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Tackling Legionella at the source
Neil Brown, Technical Director, Hygiene Group
Legionnaire’s disease is a potentially fatal infection, normally contracted by inhaling fine water droplets containing legionella pneumophila, causing a localised infection in the lungs.
Legionella protects itself from the body’s other natural defences by hiding within macrophages - white blood cells that normally attack invading bacteria. This allows it to grow quickly, with severe untreated infections causing pneumonia.
Most people do not develop Legionnaire’s disease, but around 12% of identified cases are fatal. However, if identified quickly enough, Legionnaire’s disease can be treated effectively with antibiotics.
Like any organism, legionella needs food, warmth and somewhere to live, and water systems can offer all of these. Any equipment producing a fine spray or aerosol adds an extra bonus – it allows the bacterium to travel.
It is a legal requirement for water system operators to keep them clean and demonstrate they have been treated with suitable disinfectants. This is usually required every six months, with an L8 certificate – referring to the HSE legionella control code of practice – issued by the cleaning contractor.
The employer is responsible for identifying and assessing the risk of exposure to legionella bacteria from work activities and water systems and defining any precautionary measures. In conducting this assessment, competent help should be sought.
Ideally, a survey of all water systems should be undertaken, to include an asset register of associated plant, pumps, strainers and other water handling equipment, with up-to-date drawings or diagrams. It can then be determined which components present a potential risk.
Employers should consult employees on measures and actions taken to control any risks identified.
If the assessment shows a foreseeable risk, the employer should appoint someone to take managerial responsibility and provide supervision for the implementation of precautions. This individual should know the potential sources of risk; immediate measures to be adopted, and measures to ensure controls remain effective.
Where it is impossible to avoid using systems posing the risk, a written scheme for controlling it should be implemented. This should include precautions to be taken, checks to ensure the control scheme’s efficacy, and planned remedial action if the scheme is found to be ineffective.
The findings of the risk assessment, the written scheme, and the results of any monitoring, inspection, tests or checks undertaken, with dates, should be included in records which should be retained and regularly updated.
Water systems with an identified risk should be regularly drained, flushed out and disinfected.
Management of cooling towers
The warm environment and high organic debris levels that can accumulate in cooling towers are ideal for rapid bacterial growth. A build-up of biofilm will also encourage growth of Legionella bacteria. The correct biocidal treatment regime will ensure bacterial populations remain under control.
The ‘fill’ – the trellis-type layers which permit air transfer but minimise the risk of water droplets escaping - must be removed and thoroughly cleaned and disinfected, while the tower’s insides must be cleaned and disinfected.
Treatment success depends on the compatibility of all chemical components used, and adherence to recommended application, monitoring and control procedures. However, it must be remembered that an operating cooling system is subject to unpredictable recontamination both by legionella and sources of nutrients. Regular microbiological testing will ensure the biocide programme remains effective. The tower’s operations manual should include a detailed maintenance schedule listing time intervals when system plant and water should be checked, inspected, overhauled or cleaned.
A typical cooling system requires weekly inspection for damage and soiling, and chemical checks of circulating water to monitor pH, hardness, temperature and the oxidising biocide level. It also requires weekly micro-checks to monitor general microbiological growth. A quarterly Legionella check is required, with a thorough clean of the tower interior, sump and fill twice yearly. Each check must be meticulously logged, allowing observation of any trends to promote better tower and risk management, while proving the operator has discharged his legal duties.
For other water systems, temperature control, chlorine dioxide treatment, ionisation, and ozone and UV treatment can all contribute to reducing the risk of legionella build-up. All water services should be routinely checked for temperature, water demand, cleanliness and use.
An annual check should comprise visual inspection of water storage tanks; recording water consumption to ensure water is not stagnating; checking hot and cold water circuit plans to ensure they are current; ensuring operation and maintenance schedules are readily available and updated; and checking all water connections to outside services.
Microbiological monitoring should also take place in the form of samples from both cold and hot water systems, carried out by a UKAS accredited laboratory participating in the PHLS Water Microbiology External Quality Assessment Scheme for the Isolation of Legionella from Water. Remedial action is needed if legionella bacteria reach more than 100 cfu/litre. However, this is unlikely if proper management systems exist. Indeed, simple cleaning and maintenance regimes, and consultation with an expert on chemical use and certification, will ensure this never becomes a major issue.

