Submission

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.

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.

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.

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,

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.