CPRS White Paper: EITE Assistance Program

1 Introduction to the EITE assistance program

This paper sets out how the EITE assistance program will operate as detailed by the White Paper and the subsequent Guidance Paper released in February 2009 concerning the assessment of activities for the purposes of the EITE assistance program. The final operation of the EITE assistance program will depend on the final legislation and administration procedures put in place.

The two key questions in relation to an entity’s entitlement to EITE assistance are:

• Is the entity eligible to receive any EITE assistance (Eligibility)?
• If the entity is eligible to receive EITE assistance, how much assistance is it allocated (Allocations)?

Eligibility will be determined by whether the activities conducted by the entity meet the threshold requirements of ‘emissions intensive’ and ‘trade exposed’. Once these thresholds are satisfied, the entity may be entitled to either a 60 per cent or a 90 per cent free allocation of permits in relation to the eligible activity.

Allocations will be determined by using a set permit allocation formula, which takes into account the output of a particular activity, the relevant allocative baselines for the activity and the relevant allocation factors for the activity.

The following table provides a summary of the key details of the EITE program:¹

2 Assistance determined at an ‘activity’ level

The Federal Government has decided to determine both the eligibility for and the provision of EITE assistance at an ‘activity’ level.²  Emissions associated with particular activities will be assessed economy-wide across all entities conducting a particular activity and allocative baselines will be set for the activity. Consequently there will not be any company or project specific bias. This means that an entity’s operations will be split-up into separate activities and the eligibility for and level of assistance provided to the entity will be based upon each activity it is undertaking.

An ‘activity’ is a component of an overall ‘facility’, or may in some circumstances be an entire facility. ‘Facilities’ are the basis on which the National Greenhouse and Energy Reporting system is based.

The clearest description we have seen of what will be considered to be an activity is presented in the Green Paper, in respect of the aluminium industry and breaking it into the activities of bauxite mining, alumina production, primary aluminium production and semi-fabrication of aluminium, as follows:³

A precise definition of ‘activity’ or an indication of what are likely to be the recognised activities has not been provided. However the White Paper sets out a number of principles for defining activities and the boundaries around activities, for the purposes of assessing and providing EITE assistance. These principles are:⁴

• an activity consists of the chemical or physical transformation of inputs to produce a given set of outputs
• activities should not be differentiated by the technology employed, the fuel used, the age of the plant or the quality and types of feedstock used
• boundaries around activities should be consistently and equitably applied across industries
• the approach to establishing boundaries around activities should have minimal impact on business investment, location and structure decisions
• in determining the boundaries around activities, consideration is given to the scope for intermediate inputs produced within the activity to be substituted for bought-in inputs, and
• there should be no overlap between different activity definitions to ensure that it would not be possible to receive assistance more than once for a given quantum of emissions.

The White Paper presents a fictional example in Box 12.3 on page 12–21 to illustrate how activities will be defined. It separates as separate activities:

• upstream extraction of Kryptonite ore
• Kryptonite refining, the activity of processing Krypton ore into Kryptonite, and
• downstream smelting of Kryptonite to produce Kryptonium.

It is not suggested that transport of the products between these various activities would be included within any of them.

These activities would be set regardless of the quality of Krypton ore used, the electricity  sources used (for example coal or gas) and the technology used (where some operations are newer and more energy efficient).

The Guidance Paper states that an activity definition will include the following elements:⁵

• a description of the activity—detailing the key physical or chemical transformation that takes place
• key output/s—the key product/s produced by the activity
• the basis for allocation—a common unit relating to the activity with respect to which permits will be allocated. Most often this will be the product produced by the activity
• exclusions—sub-activities or elements of production which are explicitly not included in the activity definition. There will be general exclusions and exclusions specific to each activity definition, and
• key non-labour non-capital inputs—only specified for activities for which a value added metric will be used for the assessment of emissions intensity.

