1995

Note: The electronic version of this document does not contain the charts and graphs. Hard copies of this document are no longer available.

I. INTRODUCTION

The CCSD

Founded in 1920, the Canadian Council on Social Development (CCSD) is an independent, national, non-profit organization. Led by a volunteer board of directors from across Canada, the CCSD has a broad mandate focused on issues of social and economic security. We are a non-partisan, membership-based organization that links concerned individuals and organizations from coast to coast. We form a national network that includes professionals in human service organizations, volunteers, union members, businesses, academics, and government departments, who share a commitment to social progress.

The Budget in Context

Faced with a rising debt burden, persistent annual deficits, volatile currency markets, and calls for both deep spending cuts and "no new taxes," the federal government introduced a budget that cut deeper, harder and faster than any other in recent memory. This budget attempted to reduce the deficit, make the federal government smaller and reduce its role, and appease foreign investors. The federal government said this was necessary in order to respond to the forces of globalization and the growth of public debt. There is an implicit assumption that if these criteria are met, all else including social development will follow. In fact, there are other, very serious problems facing Canada, problems that will not be solved indirectly by improving the competitiveness of Canadian exports, having the best GDP growth among the G7 nations, maintaining low inflation, or even through successful deficit reduction. Canada has amassed a serious social deficit in recent years, one that requires direct and concerted action.

The Social Deficit

The "new economy" presents many challenges and opportunities. It is said that adaptability and knowledge are key criteria in today's rapidly evolving global marketplace, and for those who are able to meet these criteria, there are many possibilities. But not everyone has adapted, and not everyone will easily find a place in this "new economy."

Our rapidly changing economy has placed tremendous strains on Canadian families, workers, and their children. Following are some of the symptoms of the broader social and economic problems that the Canadian government should be addressing: four of 10 young families and eight of 10 among families headed by a single mother live in poverty; ballooning numbers of working poor (a 30% jump since 1981); a growing income gap $5 billion moved from low and middle income earners to those with high incomes during the 1980s; an explosion in the number of food banks; growing numbers of homeless beggars on the streets; increasing stress borne by families, especially by women trying to juggle work and family responsibilities; the lack of quality subsidized child care, growing numbers of "latch-key" kids; growing youth crime; an aging population and the imminent strain this will place on the health care system and pensions; family and community breakdown; and, an increasingly turbulent labour market that affords less and less economic security to Canadian families. We cannot ignore the fact that our drive for global competitiveness, coupled with a decade of cutbacks to our social safety net, have left many Canadians on the sidelines.

A Holistic Vision

Canadians need a vision that goes beyond deficit reduction and smaller government. In establishing national priorities, the government must be guided by a collective vision of how we want to live together. After all, the role of government which includes revenue raising and spending is to reflect, through public policy, agreed-upon principles of its citizens. The CCSD suggests that the changes to come be guided by the following basic principles, which go beyond mere efficiency and cost-saving goals:

• the reduction of economic inequities between individuals and regions;
• equal access to opportunities, so that a person's future is not limited by their social and economic environments;
• means for self-support and the ability to influence decisions that affect one's life;
• collective support for those who are unable to support themselves;
• shared responsibility for our collective well-being. It is in everyone's interest that all Canadians be included in our social and economic fabric; and,
• a system that maintains income security and stability, one that does not require individuals to "hit bottom" before intervening. In other words, a system that prevents poverty, rather than simply responds to it.

The process of deficit reduction and the structural reforms of government must be guided by a vision of where we want to be in the future. Our current economic and social deficit requires more than simply cutting expenditures. It requires a hard look at all options, and a realistic consideration of how we can most equitably distribute the burdens and the responsibilities of debt and deficit reduction and of helping Canadians adapt to the changing economy. A fair and balanced approach is necessary if we are to maintain our traditional values while meeting the challenges we face.

A Balanced Approach

The CCSD is calling on the government to stick to its pledge in the Red Book that promised a "balanced approach," an approach that was reiterated in the Department of Finance paper, Creating a Healthy Fiscal Climate, but recently ignored in the February budget. Disappointingly, no serious options for generating revenue were presented in the budget; instead, a lopsided ratio of seven dollars in cuts for every dollar in revenue raised was implemented. Furthermore, little attention aside from purely symbolic measures was given to equity, or the distribution of the burden of debt and deficit reduction. A truly "balanced approach" is one that looks at both revenues and expenditures, considers the economic and the social implications of measures, and recognizes the impact of these changes, as well as the expected impact in the future.

