Proposed redistribution Tasmania into electoral divisions

Updated: 5 May 2017

Chapter 1 Background and context

This chapter outlines the legislative requirements of the redistribution, ranging from the initial triggering of the process to the release of the proposed redistribution by the Redistribution Committee. The chapter explains how these requirements were met during the redistribution process, and also provides relevant information about Tasmania.

  1. A redistribution of electoral divisions is the process where electoral divisions and their names and boundaries are reviewed, and may be altered, to ensure, as near as practicable:
    • each state and territory gains representation in the House of Representatives in proportion to their population, and
    • there are a similar number of electors in each electoral division for a given state or territory.

    Compliance with legislative requirements

  2. The Commonwealth Electoral Act 1918 (the Electoral Act) specifies that a redistribution process should be undertaken when:
    • the number of members of the House of Representatives to which a state or territory is entitled has changed (population change),
    • the number of electors in more than one-third of the electoral divisions in a state (or one of the electoral divisions in the Australian Capital Territory or the Northern Territory) deviates from the average divisional enrolment by over ten per cent for a period of more than two months, or
    • a period of seven years has elapsed since the last redistribution process was determined.1
  3. The procedures to be followed in conducting a redistribution process are also specified in the Electoral Act. Appendix A summarises the legislative requirements which have been followed in conducting this redistribution. Each of these requirements is discussed in further detail in this chapter.

    Requirement to conduct a redistribution of electoral divisions in Tasmania

  4. Paragraph 59(2)(c) of the Electoral Act requires that a redistribution process commence when a period of seven years has elapsed since the last redistribution. As the last redistribution of Tasmania was determined on Monday 16 February 2009, a redistribution process was required to commence within 30 days of Tuesday 16 February 2016.2
  5. The federal redistribution of Tasmania was delayed due to the proximity of the commencement date to the expiration of the House of Representatives.

    Proximity of the commencement date to the expiration of the House of Representatives

  6. Sub-section 59(4) of the Electoral Act provided for the deferral of the redistribution process of Tasmania as:
    • the redistribution process was required because it had been seven years since the last redistribution was determined on Monday 16 February 2009, and
    • the commencement date was within one year before the date of expiry of the House of Representatives in the 44th Parliament on Friday 11 November 2016.
  7. Following this deferral, the redistribution process was required to commence within 30 days of the first meeting day of the new House of Representatives in the 45th Parliament.
  8. The House of Representatives in the 45th Parliament met for the first time on Tuesday 30 August 2016.

    Number of members of the House of Representatives Tasmania is entitled to

  9. On Thursday 13 November 2014, the then acting Electoral Commissioner made a determination under sub-section 48(1) of the Electoral Act of the number of members of the House of Representatives each state and territory would be entitled to at the next general election.3
  10. As a result of this determination, Tasmania’s entitlement remained at five members of the House of Representatives.
  11. An explanation of how the representation entitlement of Tasmania has been calculated is in Appendix B.

    Direction for a redistribution of Tasmanian electoral divisions

  12. In accordance with sub-section 59(1) of the Electoral Act, the Electoral Commission published a notice in the Commonwealth Government Notices Gazette (the Gazette) on Thursday 1 September 2016 directing that a redistribution of Tasmania into five electoral divisions commence.

    Projection time for equality of enrolments

  13. Section 63A of the Electoral Act provides for the calculation of a projection time for the equality of enrolments. Determining the projection time is an important part of the redistribution process as one of the requirements of the Electoral Act is for the number of electors projected to be enrolled in a proposed electoral division at a specified point in the future, known as the ‘projection time’, falls within a mandated range.
  14. The starting time from which the projection time is calculated, as defined by sub-section 63A(5) of the Electoral Act, is the date at which the augmented Electoral Commission for Tasmania (the augmented Electoral Commission) will determine the names and boundaries of electoral divisions via publication of a notice in the Gazette. The starting time for the redistribution process for Tasmania is Tuesday 14 November 2017 as this is the date when the augmented Electoral Commission will cause the names and boundaries of electoral divisions in Tasmania to be published in the Gazette.
  15. The Electoral Act provides for:
    • the ‘standard’ projection time, which is the period three years and six months after the starting time,4 or
    • an ‘earlier’ projection time, when the Electoral Commission is of the opinion a redistribution process will or may be required to be undertaken as a result of a change in the number of electoral divisions a state or territory is entitled to sooner than seven years after the starting time.5
  16. On Wednesday 24 August 2016, the Electoral Commission noted there was no basis for an earlier projection time and the standard projection time of three years and six months would apply. The projection time for Tasmania is therefore Friday 14 May 2021.

