web viewtrust admin use only: eligible. y / n. attachments. y / n. objectives. y / n. budget. y / n....

25
Waste Less Recycle More Initiative Major Resource Recovery Infrastructure – Round 2 Stage 1 Expression of Interest (Preliminary Business Case) Closing date: 5.00 pm 2 December 2014

Upload: trinhphuc

Post on 06-Mar-2018

217 views

Category:

Documents


5 download

TRANSCRIPT

Page 1: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

Waste Less Recycle More Initiative

Major Resource Recovery Infrastructure – Round 2

Stage 1 Expression of Interest (Preliminary Business Case)

Closing date: 5.00 pm 2 December 2014

Page 2: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

1. Have our transported waste generated in the Regulated Area out of NSW where, at that time, there was a lawful disposal facility for that waste within NSW, where transport commenced on or after 2 December 2014?

Yes or No

If you are a Local Government Council and have answered Yes to the above go to question 2. If you are any other type of organisation and have answered yes to the above, your organisation is not eligible to apply for funding.

2. Do you have a plan to transition away from interstate waste transport and disposal within a set timeframe?

Yes or No

If you have answered Yes to the above the NSW government may consider an exemption from this requirement for NSW local government entities: Local government entities: if you are currently transporting waste out of NSW you may be considered eligible for funding for a Community Recycling Centre grant if you demonstrate a commitment to transitioning away from out of state waste transport and disposal within an acceptable timeframe.

3. Are you applying for this exemption? Yes or No

If you are a local council and are applying for this exemption you must attach your request with evidence demonstrating your commitment and plan to transition away from out of state waste transport signed by the General Manager or CEO with your grant application.

4. Has your organisation purchased any of the equipment/infrastructure prior to the opening of this round for which you are applying for in this application?

Yes or No

If you have answered yes to the above, your organisation is not eligible to apply for funding for that equipment/infrastructure already purchased or any milestones completed.

Organisations that are eligible must also meet the following conditions to qualify for funding:

Answer all questions in the application form

Submit your entire application by email to: [email protected]

Complete and attach the Application Budget (Section E) ensuring that only eligible activities/items have been included.

Complete and attach the Project Plan (Part F) including the design concept plan for the site.

2014 Major Resource Recovery: Part A – Stage 1 EOI Page i

Eligibility

Page 3: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

General information

a. You will need to read the NSW Environmental Trust’s Major Resource Recovery Infrastructure Grants Program ‘Guidelines for Applicants’ to help you fill out this Expression of Interest form.

b. Please answer every question. Where a question does not apply to your application, write ‘not applicable’ or preferably briefly explain why.

c. Grants between: $1,000,000 and $10,000,000

Section A – Registration

Applicant details

A1 Organisation’s details: Individual Application (if alliance or partnership skip to A3)

Name of organisation      

What is your ABN?       Registered for GST Yes or No

Postal address      

Suburb       State       Postcode      

A2 Contact person for this project

Title       First name       Surname      

Position       Daytime phone (0 )      

Mobile (0 )       Email      

A3 Organisation’s details: application by an alliance or partnership

Lead applicant:      

Alliance/partners members (list all)       Registered for GST Yes or No

Postal address      

Suburb       State       Postcode      

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 2

Part A: Expression of Interest Form (Preliminary Business Case)

Page 4: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

Additional partner details (where partnership exists or an alliance with another council/s)

A4 Contact details for partners in the alliance (details of lead council to be completed on page A3)

Partner Name      

Contact Name:       Contact phone:      

Contact Email:      

Postal address      

Suburb       State       Postcode      

Partner Name      

Contact Name:       Contact phone:      

Contact Email:      

Postal address      

Suburb       State       Postcode      

Partner Name      

Contact Name:       Contact Phone:      

Contact Email:      

Postal address      

Suburb       State       Postcode      

Partner Name      

Contact Name       Contact phone:      

Contact Email      

Postal address      

Suburb       State       Postcode      

Administrator details (if applicable, see Guidelines for further details)

A5 Administrator

Name of organisation      

Administrator’s ABN       Registered for GST Yes or No

Postal address      

Suburb       State       Postcode      

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 3

Page 5: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

A6 Contact details for administrator

Title       First name       Surname      

Position       Daytime phone (0 )      

Mobile No.       Email      

A7 Nominate one primary contact for correspondence

Applicant Administrator

Organisational structure and systems

See page 7 of the Guidelines for applicants for the eligibility of your organisation to apply for a grant. Please ensure that your organisation meets the eligibility criteria before submitting your application.

