1 2 CITY COUNCIL 3 CITY OF NEW YORK 4 -------------------------------x 5 THE TRANSCRIPT OF THE MINUTES 6 of the 7 COMMITTEE ON FINANCE 8 -------------------------------x 9 10 December 19, 2007 Start: 11:55 a.m. 11 Recess: 12:20 p.m. 12 City Hall Committee Room 13 New York, New York 14 B E F O R E: 15 DAVID WEPRIN 16 Chairperson, 17 COUNCIL MEMBERS: Joel Rivera 18 Maria Baez Gale Brewer 19 Leroy Comrie 20 21 22 23 24 LEGAL-EASE COURT REPORTING SERVICES, INC. 17 Battery Place - Suite 1308 25 New York, New York 10004 (800) 756-3410 2 1 2 A P P E A R A N C E S 3 COUNCIL MEMBERS: 4 Bill DeBlasio 5 Lewis Fidler James Gennaro 6 Alan Gerson Eric Gioia 7 Robert Jackson Oliver Koppell 8 Helen Sears Peter Vallone, Jr. 9 Albert Vann David Yassky 10 Vincent Gentile Vincent Ignizio 11 James Oddo 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 1 2 A P P E A R A N C E S (CONTINUED) 3 Jeremy Waldrup 4 Assistant Commissioner NYC Department of Small Business Services 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 1 COMMITTEE ON FINANCE 2 CHAIRPERSON WEPRIN: I think it's good 3 morning under the wire, so we just made good 4 morning. Welcome to this morning's Finance Committee 5 meeting. My name is David Weprin, I chair the 6 Committee. I apologize for the lateness, but for 7 those of you that have been waiting, I have as well, 8 so at least you can't blame the Chairman. 9 Today we have several items on our 10 agenda. Intro. 635, which establishes the Southern 11 Boulevard BID in Council Member Maria del Carmen 12 Arroyo's district. One Land Use item, Resolution 13 1004, which establishes a declining property tax 14 exemption on properties constructed or reconstructed 15 where such construction or reconstruction includes 16 the installation of a green roof, sponsored by 17 Council Member Oliver Koppell. And Intro. 656 which 18 would extend the Finance Commissioner's authority to 19 sell tax liens and authorize the City to conduct 20 stand-alone lien sales of delinquent water and sewer 21 charges on certain residential properties. 22 Let's begin with the Southern 23 Boulevard BID. On November 15th, 2007, this 24 Committee held its initial hearing on the proposed 25 local law after having set the date for that hearing 5 1 COMMITTEE ON FINANCE 2 by Resolution 1088, as required by the BID law. At 3 that time all individuals who wanted to be heard on 4 the establishment of the BID were given an 5 opportunity to be heard. 6 After that hearing a 30-day objection 7 period began, allowing anyone objecting to the BID 8 to be given the opportunity to file an objection 9 with the City Clerk. 10 Under the BID law, a 51 percent or 11 more of property owners or individuals owning at 12 least 51 percent of the assessed valuation of the 13 property objected, we could not adopt a local law. 14 However, as the Department of Small 15 Business Services will soon tell us, there were no 16 objections to the creation of the BID. Thus, if the 17 Committee can answer the following four questions in 18 the affirmative, we can adopt the local law 19 establishing the BID. 20 The four questions we must be 21 prepared to answer are, 1) were all notices of 22 hearing for all hearings required to be held 23 published and mailed as required by law and 24 otherwise sufficient? 25 2) does all the real property within 6 1 COMMITTEE ON FINANCE 2 the district's boundaries benefit from the 3 establishment of the district, except as otherwise 4 provided by the law? 5 3) is all real property benefitted by 6 the district included within the district? 7 And 4) is the establishment of the 8 district in the best interest of the public? 9 If the Committee finds in the 10 affirmative on these four questions, then the 11 legislation can be adopted. 12 Next on our agenda is the Land Use 13 Item. A preconsidered resolution that will provide a 14 tax exemption to the Morris Heights Senior Housing 15 for the Elderly, which will be a six-story building, 16 located in the Bronx, that will provide 70 units of 17 rental housing to elderly persons of low income. 