Chapter 3

Chapter 3

Household assessments

3.1        Submitters to the inquiry raised concerns with a range of aspects of the design, implementation and administration of the household assessments portion of the program, including:

Each of these issues is considered below.

Quality of assessor training

3.2        One of the major concerns expressed by assessors and other stakeholders in respect of the design and operation of the program was that the training received by assessors was not of a sufficiently high quality to enable them to perform high quality assessments. Evidence to the committee focussed on two aspects of assessor training:

Training courses and providers

3.3        A significant number of assessors informed the committee that they had received poor training which did not equip them to perform assessments. For example, Mr Mark Walker, an assessor from NSW, submitted that:

...the 4-day training course for this program was woefully inadequate, and the quality of training materials provided left a lot to be desired. For example, the large ring-binder provided to me contained materials photocopied or downloaded, was poorly organised and had neither a Table of Contents nor page numbers, rendering it virtually useless as a reference tool.[1]

3.4        Similarly, Dr Roger Severn, an assessor from WA, commented on the lax assessment standards to test the knowledge of newly trained assessors:

Assessment was in the form of an open book test where candidates answered questions with no time limit and full access to the printed material used in the course. Marking of each test was done by each candidate passing their test answers to another candidate who marked the paper based on their own perceptions and some key points made by the instructor as each question was answered. Unsurprisingly, all candidates met the registration criterion even though it was obvious that the knowledge level within the group varied significantly.

My point is that each candidate was not tested sufficiently for anyone to be satisfied that the knowledge required for accreditation had been achieved.[2]

3.5        These comments regarding the poor standard of assessor training were echoed by numerous other assessors in their submissions to the committee.[3]

3.6        However, not all assessors were dissatisfied with the quality of training provided under the program. For example Mr Mark Clayton, an assessor from South Australia, submitted that:

I had an advantage of a great deal of prior knowledge but still learnt plenty during the course.[4]

3.7        Similarly, another assessor submitted that:

For the record I would like to note that outside of my university degree Green Skills is the best training provider that I have ever worked with. I do not believe you will find a more committed, experienced, knowledgeable or passionate training provider in the country. Furthermore if every training provider operated with the same level of integrity as Green Skills does this programme would have been a huge success.[5]

3.8        Based on the evidence received by the committee, it is clear that the quality of assessor training differed markedly between training providers. In its submission, the Association of Building Sustainability Assessors (ABSA) explained that one of the reasons for this was that DEWHA:

...did not require the HSAS (Home Sustainability Assessment Scheme) training to be competency based or accredited as a short course, which would have brought the training within the Australian Government's Australian Quality Training Framework...rather, DEWHA signed off on the training as a non-accredited and content, rather than competency, based short course.[6]

3.9        ABSA also explained that DEWHA did not require that training facilities be Registered Training Organisations, which ABSA argued resulted in some of the training being of poor quality. In September 2009, ABSA itself implemented such a requirement as a pre-requisite for accreditation of assessors.[7]

3.10      Ms Amanda McClelland, the Chief Operating Officer of Fieldforce Services, a key participant in the program which trained and employed over 400 assessors, argued that the quality of assessor training was 'probably the one single big failing' of the Green Loans Program.[8] Ms McClelland stated that:

It seemed to be that if you were an RTO [Registered Training Organisation] you could go and train anyone. There was no governance over who trained, what they trained and the quality of that training. There was no exam. Basically, I could be an RTO who trained in data entry and, if I went and developed a two-day program, I could go and get 500 immigrant taxi drivers—which was apparently one of the things that occurred—and all of a sudden I have trained 500 assessors, who would be accredited to do energy assessments.[9]

3.11      Both ABSA and Fieldforce recommended to DEWHA that the standard of training needed to be improved, and suggested that the existing Certificate IV level program in Victoria would provide a suitable basis for training.[10] Fieldforce made this recommendation following conducting a pilot training course as early as November 2008.[11]

3.12      However, the committee was informed that this suggestion was not implemented by government because of pressures to roll out the program quickly:

The concern at the time was...to have the program up and running and to have people who were going to be able to use the assessment tool that the government had commissioned to provide sustainability assessments to households. I think the decision was taken at the time that having a more extensive training schedule or training requirement would take more time.[12]

3.13      ABSA indicated to the committee that the process for nationally endorsing the Victorian Certificate IV course has been slow because 'it is a process of going through the state governments'.[13] Further, Ms Carmichael, CEO of ABSA indicated that:

[I]t is a process that cannot be cut short. I did hear Senator Wong had asked whether that could be sped up, and it is not a process that can be.[14]

3.14      Furthermore, the government apparently had doubts as to whether the Victorian course was appropriate. In response to a question asked at Senate Estimates hearings in February 2010, DCCEE stated that:

The Victorian Course in Home Sustainability Assessment has a broader approach to sustainability issues compared to the Professional Home Sustainability Assessment course, as it incorporates ecological footprints, waste management, garden and environs, transportation and general green living aspects. It is the Department’s view that requiring assessors to undertake the broader topics covered by the Victorian course may not necessarily improve the skill sets of the Green Loans assessors as they focus only on the energy and water efficiency performance of houses.[15]

3.15      Despite the decision not to require assessors to undergo a formal, nationally endorsed training program—either because of timing, the suitability of the course, or a combination of the two—a number assessors who participated in the program had an understanding that the government intended to upgrade their qualifications to Certificate IV level at some stage.[16] The national accreditation body, ABSA, which was involved in the development of the program from an early stage, has the same apprehension with respect to DEWHA's intention to fund an upgrade in assessor training to Certificate IV.[17]

3.16      When questioned at the committee's hearing on 29 June 2010 about why the assessor community had a widespread understanding that the government would pay to upgrade assessor qualifications, Mr Malcolm Thompson, Deputy Secretary, DCCEE, informed the committee:

[T]hat was never government policy and so there has never been a position that the Australian government would pay for an upgrade of training to cert IV for assessors.[18]

3.17      In response to a question taken on notice on the matter, DCCEE provided an unhelpful answer, referring the committee to its response to the Hawke[19] and Faulkner[20] reports in which DCCEE simply stated that 'action is currently underway to investigate potential breaches identified in this report'.[21]

3.18      However, DCCEE provided further information on this matter to the Australian National Audit Office (ANAO). In its performance audit of the Green Loans Program, the ANAO confirmed that email advice was sent to an assessor in July 2009 by a DEWHA officer 'indicating that when an accredited training course is available, assessors will be offered the necessary additional training at no cost'.[22]

