Audit Report No. 25 2008-09
Chapter 2 Green Office Procurement and Sustainable Office Management
Introduction
2.1
Government agencies purchase, lease or consume a significant range of
goods and services. In 2007-08, the procurement of goods and services by
Australian Government agencies was valued at over $26 billion. These include
office supplies, vehicles, information and communications technology, energy,
waste and water services as well as office buildings and facilities. While
these goods and services are procured for agencies to achieve their outcomes,
they do have an environmental impact. This impact includes greenhouse gas
emissions (such as from energy consumption in buildings and from vehicles),
waste to landfill from paper, equipment and office refurbishments as well as
the consumption of scarce resources such as fresh water and fossil fuels.
2.2
The Australian Government has indicated that it is seeking to be at the
forefront of environmental purchasing practice. In May 2008, the Prime Minister
also commented that ‘the Government accepts its own responsibility to provide
practical leadership … with practical measures to reduce our own environmental
footprint and measures to harness savings from more efficient use of energy and
water’.[1]
2.3
In a previous audit report (No. 22, 2005-06, Cross Portfolio Audit of
Green Office Procurement), the ANAO identified a small number of
better practice examples of green office procurement across the Australian
Government. The audit also identified shortcomings in achieving the
Government’s objective to be at the forefront of sustainable procurement
practice. As a consequence, the audit concluded that sustainable development
had not been fully integrated into Australian Government operations.
2.4
Significant improvement was required by agencies in terms of introducing
targets for water, waste, energy and general procurement, and in implementing
regular monitoring and reporting. The ANAO made specific recommendations to
improve performance in sustainability. The 43 agencies involved in the audit
generally agreed with or were supportive of the recommendations.
The Audit[2]
Audit scope and objective
2.5
The objective of this further audit was to assess and report on the
progress being made by Government agencies in achieving better practice in
green office procurement and sustainable office management. The scope of the
audit included agencies incorporated under the Financial Management and
Accountability Act 1997 as well as a sample of bodies incorporated under
the Commonwealth Authorities and Companies Act 1997. Sixty-three
agencies were included in an audit survey. Detailed validation was carried out
in nine of these agencies.
2.6
The audit also relied on wider whole-of-government data sets on energy
use in Australian Government operations and the Australian Government vehicle
fleet as well as annual reports from agencies. Where necessary, the ANAO also
consulted with other parties such as state agencies and building owners. The
audit sought to assess progress relevant to sustainable development in the
following areas:
n policies and
procedures underpinning sustainable practices;
n higher value office
consumables such as paper, information and communications technology and
vehicles;
n water and waste
management;
n energy use;
n sustainability in
buildings and tenancies; and
n sustainability
reporting.
Overall audit conclusion
2.7
The ANAO made the following overall audit conclusion:
n Agencies had made
some progress towards more sustainable development practices since the 2005
audit, with more examples of agency initiatives to better conserve resources,
improve environmental performance and reduce corporate costs, particularly in
energy and water conservation.
n As was the case in
2005, there was a wide disparity of performance across agencies from very poor
to better practice. Measuring performance in waste management and water
conservation was also still problematic because of the lack of consistency in
measurement and gaps in performance information. The absence of a comprehensive
sustainability framework, as recommended in 2005, also constrained further
progress.
n Larger agencies such
as the Department of Defence, Centrelink, Medicare Australia and the Australian
Taxation Office had made progress towards more sustainable practices since
2005. This progress may have also reflected their capacity compared to smaller
agencies.
n Substantive progress
had been made in relation to environmental controls in individual agencies and
in the reporting on energy use in Australian Government operations. Key
controls such as environmental management systems are becoming more common
practice in building and facility management. However, the design and quality
of the majority of environmental management systems could be significantly
improved; particularly in the application of measurable targets.
2.8
According to the ANAO:
Notwithstanding progress in particular agencies, as a whole,
the Australian Government public sector has considerable work to do if it is to
achieve its goal of being at the forefront of sustainable procurement practice.
Many of the issues raised in the 2005 audit remain unresolved and many of the
recommendations have yet to be fully implemented. More action is required from
agencies if leadership is to be demonstrated in energy efficiency, water
conservation and waste management. Energy efficiency is particularly important
given that energy use accounts for over 95 per cent of greenhouse emissions
from Australian Government agencies.