    Current enrolment quota

  17. Section 65 of the Electoral Act requires the Electoral Commissioner, as soon as practicable after the redistribution process commences, to determine the current enrolment quota or average divisional enrolment using the following formula:

    current enrolment quota or average divisional enrolment
  18. In calculating this quota, sub-section 65(2) of the Electoral Act provides that:
    • where the result is less than 0.5, the number is rounded down to the nearest whole number, or
    • where the result is equal to or greater than 0.5, the number is rounded up to the nearest whole number.
  19. Table A shows the figures used to calculate the current enrolment quota and the resultant range of the permissible maximum and minimum number of electors in an electoral division (discussed further in the section titled ‘Statutory requirements for the making of a proposed redistribution’).
    Table A: Current enrolment quota and permissible range for Tasmania

    Number of electors enrolled in Tasmania as at the end of the day on which the redistribution commenced (Thursday 1 September 2016)

    375,072

    Number of members of the House of Representatives to which Tasmania is entitled

    5

    Current enrolment quota for Tasmania

    75,014

    Permissible maximum number of electors in an electoral division (current enrolment quota + 10 per cent)

    82,515

    Permissible minimum number of electors in an electoral division (current enrolment quota – 10 per cent)

    67,513

  20. The Electoral Commissioner signed a written instrument on Wednesday 7 September 2016, as required by sub-section 65(1) of the Electoral Act, determining the quota of electors for the purposes of the redistribution to be 75,014.
  21. As part of the redistribution process, the Redistribution Committee is required to ensure that the number of electors in a proposed electoral division is not more than plus 10 per cent or less than minus 10 per cent of the current enrolment quota (see Appendix C).
  22. The number of electors at the commencement date of Thursday 1 September 2016 at both the electoral division and Statistical Area 1s (SA1s) level were published on the AEC website when the invitation for interested parties to submit suggestions and comments on suggestions was made.6

    Enrolment projections and projected enrolment quota

  23. When making a proposed redistribution, the Redistribution Committee is required by paragraph 66(3)(a) of the Electoral Act to ensure, as far as practicable, that the number of electors enrolled in the proposed electoral division at the projection time will not be more than plus 3.5 per cent or less than minus 3.5 per cent of the projected enrolment quota (see Appendix C). This quota is calculated using the following formula:

    projected enrolment quota
  24. For the purposes of this redistribution, projected enrolment has been calculated by the Australian Bureau of Statistics (ABS). These projections were subsequently reviewed by AEC officers.
  25. Projected enrolment at the projection time of Friday 14 May 2021, together with the processes used by the ABS to calculate these projections, were published on the AEC website when the invitation for interested parties to submit suggestions and comments on suggestions was made. The projections were made available at both the electoral division and SA1 level.
  26. Table B shows the figures used to calculate the projected enrolment quota and the resultant range of the permissible maximum and minimum number of electors in an electoral division at the projection time (discussed further in the section titled ‘Statutory requirements for the making of a proposed redistribution’).
    Table B: Projected enrolment quota and permissible range for Tasmania

    Estimated total number of electors enrolled in Tasmania at the projection time (Friday 14 May 2021)

    384,915

    Number of members of the House of Representatives to which Tasmania is entitled

    5

    Projected enrolment quota for Tasmania

    76,983

    Permissible maximum number of electors in an electoral division at the projection time (projected enrolment quota + 3.5 per cent)

    79,677

    Permissible minimum number of electors in an electoral division at the projection time (projected enrolment quota – 3.5 per cent)

    74,289

    Appointment of the Redistribution Committee for Tasmania

  27. Sub-section 60(1) of the Electoral Act specifies that a Redistribution Committee for Tasmania (the Redistribution Committee) is required to be appointed by the Electoral Commission, via a written instrument, as soon as practicable after the commencement of the redistribution process. Section 60 also specifies the membership of the Redistribution Committee.
  28. The membership of the Redistribution Committee for Tasmania is outlined in Table C.
    Table C: Membership of the Redistribution Committee for Tasmania
    Position on Redistribution Committee Name Basis for membership

    Chair

    Mr Tom Rogers

    Electoral Commissioner

    Member

    Mr David Molnar

    Australian Electoral Officer for Tasmania

    Member

    Mr Michael Giudici

    Surveyor General of Tasmania

    Member

    Mr Rod Whitehead

    Auditor-General of Tasmania

    Note: Mr Molnar was acting Australian Electoral Officer for Tasmania until Wednesday 7 December 2016 and was appointed to the position of Australian Electoral Officer for Tasmania from Thursday 8 December 2016.

