Agenda item
Medium Term Financial Strategy and 2024/25 Revenue Budget
Report of the Deputy Chief Executive and City Treasurer attached.
Minutes:
The Executive considered a report of the Deputy Chief Executive and City Treasurer, which set out the strategic and financial context which supported the 2024/25 Budget based on the outcome of the Final Local Government Finance Settlement.
The report went on to set out the strategic and statutory context for setting the budget, which included:-
· The Our Manchester Strategy;
· Progress to date on delivering the Our Manchester Strategy,
· The Corporate Plan;
· A summary of the financial position and context;
· The required statutory assessment of the robustness of the proposed budget and adequacy of proposed reserves;
· Other fiduciary and statutory duties; and
· Financial Governance.
The Medium-Term Financial Strategy (MTFS), approved in February 2023, recognised that significant budget cuts would need to be delivered over the Spending Review period to set a balanced budget in future years. When the three-year MTFS was presented in February 2023 an indicative balanced 2024/25 budget was set out. The forecast gap for 2025/26 was £40m.
It was reported that the provisional finance settlement had been disappointing. Despite the well reported financial difficulties being faced by Local Authorities across the sector there was no new funding for public services announced and instead, an unexpected 84% cut in core funding Services Grant was announced. The budget impact of the provisional settlement was a £2.4m worsening of the position for 2024/25, expected to rise to £5.3m in 2025/26. At the same time the in-year budget position for the Council was worsening meaning that the budget needed to allow for topping up the General Fund reserve by at least £1m to maintain the reserve at a reasonable level to enable the overspend to be funded.
In addition to the settlement announcement, Manchester continued to face growing pressures in social care and homelessness. In the last two months there had been an increase in children's placement numbers and costs, further significant pressures across ASC budgets and some worrying trends in asylum seekers/migrant policy/homelessness. This was in line with national trends and core cities and other GM authorities were all reporting similar issues.
Work throughout January quantified the full year effect of the increased numbers of residents requiring care and support, which came to £18.4m. After demand management and proactive mitigations of £8.4m this had been reduced to an additional budget requirement of £10m in 2024/25. Whilst extremely challenging it was important that a realistic and deliverable budget was set which recognised these additional pressures and allowed a realistic budget to be set. As such the following mitigations had been proposed to finalise the revenue budget:-
· A £5.5m Greater Manchester Combined Authority waste levy rebate
· £0.6m final GMCA levy announcements
· £3.93m through improved Council Tax and Business Rates collection,
· including the introduction of a 100% Council Tax premium on
· unfurnished empty homes.
· £1.5m through extra income from buildings owned by the Council –
· through increased rental charges and the renting out of vacant units
· £1.2m through interest on airport loans and investments
· £1m through energy savings due to reductions in wholesale prices
· £0.5m through the rephasing of ICT investments
· £0.5m through the rephasing of Growth & Development investments
· £0.3m through in-year underspends in back office budgets and
· reduced travel costs
It was important to note that £8.53m of the measures proposed to close the £15m gap are non-recurrent, meaning more permanent proposals would need to be found for 2025/26 and beyond as illustrated below:-
|
2024 / 25 |
2025 / 26 |
2026 / 27 |
|
£'000 |
£'000 |
£'000 |
Position reported to Executive February 2023 MTFS |
0 |
40,392 |
54,164 |
Directorate Pressures |
25,325 |
32,589 |
38,653 |
Other changes including confirmation of 100% business rates retention |
