Policy & discussion papers


Rule Change Panel Selection Criteria Position Paper
March 2016
A best practice process for the appointment of members of the Wholesale Electricity Market Rule Change Panel would be for candidates to be recommended for appointment by a selection panel and for a determination on appointment to be made by the Minister.


Submission to the Department of Environment Regulation’s Draft Guidance Statements: Regulatory Assessment Framework, Environmental Risk Assessment Framework and Regulatory Controls
March 2016
CCI supports the intention of the Department of Environment Regulation’s (DER) regulatory reform program to provide certainty for industry and the community and to apply a higher level of standardisation in its decision making. The Regulatory Assessment Framework, Environmental Risk Assessment Framework and Regulatory Controls are a key part of the reform program and CCI has identified a number of areas where these guidance statements can be improved.


2016-17 Pre-Budget Submission
February 2016
This letter comprises CCI's submission to the State Government's 2016-17 Budget.


Regulation of Mine Dewatering
February 2016
The duplicated regulation of mine dewatering by the Department of Environment Regulation and the Department of Water is a frustration for the mining industry that CCI has raised at the departmental and ministerial level. CCI supports the Chamber of Minerals and Energy of Western Australia's submission to the Draft Guidance Statement on the Regulation of Mine Dewatering, which recommends that the scope of dewatering activities eligible for regulation solely by the Department of Water be expanded.


Submission to the Position Paper on Reforms to the Reserve Capacity Mechanism
February 2016
Arrangements for the reform of the Reserve Capacity Mechanism should ensure that the transition to a capacity auction is smooth and that existing levels of competition in the Wholesale Electricity Market in the South West Interconnected System are preserved and improved on. This is of particular importance because of the State Government’s decision not to restructure Synergy, forgoing the opportunity to enhance competition in the market.


Publication of Annual Audit Compliance Reports
December 2015
Public disclosure of Annual Audit Compliance Reports would increase the amount of information available to the public on the compliance of individual licensees with their environmental obligations. However, for the publication of this information to improve transparency it needs to be interpreted correctly. It is therefore incumbent on the DER to ensure that AACRs are in a format that facilitates the correct reporting and interpretation of this information.


Western Trade Coast Protection Area
December 2015
CCI supports the proposal to formalise a protection area around the Western Trade Coast. This will provide industry with the land use certainty it needs in the area to invest and grow. Industry in the Western Trade Coast contributes 30,000 jobs and $1.7 billion in wages and salaries to the economy, making it an industrial area of strategic importance to the State.


Rule Change Body Position Paper Response
December 2015
CCI supports the preferred design option for the new rule change body set out in the Electricity Market Review Steering Committee’s Position Paper. To ensure the independence of the new rule change body, CCI considers the Rule Change Panel and executive officer positions should be held by individuals with no association to a market participant or the Western Australian Government. A skilled and independent rule change body whose members are appointed by the Minister should be capable of determining rule changes and a Ministerial power to direct the Rule Change Panel should not be necessary.


Submission to the Environmental Protection Authority on its Draft Environmental Assessment Guideline for Separation Distances Between Industrial and Sensitive Land Uses
November 2015
CCI’s submission argues for the retention of flexibility in land use planning to accommodate variation in emissions within industry categories, consideration of site-specific issues;  and for consistency with the Department of Environment Regulation’s guidelines.


Submission to the Department of Environment Regulation on its Draft Guidance Statement on Separation Distances
November 2015
CCI supports the establishment of a guidance statement on separation distances that outlines how the Department of Environment Regulation will apply generic separation distances as it will increase transparency and certainty for proponents and operators of prescribed premises. However, CCI proposes a number of modifications to the Guidance Statement be made to improve the administration of generic separation distances and increase transparency for industry.


Submission to the Department of Transport’s On-demand Transport Green Paper
October 2015
CCI broadly supports the reforms proposed in the Department of Transport’s Green Paper, On-demand Transport — Discussion Paper for Future Innovation, in particular the proposals to remove quantity restrictions on all types of on-demand transport vehicles and to introduce a fit-for-purpose approach to regulation based on the type of activity undertaken. Ultimately the design of the reforms should be focused on improving choice and competition for the benefit of consumers.


Submission to Legislative Assembly Economics and Industry Standing Committee’s Inquiry into Technological and Service Innovation in Western Australia
September 2015
This submission deals with the Committee’s stated interest in technology and service innovation in the following Western Australia sectors: agriculture and food; advanced manufacturing; and resources and energy. In addition, CCI has provided information from preliminary international analysis, intellectual property law, and venture capital.


Submission to the Department of Environment Regulation on its Draft Guidance Statement on Environmental Standards
September 2015
The implementation of Environmental Standards has potential benefits for industry and the environment if the standards facilitate the achievement of acceptable environmental outcomes, increase certainty for proponents, and do not result in unnecessarily burdensome regulation.


The National Disability Insurance Scheme; why a Federated Approach is best for WA
September 2015
This paper has been shaped from the views of a number of CCI’s Members in the disability sector, including some who operate in the current National Disability Insurance Scheme (NDIS) trial sites in WA. The recommendations outlined in this report are designed to ensure that all Western Australians with, or who may acquire, disability can access high quality care and support under the NDIS reforms, while ensuring a strong and viable WA disability services sector into the future.


Submission in response to the Position Paper — A proposed Design for the New Rule Change Assessment Panel
August 2015
Wholesale Electricity Market participants’ confidence in the impartiality of the new Rule Change Assessment Panel would be improved by the inclusion of permanent independent members, and if the position of Executive Officer of the Secretariat is held by an independent person whose office is collocated with the Economic Regulation Authority.