3.19      In response to questioning about how the government proposes to rectify the misinformation given by departmental officers to assessors and ABSA on this matter, DCCEE informed the committee that 'action is currently underway to investigate potential breaches identified in the Faulkner report'.[23] DCCEE stated that it would:

...conduct any necessary investigations to follow up actions where further potential breaches of the APS Code of Conduct, the Financial Management and Accountability Act and the Criminal Code are identified.[24]

Pre-requisites for assessor training

3.20      Many assessors, even those satisfied with the quality of training provided to them, commented that the training was inadequate without prior knowledge and/or experience in a related field. For example, Mr Jeff Wormald, an assessor from NSW, commented:

While the HSA training course that I attended was small in number of attendees and well delivered with a very knowledgeable trainer and quite a lot of extremely useful input from the course participants, I would be at a complete loss if this were to be my only source of expertise to draw upon for the purposes of conducting an assessment. The real qualifications necessary for conducting an accurate and useful Home Sustainability Assessment may not be extremely high, but some level of proficiency in [building design or thermal performance, with energy efficiency, clean energy generation or home sustainability] is an essential if this or similar types of programmes are to have any real relevance to the house holder for use as a real and effective tool for energy efficiency and sustainability, although the importance of people skills must never be underestimated as this is after all an educational process.[25]

3.21      A number of submitters and witnesses indicated that at the beginning of the program, it was understood that assessors would be required to have pre-requisite experience and/or knowledge in addition to completing assessor training.[26] However, the omission of such a pre-requisite was argued by some to have undermined the quality of assessors. For example, Mr Mark Walker, an assessor from NSW, submitted:

...the removal of the initial restriction on prior qualifications allowed for an influx of under-qualified, uninterested, self-focused individuals whose only real motivation was accumulating capital as quickly as humanly possible. The lack of real regulation and lack of auditing of so-called training organisations, made a farce of the accreditation process.[27]

3.22      Similarly, Ms Leanne McIntosh, a GLACO assessor, stated:

I have a uni degree and three trade qualifications. I expected, when I went to training, to have a roomful of people with those sorts of qualifications. There were nurses. There were insulation installers who just wanted to tack on the $200 and be in and out within five minutes. They were open about what they were doing at the training course. To me, it should have been enforced that you had an adequate background to be able to advise people. That was definitely one of the faults, no doubt at all.[28]

3.23      ABSA explained that requiring assessors to have experience in the building industry was 'mooted' at the initial stages of developing the program as originally:

...it was considered that the tool to do Green Loans was going to be similar to what is called the NatHERS [Nationwide House Energy Rating Scheme] tool, which is all about building fabric.[29]

3.24      However, as the program and assessment tool developed, Ms Carmichael explained that Green Loans was quite different from NatHERS:

...in that you actually wanted people who would go into households and engage intelligently and sensitively with householders. So just setting a whole lot of building prerequisites became less and less appropriate as the Green Loans Program and the tool rolled out.[30]

Committee comment

3.25       Based on the evidence received by the committee, it is clear that there were serious problems with the quality and regulation of assessor training. While some assessors no doubt received excellent training by qualified and experienced training providers, the fact that assessor training was almost entirely unregulated meant that the government has no assurances as to the quality and knowledge of assessors trained under the Green Loans Program.

3.26      The committee is of the view that the lack of regulation or quality standards in relation to assessor training was largely the result of pressure on DEWHA to roll out the program within tight deadlines.[31] Had DEWHA been given the opportunity to wait until a national Certificate IV level assessor training program had been developed and accredited, these more rigorous training standards would have discouraged some of the 'sharks and shonks'[32] from taking advantage of the program.

3.27      Furthermore, had the government allowed more time for the roll-out of the program, it would have been clearer what skills would be required of assessors. This would have enabled the department and other stakeholders to better manage the expectations of assessors. The committee makes recommendations about the necessary standards of assessor training under the Green Start Program in chapter 7, in order to prevent the failings of the Green Loans Program from re-occurring.

Number of accredited assessors

3.28      A common issue raised by many submitters was the number of assessors accredited under the program. Initially, Minister Garrett indicated that there would be 1000 assessors 'ready to begin work' from 1 July 2009.[33] Some assessors submitted that this figure of 1000 assessors was in fact expressed at the start of the program to be an upper limit.[34] Other assessors claim to have had an understanding, based on information from either their trainer, or the government's website, that there would be a cap of 1500, 2000 or 3000 assessors.[35]

3.29      In evidence to the committee, Mr Malcolm Thompson, Deputy Secretary, DCCEE stated that:

[T]here was no expected target of 1,000... My recollection...is that Minister Garrett had a press release that indicated we had up to 1,000 assessors ready to go in the early period just prior to the launch of the program. There was never a statement that I am aware of from the minister or from the government that we were aiming for a target of 1,000 assessors.[36]

3.30      However, assessors claim to have been induced into joining the program on the basis of their understanding that there would be a cap on assessors. For example, Mr David Cumming, an assessor from NSW, submitted:

From a personal perspective, I funded my retraining to become a Home Sustainability Assessor on the strength of the representations made on the Green Loans website, and in the official Green Loans Style Guide... Had I known that ABSA and DEWHA were not managing the numbers of registered HSA’s I certainly would not have committed myself to the program. I think it is fair to say that many people completing their accreditation saw this as a foothold in an ongoing (though term-limited) market with a limited supply of service providers.[37]

3.31      Organisations involved in the program, including Fieldforce, which was involved in the program from the outset and assisted in its development, were under a similar apprehension about the number of assessors that would be trained:

When the program first started, the indication—given, I believe, to everybody—was that there was going to be no more than 1,000 assessors in the program.[38]

3.32      When pressed on where this belief came from, Ms McClelland, Fieldforce's Chief Operating Officer stated that it came from 'conversations with the department and ABSA'.[39]

3.33      In its submission, ABSA stated that:

At the time of DEWHA's acceptance of ABSA's application to become an Assessor Accrediting Organisation, DEWHA estimated that the program would attract approximately 800 assessors.[40]

3.34      When questioned, Ms Alison Carmichael, Chief Executive Officer of ABSA, informed the committee that ABSA was never informed by DEWHA of the basis for the figure.[41]

3.35      Ms Carmichael further informed the committee that in the initial stages of the program:

The feeling at the time was that nobody had any idea whether there would be any interest in this program. In fact the sense from the department was the fear that they would not get enough people. It was kept low and they were very hopeful that there would be 800 to 1,000 at the end of the first year.[42]

3.36      In response to why there was a wide-spread understanding amongst stakeholders that there would be 1,000 assessors, Mr Malcolm Thompson, Deputy Secretary, DCCEE stated:

...it was considered at the time that 1,000 assessors would be the minimum that the government would need to deliver this program and that is why 1,000 became significant in that sense...