There is considerable scope to reduce the ‘ecological
footprint’[3] of Australian Government
agencies. Positive results will not be achieved without a stronger effort from
all Australian Government agencies that builds on the success of those agencies
that have already integrated sustainable practices into their business
operations.
Ideally, agencies should develop an integrated sustainability
framework that identifies improvement opportunities and investment priorities
tailored to their business requirements. Where agencies have limited capacity
or resource constraints, there are still many opportunities to achieve ‘quick
wins’ and implement cost effective measures to improve sustainability. The
automated shut down of monitors and computers when not in use will provide
immediate energy and cost reductions. Setting printers to print double sided as
a default and reducing the weight of paper used for external publications will
also offer immediate savings. While the implementation of energy efficiency
initiatives will involve some capital cost, the resultant savings from such
measures would be ongoing and further increase over time as energy costs
increase.
Agencies will obviously need to prioritise their
sustainability actions with an initial focus on meeting government requirements
and achieving cost effective outcomes. For larger agencies, a focus on primary
sites or administrative areas with the most significant environmental impacts
would be expected to yield the best environmental returns. It is appreciated
that the actions put in place will, to a large extent, depend upon the
particular circumstances facing each agency. Full implementation will take time
to complete.[4]
ANAO recommendations
2.9
The ANAO made the following recommendations:
Table 2.1 ANAO recommendations, Audit Report No. 25
2008-09
1.
|
To strengthen the quality and consistency of environmental
management systems, the ANAO recommends that agencies (where they have not
already done so), ensure that their system has quantifiable objectives that
reflect better practice as well as both short and longer term sustainability
goals.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
2.
|
To improve the energy efficiency of information and
communications technology (ICT) equipment, the ANAO recommends that agencies
(where they have not already done so) introduce:
(a) environmental
criteria in ICT business planning and procurement that explicitly requires
energy efficiency and environmental performance standards for equipment; and
(b) an ICT power
management policy, that includes measures such as the automatic shut down of
monitors and personal computers when not in use.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
3.
|
To improve sustainability practices in waste management
the ANAO recommends that agencies (where they have not already done so):
(a) consider practical
measures to divert waste from landfill, such as organic and co-mingled waste
recycling for primary sites;
(b) require waste
service providers to report the weight of major waste streams, including
paper recycled, co-mingled waste recycled and general waste landfill, in
future waste management contracts;
(c) set agency-wide
targets based on a standardised measure such as the weight of waste generated
per person and/or diversion from landfill; and
(d) report performance against
these targets as part of agency commitments under the National Packaging
Covenant obligations.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
4.
|
To improve water conservation, the ANAO recommends that
agencies (where they have not already done so):
(a) consult with
building owners to obtain annual data on water consumption where practicable;
(b) set agency-wide
water reduction targets and implement cost effective water conservation
measures for all primary sites; and
(c) monitor and publicly
report progress against these water reduction targets.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
5.
|
To reduce energy consumption in Australian Government
operations and improve compliance with Government policy, the ANAO recommends
that agencies (where they have not already done so):
(a) develop and
implement an energy management plan that takes into account operational and
management requirements across their property portfolio;
(b) conduct energy
audits, where appropriate, to determine high priority energy savings that can
be made across the organisation; and
(c) implement cost
effective energy conservation initiatives within remaining lease periods.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
6.
|
To improve the sustainability of Australian Government
operations, the ANAO recommends that the Department of the Environment,
Water, Heritage and the Arts in consultation with other agencies:
(a) develops and
disseminates guidance for office refurbishments that set required
environmental standards and practices to minimise waste going to landfill
from Australian Government refurbishments; and
(b) considers
introducing a standard requirement for agencies to have a waste minimisation
plan for refurbishments over 2,000 square metres.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
7.
|
To enhance the consistency and comprehensiveness of the
annual reporting required under section 516A of the Environmental
Protection and Biodiversity Conservation Act 1999, the ANAO recommends
that the Department of the Environment, Water, Heritage and the Arts revise
the guidance material provided to agencies and include core mandatory
performance indicators for operational environmental impacts in key areas
such as energy, water and waste.
