Submissions

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The CBAA has made the following submissions on behalf of the community broadcasting sector.  

 

ACCC Digital Platforms Inquiry

On 4 December 2017, the then Treasurer, the Hon Scott Morrison MP, directed the Australian Competition & Consumer Commission (ACCC) to conduct an inquiry into digital platforms. The inquiry looked at the effect that digital search engines, social media platforms and other digital content aggregation platforms have on competition in media and advertising services markets. In particular, the inquiry looked at the impact of digital platforms on the supply of news and journalistic content and the implications of this for media content creators, advertisers and consumers.

The final report was published on 26 July 2019. In August and September 2019 the Government sought stakeholder comments on the ACCC’s findings and recommendations. In particular, views on practical options for implementation, timing and any impediments or challenges. The CBAA made a submission to this process. Our comments focused on the recommendations covering a harmonised media regualtory framework, funding for local and specialised news reporting, and philanthropic support for media organisations.

PDF icon CBAA Submission to ACCC Digital Platforms Inquiry September 2019.pdf

 

ACCC News Media Bargaining Code

On 20 April 2020, the Australian Government announced it had directed the ACCC to develop a mandatory code of conduct to address bargaining power imbalances between Australian news media businesses and each of Google and Facebook. 

The CBAA and First Nations Media Australia (FNMA) made a joint submission to the ACCC’s Concepts Paper on a Mandatory News Media Bargaining Code. The submission addressed some definitional issues in determining news content and access to information. It also encouraged the ACCC to consider community and First Nations media organisations alongside commercial news outlets when determining the best bargaining framework.

 PDF icon CBAA-FNMA response to ACCC Concepts Paper - June 2020.docx.pdf

And in August, the CBAA and FNMA made a follow up submission to the ACCC, this time responding to the draft legislation.

PDF icon CBAA - FNMA response to Exposure Draft Mandatory News Bargaining Code - August 2020.pdf

In December 2020, the CBAA and FNMA submitted similar materials to the Economics Legislation Committee inquiry into the Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill 2020, further seeking the community broadcasting sector's inclusion.

PDF icon CBAA - FNMA submission re Treasury Laws Amendment (News Media and Digital Platforms Mandatory Bargaining Code) Bill - December 2020.pdf

 

ACMA Contemporary Community Safeguards Inquiry

In May 2013, the ACMA commenced their Contemporary community safeguards inquiry issues paper to assist them to establish core principles that should guide the broadcasting industry’s code development process. The inquiry covered many issues addressed in the Community Radio Broadcasting Codes of Practice including decency, fairness, accuracy and complaints handling. The CBAA prepared a response to the issues paper addressing the core principles of relevance to community broadcasters.

PDF icon CBAA response to the ACMA Contemporary community safeguards inquiry Issues Paper.pdf

 

Australia’s creative and cultural industries and institutions

On 26 August 2020 Minister for Communications, Hon Paul Fletcher MP asked the Committee to inquire into and report on Australia’s creative and cultural industries and institutions.

The Committee was asked to consider: the direct and indirect economic benefits and employment opportunities of creative and cultural industries and how to recognise, measure and grow them; the non-economic benefits that enhance community, social wellbeing and promoting Australia's national identity, and how to recognise, measure and grow them; the best mechanism for ensuring cooperation and delivery of policy between layers of government; the impact of COVID-19 on the creative and cultural industries; and avenues for increasing access and opportunities for Australia's creative and cultural industries through innovation and the digital environment.

The CBAA made a submission in October 2020, which focused on community radio's role as a connector and nurturer of the creative and cultural industries; employment and training opportunities across the sector; challenges faced by the sector due to COVID-19; and opportunities to optimise the funding and regulatory environment within which the sector operates.

PDF icon CBAA Submission - Australia's Creative and Cultural Industries and Institutions.pdf

 

Australian content on broadcast, radio and streaming services

In June 2018, the Environment and Communications References Committee commenced a review into Australian content on broadcast, radio and streaming services. The CBAA prepared a response addressing the value and importance of local content and comunity broadcasting services.

