Macedon Ranges Residents’ Association Inc.Regn. No. A0034439T
2 Dalrymple Road, Gisborne, 3437Web: www.mrra.asn.au P.O. Box 183, Gisborne, 3437.
Email:email@example.com Telephone: (03) 5428 3197 (Pres), (03) 5427 1481 (Sec)
A Sustainable Future For Victoria: Getting Environmental Regulation Right
Victorian Competition and Efficiency Commission
15 May 2009
Thank you for this opportunity to comment.
Our Association does not support the Commission’s recommendations, or the basis for them.
It’s Not A Credible Assessment
It is admitted in the Discussion Paper that thebenefits of environmental regulation haven’t been measured (or sufficiently
measured), which is further built on by a lack of available, relevant information for costs, as noted in the report. Consequently, we
feel the resultant recommendations lack the credibility and sustainability credentials they may have had if they had been
underpinned by a genuine and informed benefit to cost assessment. They, and the justification put forward for them, instead appear
to be little more than a cost (if not corner) cutting exercise. As it stands, the recommendations respond to only a single element of
sustainability: economic. Real sustainability entails considering effects on environment and society as well, that is, looking at more
than costs and convenience for business.
Dangers Of Deregulation: Insufficient Accountability And Transparency
Regulation is about setting and meeting standards. The single most potent contributing factor in the global financial meltdown is
deregulation. The consequences of deregulation have had a detrimental impact on all, not just those who benefited from
deregulation. Deregulation advances the interests of the few, and absolves individuals and companies of the responsibility of
considering the consequences of their actions on the many. Loss of standards also entails loss of accountability – of being
accountable for actions and consequences – and concurrent loss of transparency in decision-making, none of which we believe is
in, or furthers, the public interest or environmental well-being.
Put Long-Term Public Interest Before Individual Interests Of The Day
In the quest to address individual and business interests of the day, the Commission seems to have lost sight of the long-term
interests of the public, and the environment. There are public health, genuine sustainability and inter-generational issues at play in
making decisions about winding back standards for environmental matters, particularly when such action has potential to increase
adverse environmental outcomes over time and further contribute to climate change. Nothing justifies convenience being given a
higher priority than long-term well-being and survival.
The Commission’s recommendations may save some time and money, but in our view they will also deliver lower standards,
accountability and transparency, and encourage higher and more risk taking. This is ‘getting environmental regulationwrong’. We
ask the Commission to rethink its recommendations against the long-term public interest and achieving genuine sustainability, and
to consider the potential impacts future generations will be left to deal with by the short-cuts we take today.
Christine Pruneau, Secretary.