the proposed ARPANS Act.
3. ISSUES
Allowable levels of radiation
3.1 Some submissions and witnesses at the public hearing raised issues
in relation to allowable levels of radiation provided for in the proposed
legislation. [6]
3.2 The ARPANSA Taskforce stated, however, that the ARPANS Bill and Regulations
`apply a radiation protection regime that, within the boundary of overall
dose limits, doses from justified practices must be as low as can be reasonably
achieved and that practices are optimal, within dose constraints to be
agreed by the CEO for each source'. [7] ANSTO also noted that the ARPANS legislation sets
the same standards for limiting public radiation doses from regulated
facilities and sources as recommended by international scientific and
medical authorities, such as the World Health Organisation and the International
Atomic Energy Agency; and mirrors the standard in all Australian States'
legislation on radiation safety. [8]
3.3 The Taskforce noted that the ARPANS Bill require that in deciding
whether to issue a licence authorising a radiation practice, the CEO must
take into account any matter specified in the Regulations. The Regulations
specify that these matters include whether the applicant has shown that
there is a net benefit from carrying out the proposed practice and whether
the applicant has shown that the `as low as reasonably achievable' requirement
will be met. The Regulations also set dose limits and specify that compliance
with these limits would be a condition of any licence issued by the CEO.
[9]
Independence of the proposed Agency
3.4 The ARPANSA Taskforce stated that the ARPANS Bill ensures that the
exercise of powers under the legislation is independent from the Government
of the day by creating the CEO as a statutory office holder; making it
clear that, subject to any Ministerial direction, the CEO is the decision-maker
on all matters referenced in the legislation; providing that the CEO report
quarterly and annually to Parliament; and enabling the CEO to present
a report relating to any of the CEO's functions to be tabled in either
House of Parliament at any time. [10] This
addresses the claims of several witnesses and submissions in relation
to the Agency's perceived lack of independence. [11]
Process for appointment to, and composition of, Advisory Councils
3.5 As noted above, the ARPANS legislation provides for the establishment
of three advisory structures – the Radiation Health and Safety Advisory
Council, the Radiation Health Committee and the Nuclear Safety Committee.
3.6 Some submissions and witnesses argued that that the proposed legislation
does not provide for adequate community representation on the advisory
councils and committees. [12]
3.7 The ARSANSA Taskforce noted that in relation to the Council the legislation
stipulates that each member of the Council must be appointed by the Minister
and that persons must not be appointed unless the Minister is satisfied
that the person has the relevant expertise in relation to radiation protection
or nuclear safety. The legislation also provides that that the Council
must include a person to represent the interests of the general public,
as well as representatives of two State/Territory Governments, the CEO
and up to eight other members.
3.8 In relation to the committees, the Taskforce noted that, the legislation
requires that all committee members must have expertise relevant to, or
knowledge of, nuclear safety or radiation protection. The legislation
further provides that that both committees must include a person to represent
the interests of the general public. In addition, the Nuclear Safety Committee
must include a person to represent the local government or the local administration
of an area affected by a matter related to the safety of a controlled
facility. [13]
Public review of new projects
3.9 The Sutherland Shire Council raised the issue of local government
involvement in ARPANSA processes and specifically that there was no requirement
in the proposed legislation for development applications to be submitted
to local councils. [14]
3.10 The ARPANSA Taskforce stated, however, that there are mechanisms
allowed for in the Bill which will ensure that there is public awareness
of, and allow for participation in ARPANSA decisions. These include the
role and operation of the Council and Committees (which will include community
representatives and external experts) and the requirement for the CEO
to present an annual report and quarterly reports to Parliament. The Taskforce
advised the Committee that the Radiation Health Committee will continue
to make draft codes and standards open to public comments. Arrangements
for public consultation processes for the Council and the Nuclear Safety
Committee for licensing decisions by the CEO will also be developed. [15]
Penalties
3.11 Under the ARPANS legislation, a controlled person must not undertake
prohibited dealings or conduct, without a licence or an exemption (penalty
– $1.1 million (corporation) or $220 000 (individual); and must
comply with the conditions of licence (penalty – $1.1 million (corporation)
or $220 000 (individual). The ARPANSA Taskforce noted that `as is
evident from a comparison with like legislation the penalties imposed
under the ARPANS legislation are significant and are equal to or in excess
of the penalties imposed under legislation which has similar objectives'.
