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Bill C-19, An Act to Amend the Constitution Act, 1867 (Senate tenure) was introduced in the House of Commons on 13 November 2007 by the Leader of the Government, the Honourable Peter Van Loan, PC, MP. It limits the tenure of senators appointed after the bill becomes law to one non-renewable eight-year term. At the same time it preserves the existing retirement age of 75 for current senators. It further allows a senator whose term has been interrupted to return to the Senate and complete his or her term.
The bill re-introduces, with two important modifications, Bill S-4, An Act to Amend the Constitution Act, 1867 (Senate tenure), introduced in the Senate on 30 May 2006 by Senator Gerald J. Comeau. Bill S-4 did not expressly foreclose the possibility of renewable eight‑year terms, whereas Bill C-19 expressly provides for an eight‑year non-renewable term. In addition, Bill C-19 contains a provision to permit a Senate term to be completed after an interruption. When Bill S-4 was introduced it was described by the Prime Minister as a first step toward broader Senate reform.
On 21 June 2006, the Senate established a Special Senate Committee on Senate Reform to undertake a comprehensive review of the subject-matter of Bill S-4 and any other related matter referred to it by the Senate.(1) On 28 June 2006, after debate on the motion by Senator Marjory LeBreton, PC, for second reading of the bill, it was moved by Senator Joan Fraser that the subject-matter of the bill be referred to the Special Committee.(2)
The Special Committee hearings on into the subject-matter of the bill began on 6 September 2006 and concluded on 21 September 2006. The Committee heard from witnesses on the institutional and constitutional implications of reducing Senate tenure to eight years and considered a number of related matters, including the implications and desirability of advisory or consultative elections for senators and the potential effect of renewable terms.
In addition to the subject-matter of Bill S-4, the Senate also referred a motion by Senator Lowell Murray, PC, seconded by Senator Jack Austin, PC, that the Constitution Act, 1867 be amended to alter the formulae for Western representation in the Senate. In particular, the motion called for an amendment to recognize British Columbia and the Prairie provinces as separate regions for purposes of Senate representation. The motion would alter the distribution of Senate seats in the Western provinces as follows: British Columbia – 12 senators (up from 6); Alberta – 10 senators (from 6); Saskatchewan – 7 senators (from 6); and Manitoba – 7 senators (from 6). The revised distribution would result in a total of 117 Senate seats, rather than the current 105.
The Committee tabled its Report on the Subject-Matter of Bill S-4, An Act to amend the Constitution Act, 1867 (Senate tenure) in the Senate on 26 October 2006. The report on the Murray–Austin motion was tabled on the same day.
On 30 May 2006, Bill S-4 was given first reading in the Senate. After second reading, it was referred to the Standing Senate Committee on Legal and Constitutional Affairs on 20 February 2007. The Committee conducted hearings on the bill from 21 March 2007 to 6 June 2007. The bill was reported back to the Senate with amendments, a recommendation and observations on 12 June 2007. The report was adopted by the Senate on 19 June 2007. Following the recommendation in the report that the bill "should not proceed to third reading until such time" as the Supreme Court of Canada has ruled on its constitutionality, and given the adoption of the report by the Senate, the bill will not proceed to third reading. It should be noted that the report was a majority report prepared by the Opposition.
There has been only one reform affecting Senate tenure since 1867. In 1965 the British North America Act (the BNA Act) was amended to establish a retirement age of 75 for senators. Prior to this amendment senators served for life.(3) The amendment to the BNA Act was made by Parliament using its exclusive power under section 91(1) to amend the Constitution of Canada.
Since the imposition of a mandatory retirement age of 75 in 1965, a number of proposals have been made to further reduce Senate terms, many of which have emanated from the Senate itself.(4) In 1972, the Special Joint Committee on the Constitution of Canada (the Molgat–McGuigan Committee) recommended a mandatory retirement age of 70 years. In 1980, the Standing Senate Committee on Legal and Constitutional Affairs recommended a 10-year term renewable for a five-year term. The Special Joint Committee of the Senate and the House of Commons on Senate Reform (the Molgat–Cosgrove Committee), in its 1984 Report, recommended the election of senators to serve a non-renewable term of nine years, with one-third of senators being elected every three years. Finally, the Special Joint Committee of the Senate and the House of Commons on a Renewed Canada (the Beaudoin–Dobbie Committee) called for the direct election of senators by proportional representation. Under the Beaudoin–Dobbie proposals, senators would serve non-renewable terms of six years.
The Government of Canada has also made recommendations for reforms to the Senate over the years, some of which would have affected Senate tenure. One notable effort was Bill C-60, introduced in 1978, which proposed a variable Senate term to coincide with the life of a Parliament or a provincial legislature. The proposal would have seen 50% of the Senate appointed by the House of Commons and the other 50% appointed by provincial legislatures. The terms would have varied, depending on the life of the governments in the various jurisdictions.(5)
The Supreme Court of Canada also had occasion to consider Senate reform in response to a referral for a reference opinion by the Government of Canada in respect of a series of proposals for Senate reform. In the Upper House Reference,(6) a judgment delivered in 1980, the Court articulated a number of guiding principles for the process of amending the Constitution in respect of the Senate. Although decided under the BNA Act and prior to the enactment of the current amending procedures in the Constitution Act, 1982, the judgment continues to have relevance. At the time it was decided, the case established the proposition that amendments affecting the essential characteristics or fundamental features of the Senate could not be undertaken by Parliament acting alone. Provincial involvement would be necessary.
Some argue that the principles in the Upper House Reference have been overtaken by the subsequent enactment of the amending procedures in the Constitution Act, 1982 or were incorporated into the new procedures. Others maintain that the principles are still relevant where any fundamental alterations to the Senate are being contemplated, notwithstanding the text of the new amending procedures. These issues are discussed later in this summary.
Bill C-19 proposes to amend section 29 of the Constitution Act, 1867. That section currently provides that a senator may serve in the Senate until age 75 (section 29(2)).(7)
Clause 2 in Bill C-19 responds to some of the issues raised in the course of the review of Bill S-4 in the Senate. It expressly forecloses the possibility that the eight-year term could be renewed. Clause 2 amends section 29 so that it will state:
29. (1) Subject to sections 30 and 31, a person summoned to the Senate shall hold a place in that House for one term of eight years.
(2) If that term is interrupted, that person may be summoned again for the remaining portion of the term.
(3) Notwithstanding subsection (1) but subject to sections 30 and 31, a person holding a place in the Senate on the coming into force of the Constitution Act, 2007 (Senate tenure) continues to hold a place in that House until attaining the age of seventy-five years.
The amended subsection 29(1) specifically addresses the concern raised by some members of the Standing Senate Committee on Legal and Constitutional Affairs in their study of Bill S-4 that renewable terms could undermine the independence of the Senate (see the Commentary section for a broader discussion of this issue).
Bill S-4, as originally presented, was silent on the question of whether the eight-year terms were renewable. In his appearance before the Special Senate Committee, the Prime Minister indicated that the silence could be construed as allowing for the possibility of renewal. He further noted that his position on renewability would be compatible with, and reflect his desire for, an elected Senate. The Prime Minister indicated, however, that if the Committee was strongly opposed to the idea of renewable terms, this could be accommodated by means of an amendment to the bill.(8)
The other important change in Bill C-19 from Bill S-4 is a provision to permit a senator whose eight-year term is interrupted to complete the term (new subsection 29(2)). This amendment appears to be intended to clarify that senators who are unable to complete their eight-year term because of disqualification, illness, retirement, or family obligations, for example, may be summoned again and permitted to complete the remaining portion of the term. This provision applies only to senators appointed after the coming into force of Bill C-19.
The proposed amendment to subsection 29(3) of the Constitution Act, 1867, preserves the retirement age of 75 for existing senators. Since this provision is directed at currently serving senators, the Prime Minister would presumably be free to appoint new senators to serve for eight‑year terms even if this term extended beyond age 75. In its report to the Senate, the Standing Senate Committee on Legal and Constitutional Affairs took issue with this provision, noting that the absence of a retirement age for some senators could affect the nature and quality of the Senate's work and would run counter to one of the aims of the government, which is to encourage renewal and a diversity of ideas (see the Commentary section for a discussion of this issue).
Following the proceedings of the Standing Senate Committee on Legal and Constitutional Affairs, Bill S-4 was reported back to the Senate with a number of significant amendments. The amended bill proposed:
The various preamble clauses in the bill are worth mentioning, as they provide important indications of the government's broader intentions to bring democratic reform to the Senate. The first preamble clause pronounces on the need for the Senate, along with all of Canada's representative institutions, to evolve in accordance with modern democratic principles. The second clause states that the government will explore additional measures to ensure that Canadian democratic values are reflected in the Senate. The third clause speaks more directly to Senate tenure, asserting that tenure should be "consistent with the principles of modern democracy."
The fourth clause serves as a reminder that Parliament amended the Constitution in 1965 to limit Senate terms to age 75. The next clause asserts Parliament's exclusive authority, without the need for provincial involvement, in section 44 of the Constitution Act, 1982 to amend the Constitution of Canada in relation to the Senate (see below, in the "Commentary" section, the discussion on the amending process). The final clause serves as a general acknowledgment that the essential characteristics of the Senate as a "chamber of independent, sober second thought" are not to be disturbed (this point will be explored later, in the "Commentary" section).
