Submissions

Submissions

The BCA regularly makes submissions to federal and state government committees and inquiries that have relevance to BCA policy positions and priorities.

Obtain copies of submissions released by the BCA prior to 2008 here.

Submission to DEEWR regarding Changes to the Indigenous Employment Program Assessment and Funding Processes

IEP-supported programs aid business in boosting their Indigenous workforces.
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Submission to the Senate regarding Subclass 457 Visas, Enterprise Migration Agreements and Regional Migration Agreements

A demand-driven, uncapped temporary skilled migration program is essential to Australia’s long-term prosperity.
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Submissions regarding the Fair Work Amendment Bill 2013

The recently announced second tranche amendments to the Fair Work Act 2009 is a missed opportunity resulting from poor process and poor policy.
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Submission regarding the Australian Jobs Bill 2013 Exposure Draft

The proposals to regulate the procurement processes of private projects in the Bill are a step too far.
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Submission to the Productivity Commission Study of Major Project Development Assessment Processes

The study findings should lead to reform of Australia’s major project approvals processes so that they meet policy objectives in a way that imposes lowest economic cost.
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Submission to the Senate regarding the Environment Protection and Biodiversity Conservation Amendment Bill 2013

The EPBC Amendment Bill is fundamentally bad law born of a poor regulation-making process, because the problem it seeks to address has not been properly defined.
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Submission regarding the Corporations Legislation Amendment (Remuneration Disclosures and Other Measures) Bill 2012 Exposure Draft

April 2013 – The BCA does not support the Bill in its current form.
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Submission regarding the DEEWR ‘Employment Services: Building on Success’ Issues Paper

April 2013 – Employment placement services need to be made easier for employers and jobseekers to use.
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Submission to the Treasury regarding the Monthly Pay As You Go Instalments for Large Taxpayers Consultation Paper

March 2013 – The government’s proposal to change the timing of company tax payments by large companies is not without risk to the operating environment for businesses.
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Submission regarding the Industrial Relations Implementation Guidelines to the New South Wales Code of Practice for Procurement: Building and Construction

The draft guidelines will help reduce construction costs, maintain good workplace relations and promote construction sector productivity.
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BCA Budget Submission 2013–14: Towards Fiscal Repair

The government’s execution of its fiscal strategy is not working and needs a major rethink.
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Submission to the Productivity Commission Review of the National Access Regime and the Competition and Infrastructure Reform Agreement

March 2013 – The review creates an opportunity to start a national discussion about the need to update and refresh competition policies relating to infrastructure.
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Submission to DEEWR on Improving the Employment Participation of People with Disability in Australia

February 2013 – Requiring employers to report on disability employment would fail to increase the employment of people with disability and impose unnecessary costs.
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Submission to Consumer Affairs Australia and New Zealand regarding Consumers and Fuel Price Boards

February 2013 – The Consumers and Fuel Price Boards consultation paper fails to provide adequate justification for regulatory intervention.
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Submission to the Corporations and Markets Advisory Committee AGM and Shareholder Engagement Discussion Paper

February 2013 – Australia is a high performer in an already highly regulated environment, and poorly targeted regulation can distort the focus of corporate governance.
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Submission to FaHCSIA on Reporting Matters under the Workplace Gender Equality Act 2012

February 2013 – The BCA does not support any additional reporting on workplace gender equality issues.
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Submission to the Senate Inquiry into the Environment Protection and Biodiversity Conservation Amendment (Retaining Federal Approval Powers) Bill 2012

January 2013 – The BCA does not support the Bill and urges the committee to recommend its withdrawal.
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Submission to the Department of the Prime Minister and Cabinet regarding the Digital Economy White Paper

January 2013 – The future benefits of ICT development will primarily be driven by the ongoing development of markets and by private business and consumer decisions.
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Submission to the Senate Legal and Constitutional Affairs Committee on Consolidation of Anti Discrimination Laws