Rent-a-roof versus self-funded panel installation
By Mark Gordon, Surveying Manager and Lead Consultant, Pennington Choices
How does each option work ?
Self funding is on the face of it very simple. For a small programme, which could be one installation, the property owner might choose to finance it with cash (savings). Indeed with interest rates on savings and other ‘low risk’ investments so low, using spare cash to fund PV installation and then collecting the FiTs that are generated from it, represent very good investment rates of return. However for the majority of larger programmes, there will be a need to borrow the sums required to finance a programme of installations. In such circumstances, with lending costs around 4-5%, this still represents a viable option, with typical PV installations giving overall returns in the order of 10% per year.
Rent-a-Roof is a mechanism to facilitate funding of the upfront installation by a third party.  Typically an institutional or individual investor, will provide the funds necessary to undertake the installation. In return the investor will receive the large majority of the FiT proceeds. This is established legally by the property owner granting a lease to the investor for the roof space, upon which the installation is then fitted.  While investors of this type will typically be looking for returns in excess of other relatively low risk investments such as corporate bonds or government gilts (long term government gilts provide a return of approximately 4% as at May 2011), there is sufficient head room to still share a proportion of the FiT with the property owner.
Assessing Feasibility
The starting point for any property owner thinking of installing PV panels is to establish which properties are suitable, what the expected capital costs are and what revenue might be generated. For all but the smallest of property owners, the usual starting point is to undertake a desktop study where each property is assessed, via web based imagery such as Google Earth to determine the suitability of the property for a PV installation. This can then be validated by one site surveys. Not all properties will be suitable for a PV installation, principally due to inappropriate orientation. The financial feasibility of any particular installation is a reflection of the electricity that it will generate. This can be calculated for each property, by reference to:
            - The size of the proposed installation

            - The efficiency of the panels to be installed –
            different manufacturers quote different efficiency rates

            - The expected amount of daylight hours that a
            property should be exposed to over the course of a
            year. This can be determined by reference to sun
            tables which state the average hours of daylight that
            a property can expect to be exposed too, based on
            its location in the country. There is a significant
            difference in daylight and hence electricity produced
            between southern and northern locations, which of
            course affects the financial feasibility of installations.
            - The orientation of the property, relative to South.
A simple algorithm will then calculate the amount of electricity that a particular installation should produce and hence the overall ‘income’ that is derived, made up of three things:
            - The tariff paid for the generation of the electricity. This is
            measured via a meter, fitted as part of the installation.

            - The tariff paid for selling surplus electricity back to the grid.
            This is typically determined on a ‘deemed’ basis i.e. an
            assumption is made about the level of electricity that is provided
            back to the grid which is currently 50% for domestic
            installations.

            - The saving that the property occupier makes on using the
            generated electricity and hence avoids buying electricity from the
            market.
To complete the financial feasibility picture it would be usual to produce a long term cashflow forecast, which would include the initial cost of installation and the forecasted ‘income’ over (say) 30 years. The financial forecast will allow the property owner to:
            - Assess in cash terms the revenue that would be generated

            - Assess the ‘attractiveness’ of the return, relative to other
            investment options or uses for spare cash resources, in
            comparison to the risks (albeit relatively low) that are inherent in
            PV installations

            - Determine if, from an economic perspective, self funding or
            rent-a-roof might be the best option, or indeed a combination of
            the two.
While economic considerations will be paramount in the property owners decision making, there will be other considerations that need to be considered, including:
            - The availability of spare cash or the ability to borrow, to self
            fund a programme. Most commercial lenders will not accept the
            FiT payments as sufficient security for lending and will require
            other, tangible security. Even where the property owner has such
            security, the opportunity cost of using it for PV installation as
            compared to other business activities needs to be considered.
            - The potential practical consequences of giving a long term
            lease interest over the roof of the property, in the rent-a-roof
            option. While the lease will identify who has what rights and
            responsibilities, the involvement of a third party in the property
            will be an added complication, for example where major
            maintenance has to be done to the roof.
            - The potential impact on the value of the property. While most
            commentators think that it will be neutral, it’s too early to tell
            what potential purchasers will actually think. Clearly for
            properties which are sold regularly such as homes, this
            consideration will be more significant than for those which are
            owned and used in different ways such as commercial premises.
            - The potential impact on others with an interest in the
            property. Where the property is tenanted, the lease or tenancy
            agreement may need to be changed to facilitate granting a lease
            under the rent-a-roof option.

