ATTACHMENT E – Regulatory Burden Measurement Costings
Contents
Attachment E-1: Emission reduction options ............................................................................ 2
Attachment E-2: Management of new gases .......................................................................... 11
Attachment E-3 - Approach to controlling HCFC imports post 2020 ...................................... 14
Attachment E-4 - Reduce regulatory burden on low volume importers ................................ 17
Attachment E-5 - CFC HCFC and Halon equipment thresholds ............................................... 21
Attachment E-6 - Renewal of import, export and manufacturing licences ............................. 29
Attachment E-7 - Reduction in import, export and manufacturing reporting and levy
payment frequency .................................................................................................................. 32
Attachment E-8 - Introduce a power for the Minister to waive low value levy and penalty
debts ........................................................................................................................................ 35
Attachment E-9 - Streamlining SGG import and manufacture exemptions ............................ 38
Attachment E-10 - Provide an exemption to allow for the use of methyl bromide for
laboratory and analytical purposes ......................................................................................... 42
Attachment E-11- Remove requirement for Methyl Bromide buyers to report on stockpiles
.................................................................................................................................................. 45
Attachment E-12 - Remove requirement for methyl bromide users to keep summary records
of use........................................................................................................................................ 47
Attachment E-13 - Maximum allowable import quantity of methyl bromide ........................ 50
Attachment E-14 - HCFC quota flexibility ................................................................................ 53
Attachment E-15 - Exempt feedstock uses of ozone depleting substances from the import
levy ........................................................................................................................................... 56
Attachment E-16 - Addition of internal review mechanism to Ozone Act .............................. 59
Attachment E-17 - Defining the import licensing scheme ....................................................... 61
Attachment E-18 - Restructure of import, export, manufacture controls .............................. 67
Attachment E-19 - End-use licensing provisions under the Ozone Regulations ..................... 72
Attachment E-20 - End-use reporting provisions under the Ozone Regulations .................... 88
Attachment E-21 - Restructuring end-use licences under the Ozone Regulations ................. 95
Attachment E-22 - Restructuring end-use licences under the Ozone Regulations ............... 103
Attachment E-23 - Streamlining destruction facility approval .............................................. 111
Attachment E-24 - Compliance and Enforcement ................................................................. 113
Attachment E-25 - National Halon Bank Arrangements ........................................................ 116
Page | 1
Attachment E-1: Emission reduction options
Instrument
Title
Emission reduction options
Average annual regulatory costs (from business as usual)
Change in
costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Measure 6.1.2
(HFC phasedown)
$0.017,770
$0.017,770
Measure 6.1.3
(HFC
equipment
bans)
$11.021 663
$11.021 663
Measure 6.1.4
(maintenance
and leak
testing)
$471.997,994
$471.997,994
Cost offset
($ million)
Agency
Business
$
Community
organisations
Individuals
$
$
Total, by source
($ million)
$
Are all new costs offset? (tick)
 Yes, costs are offset by savings from the Ozone Act Review project (pending Board
approval)
Total (Change in costs – Cost offset) = $.....
Background
The Australian Government is committed to reducing emissions to meet its Kyoto
Protocol target of five per cent below 2000 levels by 2020. Australia’s target poses a
challenge because emissions are projected to increase without further action. To meet
the 2020 emissions reduction target, Australia needs to reduce its emissions by a
cumulative 236 million tonnes carbon dioxide equivalent (Mt CO2-e) from 2013 to 2020.
Synthetic greenhouse gas (SGG) emissions accounted for around 1.5 per cent of
Australia’s annual net CO2-e emissions (excluding emissions from land use, land use
change and forestry) in 2012. By gas types, HFC emissions account for 1.45 per cent,
Page | 2
PFCs for 0.05 per cent and SF6 for 0.01 per cent of Australia’s total annual emissions in
2012. Reducing emission of these gases could contribute to Australia meeting its Kyoto
Protocol targets.
Reduction of direct emissions from refrigeration and air conditioning (RAC) equipment
is only part of the story. Refrigeration and air conditioning (RAC) equipment also
consumes large amounts of energy which produce large amounts of indirect greenhouse
gas emissions. For example, in 2012 there were approximately 45 million individual
pieces of RAC equipment operating in Australia which consumed approximately 22 per
cent of total energy produced, at an estimated cost of $14 billion dollars to the Australian
economy. The total indirect greenhouse gas emissions from powering RAC systems is
estimated at more than 10 per cent of Australian greenhouse emissions (57.1 MtCO2e/year). When combined with direct emissions of SGGs, RAC equipment accounts for
approximately 61.2 Mt CO2-e per annum or 11.1 per cent of Australian emissions
reported in 2011-20121.
The Interim Report considers implementing a HFC phase-down to secure technology
change which could be supported by:





Continuing the current emission reduction schemes (end-use licensing and product
stewardship)
Improved handling practices for the servicing of mobile air conditioning
Banning import and manufacture of specified equipment containing a high-GWP gas
Requiring maintenance of refrigeration and air conditioning equipment
Requiring leak testing of refrigeration and air conditioning, and fire protection
equipment
A cost benefit analysis is being undertaken for the range of options.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of
the proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 The wage rate of $37.40/hr has been used, with a wage multiplier of 1.75.The wage
rate for technicians is $150/hour (includes on-costs).
 It is assumed that the refrigeration and end use licensing scheme continues under all
options.
 Where relevant, the costs associated with maintaining an import/export licence are:
 3 hours and 45 minutes to complete licence application (finding and completing
licence application, contacting the Department throughout the application
process, obtaining certified identification documentation, time taken to pay the
application fee)
 60 minutes per quarter to complete quarterly reporting (30 minutes collecting
1
Cold Hard Facts 2: http://www.environment.gov.au/system/files/resources/fa48d00d-1fb9-4797-90f447a6eed2c9c7/files/cold-hard-facts2.pdf
Page | 3
inputs, 20 minutes to complete reporting on the Ozone Licensing and Report
System (OLaRS), 5 minutes record keeping, 5 minutes to read the notification)
 6 minutes per quarter for reading a notification that they will be receiving an
invoice
 30 minutes per quarter to pay invoices sent to the licence holder by the
Department (includes receiving, processing and lodging payments).
Explanation of measure and relevant assumptions
HFC phase-down
Total
regulatory
cost p.a.
$17,770
Description of measure: HFCs would be phased-down using a quota system based on
the current licensing scheme. A HFC phase-down schedule would be inserted, similar to
the existing HCFC phase-out schedule. The quota allocation system would have two
parts: quota allocation for existing importers and allowance for new entrants.
The regulatory burden on existing importers is expected to be low. Existing importers
would be required to educate themselves on the new regulatory requirements; the
Department would provide information on the changes. Very little change to their
current business practices would be required as they already apply for a licence, pay levy
and report their activities.
The regulatory burden on new entrants is expected to be higher than it is for existing
importers. New entrants would be required to apply for a licence and quota. In order to
apply for quota they would need to submit a justification on why they should be
allocated quota and how much is required. This would likely be based on commercial
relationships the new entrant had or was forming down the supply chain.
As these importers would be required to apply for and hold a SGG Controlled Substance
Licence irrespective of this policy, the administrative costs associated with the licence
administration have been disregarded.
Assumptions:






Quota would be allocated every second year: a total of 5 times during the RBM
period.
5 new entrants would apply for the quota each allocation period.
It takes each new quota applicant 3 hours to develop their justification for quota.
There are currently 28 importers who could be eligible as existing importers for
quota allocation. It is assumed that all 28 apply for quota.
The costs associated with holding a licence are excluded as the measure does not
introduce these requirements. These requirements would apply even if this measure
was not implemented.
End use technicians may read education materials on the new regulations. It is
assumed that this information is published in the CoolChange magazine produced by
the Australian Refrigeration Council. As the technician would be reading this
publication irrespective of this measure, it is assumed that the education costs are
Page | 4

zero.
Customs Brokers will also need to be informed on the changes to the Ozone Act. It is
assumed that this information and any additional training required would be done as
part of their business as usual training and information updates that they would be
reading irrespective of this measure. It is assumed that the education costs for this
group of stakeholders is zero.
High GWP equipment ban
Total
regulatory
cost p.a.
$11 021 663
Description of measure: Impose an import and manufacture ban on mobile air
conditioning equipment containing gas with a global warming potential (GWP) >150 in
2017 and imposing ban on supermarket equipment containing gas with GWP >2,500 in
2020. As the gas in alternative equipment will not be covered by the Ozone legislation,
importers will no longer have to hold a SGG Equipment Licence. This is a reduction in
their regulatory burden.
This measure does not limit the import of bulk gases currently used to service these
equipment types. Bulk gases can continue to be imported and existing equipment can
continue to be serviced until it reaches the end of its natural life.
The international market is transitioning to low or no-GWP alternatives in these two
equipment types. The transition is well advanced in the supermarket sector with
commercially viable alternatives already being used in the market. There is no difference
in capital costs between high GWP equipment and lower GWP alternatives (Phase Down
of HFC Consumption in the EU – Assessment of Implications for the RAC Sector, September
2012, SKM Enviros).
For passenger vehicles, there is expected to be a strong shift towards low GWP
alternatives driven largely by the European Union’s ban on introducing mobile air
conditioning units charged with gases >150 in 2017. Early shifts away from high-GWP in
this sector can also be seen in the American, Japanese and Korean car manufacturing
markets in response to policies that will have a similar result.
The dominant gas used in Australia for passenger vehicles is currently R134a. The
Expert Group estimate that by 2020 alternative technologies will have entered the
market with R134a being used in approximately 60% of the market. By 2025, this
number drops to zero (HFC Consumption in Australian in 2013 and an Assessment of the
Capacity of Industry to Transition to Nil and Lower GWP Alternatives, April 2014, Expert
Group).
As this sector is currently undergoing transition to alternatives, there is a small
difference in capital costs between high GWP equipment and lower GWP alternatives.
For small mobile air conditioning units in passenger vehicles there is estimated to be a
5% increase in capital costs of the system (not the whole vehicle) (Phase Down of HFC
Consumption in the EU – Assessment of Implications for the RAC Sector, September 2012,
SKM Enviros). This estimate was made before the technology was fully developed and as
such is likely to be on the high side of the actual capital cost increase. There is also a
Page | 5
second wave of alternative gases and alternative technologies which will force down the
price of new generation gases or new generation equipment since 2012.
Assumptions:












As the RBM period of 2017-2027 is assumed, all years would be included for MAC
importers and only seven years for supermarket equipment containing gas with GWP
>2,500.
The current numbers of licence holders is accurate for when the bans are imposed on
MAC. Unlike the importers of bulk gas, it is assumed that importers of MAC only
import this type of equipment as they generally are automotive specialists.
There are approximately 260 licensed importers of mobile air conditioning
equipment (February 2015) who will no longer need to have a licence
There are approximately 200 licensed importers of equipment containing HFC-404A,
which is primarily used in the supermarket sector (February 2015).
The number of licence holders for supermarket equipment decreases in advance of
the ban by 25% leaving 150 licensed importers in 2020. It is assumed that half of
these importers would also import other types of equipment under their licence.
Therefore 75 importers would no longer have to hold a licence.
335 importers will no longer have to hold a licence. Each importer will save
approximately 7.15 hours a year in administrative duties no longer required to
acquire and maintain licence.
It is assumed that as the ban relates directly to their business, all 335 stakeholders
will read the information material. It is assumed it take an importer 6 minutes to
read the education material (single page letter from the Department). This is a oneoff cost.
Customs Brokers will also need to be informed on the changes to the Ozone Act. It is
assumed that this information and any additional training required would be done as
part of their business as usual training and information updates that they would be
reading irrespective of this measure. It is assumed that the education costs for this
group of stakeholders is zero.
End use technicians may read education materials on the new regulations. It is
assumed that this information published in the CoolChange magazine produced by
the Australian Refrigeration Council. As the technician would be reading this
publication irrespective of this measure, it is assumed that the education costs are
zero.
There is no difference in cost between the capital cost of supermarket equipment
containing gases with GWP >2500 and equipment that contains lower GWP
refrigerant gas. This is based on modelling done in the European Union to measure
the capital cost of reducing HFC consumption (Phase Down of HFC Consumption in the
EU – Assessment of Implications for the RAC Sector: Final Report, September 2012,
SKM Enviros). The new generation of equipment is also more energy efficient,
providing a continuing saving to consumers during the life of the system.
There were approximately 20 000 pieces of supermarket equipment imported in
2014.
There is a small difference in cost between the capital cost of a mobile air
Page | 6
conditioning unit and equipment that contains lower GWP refrigerant gas. For the
compliance cost for mobile air conditioning units the following assumptions have
been made:
 There is a 5.0% increase in the capital cost of air conditioning systems in
passenger vehicles that have low GWP refrigerant and air conditioning systems in
2017. This falls by 1% each year to reflect the wider market acceptance of
alternative systems (see table below). This is a conservative assumption as it is
likely that the capital cost for this equipment has already fallen since 2012.
 The average cost of a car air conditioning unit is $1,000 (based on data from
Phase Down of HFC Consumption in the EU – Assessment of Implications for the RAC
Sector: Final Report, September 2012, SKM Enviros).
 There were approximately 920 000 passenger vehicles with air conditioning
systems charged with R134a in 2014. It is assumed that the size of the market
remains the same over the modelling period.
 Based on the transition away from mobile air conditioning using R134a, the
number of cars that are expected to be imported using low GWP alternatives each
year is set out in the table below:
Page | 7
Year
Increase in
capital cost
(%)
Difference in cost
between existing
and alternative
technology
5
Number of
passenger vehicles
imported
containing low
GWP gases
920 000
2017
2018
4
782 000
40
2019
3
644 000
30
2020
2
552 000
20
2021
1
414 000
10
2022
0
276 000
0
2023
0
184 000
0
2024
0
119 000
0
2025
0
0
0
2026
0
0
0
2027
0
0
0
50
Measure 6.1.4 : Maintenance and leak testing of equipment
Total
regulatory
cost p.a.
$471,997,994
Description of option: Require equipment owners to undertake routine maintenance
of select classes of commercial refrigeration and air conditioning equipment based on
the charge size in t CO2-e as follows:



Charge size >5 t CO2-e must be undertaken every 6 months
Charge size >50 t CO2-e must be undertaken annually
Charge size of >500 t CO2-e must be undertaken every 6 months.
This schedule is consistent with the European Union’s F-Gas regulation. It has been
assumed that many equipment owners already undertake regular maintenance. The
frequency of this activity is set out in Table 2 below. Where the levels of current
maintenance exceeds what would be required under the regulation it has been assumed
that this level is maintained (e.g. no reduction in behaviour).
Maintenance requirements do not compel an equipment owner to fix any leaking or
broken equipment and therefore stopping the ongoing emission of SGGs. Equipment
leaks are not currently covered by the current emissions ban in the Ozone Act (s45B). In
order to compel the equipment owner to not only leak test but also to fix the leak, the
emissions ban would be amended to make it an offence for an owner to knowingly
continue to use leaky equipment.
Assumptions:



There are 1.8 million pieces of equipment owned by 1.8 million commercial entities
(in reality owner numbers will be lower but the cost impact is insignificant as the
costs are centred on equipment numbers not owner numbers).
It is assumed that 50% of equipment owners already undertake equipment
maintenance across all categories of equipment. It is assumed that 50% of equipment
owners would need to implement a maintenance regime.
The number of pieces of equipment remains the same over the RBM period and are
as below:
 Refrigerated cold food chain equipment with remote condensers:
 Annual leak test: 119,050
 Six monthly leak test: 22,800
 Automatic leak detection and six monthly leak test: 700
 Refrigerated cold food chain equipment – supermarket systems (independents
only):
 Six monthly leak test: 800
 Medium air conditioning units (commercial only):
 Annual leak test: 740,950
 Six monthly leak test: 6650
 Large air conditioning units (chillers):
 Annual leak test: 450
 Six monthly leak test: 11,700
Page | 8
 Automatic leak testing and six monthly leak test: 1700
Large mobile air conditioning
 Annual leak test: 34,900
There is a transition cost for all equipment owners of 0.5 hours to read and
understand new requirements (consistent with Jacobs CBA).
It takes each owner 0.5 hours to order maintenance to be undertaken and make
appropriate records; and 0.5 hours to order leak testing to be undertaken and make
appropriate records
An automatic leak detection system costs $1,500 to purchase.
It costs $500 to have an automatic leak detection system installed.
It is assumed that it takes about 2.5 hours to undertake maintenance activity. This
includes leak testing and repairing leaks if necessary. $100 of parts is used to fix
leaks. It is assumed no new parts are used to maintain equipment.
End use technicians may need to undertake additional training to be competent in
this area. No cost is attributed to this as the technician would be undertaking training
irrespective of this measure as part of the end use licensing scheme.
End use technicians may read education materials on obligations for equipment
owners. It is assumed that this information published in the CoolChange magazine
produced by the Australian Refrigeration Council. As the technician would be reading
this publication irrespective of this measure, it is assumed that the education costs
are zero.








Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 9
Page | 10
Attachment E-2: Management of new gases
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Measure 7.1.1
$23
Measure 7.1.2
$725
$
$
$0.000 725
Business
Community
organisations
Individuals
Total, by source
$
$
Cost offset
($ million)
Agency
$
$0.000 023
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
The Ozone Act covers the gases Australia is obligated to regulate under the Montreal Protocol,
the Vienna Convention, the UNFCCC and its Kyoto Protocol. Due to changing international
obligations new gases may occasionally be added to the list of scheduled substances under the
Ozone Act.
The objective of the new policy measure is to:


Ensure Australia fulfils its international obligations on ozone depleting substances and
synthetic greenhouse gases, and
Ensure Australia has an understanding of the import, export, manufacture and use of
substances in Australia that may be subject to international obligations in the future.
The options being considered are:


To undertake informal and voluntary data collection
To regulate gases as required under Australia’s international obligations and undertake
informal and voluntary data collection
Page | 11
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 Research undertaken by the Department indicates a very small group of stakeholders would
be impacted by the proposed addition of specific new gases to the Ozone Act. It is anticpated
that approximately 7 current licence holders and no new stakeholders may be required to
report on new gases.
 Assumes standard wage rate of $37.40.
Explanation of measure and relevant assumptions
Measure 7.1.1– Undertake informal and voluntary data collection
Total
regulatory cost
p.a.
$23
Description of option:
The Department could undertake informal and voluntary data collection on the imports of
specified substances not currently covered by the Ozone Act. This would include accessing data
from the Australian Customs and Border Protection Service and seeking information from
known importers via surveys or other voluntary data collection methods.
Non-regulatory data collection

All parties importing goods into Australia must record their imports against Customs
Tarriff Codes. The Department could access data reported against these codes. This
would create nil additional burden to stakeholders.
Voluntary response to data collection


Assumes response rate of 20% to direct request to 7 known stakeholders.
Assumes it would take 30 minutes to respond to the request.
Measure 7.1.2- Include gases as required by Australia’s international
obligations and undertake informal and voluntary data collection
Total
regulatory cost
p.a.
$725
Description of option:
The Department could undertake informal data collection (as outlined in Option 2) and in
addition, regulate new substances now included in Australia’s international obligations.
Page | 12
Regulation of substances will require stakeholders to hold an import licence and undertake
regular reporting, payment and education obligations.
Non-regulatory data collection

All parties importing goods into Australia must record their imports against Customs
Tarriff Codes. The Department could access data reported against these codes. This
would create nil additional burden to stakeholders.
Voluntary response to data collection


Assumes response rate of 20% to direct request to 7 known stakeholders.
Assumes it would take 30 minutes to respond to the request.
Regulate new gases



Assumes all of the 1200 licence holders would read a direct communication of one page
from the Department. This would take 5 minutes to read.
Assumes 7 current licence holders already fulfil obligations for other substances and may
be required to report on specific new gases. New gases would add approximately 10
minutes per year additional burden to those obligations.
Assumes no new stakeholders would be affected.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 13
Attachment E-3 - Approach to controlling HCFC imports post 2020
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Option 1:
Legislative
approach
$778
$0
$0
$0.000 778
Option 2:
Low regulation
approach
$1,066
$0
$0
$0.001 066
Business
Community
organisations
Individuals
Total, by source
$
$
$
$
Cost offset
Agency
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from Ozone Act Reivew (pending Board approval)
 No
Total (Change in costs – Cost offset) =
Background
Australia is required to phase-out hydrochlorofluorocarbons (HCFCs) as part of its obligations
under the Montreal Protocol on Substances that Deplete the Ozone Layer. Australia has Montreal
Protocol obligations to limit the use of imported new HCFCs to servicing existing refrigeration
and air conditioning equipment after 2020.
Two options are being considered to assist Australia meet its obligations:

Make a legislative licence condition that bulk HCFC importers only import for the purpose of
servicing refrigeration and air conditioning equipment and a new provision making it an
offence to import HCFC for any purpose other than servicing existing refrigeration and air
conditioning equipment (Option 5.4.2).
Page | 14

A low regulation approach which would use existing licence controls on import and supply of
HCFC for the purpose of servicing existing equipment (Option 5.4,3).
The effect of each option would be similar for industry. Early industry preference is for a
legislated licence condition.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 It is assumed that the period these measures are costed over is 2017-2027.
 The standard wage rate has been used ($37.40).
 That the Department contacts each bulk import and equipment import stakeholder directly
when the change is made.
 It is assumed that all importers read the education material.
 Already a high level of knowledge amoung bulk importers and equipment importers about
their obligations. 6 minutes is required to read 2 pages of information.
 That 80,000 end users access information about licence changes through existing
Departmental material.
 The effect of these changes on HCFC fire protection equipment can be discounted as this
equipment will be banned from import or manufacture from 2020
Explanation of measure and relevant assumptions
Measure 7.2.1 : Legislative approach to HCFC imports post 2020
Description of option: A legislative approach which would see the Ozone
Act amended to add in a condition of a licence to import HCFC, that limits the
servicing of HCFC imported to existing refrigeration and air conditioning
equipment. This would be supported by extending HCFC equipment import
and manufacture bans and a new regulatory offence provision for end users.
Total
regulatory cost
p.a.
$778
Assumptions:



