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 on the Creeping Acquisitions Aspects of the Senate Economics Legislation Committee Inquiry into the Competition and Consumer Legislation Amendment Bill 2010

The BCA does not consider that any amendments are required to the merger provisions of the competition laws.
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Submission on the Proposed Amendments to the ASX Corporate Governance Council’s Corporate Governance Principles and Recommendations (Second Edition)

The proposed refinements generally strike the right balance between promoting better corporate governance practices and maintaining the flexibility for companies to operate competitively.
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Submission to the Department of Broadband, Communications and the Digital Economy on the NBN Implementation Study

The findings of the National Broadband Network Implementation Study confirm the need for a cost–benefit analysis of the project to demonstrate it is in the national interest.
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Submission to the Department of Education, Employment and Workplace Relations on the Draft National Professional Standards for Teachers

An effective set of teacher standards will help create the foundation for a national framework to improve student learning outcomes.
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Submission to the Productivity Commission Study of Bilateral and Regional Trade Agreements

Are free trade agreements achieving the desired outcomes for the future of trade liberalisation?
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Submission on Draft Legislation for the National Broadband Network Company

How can the NBN Company legislation provide a more certain business environment for other investors and lay a stronger foundation for realising the productivity benefits from high-speed broadband?
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Submission to the Productivity Commission on the Draft Research Report: Performance Benchmarking of Australian Business Regulation: Occupational Health & Safety

The BCA strongly endorses efforts to enhance the effectiveness of occupational health and safety (OHS) legislation and policy and its operation around Australia.
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Submission to the Productivity Commission Discussion Draft on Executive Remuneration in Australia

The determination of executive remuneration is best left to boards who are, in turn, answerable to shareholders.
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Submission to Prime Minister Kevin Rudd on Implementation of the National E-Health Strategy

E-health – using communication technology means to improve the flow of health information – is a key driver of future productivity gains in health.
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Recommendation for an Independent National Health Commission

The health governance merits of establishing an independent national health commission.
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Representations on the Carbon Pollution Reduction Scheme

Letters to the government, the Opposition and two independent senators calling for amendments to the compensation for emissions-intensive, trade-exposed industries in the Carbon Pollution Reduction Scheme.
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Submission to Safe Work Australia on the Exposure Draft Model Act for Occupational Health and Safety Discussion Paper

One set of OHS requirements will not only improve efficiency for both businesses and regulators, but also promote a better understanding of the requirements of the system.
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Submission on the Exposure Draft Regulations to Establish the Emissions Intensive, Trade-Exposed Assistance Program 2009

This submission addresses a number of matters related to the draft regulations for the emissions-intensive, trade-exposed (EITE) industries elements of the Carbon Pollution Reduction Scheme.
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Submissions on Legislation for the National Broadband Network

The government’s legislative framework for the National Broadband Network raises competition policy issues, including issues of competitive neutrality between government-owned and private businesses.
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Submission on the Corporations Amendment (Improving Accountability on Termination Payments) Bill 2009

Considering the issue of termination payments in isolation runs the risk of poor and inefficient regulations being imposed which will be detrimental to Australia’s economy and growth prospects.
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Submissions on the National Consumer Credit Protection Bill 2009

The BCA is generally supportive of a national system for consumer credit – but the additional costs and regulatory burdens of the new laws are of concern.
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Submission to the Productivity Commission Inquiry on Director and Executive Remuneration in Australia

There is a need to promote a wider understanding of the drivers of executive remuneration and company performance.
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Submission to the Inquiry into Building and Construction Industry Improvement Amendment (Transition to Fair Work) Bill 2009

The BCA is concerned to ensure that recent improvements in the industrial climate and stability of the building and construction industries are maintained, especially at a time of general economic downturn.
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Submission to the Department of Resources, Energy and Tourism on the Energy White Paper

The energy white paper is a perfectly timed opportunity to ensure that Australia’s energy policies support the growth of the economy in the period to 2030 and beyond.
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Submission to the Treasury on the ‘Creeping Acquisitions – The Way Forward’ Discussion Paper

No compelling case has been made for new laws on creeping acquisitions and no economy-wide ‘problem’ of creeping acquisitions has been identified.
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Submission to the Senate Select Committee on the National Broadband Network

