FARE’s submission to Treasury on the final report of the Competition Policy Review addresses the application of this legislation in regard to alcohol policy in Australia. FARE makes a total of seven recommendations to the Australian Government, with the key recommendation being that harm minimisation should be the primary objective of all legislation, regulations and policies relating to alcohol.


Recommendations

  1. FARE urges that the Australian Government acknowledge and adopts the view of the Competition Policy Review Panel as set out below:
    In particular, given the Panel’s view that the risk of harm from liquor provides a clear justification for liquor regulation, any review of liquor licensing regulations against competition principles must take proper account of the public interest in minimising this potential harm…. Accordingly, the Panel does not propose that the recommendation to deregulate trading hours for sellers of ‘ordinary’ goods and services (see Recommendation 12) should prevent policymakers from regulating trading times for alcohol retailing (or gambling) in order to achieve the public policy objective of harm minimisation. Similarly, the recommendation that competition be taken into account as an important part of the planning and zoning process (see Recommendation 9) should not be interpreted as removing any ability for governments, in dealing with planning and zoning, to take full account of harm minimisation as an objective…
  2. FARE urges that the Australian Government in its response to the Competition Policy Review Panel Final Report and subsequent Competition Policy legislation to ensure that for alcohol, harm minimisation is prioritised ahead of all other policy objectives, and that the public interest test for the regulation of alcohol be the effectiveness of the regulation to minimise the harm caused by alcohol, not competition in sale and access.
  3. FARE urges that if the Australian Government does not recommend that harm minimisation be the primary objective of all liquor licensing legislation, then alcohol should be declared to be a special product and exempt it from Competition Policy.
  4. FARE urges that Australian Government not to tie incentive payments to the application of Competition Policy to the liberalisation of liquor licensing legislation.
  5. FARE urges the Australian Government to recommend that alcohol not be sold in more supermarkets across Australia as this policy would undermine efforts to reduce harmful alcohol use. This recommendation echoes that of the Competition Policy Review Panel which stated in its Final Report that “…it is certainly not the Panel’s view that the promotion of competition should always trump other legitimate public policy considerations” such as harm minimisation.
  6. FARE urges the Australian Government to acknowledge and address the existing issues caused by competitive funding processes on the provision of alcohol and other drug (AOD) treatment services before applying Competition Policy Principles to the sector.
  7. FARE urges the Australian Government to urgently develop a resource allocation model and provide sufficient funding for AOD services that considers and recognises:
    a. Holistic approaches, collaboration between services and encourages the development of ‘wrap around’ services with health and welfare agencies.
    b. That outcome based funding or payment by results is inappropriate for AOD treatment and that this will negatively impact on client outcomes and their successful completion of treatment.
    c. That increasingly competitive processes may exacerbate division within the sector, favour larger services and ultimately reduce consumer choice within the sector.

Submission

View the submission


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