REGIONAL MUNICIPALITY OF WATERLOO LICENSING AND RETAIL COMMITTEE AGENDA

Transcription

1 MEDIA RELEASE: Friday, May 4, 2012, 4:30 p.m. REGIONAL MUNICIPALITY OF WATERLOO LICENSING AND RETAIL COMMITTEE AGENDA Tuesday, May 8, :00 p.m. (Dinner provided at 4:30 p.m. in Waterloo County Room) Regional Council Chambers 150 Frederick Street, Kitchener, Ontario 1. DECLARATIONS OF PECUNIARY INTEREST UNDER THE MUNICIPAL CONFLICT OF INTEREST ACT 2. a) b) 3. a) b) c) DELEGATIONS David Byers, United Taxi and Waterloo Region Taxi Association, re: taxi-topopulation ratio Terry Kirby, Co-op Manager, City Cabs re: additional wheelchair-accessible van license REPORTS Corporate Resources CR-CLK-LIC , 2011 Annual Report for Licensing and Enforcement Services (LES) CR-CLK-LIC , Annual Report 2011 Regional (Area) Weed Inspector CR-CLK-LIC , Giant Hogweed Reduction Program, Year # LICENSING HEARING OPENING ADDRESS Marty Sawdon, Administrator, Licensing & Enforcement Services 5. DULOVIC, Dragan City Cabs Taxi Driver #6242 Evidence M. Sawdon Reply evidence from defendant Recommendation - M. Sawdon Committee discussion and recommendation 6. KOLAR, Vladimir United Taxi Driver #5668 Evidence M. Sawdon Reply evidence from defendant Recommendation - M. Sawdon Committee discussion and recommendation 7. KOSORICH, Mile City Cabs Taxi Driver #6043 Evidence M. Sawdon Reply evidence from defendant Recommendation - M. Sawdon Committee discussion and recommendation

2 L&R Agenda /05/08 8. MAVARANI, Soleiman Waterloo Taxi Owner #5228 Evidence M. Sawdon Reply evidence from defendant Recommendation - M. Sawdon Committee discussion and recommendation 9. VANG, Chertao New Hamburg Taxi Driver #6230 Evidence M. Sawdon Reply evidence from defendant Recommendation - M. Sawdon Committee discussion and recommendation 10. MOTION TO GO INTO CLOSED SESSION (if necessary) THAT a closed meeting of Licensing and Retail Committee be held on May 8, 2012 immediately following the taxi driver licensing hearings of the Licensing and Retail Committee meeting in Regional Council Chambers in accordance with Section 239 of the Municipal Act, 2001, for the purposes of considering the following subject matters: a) Personal matters about an identifiable individual; b) A matter in respect of which committee may hold a closed meeting under another Act. 11. MOTION TO RECONVENE INTO OPEN SESSION 12. LICENSING HEARING - COMMITTEE DECISIONS 13. INFORMATION/CORRESPONDENCE 14. OTHER BUSINESS 15. NEXT MEETING To be announced 16. ADJOURN

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5 REGION OF WATERLOO Report: CR-CLK-LIC CORPORATE RESOURCES Council and Administrative Services Licensing and Enforcement Services (LES) TO: Chair G. Lorentz and Members of the Licensing and Retail Committee DATE: May 8, 2012 FILE CODE: L18-80 SUBJECT: 2011 ANNUAL REPORT FOR LICENSING AND ENFORCEMENT SERVICES (LES) RECOMMENDATION For information. SUMMARY This report summarizes the activities of the Licensing and Enforcement Services unit of Council and Administrative Services for the year REPORT: Introduction: Licensing and Enforcement Services (LES) is responsible for the licensing, administration and enforcement of the by-laws for taxi-cabs with meters, limousines, special transportation (child transport), salvage yards and second hand goods / shops as well as the enforcement of by-laws for tree cutting including exceptions, illegal dumping and garbage collection, landfill site including speed enforcement with radar and load inspections, outdoor water use (Stage II Conservation and Stage III Emergency) and smoking in public places. LES is also tasked with the enforcement of provincial statutes the Weed Control Act, the Smoke-Free Ontario Act (SFOA), the administration of the Retail Business Holidays Act (normally must be closed on designated holidays) including exception hearings and assists with the red light camera program. The number of charges from cameras installed at intersections and requests for evidence continued to increase in Staff / Fleet: The following are assigned full-time to the LES unit: 1 Administrator, 1 Licensing Clerk and 5.5 Enforcement Officers. Three and a half (3.5) officers are assigned to Licensing and By-law Enforcement Services. Two officers are assigned to Smoke Free Ontario Act enforcement. These officers are all crossappointed and can provide mutual assistance to each other. Also appointed to the Unit is a temporary (seasonal) part-time Weed Inspector. In 2011, the Giant Hogweed Reduction Program (Year 2) was completed using 2 university students as seasonal full-time weed inspectors. LES is equipped with 5 vehicles. Two additional vehicles from Fleet Services are used during the summer months. Docs # Page 1 of 6