Notification to bulk importers about changed legislative
requirements that limits HCFC imported to being used to service
refrigeration and air conditioning equipment (one-off, 8 importers, 6
minutes reading time)
Bulk importers checking with clients about intended uses of HCFC
imported (annual, 8 importers, 0.1 hour each for 5 clients per
importer)
Notification to equipment Importers about HCFC import equipment
ban (one-off, 1100 equipment importers, 6 minutes reading time)
Measure 7.2.1 (alternate): Low regulation approach to supply and
imports of HCFC post 2020
Page | 15
Total
regulatory cost
p.a.
Description of option: A low-regulatory approach which would make it a
condition of licence that HCFCs imported and supplied in Australia can only
be imported and supplied for the purpose of servicing existing refrigeration
and air conditioning equipment. This would be supported by extending
existing HCFC equipment import and manufacture bans.
$1,066
Assumptions:



Notification to bulk importers and their clients about changed licence
requirements that limits HCFC imported and supplied to servicing
existing refrigeration and air conditioning equipment (one-off, 48
importers and wholesalers, 6 minutes reading time)
Bulk importers and their clients checking with clients about intended
uses of HCFC imported (annual, 48 importers and wholesalers, 0.1
hour each for each import and wholesaler client)
Notification to equipment importers about HCFC import equipment
ban (one-off, 1100 equipment importers,6 minutes reading time).
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
Accountable Authority
Signature
(Accountable Authority)
Date
Page | 16
Attachment E-4 - Reduce regulatory burden on low volume importers
Instrument Title
Average annual regulatory costs (from business as usual)
Business
Community
organisations
Individuals
Change in costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
Total change in
costs
($ million)
-$0.177 855
$
$
-$0.177 855
Business
Community
organisations
Individuals
Total, by source
$
$
$
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$0.177 855
Background
Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 and associated legislation
(the Ozone Act) regulates the manufacture, import, export, use and disposal of ozone depleting
substances (ODS) and synthetic greenhouse gases (SGGs) and equipment containing these gases
through import, export and domestic use licensing systems.
The requirement to hold an ODS/SGG equipment licence places an administrative burden on low
volume importers which outweighs the amount of gas imported, the amount of revenue collected
and the potential for emissions to occur. The current exemption threshold for SGG equipment,
where no licence, reporting or levy requirements apply, is set at 5 pieces of equipment
containing up to 10 kilograms of gas once in a two year period. The objective of this proposal is
to consider increasing the threshold for low volume exemptions to reduce the burden on low
volume importers and so that the scheme concentrates on importers who import more
significant quantities of gas.
Currently, imports for 60% of all the entities required to hold a licence amount to 1% of the total
quantity of SGGs imported on a carbon dioxide equivalence basis. Extending the exemption to
these importers would not have a significant effect on Australia’s ability to meet its international
reporting obligations and is unlikely to provide a competitive advantage for the exempted
importers.
Page | 17
The specific proposal costed here is to remove the constraint on the number of items which may
be imported and to raise the threshold for metric tonnage from 10kg to 100kg in a two year
period.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 In the 10 year costing period there are 5 licence periods and each has a 2 year duration.
 It is assumed that the period these measures are costed over is 2017-2027.
 Costing is based on 2013-14 reporting data
 Standard labour cost of $37.40 per hr.
 This measure would impact 700 entities every two year period.
 The first page of education material takes 5 minutes to read each additional page takes one
minute.
Explanation of measure and relevant assumptions
Component: Reduced licensing
Total
regulatory cost
p.a.
-$ 0.049 480m
Excluded importers do not require a licence to import. Changing the low volume threshold from
10kg to a maximum of 100kg would exclude around 1% of imports, based on carbon dioxide
equivalence, and exempt 700 of the 1200 current licensees from the requirements of the Act. In
the 10 year costing period an entity would require 5 licences. The total savings of excluding 700
entities 5 times from the need to apply for a licence consists of:



$34,361 in total from the 1.5 hours saved by each importer who is no longer required to
submit documents needed to complete a licence application: ID certified as a true copy by a
Justice of the Peace, or other appropriate person, and collate other documents, (invoices,
shipping documents, responses to fit and proper person questions that require additional
details etc). This activity is likely to require travel time.
$11,454 in total from the 30 minutes saved by each importer who is no longer required to
complete the online licence application form.
$3,665 in total from the 10 minutes saved by each importer who no longer calls the
department midway though completing the application to ask a question about the form or
the progress of the application.
Total regulatory
cost p.a.
Component: reduced reporting, invoicing and record keeping
-$0.128 603m
Excluded importers do not provide quarterly import reports and maintain records. Current
reporting regulations require the submission of a report every quarter, including the submission
Page | 18
of a nil report in the case of no imports. Therefore, excluded importers would gain savings
arising from 5 licensing periods in which 8 reports each were not required (40 in total). These
savings would be $45,815 in total from the 15 minutes saved by each importer who is no longer
required to provide 40 quarterly reports.
Excluded importers do not need to keep a record of their imports for at least 5 years. This saving
would be $15,211 in total from the 5 minutes saved by each importer who is no longer required
to save the records associated with 40 quarterly reports.
Excluded importers do not have to read reporting reminders and financial statements. This
saving would be $73,304 in total from the 24 minutes saved by each importer who must no
longer: spend 6 minutes per quarter reading a 2 page reporting reminder or spend 18 minutes
per quarter reading 3 monthly 2 page financial statements.
Excluded importers do not receive process and pay outstanding invoices against reported
imports. Assumes that as a low volume importer the entity will only receive process and pay
against 1 substantial report each two year period i.e. 5 invoices in a ten year period. This saving
would be $5,727 in total from the 15 minutes saved by each importer who must spend 5
minutes each on receiving; processing and Lodging payment.
Total regulatory
cost p.a.
Component: increased education
$0.000 228m
One off advice read by persons on the introduction of new low volume threshold arrangements.
It is assumed that 60% or 420 of the 700 importers would research requirements for exemption
prior to import on the web. This percentage is based on rates of backdating of low volume import
fee waivers/ licences prior to commencement of the exemption.
This cost would be $228 in total from the 5 minutes of time taken by importers eligible for the
low volume import exemption to find / download and read one page of text relating to the
exemption as part of their research prior to import.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
Page | 19
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 20
Attachment E-5 - CFC HCFC and Halon equipment thresholds
Instrument Title
CFC HCFC and Halon equipment thresholds
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs (includes
CFC and HCFC
low volume
thresholds)
($ million)
CFC low volume
threshold
-$0.015,501
HCFC low volume
threshold
$0.000,077
Option 1: Halon
equipment low
volume threshold
(includes CFC and
HCFC low volume
thresholds)
-$0.000,962
-$0.016,386
Option 2: Halon
equipment general
exemption (includes
CFC and HCFC low
volume thresholds)
-$0.010,098
-$0.025,522
Option 3:
Amalgamation of
halon licence and
equipment licence
(restructure)
(includes CFC and
HCFC low volume
thresholds)
-$0.010,098
-$0.025,522
Cost offset
($ million)
Business
Community
organisations
Individuals
Total, by
source
($ million)
Page | 21
Agency
$
$
$
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
The Ozone Act controls imports, exports and manufacture of gases and equipment containing
those gases through a mixture of licensing, licensing exemptions, bans, and exemptions to those
bans.
The Ozone Act currently contains a threshold to exempt low volume importers of particular
ozone depleting substance/synthetic greenhouse gas equipment (ODS/SGG equipment). A low
volume importer is currently considered as an importer who imports up to 5 pieces of
equipment containing up to 10 kilograms of these gases once in a two year period. This includes
equipment containing HCFCs. The Ozone Act currently bans the import of equipment containing
CFCs. The Ozone Act bans the import of equipment containing halon unless a section 40
exemption is held by the importer, demonstrating that the equipment is needed for health and
safety or defence reasons, and no alternative is available.
Thresholds are being considered for equipment containing CFCs, halon and HCFCs. The objective
of this intervention is to reduce unnecessary burden on low volume importers of equipment
containing CFCs, halon and HCFCs. This regulatory burden measure considers further
exemptions or streamlining of mechanisms for exempting goods in relation to:


exemptions from equipment bans, including for equipment containing halon and the existing
section 40 exemption.
exemptions from licensing requirements
This regulatory burden measure also considers an option with a restructure of the Ozone Act,
where the current halon equipment “licence” (called a section 40 exemption) is amalgamated
with the ODS/SGG equipment licence.
Option 1:

introducing an exemption to the CFC equipment ban to allow low volume importers to bring
these (usually historical) items into the Australia.

maintaining the current low volume threshold for HCFC refrigeration and air conditioning
equipment. Only the mechanism for allowing the licence exemption would change (in
response to changes proposed to hydrofluorocarbon low volume threshold as proposed in a
separate regulatory burden measure).

retaining the halon equipment prohibition, with a low volume threshold based exemption for
essential uses such as known aviation and defence uses. This would only apply for instances
where the essential use criteria has been satisfied, as is currently the case. Higher volume
importers of this equipment would still be required to apply for a halon equipment “licence”
Page | 22
(called a section 40 exemption).

this option considers a low volume equipment threshold of 10kg, 5 pieces of equipment once
every 2 years, which applies to the sum of HCFC refrigeration and air conditioning
equipment, CFC equipment and Halon equipment.
Option 2:

introducing a CFC equipment threshold and maintaining the current low volume threshold
for HCFC refrigeration and air conditioning equipment (same as option 1).

a general exemption for particular halon product types. As with option 1, this would only
apply for instances where the essential use criteria has been satisfied such as known aviation
and defence uses. This differs from option 3 in that no halon equipment “licence” (called a
section 40 exemption) would be required for higher volume importers of this equipment.

this option considers a low volume equipment threshold of 10kg, 5 pieces of equipment once
every 2 years, which applies to the sum of HCFC refrigeration and air conditioningequipment
and CFC equipment.
Option 3 (restructure of the Ozone Act):

introducing a CFC equipment threshold and maintaining the current low volume threshold
for HCFC refrigeration and air conditioning equipment (same as option 1).

rolling the current halon equipment “licence” (called a section 40 exemption) in with the
ODS/SGG equipment licence. This would require a restructure of the Ozone Act, where the
import, export and manufacture licence scheme is simplified into two streams: goods that
require a licence and goods that do not. This streamlined approach reduces the regulatory
burden on entities that currently hold ODS/SGG equipment licences and section 40
exemptions and how they are required to apply for and report under each separately.

this option considers a low volume equipment threshold of 10kg, 5 pieces of equipment once
every 2 years, which applies to the sum of HCFC refrigeration and air conditioningequipment
and CFC equipment.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 The standard wage rate has been used ($37.40).
 The service cost for specialist ODS/SGG technicians is assumed to be $150 (per hour).
 For education costs, it is assumed that if the information is published on the Department’s
website, 100% of stakeholders would read it.
Page | 23
Explanation of measure and relevant assumptions
CFC and HCFC equipment low volume threshold (applicable to all
options):
Total
regulatory cost
-$0.015,424
CFC Equipment: A small number of vehicles containing CFCs (classic or vintage cars
manufactured before 1990) and to a lesser extent older refrigerators are stopped at the border
each year. This equipment must be modified to meet local requirements and an appropriate
licence obtained before it is able to be imported.
Given the low number of items, likelihood of depleted charges, and low likelihood of being able
to recharge the goods in Australia, an option is that such goods be allowed under a low volume
threshold. No new equipment is manufactured containing CFCs and therefore allowing import of
this type of equipment, within a threshold, is unlikely to impact on Australia’s ODS phase-out or
impact on the phase-out in other countries.
The low volume equipment threshold is 10kg, 5 pieces of equipment once every 2 years, which
applies to the sum of HCFC refrigeration and air conditioningequipment and CFC equipment. For
option 1 halon equipment is also included; the threshold is the sum of HCFC refrigeration and air
conditioningequipment, CFC equipment and halon equipment.
Assumptions:




The Department estimates there are approximately 10 instances of this type of import
annually. Importers are assumed to be individuals such as private collectors.
It is assumed that 100% of stakeholders would read the relevant information on the
Department's website. 10% would follow up this reading with a telephone call to the
Department seeking further information.
Customs Brokers would receive information through existing training or education materials
and therefore the education costs for this group of stakeholders is zero.
It is assumed that all importers will chose to avoid costs associated with engaging a qualified
technician to modify equipment if there were no longer a requirement to do so. The service
cost for a technician is assumed to be $150 (per hour).
Page | 24
HCFC Equipment: Australia has introduced a complementary approach to support the phaseout of bulk HCFCs by banning the import and manufacture of HCFC RAC equipment. There are
some exemptions to this ban, including for low volume importers of this equipment. In
contemplating an appropriate threshold for HCFC refrigeration and air conditioningequipment, it
is important to not encourage commercial import activity which would be counter to efforts
supporting the phase-out of bulk HCFCs, noting that most commercial import of HCFC equipment
has ceased.
Currently the low volume equipment threshold is 10kg, 5 pieces of equipment once every 2
years, which applies to the sum of synthetic greenhouse gas (SGG) equipment and HCFC
refrigeration and air conditioningequipment. Elsewhere in the Ozone Act review a proposal is for
the SGG threshold to be changed to 100kg. One option therefore is to separate the HCFC
equipment threshold from the SGG equipment threshold so that it can be set appropriately.
The low volume equipment threshold is 10kg, 5 pieces of equipment once every 2 years, which
applies to the sum of HCFC refrigeration and air conditioningequipment and CFC equipment. For
option 1 halon equipment is also included; the threshold is the sum of HCFC RAC equipment, CFC
equipment and halon equipment.
Assumptions:



The number of HCFC equipment importers is based on the last year of operation of the low
volume equipment licence (i.e. the 2014 calender year) The Department estimates there are
approximately 40 instances of this type of import annually.It is assumed this figure has
remained stable as the same threshold criteria apply.
It is assumed that 100% of stakeholders would read the relevant information on the
Department's website. 10% would follow up this reading with a telephone call to the
Department seeking further information.
Customs Brokers would receive information through existing training or education materials
and therefore the education costs for this group of stakeholders is zero.
It is assumed that a change:
- from HCFC refrigeration and air conditioningequipment and SGG equipment
threshold
- to a HCFC refrigeration and air conditioningequipment and CFC equipment
threshold
will not lead to any more or less HCFC refrigeration and air conditioningequipment importers
falling under a low volume exemption.
Option 1: Halon equipment low volume threshold:
Total
regulatory cost
-$0.016,386
Under this option the halon equipment prohibition would be retained with a threshold based
exemption for essential uses such as known aviation and defence uses where the essential use
criteria has been satisfied. Holding a halon equipment “licence” (called a section 40 exemption)
places an administrative burden on low volume importers which might outweigh the amount of
gas imported, the amount of revenue collected and the potential for emissions to occur. It may be
more efficient for the scheme to concentrate on importers who import significant quantities of
gas.
Page | 25
Importers who fall under the threshold would not be required to appy for a halon equipment
“licence” (called a section 40 exemption) This option reduces the regulatory burden on low
volume importers, while retaining the ability to collect halon data from larger importers and
appropriately manage essential uses. (The estimated 2 importers per year would also avoid the
$3,000 application fee)
This option considers a low volume equipment threshold of 10kg, 5 pieces of equipment once
every 2 years, which applies to the sum of HCFC refrigeration and air conditioningequipment,
CFC equipment and Halon equipment.
Assumptions:




The Department estimates there are approximately 4 instances of this type of import within
a two year period, by individuals. Therefore the combined total for low volume halon, CFC
and HCFC importers is assumed to be 52 importers annually (2 halon +10 CFC +40 HCFC)
It is assumed that 100% of stakeholders would read the relevant information on the
Department's website. 10% would follow up this reading with a telephone call to the
Department seeking further information.
The Department assumes all eligible importers will take advantage of the low volume halon
exemption and avoid applying for a Section 40 "licence"; estimated at 2 instances of this type
of import annually
Assumptions of costs therefore avoided are:
- Finding and completing online application on Departmental website
- Contacting Department through application process
- Obtaining certified identification
- Time taken to pay application fees, transaction fee
- Ongoing reporting and record keeping requirements
Option 2: Halon equipment general exemption
Total
regulatory cost
-$0.025,522
Under this option the halon equipment prohibition would be retained with a product type
exemption for essential uses such as known aviation and defence uses where the essential use
criteria has been satisfied. This differs from current arrangements in that a halon equipment
“licence” (called a section 40 exemption) with its associated fee would not need to be applied for.
While this would reduce costs to businesses that import halon equipment for aviation or defence
uses, there would be no clear mechanism for collection of import data or to enable the
government or industry to properly assess the volume and impact of activity on Australia’s
phase-out.
Assumptions:


It is assumed that there will be approximately 24 such importers within a two year
period.This figure is based on the current number of Section 40 exemption holders, and has
remained at approximately this level for some years.
It is assumed that 100% of stakeholders would read the relevant information on the
Department's website. 10% would follow up this reading with a telephone call to the
Page | 26

Department seeking further information.
There will no longer be a halon equipment “licence” (called a section 40 exemption) under
this option. Assumptions of costs therefore avoided are:
- Finding and completing online application on Departmental website
- Contacting Department through application process
- Obtaining certified identification
- Time taken to pay application fees, transaction fees
- Ongoing reporting and record keeping requirements
Option 3: Halon equipment licence amalgamation – Act restructure
Total
regulatory cost
-$0.025,522
Act restructure: The Ozone Act has been amended over time in response to Australia’s evolving
international obligations. The Act has been amended in an incremental nature in response to
those changing demands.
This has resulted in an Act where imports, exports and manufacture of gases and equipment
containing those gases are controlled through a complex mixture of licensing, licensing
exemptions, bans, and exemptions to those bans. These are scattered throughout the Ozone Act
and associated regulations. This legislative structure is complicated and difficult to navigate and
understand for users, and does not always support efficient and effective administration
The final option considers that the import, export and manufacture licence scheme be simplified
into two streams: goods that require a licence and goods that do not. Taking a streamlined
approach when restructuring the Ozone Act will support understanding, reduce complexity and
the risk of non-compliance. It will also allow for more effective management of goods in a
manner which imposes only an appropriate level of regulatory burden.
Halon equipment licence amalgamation: Rolling the current halon equipment “licence” (called
a section 40 exemption) in with the ODS/SGG equipment licence. This reduces the regulatory
burden on approximately twenty four entities that currently hold ODS/SGG equipment licences
and section 40 exemptions and how they are required to apply for and report under each
separately.
Assumptions:



It is assumed that 100% of stakeholders would read the relevant information on the
Department's website. 10% would follow up this reading with a telephone call to the
Department seeking further information.
Criteria that currently apply for halon “licences” (Section 40 exemptions) would still apply; in
short that equipment must be necessary for medical, veterinary or defence use.Currently this
is limited to halon fire systems, in particular onboard aircraft. It is assumed that there will
therefore be no change from the current 24 importers annually.
The Department assumes that instances of such importers (i.e. importers of Halon onboard
aircraft) not requiring a refrigeration and air conditioningequipment licence are negligable.
On this basis the purchase costs are assumed to be halved as only 1 not 2
Page | 27

licences/exemptions would be required. (Note that licensees will only pay one $3,000
application fee under this option, not two $3,000 application fees)
There will no longer be a separate halon equipment “licence” (called a section 40 exemption)
under this option. Assumptions of costs therefore avoided are:
- Finding and completing online application on Departmental website
- Contacting Department through application process
- Obtaining certified identification
- Time taken to pay application fees, transaction fees
- Ongoing reporting and record keeping requirements
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 28
Attachment E-6 - Renewal of import, export and manufacturing licences
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
-$0.130 272
$0
$0
-$0.130 272
Business
Community
organisations
Individuals
Total, by source
$ NA
$ NA
$ NA
($ million)
$ NA
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$0.130 272m
Background
Importers, exporters and manufacturers of Ozone Depleting Substances (ODSs) and Synthetic
Greenhouse Gases (SGGs) are required to hold a licence permitting this activity, under s13 of the
Ozone Act. Licences are issued for both one-off and regular (ongoing) importers, exporters and
manufacturers. Licences are issued for a 2 year duration, after which, if import, export or
manufacture is continuing, a new licence must be applied for, assessed and issued. The majority
of licensees require a new licence every 2 years to enable their business to continue to import,
export or manufacture ODSs and SGGs.
The licence application process is relatively time consuming, duplicating much of the effort,
paperwork and verification from licence to licence. A licence application and assessment
involves providing proof of identity and a range of other supporting documentation.
This process could be significantly streamlined through a renewal process, with existing relevant
licence holder details simply confirmed or updated and the licence then renewed or extended for
another 2 year period. There would be no need to provide the supporting information and
documentation when renewing a licence, this would significantly reduce administrative burden.
In addition, continuing to operate under the same licence will overcome import administration
Page | 29
problems where expired licence numbers are regularly cited.
Simplification of the licensing process has two aspects:


Reducing the current level of administration associated with reapplying for a licence.
Requiring licence holders who are renewing their licence to complete a new licence renewal
form.
Streamlining the process would offer regulatory savings and other benefits including:
o less confusion when reporting when an expired and a new licence occur in the same
reporting period, which may require resubmission of reports under the correct licence
number
o less confusion in identifying the correct licence number on customs declaration forms,
which may involve customs holding imports until the confusion is resolved.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 It is assumed that the period these measures are costed over is 2017-2027.
 There are 1,200 import / export / manufacturing licences.
 Licences are valid for 2 years, with half of these (600) expiring / lapsing per annum.
 There would be a one-off communication cost advising all existing licence holders of the
change. This is based on a 1 page notification, taking 5 minutes to read and absorb. It is
assumed all licence holders would read this information.
Explanation of measure and relevant assumptions
Cost of current licence application process


Total regulatory
cost p.a.
-$0.147,263m
This will be a saving as it will no longer be required.
It is estimated that it takes an applicant 3.75 hours to complete the requirements and submit
a licence application.
Cost of licence renewal process
Page | 30
Total regulatory
cost p.a.
$0.016,991m

A renewal application and payment of licence administration fee is estimated to take an
applicant 25 minutes.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 31
Attachment E-7 - Reduction in import, export and manufacturing reporting and levy
payment frequency
Instrument Title
Average annual regulatory costs (from business as usual)
Total costs for measure
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
-$0.351 574
$0
$0
-$0.351 574
Agency
$ NA
$ NA
$ NA
$ NA
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$0.351 574m.
Background
To assist Australia meet its international commitments with the managing, monitoring and
reporting of ozone depleting substances (ODSs) and synethic greenhouse gases(SGGs) under the
Montreal and Kyoto Protocols, the Ozone Act requires:



Importers, exporters and manufacturers of ODSs and SGGs to be licenced.
All licensees to report before the 15th day after the end of each quarter, details of their
imports and manufacturing for that quarter, including reporting of nil activities.
Payment of import and manufacturing levies within 60 days of the end of the reporting
quarter.
These reporting and payment requirements could be made more efficient by reducing the
frequency per annum from four times to only once, with the option available for those licensees
wishing to report more frequently to do so.
Changing the reporting requirement from quarterly to annual will reduce the associated burden
on licensees by up to 75%. It will have no impact on the Government’s ability to meet its
international obligations.
An enabling provision could also be added to the Ozone Act to allow information sharing with
the GEMS Act, in relation to reporting requirements. This legislative change would allow the
Page | 32
Department to work with the Department of Industry to share reporting information in the
future. This could help inform Australia’s international data reporting. There will be no impact
on licence holders from the addition of this enabling provision however they would be informed
of the inclusion of the enabling provision in the Ozone Act.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 It is assumed that the period these measures are costed over is 2017-2027.
 The costing is based on 1200 licensees.
 A labour rate of $37.40 per hour is used.
 Assumes licensees pay on time and the correct amount and will therefore only have an
account balance for the 2 months following the end of the reporting period, with payment
due within 60 days from the end of the reporting period.
Explanation of measure and relevant assumptions
Reduction in reporting frequency



Total regulatory
cost p.a.
-$0.217 949m
Licensees take on average 1 hour to prepare and submit a report.
Licensees would have a choice to move from quarterly reporting to annual reporting.
It is assumed there would be an adoption rate from quarterly reporting to annual reporting
of:
o
o
o
o
o
o
Year1 – 75% (900 licencees)
Year 2 – 80% (960 licencees)
Year 3 – 85% (1020 licencees)
Year 4 - 90% (1080 licencees)
Year 5 – 95% (1140 licencees)
Years 6 to 10 - 100% (1200 licencees)
Consequential reduction in levy payments
Total regulatory
cost p.a.
-$0.063 568m


Reducing the frequency of reporting from quarterly to annual will have a corresponding
reduction in levy payments.
Licensees take on average 30 minutes to process an invoice.
Communicating the change
Page | 33
Total regulatory
cost p.a.
-$0.070 058m




It is assumed that all licencees read all information provided by the Department.
All current licensees will be provided with a 1 page notification of the change. Estimated to
take 5 minutes to read and digest.
There will be a reduction of the email notification reminding licensees to submit their
(quarterly) report from 4 to 1 (now annually). 1 page notifications estimated to take 5
minutes to read and digest.
Licensee account balance statement notifications will be issued annually, reducing the
number by 75% from 8 to 2. These notifications are two pages long, it is assumed it takes 6
minutes to read two pages of information.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 34
Attachment E-8 - Introduce a power for the Minister to waive low value levy and penalty
debts
Instrument Title
Average annual regulatory costs (from business as usual)
Introduction of power within the Act to waive low value levy and penalty debts
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
-$074 484
$0
$0
-$0.074 507
Business
Community
organisations
Individuals
Total, by source
$ NA
$ NA
$ NA
($ million)
$ NA
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$0.074 507m
Background
The the Ozone Protecton and Synthetic Greenhouse Gas Management Act 1989 (the Act) currently
requires importers,manufacturers and exporters of to report their imports, manufacture and
export activity at the end of each quarter (ss46 and 46A of the Act).
Based on these reported activity levels, importers and manufacturers are required to pay an
import or manufacture levy under the Ozone Protection and Synthetic Greenhouse Gas (Import
Levy) Act 1995 and Ozone Protection and Synthetic Greenhouse Gas (Manufacture Levy) Act 1995,
respectively.
Some of these levy amounts may be as little as $0.01 for a quarter. The Act also imposes (S69(2))
a mandatory penalty for a late levy payment. Some of these penalty amounts may be as little as
$0.01.
Small value transactions can impose a relatively significant cost on import and manufacture
licence holders and collection and administration of these amounts is not cost effective for the
Department.
A threshold for waiver of low value levy and penalty debts under the Ozone Act could be
introduced to reduce this non-productive regulatory burden. It is currently intended that the
threshold be set in regulations. This would allow the Government to vary the threshold amount
Page | 35
through the regulations to maintain the waiver amount at an appropriate level.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 It is assumed that the period these measures are costed over is 2017-2027.
 Costing is based on 2013-14 invoicing data for levy and penalty debts
 Standard labour cost of $37.40 per hr.
Explanation of measure and relevant assumptions
Component: Waiver of small levy debts
Total regulatory
cost p.a.
-$0.075 136m
Setting the threshold at $50 would save in excess of 2200 quarterly reporting levy notices
annually.



Setting the threshold at $50.
In 2013-14 there were 2296 invoices issued for levy payments <$50 to 825 individual
licensees. On average, the 825 licensees received 2.783 such invoices.
An estimate of 30 minutes has been used as the time taken by business to process an invoice,
from receipt of the invoice to the making of the payment.
Component: Waiver of small penalty debts
Total regulatory
cost p.a.
-$0.0m
Penalty debts arise through an act of non-compliance (not paying levy debts by the payment due
date) and as such the proposed waiver of small penalty debts would not result in a change in
regulatory burden – it will, however, provide administrative efficiencies for both licensees and
the Department.
Setting the threshold at $50 would save in excess of 300 penalty invoices annually.


Setting the threshold at $50.
In 2013-14 there were 306 invoices issued for penalties for of <$50.
Page | 36
Total regulatory
cost p.a.
Component: Communications
$0.000 628m
Advising licence holders of the introduction of the threshold.



A one-off 1 page notification would be sent to all 1200 licensees.
It would take 5 minutes to read and absorb this information
All licensees would read the notification. Experience indicates that the vast majority of
licensees read the financial notifications, even if they do not always comply.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 37
Attachment E-9 - Streamlining SGG import and manufacture exemptions
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Option 2
-$0.000 189
$
$
-$0.000 189
Option 3
(restructure)
$0.000 049
$
$
$0.000 049
Business
Community
organisations
Individuals
Total, by source
$
$
Cost offset
($ million)
Agency
N/A
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
The Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 (the Act) controls the
manufacture, import, export, use and disposal of ozone depleting substances (ODS) and synthetic
greenhouse gases (SGG) through a licensing scheme. Currently, there are three separate
processes for exempting bulk SGGs from licensing requirements:



No paperwork or formal approval for SGGs manufactured as a by-product as part of
aluminium production (regulation 3)
Requirement to obtain a permit for use of SGG in production or casting of magnesium
(regulation 3A)
Requirement to obtain a SGG notice if the SGG is destroyed during a manufacture process
(regulation 3AA)
The first two exemptions are covered under the National Greenhouse and Energy Reporting Act
2007 which has specific provision to capture emissions of SGGs in the manufacture of aluminium
and magnesium. As this information is collected through a different Commonwealth law, it is
proposed that the permit for production of SGGs in magnesium casting is removed.
The third exemption is similar to the exemption for feedstock. It was inserted during the
Page | 38
implementation of the Equivalent Carbon Tax and is no longer needed. It is proposed that the
requirement for an SGG notice be removed.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 The standard wage rate has been used ($37.40).
 The Department will contact each stakeholder directly when the change is made.
 It is assumed that 3% of stakeholders would read the factsheet and other published
government material for one hour.
 It is assumed that the refrigeration and end use licensing scheme continues under all options.
 If the licence holder is required to pay a licence application or levy by electronic transfer, this
costs 30 cents per transaction. This is based on the fee charged by the Commonwealth Bank.
Explanation of measure and relevant assumptions
Remove requirements to obtain a permit for use of SGGs in production or
casting of magnesium and remove requirement to obtain a SGG notice if
the SGG is destroyed during a manufacture process
Total
regulatory cost
pa
-$0.000 189
Description of option: this option has two parts:


repeal the requirement in regulation 3A which requires importers or manufacturers of SGGs
for use in production or casting of magnesium to obtain a permit. Replace this provision with
a general exemption similar to that provided in regulation 3 for SGGs manufactured as a byproduct of aluminium production.
repeal the requirement in regulation 3AA which requires importers of manufacturers to
apply for a SGG notice for SGGs destroyed in a manufacturing process. Replace this provision
with a general exemption similar to that provided in regulation 3 for SGGs manufactures as a
by-product of aluminium production.
These importers and manufacturers are currently exempted from licensing and reporting
requirements under the Ozone Act. Once the change is made, these importers would still be
exempt from licensing and reporting requirements.
Assumptions:




There are currently no permit holders for SGGs produced in casting of magnesium. It
assumed that this will continue.
Only permit holders would be interested in reading information on this change. As there are
none, the education cost is $0.
There is only one SGG notice holder. It is assumed that this importer will continue to import
for this purpose over the entire RBM period. This importer will be sent educational material
regarding the proposed general exemption.
Only the one SGG notice holder permit holder would be interested in reading information on
Page | 39

this change and this will continue over the RBM period.
The SGG notice holder would have required the notice to be amended 3 times over the ten
year RBM period consistent with the Department’s experience administering SGG notices;
costs associated with this would be saved.
Restructure: Remove requirement to obtain a SGG notice if the SGG is
destroyed during a manufacture process and streamline with feedstock
provisions
Total
regulatory cost
pa
$0.000 049
Description of option: this option has two parts:


repeal the requirement in regulation 3A which requires importers or manufacturers of SGGs
for use in production or casting of magnesium. Replace this provision with a general
exemption similar to that provided in regulation 3 for SGGs manufactured as a by-product of
aluminium production.
repeal the requirement in regulation 3AA which requires importers or manufacturers to
apply for a SGG notice for SGGs destroyed in a manufacturing process. Replace this provision
by expanding the feedstock provision, which currently only covers ODS, to include SGGs.
Importers and manufacturers of:
(a) SGGs for use in production or casting of magnesium, and
(b) SGGs manufactured as a by-product of aluminium production
are currently exempted from licensing and reporting requirements under the Ozone Act. Once
the change is made, these importers would still be exempt from licensing and report
requirements.
Importers of SGG feedstock would be exempt from licensing but would be required to report
imports.
Assumptions:






There are currently no permit holders for SGGs produced in casting of magnesium. It
assumed that this will continue.
Only permit holders would be interested in reading information on this change. As there are
none, the education cost is $0.
There is only one SGG notice holder. It is assumed that this importer will continue to import
for this purpose over the entire RBM period. This importer will be sent educational material
regarding the proposed new feedstock provision.
Only the one SGG notice holder permit holder would be interested in reading information on
this change and this will continue over the RBM period.
The SGG notice holder would have required the notice to be amended 3 times over the ten
year RBM period consistent with the Department’s experience administering SGG notices;
costs associated with this would be saved.
Feedstock reporters do not pay levy, however are required to comply with other reporting
requirements. It is assumed that collecting inputs and quality assurance takes 30 minutes,
paper based reporting takes 20 minutes, and record keeping thereof takes 5 minutes. This
occurs quarterly.
Page | 40
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 41
Attachment E-10 - Provide an exemption to allow for the use of methyl bromide for
laboratory and analytical purposes
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
-$0.000 033
$0
$0
-$0.000 033
Business
Community
organisations
Individuals
Total, by source
$0
$0
$0
($ million)
$0
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$33
Background
Methyl bromide is an ozone depleting substance controlled under the Montreal Protocol on
Substances that Deplete the Ozone Layer. Methyl bromide is a broad-acting fumigant used for
quarantine and pre-shipment (QPS) purposes, for non-QPS uses and as a feedstock in the
creation of other chemical substances. Non-QPS use of methyl bromide was subject to phasedown under the Montreal Protocol and banned in Australia from 2005 under the Ozone Act and
Regulations, which give domestic legislative effect to Australia’s obligations under the Montreal
Protocol. Non-QPS use of methyl bromide is now only available under specific exemptions
provided by the Parties to the Montreal Protocol.
The Parties to the Montreal Protocol approved an exemption for the use of methyl bromide for
specific laboratory and analytical purposes, to be in effect until 31 December 2021. The
Australian Government supported this and previous exemptions but to date has not
implemented any changes to domestic legislation to give effect to them.
This costing looks at the option of amending the Ozone Act and/or Regulations to allow for the
import and use of methyl bromide for laboratory or analytical purposes, in line with the current
exemption under the Montreal Protocol.
Page | 42
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.

The costing time frame is 5 years.

Is it assumed that the period these measures are costed over is 2017-2021.
Explanation of measure and relevant assumptions
Remove current ban on the use of methyl bromide for laboratory and
analytical purposes.
Total
regulatory cost
p.a.
-$131
Removing the ban would create a regulatory saving for affected stakeholders.

The Department has anecdotally had only 2-3 enquiries / applications for the use of
methyl bromide for laboratory and analytical purposes over the past 5 years. It is
assumed that the future rate of enquiry /requirement for methyl bromide for laboratory
and analytical purposes would remain consistent with this.
Stakeholders would no longer be required to undertaking the following requirements:




It is assumed that it takes an interested party 1 hour to find and read the relevant
sections of the Ozone Act and Regulations, and information on the Department's website,
prior to contacting the Department for assistance.
It is then assumed that it takes 20 minutes to draft the email and gain approval to send
email with relevant information to the Department.
It is then assumed that it takes 20 minutes to discuss the request with a Departmental
official over the phone.
It is then assumed that there will be 2 emails / phone calls of 10 minutes each to followup and conclude the enquiry and for the Department to provide a response / approval as
required.
The Department has to date undertaken due diligence and implemented an appropriate
administrative approach that ensures ongoing compliance with the Montreal Protocol and Ozone
Act and Regulation requirements.
Issue a permit to those requiring methyl bromide for laboratory and
analytical uses
Total
regulatory cost
p.a.
$65




The Department has anecdotally had only 2-3 enquiries / applications for the use of
methyl bromide for laboratory and analytical purposes over the past 5 years. It is
assumed that the future rate of enquiry /requirement for methyl bromide for laboratory
and analytical purposes would remain consistent with this.
It is assumed that it takes an interested party 5 minutes to find and download/print the
permit application form from the Department's website.
It is then assumed that it takes 45 minutes to complete the form and send to the
Department.
It is then assumed that it takes 10 minutes to follow-up and conclude the enquiry and for
Page | 43
the Department to inform the applicant of the outcome.
Education of changes to allow for exemption and permit application
process


Total
regulatory cost
p.a.
$33
It is assumed that it will take 5 minutes to find, download and read one page of text from
the Department's website.
Enquiries for the laboratory or analytical use of methyl bromide have, to date, only been
received from 2-3 Universities in relation to their research activities. It would be good
stakeholder engagement to communicate the exemption to all Australian universities and
the CSIRO as these are the primary public research organisations in Australia. It is
assumed that of the 30 stakeholders (29 Universities plus CSIRO) 100% would read
education material on the Department's website.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
Accountable Authority
Signature
(Accountable Authority)
Date
Page | 44
Attachment E-11- Remove requirement for Methyl Bromide buyers to report on
stockpiles
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
$0
$0
$0
$0
Business
Community
organisations
Individuals
Total, by source
$0
$0
$0
($ million)
$0
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = $0
Background
Methyl bromide is an ozone depleting substance controlled under the Montreal Protocol on
Substances that Deplete the Ozone Layer. Methyl bromide is a broad-acting fumigant used for
quarantine and pre-shipment (QPS) purposes, for non-QPS uses and as a feedstock in the
creation of other chemical substances. Non-QPS use of methyl bromide was subject to phasedown under the Montreal Protocol and banned in Australia from 2005 under the Ozone Act and
Regulations, which give domestic legislative effect to Australia’s obligations under the Montreal
Protocol. Non-QPS uses of methyl bromide are now only available under a Critical Use Exemption
from the Parties to the Montreal Protocol.
Under the Montreal Protocol the Australian Government was required to identify and report on
any stockpiles of methyl bromide that may have arisen prior to the ban of methyl bromide
coming into effect.
Regulation 232 was included in the Ozone Regulations for the explicit purpose of requiring
anyone who bought methyl bromide, including importers, on or after the phase-down ban came
into effect on 1 January 2005 to provide a report to the Department, within 14 days of the end of
the first quarter in which they made the purchase, of the amount of methyl bromide they
possessed immediately before making that first purchase.
This costing looks at the option to remove the regulation relating to the reporting of stockpiles of
methyl bromide as all instances of purchase after 1 January 2005 have occurred and all potential
Page | 45
stockpiles reported.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.

Default costing time frame is 10 years.

Is it assumed that the period these measures are costed over is 2017-2027.
Explanation of measure and relevant assumptions
Draft and submit a report on stockpile amounts to the Department.
Total
regulatory cost
p.a.
$0

Removing the requirement to submit stockpile reports would have no practical effect on
current buyers as the provision was designed to report only on stockpile capacity in
Australia once the first additional purchase of methyl bromide was made after 1 January
2005. This means there has been no need to provide these reports since those first
purchases occurred in 2005.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
Matthew Dadswell
Accountable Authority
Director of Deregulation Unit
Signature
(Accountable Authority)
Date
Page | 46
Attachment E-12 - Remove requirement for methyl bromide users to keep summary
records of use
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
-$0.147 317
$0
$0
-$0.147 317
Business
Community
organisations
Individuals
Total, by source
$0
$0
$0
($ million)
$0
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$147,317
Background
Methyl bromide is an ozone depleting substance controlled under the Montreal Protocol on
Substances that Deplete the Ozone Layer. Methyl bromide is a broad-acting fumigant used for
quarantine and pre-shipment (QPS) purposes, for non-QPS uses and as a feedstock in the
creation of other chemical substances. Non-QPS uses of methyl bromide were subject to phasedown under the Montreal Protocol and banned in Australia from 2005 under the Ozone Act and
Regulations, which give domestic legislative effect to Australia’s obligations under the Montreal
Protocol. Non-QPS uses of methyl bromide are now only available under a Critical Use Exemption
from the Parties to the Montreal Protocol.
The Ozone Regulations contain a requirement under Regulation 222 for all users of methyl
bromide to keep summary records of use. The content of summary records of use duplicates
information also required under Regulation 221 ‘records of use’. To date no summary records of
use have been requested by the Australian Government. There does not appear to be any need to
ask business to continue to keep these records and maintain this regulatory burden.
This costing looks at the option to remove the regulatory requirement for users of methyl
bromide to keep summary records of use.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
Page | 47

Default costing time frame is 10 years.

Is it assumed that the period these measures are costed over is 2017-2027.

There are approximately 250 working days each year in Australia (excluding weekends and
public holidays). If we assume that there are 50,000 instances of use each year, there would
be on average 200 instances of use on each working day, being on average 2 instances of use
per fumigator.

The figure of 50,000 annual instances of use represents an extrapolation of data provided by
the Department of Agriculture Compliance Division who manage the compliance agreements
for onshore fumigations. Department of Agriculture indicated that 34 agreements were in
place, with multiple individuals licensed to undertake methyl bromide fumigations under
each agreement. These 34 agreements represented 21,570 instances of methyl bromide use
in 2014 calendar year. The Australian Wood Packaging Certification Scheme lists 26
fumigation treatment operators or manufacturers with fumigation treatment facilities. Data
from the 2012 Banks QPS survey indicated there were 87 fumigation operators using methyl
bromide (including for wood exports etc and other activities not covered by the onshore
compliance agreements). If 21,570 is assumed to represent 40% of instances of use (as 34 is
40% of 87) then 100% of use would be approx 50,000 instances of use in 2014 calendar year
across all methyl bromide QPS users.

The 2012 Banks QPS survey indicated 87 methyl bromide fumigation operators in that
sector, with a further ten known users in the non-QPS sector. The figure is rounded to 100 to
account for potential missed users.
Explanation of measure and relevant assumptions
Removing requirement for stakeholders to find, download or print initial
copy of form provided by the Department on its website.
Total
regulatory cost
p.a.
-$10,908
Stakeholders would no longer be required to:


It is assumed that the time required to find and download/print one page of text is 5
minutes.
It is assumed that for each 25 instances of methyl bromide use, a new pro-forma must be
found and downloaded by the user.
Removing requirement for stakeholders to complete summary record of
use for each day where there is at least one instance of use
Total
regulatory cost
p.a.
-$136,354
Stakeholders would no longer be required to:


It is assumed that the time required to complete the two columns of the summary record
is 1 minute. Calculations for multiple instances of use on one day are assumed to take on
average 4 minutes.
There are approximately 250 working days each year in Australia (excluding weekends
and public holidays). If we assume that there are 50,000 instances of use each year, there
would be on average 200 instances of use on each working day, being on average 2
Page | 48

instances of use per stakeholder.
It is therefore assumed that each stakeholder must spend 5 minutes to calculate and
record 2 instances of use each working day.
Educate users that there is no longer the requirement to maintain
summary records of use


Total
regulatory cost
p.a.
-$55
It is assumed that it will take 5 minutes to open and read one page of text as emailed by
the Australian Government (either the Department or the Department of Agriculture).
It is assumed that of the 100 stakeholders involved in methyl bromide fumigations, 100%
would read a direct communication from the Australian Government, sent either by the
Department or the Department of Agriculture.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
Matthew Dadswell
Accountable Authority
Director of Deregulation Unit
Signature
(Accountable Authority)
Date
Page | 49
Attachment E-13 - Maximum allowable import quantity of methyl bromide
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
-$0.000 529
$0
$0
-$0.000 529
Business
Community
organisations
Individuals
Total, by source
$0
$0
$0
($ million)
$0
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$529
Background
Methyl bromide is an ozone depleting substance controlled under the Montreal Protocol on
Substances that Deplete the Ozone Layer. Methyl bromide is a broad-acting fumigant used for
quarantine and pre-shipment (QPS) purposes, for non-QPS uses and as a feedstock in the
creation of other chemical substances. Non-QPS use of methyl bromide was subject to phasedown under the Montreal Protocol and banned in Australia from 2005 under the Ozone Act and
Regulations, which give domestic legislative effect to Australia’s obligations under the Montreal
Protocol. Non-QPS uses of methyl bromide are now only available under a Critical Use Exemption
from the Parties to the Montreal Protocol. QPS uses of methyl bromide were not subject to
phase-down.
Under the Montreal Protocol the Australian Government is required to have in place appropriate
import control mechanisms for methyl bromide. Section 16 (3) of the Ozone Act imposes a limit
on the amount of methyl bromide that may be imported or exported for QPS, non-QPS and
feedstock uses.
As QPS use of methyl bromide is not subject to phase-down, any request by a licence holder for
an increase to the limit of methyl bromide that may be imported or exported under their licence
is likely to be approved by the Department (subject to due diligence). Seeking to maintain the
restrictions places an administrative burden on the licence holder who must apply for the
amendment.
Page | 50
This costing looks at the the option to remove the requirement for a limit on the amount of
methyl bromide that may be imported or exported for QPS uses only.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.

