2012-2013
Departmental Performance Report - Supplementary Information Tables
Horizontal Initiatives
- Canada Strategic Infrastructure Fund (CSIF)
- Border Infrastructure Fund (BIF)
- Municipal Rural Infrastructure Fund (MRIF)
- Building Canada Fund (BCF)
Canada Strategic Infrastructure Fund (CSIF)
1. Name of Horizontal Initiative: Canada Strategic Infrastructure Fund
2. Name of Lead Department: Infrastructure Canada
3. Lead Department Program Activity: Canada Strategic Infrastructure Fund
4. Start Date: 2003-2004
5. End Date: 2016-2017
6. Total Federal Funding Allocation (from start date to end date): $4.3 Billion1
7. Description of the Horizontal Initiative (including funding agreement):
The CSIF, which received funding in the 2001 and 2003 federal budgets, is a cost-shared contribution program for strategic infrastructure projects. To date, funding has been approved to support 75 projects.
Investments are directed to projects of major national and regional significance and are to be made in areas that are vital to sustaining economic growth and supporting an enhanced quality of life for Canadians. The CSIF is delivered through negotiated agreements with provincial, territorial or local governments, private partners or non-governmental organizations. Contribution agreements are tailored based on the project requirements.
The Canada Strategic Infrastructure Act outlines the prime categories of investments in projects that involve fixed capital assets that are used or operated for the benefit of the public. The categories eligible under the Canada Strategic Infrastructure Fund are:
- Highway and Rail Infrastructure;
- Local Transportation Infrastructure;
- Tourism or Urban Development Infrastructure;
- Water or Sewage Infrastructure; and
- Other categories approved by regulation, e.g. Advanced Telecommunications and High-Speed Broadband, Northern Infrastructure.
8. Shared Outcome(s):
The overall planned results Infrastructure Canada expects to achieve through CSIF are to invest in projects which:
- facilitate the movement of goods and people on Canada's National Highway System for the purposes of increasing the productivity, economic efficiency, and safety of Canada's surface transportation system;
- facilitate the safe and efficient movement of goods and people, ease congestion, or reduce greenhouse gases and airborne pollutants;
- ensure that tourism continues to contribute to the economic well-being of Canadians and to serve as a bridge between Canada and the world;
- ensure that drinking water is safe, clean and reliable at drinking water facilities, and ensure sustainable treatment of wastewater; and expand broadband networks in Canada.
9. Governance Structure:
All CSIF projects are selected under the authority of the Minister of Infrastructure, Communities and Intergovernmental Affairs. Prior to selecting projects, the Minister consults other Ministers who have an interest in the region or in the substantive project area. After project selection, Treasury Board approval is sought for each contribution. At the same time, incremental operating funds required for project oversight and management by the implementing departments/agencies are identified and sought in the Treasury Board submission.
The fund is delivered in partnership involving primarily three sets of key collaborators:
- Infrastructure Canada: As the coordinating and funding agent for the contribution, Infrastructure Canada is responsible for project review, selection, approval, public announcements, environmental assessment in some cases, and program evaluation. It leads the negotiation of contribution agreements with each of the funding recipients, except for transportation projects where Transport Canada is the lead. Infrastructure Canada (or Transport Canada, for transportation projects) develops, in coordination with the implementing department/agency, the submission to Treasury Board for the approval of funds. Infrastructure Canada is also responsible for the overall management of program funding, for seeking appropriation of funds from Parliament through Contribution Votes and for transferring funds to the federal delivery partners. Over the past two years, Infrastructure Canada has taken over responsibility for the management of agreements for most projects.
- A federal delivery partner: Infrastructure Canada's relationship with each federal delivery partner varies with the capacity and the complexity of the project. Infrastructure Canada has repatriated projects from most delivery partners and at this point, only Transport Canada and Atlantic Canada Opportunities Agency (ACOA) are responsible for actively managing contribution agreements on Infrastructure Canada's behalf. A Memoranda of Understanding govern the relationship between Infrastructure Canada, Transport Canada and ACOA for the implementation of CSIF projects. TC and ACOA support the implementation of CSIF projects in a manner that upholds federal due diligence in such areas as overseeing the implementation of mitigation measures identified in the environmental assessment, assessing the eligibility and reasonability of project costs, providing information pertaining to cash flow and budget, approving claims, making payments, and conducting audits and evaluation of projects. TC and ACOA serve as the federal co-chair of the project's Agreement Steering Committee and also ensure adherence to information management requirements, including the use of the Shared Information Management System for Infrastructure, which is used to capture, monitor and report on project information. TC and ACOA also provide communication support.