It is stated in the Guidance Paper that draft definitions for potential EITE activities will be circulated to entities for comments ahead of, or following, the workshops to be held in February and March 2009.⁶

Ultimately, the activities to be recognised under the CPRS and eligible for EITE assistance will be set out in the CPRS legislation, primarily in the CPRS regulations.⁷  Draft CPRS regulations containing eligible activities are expected to be released in June 2009.⁸

3 Emissions covered by the EITE assistance program

In relation to a particular activity, the Federal Government will provide assistance for cost increases associated with:

• direct emissions from the activity⁹
• indirect electricity emissions from the activity¹⁰
• indirect steam emissions from the activity. We have not considered indirect steam emissions further in this paper;¹¹  and
•  indirect emissions associated with the extraction, production and transportation of natural gas and its components when used as a feedstock by the activity.¹²

The Federal Government has decided not to provide assistance in relation to other indirect emissions on the grounds that they are significantly less material relative to other emissions costs throughout the economy.¹³

The provision of assistance for emissions associated with the use of natural gas as a feedstock will be restricted to entities who apply for an Obligation Transfer Number (OTN) to purchase natural gas used as a feedstock net of the carbon price.¹⁴

4 Eligibility

4.1 Eligibility criteria

Entities will receive EITE assistance for activities that they carry out that are both:¹⁵

• trade exposed, and
• emissions intensive.

The precise meaning of the terms ‘trade exposed’ and ‘emissions intensive’ are considered below in paragraphs 4.2 and 4.3 respectively.

The determination of activities that will be eligible for EITE assistance will be based on:¹⁶

• an assessment of all entities conducting a given activity, and
• historical information on the emissions intensity of different activities.

4.2 Eligibility – ‘trade-exposed’

An activity will be considered to be trade-exposed if the entities that undertake it are constrained in their ability to pass through related CPRS costs because they are price-takers on world markets or face competition in domestic markets from importers that source supplies from countries that have not imposed carbon constraints.¹⁷

Trade exposure will only be a threshold test to determine eligibility for EITE assistance, and will not be used to determine the level of EITE assistance provided.¹⁸

The Federal Government will allow trade-exposure to be determined quantitatively or qualitatively.

Quantitatively, an activity its trade-exposed if its annual trade share is at or above 10 per cent in any one of the years 2004–05, 2005–06, 2006–07 or 2007–08.¹⁹  Trade shares will be examined using information provided by applicants for EITE assistance and/or data available from the Australian Bureau of Statistics and the Australian Customs Service. Trade share will be defined as the ratio of the annual value of imports plus exports to domestic production of the product.

If an activity has an annual trade share below the 10 per cent threshold, an entity may submit an application to the Federal Government for a qualitative analysis of the capacity of entities conducting the activity to pass through costs due to the potential for international competition. The potential for international competition may be demonstrated by one or more of the following:²⁰

• historical trade share greater than 10 per cent with evidence that this may recur in the future
• a high correlation between the price received by domestic producers and a transparent international price for the good, taking into account tariffs, taxes, charges and transportation costs, and
• the existence of international producers who trade in the EITE product which is an exact substitute for the domestically produced product, combined with there being a lack of barriers to imports of the EITE product increasing in the medium term including:
  • the existence of effective distribution networks and low associated with the development of any required specialised facilities
  • relatively low transport costs
  • absence of customs restrictions, and
  • low switching costs to customers choosing imports.

4.3 Eligibility – ‘emissions-intensive’

The emissions-intensity of a particular activity will be used both to determine eligibility for EITE assistance as well as the level of assistance provided to the entity undertaking the activity. Emissions-intensity, as it is used to determine the level of assistance provided, is discussed below in paragraph 4.6.

