DRAFT APRIL 2012 Housing and Homelessness Plan PDD DRAFT Building from Strength: 10 Year Housing and Homelessness Plan City and County of Peterborough PROJECT DEFINITION DOCUMENT Version 1.0 County/Townships logos as well? Project Name: 10 Year Housing and Homelessness Plan Project Number: Project Leader: Dorothy Olver Tel./Ext: 705-742-7777 Ext 1501 Project Sponsor: Susan Bacque Tel./Ext: 705-742-7777 Ext 1492 Corporate PDD Author(s) Last Revision Date Document1 Departmental Divisional Legislated Dorothy Olver, Susan Bacque, Janet Sheward and Linda Mitchelson May 2,2012 Page 1 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD CORPORATE PURPOSE OF THE PROJECT: The City of Peterborough is the Service Manager for housing programs and planning, homelessness and social services in the City and County. The City, County and eight Townships are responsible for cost sharing these services, and for land-use planning policies and practices. The Ministry of Municipal Affairs and Housing (MMAH) under the Housing Services Act, 2011 (HSA) requires all Service Managers to develop a 10 year Housing and Homelessness Plan (“the Plan”). The Plan will establish priorities for housing and homelessness services based on targeted consultations and research. The Plan must be consistent with legislation, Ontario Regulations and the provincial Housing Policy Statement, and: Identify current and future housing needs; Set out objectives and targets (goals) relating to housing needs; Propose actions to meet the goals; and, Establish a process to measure and report progress towards meeting the goals. The Plan must be approved by Council (June 2013) as Service Manager for the City and County, and be implemented beginning January 2014. The Plan must be reviewed every five years, with annual public reporting on results. The Plan will enable the City to: Create a long term community vision, shared goals, agreed upon priorities and strategies for a continuum of housing and homelessness services; Improve access to adequate, suitable and affordable housing; Coordinate and integrate housing and homelessness services to assist families and individuals; Prepare for future senior government funding and partnership opportunities; Make recommendations on process and structure of service delivery within the Corporation and with the City’s delivery partners. The Plan will include a three-year Action Plan, which will focus on the most immediate phase of detailed activities to affect change, maximize service improvements and funding efficiencies. PROJECT SCOPE What is included in the project? This project covers all phases of the creation of the Plan as follows: Document1 Solicit, select and engage a consultant who will facilitate and co-ordinate the Plan development Create and follow a timeline for the Plan development process Identify and implement internal progress reporting Report regularly on information gathered through the consultation process, research and document reviews, and provide summaries Develop and present to the Steering Committee a proposed outline for the Plan including identification of necessary content pieces in accordance with Provincial direction Create “look and feel” for the Plan, including pictures, graphics Complete targeted consultation with identified community stakeholders based on a first draft of the Plan. Present a final draft Plan for review by staff December 31, 2012 Revise the Plan in accordance with feedback received Present final Plan to Steering Committee, Council and other stakeholders Page 2 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD What is not included in the project? The Project does not include: Broad-based public consultation Direct service and implementation of the Plan Recommendations for allocation of resources Guiding Principles for the Project Project completion will be guided by the following principles: Build the Housing and Homelessness Plan on the strengths of existing housing and homelessness programs and serivces Complete research and consultation in a way that maximizes existing resources including, but not limited to: o Arranging consultations through existing committees (** see list under Community Input pg7). Building a foundation for the Plan from existing documents/reports on housing and homelessness: Attached as Appendix A Consult on and seek community input on the draft Plan, i.e. don’t start with a blank slate Ensure that City/County and urban/rural perspectives are incorporated Emphasize broad community interests including social, economic, support services, health, employment in order to maximize creative and innovative partnership opportunities. CRITICAL SUCCESS FACTORS The project will have been successfully completed when: The Plan is Approved. Joint Services Steering Committee and City Council have endorsed/approved the Plan; MMAH has commented on the Plan and returned it to the Service Manager with minimal suggestions for amendments. The Plan is supported