Quarantine Fees - If I request a review of proposed fees in line with National Guidelines but no-one is listening, does that count as consultation?

The following information was received from DAWR on 13 Nov. Still no response from the Minister.

Unfortunately the response (in italics) below fails (again) to address the issue of cross subsidisation. I have emphasised in bold those comments that relate to the topic.

As most of you may be aware, each brokerage has ONE Compliance Agreement with the Department. Under that sit the various schedules, such as NCCC and AEPCOMM, QAP, IFIS etc. How may of the large corporates have multiple such schedules compared to the amount of schedules held by small brokerages and/or importers? And why isn't billing based upon the schedules held rather than  the agreement itself? 

Am I cynical to suggest that the multinationals complain louder? And its therefore easier to take this easy route?

It's fact that SMEs are getting hit by this fee but CAPEC, major multinationals all, get savings. Why? If it is all about compliance then fees should be common rated and apply equally to the express industry / SACs.

I'm interested that DAWR claims below that part of the fees go to the development of training materials. As most brokers would know these were developed by ACCC initially and lately by CBFCA and other RTOs.

It appears that DAWR isn't listening. Next step is to check if the Commonwealth Ombudsman has jurisdiction in these matters. I encourage you to join me in lodging submissions.

"The department has redesigned its charges with a structure of fees and cost recovery levies consistent with the 2015 Australian Cost Recovery Guidelines. Fees, as you rightly point out, recover the costs of services provided directly to an individual or organisation. The fee should be set to reflect the cost of the specific service. Fees will apply for audits and assessments of applications in the case of approved arrangements.

 The department has also implemented cost recovery levies which recover the costs of activities provided to a group of individuals or organisations (eg an industry sector). The levy is set to recover the overall costs of the activity or activities.

 In the case of an approved arrangement the cost recovery levy will recover the costs involved in the development of policies and standards to support compliance agreements, quarantine approved premises and imported food compliance agreements. This includes instructional material, business improvement, risk management, and stakeholder engagement. The cost of providing these activities is not dependant on the size of an individual business within the group of businesses that hold some form of approved arrangement.

 The annual levy of $2900 does not include the costs of cargo examinations. These costs are recovered through inspection fees.

Any business that holds an approved arrangement would also be subject to audit fees in accordance with the audit regime of each arrangement that is held. Audit fees will be charged at $30 per 15 minutes if the service is provided in-office (where a departmental officer is permanently located) or $50 per 15 minutes for service provided out of office. For entities that have number of sites each site is audited at FFS rates.  Therefore entities with multiple arrangements would pay a higher amount for these activities than an entity with only one arrangement/site where the compliance of the entities is the same. If the business wanted to add an additional arrangement it would pay a fee for service for the assessment of the application for the new arrangement (charged at the in or out of office rate as relevant)."