6 Report: CR-CLK-LIC Other Interim Reports for 2011: 1. Other reports CR-CLK-LIC and CR-CLK-LIC should be read in conjunction with this report for Weed Inspector s 2011 Annual Report and the 2011 Interim report on the Giant Hogweed Reduction Program. Licensing / Permits Type Taxi-cab Broker/Company Taxi-cab Owner/Vehicle Taxi-cabs Drivers Limousines Special Transport Vehicles (child) Salvage Yards/Shops Second Hand Goods Total L&RC hearings Total Defendants L&RC Hearings Tree Cutting NIC s Tree Cutting TBEC Hearings Total Licenses Issued Total Revenues Received $213, $231, $224, ¹ NIC s Notice(s) of Intention to Cut Revenues from Licence/Permit Fees This revenue received is from all types of licences issued by the Region. Fees are revenue neutral, based on the costs to administer and enforce the licensing by-laws. There was a significant increase in the number of licences issued to new taxi-cab drivers in Given the economic situation in Canada, many people turn to operating taxi-cabs on a part-time basis to supplement or maintain their income. While this was a significant increase, it is an anomaly and will not be sustained. The preliminary reports for 2012 show taxi-cab drivers licences are declining and returning to more normal levels. The decrease of licensing revenue in 2011 was the result of licensing fees for 2011 being paid early in November/December 2010 and not being credited to Inspections: The enforcement officers of LES carry out inspections to administer and enforce licensing and other Regional By-laws and the Smoke Free Ontario Act: Type of Inspection Taxi-Cab with Meter 2,150 1, Limousine Special Transport (child) Salvage Yards / Shops Second Hand Goods Tree Cutting NIC s Smoke Free Ontario Act¹ 3,093 1,997 2,037 Total 5,418 4,068 3,878 ¹ Includes all types Routine inspections of all public and work places, retailers and using youth test shoppers of 6

7 Report: CR-CLK-LIC Taxi-Cab Inspections: A minimum of three (x3) random inspections of Taxi-cabs are carried out per year. This includes a test of the taxi-cab meters. An analysis of the inspections of Taxi-cabs revealed a 10.3% rate that taxi-cabs failed to meet inspection standards. Non-compliance could range from a dirty vehicle to more serious defects to tires or brakes. Notices to correct the defects are issued with follow-up inspections to ensure that the defect(s) has been corrected. A 10% non-compliance rate is the norm and considered acceptable for a minimum of x3 inspections per year. On May 30 th 2011, the taxi-cab tariffs (rates charged to consumers) were increased by the L&R Committee and Council to meet rising fuel, insurance and business costs. Enforcement: Complaints/Investigations: Complaints / Investigations By-laws: (municipal election signs removed 1,180 signs (including election) removed ¹ Election signs / Sign by-law Dumping Taxi-cab Limousine Garbage Second hand Salvage Trees Woodland Protection Special Transport (child) Outdoor Water Use² Not tracked Smoke Free Ontario Act Total Number of Investigations 669 1,567 1,846 ¹ 889 commercial signs removed for non-compliance. ² detailed analysis available upon request. Warnings and Charges: Enforcement Warn Charge Warn Charge Warn Charge Taxi-Cab Limo Special Transport (Child) Salvage Second-Hand Tree Cutting Garbage 911¹ ¹ 4 356¹ 6 Landfill Water Use S-FOA 104² ² 57 Election Signs By-law (no 0 0 n/a n/a n/a n/a elections) ROW Sign By-law n/a n/a 734 signs removed/warned³ 0 1,180 signs removed/warned 3 ¹Includes pro-active enforcement patrols in the City of Waterloo off-campus student housing areas ²Includes all types of warnings including warning letters to vendors. ³Mostly election signs of 6