- The funding recipient: The recipient may be a provincial, territorial, or local government, a private partner, a non-government organization, or a combination thereof. Once the project has been selected, Infrastructure Canada or Transport Canada leads the negotiations to develop a contribution agreement. The funding recipient is responsible for ensuring that the project is completed as per the Terms and Conditions of the Contribution Agreement.
10. Performance Highlights:
In 2012-2013 Infrastructure Canada:
- Collaborated with project recipients to continue the implementation of the projects funded under the Canada Strategic Infrastructure Fund (CSIF); and
- Aligned program terms and conditions with the federal government's Transfer Payment Policy.
11.-18. Program Activity: Canada Strategic Infrastructure Fund
19. Comments on Variances: Actual Spending in 2012-2013 was lower than forecasted as spending is dependent on a number of factors beyond the control of funding recipients. These factors range from lower than anticipated project costs to project delays resulting from inclement weather and from technical and other construction-related complexities that also cause construction delays.
20. Results Achieved by Non-Federal Partners (if applicable): N/A.
21. Contact Information: Claude Blanchette, Director General, Program Integration, Tel: (613) 948-9392, E-Mail: claude.blanchette@infc.gc.ca.
Border Infrastructure Fund (BIF)
1. Name of Horizontal Initiative: Border Infrastructure Fund (BIF)
2. Name of Lead Department: Infrastructure Canada
3. Lead Department Program Activity: Border Infrastructure Fund
4. Start Date: 2003-2004
5. End Date: 2015-2016
6. Total Federal Funding Allocation (from start date to end date): $600 Million2
7. Description of the Horizontal Initiative (including funding agreement):
The BIF, which was announced in Budget 2001, is a cost-shared contribution program. It complements some of the Government of Canada's other infrastructure programs such as the Canada Strategic Infrastructure Fund and the Strategic Highway Infrastructure Program, a Transport Canada program.
As part of "Canada's commitment to address land border pressures, such as traffic congestion and to continue to facilitate the large volume of trade across the Canada-United States border",
the BIF contributions are directed at or on routes leading to Canada's border crossings, with a particular focus on the six largest:
- Windsor, Ontario;
- Sarnia, Ontario;
- Fort Erie, Ontario;
- Niagara Falls, Ontario;
- Douglas, British Columbia; and
- Lacolle, Quebec.
The fund also directs some funding toward smaller and regionally important border crossings throughout Canada. Once completed, projects supported under BIF will help alleviate traffic congestion, increase system capacity and further the Smart Border Declaration (a Canada-US Declaration; see North American Partnerships).
8. Shared Outcome:
The overall planned results expected to achieve through BIF are to invest in projects that contribute to safe and efficient border crossings. Expected outcomes are to alleviate border congestion and increase border crossing capacity and to increase security and safety at border crossings, leading to cross border trade efficiencies.
9. Governance Structure:
All BIF projects are selected under the authority of the Minister of Infrastructure, Communities and Intergovernmental Affairs. Prior to selecting projects, the Minister consults with other Ministers who have an interest in the region or in the substantive project area. After project selection, public announcements are made by the Minister of Infrastructure, Communities and Intergovernmental Affairs Treasury Board approval is sought for each contribution. At the same time, incremental operating funds required for project oversight and management by Transport Canada, which implements these projects on Infrastructure Canada's behalf, are identified and sought in the Treasury Board submission.
The fund is delivered in partnership involving primarily three sets of key collaborators:
- Infrastructure Canada: As the coordinating and funding agent for the contribution, Infrastructure Canada is responsible for project review, selection, approval, public announcements, environmental assessment (in some cases) and program evaluation. It also coordinates with Transport Canada, the submission to Treasury Board for the approval of funds. Infrastructure Canada is also responsible for the overall management of program funding, for seeking appropriation of funds from Parliament through the Contribution Vote and for transferring funds to Transport Canada.