Preambles in legislation or other enactments are generally considered to act only as aids to the interpretation of the substantive provisions of legislation. They are not viewed as having independent force of law.(9) The preambles in Bill S-4 serve to provide an important context to a broader government program of democratic reform for the Senate, of which Senate tenure is but a first step.
In his historic appearance before the Special Senate Committee, the Prime Minister indicated that Bill S-4 was part of a step-by-step process for reform of the Senate that would be followed by legislation in the fall of 2006 to establish an advisory, or consultative, election process for senators on a national level.(10) He also expressed his intention to initiate a process for constitutional reform leading to an elected Senate "in the near future."(11)
The central constitutional question that preoccupied both the Special Senate Committee and the Standing Senate Committee on Legal and Constitutional Affairs was whether the amendment to the Constitution Act, 1867 could be achieved by Parliament without the involvement of the provinces. Parliament's exclusive authority to amend the Constitution of Canada is found in section 44 of the Constitution Act, 1982. That section provides that Parliament has exclusive authority, subject to sections 41 and 42 of the Act, to amend the Constitution of Canada in relation to the executive government of Canada, the Senate and the House of Commons. Section 41 lists the matters that require unanimity among Parliament and all the provincial legislatures. Paragraphs 42(1)(b) and (c) specifically outline four exceptions to Parliament's exclusive power to amend the Constitution in relation to the Senate. These paragraphs provide that the concurrence of at least seven provinces representing at least 50% of the population of all the provinces (the "7/50" process)(12) is required where Parliament proposes to alter:
Senate tenure is not one of the listed exceptions in paragraphs 42(1)(b) and (c). On a textual reading of the provision, therefore, Parliament's authority to change senatorial terms would not require provincial involvement. On this reading, section 44 of the 1982 Act grants Parliament a general amending power in respect of the Senate. From this general power, the four listed matters in paragraphs 42(1)(b) and (c) are subtracted. One need, therefore, look no further than the text of the Constitution Act, 1982.
Section 44 of the Constitution Act, 1982 replaced section 91(1) of the British North America Act, which granted broad authority to Parliament to exclusively amend the Constitution of Canada subject to five major exceptions.(13) Parliament invoked this provision in 1965 to eliminate life terms for Senators and impose a mandatory retirement age of 75. Under section 91(1), no provincial concurrence was required for this amendment.
During the Special Committee's proceedings, most of the expert witnesses in the field of constitutional law favoured this textual interpretation of Parliament's exclusive amending power. Other witnesses, however, raised concerns about adopting a strict textual analysis of the amending process in sections 44 and 42. It was maintained by some witnesses that these provisions needed to be read in light of the 1980 judgment of the Supreme Court of Canada in the Upper House Reference case.
The Upper House Reference is significant for the view expressed by the Supreme Court of Canada that alterations to the Senate that would affect "the fundamental features, or essential characteristics given to the Senate as a means of ensuring regional and provincial representation in the federal legislative process" could not be made by Parliament alone.(14) Although the Court declined to answer the reference question submitted by the Government of Canada on Senate tenure, because the government failed to specify a term, it did comment that, at some point, a reduction in the term of office might impair the function of the Senate as a body of sober second thought.
There are differing views of the significance and continuing relevance of the Upper House Reference. Scholars such as Professor P. W. Hogg maintain that whatever principles may be derived from the decision, these have been overtaken by the amending formulae that came into effect with the patriation of the Constitution of Canada in 1982.(15) Sections 41, 42 and 44 of the Constitution Act, 1982 may be viewed, therefore, as providing something in the nature of a code for determining what constitutional amendments affecting the Senate may be made by Parliament acting alone.
Others take the view that section 42 may be seen as an attempt to articulate and codify the essential characteristics of the Senate described by the Court in the Upper House Reference.(16) Still another view holds that, while the essential characteristics of the Senate are now "for the most part" incorporated into the amending process in the Constitution Act, 1982, an interpretation of those provisions would be incomplete without considering the principles in the Upper House Reference. On this view, an attempt by Parliament to act alone to limit Senate terms to an extreme level such as one year, for example, or to propose other radical alterations to the Senate, would not likely be permitted, notwithstanding the text of the Constitution Act, 1982.(17) Resort to the complex amending formula in section 38(1) would be required in those cases.
The majority of the Special Committee concluded that the evidence of the scholars and other witnesses who appeared before it supported the government's position that it could proceed to amend the Constitution Act, 1867, acting under the authority of section 44 of the Constitution Act, 1982, without resorting to the complex amending formula in section 38(1) of the Act. The majority of the Committee also indicated that, given that it was studying only the subject-matter of the bill, there would not be any need to refer the bill for a reference opinion from the Supreme Court of Canada, as was suggested by some witnesses. In the majority view, the Constitution of Canada was sufficiently clear that a reference to the Court was not necessary.
The majority of the Special Committee also endorsed the underlying principle of the bill that a defined limit on Senate terms would improve the Senate as an institution. Although the Special Committee heard from various witnesses on the effect and desirability of renewable terms, it came to no conclusions on the issue.
The Standing Senate Committee on Legal and Constitutional Affairs met six times between 21 March and 6 June 2007 to hear from witnesses and deliberate on the bill. The Committee reported the bill back to the Senate on 12 June 2007 with amendments, observations and a recommendation that the bill not proceed to third reading until the Supreme Court of Canada has ruled on its constitutionality.(18) As noted earlier, the report reflected the views of the majority and was, in fact, written by the Opposition. The decision to report the bill back with amendments, observations and a recommendation were made on division.
In its report to the Senate, the Standing Committee noted at the outset that after the Special Senate Committee submitted its report, the government introduced Bill C-43, An Act to provide for consultations with electors on their preferences for appointments to the Senate (the Senate Appointment Consultations Act). This was noted to be a significant development that caused some senators and a number of constitutional scholars who appeared before the Special Senate Committee to reconsider their earlier positions and their analyses on Bill S-4, especially with respect to the bill's constitutionality.
Bill C-43 has been reintroduced in the House of Commons as Bill C-20, An Act to provide for consultations with electors on their preferences for appointments to the Senate (short title: Senate Appointment Consultations Act). It received first reading on 13 November 2007.
The Standing Senate Committee considered the eight-year term appointment prescribed in the bill to be inadequate to preserve the essential characteristics and fundamental features of the Senate and recommended a 15-year non-renewable term in its report on the bill. The eight-year term, the Standing Committee concluded, would not meet the Supreme Court of Canada's test for constitutionality, as elaborated in the Upper House Reference. The Committee was persuaded by a number of constitutional scholars, including Gerald Horgan from Queen's University and Meg Russell from University College, London, that a longer term would be necessary to protect the role envisaged for the Senate, as articulated by the Supreme Court of Canada, as a chamber of sober second thought and to ensure regional and provincial representation. The Committee looked approvingly at the proposals for reform of the House of Lords in the United Kingdom, particularly the 15-year non-renewable term.(19)
A second concern of the Standing Committee was the renewability of the eight-year term. The Committee noted that renewable terms would be compatible with an elected Senate. It noted, however, that no constitutional amendment had been proposed by the government for an elected Senate. In the absence of an elected Senate to complement the renewable terms, the Committee expressed concern that the bill could undermine the independence with which senators have traditionally approached their work. This independence was characterized by the Committee as one of the fundamental features or essential characteristics of the Senate and a constitutional requirement. The Committee pointed to some empirical work done by Professor Andrew Heard in support of the traditional view of the Senate as fostering more independent voting than the House of Commons.(20) Renewable terms would interfere with this tradition by making senators who wished to have their appointments renewed susceptible to influence from the Prime Minister. In light of these and other concerns, the Committee recommended a non-renewable 15-year term. Such a term was viewed as more likely to meet the Supreme Court of Canada's test for constitutionality.
With respect to the retirement age, the Committee noted that the bill would result in currently serving senators being required to retire at age 75, while those appointed after the coming into force of the bill could serve beyond the age of 75. This, it was feared, would have an effect on the nature and quality of the work of the Senate. It would also run counter to the government's stated aim of renewal and diversity of ideas and perspectives in the Senate.(21) It noted that, without a retirement age, senators could conceivably serve for life, thus frustrating the policy behind the decision to eliminate life terms in 1965. Removing the age limit may be appropriate for an elected Senate, but again the Committee noted that there are no proposals to amend the Constitution Act, 1867 to effect such a change.
In its report, the Committee expressed serious reservations about the amending process proposed by the Government to effect the amendment to the Constitution Act, 1867. The critical question that the Committee poses in its report is whether the Upper House Reference continues as good law, or whether it has been superseded by the enactment of an amending formula in section 44 of the Constitution Act, 1982. Does section 44 give Parliament new amending powers, or was it intended to reproduce the powers in section 91(1) of the British North America Act (BNA Act)? The Committee considered that, overall, the expert evidence supported the Upper House Reference as good law and that section 44 of the Constitution Act, 1982 does not grant Parliament an exclusive amending power that is greater than the power it had under section 91(1) of the pre-1982 BNA Act. In other words, its view is that section 44 of the 1982 Act has the same narrow scope as section 91(1) of the BNA Act.(22)
The Committee rejected the Government's position, as presented to the Committee by a Government witness, that the alterations that would affect the fundamental features or essential characteristics of the Senate, as expressed by the Supreme Court of Canada, have all been codified in section 42. Those requirements that require the general amending formula (the "7/50" formula in section 38 of the 1982 Act), have been enumerated in section 42. (23) The report comments on the expert evidence presented to the Committee to the effect that section 42 of the 1982 Act cannot be considered as an exhaustive list of matters that require Parliament to seek provincial concurrence under the "7/50" formula.