The CCSD has proposed an approach that recognizes the debt and deficit problem, while addressing the need to look beyond the immediate bottom line. The Council is fully aware of the debt problem and supports deficit reduction; it is simply the approach presented by the government with which we disagree. Reasonable alternatives to major spending cuts exist. What is needed is a fair and realistic assessment of possible revenue measures and a more modest program of fiscal belt-tightening. By earmarking the funds generated by increased revenues, we can reduce and eventually eliminate the deficit, and then begin to tackle the debt without dismantling the social infrastructure of the country.

II. PUBLIC SPENDING

In many circles, government spending and more specifically, social programs, have been popular scapegoats for the deficit. Yet even before the cuts announced in this last budget, total federal program spending, at 16% of GDP in 1994-95, was actually lower than it was during the 1970s. With the major reductions announced in February, including $4.5 billion taken from transfers to provincial social programs, public spending will fall further, to just 13% of GDP by 1996-97. This is a level below that of the immediate post-war period. Government spending is clearly not out of control. Yet, even at 13% of GDP, there are calls for deeper cuts, as if we can continue to cut indefinitely.

We take for granted the independent rankings of the world's most livable countries that consistently rank Canada at or near the top of the list. This could not have come about without substantial investments in our social infrastructure. But with public spending soon to fall to levels of the 1950s, and considerably below the OECD average, Canadians must recognize that our current standard of living and the quality of life in this country will eventually fall as we reduce investments in our children, schools, family and social services, public health, and other pillars of our social infrastructure. Just as insufficient investment in our physical infrastructures may mean crumbling roads and bridges, falling investments in our nation's social infrastructure will inevitably lead to a weakened social fabric that will be evident in higher crime rates, lower levels of education, higher unemployment, disenfranchised and troubled youth, substance abuse, family income insecurity, and high levels of poverty.

Social investment does not mean overspending. In fact, when we separate the cost of financing the debt from current spending and revenues, it becomes clear that the federal government is already maintaining a responsible match between what it collects and what it spends. In recent years, the federal government has, in fact, managed four surplus operating budgets between 1988 and 1991, and is continuing to do so again now that the economy is recovering. And despite estimates for the coming fiscal years that show operating surpluses almost $30 billion by 1996 97 growing interest charges on the debt will continue to cause annual deficits, even though more than $25 billion in spending cuts are planned by 1997-98. As the Liberals said in their Red Book, "to achieve this target (a 3% of GDP deficit), cutting expenditures alone, as the Conservatives are proposing, will not be sufficient." The CCSD agrees. With government spending now at its lowest levels in 45 years, and growing operating surpluses, our focus for deficit reduction must move beyond this one-sided approach. It should now be clear that the deficit cannot be eliminated simply by cutting spending. If the government is truly serious about eliminating the deficit and doing so without completely dismantling the federal government in the process alternatives must be considered.

III. THE TAX SYSTEM

The so-called "grassroots" campaign against income tax hikes prior to the budget proved successful. In large numbers, Canadian taxpayers told the federal government that income taxes are already high enough, therefore the only alternative it was argued was to cut spending. Canadian taxpayers feel they are already paying enough taxes for good reason: Canada relies more on personal income taxes than any other G7 country, and the proportion of revenue raised from this source has increased steadily since 1965.

Yet in terms of overall tax burden, Canada is not a high-tax country in comparison with other industrialized nations. Figure 1 shows that among 10 countries, including the other G-7 nations, Canada's level of total taxation as a share of GDP ranks it in seventh place. At 37%, Canada's taxes are below the average of 39% for all 24 OECD countries in 1992. Canada's heavy reliance on personal income taxes, however, stands out. Figures 2 and 3 show the relative tax compositions of countries in the G7. Figure 2 demonstrates that Canada even outpaces Sweden in terms of personal income taxes, a country typically given as an example of one that leans too heavily on this form of revenue. In Canada, the proportion of revenue raised through income taxes has, in fact, almost doubled since 1965 to 40%, in comparison to corporate income taxes which have fallen from 15% of the total raised to just 5% over the same period (see Figure 4). Perhaps it is because of this great reliance on personal income taxes in Canada, and their high visibility, that many Canadians jumped on the "no new taxes" bandwagon. The fact that most Canadians are already paying their fair share in personal income taxes, however, should not preclude a serious examination of the tax system to uncover alternative sources of revenue.

