The BCA discussion paper appears to pick costs selectively and in some instances miscalculates costs. The paper also fails to address the potential benefits of the current legislation or the potential costs if the proposed streamlining occurs. Similarly, by focusing just on costs to business, the BCA paper ignores the wider discussion about improving the effectiveness of the EPBC Act.

The BCA discussion paper suggests that the proposed reform will lower costs to business, lift productivity and enhance competition. We find that the connection between streamlining environmental assessments and approvals and these three goals is not adequately presented.

Issues with state based environmental impact assessments can cause delays as community groups voice their concerns and seek amendments to, or cancellation of, projects. A table provided in this paper illustrates some of the issues Economists at Large have uncovered with a range of state-level assessments of projects in recent years.

It is our opinion that the BCA discussion paper falls short in three areas that should warrant caution by policy makers before adoption of the proposed reforms:

• The BCA paper fails to provide reliable figures, apparently cherry picking figures and making methodological errors that result in overstated costs. In addition, figures are provided in absolute rather than relative terms.
• The BCA paper fails to consider the benefits of the EPBC or the potential costs from streamlining it. Further, the BCA paper ignores the wider context of the debate by focusing only on costs to business.
• The BCA paper insufficiently links the stated objectives of lowering costs to business, lifting productivity and enhancing competition with the proposed reform.