THE 'FIT FOR 2017 BLUEPRINT' - NTEU-UTS FEEDBACK

THE ‘FIT FOR 2017 BLUEPRINT’ – NTEU-UTS FEEDBACK
‘Fit for 2027’ is the UTS response to the ‘current and future challenge’ to ‘ensure our strategic and
fiscal future’. Its driving imperative is clearly ‘fiscal’, not strategic. Its central goal is for UTS to be
debt-free by 2027 and to achieve this the university plans to start repaying bank debts from the
COVID crisis in 2022, to return to surplus by 2024, and to repay its existing $300m building bond by
2027. To do this it dedicates UTS, above all, to a ‘process to mitigate financial loss’. ‘Fit for 2027’
states it will draw on the previous UTS 2027 Strategy ‘core principles’, but also that it will be
rewriting the priorities, advancing some, ‘ceasing’ others. ‘Fit for 2027’ should therefore be
understood as the new UTS Strategy, superseding its predecessor. The long and considered UTS
2027 process of consensus-building to advance an agenda for a ‘public university of technology’ is
now to be subordinated to the imperative of shedding debt. Why?

This NTEU submission is framed around two sets of questions.

The first set of questions (Section A) centres on the range of assumptions that are outlined by ‘Fit for
2027’: What is the ‘deficit’?; Why the 150 additional Job Losses?; Why the 2022 goal for zero
deficit?; Is UTS carrying too much debt – or too little?; Why not borrow through the crisis?; Won’t
UTS be punished for going into debt?;

The second set of questions (Section B) arises from the proposed measures outlined in ‘Fit for 2027’:
What is the impact of a pan-UTS threat of forced redundancies?; Quick fixes or sustainable
solutions?; How do we provide feedback on vague concepts?; Systems and Processes: what is a
‘lifecycle’?; Operational efficiencies: how can we be more efficient with less staff?

A key problem in providing feedback on ‘Fit for 2027’ is the lack of meaningful information. There is
very limited data available on the COVID crisis and UTS finances. There have been meetings between
the NTEU and the UTS executive but no meaningful data has been released to the union by the
university either at these meetings or in other contexts.

Consequently, this submission relies on UTS annual reports, presentations to staff and the Blueprint
itself. These sources are supplemented by material released by external auditors, credit ratings
agencies, publicly released DESA data and reports in the finance media. The analysis presented here
is necessarily delimited but we believe is reliable.

A. ‘FIT FOR 2027 ASSUMPTIONS

1. What is the ‘deficit’?

It is important to put the 2020-22 deficit in context. The deficit is a temporary phenomenon driven
by the temporary problem of COVID. The deficit is immediate, in 2020, but the process of getting to
surplus need not be. As noted, ‘Fit for 2027’ aims to start paying back COVID-related bank loans in

2022, to achieve a surplus in 2024, and then for UTS to be debt-free by 2027. The University’s debt
aversion will undercut the capacity of the university to recover in years to come – we believe it is
misplaced and counter-productive.

‘Fit for 2027’ itself predicts a strong recovery from the COVID crisis. It shows that the 2019 gross
income from students falls from about $850m to about $775m by 2022, but then rises back to 2019
levels by 2023, and continues to rise to about $1,000m by 2027. This result is $175m or 15% below
the pre-COVID planned outcome for 2027 of about $1,175m. The reduction in anticipated student
revenue certainly signals a slowing from this source, 2020-2027, but it is still clearly on an overall
trajectory of expansion, equivalent to about 2% per year (from 4%).

When analysed from this medium-term perspective, across the UTS 2027 seven-year planning
horizon, the COVID crisis does not produce a deficit, but rather a reduction on anticipated growth in
income. This may require a reduction in the pace of expansion in continuing employment at UTS. To
shed staff early in the anticipated upturn would only undermine the capacity to recover.

Further, the reduced rate of growth for income from student load is itself only part of the picture.
Income from student load is only one source of UTS revenue. As outlined in ‘Fit for 2027’, the UTS
income 2020 is expected to be $1,050m. The anticipated deficit for 2020 of $83m is therefore not
even 10% of total UTS income. ‘Fit for 2027’ seeks to rewrite the entire UTS Strategy on the basis of
a temporary deficit that amounts to a relatively small proportion of the overall budget.

