On 26 September John Martin presented these ideas at the GAP Congress on Regulatory Affairs: "Opportunities for Business",  held in Parliament House of Victoria.

Regulation that fosters market competition by definition must be good for business opportunity. On the other hand market arrangements that cultivate cartels and other anti competitive are anathema to innovation. 

The Trade Practices Act 1974 (TPA) is a unique "animal" in setting a low intervention framework for policing anti-competitive arrangements and unfair trading practices to protect individual and business consumers.

Unlike some other areas of regulation of business behaviour, there is not a requirement for businesses to regularly report to the Australian Competition and Consumer Commission (ACCC) in its role administering the TPA.  Enforcement and compliance actions by the Commission are driven by specific complaints or identification of concerns in a particular sector. The ACCC handles 80,000 plus complaints and enquiries per year.

I won't go into detail on how this core business of the ACCC works other than to make three underlying points influencing the effectiveness of the ACCC's role:

• the ACCC adopts a determined and strategic enforcement approach, utilising its strong evidence gathering powers complemented by rigorous economic, legal and technical analysis along side compliance initiatives with sensitive sectors or issues. An example of our strategic approach is the ACCC immunity policy relating to cartel behaviour
• a little understood capacity that the ACCC has to approve otherwise anti competitive arrangements where there are net public benefits - this occurs through the authorisation and notification processes provided for under the TPA
• efforts in recent years to make the Commission's activities more transparent, accountable and timely and to ensure the protection of confidential information.

While there is a lot that could be said about good practice in mainstream competition and consumer law administration, it is the other aspect of the ACCC's economic regulatory role I would like to focus on today.  That is the Commission's continually expanding role in the nationally consistent regulation of infrastructure.

In this regard as part of national competition reform, Australia has opted for an omnibus economic and access regulation model administered by the ACCC, covering inter alia energy, communications, transportation and most recently water sectors.

In most other developed economies like the UK and the USA, this economic regulatory role of infrastructure is generally dealt with by specific sectoral regulators.

Infrastructure regulation - experience so far

Australian experience with regulation of natural monopoly infrastructure is fairly recent - with little over ten years since the implementation of competition policy. Yet in that short time there has been considerable transformation of Australian infrastructure.  For example in the energy sector:

• there has been substantial restructuring from vertically integrated, state owned energy businesses to disaggregated businesses with a mix of ownership structures
• Victoria and South Australia have privatised their electricity supply industries and most of the gas supply sector is in private hands
• competition has been introduced into the generation and retail sectors
• the national electricity market (NEM) is well established.

In addition, there have been substantial changes to the way that regulation is applied and to regulatory institutions.  In particular:

• access regulation has been introduced for the transmission and distribution sectors
• the Australian Energy Regulator (AER) was established in 2005 as a part of the Australian Competition and Consumer Commission (the ACCC) but one that operates as a separate legal entity to the ACCC.

The regulatory environment, including the way that regulation is designed and applied, continues to evolve.  In particular, the question of what are the characteristics of a good regulatory framework is one that frequently occupies the minds of regulated firms, policy makers and regulators.

For ACCC's part the aim is to apply best practice regulatory principles - not as mother hood statements but real guides as to how we go about our business.

These principles include:

• adapting regulations to current conditions
• balance competition with investment
• be technologically neutral
• be consistent with relevant legislation
• make decisions for the long term benefit of end-users
• look to adopt approaches used in other countries, as long as they are consistent with local conditions
• be prepared to wind back regulation where it is no longer necessary
• be prepared to change approach to regulation when appropriate
• decisions should be based on detailed empirical data
• consult widely before making decisions
• decisions able to withstand legal challenge
• consider issues that may arise in the future.

It is good practice to be continually reviewing what we are doing, and how we are doing it, to ensure that the costs imposed by regulation do not exceed the benefits of that regulation. The Commission's experience in this regard has centred in four key areas:

• achieving a consistent approach to regulation
• the relative merits and design of light-handed regulation
• the impact of regulation on investment decisions ;and
• regulatory timelines and the review of decisions.

I briefly refer briefly to each of these areas in turn.

Regulatory consistency

The ACCC has adopted internal mechanisms and external networking arrangements to facilitate consistent and transparent analytical techniques, regulatory practices and stakeholder consultation. 

