Multi-Family Recycling Discussion Paper

UE2011-06 ATTACHMENT 2 The City of Calgary Multi-Family Recycling Discussion Paper February 2011.docx ISC: UNRESTRICTED

Table of Contents Residential Recycling in Calgary... 1 Notice of Motion NM2008-25... 1 Notice of Motion NM2010-45... 1 Residential Recycling Project Work Related to Multi-Family Recycling... 1 The Multi-Family Residential Sector... 2 Multi-Family Recycling Compared to Single Family Recycling... 2 Existing Multi-Family Recycling Opportunities... 3 Community Recycling Depots (CRDs)... 3 Private Recyclers... 4 City Collection... 4 Drop Off Location for Private Recyclers Servicing the Multi-Family Residential Sector... 4 Access to the Materials Recovery Facility (MRF) for Private Recyclers... 5 Land Use Bylaw Requirement for Multi-Family Recycling Facilities... 5 Waste and Recycling Bylaw Requirements for Multi-Family Recycling... 6 Existing Challenges and Barriers with Multi-Family Recycling... 6 Multi-Family Recycling in Other Municipalities... 7 Multi-Family Recycling Strategies... 8 Optional Program Predominantly Serviced by the Private Sector... 9 Mandatory Recycling Charge for All Multi-Family Dwellings... 10 Other Opportunities for Consideration... 11 Engagement... 11 Recommended Strategy... 11 Next Steps... 11 Table 1 Breakdown of Residential Dwellings in Calgary... 2 Table 2 Summary of Multi-Family Recycling Programs in Other Municipalities... 7 Table 3 Comparison of Multi-Family Recycling Strategies... 8 Figure 1 Single Family Waste Composition... 3 Figure 2 Multi-Family Waste Composition... 3 ISC: UNRESTRICTED

Residential Recycling in Calgary Residential recycling in Calgary has advanced over the years, most recently with the introduction of Blue Cart recycling. Prior to Blue Cart recycling, The City operated about 50 community recycling depots (CRDs) for source-separated recyclable materials. In 2008, approximately 41,000 tonnes of recyclables were collected from the CRDs. Blue Cart recycling was introduced in 2009 to single family homes, providing convenient curbside collection of co-mingled recyclable materials. At the same time, the CRDs were converted to accept the same co-mingled materials as the Blue Cart program. In 2010, Calgarians recycled 70,000 tonnes of material, representing a 70 percent increase in the amount of materials recycled before the Blue Cart program. Notice of Motion NM2008-25 On 2008 May 12 Council approved Notice of Motion NM2008-25 related to multi-family recycling. This Notice of Motion directed: 1. That Administration attempt to ensure various sizes of collection vehicles will be able to access and utilize the sorting and processing facility currently being built in the Southeast quadrant of the City, and 2. That The City of Calgary will not undertake collection of recyclables from multifamily residences prior to 2020 provided The City is on track in achieving its targets to divert 80 percent of its waste from landfills by 2020. As a result of NM2008-25, Blue Cart recycling is currently not provided to multi-residential complexes by The City. The contract for sorting and processing of recyclables was awarded prior to NM2008-25. This facility is privately owned and operated. Notice of Motion NM2010-45 On 2010 December 13 Council directed Administration through NM2010-45 to report no later than 2011 February through the Standing Policy Committee on Utilities and Environment on progress toward the 80/20 by 2020 waste diversion goal in the residential sector, including opportunities for multi-family residential recycling. Further, the report is to include an estimate of both the Operating and Capital cost expenditure required, and potential savings, to implement the potential new initiatives. This discussion paper is in response to NM2010-45. Residential Recycling Project Work Related To Multi-Family Recycling Waste & Recycling Services (WRS) undertook the following work in 2010 related to multi-family recycling. Outcomes of this work are referenced throughout this report. A detailed residential waste composition study was conducted including both the single family and multi-family sectors. A survey was conducted of several municipalities throughout North America regarding their multifamily recycling programs. A CRD usage survey was conducted to identify the types of users and materials being brought to the depots. ISC: UNRESTRICTED Page 1 of 12