As noted earlier, an important factor in the Committee's analysis was the introduction of Bill C-43, tabled in the House of Commons two months after the Special Senate Committee tabled its report. Bill C-43 suggests that Bill S-4 is part of a broader package of reforms.(24) In the evidence of various expert witnesses, the effect of Bill S-4 and its constitutional implications must be considered together with these other measures. According to the witnesses, a court, reviewing the constitutionality of Bill S-4 and whether it falls within the scope of section 44, could not ignore the related measures for Senate reform. These measures would likely be seen to have, as their object or effect, to change regional representation, tenure, method of selection and – possibly through constitutional amendment – provincial representation. The package of measures would likely be seen as changing the fundamental features or essential characteristics of the Senate, and thus as not meeting the test for constitutionality set out by the Supreme Court of Canada.(25)
It is noteworthy that various provinces indicated that they could not support Bill S-4 and the government's proposal to proceed unilaterally to amend the Constitution Act, 1867. This position was taken, for instance, by the Province of Quebec, which had initially expressed support for the bill during the hearings conducted by the Special Senate Committee, because they considered it as part of a broader package of reforms, of which Bill C-43 was a part. These provinces were concerned about the effect on the structure of the Senate and the implications for preserving its role as a body protecting regional and provincial interests.
Other witnesses expressed concern that Bill S-4 could affect the powers of the Senate, and thus bring it into conflict with section 42 of the 1982 Act.(26)
It has been argued that reduced Senate terms, and the accompanying greater turnover, would invigorate the Senate, make it more effective as an upper chamber, and give it more credibility in the eyes of Canadians.
Concerns have been expressed that the long terms that Senators are currently permitted to serve in Canada are anachronistic and out of line with the experience in other Western democracies with an upper chamber, whose members are subject to term limits, and who must go to the voters periodically to obtain support for further terms. At present, a person can be appointed to the Senate as long as he or she is at least 30 years old, and then can remain in office until age 75. Such lengthy terms are sometimes viewed as undermining the legitimacy of the Senate as a legislative body.
Opponents of reduced terms argue that shorter terms will erode the institutional strength of the Senate that results from its lengthy and secure tenure. Its function as a "house of sober second thought" would by this view be impeded by the greater turnover of Senators, since institutional memory would disappear when a Senator's term limit is reached.
It has also been argued that, in the absence of elections, eight-year terms will enhance the prime ministerial power of appointment, further eroding the independence of the Senate and its strength as a chamber of sober second thought. It has been noted that any prime minister with a majority government lasting two or more terms would be able to fill every Senate seat by the time he or she left office, effectively controlling the Senate.(27)
During first reading debate on the bill, a number of senators raised concerns about the independence of the Senate under shortened, renewable terms. A parallel was drawn between Senate independence and judicial independence, with the implication that the Senate should have a level of independence comparable to that enjoyed by the judiciary. Senator Dan Hays, PC, in particular, asked whether reducing judicial tenure to eight years would not "strike very close to – perhaps not at – the heart of the independence of the judiciary."(28) Other senators maintained that independence is an essential characteristic of the Senate that would be compromised by reducing tenure to the level proposed by Bill S-4. According to this argument, such an alteration to an essential characteristic would require a constitutional amendment involving the provinces.(29)
In its seminal 1997 judgment on judicial independence, the Supreme Court of Canada, in the Reference re Remuneration of Judges of the Provincial Court of Prince Edward Island case,(30) asserted the constitutional principle of judicial independence. In so doing, it emphasized that the relationship between the courts and the other branches of government must be "depoliticized," and the separation of powers between the various branches of government – the executive, Parliament and the courts – preserved.(31) The possibility or even the appearance of political interference by means of "economic manipulation" must be forestalled by constitutional protection.(32) In developing the principle of judicial independence, the Court placed significant emphasis on unwritten constitutional principles, most of which the Court drew from the preamble to the 1867 Act, which states that Canada shall have a constitution similar in principle to that of the United Kingdom.(33)
The validity and usefulness of comparing judicial independence with Senate independence was questioned by one government witness in the course of the Special Committee's hearings. It was suggested that the principle of judicial independence is premised upon the separation of powers among the judicial, executive and legislative functions.(34) However, Senate independence as an extension of the principle of the separation of powers loses some of its force when one considers that the Senate is a constituent part of the legislative branch. It is an integral part of Parliament. As suggested by the government witness, the Senate on its own, seen as separate and distinct from Parliament, would have no claim to independence as the term is understood in the context of the separation of powers.
A number of witnesses appearing before both the Special Senate Committee and the Standing Senate Committee on Legal and Constitutional Affairs expressed a general concern that renewable terms could erode the independence of senators, particularly if there were no accompanying process for election of Senators, whether by direct election or by an advisory election process. It was argued that Senators would be less inclined to be critical of the government and less independent in pursuing their functions if their continued presence in the Senate depended upon reappointment by the prime minister.(35)
Concerns about independence are sometimes countered with the observation that senators have been, and would continue to be, guided more by party loyalty than by a sense of personal conviction in their attachment to a particular issue, or in their position on a matter before the Senate.
When a committee to which a bill has been referred considers that the bill should not be proceeded with further in the Senate it shall so report to the Senate, stating its reasons. If the motion for the adoption of the report is carried, the bill shall not reappear on the Order Paper.
See Debates of the Senate (Hansard), 1st Session, 39th Parliament, Vol. 143, Issue 108, 14 June 2007, and Rule 100, Rules of the Senate of Canada.
© Library of Parliament


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Dog Boarding Bennettswood
Where your Best Friends Wellbeing and care is at the heart of everything we do.
Oodles Inn is an in-home dog boarding service based in the suburb's of Melbourne's East. Above all, love and care of your best friend is the core of the service we provide. We offer long and short-term dog boarding facilities to customers all over the South East/East and Melbourne metropolitan area including Bennettswood.
Philosophy & Values – Dog Boarding Bennettswood
At Oodles Inn (servicing Bennettswood and surrounding suburbs), our philosophy is to provide a happy, healthy, stress-free experience for every guest and to provide them with a luxury boarding experience that feels just like home. We know that socialisation is vital to the happiness of dogs. This can be human or canine companionship and because of this, we provide intimate, nurturing care and ensure every guest is part of the family. Pet parents can rest assured that their best friend is in a relaxing, fun, and safe environment.
We know certainly that your best friend will leave the Oodles Inn holiday barking for more!
At Oodles Inn, we have staff – canine and human meeting the most stringent criteria in the following key areas: guest entertainment and management, canine care, food appreciation, hygiene and finally genuine affection.
The person that takes care of your best friend is certainly as important as the loyal pack they get to play with. With experienced and loving staff on premises , you can feel assured that your best friend is fully catered for.
Meet & Greet is Essential
Prior to any confirmed dog boarding booking, it is mandatory for you and your dog to attend for a Meet & Greet.
After the Meet & Greet it is time for the dog boarding booking. We will need additional information. You can send this through prior to the Meet & Greet or afterwards. You can fill in the form by using the following link.
RULES OF STAYING – Dog Boarding Bennettswood
First of all, the following requirements are compulsory for any booking. We will need to view your current C5 vaccination certificate. This is available through your Veterinarian. (You need to renew the VACCINATION CERTIFICATE every 12 months). You can use your local vet or one located at Bennettswood.
All pets booked in for dog boarding must have had recent flea and worm treatment not more than 1 month prior to check. This is as per the Victorian Code of Practice for Boarding Kennels and Catteries. Any dogs coming for boarding that have have fleas or worms will receive immediate treatment. This will need to be paid for by the owner.
Please label all medication with your dogs name.
We can provide food at an additional cost. We find that your dog and you both know what they like so we do encourage you to bring your own food. Please label and place into daily portions. If it is dry food a suitable cup or scoop and specific instructions must be provided.
Pet Toy/Item: You can bring a favourite item. Sometimes the item is damaged or destroyed.
Help support those that help our dogs
More Information about Bennettswood
Burwood is a suburb of Melbourne, Victoria, Australia, 14 km east of Melbourne's Central Business District.[2] Its local government areas are the Cities of Monash and Whitehorse. At the 2016 Census, Burwood had a population of 15,019.[1]
The first settlement in the area, known as Ballyshanassy, was surveyed in 1858. The settlement changed name to Norwood and subsequently Burwood in 1879. The Post Office opened on 1 May 1853 as Ballyshanassy and was renamed Burwood around June 1879.[3]

subset: commoncrawl


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- Parent Category: News
Schererville man found guilty for Monticello murder
* Prosecutors announce two more arrests in murder case *
A White County, Indiana jury has found a Schererville (IN) man guilty for his role in a Monticello murder.
Ray Chamorro was convicted for the murder of 29-year-old Tye Rentfrow.
Ther verdict was returned Thursday night after about five-hours of deliberation.
Rentfrow was shot and killed at a home last October.
A sentencing date is set for August 22nd.
Meanwhile, authorities have reported two more people are under arrest in relation to Tye Rentfrow's murder.
19-year-0ld Lashea Ramsey and 30-year-old David Jones are jailed on $50,000 bonds each.
White County Prosecutor Bob Guy said both suspects face a felony charge of assisting a criminal in a murder. Jones was reported to be with Chamorro at Rentfrow's home when the murder was committed.