The Federal Government has decided that an assessment of emissions-intensity, for determining eligibility for EITE assistance, will be based on either of two metrics:²¹

• the weighted average emissions (that is of all relevant emissions set out in paragraph 3 above) per million dollars of revenue generated by entities conducting the activity, or
• the weighted average emissions per million dollars of value added generated by entities conducting the activity. A simple proxy for ‘value added’ is used, which involves taking the revenue from the activity and removing only the most significant non-labour, non-capital inputs used by the activity.²² 

While the revenue test will be the default test, entities can request that they be assessed on the basis of the value added test.

In order to compare assessments of activities using the two alternative metrics, the Federal Government has decided that the value added test threshold for eligibility will be set at three times the revenue threshold to enable a fair comparison of activities on either basis.

The Federal Government has decided that emissions intensity will be based upon:²³

• estimates of the weighted average emissions per unit of production in 2006–07 and 2007–08 combined, and
• estimates of revenue or value added per unit of production in 2004–05, 2005–06, 2006¬–07, 2007–08 and the first half of 2008–09, where the average is calculated as the weighted average of the lowest four estimates from these five periods.

The Federal Government has decided to exclude the highest estimate of revenue or value added per unit of production to take account of commodity price spikes.

4.4 Assessment of existing activities

The Guidance Paper outlines the process for assessing whether a particular activity meets the eligibility criteria and so will be listed in the regulations as eligible for EITE assistance.²⁴  This involves two steps:

• a preliminary assessment, and
• for activities that pass the preliminary assessment, a formal assessment.

The preliminary assessment stage will require entities conducting potential EITE activities to provide the Federal Government with data and information to determine whether all or parts of a production process they conduct demonstrate the potential to meet the EITE eligibility criteria on both the emissions intensity and trade exposure requirements.²⁵  The preliminary assessment process is designed to avoid entities expending resources unnecessarily on the rigorous formal assessment process if they are very unlikely to be conducting activities that will meet the eligibility criteria.

Based upon the information received by the Federal Government prior to the release of the White Paper, entities conducting a number of production processes will be exempt from the preliminary assessment stage and will go straight to formal assessment of eligibility. The exempt production processes are those which contain activities which the Government believes are likely to be eligible for EITE assistance.²⁶  Exempt production processes are set out in Box 2.1 of the Guidance Paper and includes LNG production.

The formal assessment of the eligibility of an activity to receive EITE assistance involves 3 steps:

• the development of activity definitions
• the submission of assured data, and
• the assessment of data and determination of eligibility and allocative baselines.

Each of these steps is briefly discussed below.

(a) Development of activity definitions

This involves the establishment of a concise definition of each activity which was considered to demonstrate a potential to meet the EITE eligibility criteria.²⁷  The process for the development of activity definitions is outlined in more detail below in paragraph 7.

(b) Submission of assured data

Once a final activity definition has been released, entities can submit data that will be used to assess the eligibility of the activity and determine the allocative baseline.²⁸  This exercise will only be required once, as once an activity has been listed in the CPRS regulations as eligible, entities conducting that activity will only be required to provide annual production data on an ongoing basis.²⁹ The Federal Government is requesting that entities submit three categories of data:³⁰

• greenhouse gas emissions data
• production data, and
• financial data.

Consistent with the Federal Government’s timeframe, audited data from all entities conducting potential EITE activities must be submitted to the Department of Climate Change by close of business 1 May 2009 in order for the activity’s eligibility for EITE assistance to be formally assessed and presented in the draft regulations.³¹  The Guidance Paper states that entities may find it useful to commence the collation of key emissions, production and financial data immediately to facilitate the process of submission once the activity definition has been finalised.³²

The specific nature of the data to be supplied, estimation and measurement methodologies and particular calculations are set out in detail in Part 4 of the Guidance Paper.³³  The framework for assuring data supplied to the Federal Government is set out in detail in Part 5 of the Guidance Paper.³⁴  Please let us know if you would like further information on those matters.

(c) Assessment of data and determination of eligibility and allocative baselines

The Federal Government will use data submitted by entities conducting a particular activity, along with publicly available information, to determine:

• the industry average emissions intensity per unit of production for the activity
• the trade exposure of the activity, and
• the allocative baselines for the activity.