2. Why the 150 Additional Job Losses?

‘Fit for 2027’ seeks $100m savings in 2021 including $30m for staff cuts, estimated at 100-150
positions. Yet the 2021 deficit is in fact well below $100m, at $64m. There is no justification offered
for seeking the additional $37m (beyond the desire to minimise borrowing). Notably, if the savings
target was 64m in 2021 then there would be no need for additional staff losses.

It is unclear, even on the basis of the desire to balance the books by 2022, why the COVID deficit
requires the loss of an additional 150 continuing staff. ‘Fit for 2027’ announces that the anticipated
deficit is in fact much lower than projected, yet projects an unchanged target for additional job
losses. Logically a reduced deficit should mean a reduced requirement for job losses.

Ironically the Blueprint is caught between congratulating the university for mitigating the anticipated
losses and yet insisting that the staff cuts are needed:

Largely as a result of maintaining some international student enrolments through online learning, our
projected revenue loss while still very serious is towards the middle end of the range previously forecast. As a
result the financial outlook remains within the range previously forecast therefore staffing and other impacts
remain in line with the range previously advised. [p.7, l.20, emphasis added]

It was reported at the November meeting of Academic Board that natural staff attrition at UTS
exceeds the 100 to 150 staff reduction sought in the Blueprint. While natural attrition may decline in
2021 due to losses from the VSP, there is no clear reason why forced redundancies should be
required, especially given the existing workforce is clearly needed to work towards the recovery. If
more staff are lost now by 2022 the University will be competing for recruits with other Australian
universities while all overseas universities will also be looking for staff.

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3. Why the 2022 goal for zero deficit?

‘Fit for 2027’ clearly states that the timetable for breaking even by 2022 is determined by the need
to repay bank loans and a bond issue by 2027:

The most significant impact of the financial situation driving the need for additional, sustainable savings is to
our cash provision and the effect that this has on our ability to repay our debt, including the repayment of a
bond issue that is due in 2027. [p.9, l.13, emphasis added]

In 2017 UTS had borrowed $300m in the form of a bond, to finance Building 2, due to be repaid in
2027; it also negotiated access to $175m in loans with CBA and NAB should they be required - with
the COVID crisis it appears UTS used this facility to borrow $86m in 2020.

Under ‘Fit for 2027’ UTS will already reduce that bank loan to $20m in 2021. Bank borrowing will rise
slightly in 2022, to $57m, and then this will be paid back in 2024 and 2025, falling to zero by 2025. As
such, ‘Fit for 2027’ effectively aims to reverse the financial impact of COVID by 2025. This will then
allow the university to accumulate sufficient surplus to repay the $300m bond by 2027. A $26m
surplus is required in 2024, $46m in 2025, $49m in 2026, and $49m in 2027.

By 2027, on this plan, UTS will have no debts whatsoever.

The ‘Fit for 2027’ plan could no doubt take pride of place in any abstract rationalisation of financial
viability. But it has no place in the real world. Even householders know the benefits of raising loans
in order to, for instance, own a property, and students are routinely told they need to go into debt
to attend university and advance their prospects. Public institutions such as universities of course
have wide public responsibilities and capabilities, and borrowing to achieve future public aspirations
is not only necessary but prudent.

Most fundamentally, the financial plan, such at is, directly threatens UTS as a forward-looking,
agenda-setting institution able to imagine and prepare for the future. As discussed below, the plan
may deliver a debt-free UTS, but it will likely have achieved this at the cost of its staff and its own
strategic plan, endangering its future trajectory (and ironically erode the very foundations of its own
credit rating).

4. Is UTS carrying too much debt – or too little?

Under ‘Fit for 2027’ the desire to be free from debt is driving post-COVID operational plans. But
why? UTS has a history of being debt-averse – its capital works program, the ‘Campus Master Plan’,
of $1,300m was funded in the main by yearly surpluses, together with the $300m bond. The bond
pushed the UTS debt-to-revenue ratio from 1.2 to 1.7 though this did not affect the UTS credit
rating; the Moody’s UTS credit rating of Aa1 was retained with a ‘Stable Outlook’, though there was
some concern at the need for ‘greater revenue diversification’. 1

1
 Moody's assigns first-time provisional rating to the University of Technology Sydney's AUD Medium Term
Note Programme 03 Jul 2017 https://www.moodys.com/credit-ratings/University-of-Technology-Sydney-
credit-rating-825278605