COAG has also addressed the issue of consistency in regulation and agreed to establish a simpler and consistent approach to economic regulation of significant infrastructure by ensuring that all third party access regimes include consistent regulatory principles and times frames for making regulatory decisions.

Reflecting this, a number of amendments to Part IIIA of the Trade Practices Act were made giving specific direction to the ACCC about the principles that should be taken into account when making regulatory decisions.  Specifically, the amendments introduced:

• an objects clause that makes it clear that the focus of Part IIIA is the promotion of efficient operation of, use of and investment in regulated infrastructure to promote competition in upstream and downstream markets through the encouragement of a consistent approach to access regulation in each industry;
• pricing principles to which the ACCC is to have regard when making arbitrations, undertakings and access code decisions;
• a range of timelines and a requirement for the ACCC to report on the time taken to make arbitrations, access code and competitive tendering decisions.

These changes do not mean that there will be a ‘one size fits all' approach to regulation.  Rather the regulatory frameworks that apply to Australian natural monopoly infrastructure are tailored to the particular market failures that economic regulation is trying to fix having regard to the characteristics of the regulated sector.  While minimalist regulation remains the ideal, the individual and sometimes unique characteristics of different markets require a range of approaches to achieve the best outcomes for industries and consumers.

"Light handed" versus "full strength" regulation

A number of reports and reviews released over recent years have emphasised the role of ‘light-handed' regulation. The ACCC notes, however, that the phrase ‘light-handed' does not have a widely accepted meaning, and is not associated with any particular regulatory framework. 

It is not particularly helpful to describe a regulatory regime as ‘light' or ‘heavy' handed because any regulatory regime can have characteristics that are thought of as ‘heavy' or ‘light' in certain circumstances.  Rather it is better to ask whether a particular regulatory regime is effective in constraining market power in the particular circumstances.

If the purpose of regulation is to provide for appropriate access to bottleneck infrastructure, price monitoring is unlikely to be an effective regulatory tool.  The incentives of a monopolist are such that they are unlikely to be substantially affected by largely non-financial impact of monitoring regimes, while activities designed to suppress competition in dependent markets may be difficult to detect.

When there is substantial market power, regulation that influences prices more directly is likely to be a better regulatory tool.  Even if the threat of re-regulation under a price monitoring regime is carried out in response to the exercise of market power by the monitored firm, the response will not be immediate.  In the interim, the firm will effectively be able to act in an unconstrained manner with little incentive to undertake efficient investments and operation of infrastructure services. 

Furthermore, the regulator will not be able to ‘clawback' the high prices and returns, and associated inefficiencies, arising from the exercise of market power.  If the market power is large, then the efficiency losses arising from the exercise of that power prior to the re-introduction of regulation are likely to be large.  Under well designed incentive regulation, the constraint will be immediate while the regulated firm will retain incentives for efficient investment and cost reduction.

This is not to say that monitoring is not a useful tool available to governments.  It just doesn't constitute, and can't substitute for access regulation.  Rather, the purpose of monitoring needs to be understood so that it can be applied to situations fit for that purpose and not applied to situations where more direct forms of regulation are likely to be more effective.

Regulation & investment

The relationship between regulation and investment has at times been a contentious issue in Australia and has been fully picked up by the ACCC radar.

There is always a risk of regulatory error in price cap and ‘building block' regulation that is applied to natural monopoly infrastructure sectors, particularly in relation to a project's cost of capital.  However, the ACCC is well aware of the scope for regulatory error and consequently tends to be conservative in selection of parameter values for key cost of capital components. 

There is also the theoretical risk that regulation could distort investment if there is ex post adjustment of actual returns.  However, this does not generally occur in Australia because the usual regulatory practice is to apply an incentive based framework  where the time path of regulatory revenues are set in advance so that the regulated firm has the expectation of achieving the allowed rate of return.  

In many regulated sectors, much investment is specific, and hence sunk.  For these sectors, it is very important that the regulatory framework is both stable and predictable - otherwise the risk that the regulated firm will not be able to recoup its investment is increased.  The more important sector-specific investments, and hence sunk costs, are in an industry the more important it is for the firm's investment decision that the regulatory framework remains stable and predictable. 

The forms of incentive regulation that the ACCC and the AER currently apply to regulated infrastructure sectors are unlikely to substantially reduce the efficiency gains that regulation seeks to achieve by distorting the regulated firm's investment decisions. Ours experience is that the design and ex ante application of traditional forms of regulation substantially mitigates the theoretical concerns regarding investment incentives. 