For Contract Catering in 2012 the only constant will be change
By Nick Parker, Managing Director, Bite Catering Ltd
We all experience business life becoming more and more complex with the passing of each month. At Bite Catering we have lot of compassion for the role of our FM client where the internal expectation on their role is increasing. It’s a job with considerable responsibility: maximising the efficiency of their company’s second most expensive asset – buildings - in order to maximise the output of their company’s most expensive asset - people. 
As responsible as the role is, our clients (usually FM’s) aren’t always given the all necessary information or tools to do the job that is asked of them. Therefore, at Bite, where we are entrusted to manage a small piece of the FM puzzle - using catering space and money to help get the most out of the company's employees - we had better demonstrate that we have the right tools to manage the changing world if we are to have the luxury of working for the client over the long term. 
Here we share with you the ‘thought’ tools that help us keep your costs under control in an environment where the only constant is change. 
Strive for 100% customer understanding.
From our side of the table there are two ‘customers’ to truly understand. These are:
- Customer 1: client company employees.
-- We typically find there are two main
       customer groups, buying two differing
       services:
--- using their cash to buy every day foods    
          through the restaurant;
--- using company money to ‘entertain’
          through hospitality services.
- Customer 2: the client organisation. The owner of the subsidy and the catering facilities. Their objective is as stated above: to buy food services that help get the most out of their employees.
To complicate matters further, and very necessarily, an important subset of Customer 2 is the day to day client themselves. At Bite we are acutely aware that our client has their own very specific needs. We had better get to understand these needs if we are to hope to satisfy them.
Therefore, if the caterer is to do a great job for you, our client, then we need your permission in implementing those initiatives that will allow us to understand all customers.
One recent and successful initiative for Bite has been the launch of a Food Diary. By handing out a quirky diary to volunteers to use to record their weekly eating habits, we discovered a group of health conscious customers who, despite there being healthy foods on offer, were bringing in their own food because the information we were providing at the point of sale was insufficient for them to be able to make healthy eating decisions. As a result of what we discovered through our Food Diary, we have a better understanding of what we need to do to win business from healthy eating customers.
Demand for quality - in everything, but starting with food
High quality food brings increased sales. In turn, increased sales brings reduced subsidies. Beware of actions that force your caterer to serve cheaper/inferior food. Challenge them to ensure there is no wastage of food and labour, but do everything to enable food quality to remain at high levels.
Here’s why a focus on food quality works, based on the economics of selling a handmade sandwich from a deli bar:
Be convinced that your caterer knows their numbers
- Does your cater know
- What are the specific sales quantities of all items?
- What are the poor sellers and great sellers?
- What the wastage is?
- What is the cost of a meal?
- What is the financial contribution from each food product type (ie the gross profit)?
To understand these numbers the caterer should be conducting a ‘Cost of Sales & GP Analysis’. In the current inflationary environment it is recommended that this is done twice a year.
In addition, does your caterer monitor:
- The number of transactions per service period (eg breakfast, lunch, coffee bar)?
- Spend per head of building population?
- Subsidy cost per head of building population?
We call this a ‘Usage Analysis’ and it should be done once or twice a year, depending on the degree of change and the current state of operational performance.
Create win/win (and lose/lose by implication) to force the caterer to do better
If your contract does not include a mechanic for the caterer to earn more income by doing a better job for you, then one of the following will apply:
1. You are having to put too much time in yourself to keep
     the caterer in check
2. You will not be getting a service that is constantly
     improving over time, however good it is now
3. The service is simply not as good as it could be
The specific mechanics to incentivise the caterer are varied and numerous. They include:
- Fees linked to sales, GP achievement or labour productivity
- Share of subsidy savings
- Fixed cost contracts, so long as there are escalators for
    inflation in those areas outside the caterer’s control, eg
    labour and food
Commensurately, the mechanics should create a lose situation for the caterer if a poor job is done.  It is important however that the upside is at least as attractive as the downside is unattractive.
Expect constant change: plan to deliver
It is a statement of fact that some legal contracts take too long to get signed because they are too long in form and by the time they have been passed by three internal departments, the service has had to change.  Keep them short by focussing on the few simple KPI’s & conditions that really matter. Get more accountability from the individual people who are committing to you.
Demand:
- Monthly reporting, for the simple day to day stuff
- Quarterly meetings, with appropriate senior catering management, to review the more
                problematic things, the strategic issues, business  changes, emergent from trends. etc.
Good luck