Initial engagement began with some of the private recyclers servicing the multi-family sector. The Multi-Family Residential Sector The multi-family residential sector is comprised of a variety of housing types ranging from higher density apartments to lower density structures that are part of a multi-family complex. Because of this, it is difficult to find a consistent definition for the multi-family sector. For example, Calgary Census provides statistics based on structure type alone, and does not consider how the dwellings are grouped within a development. The Land Use Bylaw 1P2007 defines a multi-residential development as a development that consists of one or more buildings, each containing one or more units and has a minimum of three units. The Waste and Recycling Bylaw 20M2001 defines a multi-residential complex as a group of more than four dwelling units that share a common parcel of land; or share a private roadway that provides access to the dwelling units. For the purposes of this report and in the context of multi-family recycling, dwellings that do not receive Blue Cart recycling service are considered multi-family. Based on 2010 census data and Blue Cart customer data, the number of multi-family residential dwellings is estimated to be 158,000, as shown in Table 1. This represents about 35 percent of all residential housing. On a tonnage basis, multi-family residential waste is estimated to make up approximately 12-13 percent of all waste going for landfill disposal in Calgary (80,000 85,000 tonnes out of 650,000 tonnes total). This tonnage is a best estimate based on limited waste generation data for the multi-family sector. Table 1 Breakdown of Residential Dwellings in Calgary Number of Dwellings Percent of all Dwellings Total residential dwellings in Calgary (2010 Calgary 445,000 100 Census) Single family residential dwellings receiving Blue Cart 287,000 65 recycling service (single family up to and including fourplexes that are not part of a multi-residential complex) Remaining multi-family residential dwellings (mixture of high density apartments to lower density dwellings that are part of a multi-residential complex) 158,000 35 The estimated 158,000 multi-family dwellings are split between owner occupied/condominiums and rental units, and as mentioned above have varying density and configurations of housing. There is a corresponding wide variation of serviceability for collection of garbage and recycling from these dwellings, ranging from centralized front end loader collection to door-to-door hand or black cart collection. Multi-Family Recycling Compared to Single Family Recycling The extent of multi-family recycling is difficult to accurately measure compared to single family recycling. This is because the multi-family sector is serviced predominantly by the private sector for both garbage and recycling, and data on tonnages are not readily available. Similarly limited data is available on the number of multi-family households receiving recycling service. Based on preliminary discussions with some private recyclers, it is estimated that 20 to 50 percent of the multi-family sector has some form of recycling service. This ranges from mixed paper or cardboard only, to multiple source-separated materials and co-mingled collection. ISC: UNRESTRICTED Page 2 of 12

Results of a waste composition study conducted in 2010 are provided in Figures 1 and 2, comparing the single family and multi-family residential sectors. Approximately 22 percent by weight of garbage from the multi-family sector is recyclable material that would be acceptable in the Blue Cart or CRD programs. This is compared to 11 percent by weight for single family garbage, with the Blue Cart program in place. Based on best estimates of the total amount of garbage disposed of by the multi-family sector, approximately 18,000 tonnes of recyclables are currently being disposed of that could be diverted from landfill. Most of this material is comprised of paper products such as newspaper, cardboard, box board and mixed paper. Figure 1 Single Family Waste Composition (by weight) Figure 2 Multi-Family Waste Composition (by weight) Recyclables 11% Other 32% Other 40% Recyclables 22% Food and Yard waste 57% Food and Yard waste 38% Existing Multi-family Recycling Opportunities There are a number of recycling opportunities currently available to the multi-family residential sector. These are summarized below. Community Recycling Depots (CRDs) WRS operates 52 CRDs. They are located at convenient locations such as shopping malls, community centres, parks or other recreational facilities. In 2009, the CRDs were converted to accept the same comingled material that is collected in the Blue Cart recycling program. A CRD usage survey conducted by WRS in 2010 showed that 93 percent of CRD users are residential and seven percent are commercial businesses. Of the residential users, about 57 percent are from the multi-family sector. About 43 percent of CRD users are single family residents dropping off excess or oversize recyclables that cannot be accommodated with their blue cart. In 2010, approximately 11,000 ISC: UNRESTRICTED Page 3 of 12