  29. The Redistribution Committee is responsible for:
    • considering all suggestions to the redistribution and all comments on suggestions which were received by the specified lodgement times,
    • developing a proposed redistribution of Tasmania in accordance with the requirements of the Electoral Act, and
    • making the proposed redistribution, including maps showing the names and boundaries of proposed electoral divisions, and the Redistribution Committee’s reasons for the proposed redistribution available for public perusal.
  30. The Redistribution Committee met on:
    • Thursday 9 February 2017
    • Thursday 16 February 2017
    • Thursday 9 March 2017.

    Invitation for interested parties to submit suggestions and comments on suggestions

  31. The Electoral Commissioner is required by sub-sections 64(1) and 64(2) of the Electoral Act to invite written suggestions relating to the redistribution of Tasmania and written comments on suggestions via:
    • a notice published in the Gazette on a Wednesday, and
    • a notice published in two newspapers circulating throughout Tasmania.
  32. The notice in the Gazette was published on Wednesday 2 November 2016. Newspaper notices were published on Saturday 5 November 2016 in:7
    • The Advocate,8
    • The Examiner,9
    • The Mercury,10 and
    • The Weekend Australian.
  33. These notices included information about the steps followed in conducting a redistribution, how to participate in the process and where to find further information. Table D presents information on the options for making a suggestion or comment on a suggestion, and the extent to which these options were used.
    Table D: Options to make a suggestion or comment on a suggestion

    Options

    Suggestions

    Comments on a suggestion

    Number

    Percentage

    Number

    Percentage

    Form upload on AEC website

    5

    23.81%

    3

    37.50%

    Email

    12

    57.14%

    4

    50.00%

    Mail

    2

    9.52%

    0

    0.00%

    Fax

    0

    0.00%

    0

    0.00%

    In person

    2

    9.52%

    1

    12.50%

    Total

    21

    100.00%

    8

    100.00%

  34. Interested parties were able to submit written suggestions from Wednesday 2 November 2016 until 6pm (AEDT) on Friday 2 December 2016, the 5th Friday after publication of the Gazette notice.11 During this time, 21 suggestions were received by the Redistribution Committee (see Appendix D).
  35. As required by paragraph 64(3)(a) of the Electoral Act, copies of these suggestions were made available to the public for perusal at the office of the Australian Electoral Officer for Tasmania in Hobart from Monday 5 December 2016. The suggestions were also made available on the AEC website from this date.
  36. Interested parties were able to submit written comments on suggestions received from Monday 5 December 2016 until 6pm (AEDT) on Friday 16 December 2016, the 7th Friday after publication of the Gazette notice.12 During this time, eight comments on suggestions were received by the Redistribution Committee (see Appendix E). From Thursday 5 January 2017, interested parties were able to view these comments on suggestions on the AEC website.13

    Redistribution Committee’s consideration of suggestions and comments on suggestions

  37. The Redistribution Committee is required by sub-section 64(4) of the Electoral Act to consider all suggestions and comments on suggestions which were received by the required specified lodgement times.
  38. The Redistribution Committee found the suggestions to the redistribution and the comments on suggestions to be a valuable contribution and is appreciative of the time and effort expended by all those who contributed.
  39. In formulating its proposed redistribution of Tasmania, the Redistribution Committee considered each of the 21 suggestions and eight comments on suggestions. Appendix F outlines the key themes contained in these suggestions and comments on suggestions, and how the Redistribution Committee responded to them, having regard to the requirements of the Electoral Act.