A little piece of “Haven”
Exciting design uses Accoya® wood for a sustainable house and boathouse in Norfolk
The Haven project in Horning, Norfolk, is the perfect example of the increasing trend for greener building. The new house and boathouse is a gracefully designed, sustainable replacement to the previous designs, perfectly complementing and enhancing the picturesque waterside village of Horning. Due to the extremely challenging high flood and moisture area of the Norfolk Broads, only Accoya wood would have the necessary long-lasting durability to meet the demands of the project. 
A unique design
The Accoya wood, supplied by International Timber ltd, was used for cladding decking and screening. Architects, Lambert, Scott and Innes modernised the design by creating a unique, curved, glue laminated rear screen; this was influenced by the marine character of Norfolk and is designed to resemble a traditional wooden boat construction. The Accoya screen was made in The Netherlands and was manufactured by Newham & Abel Ltd. It was coated with merbau – coloured Woodguard coating; the same finish was used for the cladding.
The entrance floor of the house is set at 1.3m above ground in order to avoid the flooding that is often prevalent in the area. Accoya wood is the only timber able to face the challenge of being exposed to such conditions without shrinkage and reduced performance. Accoya has been proven to outperform even the best tropical woods in these respects.
The distinctive boathouse, also covered in sustainable Accoya wood, is a fantastic addition to this riverside property. It is purposely designed to be set above the water level, allowing any flood water to flow safely through its base. It is a perfect and secure place to store a boat in any weather conditions.
An Eco-friendly building
The house is 60% more efficient than the current building regulations and achieves Level 4 of the Code for Sustainable Homes for Energy. The construction has a ground source heat pump producing 9.7kw; this pre-heats the water and underfloor heating installations for even more energy savings. The power for the house is gained from the Photo Voltaic Cells that provide 1.8kw of electricity, which is enough for the general running of the house. A distinctively designed green roof uses green sedum to further decrease the risk of flooding. The sedum absorbs rainwater reducing the amount that will fall to the ground. It also promotes biodiversity by providing a suitable habitat for wildlife. 
The Haven project demonstrates the versatility and extreme durability of Accoya, especially in such unconventional conditions. The beauty and flexibility of Accoya wood make this unique design both practical and graceful.
Accsys Technologies is an environmental science and technology company whose primary focus is on the production of Accoya® wood and technology licensing via its 100% owned subsidiary, Titan Wood Limited, which has manufacturing operations in Arnhem, the Netherlands, a European office in London and an American office in Dallas, Texas. Accsys operations comprise three principal business units: (i) the Accoya® wood production facility; (ii) technology development, focused on a programme of continuous improvements to the process engineering and operating protocols for the acetylation of wood which are currently under development and the development of technology for the acetylation of wood elements; and (iii) the licensing of technology for the production of Accoya® wood and Tricoya® wood elements across the globe.
Accoya® wood is produced using a process, the subject of patent applications around the world, that effectively converts sustainably grown softwoods and non-durable hardwoods into what is best described as a "high technology wood". Distinguished by its durability, dimensional stability and, perhaps most importantly of all, its reliability (in terms of consistency of both supply and quality), Accoya® wood is particularly suited to exterior applications where performance and appearance are valued. Unlike most tropical and European hardwoods, its colour does not degrade when exposed to ultraviolet light. Moreover, the Accoya® wood production process does not compromise the wood's strength or machinability. The combination of UV resistance, dimensional stability, durability and retained strength means that Accoya® wood offers a wealth of new opportunities to architects, designers and specifiers. For marine uses where weight is also important, Accoya® wood for the first time provides boat builders with a wood that is strong, lightweight, durable and retains its natural beauty for far longer. 
Wood Acetylation is a process which increases the amount of 'acetyl' molecules in wood, thereby changing its physical properties. The process protects wood from rot by making it "inedible" to most micro-organisms and insects, without - unlike conventional treatments - making it toxic. It also greatly reduces the wood's tendency to swell and shrink, making it less prone to cracking and ensuring that, when painted, it requires dramatically reduced maintenance.

