Attention Ms Janet Sawides.

Dear Janet,

Please regard this email as our supplementary submission.

In our first submission we highlighted the problems evident in the policy and regulatory development processes, and the need for some means of ensuring that the proper processes were followed and that the quality of inputs and analysis were raised.

Suggestions made included the establishment of a central agency at federal and state level to vet regulatory proposals as well as supporting data and analysis, as is the case in Netherlands.  The need for quality improvement via mechanisms such as provided by the USA Data Quality Act was also raised.

We contend that it is difficult for all departments and agencies to have the necessary expertise in house to properly conduct the processes involved in policy formation and regulatory analysis, and therefore some sort of central coordination and quality control is needed.  Whilst education of staff in what is required under the various processes is obviously required, education alone cannot solve the problems evident within the system.

Attached please find a copy of a response to a submission we made to the Western Australian Department of Environment and Conservation in relation to proposed new waste legislation.  You will note that the analysis undertaken amounts to little more than a ‘popularity poll’.  There has been no assessment as to the merit of comments made or how comments reflect on the validity of what is being proposed.

This response is reflective of the internal assessment processes taking place at state level.  It suggests that the public consultation processes undertaken are not really used to address any flaws in policy or regulatory proposals, they are simple a step in the process that must be endured.

All the best,

Gerard van Rijswijk
Senior Policy Advisor
National Association of Retail Grocers of Australia