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Australian Senate Standing Committee for the Scrutiny of Bills - Scrutiny Digests |
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Purpose
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This bill seeks to establish a national framework to address the adverse
impacts of air pollution from certain products on human and
environmental
health
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Portfolio
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Environment and Energy
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Introduced
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House of Representatives on 10 August 2017
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Bill status
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Before House of Representatives
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Scrutiny principles
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Standing Order 24(1)(a)(i), (iv) and (v)
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2.81 The committee dealt with this bill in Scrutiny Digest No. 9 of 2017. The Minister responded to the committee's comments in a letter received 4 September 2017. Set out below are extracts from the committee's initial scrutiny of the bill and the Minister's response followed by the committee's comments on the response. A copy of the letter is available on the committee's website.[47]
Initial scrutiny – extract
2.82 The bill seeks to regulate emissions from certain products by setting national emissions standards. It seeks to do so by providing that rules (delegated legislation) may prescribe a product as an emissions-controlled product. The rules may also provide for an emissions-controlled product to be certified. The bill makes it an offence to import or supply an uncertified or unmarked emissions-controlled product.[49] The explanatory memorandum states that prescribing a product as an emissions-controlled product 'has the effect of triggering the key requirements in the Bill'[50] and certification, which is also left to the rules, 'is a key concept in the Bill, and underpins its operation, including the offence and civil penalty provisions'.[51]
2.83 The committee's view is that significant matters should be included in primary legislation unless a sound justification for the use of delegated legislation is provided. In this instance, the matters to be set out in the rules are central to the emissions standards framework being established. The explanatory memorandum states that 'it is anticipated' that the first emissions-controlled products to be prescribed will be non-road spark ignition engines and equipment.[52] However, the substantive clauses of the bill do not set out any basis as to what products will be prescribed as being emissions-controlled and required to be certified. It also provides no detail as to the process by which a product will be certified, the process by which certain products will be exempted and what decisions regarding the certification process will be subject to merits review. In addition, a broad power to disclose information obtained under the Act is proposed to be granted to any 'agency, body or person' as prescribed by the rules.[53]
2.84 Clause 51 sets out the power for the Minister to makes the rules, and also provides that the rules may provide for charging fees for services and the review of decisions made under the bill. The explanatory memorandum explains why these matters are to be set out in the rules rather than the primary legislation:
Because the Bill establishes a framework which enables different classes of emissions-controlled products to be prescribed in the future and the details applying to future products would vary, it is necessary and appropriate for the rules rather than the Bill to prescribe what products are emissions-controlled products and the processes that relate to their certification (including the emissions standards that must be satisfied), the fees associated with the certification process and what decisions are subject to review.[54]
2.85 The committee appreciates that the detail of future products that may need to be classified as emissions-controlled products will vary over time and as such the specific classes of products to be subject to the new framework may be more appropriately prescribed in delegated legislation. However, it is not clear why there is no detail in the primary legislation as to the type of products that may be prescribed, the process for certification and exemptions from certification and the applicability of merits review for decisions made under this regulatory scheme.