PDF icon CBAA Submission-EconomicCultutralValueofAustralianContent-June 2018.pdf

 

Broadcasting Legislation Amendment (Foreign Media Ownership and Community Radio) Bill 2017

The Broadcasting Legislation Amendment (Foreign Media Ownsership and Community Radio) was introduced to the Senate in December 2017, with the intent to strengthen localism in community radio broadcasting. The CBAA advocated for any changes to strike a balance between providing clarity for the sector, while avoiding overly prescriptive or burdensome requirements.

PDF icon CBAA Submission - Minister - Localism Changes - January 2018.pdf

 

CBF Structure and Governance Review

In April 2014, the CBF began a review of its structure and governance, appointing Nous Group to undertake an independent assessment. More information the CBAA's participation process is available here. The CBAA's two submissions to the CBF, from November 2014 and July 2015, are available to download below.

PDF icon CBF Structure & Governance Submission - November 2014.pdf

PDF icon CBF Structure & Governance Review Submission - July 2015.pdf

PDF icon CBF Structure and Governance Review Submission - December 2015.pdf

 

Charity Fundraising in the 21st Century

On 19 June 2018, the Senate established the Select Committee on Charity Fundraising in the 21st Century to inquire and report on the current framework of fundraising regulation for charities and options for reform. The CBAA made a submission, recommending a coordinated and streamlined national fundraising regulatory scheme, which would address inconsistencies, duplication, lack of clarity and wasted resources of the current layered state-based system.

PDF icon CBAA Submission - Charity Fundraising - August 2018.pdf

In March 2021, Commonwealth Treasury led a consultation on proposed changes to financial reporting thresholds for charities registered with the Australian Charities and Not-for-profits Commission. The proposed changes include the raising of thresholds for reporting, as part of an effort to promote alignment across the federal and state reporting regimes. The CBAA submission congratulates the work done to date, towards aligning those thresholds, and continues to be available for continued conversations on how to further that alignment.  You can read our submission in full, below. 

PDF icon CBAA Submission to Treasury consultation on reporting thresholds

In October 2021, the Commonwealth Treasury sought stakeholder views on exposure draft legislation implementing reforms to reduce red tape for, and increase transparency of, the charity sector. The CBAA expressed our support for higher annual revenue thresholds and recommended that thresholds be harmonised across all jurisdictions, with relevant information shared via the ACNC Charity Passport, including to the ACMA.

PDF icon CBAA Submission to Treasury consultation on ACNC Amendment (2021 Measures No. 3) Regulations 2021

 

Community Broadcasting 'Vision 2015' Submission to Minister Conroy

In October 2009, the CBAA worked with other sector representative organisations to develop a five-year plan to renew Australia’s Community Broadcasting sector and create the world’s most innovative, accessible community media.

PDF icon Vision 2015 Brochure.pdf

PDF icon Full Vision 2015 Submission.pdf

 

Community Television

In January 2015, the Department of Communications circulated the Digital Television Regulation consultation paper. The consultation paper outlines several policy principles to be considered when reforming the regulation of television services.

The CBAA is a stakeholder in this process as the peak body for community broadcasting in Australia. Community television licensees are represented by the Australian Community Television Alliance (ACTA) and the CBAA continues to advocate the public policy and regulatory principles that underpin community broadcasting generally.

In this submission, the CBAA responds to comments about the role of the internet in relation to broadcasting, supporting opportunities that the internet provides but points out that there are issues of content and structural regulation, access and cost to be considered. “There should be no cost barrier for viewers to access a mix of primary broadcast services. At least one community television service should be a part of that mix”.

The submission states that community broadcasters should be able to make use of the internet in the way that other broadcasters do: as a complementary platform to enable broader reach and facilitate on-demand services in support of free-to-access broadcast delivery.

PDF icon CBAA submission on digital television regulation - April 2015.pdf

 
COVID-19

On 8 April 2020, the Senate resolved to establish a Select Committee on COVID-19 to inquire into the Australian Government’s response to the COVID-19 pandemic. This inquiry provides an opportunity to better understand the community broadcasting sector’s engagement in the Government’s COVID-19 campaign and any roadblocks to be overcome to ensure community radio stations can be better utilised in delivering Government health and information campaigns in the future.

The CBAA's submission focused on community radio’s unique role and listenership across Australia; challenges faced by community radio stations during COVID-19 and the sector’s response; the community radio sector’s involvement in the Government’s COVID-19 campaign; issues preventing the community radio sector from being fully utilised in Government campaigns; and recommendations to ensure the community radio sector can be fully utilised in future Government campaigns.

