I hereby give notice that an ordinary meeting of the Hibiscus and Bays Local Board will be held on:

 

Date:                      

Time:

Meeting Room:

Venue:

 

Wednesday, 15 March 2017

4.30pm

Local Board Office
2 Glen Road
Browns Bay

 

Hibiscus and Bays Local Board

 

OPEN ADDENDUM AGENDA

 

 

 

MEMBERSHIP

 

Chairperson

Julia Parfitt, JP

 

Deputy Chairperson

Janet Fitzgerald, JP

 

Members

Chris Bettany

 

 

David Cooper

 

 

Gary Holmes

 

 

Caitlin Watson

 

 

Vicki Watson

 

 

Mike Williamson

 

 

(Quorum 4 members)

 

 

 

Vivienne Sullivan

Local Board Democracy Advisor

 

13 March 2017

 

Contact Telephone: (09) 427 3317

Email: vivienne.sullivan@aucklandcouncil.govt.nz

Website: www.aucklandcouncil.govt.nz

 

 

 


Hibiscus and Bays Local Board

15 March 2017

 

 

ITEM   TABLE OF CONTENTS                                                                                        PAGE

  

26        Project 17 Auckland Council Maintenance Contracts                                              5   

PUBLIC EXCLUDED

Procedural motion to exclude the public                                                                              95

26        Project 17 Auckland Council Maintenance Contracts

e.      Supplier Specific Information                                                                           95

h.      Contract Information                                                                                         95  

    


Hibiscus and Bays Local Board

15 March 2017

 

 

Project 17 Auckland Council Maintenance Contracts

 

File No.: CP2017/03410

 

  

 

Purpose

1.       To seek feedback from local boards on maintenance contracts for parks, buildings and open space, prior to Finance and Performance Committee approval on 28 March 2017. 

Executive summary

2.       Auckland Council manages over 5,000 sites across the region including parks, buildings and open space. Existing Auckland Council maintenance contracts for these sites expire on 30 June 2017. 

3.       Project 17 was setup to procure and implement new maintenance contracts due to take effect 1 July 2017.  This includes Full Facilities, Arboriculture and Ecological services across the Auckland Council region.

4.       Over the last twelve months, Community Facilities has engaged with elected members through both formal and informal processes, to shape up the direction of this project and seek feedback on maintenance requirements and service levels.  Refer to Attachment A for the Political Engagement Timeline.

5.       Elected member feedback, including local priorities, informed the Request for Proposal document which was the basis of negotiation with suppliers.  Refer to Attachment B for this local board’s resolutions dated September 2016.

6.       This report outlines the following documents which will form part of final maintenance contracts and standard service levels:

·      Attachment C                   Standard and Enhanced Assets

·      Attachment D                    Full Facilities Contract Service Specifications

·      Attachment E                    Supplier Specific Information (CONFIDENTIAL)

·      Attachment F                    Contractor Performance Balanced Scorecard

·      Attachment G                  Tupuna Maunga Values Specifications

·      Attachment H                    Contract Information (CONFIDENTIAL)

7.       Community Facilities seek feedback from local boards on Attachments C, D and E, prior to Finance and Performance Committee approval on 28 March 2017.

 

Recommendation/s

That the Hibiscus and Bays Local Board:

a)      Provides feedback on:

·      Standard and Enhanced Assets (Attachment Three)

·      Full Facilities Contract Service Specifications (Attachment Four)

·      Supplier Specific Information (Attachment Five) (CONFIDENTIAL)

b)      Notes that the local board will have the opportunity to meet successful suppliers in April and May to discuss and refine local service level variations.

 

 

Comments

Process

8.       Over the last twelve months, Community Facilities has engaged with elected members through both formal and informal processes, to shape up the direction of this project and seek feedback on maintenance requirements and service levels

9.       Refer to Attachment A for the Political Engagement Timeline. 

10.     An open, competitive tender process seeking proposals for the supply of full facilities, arboriculture and ecological maintenance services of council assets was conducted as follows:

·      On 10 August 2016, an Expression of Interest was published to identify market interest in providing maintenance services for buildings, parks and open spaces to Auckland Council.  Thirty-six Expressions of Interest were received.

·      Formal feedback from local boards on the project approach and proposed service specifications was received in September 2016.  