Agencies’ responses
All agencies agreed to or were supportive of this
recommendation.
|
The Committee’s review
2.10
The Committee held a public hearing on Wednesday 24 June 2009, with the
following witnesses:
n Australian National
Audit Office (ANAO);
n Australian Taxation
Office (ATO);
n Department of Finance
and Deregulation (DFD);
n Medicare Australia;
and
n Department of the
Environment, Water, Heritage and the Arts (DEWHA).
2.11
The Committee took evidence on the following issues:
n green information
technology:
§
green tenders and environmental management systems;
§
stewardship clauses; and
§
server virtualisation;
n green buildings:
§
environmental management systems;
§
national frameworks for environmental standards; and
§
green leases;
n resource and waste
management:
§
power management;
§
water management; and
§
waste management; and
n green car programmes.
Green information technology
Green tenders and environmental management systems
2.12
The Committee enquired whether the Department of Environment, Water,
Heritage and the Arts (DEWHA) had taken any steps to identify best practice in
green tendering and whether any information found had been disseminated
further. DEWHA replied that it had recently gone through a tender process for
information and communication technology (ICT) that was acknowledged to have a
strong emphasis on sustainability.[5]
2.13
The Committee asked whether there were any plans to make environmental
management systems (EMS) mandatory for all agencies. DEWHA replied that it was
not currently mandatory, but that there was guidance available to assist
agencies in selecting and implementing an EMS that suited their needs.[6]
Medicare, and the Australian Taxation Office (ATO) advised they had put in
place an EMS, and the Department of Finance and Deregulation (Finance) noted
that while they did not yet have an EMS in place, that it was ‘well advanced’.[7]
2.14
The Committee is concerned at an apparent lack of urgency at a public
sector-wide level. The Committee heard that the Government Leadership in
Sustainability Taskforce led by the Department of Prime Minister and Cabinet was
yet to report despite its deliberations concluding in late 2008.[8]
2.15
Whilst noting the role of the taskforce, the Committee is of the belief
that the Department of the Environment, Water, Heritage and the Arts should
take a leadership role in promoting environmental management systems. It is
clear to the Committee that these environmental management systems deliver
clear benefits, and the Committee recommends:
Recommendation 1
|
|
That taking into account the findings of the Government
Leadership in Sustainability Taskforce, environmental management systems be
made mandatory across all agencies of the Australian Government.
Further, that the Department of the Environment, Water,
Heritage and the Arts take the lead in developing a best practice
environmental management system template with minimum standards for
reporting.
|
Stewardship clauses
2.16
The Committee examined the issue of stewardship clauses for ICT waste. Approximately
100,000 desktop computers and laptops are being replaced by the Australian
Government every year. A significant proportion will end up in the waste
stream. Only 16 agencies (25 per cent) reported that their contracts for the
supply of ICT included product stewardship arrangements. Under stewardship
clauses, ICT suppliers agree to take back assets after they have finished their
working life and dispose of them appropriately. The Committee invited agencies
to report on product stewardship arrangements.
2.17
DEWHA noted that under its new ICT tender, 95 per cent of ICT
procurement included end of life provisions, and that plans for developing a handling
methodology for the remaining five per cent were underway.[9]
2.18
Medicare advised that its ICT infrastructure contracts did not contain
provisions for product stewardship as the contracts predated the Audit Report.[10]
2.19
Both the ATO[11] and Finance[12]
noted that their current ICT contracts contained stewardship clauses.
2.20
Environment noted the existence of the Environment Protection and
Heritage Council, which was a cross-jurisdictional council of environment
ministers. The Council was currently examining product stewardship schemes, and
that it was possible that a national product stewardship scheme may be created.[13]
2.21
The Committee asked whether there were cost implications in negotiating
stewardship clauses, as it would be possible for the ICT supplier to gain a saleable
asset at the conclusion of the agreement. DEWHA replied that by the time an ICT
asset had been returned to the supplier, it had reached the end of its useful
life and was considered to be a liability to the supplier.[14]
2.22
The Committee asked whether it was possible for end of life ICT assets
to be passed on to community groups or training providers, and whether any such
arrangements were in place at any of the agencies. DEWHA replied that this was
the responsibility of the ICT supplier, and that different providers did
different things with returned computers and monitors.[15]
2.23
The Committee sees great benefits in the operation of stewardship
clauses, and while noting the current situation regarding Medicare’s ICT
infrastructure contracts recommends:
Recommendation 2
|
|
That Medicare Australia enter into stewardship agreements
with its information and communication technology suppliers when its
contracts are next scheduled for renewal.