[16]
Liability in case of accidents
3.12 Sutherland Shire Council claimed that Crown activities should not
be exempt from prosecution for an offence under the proposed legislation.
[17] The ARPANSA Taskforce stated, however, that the
Bills in no way mitigate the liability of Commonwealth entities licensed
by the CEO of ARPANSA. All Commonwealth entities will retain individual
responsibility for maintaining safety in respect of radiation sources
and nuclear facilities. ARPANSA will be responsible for setting standards
and safety goals and undertaking inspections to ensure compliance with
the legislation.
3.13 The Taskforce noted that it will not assume liability for incidents
or accidents occurring within the jurisdiction of the licensed organisation
– `this is entirely appropriate and consistent with best practice
regulation in modern industries. The fundamental safeguard is the fostering
of a safety culture by the operator – and this is best achieved when
the responsibility is clearly borne by the operation'. [18]
Waste disposal and storage issues
3.14 Some submissions and witnesses raised issues relating to possible
waste disposal and storage problems. [19]
3.15 The ARPANSA Taskforce stated, however, that the Bills and Regulations
provide definitions of radiation sources and nuclear facilities, which
would include any waste disposal or storage facilities. ARPANSA also noted
that the Bill does not, however, pre-empt or replace the existing mechanisms
by which the Government would decide to construct or site such facilities.
The Taskforce noted that the legislation `simply ensures that should such
a decision be taken, that the resulting facility would be subject to the
highest level of regulatory control'. [20]
4. RECOMMENDATIONS
The Committee reports to the Senate that it has considered the Australian
Radiation Protection and Nuclear Safety Bill 1998, the Australian Radiation
Protection and Nuclear Safety (Licence Charges) Bill 1998 and the Australian
Radiation Protection and Nuclear Safety (Consequential Amendments) Bill
1998.
1. The Committee recognises and supports the need for a strong regulatory
structure to monitor Commonwealth activities involving radiation protection
and nuclear safety.
2. The Committee believes the Bills presented to the Senate provides
that structure but would recommend amendments to the legislation to:
- Ensure the CEO must have regard to the application of world's best
practice when issuing licenses.
- Ensure the Minister and the CEO consider nominations from consumer
and environmental groups before making appointments of persons on each
of the Committees.
- That the CEO have the functions of monitoring and reporting on the
operations of ARPANSA, the Radiation Health and Safety Advisory Council,
the Radiation Health Committee and the Nuclear Safety Committee, including
reporting through Quarterly and Annual reports.
- That the CEO be given direct power over the staffing of ARPANSA.
- That where the CEO gives directions to a controlled person believed
not to be complying with the Act, the direction be passed to the Minister
and tabled in the Parliament.
- Amend the definition of “nuclear installation” to delete
the references to nuclear power reactors and to reprocessing facilities,
and to add references to the following:
- a spent fuel conditioning plant
- a nuclear isotope production facility
- a nuclear waste storage facility
- a nuclear waste disposal facility.
- That the Bill distinguishes between medium scale facilities, such
as a reactor or waste storage site, which could be called “nuclear
installations” and small scale facilities which might be dubbed
“prescribed facilities” to enable an appropriate degree of
planning oversight and public participation for each category.
- That a licence under section 31 should only occur:
- in the case of a prescribed facility, after the proponent has
issued a public notice providing an opportunity for comment by third
parties to the CEO prior to a decision on the licence.
- That similar procedures as are required under the Environment Protection
(Nuclear Codes) Act 1978 should be incorporated for the development
of replacement Codes and that transitional provisions be inserted to
keep existing Codes current until new ones have been adopted be included
in the regulations.
- That the regulations include provisions that all new and existing
licenses be listed in the Quarterly Report.
