FERO GROUP PTY LTD and CITY OF NEDLANDS - [2018] WASAT 78

JURISDICTION     :   STATE ADMINISTRATIVE TRIBUNAL
ACT: BUILDING ACT 2011 (WA)
CITATION:   FERO GROUP PTY LTD and CITY OF NEDLANDS [2018] WASAT 78
MEMBER:   DEPUTY PRESIDENT, JUDGE PARRY
HEARD:   19 JULY 2018
DELIVERED          :   19 JULY 2018
PUBLISHED           :   10 AUGUST 2018
FILE NO/S:   CC 1456 of 2018
CC 1457 of 2018
CC 1458 of 2018

BETWEEN: FERO GROUP PTY LTD
Applicant
AND
CITY OF NEDLANDS
Respondent

Catchwords:

Building and construction - Application for extension of term of building permit - Practice and procedure - Stay of reviewable decision - Applicable principles - Reviewable decision is decision to refuse to extend term of building permit where application for extension of term made before expiry of term - Effect of stay of reviewable decision - Whether effect of stay of reviewable decision is that building work may continue

Legislation:

Building Act 2011 (WA), s 32(2)
Building Regulations 2012 (WA), reg 23, reg 23(2), reg 23(3), reg 23(4), reg 24, reg 24(1)
Planning and Development Act 2005 (WA), s 214(2), s 214(3)
State Administrative Tribunal Act 2004 (WA), s 25, s 25(2), s 25(4), s 25(4)(c)

Result:

Reviewable decisions stayed until further order

Summary of Tribunal's decision:

Fero Group Pty Ltd sought the stay, under s 25(2) of the State Administrative Tribunal Act 2004 (WA), of the decisions of the City of Nedlands not to extend the terms of building permits for the construction of three houses on adjoining properties in Dalkeith.
The Tribunal heard the applications on an urgent basis and granted stays in the exercise of its discretion.
Ferro Group Pty Ltd applied for the extension of the building permits prior to the expiry of their term. Regulation 23(4) of the Building Regulations 2012 (WA) provides that where an application for the extension of the term of a building permit is made before the expiry of the term, 'the permit continues to have effect on and from the expiry day ... until the permit authority extends or refuses to extend the time during which the permit has effect ...'. The Tribunal determined that the effect of the stay is that the building permits continue to have effect and authorise the building work to continue until further order.

Category: B

Representation:

Counsel:

Applicant	:	Mr P McQueen
Respondent	:	Mr TL Beckett

Solicitors:

Applicant	:	Lavan
Respondent	:	McLeods

Case(s) referred to in decision(s):

GFS Management Services Pty Ltd v Ground and Foundation Supports Pty Ltd & Ors [2001] WASC 280
Phoenix Timber Products Trading As Vintage Hardwoods and Skinner [2005] WASAT 315; (2005) 41 SR (WA) 252

REASONS FOR DECISION OF THE TRIBUNAL:

Introduction

Fero Group Pty Ltd (Fero Group), a building company, has made an application, by way of interim application, to the Tribunal, pursuant to s 25 of the State Administrative Tribunal Act 2004 (WA) (SAT Act), for the stay of the decisions of the City of Nedlands (City or Council) made on 16 July 2018 to refuse to extend the terms of building permits granted to authorise building work at three adjoining properties, Nos. 36, 38 and 40 Jutland Parade, Dalkeith (site).

