The Design and Administration of the Better Regions Program
The objective of the audit was to assess whether the Better Regions Program has been effectively designed and administered. The audit scope included examination of all 106 Better Regions projects.
1. During election campaigns political parties typically will release policy statements and the parties or their candidates may make announcements of their intention to provide certain benefits, services or facilities in the event the relevant party is elected or re-elected to government. The approach generally adopted at the Commonwealth level is that the incoming government confirms which announcements made during the campaign represent an election commitment, with relevant portfolio Ministers and departments being allocated responsibility for progressing the delivery of the confirmed announcements.
2. The allocation of election commitments from the November 2007 General election to portfolios was finalised by the Labor Government in the lead up to the May 2008 Budget. In respect to regional election commitments allocated to the Infrastructure, Transport, Regional Development and Local Government portfolio, the 2008–09 Budget included an expense measure of $176.03 million to establish the Better Regions Program, with funding allocated over the period 2007–08 to 2010–11. This Program was to help local communities deliver local infrastructure and other regional community projects. The election commitments allocated to the Program related to projects such as the revitalisation of main streets in towns, construction of multi-purpose community and resource centres, major sport and recreational venues and community transport infrastructure.
3. The Better Regions Program was not open for applications as it was established solely to fund 105 commitments made by the Australian Labor Party (ALP) in the context of the 2007 election campaign. In June 2010, a further project announced as an election commitment in the 2007 election campaign (but previously allocated to a different portfolio) was included within the Better Regions Program, bringing the total number of projects allocated to the Program to 106.
4. Until September 2010, the Department of Infrastructure, Transport, Regional Development and Local Government (DITRDLG, now the Department of Infrastructure and Transport) was responsible for the design and administration of the Better Regions Program. The Administrative Arrangements Order of 14 September 2010 created the Department of Regional Australia, Regional Development and Local Government (RA). Amongst other things, RA is responsible for dealing with the delivery of regional and rural specific services, regional development and regional Australia policy and coordination. In this context, RA's responsibilities include the ongoing administration of the Better Regions Program, with staff of the former Local Government and Regional Development Division of DITRDLG having been transferred into the new department.
5. As the projects were election commitments, neither department played a role in the selection of projects for consideration under the Better Regions Program. Rather, the role of the departments was to provide advice on the design of the Better Regions Program and to administer individual projects allocated to the Program, including obtaining information on each project from the proponent and assessing each project proposal so as to provide advice to the relevant Parliamentary Secretary as to whether the project was eligible to be funded, the provision of funding would represent an efficient, effective and ethical use of public money and whether there were any risks to implementation of the project that required management. The departments were also responsible for developing, signing and administering Funding Agreements in respect of each approved project.
6. Commonwealth grant programs involve the expenditure of public money and thus are subject to applicable financial management legislation. Specifically, the Financial Management and Accountability Act 1997 (FMA Act) provides a framework for the proper management of public money and public property. This framework includes requirements governing the process by which decisions are made about whether public money should be spent on individual grants, including those made under the Better Regions Program. In recognition of the importance of this framework, a key performance indicator adopted and reported on for the Program has been that it be designed and administered in a way that is consistent with the Financial Management and Accountability Regulations 1997 (FMA Regulations), the ANAO Better Practice Guide on grants administration and the recommendations from the ANAO audit of the Regional Partnerships program.
7. While not affecting a Minister's right to decide on the allocation of grants, since December 2007 the financial framework applying to grants decision-making has been progressively enhanced. In this context, in December 2008, the Government agreed to a range of measures to reform the administration of grants, including the development of an improved framework for grants administration. These decisions were made in response to the 31 July 2008 report of the Strategic Review of Grants. The Government's December 2008 decisions have now been reflected in the new policy framework for the administration of grant programs by agencies subject to the FMA Act that took effect from 1 July 2009.
8. Of particular relevance to the Better Regions Program, the Government accepted the Strategic Review's recommendation that the requirement on Ministers to receive and consider agency advice on the merits of proposed grants, as assessed against the relevant program guidelines, before taking any decisions on the award of individual grants should apply to all grant spending proposals, including proposals designed to satisfy commitments made in the context of election campaigns. Similarly, agencies are required to develop and publish guidelines for all new grant programs, including in respect of programs established solely to fund election commitments. This policy requirement is now reflected in the Commonwealth Grant Guidelines (CGGs).