tonnes of material was recycled from the CRDs. Some private recyclers servicing the multi-family sector are using the CRDs. WRS services the CRDs daily and transports the recyclables to the materials recovery facility (MRF) for sorting and processing. The City receives revenue from the sale of recyclable materials from the CRDs. The net cost to operate the CRDs is about $4 million per year which includes: set up and maintenance of the depots, daily servicing, transportation, and MRF processing costs. There are a number of challenges associated with operating the CRDs, such as illegal dumping of garbage, oversize items like furniture and mattresses, and household hazardous waste. Recently some of the depots have become overloaded with material, and bagged recyclables are being left on top of or beside the depot bins. This has led to concerns by some of the depot hosts, customers and collection staff. An additional challenge is that The City is paying for the transportation and processing at the MRF for recyclables dropped off by private recyclers. Private Recyclers Initial research indicates there may be as many as thirty private recycling companies in Calgary that could have multi-family customers, and that this business is growing. Discussions with some of the private recyclers indicate there is a wide range of customized collection service provided to the multi-family sector. For example, collection may be co-mingled or source separated, centralized or door-to-door, in bags, boxes or from front end loader bins. The cost for collection service is negotiated between the customer and the private recycler. Some recyclable materials collected by private recyclers are taken directly to market for revenue, while some is deposited in the CRDs. More extensive engagement is required with private recyclers to determine the extent to which the multifamily sector is serviced, the type of service provided and materials collected, and opportunities and barriers to multi-family recycling in Calgary. City Collection WRS provides collection of mixed paper in front end loader bins from approximately 75 multi-family developments, representing 7,700 dwellings. This service was in place prior to NM2008-25, and was only offered to existing waste customers. WRS is not accepting any new customers for mixed paper recycling. WRS continues to receive requests for recycling service from multi-family residents. Drop off Location for Private Recyclers Servicing the Multi-Family Residential Sector WRS recognizes there are challenges for private recyclers using the CRDs; in particular, difficulty unloading materials by hand and the depot bins being full. WRS is also experiencing challenges at some of the CRDs with overloading and excess materials outside the depot bins. As a result, WRS is working with private recyclers to alleviate concerns at the CRDs and address their operational needs. Starting in 2011, WRS is operating a temporary drop off location specifically for private recyclers servicing the multi-family sector. This drop off is located at the Shepard Landfill Throw n Go area. Private recyclers can apply for access to this drop off location and are charged a fee of $32/tonne to drop off materials. The charge covers the cost of operating the drop off location and transferring materials to the MRF. It does not cover the cost of processing the recyclables at the MRF. Approximately thirty private recycling companies were informed of this opportunity in December 2010. Two information sessions were also held in December to answer questions and address concerns; three ISC: UNRESTRICTED Page 4 of 12

private recycling companies attended these sessions. Currently, the designated drop off location is being used by two private recycling companies. Access to the Materials Recovery Facility (MRF) for Private Recyclers The MRF is privately owned and operated by Cascades Recovery Inc., who sets requirements for access to the MRF and processing fees. There is access to the MRF for some private recyclers, for material that is not co-mingled. This material is mainly mixed paper, with small amounts of bagged plastics, and comes mostly from the commercial sector. The MRF receives 60,000 to 70,000 tonnes of source separated material per year, in addition to The City s 70,000 tonnes of co-mingled material. For safety reasons and to maintain traffic flow, loads delivered to the MRF must come in vehicles that are capable of backing onto the tip floor area and dumping the load hydraulically. No unloading by hand is permitted. This limits access to the MRF by smaller private recyclers that typically use vehicles that are loaded and unloaded by hand. The MRF is currently not accepting co-mingled material from private recyclers. Some of the challenges and concerns with allowing multiple haulers access for co-mingled material include accountability for contamination, and impacts on the processing equipment. Based on discussions with Cascades Recovery Inc. and their experience across Canada, the multi-family sector typically has higher levels of contamination than the single family sector. There is a significant cost to process co-mingled recyclables at the MRF, which varies depending on the type and quantity of material, and level of contamination. Processing costs are negotiated between the processor and the collector. Some private recyclers are not interested in collecting co-mingled materials and bringing it to the MRF as they do not want to incur the processing costs, and prefer to receive revenue directly from the recycling markets for their materials. Land Use Bylaw Requirement for Multi-Family Recycling Facilities Land Use Bylaw 1P2007, Part 6, Section 567 states that Recycling facilities must be provided for every Multi-Residential Development. Part 7, Section 698 has similar provisions for recycling facilities for commercial developments containing dwelling units. The intent of these provisions is to ensure that new multi-residential developments, or developments requiring a development permit, have allocated space for waste and recycling services. According to the design guidelines for development permits, applicants are required to indicate on the development drawings that there is sufficient space allocated for waste and recycling facilities. There are a number of limitations associated with the current provision in the Land Use Bylaw and its application with respect to current recycling opportunities. It only applies to new developments or developments requiring a development permit and does not apply to existing multi-residential developments. It does not specify the extent of recycling facilities to be provided. It does not specify a requirement for signage for recycling, and does not require that the recycling facilities be used and serviced. Waste and Recycling Bylaw Requirements for Multi-Family Recycling There are no provisions in Waste and Recycling Bylaw 20M2001 requiring recycling facilities or service for multi-family developments. Section 42.2 of the bylaw specifically excludes multi-residential complexes from receiving residential recycling service by The City, to comply with Notice of Motion NM2008-25. ISC: UNRESTRICTED Page 5 of 12

