Homelessness in Waterloo Region: A Policy Analysis
1.0– Introduction
This document serves as an analysis of the current policies surrounding homelessness in the Waterloo Region. In 2011, the Provincial government mandated that all cities create a 10 Year Plan to address homelessness in their communities.[1] The Region’s 10 Year Plan for Waterloo Region will first be analyzed in this document with core pieces being brought to the forefront of the conversation. Policies will then be analyzed through an Intersectionality-Based Policy Analysis (IBPA) Framework sourced from Hankvisky[2]. This Framework will ensure that policies the Region is implementing are inclusive of all people who may be experiencing homelessness. Additionally, this Framework will help analyze whether the current policies are effectively meeting the needs of the community, and if not, what recommendations may be beneficial. Lastly, recommendations will be made to further promote equity and dignity, and work toward efficient and sustainable solutions regarding homelessness in Waterloo Region.
2.0– What is the Problem?
Homelessness has been an ongoing issue within Waterloo Region for many years, however, within the last couple of years, there has been a steady rise of people experiencing homelessness.[3] In the last 3 years, the number of people experiencing homelessness increased from 333 people in 2018 to 1,085 in 2021.[4] More recently, in 2021 there was a rapid increase in homelessness in the region as numbers rose 34% in 6 months.[5] There are multiple reasons to explain this rise in numbers, most of which revolve around the COVID-19 pandemic and the ongoing harmful effects it has had on vulnerable communities.[6]
The most detrimental effect of the pandemic has been the rising costs of rent and housing, making it nearly impossible for many people to be able to afford a place to live.[7] Due to the pandemic driving housing costs up, a range of housing options for people experiencing homelessness has begun to disappear. Growing waitlists and a lack of housing options are also ongoing issues. In 2019 with pre-pandemic numbers, the number of people on the affordable housing waitlist in Waterloo Region was 7031,[8] however, the city has noted that the need continues to rise and, thus, people have been experiencing longer wait times.[9]
Another ongoing issue that has been exacerbated due to the pandemic is a lack of stable, full-time work opportunities. The Working Centre in Kitchener states that people are experiencing trouble finding full-time work that is engaging and stable, thus causing many to be unable to afford housing.[10]
3.0– Defining ‘Homelessness’
According to the Canadian Observatory on Homelessness, homelessness is “the situation of an individual, family, or community without stable, safe, permanent, appropriate housing, or the immediate prospect means and ability of acquiring it”.[11] It is important to keep in mind that it is not all-encompassing as it doesn’t account for all types of populations.[12] Indigenous people may not be well represented in this definition, for example, because it does not mention experiences of trauma due to colonization.[13] Additionally, youth often experience homelessness very differently than adults as they are younger, living without a caregiver and do not have the means to provide a stable home for themselves.[14]
4.0– Evaluation of Criteria: IBPA Framework:
When evaluating the current policies in place regarding homelessness in Waterloo Region, I will be utilizing an Intersectionality-Based Policy Analysis (IBPA) Framework sourced from Hankvisky.[15] The Framework provides a set of guiding principles and 12 overarching questions that help shape the analysis.[16] Given the scope of this assessment, I will only be using 2 of the Transformative IBPA questions; the first being, “what inequities actually exist in relation to the problem?”, and “how will the proposed policy responses reduce inequities?”.[17] The first question addresses important intersecting social locations and systems and asks how systems of inequities interact with the policy problem. Hankvisky’s second question asks how the proposed policy options address intersectional inequities without reinforcing harmful stereotypes and inequities for some populations. I will observe the current policies through this Framework and answer these questions to find out how effectively this policy is improving inequities for all people in the Region.
5.0– The Region of Waterloo’s Current Policies on Homelessness
5.1– Introduction of the 10-Year Plan:
As mandated by the Provincial Government in 2011, Waterloo Region created a 10-Year Housing and Homeless Plan to help support and prevent homelessness within the community.[18] More recently, the Region released a 5-Year Review of the 10-Year Plan, discussing the progress made, as well as strategic future developments for the years 2019-2024.[19] I will be examining the 5-Year Review and analyzing successful implementations, as well as areas of failure or in need of improvement.