    Statutory requirements for the making of a proposed redistribution

  40. Section 66 of the Electoral Act required the Redistribution Committee to adhere to specific criteria in forming the proposed electoral divisions.
  41. The Redistribution Committee endeavoured to ensure that the number of electors in each proposed Tasmania electoral division would:
    • meet the requirement of sub-section 66(3) of the Electoral Act for the number of electors in a proposed electoral division to not be less than 90 per cent or more than 110 per cent of the current enrolment quota of 75,014 electors. (Table A indicates the number of electors enrolled in each proposed electoral division in Tasmania must therefore be between 67,513 and 82,515), and
    • meet the requirement of paragraph 66(3)(a) of the Electoral Act for the number of electors projected to be in a proposed electoral division to not be less than 96.5 per cent or more than 103.5 per cent of the projected enrolment quota of 76,983 electors at the projection time of Friday 14 May 2021. (Table B indicates the number of electors projected to be enrolled in each proposed electoral division in Tasmania at the projection time of Friday 14 May 2021 must be between 74,289 and 79,677).
  42. The Redistribution Committee also gave due consideration to the factors required by paragraph 66(3)(b) of the Electoral Act:
    1. community of interests in the proposed electoral divisions including economic, social and regional interests,
    2. means of communication and travel in the proposed electoral division,
    1. the physical features and area of the proposed electoral divisions, and
    2. the boundaries of existing electoral divisions, with this factor being subordinate to consideration of factors i, ii and iv.
  43. Further details regarding these requirements are in Appendix C.
  44. Appendix G outlines the mechanics of constructing proposed electoral divisions.

    Population and enrolment in Tasmania

  45. The periodic review of electoral divisions takes into account changes in a state’s or territory’s population and the number of electors on the electoral roll and in the geographic distribution of this population and electors.14 Specifically, redrawing electoral division boundaries address changes in:
    • the size of the population of a state or territory, which may result from natural increase, natural decrease, net overseas migration or net interstate migration,
    • the number of electors on the electoral roll for a state or territory,
    • the projected number of electors on the electoral roll for a state or territory, and/or
    • the geographic distribution of electors in the state or territory.

    The population of Tasmania

  46. On Thursday 13 November 2014, the then acting Electoral Commissioner ascertained Tasmania’s population was 514,684.15 This represents growth of 1.06 per cent in population since the previous ascertainment of the population on Thursday 29 September 2011.
  47. Similarly, Figure A shows the estimated resident population of Tasmania has grown annually over this period and has continued to grow.16 17 From Figure A, it is also evident that:
    • the rate of growth of the estimated resident population of Tasmania is starting to increase, and
    • the estimated resident population for Australia as a whole is growing at a greater rate than Tasmania’s estimated resident population.

    Figure A: Growth of estimated resident population of Tasmania and Australia in the 12 months to 30 June, 2011 to 2016

    Figure A: Growth of estimated resident population of Tasmania and Australia in the 12 months to 30 June, 2011 to 2016

    Source: 3218.0 – Regional Population Growth, Australia, 2010–11
    3218.0 – Regional Population Growth, Australia, 2011–12
    3218.0 – Regional Population Growth, Australia, 2012–13
    3218.0 – Regional Population Growth, Australia, 2013–14
    3218.0 – Regional Population Growth, Australia, 2014–15
    3218.0 – Regional Population Growth, Australia, 2015–16

    Where is population growth in Tasmania located?

  48. In the period 2011 to 2015, population grew in four of the five electoral divisions in Tasmania. The population of the Division of Braddon grew in the years prior to 2011 and has since exhibited a decrease in the size of the population.18
  49. The highest rates of population growth between 2011 and 2015 have been in the following Statistical Area 3’s (SA3)19:
    • Sorell – Dodges Ferry, which is spread across the Divisions of Franklin and Lyons,
    • Hobart – South and West, which is spread across the Divisions of Denison and Franklin, and
    • Hobart – North East, which is located in the Division of Franklin.
  50. Although 57 per cent of Tasmania’s population is located outside the greater capital city area,20 21 the largest growth in population between 2014 and 2015 was in the Greater Hobart area, which includes the three SA3s referred to above.
  51. With a population density of 7.6 people per square kilometre (sq km), Tasmania has the fourth highest population density of all states and territories in Australia. The population density across Tasmania varies considerably, with Hobart having the highest population density at 130 people per sq km. Between 2014 and 2015, the Statistical Area 2 (SA2)22 with the largest increase in population density was West Moonah (located in Greater Hobart) which now has a population density of 30 people per sq km.23
  52. The ABS has observed that, in the 10 years to 2015, the centre of population in Tasmania has moved 2.1 kilometres south-east to be located in Woods Lake. This reflects continued population growth in the Greater Hobart area.24