Library of Birmingham’s Major Flagship Regeneration Project Reaches Key Milestone
The construction of the striking Library of Birmingham has recently moved a step closer toward completion, with EMCOR Group (UK) starting work on installing a full range of mechanical and electrical systems. EMCOR has been responsible for the design of all mechanical, electrical and plumbing systems for the new Library since starting work on the project in 2009 and is now on site commencing installation, as part of its £26m contract. The high profile city regeneration project will see one of the most important libraries in Europe built – expected to attract more than three million visitors a year.
The new 31,000 square metre glass, steel and concrete facility, which will tower over Centenary Square in the heart of Birmingham city centre, will include a new studio theatre, auditorium, study areas, exhibition space and stunning book rotunda. The Shakespeare Memorial Room situated on the upper most level of the building, which includes a viewing area providing spectacular views over the city, is also being relocated from the existing library building.
EMCOR is installing a number of environmental features that support the BREEAM Excellent rating such as grey water harvesting, natural ventilation systems, and efficient cooling via passive chilled beams fed from an open loop ground water extraction and reinsertion system from the aquifer located 150 metres below the streets of Birmingham.  Heating will be provided by a district heating system incorporated within the building, and includes a combined heating and power plant and absorption chillers designed to reduce carbon emissions.  In addition, climatic conditions for storage of the Library’s internationally important archives will be controlled to extremely specific temperatures and humidity.  Fire protection for these archives will also be provided by generating a hypoxic environment where oxygen levels are maintained below the level that supports fire but still high enough to ensure that operatives are able to work safely in the area. 
EMCOR has a long-standing relationship with Birmingham City Council, who manages the Library, and who are one of the first clients to benefit from the EMCOR UK Innovation Academy, which provides research and training facilities dedicated to developing the latest services and techniques. As part of the wider contract, Carillion is construction partner to Birmingham City Council for the Library of Birmingham.
The Library of Birmingham is a major flagship for the regeneration of the city, which will create 250 new construction jobs locally, including at least 25 apprenticeships. EMCOR has adopted a recruitment policy for the project, which encompasses signing up to a skills pledge to support the development of Birmingham’s young people, and is committed to recruiting 65 local candidates specifically from areas of higher unemployment.
John Matthews, EMCOR Engineering Services’ Managing Director commented: “We are absolutely delighted the project team are commencing work on site delivering what will be one of the most important libraries in Europe, which sees us building on our long-term partnership with Birmingham City Council to deliver this unique project. The Library of Birmingham will create an exceptional new learning and cultural space for decades to come.”
Councillor Mike Whitby, Leader of Birmingham City Council, said: “Despite the global economic slowdown, demand for and confidence in Birmingham has never been higher. The Library of Birmingham will be an iconic landmark, and a testament to the role Birmingham will play in the 21st century as a truly global city. The design is further evidence of our intention to attract world-class architects to work with the city of Birmingham, and supports our ambition to create a building which will bring people together, nurture creativity, allow far greater access to our cultural heritage, and act as a focal hub within the city and the region.”