A8 What is the legal status of your organisation? (Select only ONE box)

Local government organisation Regional Organisation of Councils

Other local-government controlled organisation Not-for-profit organisation

Private business/industry Other (please specify below):

     

A9 Does your organisation have formal management systems for quality, environmental management and/or work health and safety?

Management System System in place and internally audited

System in place and independently audited

System in place and independently audited/

certified to ISO9001, ISO1400, OHSAS 18001 or other.

Quality

Environmental management

Work Health and Safety (WHS)

Business Structure (individual applicant or lead organisation of alliance/partnerships)

A10 Management structure      

Name Position title

Details of key individuals

(Attach CV to back of application. CVs are to be no more than 2 pages per person)

           

           

           

           

           

           

Years trading No. of years trading       Years trading under current owner      

Number of employees Full-time employees       Total full-time

equivalent (FTE)      

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 4

Page 6: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

Section B – Project details

B1 Project title (maximum of 68 characters including spaces)

     

B2 Project categoryWhat is it that the project is undertaking? Select only ONE box from the following choices.

Materials recovery facility Processing facility for source separated waste (paper, cardboard, plastics, glass, metals, tyres or wood/timber)

Residual waste treatment (mechanical/biological treatment) Residual waste treatment (energy from waste)

Transfer station Other (please specify below):

     

B3 Type of waste to be processed by the proposed facility (tick relevant boxes)

Municipal waste Commercial and industrial waste

Mixed dry recycling Mixed dry recycling

Separated paper of cardboard Separated paper or cardboard

Separated plastics Separated plastics

Separated glass Separated glass

Separated wood/timber Separated wood/timber

Separated metals Separated metals

Mixed, residual waste Mixed, residual waste

Separated tyres Separated tyres

Other (please specify): Other (please specify):

           

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 5

Page 7: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

B4 Project descriptionPlease describe your Major Resource Recovery Infrastructure project in 100 words or less. The description should address staging of the project, corresponding costs, government funding sought, applicant’s contribution, other source of funding planned, quantities and source of feedstock for processing; plus quantities and markets for the end product(s).Note: This summary will be used for all promotional material relating to the grant. i.e. media, website etc.

     

B5 If the project has been identified in a regional waste strategy and action plan, include the following details.

Name of region      

Document name      

Status of document (e.g. draft or final)      

Priority status of the project      

Brief statement on the need for the project in the context of the regional waste strategy and action plan

     

B6 Project Location (please specify where your project is located).

Name of site:      

Address:      

Town/Suburb:      

Post Code:      

State:      

Main local government area/s      

State electorate/s      

Will your project receive waste primarily from a levy paying region? ** Projects that do not receive waste from a levy paying region will not be eligible for funding.

Please see page 7 of the Guidelines for more information.Yes or No

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 6

Page 8: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

B7

Project milestones and estimated timeframe

MilestoneEstimated completion

date

Funding instalment required

Brief description of activitiesto be undertaken to achieve milestone

Milestone 1:Signed Deed of Agreement       $           

Milestone 2:Detailed project plan       $           

Milestone 3:Facility design and detailed costing complete

      $           

Milestone 4:Planning and investigations complete       $           

Milestone 5:Detailed engineering design, planning and approvals

      $           

Milestone 6:Environment protection licence approved

      $           

Milestone 7:Awarding of tender for construction       $           

Milestone 8:Building and slab construction complete

      $           

Milestone 9:Process equipment and installation complete

      $           

Milestone 10:Electricals, safety and testing successfully completed

      $           

Milestone 11:Commissioning of infrastructure completed

      $           

Milestone 12:Facility commissioned and operational

      $           

Milestone 13:Project completion - submission of final evaluation report

      $           

Please Note:

A report will be required for each Milestone of the project and a Final Evaluation Report at Project Completion.

All grant projects to be completed by 30 June 2017.

Not all milestones may be appropriate for your project. Choose milestones which suit the preferred delivery strategy for your projectAny equipment/infrastructure purchased or milestones completed by 15 September 2014 will not be eligible for funding.