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The reliance on surpluses to pay for buildings meant there was little in the way of a financial buffer,
leaving the university vulnerable to external shock, as manifest with COVID. This is revealed for
instance in the NSW audit office report from 2019 (p.23) which shows UTS maintaining relatively low
short term liquidity. 2 Yet there is a silver lining – Moody’s states that UTS currently has a relatively
‘low debt burden’ as compared with other universities. 3 Since 2017 other universities have
embarked on major borrowing programs, overtaking UTS. DESA collated data from 2018 shows UTS
with borrowing of $298m (current and non-current), behind Macquarie at $550m, UNSW $370m,
University of Sydney $596m; WSU borrowing stood at $174m though recently this substantially
increased, as discussed below. 4

With the COVID crisis some of the limitations of UTS reliance on student fee income to generate
surpluses was exposed. In June 2020 the impact of COVID was assessed and UTS retained its Aa1
rating but was given a ‘Negative Outlook’ reflecting ‘lower revenue from student fees that could
persist over the medium term’. 5 Nonetheless the UTS Aa1 rating was maintained due to the
university’s ‘position as Australia's top ranked university outside of the Group of Eight[1], and its
consistently high scores on key surveys of attractiveness to international students’. The university
leadership should be focused on maximising this UTS reputation for teaching and research, not its
reputation for financial rectitude.

5. Why not borrow through the crisis?

The financial position presents UTS with two options. As outlined in ‘Fit for 2027’ it could seek to
maintain its already low liquidity by cutting costs as proposed in ‘Fit for 2027’, but in the process it
would risk reducing capacity across the university to realise the projected increase enrolments
mapped out beyond 2022. Alternatively, it could choose to refinance the $300m bond and if
necessary increase its borrowing, in line with other comparable universities. This would buy it some
time, perhaps through to 2027, to address the impact of the COVID crisis, while at the same time
retaining (and expanding) the foundations of its success, namely its research and teaching
reputation (and the basis for its Aa1 rating).

The necessity to borrow through the crisis, in order to maintain capacity to recover from it, is
recognised by every financial institution, and indeed by the Government. The Governor of the
Reserve Bank of Australia recently stated that ‘creating jobs for people is much more important than
preserving credit ratings’; we would argue that the same holds for public universities, to act in the
longer term interests of society rather than what they presume to be their own narrow short term
financial interests. 6

2
  NSW Audit Office, Universities 2019 Audits, 4 June 2019.
3
  ‘Moody's changes outlook on University of Technology Sydney to negative, affirms Aa1 rating’, 26 Jun 2020.
https://www.moodys.com/credit-ratings/University-of-Technology-Sydney-credit-rating-825278605
4
  HEPs Finance Tables, DESA: https://docs.education.gov.au/node/53363
5
  Moody’s. ‘Moody's changes outlook on University of Technology Sydney to negative, affirms Aa1 rating’, 26
Jun 2020. https://www.moodys.com/credit-ratings/University-of-Technology-Sydney-credit-rating-825278605

6
 https://www.abc.net.au/news/2020-08-14/rba-governor-phil-lowe-credit-ratings-not-important-
coronavirus/12559044

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The NSW Government policy now anticipates recurring deficits for at least five years, and is explicitly
focused on supporting the private sector through the crisis. As the NSW Treasurer has stated:

‘Success is going to be in five, 10 years' time where people look back and see where the New South Wales
economy has come from… There has never been a better time to borrow.’ 7

Reflecting this, the NSW Government has specifically offered to guarantee University borrowing in
order to enable them to finance current deficits: $750m in load guarantees has been made available
though it is unclear if this has been taken-up. 8

Refinancing its current bond, issuing a new bond and maintaining bank loans would enable the
University to weather the storm, retaining its staff to allow the recovery (it could also allow the
university to retain its student accommodation - one of the more obviously counter-productive
aspects of ‘Fit for 2027’ is the proposal to sell student accommodation).

6. Won’t UTS be punished for going into debt?

There may be concerns from UTS that additional borrowing could undermine the UTS credit rating,
making it more expensive for UTS to obtain loans in the future. This concern is misplaced, for several
reasons.