There may have been discussions with departmental officials. I know some stakeholders have made reference to that. We, in our search of our records, cannot find definitive evidence of that. I am not saying that it is not the case, but if it was the case then, as far as I am aware, it was not government policy.[43]

3.37      Yet, the independent inquiry into procurement processes and contractual arrangements under the program by Ms Patricia Faulker, found that DEWHA had briefed Minister Garrett in December 2008 on various options for delivery of assessment services under the program, and in that brief indicated that 'up to 2,000 assessors were envisaged'.[44]

3.38      The difference between the figure given to the Minister in December 2008 (2000) and that given to ABSA in February 2009 (800) has not been explained by the government. While DEWHA clearly gave thought to the number of assessors that were required or likely to become involved in the program, the government has not been able to explain what these estimates were based on. Yet it is evident that different estimates were given to different stakeholders at different times, whether officially or unofficially. These estimates naturally affected the decisions of assessors and organisations to become involved with the program and expend money in order to participate.

3.39      It is also clear that there was no thought given early on in the program to the risk that many more than the projected 800 or 1000 or 2000 assessors would train and apply for contracts under the program. ABSA submitted that:

By August 2009, ABSA was aware of 2,000 individuals who had undertaken HSAS training seeking accreditation as HSAS assessors. ABSA repeatedly raised its concerns with DEWHA from August 2009 regarding the number of assessors relative to the number of funded assessments over the life of the Green Loans program and the number of assessors originally estimated by DEWHA.[45]

3.40      In response to ABSA's concerns:

DEWHA made it clear to ABSA that it did not have a view about how many assessors should be trained and accredited.[46]

3.41      In evidence to the committee, officers from DCCEE commented:

It certainly was the position that the government and the department considered that this was a matter for ABSA, as the accrediting agency, to settle. We were concerned to ensure that there were enough assessors available to deliver the program, not only as to the total number of assessments in a quantity sense but also to give a reasonable geographic spread of assessments across the country.[47]

3.42      ABSA then 'decided to take the matter into its own hands' and in early November 2009 advised DEWHA that it proposed to only accredit those who submitted their application by 24 December 2009. ABSA submitted that this decision led to ABSA receiving legal threats from training providers and potential applicants. As a consequence ABSA pushed back the date at which applications closed to 21 January 2010 for those who completed training prior to 24 December 2009.[48]

3.43      ABSA projected that this moratorium would result in there being a total of 4500 registered assessors (3000 who had already registered, plus 1500 registering between its announcement and 21 January 2010). However, instead of receiving 1500 additional applications during December and January, ABSA received 6500 applications for accreditation prior to 21 January 2010 (making a total of 9500 assessors).[49]

3.44      The almost twelve-fold difference between the number of assessors initially projected by DEWHA versus the actual number of accredited assessors led to a much greater number of assessments being performed in a shorter space of time than anticipated. ABSA submitted that of the 360 000 assessments that were intended to be funded over the 4-year life of the program, 288 170 of these had been booked by 22 January 2010.[50] This equates to more than 80 per cent of the entire program's allocated assessments which were conducted in less than 15 per cent of the program's lifespan.

3.45      A number of submitters blamed the blow-out in assessor numbers on ABSA and/or assessor training organisations. For example, Dr Roger Severn, an assessor from WA, submitted that:

Accreditation authority has been vested in a private organisation. This has meant that to be accredited an individual must become a member of that organisation paying significant fees for the privilege. In order to protect the income earning capacity of their members it is now argued that accreditation should be limited. It is true because of the enthusiasm of the training contractors far too many people were encouraged to enrol in training with unrealistic expectations of income earning.[51]

3.46      Mr Mark Walker, an assessor from NSW, argued that the oversupply resulted from:

...less scrupulous and (comparatively) unregulated training organisations had no vested interest in limiting the number of potential assessors trained and so, lacking appropriate advice or regulation from Government, attracted as many potential assessors as possible to their training courses.[52]

3.47      ABSA responded to these arguments by noting:

We wanted to shut off in August [2009]. In the end, when we did close off, we absolutely did not want any more.[53]

3.48      According to the ANAO, a draft report by PricewaterhouseCoopers, which the government has not yet publicly released, on ABSA's compliance with the protocol for the Assessor Accrediting Organisation under the program found that while ABSA had not been fully compliant with certain aspects of the protocol, '...areas of non-compliance were primarily due to factors beyond ABSA's control'.[54] The PricewaterhouseCoopers report is subject to an order for the production of documents in the Senate.[55]

3.49      Ms Amanda McClelland, Chief Operating Officer, Fieldforce, attributed the problem to the lack of clarity between the responsibilities of ABSA and DEWHA:

The line of responsibility between ABSA and DEWHA was sometimes very blurred. I would talk to ABSA and they would say that it was not their responsibility to cap the number of assessors but DEWHA's responsibility. Then DEWHA would say that ABSA is the accrediting body. I would have assumed that they would have ironed that out during program design.[56]

3.50      The Department of Climate Change and Energy Efficiency submitted that:

On 19 February 2010, the Government announced a cap of 5,000 on the number of assessors participating in the program. This will ensure a sustainable level of assessment activity for contracted assessors.[57]

3.51      DCCEE's submission suggests that this cap was possible because, of the approximately 9500 assessors who had applied to ABSA for accreditation, only approximately 4000 had been contracted to the government to work as assessors at that stage.[58]

3.52      The government gave no indication as to how it would decide which of those assessors accredited by ABSA but not yet contracted to the government would be formally contracted, and which would not.  Minister Wong suspended the issuing of new contracts to assessors in March 2010.  Mr Malcolm Thompson, Deputy Secretary, DCCEE informed the committee that Minister Wong was not going to make a decision regarding the issuing of further contracts until the PricewaterhouseCoopers audit of ABSA's accreditation processes and the Faulkner review of contracting arrangements under the Green Loans Program had been considered.[59]

3.53      The committee notes that the Faulkner review was released on 8 July 2010, simultaneously with Minister Wong's announcement that the Green Loans Program would be phased out and transition to a new Green Start Program (discussed in chapter 7). Yet, in a media release that day, the Minister announced that the suspension on new assessor contracts 'will continue'.[60] The government has made it clear that some Green Loans assessors will likely be successful in obtaining grants under the new program, and has released limited details about a retrenchment package available to those assessors not chosen to participate in Green Start. However questions remain about the status of uncontracted assessors. These issues are discussed in chapter 7.  

