9-27 July 2012
Concluding observations of the Committee on the Elimination of Discrimination against Women
1.The Committee considered the seventh periodic report of New Zealand (CEDAW/C/NZL/7) at its 1053rd and 1054th meetings, on 18 July 2012 (CEDAW/C/SR.1053 and 1054). The Committee’s list of issues and questions is contained in CEDAW/C/NZL/Q/7, and the responses of the Government of New Zealand are contained in CEDAW/C/NZL/Q/7/Add.1.
2.The Committee expresses its appreciation to the State party for the timely submission of its seventh periodic report, which was well structured and followed the Committee’s guidelines for the preparation of reports and included references to the Committee’s general recommendations. The Committee expresses its appreciation to the State party for its oral presentation, the written replies to the list of issues and questions raised by the pre-session working group, and the further clarifications to the questions posed orally by the Committee.
3.The Committee commends the State party for its high-level delegation, headed by the Minister of Women’s Affairs, the Honourable Jo Goodhew.
4.The Committee notes with appreciation that the report was prepared in a participatory process involving government institutions, Parliament and national civil society organizations, including women’s organizations.
5.The Committee welcomes the presence and contribution of the New Zealand Human Rights Commission to its work.
6.The Committee commends the State party for withdrawing its last reservation to the Convention following the passing of the Human Rights Amendment Act in 2007, which made it possible for women to serve in combat roles in the armed forces.
7.The Committee welcomes the appointment of the first Asian woman Minister and three Māori women Ministers.
8.The Committee commends the State party for a number of positive legislative and policy reforms for the advancement of women since the adoption of its last concluding observations in 2007, including:
(a)The Campaign for Action on Violence within Families (the “It’s not OK” campaign) launched by the Task Force for Action on Violence within Families in 2008 aimed at changing attitudes to family violence;
(b)Legislative changes passed in 2009 which enabled criminal courts to issue protection orders on behalf of victims in cases where a perpetrator is sentenced for a domestic violence offence;
(c)The Employment Relations (Breaks, Infant Feeding, and Other Matters) Amendment Act of 2008 which promotes breastfeeding in the workplace;
(d)A national education campaign launched in 2007 aimed at encouraging women to screen themselves for cervical cancer, which has increased testing for all groups of women;
(e)The 2008 “Indicators for Change” developed by the Ministry of Women’s Affairs which tracks the progress of women’s rights issues in New Zealand.
Principal areas of concern and recommendations
9.The Committee recalls the obligation of the State party to systematically and continuously implement all the provisions of the Convention and views the concerns and recommendations identified in the present concluding observations as requiring the priority attention of the State party between now and the submission of the next periodic report. The Committee notes with concern a number of challenges that continue to impede the full implementation of the Convention in the State party, including the recourse to gender-neutral language with respect to gender-based violence, including domestic violence; pay inequality and pay equity; the status of vulnerable groups of women, including women with disabilities and minority women; the impact of the 2011 earthquake on women; the impact of policy changes such as the financial cuts in legal aid schemes; adequacy of targets and benchmarks to advance women’s rights; and the insufficient dissemination and promotion of the Convention. Consequently, the Committee urges the State party to focus on those areas in its implementation activities and to report in its next periodic report on action taken and results achieved. The Committee calls upon the State party to submit the present concluding observations to all relevant ministries, to the Parliament, and to the judiciary, so as to ensure their full implementation.
10.While reaffirming that the Government has the primary responsibility and is particularly accountable for the full implementation of the obligations of the State party under the Convention, the Committee stresses that the Convention is binding on all branches of government, and it invites the State party to encourage the Parliament, in line with its procedures, where appropriate, to take the necessary steps with regard to the implementation of the present concluding observations between now and the Government’s next reporting process under the Convention. The Committee notes the limited distribution of its previous concluding observations and recommendations contained therein to Parliament and the lack of systematic parliamentary oversight to ensure accountability on women’s rights and gender equality. The Committee recommends increased dissemination of the State party report as well as the Committee’s concluding observations and recommendations to all parliamentarians. The Committee urges the State party to consider establishing a Human Rights Select Committee in Parliament to strengthen parliamentary oversight on human rights generally and especially on women’s rights and gender equality.