(21,170) |
(40,636) |
(41,327) |
Directorate Savings |
(2,500) |
(2,500) |
(2,500) |
Position reported to Resources and Governance 9 Nov 2023 |
1,655 |
29,845 |
48,990 |
Provisional Settlement changes |
2,374 |
6,403 |
6,394 |
Increase General Fund to reflect worsening overspend |
1,000 |
0 |
0 |
Revised Shortfall / (surplus) after settlement reported to Resources and Governance 11 Jan 2024 |
5,029 |
36,248 |
55,384 |
Full year impact of increased Social Care pressures |
10,000 |
10,000 |
10,000 |
Mitigations identified January 2024 |
(15,029) |
(17,448) |
(24,619) |
Shortfall / (surplus) |
0 |
28,800 |
40,765 |
As such, Savings options had been developed consisting of £21.3m for 2024/25 and £10.1 for 2025/26:-
|
Amount of Saving |
Indicative FTE Impact |
|||
Service Area |
2024/25 |
2025/26 |
2026/27 |
Total |
|
|
£’000 |
£’000 |
£’000 |
£’000 |
|
Adults Services |
7,855 |
2,200 |
0 |
10,055 |
0 |
Public Health |
15 |
0 |
0 |
15 |
0 |
Childrens Services |
6,142 |
3,394 |
0 |
9,536 |
0 |
Neighborhoods |
4,211 |
3,104 |
0 |
7,315 |
3 |
Corporate Core |
1,359 |
1,089 |
0 |
2,448 |
37 |
Growth and Development |
1,460 |
315 |
0 |
1,775 |
1 |
Cross Cutting |
332 |
0 |
0 |
332 |
0 |
Total Savings |
21,374 |
10,102 |
0 |
31,476 |
41 |
Taking into account the above changes to the financial assumptions; the impact of the Autumn Statement and final Finance Settlement; the setting of the Council Tax and Business Rates base and Collection Fund surplus and the changes to savings and investment proposals, the forecast budget position was:-
|
2023 / 24 |
2024 / 25 |
2025 / 26 |
2026 / 27 |
|
£'000 |
£'000 |
£'000 |
£'000 |
Resources Available: |
|
|
|
|
Business Rates / Settlement Related Funding |
376,527 |
406,999 |
418,394 |
425,002 |
Council Tax |
217,968 |
231,034 |
249,114 |
266,520 |
Grants and other External Funding |
130,494 |
142,907 |
104,614 |
104,614 |
Dividends |
0 |
195 |
390 |
390 |
Use of Reserves |
17,087 |
29,380 |
32,853 |
27,982 |
Total Resources Available |
742,076 |
810,515 |
805,365 |
824,508 |
Resources Required: |
|
|
|
|
Corporate Costs: |
|
|
|
|
Levies / Statutory Charge |
70,060 |
72,463 |
78,806 |
78,610 |
Contingency |
600 |
600 |
600 |
600 |
Capital Financing |
43,926 |
43,926 |
43,926 |
43,926 |
Transfer to Reserves |
1,335 |
8,968 |
0 |
0 |
Sub Total Corporate Costs |
115,921 |
125,957 |
123,332 |
123,136 |
Directorate Costs: |
|
|
|
|
Additional Allowances and other pension costs |
8,497 |
8,497 |
8,497 |
8,497 |
Insurance Costs |
2,004 |
2,004 |
2,004 |
2,004 |
Inflationary Pressures and budgets to be allocated |
2,101 |
17,357 |
33,492 |
50,226 |
Directorate Budgets |
613,553 |
656,700 |
666,788 |
681,267 |
Subtotal Directorate Costs |
626,155 |
684,558 |
710,781 |
741,994 |
Total Resources Required |
742,076 |
810,515 |
834,113 |
865,130 |
Shortfall / (surplus) |
0 |
0 |
28,748 |
40,622 |
The report explained that the Council's net revenue budget was funded from five main sources: Business Rates, Council Tax, government grants, dividends, and use of reserves. In recent years the on-going reductions in central government funding had increased the importance of growing and maintaining local income and local funding sources, which was now integral to the Council’s financial planning. The total resources available to support the Council’s net budget position was as follows:-
|
Revised 2022 / 23 |
2023 / 24 |
2024 / 25 |
2025 / 26 |
|
£'000 |
£'000 |
£'000 |
£'000 |
Resources Available |
|
|
|
|
Business Rates / Settlement Related Funding |
235,553 |
374,725 |
380,005 |
386,872 |
Council Tax |
208,965 |
217,968 |
228,087 |
237,279 |
Grants and other External Funding |
104,559 |
126,439 |
127,968 |
116,055 |
Dividends |
0 |
0 |
0 |
0 |
Use of Reserves |
141,522 |
17,087 |
31,861 |
28,372 |
Total Resources Available |
690,599 |
736,219 |
767,921 |
768,578 |
The assumption in regards Council Tax was that the Council would apply a 2.99% Council Tax increase in the basic amount, and a further 2% increase to provide extra funding for Adult Social Care, equating to a 4.99% Council Tax increase overall.