2.86 The committee also notes that these significant matters are to be included in 'rules' rather than in 'regulations'. The issue of the appropriateness of providing for significant matters in legislative rules (as distinct from regulations) is discussed in the committee's First Report of 2015.[55] In relation to this matter, the committee has noted that regulations are subject to a higher level of executive scrutiny than other instruments as regulations must be approved by the Federal Executive Council and must also be drafted by the Office of Parliamentary Counsel (OPC). Therefore, if significant matters are to be provided for in delegated legislation (rather than primary legislation) the committee considers they should at least be provided for in regulations, rather than other forms of delegated legislation which are subject to a lower level of executive scrutiny.[56]
2.87 In addition, where the Parliament delegates its legislative power in relation to significant regulatory schemes the committee considers that it is appropriate that specific consultation obligations (beyond those in section 17 of the Legislation Act 2003) are included in the bill and that compliance with these obligations is a condition of the validity of the legislative instrument. While subclause 51(6) provides that consultation must be undertaken with the Information Commissioner before rules are made regarding the persons to whom information can be disclosed, no other specific consultation obligations are included in the bill. The committee notes that section 17 of the Legislation Act 2003 sets out the consultation to be undertaken before making a legislative instrument. However, section 17 does not strictly require that consultation be undertaken before an instrument is made. Rather, it requires that a rule-maker is satisfied that any consultation, that he or she thinks is appropriate, is undertaken. In the event that a rule maker does not think consultation is appropriate, there is no requirement that consultation be undertaken. In addition, the Legislation Act 2003 provides that consultation may not be undertaken if a rule-maker considers it to be unnecessary or inappropriate; and the fact that consultation does not occur cannot affect the validity or enforceability of an instrument.[57]
2.88 The committee's view is that significant matters, such as the core elements of the new emissions standards framework, should be included in primary legislation unless a sound justification for the use of delegated legislation is provided. In this regard, the committee requests the Minister's detailed advice as to:
• why it is considered necessary and appropriate to leave most of the elements of this new scheme to delegated legislation;
• if significant matters are to be included in delegated legislation, why it is appropriate to include these in rules rather than regulations;
• why the bill only provides that the rules 'may' provide for the review of decisions under the Act, rather than the bill stating that decisions made regarding the certification of an emissions-controlled product, the granting of exemptions relating to those products, and the imposition of fees for service will be subject to merits review; and
• the type of consultation that it is envisaged will be conducted prior to the making of the rules and whether specific consultation obligations (beyond those in section 17 of the Legislation Act 2003) can be included in the legislation (with compliance with such obligations a condition of the validity of the legislative instrument).
Minister's response
2.89 The Minister advised:
(a) The Committee has requested advice as to why it is considered necessary and appropriate to leave most of the elements of this new scheme to delegated legislation
As the Bill is a framework bill, rules made for the purposes of the Bill will determine the products that are to be regulated under the framework and how those products are to be regulated.
The capacity to prescribe elements of the emissions standard framework in rules is consistent with good regulatory practice, particularly where there is a high level of scientific and technical detail that underpins the legislative scheme. Using rules enables flexibility and adaptability in an area where there are frequent scientific developments and advancement in relation to products, emissions standards, certification testing requirements and the risks to human health and the environment.
The extent and technical complexity of the information needed to set out what certification is required or recognised for each type of product means that these matters are better dealt with in rules rather than the Act. This also enables regular updating as new products are released, emissions standards are updated and foreign certification schemes change.
The ability to prescribe these matters in rules made for the purposes of the Bill avoids the need for product-specific legislation and promotes a consistent approach to matters such as reporting, compliance and enforcement.
(b) The Committee has requested advice as to whether, if significant matters are to be included in delegated legislation, why it is appropriate to include these in rules rather than regulations
The Bill enables rules to be made which will specify the types of products to be regulated under the framework and how those products are to be regulated. Specifying these matters in rules rather than regulations accords with the Office of Parliamentary Counsel's Drafting Direction
No. 3.8 – Subordinate Legislation. Paragraph 2 of that Drafting Direction states that "OPC's starting point is that subordinate instruments should be made in the form of legislative instruments (as distinct from regulations) unless there is good reason not to do so".
Consistent with paragraph 16 of the Drafting Direction, the approach of including the elements of the new emissions standards framework in rules (rather than regulations) has a number of advantages including:
(a) it facilitates the use of a single type of legislative instrument being needed for the Bill, thereby reducing the complexity otherwise imposed on the regulated community if these matters were to be prescribed across a number of different types of instruments;
(b) it simplifies the language and structure of the provisions in the Bill that provide the authority for the legislative instruments; and
(c) it shortens the Bill.
Due to these advantages, paragraph 17 of the Drafting Direction states that drafters should adopt this approach where appropriate with new Acts.
Paragraph 3 of the Drafting Direction states that matters such as compliance and enforcement, the imposition of taxes, setting amounts to be appropriated, and amendments to the text of an Act, should be included in regulations unless there is a strong justification otherwise. The Bill does not enable the rules to provide for any of the types of matters listed. This is clarified by clause 51(5) of the Bill, which specifically prevents the rules from including these types of matters. As rules made under the Bill cannot provide for these types of matters, it is appropriate that the elements of the emissions standards framework be prescribed in rules rather than regulations.