Definition of gender discrimination and gender equality
11.Recalling its previous recommendation (CEDAW/C/NZL/CO/6), the Committee remains concerned that there is still no explicit and comprehensive prohibition against direct and indirect discrimination against women within the State party’s Constitution or legislation in accordance with article 1 of the Convention. The Committee is concerned that sufficient protection against direct and indirect discrimination by private actors regarding equal pay for work of equal value is not provided for by law.
12. The Committee recommends that, in the context of the current constitutional review, the State party ensure full incorporation into the C onstitution and/or other legislation, of the principle of equality between women and men in accordance with article 2 (a) of the Convention. The State party is urged to establish a legal definition of discrimination on the basis of sex in line with article 1 of the Convention, and to extend state responsibility for acts of discrimination by both public and private actors in accordance with article 2 (e) of the C onvention, with a view to achieving formal and substantive equality between women and men.
Visibility of the Convention, the Optional Protocol and the Committee’s general recommendations
13.While noting with appreciation that the Ministry of Justice launched a website on human rights in 2010 which provides information on the Convention and its Optional Protocol, the Committee remains concerned that the State party has not taken adequate action to promote the visibility of the Convention throughout the country. The Committee is concerned that many women are not aware of the complaints mechanism under the Optional Protocol and that there is inadequate knowledge of the rights of women under the Convention. The Committee is concerned as well that there has been insufficient action taken on behalf of the State party to train judges and lawyers on the Convention and to integrate it into the State party’s legal framework.
14. The Committ ee urges the State party:
(a) To e nhance women ’ s awareness of their rights and the means of access to justice at the national and local levels for women claiming violations of their rights under the Convention, and ensure that information on the Convention is provided to women in all parts of the State party, including in schools and tertiary education institutions and through the use of informat ion campaigns and the media;
(b) To d isseminate the Convention, the Optional Protocol, the Committee ’ s general recommendations and its views on individual communications and e nquiries among all segments of society, and organize legal education and regular training for government officers, legislators, judges, lawyers, magistrates, prosecutors, the police, and other law enforcement officers on the Convention and its applicability so that it can serve as an effective framework for all law, court decisions and policies on gender equalit y and the advancement of women.
Access to justice and legal complaints mechanism
15.The Committee is deeply concerned about the State party’s tightened funding and proposed eligibility criteria for legal aid, which have led to fewer applications by women and which may continue to have a negative impact on women’s access to justice, especially as 65 per cent of legal aid users in the State party are women. The Committee is also concerned that migrant women lack access to appropriate legal services because of cultural, financial and linguistic barriers, and that the proportion of Māori women prosecuted and convicted for crimes as well as among victims of crime is disproportionally high. Furthermore, while the Committee welcomes the role of the Human Rights Commission in providing a mechanism to hear discrimination complaints, it is concerned that information about this complaints mechanism has not been sufficiently disseminated and that the Human Rights Commission lacks sufficient resources.
16. The Committee urges the State party:
(a) To facilitate women ’ s access to justice, including by providing free legal aid to women without sufficient means and to increase efforts to make sure that migrant women and Māori women are not discriminated against in the administration of justice;
(b) To implement systematic training to the legal profession and non ‑ governmental organizations on the application of legislation prohibiting discrimination, including in the area of access to justice, in the light of its obligations under the Conven tion and its Optional Protocol;
(c) To enhance awareness-raising initiatives for women on how to utilize available legal remedies against discrimination, including with regard to the Human Rights Commission, and to ensure that the Commission is adequately resourced.
National machinery for the advancement of women
17.The Committee is concerned that the State party has not taken sufficient measures to ensure that gender is mainstreamed into all national plans and government institutions as requested by the Committee in its previous concluding observations (CEDAW/C/NZL/CO/6, para. 15). In this context, the Committee notes with concern that the State party has not introduced a new national plan of action for women to replace the one which ended in 2009 and that the Ministry of Women’s Affairs lacks adequate resources for its many tasks.
18. The Committee encourages the State party:
(a) To mainstream gender in all national plans and government institutions;
(b) To strengthen the existing national machinery by providing adequate authority, visibility and human and financial resources at all levels and enhancing coordination among existing mechanisms for the advancement of women and the promotion of gender equality by increasing the resources for the Ministry of Women ’ s Affairs;
(c) To conduct a comprehensive study on how to improve the situation of women in the State party and develop a national act ion plan for women accordingly.
