Introduction

1. The Regional Development Australia Fund (RDAF) was established in early 2011 as a nationally competitive, merit-based grants program with discrete funding rounds. A total of some $1 billion¹ is expected to be available under the RDAF over six years. The RDAF was one of the initiatives established to deliver on the Government's 7 September 2010 agreement with the Independent Members for Lyne and New England.

2. At the time it was established, the program objective was to fund projects that support the infrastructure needs and economic and community growth of Australia’s regions. This objective was revised in November 2011 for the second funding round, and is now ‘to support the economic, environmental and community needs of Australia’s regions by providing funding for projects that meet the identified priorities of regional communities, as articulated in RDA regional plans’.

3. To date, two application rounds have been conducted, with nearly $350 million in program funding awarded to 81 projects. Three more funding rounds are proposed. The focus of this audit report is the first funding round, completed in September 2011, through which 35 projects were awarded funding of $149.65 million.

Administration and implementation of the first RDAF funding round

4. The RDAF is administered by the Department of Regional Australia, Local Government, Arts and Sport (Regional Australia). The Minister for Regional Australia announced a public call for applications to the first $100 million funding round on 11 March 2011, with applications closing during May 2011. Subsequently, the Government decided to increase the funding available in this round to $150 million.
5. Local government bodies and incorporated not-for-profit organisations were eligible to apply for funding under the first round. Applicants could request between $500 000 and $25 million from the RDAF towards projects that were predominately capital in nature. Applications were expected to include written endorsement from the relevant Regional Development Australia (RDA) committee confirming that the project aligned to the relevant regional plan.

6. Regional Australia received 553 applications, seeking total funding of over $2 billion. The applications covered a range of projects, diverse in both size and nature. The total estimated cost of the projects ranged from $502 385 to $400 million, at an average total estimated cost of $10.2 million. Projects were most commonly categorised as providing social and cultural infrastructure (39 per cent) followed by recreation facilities (22 per cent).

7. Regional Australia was responsible for checking each application for compliance with the mandatory requirements for funding. It assessed that 348 applications (63 per cent) received were ineligible. An independent advisory panel, appointed by the Minister for Regional Australia, was then responsible for assessing the relative merits of the eligible applications and for providing funding recommendations to the Minister.

8. Consistent with the program guidelines, the advisory panel categorised the 204 eligible applications² as either ‘Recommended for Funding’, ‘Suitable for Funding’³ (which it divided into two priority groups) or ‘Not Recommended for Funding’. The panel recommended that the 25 eligible applications in the Recommended for Funding category be approved for funding at a cost of up to $134.98 million.

9. On 5 September 2011, the Minister awarded a total of $149.65 million in RDAF funding to 35 applications, which included 21 of those recommended by the panel (see Table S1). Regional Australia negotiated funding agreements with the successful applicants and provided feedback to the unsuccessful applicants.

Table S1 Advisory panel categorisation and ranking of applications, and related Ministerial funding decisions

Audit objectives, criteria and scope

10. The objective of the audit was to assess the effectiveness of Regional Australia’s management of the design and implementation of the first application round of the RDAF program. The audit examined:

• whether the design of the program reflected lessons learned from audits of previous grant programs⁴ and the requirements of the grants administration framework that was progressively implemented between December 2007 and July 2009;
• whether the business practices of Regional Australia met policy and legislative requirements as well as accountability responsibilities, including those set out in the Financial Management and Accountability Regulations 1997 and Commonwealth Grant Guidelines (CGGs);
• whether the assessment of possible projects was undertaken in accordance with the published program guidelines;
• the process by which projects were ranked and subsequently approved for funding; and
  the process by which funding agreements were developed and executed with successful applicants, and feedback was provided to unsuccessful applicants.

Overall conclusion

11. The establishment of a new infrastructure program to fund projects identified by Regional Development Australia committees in regional areas was one of the initiatives established to deliver on the Government's September 2010 agreement with the Independent Members for Lyne and New England. The program was to fund projects that support the infrastructure needs and economic and community growth of Australia’s regions.

12. Through the first Regional Development Australia Fund (RDAF) funding round, nearly $150 million was awarded to 35 projects predominantly located in regional Australia. Funding agreements have been signed in respect to each approved project, with these agreements specifying partner contributions to the projects totalling some $248 million (or $1.66 in contributions from other sources for each $1 of RDAF funding). Each funding agreement included a contracted project completion date, the last of which is June 2016.

