Efficiency is not mentioned.
However Dr Hawke was directed to consider “the role of fees and charges’ and “the desirability of minimising the regulatory and administrative burden including costs, on government agencies.” The Attorney General managed to turn that into this in her Media Release:
"$41 million of taxpayer money was spent across the Federal Government in 2011-12 processing FOI requests.The review will consider how the Government’s FOI costs could be reduced, including the Information Commissioner’s recent recommendations regarding the current charging regime."
Efficiency requires an assessment of how well systems and resources are utilised and applied in the implementation of the laws.
We don't know much about this.
Dr Hawke should do some digging for information that would throw light on what resources are allocated to the information access function, whether agencies fully utilise available technology, what constitutes good practice and whether agencies apply such methods and practices.
It is unclear what gave rise to the increase. Or what agencies are doing to reduce costs.
The public also has a right to enjoy lowish costs as one of the dividends flowing from the hundreds of millions spent on improved information management systems within government over the years. In fact there should be another dividend- access to tools that assist in knowing more about what information government holds, to better inform requests from outside the loop.
The Auditor General for example has drawn attention to record management shortcomings over the years, shortcomings that must significantly impact on FOI administration.
So in my submission, Dr Hawke should look into all this while considering “the role of fees and charges’ and “the desirability of minimising the regulatory and administrative burden including costs, on government agencies.” The Attorney General could of course have given him terms of reference that put efficiency much more clearly in the frame.
However the proposed flat 40 hour cut off, without more, needs rethinking. The proposal is an attempt to put more certainty around the substantial and unreasonable diversion of resources provision that has been in the FOI act since it commenced. It's origin is a NSW ADT decision years ago that interpreted similar words in the NSW act to mean that anything that involved 40 hours processing time was getting into substantial diversion of resources territory. However it was not a strict rule and other factors, including the nature of the information sought needed to be considered.