In addition, clause 51 clarifies that the rules made under the Bill are a legislative instrument for the purposes of the Legislation Act 2003. Pursuant to sections 38 and 39 of that Act, all legislative instruments and their explanatory statements must be tabled in both Houses of the Parliament within 6 sitting days of the date of registration of the instrument on the Federal Register of Legislation. Once tabled, the rules will be subject to the same level of Parliamentary scrutiny as regulations (including consideration by the Senate Standing Committee on Regulations and Ordinances), and a motion to disallow the rules may be moved in either House of the Parliament within 15 sitting days of the date the rules are tabled (see section 42 of the Legislation Act 2003).
(c) The Committee has requested advice as to why the Bill only provides that the rules 'may' provide for the review of decisions under the Act, rather than the Bill stating that decisions made regarding the certification of an emissions-controlled product, the granting of exemptions relating to those products, and the imposition of fees for service will be subject to merits review
As stated above, the Bill creates a framework for the regulation of emissions from products. The manner in which those products are to be regulated will be specified in the rules.
It is appropriate that the Bill provides that the rules 'may' and not 'must' make provision for the merits review of certain decisions because decisions pertaining to particular types of emissions-controlled products may not apply to others. This will in tum inform what decisions contained in the rules would be subject to merits review. For example, the first rules made under the framework will be for non-road spark ignition engines and equipment (NRSIEE). It is anticipated that the rules for these products will establish an Australian certification process, including merits review for decisions to certify, or refuse to certify, products. However, future emissions-controlled products regulated under the framework may not require an Australian certification process. In this instance, it would not be possible to specify that decisions to certify products will be subject to merits review. Therefore the use of 'may' provides the necessary flexibility to adapt the rules to the manner in which each particular emissions controlled product is to be regulated.
The use of 'may' in this context is consistent with other powers in the Bill to prescribe matters in the rules. For example, clause 9 of the Bill provides that the rules may prescribe a product as an emissions-controlled product, and clause 20 provides that the rules may require a person who imports or supplies emissions-controlled products to make and keep records in relation to the imports or supplies. It is also consistent with the standard form of legislative instrument-making provisions as set out in the Office of Parliamentary Counsel's Drafting Direction No. 3.8 – Subordinate Legislation (see, for example, paragraph 12 of that Drafting Direction). The use of 'may' ensures that the Minister's rule making power in clause 51 is not fettered and that the Bill does not pre-empt future Ministerial decisions on the content of the rules.
Clause 51 clarifies that the rules made under the Bill are a legislative instrument for the purposes of the Legislation Act 2003. Once tabled, the rules will be subject to scrutiny by the Senate Standing Committee on Regulations and Ordinances. Amongst other things, the Committee examines each instrument to ensure "that it does not make the rights and liberties of citizens unduly dependent on administrative decisions which are not subject to review of their merits by a judicial or other independent tribunal". This scrutiny will also ensure that administrative decisions made under rules are subject to an appropriate level of review.
(d) The Committee has requested advice regarding the type of consultation that it is envisaged will be conducted prior to the making of the rules and whether specific consultation obligations (beyond those in section 17 of the Legislation Act 2003) can be included in the legislation (with compliance with such obligations a condition of the validity of the legislative instrument)
The Australian Government Guide to Regulation requires every policy proposal designed to introduce or abolish regulation to be accompanied by a Regulation Impact Statement (RIS). This ensures that every policy option is carefully assessed, its likely impacts costed and a range of viable alternatives considered in a transparent and accountable manner. The Australian Government Guide to Regulation defines regulation as 'any rule endorsed by government where there is an expectation of compliance'.
As stated above, rules made under clause 51 of the Bill will specify the types of products to be regulated under the framework and how those products are to be regulated. As the rules determine how emissions-controlled products are to be regulated, there is an expectation of compliance associated with the rules. Therefore, before the rules can be made, the policy options available to regulate an emissions-controlled product will be informed through the development of a RIS.
The Australian Government Guide to Regulation requires policy makers to consult in a genuine and timely way with affected businesses, community organisations and individuals. ARIS will need to demonstrate that appropriate consultation has been undertaken.
It is anticipated that the first emissions-controlled products to be regulated under the Bill are NRSIEE. Extensive stakeholder consultation with affected industry bodies and other Commonwealth agencies has been undertaken to inform the development of these rules through the preparation of the RIS for NRSIEE (available at http://ris.pmc.gov.au/2016/05/12/reducingemissions- small-engines).
