The Department doesn't intend to post comments received on the Exposure Draft (?) but if you are interested, the submission is here. (If you were getting a troublesome pop-up it has now been removed.) Discussion, observations or corrections are welcome.
• on a cost-benefit basis, is abolishing the application fee but retaining a modified charging regime, in the interests of addressing excessive cost to users, at the lowest administrative cost? Significant resources will still be involved to keep track of time, consider a range of related issues and communicate with applicants about charges, for relatively little return. $262,000 in charges was collected in the year to June 2009. Overall agencies estimate FOI cost $30 million to administer. I've no idea how much of that relates to time-keeping/ charges, but it's probably of some significance. A more cost effective approach might have been to retain an application fee for non-personal applications (an administatively simple process) and abolish charges. Tasmania has already decided to go this way in the Right to Information Act to commence 1 July 2010.