Submission to the Australian Government, Department of Environment, on its Emissions Reduction Fund: Safeguard mechanism - Consultation Paper
May 2015
CCI considers that the long run fiscal sustainability of the ERF will depend on the extent that it provides sufficient incentives for firms to reduce their emissions with minimal distortion to overall economic activity. As currently proposed by the Australian Government’s Department of Environment (DoE) in its Emissions Reduction Fund: Safeguard mechanism - Consultation Paper, the ERF Safeguard Mechanism would impose a substantial regulatory burden on businesses with facilities in Australia that have direct emissions of more than 100,000 tonnes of CO2-e a year. This additional regulatory burden, combined with confusion and uncertainty about the objectives of the ERF and inconsistencies with the proposed legislative rules, could impede future expansion and investment in the Western Australian resources sector without any guarantee that emissions across the Australian economy would fall.  In this submission, CCI proposes some modifications to the ERF safeguard mechanism that would, in large part, remove the unnecessary regulatory burdens associated with proposals outlined by DoE . 


Submission to the Department of Environment Regulation on its Draft Guidance Statement on Setting Conditions - Part V, Environmental Protection Act
March 2015
CCI considers that the implementation of regulatory principles, which provide a code against which regulators within Department of Environment Regulation (DER) must give due weight in the setting of conditions on works approvals and licences, follows good regulatory. However, in their current form, CCI considers the principles proposed by DER has some notable gaps. There should be principles that require, or guide: cost benefit analysis to allow for sustainable development; minimisation of compliance costs; and performance monitoring of outcomes, costs  and regulator engagement with stakeholders.


Submission to the Department of Environment Regulation on its Draft Guidance Statement on Land Use Planning, Roles and Responsibilities
March 2015
The circular nature of interactions between the Department of Environment Regulation (DER) and state and local government planning agencies creates substantial delays and uncertainty in land use planning; imposes excessive regulatory burdens on business and adversely affects consumption and employment opportunities for all Western Australians. CCI considers reforms proposed by DER should be implemented simultaneously with improvements in consultation and coordination between DER and state and local government planning authorities and progress in regulatory reforms by the State Government in some areas of land use planning.


Productivity Commission Review into the Workplace Relations Framework
March 2015
CCIWA welcomes the opportunity to make submissions to the Productivity Commission Review of the Workplace Relations Framework. The national industrial relations (IR) system has a significant impact upon the ability for Australian businesses to compete in a global economy, be adaptive to change, and provide opportunities for Australian employees to improve their standard of living.


Review of the Waste Avoidance and Resource Recovery Act 2007
March 2015
The efficient disposal and recovery of waste is a topic that deserves more attention from policy makers in Western Australia. Current regulations impose costs on households and businesses that exceed the environmental benefits.


Review of the Vocational Education and Training Act 1996

February 2015
Training and skill development is vital to WA business to ensure that it has access to an adaptable and productive workforce. It is essential that the VET Act delivers on its aims of providing a ‘State training system that is effective, equitable and efficient to meet the needs of industry and the community, while allowing an open and competitive training market’.

It is equally important that the VET Act is exercised efficiently and its’ powers used to full effect to ensure that the aims of the Act are achieved, delivering quality, flexible, competitive and industry relevant training.  CCI’s submission presents our policy position and recommendations for change to the VET Act.


Inquiry into Mental Illness in fly-in, fly-out workers – Discussion Paper, Education and Health Standing Committee
February 2015
Following extensive consultation with members, CCI provided a second submission in response to the Discussion Paper released by the Education and Health Standing Committee as part of the Inquiry into Mental Illness in Fly-in, Fly-out workers. The submission again expressed concern about the narrow and targeted focus of the inquiry on the FIFO workforce and conveyed the missed opportunity for an community wide response to mental health risk and prevention strategies. CCI addressed a number of issues within the Discussion Paper.


Work, Health and Safety Bill (the Green Bill) – Public Comment
February 2015
After discussions with hundreds of CCI members face to face and consultation via electronic alerts and articles with all of our members, CCI provided a detailed submission to Worksafe WA in response to a call for comments about the draft the Work, Health and Safety Bill (the Green Bill). Our submission highlighted the overall support  from the business community for the concept of harmonisation of safety laws and a WA version of legislation that will provide some consistency and alignment with other jurisdictions combined with state specific provisions. CCI further highlighted key concerns in relation to the draft Bill that which require amendment or removal before any progression of the Bill.


Submission to the City of Perth Act Advisory Group
February 2015
CCI strongly supports the introduction of a City of Perth Act that enhances the City of Perth as the centre of business, tourism and entertainment in Western Australia. To ensure that the City of Perth is responsive to the needs of businesses and other non-resident stakeholders, the voter franchise should encourage greater participation by non-resident owners and occupiers in City of Perth Council elections. To focus the Council on the strategic development of the City of Perth for the benefit of the whole state, the current electoral structure comprising a single undivided municipality should be retained.


Submission to the Draft Western Australian Approval Bilateral Agreement for a one stop shop for environmental assessments and approvals
February 2015
CCI commends the Australian and Western Australian governments for their efforts to streamline environmental assessments and approvals in Western Australia. When implemented, the proposed One-Stop Shop for environmental assessments and approvals will reduce duplication for business and government.


Draft Decision on Proposed Revisions to the Access Arrangement for the Mid-West and South-West Gas Distribution System
January 2015
CCI is concerned that the rate of return proposed by the ERA in the Draft Decision may be insufficient to attract the necessary capital to finance investment in the Mid-West and South-West Gas Distribution System, and this could lead to diminished quality, safety, reliability and security of gas supply for WA consumers.

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