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 7

Page 9: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

B8 Has your organisation previously received Environmental Trust, OEH or EPA funding? Yes or No

If YES, please provide project reference number or name of project/ and amount of grant/s and year/s

     

     

     

     

     

B9 Please provide information as to why this project would not go ahead without external (this) funding? In your explanation, please include the payback period with and without funding and what steps have been undertaken to date.

     

Section C – Regulatory/licencing

C1 Environmental Protection Licensing status of site (tick relevant options)

Site has no Environmental Protection License in place

Site has an existing Environmental Protection License in place but needs amendment to accommodate the proposed Resource Recovery Facility

Site has all Environmental Protection Licensing in place and no further licensing is required

C2 Status of site for proposed resource recovery facility (tick relevant options)

Site identified, to be purchased Also, specify date of purchase      

Site under lease by grant applicant(If so, please give details on lease status, lease term, site owner and any restrictions on capital improvements)

     

Site owned by grant applicant

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 8

Page 10: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

C3 Planning approval status of selected site (tick relevant options)

Site is a greenfield or brownfield site with no planning approvals for a Resource Recovery operation

Site has planning consent for an existing Resource Recovery operation, and planning consent needs to be amended for proposed development

Site is an existing Resource Recovery operation, greenfield or brownfield site and a planning application for the proposed development has already been submitted

Site is a greenfield site and has full planning approval for proposed development

Site is a brownfield site and has full planning approval for proposed development

C4 What Environmental Protection Authority licence/s do you currently hold(Include all licenses held for resource recovery operations you hold in NSW)

     

C5 In the last five years have you, or any alliance/partner organisations received any penalty notices, clean up notices, prevention notices, license suspensions, licence revocations, convictions or prosecutions under NSW environment protection laws including National Parks and Wildlife Act 1974, Protection of the Environment Operations Act 1997 and the Native Vegetation Act 2003?

Yes or No

If you answered yes to the above, please provide details below and what improved processes you have implemented to correct these breaches (attach additional supporting information if needed).

     

C6 Have you contravened any provision of the POEO Act with the result of avoiding, minimising or undermining the requirement to pay any waste contributions required under section 88 of the POEO Act?See Guidelines for more information on relevant sections of the Act and the Regulation.

Yes or No

If you have answered yes to the above, please answer ALL questions below:

The date(s) of the contraventions      

The sections or clauses contravened      

The person or person(s), including the full names of any relevant directors or managers, who contravened the sections or clauses

     

The nature of the contravention      

The waste activities being undertaken at the time of the contravention      

The amount in tonnes and types of waste (including by waste classification) involved      

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 9

Page 11: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

C7 Has any of the applicants transported waste generated in the Regulated Area out of New South Wales for disposal where, at that time, there was a lawful disposal facility for that waste within New South Wales, where that transport commenced on or after 2 December 2014?

Yes or No

If you have answered yes to the above, your organisation is not eligible to apply for funding unless you are a local government and request and are granted an exemption.

C8 Has your organisation already purchased any of the equipment/ infrastructure for which you are applying for in this application? Yes or No

If you have answered yes to the above, your organisation is not eligible to apply for funding.

Section D – Assessment criteria

Criterion 1: Amount diverted

D1 Materials recovered or subject to energy recoveryPlease list the materials you intend to recover identifying any priority materials as detailed in the guidelines.

Material typeProportion of total

recovered for recycling (%)Proportion of total

recovered sent for energy recovery (%)

Municipal Commercialand industrial Municipal Commercial

and industrialMixed dry recycling                        

Separated paper or cardboard                        

Separated plastics                        

Separated glass                        

Separated wood/timber                        

Separated metals                        

Mixed, residual municipal waste                        

Separated tyres                        

Other (Please specify):                        

D2 Quantity of waste diverted – municipal waste stream(include table as an attachment with tonnes over 10 FYs 2014/15 to 2024/25)*

Municipalwaste stream

Tonnes per annum

Mixed dry

recycling

Paper/cardboard Plastics Glass Wood/

timber MetalsMixed

residual waste

TyresOther

(Please specify)

Resource recovery capacity of the new facility

                                                     

Estimated quantity of waste diverted 6 months after commissioning

                                                     

Estimated quantity of waste diverted two years after commissioning

                                                     