Nevertheless, public controversies have arisen such as Telstra's 2006 withdrawal from discussions with the ACCC about the proposed fibre to the node (FTTN) network upgrade.  Telstra estimated the capital costs of this investment at around $4 billion. 

Telstra indicated that the major stumbling block was the ACCC's unwillingness to recognise the actual costs that Telstra incurs in providing its services.  However, the ACCC always accepted that Telstra should be entitled to recover its actual costs arising from the FTTN upgrade and that Telstra faces a significant risk that should be reflected in the cost of capital used to calculate access prices. 

Despite these disagreements, progress was made to the point where the ACCC asked Telstra to proceed to the next stage of the process - making the proposal available for public comment.  Telstra did not proceed to this stage, however, preferring instead to withdraw from negotiations.

The FTTN experience in no way alters the ACCC's conviction that its regulation of infrastructure does not stifle or chill investment. This conviction is supported by recent evidence of strong investment in Australian regulated infrastructure.

Taking energy for example, energy infrastructure investment since the implementation of the National Competition Policy has been remarkably high.

Annual investment in electricity networks is running at around $700 million in high voltage electricity transmission infrastructure and $3 billion in the local distribution networks. Across the networks, real investment is forecast to rise by around 40 per cent in the five years to 2007 - 08, driven largely by transmission network expansions and upgrades. Real transmission investment is forecast to rise by around 80 per cent over this period.

Strong investment is occurring in an environment in which the regulated revenues of network businesses are rising and network reliability is being maintained. The generation and transmission sectors have caused very few power outages since the NEM commenced.

There has also been significant investment in the gas industry. New gas basins and fields are being developed, often in conjunction with the construction of new transmission pipelines to ship gas to markets. For example, the development of Victoria's Otway Basin was followed by the construction of the SEA Gas Pipeline in 2004, which ships the gas to South Australian markets. Australia's gas transmission pipeline network has almost trebled in length since the early 1990s. Around $2.5 billion has been invested in new gas transmission pipelines and major expansions since 2000.

Timeliness, accountability & merit review

The final ongoing issue in Australian regulation is the need to ensure that regulatory decision making is timely, accountable and subject to appropriate review.

Statutory time guidelines - usually of six months - are increasingly being introduced for our regulatory decisions.  However, the effectiveness of these time guidelines will depend critically on whether regulated firms acknowledge and take steps to reduce:

• information asymmetry which can critically constrain a regulator's ability to make a decision in a timely manner; and
• ambit claims which reduce the speed of regulatory decisions.

A balance also needs to be struck between accountability in decision making (that is the ability to review a decision) and timeliness.  While it is important that decision makers are accountable, multiple levels of review can delay the decision making process for years.

The declaration of airside services at Sydney airport is the most spectacular example here.  This matter first began in August 2002 with a declaration recommendation in November 2003 followed by a Ministerial ruling in January 2004.  However, that ruling was reviewed by the Competition Tribunal with a decision in favour of declaration in December 2005.  That decision was appealed to the Federal Court with a decision rejecting the appeal in October 2006.

The ACCC subsequently arbitrated a dispute between Sydney Airport and an access seeker.  As it transpired the arbitration was dropped because of a commercial settlement. However if it had proceeded and one of the parties was unhappy with our ruling they could have had it reviewed by the Competition Tribunal.  Each of these steps is open to appeal by the Federal Court.

Where new evidence is admissible in reviews, the ACCC considers that such new evidence, or if circumstances show that past facts are no longer relevant, the decision should be returned to the regulator for consideration of the new material.

Reviews of regulatory decisions have been available via a range of models in Australia. For example, full merits review by the Tribunal is available for all declaration and undertaking decisions, and for proponent governments adversely affected by a certification decision. On the other hand, amendments to streamline the telecommunications access provisions in Part XIC (Telecommunications Access Regime) of the TPA mean that merits review is only available in relation to ACCC decisions on undertakings.

COAG has moved to streamline the review process by announcing that where merits review of regulatory decisions is provided for, the review will be limited to the information submitted to the regulator.  This is already a feature of merits review of some ACCC decisions relating to gas pipelines and telecommunications networks and tends to shorten the time taken by merits review.  Importantly, it prevents new evidence being considered after the decision is made and discourages forum shopping.