Temporary special measures
19.The Committee notes the State party’s indicators for change to monitor progress on women’s rights in three priority areas, namely, economic development, women in leadership and violence against women. It is concerned, however, that the targets and indicators set are not sufficient to ensure meaningful realization of women’s progress. In this regard, the Committee is concerned that the State party has declared that the use of temporary special measures is not an adequate tool to effectively accelerate the realization of substantive equality between men and women although legislation allows for their use. While recognizing some progress in the public sector, the Committee is concerned about the low representation of women in high-level and managerial positions on boards of private enterprises.
20. The Committee encourages the State party to study, review and reconsider the relevance and usefulness of temporary special measures, in accordance with article 4, paragraph 1, of the Convention, and the Committee ’ s general recommendation No. 25. It also recommends that the State party include in its equality legislation provisions to encourage the use of temporary special measures, in both the public and private sectors, in order to accelerate the realization of women ’ s de jure and de facto equality with men in all areas and sectors of the State party.
Stereotypes and harmful practices
21.While noting the efforts made by the State party to eliminate discriminatory attitudes and harmful practices affecting women, particularly through media broadcasting regulations, the Committee remains concerned about the negative stereotypes associated with men’s and women’s traditional roles in the family and in society at large. In particular, the Committee is concerned about the negative and sometimes exploitative representation of women in the media which perpetuates discrimination against women and girls. In this regard, the Committee notes with concern that the State party has not developed a national campaign on the importance of equality between men and women as recommended in the Committee’s previous concluding observations. Furthermore, the Committee is concerned about the incidence of cyberbullying, notably targeting teenage girls. The Committee is also concerned about the practice of forced marriage of young girls in migrant communities.
22. The C ommittee urges the State party:
(a) To implement without delay a national campaign on the importance of equality between women and men in a democratic society, to increase understanding of the meaning and content of substantive equality of women and to eliminate negative stereotypes associated with men ’ s and women ’ s traditional roles in the family and in society at large, in accor dance with articles 2 (f) and 5 (a) of the Convention;
(b) To systematically collect data on harmful practices, including cyberbullying targeting teenage girls, and to implement measures, such as awareness campaigns in scho ols, to prevent such practices;
(c) To take all necessary measures to combat the practice of early and forced marriages within migrant communities and to introduce sensitization campaigns in this regard.
Violence against women
23.The Committee takes note of the measures taken by the State party to protect women against violence through the legislative and institutional frameworks. At the legislative level, this includes the enactment of amendments to criminal law to strengthen protection of the rights of victims, such as the powers extended to the police to issue on-the-spot safety orders to protect victims of domestic violence. The Committee also notes that legislation also enables criminal courts to issue protection orders on behalf of victims in cases of domestic violence.
24.While the Committee notes the work of the Task Force for Action on Violence within Families, it is concerned at the lower level of representation among its members. The Committee also notes that many of the recommendations in the report of the Task Force for Action on Sexual Violence have not yet been implemented. The Committee also notes the increase in the number of Family Violence Courts, and the adoption of several awareness-raising initiatives such as the “It’s not OK” campaign, aimed at decreasing rates of family violence. Despite these positive developments, the Committee is concerned about the continued high and increasing levels of violence against women and the low rates of reporting and conviction, particularly relating to sexual violence. The Committee notes with concern insufficient statistical data on violence against women, especially on violence against Māori women, migrant women and women with disabilities.
25. The Commit tee calls upon the State party:
(a) To take the necessary measures to encourage the reporting of domestic and sexual violence cases, including by ensuring that education professionals, health-care providers and social workers are fully familiar with relevant legal provisions and are sensitized to all forms of violence against women and are capable of complying with their obligation to report cases;
(b) To strengthen training for the police, public prosecutors, the judiciary and other relevant government bodies o n domestic and sexual violence;
(c) To provide adequate assistance and protection to women victims of violence, including Māori and migrant women, by ensuring that they receive the necessary legal and psychosocial services;
(d) To improve the level of representation on the Task Force for Action on Violence within Families and ensure appropriate resourcing with a view to enhancing the perception of its status within the State party;
(e) To ensure systematic collection and publication of data, disaggregated by sex, ethnicity, type of violence, and by the relationship of the perpetrator to the victim; to collect data on the number of women killed by partners or ex ‑ partners; and to monitor the effectiveness of legislation, policy and practice relating to all forms of vi olence against women and girls.