The main Australian industry bodies that represent the recreational marine engine and powered outdoor equipment sectors support the regulation of NRSIEE through emissions standards. Initial consultation was undertaken as part of the Consultation RIS, released in May 2010. In 2012, additional consultation was undertaken and clarification sought on issues that were raised during the 2010 consultation period. Since 2012 leading up to the introduction of the Bill in August 2017, there has been ongoing consumer groups and some major retailers/suppliers, for example, through correspondence and briefing sessions. It is also intended that affected industry stakeholders will be provided with an opportunity to comment on the draft rules before they are made, including through the release of an exposure draft of the rule and a subsequent meeting with industry representatives.
Due to the extensive consultation that has occurred to date, the intention to release an exposure draft of the rules and the consultation requirements as part of the development of a RIS, it was not considered necessary to specify particular consultation requirements for the making of the rules in the Bill.
Committee comment
2.90 The committee thanks the Minister for this response. The committee notes the Minister's advice that the bill is a framework bill and avoids the need for product-specific legislation, and the extent and technical complexity of the information needed to set out the certification required or recognised for each type of product means the matter is better dealt with in the rules (delegated legislation), rather than the Act. The committee also notes the Minister's advice that these are being provided in rules rather than regulations as this accords with the Office of Parliamentary Counsel's Drafting Direction No. 3.8. The committee also notes the Minister's advice that the bill only provides that the rules 'may' and not 'must' make provision for the merits review of certain decisions because some products regulated under the framework may not require an Australian certification process and so it would not be possible that decisions to certify products will be subject to merits review. The committee notes the advice that the use of 'may' ensures that the Minister's rule-making power in clause 51 is not fettered and does not pre-empt future Ministerial decisions on the content of the rules. The committee also notes the advice that extensive stakeholder consultation with affected industry bodies and other Commonwealth agencies has been undertaken in relation to the development of the initial set of rules expected to be prescribed under this power, and the Australian Government Guide to Regulation requires policy makers to consult in a genuine and timely way.
2.91 The committee takes this opportunity to reiterate its long-standing scrutiny concerns about 'framework bills' which primarily contain only broad principles of a legislative scheme and rely heavily on delegated legislation to determine the scope and operation of the scheme. The committee has regularly highlighted instances in which primary legislation may excessively rely on delegated legislation for its operation.[58] In this instance, the rules referred to by the Minister have not been made available to the committee for its consideration. The committee appreciates that the detail of future products that may need to be classified as emissions-controlled products will vary over time and, as such, the specific classes of products to be subject to the new framework may be more appropriately prescribed in delegated legislation. However, the committee notes there is no detail in the primary legislation as to the type or classes of products that may be prescribed, the process for certification and exemptions from certification and the applicability of merits review for decisions made under this regulatory scheme.
2.92 The committee is also concerned that the rule-making power in clause 51 may provide too much flexibility and unfettered power to the Minister in relation to deciding whether a matter should be subject to merits review. While the committee appreciates that there may be different processes applicable depending on the product that the rules relate to, some of which may not require certification, the committee considers it would be possible for the bill to be drafted in such a way as to ensure that any relevant decision would be subject to merits review. The committee also notes that while extensive consultation may have been undertaken in relation to the initial set of rules to be made if the bill becomes an Act, there is no requirement that such consultation be undertaken in the future.
2.93 The committee draws its scrutiny concerns to the attention of Senators and leaves to the Senate as a whole the appropriateness of leaving core elements of the new emissions standards framework to delegated legislation.
2.94 The committee also draws this matter to the attention of the Senate Standing Committee on Regulations and Ordinances for information.
Initial scrutiny – extract
2.95 Clause 33(1) proposes to make it an offence to engage in certain conduct. Subclause 33(2) provides an exception (offence specific defence) to this offence, stating that the offence does not apply if the person engages in the conduct in accordance with a direction given to the person by the Minister. The offence carries a maximum penalty of 6 months imprisonment.
2.96 Subsection 13.3(3) of the Criminal Code Act 1995 provides that a defendant who wishes to rely on any exception, exemption, excuse, qualification or justification bears an evidential burden in relation to that matter.
2.97 At common law, it is ordinarily the duty of the prosecution to prove all elements of an offence. This is an important aspect of the right to be presumed innocent until proven guilty. Provisions that reverse the burden of proof and require a defendant to disprove, or raise evidence to disprove, one or more elements of an offence, interferes with this common law right.