Case studies of sectoral challenges

Finally I turn to some of the specific challenges in four sectoral areas of Australian infrastructure regulation. The case studies outlined help to illustrate in a practical way some of the issues of good regulatory practice mentioned in the previous section.

Some of this country's most difficult issues are in transport, water is a new area of regulatory activity for the ACCC, energy regulation is emerging from an extensive reform process with an expectation of higher wholesale prices in the future and in communications the implications for regulation of a new fibre-based broadband network have to be considered.

Transport  

It is hardly surprising that some of the most critical issues in transport regulation revolve around the movement of coal and iron ore.

Logistics chains in the transportation of coal

Huge price increases in coal have put enormous pressure on the logistics chains involved in moving coal from mine to ship. In the year 2000, the price of Australian thermal coal exported to Asia had fallen to about US$25 per tonne. By February 2008 we were seeing reports of thermal coal prices at Newcastle quoted at US$125 a tonne. The Goonyella system in Queensland and the Hunter Valley system in New South Wales are large, complex logistics systems that represent a substantial proportion of Australia's coal export capacity. The separate ownership of mines, rail track, trains, and port facilities in these coal chains inevitably leads to coordination and capacity issues.

The ACCC has had a role in authorising coordinated efforts to manage congestion. The Trade Practices Act recognises that there are circumstances where conduct, such as agreement between competitors, may be anti-competitive but should, nevertheless, be allowed where it provides an overall public benefit. Businesses can lodge an application for authorisation with the ACCC seeking immunity from the operation of the Trade Practices Act for such arrangements.

Over the past four years the ACCC has considered a number of authorisation applications dealing with coal ship queue management at the Port of Newcastle and Dalrymple Bay. Authorisations have been timely responses to reduce the serious bottlenecks that were imposing costs on industry in the form of large demurrage costs.

Queue management systems aim to ration the amount of coal each producer and exporter can send through the port terminals in order to better match coal chain capacity. Without a queue management system, producers end up racing to try and capture as much capacity as they can, at the expense of other producers. The queue management system is designed to limit this race and so reduce demurrage costs that arise from an excessive queue, without reducing overall exports of coal.

However, these authorisations were originally put in place as a timely short term solution. In the longer term there is concern that such measures blunt incentives to expand capacity. When the financial pressures associated with demurrage costs are removed the incentive for participants in the coal chains to find a long-term solution to the capacity constraints are more muted. The ACCC has flagged these concerns to industry.

Access to Pilbara rail services

Access issues particularly regarding the Pilbara rail have received considerable media attention and the Pilbara case have been used as a cause celebre to call for regulatory reforms, specifically to the national access regime, Part IIIA of the Trade Practices Act.

Services provided by rail infrastructure in the Pilbara are currently the subject of declaration applications and associated appeals through the courts. If those services are ultimately declared for the purposes of access, then the parties can continue with commercial negotiations. It is only if those negotiations are unsuccessful and one of the parties requests the ACCC to arbitrate that dispute that the ACCC assumes a role.

The ACCC cannot prejudge the matters it may be called upon to arbitrate therefore I will not comment further on the specifics of the Pilbara case. I would though like to set right some of the misconceptions that have arisen in the course of these declarations and appeal process about what can and cannot occur under Part IIIA.

Public statements imply that declaration under Part IIIA allow access without sufficient recognition of the costs of the access provider. This is not correct. Part IIIA provides for the interests of access providers.

The ACCC must consider: the access provider's legitimate business interests; the economically efficient operation of the facility; and the safe and reliable operation of the facility. Also the ACCC may decide a price (or other terms) for access that means access is not commercially feasible for the access seeker. This has been done before in the case of Sydney Water when the ACCC had an arbitration role.

Public statements also imply that the threat of declaration under Part IIIA creates uncertainty about investments in infrastructure. However, Part IIIA provides for investors to manage uncertainty though providing an access undertaking to the ACCC. Access undertakings can be provided to the ACCC even after the service is declared and/or prior to the investment in the infrastructure being made.

This is not to deny that there is some scope for reform particularly on the issue of timing. Part IIIA can potentially be a 13 step process when all avenues of appeals are exercised. There is little doubt that the extensive appeal process can and is used to slow down the decision making process. If an appeal process is used for gaming, it is important to consider what changes could be made to keep gaming in check.