5.2– 10-Year Plan Program Implementation:
The Region of Waterloo has implemented a variety of programs that aim to curb homelessness by providing hands-on support, as well as housing assistance. There are currently 7 housing and homelessness programs, including, Housing Resource Centres, Housing Helpines, Emergency Shelters, Street Outreach, Coordinated Access Process, Marillac Place, and Supportive Housing.[20] In addition to these programs, the Region also offers Affordable and Community Housing Programs, helping low and moderate-income households to access and maintain safe housing.[21] Due to the scope of this assessment, I will only focus on 4 critical areas that require the most attention for people experiencing homelessness, including long waitlists, affordable housing, and permanent & preventative solutions.
5.3– Housing Waitlist:
To address the urgent need for people with a medium to high need for housing, the Prioritized Access to Housing Supports (PATHS) program was created.[22] The PATHS program process helps people experiencing homelessness to match with housing support through one waiting list.[23] Between July to September of 2021, 42 households were secured through this program,[24] however, The Review fails to mention the previous or current wait times for housing or how the PATHS program functions with the previous waitlist and system in place.
5.4– Housing Affordability:
Housing affordability has deteriorated rapidly within the last couple of years due to several causes, including rising rents, growing demand and a lagging supply of housing availability.[25] To help curb this, the region is in the process of implementing an increase in overall housing supply, as well as affordable housing by “municipalities…adopting approaches than enable the construction of a sufficient supply of housing to meet current and future demands”.[26] This will be carried out by updating residential land-use policies and zoning regulations, encouraging a wider range of housing types throughout the city.[27] Additionally, by creating policies that allow by-laws to permit higher heights in appropriate areas of the city to promote housing development.[28] The Region is also calling for the implementation of a certain percentage of affordable units to be built along with major transit station areas, as well as policies and regulations that prevent the conversion of rental housing to condominiums.[29] Both of these implementations would help with the preservation of affordable housing.
5.5– Long-Term Supportive Housing:
Another program initiative in the works is a long-term supportive housing that helps sustain efforts of decreasing the number of people experiencing homelessness.[30] The 5-Year Review states that the Region has implemented long-term housing applicants with support, such as, assistance with rent, independent living, and strategies to maintain housing, among other supports.[31] People experiencing homelessness can access these supports through the PATHS program mentioned earlier. As of 2019, 79% of the tenants that went through the long-term supportive housing program had been housed for 12 months or longer.[32]
5.6– Preventative Measures:
The Region has attempted to curb homelessness through preventative measures, such as Housing Resource Centres and Helplines.[33] Resource Centres are drop-in sites that offer education and assistance to households that are at risk of housing loss intending to prevent eviction.[34] Additionally, Housing Helplines have been set up to support callers in preventing housing loss, or, if that is not possible, to help provide resources and next steps while trying to divert people from shelter beds.[35] The Region is also calling for policy implementation to discourage the removal of affordable units and to encourage rapid replacements when possible, thus helping to prevent the loss of affordable housing.[36]
6.0– 10-Year Plan Policy Effectiveness
6.1– Analysis Through IBPA Framework:
Using Hankvisky’s Transformative Policy questions, I will provide a brief analysis of the Region’s 10 Year Plan and answer the following 2 questions: “what inequities actually exist in relation to the problem?” and “how will the proposed policy responses reduce inequities?”.[37]
6.1.1 - Hankvisky's Question #1 The current policy does a passable job of taking an intersectional approach to determine who is most affected by homelessness based on intersecting social locations. For example, vulnerable populations that are at higher risk of experiencing chronic homelessness are addressed within the Region’s policy in Figure 4.9.[38] Population groups such as rural members, seniors, Indigenous Peoples, lone parents, and domestic abuse survivors are specifically recognized in policy documents and are typically given priority status.[39] The policy also acknowledges the diversity within the Region and is said to offer translation services when applicable.[40] The policy falls short of recognizing the needs of youths and the LGTBQ2S+ community, even though 40% of youth experiencing homelessness identify as LTGBQ2S+.[41] There are no specialized housing initiatives that work to meet the needs of the LGTBQ2S+ youth community in Canada, a noticeable gap within the Region’s policies as well.[42] Additionally, the policies should further recognize how factors such as gender and race play a role in people’s experiences and the potential privileges and oppressions one faces.[43] For example, 1 in 5 racialized families lives in poverty compared to 1 in 20 non-racialized.[44] Racialized women also earn an average of 32% less in the workforce.[45] These factors should be taken into account when creating policies.
