pricing | The Contracting Education Academy

February 22, 2012 By AMK

Is government procurement ready for the cloud?

Mention cloud computing to true believers and you’ll likely hear all about speed and agility. They’ll tell you that agencies can simply dial IT services up or down as needed to quickly support new mission plans or workload changes. As a bonus, agencies pay only for what they use instead of bankrolling the often idle, over-provisioned computing capacity common in most data centers.

Unfortunately, there’s a rub when it comes to the cloud. Many IT procurement practices and contracting vehicles were designed to help managers provision hardware and software, not on-demand services. Can the current acquisition practices translate easily to the dynamic world of cloud computing?

Not really, said Barry Brown, executive director of the Enterprise Data Management and Engineering Division at Customs and Border Protection. He echoed a view shared by others in the federal government. With cloud computing, “the technology delivery model has changed,” he said. “What has not changed is the procurement model.”

The methodology gap between procuring IT systems and procuring IT services has been intensifying in the past year, ever since former Federal CIO Vivek Kundra outlined the government’s cloud-first policy. That initiative seeks to reduce costs and increase IT acquisition flexibility by pushing federal IT systems to cloud environments. Each agency has until May to identify three IT resources that it will move to the cloud.

But the move is straining traditional procurement departments. Rather than promoting speed and agility, in some cases cloud initiatives are spawning extended contract negotiations and legal challenges that are making it take even longer for agencies to get the resources they need.

Not all the early obstacles are specific to the cloud, so they won’t be permanent. But other features that are essential parts of the cloud model will continue to present challenges. Technology executives will need to accommodate them with new procurement and vendor management practices if the switch to on-demand, utility computing is to succeed.

Stumbling blocks

Why do some experts believe that current procurement practices are ill-suited to the cloud? They point to four key challenges.

Challenge 1: Variable service levels

With the cloud model, IT managers can shop for new, on-demand services via online catalogs. That approach acknowledges that demands can change from month to month, or even more frequently.

“From a contracting perspective, that’s pretty tough to deal with,” said Wolf Tombe, chief technology officer at Customs and Border Protection. He contrasts that variability with contracts that designate the technologies purchased and specify the delivery date.

Challenge 2: Nonstandard terms of service

Backers of the cloud model promote economies of scale, whereby costs decline because multiple customers share common resources, such as a suite of office productivity software. But consultants say many agencies try to negotiate cloud contracts that have custom services, which slows the procurement process.

“Everybody thinks what they need is special,” said Michael Sorenson, director of cloud services at systems integrator QinetiQ North America. Some compare the approach to asking Microsoft to customize its Office suite before buying the product.

Challenge 3: A shifting landscape

Cloud providers bring additional uncertainties to service terms. In the past, when a software vendor revised a commercial package, agencies could choose to install the new features or stick with the existing version of the program. But cloud providers regularly revise their service offerings, and the changes automatically flow to all customers, whether they ask for them or not.

“This makes procurement uncomfortable because you cannot be sure what you buy today will be there tomorrow,” said Peter Gallagher, a partner in the Civilian Federal Systems group at Unisys. “The pace of change is more rapid than with [off-the-shelf software].”

Challenge 4: Pricing uncertainties

Some agencies struggle to determine whether a firm fixed-price or cost-plus approach delivers the most benefits in a cloud-computing contract. “The best procurement procedure we’ve seen is a firm fixed price, and then if there are any modifications to the core service — say, additional storage for an e-mail user — the agency will pay for it by the drink,” Sorenson said. “But that is more complex than a standard utility scenario.”

All of that is leading some government executives to call for new procurement methods that address contracts oriented to service and performance. Officials are still far from having all the answers, but they understand the challenges they face. “It is a new way of doing business, and it requires new contracts,” Tombe said.

Counterpoint

Not everyone agrees that cloud services represent such a significant departure from past IT practices that they require new acquisition methods. Some say only minor changes are needed for future cloud acquisitions to be well served by existing contracting vehicles, such as the General Services Administration’s Alliant governmentwide acquisition contract and IT Schedule 70 blanket purchase agreements, which specify firm fixed prices for cloud services negotiated on behalf of the entire federal government.

“I don’t think cloud procurement is as different or problematic as people make it out to be,” said Larry Allen, president of Allen Federal Business Partners, which provides procurement policy support for government contractors. “I’m not an advocate for creating new cloud-based contract vehicles. It’s much better to use what’s out there.”

