In February 2009, the federal government introduced Bill C-10, the Budget Implementation Act, 2009. Part 10 of Bill C-10 enacted the Expenditure Restraint Act, which was proclaimed into force in March 2009. The ERA (and the 2009 federal budget generally) was intended to be a response to the global financial crisis that began in 2008. The ERA limits the federal government's expenditures in relation to wages. In particular, section 16 of the ERA fixes pay increases, notwithstanding any collective agreement, arbitral award or term and condition of employment, between 1.5% and 2.5% retroactively to the 2006-2007 fiscal year for most federal government employees. Published by Federated Press in Charter and Human Rights Litigation.