Section 42.1 specifies that only acceptable materials can be dropped off at the CRDs and that no material can be deposited outside of the bins provided. The Waste and Recycling Bylaw does not specify who can and cannot use the CRDs, although they were originally intended for residents. Existing Challenges and Barriers with Multi-Family Recycling While recycling opportunities exist for the multi-family sector, there are a number of challenges and barriers that may exist including: Multi-family residents and developments not willing or unable to get to a CRD (for example, no vehicle) do not want to pay for recycling service difficulty getting condominium or homeowner association, or tenants, to agree to have recycling and pay for service space limitations or additional cost to accommodate recycling facilities wide variation in collection method required, depending on the configuration and density of the multi-family development Private recyclers MRF CRDs Other looking for clarification of future direction for multi-family recycling in Calgary before expanding their operations differing levels of service ranging from collection only, to full service including processing or delivery to the end recycling market processing cost a financial barrier to collection of co-mingled recyclables; customers may be unwilling to pay additional fees for processing desire for a level playing field to remain competitive currently no access to the MRF for co-mingled material except for The City the MRF is privately owned and operated and The City does not control access to the facility not designed for commercial use used by some private recyclers and The City incurs the cost to transport and process the material; The City receives some revenue from the sale of recyclable materials, however, the costs outweigh the revenue generated. some are overloaded with recyclables and excess material is being left outside the depot bins, causing concerns for The City, our depot hosts, the public and some private recyclers. There is disparity between single family and multi-family recycling service. Single family residents receive Blue Cart recycling and there is a mandatory monthly recycling charge. Recycling is optional for multi-family residents and there is no monthly recycling charge. ISC: UNRESTRICTED Page 6 of 12

Multi-Family Recycling in Other Municipalities In 2010, WRS conducted a review of multi-family recycling programs in several municipalities in North America. A summary of this review is provided in Table 2. As shown, the approach to multi-family recycling varies widely in whether or not the program is optional or mandatory, how the recyclables are collected (private versus public), and whether or not there is a program charge. WRS will be conducting more extensive research into multi-family recycling programs in other municipalities to identify opportunities relevant to Calgary. For example, more detailed information will be collected on the following: program capital and operating costs; recyclable materials collected; source separated or comingled; quality of material collected; types of housing units serviced and method of collection; and, level of participation and diversion. Municipality Calgary Table 2 Summary of Multi-Family Recycling Programs in Other Municipalities Bylaw Requirement Mandatory Charge Mandatory Participation Collection Serviced by Mostly Private; some City Edmonton City & Private Other Diversion Tactics Vancouver City & Private Landfill Restrictions Halifax Private (Contracted) Winnipeg Private Toronto City & Private Recycling offered at no additional cost Victoria Private Landfill Restrictions Guelph City & Private Provincial mandate Portland Private Milwaukee Private San Diego City & Private San Jose Private Phoenix City & Private State mandates; Landfill Restrictions Recycling offered at no additional cost ISC: UNRESTRICTED Page 7 of 12