In fact, for all the contracting uncertainties, agencies are making progress toward the cloud-first deadline. GSA and the National Oceanic and Atmospheric Administration are just two examples of agencies with large-scale cloud initiatives. Last year, GSA moved 17,000 staff members to Google Apps for Government, a cloud-based e-mail and collaboration system, and NOAA awarded an $11.5 million, three-year contract to migrate 25,000 employees to the Google messaging platform.

Wake-up calls

But cloud procurements don’t always go smoothly. In some cases, the problems are inherent to the cloud, such as determining how much customization of services, if any, is acceptable. In other cases, procurement officers are still sorting out when and how to apply existing rules to the cloud environment. Working through those issues can put the brakes on cloud procurements.

For example, in October 2011, the Government Accountability Office upheld a protest by Technosource Information Systems and TrueTandem that challenged a specification in a GSA request for quotations for cloud-based e-mail services. The RFQ required that data services be located in the United States or other designated countries.

GSA responded to the challenge in part by arguing that the government needs to control where information is stored because of concerns about foreign jurisdictions asserting access rights to data that resides in or moves through their country. Location would likely not have been an issue for agencies that opted to host services in-house, but in the cloud, data could conceivably be stored anywhere in the world.

Nevertheless, the challenge by the two contractors said the GSA requirement unduly restricted competition. GAO agreed, saying that GSA failed to establish a legitimate government need for the stipulation and calling on the agency to amend the RFQ to reflect its actual needs regarding data centers located outside the United States. After reviewing the decision, GSA issued an amended RFQ, nearly six months after issuing the original request.

Earlier, the Interior Department became embroiled in an even bigger contracting controversy after a lawsuit by Google put the brakes on a $59 million, five-year external private cloud intended to provide e-mail and collaboration capabilities for 88,000 of Interior’s employees. A lawsuit by Google charged that Interior’s request for proposals was “unduly restrictive of competition” because it specified a private cloud solution using Microsoft Business Productivity Online Standard Suite. Early last year, a federal judge sided with Google in a ruling that said Interior violated federal acquisition rules for open competition.

Part of the ruling stemmed from Interior’s choice of Microsoft technology, which the department had been using in a traditional implementation. The bigger question appeared to be Interior’s stipulation of a private cloud, which Google, as a supplier of technology for multi-tenant public cloud solutions, could not support.

Knowing that the private cloud stipulation might be challenged, Interior’s procurement and legal staffs tried to be proactive by documenting market research the agency had gathered about the potential risks of public clouds, said William Corrington, Interior’s CTO at the time and now cloud strategy lead at Stony Point Enterprises, a consulting firm that specializes in cloud strategies for federal agencies.

According to court documents, Interior said its research led it to a single-user, private cloud solution because of the sensitive nature of the data that would be stored in the cloud, the agency’s tolerance for risk, and “the benefits and liabilities of each cloud model.”

The case illustrates how questions about emerging cloud technologies add complexity to government procurements. As a result, some Interior officials felt they were being forced to accept undue risks because acquisition rules altered the agency’s original cloud choice, Corrington said.

The legal challenges also led to significant delays. Interior awarded the original contract in late 2010 but is still trying to move the project forward. In early January, the agency issued a new RFP that just now reopens the bidding. This time the department is calling for a commercial provider that can transition its current in-house e-mail systems to “an integrated, cost-effective, cloud solution.” It makes no mention of a private cloud or specific products.

Such legal challenges and protracted contract negotiations over sticking points such as security and service-level monitoring are prompting some observers to call for new methodologies to guide everyone in the procurement community.

“Our acquisition people are doing the best they can, but progress [toward cloud adoption] represents transformation and change for IT,” Tombe said. “That transformation and change require that some of our partners and stakeholders change along with us.

5 ways to prep for the cloud

Government acquisition personnel must often perform a balancing act to achieve the cost and efficiency benefits promised by cloud providers. On the one hand, they need to contract for solutions that share a common set of hardware and software resources to benefit from money-saving economies of scale. Unfortunately, one-size-fits-all solutions aren’t always appropriate, especially when missions and support requirements differ so widely across the government.