While the high visibility of personal income taxes makes them politically unpopular, they continue to be the most progressive form of taxation in Canada, in that the proportion of income taxes paid rises with income. The use of flat taxes, i.e., those that do not take income into consideration like sales taxes or user fees, diminishes the overall progressivity of our tax system. As a result of these regressive forms of taxation, a recent study has found that Canada's overall tax system is actually flat: rich, poor and middle-income Canadians all pay between 30 and 34 per cent of their gross income in one form of taxation or another (see Figure 5). This should be of particular concern in light of the growing trend towards user fees by all levels of government. Influenced by the "no new taxes" movement, the February budget introduced over a half billion dollars in user fees (presumably not really taxes) in lieu of personal income tax hikes, thereby further reducing the overall progressivity of the tax system.

Recognising the need to maintain an adequate level of investment in our social infrastructure, and the limitations for higher income taxes and the regressivity of user fees and sales taxes, attention must now turn to an alternative area of public spending. The CCSD strongly urges the federal government to heed the advice of the Auditor General: we must seriously address the issue tax expenditures - what the Auditor General referred to as "unlimited spending" and implement a system to track, monitor, and evaluate revenues forgone by the federal government.

lV. TAX EXPENDITURES AND ALTERNATIVE REVENUES

Almost all economic and social policy analysts today are in agreement on one thing: whether governments spend money directly through programs or through the tax system, it all constitutes government spending, because it all represents a cost to the treasury. Some $90 billion worth of tax expenditures are listed in the 1994 Personal and Corporate Income Tax Expenditures report published by the Department of Finance. This figure is more than twice the $40 billion spent on social programs, and is three-quarters of the $120 billion spent on all direct federal programs. With numbers like these, even if the government chooses to focus only on spending, it should at least examine all forms of government expenditures program spending and expenditures through the tax system.

RRSP and RPP Expenditures

For many years, the Council has been a strong supporter of tax-assisted retirement support through RRSPs and RPPs. However, we do not feel that public monies should be used to provide private pensions that far exceed average earnings. The present ceiling of $13,500 per person for RRSP contributions provides unreasonable levels of retirement pensions. The budget merely put off raising the RRSP limit to $15,500 limit, until 1998, after which time it will be indexed to average earnings. This generous indexing formula is available to few other government program expenditures, certainly not to child benefits, the refundable sales tax credit, or social assistance.

The problem with the high RRSP contributory ceiling is that all taxpayers low, middle and high income are subsidizing generous private pensions for above-average income Canadians, through higher taxes and deficits. Figure 6 shows who benefits the most from the RRSP program and it is overwhelmingly high-income Canadians. The RRSP program redistributes tax expenditures in the "wrong" direction. There is clearly a direct relationship between income and the extent to which individuals benefit from RRSPs. In essence, the higher one's income, the more likely they are to invest in RRSPs, and the greater is their tax benefit and the cost to the government.

Unfortunately, it is risky in today's atmosphere of restraint and with an aging population, to raise the issue of the RRSP tax expenditures. It seems to cause a knee-jerk reaction. Without much reflection, opponents of any RRSP changes assume that talk of RRSP reform means taxing RRSPs, or even doing away with them. Their response is, "How are people going to finance their retirement if RRSPs are not available?" The CCSD is not proposing taxing nor doing away with RRSPs, but is instead suggesting some modifications that will make the system fairer for all wage earners, and stop the subsidization of unreasonably high pensions.

The CCSD recommends reducing the annual RRSP contribution ceiling to $7,500 per person, or $15,000 per couple (see Figure 7). The Department of Finance has estimated that an $8,000 ceiling on both RRSPs and RPPs would save one billion dollars in the first year . The savings would accelerate each year as the total size of the RRSP/RPP "fund" is reduced, hence lessening the tax expenditure (or cost to the government) on these sheltered investments.

