Civil and Administrative Tribunal
New South Wales	

Case Title:	Campbell v ZW2 Pty Ltd t/as Lake Munmorah Residential Resort	
		
Medium Neutral Citation:	[2014] NSWCATCD 36	
		
Hearing Date(s):	28 February 2014	
		
Decision Date:	20 March 2014	
		
Jurisdiction:	Consumer and Commerical Division	
		
Before:	J McMillan, General Member	
		
Decision:	
1. In consideration of the evidence before it the Tribunal finds that the rent increase is allowed but introduced in two stages as per the attached schedules.

Legislation Cited:	Residential Parks Act 1998	
		
Cases Cited:	Kilaptrick v Gresser (unreported, 13 May 1987, Foster J)	
		
Category:	Principal judgment	
		
Parties:	Colin and Gail Campbell and Ors (Applicants) 
ZW2 Pty Ltd t/as Lake Munmorah Residential Resort (Respondent)	
		
Representation		
		
- Solicitors:	Mr Peter Reberger (for the applicants) 
Mr Lionel Lees (for the respondent)	
		
File Number(s):	RP 13/59443	

reasons for decision

1	The respondent park owner gave the applicant residents a notice of increase. No challenge was made to the form or service of the notice. Neither was there any other challenge to the jurisdiction of the Tribunal to hear and determine the matter.

2	The matter came before the Tribunal on 18 December 2013 and procedural directions were made on that day for the exchange of documents between the parties. The matter was then adjourned for hearing. On the day of the hearing the Tribunal made available to the parties a conciliator for the purpose of meeting with them and leading them to a resolution of the dispute. This process did not produce a settlement and the matter was then heard with the Tribunal reserving its decision.

3	When determining an application for an order that a rent increase is excessive the Tribunal does under the provision of section 57 of the Residential Parks Act 1998. Section 57 provides;

57 Matters to be considered in determining rent applications

The Tribunal may, in determining whether or not a rent increase or rent payable under a residential tenancy agreement or a proposed residential tenancy agreement for residential premises is excessive, have regard to each of the following factors:

(a) the general market level of rents for comparable premises in the same residential park and in other residential parks in the locality or a similar locality,

(b) the value of the residential premises,

(c) the frequency and amount of past rent increases under the residential tenancy agreement or previous residential tenancy agreements between the same park owner and resident,

(d) a general price index (such as the Consumer Price Index),

(e) the conduct of the parties,

(f) the amount of any outgoings in respect of the residential premises required to be borne by the park owner under the residential tenancy agreement or proposed agreement,

(g) the estimated cost of any services provided by the park owner or the resident under the residential tenancy agreement or proposed agreement,

(h) the value and nature of any fittings, appliances or other goods, services or facilities provided with the residential premises,

(i) the accommodation and amenities provided in the residential premises and the state of repair and general condition of the premises,

(j) any work done to the premises by or on behalf of the resident, to which the park owner has consented,

(k) any other relevant matter.

4	I shall deal with each of these matters separately.

5	(a) the general market level of rents for comparable premises in the same residential park and in other residential parks in the locality or a similar locality

The park was described by the applicants as having here types of blocks. These are external, corner and inside. They argued that there is a difference between these. There are five different rent structures within the park. These structures commenced in 2005 and came about due the park being developed. Residents commenced occupation of their sites during this period. The development of the residential sites within the park is now complete.

6	The residents provide some information on four other parks in the locality. The park owner provided information on seven parks. The table below shows the comparisons.

