Problems relating to Trade and Investment on Australia
23. Inefficient administrative procedures, regimes and practices |
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Issue |
Issue details |
Requests |
Reference |
| (1) Delays in the Governmental Approval Procedures of Various Kinds | - GOA's reaction is slow; taking more than 6-weeks on products (note) for which GOA's approval is required. These are the products for which GOA's approval is required for safety, market compatibility certificate, etc. before they are allowed to enter Australia. | - It is requested that GOA will reinforce its staff on provision of online approval service, which GOA has started since October 2008. Due to the staff shortage, online service takes longer than the previous manual handling. | |
| (2) Varying Licences and Approvals By State | - A licence obtained in one State is not necessarily valid in another State, due to differences of laws in the other State for example, in the adjoining states of Queensland and New South Wales. Because laws and regulations on electrical licences are different in these states, two licences are necessary to repair or service products installed over the State borders. It doubles the cost of acquiring the electrical licences. | - It is requested that GOA promulgated new regulations on the electrical licences that is valid universally nationwide or each state permits provisions of services based on the electrical licences issued by other states. | |
| (3) Inflexible Contracts on Railway/Harbour Concerning Coal Mine Development | - In the context of the coal mine development in Australia, it seems "Inflexible provision in the Contracts on Railway Transport and Harbour Utility (CRTHU)" negatively impacts in adjusting the production volume (from oversupply). Specifically, railway transport is divided into Below Rails (BR) and Above Railroad Car (ARC) against the annual contract frame, including the monthly frames (split evenly per month over 12-months). Consequently, it is suggested that the monthly tolerance (of say, plus or minus 10% over the monthly frame) would better enable contractors to accommodate the CRTHU requirements. In actual implementation, particularly in cases of open-cut mining, the coal production volume goes up during the dry season, compared to the rainy season. From users' perspective, flexibility in implementation is apparently missing. HARBOUR UTILITY: Monthly Utility Frame (MUF) is evenly split into 12-months. It is considered better to give certain flexibility (such as plus or minus 10% over the monthly frame) if within the annual frame, the same as rtransport. Apart from the foregoing, as regards Harbour utility (Hutility), compared to the existing ports, it is said that the take or pay obligations per ton under the new MUF is higher than that of the existing ports, where depreciation write-off has far advanced. GOA's price contro on Hutility feesl, to a degree, is requested from the users' perspective to avoid substantial gap in Hutility Fees between the new and the existing ports. Otherwise, it would let the existing business entities with the allocated utility frame to enjoy a better competitive position in price. |
- While, as a matter of course, including financing of the railway/port operation, its viable construction/operation is not possible without the take or pay obligations, it is equally difficult to select more advantageous ports, in respect of the relative locations of the coal mine and the ports, and the connecting railway facilities, all of which cannot be readily changed overnight. - It is requested that GOA: -- takes measures to provide some flexibility per month or -- in the event of using new ports, adopts the policy to narrow the gap in MUF between the existing and new ports. |
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