Default costing time frame is 10 years.

Is it assumed that the period these measures are costed over is 2017-2027.

There are 5 methyl bromide licence holders.
Explanation of measure and relevant assumptions
Remove QPS limits for methyl bromide import and export licensees
Total
regulatory cost
p.a.
-$532



It is assumed that each licence holder will apply for 2-3 variations over the 10 year
period. This is based on the number of actual variation requests over the last 2-3 years
and expected ongoing market changes.
It is assumed that it takes around 1 hour for a licence holder to identify the need for a
licence variation, to seek approval / clearance to approach the Department for a
variation, and to draft the request to the Department.
It is then assumed that it will take the licence holder 5 minutes to read the new licence
instrument and related terms and conditions relevant to the variation once approved by
the Department.
Education of changes to allow for exemption and permit application
process
Total
regulatory cost
p.a.
$3


It is assumed that it will take 5 minutes to open and read one page of text as emailed by
the Department.
It is assumed that of the 5 stakeholders involved in methyl bromide imports 100% would
read a direct communication from the Department.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Page | 51
Director of Deregulation Unit (EL 2)
To $500,000
Approved By
Responsible Policy Officer
Matthew Dadswell
Accountable Authority
Director of Deregulation Unit
Signature
(Accountable Authority)
Date
Page | 52

Attachment E-14 - HCFC quota flexibility
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
$0.000 281
$
$
$0.000 281
Agency
$
$
$
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from the Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $0.000 281
Background
The Australian Government and industry agreed an accelerated phase-out schedule for HCFCs in
the early 1990s. This schedule will see Australia achieve its 99.5 per cent phase-out target from
2016, four years ahead of the Montreal Protocol obligations.
The phase-out is managed through the quota system set out in Part IV of the Ozone Act. Quota is
only granted on a grandfathered system based on the ozone depleting potential (ODP) tonnage
to 6 remaining HCFC quota holders. The purpose of including the proposed HCFC quota
flexibility measure is to establish a mechanism that allows a fair redistribution of HCFC quota if
satisfied that the exceptional circumstances on which its allocation was based have changed or
were incorrect.
The current method for calculating the allocation of quota to holders specified in the Act is on a
percentage distributive basis. It does not provide specific powers that allow the minister the
flexibility to revoke and vary an incorrectly made quota allocation.
This means that if the base year used to apportion a quota amount to one entity is too low then
all of the other entities receive a bigger slice of the remaining quota. If a redistribution could
occur it would require entities who received too little quota to take quota over allocated to other
entities. Similarly the Act does not allow HCFC importers to offset over-quota imports against
exports or through other mechanisms, while preserving the overall industry limit.
While correction of a miscalculated quota would allow compliance with the Act it can disrupt and
disadvantage quota holders who have scheduled purchasing and contractual arrangements in
good faith on the basis of the original allocations.
The objective of this proposal is to establish a mechanism that allows a fair redistribution of
HCFC if satisfied that the exceptional circumstances on which its allocation was based have
changed were incorrect.
The administrative measures costed as part of these provisions do not provide details on
particular mechanisms, only that measures would be agreed in party with stakeholders and must
Page | 53
be consistent with Montreal Protocol obligations
The option costed to establish a mechanism that allows a fair redistribution of HCFC quota if
satisfied that the exceptional circumstances on which its allocation was based have changed or
were incorrect.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.

Default costing time frame is 10 years. Is it assumed that the RBM period is 2017-2027.

The standard wage rate has been used ($37.40).
Explanation of measure and relevant assumptions
Allow HCFC importers to offset over-quota imports through an administrative
mechanism established in consultation with industry.

Total
regulatory cost
p.a.
$0.000 281
All of the 6 HCFC quota holders are assumed to read information relating to changes to their
quotas. This assumption is based on responses to previous HCFC education activities
administered by the licensing team. The complete response rate is due to the very small
number of quota holders and the very high commercial value of quota to each quota holder.


$224 arising from the 2 hours of time taken by all 6 importers to understand quota
limitations and the options available to redress incorrectly allocated quotas and to factor
changes into purchasing and planning strategies.
$56 arising from the 6 quota holders calling (time 30 minutes) the Department to
confirm changes to quota allocations (i.e. off-set mechanism and potential impact on
future quota allocations
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
Page | 54
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 55
Attachment E-15 - Exempt feedstock uses of ozone depleting substances from the import
levy
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
$0.000 055
$0
$0
$0.000 055
Business
Community
organisations
Individuals
Total, by source
$0
$0
$0
($ million)
$0
Are all new costs offset? (tick)
Not required (measure is either zero cost or a saving)
Yes, costs are offset by savings from the Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $55
Background
The majority of ozone depleting substances (ODS) are controlled under the Montreal Protocol on
Substances that Deplete the Ozone Layer. The use of many of these ODS have been or are subject
to either phase-down or phase-out (ban) under the Montreal Protocol and under the Ozone Act
and Regulations, which give domestic legislative effect to Australia’s obligations under the
Montreal Protocol. Feedstock uses of ODS were not subject to phase-down or phase out under
the Montreal Protocol or the Ozone Act or Regulations.
Feedstock use occurs where a chemical substance (in this case an ODS) is used as an
intermediate substance to manufacture other chemicals. During the process the ODS is largely or
entirely destroyed. Section 12A of the Ozone Act provides that feedstocks are not subject to all
the usual controls in the Ozone Act i.e. licensing and levy requirements do not apply. However,
due to the narrow reading of the Act importers of larger containers where only a portion of the
gas is intended for feedstock use are in fact subject to the import levy for the feedstock portion.
The narrow reading of Section 12A also has an unitended flow on effect for importers of
hydrochlorofluorocarbon feedstock. Any non-feedstock import of bulk hydrochlorofluorocarbon
requires a quota allocation under the Ozone Act. However, due to the narrow reading of the Act
importers of larger containers where only a portion of the gas is intended for feedstock use are
in fact subject to the hydrochlorofluorocarbon quota requirement. Due to the strict quota
requirements under the Act, this effectively bans the import in these circumstances.
This was not the intent of the Act and scheduled substances for feedstock use should not have
levy or quota restrictions applied. This is consistent with the wider approach to feedstock in
Page | 56
section 12A and under the Montreal Protocol.
There is also an opportunity to further clarify the definition of feedstock in the Ozone Act. This
would align the definition with decisions on the Montreal Protocol and by the Technology and
Economic Assessment Panel. The change would clarify that a feedstock is completely
transformed in the manufacturing process of a new chemical, or entirely converted from its
original composition. As well as further aligning the Act with international obligations, the intent
of the proposed amendment is to clarify circumstances where a feedstock licensing exemption
may apply. The amendment will assist in identifying when a licence is or is not required, and
reduce the risk of illegal imports and non-compliance with the Ozone Act.
This costing looks at the the option to insert a clarification into the Ozone Act that no ODS
imported for use as a feedstock will be subject to the usual controls in the Ozone Act, as well as
clarifying the definition of feedstocks.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.

The costing time frame is 10 years.

Is it assumed that the period these measures are costed over is 2017-2027.
Explanation of measure and relevant assumptions
Education of changes to allow for exemption and permit application
process
Total
regulatory cost
p.a.
$55


It is assumed that it will take 5 minutes to open, download and read one page of text as
emailed directly by the Department.
It is assumed that of the 10 licence holders who either do or have the capacity to import
feedstock 15% would read a direct communication from the Department.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Page | 57
Responsible Policy Officer
Accountable Authority
Signature
(Accountable Authority)
Date
Page | 58
Attachment E-16 - Addition of internal review mechanism to Ozone Act
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
$0.000 628
$
$
$0.000 628
Business
Community
organisations
Individuals
Total, by source
$
$
$
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from the Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $0.000 628
Background
The Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 (the Ozone Act)
regulates the manufacture, import and export of ozone depleting substances (ODS) and synthetic
greenhouse gases (SGGs) and equipment containing these gases through an import, export and
manufacture licensing system.
Section 66 of the Ozone Act currently provides that applications may be made to the
Administrative Appeals Tribunal (AAT) for the review of the decisions listed in that section.
Appealable decisions include:




Decisions refusing to grant licences or exemptions
Decisions in relation to HCFC quota
Decisions to revoke, vary or impose conditions
Decisions to terminate or cancel a licence or exemption.
However, the Ozone Act does not contain an “internal review” or “reconsideration” process. In
the absence of this process, a decision-maker would not be able to review a decision before the
decision is considered by the AAT. Providing for an internal review, without precluding appeal to
the AAT may provide a more efficient and effective method to deal with review of decisions. The
option for an internal review is consistent with other legislation and the main Ozone Regulations
which allow decisions made in relation to the end use licensing schemes to be reconsidered by
the relevant authority.
The suggested amendment to the Ozone Act would insert an internal review procedure for the
import, export and manufacture licensing system. This would allow an officer independent from
the original decision to review the original decision. A mechanism would still be available to
Page | 59
allow decisions to be reviewed by the AAT after it is reviewed internally.
Standard Assumption
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Is it assumed that the period these measures are costed over is 2017-2027; i.e. the Default
costing time frame is 10 years.
 The standard wage rate has been used ($37.40).
 It is assumed that one page of information will be provided for education costs.

Notification will be a 1 page email, taking 5 minutes to read and digest.
Explanation of measure and relevant assumptions
Addition of internal review mechanism to Ozone Act
Total
regulatory cost
$628
A mechanism to be added to the Ozone Act to allow internal review of appealable decisions. This
would incur an education cost for import licence holders.


All current licence holders (assumed to be 1,200) will need to be notified of any changes.
It is assumed all licence holders will read the notification.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 60
Attachment E-17 - Defining the import licensing scheme
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Definition of
Import
$0.000 126
Definition of
Temporary
Import
$0.000 063
$0.000 063
Definition of
Export
$0.000 011
$0.000 011
Cost offset
($ million)
Agency
Business
$
$
$
Community
organisations
Individuals
$
$
$0.000 126
Total, by source
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
Yes, costs are offset by savings from Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
In order for the licence scheme to operate efficiently, its operation needs to be clearly defined.
The Ozone Act currently calls up the definition of import and export in the Customs Act 1901,
however the terms ‘import’ and ‘export’ are not defined. In practice, this means that it is
necessary to rely on judicial consideration to define the point of import and the point of export.
These common law definitions may change with judicial interpretation over time.
The absence of a clear and easily available definition has led to importers not seeking an
appropriate licence at the correct time leading to inadvertent non-compliance, importing
without a licence which is a contravention of the Ozone Act, or attempting to use a different
entities’ licence to import the goods. The definition also does not make it clear that ships may be
considered as imported into Australia.
In order to support an effective and efficient import licensing scheme based on clear definitions,
the Ozone Act would require amendment. The intent of the amendments is to clarify when a
licence is required, clarify who needs to hold a licence and reduce the risk of illegal imports and
Page | 61
non-compliance with the Ozone Act.
Delays at the border are costly for the importer and exporter as goods have to be warehoused
before being entered for home consumption or released for export. The licensing scheme should
aim to minimise such delays.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 The standard wage rate has been used ($37.40).
 For education costs, it is assumed that if the information is published on the Department’s
website, 100% of stakeholders would read it.
 Customs Brokers would receive information through existing training or education materials
and therefore the education costs for this group of stakeholders is zero.
Explanation of measure and relevant assumptions
Definition of Import
Total
regulatory cost
$0.000 126
The date of import is currently defined under well tested Common Law as being the date on
which the goods are brought within a port with the intention of landing or when the goods are
landed. This definition could be reflected in the Ozone Act. If this definition were to be brought
into the Ozone Act, the associated offence provision may also need to be adjusted so that the
provision can be appropriately enforced. A strict liability offence is not appropriate where it is
necessary to prove intent. Alternatively, the date of import could be defined as the day the goods
land in Australia.
A clear definition assists licence holders to understand when they need to hold a licence, report
and pay levy, all of which hinge from the date of import. Specific provision for ships is required
under either definition.
These changes are minor and mechanical in nature.
Option 1: Define the date of import as the day on which either:
a) the goods are brought into Australian waters with the intention of landing them in
Australia; or
b) the goods are landed in Australia.
Option 2: Define the date of import as the day on which the goods landed in Australia
Assumptions


The proposed definitions align with the current common law interpretation. The intention is
to provide greater clarity for importers. As such it is assumed that there will be some
education costs in communicating the clarified definitions.
It is assumed that the clarified definitions will lead to some reduction in non-compliance.
Page | 62




Costs associated with non-compliance have not been included in the RBM.
It is assumed that both definitions (Options 1 and 2) will have the same level of regulatory
impact. The difference between the definitions revolves around offence provisions and strict
liability, and the ease with which the provisions can be enforced. This does not impact on
regulatory burden.
The low volume equipment threshold is assumed to have minimised instances of importers
applying for a licence where no licence was actually required. Therefore, altering the
definition of date of import is expected to have negligible effect on importers who fall under
a low volume threshold.
The licensing scheme currently encompasses approximately 1200 licensees. It is assumed
that 100% of stakeholders would read the relevant information on the Department's
website. As it is assumed that 90% of imports are undertaken through customs brokers; this
leaves 120 importers who may face education in the inital two years.
It is assumed that reading one web page (the initial page including time taken to find the
page) takes 5 minutes.
Definition of temporary import
Total
regulatory cost
$0.000 063
The current definition of import does not consider temporary imports, for example ships that
sail into Australia’s territorial waters for a limited period of time, the movement of military
equipment, and the temporary import of cars, such as for motor shows. This means that an
import and, for bulk gases, an export licence is required. This is a costly and time consuming
requirement for importers and exporters, while having little environmental value. The Ozone Act
does not align with other Commonwealth legislation and policies, such as the Coastal Trading
(Revitalising Australian Shipping) Act 2012.
An option to consider is that where goods are imported temporarily (see indicative list below) a
licence would not be required. Any import/export that is not temporary in nature will require
the appropriate licence under the Ozone Act. The Department currently has administrative
measures in place to this effect. These measures are outlined in the “Interim Policy for the
Treatment of Temporary Imports Containing Scheduled Substances”. This policy better reflects
trade and commerce patterns, without unduly affecting the integrity of the licensing scheme
itself or the objectives of the Ozone Act.
Temporary imports to be included in regulation might include:

Goods in transit - goods not intended to remain in Australia and which do not change
ownership during the voyage - for example refrigerated shipping containers, known as
reefers, unloaded from one ship and transferred to another, or goods unloaded to bonded
storehouse and then shipped out

Products which are imported under Carnet or other international agreements relating to
temporary imports

Products which are regularly imported and exported from Australia, without changing
ownership

Products which are exported and re-imported (or vice – versa) for repairs or exchange
Page | 63

Importers who bring in a mix of “temporary” and “permanent” imports would still
require a licence for “permanent” imports. Only “permanent” imports would be included
in their Department quarterly activity statements (this is in line with the treatment of
medical/veterinary equipment importers reporting obligations).

Vessels engaged in a short period of coastal trade. For example: those which have been
issued a temporary licence under the Coastal Trading (Revitalising Australian Shipping)
Act 2012. This Act does not however cover the full range of vessels or circumstances that
the Ozone Act requires, and it may be necessary to amend the Ozone Act to make it clear
that all vessels are covered.

Extending the exemption for foreign ships and aircraft in section 12B of the Ozone Act so
that it applies to vessels which are foreign flagged and temporarily operating within
Australia (i.e. will operate for 12 months or less) regardless of voyage patterns. It is not
intended that temporary importers would require HCFC quota to cover this type of
import. This will provide for bulk scheduled substances (i.e. spare gas) onboard the ship
or aircraft, used to service the vessel’s air conditioning or refrigeration equipment to be
considered as a temporary import. This would provide for consistent treatment of bulk
gas and equipment in these circumstances.
Option 1: Provide a licence exemption for temporary imports through regulation, such as
altering the definition of date of import to include temporary imports
Assumptions







The Department currently has administrative measures in place which mirror the measures
proposed above. These measures are outlined in the “Interim Policy for the Treatment of
Temporary Imports Containing Scheduled Substances”. The regulatory changes proposed are
intended to accommodate temporary imports without unduly affecting importers or the
integrity of the licensing scheme itself.
The low volume equipment threshold is assumed to have minimised instances of importers
applying for a licence where no licence was actually required. Therefore, including a
definition of temporary import is expected to have negligible effect on importers who fall
under a low volume threshold.
Current administrative practice and arrangements with the Customs and Border Protection
Service see importers (or their customs brokers on their behalf) make their own assessment
as to whether an import is “temporary” in nature and whether a licence is required. It is
estimated that 90% of temporary imports are undertaken through customs brokers. This
often reflects temporary imports of a commercial nature, such as shipping engaged in coastal
trade or the temporary import/export of mining equipment.
Customs Brokers would receive information through existing training or education materials
and therefore the education costs for this group of stakeholders is zero.
For education costs, it is assumed that if the information is published on the Department’s
website, 100% of stakeholders would read it.
The Department estimates approximately 600 temporary imports in a year (this figure does
not include international airline flights). As it is assumed that 90% of temporary imports are
undertaken through customs brokers and 100% of remaining stakeholders would read
information published on the Departments website. This leaves 60 importers who may face
education costs.
It is assumed that reading one web page (the initial page including time taken to find the
Page | 64
page) takes 5 minutes.
Definition of export
Total
regulatory cost
$0.000 011
The date of export is currently defined under Common Law as being the day on which either:
a) the goods are loaded onto a ship or aircraft with the intention of landing them in a place
outside of Australia; or
b) the goods are loaded onto a ship or aircraft and the goods are, in fact, landed outside
Australia.
This definition could be reflected in the Ozone Act (Option 3), or partially reflected in the Ozone
Act (Options 1 or 2). If definitions under Options 1 or 3 were to be brought into the Ozone Act,
the associated offence provision may also need to be adjusted so that the provision can be
appropriately enforced. A strict liability offence is not appropriate where it is necessary to prove
intent.
A clear definition assists licence holders to understand the actual point of export and when they
need to report an export. A clear definition will also strengthen compliance and enforcement
provisions. Specific provision for ships is required under any export definition.
These changes are minor and mechanical in nature.
There are 19 licensed exporters under the Ozone Act, all of them export bulk scheduled
substances. Exporters of ODS/SGG equipment do not require a licence to export, nor are there
any export reporting requirements. The definition is most relevant to licence holders or
exporters of SGGs and of SGG equipment to which the equivalent carbon tax was applied and
who are eligible to apply for a refund under the Export Refund Scheme. The scheme ends on 31
December 2015.
Option 1: The date of export could be defined as the day on which the goods are loaded onto a
ship or aircraft with the intention of landing them in a place outside Australia. This definition
allows for expedient processing of the remainder of the export refund scheme, as there would be
no time lag between loading of the goods onto the vessel and the actual landing of the goods
outside of Australia. This definition also is most suited for use in Australia’s international
reporting obligations.
This definition may however compromise Australia’s ability to comply with Montreal Protocol
requirements through the ability to enforce the bans on exporting without a licence set out in
section 13 of the Ozone Act as strict liability offences. This is because the Department would
need to demonstrate that the person in question intended that the goods be landed outside
Australia.
Option 2: Export could be defined as the date on which the goods are landed outside Australia.
Under this definition it is likely that the Department could continue to enforce the offence
provision on exporting without a licence as strict liability offences, and would need to prove that
the goods were loaded onto a vessel and were subsequently landed outside Australia.
Option 3: Defines export as either the date on which the goods are loaded with the intention to
land them or when they are actually landed. This is effectively the current implied definition of
export. This may compromise the Department’s ability to enforce the offence provisions on
exporting without a licence set out in section 13 of the Ozone Act as strict liability offences,
because the Department would need to demonstrate that the person in question intended that
Page | 65
the goods be landed outside Australia and as such would need to be altered so that it was not a
strict liability offence.
Assumptions





The proposed definitions align with the current common law interpretation. The intention is
to provide greater clarity for importers. As such it is assumed that there will be some
education costs in communicating the clarified definitions.
It is assumed that all the definitions will have the same level of regulatory impact. The
difference between the definitions revolves around offence provisions and strict liability, and
the ease with which the provisions can be enforced. This does not impact on regulatory
burden.
It is assumed that it will take 5 minutes to open, download and read one page of text as
emailed directly by the Department. It is assumed that of the 19 licence holders who hold
export licences, all would read a direct communication from the Department.
The licensing scheme currently encompasses 19 licensed exporters. 90% of these use a
customs broker. It is assumed that of the remaining 10%, all would read the relevant
information on the Department's website.
There are 19 licensed exporters under the Ozone Act, all of them export bulk scheduled
substances. Exporters of ODS/SGG equipment do not require a licence to export, nor are
there any export reporting requirements.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 66
Attachment E-18 - Restructure of import, export, manufacture controls
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ million)
Total
regulatory
cost
Licence amalgamation
-$10,063
-$0.010 063
Application of Levy to
halon equipment
Total
regulatory
cost
$91
$0.000 091
Cost offset
($ million)
Business
Community
organisations
Individuals
Total, by
source
($ million)
Agency
$
$
$
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
The Ozone Act has been amended over time in response to Australia’s evolving international
obligations. The Act has been amended in an incremental nature in response to those changing
demands.
This has resulted in an Act where imports, exports and manufacture of gases and equipment
containing those gases are controlled through a complex mixture of licensing, licensing
exemptions, bans, and exemptions to those bans. These are scattered throughout the Ozone Act
and associated regulations. This legislative structure is complicated and difficult to navigate and
understand for users, and does not always support efficient and effective administration.
The Act restructure considers that the import, export and manufacture licence scheme be
Page | 67
simplified into two streams: goods that require a licence and goods that do not. Taking a
streamlined approach when restructuring the Ozone Act will support understanding, reduce
complexity and the risk of non-compliance. It will also allow for more effective management of
goods in a manner which imposes only an appropriate level of regulatory burden.
The policy’s intent and administrative changes described above would be reflected in a new
structure. A new structure would also continue to reflect and support Australia’s international
obligations under both the Montreal and Kyoto Protocols.
Any new structure should be flexible enough to encompass further changes in Australia’s
international obligations as they occur, so that the Australian Government can efficiently manage
imports of ODS/SGGs into the future.
There are several minor changes required that have not been considered already in the interim
report, specifically:

Changing the current section 40 exemption to an equipment licence. This reduces the
regulatory burden on approximately twenty four entities that currently hold ODS/SGG
equipment licences and section 40 exemptions and how they are required to apply for
and report under each separately.
The current criteria ensuring only essential equipment is imported under the new
equipment licence would be retained. This ensures that equipment that is currently
banned continues to be effectively banned, with a possible limited low volume
exemption.