The government’s National Broadband Network proposal sets a laudable objective to increase broadband provision and offers a roadmap for the ICT sector, but a cost–benefit analysis of the planned rollout is needed.
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BCA/CTA Submission to the Treasury on Employee Share Plans

Joint Business Council of Australia and Corporate Tax Association submission to the federal government on the taxation of employee share schemes.
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Submission to the Department of Broadband, Communications and the Digital Economy on Regulatory Reform for 21st-Century Broadband

This submission calls for the government to undertake a cost–benefit analysis of the NBN and to urgently complete the NBN implementation study, to provide clarity on the proposal and its likely impact on the market.
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Submission to the Minister for Competition Policy and Consumer Affairs Regarding Draft National Unfair Contracts Provisions

As currently drafted, the proposals represent a substantial change to the fundamental underlying principles of contract law and present a significant risk to businesses across all sectors.
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Submission to the House of Representatives Joint Standing Committee on Treaties regarding the ASEAN–Australia–New Zealand Free Trade Agreement

If the agreement is ratified and comes into force, it will provide some significant new commercial opportunities for businesses, and generate additional economic benefits for the people of the nations involved.
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Submission to the Senate Select Committee on Climate Change Policy on the proposed Carbon Pollution Reduction Scheme

The risks are substantial both if we take no action on global warming, and if we take the wrong action.
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Submission to the Senate Inquiry into the Fair Work (Transitional Provisions and Consequential Amendments) Bill

Through a government–business consultation process, a number of issues within the Fair Work Bill appear to have been addressed, but there are some concerns about the content of the Transitional Provisions Bill.
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Submission regarding the Commonwealth Government Consultation Paper, “The Meaning of ‘Understanding’ in the Trade Practices Act 1974”

Any amendment to the Trade Practices Act should be considered with caution, taking into account the costs and benefits of such a change.
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Submission on the Exposure Draft of the Legislation to Implement the Carbon Pollution Reduction Scheme

Legislation for an emissions trading scheme and its implementation – especially in the early years – will require a tailored approach aligned to global and national economic conditions and designed to ensure Australia’s industry and employment opportunities are not adversely impacted.
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Submission to the National Health and Hospitals Reform Commission Interim Report

The NHHRC review must identify the features of a national healthcare system that is capable of meeting the needs of Australians in the 21st century, and addressing the current and emerging patterns of disease.
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Submission to the National Transport Commission Review Steering Committee on the Operations of the National Transport Commission

This submission outlines the key foundation strategies that should underpin transport reforms in Australia.
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Submission to the Corporations and Markets Advisory Committee regarding the ‘Aspects of Market Integrity’ Discussion Paper

Regulatory intervention in markets should only occur where there is a clearly identifiable problem to be addressed, and the costs of the regulation do not outweigh its benefits to the community and business.
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Submission to the Department of Climate Change on the Renewable Energy Target and Treatment of Electricity-Intensive, Trade-Exposed Industries

The government should reconsider whether there are other, more appropriate policy tools to bring forward both renewable and low-emissions technologies without undermining the Carbon Pollution Reduction Scheme.
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Submission to the Centre for International Economics Review of the Carbon Pollution Reduction Scheme White Paper

The drafting of legislation and the development of an implementation framework for the Carbon Pollution Reduction Scheme is occurring at a time of a sudden and severe downturn in the global economy.
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Submission to the Senate Education, Employment and Workplace Relations Committee Inquiry into the Fair Work Bill 2008

This submission reviews the draft legislation against policies on workplace relations previously published by the BCA, and incorporates feedback from BCA members about their expectations of the impact of the legislation.
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Submission to the National Preventative Health Taskforce Discussion Paper ‘Australia: The Healthiest Country by 2020’

The BCA has only recently sought to contribute to the health reform debate. Despite its comparatively short review of the issues facing Australian healthcare, it is clear that tackling the growing burden of chronic disease is a key priority.
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Submission to the Senate Economics Committee Inquiry into the Statutory Definition of Unconscionable Conduct