- That there be conflict of interest provisions in relation to Committee
members included in the regulations.
3. The Committee recognises the importance of getting the new framework
in place but also notes the strong community concern about the details
of its implementation. It is therefore recommended that:
- The draft regulations to be made under the Bill should be presented
for public comment for a period of not less than two months before being
presented to Parliament by the Government and that matters of detail
be considered further at that stage.
- The Bills should be passed by the Senate, incorporating the recommended
amendments.
Senator Sue Knowles
Chairman
December 1998
ADDITIONAL COMMENTS FROM AUSTRALIAN LABOR PARTY
AUSTRALIAN RADIATION PROTECTION AND NUCLEAR SAFETY BILL 1998
AUSTRALIAN RADIATION PROTECTION AND NUCLEAR SAFETY
(LICENCE CHARGES) BILL 1998
AUSTRALIAN RADIATION PROTECTION AND NUCLEAR SAFETY (CONSEQUENTIAL
AMENDMENTS) BILL 1998
The Opposition supports the appropriate use of radiation and nuclear
material for industrial and medical uses. Hence it welcomes these Bills
which will establish an overdue national framework for regulation of these
activities at the Commonwealth level.
The Opposition welcomes the various amendments the Government has agreed
to accept to strengthen this Bill and improve the accountability of the
proposed Agency. The Opposition also welcomes the removal from the Bill
of references to nuclear activities which do not currently occur in Australia
and which should not be allowed to be established – including nuclear
power plants and commercial re-processing
There is unfortunately one area where agreement has not been reached.
In the case of a nuclear installation, the Bill should provide that prior
to making a decision on licensing for a significant nuclear installation,
the CEO has conducted a public Inquiry into the need for the facility.
On such proposals there should also be a requirement that an environmental
impact study has been undertaken in accordance with the procedures set
out in the Environment Protection (Impact of Proposals) Act 1974.
Senator Michael Forshaw (ALP, New South Wales)
Senator Kay Denman (ALP, Tasmania)
MINORITY REPORT BYSENATOR DEE MARGETTS, THE GREENS (WA) and
SENATOR NATOSHA STOTT DESPOJA, AUSTRALIAN DEMOCRATS
Senate Community Affairs Legislation Committee Report on the Australian
Radiation Protection and Nuclear Safety Bill 1998 and Related Legislation
Preface
The introduction of legislation providing for the protection of the Australian
community from the adverse effects of radiation and for the safety of
Australians who deal with radioactive materials is extremely important.
Too important to be allowed to go through Parliament without the opportunity
for the Australian community to register its concerns about the regulatory
regime which we will have to rely on to protect us from hazards which
have the potential to remain with us for an indefinite period of time.
For that reason, this committee was called at Senator Margetts' instigation
and, as predicted, heard a range of concerns expressed. Many of those
concerns have the potential to be addressed by way of amendment to the
legislation and the hearing has clarified the issues, providing a way
forward to strengthen the protection provided by the Bill.
A number of community groups expressed concern about how much of the
framework of nuclear regulation is to be contained in regulation rather
than in the legislation itself.
The Government, however, is to be commended for going some way towards
meeting those concerns and particularly for allowing a period of open
public consultation on the Regulations which are so important to the effective
functioning of ARPANSA as a regulatory body.
It does not, however go far enough and concerns remain which are outlined
in this report.
The Issues
One of the key concerns raised by several parties to the hearing and
others who made written submissions is the fundamental issue of whether
there is such a thing as a safe level of exposure to radiation.
It is the view of the minority report that there is no safe level of
exposure and to legislate to allow any increase in the radiation to which
any Australians are exposed is fundamentally flawed. Even following the
presentations by ARPANSA and ANSTO, concern remains about the allowable
exposure to radiation. A particular concern is the power of the CEO to
grant exemptions which could see workers exposed to higher doses of radiation
than otherwise allowed. The aim should be to have exposure as close to
zero as is technically possible and there should not be power to grant
exemptions.
The standard in the legislation, purports to be `World's Best Practice'.