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 10

Page 12: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

D3 Quantity of waste diverted – Commercial and industrial waste stream(include table as an attachment with tonnes over 10 FYs 2014/15 to 2024/25)*

Commercial and industrial waste

stream

Tonnes per annum

Mixed dry recycling

Paper/cardboard Plastics Glass Wood/

timber MetalsMixed

residual waste

TyresOther

(Please specify)

Resource recovery capacity of the new facility

                                                     

Estimated quantity of waste diverted six months after commissioning

                                                     

Estimated quantity of waste diverted two years after commissioning

                                                     

Criterion 2: Market analysis

Note: There are two markets, one for supply of waste and one for demand for the recovered resource.

D4 Please provide information on the expected supply of the source material? Who do you expect to obtain the waste from (provide a list if more than one) How much from each supplier or supplier type? Where does their waste currently go? What gate fee do you expect them to pay? ($/tonne)? Why will they use your new site/service at this rate?

     

D5 Describe the competition that currently exists in the market for the source material that you propose to accept.

     

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 11

Page 13: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

D6 Please provide information on the expected demand for your end product? Who do you expect will buy the additional resources or energy recovered? How much for each buyer or buyer type? What products/services are you replacing? What are the resource recovery exemption(s)*, standards and/or specifications you plan to meet? What do you expect to sell the recovered waste or recovered energy for ($/tonne of product; or $/kw of

energy recovered and exported to grid) Why will they buy your new product/service at this rate? Identify market destination – local, interstate or export

No. Product description Tonnageper annum

Product application

Status of regulatory compliance

1                        

2                        

3                        

4                        

5                        

* Under Clause 51 and 51A of the Protection of the Environment (Waste) Regulation 2005, compliance with a Resource Recovery Exemption is required in order for a waste to be lawfully used on land or as a fuel.

D7 Considering the last three years, trend prices for the target recovered resource are:Select only ONE from the following choices.

Increasing Decreasing

Stable Fluctuating

Recovered resources of this type have not been marketed for three years or longer Other      

Criterion 3: Technical analysis

D8 Describe the process of your proposed resource recovery facility including: Recycling performance (type and capacity)? Types of materials processed and efficiency?

     

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 12

Page 14: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

D9 Describe, based on the market analysis done, what infrastructure is needed to establish your resource recovery facility? What is the selected technology/process? How mature is the technology/process? Are there any reference sites where the technology/process is currently in use?

     

D10 What analysis has been undertaken of the infrastructure and/or processes to make your selection including: How suitable is the technology/process to the targeted waste and waste stream? How suitable is the technology/process for the location? Operational performance – including any Workplace Health & Safety considerations? Environmental performance?

     

Criterion 4: Cost benefits analysis

D11 Please provide a detailed cost benefit analysis of the project (attach documents as necessary). At a minimum, your analysis must: Identify all costs (capital, operating, maintenance, provision for contingencies) Identify the benefits (e.g. avoided costs, savings, revenue from sale of recovered materials) Assess net benefits (using the discounted stream of costs and benefits based on NSW Treasury

Guidelines*), and include data on: net present value with and without grant funding benefit cost ratio internal rate of return (percentage) dollars of grant funding per tonne of additional material recycled

Sensitivity testing (analyse option under different scenarios and discount rates) Document all references to data sources and assumptions

* See page 10 of the Guidelines for applicants for information on preparing a cost benefit analysis.

     

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 13

Page 15: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

D12 What is the operational life-span of the facility? Outline any staging of infrastructure Asset Management Strategy and plans developed     

Criterion 5: Planning and environment protection licensing

D13 Describe what consultation has been done with your planning consent authority, including any planning, site environmental or engineering investigations have been undertaken.(For example: council or Department of Planning and Infrastructure)

     

D14 If planning consent is required, what planning approvals are needed and what are the likely timeframes for consent?

     

D15 Describe what consultation has been done with the EPA in relation to the licensing of the new facility?

     

Name of EPAofficer consulted:

      Date EPA officer consulted:      

D16 Does your project involve energy from waste technology?

Yes - go to Question D17

No - go to question D18

D17 What investigations have been performed to ensure your energy from waste project will comply with the NSW EPA’s Energy from Waste Policy?