First, and most important, the current cost of borrowing is lower than it has been in decades. The
$300m UTS bond was taken out in 2017 at an annual bond yield of 3.75%. 9 The current rate for
Government bonds (generally the lowest rate as these are lowest risk) is at 0.87% annually for a 10-
year bond. 10 The Reserve Bank now is targeting a three-year bond rate of 0.1%, and has introduced a
wide range of measures to purchase bonds and increase the flow of funds into lending. 11 There
would be a small risk premium on a bond issue for a public university like UTS, but only on the
margins: the cost of borrowing to weather the current crisis would be negligible.

Second, it is not clear that increased UTS borrowing would in any way affect the UTS credit rating.
The credit assessment cited above, from June 2020 suggests that UTS is under-borrowing and that
this if anything increases the risk of investing in UTS as the university has a policy of running down its
cash reserves to an excessive and unnecessary degree, destabilising its capacity to maintain its
underlying reputational profile.

Third, even if the UTS credit rating is reduced, and, for instance it moves from Aa1 to Aa2, then it is
not clear what impact this will have, if any. Borrowing costs, as noted, are already approaching zero,
and there is no shortage of investment finance looking for a relatively safe haven in the form of a
publicly funded institution. Other universities in the Sydney region have an Aa2 rating – Macquarie

7
  https://www.abc.net.au/news/2020-11-16/nsw-budget-perrottet-borrows-to-build-out-of-economic-
crisis/12885110
8
  https://www.timeshighereducation.com/news/australian-state-guarantee-universities-loans

9
    https://cbonds.com/bonds/337905/
10
     http://www.worldgovernmentbonds.com/country/australia/
11
     https://www.rba.gov.au/covid-19/
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and Western Sydney University (WSU) for instance, with the latter raising considerable loans in
November to cover its campus-building program.

The WSU case is instructive as it offers an interesting counterpoint to the UTS ‘Fit for 2017’ model. In
2019 UWS gained its Aa2 rating from Moodys and has since announced a series of initiatives,
including the $350m campus at Bankstown. 12 In November 2020, under the COVID crisis, increased
indebtedness at WSU was endorsed by Moody’s as follows:

Moody's expects WSU will use the program to partially fund its Western Growth[1] strategic plan, including
revitalising the university's campus network and repurposing existing assets to generate a corpus to re-invest
into learning, teaching and research. The drawdowns from the program are also expected to lengthen the
university's debt maturity profile to make it more consistent with the duration of its capital works. 13

It is interesting that the assessment recognises the merits of borrowing, not simply to invest in new
capital works, but also to invest in ‘learning, teaching and research’. This focus on academic staff
expenditure, and especially for teaching staff, is confirmed by another credit ratings agency, S&P,
that provides ratings of several other universities in Australia. 14

B. ‘FIT FOR 2027’ MEASURES

1. What is the impact of a pan-UTS threat of forced redundancies?

The announcement of University-wide restructuring geared to achieving the required cost savings
anticipates forced redundancies, termed ‘role removal’, for up to 150 staff. This announcement has
a direct effect on all continuing staff at UTS, creating a state of heightened anxiety. This exacerbates
the pressures due to additional workload as the university sheds numerous casual and fixed term
staff and continuing staff through voluntary separation. The increased stress caused by the VSP and
now the announcement of further redundancies is having a significant impact on the health and
wellbeing of staff.

In recent presentations on ‘Fit for 2017’ the university has insisted on the necessity for pan-UTS
redundancies while in the same breath referring staff to EAP. This is a misuse of the EAP program.
Already staff are experiencing overload; adding to this the unnecessary threat of forced redundancy
clearly breaches the university’s duty of care as spelt out in WHS legislation. The NTEU has been
contacted by many staff members whose mental health has seriously deteriorated due to the levels
of work-related stress they are experiencing. The university is exacerbating the problem of work-
related stress when it is under a duty of care to ameliorate it: announcing no forced redundancies
and prioritising staff retention would be an important first step.

12
   https://www.westernsydney.edu.au/newscentre/news_centre/story_archive/2019/strong_credit_rating_a_
positive_reflection_on_the_university_and_its_role_in_transforming_western_sydney;
https://theurbandeveloper.com/articles/walker-works-on-340m-wsu-vertical-campus
13
   Moody's assigns first-time (P)Aa2 rating to Western Sydney University's medium-term note program, 10 Nov
2020.