PDF icon CBAA - COVID-19 Inquiry Submission-final 4 June 2020.pdf

 

Digital Radio

In October 2005, the Minister for Communications, Information Technology and the Arts, Hon Senator Helen Coonan, announced a framework for digital radio broadcasting in Australia. The first stage applied to metropolitan-wide broadcasting services in capital cities. For more information on digital community radio, head here.

Digital radio is a key policy priority for CBAA and the CBAA works closely with government and the wider industry on the issue. The CBAA has made the following submissions in relation to digital radio:

PDF icon Submission 25.11.2008 ACCC Access Undertakings.pdf

PDF icon Submission 24.12.2010 Technologies for Digital Radio Services in Regional Australia.pdf

PDF icon Submission March 2014 Response to Digital Radio Reviews.pdf

PDF icon CBAA Submission ACMA Digital Radio Deeming-November 2017.pdf

PDF icon CBAA Submission ACCC December 2018.pdf

PDF icon CBAA Follow Up Submission ACCC February 2019.pdf

PDF icon CBAA Submission to ACMA Mandurah March 2019.pdf

PDF icon CBAA Submission to ACMA Digital Radio Hobart RA3 Edge Deeming August 2019.pdf

PDF icon CBAA Submission to ACMA Digital Radio Expansion Deeming Principles August 2020.pdf

PDF icon CBAA Submission to ACMA Proposal to vary the QLD DRCP and declare a foundation DRMT licence for the Gold Coast October 2020.pdf

PDF icon CBAA Submission to ACMA Proposal to vary the QLD DRCP - August 2021.pdf

 

Digital Technology Hub

In February 2020, the Department of Infrastructure, Transport, Regional Development and Communications called for submissions regarding the design and implementation of an online Digital Technology Hub that will support regional, rural and remote Australians to make the most of telecommunications services.

The CBAA made a submission outlining the unique position of community radio stations in non-metro Australia, and how they are well-placed to promote the service to their communities.

PDF icon CBAA - submission - Digital Technology Hub - consultation - February 2020.pdf

 

Emergency Broadcasting

Community radio stations play a critical role in communities, particularly regional communities, both during natural disasters and in the recovery. The devastating bushfires that impacted vast regions of Australia towards the end of 2019 and into 2020 saw over 80 community radio stations broadcasting in fire affected areas or to fire affected communities. These stations are closely linked to their local areas and communities, drawing their announcing, producing and support volunteers and staff directly from the towns and locales where they broadcast. 

In 2020, the CBAA made submissions to the Royal Commission into National Natural Disaster Arrangements and the Finance and Public Administration References Committee's inquiry into lessons to be learned in relation to the Australian bushfire season 2019-20. The submissions highlight the role played by community broadcasters during the 2019-20 bushfire emergencies and other natural disasters; the challenges stations faced both during and in the aftermath of these natural disasters; the Victorian emergency broadcasting model and how it could be adapted as part of a national approach; and the need for involvement and integration of the community radio sector in the Government’s recovery programs and natural disaster planning.

Royal Commission 2020

PDF icon CBAA - Community radio resilience during emergencies and natural disasters - submission to Royal Commission - April 2020.pdf

Senate Inquiry

PDF icon CBAA - Community radio resilience during emergencies and natural disasters - submission to Senate inquiry - May 2020.pdf

PDF icon CBAA - Senate - Inquiry - Question on Notice - August 2020.pdf

 

Federal Budget

PDF icon Federal Budget submission 2021.pdf

PDF icon Federal Budget submission 2020.pdf

PDF icon Federal Budget submission 2019.pdf

PDF icon Federal Budget submission 2018.pdf

PDF icon Federal Budget submission 2017.pdf

PDF icon Federal Budget submission 2016.pdf    

 

FM broadcasting services band in the Perth RA1 licence area

In April 2021, the ACMA released an options paper to consult on options to replan the FM broadcasting services band in Perth.

A number of the options proposed impact upon community radio broadcasters, requiring either a change of frequency or a change of transmission site location: specifically regarding 6KCR, 6SEN and 6WSM. As part of the mix of primary radio services in Perth, the situation of community metropolitan-wide AM radio reading service, 6RPH, also needs to considered. The replanning also provides opportunity to tidy up and amend several long-standing historical anomalies related to 6NME, 6EBA, and 6NR.