Agency officials and consultants say some core definitions and tools could speed contract negotiations and bridge the sometimes conflicting needs of agencies and cloud providers. Here is a list of techniques that could help speed government’s move to the cloud.

1. Security accreditation

Security fears rank among the top obstacles to cloud migrations. Fortunately, procurement officers could have an important tool to address those issues this year — the Federal Risk and Authorization Management Program (FedRAMP). It will create a security baseline that any agency can use to ensure that cloud contracts meet a standard level of protection. Combined with security guidelines from the National Institute of Standards and Technology, FedRAMP promises to simplify and speed the acquisition process.

2. Service-level agreements

The FedRAMP model for an accredited baseline of requirements could be useful in other areas, including the creation of service-level agreements. Agencies and cloud providers often struggle to balance conflicting requirements when it comes to SLAs, said William Corrington, former chief technology officer at the Interior Department and now the cloud strategy lead at Stony Point Enterprises.

For example, the Office of Management and Budget or the General Services Administration might specify that all cloud-based e-mail solutions achieve a minimum uptime rating of 99.95 percent, which would relieve agencies and vendors from hashing out those terms for each contract and thereby speed negotiations.

“Government lawyers would have some confidence that contract language is coming down from OMB or GSA, and cloud vendors would understand what the government is expecting for terms and conditions,” Corrington said.

3. Standardized service definitions

A similar framework for predetermined terms and conditions would benefit common cloud services, such as e-mail solutions or IT infrastructure services. “There are a lot of variables, but if you lock everyone down into a set of services that are utilitarian, then many challenges go away and agencies can compare pricing apples to apples,” said Michael Sorenson, director of cloud services at QinetiQ North America.

The framework would differ from traditional governmentwide acquisition contracts and blanket purchase agreements (BPAs) by establishing standard service definitions all vendors in a particular cloud category would use. Cloud providers might be willing to embrace standardized definitions as a way to discourage agencies from negotiating special terms for commodity solutions.

“Even when the new BPA for [GSA’s proposed e-mail-as-a-service agreement] comes out, I still think agencies will look at terms of service and want to negotiate them,” said Peter Gallagher, a partner in the Civilian Federal Systems group at Unisys. “If you are a [software-as-a-service] provider, it is difficult to negotiate different terms of service in a multi-tenant environment.”

To accommodate varying needs, the government could create standardized terms for tiers of service, such as gold, silver and bronze levels with different performance characteristics, Gallagher added.

4. Clear rules for data management

Today, agencies must negotiate to insert clauses into cloud contracts that specify how their information is maintained and protected by cloud providers. For example, officials at Customs and Border Protection are concerned about having exit strategy options for their data if they decide to switch cloud providers.

“I want that language in the contract going in,” said Wolf Tombe, the agency’s chief technology officer. “I don’t want that to be an afterthought.”

Another issue is the physical location of the storage systems that house government data. Some security rules call for sensitive data to remain in the United States or in select overseas countries. But that can be hard to nail down, as GSA learned when two contractors successfully challenged its original e-mail-as-a-service request for quotations, which restricted data services to certain specified locations.

5. New skill sets for procurement employees

Some acquisition officers might need training to help them negotiate and manage cloud contracts. “Agencies don’t necessarily need to hire legions of new people, but they should make sure their acquisition workforce understands the difference in service acquisitions and why they’re different from products,” said Larry Allen, president of Allen Federal Business Partners.

Key skills for a cloud-rich environment include project and vendor management. The IT Acquisition Advisory Council, among others, is working with the government to promote new acquisition methodologies that are better suited to the cloud, Tombe said.

About the Author: Alan Joch is a freelance writer based in New Hampshire. This article was published by Federal Computer Week on Feb. 15, 2012 at http://fcw.com/Articles/2012/02/15/FEAT-cloud-procurement-DO-NOT-PUBLISH.aspx?Page=3&p=1.

January 27, 2012 By AMK

IT acquisition: Pay less now, more later

Given the current budget environment, in which even essential programs are under scrutiny, it’s only natural that agencies are pressuring their acquisition teams to put the squeeze on vendors for the best possible price. Unfortunately, they might get that price only to find out later that the joke is on them.

Experts increasingly fear that officials will develop a “lowest cost technically acceptable” attitude for their procurements. In other words, they will pick the bids that meet the minimal requirements and go for the cheapest price to demonstrate to the higher-ups that they are good stewards of the government’s money.