Whilst this should mean `As low as technically achievable' (ALATA), the
standard in this legislation is set `As low as reasonably achievable'.
If this is `world's best practice', it is not good enough, especially
when we know that better standards ARE achievable elsewhere. World's best
practice does not equate to IAEA acceptable levels. Standards are constantly
under review and technological developments are taking place, but `best
practice' in the nuclear industry is constrained by economic forces which
should not be the primary concern in a Bill to protect Australians from
radiation and provide for nuclear safety.
The precautionary principle MUST be the most important consideration
where nuclear health and safety issues are concerned. For this reason,
we will seek to delete the threat of imprisonment for ARPANSA inspectors
making a false or misleading statement in a warrant. Criminal law should
quite adequately deal with criminal fraud, should that be a problem. Including
threats of imprisonment in this way in this legislation could be seen
as intimidatory- and not necessarily in the best interests of the community.
Despite our stated problems with the use of the term `world's best practice',
the inclusion of a requirement for the CEO to have regard to `world's
best practice' when issuing licences is an improvement on the original
Bill.
For the regulatory authority set up under this legislation to have the
confidence of the Australian community, it must clearly be independent
of the Government of the day and be responsible to Parliament. The regulatory
authority (the Chief Executive Officer of the Australian Radiation Protection
and Nuclear Safety Agency) falls some way short of this standard because
it is not an independent statutory authority. We are pleased, however,
to see that the Government has now agreed that the CEO have direct power
over the staffing of ARPANSA.
The recommendation to exclude nuclear power reactors from the legislation
is an improvement in accountability. The Greens and Australian Democrats,
however, are concerned that licenses for `a nuclear fuel fabrication plant',
`an enrichment facility' `a fuel storage facility' and `a reprocessing
facility' remain possible under this legislation, albeit with the approval
of the CEO. These activities should either be specifically prohibited
under this legislation, or at the least, should not be able to take place
without full and separate Parliamentary scrutiny.
Separate approval should also be obtained for ANY other new facilities,
such as a spent fuel conditioning plant, a nuclear waste disposal facility,
a waste storage facility or an isotope production facility. It should
be noted however that any proposal for such a facility would itself be
of great concern to The Greens.
If our concerns regarding scrutiny of any proposal for any new nuclear
facility are not satisfactorily addressed, we will seek to amend the definition
of `nuclear installation' to delete reference to any nuclear installation
which does not currently exist.
Major nuclear installations require much greater prior scrutiny than
is envisaged in the Bill. In particular there must be a comprehensive
public inquiry into and Parliamentary scrutiny of the question of whether
there is a need for the installation before the process even gets to the
stage of an impact statement or an inquiry into the proposal itself.
No licence proposal should be considered until a public, open inquiry
into the need for the installation and an impact assessment process have
been completed. An amendment to achieve that end will be moved in the
Committee stage of the Bill.
The proposed government amendment to give public notice of the licensing
of a nuclear installation is grossly inadequate. The whole process must
be open to public participation and this should be reflected in the Regulations.
There is no reference in the Bill to the regulation of, or setting of
standards in the uranium mining industry, yet codes of practice in the
industry were covered by the Environment Protection (Nuclear Codes)
Act which is repealed by a Consequential Amendments Bill. It is desirable
for the Commonwealth to have oversight of such standards and for there
to be an open public process for the ongoing development and improvement
of the Codes. The Bill is silent on this question.
We commend the Government on clarifying the situation regarding existing
codes and development of improved codes by agreeing to have the current
requirements of the Environment Protection (Nuclear Codes) Act included
in the Regulations.
The only role for the community in this Bill is a purely advisory one
and even there it is a role severely constrained by the legislation. A
further amendment is required for protection from prosecution for Committee
or Council members who make public any information or concerns they may
have about radiation protection or nuclear safety.
We commend the introduction of conflict of interest provisions for Committee
and Council members in the Regulations and would like to see that extended
to include a register of financial interests.