	LAKE MUNORAH RESORT	VALHALLA	KINCUMBER NAUTICAL VILLAGE	PINE NEEDLES	TERAGLIN	PARK TREES	BEVINGTON SHORES	MEANDER VILLAGE	
SITE FEES PER WEEK	$149.68 - $166.05	$125 - $140	$144 - $246.15	$152.50	$150 - $160	$135 - $150	$150 - $160	$140 - $150	
LOT SIZES (SQ M)	192 - 262.5			202 - 345		190	164 - 178	180 - 220	
AGE OF PARK (YRS)	3 TO 8	2 TO 20		20		2 TO 25	6 TO 20	0 TO 35	
FRONT GARDENS MAINTAINED	Y	N	N	N	N	N	N	N	
DISTANCE TO SHOPS	600 m	4.5 kms	3.2 kms	600 m	5.1 kms	4.3 kms	2.5 kms	1.8 kms	
OUTDOOR POOL	Y	N	Y	Y	Y	Y	N	Y	
INDOOR POOL	Y	Y	N	N	N	N	N	N	
TENNIS COURT	Y	Y	Y	Y	Y	Y	N	N	
GAMES ROOM	Y	Y	Y	Y	Y	N	Y	Y	
CRAFT ROOM	Y	Y	N	Y	N	N	N	N	
COMPUTER ROOM 	Y	N	Y	N	N	N	N	N	
BILLIARDS/SNOOKER	Y	N	Y	Y	N	N	N	Y	
POOL TABLE	Y	Y	Y	N	Y	Y	N	N	
LIBRARY	Y	Y	Y	Y	Y	Y	Y	Y	
COMMUNITY BUS TO SHOPS	FREE	NOT FREE	Y	N	NOT FREE	Y	Y	Y	
BAR	Y	N	Y	N	N	N	N	N	
MOVIE THEARTRE	Y	N	N	Y	N	N	N	N	
INTERCOM TO EACH HOME	Y	Y	N	Y	N	N	N	N	
WORKSHOP	Y	Y	Y	N	N	N	N	N	
DINNING HALL	Y	Y	Y	Y	Y	N	Y	N	
LAWN BOWLS	Y	Y	N	Y	N	N	N	N	
CARPET BOWLS	Y	Y	Y	N	Y	N	Y	N	
SECURITY GATES	Y	Y	N	Y	N	Y	N	N	
BBQ AREA	3	5	2	N	1	N	1	N	
ACCESS TO LAKE	DIRECT	N	DIRECT	N	DIRECT	N	DIRECT	N	
COMMUNITY GARDEN & CARE	Y	Y	Y	Y	N	Y	N	N	
CARAVAN PARKING AREA	15 FREE	Y FREE	N	Y	N	N	N	N	
GYMNASIUM	Y	N	N	N	N	N	N	N	
GOLF FACILITY	Y	N	N	Y	N	Y	N	N	
PUTTING GREEN	Y	Y	Y	Y	N	N	N	N	
PUBLLIC TRANSPORT	Y	Y	Y	Y	Y	Y	Y	Y	
DARTS & TABLE TENNIS	Y	Y	Y	Y	Y	Y	Y	N	
FENCED YARDS	Y	PART	N	PART	N	N	N	N	
INDIVIDULA WHEELIE BINS	2	N	N	Y	N	N	N	N	

7	In addition to the items in the table, it is noted that the bar at Lake Munmorah Resort returns a profit of $21,000.00 per year which is not claimed by the park owner. The theatre at the park includes a pay TV service. The residents pay their own electricity but some pay for water while others do not. The particulars of water usage charges were not tendered by either party.

8	The rents supplied by both parties a different and there is no evidence tendered that substantiates what the parties state them to be.

9	(b) the value of the residential premises

The residents own their homes and they lease the land on which the home is erected. There was no evidence tendered that established the value of the land or site occupied.

10	(c) the frequency and amount of past rent increases under the residential tenancy agreement or previous residential tenancy agreements between the same park owner and resident,

11	(d) a general price index (such as the Consumer Price Index)

Rent increases up to 2008 had been in line with consumer price index (CPI). The park during that period was under development and these increases were provided for in the terms of the residential site agreements. Clause 71 of the agreement provided;

"71 Subject to section 53 of the Act the Resident agrees that the Park Owner may give notice of increase of the amount of rent payable under this agreement during the currency of the fixed term of this agreement, in the following manner:

71.1 The method of calculating the rent increase is in accordance with the increase in the Consumer Price Index (CPI) (Sydney All Groups) of any replacement of it, since the last increase of rent or if it is the first increase of rent, the increase in the CPI since the date of this agreement:

71.2 The rent will be increased once in every calendar year."

12	As more sites became occupied the rent that applied to each new agreement were greater than the rents that applied to those agreements entered into when the park first opened. The park owner gave letters to residents seeking their co-operation in paying rent increases greater than the CPI in order to reach parity with the rents of recent arrivals. In July 2007 rents in the park were $115.00, $120.00 and $130.00 per week. The increase that year was in accordance with the CPI. In 2009 a rents of $140.00 per week were an increase by $10.00 per week which would take about four years to reach parity with recent arrivals. In 2009 however one resident received a rent increase of $20.51 per week while another received an increase of $8.00 per week.