December 2012 – Strong support from the BCA to make a society more inclusive for all Australians.
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Submission to the Australian Law Reform Commission Review into Commonwealth Legal Barriers to Older Persons Participating in the Workforce or Other Productive Work

December 2012 – Educational strategies, high-peforming workplaces and the removal of all legislated age restrictions are key to encouraging workforce participation by older Australians.
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Submission to the Senate Standing Committees on Education, Employment and Workplace Relations in relation to the Fair Work Amendment Bill 2012

November 2012 – Australia’s international competitiveness is being challenged by a high-wage, high-cost, low-productivity economy.
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Submission to the House of Representatives Inquiry into Australia’s Oil Refining Industry

November 2012 – It is essential that governments do not undermine the competitiveness of domestic liquid fuel refining and supply through regulatory decisions and other imposts.
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Submission to the Independent Review of the Australian Government’s Regulatory Impact Analysis Process

There are considerable gains to be made from institutionalising more disciplined regulatory gatekeeping at all levels of government.
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Submission to the National Occupational Licensing Authority Board regarding Regulatory Impact Statements for National Occupational Licensing

Any national licensing scheme must license only those skills and competencies that reduce identified risks, remove all ineffective and duplicative regulatory functions across the country, and nationally recognise licences regardless of the jurisdiction in which they are obtained.
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Submission to the Essential Services Commission of South Australia regarding the 2011–2014 Electricity Standing Contract Price Determination Wholesale Electricity Cost Investigation

There is no good reason for prices to continue to be regulated in South Australia.
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Submission to the Australian Curriculum, Assessment and Reporting Authority on the Economics and Business Aspects of the Draft Shape of the National Curriculum

The new national curriculum on economics and business will significantly influence how primary and senior school students understand the role that the economy and businesses play in growing national prosperity.
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Submission in Response to the Business Tax Working Group Discussion Paper

The findings of the Business Tax Working Group should be rolled into a 10-year comprehensive tax reform process.
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Submission to the Climate Change Authority Review of the Renewable Energy Target

September 2012 – How can the costs of the Renewable Energy Target policy be minimised?
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Submission to the Senate Inquiry into the Protecting Local Jobs (Regulating Enterprise Migration Agreements) Bill 2012

Enterprise Migration Agreements play an important role in helping to manage labour shortages and support companies to deliver projects in a difficult economic environment.
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Submission to the Senate Select Committee on Electricity Prices

September 2012 – Electricity prices should reflect the efficient costs of providing electricity to end-users.
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Submission to the Department of Climate Change and Energy Efficiency regarding the Draft Clean Energy Legislation Amendment (International Emissions Trading and Other Measures) Bill 2012 and Related Bills

No restrictions should be placed on businesses’ use of international permits to meet their full liabilities under the Clean Energy Act.
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Submission to the Tasmanian Climate Change Office Responding to Part Two of the Review of the Climate Change (State Action) Act 2008

In pursuing the objective of emissions reduction, a key assessment of any proposal is whether it enables emissions reduction at least cost to the economy.
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Submission to the Senate Inquiry into the Adequacy of the Allowance Payment System for Jobseekers and Others

Reforming the Newstart Allowance should be part of a more comprehensive review that takes into consideration all income support arrangements.
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Submission to the Treasury GST Distribution Review: Response to Interim Reports

The fiscal imbalance is set to become even more acute in the future and at some stage the structure of state tax systems will need to be reformed.
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Submission to the EPBC Act Cost Recovery Consultation

June 2012 – Maintaining Australia’s sound environmental regulatory standards should be done with a risk management approach and ensuring regulations are streamlined and outcomes focused.
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Submission to the Commonwealth Financial Accountability Review Discussion Paper

Calls for further institutional reforms that will help drive longer-term fiscal sustainability through increased transparency and accountability.
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Submission to the Australian Law Reform Commission Inquiry into Commonwealth Legal Barriers to Employing Older Workers

The BCA supports the full economic and social participation of all Australians. However, we believe proposals to regulate unnecessarily duplicate existing protections.
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Submission responding to the International Education Advisory Council Discussion Paper for the Development of an International Education Strategy for Australia