·      Feedback was also sought from local boards on the list of assets in their area, used as the basis of asset data in the Request for Proposal. 

·      Refer to Attachment B for this local board’s resolutions.

·      Feedback was used to inform the Request for Proposal document which was released on 28 October 2016 and submissions closed 9 January 2017.

·      Submissions were assessed and scored by an evaluation team against weighted criteria including methodology, resources and capability, innovation and SMART procurement, and price.

·      Negotiations are now underway with shortlisted suppliers, due for completion 10 March.

·      Recommended contracts for five areas across the region, including pricing and baseline service levels, will be presented to the Finance and Performance Committee on 28 March 2017 for final approval.

11.     Community Facilities seek feedback from local boards on Attachments C, D and E, prior to Finance and Performance Committee approval on 28 March 2017.

 

Approach

12.     Following a review last year of management and maintenance processes of council’s assets, this project has adopted an improved approach to maintenance services, to:

·      focus on the whole-of-life cycle of assets;

·      deliver more services without compromising quality;

·      encourage and incentivise contractors to be accountable for the assets and develop ownership at all levels of their service delivery;

·      provide a contractual framework that enables contractors to employ innovate ideas and methods without compromising on quality delivery; and


 

·      implement five new contract areas (called Tahi, Rua, Toru, Whā, Rima) to allow for better economies of scale.  The local boards represented within each area are:

Contract Area

Tahi

Rua

Toru

Whā

Rima

Devonport-Takapuna

Hibiscus & Bays

Kaipātiki

Upper Harbour

Albert-Eden

Great Barrier

Puketāpapa

Waiheke

Whau

Henderson-Massey

Rodney

Waitākere Ranges

Howick

Maungakiekie-Tāmaki

Orākei

Waitematā

Franklin

Māngere-Ōtāhuhu

Manurewa

Ōtara-Papatoetoe

Papakura

 

13.     A key change is that contracts will have a more outcome-based focus on service levels, as opposed to predictive or frequency based maintenance schedules (unless where necessary).  This ensures service standards are consistently maintained and managed by suppliers.

14.     A standard maintenance service level is applied to every asset to ensure it is fit for purpose, in good condition and achieves community outcomes.

15.     Where an asset may have specific known demands such as high frequency use, high reputational risk, requires attendance due to its nature (e.g. old, troublesome asset) or is a heritage site, an enhanced level of service may be applied to the asset. 

16.     An enhanced service level should not be confused with poor performance from a supplier to provide the agreed standard service level.

17.     Refer to Attachment B outlining the updated asset list (including those requiring an enhanced service level) for this local board area as at March 2017.  Please note that this asset list is continually reviewed to ensure up to date data in alignment to council decisions and asset assessments.

18.     Maintenance contracts have been negotiated to cover three core functions across the five areas:

·      Full Facilities

·      Specialist Arboriculture

·      Specialist Ecological

19.     Council may immediately terminate (or suspend the supplier’s performance of) the contract in whole or in part, by written notice to the supplier, if a persistent performance breach occurs.   Please refer to the Contractor Management section in this report for further details.

20.     Refer to Attachment H (confidential) for further information about contract terms and Attachment E (confidential) for supplier specific information. 

 

Standard Service Levels

Full Facilities Contract (FFC)

21.     Service specifications determine the criteria and outcomes associated with maintaining an asset or facility, which then sets the foundation of a contract agreement.

22.     Refer to Attachment D for the Service Specifications expected across the Auckland region for Full Facilities maintenance work.  In summary, these are service level output statements by category:

 

Full Facilities Category

Output Statement

Open Space

Parks, reserves and roadsides within Auckland are maintained and developed to provide a sustainable, safe, clean and healthy environment while assets are maintained and enhanced to meet the amenity and use needs of council, Auckland residents and visitors.

Arboriculture

 

Trees (under three metres in height) are maintained to an aesthetically pleasing state which promotes healthy growth with the tree adding to the resident or visitors experience with targeted maintenance activities to achieve healthy and safe trees.

Locking and Unlocking

Assets are actively managed to minimise vandalism and anti-social behavior

Buildings - Maintenance

All Auckland Council owned and/or operated facilities require on-going Planned and Response Maintenance (compliance and non-compliance) to ensure that all facilities provided for public and Auckland Council staff use are functional, fit-for-purpose, safe and where possible ensure that the building services are optimised to reduce disruption to the facilities operation.