    Enrolment in Tasmania

  53. When the redistribution of Tasmania commenced on Thursday 1 September 2016, 375,072 electors were enrolled to vote. This is a growth of 17,396 electors, or 4.86 per cent, since Friday 30 September 2011.
  54. Figure B shows that:
    • the number of electors enrolled in each electoral division in Tasmania has grown in the period Friday 30 September 2011 to Saturday 31 December 2016, and
    • the highest rate of growth in enrolment over this period has been in the Divisions of Franklin and Lyons, with the lowest rate of growth being in the Division of Braddon.

    Figure B: Monthly enrolment in the Divisions of Bass, Braddon, Denison, Franklin and Lyons, Friday 30 September 2011 to Saturday 31 December 2016

    Figure B: Monthly enrolment in the Divisions of Bass, Braddon, Denison, Franklin and Lyons, Friday 30 September 2011 to Saturday 31 December 2016

    Source: Enrolment statistics available from www.aec.gov.au

  55. By the projection time of Friday 14 May 2021, it is projected the size of the federal electoral roll for Tasmania would have grown by 2.62 per cent to 384,915 electors.
  56. Table E shows that all Tasmanian electoral divisions are expected to grow in the period from Thursday 1 September 2016 to Friday 14 May 2021, although the percentage growth differs for each electoral division.
    Table E: Projected growth of current electoral divisions in Tasmania
    Current electoral division

    Enrolment as at Thursday 1 September 2016

    Projected enrolment as at Friday 14 May 2021

    Percentage growth

    Bass

    73,632

    75,058

    1.94%

    Braddon

    73,208

    73,286

    0.11%

    Denison

    73,993

    76,019

    2.74%

    Franklin

    77,058

    80,997

    5.11%

    Lyons

    77,181

    79,555

    3.08%

    Total

    375,072

    384,915

    2.62%

  57. Of the 301 SA1s that make up the Division of Braddon, 66.78 per cent are projected to experience a decrease in the number of electors between the commencement date of Thursday 1 September 2016 and the projection date of Friday 14 May 2021 or are projected to remain unchanged. In contrast, more than half of the SA1s that make up each of the remaining four electoral divisions are projected to grow, however the growth of individual SA1s in the Divisions of Bass and Denison is of a smaller magnitude than those in the Divisions of Franklin and Lyons.
  58. As discussed previously, in making a proposed redistribution, the Electoral Act requires the Redistribution Committee to ensure the number of electors in each proposed Tasmanian electoral division would:
    • not be less than 90 per cent or more than 110 per cent of the current enrolment quota of 75,014 electors, and
    • not be less than 96.5 per cent or more than 103.5 per cent of the projected enrolment quota of 76,983 electors at the projection time of Friday 14 May 2021.
  59. Figure C shows that, on the current boundaries, the number of electors enrolled in each of the five electoral divisions meet the requirement to be not less than 90 per cent or more than 110 per cent of the current enrolment quota. However, Figure D indicates that two of the five electoral divisions do not meet the second requirement as:
    • the Division of Braddon, with a projected enrolment of 73,286 electors, is less than 96.5 per cent of the projected enrolment quota of 76,983 electors at the projection time of Friday 14 May 2021, and
    • the Division of Franklin, with a projected enrolment of 80,997 electors, is more than 103.5 per cent of the projected enrolment quota of 76,983 electors at the projection time of Friday 14 May 2021.
  60. As a consequence, the Redistribution Committee was required to adjust the boundaries of electoral divisions to meet the requirements of the Electoral Act. As a consequence of adjusting the boundaries of the Divisions of Braddon and Franklin, changes were also required to be made to the boundaries of other electoral divisions in Tasmania to ensure that all five electoral divisions met both numerical requirements of the Electoral Act.