13. Overall, in assisting the Government to deliver on its commitment to establish a new regional grants program, Regional Australia’s management of the design and implementation of the first RDAF funding round was effective. This included improvements in the approach taken to briefing the Minister to inform his funding decisions, particularly by identifying to the Minister those applications the RDAF advisory panel had recommended be approved. That said, the department’s advice to the Minister suggested that the Minister could consider approving more projects than those recommended by the panel, but without outlining to the Minister a structured process for this to occur in a way that was consistent with the published program guidelines.

14. Regional Australia has invested resources into analysing the recommendations of previous Parliamentary Committee and ANAO reports to improve the program design and delivery arrangements. Of note, particularly in the context of shortcomings observed in audits of predecessor programs and the requirements of the grants administration framework, was that eligibility and assessment criteria were developed, published and applied to inform the decision about which applications should be awarded funding. In addition, the department provided all unsuccessful applicants with feedback on their applications, and took steps to identify and implement improvements to the application processes for the second funding round.

15. Improvements in the quality of Regional Australia’s assessment work were also evident, although there remains scope to improve the assessment of whether eligible applications represent value for money. There would also be benefits from a more robust rating system being adopted to record the assessment of each eligible application’s performance against the published merit assessment criteria, providing a stronger link between the detailed assessment of each application and the final order of merit.

16. As was intended by the design of the program, the advisory panel injected external expertise into the merit assessment process. All applications assessed by Regional Australia as eligible were examined by the panel. Consistent with the program guidelines, the panel categorised each eligible application as either Recommended for Funding, Suitable for Funding or Not Recommended for Funding. Through this process, the panel also developed an order of merit and provided the Minister with a clear funding recommendation for those 25 projects that it considered should be approved for total RDAF funding of up to $135 million. The Minister approved 21 of those applications, and recorded his reasons for not approving the other four recommended projects. The recorded reasons related to the regional distribution of funding across the program and the regional benefits associated with urban projects.

17. The Minister also approved 14 projects from the Suitable for Funding category—the panel had not recommended that funding be awarded to any projects in that category. Regional Australia had suggested to the Minister that funding could be awarded to projects in addition to those categorised by the panel as Recommended for Funding. However, the department did not advise the Minister of the importance of his decisions having regard to the published assessment criteria—including the expectation that the recorded reasons for approving such applications address any limitations identified with these applications in terms of the criteria and in comparison to more highly ranked applications that are not approved for funding.

18. Regional Australia did advise the Minister that he would need to record his reasons for approving any projects that the panel had not included in the list of 25 recommended projects, and report such instances to the Finance Minister⁵. The Minister provided his reasons for approving a project he selected from the Suitable for Funding—Priority Two category. The Minister then worked through the panel’s Suitable for Funding—Priority One order of merit list. He approved 13 of these projects, and recorded his reasons for not approving nine of the projects⁶ , until the available $150 million in funding was exhausted. However, reflecting the shortcomings in the departmental advice referred to in paragraph 17, the various reasons recorded by the Minister focused on the Minister being satisfied with the regional distribution of funding across the program and with the regional benefits associated with urban projects but did not directly relate to the published program criteria.

19. This latest audit of a regional grant funding program indicates that the grants administration framework now in place is soundly structured to achieve outcomes consistent with program objectives, as well as promote decision-making processes that satisfy the requirements of the financial management legislation. Given their particular experiences and areas of expertise, the framework recognises that departments, advisory panels (where they are in place) and Ministers will at times have different perspectives on the relative merits of candidates for grant funding. In such circumstances, there is an important role for departments to advise Ministers on the steps to be followed where the Minister reaches a different conclusion about the relative merits of grant proposals (in terms of the published assessment criteria⁷ ) from that recommended to them.

20. Recognising that further RDAF funding rounds are proposed, the ANAO has made three recommendations. These recommendations are focused on further improving key elements of Regional Australia’s application assessment and approval processes.

Key findings by chapter

Access to the program (Chapter 2)

21. Regional Australia had estimated it would receive between 500 and 700 applications for RDAF funding under the first round. In total, 553 applications were received, at the lower end of the expected range.

22. Applications were to be lodged online via Regional Australia’s grant management system portal. However, significant issues arose with the use of this portal, making it difficult for applicants to lodge their applications. In this context, following the conclusion of the first application round, the department sought to identify lessons that could be learned from the application lodgment process. In light of stakeholder feedback, changes have been made to the application process for the second RDAF funding round.