Buildings –
Cleaning

All Auckland Council owned and/or operated buildings that require planned and response cleaning shall be cleaned to a standard that allows all buildings users to utilise a sanitary, hygienic, safe, functional and fit for purpose space for their operation. All litter and debris shall be removed from site and done so in a sustainable manner.

 

23.     Standard Operating Procedures have been developed to agree minimal functional requirements such as height of grass mowing, mulching thickness, goal post painting etc.  These procedures have been developed through expertise knowledge and are operational in nature.  

24.     Minor Capital Works (low value, low risk) is included in these contracts to ensure appropriate mitigation measures are incorporated when maintaining assets.

25.     The baseline service level for specialist sportsfield maintenance ensures sports playing surfaces are managed to provide surfaces and assets that are ‘fit for use’ for the type and level of sport being played and which maximise usage and support organised sporting activities.

26.     Specialist sportsfield renovation work includes:

·      Fertilisation, application, fertilisers

·      Winter Treatment - cambridge rolling, slicing and spiking, solid tine vertidraining, ground breaking , vibramoling

·      Summer - vertimowing, dethatching, organic matter removal, leaf collection, scarifying/ dethatching, coring/hollow tine, core harvesting, undersowing/oversowing, sand topdressing, soil topdressing, vibramoling, mole plough, verti-draining, ground probe aeration, weed control, weed control (couch), agrichemical controls on sportsfields, top planing

·      Turfing – turf replacement (minor)

·      Artificial - cleaning, rubber top-ups, grooming, repair, hygiene

·      Supply bulk supply materials - eg sand, soil, seed, agrichemicals, turf (winter and summer species), fertilizer

·      Renovation works programme development

·      Note that the Full Facilities contract incorporates sports mowing, line marking, goal posts/furniture, soil and/or tissue sample analysis, grass selection, pest and disease detection, minor turf repairs, renovation works programme report, cricket

27.     Sportsfield renovations seasonally renovate surfaces back into condition for subsequent sporting code use, including renewal of surfaces that have reached their life span, or reinstating an asset that has been damaged through excessive overuse.

28.     Sportsfield renovations are collaboratively implemented to complement maintenance activities in the contract.

29.     When asset components are replaced (e.g. turf type), the same style and material type is supplied, unless otherwise directed by Auckland Council.

 

Arboriculture Specialist Contract

30.     The scope of the arboriculture contract covers the management of council owned trees i.e. it’s ‘urban forest and rural surrounds’

31.     The arboriculture contract includes, but is not limited to, the following services:

·      General administration and communication

·      Inspections and programmes

·      Pruning

·      Reactive works

·      Clean-up

·      Tree removal

·      Planting

·      Aftercare maintenance

·      Tree asset inventory

32.     The arboriculture contract will be managed as a prescriptive measure and value contract, but may shift to output basis through the term of the contract. Work will be managed on both a scheduled and reactive basis.

33.     Auckland Council will retain ownership of all chipped bio-mass (foliage, brushwood and wood) resulting from Arboriculture Specialist contracts. 

34.     It will be expected that the supplier takes a proactive approach in relation to council’s assets, including those not directly related to the contract’s scope. This will involve reporting any faults or issues, regardless of asset ownership in a timely manner e.g. reporting a vandalised bus shelter (Auckland Transport) next to a street garden.

35.     The management of Kauri Dieback and weeds are incorporated into Standard Operating Procedures included in the Arboriculture Specialist contract.

 

Ecological Specialist Contract

36.     The ecological contract provides for the maintenance of Auckland Council’s high value ecology sites, and significant bush and natural areas. The prioritised targeted removal of animal and plant pests from council’s open spaces is a core service within this contract. The overarching objective is to restore and rehabilitate native biodiversity in a sustainable and long term approach.

37.     The scope of the ecological contract includes:

·      preparing ecological restoration plans that take a long term perspective and provide the optimum cost effective management to reinstate the ecological processes, so the site environmental values are conserved and enhanced.

·      assessing, monitoring and controlling pests impacting the ecological processes and or values at each site. This includes but is not limited to plant, animal and invertebrate pests.

·      restorative planting of sites

38.     The supplier is required to have all vehicles to carry a web based Global Positioning System tracking system.  This enables reports to be produced on journey length and stay.