|
Recommendation 3
|
|
That the Department of Environment, Heritage and the Arts
draft and promote an explicit policy that product stewardship clauses be the
preferred option for public sector information and communication technology
(ICT) in all cases where ICT assets are not to be re-sold or gifted at the
end of their working life.
|
Green buildings
National frameworks for environmental standards
2.24
The Committee noted that Medicare had implemented a national framework
for environmental standards across all of its offices. Medicare reported that it
had achieved considerable cost savings by implementing videoconferencing,
purchasing hybrid cars, and using more public transport for staff in some
capital cities.[16]
Green leases
2.25
The Committee explored the issue of green buildings and green leases. DEWHA
advised that any new buildings, leases for new buildings, or major
refurbishments must be done on the basis of the office space achieving a
minimum four and a half star energy rating.[17] Additionally, Finance
reported that it was looking to introduce a green lease schedule as part of its
next round of leasing arrangements.[18] Further, Finance
reported that it had entered into voluntary green improvement programs with
tenants in a number of its major buildings, a process which mimics the green
lease schedule:
What Finance has done with a number of its major buildings is
entered into voluntary green improvement programs with our major tenants. Those
voluntary green improvement programs mimic the green lease schedule. We have
management meetings where we discuss issues to do with the environmental
performance of the buildings and we put green improvement programs in place in
those buildings. Once the leases do expire, which is still a few years away, we
will certainly move to the green leases as required under the EEGO policy. But,
in the meantime, we have got voluntary green improvement programs to try and
get the same result.[19]
2.26
Medicare noted it had two green lease schedules, and green office
guidelines,[20] and the ATO noted it had
a number of new green leases which incorporated aspects of green energy and
waste management arrangements.[21]
Resource and waste management
2.27
The Committee expressed its disappointment in the ANAO finding that many
issues raised in the 2005 Audit Report remained unresolved, and that many
recommendations had not yet been fully implemented.
Power management
2.28
The Committee noted the ANAO finding that energy use accounted for more
than 95 per cent of greenhouse gas emissions from Australian Government
agencies, and that savings of $75 million per annum had been identified if more
agencies adopted better practices. The Committee asked agencies about their
power management practices and the savings identified as a result.
2.29
The ATO replied that building lights were only on for “core hours”, from
seven in the morning until seven at night, and that lighting after hours was
supplied via “zoned lighting”, allowing a small part of an office to be lit,
rather than the entire floor.[22]
2.30
DEWHA noted that the issue was managed through its EMS, and that it was
pursuing change through cultural measures, encouraging turning off ICT assets
when not in use.[23] Finance noted that it
had similar measures in place.[24] DEWHA added that it had
EMS targets and objectives set regarding electricity, fuel and paper use, and
that these targets were reviewed annually.
2.31
Medicare reported that it audited energy usage on its sites, and noted the
importance of monitoring, auditing and reinforcing the message of power
management. [25]
2.32
ANAO’s 2005 audit recommended that agencies consider energy efficiency
in their ICT purchases. In the 2008 survey, 65 per cent of agencies advised
that they now considered energy consumption in their ICT procurement. In
addition, the vast majority of agencies indicated they had implemented at least
one measure to reduce energy consumption of office and ICT equipment. Some of
the 48 per cent of agencies who shut down personal computers overnight reported
significant savings from the initiative.
2.33
Medicare cited substantial savings from implementing a PC shutdown
policy and the automatic shutdown of monitors after 15 minutes of non-use
($237,000 from PC shutdowns and over $100,000 in the case of monitors),[26]
noting that the process had been centralised by its IT department.[27]
Server virtualisation
2.34
The Committee asked for more information on DEWHA’s desktop and server
virtualisation project. DEWHA advised that instead of running multiple servers
that performed different functions, that a single server had been established
with imaginary partitions allowing the system to perform separate functions.