Building permits and extension applications

Building permits were granted by the City to authorise building works in relation to large dwellings on each of the properties comprising the site on 9 June 2016. Under s 32(2) of the Building Act 2011 (WA) (Building Act), the building permits had effect for a period of two years from the time they were granted. Subject to an application to extend the term of the building permits, they would have expired on 9 June 2018.
On 5 June 2018, Fero Group applied to the City, pursuant to reg 23 of the Building Regulations 2012 (WA) (Building Regs) to extend the time during which the permits in respect of each of the dwellings under construction on the properties comprising the site have effect. Regulation 23(2) of the Building Regs states as follows:
An application to extend the time during which a permit has effect
(a)must be made to the relevant permit authority in a manner and form approved by the Building Commissioner; and
(b)must set out
(i)the reference number of the permit; and
(ii)the grounds for requesting the extension; and
(iii)the period for which the extension is sought.
It is common ground that the applications made by Fero Group for extension of the building permits comply with this subregulation.
Regulation 23(3) of the Building Regs allows the permit authority, that is, the City, by written notice, to refuse to accept an application made after the expiry date in certain circumstances. That provision is not applicable, because the applications for extension were made before the expiry date.
Significantly, reg 23(4) of the Building Regs states as follows:
If an application is made before the expiry day for a permit and has not been determined by the expiry day, the permit continues to have effect on and from expiry day
(a)until the permit authority extends, or refuses to extend the time during which the permit has effect; or
(b)until the applicant withdraws the application or gives notice of completion in relation to the permit,
except for any period when the permit does not have effect under section 35.
The effect of reg 23(4) of the Building Regs is that the building permits in relation to the dwellings on the properties forming the site continued to have effect after 9 June 2018, and continued to have effect until the City refused to extend the time under each permit on 16 July 2018.
Regulation 24 of the Building Regs provides, in subregulation (1), as follows:
The relevant permit authority may extend the time during which a permit has effect if the permit authority is satisfied that
(a)the work, or stage of work, for which the permit was granted has not been completed; or
(b)the extension is necessary to allow rectification of defects in the work, or the stage of work, for which the permit was granted.

Background

The approved application form for an extension of the term of a building permit (Form BA22) states the following question:
Have there been any alterations/amendments to works covered in the original permit?
To that question, Fero Group answered 'Yes' by crossing the relevant box. The next part of the application form states:
If yes, please give details.
Fero Group gave the following details in relation to each of the applications to extend the term of the relevant building permit:
Wall alignment and adjacent landscaping is currently subject to SAT proceedings. Construction activity in this area has been halted (as directed by SAT) until SAT outcome has been reached.
It is common ground that, for the purposes of reg 24 of the Building Regs:
the work…for which the permit was granted has not been completed[.]
A photograph in evidence (Exhibit 3) shows that the works have certainly not been completed. They indicate a considerable amount of work having been undertaken in relation to each of the dwellings, but with considerable work still to be completed.
However, as a result of Fero Group's statement in the applications for extension of the building permits that there have been alterations or amendments to works covered by the original permit, the City has taken the view that, without plans showing precisely what works have been carried out, the applications for extension of the building permits should not be approved.
As will be seen in the evidence that I will refer to, the City has made a number of requests of Fero Group for the provision of 'as constructed' drawings and other information.
Finally, in terms of the factual background to these reasons, as indicated in the response by Fero Group to the requirement to give details of the alterations or amendments to the works covered in the original permits, there are other proceedings on foot in the Tribunal.
Relevant to the application in relation to the extension application for the building permit concerning No. 40 Jutland Parade, Dalkeith, which is proceeding CC 1456 of 2018, are two related development and resources proceedings currently pending in the Tribunal: DR 61 and DR 65 of 2018. Relevant to the extension application in relation to No. 38 Jutland Parade, Dalkeith, which is proceeding CC 1457 of 2018, are two related development and resources proceedings pending before the Tribunal: DR 60 and DR 63 of 2018. Relevant to the extension application in relation to No. 36 Jutland Parade, Dalkeith, are two related development and resources proceedings pending before the Tribunal: DR59 and DR62 of 2018.
In relation to No. 40 Jutland Parade, the related development and resources proceedings concern applications for review of directions issued by the City to the owner of that property, Mr Michael Franco, pursuant to s 214(2) and s 214(3) of the Planning and Development Act 2005 (WA) (PD Act), requiring the cessation of development and the demolition of works involving the construction of a staircase and concrete structure not shown on the approved development plans.
In relation to No. 38 Jutland Parade, the related development and resources proceedings involve applications for review of directions given by the City to the owner of that property, Mr Mario Franco and Mrs Immacolata Franco, pursuant to s 214(2) and s 214(3) of the PD Act, requiring the cessation of development and the demolition of a staircase and amphitheatre being constructed which are not shown on the approved development plans.
In relation to No. 36 Jutland Parade, the related development and resources proceedings involve applications for review of the directions given by the City to the owner of that property, Mr Robert Franco, pursuant to s 214(2) and s 214(3) of the PD Act, requiring him to cease development and remove a retaining wall not authorised by the development approval for the house on that site.
In relation to those proceedings which are pending before the Tribunal, on 13 April 2018, the Tribunal granted a stay, pursuant to s 25(2) of the SAT Act, of each of the directions. The stay, however, was on condition that it excluded from the stay the following parts of the development which has taken place on parts of the site:
(a)the retaining wall facing the river;
(b)the area of the house under construction within five metres of the retaining wall facing the river; and
(c)the area between the retaining wall facing the river and the river frontage of the property.
The effect of the stay, and the exclusion for the stay that the Tribunal imposed in those proceedings on 13 April 2018, is that so far as planning authority for the construction of the houses on the properties forming the site is concerned, that development can continue, but subject to the exclusion from the stay, effectively quarantining the current state of construction in the area at the rear of each of the houses under construction within five metres of the end of those buildings, and in the area between the retaining wall facing the river, and the river frontage of each property. Those proceedings are pending before the Tribunal, and the parties have indicated that mediation between them in those proceedings is ongoing.