Trafficking and exploitation of prostitution
26.While the Committee appreciates the 2009 Plan of Action to Prevent People Trafficking and improvements in the protection of sex workers since the Prostitution Reform Act of 2003, the Committee regrets the absence of comprehensive information and data on trafficking in women and girls. The Committee notes that there have been no prosecutions or convictions for trafficking in women and girls and is concerned that this may be linked to insufficient knowledge and awareness of the threat of trafficking and exploitation, particularly given reports on trafficking of migrant women and girls, including “mail-order” and “Internet” brides.
27. The Committee recommends that the State party:
(a) Identify, prosecute and punish traffickers, and ensure protection of the human rights of the trafficked women and girls;
(b) Ensure that trafficked women and girls have adequate support so as to be in a position to provide testimony against their traffickers;
(c) Ensure systematic monitoring and periodic evaluation, including the collection and analysis of data on trafficking and exploitation of women in prostitution, and to include such data in it s next periodic report;
(d) Raise awareness of threats of trafficking and exploitation and make efforts to proactively screen vulnerable populations, including migrant women and girls, such as “ mail-order ” and “ Internet ” brides.
Participation in political and public life
28.The Committee notes the high level of participation of women in public life and that the State party was ranked sixth out of 135 countries in The Global Gender Gap Report for 2011 and fifteenth out of 134 countries for women’s representation in Parliament. Despite this high level of representation of women at the central and local government levels as well as in the Foreign Service, the Committee is concerned that women continue to be underrepresented in senior management positions and higher positions within the legal profession, especially in the judiciary, and that there has been a reduction in representation of women public chief executives since the last report of the State party. The Committee notes that while there is cooperation between the Government and the private sector to identify targets for the advancement of women in decision-making positions, the targets, goals and time frames set are not sufficient and may be a symptom of regression rather than progress in women’s representation.
29. The Committee recommends that the State party:
(a) Take measures to increase the number of women in decision-making positions at all levels and in all areas, in the light of the Committee ’ s general recommendation No. 23 on women in politic al and public life;
(b) Make every effort to disseminate information on the Convention among both private and public actors to increase awareness and understanding of the meaning and content of substantive equality of women and men;
(c) Review the targets, goals and time frames set for the advancement of women in decision-making positions to ensure that they sufficiently enhance progress in women ’ s representation.
30.The Committee welcomes several positive trends within the State party in the field of education, including an increase in the number of children in early childhood education, higher retention rates for girls attending secondary school, and a steady increase in the number of women who obtain graduate degrees. The Committee further welcomes the information provided by the State party indicating that more women than men are participating in tertiary education and more Māori and Pacific Islander women are participating at the certificate, diploma, degree and post-graduate levels as compared to either their European or their Asian counterparts. Nevertheless, the Committee is concerned that the State party has not taken sufficient action to clarify and publicize the voluntary nature of school fees as recommended in previous concluding observations. The Committee is therefore concerned that parents may be under considerable pressure to pay school fees, which places a financial burden on low-income families and single-headed households. The Committee is also concerned that the overall dropout rate for Māori girls has increased in recent years despite their improvement at the tertiary level. Further, the Committee is concerned about the continuation of gender-segregated thematic subjects, which affects future employment opportunities and perpetuates occupational segregation.
31. The Committee recommends that the State party:
(a) D evelop a systematic programme to ensure that parents understand the voluntary nature of payments requested by schools and monitor schools ’ practices regarding the c ollection of fees from parents;
(b) C ollect data on the rea l cost of education to parents;
(c) I mplement measures to decrease dropout rates among Māori girls and to reintegrate th em into the educational system;
(d) I ntroduce measures to desegregate gender thematic subjects with a view to ensuring that women and girls equally access non-traditional thematic subject areas, widening their opportunities for future employment and breaking the trend of occupational segregation.