18 The sponsor, Morris Heights, Senior 19 Housing Development Fund Corporation will develop 20 the project under the Section 202 Supportive Housing 21 Program for the Elderly, with financing and 22 operating subsidies from HUD. 23 This project is located in Council 24 Member Maria Baez's district, and I am told she 25 supports the exemption. 7 1 COMMITTEE ON FINANCE 2 The next item on our agenda is 3 resolution 1004, which calls upon the State 4 legislature to provide a property tax exemption for 5 the installation of a green roof by a commercial or 6 residential property owner. And this is sponsored by 7 Council Member Oliver Koppell. 8 If you recall, the Finance Committee 9 had a hearing on this resolution on November 29th of 10 this year. At that time we heard all about the great 11 economic, environmental and aesthetic benefit green 12 roofs offer. 13 I would like to thank Council Member 14 Oliver Koppell for his sponsorship of this 15 legislation and bringing this important issue to the 16 City's attention. 17 Lastly, we have Intro. 656 which 18 would extend the Finance Commissioner's Authority to 19 sell tax lien sales, and authorize the City to 20 conduct stand-alone lien sales to delinquent water 21 and sewer charges on certain residential properties. 22 On Monday, DEP Commissioner Emily 23 Lloyd testified that stand-alone lien sales 24 authority brings the system, the security of future 25 revenue collection, and as a result, it will not be 8 1 COMMITTEE ON FINANCE 2 necessary to enact a mid-year rate hike. 3 Without this legislation, an 18 4 percent mid-year rate increase would take effect on 5 January 1st, 2008. The legislation incorporates new 6 protection and assures that the City's most 7 vulnerable population, low-income seniors, disabled 8 persons, and other low-income owners would be exempt 9 from such lien sales, as well as single-family 10 homeowners. 11 In addition to the legislation as 12 discussed on Monday, DEP and the Council have 13 entered into an agreement in the form of a 14 Memorandum of Understanding, which is attached to 15 the legislation which outlines additional safeguards 16 to DEP customers. 17 I am extremely pleased that the 18 Council and the Administration were finally able to 19 agree on the water lien issue, and have managed to 20 avoid a mid-year rate increase. 21 We have been joined by a number of 22 our colleagues. We have Council Member Gale Brewer 23 from Manhattan, Council Member Lew Fidler from 24 Brooklyn, Council Member Peter Vallone, Jr., from 25 Queens, Council Member David Yassky from Brooklyn, 9 1 COMMITTEE ON FINANCE 2 Council Member Helen Sears from Queens, Council 3 Member Leroy Comrie from Queens, Council Member 4 Albert Vann from Brooklyn, Council Member Vincent 5 Ignizio from Staten Island, and Council Member 6 Oliver Koppell from the Bronx. 7 We will now hear from Small Business 8 Services, Assistant Commissioner Jeremy Waldrup. 9 ASSISTANT COMMISSIONER WALDRUP: Good 10 morning, Mr. Chairman, and members of the Finance 11 Committee. I am Jeremy Waldrup, Assistant 12 Commissioner at the Department of Small Business 13 Services. 14 As required by BID law, the Southern 15 Boulevard BID Steering Committee mailed the summary 16 of the City Council resolution to each owner of real 17 property within the proposed district at the address 18 shown on the latest City assessment roll. Or to such 19 other persons as registered with the City to receive 20 tax bills concerning real property within the 21 district and to tenants of each building within the 22 proposed district. 23 In addition, SBS arranged for the 24 required publication of a copy of a summary of the 25 resolutions in the City Record. We are pleased to 10 1 COMMITTEE ON FINANCE 2 report on the result of the objections filed with 3 the City Clerk against the establishment of the 4 proposed Southern Boulevard Business Improvement 5 District. 6 At the conclusion of the objection 7 period, at 5:00 p.m. on December 14th, 2007, and 8 taking into consideration any objections postmarked 9 by that date, no objections were filed. 10 Our review concludes that the level 11 of objection filed in terms of either the number of 12 property owners or percentage of assessed valuation 13 is within the acceptable threshold needed to advance 14 the bill for a favorable consideration by the full 15 City Council. 