8 Report: CR-CLK-LIC Garbage/Dumping Although these complaints continue to dominate unit activities especially in the City of Waterloo where complaints outnumber the rest of the Region combined. Most complaints are received from Waste Management Services and most are accorded same-day service. These complaints are for the most part, situated in the off-campus student housing areas especially during the critical periods in the spring and fall when students are moving in/out. The complaints in 2011 were driven by pro-active enforcement efforts by LES working with Waste Management Services, the City of Waterloo and the Regional Police. The Unit continues to use gentle persuasion and other enforcement against offenders including both tenants and property owners resulting by Regional officers. Smoke-Free Ontario Act Enforcement The number of tobacco vendors that were charged with selling tobacco products to youth decreased in At the same time, there was a decrease in the number of vendors selling tobacco products. In 2011, two tobacco vendors were each suspended by the Ministry of Health Promotion and Sport from selling tobacco products for six months following second convictions for selling tobacco to youth. A trend that continues to increase here in the Region and elsewhere in the province is hookah pipe parlours and restaurants. Tobacco is being mixed in with the sheesha product used with the pipes. For additional information refer to the Report submitted to the Community Services Committee, PH /CR-CLK-LIC (available upon request). The Tobacco Enforcement Officers continue to work closely with the Waterloo Regional Police, the Ministries of Finance (Taxation) and Health Promotion, the Alcohol and Gaming Commission of Ontario and Regional Public Health. Regional Sign By-law Following a lengthy education of the public, the Regional Sign By-law was enacted in June There were two elections (federal and provincial) in 2011and compliance improved from the municipal election in No charges were laid in these elections but 197 signs (federal) and 94 signs (provincial) were removed by officers. In mid-2011, complaints about commercial signs and particularly the ground mounted wire signs escalated. Hundreds of these signs were being observed on the Regional roads, streets, allowances and on traffic signal / utility poles. It was determined that a more proactive enforcement approach was required rather than reacting on a complaint basis. Signs were to be removed and disposed of without notice, followed by notification and/or charges to the offenders. A joint operation was undertaken by LES officers assisted by municipal law enforcement officers from the Townships, the City of Cambridge along with staff from Traffic Engineering and Transportation Operations. This operation officially kicked off in early November and by year end, 889 commercial signs had been removed from Regional property. In addition, charges were laid. Because of the mild winter, the operation continued into By year end, officers were observing that roads and streets had a cleaner" and safer appearance. It was also observed that signs that had been on Regional property were now popping up on city and township streets. Further, at year end, it was observed that signs were being posted higher up on utility and traffic signal poles out of the reach of enforcement officers. This requires a Regional Roads crew to respond with ladders or a cherry picker to remove these signs. This can be considered wilful non-compliance and ramped-up enforcement in 2012 will be required to discourage this practice of 6

9 Report: CR-CLK-LIC Red Light Cameras Program The number of violations detected by red light cameras at intersections increased again in If a person is detected by the camera going through a red traffic light, the information is forwarded to the Red Light Camera Program in Toronto via secured . An authorized examiner will confirm the violation and authorize a summons to be issued which is mailed to the registered owner of the vehicle. A copy of this summons is also forwarded to LES in order for it to be filed by officers with the provincial offences court. This owner can pay the summons or request to have a trial and seek disclosure of the evidence against him/her (photographs). If the latter option is chosen, the provincial prosecutor will then direct Licensing and Enforcement Services to obtain the photographs for disclosure to the defendant. This program has a significant impact on LES resources and staffing. When this program first started in 2005, only 516 charges were laid compared to 7,258 in Of course, the number of cameras has also increased considerably during this 6 year period. Licensing and Enforcement Services submitted 1,029 disclosure requests to the Red Light Program in These requests are increasing each year (almost doubled in 2011 over 2010). The pictures are returned to LES, sworn to and filed with the prosecutor by a by-law officer. Most pictures result in guilty pleas by the defendants. Red Light Camera - Charges & Disclosure Requests ,024 / 540 7,528 / 1,029 Staff Achievements in 2011: Officer Connie Gardner continues to be enrolled in the Municipal Law Clerk Program at Conestoga College and in 2011, successfully received credits toward her certificate. At his own expense and on his own time, Officer Ryan Milanovic attended and successfully completed the Managing Patrol Operations course at the Ohio State Peace Officers Academy (USA) in London, OH. He also attended and successfully completed the Organizational Behaviour course at Conestoga College - Business School program. Officer Phil Neville attended and completed several workshops / seminars presented by the Ontario Municipal Law Enforcement Officers Association (MLEOA). He also prepared and presented to the MLEOA a seminar entitled, Forensics for By-law Officers. Conclusion: LES duties and tasks remained constant in 2011 with a continuing increase in activities. The number of taxi-cabs in the Region rose by 5 licences to 326 in accordance to the 1:1650 ratios and the population increase report received in Additionally there are 15 licences issued for Accessible Taxi-cabs. LES continues to work together with other enforcement agencies such as the Waterloo Regional Police, area fire services, and Ministries of the Environment, Transport, Labour, Agriculture, Finance Taxation, the Alcohol and Gaming Commission and area By-law services. The unit and its staff are members of professional associations, e.g. Municipal Law Enforcement Officers Association, Prosecutors Association of Ontario, the OMBI Group for Licensing and By-law Enforcement and the Ontario Association of Chiefs of Police. CORPORATE STRATEGIC PLAN This Report is in keeping with the Region s statutory obligations and supports the Region s Strategic Plan of 6