Committee comment

3.54      The huge blow-out in assessor numbers that occurred under the Green Loans Program is arguably one of its most significant failings. The demand that that blow-out created in household assessment bookings; the resulting numbers of assessment reports; and the huge number of invoices that needed to be processed by the departments were all significant flow on effects. DEWHA's management systems were simply not designed to handle this huge number of assessors and the resulting deluge of assessments. The combination of these factors led to the program's funding being exhausted well before its planned end date, which has left thousands of assessors without the income they had anticipated from the program.

3.55      DCCEE has stated that the government did not, at any stage, have an official policy on how many assessors should be contracted. Yet it is clear that various projections of assessor numbers were given by DEWHA officers to individuals and organisations during the course of the program. On the strength of these representations, individuals and organisations invested substantial resources into the program, and made business decisions on the basis of these projections. It is the committee's firm view that members of the public should be able to rely on information given to them by government.

3.56      Furthermore, the committee finds it unacceptable that the federal government would embark on a program of this size and scope without having firm projections of the number of assessors likely to be involved and clear agreements with partner organisations as to whose responsibility it was to ensure that sustainable numbers were not exceeded. If the government was not going to monitor assessor numbers, it should have made it clear to ABSA that this was part of their role, and given ABSA ownership of any related aspects of the program.

3.57      The fact that neither ABSA nor DEWHA considered themselves responsible for assessor numbers is another indication of the lack of planning that went into the Green Loans Program.

3.58      The arrangements put in place once the government became aware of this enormous problem—of capping the number of contracts at 5000 and suspending the issue of new contracts—are simply unacceptable from the point of view of assessors who trained under the program expecting to be contracted to the government under the program. This decision has left over 5000 Australians in limbo since February 2010. The committee makes various recommendations as to how similar problems caused by a lack of communication and planning may be avoided under the Green Start Program in chapter 7.

Accrediting and contracting assessors

3.59      A large number of assessors who submitted to the inquiry complained about the time it took both ABSA and DEWHA to process paperwork relating to accreditation and contracting respectively.

3.60      Some assessors claim to have waited for six months or more after undertaking training and submitting the relevant documentation, to obtain the accreditation and contract, without which they were not able to perform assessments under the program. For example, Mr Mohamed Hawli, an assessor, submitted:

Upon submitting my application to ABSA, it took approximately 10 weeks to receive the [Home Sustainability Assessor] numbers and cards. After a long and drawn out effort to obtain the [Home Sustainability Assessor] numbers I promptly sent off my contract to the Green Loans Program. I sent off the contract in the first week in February [2010] and have been waiting since for some indication but nothing has come through.[61]

3.61      A list of the periods that various assessors claim to have had to wait for the government to approve their paperwork is at Appendix 3.

3.62      Like Mr Hawli, many other assessors complained of not yet having been contracted to the government, despite being accredited by ABSA and having paid the requisite training, accreditation and insurance fees. Based on DCCEE and ABSA's submissions, there are between 5300 and 5500 assessors in this position.[62]

3.63      Based on the submissions received by the committee, the average assessor would have spent between $2000 and $3000 on training, insurance, police checks, ABSA fees and other costs, prior to being contracted with DEWHA and being allowed to begin performing assessments under the program.[63]

Committee comment

3.64      As discussed above, the length of time it took for DEWHA to approve assessors' contracts was likely to have been a flow-on effect of the lack of projections and controls on assessor numbers.

3.65      It also reflects poor resourcing decisions by the government. In order for an agency usually focussed on policy to undertake a project of the size and complexity of Green Loans, it is obvious that substantial additional resources would be required. It appears that not nearly enough resources were provided to the team managing the project within DEWHA. Indeed, this was a finding of both the Faulkner review and the review of the program by Resolution Consulting.[64]

3.66      In chapter 7, the committee makes recommendations about resourcing and planning of the Green Start Program, in order to prevent the failings of the Green Loans Program from re-occurring.

Quality of assessments

3.67      Another significant concern, raised by both assessors and participating householders, was the quality of home sustainability assessments. Problems with the quality of assessments are argued to have arisen as a result of the:

Design of assessment tool

3.68      A number of assessors submitted that the assessment tool was flawed, and did not account for climate variations across the country and various other important factors in the environmental performance of a house. Ms Enga Lockey, an assessor from Victoria submitted that:

The assessment tool has so many flaws as to make any resultant information supplied to the homeowner worthless.[65]

3.69      Similarly, Mr Sam Tuck, another assessor from Victoria, submitted:

The assessment books were so irrelevant to the information required by the online tool they were useless. A massive waste of resources...

The biggest reductions in energy use in homes I have assessed would be gained from implementing draft proofing and insulation effectively – but this is very limited in the scope of the report. There is no priority given to measures to improve the householder’s emissions in the report, which is our area of expertise.[66]

3.70      Mr Darryl Smith, a participating householder, analysed the report he received under the program and found 'a significant number of issues' with it. These 'issues' include:

3.71      Assessors argued that the time it took to complete the report did not justify the value of the end product. For example, Mr Michael Lewin, an assessor from Victoria, submitted:

The software tool is simplistic and perhaps has to be. Most receivers of the report have found it hard to relate to and don’t see it as being worth investing several hours to get.[73]

3.72      Similarly, Mr Sam Tuck, another assessor from Victoria, submitted:

The data entry for a typical household took over an hour (much much longer initially!). Repetition, data loss etc. wasted so much of our time. The fixes took months, and IT savvy colleagues commented on the archaic manner the online tool operated.[74]

3.73      Assessors reported that the poor quality of reports reflected poorly on the ability of assessors and on the program generally:

Some assessment reports were so deeply and obviously flawed that they inevitably caused the householder to doubt the capability of the assessor. I was embarrassed by some householder's disappointment in the reports. Many held me responsible for the inaccurate statements/recommendations they received. As such they would not recommend my services, or the program, to others. My reputation in my local community, for both home assessments and any future business, has been negatively affected by DEWHA's flawed assessment software and slow/non-delivery of reports.[75]

3.74      The media reported on one extreme example of the failings of the assessment tool, and the lack of even basic audit of it, involving a Brisbane man being told he could save more than $31 million per year by installing a new air conditioner and ceiling fans, when his quarterly power bills only totalled $195 and he already had ceiling fans in most rooms.[76]

3.75      The software for the assessment tool was developed by RMIT, under a contract with DEWHA. The Faulkner review of procurement practices and contractual arrangements under the program found serious flaws with the awarding and managing of contracts under the program.[77] The findings of the Faulkner review are discussed in chapter 6.