16 SBS requests the City Council approve 17 the establishment of the Southern Boulevard BID in 18 the Bronx. The Department of Small Business Services 19 supports the establishment of the BID. In our 20 judgment, the BID will approve business conditions 21 and quality of life of the Southern Boulevard BID, 22 making it a good place to live, work and visit, and 23 laying the groundwork for further neighborhood 24 development activities in the Bronx. 25 Thank you. 11 1 COMMITTEE ON FINANCE 2 CHAIRPERSON WEPRIN: Thank you. 3 Are there any questions from the 4 Council members? 5 Council Member Vann. 6 COUNCIL MEMBER VANN: I'm sorry, I 7 came in late. What we're doing here is 8 reestablishing the lien sale on property that we 9 delayed previously? 10 CHAIRPERSON WEPRIN: (Not using 11 microphone.) 12 COUNCIL MEMBER VANN: So, we're 13 authorizing the water lien sale along with the 14 property tax. 15 CHAIRPERSON WEPRIN: (Not using 16 microphone.) 17 COUNCIL MEMBER VANN: The staff has 18 pretty much kept me abreast of the issues as they 19 were being negotiated, the exemptions they were 20 trying to get, all of it sounded pretty good. 21 My community has a lot of two- and 22 three-family brownstones. We are one of the areas 23 that is hardest hit in terms of tax lien and the 24 subsequent foreclosure epidemic, if you will, both 25 in my area and parts of Queens. It is my 12 1 COMMITTEE ON FINANCE 2 understanding from talking to a lot of the 3 organizations involved, we're trying to abate the 4 predatory lending impact on our citizens, that we 5 think, they believe, that an additional water tax 6 lien would be overburdensome to a lot of my 7 homeowners in my area who are struggling to stay out 8 of foreclosure and struggling to pay off the 9 agreement as a result of the tax lien. 10 So, this would be like the straw, you 11 know, that would break the camel's back. So, I think 12 there are a lot of good things that have been 13 negotiated here. I think the intent is good, but in 14 some areas, and in communities that are similar to 15 mine, this is not something that we can actually 16 sustain. 17 CHAIRPERSON WEPRIN: (Not using 18 microphone.) As part of the agreement, Council 19 member, they are creating an ombudsman office to 20 deal with these type of issues, and they also said 21 that they would work closely with every Council 22 member's office to have a person assigned to these 23 type of situations. 24 So, we're hoping with the regular 25 safeguards that lien sale would happen as a last 13 1 COMMITTEE ON FINANCE 2 resort, we're hoping that your office can work with 3 them to kind of solve -- 4 COUNCIL MEMBER VANN: I believe in 5 keeping hope alive, and, you know, hope springs 6 eternal and all of that, and I do appreciate the 7 effort that the Speaker's staff has made to make the 8 best situations possible, to minimize as much impact 9 as they could, but in my district, I've looked at 10 it, I've tried to be supportive of it, I'm not going 11 to be able to support this legislation. 12 CHAIRPERSON WEPRIN: I understand 13 fully, Council member. 14 Council Member Fidler. 15 COUNCIL MEMBER FIDLER: Some people 16 have to vote, so I will be very brief. 17 I just wanted to comment on what 18 Council Member Vann stated, because I also represent 19 Canarsie, which is a community which has many, many 20 two- and three-family homes, and is certainly as 21 much an epicenter of the subprime lending crisis as 22 there is in the City of New York, my concern and my 23 understanding is that DEP has agreed that before 24 they moved to sell a water lien on a two- or a 25 three-family home, that they're going to implement 14 1 COMMITTEE ON FINANCE 2 the same kind of utility rate structure that, 3 payment plan that Con Ed does, where they allow 4 tenants to pay the water bill, and have it off-set 5 on their rent so that the water is not shut off and 6 we don't get to the point of a water bill lien sale. 7 The other competing consideration is 8 that DEP has made it entirely clear that if this 9 does not happen, they're going to raise the water 10 rates entirely, and that concerns me as well, in 11 terms of the subprime lending situation, that those 12 people who are struggling to meet their bills will 13 have a bill that is, once again, ten, or 12 percent 14 higher for a critical element to the maintenance of 15 their property, and that, too, would put due 16 pressure on two- and three-family homeowners. 