This bill was last introduced in the 42nd Parliament, 1st Session, which ended in September 2019.
Marc Garneau Liberal
This bill has received Royal Assent and is now law.
This is from the published bill.
This enactment amends the Canada Transportation Act in respect of air transportation and railway transportation.
With respect to air transportation, it amends the Canada Transportation Act to require the Canadian Transportation Agency to make regulations establishing a new air passenger rights regime and to authorize the Governor in Council to make regulations requiring air carriers and other persons providing services in relation to air transportation to report on different aspects of their performance with respect to passenger experience or quality of service. It amends the definition of Canadian in that Act in order to raise the threshold of voting interests in an air carrier that may be owned and controlled by non-Canadians while retaining its Canadian status, while also establishing specific limits related to such interests. It also amends that Act to create a new process for the review and authorization of arrangements involving two or more transportation undertakings providing air services to take into account considerations respecting competition and broader considerations respecting public interest.
With respect to railway transportation, it amends the Act to, among other things,
(a) provide that the Canadian Transportation Agency will offer information and informal dispute resolution services;
(b) expand the Governor in Council’s powers to make regulations requiring major railway companies to provide to the Minister of Transport and the Agency information relating to rates, service and performance;
(c) repeal provisions of the Act dealing with insolvent railway companies in order to allow the laws of general application respecting bankruptcy and insolvency to apply to those companies;
(d) clarify the factors that must be applied in determining whether railway companies are fulfilling their service obligations;
(e) shorten the period within which a level of service complaint is to be adjudicated by the Agency;
(f) enable shippers to obtain terms in their contracts dealing with amounts to be paid in relation to a failure to comply with conditions related to railway companies’ service obligations;
(g) require the Agency to set the interswitching rate annually;
(h) create a new remedy for shippers who have access to the lines of only one railway company at the point of origin or destination of the movement of traffic in circumstances where interswitching is not available;
(i) change the process for the transfer and discontinuance of railway lines to, among other things, require railway companies to make certain information available to the Minister and the public and establish a remedy for non-compliance with the process;
(j) change provisions respecting the maximum revenue entitlement for the movement of Western grain and require certain railway companies to provide to the Minister and the public information respecting the movement of grain; and
(k) change provisions respecting the final offer arbitration process by, among other things, increasing the maximum amount for the summary process to $2 million and by making a decision of an arbitrator applicable for a period requested by the shipper of up to two years.
It amends the CN Commercialization Act to increase the maximum proportion of voting shares of the Canadian National Railway Company that can be held by any one person to 25%.
It amends the Railway Safety Act to prohibit a railway company from operating railway equipment and a local railway company from operating railway equipment on a railway unless the equipment is fitted with the prescribed recording instruments and the company, in the prescribed manner and circumstances, records the prescribed information using those instruments, collects the information that it records and preserves the information that it collects. This enactment also specifies the circumstances in which the prescribed information that is recorded can be used and communicated by companies, the Minister of Transport and railway safety inspectors.
It amends the Canadian Transportation Accident Investigation and Safety Board Act to allow the use or communication of an on-board recording, as defined in subsection 28(1) of that Act, if that use or communication is expressly authorized under the Aeronautics Act, the National Energy Board Act, the Railway Safety Act or the Canada Shipping Act, 2001.
It amends the Canadian Air Transport Security Authority Act to authorize the Canadian Air Transport Security Authority to enter into agreements for the delivery of screening services on a cost-recovery basis.
It amends the Coasting Trade Act to enable repositioning of empty containers by ships registered in any register. These amendments are conditional on Bill C-30, introduced in the 1st session of the 42nd Parliament and entitled the Canada–European Union Comprehensive Economic and Trade Agreement Implementation Act, receiving royal assent and sections 91 to 94 of that Act coming into force.
It amends the Canada Marine Act to permit port authorities and their wholly-owned subsidiaries to receive loans and loan guarantees from the Canada Infrastructure Bank. These amendments are conditional on Bill C-44, introduced in the 1st session of the 42nd Parliament and entitled the Budget Implementation Act, 2017, No. 1, receiving royal assent.
Finally, it makes related and consequential amendments to the Bankruptcy and Insolvency Act, the Competition Act, the Companies’ Creditors Arrangement Act, the Air Canada Public Participation Act, the Budget Implementation Act, 2009 and the Fair Rail for Grain Farmers Act.