The trial covered 22 staff over five weeks, and identified energy savings of 83
per cent compared to the traditional PC model.[28]
Recommendation 4
|
|
That the methodology used and results of the Department of
the Environment, Water, Heritage and the Arts desktop and server
virtualisation project be disseminated to the other audited agencies.
|
Water management
2.35
The Committee expressed its concern at the ANAO finding that only 35 per
cent of surveyed agencies were able to measure their water usage, a small
increase from 28 per cent at the previous audit in 2005. The Committee asked
for further information on water management and reporting.
2.36
DEWHA replied that it was difficult to meter water usage in different
buildings and under different tenancy operations, as in co-tenanted buildings,
water consumption was often only measured at one point, making it difficult for
individual tenants to find out their water consumption. Further, it was
expensive to retrofit individual water metering for different tenants in
different buildings.[29]
2.37
Finance noted that even though they were landlords in several buildings
and it would be able to track water consumption in each building, that it would
not be possible to ascertain how much water each agency located in the building
used. Noting the importance of water consumption management, Finance advised
that it would review the lease clauses in relation to water consumption
management when leases were due for renewal.[30]
2.38
Medicare reported that there was data for its national headquarters, and
that this data was used to produce estimates of water consumption at larger
sites. However, it was difficult to estimate water usage in Medicare offices in
shopping centres, as in some cases, offices did not contain a bathroom on site.
When asked whether it had water management practices in place, Medicare noted
that it had policies in place at an infrastructure level, and was continuing to
promote cultural practices aimed at saving water.[31]
Waste management
2.39
The quantity of solid waste produced in Australia continues to grow. The
ANAO’s 2005 audit found that the performance of agencies in managing waste was
poor and recommended waste targets and improved measurement and reporting be
introduced across all agencies. The ANAO also recommended agencies implement
co-mingled and organic recycling schemes for office waste and include clauses
in purchasing contracts to minimise packaging waste.
2.40
Little has changed in waste management since 2005. Performance across
Australian Government agencies varies considerably. Agencies that have
implemented recycling for co-mingled office waste increased from 65 per cent in
2005 to 89 per cent in 2008. Organic recycling increased from 28 per cent in
2005 to 33 per cent in 2008. Only 10 per cent of surveyed agencies were able to
provide complete reporting on all waste streams. Only 21 per cent of agencies
include contract clauses to minimise packaging waste. From the available data,
the average rate of diversion from landfill was 67 per cent compared to
Environment at 74 per cent.
2.41
The majority of surveyed agencies (52 per cent) were unable to provide
any waste reporting data despite agencies advising Environment in 2006-07 that
waste management reporting systems were in place or under development. When
agencies have been required to measure and report on waste, such as under the
Government’s commitment to the National Packaging Covenant (NPC), performance
by the majority of agencies was poor. To date, Australian Government agencies
have not collectively been able to provide any meaningful performance data to
indicate the success or otherwise of the NPC Action Plan (July 2006-June 2008).
If Environment is to be in a position to report on progress in the next NPC
reporting period (2008-10), there will need to be considerable improvement in
the quality of data provided by agencies.
2.42
The Committee expressed its disappointment in the ANAO finding that 52
per cent of agencies were still unable to provide any waste reporting data. DEWHA
advised that the Commonwealth was a signatory to the National Packaging
Covenant, and, as a result, the department had whole-of-government
responsibility for collecting and reporting data on packaging waste.[32]
It advised that in preparing the report for the 2007-08 financial year it now
had 83 per cent data coverage, though the presence of multi-tenanted buildings
made data collection difficult.[33]
2.43
Survey results indicate that there has been a general improvement in
more sustainable building and refurbishment materials since 2005. However, the
recycling of construction and refurbishment waste is still a low priority for
most agencies. The 2008 survey indicated that only 13 agencies (21 per cent) had
provisions for minimising and/or recycling of waste generated in their
contracts for refurbishments (a decrease from 31 per cent in 2005) and only two
agencies were able to provide estimates of the amount of waste going to
landfill from the refurbishments. This figure was similar to 2005 when only
three agencies provided estimates. Guidance for office refurbishments that set
required environmental standards and practices to minimise waste going to
landfill would be particularly helpful for agencies.
