Monthly Policy Review

May 1, 2014 PRS Legislative Research  Institute for Policy Research Studies 3 rd Floor, Gandharva Mahavidyalaya  212, Deen Dayal Upadhyaya Marg  New Delhi – 110002 Tel: (011) 43434035-36, 23234801-02  www.prsindia.org Monthly Policy Review April 2014 Highlights of this Issue Inflation increases after three months decline; RBI keeps policy rate unchanged (p. 2) Inflation increased for the first time in three months on account of an increase in food prices. RBI, in its monetary policy review, maintains the policy repo rate at 8%. Government releases Direct Taxes Code 2013 for public comments (p. 2) The Direct Taxes Code 2013 is a revised version of the Direct Taxes Code 2010, incorporating recommendations of the Standing Committee and the Kelkar Committee on Fiscal Consolidation. Supreme Court recognises constitutional rights of transgender persons (p. 4) The Supreme Court has recognized transgender persons as a „third gender‟, and directed the central and state governments to treat them as an educationally and socially backward class. Comments invited on draft minimum standards for various clinical establishments (p. 4) The standards specify matters related to infrastructure, human resource, medical equipment, drugs and bio-medical waste management in all hospitals, laboratories, clinics etc and are applicable in all union territories and some states. Dissolution of Andhra Pradesh assembly approved by President (p. 5) The President approved the dissolution of the AP Assembly and issued a fresh proclamation of central rule. The President‟s rule was proclaimed in March 2014, following the passage of the AP Reorganisation Act, 2014. Supreme Court rejects private telecom operators’ plea against CAG audit (p. 4) The Supreme Court has rejected a petition by private telecom operators challenging the January 2014 Delhi High Court decision, which allowed the Comptroller and Auditor General (CAG) to audit their accounts. Supreme Court allows resumption of iron ore mining in Goa but places cap on output (p. 4) The Supreme Court has lifted its ban on iron ore mining in Goa, subject to an interim annual production limit of 20 million tonnes. The miners will have to obtain fresh mining leases and other approvals to restart production. Comments invited on national strategy for reducing emissions from deforestation (p. 6) The Ministry of Environment and Forests has invited comments on the national strategy for reducing emissions from deforestation and degradation of forests. Standing Committees present reports on the agricultural sector (p. 5 and 6) The Committee presented reports evaluating the Rashtriya Krishi Vikas Yojana, which seeks to provide states with funds to generate growth in agriculture. It also submitted a report on the pricing of agricultural produce. RBI grants in-principal approval for banking licences to two applicants (p. 3) The Reserve Bank of India (RBI) has granted in-principle approval to IDFC Ltd. and Bandhan Financial Services Pvt. Ltd. to set up banks under the Guidelines on Licensing of New Banks in the Private Sector. Monthly Policy Review – April 2014 PRS Legislative Research -2- Macroeconomic Developments Saumya Vaishnava (saumya@prsindia.org) Inflation increases after three months The wholesale price inflation and retail price inflation both increased after three months, due to inflation in food articles, which rose from 8.1% in February to 9.9% in March 2014. Wholesale Price Index (WPI) inflation increased to 5.7% in March from 4.7% in February, while Consumer Price Index (CPI) inflation increased to 9.1% in March from 8.6% in the previous month.1,2 Inflation had decreased for the first time in six months in December 2013 due to softening of food price inflation. RBI keeps policy rates unchanged On April 1, 2014, the Reserve Bank of India (RBI) released its first bi-monthly policy review.3 The following decisions were taken:  Policy rates remain unchanged: RBI maintained the policy repo rate at 8%, stating that inflation remains a concern. RBI reaffirmed its focus on achieving 8% CPI inflation by January 2015 and 6% by January 2016.  Term repos: Term repos of 7-day and 14- day tenure were introduced in October 2013. 4 RBI increased the liquidity provided under term repos from 0.5% to 0.75% of Net Demand and Time Liabilities (NDTL; roughly speaking, all bank deposits) of the banking system. Simultaneously, it reduced the liquidity under overnight repo from 0.5% to 0.25% of NDTL.  