All sorts of information on this bill is available at LEGISinfo, an excellent resource from the Library of Parliament. You can also read the full text of the bill.
Jean-Claude Poissant Liberal La Prairie, QC
Similarly, we agree that Bill C-49 must be passed quickly. That being said, I realize that this bill alone will not be enough. We have talked about the APP, Farm Credit Canada, infrastructures, elevators, road infrastructure, and the need to listen to farmers.
With regard to elevators, is it feasible to have infrastructures closer to the ports and to transport a certain amount of grain there in advance of any difficulties that may arise?
If what we saw on the letter that they posted on their website and circulated on the 15th is an indication of what their planning looks like.... With the passing of Bill C-49 and the planning aspect in that bill for them to submit a plan for the winter haul, if that's what it's going to look like—vague, broad, sweeping—then we're in trouble. As producers, we're in trouble, because that isn't a plan.
I want a plan. I want the number of cars by quarter, by province, by sector. That's what we need. We need a concrete plan that's going to work for the industry. I don't have any recourse, because I'm not a shipper. As a producer, I want a plan.
Alistair MacGregor NDP Cowichan—Malahat—Langford, BC
Mr. Nielsen and Mr. Boxall, you've possibly had the chance to hear the statements from CN and CP. You've heard of their plans to rectify the situation and hopefully get us to a place where we don't have to repeat this scenario.
Are you filled with much optimism and hope that we're going to get there with this plan, in addition to Bill C-49 being passed?
Francis Drouin Liberal Glengarry—Prescott—Russell, ON
Mr. Nielsen, what do you believe? You've mentioned that there needs to be greater collaboration between the House and the Senate and that we need to pass Bill C-49 as quickly as possible. Is it your wish that we amend it or that we just get it passed? Again, we're getting mixed messages from industry on that.
Ian Boxall Vice-President, Agricultural Producers Association of Saskatchewan
Thank you, Mr. Chair, and thank you for the opportunity to present to this committee.
I'm here today to explain how poor rail performance affects my industry, my community, and my family business, and why we need Parliament to take immediate action.
I and my wife Lisa and my brother and my sister-in-law together farm 8,300 acres of grains and oilseeds in northeast Saskatchewan. I am also vice-president of the Agricultural Producers Association of Saskatchewan.
We farm about as far from port as you can get, and in an average year our farm pays $360,000 in freight to get our products to our customers. The backlog of grain in the Prairies has had a huge effect on the ability of producers to cash-flow their operations and is making things extremely difficult for farmers going into their most expensive season. In the northeast, we are sitting with 3-month-old grain contracts undelivered due to the shortage of timely and sufficient railcar service to the elevators. At the end of February, personally, we were sitting with an outstanding wheat contract from December that we had been unable to deliver. This was leaving us in an extremely tough financial position. Luckily, our local elevator, which is one of only four in Canada that are serviced by both CN and CP, found some room to take our product and help us out. They didn't have room to take the entire contracted amount, but just enough to give us the money we needed at that time. We don't get paid on a contract until we deliver, and these delays place financial and personal stress on us as producers for something that shouldn't be a concern.
Two of the short lines that operate in northeast Saskatchewan have also felt the pinch of the lack of rail service this season. They have had a very poor and inconsistent supply of cars this shipping year, and this problem started in October, long before winter showed up again in Canada. They have also had several cases of cars that have been loaded and then not picked up for weeks. Producers do not get paid for the product loaded in these cars until it is received by the end user, so this is again placing unnecessary financial and mental stress on producers.
A lot of the highly sought-after oats grown in northeast Saskatchewan are loaded on these short lines in either dealer or producer cars. I grow 2,200 acres of these oats every year, and with poor rail service the market for these oats is in jeopardy. The processors need to find alternative sources for their oat supply, since our railroads have dropped the ball on shipping our product in a timely manner. My little boys want their oatmeal most mornings. I want that to be Canadian oats from Tisdale, not oats from Australia.