2023/24 C’Tax |
2025/25 C’Tax |
Proposed Increase |
Increase per week |
||
£ |
£ |
£ |
% |
£ |
|
Manchester City Council - Band D |
1,969.50 |
2,068.25 |
98.75 |
5.01% |
1.90 |
Manchester City Council - Band A |
1,312.99 |
1,378.83 |
65.84 |
5.01% |
1.27 |
Band A receiving CTS at 82.5% plus CTS Fund of £25 in 2023/24, compared to 2024/25 at 85.0% |
204.77 |
206.83 |
2.05 |
1.00% |
0.04 |
It was also reported that the forecasted council tax collection rate was 96.5% in 2024/25, and an increase in the council tax base of 2.0% was forecasted reflecting housing growth within the city. This would bring an additional £5.6m income
The report examined the future funding uncertainties facing the Council. The Deputy Chief Executive and City Treasurer had examined the major assumptions used within the budget calculations and had carried out sensitivity analysis to ascertain the levels of potential risk in the assumptions being used. The key risks identified to the delivery of a balanced budget and their mitigation were set out in the report.
The details of the Business Rate calculations, forecasts and assumptions were set out in the report, as well as the financial changes arising from the business rate related grants and funding the government had provided to support businesses.
The report provided a breakdown of the other non-ringfenced grants and contributions included in the budget. The most significant grants and contributions were described in detail in the report.
|
2023 / 24 |
2024 / 25 |
2025 / 26 |
2026 / 27 |
|
£'000 |
£'000 |
£'000 |
£'000 |
Better Care Fund (Improved) |
31,748 |
31,748 |
31,748 |
31,748 |
Children's and Adult's Social Care Grant |
50,695 |
65,773 |
60,218 |
60,218 |
Market Sustainability and Fair Cost of Care Fund |
10,298 |
11,664 |
11,664 |
11,664 |
Adult Social Care Discharge Fund |
4,451 |
7,420 |
7,420 |
7,420 |
2022/23 Services Grant |
7,230 |
1,248 |
0 |
0 |
New Homes Bonus Grant |
6,637 |
4,109 |
0 |
0 |
Loan Income from Airport |
6,913 |
7,913 |
1,000 |
1,000 |
Contribution from MHCC |
4,000 |
4,000 |
4,000 |
4,000 |
Education Services Grant |
1,055 |
955 |
955 |
955 |
Housing Benefit Admin Subsidy |
2,514 |
2,514 |
2,514 |
2,514 |
Care Act Grant - Prison only from 16/17 |
95 |
95 |
95 |
95 |
Settlement Risk |
|
|
|
|
Proposed share of waste rebate |
4,858 |
5,468 |
0 |
0 |
Settlement risk |
0 |
0 |
(15,000) |
(15,000) |
Total Non Ring-fenced Grants |
130,494 |
142,907 |
104,614 |
104,614 |
The report also examined the use of resources and the proposed revenue expenditure by the Council in 2024/25. The forecast of levy payments the Council would have to make to other authorities in 2024/245 was:-
|
2023 / 24 |
2024 / 25 |
2025 / 26 |
2026 / 27 |
|
£'000 |
£'000 |
£'000 |
£'000 |
GMCA - Waste Disposal Authority |
30,632 |
31,809 |
33,059 |
34,669 |
Transport Levy |
39,076 |
40,289 |
41,901 |
43,577 |
Statutory Charge to GMCA |
0 |
0 |
3,481 |
0 |
Environment Agency |
258 |
258 |
258 |
258 |
Port Health |
94 |
96 |
96 |
96 |
Net Cost of Levies |
70,060 |
72,452 |
78,795 |
78,599 |
The waste disposal levy was paid over to Greater Manchester Combined Authority (GMCA) and this contributed towards their costs of funding Greater Manchester Waste Disposal Authority (GMWDA). Based on figures provided by GMCA the 2024/25 levy costs were to increase by £1.2m inclusive of changes in costs, recycling rates and market prices for recyclates and energy. The Transport Levy was to cover the costs of providing the greater Manchester integrated transport system, including the Metrolink and subsidised bus services, as well as transport infrastructure developments. The final amount would be decided as part of the GMCA budget process. In addition the ten GM authorities had committed to contributing toward the GM Mayors bus franchising policy, and bus reform. The £3.481m in 2025/26 reflected the council’s contribution for this.