6.1.2 - Hankvisky's Question #2 The proposed policy promotes social justice through a dignified process that aims to provide support to people experiencing homelessness. The recent policy revision of encampments and the “enforcement as a last resort” shows the Region is willing to continue progressing towards more just policies.[46] These factors are essential when attempting to reduce inequities through policy. For example, policies such as the PATHS program help vulnerable communities to be seen and prioritized, an important step in reducing inequities.[47]
6.2– Policy Successes:
After the implementation of multiple policies, there was a positive trend in securing housing, providing better support for people experiencing homelessness, and improving database systems.[48] The policies seemed to be effective during the starting dates between 2016 and 2019, however, it should be noted that these results are pre-COVID-19 pandemic.
6.2.1 - PATHS Several programs have helped relieve homelessness in the Region, including the launching of the PATHS program in 2016. There was an obvious need for a program that would address the long wait times that many people were facing and the PATHS program was created to help fill this gap.[49] After the program's implementation in 2019, 42 households found housing through the program in 3 months (July-September), which should be considered a success.[50] Little data has been released since this report, however, causing this analysis to be unable to confirm an ongoing positive trend.
6.2.2 - HIFIS Database In April of 2018, the Region also implemented a Homeless Individuals and Families Information System (HIFIS), a web-based database that allows for shared service planning among housing service employees.[51] This database is considered a success because it allows for efficient access to case management across the regions and utilizes real-time data collection and evidence-informed service planning.[52] These technological upgrades allow for reduced wait times and prioritize the client’s needs effectively through matching services on the web.[53] Enhancing this database system will also allow for the collection and storage of local data on Indigenous populations, proving that Indigenous peoples are experiencing homelessness more than what is being collected.[54]
6.2.3. - Diversion from Emergency Shelters The program Families in Transition helps support families who are experiencing homelessness to find secure housing and decreases the number of families needing to access emergency shelters.[55] This program helped support and divert 402 participants from needing emergency shelters in 2018/2019, an achievement for the Region.[56]
6.3– Policy Improvements Needed:
COVID-19 has greatly impacted homeless and low-income communities as the price of housing, rent, and the overall cost of living has continued to increase while the minimum wage has not increased enough to balance these costs.[57] Policy improvements should be made to address the current needs of the community.
6.3.1. - Rise in Homelessness As previously mentioned, the rise of chronic homelessness has risen 34% in the last 6 months last year, proving that the policies currently in place require improvement.[58] This rise in homelessness points to the weakness of the preventative measures in place. This can also be noted through the rise in encampments across the Region.[59] Experts state this is due to increased rental costs, a lack of regulation in rental housing, and a lack of affordable housing, all of which can be addressed through updated policies.[60]
6.3.2 - Rise in Housing Costs The steep rise in housing costs and the overall cost of living has impacted the effectiveness of the policies in place. Section 4.5 in the Region’s policy recognizes the rising costs of ownership and rental housing markets, however, it doesn’t mention how this will be addressed.[61] Under the Affordable Housing Strategy, the Region has added roughly 100 new affordable units per year, however, these agreements have been expiring since 2014.[62] Between 2019 and 2030, 13 Federal and 54 Provincial housing providers will expire, putting another 3,627 units at risk and adding more people to the housing wait-list and system.[63] There is no long-term, sustainable plan in place and this needs to be addressed immediately through policies that safeguard affordable housing units.
6.3.3. - Rise in Wait Times The need for housing has grown since 2014 and as of 2019, over 7,000 people were on a waitlist seeking affordable housing.[64] This number does not account for people whose affordable units have the potential to expire as discussed in 6.3.2 of this document.[65] The Region noted that in addition to a growing waitlist, the number of people housed each year has been declining.[66] Both factors combined show a failure in the current system.
