WAFIC responds to AMSA review on cost recovery
The WA Fishing Industry Council has provided its response to the Australian Government’s independent review into cost and charging arrangements for domestic commercial vessel safety legislation (Phase 2).
The review is in two phases:
- Phase 1 – to consider whether Australia’s legal framework for the safety of domestic commercial vessels (DCVs) is fit for purpose,
- Phase 2 – to consider whether the framework is being delivered efficiently and effectively, and options for future funding arrangements for the National System – including costs recovery.
Phase 1 consultation is complete. You can read the Phase One submission here.
WAFIC co-ordinated an industry-wide submission response, as well as an online meeting with the Panel in January 2023.
When considering ‘who pays the costs,’ WAFIC suggested the first step is to determine ‘what are the costs?’
WAFIC set out to ensure that there is not a set-and-forget approach to the AMSA service delivery activities and that there is an agreed formal consultation arrangement in place for stakeholders to assist AMSA through regular review and recommendation of changes to the annual service delivery activity program. This supports the industry view that ‘user pays/user has some say’ approach to cost recovery.
The commercial fishing industry has significant experience with cost recovery through application of the Australian Government Cost Recovery Guidelines within the Australian Fisheries Management Authority (AFMA) and several state jurisdictions over time. In reviewing cost recovery each year, AFMA will seek comment on draft budgets from relevant stakeholders such as the relevant peak industry associations, each of the fishery Management Advisory Committees and other relevant consultative bodies using an activity-based costing process.
This consultation process is important, from an AMSA perspective, and WAFIC is of the view that this could be carried out through the existing AMSA National Safety Committee and Regional Safety Committees industry advisory processes.
Under the AFMA system, the Commonwealth commercial fishing industry pays for those costs directly attributable to the fishing industry, while the Australian Government pays for any costs identified as more directly benefiting the broader community, or where it is inefficient to recover the cost.
In accordance with the Australian Government Charging Framework and the Guidelines a review and analysis of the activities undertaken by AFMA is conducted to determine which of those should be cost recovered.
AFMA applies an activity-based approach to enable the agency to determine the costs associated with each activity within the defined key activity groups.
The AFMA key activity groups provide an overview of the activities included and, most importantly, the beneficiaries of those activities to enable determination of who is responsible for the costs associated with each activity.
WAFIC proposed a combination for the AMSA levy formula incorporating:
- A flat rate per metre of vessel length; plus
- A tiered level for inspection/audit by Class.
You can view the WAFIC submission here
The Independent Panel will be holding targeted public consultation sessions in Perth, Albany and Geraldton in the week 6-10 March 2023. You can register your interest in attending these meetings with the Panel by emailing [email protected]