14
  https://www.afr.com/work-and-careers/education/ratings-tell-a-good-story-for-unis-but-some-are-better-
than-others-20200129-p53vv7

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Under the UTS Enterprise Agreements the university states unconditionally that forced redundancies
are a last resort:

 ‘The University recognises that job security is important for staff and is committed to minimising the need for
forced redundancies by exploring alternative measures… Forced redundancies will be implemented as a last
resort’ (clause 55 Academic EA, 59 Professional EA)

As outlined above there are many ways of mitigating the situation to prevent resort to forced
redundancies at UTS. ‘Fit for 2027’ chooses to create a context where forced redundancies are
required. If the university was genuinely concerned to ensure that ‘redundancies will be
implemented as a last resort’ then it would choose a different course. The NTEU believes that ‘Fit for
2027’, in preparing the ground for potentially 150 forced redundancies at UTS, is potentially
breaching its obligations in the EA to implement forced redundancies as a last resort.

2. Quick fixes or sustainable solutions?

The Blueprint is disappointing in its lack of vision, but more concerning is its lack of consideration of
the risk of long-lasting reputational damage from its proposed initiatives, especially for the
University’s core business of teaching and research. The proposal to ‘cluster’ professional services is
also concerning.

Whilst no staff or student would support an obviously inefficient service, efficiency cannot be
understood purely in terms of the cost of the service. A student or staff member seeking the services
of professional staff will be rating the service in terms of its quality, and most importantly, ‘was my
need served’, not by how much it costs the University. In a university organised largely around
different ‘professions’, it is not surprising that each faculty - and in some cases schools within
faculties – have developed distinctive systems and methodologies for managing a range of student-
related services.

For example, the nature of the work-integrated learning that is part of their course in one program
may require certain ways of working with industry and other partner organisations, but the same
system may not work in another program because of differences in the nature of work-integrated
learning and the types of partners they work with. The effectiveness (and efficiency) of these
systems rely heavily on relationships built between academic units and external partners as well as
deep engagement with external partners.

There have been a number of attempts in the past at centralising UTS services, for example, moving
student administration from faculty units to building-based units. ‘Fit for 2027’ now proposes
university-wide services across the board. Centralisation of this kind can be depersonalising and
counterproductive, creating reduced efficiency with a triple handling of cases, from student to
academic to school administrator to central service for instance. If clustering of professional services
is to be considered, this cannot be undertaken under any preconceived assumption that
centralisation is necessarily the best option. In many circumstances, decentralisation may be more
effective and efficient. An open mind is required, with a genuine consultation process, negotiated
with staff and student representatives, giving voice and using evidence from the people who are
providing and receiving these services.

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3. How do we provide feedback on vague concepts?

The Blueprint contains a number of streams and proposed outcomes but each is characterised by a
lack of concrete examples and overall vagueness. The information sessions have not provided any
greater clarity and many questions asked at these sessions have been met with vague answers.
There has also been very little transparency regarding the rationale or how the assumptions on the
potential benefits have been reached. This lack of clarity makes it very difficult to provide specific
feedback. How is it possible to provide feedback on concepts that are not supported by concrete
examples, case studies or data? This vagueness makes the Blueprint document very difficult to
evaluate and adds to the growing uncertainty around the future at UTS for staff.

By way of illustration, the Blueprint section on ‘scale and scope’, offers a number of components:

1. Identification of new approaches, operational efficiencies and cessation of lower priority activities, as well as
continuous improvement programs:

    •    Potential clustering of professional support across faculties
    •    Facility and property usage
    •    Data strategy
    •    Divisional portfolio realignment
    •    UTS Insearch support integration.

Changes in delivery of services arising from these proposals will lead to savings of approximately $15m (in
addition to VSP savings already achieved).

2. Achieving the right size and scope for changing student demand:

    •    Teaching priorities
    •    Discipline mix
    •    Research priorities.

It isn’t clear what any of these measures refer to. Is ‘right size and scope for changing student
demand’ a euphemism, and if so for what? Making such open-ended statements and leaving staff to
‘read between the lines’ or more accurately to ‘read the tea leaves’ only creates a heightened state
of uncertainty and anxiety.