The rail issue isn't just affecting grain deliveries. Our local fertilizer dealer has been trying to put fertilizer in place for us, its customers, since last fall. Due to rail logistics, they have to pull fertilizer by truck out of Redwater, Alberta, instead of Clavet, Saskatchewan. That's an additional 1,000 kilometres per trip. So far this season, they have had to pull roughly 60 loads of fertilizer from Alberta, and that is only half of the product they require. If things continue like this, we are looking at an additional 120,000 kilometres of trucking freight. That's added manpower, truck power, wear and tear on the roads and equipment, costs, and carbon emissions that we as the end users are going to have to pay for. Spring road bans will be coming into effect very soon, and we could be short of fertilizer in western Canada to put in this year's crop. All of this is due to poor management and planning on the side of the railroads.
Farmers need to get the rail service that we pay good money for. Bill C-49 was drafted because of the disastrous shipping season of 2013-14, and it's completely outrageous that we are even here today and talking about this again.
In closing, we need all parliamentarians, from both the House and the Senate, to come together and pass Bill C-49 for the sake of the shippers, the processors, the retailers, our economy, our farmers, and all Canadians. Farmers already deal with so many unreliable factors—weather, crop prices, input costs—but reliable rail service is something we should be able to depend on every year.
Thank you.
Jeff Nielsen President, Grain Growers of Canada
Thank you, Mr. Chair, senators, and MPs, for allowing me to come and provide some comments to you today.
Across the Prairies, farmers are once again suffering the impacts of poor rail service. Unfortunately, this is not a unique experience. We dealt with it four years ago, and that's why I am here today: to ask the committee to back the systemic solutions that can fix rail transportation for the long term.
Grain Growers of Canada represents 50,000 grain, pulse, corn, oilseed, and soybean farmers across Canada, from the Atlantic provinces to the Peace Country of British Columbia.
Personally, I run a family-owned incorporated grain farm in south central Alberta, near Olds, growing wheat, malt barley, and canola. Grains off my farm are shipped south to the U.S. and to Mexico, and shipped through the west coast to ports in Asia and around the world. Effectively, every tonne of grain I sell off my farm must travel by rail to get to the end customer, be it in Canada, the U.S., or overseas.
Over the last couple of months, because of poor rail service, elevators are filling up and our grain is not able to get to our customers. This situation has put many farmers across the Prairies in the position where, because their own grain hasn't moved, they haven't been able to get paid.
We appreciate that this committee has recognized the difficult position this has put grain farmers in and has agreed to hold this hearing today. We believe that transportation is not a partisan issue and that all members of the committee should be able to agree on the need to have a rail transportation system that works. That is why we're asking you to come together and support getting Bill C-49 amended as we've presented it and passed as quickly as possible.
As has been mentioned, the unfortunate reality is that road bans and seeding are fast approaching. I will quickly just give a bit more information on road bans. Every 10 loads of grain I can haul today without the road ban would mean 13 trips the next time, once the bans are in place. That costs me more money in manpower for that trucker, and naturally it costs more for fuel. Farmers will have to use their skills as business managers to work through the difficult position they have been put in due to these new issues.
However, there is an opportunity to fix this situation for the long term so that farmers are not forced into a rail crisis again. With the amended Bill C-49 in place, the industry will have effective tools to hold the railways to account or to be able to take their business to another railway if they cannot get acceptable performance.
I know you've heard of the problems farmers face today, and that is why there is a focus on Bill C-49. First and foremost, the bill provides the ability to hold the railways financially accountable for the service through reciprocal penalties. The current lack of accountability impacts all the players in the supply chain, and ultimately farmers. Giving shippers the ability to hold railways to account through the reciprocal penalties in Bill C-49 will help ensure that car orders are fulfilled and my grain can get delivered.
Other benefits of Bill C-49 include a clear definition for “adequate and suitable service”, increased requirements for reporting and railway contingency planning, improved data collection, and new powers so that the Canadian Transportation Agency can play a larger role in areas such as improved dispute resolution processes.
However, it is important to understand where Bill C-49 falls short.
First, the maximum revenue entitlement, or MRE, is a key tool for protecting grower interest, and it needs to be amended to cover the movement of soybeans. I understand that when schedule II was created in 2000, soybeans were not really grown yet on the Prairies; however, soybeans are now a major commodity. They are the third-largest crop in Manitoba and soon will become second. Their production is spreading across Saskatchewan and Alberta as growers get new varieties. The act also excludes chickpeas, which should be corrected. It is simply unfair that some producers are protected, but not all of us are.