10 Report: CR-CLK-LIC FINANCIAL IMPLICATIONS The Licensing and Enforcement Unit is financed through the general tax levy, cost recoveries from licensing revenues and Transportation and Environmental Services. The Ministry of Health Promotion provides funding to pay for two tobacco enforcement officers and their related logistical support costs. OTHER DEPARTMENT CONSULTATIONS Facilities (security), Traffic Engineering (signs), Public Health, Legal including Provincial Offences Act Court, Waste Management, Water Efficiency, Planning (Trees), Finance (OMBI), Fleet Services and Transportation (GRT) are regularly consulted on an on-going basis. PREPARED BY: M. (Marty) Sawdon, Administrator, Licensing and Enforcement Services APPROVED BY: Kris Fletcher, Director, Council and Administrative Services/Regional Clerk of 6

11 Report: CR-CLK-LIC REGION OF WATERLOO CORPORATE RESOURCES Council & Administrative Services Licensing and Enforcement Services TO: Chair G. Lorentz and Members of the Licensing and Retail Committee DATE: May 8, 2012 FILE CODE: L19-03 SUBJECT: ANNUAL REPORT REGIONAL (AREA) WEED INSPECTOR RECOMMENDATIONS: For Information. SUMMARY: Each year, Council appoints an Area or Regional Weed Inspector as required by the Weed Control Act, R.S.O. to enforce said Act within the Council s jurisdiction. From 2004 to 2011 inclusive, Council appointed Mr. Larry Martin to carry out inspections and assist the Weed Inspectors appointed by area municipalities. The cities of Cambridge, Kitchener and Waterloo appoint their own Municipal Weed Inspectors. The Townships of North Dumfries, Wellesley, Wilmot and Woolwich do not appoint a Weed Inspector; they use the services of the Regional or Area Weed Inspector. REPORT: Activities Includes Calls, Queries and Complaints¹ City 2009¹ 2010¹ 2011² Cambridge Kitchener Waterloo North Dumfries Wellesley Wilmot Woolwich Out of Region New Pesticide 45 n/a n/a Info. Calls Total Complaints ¹ These include all designated noxious weeds, including Giant Hogweed (GHW). ² Year 1 of the GHW Reduction Program ³ Year 2 of the GHW Reduction Program Docs# of 3