The result could be abysmal performance.

“Think performance is bad now? Wait,” said Jaime Gracia, president and CEO of Seville Government Consulting, a federal acquisition and program management consulting firm. “Soon, these jokers will come in to start work and they’ll be like the Three Stooges.”

In some cases, experts say, the lowest bid could actually end up costing agencies more as they eat up all the savings — and more — with make-good work.

“Suddenly, the lowest cost technically acceptable isn’t the lowest cost,” said Robert Burton, former deputy administrator at the Office of Federal Procurement Policy.

But several factors work against buying the best value, which weighs both cost and quality. One problem is timing: Investing in quality might not pay off right away, which could frustrate Obama administration officials who are eager to show that they are running the government efficiently.

Another problem is that best value is inherently subjective. Buyers must factor in the probability of success and the associated risks — both of which elude hard analysis — against any differences in cost. In contrast, when success is measured on price alone, it’s easier to set goals and measure progress against them. You can just watch that bottom line.

Those difficulties are compounded by the fact that shrinking budgets also mean acquisition officials are getting less support from contractors. In the past, contractors have often helped with market research and other important tasks that can help justify higher bids.

Dan Gordon, who recently stepped down as OFPP administrator, offers a more tempered view. There are times when the lowest cost is fine, he said. But on more complicated procurements, the best value deserves a close look, too.

He said he is confident that the federal acquisition workforce has the training and experience to navigate those choices. They know they are “entrusted with the discretion to find the way to best protect taxpayers’ dollars,” Gordon said.

But others are less optimistic. Larry Allen, president of Allen Federal Business Partners, said he believes the low-cost mentality might have already taken hold in some parts of the government, such as the Defense Department.

The Three Stooges just might be arriving with a “fleet of Yugos,” Allen said.

Data management

The government is sitting on an oil field of information that could help agencies operate better and more efficiently. If it could tap the wealth in those data reserves, it would be rich enough to move to Beverly Hills.

Managing that data in 2012 will help the government make valuable decisions that can save money and give insight into its buying habits.

Federal officials will want to know where their money is going because Office of Management and Budget officials will be asking. OMB has directed financial and acquisition officials to decrease spending — specifically spending on contracting — and it recently mandated a 15 percent decrease in contract management support services by the end of the fiscal year. Agencies will need hard data to prove that they have made the cuts.

Strategic sourcing

Officials from the Clinton, George W. Bush and Obama administrations might have disagreed on numerous policies, but they could agree on this: The federal government ought to leverage its collective buying power to get better prices on common commercial products.

Today that concept goes by the name of strategic sourcing, and agencies are beginning to see the wisdom of it. Yes, they might have to pay a fee to buy from a strategic sourcing contract, but in the end, the savings outweigh the initial cost.

As of now, the General Services Administration offers strategic sourcing contracts for printing services and for domestic delivery services, with several IT products covered by blanket purchase agreements. But the range of products available through strategic sourcing is expected to expand as interest grows.

With agencies searching under their couch cushions for loose change to put toward their shrinking budgets, strategic sourcing has the potential to catch on big.

Cuts to support services

As noted earlier, just when acquisition officials could use more help, they are likely to have a lot less of it.

In the past decade, agencies have quadrupled the amount of money they spend on management-related support functions, far outpacing the growth in overall contract spending, according to an OMB memo released late last year.

In fiscal 2010, agencies spent more than $44 billion on 12 types of support services, including IT services, acquisition planning and program management. That’s too much, OMB officials say. They will be paying close attention to agencies’ compliance with OMB’s required 15 percent reduction in spending on support services.

The process will be painful for agencies. Contracting officers will feel the pain when they’re doing the market research for solicitations, and managers will feel it when they try to get help evaluating a program only to find an empty desk where a contractor once sat. Agency employees will be doing all that work themselves.

Dialogue with industry

The Obama administration has made a lot of acquisition officials nervous with its efforts to keep dealings between agencies and companies on the up and up. But at the same time, administration officials have pushed agencies to make sure those conversations happen.

One example is the mythbusters campaign Gordon launched while at OFPP to dispel unfounded ethical concerns that are hindering government/industry dialogue. Another is GSA’s BetterBuy initiative, an effort to use Web 2.0 technology to give industry more input on planned acquisitions.