The real benefit of Bill C-49 is the long-haul interswitching, which gives shippers the ability to take their business elsewhere if they can't get acceptable service. Grain farmers saw improved service when interswitching was in place previously; often the threat of taking their business elsewhere was enough to get the railways to improve service.
However, as the bill is written today, too many elevators and too many processors will be excluded from long-haul interswitching. This means farmers will likely be put in the same situation of grain being backed up in their bins the next time one railway starts to suffer.
That is why the second target amendment that Grain Growers of Canada supports is to amend the provisions for long-haul interswitching so that it can remain a very useful tool for our grain companies to obtain more competitive terms of service.
Bill C-49's long-haul interswitching provision allows some of the same benefits as the previous extended interswitching; adoption of the amendments proposed by the crop logistics working group will ensure that oat and other grain farmers will receive the service they require.
Grain farmers across Canada have worked hard to provide the world with top-quality grain, oilseeds, pulses, and corn. We strongly support the government's ambitious target to increase agrifood exports to $75 billion by 2025, but this can only be achieved with a dependable and accountable rail transportation system. We can't meet our target if we can't get our grain to market.
The bottom line is that this year's repeat of the 2013-14 rail crisis is another example showing that we need to see Bill C-49 amended and passed as soon as possible. While it may be too late to see significant improvement this year, Parliament has an opportunity to give shippers the tools they need to prevent this situation from happening again. CN and CP have demonstrated time and again that they will not act on their own, and that is why shippers need tools to hold them to account. Without these legislative tools, we know it will happen again. It shouldn't take a farm crisis to get the grain moving.
I thank you and look forward to your questions.
Alistair MacGregor NDP Cowichan—Malahat—Langford, BC
I've heard all of you talk about Bill C-49. It was my colleague Robert Aubin, the NDP transport critic, who moved the motion to split the rail provisions off of Bill C-49, create a new bill, Bill C-51, and refer it directly to the transport committee. Unfortunately, we were not successful, but it was our hope at the time that those particular clauses of Bill C-49 could make a speedy passage. In hindsight, that might have been the best option. Unfortunately, as a House body we have no control over the other place, but I hope they are hearing the message loud and clear that those provisions need to get the attention they deserve.
Thank you, Chair.
The initial reaction is that I think we got their attention. The frustrating thing is that it's taken a lot of pressure from government officials, individual MPs, and farm organizations, as well as an almost crisis situation that developed in February, when Manitoba didn't have any cars delivered in one week. Some of what we're hearing sounds so similar to what we heard in 2013 and 2014. There is a need to make sure we have some type of system so that proper planning takes place, but it has to go beyond that. There have to be some teeth, and Bill C-49 provides part of that, to ensure there's compliance.
It's not the same as trucking grain. In that case you can go hire another trucker if one isn't performing. You're stuck with those railroads, so you don't have the flexibility to do that. That's why the regulatory system has to be in place to ensure there's compliance.
With the ability to continue to innovate and adopt new technologies at the production level as well as the handling and grain processing levels, we definitely see the potential to reach those levels. In terms of our ability to deliver on that, there are still a lot of question marks. That is why the remedies in Bill C-49 are so critical, from our point of view.
The cash flow is just one point.
I was a little disappointed when I listened to some of the railroad presentations. The one thing that gets missed in there is about getting the planning in place so that you can deal with the issues. Everybody knew back in October that there was going to be an issue, and then all of a sudden it's February when you start putting locomotives in place and drawing people back. I think the only reason they put those people in place was the threat of government action, and I think what we're looking at with Bill C-49 is that this threat is always going to be there. They have performance standards that they're going to have to meet.
We're talking about a bridge with the advance payment programs, but we have to remember that the core issue is that farmers can't market that grain when the grain is ready to be marketed. That's going to affect the cash flow, so unless we have a long-term solution, we could be back at this table in three years.
It's interesting that they talked about putting in interim engines to keep the lines open. That was discussed when they were in front of this committee four years ago as well. Why wouldn't that type of planning be in place?
I did mention briefly about the advance payments program. As a proactive measure, the government should be looking at the advance limits that are currently in place. Right now, if farmers have not delivered and paid down much of their advance and they're at the maximum $400,000—say they paid it down to $300,000 due to slow movement—they're running into a brand new program on April 1 and they're only eligible for another $100,000. That's catching some of them in the pinch between two programs, because the overall maximum is $400,000.