3.76      A particular concern was that the tool did not take account of air leakage. DCCEE advised the committee that:

...the tool has always included both questions relating to the level of air leakage in the dwelling and recommendations to improve this aspect of the dwelling as is appropriate...

Air leakage has always been considered as part of the building thermal load calculation (heating and cooling), and this module has been subject to upgrades during delivery of the program.[78]

3.77      The committee was also made aware of potential issues related to the loadings given to various technologies in the assessment tool, and how preferences for various technologies were made in the design of the tool. The committee questioned DCCEE about whether any persons or organisations had corresponded with either the department or RMIT about the loadings to be given to various technologies by the tool, and was informed:

RMIT has advised that all technologies included (or not included) in the assessment tool have been based on the available research in the field of residential building energy use.[79]

3.78      The review of the program by Resolution Consulting Services found that:

The assessment software appears to be one of the key failures of the system in two ways. Firstly, the development of the software appears to have breached a number of procurement processes within the Department. Secondly it did not work to a standard that could be expected and this was not detected until after the trial was completed and the program had gone live.[80]

3.79      The ANAO's performance audit of the program found that a key reason for the problems experienced with the assessment tool was the fact that it was developed so late in the program-development phase. RMIT was only engaged three months prior to the start date for the pilot program, and was asked to develop an online component for the assessment tool only three weeks before the 'go-live' date for the entire program.[81] Accordingly, the full tool was not available for the pilot program and there was no testing phase for the assessment tool which would have enabled modifications, which are standard on a software program of this scale and type, to be made.[82]

Committee comment

3.80      Based on the evidence from householders, assessors and the reviews conducted by Resolution Consulting Services and Ms Patricia Faulkner, it appears to the committee that the tool was inappropriate, inadequate and highly faulty. The key reason for the problems experienced with the assessment tool, however, appears to be the fact that the developer was not given sufficient time to develop and test it. This resulted from DEWHA's tardiness in contracting the developer, as well as the speed at which the program was implemented.

3.81      The committee is disappointed that the government wasted money on the development and implementation of an assessment tool that was not able to give constructive feedback about how householders might save energy. In the committee's view, the provision of sub-standard assessments has undermined the effectiveness of the Green Loans Program and nullified any benefit that it may have had.

3.82      The committee makes a recommendation about the assessment tool to be used in Green Start in chapter 7, in order to prevent failings that occurred in relation to the quality of assessments in Green Loans from being repeated.

Speed of assessments

3.83      A further issue with the quality of assessments under the program related to the time taken for assessments to be conducted. DEWHA paid assessors $200 per assessment, and it appears from the submissions that this figure was based on each assessment, including travel to and from the assessment by the assessor, taking a total of two hours.[83] The Sustainability Advice Team, an ACT company which has been conducting energy audits and assessments of households since 2004, submitted that:

The two hour time allowed for the assessment and travel is insufficient to do a competent and complete job of collecting and entering the very large amount of data required by the assessment tool, except for very small houses.[84]

3.84      Under the program, assessors were able to contract individually to DEWHA, or conduct assessments as a nominee of their employer. The second arrangement seems to have typically involved a company arranging and booking assessments for assessors, in return for a portion of the assessment fee. For example, Fieldforce entered into arrangements with assessors whereby it marketed and booked assessments on their behalf in return for $100 of the $200 assessment payment.[85]

3.85      Mr Mark Walker, an assessor from NSW, submitted that assessors engaged under these arrangements were routinely required to perform up to five assessments per day.[86] Mr Walker submits that the short timeframe this left for assessments resulted in assessors being unable to perform thorough, high quality assessments:

It is widely known that many organisations involved actively encouraged their employed assessors to perform in excess of 5 assessments per day, in as little time as it was possible to do so, and claims of half hour assessments and ‘ghost’ assessments are common.[87]

3.86      The evidence received from Mr Chorazy, a Fieldforce assessor, confirms that:

...the Assessment scheme provided the opportunity for 5 assessments per day per assessor and Fieldforce contractors were achieving these levels.[88]

3.87      Energy Makeovers submitted that it was not only companies encouraging assessors to perform as many assessments as possible at the expense of quality, but also individual assessors:

Further, there is an opportunity for unscrupulous assessors seeking to minimise time on site (to reduce costs) to overly rely on “default settings” at the expense of accuracy of the assessment outcome.[89]

3.88      As part of its performance audit of the program, the ANAO surveyed householders who received assessments under the program. Almost half of those who responded indicated that the assessment took less than an hour.[90] Even more concerning was the small proportion of householders surveyed who stated that they did not receive assessments under the program at all.[91] Issues related to misuse of the program are discussed in further detail below.

3.89      Submitters argued that these practices impacted on the quality of assessments and the integrity of the program.[92]

3.90      A number of submitters made the point that many of these issues with the quality of assessments may have been prevented if there had been a system for auditing assessors.[93]

3.91      In its submission, DCCEE informed the committee that it has been directed by Minister Wong, who assumed responsibility for the program on 8 March 2010, to provide her with 'options to assure and improve the professional standard of assessors contracted to the program'.[94]

3.92      However, the Minister's media release of 8 July 2010, announcing that the Green Loans Program will be phased out but that assessments will continue in the meantime, did not include any details of how these issues will be addressed while assessments continue to be performed.[95]

Committee comment

3.93      In the committee's view, the issues relating to the quality of assessments performed under the Green Loans Program would have been prevented had basic processes been followed and implemented from the outset.

3.94      Like a number of the other problems with the program discussed above, had the government not placed so much pressure on DEWHA to roll-out the program by July 2009, RMIT would have been given more time to develop and test the assessment tool and problems with the tool could have been ironed out prior to the system being rolled out nationally.