2.44
The Committee asked what happened to waste materials produced during the
construction and refurbishment of buildings. DEWHA advised there were no
specific guidelines, but that a national waste policy was being examined by the
Environment Protection and Heritage Council, and that a report was due.[34]
2.45
The Committee is pleased to note the publication of the National
Waste Report 2010 by the Environment Protection and Heritage Council, and
encourages all departments and agencies to take the report’s findings into account
when developing policy, procedures and processes.[35]
The Committee particularly notes the difficulties with regard to data availability
and collection and urges all relevant stakeholders to implement reforms in this
area.
Green car programs
2.46
The Australian Government is a significant consumer of motor vehicles
with the Government fleet, including the Department of Defence ‘white vehicle
fleet’ (non-military, commercially available vehicles) having over 13,000
vehicles in total. In February 2003, a target was established to have 28 per
cent of the Government fleet vehicles scoring in the top half of the Green
Vehicle Guide (GVG) by December 2005. This target was achieved in June 2007.
The proportion of vehicles in the top half of the GVG by June 2008 was 36 per
cent. The target was reviewed by the Government Leadership in Sustainability
Taskforce in late 2008 and a revised target has been proposed to Ministers to
achieve more sustainable and cost effective vehicle fleets. At the date of
preparation of this report, there has been no decision to update the target or
revise the guidelines.
2.47
The 2005 audit highlighted tensions between costs, preferences for
Australian made vehicles and meeting the Government’s goal to reduce emissions.
In 2008, these tensions still exist. Consistent with the findings in the 2005
audit, discounts of up to 30 per cent for large Australian made six cylinder
cars are helping to keep the proportion of large cars in the fleet high. The
most popular small cars tend to receive around ten per cent discount, while the
most popular medium sized cars receive a discount of around 18 per cent.
However, when considered on a whole-of-life cycle basis, large vehicles are 35
per cent more expensive than small cars.
2.48
Although the Defence white fleet was not included when the original GVG
target was set, Defence advised that it is working towards achieving a target
of 28 per cent of its passenger vehicles scoring a GVG rating greater than
10.5. However, with only seven per cent of vehicles currently in the top half
of the GVG, little progress has been made in this area. The poor environmental
performance of the Defence fleet may be partly explained by the high proportion
of commercial vehicles (55 per cent), which have low GVG scores. However, other
large agencies with a similar proportion of commercial vehicles in their fleets
manage to have between 14 and 25 per cent of vehicles in the top half of the
GVG. Defence advised that it is conducting further investigations into
improving the environmental rating of its vehicle fleet.
2.49
The Committee asked about green car programs, with Finance replying that
in 2003, a target was set that 28 per cent of government passenger vehicles
would score 10 or better on the Green Vehicle Guide. While by 2005 this
target had not yet been met, currently 49.5 per cent of government passenger
vehicles meet the requirement. When asked why there had been a rapid increase
in green car purchases, Finance replied that agencies had begun to consider
environmental issues more seriously as a result of the adoption of a policy
stating that:
… by 2020, 50 per cent of the Commonwealth’s passenger
vehicle fleet will be Australian made, value for money vehicles and
environmentally friendly cars.[36]
2.50
The Committee notes the high proportion of commercial vehicles in
Defence ‘white vehicle fleet’ raises the importance of considering separate
targets for passenger and commercial vehicles to allow for a stronger focus on
the environmental performance of the Defence white fleet. Accordingly, the
Committee recommends:
Recommendation 5
|
|
That the Department of Climate Change and Energy Efficiency
create separate targets for commercial and passenger vehicles in the Defence
white fleet to allow for a stronger focus on the environmental performance of
the Defence white fleet.
|
Conclusion
2.51
The Committee is pleased to see some of the progress made by agencies to
improve their green procurement practices. The development of environmental
management systems across the audited agencies is a positive development, and
the Committee looks forward to seeing further positive outcomes stemming from
these systems. However, clear disparities in performance across the entire
public sector makes it clear that there is still more work to be done.
2.52
The Committee sees great benefit in stewardship clauses in ICT
contracts, and is glad to see them in place at most agencies. The Committee is
of the belief that stewardship clauses should be compulsory across all agencies
that lease ICT infrastructure.
2.53
The Committee looks forward to seeing further progress in the next audit
anticipated for 2011.