Legal framework and principles

Section 25(2) of the SAT Act states as follows:
The Tribunal, on the application of a party or its own initiative, may make an order staying the operation of a decision that is the subject of a proceeding for review.
Section 25(4) of the SAT Act prescribes in a non-exhaustive manner matters for consideration in the exercise of the Tribunal's discretion in relation to an application for a stay. Section 25(4) states as follows:
The Tribunal may make an order under subsection (2) only if it considers that it is desirable to do so after taking into account
(a)the interests of any persons whose interests may be affected by the order; and
(b)any submission made by or on behalf of the decisionmaker; and
(c)the public interest.
It is also common ground between the parties that two significant considerations which apply in relation to an exercise of discretion under s 25(2) of the SAT Act are 'the balance of convenience' and whether there is an arguable case for review.
Those matters for consideration were stated in the judgment of Templeman J in GFS Management Services Pty Ltd v Ground and Foundation Supports Pty Ltd & Ors [2001] WASC 280 (GFS), in terms applied by the Tribunal in cases including Phoenix Timber Products Trading As Vintage Hardwoods and Skinner [2005] WASAT 315; (2005) 41 SR (WA) 252 at [11]. In GFS at [21], Templeman J endorsed the following principles in relation to the discretion to stay execution of a judgment pending appeal stated in Seaman, Civil Procedure in Australia (Butterworths, 1990) at [63.15.1]:
The discretion to stay execution pending an appeal is unfettered and the applicant for a stay carries the onus of showing that the circumstances are appropriate for a stay to be granted. Before weighing other factors the court needs to be satisfied that there is an arguable case for an appeal to ensure that the appeal has not been lodged simply to delay execution: see Croney v Nand [1999] 2 Qd R 342 at 348, 349 CA. The onus is upon the applicant to demonstrate a proper basis for a stay which will be fair to all parties and the court will weigh the balance of convenience and the rights of the parties: Alexander v Cambridge Credit Corporation Ltd (1985) 2 NSWLR 685, 69. Appropriate circumstances may exist if it is shown that if a stay of execution is not granted, the appeal may be nugatory: Wilson v Church(No 2) (1879) 12 ChD 454 at 458 or that serious injury will result to the applicant unless a stay is granted: McBride v Sandland (No 2) (1918) 25 CLR 369 at 375. An appeal will be nugatory when, because of the respondent's financial state, there is no reasonable prospect of recovering moneys paid to him or her pursuant to the judgment, but appropriate circumstances are not limited to that situation and will exist whenever there is a real risk that it will not be possible for a successful appellant to be restored substantially to his or her former position: Federal Commissioner of Taxation v Myer Emporium Ltd (No 1) (1986) 160 CLR 220 at 223 …
It will be seen that there is overlap between those considerations and matters required to be taken into account under s 25(4) of the SAT Act.