3.95      The committee further considers that had DEWHA followed the proper legal procurement procedures, it is possible that some of the issues with the assessment tool may also have been avoided.

3.96      With respect to issues related to individual assessors performing substandard assessments, the committee's view is that this issue would have been avoided had adequate training and audit systems been in place.[96] In addition to quality training, the government needed to have a system in place whereby assessors were audited in order to ensure their quality. While the government repeatedly promised that such an audit program would be put in place, to date, more than 12 months after the program's commencement, and seemingly right before its demise, no such program has eventuated. The committee finds this unacceptable.

3.97      The committee makes a recommendation in chapter 7 on the need to establish audit systems from the outset of the Green Start Program in order to ensure the quality of assessments delivered under that program.

Problems with the booking system

3.98      Household assessments could be booked either by the assessor (or an organisation acting on their behalf) or by a householder requesting an assessment. Bookings were made through an outsourced call centre which was managed by the Department.[97]

3.99      It was initially intended that bookings would be made online, however the online booking portal was not developed until December 2009 to January 2010, immediately before the demise of the program, at a cost of over $1.3 million.[98] Instead, the telephone booking system developed for the Household Insulation Program was used throughout the Green Loans Program.

3.100         Almost every assessor who submitted to the inquiry complained about the booking system and call centre. Predominantly, assessors were angered by the amount of time it took them to book assessments while waiting on hold. Assessors also noted flaws with other aspects of the booking system including its accuracy and the lack of an online booking portal.

3.101         Assessors submitted that they waited on hold for up to three hours in order to book assessments during December 2009 and January 2010.[99] The Sustainability Advice Team, based in the ACT, submitted that:

Phoning to book assessments was extremely difficult. At the worst, hold times were well over an hour. Between December [2009] and the end of February [2010] we made a total of 201 calls, many very lengthy, to the 1800 Green Loans line in order to try and register our assessments, from which we eventually booked about 30 assessments. From the 9th of February to the 9th of March [2010] we made 136 calls to undertake a total of 10 assessments.[100]

3.102         The ANAO's performance audit contains details of the performance of the call centre over the life of the program.[101] At its peak, in January to February 2010:

3.103         Mr Tom Livanos, an assessor from NSW, submitted that when he called the booking centre:

I was greeted with a message that the call centre had reached its maximum capacity, that I should call again at another time and the call then proceeded to an engaged tone. This is an event which is without precedent in my life. It occurred repeatedly. When I did get through, it took over 90 minutes to speak to a call centre consultant.[103]

3.104         Ms Leanne McIntosh, a GLACO assessor, gave evidence that the long delays experienced by assessors with the booking system were a key reason for assessors contracting with marketing companies, including GLACO, which booked assessments on their behalf. Ms McIntosh stated:

Seriously, three-quarters of the week was literally trying to get the AN (Assessment Number) numbers and hit redial on the phone endlessly and wait hours in the phone queue. If you were with GLACO they did that, so you could be out assessing and actually working as opposed to sitting on the phone with a sore finger.[104]

3.105         Mr David Cumming, Principal Consultant from Sustainable Evolution, an assessor from NSW, argued that the booking system was 'emblematic of the inefficiency of the Green Loans Program execution as a whole'.[105] Mr Cumming explained:

In the age of the internet, online data, validation and analytics, the Green Loans Booking Process was bizarre. No commercial enterprise would force their field agents to phone a number in order to dictate basic booking information to an operator to in-turn transcribe into a booking system.[106]

3.106         In addition to long delays, assessors also complained about various inaccuracies within the booking system:

Inadequate operation of the Department’s booking system meant that on a number of occasions assessors did not receive email alerts of an assessment booked by the system until the day of the booking or even, on some occasions, after the assessment was supposed to be conducted. This made the business delivering the assessments, and the individual assessor, look very poor.[107]

3.107         Mr Cumming outlined various inherent problems with the booking system, being that it was:

Slow – dictating, transcribing, correcting basic data input;

Error-prone – as operators inevitably made transcription errors, which could subsequently impact programming invoicing and validation procedures;

Costly – involving call costs many time more expensive than online alternatives, and requiring the employment of a dedicated operator to enter information that the caller could have so readily entered themselves via an online portal;

Susceptible to Overloading – the obvious possibility of hundreds if not thousands of assessors making multiple attempts to phone through and then tying-up available lines while transcribing booking information.[108]

3.108         Assessors involved since the beginning of the program informed the committee that at the start the booking system 'seemed to be working well', and that it was only the changes made in late 2009 plus the increasing number of assessors using the system that led to its problems.[109]

3.109         However, the committee received evidence that certain actions by DEWHA compounded the problems. For example, DEWHA announced as late as 24 December that the booking line would be closed over the Christmas and New Year's period. Many assessors were angry about this late notice. For example, Ms Larissa Nicholls, an assessor from Victoria submitted:

On Christmas Eve assessors were given less than 2 hours by DEWHA that the Green Loans booking line would be closed for an extended period. Access to the assessor's online assessment bookings calendar had also been removed. Assessors were required to lodge bookings with the call centre before performing assessments so this unexpected closure prevented booking and working for over 3 weeks. When the call centre reopened it was inundated. It took several hours, or several days, of dialling and waiting on hold to book a maximum of 5 assessments. Bookings were lost as householders were unimpressed by the unexplainable delays.[110]

3.110         Apparently, in response to complaints about the booking system being shut down for Christmas, DEWHA informed assessors that they should undertake assessments and obtain booking numbers afterwards via email.[111] However, Mr Walker, an assessor from NSW informed the committee that:

These “January email bookings” have largely been neither recognised, nor provided with booking numbers, much less paid, leaving many assessors seriously out of pocket for work they performed – with the best intentions and with the Department’s tacit approval – and yet no solution has been offered to rectify this gross oversight.[112]

3.111         With respect to these January 2010 email bookings, DCCEE informed the committee that 'significant progress' has been made in processing them, and the 'majority of valid assessment bookings received in the period 14 January 2010 to 1 February 2010, when the temporary email booking system was in place, have been processed'.[113]

3.112         Assessors submitted that they had great difficulty contacting DEWHA to discuss and resolve these problems with the booking system.[114] For example, Mr Trevor McTaggart, the director of GLACO, an organisation which booked assessments on behalf of assessors, submitted:

We could not connect with a Manager in the [call centre]. They diverted their phones, redirected their emails or didn't bother to respond. Complaints to the then Ministers [sic] Office bought no reply. The Management were clearly hiding. They left the 'dirty business' to their staff.[115]

3.113         A number of assessors submitted that at the outset of the program, assessors were led to believe that an online booking system would be implemented.[116] However, this online booking system never eventuated, at least for individual assessors.