39.     The ecological contract is supplemented by an Ecological and Environmental Pest Control Standard Operating Procedure which provides guidance to methodologies and site-specific requirements.

40.     The supplier is required to report any hazardous dumping to Auckland Council’s Pollution Hot Line immediately

 

Other Maintenance Priorities

SMART Procurement

41.     The following SMART procurement outcomes are requirements outlined in maintenance contracts:

·      Increase capability and capacity – suppliers are required to create sustainable businesses that provide training and development to ensure continued quality delivery of services over the term of the contract.

·      Youth employment - contracts should facilitate connecting work-ready youth to local employment by creating local jobs with training and development opportunities.

·      Diversity and inclusion - contracts should promote inclusion, reduce discrimination and remove barriers to opportunity and participation, particularly for disadvantaged groups who face barriers to employment e.g. long term unemployed, and people with disabilities.

·      Valuing Māori - suppliers are required to work collaboratively with council to achieve better outcomes with Māori, by supporting skill development and labour market participation, and engagement with Māori owned businesses.

·      Pacific Auckland - contracts should support further training, development and labour market participation for Pacific youth and communities.

·      Local community and economy - contracts should support local business where reasonable/practical, and should meet the social needs of the delivery area.

42.     Contracts have retained flexibility to remove assets (by contract variation) to facilitate active participation by the third sector/volunteers to deliver maintenance outcomes.

43.     Suppliers (and subcontractors) are required to establish, document, implement, maintain and continually improve an environmental management system. This will capture practices such as an environmental policy, environmental impacts of significance, legal requirements, environmental objectives and targets.  At a mimimum the management system will monitor and measure energy conservation, water conservation, waste management and recycling, chemical use, Scope 1 and Scope 2 Greenhouse gas (GHG) emissions.

44.     Suppliers are proposed to annually reduce the carbon footprint from year two onwards.

45.     The environmental management system must be certified by an accredited third party to the standard of ISO14001, EcoWarranty, Enviro-Mark or an agreed-upon alternative programme. Where the supplier has certified to the Enviro-Mark programme they will commit to attaining the highest level of certification, Enviro-Mark Diamond.

46.     Please refer to Attachment E (Confidential) for further supplier specific information.

 

Weed Management

47.     A memorandum from Barry Potter, Director Infrastructure and Environmental Services, was circulated to local board members on 15 November 2016 regarding weed management.  A second memorandum was circulated to all elected members on 16 December 2016 providing an update on the implementation of Auckland Council’s Weed Management Policy, particularly with regards to this project. 

48.     New maintenance contracts have been designed to reflect the objectives of Auckland Council’s Weed Management Policy which includes implementing the following changes:

49.     What will change?

o   Minimise agrichemical use

§  The new contracts require a reduction in agrichemical usage and this will be closely monitored - a 10% penalty of the monthly invoice to the supplier will be applied if the ‘annual reduction in use of agrichemicals’ Key Performance Indicator (KPI) is not met. 

§  Chemical usage will be reported monthly by suppliers and tracked on a local park by local park basis.  Please refer to the Contract Management section in this report for further information on reporting, auditing and KPI’s. 

§  Contracts will standardise which type of glysophate will be used across the region by all suppliers.

§  Manual and mechanical weed control methods are currently used in and around children’s playgrounds across the region.  Agrichemicals are not used within these spaces. This will continue under new contracts.

§  Mechanical edging will be applied along paving and other hard edges. 

o   Integrated weed management, ensure best practice and value for money

§  The volume of mulch in gardens and garden beds will be increased to reduce other methods of weed control

§  Change from frequency based maintenance contracts to a focus on environmental outcomes, to encourage suppliers to be more innovative in their approach to weed management and edge control

§  Learnings from innovations will be socialized across all suppliers to promote continuous improvement and best practice methodology

§  Suppliers will be encouraged and rewarded for innovation in weed management at quarterly supplier forums

§  Development of a weed management manual which is currently being reviewed by the Best Practice Reference Group.

§  Establishment of the Best Practice Reference Group made up of external technical experts and community representatives as per the policy action plan.

§  A No-Spray Register will be used by suppliers to ensure consistency in practice and process.

o   Empower the community to manage weeds in accordance with the policy

§  Weed control programmes in ecological restoration contracts will be planned and agreed in advance of the works. 