by key stakeholders. Senior Management, the community, users and operators of shelters and housing, all embrace the vision, goals, priorities and strategies provided in the Plan. The Plan has breadth and scope to address the housing continuum, including its social, economic and political dimensions in both rural and urban settings. The Plan links with plans in other sectors, The Plan is informed by good examples of the activities in other jurisdictions The Plan takes into consideration local social and economic demographics (unemployment rate/job creation, vacancy rate/housing starts, shelter statistics, labour market information, housing information, local census data) PROJECT CHANGES – Procedures to change the Scope, Deliverables, etc. on this project Outline the steps to change any major aspect of this project Document1 Steps required to change any major aspect of this project include: The Steering Committee must approve any major changes to project implementation that will affect the project e.g. new deliverables, extended timelines, broaden scope, etc. The Consultant is responsible for executing the project in accordance with the RFP. The Consultant will require Steering Committee approval for any changes in the direction of the project that are outside of what is outlined in the Project Definition Document. Page 3 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD The Project Leader will keep the Steering Committee apprised of delays, cost changes and required scope changes to the project. PROJECT GOALS & OBJECTIVES: The Plan must meet specific provincial directions which include: Establish increased accountability and outcomes Goal of ending homelessness Engage and support of Non-Profit Housing Corporations and Co-operatives Engage the private market including promoting and supporting secondary suites Improve integration of housing and homelessness plans and services with other human services planning and delivery resulting in better outcomes for individuals and families Allow for a range of housing options to meet a broad range of needs Promote environmental sustainability and energy conservation Have safe, accessible places for people to live DELIVERABLES PERSON MOST RESPONSIBLE The Plan includes: Background Reports: Needs analysis - current and future housing needs for the City and County of Peterborough, including demographic trend analysis, social, economic and cultural considerations; identify gaps, performance measures Summarize current strengths in the housing and homelessness service system - what the municipality is currently doing, create service map, provide analysis City’s progress over last 10 years - City’s accomplishments, lessons learned Summary and analysis of existing documents Communication Strategy – Community Education and Engagement Plan, with phases appropriate to kick-off, consultations, and public education Scope for 10 Year Plan: Strategic Directions : need to align with provincial interests, demonstrate ‘made in Peterborough’ approach and be appropriate to financial circumstances Vision and Goals: based on theme of ‘Building from Strength” needs and background research Barriers/Obstacles: describe external influences outside municipal control Measures: Establish measurable outcomes, metrics, annual reporting, etc 3 Year Action Plan: The Action Plan is separate from the Plan, and includes funding implications and identifies priority actions, responsibility centres and community partners for the first three years of the Plan. Document1 Page 4 Last DRAFT: March 22, 2016 Consultant (assisted by community partners and City staff) DRAFT APRIL 2012 Housing and Homelessness Plan PDD Well Managed, Effectively targeted Consultation Process and Supervision of Consultant: RFP, hire consultant, contract, determine tasks for consultant and tasks for community partners and City Divisions; basic structure of report Document1 Page 5 Last DRAFT: March 22, 2016 Project Leader DRAFT APRIL 2012 Housing and Homelessness Plan PDD ROLES AND RESPONSIBILITIES Role STEERING COMMITTEE (Internal) Responsibility or Accountability The Steering Committee governs decision making and will: Malcolm Hunt (Chair) Susan Bacque Linda Mitchelson Ken Doherty Dorothy Olver Kim Beach Alex McLeod Angela Chittick (TBC) PROJECT TEAM Susan Bacque (Chair) Linda Mitchelon Dorothy Olver Suzie Johnson Rebecca Morgan-Quin (as of July 2012) Janet Sheward Sharron Hayton Paul Pentikainen Kathleen Williamson Ken Hetherington Iain Mudd (TBC) Kerri Kightly (TBC Document1 Oversee the project at specific milestones Ensure project meets objectives Determine project scope and scope changes Approve project schedule and any extensions of the project schedule Oversee Project Leader’s budget control - recommending any budget increases to the Project Sponsor and any necessary resource changes. Approve, own and promote the project within the Corporation Provide a forum for direction setting and clarification Receive reports