3.114         Ms Anne Leo, Acting Assistant Secretary, DCCEE, informed the committee:

I understand that the IT module to allow [online bookings] to happen was developed, but it was ready around the same time that problems started to emerge with the bookings over January and February [2010]. Part of the problem at that time—what was slowing the performance of the booking system—was releasing some of the modules. I was concerned that it would further affect the performance of that system. Our focus at the time was on trying to make sure we had a system whereby all assessors could make bookings quickly and efficiently.[117]

Arrangements with Fieldforce

3.115         It has been alleged, both by assessors in their submissions,[118] as well as in media reports,[119] that one company, Fieldforce, was given priority access to the booking system through an online portal.

3.116         Reports of Fieldforce's 'special treatment' angered assessors who were forced to wait for hours on the phone to book assessments. For example, Mr Simon Walsh, an assessor from NSW, submitted that:

Field Force being given a direct link into the Department’s computer systems is unthinkable and highly inappropriate. While a small business like ours was forced to endure call-waiting times in excess of 60 mins, Field Force were given special treatment and eventually siphoned away a huge amount of the program’s allocated funds. The Department’s preferential treatment of Field Force was unethical, highly inappropriate and I suspect it is illegal according to laws that bind Federal Government Departments.[120]

3.117         DCCEE did not respond to this allegation in its submission. However, on 3 February 2010, Senator the Hon Joe Ludwig, then Special Minister of State and Cabinet Secretary, informed the Senate that:

Fieldforce is the single largest operator under the Green Loans Program, and to accommodate this, they make bulk bookings which are processed by the Department once a week.

These bookings are subject to a weekly limit, in order to ensure there is adequate work for all assessors.

Jobs are available to all assessors, whether they are individuals or part of a company.

Over half the assessors contracted to the Department (59 per cent) choose to operate as sole traders, and are provided with bookings generated via the call centre. Work is allocated equitably.[121]

3.118         Mr Roland Chorazy, an assessor who participated in the program through Fieldforce, outlined the benefits of working with Fieldforce. He stated that:

Press reports indicate that the committee has had many complaints from individual assessors of ‘unfair ‘competition from Fieldforce which has been very effective in this market. I seek to give some balance to the committee’s evidence by presenting the experience of a Fieldforce assessor...

Fieldforce has the great advantage of a professional marketing team and a large database freeing me from cold calling and selling. It is no surprise to me that many independents are having difficulty.[122]

3.119         In its evidence to the committee, Fieldforce explained how they had come to have online access to DEWHA's booking system. Ms McClelland, Chief Operating Officer, Fieldforce, informed the committee that Fieldforce had repeatedly raised concerns about the booking system during August and September 2009:

In September I rang the department and asked them for a meeting. I travelled to Canberra and provided them with a large document of issues with the program... [Officers from the department] suggested that we start to work with them on alternative ways to redesign some of the processes.[123]

3.120         Ms McClelland told the committee that the department suggested that Fieldforce develop a 'SOAP' interface[124] 'to interface our system into their system'.[125] The department attempted to develop its own portal, but according to Ms McClelland, they 'got it all wrong', and 'at that stage they decided that the best way to do it was for us to do a B2B [business-to-business] interface via SOAP into their system'.[126] This involved Fieldforce implementing 'five daily file transfers' from 7 December 2009 forward.[127]

3.121         Mr Timothy Ryerson, Executive General Manager, Fieldforce, further explained that:

...because we [Fieldforce] were so intimately involved from the beginning—we were actively providing advice—that, when the department saw that they were starting to have issues with their call centre and the number of people involved in it, they actively pursued a solution which would enable the assessors working for Fieldforce to reduce the burden on their call centre. This is the reason why they entered into what was called a call centre agreement, which effectively was just a file transfer of our appointments.[128]

3.122         Furthermore, Mr Ryerson gave evidence that if any other company had approached DEWHA requesting the same arrangement as Fieldforce, Fieldforce would not have objected as 'trying to find alternatives in any way possible at the height of the program was probably a good idea'.[129] Ms McClelland stated that she had assumed the department was 'talking to other organisations about B2B interfacing between the systems'.[130]

3.123         When asked how Fieldforce came to be in the position of having this 'special arrangement' and whether they had provided any payment to DEWHA, Mr Ryerson stated:

Fieldforce were involved in providing advice because we are experts. We have been running these programs for 17 years, so naturally [DEWHA] came and gravitated to us to ask for help. We have received nothing apart from the contract that we signed [to train 300 plus assessors].[131]

3.124         Ms McClelland also informed the committee that on numerous occasions Fieldforce offered their booking system to DEWHA free of charge:

I could have set up our system with every assessor. It would have taken me a week and they could have gone online, typed in their HO number and a booking. It would have fed via the five-fold transfer process that we set up in December [2009] automatically into the DEWHA systems and we could have solved a lot of the problems.[132]

3.125         Yet DEWHA apparently chose to ignore the solution proposed by Fieldforce. When asked why the government did not take up Fieldforce's offer, DCCEE advised that it does not have any record of having received such an offer from Fieldforce.[133]

3.126         The Faulkner review of procurement processes and contractual arrangements found no misconduct with respect to the arrangement between Fieldforce and DEWHA. According to that review the Memorandum of Understanding (MOU) between the organisations did not involve any financial obligations.[134]

3.127         However, regardless of the fact that no money was exchanged in return for this special arrangement with Fieldforce, the ANAO has found that 'it allowed Fieldforce to gain a market advantage'.[135]

Committee comment

3.128         As discussed above, the problems experienced with the booking system were directly related to the government's lack of foresight and planning regarding controlling assessor numbers.

3.129         Furthermore DEWHA was obviously not prepared, nor resourced, to handle the significant escalation of the program when it occurred. According to the Faulkner review, the contract for the call centre blew out from $770 000 to $3.4 million.[136] A cost blow-out of this scale clearly shows that DEWHA lacked the project management expertise to plan for and manage a program of this nature and size.