Applying a levy to equipment imported under an equipment licence, including
equipment that would have been imported under a section 40 exemption. This is
consistent with treatment of other imports and the purposes of the Ozone and SGG
Special Account.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 The standard wage rate has been used ($37.40).
 For education costs, it is assumed that if the information is published on the Department’s
website, 100% of stakeholders would read it.
 It is assumed that 100% of stakeholders would read the relevant information sent to them
directly
Explanation of measure and relevant assumptions
Act restructure - Halon equipment licence amalgamation
Page | 68
Total
regulatory cost
-$0.010 063
Act restructure: The Ozone Act has been amended over time in response to Australia’s evolving
international obligations. The Act has been amended in an incremental nature in response to
those changing demands.
This has resulted in an Act where imports, exports and manufacture of gases and equipment
containing those gases are controlled through a complex mixture of licensing, licensing
exemptions, bans, and exemptions to those bans. These are scattered throughout the Ozone Act
and associated regulations. This legislative structure is complicated and difficult to navigate and
understand for users, and does not always support efficient and effective administration.
The Act restructure considers that the import, export and manufacture licence scheme be
simplified into two streams: goods that require a licence and goods that do not. Taking a
streamlined approach when restructuring the Ozone Act will support understanding, reduce
complexity and the risk of non-compliance. It will also allow for more effective management of
goods in a manner which imposes only an appropriate level of regulatory burden.
Halon equipment licence amalgamation: Rolling the current halon equipment “licence” (called
a section 40 exemption) in with the ODS/SGG equipment licence. This reduces the regulatory
burden on approximately twenty four entities that currently hold ODS/SGG equipment licences
and section 40 exemptions and how they are required to apply for and report under each
separately.
Assumptions:




The Department would provide information on the changes to all stakeholders.
Criteria that currently apply for halon “licences” (Section 40 exemptions) would still apply; in
short that equipment must be necessary for medical, veterinary or defence use.Currently this
is limited to halon fire systems, in particular onboard aircraft. It is assumed that there will
therefore be no change from the current 24 importers annually.
The Department assumes that instances of such importers (i.e. importers of Halon onboard
aircraft) not requiring a refrigeration and air conditioningequipment licence are negligable.
On this basis the purchase costs are assumed to be halved as only 1 not 2
licences/exemptions would be required. (Note that licensees will only pay one $3,000
application fee under this option, not two $3,000 application fees)
There will no longer be a separate halon equipment “licence” (called a section 40 exemption)
under this option. Assumptions of costs therefore avoided are:
- Finding and completing online application on Departmental website
- Contacting Department through application process
- Obtaining certified identification
- Time taken to pay application fees, transaction fees
- Ongoing reporting and record keeping requirements
Act restructure - Imposition of levies for special equipment licensees
Page | 69
Total
regulatory cost
$0.000 091
Section 40 exemptions do not have levies associated with the scheduled substances imported.
With an amalgamated equipment licence under a restructure, it is possible that levies could be
imposed on the imported halon. This would not affect low-volume halon equipment importers if
a low volume threshold were instigated. Options for levies could include:
a) no levy is charged, in line with the status quo with Section 40 exemptions
b) levy is charged at a metric tonne rate, on an ozone depleting potential basis, or at the
same per kilogram rate as the National Halon Bank (NHB) charges for halon
The current imports of halon in equipment into Australia amounted to less than 1.4 metric
tonnes in 2013 (around 12 ODP tonnes), most being halon 1301.
Assumptions:




The levies themselves are direct financial costs which will be attached to a regulation, and
are payable to government. They are therefore not included in the regulatory burden
measure.
If no levy is charged, there is no change to costings provided for an amalgamated halon and
refrigeration and air conditioning equipment licence.
The Department would provide information on the changes to all stakeholders.
Criteria that currently apply for halon “licences” (Section 40 exemptions) would still apply; in
short that equipment must be necessary for medical, veterinary or defence use.Currently this
is limited to halon fire systems, in particular onboard aircraft. It is assumed that there will
therefore be no change from the current 24 importers annually.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
[Signature of Accountable Authority or Dep Sec if EB approves –
Page | 70
(Accountable Authority)
Date
Page | 71
scan to PDF and file]
Attachment E-19 - End-use licensing provisions under the Ozone Regulations
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ )
N/A
Option 1 = BAU
Total, option 2a
(RAC only)
-$5,922,527
$
$
- 5,922,527*
Total, option 2b
(FP only)
-$114,221
$
$
- 114,221*
Total, option 2c
(FP only, retain
licences for
handlers of
halon)
-$68,572
$
$
-68,572
Total, option 2d
(both schemes)
- $6,036,748
$
$
- 6,036,748
Total, option 3
-$1,758,334
$
$
-1,758,334
Total, option 4
$51,309
$
$
51,309
Business
Community
organisations
Individuals
Total, by source
$
$
Cost offset
($ million)
Agency
$
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
Page | 72
End-use licensing schemes for refrigeration and air conditioning (RAC) and for fire protection
are currently in place under the Ozone regulations. Under the terms of the licensing schemes, all
businesses that acquire, store or dispose of either refrigerant or extinguishing agent that is a
scheduled substance under the Ozone Act (an ozone depleting substance (ODS) or synthetic
greenhouse gas (SGG) are required to hold a trading authorisation. Any technician handling
these substances must hold a handling licence. Refrigerant trading authorisations (RTAs) and
Refrigerant Handling Licences (RHLs) are issued for the RAC industry; Extingiuishing Agent
Trading Authorisations (EATAs), Halon Special Permits (HSPs) and Extinguishing Agent
Handling Licences (EAHLs) are issued for the fire protection industry.
The aim of the schemes is to protect the environment by minimising the emission of high global
warming refrigerant and extinguishing agents as they are being used.
Global industry is transitioning towards alternative gases that have low global warming
potentials. In the RAC industry, many of these alternatives have toxic or flammable properties
and the health risk to technicians and potentially consumers is increasing.
The need for end-use licensing to reduce emissions is diminishing; however, the need for
controls on work health safety and consumer protection – which is regulated by states and
territories – remains and may be increasing.
The objective of new policy measures is to:


Reduce regulatory burden on businesses where current controls are becoming less effective
Provide opportunities for full regulatory coverage of RAC and/or fire protection issues
General Assumptions
 Costing period is for 10 years (from 2017-2027).
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth, with the exception of option 4.
 The wage rates are based on an industry-agreed “call out rate” of $150 per hour for RAC; $70
per hour for fire protection. These rates apply to RAC and fire protection business
owners/managers and technicians.
 Costs to business owners / managers and individual technicians that are associated with the
cost of gaining and retaining a permit are considered business costs.
 Assumes new licence / authorisation structures would commence in 2018.
 Assumes one-off transition costs in 2017 for scheme members to become familiar with changes.
Assumes 2 pages of educational material to inform permit holders:
 100% of permit holders would take 10 minutes to read the material on average.
 The standard wage rate is assumed for reading time, rather than the call out rate.
 It costs $18 and 20 minutes to obtain an ID photo for an application form and it is assumed that
10% of applicants do not already have an ID photo and need to obtain one.
 A re-application currently takes 20 minutes to complete 98.2% of applicants are re-applicants.
 There are several different types of handling licences under each scheme, some of which need
to be renewed every 2 years and some every year:
 88.4% of RHL holders have 2-year licence types while 11.6% hold 1-year licence types.
 97.9% of EAHL holders have 2-year licence types while 2.1% hold 1-year licence types.
 It costs $1.50 to print and post a new application form or reapplication form (applies to hard
copy applicants for RAC (= 10% of applicants/reapplicants)
 70% of all licence and authorisation holders will spend 5 mins, four times per year reading the
quarterly newsletter by the industy board administering the licensing scheme.
 15% of all permit holders spend an addition 30 mins four times per year reading the quarterly
Page | 73






newsletter and undertaking further research = equivalent of 2 hours per year.
This is estimated to be the time taken to read the content relevant to maintaining knowledge of
the requirements of the licensing scheme and of issues relevant to running a RAC business. It is
not mandatory and reflects statistics for actual readership.
Assumes standard wage rate rather than call out rate for reading information about the scheme
as is it considered that businesses would only read this information when they had time to
spare (i.e. they would not choose to read information about the licensing scheme at a time when
they had the opportunity to attend to a call out if they had the choice).
Authorisation holders would continue to maintain records of gas use as part of good business
practice – no change
Authorisation and licence holders are already required to keep their contact and other relevant
details up to date with the relevant industry board – no change
Where licensing requirements are transferred to either a voluntary scheme or to a different
jurisdiction the licensing requirements and model remain the same and so the regulatory
burden for members of those schemes remains the same.
Based on industry consultation and an assessment of state and territory licensing requirements,
It is assumed that new RAC technicians would maintain the same training requirements with or
without the current ODS/SGG licence requirements. Similarly based on industry consultation,
the fire protection industry considered training requirements with an environmental focus
would be reduced for all states except for QLD and training would be retained at current levels
by the 30% of technicians whose companies would likely retain training at current levels. The
assumptions and costs below reflect this advice.
Basis for permit numbers used in costings:
 Growth in the number of refrigerant trading authorisations (RTAs), refrigerant handling
licences (RHLs) and extinguishing agent handling licences (EAHLs) is 1.8% p.a. over the
projection period. The average number of permits over this period is used to estimate cost.
Assumes zero growth in the number of extinguishing agent trading authorities (EATAs).
 Some licence holders also hold RTAs / EATAs and some RAC licensees also hold two licences.
Because some costs apply per permit and some costs (such as education costs) apply only to
each individual who may hold multiple permits, the number of individuals is provided below,
along with the number of authorisations and licences. takes licence holders who also hold
trading authorisations and/or multiple licences.
 The figures below provide the projected number of permits and individuals as well as the
average number over the projection period. The averages are used for the costings below:
EATAs
EAHLs
Businesses
Businesses
(incl. HSPs)
17241
17551
17867
18189
18516
18850
19189
46633
47472
48327
49197
50082
50984
51902
145
145
145
145
145
145
145
1359
1383
1408
1434
1460
1486
1513
145
145
145
145
145
145
145
164
167
170
173
176
179
183
Page | 74
1246
1268
1291
1315
1338
1362
1387
40
41
41
42
43
44
45
EAHLs
handling
halon
Individuals
58873
59933
61012
62110
63228
64366
65524
HSPs
Businesses
17241
17551
17867
18189
18516
18850
19189
Individuals
RHLs
2015
2016
2017
2018
2019
2020
2021
Fire
RTAs
RAC
697
710
722
735
749
762
776
2022 19534 66704 19534 52836
2023 19886 67904 19886 53787
2024 20244 69127 20244 54755
2025 20608 70371 20608 55741
2026 20979 71638 20979 56744
2027 21357 72927 21357 57765
AVG 19565 66810 19565 52920
145 1540 145
145 1567 145
145 1596 145
145 1624 145
145 1654 145
145 1683 145
145 1542 145
186 1412
189 1437
193 1463
196 1489
200 1516
203 1543
186 1414
45
46
47
48
49
50
45
790
804
818
833
848
863
791
* Cautionary note on assumptions


It is difficult to predict how training would be taken up by new entrants to the industry if
licensing requirements were removed. Consultation with representatives of the RAC industry
supported the scenario where there would be no reduction in training costs for RAC as new
entrants to any trade completing a full trade certificate before commencing work in either the
RAC industry or on special harzard fire protection systems. Representatives of the fire
protection industry suggested that there would be a limited reduction in formal training costs
for new entrants. If training expectations for new fire protection technicians did remain as they
are now it would significantly reduce the regulatory burden saving by $202,500 over the
costing period.
It should also be noted that the removal of legislative requirements may result in significant
growth in the number of allied tradespeople undertaking some elements of RAC or fire
protection work without the full complement of training that would ensure work practices that
minimise emissions.
Explanation of measure and relevant assumptions
Option 2a: remove end-use licensing from the Ozone Regulations – RAC
only
Total regulatory saving for option 2a
Total
regulatory cost
p.a.
-$5,922,527
Application component
Remove need to apply or reapply for an authorisation

Businesses no longer need to apply anew or re-apply every two years:
o 1.8% or 352 x 4.5 hours to apply for the first time +
o 19,213 x 0.33 hours to reapply
o Hard copy application + ID photo: 19,565 x 10% = 1,956 x
0.33 hours + $19.50
Remove need to apply or reapply for a handling licence

Licence holders no longer need to apply or reapply every two years:
o 57,997 x 0.33 hours to reapply
o 1,063 x 1 hour to apply for the first time
o Hard copy application + ID photo: 59,060 x 10% = 5,906 x

- $2,948,704
0.33 hours + $19.50
Individuals no longer need to apply or reapply every year:
o 7,610 x 0.33 hours to reapply
Page | 75
-757,586
o 140 x 1 hour to apply for the first time
o Hard copy application + ID photo: 7,750 x 10% = 775 x 0.33
-$1,785,038
hours + $19.50
-$406,079
Assumptions:
A new RTA application takes 4.5 hours to complete; a new RHL application takes 1 hour
(including sourcing and noting additional information). A reapplication takes 20 minutes.
19,213 businesses and 65,607 (57,997 2 yr + 7,610 1 yr) technicians need to reapply. 352
businesses and 1,203 (1,063 2 yr + 140 1 yr) technicians will apply for the first time in any given
year.
Compliance component:
- $528,290
Remove need for businesses to accommodate compliance/education visits
Business owners/managers no longer need to spend time during education
visits to ensure they are aware of and carrying out their obligations under
the scheme:
3,913 x 1 hour p.a.
Assumptions:
3,913 (= 20% of RTA holders) education visits conducted each year at 1 hour per visit
Education component:
- $2,973,823
Remove need to update knowledge of the rules/requirements of the scheme:
Technicians no longer need to stay up to date with the requirements of the
Regulations as they relate to the conditions of the licensing scheme.
Businesses (holders of RTAs):
19,565 x 70% = 13,696 x 0.33 hours p.a.
Individuals (holders of RHLs without a trading authorisation):
52,920 x 70% = 37,044 x 0.33 hours p.a.
Businesses (holders of RTAs):
19,565 x 15% = 2,935 x 2 hours p.a.
Individuals (holders of RHLs without a trading authorisation):
52,920 x 15% = 7,938 x 2 hours p.a.
Page | 76
- $3,047,474
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
RAC:
Businesses (holders of RTAs):
17,867 x 10 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 10 minutes in 2017
One-off cost in
2017:
$73,651
Assumptions
 Assumes ongoing learning to remain awareness of the regulatory
requirements occurs in between call outs: assumes standard wage rate of
$65 per hour.
Option 2b: remove end-use licensing from the Ozone Regulations – fire
protection only
Total regulatory saving for option 2b
Total
regulatory cost
p.a.
-$114,221
Application component
Remove need to apply or reapply for an authorisation
Page | 77
$-27,706
Businesses (holders of EATAs) no longer need to re-apply every two
years:
o 145 x 20 minutes to reapply + hard copy application form @
$1.50
o 10% x 145 = 15 ID photos x $18.00 + 20 minutes
Remove need to apply or reapply for a handling licence
-$1,784
-$308
Individuals no longer need to apply or reapply every two years:
o 1,482 x 20 minutes to reapply + hard copy application form @
$1.50
o 27 x 1.33 hours to apply for the first time + hard copy
application
o 10% x total (1,509) = 151 ID photos x $18.00 + 20 minutes
Individuals no longer need to apply or reapply every year:
o 32 x 20 minutes to reapply + hard copy application @$1.50
o 1 x 1.33 hours to apply for the first time + hard copy
-$18,229
application @ $1.50
o 10% x 33 = 3 ID photos x $18.00 + 20 minutes
-$1,737
-$5,585
-$708
-$64
-$111
Additional assumptions


Assumes HSPs are retained.
Assumes 145 business licence holders need to reapply every 2 years.
Education component
- $67,424
Reduction in level of formal training required for new entrants

Reduced training cost for 70% of new entrants in all states and
territories with the exception of QLD (proportion of licensees in QLD =
20.4% . = 6 people):
28 new entrants – 6 = 22 people
70% of all remaining new entrants = 15
15 people p.a, cost reduction $1,500 over nine years.
Remove need to update knowledge of the rules/requirements of the scheme:
Page | 78
-$20,250
Technicians no longer need to stay up to date with the requirements of the
Regulations as they relate to the conditions of the licensing scheme.
Businesses (holders of EATAs):
145 x 70% = 102 x 0.33 hours p.a.
Individuals (holders of EAHLs without a trading authorisation):
1,414 x 70% = 990 x 0.33 hours p.a.
- $48,795
Businesses (holders of RTAs):
145 x 15% = 22 x 2 hours p.a.
Individuals (holders of RHLs without a trading authorisation):
1,414 x 15% = 212 x 2 hours p.a.
Additional cost of transitonal information about upcoming changes /
requirements of the scheme:
All scheme members would be given educational material to explain the
changes to their licensing scheme:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 10 mins in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 10 minutes in 2017
One-off cost in
2017:
+ $1,621
Additional Assumptions



Assumes that existing state and territory training requirements remain the same – no change
Assumed that in Queensland training will remain the same for all new fire protection
technicians
Assuming cost reduction of $1,500 per person for 70% of licence holders in all states and
territories with the exception of QLD. Assumes remaining 30% will continue to be trained by
the larger companies that employ them.
Reporting component
Remove need for businesses to provide quarterly useage reports
Businesses would no longer need to provide quarterly extinguishing agent
useage reports to the Industry Board administering the scheme:
2 hours p.a. x 145 EATA businesses
Page | 79
- $18,270
Assumptions


On average, businesses would spend 30 minutes four times per year completing and sending
to the industry board the 1 page useage report
Assumes HSPs are retained – no change
Option 2c: remove licensing for fire protection but retain permits and
handling licences for halon
Reduction in regulatory burden = 2b = -$114,221 + retained costs for EAHL
holders who handle halon = $45,649
Retention of costs for EAHLs for handlers of halon
Total
regulatory cost
p.a.
-$68,572
$45,649
Application component
Retain the need to apply or reapply for a handling licence
Individuals need to apply or reapply every two years:
$11,290
o 694 x 20 minutes to reapply + hard copy application form @
$1.50
o 13 x 1 hour to apply for the first time + hard copy application
o 10% x 707 = 71 ID photos x $18.00 + 20 minutes
$10,865
Individuals need to apply or reapply every year:
o 15 x 20 minutes to reapply + hard copy application @$1.50
o 0.3 x 1 hours to apply for the first time + hard copy
application @ $1.50
o 10% x 15 = 2 ID photos x $18.00 + 20 minutes
Education component
Technicians should update knowledge of the rules/requirements of the
scheme:
Individuals (holders of EAHLs without a trading authorisation who
handle halon):
772 x 70% = 540 x 0.33 hours p.a.
772 x 15% = 116 x 2 hours p.a.
Retention in level of formal training required for new entrants

Reduced training cost for 70% of new entrants in all states and
territories with the exception of QLD (proportion of licensees in QLD =
20.4% . = 6 people):
28 new entrants – 6 = 22 people
Page | 80
$425

70% of all remaining new entrants = 15
15 people p.a, cost reduction $1,500 over nine years.
Under this option, 46.81% or 7 additional people would retain the cost of
formal training, so the cost reduction would be for 8 people rather than
15.
$34,359
$24,909
$9,450
Assumptions:






45 businesses will still need to hold a Halon Special Permit to be able to acquire halon where
there is a critical need – no change.
46.81% of the 1,542 EAHLs holders are listed on a Halon Special Permit = 722. Therefore,
722 individuals continue to apply for and hold an EAHL to be able to handle halon. Of these,
709 would reapply: 97.9% or 694 every 2 years, 2.1% or 15 every year. 13 would apply p.a.
for the first time.
Assumes most remaining fire protection scheme members would read the quarterly
newsletter: 70% would spend 20 minutes p.a. while 15% would spend an additional 2 hours
p.a.
Assumes all fire protection scheme members will need to read one-off educational material
to explain changes to the scheme.
Assumes that all fire protection scheme members would need to read about changes to the
scheme – average of 10 minutes for 100% of participants.
Assumes the same proportion of reduced formal training costs for new technicians as for the
removal of all fire protection licensing (70% of total number of licensees)
Option 2d: remove licensing for both RAC and fire protection
Total
regulatory cost
p.a.
Reduction in regulatory burden = 2a (-$5,922,527) + 2b (-$114,221)
- $6,036,748
Assumptions:

45 businesses will still need to hold a Halon Special Permit to be able to acquire halon where
there is a critical need – no change.
Option 3: voluntary licensing for RAC and fire protection
Page | 81
Total
regulatory cost
p.a.
-$1,758,334
Reduction in regulatory burden = (total reduction for option 2a + total
reduction for option 2b = - $6,036,748) - (one off transitional education costs
$75,272) = -$6,112,020 x 30% = -$1,833,606
+
Additional one-off educational costs in 2017 for all licence holders to learn
about the changes to the scheme: total $75,272
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
$73,651
RAC:
Businesses (holders of RTAs):
17,867 x 10 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 10 minutes in 2017
Additional cost of transitonal information about upcoming changes /
requirements of the scheme:
All scheme members would be given educational material to explain the
changes to their licensing scheme:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 10 mins in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 10 minutes in 2017
$1,621
Assumptions:


Assumes 70% of licence holders “opt in” for both industries, based on the assumption that
the majority of the industry are already members of the scheme and are familiar with the
services it provides; and that members will continue to see value in the legitimacy brought
by industry accreditation and in the provision of targeted information and representation.
Assumes that the regulatory reduction of removing licensing requirements applies only to
the 30% of current licensees who “opt out”. However, the cost of learning about the changes
Page | 82


to the schemes apply to all current licence holders.
Ongoing regulatory costs for technicians and businesses would remain under a voluntary
scheme – no change.
It is assumed that the industry bodies running the voluntary schemes would retain
administrative arrangements and would still need to conduct audits to ensure members
were meeting the requirements of accreditation – no change
Option 4: Transition end-use licensing to state and territory jurisdictions
Total
regulatory
cost p.a.
Total costs for option 4 - $102,618
$102,618
50% of the additional costs and savings in education apportioned to Cth: $51,309
50% of the additional costs apportioned to jurisdictions: $51,309
The number of multiple permits to operate in multiple jurisdictions are worked out on the
basis of the numbers below. The number of permits held in multiple states and territories is
based on the per centage of permits currently held in 1,2,3,4 etc. jurisdictions and these per
centages are then applied to the average number of permits for the costing period which takes
into account the assumed growth rate of 1.8% p.a., except for EATAs. The Average # of
permits is therefore used to establish how many multiple permits would be required by multistate operators.
RTAs
EATAs
AVG #
Extra
AVG #
Extra
States
2015 permits %
permits States permits %
permits
0
1 17195 19,365 98.98%
1
126 86.90%
0
2
93
106
0.54%
52
2
8
5.52%
4
3
32
35
0.18%
24
3
1
0.69%
0.7
4
19
21
0.11%
16
4
2
1.38%
1.5
5
13
14
0.07%
11
5
0
0.00%
0
6
8
10
0.05%
8
6
0
0.00%
0
7
4
4
0.02%
3
7
0
0.00%
0
8
8
10
0.05%
8
8
8
5.52%
7
Total 17372 19,565
123 Total
145
13
Note: No growth was projected for EATAs over the costing period.
RHLs
States
1
2
3
4
Page | 83
EAHLs
#
AVG #
Extra
#
AVG #
Extra
2015
permit %
permits States 2015 permits %
permits
0
0
58861 66,129 98.98%
1
126
1,340 86.90%
318
361
0.54%
181
2
8
85
5.52%
43
106
120
0.18%
80
3
1
11
0.69%
7
65
74
0.11%
50
4
2
21
1.38%
16
5
47
47
6
29
33
7
12
13
8
29
33
Total 58,873 66,810
0.07%
0.05%
0.02%
0.05%
Total
37
5
28
6
11
7
29
8
416 Total
0
0
0
8
145
0
0
0
85
1542
0.00%
0.00%
0.00%
5.52%
Total
0
0
0
75
140
Apportionment
The current regulatory burden for RAC and fire protection licensing is transferred to states
and territories but is not apportioned as there is no net change.
It is assumed that the decision to transfer the existing schemes to state and territory
jurisdictions would be jointly agreed and therefore additional costs of this option are
apportioned 50% Cth / 50% state and territory governments.
$19,540
Additional costs associated with requiring multiple permits
Application component
$4,624
RAC
Need to apply or reapply for additional authorisations:
 Businesses need to apply anew or re-apply every two years:
o 2 x 4.5 hours to apply for the first time +
o 121 x 0.33 hours to reapply
o Hard copy application + ID photo: 123 x 10% = 12 x 0.33 hours + $19.50
Need to apply or reapply for additional handling licences:

$12,545
Licence holders no longer need to apply or reapply every two years:
o 7 x 1 hour to apply for the first time
o 409 x 0.33 hours to reapply
o Hard copy application + ID photo: 416 x 10% = 42 x 0.33 hours + $19.50
Fire Protection
Need to apply or reapply for additional authorisations:
Businesses need to apply or reapply every two years:
o 13 x 20 minutes to reapply + hard copy application form @ $1.50
o 10% x 13 = 1 ID photos x $18.00 + 20 minutes
$180
Need to apply or reapply for additional handling licences:
Technicians need to apply or reapply every two years:
o 139 x 20 minutes to reapply + hard copy application form @ $1.50
o 3 x 1 hour to apply for the first time + hard copy application
o 10% x 139 = 14 ID photos x $18.00 + 20 minutes
Page | 84
$2,190
Education component
Businesses and technicians should remain up to date with the rules/requirements of multiple
state / territory schemes:
Businesses (123 RTAs + 13 EATAs):
136 x 70% = 95 x 0.33 hours p.a.
$78,065
$22,368
Individuals (416 RHLs + 140 EAHLs):
556 x 70% = 389 x 0.33 hours p.a.
Businesses (123 RTAs + 13 EATAs):
136 x 15% = 27 x 2 hours p.a.
Individuals (416 RHLs + 140 EAHLs):
556 x 15% = 83 x 2 hours p.a.
Assumptions






All permit holders would need to continue to apply for and hold a permit in their state or territory – no
change
Assumes additional applications will be required on the basis of technicians who operated in multiple
states/territories. Additional application costs reflect this need for extra applications.
Application costs are based on assumptions for options 2a and 2b.
Assumes the same proportion of new applicants and reapplicants as for other options: 98.2% of
additional licence holders would be reapplying, the remaining 1.8% would be applying for the first
time.
For simplicity it is assumed for this scenario that all licences are for two years duration. There would
be a slight increase in cost if it was assumed that 1 year licences were factored in, however this
difference would be too small to counter the degree of accuracy in the remaining assumptions.
It is assumed that halon special permits would remain under current arrangements.
Education component
Additional one off cost of transitonal information about upcoming changes / requirements of
the scheme (for all current scheme members):
All scheme members would be given educational material to explain the changes to their
licensing scheme:
RAC:
Businesses (holders of RTAs):
17,867 x 10 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 10 minutes in 2017
Additional cost of transitonal information about upcoming changes / requirements of the
Page | 85
One off
cost in
2017:
$73,651
scheme:
All scheme members would be given educational material to explain the changes to their
licensing scheme:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 100% x 10 mins in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 100% x 10 minutes in 2017
Reduction in level of formal training required for new entrants


Reduced training cost for 70% of new entrants in all states and territories with the
exception of QLD (proportion of licensees in QLD = 20.4% . = 6 people):
28 new entrants – 6 = 22 people
70% of all remaining new entrants = 15
15 people p.a, cost reduction $1,500 over nine years.
Under this option, based on current proportions of licences held in QLD, 29 of the
additional 140 licences are held in QLD. Therefore the reduction in the level of formal
training = 29 x 1.8% = 0.5 new entrants. Therefore 14.5 people p.a. see a cost reduction of
$1,500 p.a. over nine years.
One-off
cost in
2017:
$1,621
- $19,575
Reporting component
$1,638
Requirement for multiple fire protection trading authority holders to meet quarterly usage
reporting requirements in multiple jurisdictions:
13 additional reports x 2 hours per person
Compliance component
$3,375
Requirement for multiple refrigerant trading authority holders to allow for compliance /
education visits in multiple jurisdictions:
123 x20% = 25 additional audits x 1 hour per person
Assumptions




Assumes one-off transition costs in 2017 for all scheme members to become familiar with changes.
Assumes 2 pages of educational material to inform all permit holders:
All permit holders would take 5 minutes to read the material
Assumes HSPs are retained.
Assumes reporting and auditing requirements remain the same as under the current scheme
Assumes that state and territory training requirements remain the same – no change
Page | 86
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 87
Attachment E-20 - End-use reporting provisions under the Ozone Regulations
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Business
Community
organisations
Individuals
Total change in
costs
($ )
Total, option 1
-$18,194
$
$
- 18,194
Total, option 2
$5,312,137
$
$
5,312,137
Total, option 3
$1,336,334
$
$
1,336,334
Total, option 4
-$18,033
$
$
- 18,033
Business
Community
organisations
Individuals
Total, by source
$
$
Cost offset
($ million)
Agency
$
($ million)
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
End-use licensing schemes for refrigeration and air conditioning (RAC) and for fire protection
are currently in place under the Ozone regulations. Under the terms of the licensing schemes, all
businesses that acquire, store or dispose of either refrigerant or extinguishing agent that is a
scheduled substance under the Ozone Act (an ozone depleting substance (ODS) or synthetic
greenhouse gas (SGG) are required to hold a trading authorisation. Any technician handling
these substances must hold a handling licence. Refrigerant trading authorisations (RTAs) and
Refrigerant Handling Licences (RHLs) are issued for the RAC industry; Extingiuishing Agent
Trading Authorisations (EATAs), Halon Special Permits (HSPs) and Extinguishing Agent
Handling Licences (EAHLs) are issued for the fire protection industry.
The aim of the schemes is to protect the environment by minimising the emission of high global
warming refrigerant and extinguishing agents as they are being used.
Global industry is transitioning towards alternative gases that have low global warming
potentials.
Page | 88
The equipment that contains gases that are scheduled under the Act can have a lifespan of
between two to more than 20 years. The need for end-use licensing to reduce emissions is
diminishing, however, with long lifespans for equipment there will continue to be a need to
regulate end-use for some time.
Under current regulatory arrangements authorised fire protection businesses must report gas
usage on a quarterly basis. Theses requirements provide what is potentially a valuable source of
data for understanding the rates of use and change within the industry as gas use transitions to
low global warming potential gases. However, currently this data is collated but goes unused and
in this sense represents a form of unnecessary regulatory burden for the businesses that are
required to report that information. Further, while these requirements are in place for fire
protection businesses, refrigeration and air conditioning businesses have different quarterly
record keeping requirements whereby they must record equipment and gas storage testing and
maintenance as per the requirements for fire protection, but they are not required to collect and
report actual gas usage.
The options presented below seek to measure the regulatory burden of different ways to
harmonise record keeping and reporting requirements for fire protection and refrigeration and
air conditioning businesses.
The objective of new policy measures is to:


Reduce regulatory burden on businesses where current controls are becoming less effective
Provide opportunities for full regulatory coverage of RAC and/or fire protection issues
General Assumptions
 Costing period is for 10 years (from 2017-2027).
 The wage rates are based on an industry-agreed “call out rate” of $150 per hour for RAC; $70
per hour for fire protection unless otherwise stated. These rates apply to RAC and fire
protection business owners/managers and technicians.
 Costs to business owners / managers and individual technicians that are associated with the
cost of gaining and retaining a permit are considered business costs.
 Assumes new licence / authorisation structures would commence in 2018.
 Assumes one-off transition costs in 2017 for scheme members to become familiar with changes.
Assumes 2 pages of educational material to inform permit holders:
 100% of permit holders would take 5 minutes to read the material on average.
 Assumes standard wage rate of $65 per hour rather than call out rate for reading information
about the scheme as is it considered that businesses would only read this information when
they had time to spare (i.e. they would not choose to read information about the licensing
scheme at a time when they had the opportunity to attend to a call out if they had the choice).
 Authorisation holders would maintain records of gas use and equipment maintenance as part of
good business practice – no change.
 HSP holders would continue to report usage – no change.
Basis for permit numbers used in costings:
 Growth in the number of refrigerant trading authorisations (RTAs), refrigerant handling
licences (RHLs) and extinguishing agent handling licences (EAHLs) is 1.8% p.a. over the
projection period. The average number of permits over this period is used to estimate cost.
Assumes zero growth in the number of extinguishing agent trading authorities (EATAs).
 Some licence holders also hold RTAs / EATAs and some RAC licensees also hold two licences.
Because some costs apply per permit and some costs (such as education costs) apply only to
each individual who may hold multiple permits, the number of individuals is provided below,
Page | 89
2015 17241 58873 17241 46633
2016 17551 59933 17551 47472
2017 17867 61012 17867 48327
2018 18189 62110 18189 49197
2019 18516 63228 18516 50082
2020 18850 64366 18850 50984
2021 19189 65524 19189 51902
2022 19534 66704 19534 52836
2023 19886 67904 19886 53787
2024 20244 69127 20244 54755
2025 20608 70371 20608 55741
2026 20979 71638 20979 56744
2027 21357 72927 21357 57765
AVG 19565 66810 19565 52920
145 1359 145
145 1383 145
145 1408 145
145 1434 145
145 1460 145
145 1486 145
145 1513 145
145 1540 145
145 1567 145
145 1596 145
145 1624 145
145 1654 145
145 1683 145
145 1542 145
164 1246
167 1268
170 1291
173 1315
176 1338
179 1362
183 1387
186 1412
189 1437
193 1463
196 1489
200 1516
203 1543
186 1414
EAHLs
handling
halon
HSPs
Individuals
Businesses
(incl. HSPs)
Businesses
EAHLs
Individuals
Businesses
Fire
RHLs
RTAs
RAC
EATAs

along with the number of authorisations and licences. takes licence holders who also hold
trading authorisations and/or multiple licences.
The figures below provide the projected number of permits and individuals as well as the
average number over the projection period. The averages are used for the costings below:
40
41
41
42
43
44
45
45
46
47
48
49
50
45
697
710
722
735
749
762
776
790
804
818
833
848
863
791
Explanation of measure and relevant assumptions
Option 1: Remove the quarterly usage reporting requirements
currently placed upon fire protection authorisation holders
Total
regulatory cost
p.a.
Total regulatory saving for option 1
-$18,194
Reporting component
- $18,270
Remove need for businesses to provide quarterly useage reports
Businesses would no longer need to provide quarterly extinguishing agent
useage reports to the Industry Board administering the scheme:
2 hours p.a. x 145 EATA businesses
Additional cost of transitonal information about upcoming changes /
requirements of the scheme:
One-off cost in
2017:
All EATA holders would be given educational material to explain the changes
to their licensing scheme:
$76
Businesses (holders of EATAs):
Page | 90
145 x 5 mins in 2017
Assumptions




On average, businesses would spend 30 minutes four times per year completing and sending
to the industry board the 1 page useage report.
It is assumed that as part of good business practice, businesses would maintain records of
gas use, equipment inventory and maintenance schedules. As such it is assumed that the only
additional cost to fire protection businesses of adopting the same quarterly record keeping
requirements as currently apply to RAC businesses would be incurred by the need to
understand the timing and potential reporting obligations on RAC businesses.
Assumes current arrangements for HSPs are retained – no change.
It is assumed that businesses would take approximately 5 minutes to read advice about the
removal of reporting requirements and adapt.
Option 2: Retain the quarterly usage reporting requirements currently
placed upon fire protection authorisation holders and extend them to
holders of RAC authorisation holders.
Total
regulatory cost
p.a.
Total regulatory cost for option 2
$5,312,137
Reporting component
$5,282,902
Include a new requirement for RAC businesses to provide quarterly useage
reports
Businesses would need to provide quarterly refrigerant useage reports to the
Industry Board administering the scheme:
2 hours p.a. x 19,565 RTA businesses
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All RTA holders would be given educational material to explain the changes
to their licensing scheme:
RAC:
One-off cost in
2017:
$29,235
Businesses (holders of RTAs):
17,867 x 15 minutes in 2017
Assumptions


On average, businesses would spend 30 minutes four times per year completing and sending
to the industry board the 1 page useage report. The same timeframes are assumed for RAC
businesses.
It is assumed that as part of good business practice, businesses would maintain records of
gas use, equipment inventory and maintenance schedules. As such it is assumed that the only
additional cost to fire protection businesses of adopting the same quarterly record keeping
Page | 91

requirements as currently apply to RAC businesses would be incurred by the need to
understand the timing and potential reporting obligations on RAC businesses.
It is assumed that businesses would take an average of approximately 15 minutes to read
advice about the new reporting requirements and adapt their practices.
Option 3: Retain current reporting requirements for fire protection
and extend them to RAC authorisation holders, but extend the reporting
period from a quarterly to an annual basis.
Total regulatory cost of option 3
Total
regulatory cost
p.a.
$1,336,334
Reporting component
Reduce the reporting period for fire protection businesses from quarterly to
annual useage reports
-$13,703
Businesses would no longer need to provide quarterly extinguishing agent
useage reports to the Industry Board administering the scheme:
2 hours p.a. x 145 EATA businesses
But instead provide annual reports:
30 minutes p.a. x 145 EATA businesses
Include a new requirement for RAC businesses to provide annual useage
reports
Businesses would need to provide quarterly refrigerant useage reports to the
Industry Board administering the scheme:
$1,320,726
30 minutes p.a. x 19,565 RTA businesses
Additional cost of transitonal information about upcoming changes /
requirements of the scheme:
All scheme members would be given educational material to explain the
changes to their licensing scheme:
One-off cost in
2017:
$76
Businesses (holders of EATAs):
145 x 5 mins in 2017
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
Businesses (holders of RTAs):
17,867 x 15 minutes in 2017
Assumptions
Page | 92
One-off cost in
2017:
$29,135





On average, businesses would spend 30 minutes four times per year completing and sending
to the industry board the 1 page useage report. The same timeframes are assumed for RAC
businesses. Under this option this period is extended to 30 minutes per year.
It is assumed that as part of good business practice, businesses would maintain records of
gas use, equipment inventory and maintenance schedules. As such it is assumed that the only
additional cost to fire protection businesses of adopting the same quarterly record keeping
requirements as currently apply to RAC businesses would be incurred by the need to
understand the timing and potential reporting obligations on RAC businesses.
Assumes current arrangements for HSPs are retained – no change
It is assumed that fire protection businesses would take an average of approximately 5
minutes to read advice about changes to the reporting requirements and adapt their
practices.
It is assumed that RAC businesses would take an average of approximately 15 minutes to
read advice about the new reporting requirements and adapt their practices.
Option 4: Remove the quarterly usage reporting requirements
currently placed upon fire protection authorisation holders and replace
with the same type of record keeping requirements as those in place for
RAC.
Total
regulatory cost
p.a.
Total regulatory saving for option 4
-$18,033
Reporting component
- $18,270
Remove need for businesses to provide quarterly useage reports
Businesses would no longer need to provide quarterly extinguishing agent
useage reports to the Industry Board administering the scheme:
2 hours p.a. x 145 EATA businesses
Additional cost of transitonal information about upcoming changes /
requirements of the scheme:
One-off cost in
2017:
All scheme members would be given educational material to explain the
changes to their licensing scheme:
$237
Businesses (holders of EATAs and holders of HSPs only):
145 x 15 mins in 2017
Assumptions



On average, businesses would spend 30 minutes four times per year completing and sending
to the industry board the 1 page useage report. This requirement would be removed.
It is assumed that as part of good business practice, businesses would maintain records of
gas use, equipment inventory and maintenance schedules. As such it is assumed that the only
additional cost to fire protection businesses of adopting the same quarterly record keeping
requirements as currently apply to RAC businesses would be incurred by the need to
understand the timing and potential reporting obligations on RAC businesses.
Assumes current arrangements for HSPs are retained – no change
Page | 93
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 94
Attachment E-21 - Restructuring end-use licences under the Ozone Regulations
Instrument Title
Average annual regulatory costs (from business as usual)
Business
Community
organisations
Individuals
Total change in
costs
($)
Total, option 1
-$66,367
$
$
-66,367
Total, option 2
-$21,429
$
$
-21,429
Total, option 3
-$3,858
$
$
-3,858
Business
Community
organisations
Individuals
Total, by source
($ million)
$
$
$
$
Change in costs
($ million)
Cost offset
($ million)
Agency
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
End-use licensing schemes for refrigeration and air conditioning (RAC) and for fire protection
are currently in place under the Ozone regulations. Under the terms of the licensing schemes, all
businesses that acquire, store or dispose of either refrigerant or extinguishing agent that is a
scheduled substance under the Ozone Act (an ozone depleting substance (ODS) or synthetic
greenhouse gas (SGG) are required to hold a trading authorisation. Any technician handling
these substances must hold a handling licence. Refrigerant trading authorisations (RTAs) and
Refrigerant Handling Licences (RHLs) are issued for the RAC industry; Extingiuishing Agent
Trading Authorisations (EATAs), Halon Special Permits (HSPs) and Extinguishing Agent
Handling Licences (EAHLs) are issued for the fire protection industry.
The current structure of end-use licences is highly complex and can be duplicative.
Eligibility for particular licences is determined by relevant trade qualifications and units of
competency. By establishing a number of specific licence types, and especially restricted licence
types, a balance could be reached whereby technicians with very limited roles in using RAC or
fire protection equipment could undertake training that was limited to their work needs.
While there are some practicalities to this approach, its level of complexity has helped to develop
the perception and some of the attributes of an occupational licensing scheme, rather than
focusing only on the objectives of the Ozone Act.
Page | 95
The level of specialisation in RAC licences also means that there is scope for some industry
sectors to use the system to create a barrier to entry and reduce competition.
Finally, the system of establishing a highly specialised licence type for each specialty application
has entrenched a need for ever-increasing licence types which in turn has led to duplicative
administration.
Options to reduce this level of complexity and to potentially clarify the regulatory coverage of
end-use licensing provide a significant opportunity to ensure the schemes are focused on the
objectives of the Ozone legislation as well as providing an opportunity to streamline the
administration requirements for business and regulators. The options being considered are:
 Restructure of end-use licensing, simplifying licences to a basic ODS/SGG licence
 Change the physical licence card to a “membership card” and retain licence conditions
online and in supplementary documentation provided to the technician
 Minor changes to the current RAC structure to streamline the administration of licensing
General Assumptions
 Costing period is for 10 years (2017 – 2027)
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 The options assume that the licensing schemes for RAC and for fire protection would continue
under the Ozone Regulations.
 The wage rates are based on an industry-agreed “call out rate” of $150 per hour for RAC; $70
per hour for fire protection. These rates apply to RAC and fire protection business
owners/managers and technicians.
 It costs $18 and 20 minutes to obtain an ID photo for an application form and it is assumed that
10% of applicants do not already have an ID photo and need to obtain one.
 It costs an average of $1.50 to print and post an application or reapplication form (applies to
hard copy applicants for RAC (10% of RAC applicants) and all reapplicants for fire protection)
 A new RTA and EATA application takes 4.5 hours to complete. A new RHL and EAHL application
takes 1 hour to complete (including sourcing and noting additional information)
 A reapplication for an RTA and EATA takes 20 minutes to complete; an RHL and EAHL
reapplication currently takes 20 minutes to complete.
 There are several different types of handling licences under each scheme, some of which need
to be renewed every 2 years and some every year:
 88.4% of RHL holders have 2-year licence types while 11.6% hold 1-year licence types.
 97.9% of EAHL holders have 2-year licence types while 2.1% hold 1-year licence types.
 Assumes new licence / authorisation structures would commence in 2018.
 Assumes one-off transition costs in 2017 for scheme members to become familiar with changes.
Assumes 2 pages of educational material to inform permit holders:
 100% of permit holders would take 5 minutes to read the material on average.
 The standard wage rate is assumed for reading time, rather than the call out rate.
Basis for permit numbers used in costings:
 Growth in the number of refrigerant trading authorisations (RTAs), refrigerant handling
licences (RHLs) and extinguishing agent handling licences (EAHLs) is 1.8% p.a. over the
projection period. The average number of permits over this period is used to estimate cost.
Assumes zero growth in the number of extinguishing agent trading authorities (EATAs).
 Some licence holders also hold RTAs / EATAs and some RAC licensees also hold two licences.
Because some costs apply per permit and some costs (such as education costs) apply only to
each individual who may hold multiple permits, the number of individuals (which takes into
Page | 96
2015 17241 58873 17241 46633
2016 17551 59933 17551 47472
2017 17867 61012 17867 48327
2018 18189 62110 18189 49197
2019 18516 63228 18516 50082
2020 18850 64366 18850 50984
2021 19189 65524 19189 51902
2022 19534 66704 19534 52836
2023 19886 67904 19886 53787
2024 20244 69127 20244 54755
2025 20608 70371 20608 55741
2026 20979 71638 20979 56744
2027 21357 72927 21357 57765
AVG 19565 66810 19565 52920
145 1359 145
145 1383 145
145 1408 145
145 1434 145
145 1460 145
145 1486 145
145 1513 145
145 1540 145
145 1567 145
145 1596 145
145 1624 145
145 1654 145
145 1683 145
145 1542 145
164 1246
167 1268
170 1291
173 1315
176 1338
179 1362
183 1387
186 1412
189 1437
193 1463
196 1489
200 1516
203 1543
186 1414
40
41
41
42
43
44
45
45
46
47
48
49
50
45
EAHLs
handling
halon
HSPs
Individuals
Businesses
(incl. HSPs)
Businesses
EAHLs
EATAs
Individuals
Businesses
RHLs
RTAs

account licence holders who also hold trading authorisations and/or multiple licences) is
provided below, as well as the total number of authorisations and licences.
The figures below provide the projected number of permits and individuals as well as the
average number over the projection period. The averages are used for the costings below:
RAC
Fire
697
710
722
735
749
762
776
790
804
818
833
848
863
791
Explanation of measure and relevant assumptions
Option 1: Restructure of end-use licensing, simplifying licences to a
basic ODS/SGG licence
Total
regulatory cost
p.a.
Total regulatory reduction for option 1
-$66,367
Reduced time costs
All RAC and fire protection licensees previously licensed for 1 year would be
licensed for 2 years (includes new applicants and reapplicants):
65,607 x 11.6% = 7,750 RAC licensees.
1,542 x 2.1% = 32 fire protection licensees.
Reduction in time and material cost to provide hard copy applications – All
Removed material cost of applying in hard copy for 90% of fire protection
business owners and individual technicians:




Applicants every two years (145 EATA holders + 1,509 2-year licence
holders) x 90% = 1,489 x 20 minutes + $1.50 every two years
Applicants every year (45 halon special permit holders + 33 1-year
licence holders) x 90% = 70 x 20 minutes + $1.50 every year
Reduced time cost of applying in hard copy for RAC licencees with 1
year permits by 5 times in ten years (reduction of 20 mins each p.a.):
7,618 x 10% = 762 RAC licensees
Reduced material cost of applying in hard copy for those with 1 year
Page | 97
-$209,679
licences by 5 times in ten years:
7,750 x 10% = 775 RAC licensees +
77 x 10% = 8 fire protection licences and Halon Special Permit
holders $19.50 each
New Education costs

Completion of a new “minimising emissions” unit of competency at
$300 per person for new entrants (based on the growth rate of
1.8%):
20% of 1181 new entrants to RAC = 236 applicants per year =
$70,800
60% of 27 new entrants to fire protection = 16 applicants per year =
$4,800
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
$68,040
One off cost in
2017:
$73,651
RAC:
Businesses (holders of RTAs):
17,867 x 8 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 8 minutes in 2017
One off cost in
2017:
$1,621
Fire Protection:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 100% x 8 minutes in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 100% x 8 minutes in 2017
Assumptions
 All technicians would transfer to an “ODS / SGG licence” from 2018. This would be the
same for RAC and fire protection and signifies that the holder is aware of how to avoid
emissions during the course of their work
 The ODS / SGG licence would be of a standard 2 years duration.
 Assumes current rates of 2 year to 1 year licence duration (for RAC, 88.4% 2-year /
11.6% 1-year. For fire protection, 97.9% 2-year / 2.1% 1-year).
 Of the 45 holders of HSPs, 21 do not also hold an EATA.
 Assumed that a new licence application would take 1 hour to complete; a licence renewal
would take 20 minutes to complete.
 Assumes that 90% of applicants would take up the online application option, while 10%
of applicants would continue to apply in hard copy and would need to purchase a photo
ID: every 2 years.
 Refrigerant Trading Authorities, Extinguishing Agent Trading Authorities and Halon
Special Permits would remain in place – no change.
 States and territories continue to regulate the RAC and fire protection industries in
relation to work health safety and consumer protection. Technical training requirements
for technicians to be eligible for a licence would not change
 Regulatory requirements to work in accordance with the relevant, current standards and
Page | 98

codes of practice as set out under the regulations would remain – no change
New entrants would be required to demonstrate that they have received training in
minimising emissions and the environmental impacts of ODS/SGGs or undertake a single
unit of competency that is relevant to their work.
Based on the coverage of emissions reduction related content in current RAC and fire
protection training required to meet state and territory requirements, assumes 20% of
new entrants to RAC and 60% of new entrants to fire protection would need to
undertake an additional unit. Assumes cost per unit of $300. New training requirements
would commence in 2018.
Option 2: Change the physical licence card to a “membership card” and
retain licence conditions online and in supplementary documentation
provided to the technician
Total
regulatory cost
p.a.
Total annual regulatory reduction for Option 2
-$21,429
Removed time costs
-$44,589


1,445 RHL holders would no longer need to apply for multiple
licences:
2,890 x 88.4% = 2,555 applications every two years. Half the number
of applications would now be required (1 per person) = 1,278 x 20
minutes
2,890 x 11.6% = 335 applications every year: Half the number of
applications would now be required (1 per person) = 168 x 20
minutes
10% of those RHL holders would no longer need to apply in hard
copy for multiple licences:
every two years: 1,278 x 10% = 128 x 20 minutes
every year: 168 x 10% = 17 x 20 minutes
Removed material costs
10% of 1,446 RHL holders would no longer need to apply in hard copy for
multiple licences and provide photo ID:
every two years: 128 x 20 minutes + $19.50
-$34,400
every year: 17 x 20 minutes + $19.50
Reduced time and material costs for fire protection – hard copy applications
Removed material cost of applying in hard copy for 90% of fire protection
business owners and individual technicians:


Applicants every two years (145 EATA holders + 1,509 2-year licence
holders) x 90% = 1,489 x 20 minutes + $1.50 every two years
Applicants every year (45 halon special permit holders + 33 1-year
licence holders) x 90% = 70 x 20 minutes + $1.50 every year
Education component
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
Page | 99
On-off cost in
2017
$57,561
RAC:
Businesses (holders of RTAs):
17,867 x 8 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 8 minutes in 2017
Fire Protection:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 100% x 8 minutes in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 100% x 8 minutes in 2017
Assumptions
 Currently the 1,445 holders (based on average number over costing period) of multiple
RAC licences hold 2 licences each. This is assumed for the costing, however, there is
potential for future licensees to hold more than 2 licences, in which case there would be a
further reduction in regulatory burden overall. It is assumed that each licence holder in
this situation would need to apply once rather than twice as is currently the case.
 Fire protection licence holders can already apply for multiple licences at once – no
change.
 The current range of regulatory conditions set out for authorisation and licence holders
remains – no change
 One card would be issued to each trading authorisation holder; one card would be issued
to each licence holder.
 Trading authorisations would be reduced to a single type for RAC, a single type for fire
protection and a halon special permit
 RAC licence types would be reduced to a single licence and a trainee licence
 Fire protection licence types would be reduced to a single licence type and a trainee
licence type
 All relevant licence types and conditions placed on a licence would be linked via a Quick
Response Code (QR code) – a type of matrix bar code – on the licence card and also
provided to the holder in supporting documentation and retained for compliance
purposes by the relevant authority.
 The holder would be bound by the conditions and limitations on their licence – no change
 Applying and reapplying for a RAC licence would be simplified to a single form to cover
all RTA types and a single form to cover all RHL types. The applicant could apply for one
or more licences at the same time
 Licence application and renewal process for fire protection would shift to predominantly
an online system. As is currently the case for RAC, it is assumed that 10% of fire
protection applicants would continue to apply in hard copy.
 Current training requirements would remain in place
Option 3: Minor changes to the current RAC structure to streamline the
administration of licensing
Total
regulatory cost
p.a.
Total regulatory saving for option 3
-$3,858
Removed time costs
-$12,557
Page | 100

281 restricted RHL holders would no longer need to apply for
multiple restricted or full and restricted licences each year:
281 x 20 minutes
Removed material costs

10% of 281 RHL holders would no longer need to apply in hard copy
for multiple licences:
281 x 10% = 28 x $1.50
New costs - education
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
One off cost in
2017:
$8,699
All scheme members would be given educational material to explain the
changes to their licensing scheme:
RAC:
Businesses (holders of RTAs):
17,867 x 3 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 0.42% = 203 x 15 minutes in 2017
48,327 x 99.58% = 48,124 x 30 seconds in 2017
Assumptions
 The changes would only apply to RAC licences. Fire protection licence arrangements
would remain the same.
 The current range of regulatory conditions set out for authorisation and licence holders
remains – no change
 In 2015, 246 licensees (0.42% of total) were multiple restricted licence holders. Based on
the growth rate of 1.8% over the projection period the average number is 281.
 It is assumed that those who need to obtain a passport-style photo ID would receive
more than one photo so would incur that time and material cost anyway. Therefore the
material cost of one hard copy application is included, but other material and time costs
for hard copy applications are considered BAU.
 Full and trainee licence types would remain.
 The range of 21restricted licence types would be reduced to a single restricted licence
type.
 All relevant conditions place on a restricted licence would be provided to the holder in
supporting documentation and retained for compliance purposes by the relevant
authority and could be updated at any time without needing to supply another licence.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Page | 101
Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 102
Attachment E-22 - Restructuring end-use licences under the Ozone Regulations
Instrument Title
Average annual regulatory costs (from business as usual)
Business
Community
organisations
Individuals
Total change in
costs
($)
Total, option 1
-$66,367
$
$
-66,367
Total, option 2
-$21,429
$
$
-21,429
Total, option 3
-$3,858
$
$
-3,858
Business
Community
organisations
Individuals
Total, by source
($ million)
$
$
$
$
Change in costs
($ million)
Cost offset
($ million)
Agency
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
End-use licensing schemes for refrigeration and air conditioning (RAC) and for fire protection
are currently in place under the Ozone regulations. Under the terms of the licensing schemes, all
businesses that acquire, store or dispose of either refrigerant or extinguishing agent that is a
scheduled substance under the Ozone Act (an ozone depleting substance (ODS) or synthetic
greenhouse gas (SGG) are required to hold a trading authorisation. Any technician handling
these substances must hold a handling licence. Refrigerant trading authorisations (RTAs) and
Refrigerant Handling Licences (RHLs) are issued for the RAC industry; Extingiuishing Agent
Trading Authorisations (EATAs), Halon Special Permits (HSPs) and Extinguishing Agent
Handling Licences (EAHLs) are issued for the fire protection industry.
The current structure of end-use licences is highly complex and can be duplicative.
Eligibility for particular licences is determined by relevant trade qualifications and units of
competency. By establishing a number of specific licence types, and especially restricted licence
types, a balance could be reached whereby technicians with very limited roles in using RAC or
fire protection equipment could undertake training that was limited to their work needs.
While there are some practicalities to this approach, its level of complexity has helped to develop
the perception and some of the attributes of an occupational licensing scheme, rather than
focusing only on the objectives of the Ozone Act.
Page | 103
The level of specialisation in RAC licences also means that there is scope for some industry
sectors to use the system to create a barrier to entry and reduce competition.
Finally, the system of establishing a highly specialised licence type for each specialty application
has entrenched a need for ever-increasing licence types which in turn has led to duplicative
administration.
Options to reduce this level of complexity and to potentially clarify the regulatory coverage of
end-use licensing provide a significant opportunity to ensure the schemes are focused on the
objectives of the Ozone legislation as well as providing an opportunity to streamline the
administration requirements for business and regulators. The options being considered are:
 Restructure of end-use licensing, simplifying licences to a basic ODS/SGG licence
 Change the physical licence card to a “membership card” and retain licence conditions
online and in supplementary documentation provided to the technician
 Minor changes to the current RAC structure to streamline the administration of licensing
General Assumptions
 Costing period is for 10 years (2017 – 2027)
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 The options assume that the licensing schemes for RAC and for fire protection would continue
under the Ozone Regulations.
 The wage rates are based on an industry-agreed “call out rate” of $150 per hour for RAC; $70
per hour for fire protection. These rates apply to RAC and fire protection business
owners/managers and technicians.
 It costs $18 and 20 minutes to obtain an ID photo for an application form and it is assumed that
10% of applicants do not already have an ID photo and need to obtain one.
 It costs an average of $1.50 to print and post an application or reapplication form (applies to
hard copy applicants for RAC (10% of RAC applicants) and all reapplicants for fire protection)
 A new RTA and EATA application takes 4.5 hours to complete. A new RHL and EAHL application
takes 1 hour to complete (including sourcing and noting additional information)
 A reapplication for an RTA and EATA takes 20 minutes to complete; an RHL and EAHL
reapplication currently takes 20 minutes to complete.
 There are several different types of handling licences under each scheme, some of which need
to be renewed every 2 years and some every year:
 88.4% of RHL holders have 2-year licence types while 11.6% hold 1-year licence types.
 97.9% of EAHL holders have 2-year licence types while 2.1% hold 1-year licence types.
 Assumes new licence / authorisation structures would commence in 2018.
 Assumes one-off transition costs in 2017 for scheme members to become familiar with changes.
Assumes 2 pages of educational material to inform permit holders:
 100% of permit holders would take 5 minutes to read the material on average.
 The standard wage rate is assumed for reading time, rather than the call out rate.
Basis for permit numbers used in costings:
 Growth in the number of refrigerant trading authorisations (RTAs), refrigerant handling
licences (RHLs) and extinguishing agent handling licences (EAHLs) is 1.8% p.a. over the
projection period. The average number of permits over this period is used to estimate cost.
Assumes zero growth in the number of extinguishing agent trading authorities (EATAs).
 Some licence holders also hold RTAs / EATAs and some RAC licensees also hold two licences.
Because some costs apply per permit and some costs (such as education costs) apply only to
each individual who may hold multiple permits, the number of individuals (which takes into
Page | 104
2015 17241 58873 17241 46633
2016 17551 59933 17551 47472
2017 17867 61012 17867 48327
2018 18189 62110 18189 49197
2019 18516 63228 18516 50082
2020 18850 64366 18850 50984
2021 19189 65524 19189 51902
2022 19534 66704 19534 52836
2023 19886 67904 19886 53787
2024 20244 69127 20244 54755
2025 20608 70371 20608 55741
2026 20979 71638 20979 56744
2027 21357 72927 21357 57765
AVG 19565 66810 19565 52920
145 1359 145
145 1383 145
145 1408 145
145 1434 145
145 1460 145
145 1486 145
145 1513 145
145 1540 145
145 1567 145
145 1596 145
145 1624 145
145 1654 145
145 1683 145
145 1542 145
164 1246
167 1268
170 1291
173 1315
176 1338
179 1362
183 1387
186 1412
189 1437
193 1463
196 1489
200 1516
203 1543
186 1414
40
41
41
42
43
44
45
45
46
47
48
49
50
45
EAHLs
handling
halon
HSPs
Individuals
Businesses
(incl. HSPs)
Businesses
EAHLs
EATAs
Individuals
Businesses
RHLs
RTAs

account licence holders who also hold trading authorisations and/or multiple licences) is
provided below, as well as the total number of authorisations and licences.
The figures below provide the projected number of permits and individuals as well as the
average number over the projection period. The averages are used for the costings below:
RAC
Fire
697
710
722
735
749
762
776
790
804
818
833
848
863
791
Explanation of measure and relevant assumptions
Option 1: Restructure of end-use licensing, simplifying licences to a
basic ODS/SGG licence
Total
regulatory cost
p.a.
Total regulatory reduction for option 1
-$66,367
Reduced time costs
All RAC and fire protection licensees previously licensed for 1 year would be
licensed for 2 years (includes new applicants and reapplicants):
65,607 x 11.6% = 7,750 RAC licensees.
1,542 x 2.1% = 32 fire protection licensees.
Reduction in time and material cost to provide hard copy applications – All
Removed material cost of applying in hard copy for 90% of fire protection
business owners and individual technicians:




Applicants every two years (145 EATA holders + 1,509 2-year licence
holders) x 90% = 1,489 x 20 minutes + $1.50 every two years
Applicants every year (45 halon special permit holders + 33 1-year
licence holders) x 90% = 70 x 20 minutes + $1.50 every year
Reduced time cost of applying in hard copy for RAC licencees with 1
year permits by 5 times in ten years (reduction of 20 mins each p.a.):
7,618 x 10% = 762 RAC licensees
Reduced material cost of applying in hard copy for those with 1 year
Page | 105
-$209,679
licences by 5 times in ten years:
7,750 x 10% = 775 RAC licensees +
77 x 10% = 8 fire protection licences and Halon Special Permit
holders $19.50 each
New Education costs

Completion of a new “minimising emissions” unit of competency at
$300 per person for new entrants (based on the growth rate of
1.8%):
20% of 1181 new entrants to RAC = 236 applicants per year =
$70,800
60% of 27 new entrants to fire protection = 16 applicants per year =
$4,800
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
$68,040
One off cost in
2017:
$73,651
RAC:
Businesses (holders of RTAs):
17,867 x 8 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 8 minutes in 2017
One off cost in
2017:
$1,621
Fire Protection:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 100% x 8 minutes in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 100% x 8 minutes in 2017
Assumptions
 All technicians would transfer to an “ODS / SGG licence” from 2018. This would be the
same for RAC and fire protection and signifies that the holder is aware of how to avoid
emissions during the course of their work
 The ODS / SGG licence would be of a standard 2 years duration.
 Assumes current rates of 2 year to 1 year licence duration (for RAC, 88.4% 2-year /
11.6% 1-year. For fire protection, 97.9% 2-year / 2.1% 1-year).
 Of the 45 holders of HSPs, 21 do not also hold an EATA.
 Assumed that a new licence application would take 1 hour to complete; a licence renewal
would take 20 minutes to complete.
 Assumes that 90% of applicants would take up the online application option, while 10%
of applicants would continue to apply in hard copy and would need to purchase a photo
ID: every 2 years.
 Refrigerant Trading Authorities, Extinguishing Agent Trading Authorities and Halon
Special Permits would remain in place – no change.
 States and territories continue to regulate the RAC and fire protection industries in
relation to work health safety and consumer protection. Technical training requirements
for technicians to be eligible for a licence would not change
 Regulatory requirements to work in accordance with the relevant, current standards and
Page | 106

codes of practice as set out under the regulations would remain – no change
New entrants would be required to demonstrate that they have received training in
minimising emissions and the environmental impacts of ODS/SGGs or undertake a single
unit of competency that is relevant to their work.
Based on the coverage of emissions reduction related content in current RAC and fire
protection training required to meet state and territory requirements, assumes 20% of
new entrants to RAC and 60% of new entrants to fire protection would need to
undertake an additional unit. Assumes cost per unit of $300. New training requirements
would commence in 2018.
Option 2: Change the physical licence card to a “membership card” and
retain licence conditions online and in supplementary documentation
provided to the technician
Total
regulatory cost
p.a.
Total annual regulatory reduction for Option 2
-$21,429
Removed time costs
-$44,589


1,445 RHL holders would no longer need to apply for multiple
licences:
2,890 x 88.4% = 2,555 applications every two years. Half the number
of applications would now be required (1 per person) = 1,278 x 20
minutes
2,890 x 11.6% = 335 applications every year: Half the number of
applications would now be required (1 per person) = 168 x 20
minutes
10% of those RHL holders would no longer need to apply in hard
copy for multiple licences:
every two years: 1,278 x 10% = 128 x 20 minutes
every year: 168 x 10% = 17 x 20 minutes
Removed material costs
10% of 1,446 RHL holders would no longer need to apply in hard copy for
multiple licences and provide photo ID:
every two years: 128 x 20 minutes + $19.50
-$34,400
every year: 17 x 20 minutes + $19.50
Reduced time and material costs for fire protection – hard copy applications
Removed material cost of applying in hard copy for 90% of fire protection
business owners and individual technicians:


Applicants every two years (145 EATA holders + 1,509 2-year licence
holders) x 90% = 1,489 x 20 minutes + $1.50 every two years
Applicants every year (45 halon special permit holders + 33 1-year
licence holders) x 90% = 70 x 20 minutes + $1.50 every year
Education component
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
All scheme members would be given educational material to explain the
changes to their licensing scheme:
Page | 107
On-off cost in
2017
$57,561
RAC:
Businesses (holders of RTAs):
17,867 x 8 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 8 minutes in 2017
Fire Protection:
Businesses (holders of EATAs and holders of HSPs only):
(145+21) = 166 x 100% x 8 minutes in 2017
Individuals (holders of EAHLs without a trading authorisation):
1,291 x 100% x 8 minutes in 2017
Assumptions
 Currently the 1,445 holders (based on average number over costing period) of multiple
RAC licences hold 2 licences each. This is assumed for the costing, however, there is
potential for future licensees to hold more than 2 licences, in which case there would be a
further reduction in regulatory burden overall. It is assumed that each licence holder in
this situation would need to apply once rather than twice as is currently the case.
 Fire protection licence holders can already apply for multiple licences at once – no
change.
 The current range of regulatory conditions set out for authorisation and licence holders
remains – no change
 One card would be issued to each trading authorisation holder; one card would be issued
to each licence holder.
 Trading authorisations would be reduced to a single type for RAC, a single type for fire
protection and a halon special permit
 RAC licence types would be reduced to a single licence and a trainee licence
 Fire protection licence types would be reduced to a single licence type and a trainee
licence type
 All relevant licence types and conditions placed on a licence would be linked via a Quick
Response Code (QR code) – a type of matrix bar code – on the licence card and also
provided to the holder in supporting documentation and retained for compliance
purposes by the relevant authority.
 The holder would be bound by the conditions and limitations on their licence – no change
 Applying and reapplying for a RAC licence would be simplified to a single form to cover
all RTA types and a single form to cover all RHL types. The applicant could apply for one
or more licences at the same time
 Licence application and renewal process for fire protection would shift to predominantly
an online system. As is currently the case for RAC, it is assumed that 10% of fire
protection applicants would continue to apply in hard copy.
 Current training requirements would remain in place
Option 3: Minor changes to the current RAC structure to streamline the
administration of licensing
Total
regulatory cost
p.a.
Total regulatory saving for option 3
-$3,858
Removed time costs
-$12,557
Page | 108