    Figure C: Current Divisions of Bass, Braddon, Denison, Franklin and Lyons – enrolment as at Thursday 1 September 2016, current enrolment quota and permissible range of electors

    Figure C: Current Divisions of Bass, Braddon, Denison, Franklin and Lyons – enrolment as at Thursday 1 September 2016, current enrolment quota and permissible range of electors

    Source: Available from www.aec.gov.au/tas-redistribution

    Figure D: Current Divisions of Bass, Braddon, Denison, Franklin and Lyons – projected enrolment as at Friday 14 May 2021, projected enrolment quota and permissible range of electors

    Figure D: Current Divisions of Bass, Braddon, Denison, Franklin and Lyons – projected enrolment as at Friday 14 May 2021, projected enrolment quota and permissible range of electors

    Source: Available from www.aec.gov.au/tas-redistribution


  1. Sub-section 59(2) of the Electoral Act specifies when a redistribution process should be undertaken.
  2. Paragraph 59(2)(c) of the Electoral Act requires the redistribution commence within 30 days after the expiration of the period of seven years.
  3. A copy of this determination is available on the Australian Electoral Commission (AEC) website.
  4. The ‘standard’ projection time is specified by sub-section 63A(2) of the Electoral Act.
  5. Sub-section 63A(3) of the Electoral Act provides that when the Electoral Commission considers a redistribution will be required sooner than seven years after the starting time, the earlier projection time is half-way between the projection time and the time when the Electoral Commission believes the redistribution will or may be required. To make this decision, the Electoral Commission utilises projected populations and the same process used to calculate the number of members of the House of Representatives each state and territory is entitled to, as detailed in Appendix B.
  6. See Appendix G for a discussion of how the AEC uses SA1s. SA1s are the smallest unit at which the ABS makes available disaggregated Census data. At the time of the 2011 Census, there were 54,805 SA1s with populations in the range of 200–800. SA1s, which are part of the Australian Statistical Geography Standard, are defined by the ABS and remain stable between censuses. The SA1s currently in use were defined for the 2011 Census.
  7. Sub-section 64(2) of the Electoral Act notes that the newspaper notices do not need to be published on the same day as the Gazette notice.
  8. The Advocate is published in Burnie.
  9. The Examiner is published in Launceston.
  10. The Mercury is published in Hobart.
  11. This requirement is specified by paragraph 64(1)(a) of the Electoral Act.
  12. This requirement is specified by paragraph 64(1)(b) of the Electoral Act.
  13. Copies of comments on suggestions are not required to be made available for public perusal until the Redistribution Committee’s proposed redistribution is made available (see sub-section 68(1) of the Electoral Act). In previous redistributions, comments on suggestions have been made available at an earlier time.
  14. Electors are a sub-set of the population, comprising those who are on the Commonwealth electoral roll and who are therefore an Australian citizen, or eligible British subject, who is aged 18 years of age or over and who has lived at their address for at least one month.
  15. An explanation of how this population was ascertained is in Appendix B.
  16. Estimated resident population is the ABS official estimate of the Australian population, which links people to a place of usual residence in Australia. Usual residence in Australia refers to that address at which the person has lived or intends to live for six months or more in a given reference year. Estimates of the resident population are based on Census counts by place of usual residence (excluding short-term overseas visitors in Australia), with an allowance for Census net undercount, to which are added the estimated number of Australian residents temporarily overseas at the time of the Census. For further information, see the explanatory notes in 3218.0 – Regional Population Growth, Australia, 2013–14, available at: www.abs.gov.au
  17. The ABS estimated resident population is calculated on a different basis to the population ascertained on Thursday 13 November 2014.
  18. ABS, 3218.0 – Regional Population Growth, Australia, 2014–15
  19. SA3s represent regions of between approximately 30,000 and 130,000 people, with their boundaries reflecting a combination of widely recognised informal regions as well as existing administrative regions such as State Government Regions in rural areas and local government areas in urban areas.
  20. The ABS has defined Greater Hobart as consisting of the SA3s of Brighton, Hobart – North East, Hobart – North West, Hobart – South and West, Hobart Inner and Sorrell – Dodges Ferry.
  21. ABS, 3218.0 – Regional Population Growth, Australia, 2014–15
  22. SA2s are an area defined in the Australian Statistical Geography Standard, and consist of one or more whole SA1s. Wherever possible, SA2s are based on officially gazetted state/territory suburbs and localities. In urban areas SA2s largely conform to whole suburbs and combinations of whole suburbs, while in rural areas they define functional zones of social and economic links. Geography is also taken into account in SA2 design.
  23. ABS, op. cit.
  24. ibid.