The capital financing budget of £43.926m was to cover the costs of borrowing. For 2024/25 the forecast breakdown included:-
? Costs of £91.5m as follows:
· Interest costs of £51.0m,
· Minimum Revenue Provision (MRP) of £40.2m, being the provision for the repayment of debt incurred to fund an asset, spread over the useful economic life of the asset,
· Debt Management Expenses of £0.3m, and
? Partly offset by:
· interest receivable of £46.2m; and
· Contribution from capital financing reserve of £1.4m
Allowances of £8.497m had also been made for retired staff and teachers’ pensions to meet the cost of added-years payments awarded to former employees.
The report explained the main assumptions that had been made when calculating provision to be made for inflation and other anticipated costs. These could not, at this point in time, be allocated to Directorate or other budgets. They would instead be allocated throughout the coming year. The total provision being proposed was £7.169m for 2024/25, broken down into:-
2023 / 24 |
2024 / 25 |
2025 / 26 |
2026 / 27 |
|
|
£'000 |
£'000 |
£'000 |
£'000 |
Non Pay Inflation |
1,041 |
9,497 |
14,300 |
19,300 |
Pay Inflation |
0 |
11,100 |
22,400 |
34,100 |
Apprentice Levy (0.5%) |
1,060 |
1,092 |
1,124 |
1,158 |
Utilities Reductions |
0 |
(4,000) |
(4,000) |
(4,000)
|
Cross Cutting Savings |
0 |
(332) |
(332) |
(332) |
Total |
2,101 |
17,357 |
33,492 |
50,226 |
Year on year Impact |
2,101 |
15,256 |
16,136 |
16,734 |
The report explained that the Council held a number of reserves, all of which, aside from the General Fund Reserve, had been set aside to meet specific future expenditure or risks. A full review of all the reserves held had been carried out as part of the budget setting process and the planned use of reserves in 2024/25 to support revenue expenditure was as follows:-
|
2023 / 24 |
2024 / 25 |
Spend supported by the reserve |
|
£'000 |
£'000 |
|
Reserves directly supporting the council wide revenue budget: |
|
|
|
Airport Dividend reserve |
1,073 |
13,116 |
The balance of £14.2m has been applied to support the MTFP budget in 2023/24 (£1.1m) and 2024/25 (£13.1m). |
Budget Smoothing Reserve |
0 |
3,742 |
Created through underspends in precious years as reported through Executive and from transfers from other reserves following a full review. It has been applied across the next four years to reduce the requirement for savings and smooth the funding cliff edge until the future funding position becomes clearer. |
Business Rates Reserve |
7,166 |
0 |
Business rates relief provided over the pandemic and funded by Government. Applied to offset Collection Fund deficit in arrears. |
Use of St Johns growth reserve to support revenue budget |
1,156 |
830 |
Growth in business rates income in the St Johns footprint, used to support the budget |
Use of reserves to contribute to the cost of Anti Poverty measures |
0 |
2,000 |
Contribution to the additional £3.5m support which has been provided to support residents through the Cost of Living crisis |
Contribution to GMCA relating to bus reform |
0 |
0 |
£3.5m contribution to GMCA relating to budget reform. Note this is funded from rebates previously received from GMCA. |
Use of Smoothing reserve to fund Adult Social Care budget for New Care Models |
1,300 |
1,300 |
An investment of £1.3m per year 2023-26 will sustain the social work infrastructure and reablement capacity, supporting care models covering Crisis, Discharge to Assess and Manchester Case Management. |
Use of Bus Lane and Parking reserves reserve to support transport levy |
6,392 |
8,392 |
This includes the continuation of £6.3m a year agreed in previous years, an additional contribution from annual trend growth and £1m from 2024/25 increasing to £2m 2025/26 funded through forecast income from moving Traffic offences. |
Sub Total |
17,087 |
29,380 |
|
Ring-fenced Reserves outside the General Fund: |
|
|
|
HRA Reserves |
11,814 |
25,675 |
HRA reserves are ringfenced – not available to support Council position. Significant balance to support future capital investment, including Carbon reduction and increased housing provision. The HRA must balance in year, and work is ongoing to identify sufficient savings to ensure this is the case. Much of the reserve will be used during this period. |
School Reserves |
0 |
0 |
Ringfenced – School balances not available to support the Council position. The expected 22/23 drawdowns are based on returns from schools. |
Sub Total |
11,814 |
25,675 |
|
Other Earmarked reserves: |
|
|
|
Statutory Reserves |
8,179 |
6,597 |