Other decisions: The developmental and regulatory decisions taken by RBI in April 2014 are given in Table 1. Table 1: RBI Developmental and Regulatory Policies Committee Action taken by RBI Urjit Patel Committee to revise and strengthen the Monetary Policy Framework Some of the recommendations, such as those relating to the adoption of CPI as key measure of inflation, progressive increase in liquidity provided through term repos, etc. have been accepted Basel III Full implementation of the Basel III Capital Regulations has been postponed to March 31, 2019 from March 31, 2018. Vijay Bhaskar Committee on RBI has advised the FIMMDA and FEDAI to act as administrators of the Financial Benchmarks Indian Rupee Exchange Rate and the foreign exchange benchmarks respectively. They will take the necessary steps to implement the recommendations of the committee. 5 Credit pricing Scheduled Commercial Banks to provide differential interest rates for Micro and Small Enterprises.6 Sources: RBI; PRS. Notes: FIMMDA-Fixed Income Money Market and Derivatives Association of India; FEDAI-Foreign Exchange Dealers „Association of India. Taxation Saumya Vaishnava (saumya@prsindia.org) Government released new draft Direct Taxes Code 2013 The draft Direct Taxes Code, 2013 was released on the Department of Income Tax website for comments on April 1, 2014.7 This is a revised version of the Direct Taxes Code Bill, 2010, which was introduced in Parliament on August 31, 2010, and thereafter, was referred to the Standing Committee on Finance. The Direct Taxes Code proposes to consolidate and amend the laws relating to direct taxes. Consequently, it replaces the Income Tax Act 1961 and the Wealth Tax Act, 1957. The Direct Taxes Code, 2010 (DTC 2010) had proposed to widen tax slabs for individuals, and increase tax on companies. In addition, it had proposed to remove several deductions currently allowed for companies and retain deductions available to individuals. The Bill had also proposed the General Anti-Avoidance Rules (GAAR) to allow tax authorities to classify any arrangement as one entered into for evading taxes. The Bill will lapse with the dissolution of the 15th Lok Sabha. In Direct Taxes Code, 2013 (DTC 2013), various recommendations of the Standing Committee, as well as recommendations of the Kelkar Committee on fiscal consolidation have been incorporated. Some of the changes made in the DTC 2013 are:8  The age of senior citizens is proposed to be relaxed from 65 years in DTC 2010 to 60 years in DTC 2013.  GAAR in the DTC 2010 was discussed as one of the rules regarding avoidance of tax. However, in DTC 2013, more clarity and Monthly Policy Review – April 2014 PRS Legislative Research -3- precision has been brought to the provisions. DTC 2013 includes the applicability of the GAAR, the impermissible avoidance agreements and the treatment of connected person etc. Importantly, the onus of proof is to rest with the tax authority invoking GAAR.  For the purpose of wealth tax determination, DTC 2013 includes all assets as the base for wealth tax. The 2010 version had included only the unproductive assets for the levy of wealth tax.  An additional tax of 10% (over the 15% dividend distribution tax) is proposed to be levied on recipients of dividend exceeding Rs one crore.  A fourth slab for income tax may be introduced. Currently, the highest slab is for incomes in excess of Rs 10 lakh, which is taxed at 30%. The new slab will tax total income in excess of Rs 10 crore at 35%. For a PRS analysis of the DTC Bill 2010, see here. Finance Alok Rawat (alok@prsindia.org) RBI grants in-principal approval for banking licences to two applicants The Reserve Bank of India (RBI) has granted inprinciple approval to IDFC Ltd. and Bandhan Financial Services Pvt. Ltd. to set up banks under the Guidelines on Licensing of New Banks in the Private Sector. 9 RBI had notified the Guidelines and invited applications for licences in February 2013. A High Level Advisory Committee was constituted in October 2013 to screen the applications. These applicants were recommended for grant of in-principle approval by the Committee. RBI also accepted the Committee‟s recommendation that RBI consider the licence application by the Department of Posts separately in consultation with the government. The in-principle approval will be valid for a period of 18 months. The applicants have to meet the requirements under the Guidelines and other stipulated conditions during this period. They will be granted a licence for commencement of banking business once RBI is satisfied that they have complied with the requisite conditions. RBI will use the learnings from current licensing exercise to revise the Guidelines. It hopes to ultimately move to a system where eligible entities can be granted licences on demand. Draft report of the Working Group on pricing of credit The RBI Working Group on pricing of credit (Chairperson: Mr. Anand Sinha) submitted its report on April 10, 2014. 