In its response, the CBAA made a number of points in support of the needs of community broadcasters to provide the best outcome for stations and listeners, including better DAB+ digital radio service outcomes.

As the proposal currently stands, the CBAA would not support the ACMA moving to consult on a formal variation to the Perth RA1 LAP.

PDF icon CBAA response to ACMA's Perth radio options paper - June 2021.pdf

 

Future Delivery of Radio Services in Australia

In May 2019, the ACMA released a discussion paper seeking feedback from industry about the drivers of radio industry change; the suitability of alternative audio content delivery platforms; alternative spectrum approaches needed to support radio in the future; and the impact of new delivery platforms on broadcasting policy objectives and the existing regulatory framework.

The CBAA, after consulting with members, Sector Representative Organisations and key stakeholders made a submission. The CBAA's submission emphasised that any changes to legislation, regulation or how services are broadcast must continue to enshrine key principles for the public good: that there is diversity in terms of media ownership and control, and that a mix of broadcast services remain free-to-receive. We put forward positions in support of options for extending digital radio, and mechanisms to support the future of free-to-air radio in the digital age.

PDF icon CBAA Response to ACMA Future Delivery Issues Paper - August 2019.pdf

 

Future of Public Interest Journalism

In June 2017, the CBAA made a submission to the newly established Select Committee on the Future of Public Interest Journalism. The Committee will look into the current state of public interest journalism in Australia and around the world, the future of public and community broadcasters in delivering public interest journalism, particularly in underserviced markets like regional Australia, and culturally and linguistically diverse communities and other aspects of public interest journalism, such as fake news. 

The CBAA's submission adds to the many voices calling for greater support and certainty for Australia’s community broadcasters who deliver high-quality and diverse public interest journalism, particularly in underserviced markets like regional Australia, indigenous and culturally and linguistically diverse communities.

PDF icon CBAA Submission - Senate Committee on the Future of Public Interest Journalism.pdf

PDF icon Additional Information - CBAA Submission to the Senate Committee of the Future of Public Journalism.pdf

 

Inquiry into the Australian music industry

In August 2018, the Minister for Communications and the Arts, Senator the Hon Mitch Fifield, asked the Committee to inquire into and report on factors contributing to the growth and sustainability of the Australian music industry. The CBAA made a submission to the Inquiry, highlighting the pivotal role community radio plays across the country in shaping and supporting local music scenes.

The submission highlighted the wide-reach and listenership of community radio, its unique role within the broader music industry, its important role in regional communities, and some recent examples of related policy and program success from across the country supporting the sector. The CBAA also underlined the need for greater policy support and funding certainty to ensure community broadcasting can operate and plan over the longer term and ensure the sector’s public good contributions for all Australians can continue.

PDF icon CBAA Submission - Inquiry into the Australian Music Industry - September 2018.pdf

 

Inquiry into broadcasting, online content and live production to rural and regional Australia

The CBAA has made a submission to the Federal House of Representatives Inquiry into broadcasting, online content and live production to regional and rural Australia.

The CBAA submission pointed out not only the coverage of community radio stations, but also their importance in being in, of and for regional communities. The CBAA offered to provide more specific details about our sector directly to the committee during hearings.

PDF icon CBAA Submission to Inquiry into broadcasting, online content and live production in rural and regional Australia.pdf 

 

Inquiry into the music and arts economy in New South Wales

In July 2018, the CBAA made a submission to the inquiry into music and arts economy in New South Wales.

PDF icon CBAA Submission - Music & Arts Economy - July 2018.pdf

 

Joint Select Committee on Sydney's night time economy

In July 2019, the CBAA made a submission to the Joint Select Committee on Sydney’s Night Time Economy, outlining the unique role community broadcasting plays in Sydney. This includes by serving as catalysts for building diverse and passionate music and arts communities, and by supporting vibrant scenes and the venues, businesses and employees that host them. Further, community broadcasting provides opportunities for people to positively contribute to Sydney’s music and arts culture by being an important conduit for skills, training and employment and through local partnerships.