3.130         While it is understandable, particularly from Fieldforce's perspective, how the arrangement between Fieldforce and DEWHA came to be at a time when the call centre was under significant pressure, the committee is not satisfied that the arrangement was appropriate. It is possible that the arrangement reduced the call centre constraints by diverting what would otherwise be a significant percentage of assessment bookings. However, any small advantage this may have provided to assessors generally, was more than offset by the disadvantage they experienced by having to book through the inefficient call centre.

3.131         The arrangement was also far from transparent: the Faulkner review found that the DEWHA Executive and Minister Garrett were not informed of the arrangement;[137] and no other assessors or assessor organisations were offered such an arrangement. This lack of transparency casts doubt on the findings of the Faulkner review that the agreement was reached 'in good faith'.[138]

3.132         Thus, in the committee's view, while perhaps not illegal, the entry into a special arrangement with Fieldforce by DEWHA was grossly unfair to other assessors and highly improper. The committee makes a recommendation to this effect in chapter 7, in order to prevent the problems that occurred under Green Loans from being repeated in the Green Start program.

Misuse of the program

3.133         The submissions received by the committee contain allegations of the program being 'rorted' in various ways. These 'rorts' included:

3.134         It was suggested by a number of submitters that some of the companies which entered into 'organisation contracts' under the program and marketed and booked assessments on behalf of their assessors, used dishonest means to urge householders to book assessments.

3.135         For example, as the operator of the ACT home energy advisory service, the Sustainability Advice Team received complaints about the program of:

...aggressive cold calling from lists apparently compiled as a result of previously supplying compact fluorescent light bulbs under the NSW Greenhouse Gas Abatement Scheme, followed by setting times against the will of the householders (a particular concern of elderly householders).[139]

3.136         The committee also received anecdotal evidence of assessors misleading householders into believing that if they did not agree to an assessment now, they would be required to pay for an assessment themselves in the future:

I have heard stories of assessors door knocking, cold calling and marketing practices in retirement villages using mandatory disclosure and a “get it done now or you’ll have to pay for it later” tactic being employed.[140]

3.137         A number of assessors also alleged that some companies which manufacture or sell environmental products, such as solar panels or water heating systems, became involved in the program as a means of promoting their products.[141] For example, Dr Roger Severn, an assessor from Western Australia submitted that:

Many of the candidates [in the Assessor training course] were sales support employees of companies engaged in selling environmental services such as solar panels and hot water systems.[142]

3.138         This conflict of interest is argued to have diminished the value of the assessments performed by those companies, and to have been in contravention of the contract that assessors signed with DEWHA.[143] Mr Mark Walker, an assessor from NSW argued:

It is also clear that these many organisations blatantly breached the conflict of interest provisions of the Contract by encouraging their ‘assessors’ to up-sell products and services of their own or linked businesses, contrary to the specific terms of the Contract.[144]

3.139         Specifically, subclause 17.1 of the DEWHA assessor contract provides that:

(a) The Assessor must act impartially at all times and provide Assessments that are accurate, independent and free of commercial influence.[145]

3.140         Subparagraph 17.1(b)(ii) further states that Assessors must not:

...direct Householders towards a range of products or services developed or supported by an enterprise with which the Assessor is associated or from whom the Assessor receives a commission or other benefit.[146]

3.141         These obligations are also included in the Assessor Code of Professional Practice.[147]

3.142         However, there was no auditing of assessors or the quality of their assessments under the program, or of their compliance with the Code of Professional Practice.[148]

3.143         Dr Severn submitted that he questioned DEWHA on this issue, and was told that:

...it was alright to re-contact the householder on behalf of an employer once the Household Assessment Report had been issued. In other words, the information received in order to carry out the household assessment can then be used for another purpose namely as a sales lead. This advice from DEWHA is at odds with their own contracts and the code of practice for assessors.[149]

Committee comment

3.144         As with many of the other problems that occurred within the Green Loans Program, the issue of misuse of the program would likely have been circumvented had an audit system been built into the program.

3.145         In the committee's view it is unacceptable, but entirely predictable given the lack of program regulations and controls, that such practices were allowed to take place under a federal government program.

3.146         The committee makes a recommendation in chapter 7 about the necessity of implementing proper audit processes in the Green Start Program right from the outset, in order to prevent widespread misuse such as occurred under the Green Loans Program.

Payments to assessors

3.147         Under its contract with individual assessors, DEWHA agreed to 'make payment of a correctly rendered invoice within 30 days after receiving the invoice'.[150]

3.148         However, according to many assessors, this did not occur. For example, Mr Shayn Harkness, an assessor from Tasmania, submitted that he is yet to receive payment for assessments conducted in November 2009, and 'cannot access a responsible person by phone or email to resolve this problem'.[151]

3.149         In response to this issue, DCCEE stated in its submission that:

The 30-day timeframe for payment applies from the date at which a complete and correct invoice is received. Some delays in relation to the payment of invoices have been experienced by some assessors, while there have also been problems with some assessors submitting incorrect invoices.[152]

3.150         In order to address these delays, DCCEE informed the committee:

...a template has been developed for assessors to use, along with a step-by-step guide to filling in the template. Departmental staff have also been contacting assessors directly if they have submitted an incorrect invoice to explain what needs to be fixed... In addition, the Department is allocating additional resources to invoicing. As a result, the throughput of invoices has increased by 50 percent in recent weeks. Overtime shifts are planned until the backlog of invoices has been cleared.[153]

3.151         At the committee's public hearing on 29 June 2010, Mr Malcolm Thompson, Deputy Secretary, DCCEE further informed the committee that:

Correctly rendered invoiced are currently being paid within the 30-day time frame. There has been a significant reduction in the number of outstanding inquiries and complaints, although a reasonable number of those remain and we are working on reducing those further.[154]

Committee comment

3.152         The committee expresses its strong disappointment with the government not meeting its payment obligations to individual contractors. The government's tardiness would undoubtedly have created serious cash-flow problems for many assessors.

3.153         As with call-centre delays and delays in issuing contracts, the government's delay in paying assessors was a direct result of the lack of control DEWHA had over various aspects of the program, and particularly assessor numbers. It also reflects the serious lack of project management expertise within DEWHA.

3.154         In chapter 7, the committee makes a recommendation on payments to assessors, in addition to recommendations about ensuring that DCCEE has appropriate expertise within the staff managing the Green Start Program, in order to prevent the failings of the Green Loans Program from re-occurring.

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