Ramsay is Chamorro's girlfriend.


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But happy Friday!
~From the World Wide Internet~
- We all need pretty gift wrapping ideas like these
- Friendship bracelets are always a cute gift
- slinky 60's black party dress...with a BOW. yo. tempting.
- bearded hats..haha
- I'm loving these fun lego pictures :)
- this ode to dogs (and funny video) post made me happy
- Do like this cardigan? Is it to bright?
- Did you check out my mad collection of gift guides? spread the word if you want!
- My fave gift idea for little kids, I'm going to do this :)
- Purses Pastries Etc is giving away some of her hand drawn cards.
- El Vintage is giving away a bracelet..
- Win the entire Burlesque OPI collection at Fashion Meets Food
- Win a donation to an organization of your choice at The Well-Appointed Catwalk
- Bigelow Seasonal Tea giveaway at Snacking Squirrel
- Amen leather jacket giveaway at Belles 'n Rebelles!


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I research emerging trends, fitness fads, industry changes and economic historical referencing every month. Also, being nearest in age to that constantly-in-the-news-set called Boomers, I devote substantial study to the largest of our consumer groups. Recently, I read several articles that described best what was likely to happen as this 76-million-person marketplace shifted its focus during the next few years.
Although the research came from magazines, studies of economics, stock market reports and a host of other sources, they all basically said the same thing: Boomers are going to ratchet down their spending, tighten their belts, simplify their lifestyles and go a more conservative route over the next 10 to 15 years. This change will profoundly affect the North American health club industry.
Investment specialists on many fronts are predicting that Boomers will soon begin a massive switch from growth stocks to dividend-paying equities. Why? Simple. Whereas capital gains may be taxed at as much as 35 percent, the maximum tax on dividends is just 15 percent. What this means is that Boomers will take trillions out of growth-stock portfolios and shift those monies over to higher-cash-payback shares of more conservatively run companies. This is a likely end to the stock market's go-go syndrome of the past decade. Eventually, it should mean a more stable stock market.
Why will Boomers go this route? Because they need additional dollars from investments to offset the difference between what they're currently earning and what their retirement incomes will be. Social Security and pensions simply will not make up enough of that shortfall.
Predictable outcomes accompanying this phenomenon will be that Boomers will look to downsize their spending in discretionary-purchase categories. Since gas and heating fuel prices are not negotiable, it is likely that Boomers will trim outlays for food, entertainment, vacations, socializing, charities and fitness facilities. They probably will cash out on their homes and move to warmer climates where living expenses are cheaper and social/vacation/entertainment comes with the territory. This means a continued boom for the Southeastern and Southwestern regions of the United States.
Shopping clubs, housing areas that feature multi-faceted leisure-living amenities, group vacation clubs and the like will flourish in the next decade-and-a-half. It is highly probable that national fast-food chains will switch to healthier menus in an effort to benefit from Boomer reduced-spending tendencies. Future Boomers are likely to go out less and attempt to get their entertainment in-home from cable, satellite and subscription-type programs.
Thousands of operators in the national health club business likely will go into a coma within the next few years as this Boomer market changes its spending habits. Boomers — who represent more than 40 percent of the entire 41-million-plus health club membership roster in the United States and who tend to patronize mid-size, mid-priced clubs up to larger, more expensive facilities — are apt to begin looking for lower-priced clubs that offer clean, well-equipped fitness floors but are devoid of generally non-used group exercise classes, child care and executive lockers. The savvy consumer understands that he/she is paying for all those extras in monthly dues — whether or not they are being used. Evidence from value-priced operators in several regions of the country show that this has already begun.
I have been saying for some time that we no longer dictate how fitness will play out — the consumer does. Fitness has become a consumer-driven entity. Whenever that has happened in all except very-high-luxury-purchase industries, prices have generally dropped. In other words, commoditization of pricing occurs as a natural result. Combine that with a slower economy and less discretionary income availability to the record-highest-spending group ever in the world and you have the seeds for a substantial and dramatic change. Undoubtedly, that change will also have an effect on our businesses.
When? It's anybody's guess. Mine is that it will accompany key economic indicators and that it is just around the corner. Value-pricers in most areas will be happy. All the others may be in for a very rough road ahead.
Michael Scott Scudder owns and operates MSS FitBiz Connection, an online-based club consulting and training service. Scudder can be reached at 505-690-5974 or email@example.com.


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Hedging December 2014 Corn & December 2013 Corn for 9/20/13
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Attention Corn & Soybean Producers:
Feel free to inquire on learning about the best way to hedge. In my opinion my strategy is the best I have seen since I became a member in 1976 trading corn and soybeans for my own account.
Are you tired of listening to the same BULL ****, and services that do not have a plan if the market goes down instead? Hedge means to take risk off the table, and my service has all producers 100% hedged and they do have most of the upside unhedged (if we can rally for whatever reason). Hedge with a Pro and option expert who has been trading grains for 40 years.
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This report was sent to subscribers on 9/19/13 3:30 p.m. Chicago time to be used for trading on 9/20/13.
December 2014 Corn
After the close recap on 9/20/13: My pivot acted as resistance and was 4.97 3/4, .00 1/2 from the actual high, and my support was 4.91 1/2, .01 3/4 from the actual low.
December 2013
After the close recap on 9/20/13: My pivot acted as resistance and was 4.59 1/2, .00 1/2 from the actual high, and my support was 4.45 3/4, .04 3/4 from the actual low.
All charts and numbers for 9/23/13 have already been sent to subscribers at 2:30 pm.
Numbers for 9/20/13 were:
December 2014 Corn
-------------4.97 ¾ Pivot
4.91 ½
4.83 ½ 2013 Low
5 day chart.... Down from last week same day
Daily chart ... Sideways
Weekly chart... Down
Monthly chart...Down 5.45 is the 200 DMA
ATR 9 ½ Oversold 34%
For 9/20/13: I continue to say "Downtrend Line near $5.17 resists, 2013 low at $4.83 ½ supports". $5.04 ¼ is the pivot (now resistance) of those two numbers.
New low for the run and closed higher bodes well for another up day on Thurs. Indeed it did.
In my daily December 2014 corn numbers on Thursday my resistance was .00 ¼ from the actual high; my pivot acted as support and was .01 ¾ from the actual low.
December 2013 Corn
4.68 ½
4.63 ¼
-------------4.59 ½ Pivot
4.55 ½
4.45 ¾ 2013 Low
5 day chart.... Down from last week same day
Daily chart ... Sideways
Weekly chart ... Down
Monthly chart ...Down 5.39 is the 200 DMA
ATR 11 Oversold 34%
For 9/20/13: I continue to say "$4.85 is strong resistance (near new downtrend line). The 2013 low supports".
New low for the run and closed higher bodes well for another up day on Thurs. Indeed it did.
In my daily December 2013 corn numbers on Thursday my resistance was the EXACT actual high; my pivot acted as support and was .01 from the actual low.
2012 low was $5.11 FG, 2011 low was $5.10 (now resistance), and 2010 it was $4.
Grains: Soybeans opened on the high and worked its way lower throughout the day, and only bouncing off the key gap support that has yet to be filled. I know you read from everyone that the gap was filled at $13.31 ¼, but as I have taught you the gap is the settlement that created the gap not the low of the day it gapped higher. Filled the gap for me is actually filling the gap by trading the actual price. 40 years of personally charting myself, I have found without a doubt in my mind the gap is settlement and works much better for me year in and year out.
What is important is the fact soybeans have had good news fundamentally, but failed to hold its rally. Only the funds know if they are going to buy more contracts and bid the market higher, but the price action tells me the bulls are losing their stomach for pressing the upside as we get closer to harvest. Maybe farmers are looking at the current price and realize that we have only been above $13.30 the last 4 weeks, and a few months last year during the drought, and the contract high made then was $14.09 ¾, was just tested 3 weeks in a row, and we backed off and have held the gap support since then. We know there are sellers at $14 no matter the reason it gets up there. We sold $14 or improved our hedge every time, because you have learned not to "cheer lead" the market higher where you should be selling it. Near the gap support of $13.28 we improve our upside, and for no other reason but to sell once again if it can make another run to $14. If not, we always keep this kind of idea cheap, for $.10 or less, and have a known risk.
No matter if I think I know the fundamentals, or the last 2 years where I have clearly have said that fundamentals are a fool's game when the "top 10 analysts" cannot agree within reason of each other, and seem to adjust their predictions more on the price action. Are they still talking $10 corn? Are they still recommending not selling it under $5.50 and throwing it into the bin until 2014, like that is when the rabbit will come out of the hat? Price is always the most important factor, because no matter the reason, it gives you or takes your money. Since last September I have been bearish soybeans and corn, and have been 100% hedged since September 2012 at $6.50 for December 2013 corn, and $13.40 November 2013 soybeans. When soybeans were making lows for 2013, we bought back call spreads that we sold and took profits leaving only pennies on the table, and rolled down put spreads taking profits there too, and by doing so we got some of our upside back. It did not matter if you were bearish like me, or bullish, we were able to sell November 2013 $14.50 calls for $.30+ and the $15 calls for $.20, and would still be happy if we "lost/cash sell" it at that price. We are basically long above $13.60 now, and protected all the way down to at least $11.40. The best part is that YOU are in control, not me; you reflect your appetite for risk, and can reflect your bullishness or bearishness.