7.0– Recommendations
A thorough analysis of Waterloo Region’s current policies on homelessness has prompted 3 potential policy recommendations that work to improve the policies in place. Firstly, implementing programs and workshops that address job instability and skill-building opportunities. Secondly, as mentioned above, a more inclusive intersectional approach is needed to provide safe spaces for LGTBQ2S+ communities experiencing homelessness. Lastly, using a ‘Housing-First’ model to target homelessness has proven effective in places like Finland and is the final recommendation.
7.1– Addressing Job Instability and Skill-Building:
There are clear links between homelessness and economic instability, largely due to job insecurity (5 year, 20). Initiating programs that support people experiencing job instability would allow for a steady flow of income, providing sustainable solutions to those struggling with paying for housing. The Housing Resource Centres and Helplines currently in place are a good foundation, however, I suggest building off them to provide a more holistic support. New programs would include career help such as resume & cover letter help and assistance with job searching.
Additionally, the Region would provide free skill-building workshops that would help people gain skills required for entry-level or advanced jobs. This may include workshops for training in Microsoft Suite or hands-on skills such as basic building techniques. Programs would be run by community members with experience in these fields and would occur roughly once a month, focusing on a different skill each month.
7.2– Intersectional LGTBQ2S+ Policies:
LGTBQ2S+ youth are at a higher risk of experiencing homelessness due to homophobia and transphobia discrimination, experienced both at home and in shelters.[67] LGTBQ2S+ youth are more likely to be homeless due to an inability to get along with their parents (51%), compared to heterosexual cisgender youth (36%).[68] Due to potential violence and discrimination occurring in shelters, LGTBQ2S+ have reported they feel safer on the streets.[69]
To combat this, I recommend the Region create a shelter that is specific to the LGTBQ2S+ community, providing a safe space for youth, in particular, to feel supported. The shelter would provide bedding and resources that support mental and physical well-being. This shelter would be created through the combined help of community efforts and Provincial government homelessness grant opportunities.
7.3– A ‘Housing-First’ Model:
A housing-first model addresses issues of homelessness by providing a stable home first, rather than progressing through multiple levels of temporary housing.[70] The idea is that once people are housed, it is easier to address other issues that put them at risk of being homeless are addressed later.[71] The Region of Waterloo has actively been looking into a housing-first model and brought it to the council’s attention in 2020[72]; this recommendation further supports their suggestion.
The housing-first model is successfully exemplified in Finland, the only European country where homelessness has declined in recent years.[73] When this policy was established, it involved wide partnerships with state authorities, local communities and non-governmental organizations (NGOs).[74] To address the large number of housing options needed, Finland provided multiple options, including, social housing, buying flats from the private market and using them as rental apartments, as well as building new housing blocks for supported housing.[75] A key part of this project was also the conversion of shelters into supported housing.[76]
The difference between this model compared to others is that it is attempting to end homelessness rather than manage it.[77] This policy does require a rather large investment, however, it has proven that it is more cost-effective to invest in stable housing than it is to provide scattered, temporary options.[78] The housing-first model would address the rise in homelessness and wait times by providing immediate housing options for those in need.[79] This model would also work with the other recommendations as the programs mentioned would provide supplementary support after people experiencing homelessness are housed.
8.0– Bibliography:
Falvo, Nick. “The Long-Term Impact of The COVID-19 Recession on Homelessness in Canada: What to Expect, What to Track, What to Do”. Nick Falvo Consulting, December, 2020. https://nickfalvo.ca/wp-content/uploads/2020/11/Falvo-Final-report-for-ESDC-FINAL-28nov2020.pdf
Ghonaim, Hala. “As Kitchener Encampment Grows, Region Says Enforcement’s a ‘Last Resort’.” CBC News, Updated March 24, 2022. https://www.cbc.ca/news/canada/kitchener-waterloo/encampment-kitchener-waterloo-region-action-1.6393871
Hankvisky, Olena et. al. Intersectionality-Based Policy Analysis. Vancouver, BC: Institute for Intersectionality Research and Policy, Simon Fraser University,2012.