More recently, GSA has launched the Integrations Industry Community as an online venue for vendors to provide input on an upcoming governmentwide acquisition contract for IT-related professional services.

The thinking behind all those initiatives is that, now more than ever, federal agencies are in the market for new ideas — especially ones that can save them money — and contractors have innovation to spare.

One way or another, contracting officials and program managers must find a way to talk, Gordon said. He once jokingly told an apprehensive contracting officer, “Take five lawyers with you if you need to, but you’ve got to find a way to feel more comfortable talking and listening to vendors.”

About the Author: Matthew Weigelt is a senior writer covering acquisition and procurement for Federal Computer Week. This article appeared on Jan. 20, 2012 at http://fcw.com/articles/2012/01/15/feat-watch-list-acquisition.aspx.

June 25, 2011 By AMK

Oops, GSA takes back major contract awards

General Services Administration officials quickly rescinded an e-mail message sent to small businesses telling them they had won spots on its major small business governmentwide IT contract, according to an e-mail message obtained by Washington Technology and Federal Computer Week.

Officials wrote in a follow-up message, which came a day after the award notice, that they were checking prices again for the 8(a) Streamlined Technology Acquisition Resources for Services (STARS) II contract. The message contained an unsubtle suggestion that bidders might want to offer lower prices.

“Any part of previous communications from GSA stating or implying that offerors were deemed apparently successful is hereby rescinded,” agency officials wrote. “This discussion e-mail serves as notice that GSA has made the decision to hold additional discussions, with an emphasis on pricing.”

STARS II is a 5-year, $10 billion indefinite-delivery, indefinite-quantity (IDIQ) IT contract. GSA issued the first solicitation for the GWAC in July 2009. Officials expect an award this month, according to GSA.gov.

GSA officials didn’t immediately respond to requests for comment..

Prices are becoming a central theme in the government as Congress and the Obama administration attempte to rein in spending.

GSA is giving the 8(a) small businesses time to reexamine the prices they offered in their initial bids and adjust the pricing to “amplify its potential to be favorably considered,” according to the follow-up message.

The opportunity for price revisions is not merely a request for an update, but it will play into GSA’s evaluations.

“This is a competitive 8(a) procurement where comparative analysis with other offerors’ pricing in response to this [Final Proposal Revision] opportunity, and possibly other price analysis, will occur in order to assess price reasonableness [or] unreasonableness,” GSA wrote.

In the rescission e-mail message, GSA gave companies pricing averages from the initial bids as a guide for what’s been offered so far to let companies know where their prices compare to other bidders.

Observers speculated that someone may have sent out an email too soon, or a senior management official could have recognized in the 12th hour that the agency needed look over the prices again.

“Oops,” Larry Allen, president of Allen Federal Business Partners, said about the initial message.

Either way, the STARS GWAC is “a crown jewel” of GSA and its small business contracts. It’s next to the GSA’s Schedules in importance to the agency, he said.

The follow-up rescission message may be awkward, but, Allen said, it’s better than being criticized throughout the life of the contract because of high prices.

Nevertheless, the small-business aspect, such as getting a good mix of various business types, likely would get officials’ attention from the outset before prices, he said. STARS offers customer agencies an avenue to boost their small-business contacting percentages, which has helped to make the GWAC successful.

Across the government though, pricing has become another essential topic in a time when funding is set to diminish. It’s important enough that the Defense Department made Shay Assad, a senior procurement policy official, the first director of defense pricing in May.

That appointment points to the weight of the pricing issue, said Hope Lane, a government contract consultant at Aronson Consulting.

“The government has to start implementing austerity measures,” said Lane, who focuses on GSA Schedules.

It isn’t surprising that GSA may have rescinded its award notice in order to make contractors improve their prices, she said. As agencies hunt for the best value for their money, GSA’s STARS GWAC has to prove that it can actually save money, or GSA will lose business to another IDIQ hosted by another agency, she said.

“IT, in particular, is a competitive market among GWACs,” she said.

This mix-up may cost GSA by way of protests to the contract. Allen said the likelihood of protests just jumped much higher.