Control is what it is all about. You cannot control the market but you can and must control what you do. You have learned through my simple strategy, which you can control what downside you want to protect, and what upside you seek. You learned options are rights, not obligations, and so you have the right to morph your position when need be. You know exactly what to expect when you look at your position, you understand fully where you are participating in the market, and what prices you are not. The unhedged out there have absolutely no control, they will either be victims of their own inaction and the market continues lower, or rewarded because the market rallies. Trouble with that is, they never seem to sell it when higher either, it either gets to their objective and they do little, or they do nothing and move the goalposts farther away. Stress, and the long road back up, is not helped by bullish talking points. My charts lead our hedge which is based on price, but my bearish talking points have always been that the more the farmers hold onto their grain, the more bearish it is in the longer term, and it is bearish when the bull's main fundamental is based on continued production shortfalls.
Nobody knows production, but each of us is entitled to a guess, so my guess is the same as last year, when every one of my producers went into their fields the day before combining and made a guess, and every one of them was pleasantly surprised with more BPA. I believe it will be the same this year. I continue to be bearish, and with decent production in SA I will continue to be. With a good growing season in the US next year, I will continue to be bearish until much lower price levels are seen.
I continue to recommend getting out of the put spreads that have captured all but a few cents of its premium, because that last $.04 is all you get. It can do much more harm than good, and there is only 9 weeks remaining until the December options expire, so this spread will move slowly for you, but quickly against you. I still recommend if you need or want more protection beside your insurance, buying the $4.60/$4.30 spread instead. It settled at $.11 ½ but has $.18 ½ to be captured. You have different odds, but much less risk and more reward. This totally depends on you and if you still need to hedge. All who started last year have already removed their corn hedge and have $1.10 or more in their pockets. Now it is revenue insurance that protects, no reason not to take the hedge off.
We are also 100% hedged 2014 corn and soybeans, but some of my producers have yet to do any, half have hedged 100%. Everyone is self directed and in control, I am here to answer any question on futures or its options. All you need to look at is this year's performance on hedging from the experts and ask yourself, do I want to continue to listen to more of what got me into this position? Could you do worse than them? If the answer is yes, that means you are 100% unhedged, or should I say, you have more unhedged than they do. I was brought up to try to learn what I could about something before I "wager" my money on it. That includes opening a business or buying anything to sell at a profit. Take responsibility in what you do, and the most important thing to a producer is how they control risk as they seek higher prices and a better basis. Anyone who was seeking higher corn prices and watched it go to $6 as they were trying to sell it for $7 is one thing and I could have been one of them, but to do NOTHING and let it go to $4.60 is ridiculous and incompetent if your job was to secure income for the farm.
I continue to say if you are not 100% hedged, get a line in the sand by doing so. 5 weeks from today the November options expire, and 9 weeks from today the December options. October 11 report is in position to be a mover and shaker, so adjust your positions by then, and should get out of any corn put spread more than $.30 by then.
I continue to say "I am bearish longer term, but would day trade without bias risking $.03 ½ in corn and $.06 in soybeans using a stop to protect any idea".
Grains: Soybean bracket line was perfect support, and the gap has yet to be filled. It does not surprise me that the line has held the last 4 weeks, but the gap from Friday at $13.82 is now the objective of the next rally. Gap at $13.28 supports, gap at $13.82 resists, and the pivot of those two numbers is $13.55. Only a close above the contract high would signal higher prices to come, but until then that price is major resistance. On the other hand, if $13.28 goes I would look for the next strong support at $12.80. What drives the market to those prices is irrelevant to me, what is important is the fact it is at an extreme and I can take advantage of it cheaply. The price gives or takes away money from your pocket, and the fundamentals might be factual but does not help discover what the price is or will be in the future.
Does not take much to move the market on this low volume, but the market is not close to trading its ATR and that speaks for itself. The bull case comes down to production shortfalls, and it is on their shoulders to prove. I do not like the fact that the funds have a big chunk of the bull position in soybeans, and it bothers me that farmers are holding on to their grain that eventually no matter the price must be sold in the future. To me it is really foolish to only look at the reward you seek and make that a priority, instead of the priority of locking in some protection as you seek higher prices. That not only goes for hedging, but risks must be controlled in speculation too.
Soybean action is still decent, but it looks more vulnerable to further downside with fund liquidation. Corn looks terrible, and the "pin action" in there is pathetic at best. December corn bulls can look for a retest of $4.75, but it would only be a corrective action before the low will be tested once again. I am looking at the lows to be taken out as we get closer to harvest, but with bullish news yesterday and the failure to close higher, tells me the market is weak and could make new lows sooner rather than later. Stock market fever takes away from the commodity play, and unless we get a shortfall in SA, money will go away from the grain market. Speculators and funds love to play the long side, and with those players not interested in trading a sideways to lower grain market, that is not good for the bulls that remain.
Make sure if you have put spreads nearing full value, that you do not let the market get above $4.75 without exiting some of your spreads. If you get out here you could stay in the rest above $4.75, but if it got above the downtrend line at $4.85 I would be exiting half of what I have. If you need the put spreads for protection I would keep them, but if you have revenue insurance then I would only have a $.30 $4.60/$4.30 put spread that settled at $.12 ½. Risk that to get $.17 ½ minus commissions, and let the insurance do the rest if this applies to you. This allows you risk little and are protected nicely until harvest. Since there is not much time until expiration, the slightest rally will make it cheap, and as it gets "in the money" it appreciates quickly.
2014 is not going away, and everyone who hedged already is not concerned with it right now, and need only worry about the crop coming out of the ground. Imagine, if others are not fully hedged in 2013, chances are not much was done for 2014 too, so if the toothache of 2013 subsides, then they will feel the pain coming on another tooth that could really hurt in 2014. You know what it was like in the past when you watched yourself unhedged completely and the market keeps going down, and you know what it is like to be fully hedged and the market rallied and you made more money, as well as this year when you locked in protection and income already, have next year hedged too, and really relaxed no matter when the market rallied, or when we went down. The strategy allows you the ability to control emotions and think more clearly, and the most important aspect of a hedge, protecting income.
Lastly, always remember what you do in your hedge, whatever your position is, it is for EXPIRATION, so imagine what your position will do if we are $.50 higher or $.50 lower from here, or any price in between. Whatever you do, and whenever you adjust it, it is for expiration, not what the market will do in a week or a month. Be honest, and write down the price you think we will be at 1 week from today, 1 month from today, and at option expiration, and whenever your thoughts change, write it down below your last prediction. You will see how often you change your thoughts and ideas, and if your position reflects what you think. Keep it real. When you write down what you think the futures will be, it is like betting before the race or game begins, anything else is like an old lady (no disrespect intended) at the race track and tells you she knew the horse was going to win, but bet only $5 on that horse, and $25 on another horse in the race too. Just like a market reporter, they tell you what happened after the fact. Hedging and trading the future needs to predict before, not after the fact.
My service has been hedged for 2014 for 6 months now, but unhedged producers should have a plan and not let the market go down more than it already has. Have a plan, whatever it is, and execute it.
I continue to say "Look at buying back short calls which are getting cheap now, and resell if it can rally. I am bearish longer term, but would day trade without bias risking $.03 ½ in corn and $.06 in soybeans using a stop to protect any idea".
Grains: FSA cutting acreage this morning was a bullish factor that sent prices sharply higher in open outcry, but it did not take long for the market to take advantage of the rally to sell the market. This resulted in the market coming down to test support, and totally disregarded the "news" of lower production. This is another example of what I say year in and out; it does not matter what made the market rally or breakdown, I just want to take advantage of it. Buying today might have seemed like a good idea, but in a few hours you were losing greatly if you did not use a stop or known risk strategy. So you bought into the idea that there is less grain coming then thought, and absolutely nothing changed in 2 hours except one thing, the price! So how did the bullish fundamental help you to make money or improve your hedge? Did it reduce your risk? Was the market wrong for not closing higher? Remember this, the market is NEVER wrong! It does not read headlines, and it need not trade in accordance with its underlying fundamentals.
The market is a vehicle for price discovery, and the market will swing past its "fair value" both to the up and downside as well. That is where real value for me is. When things are at prices that have not proven its sustainability, this is where I can risk the least and make the most, and if I buy time and control risk with an option strategy, then I am in a position that is unemotional, and has the time for the chart to prove my idea right or wrong.
Everyone else can only talk fundamentals because that is an "opinion", but it seems like they really do not have much skill in participating in the market. I would talk fundamentals if it could help, but instead I teach you how to trade or hedge the market without any knowledge fundamentally or not. I am teaching you to be self directed, what makes you think you cannot earn more than any broker or service? Let us face the facts, when hedge services are not 100% hedged long ago, and instead on concentrating on hedging what is still needed, they recommend buying call spreads, or worse, selling a put to buy a call, so how is that reducing risk (hedging) when you are buying the upside? Is this was for a speculator it would be one thing, but for a producer it adds risk not take it away. Seems like that they are more worried in hedging and the market rallies, than worrying about losing more money in a market going down. But the job of a hedge is to protect the downside so you do not worry about losing more of your income. Making more money is one thing, but losing money is another.