Kaakinen, Juha. “Lessons From Finland: Helping Homeless People Starts With Giving Them Homes.” The Guardian, September 14, 2016. https://www.theguardian.com/housing-network/2016/sep/14/lessons-from-finland-helping-homeless-housing-model-homes
Lampa, Nicole. “Homelessness Nearly Triples in Waterloo Region Over the Past Three Years: Survey.” CTV News Kitchener, Nov. 3, 2021. https://kitchener.ctvnews.ca/homelessness-nearly-triples-in-waterloo-region-over-past-three-years-survey-1.5650868
Senoran, Heather. “Chronic Homelessness in Waterloo Region Climbs 34% in 6 Months.” CTV News Kitchener, July 7, 2021. https://kitchener.ctvnews.ca/chronic-homelessness-in-waterloo-region-climbs-34-per-cent-in-6-months-1.5500523
Thompson, C. “Waterloo Region’s New Policy On Homeless Camps Says Eviction A Last Resort.” The Record, Updated Dec. 21, 2021. https://www.therecord.com/news/council/2021/12/16/waterloo-regions-new-policy-on-homeless-camps-says-eviction-a-last-resort.html
“10-Year Housing and Homelessness Plan: Five-Year Review.” Region of Waterloo Community Services, 2019. https://www.regionofwaterloo.ca/en/living-here/resources/Documents/Housing/Five-Year-Review-of-the-Waterloo-Region-10-Year-Housing-and-Homelessness-Plan-access.pdf
“Affordable Housing Strategy: Waterloo.” Engage Waterloo Region, Updated April 6, 2022. https://www.engagewr.ca/affordable-housing-waterloo
“Canadian Definition Of Homelessness.” Canadian Observatory on Homelessness, Date Accessed April 4, 2022. https://www.homelesshub.ca/sites/default/files/COHhomelessdefinition.pdf
“Homeless Hub: Causes of Homelessness”. Homeless Hub, 2021. https://www.homelesshub.ca/about-homelessness/homelessness-101/causes-homelessness
“Homeless Hub: Lesbian, Gay, Bisexual, Transgender, Transsexual, Queer, Questioning and Two-Spirit (LGTBQ2S).” Homeless Hub, 2021.https://www.homelesshub.ca/about-homelessness/population-specific/lesbian-gay-bisexual-transgender-transsexual-queer
“Homeless Hub: Racialized Communities”. Homeless Hub, 2021. https://www.homelesshub.ca/about-homelessness/population-specific/racialized-communities
“Reaching Home”. Waterloo Region Homeless Plan 2019-2024, Date Accessed March 17, 2022. 1-8. https://www.homelesshub.ca/sites/default/files/attachments/Finalized%20Community%20Plan%20-%20Waterloo.pdf
[1] “10-Year Housing and Homelessness Plan: Five Year Review”, Region of Waterloo Community Services, 2019, 5 https://www.regionofwaterloo.ca/en/living-here/resources/Documents/Housing/Five-Year-Review-of-the-Waterloo-Region-10-Year-Housing-and-Homelessness-Plan-access.pdf
[2] Olena Hankvisky, Intersectionality-Based Policy Analysis. (Vancouver, BC: Institute for Intersectionality Research and Policy, Simon Fraser University,2012), 33.