About the Author: Matthew Weigelt is acquisition editor for Federal Computer Week – June 22, 2011 – http://washingtontechnology.com/Articles/2011/06/22/GSA-rescinds-STARS-II-GWAC-award.aspx?p=1

June 16, 2011 By AMK

Assad, Ginman look to cut costs in new DoD roles

The Department of Defense has a new plan to cut an announced $400 billion from the bottom line over the next 12 years. Called the “Better Buying Power” initiative, the “23-point strategy seeks to restore affordability in defense procurement and to improve defense industry productivity,” said Under Secretary of Defense for Acquisition, Technology & Logistics, Dr. Ashton Carter.

Under Better Buying, the role of the office of Defense Procurement and Acquisition Policy (DPAP) has grown to the point where it’s now created a new position, the director of defense pricing.

The new director, Shay Assad, appearing on Off the Shelf, told host Roger Waldron he’s “very excited about this because there are a number of things that we’re doing to improve the capability of the workforce and the capability of the department as it relates to the price we pay for the goods and services we buy and increasing the value to the taxpayers for every dollar that we’re spending on their behalf.”

As Assad assumes the duties of the new position, Dick Ginman has taken over Assad’s former position as the director of Defense procurement and acquisition policy.

“Fundamentally, what’s happening Roger, is that I will be focused on cost, price and finance aspects of acquisition as well as supporting programs….through the Defense Acquisition Board. And in addition, I’ll be responsible for advising Dr. Carter on acquisition strategies for multi-years and things of that nature. And finally, the workforce, which has been my passion, so I will continue to carry through on that.”

Ginman, said Assad, will be responsible for contingency contracting, e-business, and for the acquisition regulation side of DPAP.

In terms of policy, Assad will be advising Dr. Carter on pricing and profit policies and while Ginman will be advising on “all other matters related to acquisition contracting policy.”

Now that they’ve defined who will be handling what, the bigger questions would include how the initiatives work, and how they should work.

Assad explained, going even a step further, and considered how the initiatives should not work.

“The Better Buying Power initiatives are not at all a war on profitability of contractors. That’s not what this is about. What it’s all about is trying to understand how can we use profit to properly motivate contractors to reduce the prices that we pay,” he said.

For example, said Assad, “if we’re paying $100 for a product and included in that $100 is $10 of profit, we’d much rather pay $90 and if the contractor made $15 as a result of that, we’d be okay with that.”

At the bottom line, said Assad, is the bottom line. “What we’re doing is we’re trying to align profitability and performance.”

The area with the greatest potential for savings, according to Assad, is at the beginning of the acquisition process and in more clearly defining the requirements for contracts. “If we’re going to make a quantum leap in improving what we pay for goods and services, it’s going to be in this particular area.”

Communication with industry is an incredibly powerful, but intimidating tool, for contracting officers. Acquisition officers are generally uncomfortable sharing information with industry, not wanting to give the appearance of favoring any one contractor over others. Learning how to communicate, and why it’s important, is a priority for Assad.

“We’re really spending a lot of time with our contracting officers, encouraging them to spend time discussing the requirement with contractors; that there’s nothing inappropriate about it. That the better that contractors understand our requirement, the more precise we are and exacting about what we want, the better proposals and the better competition we’re going to get.”

Changing the acquisition workforce, from tooth to tail, in Defense has been one of Assad’s greatest challenges and satisfactions so far. He said about 8,600 people have been brought on board, with “another 4 or 5 thousand folks we’re going to hire.”

Frank Anderson, the former president of Defense Acquisition University and myself are kind of the key guys behind ensuring that we develop that acquisition strategy and what feels so good about it is that we’re seeing it come to fruition. I’m very excited about it because we’re not just hiring younger folks or folks with little experience. The reality is, Roger, the breakout is about 65 percent entry level folks, about 34 percent journeyman level and then one percent very senior folks, and that was kind of how we set it up. And we’re within one percent of the 65 and one percent of the 34 of getting to where we wanted to be, so we’re pretty excited that we’re, in fact, filling in the workforce with a good mix of folks.

Overall, Assad said the Better Buying initiatives are one of the biggest changes for good he’s seen in his career. “That was a statement from a senior leader that I think will have a profound impact on how we buy goods and services throughout the department.”

For more from Shay Assad and Dick Ginman, you can hear the entire Off the Shelf program by visiting http://www.wfed.com/?nid=46&sid=2412012.

— by Suzanne Kubota, Senior Internet Editor, Federal News Radio, June 7, 2011

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