§  Targeted weed control, including the use of volunteers, will be enabled to ensure that agrichemical usage is minimized and integrated with other sustainable practices such as replanting with eco-sourced species to prevent weed re-infestation.

§  Contracts include supplier inductions and training on public awareness of vegetation controls, including herbicides and the importance of public education, including signage when spraying.

§  Improved information on council’s website outlining how and why council controls weeds.

50.     At the 13 December 2016 Finance and Performance Committee meeting, the following resolutions relating to weed management were approved:

o   An addition to recommend to the Environment and Community Committee as follows:

a)      Note that significant funding reallocations are not within the scope of the Annual Plan process

b)      Endorse glysophate reduction targets within the current budget

c)      Express support for the continued implementation of the Weed Management Policy

d)      Agree that a political group be appointed by the Mayor, monitors and reviews the implementation of Auckland Council’s Weed Management Policy and practice

e)      Recommend that a review and consultation of allocated funding take place through the upcoming Long-term Plan process

o   Resolution d) reshapes the weed management political advisory group

 

Co-Governance

51.     As pre-agreed with co-governance partners, suppliers submitted a detailed report and costings on how they would manage and provide specific services to the Tūpuna Maunga Authority and / or Parakai Recreation Reserve in their preferred areas. 

52.     This report is being socialised with leaders and representatives from co-governance entities with the outcome being determined at the end of March 2017 with either of the following options being the preferred solution:

·    Maintain the status quo

·    Offer maintenance services to the supplier in the specific area

·    Offer maintenance services to only one supplier who would be accountable for all outcomes.

53.     Whenua Rangatira (Bastion Point) – no change proposed to current maintenance agreements where iwi are responsible for managing this site

 

Community Empowerment

54.     Local boards expressed strong support to enable community empowerment including volunteers, through these contracts.

55.     Contracts have the flexibility to accommodate contract variations such as community empowerment initiatives, however compliance with Health and Safety, legislative obligations, agreed service levels and operating procedures are critical in these cases.

56.     Local boards should work with their strategic brokers (within the Arts, Community and Events team) to identify requirements and opportunities, who will then liaise with Community Facilities to agree and implement suitable solutions.

 

Contract Management

Contractor performance

57.     KPI’s measure how well the supplier is doing to meet specifications and outcomes. KPI’s cover five categories:

o   quality

o   innovation

o   management

o   Smart procurement and environmental management

o   stakeholder, customer and community impact

58.     Health and Safety (H&S) is a contractual obligation.

59.     KPI’s are measured monthly, bi-monthly, quarterly or annually.

60.     Suppliers are required to meet Full Facilities Key Performance Indicators (KPI’s) and Minor Capital Work KPI’s to have their level of direct award for Minor Capital Works increased, as an incentive for good performance.

61.     For each category component failed, suppliers must provide an improvement plan to resolve the performance issue.

62.     If a supplier continues to fail on a category component beyond the performance resolution improvement plan deadline, council will be entitled to withhold payment of 10% of each month's invoices (excluding minor capex) until the supplier starts meeting the category component target.

63.     Suppliers have the right to earn back withheld payments relating to category components if they start meeting required target levels by a timeframe set by council.

64.     Attachment F outlines the Contractor Performance Balanced Scorecard that will be monitored and applied across the region.

Auditing

65.     Auditing of contractor performance was previously conducted by external parties.  However, this function is now being conducted internally by Community Facilities.  A team of auditors conduct spot checks onsite targeting 10% of all maintenance work conducted by each supplier.

Response maintenance

66.     Response maintenance work will be categorised by urgency and a maximum response time determined.  Criteria is still under negotiation and agreement for some suppliers.

67.     The supplier will undertake programmed maintenance, responsive maintenance and all other minor contract works (including emergency works on an as needs basis only) on Monday to Sunday, restricting noisy and any activities that may cause a nuisance to between the hours of:

o   7:00am and  6:00pm (52 weeks of the year); and

o   10:00am and 6:00pm (Saturdays and Sundays and statutory holidays).

68.     The supplier will provide a call out service 24 hours, 7 days a week, carried out as part of normal duties.

69.     Following completion of response maintenance work, the supplier will call the customer (between 8:00am and 6:00pm unless otherwise stated), to inform them that works have been undertaken and check that the customer is satisfied.