23. Eligibility requirements for the first round of RDAF were set out across the program guidelines, a related Frequently Asked Questions (FAQ) document published on Regional Australia’s website as well as in the application form⁸. Regional Australia checked the eligibility of each application received against the eligibility criteria. Only those applications assessed as eligible progressed to the next stage of the assessment process.

24. Of the 553 applications that were recorded as having been received, 348 (63 per cent) were assessed by Regional Australia as ineligible. Compared to other applications-based competitive grant programs (including for community infrastructure) examined by ANAO, this was a high rate of ineligibility. It was also considerably higher than the department had estimated during the program planning phase, which was that around 20 per cent of all RDAF applications would be ineligible.⁹ This situation does not reflect well on the accessibility of the program to applicants.¹⁰

Departmental assessment of eligible applications (Chapter 3)

25. Assessment criteria were developed and published in the program guidelines. Regional Australia assessed eligible applications in terms of:

• risk, including the extent of any risks to the proposed project being delivered and sustained;
• the extent to which the project was aligned with the regional plan for the relevant RDA committee; and
• the extent to which the application met the published merit criteria, to assist the advisory panel (which was responsible for the final merit assessment of each eligible application).

26. Regional Australia undertook the assessment work to assist the advisory panel. There were few instances where the panel records indicated it had a different view as to the extent to which an application met one or more of the assessment criteria. For future funding rounds, the assessment process would be strengthened if:

• the rating scale that is used differentiated more effectively between individual projects and classes of projects so as to enable a clearer link between the final ranking of eligible applications and the underlying assessment of each application in terms of the published merit assessment criteria¹¹ ; and
• more comprehensive advice was provided to decision-makers on the extent to which eligible applications represent value for money, particularly in circumstances where they are assessed as not meeting one or more of the published assessment criteria.¹²

Advisory panel deliberations (Chapter 4)

27. The role of the advisory panel was to consider the relative merits of projects based on its assessment against the published assessment criteria so as to provide funding recommendations to the Minister.

28. The panel brought external expertise to the assessment process and outcomes, using the initial assessment of the merits of the 204 applications prepared by Regional Australia as a starting point. The panel’s assessment proceeded in the following three stages:

• separating the eligible applications into two categories—those that did not merit further consideration (categorised as Not Recommended for Funding (NRF)) and those that were suitable candidates for possible funding (categorised as Suitable for Funding (SFF));
• adopting a scoring approach to identify the most meritorious of the SFF applications for further consideration; and
• ranking the 64 applications that had been allocated the highest scores to produce a preliminary order of merit.

29. The panel categorised 25 applications as Recommended for Funding, 117 applications as Suitable for Funding (divided into two groups called Priority One and Priority Two) and 62 applications as Not Recommended for Funding. The applications categorised as Recommended for Funding and Suitable for Funding—Priority One were individually ranked by the panel in an order of merit. In the absence of additional explanation, it would be expected that there would be a reasonably strong correlation between an application’s position on the final order of merit list and the outcome of the assessment of that application against the published criteria. However, there was not a clear and consistent correlation between an application’s position on the panel’s final order of merit list and the documented assessment of each application against the selection criteria.¹³ Nevertheless, the approach taken enabled the panel to provide a clear funding recommendation to the Minister.

30. Regional Australia assisted the panel by providing a range of documentation and other support so that it could make informed judgments about the competing merits of each eligible application. However, other aspects of the administrative support for the panel could have been improved. In particular, there was an extensive delay in the minutes from the August 2011 advisory panel meetings¹⁴ being finalised and approved by the panel, and the minutes lack sufficient detail to provide evidence of the panel’s assessment of each application against the merit criteria and the related categorisation and ranking of competing applications.¹⁵ The department has advised ANAO that the minutes for the second funding round were finalised in a timely manner and that the content of the minutes for forthcoming rounds will reflect ANAO feedback, including recording the reasons for assessment decisions.

Advice to the minister and funding decisions (Chapter 5)

31. The panel provided the Minister for Regional Australia with a clear funding recommendation for his consideration. Specifically, it recommended that the 25 projects in the Recommended for Funding category be approved at a cost of up to $134.98 million. It further recommended to the Minister that Regional Australia negotiate with three applicants that had sought more than $10 million to reduce the Australian Government contribution where possible. The panel estimated that this would reduce the funding needed for the recommended 25 projects from $134.98 million to $126.18 million. The panel did not propose that any additional projects be funded with the amount remaining from the $150 million.