Can only be used for specific purposes under statute e.g. Bus Lane Enforcement and on street parking income which support costs associated with transport provision and highways / environmental improvements. Some of the reserve funds the free bus from Piccadilly and the Transport levy. |
Balances Held for PFI's |
65 |
198 |
Held to meet costs across the life of the PFI schemes |
Managing economic and commercial risks |
5,890 |
7,166 |
These reserves help manage annual fluctuations in income including planning, investment and licencing. A significant part of the Planning Reserve will be required to support the development of the Local Plan. |
Insurance Fund |
500 |
500 |
Insurance fund reserve to meet uninsured risks, amount required is estimated each year. |
Capital Fund Reserve |
40,708 |
14,117 |
Contribution to schemes which are supporting employment and growth, future carbon reduction investments and high priority strategic development opportunities in the city. |
Investment Reserve |
1,873 |
2,047 |
This reserve is in place to support regeneration projects. The proposed use includes funding for staffing posts in Strategic Housing, Major Regeneration, the Investment Estate, and City Centre Regeneration |
Manchester International Festival Reserve |
2,659 |
1,000 |
To fund agreed contributions to Factory International |
Eastlands Reserve |
4,389 |
4,050 |
This reserve reflects the contribution from Manchester City Football Club and will be used for various projects including English Institute of Sport. |
Town Hall Reserve |
2,103 |
2,917 |
The refurbishment of the Town Hall, which is included within the Capital Programme Budget will also have revenue implications such as the cost of financing capital, alternative accommodation costs, and loss of income over a number of years; offset in part by reduced spend on maintenance and utilities |
Enterprise Reserve |
99 |
102 |
Enterprise Zone reserve which will fund EZ Manager post and activities to attract businesses to the zone |
Highways Commuted Sum |
89 |
89 |
Highways Commuted sums contribute towards future maintenance |
Other reserves held to support delivery and risk of the Medium Term Financial Plan |
7,332 |
3,534 |
Includes funding for to drive the delivery of Our Manchester; (for example through providing Voluntary Sector Grants) and Supporting Families reserve to support the Thriving Families initiative, a whole family, strengths-based approach to child protection. |
Reserves held for accounting purposes |
6,672 |
4,069 |
Relates to grants received - under accounting standards these must be held in a reserve to move between financial years. |
Making Manchester Fairer |
2,089 |
900 |
To provide capacity to fund the kickstarter schemes supporting the Making Manchester Fairer ambition |
Adult Social Care Reserve |
5,264 |
2,449 |
To support Adult and Social Care Improvement Plan |
ICT Investment Reserve |
1,914 |
16,866 |
To support ICT Digital Strategy |
Other Specific Reserves |
2,562 |
4,448 |
Includes Community Safety, Primary School Catering and Social Value Fund |
General Fund |
6,206 |
0 |
Forecast drawdown of General Fund reserve |
|
127,494 |
126,103 |
|
Where reserves were used to support the Council’s overall budget position or corporate expenditure such as levies, these were shown gross as part of the Resources required. The use of these reserves totalled £29m in 2024/25. Of this £13m is from the airport reserve, £1.3m for New Care Models, £2m to support anti poverty and £8.3m supporting the transport levy.
The proposals for the Directorates’ cash limit budgets were detailed in the Directorate Budgets 2024/25 reports that were also being considered at the meeting (Minute Exe/24/17 to 24/26 below). The overall position was:-
|
2023 / 24 Revised |
2024 / 25 |
||
|
Net Budget |
Gross Budget |
Net Budget |
Gross Budget |
|
£'000 |
£'000 |
£'000 |
£'000 |
Children Services |
143,806 |
607,129 |
156,383 |
631,740 |
Adults Services |
219,666 |
285,023 |
247,439 |
314,972 |
Public Health |
43,266 |
54,126 |
45,016 |
55,684 |
Corporate Core |
109,617 |
333,586 |
112,535 |
333,940 |
Neighbourhoods (Incl. Highways) |
108,593 |
248,834 |
108,182 |
247,543 |
Growth and Development |
(11,395) |
37,860 |
(12,855) |
38,236 |
Total |
613,553 |
1,566,558 |
656,700 |
1,622,115 |
The budget assumptions that underpinned 2024/25 to 2026/27 included the commitments made as part of the 2023/24 budget process to fund ongoing demand pressures, as well as provision to meet other known pressures and investments. Whilst this contributed to the scale of the budget gap it was important that a realistic budget was set which reflected ongoing cost and demand pressures.