70.     It is expected that suppliers assist with ‘whole of life’ asset management which requires the supplier to assess and make recommendations on the optimal most cost effective balance of programmed maintenance, responsive maintenance, and renewal of assets across their whole life.

71.     Suppliers are required to update a condition assessment grading once a maintenance service has been undertaken, to be included in council’s asset management system, and to notify council of any significant degradation.

Consideration

Local board views and implications

72.     Project 17 has engaged with local boards through various channels including:

o   Local Board Chairs Procurement Working Group;

o   Local Board Chairs Forum presentations;

o   memorandums;

o   cluster workshops;

o   individual local board workshops; and

o   business meeting reports.

73.     Refer to Attachment A outlining the political engagement timeline.

74.     Community Facilities is now seeking feedback from local boards during the final stage of this procurement process, prior to Finance and Performance Committee approval of contracts.

Māori impact statement

75.     Auckland Council is committed to meeting its responsibilities under Te Tiriti o Waitangi/the Treaty of Waitangi and its broader statutory obligations to Māori.

76.     Māori responsiveness requires the collective effort of everyone. Under the new contracts, suppliers will work collaboratively with council to achieve better outcomes with Māori and for Auckland. This will include:

o   Building positive relationships with Māori – effective communication and engagement with Māori, developing resilient relationships with mana whenua;

o   Significantly lift Māori social and economic well-being; and

o   Building Māori capability and capacity.

77.     Through these contracts, opportunities to support local community outcomes and economic development include (but are not limited to):

o   Providing employment opportunities, in particular for local people and for youth;

o   Increasing capability and capacity (apprenticeships, cadetships or equivalent) in particular for youth;

o    Building on community and volunteer networks.

78.     The Request for Proposal outlined Tūpuna Maunga Value Specifications as outlined in Attachment G, which suppliers are required to support as part of new maintenance contracts. 

Implementation

79.     The transition into new contracts will commence once formal approval is agreed by the Finance and Performance Committee.

80.     Local boards will have the opportunity to meet new suppliers in April and May 2017 to discuss specific local priorities. Any local service level variations may need to be reflected in contract variations and implementation timelines agreed with the supplier.

81.     New maintenance contracts take effect on 1July 2017. Note that there will be approximately six to twelve months to bed in changes, in particularly systems and reporting.

 

 

Attachments

No.

Title

Page

a

Political Engagement Timeline

17

b

Local Board Resolution (September 2016)

19

c

Standard and Enhanced Assets

25

d

FFC Service Specifications

35

e

Supplier Specific Information (Under Separate Cover) - Confidential

 

f

Contractor Performance Balanced Scorecard

87

g

Tupuna Maunga Values Specifications

91

h

Contract Information (Under Separate Cover) - Confidential

 

      

Signatories

Authors

Kate Marsh - Financial Planning Manager - Local Boards

Authorisers

Rod Sheridan - General Manager Community Facilities

Karen Lyons - General Manager Local Board Services

 


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Hibiscus and Bays Local Board

15 March 2017

 

 

Exclusion of the Public: Local Government Official Information and Meetings Act 1987

 

That the Hibiscus and Bays Local Board:

a)      exclude the public from the following part(s) of the proceedings of this meeting.

The general subject of each matter to be considered while the public is excluded, the reason for passing this resolution in relation to each matter, and the specific grounds under section 48(1) of the Local Government Official Information and Meetings Act 1987 for the passing of this resolution follows.

 

26        Project 17 Auckland Council Maintenance Contracts - Attachment e - Supplier Specific Information and Attachment H – Contract Information

Reason for passing this resolution in relation to each matter

Particular interest(s) protected (where applicable)

Ground(s) under section 48(1) for the passing of this resolution

The public conduct of the part of the meeting would be likely to result in the disclosure of information for which good reason for withholding exists under section 7.

s7(2)(c)(i) - The withholding of the information is necessary to protect information which is subject to an obligation of confidence or which any person has been or could be compelled to provide under the authority of any enactment, where the making available of the information would be likely to prejudice the supply of similar information or information from the same source and it is in the public interest that such information should continue to be supplied.

In particular, the report contains sensitive commecial information and the negotiations of the process are ongoing.

s48(1)(a)

The public conduct of the part of the meeting would be likely to result in the disclosure of information for which good reason for withholding exists under section 7.