10 RBI had constituted the working group in October 2011 to examine issues related to pricing of floating rate loans. It will accept comments from stakeholders by May 16, 2014. Key observations and recommendations of the working group are:  Base Rate: Each bank periodically sets its Base Rate according to its weighted average cost of deposits. Banks usually price floating rate loans by specifying a fixed spread on the Base Rate. The Group recommended that banks calculate the Base Rate on the basis of marginal cost of funds.  Spread: Banks should have a Board approved policy identifying the factors which determine the spread on a loan. They should also be able demonstrate the rationale behind the pricing policy to RBI.  IBA benchmark: The Indian Banking Association (IBA) could develop an industry-wide benchmark for floating rate products. Banks may offer floating rate loans linked to this benchmark, starting with home loans.  Exit clause: Retail loans should be offered to customers both with and without a reasonably-priced exit option. The exit option should be easily exercisable. IBA should also evolve guidelines for easier and quicker refinancing of loans, particularly mortgages and housing loans. Monthly Policy Review – April 2014 PRS Legislative Research -4- Telecom Alok Rawat (alok@prsindia.org) Supreme Court rejects private telecom operators’ plea against CAG audit The Supreme Court has allowed the Comptroller and Auditor General (CAG) to audit the accounts of private telecom service providers. The service providers had challenged the January 2014 Delhi High Court decision which allowed CAG to audit their accounts.11 For details on the High Court decision, please see here. The audits are for calculation of revenue and determination of licence fees and spectrum charges payable to the government by service providers. Rejecting the service providers‟ petition, the Supreme Court observed that a CAG audit is necessary to ensure that the government gets its share of the revenues generated from public resources. Mining Alok Rawat (alok@prsindia.org) Supreme Court allows resumption of iron ore mining in Goa; places cap on output The Supreme Court has lifted its ban on iron ore mining in Goa, subject to an interim annual production limit of 20 million tonnes. 12 The state government had placed a ban on iron ore mining and transportation in September 2012 due to concerns regarding adverse impact of illegal mining. In the same month, the Union Ministry of Environment and Forests (MoEF) decided to suspend the environmental approvals granted to all mines in Goa. The Court had upheld the ban in its October 2012 order. The iron ore mining concessions awarded by the Portuguese administration in Goa were converted into mining leases under the Mines and Minerals (Development & Regulation) Act, 1957 in 1987. The Court held that these leases expired in 1987 and could have been extended only till 2007. Hence, any mining after 2007 on such leases was illegal. The miners will have to obtain new mining leases from the state government and environmental approvals from MoEF to restart iron ore mining. The Court asked the state government to formulate a policy for award of fresh leases to such miners. It also asked MoEF to notify ecosensitive zones around the national park and wildlife sanctuaries of Goa. A Court-appointed Expert Committee will submit a report on dealing with mining dumps and annual production limit within six months. Health Mandira Kala (mandira@prsindia.org) Comments invited on draft minimum standards for various clinical establishments The Ministry of Health and Family Welfare has invited comments on the draft minimum standards for clinical establishments under the Clinical Establishments (Registration & Regulation) Act, 2010. 13 The Act provides for registration and regulation of all clinical establishments, i.e. hospitals, clinics, other facilities that offer treatment for illness including laboratories that offer pathological and diagnostic services. The Act applies to the four states of Arunachal Pradesh, Himachal Pradesh, Mizoram, Sikkim, all union territories and Uttar Pradesh, Rajasthan and Jharkhand, who have chosen to adopt the law. Under the Act, the National Council for Clinical Establishments is responsible for determining the minimum standards to be followed by these establishments. The draft standards apply to various categories of clinical establishments, such as: (i) hospitals, (ii) dental centres, (iii) laboratories and radiology, imaging and ultrasound centres and, (iv) stem cell laboratories. The standards specify matters related to infrastructure, human resource, medical equipment, drugs and bio-medical waste management in such establishments. The last date for submitting feedback was April 30, 2014. Law and Justice Prianka Rao (prianka@prsindia.org) Supreme Court recognises constitutional rights of transgender persons On April 15, 2014, the Supreme Court passed a judgment that gave legal recognition to transgender persons