32. However, Regional Australia’s advice to the Minister differed from that provided by the panel. In particular, the department advised the Minister that the available funding enabled him to accommodate all of the panel’s recommendations as well as draw additional projects from the ‘Suitable for Funding’ list. The department did not advise the Minister of the basis on which it had determined that such a course would be open to the Minister, having regard to the selection process set out in the program guidelines and the conclusion reached by the panel that not all of the available funding for the first round should be awarded. Nor did the department identify the basis on which it was proposing that the Minister should select the additional projects from within the Suitable for Funding category (which comprised two distinct groupings).

33. In light of Regional Australia’s advice, 14 of the 35 projects approved by the Minister had been selected from the Suitable for Funding category. Consequently, a feature of the projects approved for funding was that a relatively high proportion (40 per cent) had not been recommended for approval by the panel, and the total amount of RDAF funding approved ($149.65 million) was 19 per cent higher than the amount the panel had proposed be awarded.

34. Reflecting the different experiences and expertise brought to bear by those responsible for assessing proposed grants and Ministerial decision-makers, the financial framework applying to grants decision-making recognises that different conclusions can legitimately be drawn from any given set of information and evidence, and accordingly it is open to a Minister to reach a decision different from that recommended in an agency’s advice. However, in respect to all grant funding decisions, the financial framework also requires that the basis for the decision be recorded. In this context, where the assessment advice provided to the Minister has identified relative shortcomings against one or more of the published assessment criteria, compliance with the framework necessitates that the recorded basis of the funding decisions outlines how the decision-maker arrived at a different view as to the performance of the relevant application against these criteria (and, in the context of a competitive grant program, how that compares to that of competing applications).¹⁶

35. The Minister approved 21 of the 25 projects recommended for funding and recorded individual reasons for not approving the other four of these recommended projects. The Minister also approved one project from the Suitable for Funding—Priority Two category at this time, and recorded his reason for approving it.¹⁷ However, the recorded reason did not outline how (in terms of the published assessment criteria) it had been identified as more meritorious than the other 40 projects that were ranked equally, or the 76 projects that were ranked more highly, by the panel in the Suitable for Funding categories.

36. The Minister then considered the 39 projects in the Suitable for Funding—Priority One category by working through them in order of merit. The Minister approved 13 projects, recorded individual reasons for not approving nine projects¹⁸ , and recorded the reason ‘funds exhausted’ in reference to the remaining 17 projects. Reflecting that Regional Australia had not advised the Minister on how such selections should be made, including clearly relating any such decisions to the comparative merits of competing applications in terms of the published assessment criteria, the recorded reasons did not directly relate to the published program criteria. Rather, they focused on the Minister being satisfied with the regional distribution of funding across the program and with the regional benefits associated with urban projects.

37. In addition to recording the basis for grant approval decisions, the CGGs require that Ministers provide an annual report to the Finance Minister by 31 March of each year outlining all instances for the preceding calendar year where they had awarded a grant that the agency had recommended be rejected. Regional Australia’s advice had outlined that the approval of any projects other than the 25 projects that had been included by the panel in the Recommended for Funding category would require reporting to the Finance Minister. However, the report for the 2011 calendar year prepared by Regional Australia and sent by the Minister to the Finance Minister in February 2012 in relation to the approval of grants that the agency advice had recommended be rejected did not identify the 14 decisions taken in relation to the first round of the RDAF. In July 2012, Regional Australia advised ANAO that it has prepared a brief to the Minister, and draft correspondence from the Minister to the Finance Minister, so as to report these 14 decisions to the Finance Minister.

Funding distribution, feedback to applicants and signing of funding agreements (Chapter 6)

38. Most of the funding awarded under the first round of RDAF was for projects located in regional Australia. However, projects located in major cities were eligible to apply for funding and, accordingly, eight of the projects approved were located in major cities.¹⁹ The proportion of projects located in regional Australia that were approved for funding was consistent (both in terms of the number of applications and the quantum of funding) with the proportion of applications received.