- Transport Canada: An umbrella Memorandum of Understanding governs the relationship between Infrastructure Canada and Transport Canada for the implementation of BIF projects. Transport Canada may provide technical assistance in the analysis of the business case, determining the costs and benefits to be realized, and leads the development of the contribution agreement and Treasury Board submission. Transport Canada will support implementation of BIF projects in a manner that upholds federal due diligence in such areas as overseeing the implementation of mitigation measures identified in the environmental assessment, assessing the eligibility and reasonability of project costs, providing information pertaining to cash flow and budget, approving claims, making payments, and conducting audits and evaluation of projects. Transport Canada serves as the federal co-chair of the project's Agreement Steering Committee. Transport Canada also ensures adherence to information management requirements, including the use of the Shared Information Management System for Infrastructure, which captures, monitors and reports on project information.
- The funding recipient: The recipient may be a provincial, territorial, or local government, a private partner, a non-government organization, or a combination thereof. Once the project has been selected, Transport Canada leads the negotiations to develop a contribution agreement. The recipient is responsible for ensuring that the project is completed as per the Terms and Conditions of the Contribution Agreement.
10. Performance Highlights:
In 2012-2013 Infrastructure Canada:
- Continued to work closely with Transport Canada to monitor the implementation of infrastructure projects at border crossing under the BIF; and
- Aligned program terms and conditions with the federal government's Transfer Payment Policy.
11.-18. Program Activity: Border Infrastructure Fund
($ millions)
11. Federal Partners | 12. Federal Partner Program Activity | 13. Names of Programs for Federal Partners | 14. Total Allocation (from start date to end date) | 15. Planned Spending for 2011-12 | 16. Actual Spending for 2011-12 | 17. Expected Results for 2011-12 | 18. Results Achieved in 2011-12 |
---|---|---|---|---|---|---|---|
1. Transport Canada | PA1 | a. | $604.1 | $35.9 | $7.4 | Transport Canada will continue to serve as the lead partner in the management of projects throughout the country that deal with highways and other major transportation infrastructure and is planning to complete one physical infrastructure project during the fiscal year 2012-2013 in Ontario. | Infrastructure Canada worked closely with Transport Canada to monitor the progress of ongoing projects. As of March 31, 2013, nine projects under the fund have been completed. |
Transport Canada Total | $604.1 | $35.9 | $7.4 |
19. Comments on Variances: Transportation projects funded under the BIF are large and complex by nature which makes them at higher risk of experiencing unexpected delays during their implementation. During 2012-2013, projects faced delays due to various reasons from technical and other construction-related complexities. It is also important to note that the disbursement of federal contributions follows the actual construction of projects as recipients are reimbursed for incurred expenditures only once they submit claims.
20. Results Achieved by Non-Federal Partners (if applicable): N/A.
21. Contact Information: Claude Blanchette, Director General, Program Integration, Tel: (613) 948-9392, E-Mail: claude.blanchette@infc.gc.ca.
Municipal Rural Infrastructure Fund (MRIF)
1. Name of Horizontal Initiative: Municipal Rural Infrastructure Fund (MRIF)
2. Name of Lead Department: Infrastructure Canada
3. Lead Department Program Activity: Municipal Rural Infrastructure Fund
4. Start Date: 2004-2005
5. End Date: 2013-2014
6. Total Federal Funding Allocation (from start date to end date): $1.2 Billion3
7. Description of the Horizontal Initiative (including funding agreement):
The $1.2 billion MRIF has been structured to provide a balanced response to local infrastructure needs in urban and rural Canada and will ensure that all Canadians, whether they live in large, small or remote communities, will share in the benefits of infrastructure investments.
The fund improves and increases the stock of core public infrastructure in areas such as water, wastewater, culture, recreation. It targets communities of less than 250,000 residents as well as First Nation communities. Like other infrastructure programs, MRIF seeks to ensure that the projects it funds support the goals of the Government of Canada, encourages new and innovative approaches and favours partnerships, including an emphasis on 'green' projects which are sustainable and reduce greenhouse gases.
Through MRIF, the Government of Canada continues to work in productive partnerships with provinces, territories, and municipalities, as well as First Nations and the private sector to invest in local infrastructure projects. These projects will be vital to sustaining economic growth and supporting an enhanced quality of life in Canadian communities.
The fund is cost-shared with the Government of Canada contributing, on average, one-third of total project eligible costs. Provinces and municipalities contribute the remainder of these costs. In recognition of the unique circumstances of the First Nations and the Territories, where many communities have no tax base, the Government of Canada may contribute a higher percentage of total project eligible costs.