The BCA supports appropriate and proportionate laws to promote competition and protect Australian consumers, but it views the existing legislation provides such protection while ensuring that business is also provided with a regime that is workable and certain.
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Submission to Infrastructure Australia on Australia’s Future Infrastructure Requirements

Australia has $20 billion a year to gain from smarter spending on new infrastructure investments, and from making more efficient use of existing investments.
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Submission to the Treasury ‘Creeping Acquisitions’ Discussion Paper

Proposals to amend competition laws for creeping acquisitions may directly contradict commitments to achieve significant deregulation.
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Submission on the Carbon Pollution Reduction Scheme Green Paper

Australia should take a long-term and risk management approach to climate change policy which incorporates both mitigation and adaptation elements, is calibrated to international responses and builds on our skills, resources and regional location.
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Submission to the Review of the Australian Higher Education System

Business is looking to higher education to contribute to meeting the challenges and making the most of the opportunities that Australia will confront over the next decade and beyond.
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Submission on the Design Options for the Expanded National Renewable Energy Target Scheme

While the federal government’s renewable energy target may stimulate the development of renewable energy sources, it is unclear whether this will be done in the most economically efficient manner, and whether it will bias the options for renewable energy expansion.
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Submission on the Trade Practices Legislation Amendment Bill 2008

Any proposals to amend or reform the Trade Practices Act 1974 (Cth) (TPA) require proper economic analysis and consideration of both the policy objectives and practical effect of the proposals.
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Submission on the Trade Practices (Creeping Acquisitions) Bill 2007

The BCA supports robust and effective competition law, because it is an important element of business regulation in Australia. Effective competition is important to maintain adequate consumer choice and to keep prices low.
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Submission to the Review of Export Policies and Programs

Australia has been at the forefront of global market liberalisation in recent years. Market liberalisation has provided Australian enterprises with the opportunity to enter new markets, grow their businesses and contribute to higher levels of domestic growth and higher living standards.
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National Review into Model OHS Laws

Employers operating nationally face a myriad of different legislative and regulatory requirements, which compromises the efficiency, equity and potential effectiveness of occupational health and safety laws.
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Submission to the Review of the National Innovation System

Innovation by Australia’s businesses, governments and research institutions has delivered many economic and social achievements. But we need to continually improve and adapt to a fast-changing global environment.
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Initial Submission to the National Health and Hospitals Reform Commission

As we face new possibilities and difficult choices about the allocation of scarce resources, we all need to take responsibility for understanding the challenges and participating in the health debate.
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Submission to the Productivity Commission Inquiry into Paid Maternity, Paternity and Parental Leave

Work–family issues are integral to Australia’s future economic and social prosperity, and as a society we must find ways to make workforce participation easier for women of child-bearing age.
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Submission to the Strategic Review of Climate Change Programs

There is a renewed focus on national and international responses to climate change and in particular, the design of a national emissions trading scheme.
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Submission on Component Pricing: Trade Practices Amendment (Component Pricing and Other Measures) Bill 2008

April 2008: This submission follows previous submissions on section 53C of the TPA, in which the BCA did not support the proposed amendments.
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Submission to the Garnaut Climate Change Review on Emissions Trading Scheme Design Principles

Climate change policy must not disadvantage Australia’s competiveness and must ensure a smooth, long-term transition to a low-emissions economy in line with global action.
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Submission to the Senate Inquiry into State and Territory Fiscal Relations and State and Territory Government Financial Management

March 2008: This submission argues that major barriers to reform in areas such as special purpose payments, state government financial management and infrastructure, are associated with poor cooperation between governments.
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Submission on the Draft Legislation for Criminal Penalties for Serious Cartel Conduct

March 2008: Cartel conduct is inconsistent with the efficient operation of markets, and the BCA has always supported the criminalisation of serious cartel conduct.
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Submission to the Inquiry into Shareholder Engagement and Participation

The Australian corporate governance environment is overregulated, which creates major impediments to effective shareholder engagement.
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Submission to the Senate Standing Committee on Education, Employment and Workplace Relations Inquiry into the Workplace Relations Amendment (Transition to Forward with Fairness) Bill 2008

Those who are implementing and administering the workplace relations legislation must minimise risks to productivity, employment opportunities and inflation.
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