PDF icon CBAA-Submission-Sydney'sNightTimeEconomy-2019.pdf

 

Media Diversity in Australia

On 11 November 2020, the Senate referred an inquiry into the state of media diversity, independence and reliability in Australia to the Senate Environment and Communications References Committee for report by 31 March 2021.

The CBAA made a submission, focusing on community broadcasting's unique role in Australia' media landscape and wide listenership; the sector's size and point of difference; hyperlocal news and journalism production; the increase of news and public interest journalism in the community radio sector; and barriers and challenges facing the sector. The CBAA proposed recommendations for optimised funding arrangements for the sector, regulatory reform to enhance the sector's impact; and broad Government support measures that would enhance public interest journalism.

PDF icon CBAA Submission - Media Diversity in Australia - December 2020.pdf

 

Media Reform Green Paper: Modernising television regulation

From November 2020 to May 2021, the Government sought views on the proposed measures outlined in its Media Reform Green Paper.

The CBAA provided a response to the Government's Media Reform Green Paper. The Paper recognises that Government public policy and cultural objectives rely heavily on free-to-air broadcasting: both television and radio. The CBAA's submission outlined a number of points regarding, the repurpose of spectrum used by television; multiplex capacity sharing; the licensing framework; funding for transition and content; satellite, online, free-to-air and the role of community broadcasting.

PDF icon CBAA Submission - Media Reform Green Paper May 2021.pdf

 

Press Freedom

In July 2019, the Australia’s Right To Know (ARTK) media industry advocacy group, which includes the CBAA, made a submission to the Parliamentary Joint Committee on Intelligence and Security's inquiry into the impact of the exercise of law enforcement and intelligence powers on the freedom of the press. 

In September 2019, the ARTK coalition made a similar submission to the Environment and Communications References Committee inquiry into Press Freedom.

The submissions addressed several key issues regarding the need to uphold the public's right to know. They highlighted the need for protection for whistleblowers, increasing transparency of Government documents and a robust freedom of information regime, defamation law reform, and a review of national security laws that impede journalists' ability to do their jobs.

PDF icon ARTK submission to PJCIS inquiry July 2019.pdf

PDF icon ARTK submission to EC Cttee Inquiry into press freedom September 2019.pdf

PDF icon ARTK supplementary submission to PJCIS October 2019.pdf

 

Radiocommunications Legislation Amendment (Reform and Modernisation) Bill

Spectrum is essential to today's digitally-networked economy and is a major contributor to Australia's economic and social wellbeing. Management of spectrum is legislated under the Radiocommunications Act 1992 (the Act).

In October 2019, the Government committed to progressing a set of targeted amendments which will update and streamline the Act. On the 24 June 2020 consultation opened on a draft bill package which included targeted amendments focussed on removing existing unnecessary prescription and legislative barriers.

Consultation formally closed on 17 July 2020, and the CBAA made a submission, providng high-level comments on the effects of the Bill on community broadcasting, as well as points regarding studio-to-transmitter linking, digital radio, digital television and broadcasting and online delivery.

PDF icon CBAA - Radcomm-Amendment - July 2020.pdf

The CBAA also submitted this to the Senate Standing Committees on Environment and Communications's inquiry into the Radiocommunications Bills 2020 in September 2020. After appearing at the inquiry's public hearing, the CBAA made the following additional submission:

PDF icon CBAA - RadComms - Senate - Committee - October 2020-Further.pdf

 

Regional and Small Publishers Innovation Fund

In March 2018, the CBAA made a submission to the Regional and Small Publishers Innovation Fund consultation.

PDF icon CBAA Submission - Regional and Small Publishers Innovation Fund.pdf

 

Regional Australia Inquiry

On 25 July 2019 the Assistant Minister for Children and Families, Hon Michelle Landry MP, asked the Committee to inquire into and report on matters affecting Regional Australia.

In November 2019, the CBAA made a submission outlining the contribution of community radio to regional Australia (by enabling community participation, overcoming social isolation, providing local news and information, contributing to national identity, supporting music and arts, and providing emergency broadcasts); the operating challenges faced by community radio in regional Australia; and what better support might enable regional broadcasters to best serve their communities.