Evidence

The evidence before me consists of two affidavits and documents tendered by the parties.
The first affidavit is that of Mr Robert Franco who, in addition to being the owner of No. 36 Jutland Parade, is a director of Fero Group. Mr Franco was not required for cross-examination. Mr Franco gives evidence that the areas of non-compliance with the approved development plans which are the subject of the development and resources proceedings that I have referred to have not been the subject of any further building work since the stay and the exclusion from the stay were made on 13 April 2018.
Mr Franco also gives evidence that if the project, that is to say, the construction of the houses on the site, is put on hold indefinitely due to the absence of a building permit, Fero Group will have to terminate the engagement of three full-time staff and three contractors, or alternatively, ask them to take indefinite leave. He also gives evidence that currently employed or contracted at the project are approximately 30 workers who, until the City's decision to refuse to extend the terms of the building permits on 16 July 2018, were engaged full-time on the site. Mr Franco says that, or relates his understanding that, many of these workers are employees of small firms who have relied upon continuity of employment at the site.
He refers in particular to some six contractors, each of whom are engaged on the site, or were engaged on the site until 16 July 2018 in small teams. An example is Cowan Contracting, which is a six person team. Mr Franco attaches to his affidavit a letter from Mr Jesse Cowan, a principal of Cowan Contracting, that states as follows:
As you are aware, we have had our 6 man team solely dedicated to the project now for two years. As a contractor, I have not pursued other works during this time. With an anticipated 6 months left on the project, I have not looked for other works.
Over 80% of our materials are currently on your site, which we now can[']t even access. This means even if we could find any other work at such short notice, we don't even have the resources to do it.
The result of this is my whole team of staff will have to be laidoff in the next few days, leaving us all in an extremely bad position.
Mr Franco also gives evidence that if work cannot continue on the site, then certain equipment will need to be demobilised from the site, at least in the short term, and that Fero Group would incur significant costs in demobilising or removing those items and having to have them returned or re-erected on site at some future time.
Penultimately, Mr Franco also refers to a tower crane being located on the site, and licences having been obtained from relevant neighbours to use their air space, which are only for a term expiring at the end of 2018. Mr Franco gives evidence that:
Completing the project would be placed in real jeopardy if the Applicant is unable to use the crane, due to a lack of any right to use the neighbouring airspace[,]
in the event that the neighbours do not grant further licences beyond the end of this year.
Finally, Mr Franco gives evidence that in addition to the potentially significant detrimental affect on the contractors and their employees, there would be significant financial cost to the applicant building company if the building works could not continue on the site. He estimates that the holding costs to Fero Group for the project associated with the construction, if the works would stop indefinitely, in the amount of approximately $120,000 per month.
The City presented a witness statement of Mr Paul Busby, who is the Manager Building Services at the City. Mr Busby was not required for cross-examination. In his witness statement Mr Busby refers, by way of background, to the directions issued by the City to the owners of the properties forming the site that I have referred to and which are now the subject of the related development and resources proceedings.
Mr Busby refers to orders made by the Tribunal on 13 April 2018 requiring the landowners of the site to provide certain information, and in particular a current survey of the site by a registered surveyor, an elevation of the developments currently under construction as they will appear from the river upon completion, a site plan of the development under construction upon completion, and a substituted landscape plan for the area of the properties between the retaining wall facing the river and the river frontage of those properties, and says that although some information has been provided, Fero Group:
… has failed to supply plans to that effect, and the Respondent has been unable to carry out site inspections of the Properties to ascertain the extent of the departures carried out to date.
Mr Busby expresses the opinion that it would be inappropriate for either the City or the Tribunal to grant an extension to the permits to enable building work to continue on the properties until Fero Group or the owners of the properties provide the information required in the Tribunal orders, and also overlapping information sought by the City in a letter to Fero Group on 12 June 2018. In particular the City required Fero Group to provide plans and drawings:
… of the amended works that differ from the original permit.
Mr Busby also says that a further opportunity was given to Fero Group to provide this information by way of a letter on 25 June 2018. In that letter Mr Busby advised Fero Group that if the information sought was not provided within 21 business days from the time of the original request, that is by 11 July 2018, the application for extension of each of the building permits would be determined by Friday 13 July 2018.

In addition, the parties provided certain correspondence between their respective solicitors relating to the information required by the Tribunal's orders of 13 April 2018 in the related development and resources proceedings. There is a continuing dispute between the parties as to whether there has been full compliance with those orders.