13	One rent increase was not in accordance with this policy. It came about when the swimming pool was electrically heated. By notice dated 19 August 2006 the park owner made a decision to increase rents by $0.50 per week to meet the cost on the basis that it was fair to charge all residents the same amount for this facility whether they used the pool or not.

14	Once the fixed term of any agreement ended the park owner increased rents to reach parity with the recent arrivals in the park. The park owner did this by stages and the present increase is part of it.

15	There was discussion as to how the CPI was calculated and the park owner has underestimated the amount. This has meant a lower increase to the resident. The park owner is in the process of recovering this shortfall.

16	(e) the conduct of the parties

The residents argued that the park owner has issued ambiguous notices relating to rent increases and has not been prepared to negotiate with residents on matter relating to the increases. They quoted the example of the pool heating and that when average rents are stated by the park owner to be $10.00 per week the figure is not substantiated in any way.

17	(f) the amount of any outgoings in respect of the residential premises required to be borne by the park owner under the residential tenancy agreement or proposed agreement

No evidence was tendered by the applicants for this head of consideration.

18	(g) the estimated cost of any services provided by the park owner or the resident under the residential tenancy agreement or proposed agreement

The applicants asserted that the staffing numbers in the park have not increased. \it has been function now for a period of nine years. They have not received any advice or other information from the park owner that operating costs have increased. They claimed that staffing levels have decreased with the numbers of staff now that the construction work has ceased.

19	It was further claimed that fall in staffing levels has resulted in a decline in maintenance, a reduction in the frequency of removal of rubbish and debris, increased problems with the operation of the security gates (no operation for 7 - 10 days) and tardy response to request from residents for repairs. In the light of no information from the park owner on the increase in operating costs the residents argue that the rent should be limited to CPI increase only.

20	The park owner denied there was decrease in staff numbers services and facilities.

21	(h) the value and nature of any fittings, appliances or other goods, services or facilities provided with the residential premises

No evidence was tendered by the applicants for this head of consideration.

22	(i) the accommodation and amenities provided in the residential premises and the state of repair and general condition of the premises

The applicants raised a number of matters that require attention within the park. These are;

•	Old surface matting from bowling green not removed.

•	Garden edging formwork not removed.

•	Palm fronds cut from trees in the vicinity of the caravan parking area have not been removed for a period of three months.

•	Cracking road pavements.

•	No information as to any notices served by Wyong Council in relation to the swimming pool.

•	No plan from park management as to maintenance of community areas.

•	Management has decided not to maintain the spa but will trade it for a larger dishwasher in the clubhouse kitchen.

23	(j) any work done to the premises by or on behalf of the resident, to which the park owner has consented

The residents acknowledged the park owner has co-operated with requests from residents in relation to alterations to their residences such as sheds, solar heating and panels, blinds, awnings.

24	(k) any other relevant matter

Under this head of consideration the applicants again raised the issue of the rent increase being in accordance with the CPI. There are inconsistencies in the number of rent increases with some residents receiving more than one in a 12 month period and the CPI when applied is not done so consistently between residents.

25	The park owner does not negotiate the rent increase.

26	Kilaptrick v Gresser (unreported, 13 May 1987, Foster J) is a matter where the provisions of section 52 of the Residential Tenancies Act 1987 were considered. Section 52 of that Act and section 57 of the Act are comparable. The Court held "...I do not think that the matters referred to in those sub-paragraphs can be divorced from the overall obvious intention expressed in this section that the overriding matter to be considered by the Tribunal in determining whether a rental is excessive is the comparison of that rental with general market levels for rents for comparable premises."

27	The Act does not mandate that rent increases are to be limited to the CPI. The CPI is only a factor in determining whether a rent increase is excessive.

28	The applicants in their submissions to the Tribunal state;

"While we agree in theory with there being a number of parks in our locality of similar condition, we feel that we are superior owing to the fact that we have been constructed with a number of items for residents use...".

29	No other park among those tendered for comparison has extent of facilities that Lake Munorah Resort has. The lot sizes are not the largest (Pine Needles have larger sites) but they are within the same size as other parks. The rent range within Lake Munmorah Resort also overlaps those parks with lesser services and facilities.

The Tribunal also takes into consideration the number of sites within the park. The park has a total of 223 sites. Less than half the residents are opposed to the increase. It is reasonable to conclude that neighbouring sites with the park that enjoy the same standard of services and facilities should be paying similar rents and therefore the park owner may seek to have parity of rents within the park.

30	It is the finding of the Tribunal that the range of rents within the park of $149.68 to 166.05 is consistent with the services and standard of facilities provided.