from the Project Team Conduct a post-implementation review Add working groups based on recommendations from the Project Leader. Meet monthly for duration of project (through to June 2013) The Project Team manages the project and will: Drive the project to successful completion Provide regular progress reports to the Steering Committee Supervises and directs Consultant’s work Serve as a sounding board for issues and to ensure Project is on the right track Brainstorm on issues/challenges (example: how to engage the community) Recommend specific actions as challenges arise and changes to the project Call in technical support from subject matter experts Meet regularly, bi-monthly at first Page 6 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD SUBJECT MATTER EXPERTS Subject matter experts will be contacted: Social Services Building Public works Legal Police Housing Fire Finance Technology Services Planning Townships and County CE-LHIN School Board On an as-needed basis On specific issues where the Project Team relies on experts to clarify or provide necessary information. Recipients of City/County funding not elsewhere listed COMMUNITY INPUT (External) ** Regularly Scheduled Meetings: Clerks and Treasurers 8 townships and County Public Health Homeless Partnering Strategy Community Advisory Board Ptboro small landlords, PtboroRealtors, Ptboro Home Builders, Peterborough Seniors Planning Table, GPAEDC Friendship Center, 3 reserves Poverty Reduction Network (including Community Food Network and Basic Needs Group) Consultant will meet with existing committees 2 times each or as needed Obtain input and feedback in to process Review background report/recommendations and provide feedback Review draft Plan and provide feedback AHAC – monthly meeting HSSCC – monthly meeting Supportive Housing Network – monthly meeting Social Housing Providers - quarterly meeting Ad hoc Meetings Other External Contacts Executive Directors of human service organizations People with lived experience Participant at Open Table Tenants and shelter users Community advocates Faith groups Document1 Page 7 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD PROJECT SPONSORS Susan Bacque (Manager, Housing) Linda Mitchelson (Manager, Social Services) PROJECT CHAMPION Malcolm Hunt (Director, Planning) PROJECT LEADER Dorothy Olver to July 2012 TBD July 2012 to completion CONSULTANT Document1 The Project Sponsors provides the vision and leadership for the project: Initiates the project and is ultimately responsible for it Provides budget approval Promotes the project and the benefits it will achieve across the corporation Motivates the steering committee and project team Builds support for the project within Planning and Community Services “Owns” the plan when implemented. Champion of the project Educates Senior Admin Team on the importance of the project and their roles Keeps the Project on Senior Admin Team radar Elicits the assistance/engagement of the Senior Team as needed Builds support and commitment on Senior Team Directs day to day operation of the project Key contact for the Consultant Responsible to Project Steering Committee for budget control, scope control, and resource management Represents the department within the Steering Committee and the Project Team Makes [weekly, bi-weekly, monthly] reports to Project Steering Committee on project status Schedules update with the Steering Committee Develops and maintains project plan Brings issues to the attention of the Project Sponsor Educate The role of the Consultant includes, but is not limited to: Create and implement an approach/strategy for consultation and communications Lead research for Background Reports and create reports Develop the Plan and 3 year Action Plan Accountable to Project Leader with reports to the Steering Committee Report and present to Senior Admin and Council Page 8 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD CONSTRAINTS & ISSUES: Are there constraints or issues existing on the project, or on the planning for the project? Description Mitigating Action Lack of dedicated staffing resources – given Hire a consultant to complete the background the scope and magnitude of the project and given research, consultations and final report. the uncertainty that exists in information gaps, staff resources may be required. Engaging existing staff and Council who are Strategically plan for the involvement of key staff at already busy – existing staff involvement will be critical points in the project to minimize their time key in all phases of the project. commitment through the use of subject matter experts. Commitments extending beyond Council Maintain focus on strategic, high level vision, create cycle – term of Council is to 2014 but the Plan shorter term “Action Plans” which better correspond extends to 2024 to Council cycles Engaging the community – the community Need to develop and implement a well-designed needs to be engaged or the plan will