The Federal Government’s options in relation to entities that provide misleading information, partial information or fail to provide information are set out in Part 6 of the Guidance Paper.³⁵

Stakeholders will be made aware of the Federal Government’s decisions on eligibility for EITE assistance and allocative baselines through the publication of draft regulations and supporting documentation.³⁶

4.5 Assessment of activities new to Australia

When an entity commences an activity which is new to Australia, and therefore has not previously been assessed for assistance, the Government has decided that the assessment of eligibility will be made in reference to international best-practice emissions intensity for the production of the primary output of the new activity.³⁷  If the Federal Government decides that a new activity is eligible for EITE assistance, the Scheme regulations will be amended to include the new activity.³⁸

Assistance rates provided will be adjusted by the carbon productivity contribution discussed below in paragraph 4.6(a).

4.6 Eligibility thresholds

The Federal Government has decided that the emissions-intensity thresholds for the two available rates of assistance will be:³⁹

No EITE assistance will be available in relation to activities with an emissions intensity of less than 1,000t CO2e/$million revenue or 3,000t CO2e/$million value added.

The Federal Government does not intend to readjust or recalibrate the eligibility thresholds or initial rates of assistance in light of any subsequent information about the quantum of assistance likely to be provided as EITE assistance.⁴⁰ 

(a) Carbon productivity contribution

The level of EITE assistance provided to eligible activities will gradually reduce each year by the ‘carbon productivity contribution’. The carbon productivity contribution is set at 1.3 per cent per year to ensure that EITE industriesmake some contribution to the national improvement in carbon productivity.⁴¹

5 Allocations

5.1 The allocation formula

The allocation of free permits to an entity carrying on a particular EITE eligible activity will be made with respect to the:

• direct emissions
• indirect electricity emissions, and
• upstream natural gas emissions (when used as feedstock),

for the activity, according to set activity baselines (comprised of allocations in respect of these covered emissions sources), calculated for the level of output and then adjusted for by the applicable assistance rate (60 per cent or 90 per cent).⁴²

This can be expressed with the following formulae:

As such, the only entity-specific factor that will influence an entity’s allocation of permits in relation to a particular activity is the level of output of the activity for the individual entity.

5.2 Level of production

Allocations will be based on an entity’s production from the previous year.⁴³  For the first year’s allocation, the three financial years before the CPRS begins will be considered and the average production of the two highest years of those three will be used.

5.3 Allocative baselines

Allocative baselines measure the emissions generated per unit of output for a given activity, or the quantity of a relevant input such as electricity or natural gas used per unit of output for a given activity.⁴⁴  Baselines are required to calculate the number of permits to issue to an entity conducting an EITE activity for every unit of output they produce.
Allocative baselines will be set on an industry-wide basis for each activity. This means that all entities conducting a given activity will receive permits on the same basis, regardless of their specific emissions intensity.⁴⁵  Baselines will be determined up front by the Government and prescribed in the CPRS regulations.⁴⁶

Three different baselines will be used to determine the emissions produced by an activity per unit of output. These are: ⁴⁷

• direct emissions per unit of output for an activity
• electricity-intensity baseline for indirect electricity emissions for an activity, and
• natural gas (or its components) feedstock intensity baseline for indirect natural gas emissions for an activity.

Baselines for allocations will not be updated over time for changes in the average emissions-intensity of activities, in order to maximise abatement incentives, and will be used to determine allocations to new and existing entities conducting a given activity.⁴⁸

For individual companies the use of allocative baselines that are set on an industry-wide basis by activity means they may either:

• receive a greater level of assistance, assessed at the industry baseline, than their particular operations require, because their operations’ emissions are less than the allocative baseline, which provides an incentive for companies to reduce their emissions, or
• receive a lesser level of assistance, assessed at the industry baseline, than their particular operations require, because their operations’ emissions are more than the allocative baseline, which again provides an incentive for companies to reduce their emissions.