Parties' submissions

Fero Group contends that there is power to grant a stay in the circumstances of this case, and that if a stay were granted the effect of the stay, together with reg 23(4) of the Building Regs, is that the building permits would continue to have effect, and therefore, that the building work approved by those permits could continue. The City does not take a different view.
I agree, given the terms of reg 23(4) of the Building Regs, that the effect of granting a stay of the decision of the City to refuse to extend the terms of the building permits would be that the building permits would continue to have effect and would, therefore, authorise the building work to be undertaken from the time the Tribunal grants a stay. It is, therefore, common ground that there is a discretion in the circumstances of this case to grant a stay, and that the exercise of that discretion, if in favour of Fero Group, would be such as to, in effect, permit building work to continue on the site until further order.
Fero Group's position is that given the very significant financial consequences not only to itself, but to the third party contractors and their employees, referred to by Mr Franco in his affidavit, and given that insofar as unauthorised works have been undertaken, they are the subject of enforcement action and SAT proceedings, that the balance of convenience favours the granting of the stays sought.
Related to that submission, Fero Group submits that there is no prejudice to the City in granting a stay, because insofar as unauthorised works have occurred, they are the subject of enforcement action and the SAT proceedings, and furthermore, given the exclusion from the stay in the development and resources proceedings concerning the directions, no further work can take place in the area of the unauthorised development works.
Fero Group also submits that it has an arguable case for review, given that the evidence indicates, even at this stage, that the work for which the permits were granted has not been completed, and that, as I said earlier, reg 24(1) of the Building Regs confers a discretion on the permit authority, and on review on this Tribunal, to extend the time during which a permit has effect if the permit authority is satisfied that the work for which the permit was granted has not been completed.
The City opposes the grant of a stay. The City submits that, in terms of the balance of convenience, it has given ample opportunity to Fero Group to provide 'as built' drawings and plans indicating precisely what has been constructed on the site to date, including five weeks' notice that it required that information and would not determine the applications favourably otherwise.
Insofar as the matter has come on an urgent basis and third party contractors may need to terminate employment of employees, while unfortunate, the City submits, that is a matter of Fero Group's own making by its failure to provide the information sought by the City.
The City also submits that it would be contrary to the public interest in terms of s 25(4)(c) of the SAT Act to grant a stay in the circumstances of this case, given that Fero Group concedes in its applications to extend the permits that unauthorised development has occurred. The City submits that, in effect, such unlawful development would be condoned by a stay being granted, thereby, in effect, permitting the building work to continue.
In terms of public interest, the City also submits that there is a public interest in the orderly enforcement and application of development and buildings laws, and that, at the very least, Fero Group should be required to provide the information sought by the City in terms of 'as built' building plans before a stay application is determined.
The City also submits that there is not a 'high likelihood of success' of the Tribunal ultimately granting the applications for extension of the building permits, given that it is conceded that part of the works do not comply with the building permits.
The City, in the course of its submissions, referred to concerns about other aspects of the building works not being in compliance with the approved development and building permit plans, that is to say, other than the parts of the development the subject of the directions which are now pending in the development and resources review proceedings before the Tribunal.