as a third gender. It also Monthly Policy Review – April 2014 PRS Legislative Research -5- gave directions to safeguard their constitutional rights on the grounds of right to equality and equal protection under Articles 14 and 15 and the right against gender discrimination under Article 16 of the Constitution.14 The Court also directed the central and state governments to take appropriate steps to:  Treat transgender persons as socially and educationally backward classes, and extend reservation in cases of admission to educational institutions and for public appointments;  Operate separate HIV sero-surveillance centres for transgender persons;  Provide adequate medical care to transgender persons in hospitals and ensure separate public toilets and other facilities. The Court noted that an expert committee is already looking into issues related to transgender persons. It stated that the Committee must make recommendations in light of these legal developments. Further, the recommendations of the Committee should be implemented within six months. „Transgender‟ is an umbrella term that describes persons whose gender identity, gender expression or behaviour does not conform to their biological sex. Supreme Court constitutes committee on best practices in public advertisements The Supreme Court has constituted a committee to look into the use of public funds in advertising campaigns of the government and political parties. It has directed the committee to suggest best practices for the regulation of public advertisements, and prevent abuse of public funds in this regard.15 The three member committee, headed by Prof. Madhava Menon, is required to submit its report within three months. The judgment was passed on April 23, 2014 on a Public Interest Litigation (PIL) filed by the NGO Common Cause in 2003. The PIL claimed that the use of public funds for advertising political parties or particular governments was in violation of Articles 14 and 21. Home Affairs Prianka Rao (prianka@prsindia.org) Dissolution of Andhra Pradesh assembly approved by President According to news reports, the President of India gave his approval for dissolution of the Andhra Pradesh Assembly, and for fresh proclamation of central rule, on April 28, 2014. The Union Cabinet had recommended the dissolution on April 25, 2014.16 The state of Andhra Pradesh has been under President‟s rule since March 1, 2014, following the bifurcation of the state and resignation of its Chief Minister. The earlier proclamation of President‟s rule would cease to operate at the end of two months, on April 30, 2014, if not ratified by Parliament. Hence, a fresh proclamation for re-imposition of President‟s rule was sought by the Cabinet. Expert committee on capital for the successor state of Andhra Pradesh An Expert Committee to suggest a capital city for the successor state of Andhra Pradesh has been constituted by the centre. This is in accordance with the provisions of the Andhra Pradesh Reorganisation Act, 2014.17 The Act stipulates that the state of Andhra Pradesh is to be bifurcated into Telangana and the successor state of Andhra Pradesh (Seemandhra). Further, Hyderabad will be the common capital for 10 years, following which it would be the capital of the new state of Telangana. The Act required that a committee to suggest a capital city for the successor state of Andhra Pradesh be constituted by the centre, within 45 days of the Act in force. The five member Committee (Chairperson: K.C. Sivaramakrishnan) is to study various alternatives, consult with stakeholders and present its report by August 31, 2014. Agriculture Sakshi Balani (sakshi@prsindia.org) Standing Committee submits report on pricing of agricultural produce The Standing Committee on Agriculture submitted a report on the pricing of agricultural Monthly Policy Review – April 2014 PRS Legislative Research -6- produce on March 15, 2014.18 The Committee analysed the price policy for agricultural produce, particularly the role of the Commission for Agricultural Costs and Prices (CACP) and its method for calculating the Minimum Support Price (MSP) of 24 crops. The Committee made the following recommendations:  Remunerative pricing of agricultural produce: The Committee noted that CACP does not consider a specific profit margin over the cost of production while calculating the MSP for a crop. It recommended that steps be taken to fix remunerative pricing with a 50% profit margin over the cost of production for all 24 crops without further delay.  Setting of region-wise MSP: The Committee noted that the cost of production of crops varies from region to region even though a uniform MSP is set for the entire country. The Committee recommended fixing a region-wise MSP with appropriate restrictions on an experimental basis.  