Multi-Family Recycling Strategies There is a continuum of possible multi-family recycling strategies involving optional and mandatory programs. Table 3 provides a comparison of strategies at either end of the continuum. These are described in more detail below. Table 3 Comparison of Multi-Family Recycling Strategies Features Potential Advantages Potential Disadvantages Cost Implications Optional program predominantly serviced by the private sector Optional program Current situation for multi-family recycling Service predominantly by private sector City collection limited to mixed paper for existing customers CRDs available at no charge to multifamily residents CRDs available for use by private recyclers Private recycling available on a fee for service basis Choice for multi-family residents Range of recycling service available Business opportunities for private sector Limited recycling by multi-family residents not willing to pay for service or use the CRDs Disparity between single family and multifamily recycling programs No additional capital or operating costs to The City City continues to pay processing cost for multi-family recyclables Mandatory recycling charge for all multi-family dwellings Mandatory recycling charge for all multi-family dwellings; monthly charge on utility bill The City oversees and administers the program Collection service by both the private sector and The City The City administers collection contracts CRDs available for use by multi-family residents Private recyclers have access to the MRF or a designated drop off location Increased multi-family recycling as charge is mandatory and collection service guaranteed Equity between single family recycling and multi-family recycling Business opportunities for private sector Program self-funded from the monthly program charge A limited number of private collection contracts would be awarded Some multi-family residents will not want to pay a monthly charge All costs covered by monthly program charge No additional capital cost to The City, except for construction of a permanent drop off location for private recyclers unable to use the MRF One time operating costs to develop and implement the program; funded from the monthly program charge Ongoing additional operating costs to sustain the program; funded from the monthly program charge Operational savings if the number of CRDs is reduced The processing cost for multi-family co-mingled material is built into the monthly charge Multi-family developments may incur additional capital costs to accommodate recycling facilities Potential cost savings in garbage collection for multi-family developments ISC: UNRESTRICTED Page 8 of 12

Optional Program Predominantly Serviced by the Private Sector This strategy represents the current situation for multi-family recycling service, where multi-family residents have the option to use the CRDs at no charge or to hire a private recycling company on a fee for service basis. Potential advantages to this strategy include: choice for multi-family residents; range of recycling service available; and, business opportunities for the private sector. Potential disadvantages to this strategy include: limited recycling by multi-family residents not willing to pay for recycling service or use the CRDs; and, continued disparity between single family and multi-family recycling. The City s responsibilities with this strategy include: promote recycling to the multi-family sector through communications and public education; continue to operate the CRDs; work with the MRF to explore opportunities to improve access for private recycling companies who are willing to pay for co-mingled processing and who meet MRF access and unloading requirements; continue to provide mixed paper recycling to multi-family customers that received this service according to agreements in place before NM2008-25; continue to operate a drop off location for co-mingled material from private recyclers servicing the multi-family sector to alleviate problems at the CRDs and allow for quicker unloading by hand; monitor and enforce existing requirements at the CRDs (e.g. only acceptable materials inside the bins provided); continue to pay the co-mingled recycling processing fee for materials dropped off by private recyclers servicing the multi-family sector; and, conduct more extensive research and engagement with multi-family residents, private recyclers and property managers to determine the extent of multi-family recycling in Calgary and identify opportunities and barriers to increased recycling. There are no additional capital costs for The City with this strategy. The costs for communication, public education and engagement are within the current operating budget. With this strategy, The City continues to incur the processing fee for multi-family recyclables dropped off at the CRDs and the designated drop off location at the Shepard Landfill. This cost varies depending on the quantity of recyclables deposited in the CRDs and the net processing cost at the MRF. Multi-family residential developments may incur additional operating cost for recycling service; however, this could be partially offset with a corresponding decrease in garbage collection costs. ISC: UNRESTRICTED Page 9 of 12