9. Whilst the enhancements to the grants administration framework made since December 2007 applied to the design and implementation of the Better Regions Program, 86 Better Regions projects (81 per cent) had been approved for funding prior to the July 2009 changes to the FMA Regulations and introduction of the CGGs. Assessments of the remaining 20 projects were finalised after the changes were made to the FMA Regulations and after the introduction of the CGGs.
10. The objective of the audit was to assess whether the Better Regions Program has been effectively designed and administered. The audit scope included examination of all 106 Better Regions projects.
11. The establishment of a specific election commitments program was a new approach aimed at promoting better practice in the consideration and implementation of regional election commitments. This approach assisted to balance the expectation of governments seeking to deliver upon their election commitments with the legislative obligations that:
- the decision-maker has obtained and considered sufficient information to inform an assessment that it would be efficient, effective and ethical (and not inconsistent with relevant Government policies) to approve the spending of public money; and
- the reasons for decisions to spend public money on a grant have been recorded.
12. Implemented during a period of changing arrangements for grants administration, overall the Better Regions Program was effectively designed and has been well administered. In this context, considerable effort was invested to meet the Government's stated commitment that the Better Regions Program would be designed and administered in a way that was consistent with the FMA Regulations, the ANAO Better Practice Guide on grants administration and the recommendations from the ANAO audit of the Regional Partnerships program.
13. The July 2008 report of the Strategic Review of Grants emphasised the importance of sound planning and governance arrangements for all grant programs, including those used to fund election commitments. Consistent with the enhanced grants administration framework, Program Guidelines were developed and published. These Guidelines, and supporting internal procedures, provided a sound framework under which the department obtained relevant information from project proponents, assessed this information and provided advice to the relevant Parliamentary Secretary concerning the approval of funding for each project. However, whilst it was intended that the Guidelines would include program assessment criteria, they did not.
14. Since December 2007, the enhanced grants administration framework has required agencies to provide advice on the merits of each proposed grant, including a clear recommendation to the decision-maker concerning whether or not funding should be approved under the relevant program's guidelines. For applications-based grant programs meeting this obligation would require the agency to assess eligible applications received by the closing date against selection criteria set down for the program and then to rank competing, eligible applications in terms of the available funding. As a program established solely to fund various regional election commitments, neither DITRDLG or RA had a role in the selection of projects. Nevertheless, the obligation to assess the efficient and effective use of public money for a proposed grant exists regardless of how a project proposal comes before an approver and regardless of whether project proposals are assessed and ranked in comparison to one another.
15. The published Program Guidelines and departmental administration of the Program recognised that there was a requirement for both an assessment of whether each project would make efficient and effective use of public money as well as an assessment as to whether any risk mitigation measures should be imposed. The department clearly and effectively communicated the results of its risk analysis and mitigation proposals to the relevant Parliamentary Secretary. However, the assessment briefings provided to the relevant Parliamentary Secretary did not similarly outline the basis upon which the department had assessed each project as representing an efficient and effective use of public money (in support of its recommendation to the relevant Parliamentary Secretary that funding be approved). ANAO has made one recommendation in this regard.
16. The effective management of risk was a feature of the Better Regions Program. To promote informed decision-making and guard against underdeveloped projects being submitted for possible funding approval, the department only provided its advice to the relevant Parliamentary Secretary once it was satisfied that it was sufficiently well informed about the project and any attendant risks. The department also took steps to manage identified risks as appropriate across the lifecycle of individual projects: in some instances the proponent was required to address one or more implementation risks prior to a Funding Agreement being signed whereas other risks were required to be addressed after the Funding Agreement was signed but prior to any payments being made, or through Funding Agreement milestones.
17. Most of the announced election commitments are proceeding in whole or part under a signed Funding Agreement and monitoring of project progress under the Funding Agreements has been effective. This has meant that RA has been aware of delays in the commencement and/or delivery of a significant number of projects. Consistent with better practice given the nature of the projects allocated to the Better Regions Program, project payments were structured to reflect actual progress rather than initial payments being made solely upon signing of a Funding Agreement. Additionally, progress payments have been withheld until such time as project milestones have been met. As a result, there have been rephasings of the budgeted expenditure for the Program, and the Program may need to be extended for an additional year to enable projects to be completed. As the Better Regions Program is not an economic stimulus program, and projects were not otherwise selected for funding on the basis of their ability to commence and be completed in a timely manner, this situation does not reflect poor assessment practices or program management. Rather, it reflects that some of the projects announced as an election commitment were at an early stage of planning and development when they were announced and/or there have been delays by the proponent in progressing the project.