31	In relation to the CPI, clause 71 of the agreement applies only to rent increases during the fixed term of that particular agreement. Once the fixed term has ended the park owner is no longer bound by the requirement to limit a rent increase to the CPI. The evidence before the Tribunal is that among the applicants before it none is on a fixed term and therefore clause 71 does not apply.

32	In this particular rent increase the average rent increase is $5.72 compared with the average of the CPI increase of $2.74. The increase is more than double the CPI average and reflects the gap between market forces as they affect rents and the costs in living as comprising those items measured in determining the CPI. The Tribunal accepts that rents were held back during the development period of the park and a limitation on increases was put in place as all facilities were not available for the residents' use and the park was a construction zone. That period has now passed and limiting rent increases to the CPI is not sustainable. The evidence shows that rent increases in the past have not been consistent across the park and some residents have not had rent increases each year.

33	In regard to the other considerations the residents also stated in their submission;

"...but unless they (the items constructed for residents 'use) are maintained we will lose our resorts outlook and therefore the status of the resort will fall away".

34	It is clear an effort was made to present the park at its best at the time of the hearing however its presentation did not hide minor problems such as an uneven surface on the bowling green (the rain ponded in some areas). The applicants were not able to satisfy the Tribunal that the park is falling into disrepair. He matters raised in relation to repairs may be breaches of the terms of the agreement and do not impact in this particular application. The park owner is reminded of its obligation under the residential tenancy agreement. Section 24 of the Act provides;

24 Park owner's responsibility for cleanliness and repairs

(1) It is a term of every residential tenancy agreement that:

(a) the park owner must provide the residential premises (for instance, the moveable dwelling and the residential site or the residential site only) and the common areas of the residential park in a reasonable state of cleanliness and fit for habitation by the resident, and

(b) the park owner must provide and maintain the residential premises in a reasonable state of repair, having regard to the age of, rent payable for and prospective life of the premises.

(2) In this section:

residential premises includes everything provided with the premises, for use by the resident, under the residential tenancy agreement.

35	In consideration of the evidence before it the Tribunal finds that the rent increase is allowed but introduced in two stages as per the attached schedules.

J McMillan
General Member
Civil and Administrative Tribunal of New South Wales

20 March 2014

SCHEDULES OF RENT INCREASES

SITE No	RENT	FROM	TO	SITE No	RENT	FROM	TO	
3	$153.30	02-Jan-14	01-Jul-13	74	$151.71	19-Dec-13	18-Jun-14	
	$156.61	02-Jul-14	01-Jan-15		$154.21	19-Jun-14	18-Dec-14	
5	$151.71	19-Dec-13	18-Jun-14	75	$148.82	02-Jan-14	01-Jul-13	
	$154.21	19-Jun-14	18-Dec-14		$151.63	02-Jul-14	01-Jan-15	
8	$156.08	19-Dec-13	18-Jun-14	76	$144.51	02-Jan-14	01-Jul-13	
	$160.08	19-Jun-14	18-Dec-14		$147.20	02-Jul-14	01-Jan-15	
9	$156.08	19-Dec-13	18-Jun-14	77	$151.71	19-Dec-13	18-Jun-14	
	$160.08	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
10	$156.08	19-Dec-13	18-Jun-14	80	$151.71	19-Dec-13	18-Jun-14	
	$160.08	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
14	$148.70	19-Dec-13	18-Jun-14	81	$151.71	19-Dec-13	18-Jun-14	
	$153.70	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
17	$156.08	19-Dec-13	18-Jun-14	82	$155.26	02-Jan-14	01-Jul-13	
	$160.08	19-Jun-14	18-Dec-14		$158.18	02-Jul-14	01-Jan-15	
18	$148.70	19-Dec-13	18-Jun-14	83	$151.71	19-Dec-13	18-Jun-14	
	$153.70	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
21	$155.49	19-Dec-13	18-Jun-14	84	$163.03	02-Jan-14	01-Jul-13	
	$159.49	19-Jun-14	18-Dec-14		$166.05	02-Jul-14	01-Jan-15	
23	$155.49	19-Dec-13	18-Jun-14	86	$156.08	19-Dec-13	18-Jun-14	
	$159.49	19-Jun-14	18-Dec-14		$160.08	19-Jun-14	18-Dec-14	
24	$149.97	02-Jan-14	01-Jul-13	88	$155.49	19-Dec-13	18-Jun-14	
	$152.74	02-Jul-14	01-Jan-15		$159.49	19-Jun-14	18-Dec-14	
33	$151.71	19-Dec-13	18-Jun-14	89	$153.38	02-Jan-14	01-Jul-13	
	$154.21	19-Jun-14	18-Dec-14		$156.76	02-Jul-14	01-Jan-15	
39	$151.71	19-Dec-13	18-Jun-14	90	$151.71	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
40	$151.71	19-Dec-13	18-Jun-14	92	$151.71	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
41	$155.49	19-Dec-13	18-Jun-14	93	$148.70	19-Dec-13	18-Jun-14	
	$159.49	19-Jun-14	18-Dec-14		$153.70	19-Jun-14	18-Dec-14	
42	$151.71	19-Dec-13	18-Jun-14	96	$151.71	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14
	