32.The Committee notes with concern the high level of unemployment, especially for young women and within ethnic minority groups. It also notes the persistence in the high levels of occupational segregation. While noting with appreciation the extension of parental leave for the self-employed, the Committee notes with concern the challenges in implementing parental leave, including paid parental leave for men, in ensuring paid leave for seasonal or fixed-term workers with multiple employment relationships, and in increasing the levels of representation of women in managerial and decision-making positions. Furthermore the Committee is concerned about the proposed legislative changes to collective bargaining, allowing employers to hire new workers on lower individual terms even when a union-negotiated collective agreement exists. The Committee takes note that there has been a slight regression with regard to the number of women chief executive officers and directors on boards of private companies since 2007. The Committee further notes with concern the closure of the Pay and Employment Equity Unit in the Department of Labour, and notes that the Ministry of Women’s Affairs lacks a consistent policy for bridging the persistent wage gaps between women and men.
33. The Committee recommends that the State party:
(a) Enact appropriate legislation that guarantees the operationalization and implementation of the principle of “ equal pay for work of equal value ” , in line with article 11 (d) of the Convention;
(b) Effectively enforce the principle of equal pay for work of equal value, through establishing specific measures and indicators, identifying time frames to redress pay inequality in different sectors and reviewing the accountabilities of public service chief executives for pay policies;
(c) Introduce appropriate legal measures to ensure parental leave, including paid parental leave for men as well as paid leave for seasonal or fixed-term workers with multiple employment relationships, and consider the ratification of ILO Convention No. 156 concerning workers with family obligations;
(d) Adopt policies and take all necessary measures, including temporary special measures in accordance with article 4, paragraph 1, of the Convention and the Committee ’ s general recommendation No. 25 with time-bound targets, to eliminate occupational segregation, both horizontal and vertical;
(e) Carry out an independent evaluation of the gendered impact of the reform of collective bargaining and ensure that it does not negatively affect women ’ s emp loyment and trade union rights;
(f) Ensure that there is a monitoring institution for gender pay inequity within the State party ’ s administration despite the closure of the Pay and Employment Equity Un it in the Department of Labour.
34.The Committee commends the State party for its advocacy on the protection of women’s sexual and reproductive health rights and prevention of maternal mortality. The Committee notes with concern, however, the convoluted abortion laws which require women to get certificates from two certified consultants before an abortion can be performed, thus making women dependent on the benevolent interpretation of a rule which nullifies their autonomy. The Committee is also concerned that abortion remains criminalized in the State party, which leads women to seek illegal abortions, which are often unsafe. The Committee appreciates measures taken by the State party to improve mental health services for young women, but notes with concern the prevailing high level of suicide among young women, particularly minority and migrant youth. The Committee acknowledges the State party’s comprehensive health coverage and recent successful health education campaigns, such as the campaign to promote cervical cancer screening and good practice guidelines on health services for lesbian women and transgendered persons, but remains concerned about the access to and quality of these health services. The Committee also remains concerned about inequalities in access to health care by minority women. In particular, the Committee is concerned about the high rates of teenage pregnancy among Māori women and the lack of access to effective age-appropriate education on sexual and reproductive health and rights. Furthermore, the Committee is concerned about reports that some health practitioners perceive HIV testing of pregnant women as mandatory and are testing women without their consent.
35. The C ommittee urges the State party:
(a) To review the abortion law and practice with a view to simplifying it and to ensure women ’ s autonomy to choose;
(b) To prevent women from having to resort to unsafe abortions and remove punitive provisions imposed on women who undergo an abortion;
(c) To take the necessary measures to address the deteriorating mental health situation of young girls, to prevent and combat the abuse of alcohol and use of drugs, and to prevent girls ’ suicide, especially girls from mi grant and minority communities;
(d) To increase efforts to improve health-care services, including mental health care, for minority women, espe cially Māori and Pacific women;
(e) To improve access and quality of health services for lesbian women and transgendered persons;
(f) To promote widely education on sexual and reproductive health rights, particularly with regard to the prevention of teenage and unwanted pregnancies, and to strengthen measures to support pregnant girls;
(g) To take steps to ensure that pregnant women are informed that HIV testing is not mandatory and ensure that, when they are tested, thei r informed consent is obtained.
Disadvantaged groups of women
36.The Committee is concerned about the situation of disadvantaged groups of women, including women with disabilities, women of ethnic and minority communities, rural women and migrant women, who may be more vulnerable to multiple forms of discrimination with respect to education, health, social and political participation and employment. As noted in the report of the State party, disabled women are disproportionately represented among those who lack qualifications, those who do not work, and those on low incomes. The Committee is concerned that the new social security legislation will likely predominantly affect Māori women and reduce their social benefits. The Committee is further concerned that there are few education and employment programmes targeted at women and girls with disabilities. The Committee notes with concern the impact of the Christchurch earthquake on women, particularly rural women and older women, including their reported higher degrees of stress, anxiety and depression as well as their resulting higher numbers of displacement and unemployment.