39. In terms of electoral distribution, applications for projects located in an electorate held by the ALP were more successful. That is, projects located in ALP-held electorates had an approval rate of 22 per cent, compared with the approval rate of 14 per cent for projects located in an electorate held by the Coalition parties or Independent Members. In large part, this outcome was because projects located in ALP-held electorates were more highly represented in the panel’s funding recommendations to the Minister.²⁰

40. The details of all 35 projects funded under the first round were published within a single media release on 7 September 2011, which was two days after the grants were approved. This approach avoided any perception that the timing of announcements was being used for party-political purposes. It also allowed applicants to seek alternative funding sources as soon as possible where their application was unsuccessful, or to proceed toward project implementation where they were successful. However, there were subsequent delays with project implementation because of delays with the finalisation of funding agreements with a significant number of the successful applicants. The funding agreements were signed over the period 13 December 2011 to 23 May 2012.

41. During the funding agreement negotiations, the partnership contributions were reviewed. The result was that the value of the partnership contributions differed from that specified in the application, and in subsequent advice to the advisory panel and the Minister, for 18 of the projects. Based on the signed funding agreements, RDAF funding totalled $149.2 million and the partner contributions totalled $247.8 million. Therefore, for every $1 of RDAF funding there was $1.66 contributed by other sources.

42. All unsuccessful applicants were given written feedback on their application and offered the opportunity to obtain more detailed verbal feedback. There was also an opportunity for stakeholders to provide both verbal and written feedback to Regional Australia and the panel on their experiences with round one. The feedback received was used to inform the design of the second round.

Summary of agency response to the proposed audit report

43. The proposed audit report was provided to Regional Australia, the Minister for Regional Australia and the chair of the RDAF advisory panel for comment. Regional Australia provided the following summary response with the full response included at Appendix 1:

The Department of Regional Australia, Local Government, Arts and Sport has adopted a continuous improvement approach to the management of its grants programs. As such, I appreciate the ANAO’s acknowledgement that the Department has effectively managed the design and implementation of the first round of RDAF, and that the Department has invested resources into analysing previous ANAO reports to improve the design and delivery of the program. I also appreciate the ANAO’s confirmation that a sound grants administration framework is in place, which supports both the achievement of program outcomes and decision-making processes that satisfy the requirements of grants management legislation.

The Department notes that it conducts its own review of programs at the conclusion of each round, and has incorporated the findings of those reviews in the design and delivery of RDAF. In addition, the Department has sought to implement the recommendations from previous ANAO reports in the establishment and delivery of Round One of RDAF. The Department has used early advice from the ANAO on Round One to improve and refine the delivery of Round Two. Recommendations in this Audit Report will be adopted in Round Three and subsequent rounds.

Footnotes

¹ The 2012–13 Budget Papers disclosed administered expenses for RDAF of $974 million between 2011–12 and 2016–17 (source: Regional Australia, Regional Development, Local Government, Arts and Sports portfolio, Portfolio Budget Statements 2012–13, Budget Related Paper 1.16, p. 35).

² There were 205 applications assessed as eligible and, as one of these was subsequently withdrawn by the applicant, 204 were provided to the panel for consideration.

³ The program guidelines for the first round of the RDAF outlined that any projects categorised as ‘Suitable for Funding’ would not be recommended for approval by the panel, but could be re-submitted for consideration at subsequent meetings of the panel. Accordingly, and consistent with the panel’s decision to only recommend for funding approval those 25 projects included in the Recommended for Funding category, Regional Australia’s briefing to its Minister had outlined that any projects in the Suitable for Funding category that were approved for funding would need to be reported to the Finance Minister (the Commonwealth Grant Guidelines require that an annual report be provided to the Finance Minister identifying all decisions to approve a particular grant which the agency has recommended be rejected).

 ⁴ In particular, the Strategic Projects Component of the Regional and Local Community Infrastructure Program. See further in 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 and Joint Committee of Public Accounts and Audit, Report 423: Review of Auditor-General’s Reports Nos 39 2009–10 to 15 2010–11, Canberra, July 2011.

⁵ Since January 2009, Ministers have been required to provide an annual report to the Finance Minister outlining all decisions to approve a particular grant which the agency has recommended be rejected. This report is to be provided by 31 March each year for the preceding calendar year and is to include a brief statement of the basis of the approval for each grant.

⁶ The documented reasons related to the Minister’s concerns about not funding too many projects in one geographical area (referred to by the Minister as ‘distributional impact’) or insufficient ‘broader regional impact’ for various projects that were in an urban, inner urban or peri urban location.