17 It's not all that simple in that 18 respect. No one wants to pay. I understand that. I 19 don't like paying either. But it seems that this is 20 the best solution, notwithstanding the concerns 21 Council Member Vann raises, which are legitimate, I 22 think we have come to a middle ground that protects 23 everybody to some degree and at least protects 24 everybody from the water tax increase. 25 CHAIRPERSON WEPRIN: Thank you. 15 1 COMMITTEE ON FINANCE 2 Call the roll. 3 COUNCIL CLERK MARTIN: Council Member 4 Weprin. 5 CHAIRPERSON WEPRIN: Aye on all. 6 COUNCIL CLERK MARTIN: Rivera. 7 COUNCIL MEMBER RIVERA: I vote aye on 8 all. 9 COUNCIL CLERK MARTIN: Baez. 10 COUNCIL MEMBER BAEZ: Aye. 11 COUNCIL CLERK MARTIN: Brewer. 12 COUNCIL MEMBER BREWER: I have 13 laryngitis. I vote aye, but I wanted to mention in 14 terms of the water bill, to thank all parties 15 concerned, and to say that in terms of the bill, my 16 bill, I mentioned this at the hearing but this bill 17 reflects the recent rate increase, which I think 18 applies to June, depending on specific usage, a 19 single-family homeowner should see his or her bill 20 increased by $18 per quarter. 21 I mentioned this, because I know that 22 we talked about having different words in that 23 paragraph for the next bill. I also want to 24 congratulate Council Member Koppell, who just had a 25 meeting on the West Side talking about green roofs, 16 1 COMMITTEE ON FINANCE 2 and all the other things we can do in the 3 neighborhood, and certainly Resolution 1004 would 4 help. 5 Thank you very much. I vote aye. 6 CHAIRPERSON WEPRIN: Thank you, 7 Council member. 8 COUNCIL CLERK MARTIN: Comrie. 9 COUNCIL MEMBER COMRIE: I'm going to 10 vote aye on all. 11 I am also part of the epicenter of 12 the predatory lending, but I had DEP do the first 13 payment incentive plan fair in my district to see 14 how it works, and the way that they are working to 15 try to mitigate problems with homeowners that are 16 really having a problem with payment, where they're 17 bringing in other agencies, they're bringing in 18 opportunities for people to look at refinancing 19 their loans, they're doing it in a very holistic 20 manner where they're bringing in the checks and 21 balances all throughout the process to try to make 22 sure that no one loses their home over a water lien, 23 I think is setting a new precedent in the City and I 24 want to congratulate DEP and Finance for all of 25 their efforts. 17 1 COMMITTEE ON FINANCE 2 When they did the Payment Incentive 3 Program in my district, they brought in HPD, they 4 brought in HRA, they brought in the Neighborhood 5 Housing Service of the City to look at the 6 restructuring loan and restructuring debt. Because 7 normally when a person is not paying their water 8 bill, they're probably in general debt all together, 9 and to do it in a holistic manner, to do it in the 10 district in the evening or in a weekend when people 11 can come and not have to go to one office but to get 12 the whole total service in one area I think is a 13 real help to home owners. And to prevent an offset 14 of an 18 percent raise I think is critical to people 15 that are struggling to pay their bills now, and for 16 people to have to come in get a one-shot opportunity 17 to restructure their finances I think is a good 18 piece. And also DEP has promised to notify members 19 all through the process so that you can work with 20 your homeowner then they do not have to suffer -- 21 CHAIRPERSON WEPRIN: Council member. 22 COUNCIL MEMBER COMRIE: Am I going too 23 long for my yes vote? Oh, sorry. I just wanted to 24 explain. Yes, thank you. I just wanted to explain my 25 reasons for voting yes, that it's a process for 18 1 COMMITTEE ON FINANCE 2 inclusion and not putting people in jeopardy. Thank 3 you. 4 CHAIRPERSON WEPRIN: Thank you. 5 Vallone. 6 COUNCIL CLERK MARTIN: Vallone. 7 COUNCIL MEMBER VALLONE: Thank you. 8 Let me very quickly thank the Chair, as a member of 9 both Finance and Environmental, I know the amount of 10 work that they've done to come to this agreement and 11 the Administration for this agreement. 