Program funding and distribution
18. Earlier ANAO performance audits, and the July 2008 report of the Strategic Review of Grants, have identified challenges in governments seeking to fund election commitments through existing grant programs. In particular, it has been noted that:
- the policy intent underpinning an election commitment may not be consistent with the eligibility or other criteria for the existing program. In particular, where the grant proposal is unlikely to satisfy those criteria, equity issues arise when applicants through a competitive process are unable to secure funding because some of the available funding has been set aside to fund election commitments that otherwise may have ranked lower if assessed in terms of their comparative merit; and/or
- funding election commitments through an existing grant program, or reducing the funding available under an existing grant program in order to fund election commitments, can lead to calls for the size of the existing program to be increased or reinstated as well as adversely affecting the achievement of program outcomes.
19. In this context, as outlined in the recently released update of ANAO's Administration of Grants Better Practice Guide, a more appropriate funding platform for the implementation of one or more election commitments relating to a particular portfolio of responsibility may be the establishment of a separate grant program to be used for the exclusive purpose of administering the election commitments. This is the approach that was taken in respect to the Better Regions Program. Specifically, once decisions were taken about which regional election commitments were to be allocated to DITRDLG for administration, $176.03 million was provided for the Better Regions Program in the May 2008 Budget so as to provide sufficient funding to cover all commitments. Further in this respect, the amount allocated to other existing applications-based regional development programs was not reduced in order to fund the Better Regions Program.
Distribution of funding
20. As indicated at paragraph 5, the projects were election commitments that were later allocated to be considered for funding under the Better Regions Program. In this context, as outlined in ANAO's Better Practice Guide on the administration of grant programs, and acknowledged in the Commonwealth Grant Guidelines, a measure of grant program outcomes that is frequently the subject of public and parliamentary scrutiny is the distribution of funding awarded under the program. In particular, the geographic and political distribution of grants may be seen as indicators of the general equity of access to a program, as well as its effectiveness in targeting funding in accordance with the stated policy objectives of the program.
21. As noted, the Better Regions Program was not open to applications but was established solely to fund various election commitments. In this context:
- the majority of Better Regions projects involving nearly 90 per cent of announced funding (87 projects or 82 per cent of the 106 projects in the Program) were located in electorates classified by the Australian Electoral Commission (AEC) as either Rural (54 per cent of projects and 56 per cent of announced funding) or Provincial (28 per cent of projects and 34 per cent of announced funding) electorates;
- the significant majority (73 per cent) of Rural and Provincial electorates were held by the Coalition at the time of the 2007 General election. Accordingly, given the concentration in those electorates of projects that were the subject of election commitments allocated to the Better Regions Program, 72 projects (69 per cent) and $132.7 million of the announced funding (75 per cent of the total) related to seats which were Coalition-held prior to the 2007 election and that were classified as Rural or Provincial; and
- funding for projects allocated to the Program was largely focused on seats held by the Coalition at the time of 2007 election that were classified by the AEC as Marginal (that is, electorates in which the two-party preferred margin was less than six per cent) and, to a lesser extent, Fairly Safe (a two-party preferred margin of between six per cent and 10 per cent).
22. Consistent with the enhanced grants administration framework, Better Regions Program Guidelines were developed by DITRDLG, approved by the Expenditure Review Committee of Cabinet and published. The importance of funding decisions being well-informed was reinforced in the published Guidelines which outlined that:
- in order for a Better Regions proposal to be approved for funding and a Funding Agreement developed, each proponent would need to provide information about their organisation and the project to the department;
- projects needed to be consistent with the details identified in the announcement of the election commitment; and
- the funding decisions would be taken by the relevant Parliamentary Secretary based on two considerations:
- whether the project would make efficient and effective use of public money (as required by the FMA Regulations); and
- whether any risk management strategies would need to be imposed as a condition of funding, based on risk assessments undertaken by the department.