⁷ In an audit of a predecessor regional grant funding program, the ANAO concluded that potential applicants and other stakeholders may reasonably expect that grant program funding decisions will be made in a manner, and on a basis, that is consistent with the published guidelines. Subsequently, the Government commissioned a strategic review of grants administration. The report of that review similarly concluded that ‘potential applicants and other stakeholders have a right to expect that program funding decisions will be made in a manner, and on a basis, consistent with the published program guidelines and selection documentation’ and that, in situations where the Ministerial decision differs from that recommended, ‘special care will be needed in order to demonstrate that the relevant program guidelines and selection criteria have been observed, that all grant applicants have been treated fairly, and that the requirements of the financial framework have been met’. As a result of the recommendations made by that review, the Commonwealth Grant Guidelines that came into effect on 1 July 2009 outline that the program guidelines for a grant program are a policy of the Commonwealth that must be considered before any funding decision is made under the particular program.

⁸ Some eligibility requirements were amended and/or clarified after the program opened to applications.

 ⁹ Rather than assessing between 400 and 560 eligible applications as had been anticipated, the panel only had to assess 204 applications.

¹⁰ The factor that made the most significant contribution to the high number of applications that were ineligible was that the program guidelines and related program documentation did not provide sufficiently clear and consistent guidance to applicants on the various threshold requirements that needed to be satisfied in order to be assessed as eligible.

¹¹ As outlined in ANAO Better Practice Guide, Implementing Better Practice Grants Administration, June 2010, pp. 65–66 and p. 75, numerical rating scales have a number of advantages in differentiating effectively between individual projects and classes of projects. Consistent with this, ANAO’s recent audits of grants programs across a number of agencies have shown a trend towards greater use of numerical scoring systems.

¹² For the first RDAF funding round, only those applications assessed as ineligible were considered by Regional Australia to not represent value for money. In this respect, Regional Australia advised its Minister that applications the panel was not recommending for funding still represented value for money notwithstanding that a significant number of these had been assessed as Poorly Developed against one or more assessment criteria (and, in some case, with a high level of associated project risk).

¹³ For example, some applications assessed as meeting to a high standard most or all of the published criteria were categorised and ranked lower than other applications where the documented assessment indicated that they were less meritorious in terms of the published criteria. The reasons for the ranking awarded each application by the advisory panel were not recorded in the meeting minutes.

¹⁴ The panel convened over seven days during August 2011 to assess the eligible applications and determine its recommendations, which were finalised on 1 September 2011. The minutes were not finalised until April 2012.

¹⁵ For example, the scores developed in the third stage of the assessment process were not recorded in the meeting minutes even though they provided a key input to the panel’s final categorisation and ranking of eligible applications. Similarly, adjustments made to the ranking and scoring of applications (some of which were significant) and the related reasons for these adjustments were not recorded in the meeting minutes. The meeting minutes also did not contain the final order of merit list nor explain the process for categorising applications as Suitable for Funding—Priority One and Suitable for Funding—Priority Two.

 ¹⁶ Alternatively, it might be possible for a decision-maker to waive one or more criteria but the CGGs outline that, in the interests of transparency, accountability and equity, grant guidelines should document the circumstances in which the eligibility and assessment criteria set out in grant guidelines may be waived. The RDAF program guidelines did not permit any of the assessment criteria to be waived.

¹⁷ The Minister recorded that his decision to approve funding for both the new Geelong Library and Heritage Centre (the highest ranked project located in the Geelong region, which the panel had recommended for approval) and stage 3 of the Geelong Football Club’s Skilled Stadium redevelopment was ‘based on my knowledge and advice as well as its strong business case and the leveraged funds for both the library and football proposals and further given the distributional impact of both projects’.

¹⁸ See footnote 6.

¹⁹ In accordance with the government’s spatial reporting framework, regional Australia is defined as being all of Australia except for areas classified as Major Cities under the Australian Bureau of Statistics Australian Standard Geographic Classification Remoteness Structure.

²⁰ Applicants were required to specify the electorate in which the project was located. However, while the information provided to the panel and the Minister identified the location of each project as well as the relevant RDA committee, it did not specify the Federal electorate. Regional Australia has advised ANAO that at no time during the assessment process, panel discussions or in advice to the Minister was any analysis or discussion about electorates undertaken.