8. Shared Outcome:
The overall expected outcomes are:
- Improved and increased core public infrastructure in areas such as water, wastewater, culture and recreation; and
- Improved quality of life and economic opportunities for smaller communities and First Nations.
9. Governance Structure(s):
The MRIF is based on a federal partnership arrangement between Infrastructure Canada and five federal partners: Western Economic Diversification, Economic Development Agency of Canada for the Regions of Quebec, the Atlantic Canada Opportunities Agency, Federal Economic Development Agency for Southern Ontario, and the Canadian Northern Economic Development Agency. It involves 14 sub-programs, one joint sub-program for each province and territory, and a sub-program for First Nations communities. Each of the 14 sub-programs follows the same general conditions, priorities and approaches. Also, recognizing the individual nature of each sub-program, the various agreements reflect the nature of the partnership as it relates to the order of government.
To affect expected outcomes, MRIF eligible projects must conform to a policy leveraging framework based on a common baseline, but adapted for each jurisdiction. To ensure broad support and effective, innovative project delivery, partnerships of various types, including public-private partnerships are encouraged in the formulation and delivery of the fund projects. The program relies on strong input from local and rural municipalities, including the support of the locally elected councils. In addition, municipal representatives are involved in the processes and management of the program in the respective province or territory.10. Performance Highlights:
In 2012-2013 the Department:
- Collaborated with Federal Delivery Partners and provinces to oversee construction and completion of approved projects.
- Collaborated with Federal Delivery Partners and provinces towards the completion of the program in all jurisdictions.
11.-18. Program Activity: Municipal Rural Infrastructure Fund
19. Comments on Variances: Program spending in 2012-2013 was lower than planned. This can be attributed to a number of factors beyond the control of funding recipients. These factors range from lower than anticipated project costs to project delays resulting from inclement weather and from technical and other construction-related complexities that can lead to construction delays. As the program is sunsetting, all funds must be disbursed by Infrastructure Canada by the end of fiscal year 2013-2014.
20. Results Achieved by Non-Federal Partners (if applicable): N/A.
21. Contact Information: Claude Blanchette, Director General, Program Integration, Tel: (613) 948-9392, E-Mail: claude.blanchette@infc.gc.ca.
Building Canada Fund (BCF)
1. Name of Horizontal Initiative: Building Canada Fund
2. Name of Lead Department: Infrastructure Canada
3. Lead Department Program Activity: Building Canada Fund-Communities Component and Building Canada Fund-Major Infrastructure Fund
4. Start Date: 2007-2008
5. End Date: 2016-2017
6. Total Federal Funding Allocation (from start date to end date): $8.8 Billion4
7. Description of the Horizontal Initiative (including funding agreement):
The Building Canada Fund focuses on projects that deliver economic, environmental and social benefits to Canadians.
The national priorities for funding are the core National Highway System, drinking water, wastewater, public transit and green energy. Other eligible categories include projects that support economic growth and development (short-line rail and short-sea shipping, connectivity and broadband, tourism and regional and local airports), environmental projects (solid waste management), as well as projects that contribute to the ongoing development of safe and strong communities (disaster mitigation, culture, sport, recreation, local roads and bridges, and brownfield re-development). Funding is used to support public infrastructure owned by provincial, territorial and municipal governments and entities, as well as the non-profit sector and private industry, in certain cases.
Funding is allocated for projects in the various provinces and territories based on their population (as of the 2006 Census). In the provinces, the program operates through two components: the Major Infrastructure Component and the Communities Component. In the territories, in recognition of their very low per capita allocations, the Building Canada funding has been rolled into the Provincial-Territorial Infrastructure Base Fund program and is managed under the terms of this latter program in each territory.
The Major Infrastructure Component (BCF-MIC) targets larger projects of national and regional significance. Under this component, two-thirds of national funding is directed to the above-mentioned national priorities. Projects under the BCF-MIC are selected jointly through a federal-provincial/territorial negotiation process with all projects required to meet minimum federal eligibility criteria.
The Building Canada Fund-Communities Component (BCF-CC) focuses on projects in communities with populations of less than 100,000. Projects are selected through an application-based process and, like projects under the BCF-MIC, are evaluated on the extent to which they meet minimum federal eligibility criteria. This will significantly help smaller communities to address their infrastructure pressures, and serve as a complementary instrument to the Gas Tax Fund.