Water

The ACCC has most recently embarked on a major new area of activity with its involvement in the water sector. Our role here is quite complex and I will try to provide a high level overview of it today. From the outset though let me be clear that the ACCC does not have specific functions that directly relate to the supply of water in urban settings, either within our outside the Murray Darling Basin.

The Water Act 2007, which came into effect on 3 March 2008, builds on earlier reform initiatives while creating new institutional and governance arrangements to address the sustainability and management of water resources in the Murray-Darling Basin. Reforms include the removal of barriers to water trade to facilitate the operation of efficient water markets and provide opportunities for water trading.

As part of these reform initiatives the Act creates a number of new functions for the ACCC:

• advising the (yet to be formed) Murray-Darling Basin Authority on water trading rules as part of the Authority's development of the Basin Plan,
• advising the Minister on water market rules by December 2008. Water market rules are to free up the trade of water access rights and relate to the actions or inaction of irrigation infrastructure operators that prevent or unreasonably delay an individual from first transforming, their share of a group water access entitlement into a tradable water right, and then potentially trading this right.
• advising the Minister on water charge rules by June 2009. Water charge rules will ensure that fees and charges for similar products and services are set on a consistent and transparent basis across the Murray-Darling Basin. Water charge rules are ‘rules' that must be applied when determining the amount for regulated water charges and are to include:
• - bulk water charges (such as those levied by StateWater in NSW and Goulburn-Murray Water in Victoria).
• - fees and charges payable to an irrigation infrastructure operator in relation to access to the operator's irrigation network, including for terminating access, and
• - fees and charges levied to recover the cost of water planning and management activities, which are predominantly undertaken by governments.

The ACCC will also have a role in monitoring compliance with and enforcing the water market and charge rules.

Since the legislation was passed last year it has come to be understood that further enhancement of the ACCC role was required. On 3 July 2008, the Council of Australian Governments in an inter-governmental agreement strengthened the role of the ACCC in a number of areas including:

• Extending the application of water market and water charge rules to all entities that levy regulated water charges (including those outside the scope of the Commonwealth's powers). The aim is to enable a uniform approach to regulation and will require a referral from Basin States.
• Enabling the ACCC to make determinations or approvals of all regulated water charges and not just bulk water charges. This can be done through the Commonwealth's existing powers.
• Expanding the water market and water charge rules across the Basin States where states choose to opt in will ensure that the same regulatory framework is applied within and outside the Basin and assist where a single entity operates across the boundary of the Basin.

With these reforms the expectation is that water charges based on the full cost recovery for water services will contribute to achieving an economically efficient and sustainable use of water resources and water infrastructure assets. It water charge rules are applied consistently across the basin this should facilitate the efficient functioning of water markets by removing distortions to trade and by sending signals to water users about efficient investment in water infrastructure assets.

Putting this regulatory framework in place will be a very demanding agenda for the ACCC over the next year in a new (for the ACCC) and complex area of regulation.

Energy

The establishment in July 2005 of the Australian Energy Regulator (AER) was a major step in the reform cycle and part of the process of developing a single national regulatory framework. A single national energy regulator was necessary to reduce regulatory costs and uncertainty to business, and to allow both the gas and electricity markets to evolve within a consistent regulatory framework.

The AER is responsible for regulating the revenues associated with the non-contestable elements of the electricity transmission services provided by TNSPs in the national electricity market. The AER also has responsibility for monitoring the electricity wholesale market, including responsibility for monitoring and reporting on compliance and enforcing the National Electricity Law and the National Electricity Rules.

In 2008, the AER formally assumed responsibility for the economic regulation of electricity distribution from state regulators. This will begin with the determination of revenues and prices for NSW and ACT DNSPs for the 2009-14 period. The responsibility for gas transmission and gas distribution also transferred to the AER on 1 July 2008 with the enactment of the new National Gas Law and National Gas Rules.

As the national economic regulator of electricity distribution and transmission networks, the AER must exercise its functions in a way that is likely to promote efficient investment in and use of electricity services for the long term interests of consumers - taking into account such matters as price and reliability of supply. The approach is to determine a revenue/price cap for each network, based on what is necessary to cover efficient costs, while providing for a commercial return to the owner.