PDF icon CBAA Submission - Regional Australia Inquiry - 2019.pdf

 

Rental arrangements of communication towers on Crown Land

The NSW Government asked the Independent Pricing and Regulatory Tribunal NSW (IPART) to review the rental arrangements for communication towers on Crown Lands. IPART sought feedback on updating rents to reflect recent market changes, improve simplicity and transparency and help facilitate the roll out of emerging technologies. The CBAA made a submission to the Draft Report in September 2019, outlining key concerns about changes and costs which would adversely effect community radio stations.

PDF icon CBAA Submission IPART September 2019.pdf

 

Review of digital broadcast radio facilities legislative instruments

In 2018 the ACCC is conducting a review to assess the continuing need for two digital broadcast radio facilities legislative instruments which are due to sunset on 1 October 2018.

PDF icon CBAA Submission - ACCC Review April 2018.pdf

PDF icon CBAA Submission - ACCC Review - November 2008.pdf

 

Review of VAST

In June 2018 the CBAA responded to the Department of Communications and the Arts request for submissions for their review of the VAST service, to assess its performance since its commencement in 2010 and to consider options on how best to provide free-to-air broadcasting services to areas without reliable access to local terrestrial TV transmissions.

PDF icon CBAA Submission - VAST - June 2018.pdf

 

Revised B66 Form

In November 2010, the CBAA provided advice to the ACMA in relation to the application process for the renewal of community radio broadcasting licences. 

PDF icon CBAA Submission.pdf

In May 2017, the CBAA provided further advice to the ACMA in relation to the application process for the renewal of community radio broadcasting licences.

PDF icon CBAA Submission - 2017.pdf

In September 2021, the CBAA together with other sector bodies provided recommendations to the ACMA's consultation on streamlining the community broadcasting licence renewal form (the B66 form).

PDF icon CBAA, FNMA, CMAA, RPH Australia and NEMBC Submission - 2021.pdf

 

Senate Inquiry into Simulcasting

On 21 March 2013 the Senate referred the effectiveness of current regulatory arrangements in dealing with the simultaneous transmission of radio programs using the broadcasting services bands and the Internet ('simulcast') to the Senate Standing Committees on Environment and Communications for inquiry and report.

The CBAA worked collaboratively with the Australian Broadcasting Corporation (ABC), Commercial Radio Australia (CRA) and the Special Broadcasting Service (SBS) and made the following joint submissions to the Senate inquiry.

PDF icon Submission 10.5.2013 Inquiry into Simulcasting - from Australian Broadcasting Corporation, Commercial Radio Australia, the Community Broadcasting Association of Australia and the Special Broadcasting Service.pdf

PDF icon Supplementary submission.pdf

 

Spectrum Review

In December 2014, the CBAA made a submission in response to the Department of Communications Spectrum Review consultation paper. The consultation paper was part of a review of spectrum policy arrangements first announced by the Minister for Communications in May 2014, and explores proposals intended to maximise the economic and social return from spectrum.

PDF icon Spectrum Review - Potential Reform Directions - December 2014.pdf

The CBAA made a submission in relation to the Radiocommunications Bill 2017, Broadcasting Spectrum and Spectrum Pricing consultation package issued by the Department of Communications in August 2017.

PDF icon CBAA Submission_Spectrum Framework_August 2017.pdf

 

Tax Deductible Gift Recipient Reform Opportunities

In August 2017, the CBAA made a submission in regards to potential reforms to the Deductible Gift Recipient (DGR) tax arrangements. DGR status allows an organisation to receive gifts and contributions for which donors are able to claim a tax deduction. The DGR tax arrangements are intended to encourage philanthropy and provide support for the not-for-profit (NFP) sector.

PDF icon CBAA Submission - Letter to the Treasury - DGR Status - August 2018.pdf

 

Temporary Community Broadcasting Licences

The Temporary Community Broadcasting Licence Determination was due to expire in April 2015. In the lead up, the ACMA requested feedback from stakeholders on a proposal to remake the instrument with minor changes, to ensure that it remained in ongoing effect. The CBAA prepared a submission responding to the proposed changes. 

PDF icon CBAA response to the ACMA proposal to remake the Radiocommunications Licence Conditions (Temporary Community Broadcasting Licence) Determination 2003 (TCBL Licence Determination).pdf

The CBAA made a submission to the ACMA’s 2021 consultation on revising the Temporary Community Broadcasting Guidelines.

PDF icon CBAA Submission -TCBL Guidelines - April 2021.pdf