It was the opinion of the Deputy Chief Executive and City Treasurer that any significant budget risks to the General Fund and the Housing Revenue Account had been identified and that suitable proposals were being put in place to mitigate against these risks where possible. The Council’s budget monitoring procedures were very well embedded and were designed to monitor high level risks and volatile budgets. An assessment of anticipated business rates income had been carried out based on the information available and provision had been made for outstanding appeals. This was considered to be a prudent provision.
The Deputy Chief Executive and City Treasurer considered that the assumptions on which the budget had been proposed whilst challenging were manageable within the flexibility allowed by the General Fund balance and the smoothing reserve available to support the future budget position. This meant the Deputy Chief Executive and City Treasurer was confident the overall budget position of the Council could be sustained within the overall level of resources available. However, to the degree that the budget savings were not achieved in a timely manner and reserves were called on to achieve a balanced position, further savings would need to be identified and implemented in order to ensure the Council’s future financial stability was maintained.
It was recognised that Manchester continued to lead the way in terms of transformation, delivering efficient services and creating the conditions for all of its communities to benefit from economic growth. The Council had maintained its reputation for innovation and reform through a number of key mechanisms and the proposed budget and business plan was a continuation of commitment to the delivery of the Our Manchester Strategy and how it has been used as a framework for prioritising the deployment of resources.
Decisions
The Executive:-
(1) Note the Deputy Chief Executive and City Treasurer’s review of the robustness of the estimates and the adequacy of the reserves.
(2) Note that the financial position has been based on the final Local Government Finance Settlement announced on 5 February 2024 together with any further announcements at that date.
(3) Note the anticipated financial position for the Council for the period of 2024/25 which is based on all proposals being agreed.
(4) Note the resources available are utilised to support the financial position to best effect, including use of reserves and prior years dividends; consideration of the updated Council Tax and Business Rates position; the financing of capital investment, and the availability and application of grants.
(5) Note that the Capital Strategy and Budget 2024/25 to 2026/2 has been presented alongside this report
(6) Recommend to Council to approve, as elements of the budget for 2024/25:-
a. an increase in the basic amount of Council Tax (i.e., the Council’s element of Council Tax) by 2.99% and Adult Social Care precept increase of 2%.
b. the contingency sum of £0.6m
c. corporate budget requirements to cover levies/charges of £70.060m, capital financing costs of £43.926m, additional allowances and other pension costs of £8.497m and insurance costs of £2.004m.
d. the inflationary pressures and budgets to be allocated in the sum of £17.357m; and delegate the final allocations to the Deputy Chief Executive and City Treasurer in consultation with the Executive Member for Finance and Human Resources.
(7) Approve the gross and net Directorate cash limits
(8) Approve the in-principal contribution to the Adults aligned budget, subject to the extension of the S75 Agreement with Manchester Foundation Trust, which will be considered by Executive in March 2024.
(9) Delegate authority to the Deputy Chief Executive and City Treasurer and Chief Executive in consultation with the Executive Member for Finance and Human Resources and the Leader of the Council to draft the recommended budget resolution for budget setting Council to provide an itemised council tax bill which, on the face of the bill, informs taxpayers of that part of any increase in council tax which is being used to fund adult social care.
(10) Recommend that Council approve and adopt the budget for 2024/25
Supporting documents:
- Medium Term Financial Strategy and 2024-25 Revenue Budget, item 16. PDF 548 KB
- Appendix 1 - Summary Business Plan 24/25, item 16. PDF 174 KB
- Appendix 2 - Savings Proposals 2023/24 to 2025/26, item 16. PDF 160 KB
- Appendix 3 - Growth and Investment 24/25, item 16. PDF 94 KB
- Appendix 4 - Legal Background to setting the budget, item 16. PDF 108 KB
- Appendix 5 - Reserves Strategy 24/25, item 16. PDF 308 KB
- Appendix 6 - Sales, Fees and Charges, item 16. PDF 305 KB