Partial Inclusion of Capital Gains

Until 1990, only two-thirds of capital gains income was included for taxation purposes. In 1990, this was increased to 75%. This still means, however, that 25% of all capital gains go untaxed. By the government's own estimates, the cost to the public treasury for this tax expenditure was over a billion dollars in 1991. The CCSD urges the government to recognize that "a buck is a buck" and that capital gains should be taxed, as are other forms of income. (Even the U.S. recently moved to full inclusion of capital gains income for tax purposes.)

Dividend Tax Credit

Dividends received by the shareholders of Canadian corporations are subject to a special tax break, amounting to one-third off the normal tax. In 1991, this cost the government $700 million in foregone revenues. The CCSD understands the rationale behind this practice, which is to avoid double taxation of corporate income: since dividends are paid out of after-tax corporate income, they have already been taxed. However, figures produced for the Ontario Fair Tax Commission show that annually, about -one-third of profitable corporations - those most likely to be paying dividends - did not pay any corporate tax. Consequently, dividends passed on to shareholders have not yet been taxed and should therefore be taxed at regular rates. The savings from this change alone could reach $230 million - one third of the amount of taxes foregone to support the Dividend Tax Credit.

Meals and Entertainment Expense

The 50% write-off for all entertainment and meal expenses by individuals and corporations accounts for almost a half billion dollars in lost tax revenues. Typical expenses in this category include season's tickets to sports stadiums, golf excursions, and lunch or dinner tabs, among others. At a time of massive public servant layoffs, and deep cuts in social and general government spending, subsidization of such a perk cannot be justified.

Accountability

To permit proper scrutiny of these tax expenditures, by both the public and government committees, the government should produce an annual tax expenditure account as part of its public accounts. As well, a system for evaluating various tax expenditures should be put in place to determine the degree to which policy objectives are being achieved by these forgone revenues, as the Auditor General has been suggesting for since the mid-1980s. The government has made very little progress on this front, despite pre-budget assurances of fairness. Tax deferrals, credits, and deductions cost the taxpayer tens of billions of dollars each year. If the government is serious about eliminating the deficit and ensuring fairness in the tax system, it cannot afford to ignore the issue of tax expenditures any longer.

Inheritance Tax

Although not a tax expenditure, an inheritance tax represents an alternative source of revenue that deserves serious consideration. Having dropped the tax in 1972, Canada is now one of only three OECD countries without an inheritance tax on wealth. Research by Royal Trust estimates there will be a transfer of $1 trillion dollars between generations over the next 15 years. Even with a 5% tax rate on inheritances, roughly $50 billion over 15 years, or $3.3 billion annually, could be raised to reduce the deficit.

Savings achieved through proposed tax changes governing RPPs, RRSPs, capital gains, and dividend tax credits, combined with new revenue from a 5% tax on inheritances, would produce about $6 billion in the first year, and this would grow over time. This figure represents only the savings made possible by changes specifically identified in this paper. Keeping in mind that total tax expenditures in Canada amount to almost $90 billion, there is obviously room for additional measures. As well, these savings represent only those accruing to the federal treasury, but in most cases, changes in tax expenditures would also contribute significantly to provincial treasuries. The money saved by these actions - along with other revenue-generating measures and savings not specifically mentioned - would allow the federal government to meet its deficit targets without having to resort to severe and damaging cuts to our social safety net.

V. SOCIAL POLICY

Despite the opportunity to seek alternative sources of revenue and savings, and to adapt to the machinery of the federal government to changes in the economy without sacrificing traditional Canadian values, the budget instead laid the groundwork for a radically different country. The deep spending cuts, decentralization and downloading of federal responsibilities, privatization, and massive public service layoffs announced in the budget, will leave Canadians with a very different country. Perhaps the most profound change introduced in the budget, though not generally recognized as such, was the announcement of a new block fund transfer to the provinces, the Canada Health and Social Transfer (CHST). The CHST will replace both the Canada Assistance Plan (CAP) which covers social assistance and social services, and Established Programs Financing (EPF), the transfer arrangement covering health and post-secondary education. This new consolidated block fund arrangement will greatly diminish the federal government's ability to ensure that basic national priorities are met, as reflected in national standards, and will leave Canada with a fragmented and weakened social safety net.