23. This approach was supported by the department developing proformas to aid in consistently obtaining all relevant information from proponents (including from those proponent that had previously submitted an application for funding under the Regional Partnerships Program). The extent and nature of the information sought through these proformas from project proponents was sufficient and appropriate to provide the basis for informed departmental assessments and advice to the then Parliamentary Secretary on the nature of the project and any attendant risks that might require management. However, information was not sought from project proponents on the intended benefits or outcomes from their respective projects.
Departmental advice on the merits of individual projects
24. Since December 2007, the enhanced grants administration framework has required departments to provide advice to Ministers on the merits of each grant application relative to the guidelines for the program. This approach does not affect a Minister's right to decide on the allocation of grants but is designed to ensure that where Ministers elect to assume a decision-making role in relation to the award of grants, they are well-informed of the departmental assessment of the merits of grant applications and suitably briefed on any other relevant considerations. In this context, guidance to agencies from the Department of Finance and Deregulation is that:
- an important consideration is whether the decision-maker has marshalled sufficient information to make a defensible decision. In this context, FMA Regulation 9 obligates a decision-maker to undertake reasonable inquiries so as to form a view about the merits of a spending proposal; and
- FMA Regulation 12 requires that a written record be made both of the terms of the grant and the basis for the approval.
25. Individual project assessment briefings were submitted to the Parliamentary Secretary for funding consideration once the department was satisfied it was sufficiently well informed about the project and any risks to project implementation. Briefings were finalised and provided over an extended period (between November 2008 and June 2010). The delays were the result of some project proponents being unable to readily provide the department with all necessary information for assessment, and/or because the project announced as an election commitment was not yet well developed. In each instance, the department recommended that funding be approved, although it was relatively common for this to be subject to certain conditions so as to address project implementation risks that had been identified by the departmental risk assessment.
26. In this context, there were three key elements to the department's advice to the relevant Parliamentary Secretary as to whether funding should be approved, as follows:
- consideration as to whether the project was eligible to be funded;
- a risk analysis of each project; and
- a statement as to whether the department considered that, based on the information provided by the project proponent, the provision of funding for the project represented an efficient and effective use of public money.
27. The department's advice to the then Parliamentary Secretary on project risks was supported in each brief with an attached table summarising the identified risks and proposed risk management strategies. However, the departmental briefing material did not identify the basis on which the proposed grant had been assessed by the department as representing an efficient and effective use of public money. The department has advised ANAO that it accepts that refinements are required to its assessment approach so as to satisfy the enhanced grants administration framework.
28. Departments providing decision-makers with a documented assessment of each proposed grant in terms of the program selection criteria assists the decision-maker to meet their obligation to record the basis on which they were satisfied that a proposed grant should be approved. In this respect, the absence of any assessments to support the advice to the Parliamentary Secretary that projects represented efficient and effective use of public money was particularly apparent with respect to those projects allocated to the Better Regions Program that had previously been assessed under the Regional Partnerships Program. There was an important similarity in the project assessment arrangements for both the Regional Partnerships Program and the Better Regions Program in that under both programs projects were assessed in isolation to one another rather than eligible applications competing for a quantum of available funding. However, whereas the Better Regions Program Guidelines did not include any assessment criteria, the published Guidelines for the Regional Partnerships Program had identified assessment criteria which were sound and appropriate to a regional grant program.
29. Further, in assessing project proposals under the Better Regions Program that related to earlier applications to the Regional Partnerships Program, the department did not address how any concerns identified in respect to value for money for previous unsuccessful applications to the former program had been addressed such that awarding a grant for the same project under the Better Regions Program represented an efficient and effective use of public money. The department has informed ANAO that, in retrospect, additional information could have been provided in individual project assessments and recommendations to inform the Minister and assist in recording the basis of approving a spending proposal. This is particularly important for projects which had previously been assessed as being not suitable for funding under other Commonwealth grants programs.
Project and program delivery
30. The extent to which the commitments made in the context of an election campaign relate to well developed and substantiated project proposals can vary extensively. This has been reflected in the Better Regions Program such that, whilst most of the announced election commitments are proceeding in whole or part under a signed Funding Agreement:
- in four instances, a Funding Agreement has not been signed and consideration has or is being given to withdrawing the offer of funding; and
- departmental tracking of project progress indicated that, as of September 2010, only 35 projects (33 per cent) had been completed.