The submission lays out some high-level elements the BCA hopes to see considered in the international education strategy and highlights this.
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Submission to the Joint Select Committee Inquiry into the New South Wales Workers Compensation Scheme

The system places major costs on the state’s employers, does not sufficiently provide the right incentives, and is not providing the opportunities NSW workers need to support them in an early return to work.
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Submission to the Department of Resources, Energy and Tourism regarding the Draft Energy White Paper

It is critical to Australia’s economic growth and prosperity to implement sound long-term energy policies and planning and in the future consider climate change related policies within this context.
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Submission to the Senate Inquiry into the Equal Opportunity for Women in the Workplace Amendment Bill 2012

Certain parts of the Bill could unnecessarily increase business reporting costs and fail to achieve the objective to improve workplace gender equality.
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Submission to the New South Wales Ministerial Taskforce on Aboriginal Affairs

Some key themes that have emerged in feedback provided by BCA member companies through surveys and other forums.
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Submission to the Department of Immigration and Citizenship Review of the Student Visa Assessment Level Framework

Our current student visa assessment level framework is less flexible than it needs to be and needs reform.
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Supplementary Submission to the Review of the Fair Work Act

An examination of the drivers and consequences of growth in alternative working arrangements in Australia over recent decades.
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BCA Budget Submission 2012–13

The 2012–13 Budget could be a watershed for Australia.
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Submission to the Department of Climate Change and Energy Efficiency regarding the Price Floor for Australia’s Carbon Pricing Mechanism

Calls for further consultation on two of the options presented before a final decision is made.
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Submission to the Review of the Fair Work Act

The Fair Work Act is not supporting Australian businesses to stay competitive in a particularly challenging economic environment.
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Submission regarding the Tasks of the Productivity Commission in Carbon Policy Assistance Reviews

Addresses the role of the Productivity Commission in relation to the Jobs and Competitiveness Package.
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Submission to the Board of Taxation on the Tax Studies Institute

The proposed Tax Studies Institute will need to have a strong mandate and be practically focused if it is to make a valuable contribution to the task of comprehensive long-term tax reform.
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Submission to the Attorney-General’s Department on the Consolidation of Commonwealth Anti-Discrimination Laws

Calls for one Anti-Discrimination Act with which everyone in Australia must comply.
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Submission to the Department of Infrastructure and Transport on the Exposure Draft of the Coastal Trading Bill 2012

The proposed reform of Australia’s coastal shipping sector may lead to higher costs and lower-quality services for domestic shipping users.
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Submission to the Treasury Review of Transfer Pricing Rules

Retrospective tax law changes are inconsistent with long-standing principles of sound tax design and do little to enhance Australia’s reputation as a destination for foreign investment.
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Submission to the Australia in the Asian Century White Paper: Assessing Australia’s Trade and Investment with Asia

A competitive Australia is key to effective Asian engagement.
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Submission to the Treasury GST Distribution Review

The current system of GST distribution involves an overwhelming level of effort and complexity for a relatively low national return.
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Submission to the Productivity Commission on the Role of Local Government as Regulator

Examples of the difficulty business has in dealing with local government, and specific recommendations for improvement.
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Submission to the Expert Panel on Constitutional Recognition of Indigenous Australians

Prepared in response to the discussion paper released by the Expert Panel on Constitutional Recognition of Indigenous Australians as part of its consultation process.
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Submission to the Joint Select Committee Inquiry into Australia’s Clean Energy Future

Why the clean energy future package lacks essential and responsible safeguards
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Submission to Infrastructure Australia on Infrastructure Financing Reform

Calls for an examination of how governments can best bring forward their priority infrastructure projects for implementation.
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Submission on the Clean Energy Legislative Package

Calls for additional safeguards to help address the risks associated with global and domestic economic cycles and the limited progress in international negotiations.
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Submission to the Minister for Workplace Relations Seeking Amendments to the Fair Work Act 2009