12 I do want to state on the record that 13 I, as I believe almost every Council Member here, 14 are opposed to this rental payment to the City that 15 the Water Board makes. To the extent that any 16 increase in the water rates goes to the general 17 fund, that's a tax increase by an unelected body. 18 It's unconstitutional. This agreement does say that 19 that will be discussed, so it's still on the table 20 and I believe it's wrong and it still exists, but 21 it's something we're going to continue to work on. 22 With that, I vote aye. 23 COUNCIL CLERK MARTIN: Yassky. 24 COUNCIL MEMBER YASSKY: I vote aye. 25 COUNCIL CLERK MARTIN: Fidler. 19 1 COMMITTEE ON FINANCE 2 COUNCIL MEMBER FIDLER: I just want to 3 note for the record, as I did at Monday's hearing, 4 that I am casting my yes vote based upon the 5 representation of the promise that was made here by 6 DEP that the New York City Water Board will cancel 7 their plans for a rate increase. And that is the 8 basis for my agreeing to do this, and so I vote aye. 9 COUNCIL CLERK MARTIN: Gennaro. 10 COUNCIL MEMBER GENNARO: Mr. Chairman, 11 I wish to speak on my vote briefly. 12 Yes, many good things have been said 13 and I certainly wish to associate myself with some 14 of the supportive things that have been said here. 15 I, of course, have been working hard 16 on this and I was a real hold out on this, but we 17 were able, as you've heard, to structure something 18 that really does avoid the 18 percent increase, and 19 provides protection for those who most need it. 20 And also, people should bear in mind 21 that the City Council is not going away on this 22 issue. I mean, we still have our oversight 23 responsibility, we still have the Finance Committee, 24 we still have my Committee, we still have all of you 25 with an active interest in this. To the extent that 20 1 COMMITTEE ON FINANCE 2 this doesn't go well for whatever reason, we will 3 step in and do whatever is necessary. So, this is 4 not necessarily the last word. There is still 5 improvements that have to be made with DEP's overall 6 billing operation, they're the first to admit that. 7 They have taken upon themselves the challenge to do 8 that, so this is not the last word. 9 I want to thank Peter Vallone also 10 for the encouragement on the rental payment issue, 11 which is certainly something that David, myself and 12 others will be making an issue of between now and 13 the next rate setting in June, because we do have to 14 stop that practice, but let's just do, you know, one 15 battle at a time. 16 I want to thank Mike Keogh, and Ramon 17 and the Council staff in a very special way, for 18 helping us to come to where we are today, and sort 19 of putting up with me, which is not always easy. And 20 also the folks in the Bloomberg Administration -- 21 CHAIRPERSON WEPRIN: That's what 22 Joanne told me. 23 COUNCIL MEMBER GENNARO: She thanks 24 you for your support. 25 So, with that I thank all involved 21 1 COMMITTEE ON FINANCE 2 and I vote aye. 3 COUNCIL CLERK MARTIN: Gioia. 4 COUNCIL MEMBER GIOIA: Thank you. I 5 vote yes. 6 COUNCIL CLERK MARTIN: Koppell. 7 COUNCIL MEMBER KOPPELL: Mr. Chairman, 8 just to briefly say, with respect to the green 9 roofs, I look forward to your assistance. It's 10 rumored that you have some influence in Albany, so I 11 look forward to your assistance in getting this 12 enacted and your help with the Administration in 13 convincing them, because it will cost some money to 14 the City in terms of tax abatement, and getting the 15 Administration, that has indicated some interest in 16 this but not full support, because I think it is 17 something the green roofs, it's something that's a 18 really tremendous benefit in so many different ways, 19 both environmentally and in terms of energy saving. 20 I mean, your staff has done a great job in pointing 21 out all the ways in which putting these green roofs 22 on top of buildings can be of assistance in, as I 23 said, a number of different ways. 24 In Germany this is a very common 25 practice, and this is very effective in saving 22 1 COMMITTEE ON FINANCE 2 energy and providing cooling and absorbing 3 stormwater and so on. 4 So, we need to go further with it, 5 but I'm delighted that you have moved this, and I 6 vote aye. 7 I also feel on the water rate that 8 it's a good compromise, and ultimately, everybody 9 who pays their bill on time should also get the 10 benefit of, you know, of this measure. 