Mandatory Recycling Charge for All Multi-Family Dwellings This strategy would include a mandatory recycling charge for all multi-family dwellings, and The City would ensure that recycling service is provided. The multi-family recycling charge would be a monthly charge on the resident s utility bill, similar to the Blue Cart recycling charge for single family residents. All multi-family dwellings would pay a monthly recycling charge, which would likely be less than the Blue Cart recycling charge, as the multi-family sector generates less recyclables per household than the single family sector. Collection service could be provided entirely by the private sector or a combination of The City and the private sector. Multi-family residents could continue to use the CRDs. Potential advantages of this strategy include: increase in multi-family recycling with a mandatory charge and guaranteed collection service; equity between the single family and multi-family sectors as both pay a mandatory charge and receive recycling service; the program would be self-funded from the monthly recycling charge similar to the Blue Cart program; and, business opportunities for the private sector. Potential disadvantages of this strategy include: a limited number of collection contracts would be issued to the private sector; and, some multi-family residents will not want to pay the monthly recycling charge. The City s responsibilities with this strategy would include: conduct more extensive research and engagement with multi-family residents, private recyclers and property managers to develop the structure and framework for a mandatory multi-family recycling program; oversee and administer a multi-family recycling program; amend the Waste & Recycling Bylaw to require a monthly recycling charge for multi-family dwellings; explore requirements for mandatory recycling facilities through the Land Use Bylaw ensure all multi-family dwellings are provided with access to recycling service; administer contracts with the private sector for collection of multi-family recyclables; promote recycling to the multi-family sector through communications and public education; negotiate with the MRF to allow private recycling companies access to the MRF; operate a drop off location to accommodate private recyclers unable to meet accessibility requirements at the MRF; and, continue to operate the CRDs. Additional capital costs for The City with this strategy may include the construction of a permanent drop off location for private recyclers unable to meet accessibility requirements at the MRF. There would be additional operating costs to develop and implement a mandatory multi-family recycling program. This would include additional resources to coordinate the multi-family customer addressing and billing; review of multi-family developments to assess recycling collection service; issue a collection Request for Proposal, review proposals and award collection contracts; and communications and public education with the multi-family sector. ISC: UNRESTRICTED Page 10 of 12

Depending on who provides collection service, there would be additional ongoing operating costs with a mandatory multi-family recycling program including resources to administer collection contracts; monitor and assess collection services; maintain correct customer list and billing information; and, customer service and communications. There could be some operational savings if the number of CRDs was reduced. All program costs would be covered by the monthly charge paid by multi-family residents. Multi-family residential developments may incur additional capital costs if structural changes are required to accommodate recycling facilities. This could be partially offset by a corresponding decrease in garbage collection costs. Other Opportunities for Consideration Other opportunities to encourage multi-family recycling in Calgary include the following: The City could discourage landfill disposal of readily recyclable materials. Materials could be banned from landfill disposal or be added to the list of designated materials, which are charged a higher rate for disposal. This strategy provides a financial disincentive to landfilling and financial incentive to recycling. Engagement WRS plans to undertake engagement with stakeholders interested in multi-family recycling including but not limited to multi-family residents, private recyclers, property management companies and associations, and the MRF operator. The purpose of this engagement is to better understand the following: current extent of recycling in the multi-family sector; current barriers and opportunities for multi-family recycling; desire for recycling service and willingness to pay; preference for type of service; preference for source separated or co-mingled recycling; and, ability to receive private collectors and process multi-family recyclables at the MRF. Recommended Strategy In the short term, WRS recommends an optional program serviced predominantly by private recyclers. This strategy is consistent with previous Council direction (NM2008-25) and there appears to be growing opportunities for multi-family recycling in Calgary. At the same time there is a need to better understand and address current barriers, and better measure the extent of recycling within the multi-family sector. Next Steps WRS proposes to take the following next steps in conjunction with this strategy: engage multi-family stakeholders including residents, private recyclers and property management companies and associations; this will start in 2011 and continue into the 2012-2014 business cycle; work with the MRF operator to explore opportunities to improve access by private recyclers, within their operational and safety limitations; ISC: UNRESTRICTED Page 11 of 12

work with private recyclers to promote multi-family recycling and alleviate operational concerns at the CRDs; continue to operate the temporary drop off location at the Shepard Landfill for private recyclers servicing the multi-family sector; continue to promote multi-family recycling through communication and education; conduct more extensive research of multi-family recycling programs in other municipalities to identify opportunities relevant to Calgary; continue to monitor multi-family recycling opportunities, barriers, and participation; monitor the CRDs; provide education and enforcement for unacceptable materials and materials left outside the depot bins; review and look for opportunities to strengthen the Land Use Bylaw and Waste and Recycling Bylaw to encourage multi-family recycling; develop a full cost of service multi-family recycling strategy during 2012-2014, based on industry and multi-family stakeholder engagement; and report back to Council by February 2014 on progress in multi-family recycling in Calgary, and recommendations for a multi-family recycling program to be implemented in the 2015-2017 business cycle; and apply learnings about collection and servicing needs of the multi-family sector to the development of a future yard and food waste program, to be implemented following a multi-family recycling program. ISC: UNRESTRICTED Page 12 of 12