Outlines a number of issues of concern to BCA members that warrant legislative amendment to the Act.
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Submission regarding Proposed Price Signalling Amendments to the Competition and Consumer Act

Providing the ACCC with additional powers to deal with so called ‘price signalling’ would represent an unwarranted regulatory overreach with potentially adverse consequences for the rest of the economy.
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Submission to the Productivity Commission Inquiry into Disability Care and Support

Supports the establishment of a National Disability Insurance Scheme as proposed by the Productivity Commission’s draft report on disability care and support.
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Submission to the Australian Energy Market Commission on Strategic Priorities for Energy Market Development

A continuing focus on an efficient and effective energy market is needed to meet the substantial investment task ahead.
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Submission to the Joint Committee of Public Accounts and Audit Inquiry into National Funding Agreements

There has been a proliferation of national partnership agreements, which in many cases is reintroducing Commonwealth direction over funding.
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Submission to the Review of Funding for Schooling

Calls for funding to be reallocated to ‘follow the student’, better support disadvantaged students, and improve student transitions to post-compulsory education.
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Submission to the Review of Higher Education Base Funding

Reinforces the need for a funding model that promotes better outcomes for students, business, industry and the community as a whole by driving the productivity growth Australia needs.
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Submission to the Department of Immigration and Citizenship Strategic Review of the Student Visa Program

Calls on the government to create new, faster, less expensive and less onerous visa categories linked to study at high-quality Australian education and training institutions.
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Submission to Safe Work Australia on the Draft Model Work Health and Safety Regulations and Model Codes of Practice

The submission outlines a number of high-level issues including the importance of efforts to develop a harmonised national occupational health and safety framework to apply across Australia.
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Clawback of Executive Remuneration where Financial Statements Are Materially Misstated

We do not believe a case has been made as to why the present provisions of the law are not adequate.
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Submission regarding the Treasury’s ‘Designing a Tax System Advisory Board’ Discussion Paper

A properly constituted oversight board could play a very important role in helping the Australian Taxation Office meet the community’s legitimate expectations for the operation and administration of the country’s tax laws.
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Submission to the House of Representatives Inquiry into the Role and Potential of the National Broadband Network

Realising potential benefits from fixed and wireless broadband services requires a competitive and efficient communications sector that provides accessible and high-quality broadband products at least cost to consumers.
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Submission to the Department of Infrastructure and Transport on National Urban Policy

The submission highlights the importance of integrated strategic cities planning systems, effective federal–state relations and rigorous assessment of projects for successfully managing the growth of our cities.
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Submission on the National Health Reform Amendment (National Health Performance Authority) Bill 2011

Comments on the overall system governance design, who the authority reports to, and its degree of independence, focus and objectives and coverage.
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Submission regarding the Government Response to the Report of the Prime Minister’s Task Group on Energy Efficiency

At this stage, a compelling case for the need for an energy efficiency obligation has not been made.
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Submission on the Development of Australia’s Sustainable Population Strategy

A national population strategy should chart a course towards Australia’s future that reflects the shared goals and aspirations of the Australian people.
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Submission to the Department of Infrastructure and Transport on Reforming Australia’s Shipping

A call for the Productivity Commission to assess the economic and productivity impacts of the proposed shipping reforms and the implications for the cost and availability of domestic shipping services.
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Submission to the Minister for Employment Participation on the Review of Employment Services

This submission outlines a number of suggestions relating to the government’s review of the employment services.
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Submission on the Competition and Consumer Amendment Bill (No. 1) 2011

This submission argues that in practice we do not believe the approach taken or the legislation as presently drafted will necessarily enhance the functioning of markets or achieve these outcomes.
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Submission regarding the Corporations Amendment (Improving Accountability on Director and Executive Remuneration) Bill 2011

We oppose the “two-strikes test” and the “no vacancy” rule, and we have also raised a number of concerns with the new provisions relating to the accountability of remuneration consultants.
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