5.4 Allocation factors

As assistance is provided to EITE activities in relation to the cost increases associated with the use of electricity and natural gas feedstock (and therefore their indirect CPRS costs), it is necessary to convert cost increases for these inputs into ‘emissions equivalent measures’. The electricity and natural gas allocation factors are estimates of the cost increases associated with these inputs and will be used to convert electricity and natural gas feedstock use into emissions for eligibility assessment purposes.⁴⁹

(a) Electricity allocation factor

A single national electricity allocation factor set at one permit per megawatt-hour will be used. This implies that in the allocative baseline, one permit will be provided for each megawatt-hour of electricity used on average, by an activity. This national electricity allocation factor will not be varied over time.⁵⁰

(b) Natural gas allocation factor

State-based natural gas allocation factors will be used in relation to the upstream emissions associated with the extraction, production and transportation of natural gas and its components used as feedstock. These factors will be determined with reference to the relevant emissions factors published in the National Greenhouse Accounts Factors (November 2008).⁵¹

5.5 New entrants

The EITE assistance program will provide assistance to new entrants (and significant expansions) on the same basis as to existing entities conducting a given activity.⁵² 

The regulations will set out rules for the regulator when determining production levels upon which to allocate assistance for new entrants and significant expansions, including a ‘ramp up’ to full production if appropriate. These will be designed to estimate fairly the expected production of the facility for the first few years of operation.⁵³

5.6 Closures

An entity will be required to relinquish permits allocated to it for production that did not occur if the entity ceases to operate. The details, including relevant reporting requirements upon closure, will be set out in the Act and regulations. Failure to relinquish permits will attract an administrative penalty.⁵⁴

5.7 Form of EITE assistance

The Green Paper discussed a number of alternatives for the form of EITE assistance, including:

• exemption of EITE industries from obligations under the CPRS
• border adjustments, whereby adjustments are made to the prices of traded products to remove the carbon price from exported goods and add a carbon price to imported goods
• cash payments by the Federal Government directly to EITE industries, or
• administrative allocations of permits to EITE industries.

In the Green Paper it was proposed that assistance would be provided to emissions-intensive trade-exposed industries in the form of free allocations of CPRS permits at the beginning of each compliance period, contingent on production.⁵⁵ 

The White Paper further considered these options in light of stakeholder submissions, and reaffirmed the position that EITE assistance will be provided to EITE industries in the form of an administrative allocation of CPRS permits at the beginning of each compliance period. The main advantage of administratively allocated permits is that their value moves in line with the CPRS costs faced by the entity; in effect acting as a natural hedge against CPRS costs.⁵⁶

The free allocations of CPRS permits will be made at the beginning of each compliance period (that is, each financial year).⁵⁷  Allocations to EITE entities will be based upon the entity’s level of output in the previous compliance period (see para 5.2 above). At the end of each compliance period, the entity must relinquish permits for production that did not occur in that year.⁵⁸  The White Paper is not clear on whether this would occur on the date by which emissions must be reported (31 October)⁵⁹  or on the date by which permits must be surrendered (15 December)⁶⁰  for a particular compliance period.

The regulator is required to publish details of the permits allocated as EITE assistance, including:⁶¹

• the recipients of EITE assistance, the numbers of permits allocated to each recipient and the provision under which they were allocated
• total permits allocated for the EITE assistance program, and
• the total for each activity within the program.

(a) Entity to receive allocation

When allocating EITE assistance, the Government must determine the appropriate legal entity to provide assistance to, so as to ensure that assistance is only claimed once for a given activity.⁶²

Given the complexities of CPRS liability, eligibility for EITE assistance will be linked directly to the entity that is, or would be, liable for the direct emissions from the activity.