There is clearly a need for the strengthening of reporting requirements
throughout the Bill. We are particularly concerned that the CEO's functions
include the monitoring and reporting on the operations of the Agency and
it's advisory bodies, and it is pleasing to see that the Government will
be moving appropriate amendments in this regard.
In summary, whilst the Greens (WA) and Australian Democrats are pleased
that the Government has made some concessions to acknowledge community
concerns about this Bill, we feel that further amendments are required
to ensure adequate protection for the community from the dangers of radiation
and nuclear activities.
Senator Dee Margetts, The Greens (WA)
Senator Natasha Stott Despoja , Australian Democrats, South Australia
APPENDIX 1 - Submissions received by the committee
| 1 |
Dr Jim Green |
| 2 |
ARPANSA Taskforce,
Australian Radiation Protection and Nuclear Safety Agency
|
| 3 |
Australian Nuclear Science & Technology
Organisation (ANSTO)
- Additional Information, dated 30 November 1998
|
| 4 |
Dr Alan Roberts |
| 5 |
Sutherland Shire Council
- Additional Information, dated 30 November 1998
|
| 6 |
Ms Jean McSorley
- Additional Information, dated 30 November 1998
|
| 7 |
Campaign for a Nuclear Free Future and
Australian Conservation Foundation
- Additional Information, dated 30 November 1998
|
APPENDIX 2 - Public hearing
A public hearing was held on the Bill on 30 November 1998 in Senate
Committee Room 2S2.
Committee Members in attendance
Senator Sue Knowles (Chairman)
Senator Andrew Bartlett (Deputy Chairman)
Senator Kay Denman
Senator Alan Eggleston
Senator Michael Forshaw
Senator Dee Margetts
Senator Natasha Stott Despoja
Witnesses
Australian Conservation Foundation (ACT)
Mr Larry O'Loughlin, A/g National Liaison Officer
Ms Jean McSorley, Nuclear consultant
Dr Jim Green, Nuclear consultant
Sutherland Shire Council
Councillor Kevin Schreiber, Mayor
Dr Garry Smith, Principal Environmental Scientist
Councillor Ken McDonell
Councillor Genevieve Rankin
Australian Nuclear Science and Technology Organisation (ANSTO)
Dr Ron Cameron, Director Safety
Mr Allan Murray, Government & Public Affairs Division
ARPANSA Taskforce
Australian Radiation Protection and Nuclear Safety Agency
Dr John Loy, A/g Chief Executive Officer
Nuclear Safety Bureau,
Mr Don MacNab, A/g Director
Australian Radiation Laboratory
Dr John Cable, A/g Director
FOOTNOTES
[1] Explanatory Memorandum, p.2.
[2] Minister's Second Reading Speech.
[3] Senate Select Committee on the Dangers of
Radioactive Waste, No Time to Waste, April 1996.
[4] Minister's Second Reading Speech.
[5] Explanatory Memorandum, p.2; Minister's
Second Reading Speech.
[6] Submission No.1, pp.3-5; Submission No.6,
p.1; Submission No.7, p.3; Committee Hansard, pp.4-6, 14.
[7] Submission No.2, p.2.
[8] Submission No.3, pp.3-4. See also Committee
Hansard, pp.25-26, 28-29.
[9] Submission No.2, p.1.
[10] Submission No.2, p.2. See also Committee
Hansard, pp. 32-33.
[11] Committee Hansard, pp. 2, 12, 17-18,
21-22; Submission No.1, p.3; Submission No.4, p.1; Submission No.6, p.5;
Submission No.7, p.9.
[12] Submission No.1, p.2; Submission No.4,
p.1; Committee Hansard, pp.2, 11, 16-17.
[13] Submission No.2, p.3. See also Submission
No.3, p.4.
[14] Committee Hansard, p.14.
[15] Submission No.2, p.3.
[16] Submission No.2, p.4.
[17] Submission No.5, p.3.
[18] Submission No.2 p.5. See also Submission
No.3, p.2.
[19] Submission No.1, pp.5-6; Committee
Hansard, pp.10-11, 14-15.
[20] Submission No.2, p.5.