More information on the Building Canada Fund can be found on Infrastructure Canada's website.
8. Shared Outcome:
The expected outcomes are to deliver results that matter to Canadians, including cleaner air and water, safer roads and shorter commutes, while supporting broad federal priorities of a stronger economy, cleaner environment and better communities.
9. Governance Structure:
i. BCF-MIC
BCF-MIC is delivered in partnership involving primarily three sets of key collaborators:
- Infrastructure Canada: As the coordinating and funding agent for the contribution, Infrastructure Canada is responsible for assessing potential priorities, undertaking the detailed review of identified priorities against program terms and conditions, and recommending projects for approval-in-principle to the Minister. Infrastructure Canada is also responsible for public announcements, environmental assessment in some cases and program evaluation. For non-transportation projects, in addition to the above, Infrastructure Canada is responsible for the preparation of Treasury Board submissions (where required), the negotiation of contribution agreements with each of the funding recipients and the oversight of these agreements. To monitor activities and milestones throughout the project life cycle, an Infrastructure Canada representative sits on the project's Agreement Steering Committee. Infrastructure Canada oversees the implementation of mitigation measures identified in the environmental assessment, assesses the eligibility and reasonability of project costs, monitors information pertaining to cash flow and budget, approves claims, make payments, and conducts audits and evaluations of the projects. Infrastructure Canada will use the Shared Information Management System for Infrastructure (SIMSI) database, to capture, monitor and report project information.
- Transport Canada: For transportation projects, Transport Canada drafts a project review/due diligence for Infrastructure Canada's review (except Public Transit Infrastructure projects, where Infrastructure Canada is solely responsible for reviewing transit projects), prepares any required Treasury Board submissions and leads the negotiations of contribution agreements. Transport Canada monitors activities and milestones throughout the project life cycle, and nominates federal representatives to sit on projects' Agreement Steering Committees. Transport Canada oversees the implementation of mitigation measures identified in the environmental assessment, assesses the eligibility and reasonability of project costs, monitors information pertaining to cash flow and budget, approves claims, makes payments, and conducts audits and evaluations of the projects. Transport Canada will also ensure adherence to Infrastructure Canada's information management requirements, including the use of Infrastructure Canada's Shared Information Management System for Infrastructure (SIMSI) database, which captures, monitors and reports project information. Transport Canada also provides communication support to Infrastructure Canada.
- The funding recipient: The recipient may be a provincial, territorial or local government, a private partner, a non-government organization or a combination thereof. The recipient is responsible for ensuring that the project is completed as per the Terms and Conditions of the Contribution Agreement, and is also responsible for the ongoing operation and maintenance of the asset.
ii. BCF-CC
BCF-CC is governed by separate federal-provincial contribution agreements, each of which is managed by an Oversight Committee that includes both federal and provincial senior officials. To support the operation of the Communities Component and Oversight Committees, each jurisdiction has a federal-provincial Joint Secretariat staffed by Federal Delivery Partners and provincial officials. The federal co-chair of the Oversight Committee is a senior official from Infrastructure Canada appointed by the Minister.
All project applications under the BCF-CC are subject to a competitive application-based process. This process is administered by the Joint Secretariat, but a material role for the respective provincial municipal association (for those provinces that have municipal associations) may also have been established as part of the application review process. Allowing some implementation flexibility to the Joint Secretariats and Oversight Committees, all competitive processes issue calls for applications (either one open window for applications or multiple shorter windows with set closing dates). Some provinces may limit the number of applications per community within and/or across all intakes.
Joint Secretariats provide the first level of due diligence, including engineering, environmental, and legal review of the applications and prepare briefing material for the Oversight Committees. The Oversight Committees review and rank the application against the mandatory and additional leveraging criteria established in the Policy Leveraging Framework of the Building Canada Fund. The Oversight Committee presents the recommended list of projects to the Minister or the Federal Delivery Partner Minister for consideration, in accordance with the delegations of authority. After consulting with other Ministers who have a mandate in the substantive project area, the Minister or the Federal Delivery Partner Minister provide feedback on the list of projects to the Oversight Committee. The Oversight Committee then performs a final review of the list and makes a recommendation to the appropriate Minister, in accordance with the delegations of authority. Federal funding for projects is announced once final approval has been granted in writing.