Look at the reality of the task, if it was easy everyone would be trading for a living, but yet in my 40 years I am hard pressed to say 1 out of 100 people make money trading. One or two years do not prove success, but you are on the right road. It only takes one idea and loss of control to bankrupt you. Discipline must be in control and can never be neglected. Let me compare it to the real world of sports. Millions dream of making it to the pros. You are a star in high school, you play 4 years in college and make it to the pros, which mean you are now playing amongst the best in the world, and even if you are "rookie of the year" you have so much more to learn playing on a professional level. This is what experience does, gives you wisdom. Otherwise, you hit the wall; you cannot do better no matter how hard you try. What I am trying to say, is that out of millions that play sports on various levels, only the cream of the crop, the best of the best, can make it on the professional level. Professional, means making money from what you do, and this applies to trading. You can trade like you are going to Vegas, on allocated money to trading, or betting football, or stocks, or whatever, its taking part of your disposable income on a game of chance. People who make a living trading can call themselves professional, but just like in sports, if your game starts to decline your days are numbered.
So what makes you think you can make it to the pros? And if I were a producer and looked at how much money your peers or services that you went along with THEIR ideas, made their risk YOUR own, I do not think if you were self directed, not listened or read anything, and just looked at the price and said I will hedge $1.00 higher or $.50 lower but I will put a line in the sand, you could not do any worse even if you tried. We hedged December 2013 corn at $6.50 last year, and soybeans at $13.20, so the unhedged lost $2 going after a random price they said corn is worth. They already could have locked in a high income, instead now they are victims of their own inaction. Yes, soybeans are a little higher than where we hedged, but we already took advantage of the rally by adding income. The difference is like in corn, if it goes down we have some protection. My producers and subscribers have learned how to use charts as a roadmap, learned how to control risk, learned the proper way to use options for hedging, and are now self directed. Now you are a rookie in the pros. Every year you get better. New subscribers are learning, but do not take too much time getting the basics.
Talk about fundamentals now, I'll leave that to the others who trade off that. I continue to say "Look at buying back short calls which are getting cheap now, and resell if it can rally. I am bearish longer term, but would day trade without bias risking $.03 ½ in corn and $.06 in soybeans using a stop to protect any idea".
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text:
U.S. Equal Employment Opportunity Commission
Meeting of May 8, 2013 - Wellness Programs Under Federal Equal Employment Opportunity Laws
Chair Berrien and Commissioners Barker, Feldblum and Lipnic:
Thank you for inviting the Consortium of Citizens with Disabilities (CCD) to testify at this public meeting. CCD is a coalition of national disability-related organizations working together to advocate for national public policy that ensures full equality, self-determination, independence, empowerment, integration and inclusion of children and adults with disabilities in all aspects of society. My organization, the Bazelon Center for Mental Health Law, is a member organization of CCD, and I submit this testimony on behalf of CCD.
While CCD believes that wellness programs can be useful tools to promote health and well-being, we have significant concerns about their potential to discriminate against individuals with disabilities.1 As you know, the employment rate of people with disabilities is far lower than that of any other group tracked by the Bureau of Labor Statistics, and people with disabilities have been disproportionately impacted by the economic downturn. Against this backdrop, we are concerned that employer-based health programs which penalize people with disabilities for not being as "well" as others - and for failing to disclose disability-related information that the Americans with Disabilities Act (ADA) permits them to keep confidential in order to avoid discrimination - make it even more difficult for individuals with disabilities to obtain employment on fair and equal terms.
As these programs become more widespread, it is imperative that the Commission issue regulations or guidance to help employers and employees understand the ADA's application in this area. Moreover, the need for clarity about the ADA's application has become even more urgent in order to avoid confusion as the Departments of Labor, Health and Human Services, and Treasury finalize their regulations implementing the Affordable Care Act's provisions concerning wellness programs.
The ADA Imposes Requirements on Employer-Based Wellness Programs in Addition to those Imposed by Other Federal Laws
The Commission has recognized that the ADA imposes requirements on employer-based wellness programs in addition to those imposed by other federal laws, such as the Health Insurance Portability and Accountability Act (HIPAA), the Genetic Information Nondiscrimination Act (GINA), and the Affordable Care Act (ACA). The Commission's regulations implementing GINA state that nothing in the GINA regulation concerning inducements to participate in wellness programs "limits the rights or protections of an individual under the Americans with Disabilities Act (ADA) . . . ." 29 C.F.R. § 1635.8(b)(2)(iv) (providing examples of circumstances in which the ADA requires employers to make reasonable accommodations to avoid disability discrimination in wellness programs).
The ADA's separate application to wellness programs was also recognized in the wellness programs review sponsored by the Departments of Labor and Health and Human Services in anticipation of their proposed rule implementing the ACA's wellness program provisions ("The Affordable Care Act does not, however, supersede other federal requirements relating to the provision of incentives by group health plans, including requirements of the Genetic Information Nondiscrimination Act (GINA) and the Americans with Disabilities Act (ADA))."2
Congress chose to enact the ACA's provisions concerning wellness programs without stating that these provisions applied "notwithstanding any other provision of law." Indeed, Congress considered and rejected amendments concerning wellness programs that would have provided, for example, that:
Nothing in the Americans with Disabilities Act of 1990, title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act of 1967, or the Genetic Information Non-discrimination Act of 2008 shall be construed to prohibit a covered entity from adopting, sponsoring, administering, or providing products or services in connection with, or relating to, programs of health promotion or disease prevention that requests individuals to participate in medical examinations, answer medical inquiries, or complete health risk assessments or questionnaires, if such requirements are otherwise authorized under this Act.
Congress' decision to pass the ACA without such language demonstrates its intent that the ADA have separate and concurrent applicability to wellness programs.
The ADA's Requirements Concerning Wellness Programs
1) The ADA requires reasonable accommodation of employees with disabilities in wellness programs.
The ADA prohibits covered entities from discriminating based on disability in fringe benefits and other terms, conditions and privileges of employment. 42 U.S.C. § 12112(a)-(b), 29 C.F.R. § 1630.4. Among other things, it requires employers to reasonably accommodate employees with disabilities to ensure that they have rights and privileges in employment equal to those of nondisabled employees, including the right to participate equally in workplace activities like wellness programs. 42 U.S.C. § 12112(b)(5). The ADA's reasonable accommodation provisions apply to both participatory wellness programs (programs that do not require an individual to meet a health-related standard in order to obtain a reward, or do not offer a reward at all) and health-contingent wellness programs (programs that require an individual to meet a health-related standard in order to obtain a reward or avoid a penalty).
Health-contingent wellness programs: Health-contingent wellness programs pose the most significant concerns for people with disabilities. These programs reward individuals for meeting health targets or penalize them for failing to meet those targets. There is no logical difference between imposing a penalty and offering a reward; offering a reward only to those individuals who meet a health standard means denying the reward to those individuals who do not meet the standard - that is, penalizing the latter individuals.
The Commission has already recognized that reasonable accommodations are required to afford employees with disabilities equal opportunity in wellness programs:
. . . if an employer offers a financial inducement for participation in disease management programs or other programs that promote healthy lifestyles and/or require individuals to meet particular health goals, the employer must make reasonable accommodations to the extent required by the ADA, that is, the employer must make "modifications or adjustments that enable a covered entity's employee with a disability to enjoy equal benefits and privileges of employment as are enjoyed by its other similarly situated employees without disabilities" unless "such covered entity can demonstrate that the accommodation would impose an undue hardship on the operation of its business." 29 CFR 1630.2(o)(1)(iii); 29 CFR 1630.9(a).
29 C.F.R. §1635.8(b)(2)(iv).
We urge the Commission to clarify that an employer who offers its employees a health-contingent wellness program must ensure that if an employee cannot meet the standard due to a disability, the employee is afforded the reasonable accommodation of having the opportunity to meet an alternative standard that is feasible for the individual to meet given his or her disability - or waiver of the standard if there is no feasible alternative standard (unless the employer demonstrates that doing so is an undue hardship).3
In addition, health targets that actually define a disability (for example, high blood glucose levels that indicate diabetes) should not be permitted to be used as the basis for penalties or rewards; doing so would mean using participants' disabilities as the basis for adverse treatment.
Participatory wellness programs: We recommend that the Commission clarify that employers must also make reasonable accommodations to avoid disability-based discrimination in participatory wellness programs. Regardless of whether rewards or penalties are attendant upon the outcome of the program, reasonable accommodations may be necessary to afford equal opportunity to people with disabilities. For example, an employer-based wellness program offering reimbursement for membership at a fitness center that does not offer physical accessibility or universally designed fitness equipment, or that does not permit a person with a disability to bring a personal attendant without an extra admission fee, may need to make accommodations in order to provide equal opportunity to participants with disabilities. A wellness program must also ensure effective communication with participants - for example, by providing print materials in alternative formats, providing sign language interpreters when required by deaf and hard-of-hearing individuals, and ensuring that websites meet current accessibility standards.
2) The ADA limits disability-related inquiries by participatory and health-contingent wellness programs.