Avoiding distress sale of produce: The Committee noted that even though MSP is set to ensure that there is no distress sale of produce, there have been reports of distress sale by small and marginal farmers in West Bengal, Odisha, and Bihar. This is due to the lack of proper marketing infrastructure, storage capacity, milling capacity, etc. that adversely affect procurement. It urged state governments to address distress sale by farmers on a priority basis and involve farmers‟ cooperatives and self-help groups in procurement. Standing Committee submits report on evaluation of Rashtriya Krishi Vikas Yojana The Standing Committee on Agriculture submitted a report on its evaluation of the Rashtriya Krishi Vikas Yojana (RKVY) scheme on March 15, 2014.19 RKVY was designed to generate growth and development in agriculture and allied sectors by incentivising states to allocate more on agriculture. The Committee made the following recommendations:  Data regarding yield and investment: The Committee urged the Department of Agriculture and Cooperation (DAC) to furnish data regarding yield gaps in major crops and the quantum of private investment in agriculture and allied sectors at the beginning of the Eleventh Plan. This would help the Committee provide an objective assessment of the achievements under RKVY.  Poor monitoring of RKVY: The Committee noted that there is hardly any monitoring of RKVY at the central level. It recommended that DAC devise a suitable mechanism to ensure that the projects/schemes for which funds are made available to states are monitored and coordinated properly. The DAC should monitor the timely implementation of these projects and ensure that there is no misuse or diversion of funds.  Imbalanced investments under RKVY: According to a study by the National Institute of Rural Development, Hyderabad, states have not been able to balance investments between growth oriented projects and projects for the development of agricultural infrastructure. Infrastructure development was not found to be based on a definite vision or plan. The Committee urged DAC to examine the issues in implementation highlighted in the study and take necessary action. Environment Joyita Ghose (joyita@prsindia.org) Comments invited on the national strategy for reducing emissions from deforestation and forest degradation The Ministry of Environment and Forests (MoEF) has invited comments on the national strategy for Reducing Emissions from Deforestation and Degradation (REDD+). 20 REDD+ is part of the United Nations Framework Convention on Climate Change, an international environment treaty to which India is a signatory. This treaty aims at stabilising levels of greenhouses gases in the atmosphere. REDD+ offers incentives to developing countries to reduce emissions due to deforestation. It also includes measures for the conservation and sustainable management of forests. It is mandated that developing countries willing to undertake REDD+ activities prepare a national strategy. Accordingly, the MoEF constituted an Monthly Policy Review – April 2014 PRS Legislative Research -7- Expert Committee (Chair: Mr. Jagdish Kiswan) to prepare a national strategy for REDD+. Key areas identified for REDD+ implementation by the Committee are establishing a national forest monitoring system, and improving REDD+ governance and stakeholder engagement. A National REDD+ Authority supported by REDD+ cells at the state level will be established. Comments and suggestions on the national strategy are invited till May 27, 2014. The strategy document is available here, and the format for providing comments is available here. Urban Development Joyita Ghose (joyita@prsindia.org) Mission document on National Mission on Sustainable Habitat The Ministry of Urban Development has placed the mission document on the National Mission on Sustainable Habitat (NMSH) in the public domain.21 Key features of NMSH are outlined below. Objectives: The major objective of NMSH is to make habitats more sustainable by improving: (a) energy efficiency in buildings, (b) urban planning, (c) waste management, and (d) public transport. It also seeks to improve the ability of habitats to adapt to climate change. Implementation: NMSH will be implemented through: (a) changes in the legal and regulatory framework, (b) mainstreaming of sustainable development in city planning, and (c) preparing comprehensive mobility plans for improving public transport. Institutional arrangements: NMSH will be headed by an Inter-Ministerial Group which will frame policies for the implementation and monitoring of NMSH. It will be supported by a Mission Implementation and Monitoring Group which will appraise proposals related to NMSH. A Mission Directorate will be established in the Ministry for day to day monitoring. State Level Apex Coordination Committees will be established to review proposals at the state level, supported by nodal agencies. City level committees will be established in urban areas. 