Display Energy Certificates for all Public Buildings
Clause 22 of The Energy Bill
With the proposal of Clause 22 in The Energy Bill, Vicky Kenrick at International Sustainability Recruitment Consultancy, Allen & York explores the benefits of Display Energy Certificates (DEC) for all.
Introduced in 2008; Display Energy Certificates (DEC) were originally required in all public sector buildings/offices larger than 1000m2; that are frequently visited by the public. DECs were not made compulsory for private sector property.
The aim of the DEC is to display the rate of the operational energy efficiency and performance of a building, rating from A to G, they should be prominently displayed where all public visitors will be able to see them. There are large financial penalties for failure to display a DEC at all times, in a prominent place.  For example, a maximum fine of £5,000 may be imposed dependent on the nature of the breach of regulations.
With the government’s plan for delivering a low carbon construction and building services sector being broadly welcomed by the industry; the Low Carbon Construction Innovation and Growth Team (IGT), led by chief construction adviser Paul Morrell have proposed several recommendations to green construction.  One of which is to create an existing homes hub that will monitor and enforce the mandatory use of DECs in all public sector buildings, not just those that are larger than 1,000 m2.   In May 2011 Construction Minister, Mark Prisk, hinted that the government would back this recommendation and ensure DECs were rolled out. 
The UK Government target of an 80% cut in carbon emissions by 2050 (as outlined in The Climate Change Act 2008) has the full commitment of the independent Committee on Climate Change, who has suggested that we should be reaching the 50% point by 2025.
A barrier to the construction industry lowering their carbon emissions has been the issue of there not being a common method or rating system for the measurement of operational energy use in all non-domestic buildings: if you can’t measure it, you can’t manage it. 
DECs provide data on how a building is performing which is essential to allow the design and implementation of an effective energy reduction strategy. Savings of between 5 and 30% can be made through simple, low cost changes to the way a building is managed and occupied, and mandatory ratings based on actual energy use, are a crucial first step.
The Chartered Institution of Building Services Engineers (CIBSE) along with the UK Green Building Council supports the wider roll out of DEC.  CIBSE's Technical Director, Hywel Davies, states that “There is now a clear industry consensus around making more use of Display Energy Certificates to identify potential energy and cost savings”.
The Energy Bill, according to the Government, “has been designed to provide for a step change in the provision of energy efficiency measures to homes and businesses”. In order to achieve that aim, we need to know how much energy is being used in the first place.
A mandatory roll-out of DECs would address this in a way that would bring significant economic, as well as environmental, benefits.  In fact, some large property companies have chosen to carry out DECs on their buildings as part of their sustainability strategy and out of choice. These companies found that DECs can help provide them with information on which to base investment decisions.
The Energy Bill to recognise the benefits of DECs for all
DECs also provide a common methodology for measuring energy efficiency in buildings and could therefore also form the basis for monitoring other property-related policies, such as the Carbon Reduction Commitment and the Green Deal for Business and in the long term reducing the overall cost of compliance.
Corporations have championed the efforts of Conservative MP, Zac Goldsmith, to amend the Government’s Energy Bill. 
Goldsmith tabled a new clause, named clause 22 and published in June 2011, which would see all commercial buildings require Display Energy Certificates (DECs) - A-G ratings for energy performance - a requirement which currently only applied to public buildings of more than 1000m2.  Zac Goldsmith states his intentions of the new clause: “mandatory A to G ratings are the crucial first step in helping businesses understand how to reduce their energy use”.
Buildings are responsible for over 40% of the UK’s total carbon emissions, with non domestic buildings accounting for 17%.  In addition, it is estimated that 75% of the buildings that will exist in 2050 have already been built, which means that we must take action to improve energy efficiency and reduce carbon emission from existing buildings.
Whilst the carbon plan published in March 2001 includes a commitment to extend DECs to commercial buildings by October 2012, in order to fulfil that commitment the Energy Bill must be used to introduce the necessary enabling legislation, giving the Secretary of State the power to extend DECs through regulations.
The UK Green Building Council (UK-GBC) fears that if the Energy Bill is not used to introduce DECs they will not be adopted in time be able to reach the Government target, outlined in The Climate Change Act 2008, of reducing carbon emissions by 50% by 2025 and by 80% by 2050.
Paul King, Chief Executive of the UK Green Building Council supports clause 22 and said: “there is widespread business support for the extension of DECs to commercial buildings because they help companies save money on energy bills and they provide a level playing field for comparing the market. This is an ideal opportunity for Government to fulfil the commitment it gave in March.”
Going a step further, members of the UK property industry also support clause 22 and have asked for the Energy Bill to include legislation for the roll out of DECs for all buildings.
Commercial property agents Colliers International have also signed up to support the amendment to the Energy Bill. In addition, International Sustainability Recruitment Consultancy, Allen & York, who specialise in recruiting for the energy and building services industry also suggest that “rolling out DECs to all public buildings could provide better data on energy use in non-domestic buildings. This information enables better building management and results in energy, carbon and financial savings”. Nikki Clark, Senior Recruitment Consultant, Energy Management – Allen & York
To conclude, the roll out of DEC’s for all commercial buildings will aid the increase of workplace efficiency and cut carbon emissions – therefore making a significant step towards The Climate Change Act 2008 targets of a 50% reduction in carbon emissions by 2025.  
There is substantial business support for the roll out of clause 22 in The Energy Bill and in regards to the progress within government; a Report is initially required in order to draft legislation and procedures that will enable the roll out of DECs for all.