There has been no further clarity on offer in the ‘Fit for 2027’ information sessions, with vague
references to the need to ‘streamline all processes’, ‘remove the waste’, ‘remove duplication’,
‘increase efficiency’, and no evidence to demonstrate what is inefficient and why. Neither the
Blueprint nor the information session inspire any confidence that ‘clustering’ will not result in the
reduction of already stretched support services for staff and students. And how can it be guaranteed
that the specialist knowledge of professional staff in specific areas will not be lost or diminished with
the proposed sharing of services across faculties or units?

4. Systems and Processes: what is a ‘lifecycle’?

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The Blueprint refers to ‘learner lifecycles’ and ‘staff lifecycles’, but again, these terms are not clearly
defined or articulated. If the ‘learner lifecycle’ is referring to the ways in which students might access
education at different stages of their lives (ie, as recent school leavers, or mature-aged students etc),
then what evidence is available to show what kind of educational experiences they are likely to be
looking for? If there is to be a ‘greater focus on employability of graduates through the integration of
work-integrated learning into learning design’, what are the implications for academic staff in terms
of course design and delivery? Will academic staff be consulted on the best pedagogical approaches,
or will be handed down from those ‘in the know’?

‘Staff lifecycle’ includes reference to the ‘New Ways of Working Initiative’, but the information
provided in the New Ways of Working page is vague and lacks concrete examples. What exactly does
this entail, what could be the specific effects on staff workloads? There is also reference to a need to
‘explore the use of better workload planning tools’. Does this mean staff will be consulted over
workload allocation, or that there are plans for new workload models? If other elements of the ‘staff
lifecycle’ are to be reviewed, such as ‘recruitment, development and performance
management/support’, this need to be in line with the staff enterprise agreements. The ‘systems
and processes’ section states that outcomes will need to be met via ‘redeployment and/or
realignment of existing activities across Student Administration, UTS International, and Marketing
and Communications’. What are the implications in terms of staffing and of the potential impact on
support services for staff and students?

5. Operational efficiencies: how can we be more efficient with less staff?

As well as the clustering mentioned above, the ‘operational efficiencies’ section also refers to
possible automation of services , along with ‘streamlining of data management’, ‘activity reduction
or elimination’. How will this be achieved? Are there plans to outsource services to cheaper
providers? What kinds of activities can be reduced or eliminated? What kind of consultation will
occur in targeted areas? If ‘alignment’ is to occur in ‘relevant areas in Insearch’, what does this
mean? Will Insearch staff become UTS employees?

If there is to be consideration of selling or leasing current teaching space, will this mean a more
permanent move to online teaching? If so, has there been any consultation with students regarding
their preference for online or on-campus learning? The move to online learning as a result of COVID
was rapid and a crisis-response. It was not based on research into learning delivery or consideration
of the different pedagogies involved in online-only learning. Academic staff attempted to replicate
on-campus classes online in order to minimise the disruption already faced by students. No evidence
has been provided to demonstrate that students want online-only classes/learning delivery; in fact,
many staff have anecdotal evidence to the contrary..

RECOMMENDATIONS

A. Financial policy

1. UTS should refinance its current $300m bond for Building 2 for at least a further 5 years given that
the University should not be required to repay the loan until it is able to reap the rewards from the
investment.

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2. UTS should take out a new $300m loan to finance the original UTS 2027 program as an investment
in future capacity at UTS to meet emerging educational and research needs into the post-COVID
context.

3. UTS should extend the repayment schedule for its current bank loans over the full 2020-2027
period.

B. Institutional policy

1. UTS should announce a policy of no forced redundancies under the COVID crisis as part of its
obligation to minimise workplace stress and anxiety and its commitment to social justice.

2. UTS should retain all currently-owned student accommodation as an important foundation for the
future growth.

3. UTS should only open discussions on the question of clustering services if the option of
decentralised clusters is on the table as well as the possibility of centralised clusters.

4. UTS should undertake a self-assessment of all of its proposals against its own espoused vision and
principles of - a lifetime of learning, personal learning etc, before proposing changes that are
arguably in direct conflict with some of these commitments.

5. UTS should be planning for the long term, and using this recovery period to invest in its future
growth rather than shedding staff and capital.

6. UTS should extend the deadline for feedback on ‘Fit for 2027’ by at least two weeks.

7. UTS should publish a synthesis of the staff feedback and UTS management’s response to this
feedback within two weeks of the close of this round of feedback. UTS should then open a second
round of consultations with staff based on this published information..

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