not succeed community engagement and communication strategy. for implementation Provincial Guidelines/direction – the provincial Access opportunities for sharing ideas and interests and plan requirements outlined in the brainstorming issues at sessions provided by the Housing Services Act and the Housing Policy Ministry and OMSSA (OMSSA Resource Centre), as Statement are not clearly or concisely defined by well as involvement in OMSSA Housing and the Ministry Homelessness Networks. Provincial interests may require actions and/or Proactively identify what they are in the Plan and participation which are outside the influence or outline strategies to address them. control of the municipality. Macro-economic climate is unfavourable to Involve decision makers at appropriate intervals plan development [rethink wording of this point] RISKS – Project risks are characteristics, circumstances or features of the project environment that may have an adverse effect on the project or the quality of the deliverables. (Whereas a constraint or issues is a current problem that must be dealt with, a risk is a potential problem that has not yet occurred.) Risk Area Level Risk Mitigation Plan (H/M/L) High expectations that the Plan will solve all Med Within the Plan, identify the issues that the housing and homelessness issues. Plan is intended to solve and the issues that the Plan will not solve – have sections in the Plan to deal with this. Effective communication within and outside the Plan. Perception that funding will come with the High Identify any funding implications in the 3-year Plan and the Plan cannot be implemented Action Plan. without funding. Political division if there are contentious High Updates to Council and community on the issues within the Plan, making it more project so they have a sense of ownership. challenging for Council support. Create positive momentum around the Plan’s successes. Ensure strategic communications are conducted related to the Plan development and roll out. A lack of inter-departmental understanding Med Communication strategy for interabout the Plan that may affect project buydepartmental communication. Help in. Departments understand the relevance of the Plan to their work and how the Plan will benefit them. DEPENDENCIES: (This section will outline the dependencies that this project has that are outside of the scope of this project) Document1 Page 9 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD Phase 1 Program Consolidation of Housing and Homelessness Programs will be effective January 1, 2013. Throughout 2012, more information will be received about what this will look like and implications for our community (funding level, local flexibility). The Ministry is also hosting focus groups with service providers. The new program funding is a critical component to the resources available for the Plan. Housing Services Act was enacted in 2011. The new legislation provides greater flexibility to Service Managers, however requires new local rules and directives and a review of the centralized waiting list. The local rules need to be created with housing and homelessness in mind. Planning Act – The City of Peterborough Planning Department has released the Community Improvement Plan (CIP) for Affordable Housing that provides funding incentives for the development of affordable housing in Peterborough. CIP’s need to be considered in the development of the Plan. Expiry of Operating Agreements: Social Housing Providers operating agreements are due to expire over the next several years. At the same time, the HSA requires the Service Manager to maintain service level standards that are now embedded in the Act. The expiry of operating agreements will need to be addressed in the 10 year plan. Expiry of Affordable Housing Programs: Affordable Housing programs will expire in 2013 as well as the Investment in Affordable Housing Program (2015) that will result in the end of rent supplement programs, repair programs, affordable housing construction and home ownership loan assistance. The potential absence of these programs must be considered in the development of the Plan. Provincial Housing Policy Statement sets provincial interests that may require actions and/or participation of other organizations or entities that are outside of the influence or control of the municipality (e.g. other Ministries, private sector, etc). The Plan will need to contain a section that addresses these dependencies. Document1 Page 10 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD PROJECT COMMUNICATIONS PLAN Author What Throughout All Project Phases Project Leader and Initial orientation of Steering Committee Consultant (Project followed by written project status reports Sponsors will likely lead communication related to the orientation phase) Project Leader Initial orientation of Project Team on the (occasionally Project Project followed by verbal and written Sponsors) updates on the progress of the