2.98 While in this instance the defendant bears an evidential burden (requiring the defendant to raise evidence about the matter), rather than a legal burden (requiring the defendant to positively prove the matter), the committee expects any such reversal of the evidential burden of proof to be justified.
2.99 In this case, the explanatory memorandum states that reversal of the burden of proof is appropriate here 'as the manner of the person's conduct are within the knowledge of that person'.[60] In addition, the statement of compatibility states:
The reversal is justified in this instance, as the matter to be proved (namely that the person's conduct was in accordance with a direction give to the person by the Minister) is a matter that would be in the particular knowledge of the defendant. It is expected that it would not be unreasonably difficult for the defendant to discharge the evidentiary burden in this circumstance.[61]
2.100 The committee notes that the Guide to Framing Commonwealth Offences[62] provides that a matter should only be included in an offence-specific defence (as opposed to being specified as an element of the offence), where:
• it is peculiarly within the knowledge of the defendant; and
• it would be significantly more difficult and costly for the prosecution to disprove than for the defendant to establish the matter.[63]
2.101 In this case, it is not apparent that whether a person engages in conduct in accordance with a direction given to the person by the Minister is one that is peculiarly within the defendant's knowledge, or that it would be significantly more difficult or costly for the prosecution to establish the matters. It would appear that whether the Minister has issued a direction for a person to engage in specified conduct would be a matter that the Minister (and therefore the prosecution) would be particularly apprised of. The committee considers that this matter appears to be one that would be more appropriate to be included as an element of the offence, rather than as a defence.
2.102 The committee requests the Minister's detailed justification as to the appropriateness of including the specified matter as an offence-specific defence. The committee suggests that it may be appropriate if clause 33(1) were amended to add an additional paragraph providing that a person will commit the offence if the Minister has not given a direction to the person to engage in that conduct (and the defence at subclause 33(2) were removed). The committee also requests the Minister's advice in relation to this matter.
Minister's response
2.103 The Minister advised:
Subclause 33(1) of the Bill makes it an offence for a person to engage in conduct which causes an emissions-controlled product that is the subject of a forfeiture notice under subclause 32(2) to be moved, altered or interfered with. Subclause 33(2) provides that subclause 33(1) does not apply if the person engages in conduct in accordance with the direction given to the person by the Minister. The note to subclause 33(2) directs readers to subsection 13.3(3) of the Criminal Code which provides that a defendant who wishes to rely on any exception, exemption, excuse, qualification or justification provided by the law creating an offence bears an evidential burden in relation to that matter.
An evidential burden of proof requires a defendant to adduce or point to evidence which suggests there is a reasonable possibility that the defence is made out (section 13.6 of the Criminal Code). If the defendant meets the standard of proof required, the prosecution then has to refute the defence beyond reasonable doubt (section 13.1 of the Criminal Code).
The Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers provides that an evidential burden is easier for a defendant to discharge, and does not completely displace the prosecutor's burden (only defers that burden). Thus as a general rule, the default position in section 13.3 of the Criminal Code should apply and the defendant should bear an evidential burden for an offence-specific defence, unless there are good reasons to depart from this position.[64]
Framing this as a defence has the effect of requiring the defendant to put forward adequate evidence that their conduct, which caused an emissions-controlled product that is the subject of a forfeiture notice, to be moved, altered or interfered with, was in accordance with a direction given by the Minister. It would then be for the prosecution to refute that evidence beyond reasonable doubt. This does not place the defendant in a position in which he or she would find it difficult to produce the information needed to suggest there is a reasonable possibility that the defence is made out. It is peculiarly within the knowledge of the defendant whether their conduct was in accordance with a direction given by the Minister. It would be relatively easy for the defendant to raise evidence of this, whereas it would be significantly more difficult and costly for the prosecution to establish that the defendant's conduct was not in accordance with that direction.
For the reasons outlined above, it is appropriate and consistent with the provisions of the Criminal Code and the Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers that the evidential burden of proof be imposed on a defendant seeking to prove the existence of the defence. As this is the case, it is not necessary to amend clause 33 of the Bill to add an additional paragraph as suggested by the Committee.