31. In this context, most of the risks identified by the department during the assessment of project proposals had related to questions about whether the projects were sufficiently planned, designed (where relevant), costed and approved to proceed in a timely manner. As noted in ANAO Audit Report No. 3 2010–11, it is not feasible for all project risks to be managed in a cost-effective manner through Funding Agreements, particularly in circumstances where significant amounts of the grant are paid upon signing of the Funding Agreement. In particular, some risks are more cost-effectively managed prior to a Funding Agreement being signed or prior to any payments being made to the project proponent. These principles were reflected in the department's administration of the Better Regions Program, as follows:
- for 26 of the 77 projects with one or more implementation risks identified, the department proposed, and the relevant Parliamentary Secretary agreed, that at least some of the risks needed to be managed during the Funding Agreement negotiations; and
- for 75 of the 77 projects with one or more implementation risks identified, the department proposed, and the relevant Parliamentary Secretary agreed, that one or more risks needed to be addressed through the Funding Agreement prior to any funding being paid.
32. In developing strategies for paying approved grants to funding recipients, care needs to be taken to ensure that the strategy adopted for the payment of approved funds appropriately safeguards the public money and promotes achievement of the agency's obligation to make proper use of Commonwealth resources. For the Better Regions Program, there were no instances where a payment was based on the signing of the Funding Agreement (as had been the case in previous ANAO audits of regional grant programs). Further, except in instances where the project had sufficiently progressed in line with contracted milestones, there were no Funding Agreements that involved a payment being made within the same month as signing of the Funding Agreement. Rather, the department endeavoured to structure milestone payments under each Funding Agreement to reflect actual project progress.
33. Effective procedures were developed for the department to monitor proponent progress with implementing contracted projects. Because of delays with various projects, the department's approach to managing risk by linking Program payments to project progress has meant that there have been delays in Program expenditure compared to the budget expenditure profile. As a result, as of November 2010, the department expected that potential delays in construction in relation to 32 projects may require a movement of funds of up to $31.34 million to enable those projects to complete in 2011–12.
34. A copy of the proposed report was provided to RA, the Department of Infrastructure and Transport, and relevant Ministerial decision-makers since the Program was introduced. Relevant extracts of the proposed report were also provided to various project proponents mentioned in the proposed report. Written comments were provided by some project proponents, and they have been incorporated as appropriate in the report.
35. Summary comments received by RA on the proposed report are reproduced below, with the full response included in Appendix 1 to the report:
The Department agrees with the ANAO's recommendation and other findings which will be taken into consideration in the development and implementation of guidelines and program management arrangements for future programs.
The Department notes the acknowledgement by the ANAO that overall the Better Regions program was effectively designed and has been well administered. The Department also acknowledges further refinements to the assessment process and subsequent advice to the Minister is required for future programs on the efficient and effective use of public money.
 This project was able to be included because two of the projects originally allocated to the Better Regions Program within the funding of $176.03 million had been approved and contracted under the Regional Partnerships Program such that the cost of these projects did not need to be met from the Better Regions Program appropriation.
 In this report, ANAO refers to DITRDLG in relation to administration of the Better Regions Program during the period that department was responsible for the Program and to RA in respect to administration of the Program from 14 September 2010 onwards.
 The Hon. Gary Gray MP, Member for Brand, was the Parliamentary Secretary for Regional Development and Northern Australia from 3 December 2007 to 9 June 2009. From 9 June 2009, the then Member for Bennelong, the Hon. Maxine McKew, was the Parliamentary Secretary for Infrastructure, Transport, Regional Development and Local Government. Since 14 September 2010, Better Regions Program funding decisions have been the responsibility of the Minister for Regional Australia, Regional Development and Local Government, the Hon. Simon Crean MP (the Minister).
 In the context of the Better Regions Program, the departmental assessment of project eligibility considered whether the project was included on the list of election commitments allocated to the Program. In advising as to whether funding should be approved for individual projects, the department also provided advice to the relevant Parliamentary Secretary as to whether the project submitted by the proponent was consistent with the intent of the announced election commitment.
 For grant programs, relevant policies of the Commonwealth include the Commonwealth Grant Guidelines (CGGs) and the published guidelines for the particular program. In providing advice to the relevant Parliamentary Secretary as to whether funding should be approved in relation to individual projects, the department provided a clear statement as to whether it considered the spending proposal represented efficient and effective use of public money.