Project Any Team Member Communication of Project changes, issues, etc. verbally, in writing, via phone, email etc. Project Steering Communication of Project Vision, Scope, Committee Priorities to ensure the importance of the Communication Project is widely understood and to material to be encourage staff support and involvement developed by the Project Leader Project Team Communication of Project details, progress, importance etc. to ensure positive momentum for the Project Consultant Develop and implement a Community Engagement and Communication Plan to achieve the following objectives: - Engage key community stakeholders in the Plan - Report to Sr. Staff and Council on the Plan - Promote and encourage participation in community consultation - Generate enthusiasm and commitment to the process and contents of the Plan - Communicate progress on the development of the Plan Develop responses and key messages suited to stakeholder reactions The Community Engagement & Communication Plan must include: - The identification of key messages - Key communication milestones (i.e. updates to stakeholders, presentations of Plan etc.) - Plans/details for the Project Kick Off (i.e. with HSSCC, AHAC, JSSC, Council etc.) - Identification of the key components of the Plan that require consultation and the strategies/mechanisms/ time lines for conducting the consultations - Strategies for disseminating information via website, media releases, displays at events, advertising etc. Document1 Page 11 Last DRAFT: March 22, 2016 When To Whom At each monthly meeting Project Steering Committee Twice monthly Project Team Any time Project Leader Ongoing To other Senior staff and reporting staff Ongoing To other City staff, key stakeholders To be detailed in the Engagement & Communicati on Plan being developed by the Consultant May 2012 for completion of Engagement & Communication Plan (E&C Plan) E&C Plan will then be implemented throughout the Project as outlined in the E&C Plan DRAFT APRIL 2012 Housing and Homelessness Plan PDD TEAM OPERATING AGREEMENT: The Steering Committee will do the utmost to ensure that everyone is kept up to date with the status of the project. This will be accomplished with regular status meetings, a work plan, and a clear list of what tasks are outstanding and who is responsible for them. The Steering Committee will resolve project issues that cannot be solved at other levels. The Project Leader will schedule meetings on a regular and timely basis. The agenda will be provided a minimum of 48 business hours prior to the meeting. The Project Leader will distribute meeting minutes in a timely manner following each meeting. The Project Leader will ensure that all Team members are copied on all correspondence related to significant changes, delays, etc in the project. Roles and responsibilities for team members and committees have been identified in the Roles and Responsibilities section. All Committee members are encouraged to exchange views in a respectful environment. Decisions will be reached based on a consensus of the team; otherwise they will be referred to the Steering Committee for a decision. ASSUMPTIONS: Assumptions that will be built into the Plan include: Housing continuum: The plan must cover the spectrum from homelessness to home ownership (Homelessness, emergency shelters, transitional housing, supportive housing, social housing, subsidized rental, private market rental and home ownership) and address the broad range of needs in the community (accessibility, special priority, aboriginal peoples living off-reserve, seniors, youth, etc.). A low-key communications and targeted consultation approach is required. A progressive, incremental approach to gain buy-in and support is required for the community, as well as for the City’s internal stakeholders. Consultant services are necessary to lead the Plan development – RFP, selection, contract and monitoring. Staffing Resources – a staff member as a lead to oversee the work of the Consultant and ensure project time lines are being met; staff members to be part of the Steering Committee and Project Team. BUDGET AND FINANCIAL MANAGEMENT OF THE PROJECT: The Steering Committee will review, discuss and approve the project plan, expenditures, and financial reports prepared by the Project Leader. The Steering Committee will be accountable for decisions taken on the project. The Project Leader will monitor and approve the expenditures for the project. The Project Leader will prepare the project plan and estimate the costs associated with the required resources and timetables, and approve payments under the contracts. The Project Leader will be accountable to the Steering Committee for regular financial reporting which, at a minimum, should include the total budget, planned expenditures, committed expenditures, and total spent to date. Document1 Page 12 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD ESTIMATED RESOURCE & BUDGET REQUIREMENTS Staff