281 restricted RHL holders would no longer need to apply for
multiple restricted or full and restricted licences each year:
281 x 20 minutes
Removed material costs

10% of 281 RHL holders would no longer need to apply in hard copy
for multiple licences:
281 x 10% = 28 x $1.50
New costs - education
Additional one off cost of transitonal information about upcoming changes /
requirements of the scheme (for all current scheme members):
One off cost in
2017:
$8,699
All scheme members would be given educational material to explain the
changes to their licensing scheme:
RAC:
Businesses (holders of RTAs):
17,867 x 3 minutes in 2017
Individuals (holders of RHLs without a trading authorisation):
48,327 x 0.42% = 203 x 15 minutes in 2017
48,327 x 99.58% = 48,124 x 30 seconds in 2017
Assumptions
 The changes would only apply to RAC licences. Fire protection licence arrangements
would remain the same.
 The current range of regulatory conditions set out for authorisation and licence holders
remains – no change
 In 2015, 246 licensees (0.42% of total) were multiple restricted licence holders. Based on
the growth rate of 1.8% over the projection period the average number is 281.
 It is assumed that those who need to obtain a passport-style photo ID would receive
more than one photo so would incur that time and material cost anyway. Therefore the
material cost of one hard copy application is included, but other material and time costs
for hard copy applications are considered BAU.
 Full and trainee licence types would remain.
 The range of 21restricted licence types would be reduced to a single restricted licence
type.
 All relevant conditions place on a restricted licence would be provided to the holder in
supporting documentation and retained for compliance purposes by the relevant
authority and could be updated at any time without needing to supply another licence.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Page | 109
Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 110
Attachment E-23 - Streamlining destruction facility approval
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
Total, by sector
Cost offset
($ million)
Agency
Business
Community
organisations
Individuals
Total change in
costs
($ million)
-$0.000,130
$0
$0
-$0.000,130
Business
Community
organisations
Individuals
Total, by source
($ million)
N/A
N/A
N/A
N/A
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
Total (Change in costs – Cost offset) = N/A
Background
Destruction facilities for refrigerants and extinguishing agents must be approved separately. A
two-staged approval process is required whereby a facility is first approved as a trial destruction
facility and then a destruction facility. This requires applicants to submit two applications if they
would like to destroy gas that has been used for different purposes. The prior use of the gas is
largely irrelevant as it is the specific destruction technology that must be in accordance with
Montreal Protocol guidelines and destruction efficiency.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
 Default costing time frame is 10 years.
 Is it assumed that the period these measures are costed over is 2017-2027.
 The standard wage rate has been used ($37.40).
 That the Department contacts each stakeholder directly when the change is made.
 It is assumed that 3% of stakeholders would read the factsheet and other published
government material for one hour.
Explanation of measure and relevant assumptions
Streamline approval of destruction facilities
Total
regulatory cost
p.a.
Description of option:
It is proposed that the four approvals for trial destruction facilities (extinguishing agent and
refrigerant gases) and destruction facilities (extinguishing agent and refrigerant gas) are
streamlined to two approval processes (trail destruction and destruction facility approval).
Page | 111
Assumptions:
 the existing facility that has been approved as a trial destruction facility would also apply and
be approved as a destruction facility.
 one further facility would seek approval for both a trail destruction facility and a destruction
facility over the RBM period.
 There are no changes to the existing two destruction facilities’ approval.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 112
Attachment E-24 - Compliance and Enforcement
Instrument Title
Average annual regulatory costs (from business as usual)
Change in costs
Total, by sector
Cost offset
($ million)
Agency
Business
Community
organisations
Individuals
Total change in
costs
-$1032.00
$
$
-$1032.00
Business
Community
organisations
Individuals
Total, by source
($ million)
$
$
$
$
Are all new costs offset? (tick)
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from [insert name of offset measure ] (pending Board
approval)
 No
Total (Change in costs – Cost offset) = -$1032.00
Background
The Ozone Protection and Synthetic Greenhouse Gas Management Act 1989 (the Act) controls the
manufacture, import, export, use and disposal of ozone depleting substances (ODS) and synthetic
greenhouse gases (SGG). The Act implements Australia’s obligations under the Vienna
Convention for the Protection of the Ozone Layer, the Montreal Protocol on Substances that
Deplete the Ozone Layer and the Kyoto Protocol to the United Nations Framework Convention
on Climate Change.
The Department undertakes compliance and enforcement of the Ozone Act to promote the
protection of the environment, support compliance with our international obligations and
achieve the objectives of the legislation to reduce emissions of ODS and SGGs. For the industry,
enforcement is regarded as an important measure in ensuring a level playing field and an
essential element of fair competitive arrangements between businesses.
The proposed changes will strengthen and streamline compliance and enforcement of the Ozone
Act. They will provide the Department with an enhanced ability to manage known risks and
make it easier for industry to comply and for the Department to administer. Additional
enforcement options for the Department will encourage stakeholders to reduce emissions of
scheduled substances. Options to reduce the burden on stakeholders to fulfil compliance
requirements have also been considered.
General Assumptions
 100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
Page | 113




Default costing time frame is 10 years.
Is it assumed that the period these measures are costed over is 2017-2027.
Only import/export licence holders would require specific education information, all other
stakeholders would receive non-regulatory communication. This includes industry
publications part funded by the Department and industry training days.
It is assumed that enforcement actions and actions undertaken under a warrant do not
require costing.
Explanation of measure and relevant assumptions
Compliance and enforcement
Total
regulatory cost
p.a.
-$0.001 032m
Education for introduction of new provisions and penalties
 For breaking or destroying goods to prevent seizure.
 For distributing illegally imported or manufactured goods.
 Management of seized and surrendered goods.
 For owner/occupiers to provide reasonable assistance during a search under warrant.
 False representations for fire protection.
 Suspend an import/export licence.
 Expand the infringement notice scheme to end use licence holders.
Education for introduction of new provisions
 New exemptions for emissions of scheduled substances.
 To allow information sharing between the Department, State and Territory and
Australian Government agencies.
 To allow Delegate to consider undpaid levies when determining whether a person is fit
and proper (s16).
Assumptions
 Information on these compliance and enforcement changes would be provided as a single
factsheet (4 pages).
 Assumed it would take 8 minutes to read the 4 pages.
 There are approximately 1200 import/export licence holders, all would read the
information provided.
 End use licence holders would receive communication already costed under another
measure. Customs Brokers and allied industry and medical and veterinary and other
affected stakeholders would receive communication through methods already costed.
 The standard wage rate has been used for import/export licence holders ($37.40).
Increase enforcement options for existing offences
 Increase penalty units in the Regulations
Assumptions
 This is not a new offence; it is expanding on the enforcement options available to the
Department when a breach of the Regulations occurs. Therefore no costing is required.
Undertaking enforcement actions under warrant
 Sampling and testing of scheduled substances
 For owner/occupiers to provide reasonable assistance during a search
Assumptions
Page | 114

Office of Deregulation has advised that activities undertaken under a warrant do not
need to be costed.
Other new provisions with nil burden change
 To allow reporting of de-identified compliance data
Assumptions
 Collection and sharing of data by the Department would not create or reduce burden for
stakeholders.
 This information would only be reported following non-compliance.
New provisions with reduced burden
 To allow for Notice to Produce
Assumptions
 Reduced cost to business by enabling owner/occupiers to provide information within a
timeframe rather than be subject to a site visit by a Department inspector. This would
save licence holders 20 minutes from not having a site visit.
 40 end use licence holders per year would be affected.
 Wage cost based on technician costs as these provisions are for end use licence holders
($85.71).
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 115
Attachment E-25 - National Halon Bank Arrangements
Instrument Title
Halon Management
Average annual regulatory costs (from business as usual)
Change in costs
($ million)
1 (a) The National
Halon Bank remains a
Commonwealth
managed facility –Cost
recovery by
management fee
1 (b) The National
Halon Bank remains a
Commonwealth
managed facility –Cost
recovery by raising
the price of halon
1. (c) The National
Halon Bank remains a
Commonwealth
managed facility –Cost
recovery by raising
Fees and levies
Divest the halon stock
to users for their own
ongoing management
Privatise the National
halon Bank
Cost offset
($ million)
Agency
Business
Individuals
Total change in
costs
($ million)
$0.001,801
Total
regulatory
cost
$0.001,801
$0.000,042
Total
regulatory
cost
$0.000,042
$0.000,006
Total
regulatory
cost
$0.000,006
Total
regulatory
cost
$1,253,491
Total
regulatory
cost
$0.000,020
$1,253,491
$0.000,020
Business
Community
organisations
Individuals
Total, by
source
($ million)
$
$
$
$
Are all new costs offset? (tick)
Page | 116
Community
organisations
 Not required (measure is either zero cost or a saving)
 Yes, costs are offset by savings from Ozone Act Review (pending Board approval)
 No
Total (Change in costs – Cost offset) = $.....
Background
Australia’s obligations: The Ozone Act regulates the import, export and manufacture of halon,
used halon and equipment. These controls satisfy Australia’s obligations under the Montreal
Protocol (Article 2B). The Department also manages the Australian Halon Management Strategy
(AHMS) required under Decision X/7 of the Parties to the Montreal Protocol. The AHMS provides
a framework for the responsible management of Australia’s essential civilian halon stocks in the
lead up to replacement of all remaining halon uses once alternatives are commercially available.
Australia has met its international obligations with regards to halon, including from an
environmental perspective:




The phase-out of the import, export and manufacture of bulk halon has been completed
Halon equipment import is controlled under the Ozone Act
Australia has developed a halon management strategy
End-use licensing supports the appropriate handling of halons to reduce their emission to
the atmosphere.
The need for halon:
In 2012 the Department commissioned a report2 to better understand Australia’s current and
projected future halon essential uses. The report found that halon would be required beyond
2030 to meet servicing demands for essential equipment. Projections have been confirmed by
government and industry. As Australia is largely a technology taker the transition from halon
systems will be dependent on the development of alternative technology and take up in key
markets such as the United States and the European Union.
Halon is no longer used in the majority of fire protection applications where previously it was
considered important for fire protection. However, there remain applications where there is no
practical alternative. The aviation industry and defence sectors still require a domestic reserve of
halon stock to service/supply their essential use equipment.
The Report found that there were sufficient stocks of halon held at the National Halon Bank to
satisfy essential civilian usage in the medium term based on past sales and predicted equipment
usage.
National Halon Bank:
Australia maintains a stock of halon, accumulated through collections of halon from
decommissioned equipment, to meet essential (where no alternative exists and it is required to
safeguard health and safety and essential property) civilian requirement. The halon is stored in
the National Halon Bank. The Bank is administered by the Department. The main civilian user of
halon stocks is the aviation sector. The Department of Defence also has a separate stock of their
own halon stored at the National Halon Bank.
The cost to the Department in managing the National Halon Bank is about $1 900 000 per year.
This cost is only partially offset (approximately $570 000) by storage charges and sales revenue.
2
Review of Australia’s Halon Essential Use Requirements Energy International Australia, May 2012
Page | 117
The management of the National Halon Bank is a significant draw on resources and is only partly
cost recovered.
Future management options for the National Halon Bank
Legacy uses of halon remains. The aviation industry and defence sectors still require a domestic
reserve of halon stock to service/supply their essential use equipment. The National Halon Bank
is serving these industry and strategic sector needs, and not international obligations which have
already been met. In this context the Department may not be the appropriate entity to manage
the National Halon Bank with either other portfolios or private sector operators being more
suitable. This raises the question of how the halon stock should be managed and who should do
it.
Three options being considered for future halon stock management are:
1. Maintain the National Halon Bank as a Commonwealth entity. This might be through the
Department, the Civil Aviation Safety Authority, the Department of Infrastructure and
Regional Development or the Department of Defence, noting that the Australian Defence
Force is also a user of Halon.
The production of new halon has been banned under the Montreal Protocol, and would
only be allowed under an Essential Use Nomination. The United Nations Environment
Programme (UNEP)3 has raised the issue of the global strategic approach to halon bank
management in order to avoid a supply disruption that would lead to an Essential Use
Nomination for the production of new halon. It could be argued that a Commonwealth
managed National Halon Bank best facilitates international movement of halons for
essential uses, thus minimising the need for an Essential Use Nomination.
If the management of the National Halon Bank remains with the Department, the cost
recovery arrangements to ensure the facility is sustainable will need to be revisited. Cost
recovery arrangements could include:
(a) Management fee: the imposition of a management fee on strategic users, based on
covering the cost of running the halon bank year by year
(b) Halon Price: raising the price of halon
(c)Fees and Levies: increasing import and end use licence and levy fees associated with
halon equipment
2. Divest the halon stock to users for their own ongoing management
3. Privatise the National halon Bank
If the stock were to be divested to industry for management or privatised, some reporting
requirements may be required to support Australia’s estimation of annual usage and future
strategic requirements. This informs international policy development under the Montreal
Protocol.
General Assumptions
3
UNEP Halons Technical Options Committee 2014 Assessment Report (Volume 1)
Page | 118








100% of the total regulatory burden is attributable to the Commonwealth given all of the
proposed reforms will be implemented by the Commonwealth.
Default costing time frame is 10 years.
Is it assumed that the period these measures are costed over is 2017-2027.
The standard wage rate has been used ($37.40).
For education costs, it is assumed that if the information is published on the Department’s
website, 100% of stakeholders would read it.
For education costs, to read one page it takes 5 minutes. Second and subsequent pages take
one minute each.
If information is sent directly to the stakeholder and is not contained in a standard
communication, 100% of stakeholders would read it.
Customs Brokers would receive information through existing training or education materials
and therefore the education costs for this group of stakeholders is zero.
Explanation of measure and relevant assumptions
Total
regulatory cost
$0.001,801
A management fee is charged to strategic users, based on covering the cost of running the halon
bank year by year. Airlines as strategic users could chose to recoup these costs as suits their
business needs. For example, a fee of several cents could be added to every domestic airline
ticket. It is assumed that airlines would already have sophisticated ticketing systems in place and
costs involved in administering such a fee would be minimal.
1 (a) Management fee: The National Halon Bank remains a
Commonwealth managed facility –Cost recovery by management fee
Assumptions:
 There are 9 domestic airlines in Australia. It is assumed, supported by National Halon Bank
data, that all airlines currently do and will continue to carry out halon aircraft equipment
maintenance in Australia. These are the main strategic users who would pay management
fees under this option.
 A section 40 exemption allows the import of halon in equipment onboard aircraft.There are
24 holders of Section 40 exemptions, which includes the 9 domestic airlines noted above.
These stakeholders could also pay management fees under this option.
 A halon special permit allows a person (for example, a business) to posesss halon that is for
use in fire protection equipment. There are 40 holders of halon special permits who could
potentially supply strategic users (the 9 airlines). These stakeholders could also pay
management fees under this option.
 This equates to 64 stakeholders in total.
 The Department of Defence draws down on essential use stocks through civilian contractors;
however as a Commonwealth Department they are not included in this costing.
 It is assumed management fees will be paid on an annual basis.
 It is assumed that 100% of stakeholders would read communications sent directly to them (2
pages)
 It is assumed that the imposition of a management fee on strategic users will not impose any
further regulatory burden apart from administrative costs associated with paying the
management fee and transitional education costs.
1. (b) Halon Price: The National Halon Bank remains a Commonwealth
managed facility –Cost recovery by raising the halon price
Page | 119
Total
regulatory cost
$0.000,042
Assumptions:
 There are 40 holders of halon special permits. There are 24 holders of Section 40
exemptions, which includes the 9 domestic airlines noted in option 1(a). There are 64
stakeholders in total.
 It is assumed that 100% of stakeholders would read communications sent directly to them (2
pages)
 It is assumed that increasing the price of halon will not impose any further regulatory burden
apart from transitional education costs.
 Halon is mandated for aircraft use by the Civil Aviation Safety Authority, and a change in the
price of halon is not included in the regulatory burden measurement.
1. (c)Fees and Levies The National Halon Bank remains a
Commonwealth managed facility –Cost recovery by raising Fees and
levies
Total
regulatory cost
$0.000,042
Assumptions:
 Currently, importers of halon essential use equipment are not subject to levy. The regulatory
burden measure titled “Act Restructure” considers the imposition of a new halon equipment
levy.
 It is assumed that increasing the price of licence fees and import levies will not impose any
further regulatory burden apart from transitional education costs.
 The licence fees and levies themselves are direct financial costs attached to regulation and
are not included in the regulatory burden measure.
 There are 40 holders of halon special permits. There are 24 holders of Section 40
exemptions, which includes the 9 domestic airlines noted in option 1(a). There are 64
stakeholders in total.
 It is assumed that 100% of stakeholders would read communications sent directly to them (2
pages)
Total
2. Divest the halon stock to users for their own ongoing management
regulatory cost
$1,253,491
Option2: Divest the halon stock to users for their own ongoing management and to satisfy their
strategic needs. For example, stock could be divested to the aviation industry, as well as the
Department of Defence. There is a case for the current and potential users of the bank to be those
responsible for it. Divesting the stock could involve its sale. Private sector owners would be
required to adhere to handling and storage conditions consistent with the provisions of the
Ozone Act.
Stakeholder Assumptions:
 This scenario assumes all halon is divested to halon end users (airlines and Defence) and not
to halon suppliers. Divestment to halon suppliers is considered under option 3, “privatising
the National Halon Bank”.
 The Department of Defence draws down on essential use stocks, however as a
Commonwealth Department they are not included in this costing.
 There are 9 domestic airlines in Australia who may require halon. It is assumed that all 9
stakeholders will read information provided to them and research changes.
Page | 120
Reporting and Permit Assumptions:
 A halon special permit allows a person (for example, a business) to posesss halon that is for
use in fire protection equipment. Any entity that the halon bank would be divested to would
need to hold a halon special permit. Administrative costs associated with this are included in
the regulatory burden measure.
 To inform international policy development under the Montreal Protocol, some reporting is
required to support Australia’s estimation of annual usage and future strategic requirements.
Current reporting requirements for the Halon Special Permits are adequate to support
Australia’s estimation of annual usage and future strategic requirements.
 It is assumed that airline maintenance staff have the appropriate extinguishing agent
handling licence. Administrative costs associated with this are therefore not included in the
regulatory burden measure as this is business as usual.
Busines as Usual and New Cost Assumptions:
 It is assumed, supported by National Halon Bank data, that all airlines currently do and will
continue to carry out halon aircraft equipment maintenance in Australia. Business as usual is
assumed to be licensed technicians continuing to carry out halon aircraft equipment
maintenance in Australia. This includes costs for equipment, facilities, and associated
administrative support thereof.
 Costs that are not business as usual are assumed to include purchase of storage cylinders
and/or lifetime cylinder monitoring and maintenance; purification costs, and costs of halon
destruction. The total cost of these activities is assumed to be the current cost of maintaining
the present National Halon Bank (minus ancillary costs). Departmental data indicates this to
be approximately $1.25 million, and this reflects full compliance with Ozone legislation.
While stakeholders have been identified, costs have not been split amongst individual
stakeholders.
General/background Assumptions:
 Airline maintenance staff are technicians licensed under the Act, and are required by licence
conditions to adhere to various standards relating to fire protection equipment and the
handling and storage of extinguishing agents.
 Based on the Energy International Australia report and industry consultation, it is assumed
that halon requirements for aircraft will remain steady over the default costing timeframe
(10 years)
Privatise the National halon Bank
Total
regulatory cost
$0.000,020
Option 3: Privatise the National halon Bank to one or more halon suppliers
Assumptions:
 The only regulatory burden measure costs associated with this option are transitional
education costs.
 This scenario assumes all halon is divested to one or more halon suppliers and not to halon
users (airlines and Defence). Through the Department’s stakeholder consultations conducted
during the Act review process, it is estimated that there are 6 or less entities that may have
an interest in aquiring the National Halon Bank or part thereof.
 Divestment to halon end users (airlines and Defence) is considered under option 2,
“divesting the halon stock to users for their own ongoing management”.
 Any entity that the halon bank would be divested to would already hold a halon special
permit and extinguishing agent handling licence. In terms of this licensing there is no change
from business as usual.
 To inform international policy development under the Montreal Protocol, some reporting is
Page | 121

required to support Australia’s estimation of annual usage and future strategic requirements.
Current reporting requirements for the Halon Special Permits are adequate to support
Australia’s estimation of annual usage and future strategic requirements.
For a supplier, business as usual is assumed to include costs for equipment, facilities, and
associated administrative support thereof. This includes purchase of storage cylinders and/or
lifetime cylinder monitoring and maintenance; purification costs, and costs of halon
destruction.
Accountable Authority to approve regulatory burden costings based on their This costing
net value (costs or savings)
(tick)
Delegate
Limit of delegation
Executive Board or Deputy Secretary
Above $2 million

Head of Deregulation Unit (SES Band
1)
To $2 million

Director of Deregulation Unit (EL 2)
To $500,000

Approved By
Responsible Policy Officer
[Name and position of approver (SES Band 1)]
Accountable Authority
[Name and position of Accountable Authority as per table above]
Signature
(Accountable Authority)
[Signature of Accountable Authority or Dep Sec if EB approves –
scan to PDF and file]
Date
Page | 122