As you know, the ADA sets out careful limitations on disability-related inquiries pre-employment as well as post-employment. 42 U.S.C. § 12112(d). The purpose of these limitations is to guard against discrimination and ensure that disability-related inquiries are limited to those where there is a need to know for purposes of determining whether an individual can do the job (that is, inquiries that are job-related and consistent with business necessity).4 As the Commission noted in its guidance concerning disability-related inquiries of employees:
Historically, many employers asked applicants and employees to provide information concerning their physical and/or mental condition. This information often was used to exclude and otherwise discriminate against individuals with disabilities -- particularly nonvisible disabilities, such as diabetes, epilepsy, heart disease, cancer, and mental illness -- despite their ability to perform the job. The ADA's provisions concerning disability-related inquiries and medical examinations reflect Congress's intent to protect the rights of applicants and employees to be assessed on merit alone, while protecting the rights of employers to ensure that individuals in the workplace can efficiently perform the essential functions of their jobs.5
The ADA exempts workplace wellness programs from these limitations to the extent such programs include "voluntary medical examinations, including voluntary medical histories." Id. at § 12112(d)(4)(B). The Commission has stated in guidance that medical exams or inquiries conducted as part of workplace wellness programs are not "voluntary" under the ADA where they are mandatory or include penalties for failing to complete such exams or inquiries.6
Some employers have wellness programs that use "health risk assessments" offering significant financial rewards for providing disability-related information that the ADA would otherwise prohibit the employer from requesting. Other employers have required all employees to provide disability-related information as part of such "health risk assessments" - whether or not they choose to participate in a wellness program - or face financial penalties. Still others use health risk assessments that ask disability-related questions (for example, questions about the participant's mental health) that seem to be unrelated to any actual wellness services provided to wellness program participants.
The Commission should address the ADA's application to such practices. First, the Commission should address what constitutes a "voluntary" wellness program. If a wellness program imposes financial penalties for not participating in the program, the program is not voluntary. Similarly, the program is not voluntary if individuals who choose not to participate are denied financial rewards. If a voluntary wellness program includes a health risk assessment that asks disability-related questions, an individual cannot be penalized for refusing to answer those questions or given financial rewards for answering them.
In addition, the Commission should address the circumstances under which disability-related questions may be considered part of a wellness program. If disability-related questions are asked as part of a health risk assessment, in order to be part of a wellness program, those questions must be necessary for the wellness services actually provided. For example, a health risk assessment that asks questions about a participant's mental health should not be considered part of a wellness program that focuses on management or improvement of other health conditions and does not offer mental health services. Second, there must actually be wellness services offered; a voluntary wellness program cannot simply consist of a health risk assessment. While one court rejected an ADA challenge to an employer's imposition of penalties on employees who failed to answer disability-related questions as part of a "wellness program" consisting only of a biometric screening and a health risk assessment questionnaire,7 we believe that court's analysis was incorrect. That court held that the ADA imposed no liability because the wellness program fell within the ADA's "safe harbor" for bona fide benefit plan terms that are based on underwriting or classifying risks. The court did not consider, however, the differences between wellness programs -- which are designed to promote health or prevent disease - and underwriting practices.
Finally, the Commission should also clarify that information obtained as a result of a workplace wellness program's voluntary medical exam, health risk assessment or other inquiry - whether in a participatory or health-contingent wellness program - must be "collected and maintained on separate forms and in separate medical files and [] treated as a confidential medical record" in accordance with the ADA. 42 U.S.C. § 12112(d)(3)(B), (d)(4)(C).
Thank you for the opportunity to provide testimony on this important issue. The Consortium of Citizens with Disabilities appreciates the Commission's interest in this issue and stands ready to assist the Commission in any effort to provide further guidance concerning the ADA's application to wellness programs.
1 Wellness programs also raise concerns under Title VII and the Age Discrimination in Employment Act, which are addressed by other witnesses and commenters.
2 Soeren Mattke et al., RAND Health, "A Review of the U.S. Workplace Wellness Market," at 7, available at http://www.dol.gov/ebsa/pdf/workplacewellnessmarketreview2012.pdf.
3 While the ACA permits individuals to request an alternative standard when their medical conditions make it "unreasonably difficult" to meet a health standard, it is unclear how this language will be interpreted. In any event, it does not limit the ADA's reasonable accommodation mandate.
4 Typically health risk assessment inquiries concern participants' health rather than their ability to do the job, and are therefore not job-related.
5 EEOC Enforcement Guidance on Disability-Related Inquiries and Medical Examinations of Employees Under the ADA at ¶ 22 (July 27, 2000) (available at www.eeoc.gov/policy/docs/guidance-inquiries.html).


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Despite high-sticker price, this product earns Reviewer's Choice designation for the best antivirus solution in this roundup for midsize to large networks
Network security suites
Security software suites offer more than antivirus protection
Red Condor Hosted Service
Symantec Endpoint Protection 11.0
Triumfant Resolution Manager
Trend Micro Version 6.0 Advanced
This is the first time we have reviewed Sophos Endpoint Security at GCN. And for an inaugural test run, Sophos impressed us from the beginning. It's similar to Symantec's Endpoint Protection 11.0 with the exception that Sophos is easier to use and navigate.
Sophos can protect a midsize to large network from viruses, spyware, adware, rootkits and unwanted applications such as iTunes or restricted Internet browsers. With Sophos, you can also control the use of removable storage devices and installation and use of unauthorized software. That includes voice over IP, instant messaging, peer-to-peer file-sharing applications, media players and video games.
The suite's Enterprise Console provides a single point from which to deploy, update and report. One console can manage tens of thousands of Windows, Mac, Linux and Unix computers. Managing that many nodes from a single console can save a lot of time and even more money because one network administrator can do the tasks of several.
Sophos also lets you configure the times at which different parts of your agency's network will update. This feature is particularly useful if your organization has large networks that cover different time zones or staff members who work at their PCs at different times. If you have remote laptop PCs that connect to the network at different times, you would want this feature to optimize the coverage and make sure all computers are up-to-date with the latest security patches.
Controlling automatic update settings also lets you minimize the effect of updates on network performance. You can also use bandwidth throttling, which prevents computers from using all the bandwidth for updates when they need it for work-related purposes.
Despite the high sticker price, we found the versatility, compatibility, features and ease of use of Sophos worth the Reviewer's Choice designation for the best antivirus solution in this roundup for midsize to large networks. Sophos' ability to offer security to a wide breadth of operating systems and software in an easy-to-use manner sets this program apart. If the company could lower the price per node to less than $50 a computer, they'd be the ideal solution for most agencies.
Sophos, 866-866-2802, www.sophos.com
About the Author
Carlos A. Soto is a former GCN Lab technology analyst.
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Nutrition Facts
Ingredients and Preparation
- Mix together ginger, garlic, honey, soy sauce, and orange juice. Place fish and marinade into a resealable plastic bag. Refrigerate for 30 minutes to overnight.
- Preheat broiler (on low setting if your broiler has an option) and position the oven rack about 4 inches below the heat.
- Remove fish from bag, reserving marinade, and place skin-side up on a broiling rack coated with nonstick cooking spray. Broil fish for about 2 minutes, then remove from oven and pull the skin off with tongs. Baste with marinade and return to oven. After another 2-3 minutes, turn fish over and broil another 4-5 minutes. Fish will flake easily when done.
- When fish is done, garnish with the green onion and enjoy!


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CC ignorance
Club 150-3 is not well described. It says that multiplier resets on loss while it really resets on draw. I wrote about this issue at least a dozen times, but it looks like you just don't care about your users. I was on this site since its beginning and I can tell you it was much better before. Nobody replied to my message about being muted for no reason. I am muted for months and there is no good reason, and nobody replied to my mail message about that. Once again, way to go CC!


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|Birth Date:
|Sunnyvale, Calif.
|High School:
|Fremont High School (Sunnyvale)
SENIOR 2007-08: Walked on to team in for the spring of 2008 ... played primarily at the No. 3 singles position, but saw time at the No. 2 spot as well ... played in every match for the Broncos ... posted a 3-15 singles record ... earned first career victory in first collegiate match versus UC Santa Cruz's Max Liberty-Point, 4-6, 7-6, 7-5 ... clinched Broncos second victory of the season versus conference rival Gonzaga ... 3-17 in doubles, playing at the No. 1, No. 2 and No. 3 positions ... played primarily with Charlie Burke at the No. 3 spot ... 2-5 with Kenzo Hirakawa-Wong at the No. 2 position.
HIGH SCHOOL: A 2004 graduate of Fremont High School (Sunnyvale) ... played for Rick Newman ... in both junior and senior seasons he won team MVP and finished second in the league ... earned All-District Honors for SCVAL League.
PERSONAL: Full name is Senthil Chidambaram ... born in Tacoma, Wash. ... parents are Chid Anramalai and Metcha Chidambaram ... has one younger sister, Uma ... majoring in electrical engineering ... enjoys playing tennis, working out, and watching football.


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Exmouth in Western Australia is one of the worlds richest and most diverse fishing destinations. The Ningaloo Coastline has been declared a World Heritage Marine Park which means that the area will remain protected, to be looked after and enjoyed as an untouched wilderness.
Now is your chance to visit this unique part of the World and to experience this truly amazing fishery and be professionally guided onto an amazing array of species.
Fly fishing in saltwaters couldn't be more exciting than it is in Exmouth. No other destination on the planet has a more diverse range of species to target, in such a pristine, safe and easily accessible environment.
Welcome to an entirely new chapter of saltwater fly fishing.
Welcome to Exmouth Fly Fishing.


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The International Postal System Web Client ( IPS Web Client ) designed to faciliate data entry of booking, attempted delivery and final delivery particulars of International Registered, EMS articles and International Parcels.
The list of undelivered International Inbound articles sent by various Office of Exchanges in india (whose delivery information's are yet to be updated by respective delivery post offices through IPS web client) and list of delivered articles at delivery post offices in the month of November-2013 and December-2013 in ZIP format is enclosed at below mentioned link for kind perusal and necessary action please. --
Please open all the below mentioned list in Excel-2007 and above format.