11 So, I vote aye on all. 12 COUNCIL CLERK MARTIN: Sears. 13 COUNCIL MEMBER SEARS: Aye on all. 14 COUNCIL CLERK MARTIN: Vann. 15 COUNCIL MEMBER VANN: Aye on all, 16 except on Intro. 656 I vote no. 17 COUNCIL CLERK MARTIN: Gentile. 18 COUNCIL MEMBER GENTILE: Aye on all. 19 COUNCIL CLERK MARTIN: Ignizio. 20 COUNCIL MEMBER IGNIZIO: Yes. I have a 21 green-colored roof, so I hope that would apply to my 22 home as well. I want to, you know, thank Mike Keogh 23 for his hard work in negotiating this bill with DEP. 24 I believe that off the bat, though, the 11 percent 25 increase proposed for next year ought be tabled 23 1 COMMITTEE ON FINANCE 2 immediately with the passage of this bill by the 3 agency as an act of good faith, and I do believe in 4 Commissioner Joe Singleton, I hope he will continue 5 to work with the local City Council offices and not 6 refer or defer conversations to 3-1-1 or any 7 therein, and hopefully continue to work with this 8 body. Thank you very much. I vote aye on all. 9 COUNCIL CLERK MARTIN: Oddo. 10 COUNCIL MEMBER ODDO: I vote yes on 11 all, and I would like to associate myself with the 12 comments of Council Member Fidler, not because of 13 the substance of what he said, but because I'm 14 working a rotisserie baseball deal with him and I'm 15 trying curry favor with him. Thank you. 16 COUNCIL CLERK MARTIN: By a vote of 16 17 in the affirmative, zero in the negative and no 18 abstentions, all items are adopted, with the 19 exception of Introduction 656, which is adopted by a 20 vote of 15 in the affirmative, one in the negative 21 and zero abstentions. 22 All members, please sign the 23 Committee reports. Thank you. 24 CHAIRPERSON WEPRIN: Okay, before we 25 adjourn, I would also like to state for the record 24 1 COMMITTEE ON FINANCE 2 that I want to thank Mike Keogh and the Speaker's 3 staff, as well as DEP and the Department of Finance 4 for what I consider to be a very good negotiated 5 agreement, which I hope will bode well for future 6 debate and issues as we proceed forward on these 7 type of issues. 8 Other than that, we're going to be 9 adjourned, and I'm going to keep the roll open for a 10 half hour for those members that have called and are 11 on their way or in and around the building. 12 Other than that, we're adjourned. 13 COUNCIL CLERK MARTIN: Council Member 14 Gerson. 15 COUNCIL MEMBER GERSON: I vote aye. 16 COUNCIL CLERK MARTIN: Council Member 17 Jackson. 18 COUNCIL MEMBER JACKSON: Aye on all. 19 COUNCIL CLERK MARTIN: Council Member 20 DeBlasio. 21 COUNCIL MEMBER DeBLASIO: Aye on all, 22 and happy holidays. 23 COUNCIL CLERK MARTIN: The final vote 24 on the Committee on Land Use (sic) now stands at 19 25 in the affirmative, zero in the negative and no 25 1 COMMITTEE ON FINANCE 2 abstentions, with the exception of Introduction 656, 3 which is adopted by a vote of 18 in the affirmative, 4 one in the negative and zero abstentions. Thank you. 5 (Hearing concluded at 12:20 p.m.) 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 1 2 CERTIFICATION 3 4 5 STATE OF NEW YORK ) 6 COUNTY OF NEW YORK ) 7 8 9 I, CINDY MILLELOT, a Certified 10 Shorthand Reporter, do hereby certify that the 11 foregoing is a true and accurate transcript of the 12 within proceeding. 13 I further certify that I am not 14 related to any of the parties to this action by 15 blood or marriage, and that I am in no way 16 interested in the outcome of this matter. 17 IN WITNESS WHEREOF, I have hereunto 18 set my hand this 19th day of December 2007. 19 20 21 22 23 --------------------- 24 CINDY MILLELOT, CSR. 25 27 1 2 C E R T I F I C A T I O N 3 4 5 6 7 8 9 I, CINDY MILLELOT, a Certified Shorthand 10 Reporter and a Notary Public in and for the State of 11 New York, do hereby certify the aforesaid to be a 12 true and accurate copy of the transcription of the 13 audio tapes of this hearing. 14 15 16 17 18 19 20 21 22 23 24 ----------------------- CINDY MILLELOT, CSR. 25