Exercise of discretion

As indicated earlier, the interests of any persons whose interests may be affected by the order is expressly prescribed as a matter for consideration in the exercise of discretion under s 25(4) of the SAT Act. The evidence overwhelmingly demonstrates that, in terms of the considerable number of workers who have been employed or contracted to work fulltime on the site for a considerable period, there would be very significant financial consequences, including the termination from employment of a number of workers, as contractors had reasonably understood that the building work would continue for the next six months as they have continued for the past two years.
Although the interests of persons whose interests may be affected by the order sought would include third parties such as neighbours, there is no evidence before the Tribunal in relation to their positions about the stay that is sought.
That consideration of the interests of any persons whose interests may be affected by the order is also necessarily part of a consideration of the balance of convenience. The balance of convenience or, as sometimes said, the balance of the risk of doing an injustice, embraces a broad range of considerations.
The Tribunal is satisfied that the balance of convenience favours the granting of a stay in the circumstances of this case for these reasons. There would be substantial financial consequences to Fero Group, namely, holding costs of $120,000 per month, if a stay is not granted. Furthermore, as I have said, there would be very significant financial consequences to contractors and to their employees if a stay were not granted in this case.
Although the City is quite correct in its submission that there is a public interest in orderly application of building laws, insofar as there are noncompliances with the approved plans, those are the subject of directions and the pending development and resources proceedings. Given the exclusion from the stay or stays granted on 13 April 2018, no development or building work can take place in relation to any of the non-compliant parts of the development.
In that regard, I reiterate that the section of the development where alterations or amendments to works have been done as stated on the extension of time application lodged by Fero Group involve:
Wall alignment and adjacent landscaping is currently subject to SAT proceedings. Construction activity in this area has been halted (as directed by SAT) until SAT outcome has been reached.
Although it is correct, as the City submits and Fero Group concedes, that there is unauthorised development, the concession is only in relation to the development the subject of the related development and resources proceedings.
While the City has raised a concern as to whether there are other aspects of the building works that are non-compliant, there is no evidence at all before the Tribunal that there is any such non-compliant work. The City's concern is pure speculation, and does not persuade the Tribunal that the balance of convenience is other than in favour of the granting of a stay in the circumstances of this case.
Moreover, Mr Busby's correspondence and witness statement, and the consequent submissions of the City on the stay application, to some extent conflate the present applications for extension of the building permits with enforcement and remedying non-compliance with development and building laws.
The Tribunal understands, certainly, that the City wishes to determine whether there are any other non-compliances with development or building approvals in relation to the site.
However, there is no basis in the application made, nor in any of the other evidence before the Tribunal, to found a concern that there is any non-compliant building work other than the development the subject of the development and resources proceedings, as to which no further work can occur until the resolution of those other proceedings.
Furthermore, approval of the extension applications, if ultimately, following the final hearing in this matter, they are approved, would only have the effect of enabling the completion of the building work in accordance with the building permit plans lodged and approved by the City on 9 June 2016. Extension of the building permits could not authorise the construction or carrying out of building work not the subject of and not shown on the building permit plans.
For these reasons, in my view, the balance of convenience favours the granting of the stay sought.
Furthermore, as I have said, while there is a public interest in proper enforcement and application of building laws, the granting of a stay of the City's refusal to extend the building permits' terms, is not contrary to the public interest.
There is a public interest in the enforcement of building laws and planning laws. That public interest is met by the City's issue of directions, and the exclusion from the stay or stays granted on 13 April 2018 of the sections of the development which are non-compliant. Certainly, ultimately, as Fero Group concedes, it will need to, or the owners will need to obtain authorisation by way of development approval of any unauthorised works, and a building licence to enable completion of any unauthorised works.
In terms of whether there is an arguable case for review, the City submits, as I have said, that there is not a high likelihood of success in this proceeding, because it is conceded that part of the works the subject of the building permits have not been constructed in accordance with the approvals. However, in my view, that does not have the effect that there is limited arguability of the case for review.
It is common ground that insofar as the building permits are concerned, in the area excluded from the stays granted on 13 April 2018, that there will have to be, after development approval is sought, and if development approval is obtained in relation to retrospective approval of those works, a building licence obtained to enable the completion of those works. That building licence, no doubt, insofar as that part of the site is concerned, will be different in some respects to the building licence granted, or building licences granted by the City in June 2016.
However, that does mean that there is no arguable case for review. The applicants have an arguable case for review, given that the evidence clearly establishes that building works have been undertaken on the site, have progressed to a significant extent, but are uncompleted. Those building works, as the photograph in Exhibit 3 shows, includes considerable building works in the central and front parts of the site. Those areas are not included in the area where unauthorised building and development has occurred.

Conclusion

For these reasons, in my view, the Tribunal has power and discretion in the circumstances of this case to grant the stays sought by Fero Group and it is desirable and appropriate to grant stays in the circumstances of this case.
The effect of the stays, given the particular legislation in question in terms of the enabling provisions, and in particular reg 23(4) of the Building Regs, enables the continuation of building work on the site.
Given that the stays and the exclusion from the stays granted on 13 April 2018 in the related development and resources proceedings remain in force, building work cannot take place in the area of the retaining walls facing the river, the area of the houses under construction within five metres of the retaining walls facing the river, and the area between the retaining walls facing the river and the river frontage of each property.

Orders

For these reasons, I make the following orders in each of the proceedings.
1.Pursuant to s 25(2) of the State Administrative Tribunal Act 2004 (WA), the decision made on 16 July 2018 to refuse to extend the term of the building permit granted on 9 June 2016 is stayed until further order.
2.The proceeding is listed for a further directions hearing at 3 pm on 27 July 2018 at 565 Hay Street, Perth, Western Australia in order to make further programming orders for the matter.

I certify that the preceding paragraph(s) comprise the reasons for decision of the State Administrative Tribunal.
JUDGE D PARRY, DEPUTY PRESIDENT
10 AUGUST 2018