 On 15 November 2007, the ANAO completed a performance audit of the Regional Partnerships Program. The audit made 19 recommendations to improve departmental procedures and practices, and to encourage further attention to aspects of the programs administration, in the interests of improving transparency and accountability. A further recommendation was directed at enhancing the existing framework governing the expenditure of public money, including through discretionary grant programs such as the Regional Partnerships Program. (ANAO Audit Report No. 14 2007–2008, The Regional Partnerships Program, Canberra, 15 November 2007, Volume 1—Summary and Recommendations, Canberra, 15 November 2007, p. 31.)
 Mr Peter Grant PSM, Strategic Review of the Administration of Australian Government Grant Programs, 31 July 2008.
 This requirement was originally introduced through Finance Minister's Instructions issued in December 2007, which stipulated that Ministers should not make any decisions on discretionary grants without first receiving departmental advice on the merits of the grant application relative to the guidelines for that grants program.
 Department of Finance and Deregulation, Commonwealth Grant Guidelines—Policies and Principles for Grants Administration, Financial Management Guidance No. 23, July 2009, paragraph 3.19.
 As noted at footnote 5, for grant programs, relevant policies of the Commonwealth include the Commonwealth Grant Guidelines and the published guidelines for the particular program.
 Since 1 July 2009, the enhanced grants administration framework has required decision-makers to record the basis upon which they were satisfied that a proposed grant represents proper use of public money. Prior to that date, the recording of reasons for decisions was recognised as better practice but was not a statutory requirement.
 Identifying through the departmental briefing material the basis on which each proposed grant had been assessed by the department as representing an efficient and effective use of public money would have been aided had the published Guidelines outlined the criteria that would be applied to inform the department's assessment and had information been specifically sought from proponents on the expected benefits or outcomes of their project (so as to inform an assessment of whether the project represented value for money).
 Where Ministers or other decision-makers agree with the agency funding recommendation, they are able to point to the agency assessment and advice as representing the reasonable inquiries they have made as required by FMA Regulation 9, so long as:
they are satisfied that the assessment was conducted with rigour and in accordance with the program guidelines; and
the inquiries that were undertaken by the department, and the reasons why the department has concluded that the spending proposal represents a proper use of public money, are recorded in the advice.
 ANAO Better Practice Guide, Implementing Better Practice Grants Administration, Canberra, June 2010, p. 56.
 The cost of funding projects allocated to the Better Regions Program was offset by the incoming Government not proceeding to establish the Growing Regions Program. The establishment of the Growing Regions Program had been announced prior to the 2007 General election but the Parliament had not appropriated any funds to this program prior to the change of government.
 ANAO Better Practice Guide, Implementing Better Practice Grants Administration, op. cit., p. 100.
 The level of detail sought from proponents varied depending on the perceived potential risk of the project, with that risk evaluation being based on the level of Better Regions Program funding being sought: one proforma was developed for projects seeking up to $50 000; another proforma was developed for those projects seeking between $50 001 and $250 000; and a third proforma was developed for those projects seeing more than $250 000 in Better Regions funding.
 Obtaining information of that nature is important because, in assessing whether a proposed grant represents efficient and effective use of public money, it is necessary to examine the likely or intended outcomes of a project in light of the amount of funding being sought.
 Strategic Review of the Administration of Australian Government Grant Programs, op. cit., p. 7.
 Department of Finance and Deregulation, Finance Circular 2009/05, Commitments to spend public money (FMA Regulations 7 to 13), 29 June 2009, pp. 9–12.
 See footnote 13.
 Two projects that had been the subject of ALP election commitments during the 2007 election campaign which had been subsequently allocated to the Better Regions Program for administration were later found to have a Regional Partnerships Program Funding Agreement signed prior to the Better Regions Program being established. Accordingly, project assessments were only required in relation to 104 of the 106 projects allocated to the Better Regions Program.
 ANAO Audit Report No.14 2007–08, Volume 1—Summary and Recommendations, op. cit., p. 21.
 As noted at paragraph 6, it was intended that the Better Regions Program be designed and administered in a way that was consistent with (amongst other things) the recommendations from the ANAO audit of the Regional Partnerships program.
 In one instance, one component of the project has been contracted but the more significant component has not yet been contracted.
 ANAO Audit Report No.3 2010–11, The Establishment, Implementation and Administration of the Strategic Projects Component of the Regional and Local Community Infrastructure Program, Canberra, 27 July 2010, pp. 41 and 140.