1 “Index Numbers of Wholesale Price in India (BASE: 2004- 05=100), Review for the Month of March, 2014”, Press Information Bureau, Ministry of Commerce and Industry, April 15, 2014. 2 “Consumer Price Index Numbers on Base 2010=100 for Rural, Urban and Combined for the Month of March, 2014”, Press Information Bureau, Ministry of Statistics and Programme Implementation, April 15, 2014. 3 First Bi-monthly Monetary Policy Statement, 2014-15 By Dr. Raghuram Rajan, Governor, RBI Press Release, April 1, 2014, http://www.rbi.org.in/scripts/BS_PressReleaseDisplay.aspx?p rid=30911. 4 “Term Repo under Liquidity Adjustment Facility”, RBI Bulletin, October 8, 2013, http://rbi.org.in/scripts/NotificationUser.aspx?Id=8501&Mod e=0#A1. 5 “Financial Benchmarks-Governance Framework for Benchmark Submitters”, RBI notifications, April 16, 2014, http://www.rbi.org.in/scripts/NotificationUser.aspx?Id=8841 &Mode=0. 6 “Differential Rate of Interest for Micro and Small Enterprises”, RBI notifications, April 15, 2014, http://www.rbi.org.in/scripts/NotificationUser.aspx?Id=8840 &Mode=0. 7 The Direct Taxes Code, 2013, http://incometaxindia.gov.in/archive/BreakingNEws_DirectT axesCode2013_31032014.pdf. 8 “Significant changes in the proposed Direct Taxes Code, 2013”, Income Tax Department, April 1, 2014, http://incometaxindia.gov.in/archive/BreakingNews_changes DTC2013_31032014.pdf. 9 “RBI decides to grant “in-principle” approval for banking licences”, Reserve Bank of India, April 2, 2014,http://www.rbi.org.in/scripts/BS_PressReleaseDisplay.a spx?prid=30931. 10 “RBI releases Draft Report on „Working Group on Pricing of Credit‟”, Reserve Bank of India, April 10, 2014,http://www.rbi.org.in/scripts/BS_PressReleaseDisplay.a spx?prid=30984. 11 “Association of Unified Tele ServicesProviders& Othersvs.Union of India”, Civil Appeal No. 4591 of 2014, Supreme Court of India, April 17, 2014,http://judis.nic.in/supremecourt/imgs1.aspx?filename=4 1429. 12 “Goa Foundation vs. Union of India &Ors.”, Supreme Court of India, Writ Petition (Civil) No. 435 of 2012, April 21, 2014, http://hash-cookies.s3.amazonaws.com/2014-04- 21%20-%20SC%20Judgement%20- %20WP%20435%20of%202012%20- %20GF%20in%20Goa%20mining%20case.pdf 13 Comments Invited on Draft Minimum Standards under Clinical Establishments Act. 2010, Ministry of Health and Family Welfare, http://www.clinicalestablishments.nic.in/WriteReadData/414. pdf. 14 National Legal Service Authority vs. Union of India, Civil Original Jurisdiction, Supreme Court of India, Writ petition (civil) No.400 of 2012, Date of Judgment: April 15, 2014, http://judis.nic.in/supremecourt/imgs1.aspx?filename=41411. 15 Common Cause vs. Union of India, Civil Original Jurisdiction, Writ petition (civil) no. 13 of 2003, Date of Judgment: April 23, 2014, http://www.supremecourtofindia.nic.in/outtoday/common%2 0cause.pdf. Monthly Policy Review – April 2014 PRS Legislative Research -8- 16 “President approves dissolution of Andhra Pradesh assembly”, The Mint and Wall Street Journal, April 28, 2014; “President Nod for Dissolution of AP House, Extension of Central Rule”, The New Indian Express, April 29, 2014; “Andhra Pradesh assembly dissolved; President's rule imposed”, Deccan Chronicle, April 29, 2014. 17 “Expert Committee Regarding New Capital for Successor State of Andhra Pradesh Constituted”, Press Information Bureau, Ministry of Home Affairs, April 25, 2014. 18 “Pricing of Agricultural Produce”, Standing Committee on Agriculture, March 15, 2014, http://164.100.47.134/lsscommittee/Agriculture/15_Agricultu re_60.pdf. 19 “Rashtriya Krishi Vikas Yojana – An Evaluation”, Standing Committee on Agriculture, March 15, 2014, http://164.100.47.134/lsscommittee/Agriculture/15_Agricultu re_61.pdf. 20 “Comments on the reference document for REDD+ in India”, Ministry of Environment and Forests, April 28, 2014, http://envfor.nic.in/sites/default/files/Comments%20on%20D raft%20Reference%20Documents.pdf. 21 “National Mission on Sustainable Habitat” Ministry of Urban Development, April 2014, http://www.urbanindia.nic.in/programme/uwss/NMSH.pdf. DISCLAIMER: This document is being furnished to you for your information. You may choose to reproduce or redistribute this report for non-commercial purposes in part or in full to any other person with due acknowledgement of PRS Legislative Research (“PRS”). The opinions expressed herein are entirely those of the author(s). PRS makes every effort to use reliable and comprehensive information, but PRS does not represent that the contents of the report are accurate or complete. PRS is an independent, not-for-profit group. This document has been prepared without regard to the objectives or opinions of those who may receive it.