37. The Committee recommends that the State party:
(a) Provide in its next report data and information on the situation of women with disabilities, rural women, older women and women from ethnic minority groups, including with regard to their access to education, emplo yment and health-care services;
(b) Ensure that the ongoing welfare reforms do not discriminate against disadvantaged groups of women and that an independent evaluation of their gendered impact is made;
(c) Ensure the gender mainstreaming of policies relating to the process of recovery from the 2011 earthquake, and engage in analysis of their gender impact by using data disaggregated by sex, age, ethnicity and other status.
Discrimination against women in marriage and family relations
38.The Committee is concerned about reports of forced marriages among migrant communities and regrets that there is no legislation to prohibit underage and forced marriages. The Committee is further concerned that the rights of migrant women in terms of family law, particularly forced marriages, polygamy and dowry-related violence have not been sufficiently addressed in law and practice and that girls as young as 16 years could marry with parental consent.
39. The Committee recommends that the State party:
(a) Revise the legal minimum age of marriage to 18 years without any exce ptions for parental consent;
(b) Introduce legal measures to prohibit underage and forced marriages and promote measures to protect women affected by polyg amy and dowry-related violence.
Beijing Declaration and Platform for Action
40. The Committee urges the State party, in the implementation of its obligations under the Convention, to fully utilize the Beijing Declaration and Platform for Action, which reinforce the provisions of the Convention, and requests the State party to include information thereon in its next periodic report.
Millennium Development Goals
41. The Committee emphasizes that full and effective implementation of the Convention is indispensable for achieving the Millennium Development Goals. It calls for the integration of a gender perspective and an explicit reflection of the provisions of the Convention in all efforts aimed at the achievement of the Millennium Development Goals and requests the State party to include information there on in its next periodic report.
42. The Committee requests the wide dissemination in New Zealand of the present concluding observations in order to make the people, government officials, politicians, parliamentarians and women ’ s and human rights organizations aware of the steps that have been taken to ensure the de jure and de facto equality of women, as well as the further steps that are required in this regard. The Committee requests the State party to continue to disseminate widely, in particular to women ’ s and human rights organizations, the Committee ’ s general recommendations, the Beijing Declaration and Platform for Action and the outcome of the twenty-third special session of the General Assembly on the theme “ Women 2000: gender equality, development and pea ce for the twenty-first century ” .
Ratification of other treaties
43. The Committee notes that the adherence of the State party to the nine major international human rights instruments would enhance the enjoyment by women of their human rights and fundamental freedoms in all aspects of life. The Committee therefore encourages the State party to consider ratifying the treaties to which it is not yet a party, i.e. , the International Convention for the Protection of All Persons from Enforced Disappearance and the International Convention on the Protection of the Rights of All Migrant Workers and Members of Their Families.
Follow-up to concluding observations
44. The Committee requests the S tate party to provide, within two years, writte n information on the steps taken to implement the recommendations contained in paragraphs 37 and 39 above.
Preparation of next report
45. The Committee requests the State party to ensure the wide participation of all ministries and public bodies in the preparation of its next report, as well as to consult a variety of women ’ s and human rights organizations during that phase.
46. The Committee requests the State party to respond to concerns expressed in the concluding observations in its next periodic report under article 18 of the Convention. The Committee invites the State party to submit its next periodic report in July 2016.
47. The Committee invites the State party to follow the “ Harmonized guidelines on reporting under the international human rights treaties, including guidelines on a common core document and treaty-specific documents ” , approved at the fifth Inter-Committee Meeting of the human rights treaty bodies in June 2006 (see HRI/MC/2006/3 and Corr.1). The treaty-specific reporting guidelines, adopted by the Committee at its fortieth session, in January 2008, must be applied in conjunction with the harmonized reporting guidelines on a common core document. Together they constitute the harmonized guidelines on reporting under the Convention on the Elimination of A ll Forms of Discrimination against Women. The treaty-specific document should be limited to 40 pages, while the updated common core document should not exceed 80 pages.