Where the EITE activity is carried out at a single facility, the assistance will be given to the entity that is liable for the direct emissions of the facility, as assessed on the last day of the previous financial year.⁶³

Where the liability provisions result in more than one entity being liable for the direct emissions associated with the activity, all the parties that might have potential liability under the CPRS for the direct emissions of the activity must make a joint application to the regulator for assistance in respect of the activity.⁶⁴  The joint application must set out how permits would be apportioned between each party to the application, which is up to the parties to negotiate.

The details of these eligibility requirements will be set out in the regulations.

5.8 Tax issues

The free allocation of permits raises a number of tax issues. Please let us know if you would like further information on those matters.

6 Review of EITE assistance program

6.1 General review

The EITE assistance program will be reviewed by an Independent Expert Advisory Committee at each 5-yearly review or at another date at the request of the responsible Minister.⁶⁵

The EITE assistance program review will advise as to whether:⁶⁶

• modifications should be made to the EITE assistance program on the basis of whether it:
  • continues to be consistent with the rationale for assistance
  • is conferring windfall gains on entities conducting activities, and
  • is appropriately balancing the competing policy objectives
• activities not initially eligible for EITE assistance should be reconsidered for assistance, and
• broadly comparable carbon constraints are applying internationally, at either an industry or economy-wide level, or an international agreement involving Australia and all major emitting economies is concluded, in which case the Committee would make recommendations to Federal Government with regard to the withdrawal of EITE assistance.

5 years’ notice will be provided of any modifications to the EITE assistance program, unless the modifications were required for compliance with Australia’s international trade obligations.

Once the CPRS has commenced, firms may request that the Government commission the Productivity Commission (PC) to undertake an assessment of the CPRS impact on the industry. If the Government refers a request to the PC, it will make an assessment of the impact of the introduction of the CPRS on the industry, taking into account the industry’s circumstances, including a range of factors affecting profitability, and the assistance provided under the EITE and Climate Change Action Fund (CCAF). The PC will make recommendations to the Government about whether it should provide additional support to the industry from the CCAF, and the appropriate mechanism for that support.⁶⁷

6.2 Review of eligibility

The Government will include a provision in the CPRS to review the eligibility of activities for EITE assistance every five years on the basis of significant commodity price movements and changes in CPRS coverage.⁶⁸

(a) Review in light of commodity price changes

In relation to reassessment on the basis of commodity price changes, only changes in the price of the product, not the emissions of an activity, will be considered in the reassessment. The same historical emissions data from 2006–07 and 2007–08 will be used. This reassessment will be available for activities initially assessed as ineligible for EITE assistance and activities initially assessed eligible at the lower (60 per cent) rate of assistance. Further, the review will only relate to activities for which the rate of assistance will increase, in order to maintain certainty for entities conducting EITE activities.⁶⁹  Thus activities will not move to the lower level of assistance or lose eligibility for assistance altogether. If an activity is assessed as becoming eligible, the allocative baseline (see paragraph 5.3) will be set using 2006–07 and 2007–08 emissions levels or on international best practice benchmarks. Assistance rates provided will be adjusted by the carbon productivity contribution discussed in para 4.6(a).

(b) Review in light of CPRS coverage changes

If agricultural emissions are included in the CPRS from 2015, the eligibility of agricultural activities for EITE assistance will be reconsidered.⁷⁰  Assistance rates provided will be adjusted by the carbon productivity contribution discussed in paragraph 4.6(a).

7 Governance and implementation

The White Paper sets out the process for data collection by the DCC to guide the final determination of EITE issues, including the demarcation of activities. The key steps will be:⁷¹

The Guidance Paper was released in mid-February 2009, and provides further detail regarding:

• the process and timing for the assessment of existing activities
• activity definitions
• the greenhouse gas emissions data, production data and financial data that entities are requested to provide to the Federal Government
• the framework for assuring data provided to the Federal Government
• the consequences of the provision of misleading or partial data or the non-provision of information, and
• the process and timing for assessment of activities new to Australia.