12 Report CR-CLK-LIC Designated Noxious Weeds: The number of calls to the Regional Weed Inspector about designated noxious weeds, other then GHW has remained constant between 2009 and 2011 approximately 80 calls per year. The GHW Reduction Program continued in 2011 (Year 2) and is reported in CR-CLK-LIC There was a significant increase in the number of GHW calls in However, the number of GHW plants counted in the Region decreased slightly but still remains in the thousands. Based on observations by Inspector Martin and his team along with reports/complaints from the township (rural) property owners, GHW and European Buckthorn are thriving in the roadside areas (including ditches) of Regional and Township roads. European Buckthorn is a tree-like designated noxious weed and is spreading rapidly throughout the Region with thousands of plants being observed. European Buckthorn, a designated noxious weed, causes fungus problems with grain crops. Property owners were directed to destroy this weed and they have complied. Partial cutting of these weeds is the current practice and is not working; instead it is promoting the spread and growth of these noxious weeds. Roadside spraying of Regional and Township roads with herbicides is being recommended to promote the eradication of these weeds. Such spraying for the purpose of eradicating designated noxious weeds is permissible under the Pesticides Act of Ontario. Perth and Wellington Counties are carrying out roadside spraying. Transportation and Environmental Services has been notified of this recommendation and can do this as part of the summer roadside road maintenance program. Roadside spraying will have to be done for a few years to eradicate these designated noxious weeds. Reports, complaints and queries that are received about designated weeds within the three cities are referred to city-appointed weed inspectors. Non-Designated Noxious Weeds The presence of non-designated invasive weeds such as Garlic Mustard and Dog Strangling Vine continues to be observed and reported to the Ontario Invasive Plants Council. Garlic Mustard can destroy woodlots and if eaten by cows it can sour milk affecting milk, cheese and meat production. In addition, Garlic Mustard is a threat to the butterfly population which provides plant pollination. Recommendations have been made to the Ontario Ministry of Food, Rural Affairs and Agriculture to designate Garlic Mustard as a noxious weed. Training Inspector Larry Martin attended the following education sessions in 2011: Weed Inspectors Conference - Guelph, Ont. Ontario Invasive Plant Conference - Picton, Ont. Conclusion All property owners complied in the destruction of noxious weeds including GHW on their property, either destroying the weeds themselves or having spraying companies do it for them. No orders were required to be issued in Continued appreciation is extended to the Township of Wellesley for providing office space for the GHW students and Inspector Martin. There has been great rapport between the students, Insp. Martin and the township staff members of 3

13 Report CR-CLK-LIC CORPORATE STRATEGIC PLAN: Focus Area 1: Weed Control Act: Environmental Sustainability: Protect and enhance the environment A legislative requirement. FINANCIAL IMPLICATIONS: The cost for this program is approximately $17, (excluding the student GHW Program) per year which includes part-time salary, benefits, equipment, supplies, training and transportation for Insp. Martin. OTHER DEPARTMENT CONSULTATIONS: Finance department Municipal Weed Inspectors for Cambridge, Waterloo and Kitchener Transportation and Environment Services PREPARED BY: APPROVED BY: Larry Martin, Area Weed Inspector, Licensing and Enforcement Services M. (Marty) Sawdon, Administrator, Licensing and Enforcement Services Kris Fletcher, Director, Council and Administrative Services/ Regional Clerk of 3

14 REGION OF WATERLOO Report: CR-CLK-LIC Li CORPORATE RESOURCES Council and Administrative Services Licensing and Enforcement Services TO: Chair G. Lorentz and Members of the Licensing and Retail Committee DATE: May 8, 2012 FILE CODE: L19-03 SUBJECT: GIANT HOGWEED REDUCTION PROGRAM, YEAR # RECOMMENDATION: For Information SUMMARY: In 2008, Regional Council passed By-law designating Giant Hogweed (GHW) as a local noxious weed. In 2010 the Ministry of Agriculture and Rural Affairs then recognized Giant Hogweed as a noxious weed under the Weed Control Act. Resulting from Council direction, a program was instituted to identify and reduce the quantity of plants. Students were hired in 2010 and subsequently in 2011 to carryout inspections. As in 2010, the majority of plants were discovered in Wellesley and Woolwich Townships attributed to the waterways. This report includes data and information collected and prepared by the students. REPORT: Giant Hogweed (GHW) was seeing a rapid expansion onto agricultural lands in the Region of Waterloo after first being recorded in Ontario in Council passed By-law designating GHW as a local noxious weed. In 2010, Council directed staff to undertake a GHW Reduction program to curtail expansion and plant growth. A reduction program was developed and instituted in 2010 employing several methods; education, property inspections, public feedback and pro-active inspections. Three students were hired in the summer of 2010 to introduce the program. Since 2010 two students have been hired for the 2011 season and again in 2012 to undertake the program. Year 3, 2012, is the last scheduled year of the student program. Reports, complaints and queries that are received about GHW within the three cities are referred to city-appointed weed inspectors. All property owners complied in the destruction of GHW plants on their property, either destroying them themselves or bringing in qualified professionals. No orders were issued in 2011 for the destruction of GHW under the Weed Control Act. Findings and recommendations The following findings and recommendations were made by the students: New complaints suspecting the presence of GHW in 2011, increased by 171% over Page 1 of 12