In the federal-provincial contribution agreement, the parties agreed to establish a Joint Secretariat to support the Oversight Committee and administer BCF-CC. This secretariat is staffed by officials from the provincial government and the Federal Delivery Partner.
10. Performance Highlights:
Under the BCF-MIC, Infrastructure Canada has continued to work with federal and provincial partners to expeditiously identify, approve and fund projects in the key national priority areas of water, wastewater, public transit, the core National Highway System and green energy, as well as in other eligible categories of investment. The implementation of each project-specific funding agreement is being conducted in a streamlined manner to ensure that the terms of agreements are respected while claims for payment are processed efficiently.
Under BCF-CC, Infrastructure Canada and Federal Delivery Partners focused on completing all activities for the Top-Up funding provided to the program under the 2009 Economic Action Plan. As of April 1, 2012, the partners also continued with the implementation of the BCF-CC with provinces in support of 258 projects nation-wide dealing with wastewater treatment, potable water, local roads and other infrastructure needs.
11.-18. Program Activity: Building Canada Fund
19. Comments on Variances: The BCF-MIC program provides significant funding for large, complex projects. It is typical for these projects to require a significant amount of upfront planning, design and procurement. These processes may occur, in whole or in part, after funding commitments are announced. As a result, there is often a period of time that will pass between project announcements and when construction starts. Even when construction has started, a number of factors beyond the control of funding recipients can result in lower spending than forecasted. These factors range from lower than anticipated project costs to project delays resulting from inclement weather and from technical and other construction- related complexities that also cause construction delays. It is also important to note that actual spending lags behind the actual rate of construction of projects since recipients are reimbursed only once claims are submitted, even though eligible costs may have already been incurred.
The BCF-CC program provides funding for unique infrastructure pressures facing smaller communities. Program spending can be lower than planned. This can be attributed to a number of factors beyond the control of funding recipients. These factors range from lower than anticipated project costs to project delays resulting from inclement weather and from technical and other construction-related complexities that can lead to construction delays. It is also important to note that the disbursement of federal contributions follows the actual construction of projects as recipients are reimbursed for incurred expenditures only once they submit claims.
20. Results Achieved by Non-Federal Partners (if applicable): N/A.21. Contact Information: Claude Blanchette, Director General, Program Integration, Tel: (613) 948-9392, E-Mail: claude.blanchette@infc.gc.ca.
Notes
[1] Of the $4.3 billion originally allocated to the CSIF, approximately $50 million has been transferred to the Parks Canada Agency to support a high priority infrastructure project. These funds were reallocated through Main Estimates prior to 2012-2013. Column 14 of the table reflects the actual project funding delivered by federal delivery partners under the CSIF terms and conditions, as well as their associated administrative costs.
[2] Of the $600 million originally allocated to the BIF, approximately $18 million has been transferred to Canada Border Services Agency for border projects. These funds were reallocated through Main Estimates prior to 2012-2013.
As part of the 2010 Strategic Review, $10.4 million in unallocated funds from the Border Infrastructure Fund was identified for reallocation to other Government priorities. Prior to 2012-2013, $5.2 million was removed from departmental reference levels through the 2011-2012 Supplementary Estimates. An additional $5.2 million will be removed through the 2012-2013 Main Estimates, subject to Parliamentary approval. No projects have been cancelled or otherwise affected as a result of this reallocation.[3] As part of the 2010 Strategic Review, $23 million in unallocated funds from MRIF was reallocated to other Government priorities. These funds were removed from departmental reference levels through 2011-2012 Supplementary Estimates. No projects have been cancelled or otherwise affected as result of this reallocation. Column 14 of the table reflects the actual project funding delivered by federal delivery partners, under the MRIF terms and conditions, as well as their associated administrative costs.
[4] As a result of the 2010 Strategic Review, Infrastructure Canada is saving $5.4 million and $4.9 million by delivering the BCF-CC and BCF-MIC respectively, more efficiently. These funds are being removed from the Fiscal Framework and made available for other Government of Canada priorities. The funding for projects remains unchanged. Column 14 of the table reflects the actual project funding delivered by federal delivery partners, under the BCF terms and conditions, as well as their associated administrative costs.
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