     

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 14

Page 16: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

Criterion 6: Project impacts

D18 It is expected that the project will implement best practice in sustainability, please detail how you intend to achieve this?

     

D19 What will be the key environmental benefits generated by the project and when will these be realised and for how long?

     

D20 What social benefits (e.g. strengthened communities, jobs for disadvantaged people) will be generated by the project and when will these be realised and for how long?

     

D21 What economic benefits (e.g. new jobs, new products, new markets) will be generated by the project and when will these be realised and for how long?

     

Section E – Milestones and budget

Criterion 7: Value for money

This will be determined using the information provided in Section E – Milestones and Budget. Applicants that are willing to contribute more will be favoured in the EOI assessment process.

This part of the application form is a separate Excel document and can be downloaded from the website.

This form must be completed and submitted with the application form together with other required attachments. Form must be submitted in EXCEL format. Do not PDF.

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 15

Page 17: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

Section F – Project planning, including risk assessment

This part of the application form is a separate Word document and can be downloaded from the website.

This form must be completed and submitted with the application form and other required attachments.

Section G – Authorisations

G1 Please declare any real, potential or perceived conflict of interest that you may be aware of.This can relate to land ownership, salary and/or contractor payments (see page 18 of the Guidelines).

     

Applicant Include the names of two office-bearers in your organisation (e.g. General Manager, Chief Executive Officer or Executive Officer) who are able to attest to the accuracy of the information within the application.

What happens if I supply false or misleading information?Applicants must certify by signature that all of the information in the application is true and correct. Please

note that if applicants supply information as part of the application that is false or misleading in a material particular, the application will not be considered OR, if the grant is made and it is discovered that information supplied was false or misleading in a material particular, the grant will be revoked and funds, plus interest, must be repaid.

Name      

Title/position      

Organisation      

E-mail      

Phone no (0 )      

Date      

Name      

Title/position      

Organisation      

E-mail      

Phone no (0 )      

Date      

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 16

Page 18: Web viewTrust Admin Use Only: Eligible. Y / N. Attachments. Y / N. Objectives. Y / N. Budget. Y / N. Reference. 2013 /CRC / 2014 Improved Systems for Household

Section H – inquiries

Street Address

NSW Environmental TrustMacquarie TowerLevel 610 Valentine AvenuePARRAMATTA NSW 2150

Telephone: (02) 8837 6093

Email: [email protected]

Section I – Submission details

Use the following checklist to make sure that your application is complete and accurately represents your project. You should read the Guidelines for applicants, particularly those sections covering the objectives of the program, eligibility, assessment criteria and GST.

Grant application check list

Answer all questions in the application form.

Submit your entire application by ONE of the methods below. (i.e. DO NOT Email AND post). Email is the preferred option.Type only in the spaces provided in the application form. The boxes provided for answers to questions are a set size; the boxes will not expand to accommodate additional text if you continue to type beyond the bottom of the text box. Please ensure answers to questions are fully contained within the limits of the text boxes.Complete the Application form, answering all required questions.Compete and submit Section E - Milestone and Budget spreadsheet.Complete and submit Section F - Project plan.Have your application authorised by the appropriately authorised person.Attach all required supporting information (e.g. quantity of waste diverted (10 year), financial analysis).Do Not Fax any part of your application.Submit your application form and all other documents by the closing date – 5.00 pm 2 December 2014.

Email to: [email protected]

Email subject line must use this format.Organisation Name – MRR Application. Only one application per email. If more than one being submitted number accordingly, ie 1. 2 etc. after the word Application.

Please email the application form as a Word document and the budget spreadsheet as an Excel document - DO NOT PDF. Attachments can be emailed as Word, Excel or PDF documents.

Ensure you email your entire application, including all attachment.

NB: Emailed applications must not be larger than 10MB including all attachments.

Post to:NSW Environmental TrustPO Box 644PARRAMATTA NSW 2124

Please submit all your forms and supporting documents on a USB. Hardcopies will not be accepted.

Any application that is late, incomplete or ineligible will not be considered.Published by the NSW Environmental Trust, PO Box 644, Parramatta 2124 Phone: 02 8837 6093 Fax: 02 8837 6099

Email: [email protected] Website: www.environment.nsw.gov.au 2014/0705 September 2014

2014 Major Resource Recovery: Part A – Stage 1 EOI Page 17