Kindly find below 04 download links to see the lists of Undelivered / Delivered International IPSWEB articles.
1. Cick here to Download List of Undelivered International Inbound articles from 01 November 2013 to 25 December-2013 in Zip Format. (Pincode wise List of Undelivered International Articles). Please enter delivery particulars at the earliest. Copy and Paste all the data in Excel 2007 - Use filter option to select articles pertaining to your Circle / Region / Division.
2. Click here to Download List of Delivered International Inbound articles from 01 November 2013 to 25 December 2013 in zip Format.(Pincode Office wise List of Delivered International Articles, whose delivery details are already updated - For Monitoring Purpose)
3. Click here to Download Dashboard : Summary : Undelivered / Delivered articles monthwise (Summary in excel format showing number of undelivered articles against delivery P.O. - For Monitoring Purpose)


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About 1 out of 3 people with
lupus produce an
antibody that attacks certain blood-clotting factors,
which can cause the blood to clot easily.1 A person who has this antibody and has had blood clots is said to have antiphospholipid antibody syndrome. This
can lead to mild or severe blood-clotting complications, including:
A blood test can detect antiphospholipid antibodies. When diagnosed, the condition is usually treated with
anticoagulants. Pregnant women with antiphospholipid
antibody syndrome need to be closely monitored.
CitationsCrow MK (2012). Systemic lupus erythematosus. In L Goldman, A Schafer, eds., Goldman's Cecil Medicine, 24th ed., pp. 1697–1705. Philadelphia: Saunders.
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However, you may still request and order these other images in the galleries to be converted by using our 'Pre-Release Patterns' service.
How it works
If you would like an image from those galleries made into a pattern we can do that right away for you. You decide if you would like it in any special size, or you can leave that for us to decide.
When we have created the pattern and you have paid for it you will receive it immediately.
The pattern will then also be released in our regular catalog at the next release date and priced according to our regular stock price list at that time.
The cost for this service is US$ 89.99 for one pattern in .pdf format sent to you by email, and US$ 99.99 (plus postage) for one printed pattern sent via regular mail.
The usual 30% discount for ordering three or more patterns will be applicable if you decide to combine this order with stock patterns from our on-line store.
Ordering Information
Send us an email to email@example.com with information about the image, request size etc.
Happy Stitching!


text: With the holiday this week, garbage pickup days will be a little different for some people in the City of Washington. Luke's Sanitation will collect like they usually do today, but there will be no pickup tomorrow. To make up for the missed day, Tuesday's garbage will be collected on Wednesday along with what would normally be picked up and things will be back to normal on Thursday.


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Usage of Tune Hotels website states your compliance of our Terms & Conditions and Privacy Policy.
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We Know Worthington, OH Real Estate
Worthington has a lot to offer such as a weekly Farmers Market, Concerts on the Green, and the Worthington Arts Festival, which is ranked in the top 200 arts festivals in the country.
The community also has a state-of-the-art community center, the Griswold Center, and over 200 acres of parkland. Downtown Worthington has a small-town charm and offers local boutiques and great dining.
The Worthington Local School District has one preschool, eleven elementary schools, four middle schools, an alternative school, and two high schools. The school district also received an A+ rating by Niche.
HER Realtors are your local experts in Worthington, Ohio homes for sale and Worthington, Ohio Real Estate listings. There are currently 34 active listings of rental properties, land and lots, commercial real estate, and homes for sale in Worthington, Ohio. Worthington, Ohio has a current population of 14540 people and is considered is more family-centric than the surrounding county with 32% of the households containing married families with children. The county average for households married with children is 28%.
Worthington Ohio Homes for SaleSearch all >>
The median household income in Worthington, Ohio is $79,311. The median household income for the surrounding county is $48,620 compared to the national median of $49,877. The median age of people living in Worthington is 46.4 years.
Worthington, Ohio Weather
The average high temperature in July is 85.4 degrees, with an average low temperature in January of 19.7 degrees. The average rainfall is approximately 39.35 inches per year, with inches of snow per year. No weather information available.
Worthington Map
Worthington, OH real estate offices
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Modem Terbaru 2011 - Bagi pecinta kecepatan akses internet tentu membutuhkan modem terbaik dan terbaru 2011 dengan kualitas dan fitur terbaik. Untuk itu, blog info teknologi 2011 memberikan satu review modem dari D-Link.
Modem Terbaru 2011 Terbaik D-Link DSL-2320B
Produsen : D-Link Corporation
Kelebihan : Produk ini termasuk sebuah firewall terintegrasi dan VPN passthrough.
Kekurangan : Port USB opsional bukan versi tercepat USB.
Kesimpulan : D-Link DSL-2320B adalah modem DSL terbaik yang tersedia dalam saluran ritel.
Spesifikasi Modem Terbaru 2011 Terbaik D-Link DSL-2320B
The D-Link ADSL2/2+ Ethernet/USB Modem (DSL-2320B) enables you to access a high-speed DSL Internet connection. The DSL-2320B supports the latest ADSL2/2+ standards to provide higher performance (up to 24Mbps1 downstream and 3.5Mbps1 upstream) and longer reach from your Internet Service Provider's (ISP) Digital Subscriber Line Access Multiplexer (DSLAM). The DSL-2320B is also backward compatible with standard ADSL. To create a home or office network, simply add a multi-port router2.
Always on, always connected
Unlike a dial-up Internet service, a DSL Internet connection is always on so that you do not have to wait to access the Web. The DSL-2320B supports TR-067 standards ensuring compatibility with your ISP's infrastructure. This modem automatically detects your DSL settings to quickly establish a connection to the Internet. The DSL-2320B includes a simple configuration tool and a Web-based Graphic User Interface (GUI) that enables you to easily modify settings to connect to a DSL Internet service. The conveniently located LED indicators let you quickly check the modem's status and activity.
Choice of connectivity
The DSL-2320B offers both Ethernet and USB ports for flexible connectivity. The RJ-45 port enables you to connect an Ethernet device such a multiple-port router or an Ethernet-enabled computer. If the Ethernet port is not being utilized, then you can use the USB port to connect a USB-enabled computer and vice versa3.
The D-Link ADSL2/2+ Ethernet/USB Modem (DSL-2320B) is a great all-around high-speed DSL Internet access solution, whether you are a home user who requires a high-speed Internet access for faster file downloads, or a business user that relies on the Internet to conduct daily business.
About D-Link
Founded in 1986, D-Link is a global leader in the design, manufacture and marketing of advanced networking, broadband, digital, voice and data communications solutions. Following our company motto, "Building Networks for People", D-Link continually meets the global networking and connectivity needs of digital home consumers, small office professionals, small- to medium-sized businesses, and enterprise environments.
D-Link's core competency is in Ethernet connectivity. In fact, we are the global leader in providing network connectivity solutions to small and medium-sized business. From the beginning, D-Link engineers have researched, designed and manufactured innovative, standards-based networking solutions. We sell our state-of-the-art hardware at the best prices. Price may be the deciding factor for many new customers, but D-Link innovation, reliability and service keeps them loyal year after year.
A major contributor to our success is our established and expanding network of global distribution and delivery channels that brings products to more than 100 countries every day. We do more than meet the growing demand for computer networking and communications solutions - we fuel it. Our development of global distribution channels in more than 100 countries has resulted in double-digit growth every year for 20 years. D-Link surpassed the $1 billion revenue milestone in 2005, driven by record sales in every geographic region of the world.
D-Link's international headquarters are located in Taipei, Taiwan, Republic of China. More than 90 global offices serve North America, Asia and Europe, including the North American headquarters in Fountain Valley, California. D-Link maintains strategic operations in Canada, the United Kingdom, Germany, France, Spain, Italy, Greece, Turkey, Sweden, Norway, the Netherlands, Denmark, Finland, Russia, Israel, the Middle East, South Africa, Chile, Australia, Japan, Vietnam, Singapore, China, India and other countries on five continents.
Our engineers have been key contributors to the development of the rapidly expanding home and business networking environment we take for granted today. D-Link has been awarded patents and copyrights on a variety of technology platforms - including Application Specific Integrated Circuit (ASIC) computer chips, hardware technology designs, software applications and other intellectual properties. D-Link product solutions are high-performance and feature-rich by design.
As a key contributor to the Digital Home Working Group (DHWG), D-Link embraces industry standards as criterion for the development of new and innovative connectivity and communications solutions for home and business. D-Link products are certified by the FCC, the Wi-Fi Alliance and CableLabs.
Fitur Modem Terbaru 2011 Terbaik D-Link DSL-2320B
Windows/Mac/Linux : Yes Support
24Mbps downstream/2Mbps upstream : Yes Support
ADSL port (RJ-11) : Yes Support
Fast Ethernet port (RJ-45) : Yes Support
RoHS compliant : Yes Support
ADSL/ADSL2/ADSL2+ : Yes Support
Integrated firewall : Yes Support
VPN passthrough : Yes Support
USB port : Windows
Ease of Use
Diagnostic LEDs : Yes Support
Management method : Web UI
Firmware upgrade : Web UI
Installation : Web UI
Help and Support
Warranty : 1 year
Foto-Foto Modem Terbaru 2011 Terbaik D-Link DSL-2320B
D-Link DSL-2320B memang menjadi "Modem Terbaru 2011 Terbaik" untuk saat ini dan menjadi salah satu modem paling dicari, sementara untuk harga, modem ini dibanderol dengan harga $39.99.
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