name and division, business unit and/or external Org.; Hardware, Software, etc. Consultant Public consultation Staffing to manage the process Tech support Time (workdays) Skills / Expertise / Role Research, presenting writing, consulting, Room rental, refreshments Project management Data bases, maps, communications, etc @$850/day 120 days Estimated $$ $102,000 $2,000 web $2,000 $4,000 $4,000 $3,000 Materials and supplies Printing/distribution Travel OPERATING VS CAPITAL BUDGET Capital $ Contingency % Operating $ Contingency % Misc $ Approved Required Project Total $ City GL Account # $117,000 PUSI JC # PROJECT SCHEDULE - OVERVIEW Date Project Requested Start Date Target Completion Date Mandatory Completion Dates June 2012 July 2012 June 2013 March 2013 – Plan to JSSC June 2013 – Plan to Council for approval June 2013 – Plan to MMAH for comment PROJECT SCHEDULE - SPECIFICS PDD Final June 5, 2012 PDD Review City and County PDD Approved JSSC : June 14 2012 Committee of the Whole/City Council: June 18, 2012 RFP Draft July, 2012 RFP Approved and Issued July, 2012 Consultant selected August, 2012 Identification and June, 2012 Orientation of Team Members Orientation and Introduction August 15 to Sept 1, 2012 of Consultant Clarifying/Work through with Ongoing Ministry and other Service Managers Project Requirements Background Reports Needs Analysis Fall 2012 Review of existing Plans Fall 2012 (City and County) – do a summary and analysis Progress of last 10 years Fall 2012 Document1 Page 13 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD Document of Inventory of Fall 2012 existing housing and homelessness programs and services Plan Framework Develop the Plan Sept – Nov 2012 (Framework, looking at examples of other similar plans) Develop Vision, Goals, Oct 2012 Strategic Directions and Measures Analysis of dependencies, Nov 2012 limitations, barriers Communication Plan Sept 2012 Kick-off During consultations Public release and Plan circulation Communication Material – Sept 2012 content and production Plan Development Write the Draft Plan and a Fall – Winter 2012 3-year Action Plan Graphics, pictures, layout, Winter 2012 design for the plan and communication material Consult on Draft Plan – Winter 2012 Presentation at City October 2012 Directors Presentations at existing Participation of City staff and consultant in up to 15 community committees community committees (cited earlier), some to be attended twice Convene broad, local human services Executive Director’s forum Plan Revisions Plan Revisions based on consultations Winter 2012/13 Final Plan Presentation to City Directors January 2013 Final Plan completed February2013 Management Approvals JSSC Agenda setting February 2013 City Administration Committee meeting March 2013 County/City Approvals JSSC meeting June 2013 C of Whole meeting June 2013 Council meeting June 2013 Ministry of Municipal Affairs and Housing (MMAH) Approved Plan sent to MMAH for comment July 2013 Print and Distribution of the Approved Plan Plan for printing and Fall 2013 distributing the final, approved Plan Document1 Page 14 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD PDD REVIEW DATES: Project to be reviewed by the Project Steering Committee and Core Team 1st Review Date yy mmm dd 2nd Review Date yy mmm dd 3rd Review Date High High High Medium Medium Medium Low Low Low Resubmit Resubmit Resubmit Decline Decline Decline yy mmm SIGN OFF APPROVED FOR PLANNING SIGNATURE PROJECT LEADER: PROJECT SPONSOR: STEERING COMMITTEE REPRESENTATIVE: Document1 Page 15 Last DRAFT: March 22, 2016 DATE dd DRAFT APRIL 2012 Housing and Homelessness Plan PDD Appendix A: List of Existing Housing and Homelessness Related Reports or Documents Building Condition Assessment Report for Social Housing (2010) Community Conversations Homelessness Report (2011) Draft Housing Strategy (2010) Emergency and VAW Shelter service statistics Federal Homelessness Partnering Strategy Community Plan (2011-2014) Hostel Review (2009) Housing Access Peterborough (multi-year statistics on social housing waiting list) Housing is Fundamental (annual report) Housing Needs Study (2005) Housing Resource Centre service statistics Residential Monitoring Report (2011) Social Housing Reporting (ie SMAIR and AIR) Taking Charge (2003) With a Little Bit of Help (2008) Appendix B: List of Other Sector Plans Document1 Page 16 Last DRAFT: March 22, 2016 DRAFT APRIL 2012 Housing and Homelessness Plan PDD Community Improvement Plans (2011) GPAEDC Strategic Plan for Economic Development (2010-2014) Municipal Cultural Plan (2011) Official Plan (2009) Peterborough Drug Strategy (draft 2012) Peterborough Healthy Communities Partnership Report (2010), Peterborough Partnership Council on Immigrant Integration – Integration Strategy (2010-2015) Peterborough Poverty Reduction Network Plan (2011) Sustainable Peterborough Plan (Draft 2012) Development Charge studies, work force planning trends Document1 Page 17 Last DRAFT: March 22, 2016