15 Report: CR-CLK-LIC The majority of complaints were discovered to be a similar plant called Angelica, which is native to the Region and harmless. This could be directly attributed to educational efforts taken in Year 1 and 2 creating a public awareness of the identification of GHW plants. It is recommended that educational efforts continue in year 3 but better descriptors are necessary to ensure proper identification. The cluster size has increased minimally but the number of plants and number of properties with GHW has decreased. This should continue to be monitored because although this is a positive indicator, GHW can lay dormant for up to 10 years. A similar amount of inspections were conducted in 2010 and 2011 however 2012 (year 3 of the program) may see an increase of inspections in order to follow-up on calls received in 2011 and to respond to new calls in A majority of the GHW was found along the Conestoga and Grand Rivers. The rivers transport seeds to other locations further downstream and could eventually leave ROW and establish GHW populations throughout the Great Lakes. As can be seen in Figure 1 in Appendix A, newly discovered instances of GHW were found farther down river and up stream from those discovered in Additionally, GHW continues to spread downstream into the Region from Wellington County. The graph below shows the average cluster size of GHW found in the Region. Clusters of 1-5 plants was discovered 37% of the time, 6-20 plants 30% of the time and plants 21% of the time. 12% of clusters fell into less manageable clusters of 100 plants or more. This cluster size has increased by 4% over the previous year. This will continue to be monitored in Size of GHW Populations 8% 4% 21% 37% 1 to 5 6 to to to % Conclusion Through the increase of calls and complaints, it is evident that the public is more aware of the presence of GHW in the Region and therefore education is key to its successful eradication. Education will need to be continued in the upcoming years to inform the current and future residents of the dangers of GHW. Providing more educational programs to the public will create awareness; thus creating the likelihood of reporting GHW. This also combined with collaboration with other municipalities throughout Ontario Page 2 of 12

16 Report: CR-CLK-LIC The GHW Reduction Program will continue in 2012, for its final year. At that time recommendations will be made for the future of the GHW program with plans to merge responsibilities for GHW into the current Area Weed Inspectors role. CORPORATE STRATEGIC PLAN: Focus Area 1: Environmental Sustainability Protect and enhance the environment FINANCIAL IMPLICATIONS: Funding for the three-year program was provided by Regional Council. No change to the program is required at this time. OTHER DEPARTMENT CONSULTATIONS/CONCURRENCE: ITS provided assistance in the development and preparation of the maps and figures included in Appendix A. ATTACHMENTS Appendix A - GHW Clusters by Area Municipalities PREPARED BY: APPROVED BY: Katrina Shaw and Warren Stevenson, Assistant Area Weed Inspectors Oriana Sharp, Manager, Information Management and Archives M. (Marty) Sawdon, Administrator, Licensing and Enforcement Services Kris Fletcher, Director, Council & Administrative Services / Regional Clerk Page 3 of 12

17 Report: CR-CLK-LIC Appendix A - GHW Clusters by Area Municipalities The following figures show the locations of all found Giant Hogweed in the Region. Each municipality is shown to compare between 2010 and Figure 1: Comparison of GHW from 2010 to Page 4 of 12

18 Report: CR-CLK-LIC Figure 2a: Region of Waterloo 2011 Figure 2b: Region of Waterloo Page 5 of 12

19 Report: CR-CLK-LIC Figure 3a: Cambridge 2011 Figure 3b: Cambridge Page 6 of 12

20 Report: CR-CLK-LIC Figure 4a: Kitchener 2011 Figure 4b: Kitchener Page 7 of 12

21 Report: CR-CLK-LIC Figure 5a: North Dumfries 2011 Figure 5b: North Dumfries Page 8 of 12

22 Report: CR-CLK-LIC Figure 6a: Waterloo 2011 Figure 6b: Waterloo Page 9 of 12

23 Report: CR-CLK-LIC Figure 7a: Wellesley 2011 Figure 7b: Wellesley Page 10 of 12

24 Report: CR-CLK-LIC Figure 8a: Wilmot 2011 Figure 8b: Wilmot Page 11 of 12

25 Report: CR-CLK-LIC Figure 9a: Woolwich 2011 Figure 9b: Woolwich Page 12 of 12