43	$151.71	19-Dec-13	18-Jun-14	97	$151.71	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
46	$155.49	19-Dec-13	18-Jun-14	98	$150.18	19-Dec-13	18-Jun-14	
	$159.49	19-Jun-14	18-Dec-14		$152.68	19-Jun-14	18-Dec-14	
49	$151.71	19-Dec-13	18-Jun-14	103	$155.49	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$159.49	19-Jun-14	18-Dec-14	
50	$151.71	19-Dec-13	18-Jun-14	106	$158.74	02-Jan-14	01-Jul-13	
	$154.21	19-Jun-14	18-Dec-14		$161.71	02-Jul-14	01-Jan-15	
51	$149.91	02-Jan-14	01-Jul-13	107	$154.32	02-Jan-14	01-Jul-13	
	$152.74	02-Jul-14	01-Jan-15		$157.18	02-Jul-14	01-Jan-15	
52	$151.71	19-Dec-13	18-Jun-14	108	$156.08	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$160.08	19-Jun-14	18-Dec-14	
53	$151.71	19-Dec-13	18-Jun-14	110	$156.08	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$160.08	19-Jun-14	18-Dec-14	
54	$147.18	02-Jan-14	01-Jul-13	112	$147.18	02-Jan-14	01-Jul-13	
	$149.68	02-Jul-14	01-Jan-15		$149.68	02-Jul-14	01-Jan-15	
65	$156.08	19-Dec-13	18-Jun-14	113	$154.67	02-Jan-14	01-Jul-13	
	$160.08	19-Jun-14	18-Dec-14		$157.52	02-Jul-14	01-Jan-15	
66	$151.81	02-Jan-14	01-Jul-13	114	$156.08	19-Dec-13	18-Jun-14	
	$154.68	02-Jul-14	01-Jan-15		$160.08	19-Jun-14	18-Dec-14	
68	$151.71	19-Dec-13	18-Jun-14	115	$156.08	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$160.08	19-Jun-14	18-Dec-14	
70	$156.08	19-Dec-13	18-Jun-14	117	$156.08	19-Dec-13	18-Jun-14	
	$160.08	19-Jun-14	18-Dec-14		$160.08	19-Jun-14	18-Dec-14	
71	$151.18	19-Dec-13	18-Jun-14	118	$149.42	02-Jan-14	01-Jul-13	
	$154.21	19-Jun-14	18-Dec-14		$151.63	02-Jul-14	01-Jan-15	