[3] Nicole Lampa, “Homelessness Nearly Triples in Waterloo Region Over the Past Three Years: Survey”, CTV News Kitchener, 2021. https://kitchener.ctvnews.ca/homelessness-nearly-triples-in-waterloo-region-over-past-three-years-survey-1.5650868
[4] Lampa
[5] Heather Senoran, “Chronic Homelessness in Waterloo Region Climbs 34% in 6 Months”, CTV News Kitchener, 2021. https://kitchener.ctvnews.ca/chronic-homelessness-in-waterloo-region-climbs-34-per-cent-in-6-months-1.5500523
[6] Senoran
[7] Senoran
[8] “10-Year Housing and Homelessness Plan: Five Year Review”, 16
[9] “Affordable Housing Strategy: Waterloo”, Engage Waterloo Region, Updated April 6, 2022, https://www.engagewr.ca/affordable-housing-waterloo
[10] Senoran
[11] “Canadian Definition Of Homelessness”, Canadian Observatory on Homelessness, Date Accessed: April 4, 2022, https://www.homelesshub.ca/sites/default/files/COHhomelessdefinition.pdf
[12] “Homeless Hub: Causes of Homelessness”, Homeless Hub, 2021, https://www.homelesshub.ca/about-homelessness/homelessness-101/causes-homelessness
[13] “Homeless Hub: Causes of Homelessness”
[14] “Homeless Hub: Causes of Homelessness”
[15] Hankvisky, 33-42
[16] Ibid
[17] Hankvisky, 40-41
[18] “10-Year Housing and Homelessness Plan: Five Year Review”, 5
[19] Ibid
[20] “10-Year Housing and Homelessness Plan: Five Year Review”, 6
[21] “10-Year Housing and Homelessness Plan: Five Year Review”, 7
[22] “10-Year Housing and Homelessness Plan: Five Year Review”, 9
[23] Ibid
[24] Ibid
[25] “Affordable Housing Strategy: Waterloo”
[26] “Affordable Housing Strategy: Waterloo”
[27] Ibid
[28] Ibid
[29] Ibid
[30] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 13
[31] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 6
[32] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 13
[33] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 6
[34] Ibid
[35] Ibid
[36] “Affordable Housing Strategy: Waterloo”
[37] Hankvisky, 40-41
[38] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 17-18
[39] Ibid
[40] “Reaching Home”, Waterloo Region Homeless Plan 2019-2024, Date Accessed March 17, 2022. https://www.homelesshub.ca/sites/default/files/attachments/Finalized%20Community%20Plan%20-%20Waterloo.pdf, 7
[41] “Homeless Hub: Lesbian, Gay, Bisexual, Transgender, Transsexual, Queer, Questioning and Two-Spirit (LGTBQ2S)”, Homeless Hub, 2021, https://www.homelesshub.ca/about-homelessness/population-specific/lesbian-gay-bisexual-transgender-transsexual-queer
[42] “Homeless Hub: Lesbian, Gay, Bisexual, Transgender, Transsexual, Queer, Questioning and Two-Spirit (LGTBQ2S)”
[43] “Homeless Hub: Racialized Communities”, Homeless Hub, 2021, https://www.homelesshub.ca/about-homelessness/population-specific/racialized-communities
[44] “Homeless Hub: Racialized Communities”
[45] Ibid
[46] Hala Ghonaim, “As Kitchener Encampment Grows, Region Says Enforcement’s a ‘Last Resort’”, CBC News, Updated March 24, 2022, https://www.cbc.ca/news/canada/kitchener-waterloo/encampment-kitchener-waterloo-region-action-1.6393871
[47] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 9
[48] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 8-10
[49] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 9
[50] Ibid
[51] Ibid
[52] Ibid
[53] “Reaching Home”, 6
[54] “Reaching Home”, 6
[55] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 8
[56] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 8
[57] Nick Falvo, “The Long-Term Impact of The COVID-19 Recession on Homelessness in Canada: What to Expect, What to Track, What to Do, Nick Falvo Consulting, December, 2020, 14, https://nickfalvo.ca/wp-content/uploads/2020/11/Falvo-Final-report-for-ESDC-FINAL-28nov2020.pdf
[58] Senoran
[59] Ghonaim
[60] Ibid
[61] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 13-14
[62] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 15
[63] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 15-16
[64] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 16
[65] Ibid
[66] Ibid
[67] “Homeless Hub: Lesbian, Gay, Bisexual, Transgender, Transsexual, Queer, Questioning and Two-Spirit (LGTBQ2S)”
[68] “Homeless Hub: Lesbian, Gay, Bisexual, Transgender, Transsexual, Queer, Questioning and Two-Spirit (LGTBQ2S)”
[69] Ibid
[70] Juha Kaakinen, “Lessons From Finland: Helping Homeless People Starts With Giving Them Homes”, The Guardian, September 14, 2016, https://www.theguardian.com/housing-network/2016/sep/14/lessons-from-finland-helping-homeless-housing-model-homes
[71] Kaakinen
[72] “10-Year Housing and Homelessness Plan: Five-Year Review.”, 22
[73] Kaakinen
[74] Kaakinen
[75] Kaakinen
[76] Ibid
[77] Ibid
[78] Ibid
[79] Ibid