Dollars Cut = Services Lost

Along with the announcement of the CHST, the budget also reduced the combined spending currently transferred to the provinces under EPF and CAP from $29.5 billion to $25 billion by 1997-98. The cuts will start with $2.5 billion in 1996-97, and another $2 billion the following year, but the cumulative impact will be $7 billion over the two fiscal years . These cuts will have an enormous impact on communities across Canada for they compound several years of provincial cutbacks, downsizing, and re-organization. Just as the federal government has been struggling with its own deficit woes, provinces and municipalities have been doing the same. This most recent cut in transfers - "deficit downloading" in effect - will result in an even greater impact on local services and programs. Canadians will feel the effects at all levels, from hospital services and education, to local municipal and community services.

The Loss of Fiscal Levers

For social assistance and social services, and for health, the federal government currently has the authority to withhold transfer monies from provincial governments if they veer too widely from established national standards. This "fiscal stick," although derived from different means for social assistance and services than for health, is based on a simple factor - cash. Without the transfer of cash to the provinces, the federal government has no leverage to enforce national standards. This was already a problem for health and post-secondary education which, under EPF, are headed for a cashless transfer formula within a decade. The fact that CAP is now being brought under this same diminishing cash transfer formula (i.e., replacing cash with tax points), will have serious consequences for social assistance and services, just as it has for health and post-secondary education. Canadians must recognize that once the Canadian Health and Social Transfer tax points replace cash transfers, national standards will no longer be enforceable. Even Prime Minister Chretien admitted that "when you transfer tax points, you lose all leverage...because you don't collect the money, they (the provinces) collect the money."

Traditionally, CAP has had an additional feature that has been vital in the development and support of Canada's social infrastructure. The impetus provided by "50 cent dollars" (i.e., federal matching of provincial dollars under CAP) has fostered the development of many programs and services that support and invest in our communities, including services for child protection, mental rehabilitation, family counselling, rape crisis centres, shelters for women, and subsidized daycare for low-income families. Even if the federal government was somehow able to continue to ensure provincial compliance to national standards through some form of fiscal penalty, the loss of this shared cost incentive would still mean that the "fiscal carrot" to maintain these programs and services would be lost. The matching of provincial dollars also provides an additional advantage: it ensures, almost automatically, that the monies are spent in the areas for which they were intended. The CHST arrangement provides no such assurance.

Priorities Follow Political Clout

The major problem with consolidation under the CHST concerns accountability. If the federal government were to transfer a sum of money, say $25 billion in 1997-98 for example, to the provinces to pay for three different policy areas, there would be no way of ensuring that the funds were adequately distributed among health, post-secondary education, and social assistance and services. And with competition for a diminishing pool of funds intensifying, social assistance and services may well be at a disadvantage. The considerably more powerful upper - and middle - class voices arguing against cutbacks to health and post-secondary education would, no doubt, have more influence than the more fragmented and often vulnerable population that relies on social assistance and services - 40% of whom are children.

Unfortunately, we often overlook the links between developing and sustaining healthy families and communities, both mentally and physically, and overall public health. The over-emphasis on doctors, hospitals, and medicine - or curative measures - has made longer term, or preventative investment in children, families, and communities less of a political priority. When making tough budgetary choices, provincial government priorities for social spending will favour health and post-secondary education (and training). Social services and social assistance are certain to take the deepest cuts, sparing health care but only for the time being.

Matching Priorities with Leverage

If Canadians want to continue to express their national social priorities, the federal government must play a role in the development of social policies. In response to the current public demands, the federal government has set out what it sees as national priorities. On the federal agenda, for example, is the government's commitment to eliminate child poverty by the year 2000. By which mechanisms does the federal government intend to formulate, implement and enforce public policies to address this and other important national social priorities? If the federal government truly has a strong interest in pursuing social policy goals, it must provide adequate levels of funding and maintain a funding mechanism that will provide effective leverage to influence social policy. Without these basic pre- conditions, stated goals, objectives and national standards will be ineffective and unenforceable.

The National Role

Collectively the combination of fewer dollars, the loss of federal levers to ensure national standards, and the loss of accountability for where transferred dollars are being spent, will result in a radically different vision of Canadian social policy. Why should Canadians be concerned about losing the national dimension in social policy?