SITE No	RENT	FROM	TO	SITE No	RENT	FROM	TO	
121	$150.18	19-Dec-13	18-Jun-14	200	$151.71	19-Dec-13	18-Jun-14	
	$152.68	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
130	$152.84	02-Jan-14	01-Jul-13	201	$154.67	02-Jan-14	01-Jul-13	
	$155.67	02-Jul-14	01-Jan-15		$157.52	02-Jul-14	01-Jan-15	
138	$151.81	02-Jan-14	01-Jul-13	204	$152.84	02-Jan-14	01-Jul-13	
	$154.68	02-Jul-14	01-Jan-15		$155.67	02-Jul-14	01-Jan-15	
144	$155.11	02-Jan-14	01-Jul-13	206	$151.71	19-Dec-13	18-Jun-14	
	$158.03	02-Jul-14	01-Jan-15		$154.21	19-Jun-14	18-Dec-14	
147	$154.32	02-Jan-14	01-Jul-13	214	$147.32	02-Jan-14	01-Jul-13	
	$157.18	02-Jul-14	01-Jan-15		$151.00	02-Jul-14	01-Jan-15	
150	$155.11	02-Jan-14	01-Jul-13	222	$154.32	02-Jan-14	01-Jul-13	
	$158.03	02-Jul-14	01-Jan-15		$157.18	02-Jul-14	01-Jan-15	
155	$146.25	02-Jan-14	01-Jul-13	225	$143.52	02-Jan-14	01-Jul-13	
	$151.63	02-Jul-14	01-Jan-15		$146.17	02-Jul-14	01-Jan-15	
156	$143.09	02-Jan-14	01-Jul-13	136	$151.81	02-Jan-14	01-Jul-13	
	$146.17	02-Jul-14	01-Jan-15		$154.68	02-Jul-14	01-Jan-15	
157	$153.31	02-Jan-14	01-Jul-13	133	$164.08	19-Dec-13	18-Jun-14	
	$156.61	02-Jul-14	01-Jan-15		$168.08	19-Jun-14	18-Dec-14	
160	$152.67	02-Jan-14	01-Jul-13	175	$145.94	02-Jan-14	01-Jul-13	
	$155.51	02-Jul-14	01-Jan-15		$148.70	02-Jul-14	01-Jan-15	
161	$151.71	19-Dec-13	18-Jun-14	171	$151.71	19-Dec-13	18-Jun-14	
	$154.21	19-Jun-14	18-Dec-14		$154.21	19-Jun-14	18-Dec-14	
163	$153.31	02-Jan-14	01-Jul-13	6	$149.97	02-Jan-14	01-Jul-13	
	$156.61	02-Jul-14	01-Jan-15		$152.74	02-Jul-14	01-Jan-15	
168	$152.84	02-Jan-14	01-Jul-13	143	$149.97	02-Jan-14	01-Jul-13	
	$155.67	02-Jul-14	01-Jan-15		$152.74	02-Jul-14	01-Jan-15	
167	$153.31	02-Jan-14	01-Jul-13	32	$151.71	19-Dec-13	18-Jun-14	
	$156.61	02-Jul-14	01-Jan-15		$154.21	19-Jun-14	18-Dec-14	
170	$152.67	02-Jan-14	01-Jul-13	172	$151.81	02-Jan-14	01-Jul-13	
	$155.51	02-Jul-14	01-Jan-15		$154.68	02-Jul-14	01-Jan-15	
176	$144.51	02-Jan-14	01-Jul-13	173	$143.52	02-Jan-14	01-Jul-13	
	$147.20	02-Jul-14	01-Jan-15		$146.17	02-Jul-14	01-Jan-15	
177	$143.52	02-Jan-14	01-Jul-13	30	$150.18	19-Dec-13	18-Jun-14	
	$146.17	02-Jul-14	01-Jan-15		$152.68	19-Jun-14	18-Dec-14	
178	$149.97	02-Jan-14	01-Jul-13	124	$151.71	19-Dec-13	18-Jun-14	
	$152.74	02-Jul-14	01-Jan-15		$154.21	19-Jun-14	18-Dec-14	
179	$155.11	02-Jan-14	01-Jul-13	174	$153.31	02-Jan-14	01-Jul-13	
	$158.03	02-Jul-14	01-Jan-15		$156.61	02-Jul-14	01-Jan-15	
180	$151.71	02-Jan-14	01-Jul-13	216	$150.55	02-Jan-14	01-Jul-13	
	$154.21	02-Jul-14	01-Jan-15		$153.38	02-Jul-14	01-Jan-15	

182	$151.81	02-Jan-14	01-Jul-13	
	$154.68	02-Jul-14	01-Jan-15	
183	$155.11	02-Jan-14	01-Jul-13	
	$158.03	02-Jul-14	01-Jan-15	
185	$154.67	02-Jan-14	01-Jul-13	
	$157.52	02-Jul-14	01-Jan-15	
187	$152.67	02-Jan-14	01-Jul-13	
	$155.51	02-Jul-14	01-Jan-15	
188	$155.11	02-Jan-14	01-Jul-13	
	$158.03	02-Jul-14	01-Jan-15	
192	$154.67	02-Jan-14	01-Jul-13	
	$157.52	02-Jul-14	01-Jan-15	
194	$152.67	02-Jan-14	01-Jul-13	
	$155.51	02-Jul-14	01-Jan-15	
197	$152.67	02-Jan-14	01-Jul-13	
	$155.51	02-Jul-14	01-Jan-15	
199	$145.94	02-Jan-14	01-Jul-13	
	$148.70	02-Jul-14	01-Jan-15