The DCC will conduct a series of workshops with industries in February and March 2009.⁷²  Draft definitions for potential EITE activities will be circulated to entities for comment ahead of, or following, these workshops.⁷³  The purpose of the workshops will be:⁷⁴

• to outline the Government’s process for assessing the eligibility of activities under the EITE assistance program
• to discuss the relevant draft activity definition, and
• to outline the data required to be collected and submitted for the eligibility assessment of the activity to occur.

If an entity wishes to use the value added metric for the assessment of emissions intensity of a particular activity, it will need to raise this with the Department of Climate Change during the discussion of the draft activity definition at the workshop.⁷⁵

Entities conducting any of the activities listed in Box 2.1 of the Guidance Paper (including the production of LNG) should be contacted by the DCC with details of their workshop by 27 February 2009.⁷⁶

It is also likely that the DCC will look to use the data provided in respect of the EITE program in relation to any electricity-intensive, trade-exposed assistance regime under the Renewable Energy Target scheme. A discussion paper on that issue was released in late 2008, with submissions due by 20 February 2009. We can provide further information on this assistance and assist with submissions if required.

Endnotes

1. White Paper page 12-2.
2. White Paper pages 12-19 and 12-20.
3. Green Paper page 305/para 9.3.1.
4. White Paper page 12-20.
5. Guidance Paper page 16.
6. Guidance Paper page 16.
7. White Paper pages 12-20 & 12-87-88.
8. Guidance Paper pages 7 & 11.
9. White Paper page 12-23.
10. White Paper page 12-23.
11. White Paper page 12-23.
12. White Paper page 12-24.
13. White Paper page 12-25.
14. White Paper page 12-25. The use of an OTN is discussed further in the White Paper in Chapter 6.
15. White Paper page 12-26.
16. White Paper page 12-26.
17. White Paper page 12-27.
18. White Paper page 12-29.
19. White Paper page 12-29.
20. White Paper pages 12-29 and 12-30.
21. White Paper page 12-34.
22. White Paper page 12-34.
23. White Paper page 12-37.
24. Guidance Paper pages 8-12.
25. Guidance Paper page 8.
26. Guidance Paper page 8.
27. Guidance Paper pages 9-10.
28. Guidance Paper page 10.
29. Guidance Paper page 11.
30. Guidance Paper page 17.
31. Guidance Paper page 11.
32. Guidance Paper pages 10-11.
33. Guidance Paper pages 17-29.
34. Guidance Paper pages 31-40.
35. Guidance Paper pages 41-42.
36. Guidance Paper page 12.
37. White Paper page 12-40.
38. Guidance Paper page 43.
39. White Paper page 12-44.
40. White Paper policy position 12.11/page 12-50.
41. White Paper page 12-52.
42. White Paper pages 12-57 to 12-59.
43. White Paper page 12-74.
44. White Paper page 12-60.
45. White Paper page 12-60.
46. White Paper page 12-59.
47. White Paper page 12-59.
48. White Paper policy position 12.13/page 12-69.
49. White Paper page 12-35.
50. White Paper page 12-65.
51. White Paper page 12-68.
52. White Paper page 12-76.
53. White Paper pages 12-76 to 12-77.
54. White Paper page 12-79.
55. White Paper page 12-14.
56. White Paper page 12-17.
57. White Paper policy position 12.3/page 12-18.
58. White Paper page 12-2.
59. White Paper page 7-27.
60. White Paper page 7-39.
61. White Paper page 12-17.
62. White Paper page 12-79.
63. White Paper page 12-80.
64. White Paper page 12-81.
65. White Paper page 12-82.
66. White Paper Policy position 12.16/page 12-87.
67. White Paper Policy position 12.16/page 12-87.
68. White Paper page 12-38.
69. White Paper page 12-38.
70. White Paper page 12-39.
71. White Paper page 12-89.
72. White Paper page 12-91 and Guidance Paper, page 7.
73. Guidance Paper page 16.
74. Guidance Paper page 10.
75. Guidance Paper page 10.
76. Guidance Paper page 9.

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