The role of the federal government in ensuring equitable levels of services and programs across Canada through the establishment and enforcement of national standards has been, and continues to be, a primary reason for federal involvement in social policy. The basic assurances provided by our national system of Medicare, for example, and the social safety net of last resort that exists for all that need it, contribute to our national identity. National unity and social cohesion in Canada have been supported by this national social vision and our sense of collective responsibility that is exemplified by Canada's social framework. The cost of losing this vision, and the collective values that underlie it, would far exceed any "savings" from cuts to our social security system. The real cost would be a diminished sense of nationhood and social responsibility over time; we would no longer belong to a nation in which our collective interests extend beyond the borders of each province or region.

A Negotiated Minimum

Although the CCSD is not supportive of the CHST option, the decision has been made: CAP and EPF have been consolidated. Recognizing this, the focus must now be on what can be done to minimize the pitfalls of this arrangement. There are two basic elements: cash and standards. There must be some form of cash transfer from the federal government to all provinces - equalization payments are not sufficient - and they must be accompanied by accepted national standards. Cash transfers and standards must work in tandem - the exclusion of the one is as ineffective as having neither. The example of post-secondary education demonstrates this point. Even though part of the transfer for post-secondary education is in cash, the fact that there are no standards means that the provinces can do as they wish with the funds. As a result, the federal government has had virtually no influence in this field, and is unable to establish such priorities as the portability of post-secondary credentials from one province to another.

Establishing national standards without cash transfers is of equal concern. As was mentioned, once tax points replace cash transfers under the CHST, there will be no way, for the federal government to set national priorities because the standards will be largely unenforceable. Only by combining cash transfers with accepted standards, will the parameters of activity in these three fields of social policy be clearly established, and participation and agreed-upon priorities will be safeguarded. The CCSD suggests that the following minimum national standards and principles form the foundation of the CHST: for health - universality, portability, comprehensiveness, public administration, and accessibility; for social assistance - financial assistance to anyone in need, no residency requirement, and access to appeal; and for post-secondary education - accessibility, portability, and public administration.

No National Debate

The introduction of the CHST amounts to an unprecedented transfer of financial and administrative authority from Ottawa to the provinces. Through the budget, the federal government has all but vacated the field of social policy, without giving the matter the attention it should have received through the traditional legislative process or a full-scale constitutional debate. As a result, there has been no real public debate on this issue. Despite having the opportunity for public debate and input at countless government sponsored community meetings during the Social Security Review process, the government did not reveal its intentions to move ahead with the CHST. Why was such a major social policy initiative perhaps the largest single social reform in decades not included on the social reform agenda? Canadians demonstrated their willingness to participate in social reform during these hearings, but they were denied the opportunity to speak to this critical issue. This process of reform, which will shape the future of Canada's social safety net, should have been open to public debate.

VI. CONCLUSION

The CCSD is well aware of the pressures facing the federal government as it attempts to adapt to national and global changes, and to tackle the deficit and accumulated debt. We do not deny that some "re-thinking" of government must take place. The federal government does not need to be involved in all aspects of the economy, and perhaps some areas of public policy are best left to the provinces and local governments. But this does not mean that we have to abandon our traditional Canadian values or dismantle the structures that contribute to the unity and national vision of this country. Nor does this justify the government's tight monetary policy at the expense of jobs and ordinary Canadians seeking mortgages and personal loans, or deep spending cuts that effect vital public investments in children, families and communities. Versions of this approach by previous governments were rejected after a decade of ineffective experimentation. There are alternatives to deep spending cuts. The entire federal system does not need to be replaced in order to deal with the deficit and adapt to changes in the economy. Canadians need to have more creative alternatives. The simple "cuts vs. personal income taxes" debate has left the public feeling as though little else can be done. There is, in fact, plenty that can be done to improve our current system without completely reinventing it. The CCSD has given several suggestions in this paper about how to raise new revenues and reduce tax expenditures. Along with efforts to improve the functioning and efficiency of the federal government, and a refocusing on employment and investment in people and communities, the deficit problem can be managed in a fair and balanced manner.

Over the course of several generations, Canadians have developed a social security system and a standard of living that is unrivalled, but we must not forget that our quality of life is directly related to our investments in people, schools, communities, and public services. These investments have been possible through our system of federal/provincial arrangements, by providing incentives and the means to support a network of social, education, and health services across the country, and a social safety net that provides support to all in need. It is imperative that a national framework, supported by national standards and federal/provincial transfers, continue to contribute to the quality of life in Canada, and that social cohesion and a national vision continue to be supported by the policies of the federal government.

REFERENCES

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