An easy fix would be to expand that limit to whatever the government would be comfortable with. We would say double it to $800,000. Farmers use the program for what it's intended for, which is to cash-flow themselves so they can market their grain appropriately. They can't market now because of the grain transportation problems that are plaguing the industry such that they're not able to sell their grain. That is one very proactive measure on the finance side.
Again, I don't want to take away from the focus on the service issues at hand. Bill C-49 is what we really need long term, and we really need that bill amended and passed. There are some good amendments coming forward. It needs to be done this year to get ready for next year, because this year, what's happening is going to happen. We can address some of the financing, as I suggested—a short-term Band-Aid fix to help farmers through it financially—but at the end of the day, Bill C-49 is the focus. We need to get it passed. We need to get it through the Senate. We need co-operation with the House to get royal assent on it before we go into the summer break, because we need to start next year in a lot better place than we have been this year.
John Barlow Conservative Foothills, AB
Thanks again, Luc. You're exactly right.
Tyler, you touched on it. I remember speaking in the House about this last September and October; we did want to work across the floor. We adamantly supported splitting the rail transportation off of Bill C-49. We would move it through. I think if that had been the case, we would have caught some of these proposed amendments that you're bringing forward, like the long-haul interswitching and those types of things. If it had been a separate bill, we could have addressed some of these points then, but because it's such a huge bill, it's now stuck in the Senate on something that has nothing to do with what we are talking about right now. That's the frustrating part of this entire discussion.
I like to think that when we went through this in 2013-2014 as the government, we knew what we were facing. Bill C-30 would have addressed some of these issues in good faith. We said, “We're warning you that this is going to happen, so let's try to address it.” It is frustrating for us, but it's more frustrating for you as producers and stakeholders that you're having to go through this again when there was opportunity to try to fix this situation.
Rick, you brought up an interesting point that I think we missed out on, and it's a fact that Tyler brought up too: we're missing markets that we may have had. We're not getting a premium for our product, because on the international trade market when we're talking about our producers and we want agriculture to have a $75-billion trade business, which is fantastic, we're taking away every possible tool for our producers to be able to reach those types of goals.
Can you touch on the fact that we are not getting a premium for our product because we are no longer a reliable trading partner because we cannot meet our sales deadlines because we can not get our product to market?
I think our issue is very similar. We know we have a problem with grain transportation. Frankly, it's not our job to fix it; it's the government's role to figure out the best way to fix it. I think what you've heard from the presentations is the urgency that's required, and I think what we have to focus on now is that urgency.
This is about the Senate, this committee, and the minister working together to figure out how to make sure that we can get Bill C-49 passed and how to make sure it has the teeth that are necessary to make it work.
Luc Berthold Conservative Mégantic—L'Érable, QC
For the last little while, you have been calling for Bill C-49 to be passed as quickly as possible. Do you have an opinion on the Canadian passenger bill of rights, though? Do you have an opinion on the public participation of foreigners in the funding and shareholding of Air Canada? That is the problem with Bill C-49.
The problems with Bill C-49 can be traced primarily to the fact that the Liberals refused last June to divide up the bill so as to speed up the adoption of certain measures. The two opposition parties wanted to proceed very quickly in order to avoid the black hole of August, given that the special measures established in Bill C-30 were about to expire and become void. That is the truth.
The government does not want us to be partisan, but it behaved in a partisan way itself by putting forward Bill C-49, which is full of things that have nothing to do with each other. Now, it is using us to get this bill passed as quickly as possible, but you have nothing to do with the passenger bill of rights.
What we want is for the grain to be shipped. What we want is for you to sell it on the market. What we want is for the system to work. Unfortunately, what the government wants is to pass an omnibus bill that is full of things that have nothing to do with grain shipment. That is the problem.
If the bill had been divided up and we had been able to pass these measures last June, would we be in the same situation today?
Tyler Bjornson Consultant, Western Grain Elevator Association
Thank you, Mr. Chair and members of the committee.
I'm presenting to you today on behalf of my client, the Western Grain Elevator Association. We're pleased to have the opportunity to contribute to your study of the grain transportation backlog.
The WGEA represents Canada's six major grain handling companies, with inland and port facilities from Quebec to British Columbia. Collectively, these companies handle in excess of 90% of western Canada's bulk grain movements. Working alongside grain producers and other rail-reliant industry sectors, the WGEA has been committed to finding long-term solutions to chronic capacity and performance deficiencies in our rail freight system.