To date reforms have led to substantial new investment. The trend towards higher levels of network investment is driven by a range of factors:

• strong peak demand growth - such as the growing impact of air-conditioners over summer
• the replacement of ageing assets - many of these were deployed after WWII in the1950s and1960s, and
• shifting load locations and the need to accommodate new generation technologies and locations as the likely impact of carbon abatement policies are considered.

The strong growth in levels of network investment over the past few years, combined with even higher levels of projected spending in the immediate future, means that increased network charges will occur. This will be unavoidable given that distribution network costs comprise 40 percent of a typical customer bill (generation costs - 40 percent, transmission network costs - 10 percent, retail costs - 10 percent).

Reform and a stable, transparent approach to regulation has led to substantial new investments and as explained above this will lead to increased network charges for electricity. The ACCC/AER will have to help the community understand that prices increases reflect the need to expand and modernise networks. Without the projected investment demand may not be met and it may not be possible to ensure the level of reliability that the community has come to expect of the energy market.

Communications

A critical current activity in Communications is the Federal Government's proposal to provide up to $4.7 billion to facilitate the roll-out of a fibre-based broadband network, known as the National Broadband Network. Probity considerations mean that I cannot discuss the issues but can just relay to you the process that is in place and the ACCC's role in that process.

A panel of experts has been appointed by the Minister for Broadband, Communications and the Digital Economy, Senator Stephen Conroy to assess proposals to build the network, and recommend any necessary changes to the policy and legislative framework.

The ACCC has a role to play in proving ongoing advice and a detailed, independent, written report to the expert panel. The issues that the ACCC will have an advisory role on include pricing, competition and the effect that any proposed broadband network may have on the long term interests of end-users in the communications sector.

New technologies will shape the competitive environment by changing the economics of service provision and the way the companies compete.  The new regulatory structures that are put in place have to support not hinder any new competitive practices.

Assessing regulatory performance

Every year in July the ACCC holds a major conference on regulatory issues in infrastructure. The theme for this year's conference was revisiting the rationale for regulation. The question posed was not whether the ACCC (or other regulators) should be involved in economic regulation but to see where different trends are taking us.

The conference brings together leading international economists involved in regulation as well as Australian experts in this area. While it is not possible (of course) to bring together so many economists and achieve any type of precise agreement, the Convenor of the conference (and head of the ACCC Regulatory Division, Joe Dimasi) took away the following as a broad consensus:

• After a decade or more of regulatory experience in Australia and elsewhere enthusiasm for market based outcomes has not been diminished - an effectively functioning competitive market is the surest means of processing the complexity of information needed to achieve efficiency gains and growth.
• Where competitive markets are not available - in the case of monopoly infrastructure provision for example, some types of regulation may be required to create the possibility of competition in upstream or downstream markets
• In looking for insights about the means of regulation, regulatory economics has now developed a significant body of research - the theory of economic regulation does provide critical insights for the practice of regulation. Nevertheless the practice of regulation remains considerably more complicated than our theoretical models. Theory needs to be enriched by experience and context.
• In Australia we now have well over a decade of regulatory experience to call upon and enrich our theoretical understanding and it is clear that a certain stability has been achieved in the practice of regulation.
• Of course this is not to down play future challenges that regulators will continue to face as they attempt to find the ‘right' trade-offs.

Conclusion

For much of 2008, grocery and petrol prices have kept the ACCC on the front pages of most of Australia's newspapers. Away from the front pages our regulatory work is ongoing and processes are now well developed where regulatory frameworks are reviewed, modified and further developed in response to market needs and changing in technology.

John Martin was appointed as Commissioner of the Australian Competition and Consumer Commission (ACCC) in June 1999 with special responsibilities for small business related matters. He is Chairman of the Commission's Transport Committee, a member of the Enforcement and Adjudication Committees and is responsible for health-related issues. Mr Martin is also the Chairman of the International Air Services Commission. Mr Martin was Executive Director of the Australian Chamber of Commerce and Industry from 1989 until his appointment to the ACCC. Mr Martin was a member of the Board of Standards Australia for over 5 years and represented Australia on the Business and Industry Advisory Committee (BIAC) to the OECD.

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John Martin was a keynote speaker at the GAP Congress on Regulatory Affairs, held in Parliament House of Victoria on 26 September 2008 in Melbourne.

To read keynote presentations by other speakers, go to our 'Regulation as a Business Opportunity' discussion forum.