Committee comment
2.104 The committee thanks the Minister for this response. The committee notes the Minister's advice that requiring a defendant to put forward adequate evidence that their conduct was in accordance with a direction by the Minister would not place the defendant in a position of difficulty, that it is a matter peculiarly within the knowledge of the defendant and it would be relatively easy for the defendant to raise evidence of this whereas it would be significantly more difficult and costly for the prosecution to establish that the defendant's conduct was not in accordance with that direction.
2.105 The committee also notes the Minister's statement that the Guide to Framing Commonwealth Offences[65] provides that an evidential burden is easier for the defendant to discharge and that as a general rule the default position in section 13.3 of the Criminal Code should apply and the defendant should bear an evidential burden of proof for an offence-specific defence, unless there are good reasons to depart from this. The committee notes that the Guide to Framing Commonwealth Offences is, in this instance, noting that it is preferable to apply an evidential burden of proof rather than a legal burden of proof and does not provide a justification for including a matter as an offence-specific defence. The committee reiterates that the Guide provides that a matter should only be included as an offence-specific defence (as opposed to being specified as an element of the offence), where:
• it is peculiarly within the knowledge of the defendant; and
• it would be significantly more difficult and costly for the prosecution to disprove than for the defendant to establish the matter.[66]
2.106 The committee notes that the Minister's response does not explain why it would be significantly more difficult and costly for the prosecution to establish that the defendant's conduct was not in accordance with a Ministerial direction, given it would be within the prosecution's knowledge as to whether the Minister has issued a direction for a person to engage in specified conduct. The committee also notes that the advice does not explain how such a matter would be peculiarly within the defendant's knowledge. The committee appreciates it may be relatively easy for the defendant to raise evidence as to whether their conduct was in accordance with a Ministerial direction. However, the committee reiterates that at common law, it is ordinarily the duty of the prosecution to prove all elements of an offence. This is an important aspect of the right to be presumed innocent until proven guilty. Provisions that reverse the burden of proof and require a defendant to raise evidence to disprove one or more elements of an offence, interferes with this common law right, and the burden should not be reversed simply on the basis of the ease by which a defendant may raise evidence.
2.107 In order to address the committee's scrutiny concerns outlined above, the committee considers it would be appropriate for subclause 33(1) to be amended to add an additional element providing that a person will commit the offence if the Minister has not given a direction to the person to engage in that conduct (and the defence at subclause 33(2) is removed).
2.108 The committee draws its scrutiny concerns to the attention of Senators and leaves to the Senate as a whole the appropriateness of reversing the evidential burden of proof in relation to a matter that does not appear to be peculiarly within the defendant's knowledge or significantly more costly for the prosecution to disprove.
[47] See correspondence relating to Scrutiny Digest No. 10 of 2017 available at: www.aph.gov.au/senate_scrutiny_digest.
[48] Clauses 9, 10, 11, 20, 22, 43 and 51. The committee draws Senators' attention to these provisions pursuant to principles 1(a)(iv) and (v) of the committee's terms of reference.
[49] Clauses 13-16.
[50] Explanatory memorandum, p. 16.
[51] Explanatory memorandum, p. 17.
[52] Explanatory memorandum, p. 2.
[53] See paragraph 43(1)(b).
[54] Explanatory memorandum, p. 43.
[55] Senate Standing Committee for the Scrutiny of Bills, First Report of 2015, 11 February 2015, pp 21–35.
[56] See also Senate Standing Committee on Regulations and Ordinances, Delegated Legislation Monitor No. 17 of 2014, 3 December 2014, pp 6–24.
[57] See sections 18 and 19 of the Legislation Act 2003.
[58] See Senate Standing Committee for the Scrutiny of Bills, Inquiry into the future role and direction of the Senate Scrutiny of Bills Committee, Final Report, May 2012, pp 33–36.
[59] Subclause 33(2). The committee draws Senators' attention to this provision pursuant to principle 1(a)(i) of the committee's terms of reference.
[60] Explanatory memorandum, p. 35.
[61] Statement of compatibility, p. 10.
[62] Attorney-General's Department, A Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers, September 2011, pp 50–52.
[63] Attorney-General's Department, A Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers, September 2011, p. 50.
[64] Attorney-General's Department, A Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers, September 2011, p. 52.
[65] Attorney-General's Department, A Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers, September 2011, p. 52.
[66] Attorney-General's Department, A Guide to Framing Commonwealth Offences, Infringement Notices and Enforcement Powers, September 2011, p. 50.
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