The growing backlog of rail shipments in western Canada continues to have a significant negative impact on shippers and the farmers they serve. As you will hear from numerous witnesses over the course of this study, declining rail service over the winter months has created the worst backlog we have experienced since 2013-14.
According to the Ag Transport Coalition, the total railcar shortfall is currently at almost 28,000 railcars. This represents over two and a half million tonnes of grain that companies have submitted orders for that have not been filled in the week they were ordered.
Overall performance over the course of this shipping season has been steadily deteriorating, with car order fulfillment below 50% on average in most weeks. One railway in particular has brought the average down, hitting an all-time low in the week of February 12, when just 17% of cars ordered were filled for that order week.
For grain shippers, that translates into serious costs in the form of not just lost sales but penalties due to vessels waiting at port. It also means a hit to Canada's reputation as a reliable supplier, a reputation that has not yet recovered from the 2013-14 grain crisis. As members of the committee will know, in a highly competitive market like ours, once business is lost to a competing supplier, it is very difficult to win that business back. These are the immeasurable costs that hurt us not only in the immediate term but also for years to come.
In this context of challenging service, we would like to thank Minister MacAulay and Minister Garneau for their interaction with the railways and for working to find ways to see an immediate improvement in rail service, not only for grain but also for the many sectors that are experiencing problems.
As most of you will know, the WGEA has been singularly focused on fixing rail issues in a permanent way. While this current backlog is shining much-needed light on the systemic problems that plague Canada's rail logistics system, the issues are of a much more chronic nature.
The WGEA is of the view that the measures contained within Bill C-49 represent a big step in the right direction toward arriving at permanent legislative solutions. The ability to negotiate reciprocal penalties into our service level agreements, for example, is in our view one of the most important provisions contained within the bill.
Consider what has likely precipitated the current rail backlog. Would the railways have planned differently this fall had there been the legitimate threat of penalties for not moving grain and other bulk commodities? We believe the railways would have taken different decisions if credible reciprocal penalties had been in place. Unfortunately, with the provisions of Bill C-30 expired and the passage of Bill C-49 uncertain, grain companies and farmers are effectively left in this no man's land with no tools or remedies for poor service.
It is to that end that the WGEA has joined with farmers and the entire grain sector in asking that Bill C-49 be passed without delay. The bill, as you know, is currently before the Senate committee on transport and communications. We are grateful to the senators of that committee, who are taking the time to ensure the bill achieves its intended goal of better performance by rail.
It will be well known to members that the WGEA is of the view that the bill needs to be improved in a key area with respect to the long-haul interswitching mechanism, the LHI mechanism. The LHI provision is not only more bureaucratic and difficult to use than the extended interswitching mechanism we saw in Bill C-30; we are also concerned that the grain sector will not be able to leverage its use properly if two small targeted amendments are not made.
As the bill is current written, if an elevator is dual-served—meaning it already has access to two competing rail lines on site—or if it's located within 30 kilometres of an existing interchange, the facility will be excluded from applying for an LHI order. Now, if those two rail lines are both headed in the relatively wrong direction—for example, east-west when the traffic's final destination is the southwestern U.S.—that elevator for all intents and purposes is still captive. The LHI is useless to them.
We have done an analysis on this point and have determined that 75% of all Canada's value-added grain processing facilities would be prohibited from using LHI because of this restriction. In terms of creating competition, we believe this was not the intent the government had when it drafted this provision.
The grain sector submitted an amendment to the House of Commons transport committee study to address this situation, but unfortunately it was ultimately rejected by the House.
It is our hope that now, during these final hours of consideration and in the context of the current grain handling situation, the Senate committee will take this opportunity to include these important targeted amendments in their report.
I want to take these final seconds to address you, the members of this agriculture committee, to ask for your help to ensure that once the bill is brought back to the House, you will work with your colleagues to do whatever is necessary to get the bill passed.
The WGEA, grain farmers, and our sector as a whole have waited too long to see this bill made law. We implore you to work across party lines in the interest of this sector to get the job done.
Members of the committee, the reality is that we've already lost too much in this shipping season. Let's not lose the next one as well.
Thank you for your time. I look forward to your questions.