The Minerals Council of Australia, Victoria Division (MCA) welcomes the opportunity to comment on the Regulatory Impact Statement and Draft Mineral Resources (Sustainable Development) (MR(SD) Regulations.

The MCA does not support cost recovery to fund the State in carrying out its legislative responsibilities.

Cost recovery is viewed as an additional disincentive to invest in Victoria, at a time when attracting investment is increasingly difficult and Victoria is considered a less than attractive place to invest in comparison with other Australian and international jurisdictions.

The Regulatory Impact Statement (RIS) does not adequately explore the costs to industry and therefore strange that a proposal to increase the costs of doing business at a time when cost pressures are high and exploration expenditure is the lowest for some time is recommended. This sends a poor signal to investors who already consider Victoria less than attractive as an investment destination.

Of the options presented in the RIS - Option 2a is supported.

The MCA is supportive of the Victorian Government’s appointment of a Commissioner for Red Tape to deliver on its commitment to reduce red tape by 25 per cent and implement the recommendations arising from the Economic Development and Infrastructure Committee Inquiry into Greenfields Exploration and Mineral Development in Victoria (EDIC), including to enshrine statutory time frames into the MR(SD) Act.

Given the expected substantial reforms to the MR(SD) Act and subsequently the MR(SD) Regulations, cost recovery should not be introduced. Recovering costs for regulatory effort based on today’s laws and regulatory practices means that a significant reassessment and calculation is required soon thereafter.

Furthermore with the Machinery of Government changes; a renewed focus on organisational culture change and the potential for performance incentives will drive improvements in regulatory practice.

Cost recovery should only be considered within the wider MR(SD) Act reform process, through the facilitation of higher and more efficient levels of service. Accordingly, the MCA considers that any cost recovery imposed on industry be clearly linked to improved service delivery and only commence once the service expectations have been met.

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