Chapter 3
Discussion of key issues
3.1
Many community groups and individuals supported the bill and believed
that the additional requirements for carriers to consult more widely would result
in better community consultation and improved rollout of telecommunications
infrastructure.[1]
3.2
The bill's requirement for regular independent reviews of
electromagnetic energy (EME) was also strongly supported by community groups
and individuals.[2]
The application of the precautionary principle to EME was seen by these groups
as an important safeguard against any potential health issues caused by
non-ionising radiation of the type associated with mobile telecommunications.
3.3
The bill was opposed by telecommunication carriers and their industry
representatives.[3]
According to these groups the bill would only serve to duplicate consultation
requirements that are already imposed on carriers in existing codes and
legislation. They argued the bill would also impose significant costs on
carriers and would delay the rollout and repair of telecommunications
infrastructure.
3.4
It was suggested by telecommunications carriers and the Department of
Broadband, Communications and the Digital Economy (DBCDE) alike that the bill
may have unintended consequences relating to the deployment and maintenance of telecommunications
infrastructure, such as emergency communications facilities, simple maintenance
issues and state and territory planning legislation.
3.5
As part of this inquiry many individuals and community groups raised
concerns about individual telecommunications installations occurring in their
area. The committee would like to reiterate that it is not the committee's role
to investigate or pursue individual cases.
3.6
As mentioned in Chapter 2, this chapter discusses key issues raised during
the course of the inquiry, namely the requirement of carriers to notify and consult
with landowners and community groups and the issue of EME. The chapter also
examines potential costs and unintended consequences associated with the bill.
Notification, consultation and the complaints process
Notification
3.7
The bill seeks to impose additional requirements on carriers to notify
land owners and communities of proposed installation or maintenance of telecommunications
infrastructure. The bill would provide for changes to the current Ministerial
Code of Practice so that telecommunication carriers must:
- notify and consult with owners and occupiers of land within 500
metres of any facility that will emit electromagnetic radiation; and
- provide full disclosure plans for the facility being installed
(including cumulative electromagnetic emission reports and the likelihood of
co-locations and upgrades) and the reasons for the selection of the site. [4]
3.8
The bill would also increase from 10 business days to 30 business days the
time at which a carrier must give notice to owners and occupiers of the
carrier's intention to conduct work.[5]
3.9
There was widespread support from individuals and community
organisations for these provisions in the bill.[6]
It was felt that at present there is an overall lack of community power and too
much control residing with the telecommunications carriers. The Worried
Householders Action Against Tower group (WHAAT!) asked:
...that the Telecommunications Act be amended to allow
citizens to live safely in their homes, without the fear of Telecommunications
companies sitting in an office, looking at a map and deciding the highest point
in a town and deciding that spot is the best for their business, so they will
forge forward, no matter what objection is raised by residents or agencies. If
Telecommunications companies want to build, the wellbeing of the citizens must
be paramount and residents must be consulted.[7]
3.10
The extension to the timeframe for notification was welcomed by a number
of submitters who felt that 10 business days did not provide sufficient time
for individuals and communities to organise themselves to discuss carriers'
intentions. WHAAT! informed the committee that:
Such a short notice time to reply is blatantly unfair. It
takes time for residents surrounding the proposed site, who in many cases do
not know each other, to even call a meeting to discuss the way forward.[8]
3.11
Mrs Anthea Hopkins similarly argued that:
The existing 10 day response period provided to communities
is highly inadequate and is not nearly long enough to allow the community to
provide an informed response...Anything shorter [than the 30 days] will
unfairly disadvantage community members and not be representative of a genuine
effort to consider community consultation. A shorter period would particularly
disadvantage those in isolated locations, the elderly, those with disabilities,
health issues or those who need to access translation services.[9]
3.12
Community groups also wanted to ensure that their concerns are heard
from the very beginning of the planning and development process. Ms Sue Hetherington
of WHAAT! described an example where despite a carrier undertaking planning for
two years, the community was only notified of the installation of a telecommunications
facility 10 days prior to the installation commencing (as per the current requirements).[10]
3.13
These provisions in the bill were opposed by carriers and the Australian
Mobile Telecommunications Association (AMTA) on the basis they would duplicate existing
requirements, increase costs and make maintenance work extremely difficult.[11]
3.14
AMTA submitted that the telecommunications industry has 'adequately
demonstrated its willingness to notify properties in the surrounding area
pursuant to the provisions of the Industry Code for Deployment of Mobile Phone
Network Infrastructure'.[12]
3.15
The industry code, developed by the industry with input from community
groups and local government, requires carriers to provide at least 10 business
days notice for community consultation: AMTA emphasised that this is consistent
with local government development application notice periods.[13]
3.16
According to AMTA, a 30 day notification period for some projects might
be feasible.[14]
However, AMTA was of the opinion that for most projects the imposition of a
lengthy notification period would 'materially obstruct the carrier's ability to
respond to customer demand and carry out standard network maintenance'.[15]
AMTA noted that:
Scheduling these activities around weather, project
readiness, and staff and equipment availability is a considerable logistical
challenge, and an increased notification period will substantially impede this
ability.[16]
3.17
AMTA further informed the committee that the revised industry code will
extend the notification period from 10 business days to 15 business days.[17]
3.18
Carriers and AMTA were also opposed to the proposed requirement for
notification to be given to owners and occupiers within a 500 metre radius of an
installation. It was suggested by AMTA that:
The logistics and costs associated with indentifying all
owners and occupiers within 500m is a very difficult task requiring (but not
limited to) searching council records (where this is not restricted) and
undertaking a formal Title Search. These activities would place a significant
administrative burden on State Titles officers (where this is not automated)
and Councils.[18]
3.19
Telstra echoed these concerns and informed the committee that it
undertakes approximately 10 000 maintenance activities every year.[19]
Under the bill the number of individual notices required could increase to
400 000 notices annually (based on there being 40 owners/occupiers within
the 500 metre radius).[20]
Telstra estimated that at a cost of $250 to prepare and send each individual
notice, the additional notices required could cost the company $100 million
annually.[21]
3.20
Similarly, AMTA quoted a Deloitte Access Economics report estimating
that the additional annual costs resulting from the bill for maintenance
activities could reach $1.42 billion dollars per annum.[22]
3.21
Telstra also raised concerns that the bill would require notifications
to be issued for all maintenance activities and all low-impact facility
installations which relate to radiocommunications infrastructure. Telstra stated
that 'the range of activities caught by the new notification requirements in
the bill is very broad and extends beyond facilities which themselves emit
EME'.[23]
Telstra believed the new provisions would require notification to be given for
upgrading old technology antennae, reinforcing lattice towers damaged by
corrosion, lifecycle replacement of batteries and feeder cabling, and
like-for-like "swap-outs" of towers.[24]
3.22
DBCDE advised the committee that the bill's provisions for increased
notification could result in delays for infrastructure rollouts and maintenance
in emergencies.[25]
The provisions may also limit a carrier's ability to provide reliable services
thus impacting on their ability to carry out other statutory requirements, such
as the Customer Service Guarantee.[26]
Consultation
3.23
The bill seeks to require carriers to consult with owners and occupiers
of land within 500 metres of any facility that will emit EME.[27]
3.24
The Tower Action Group submitted that:
At present, it would seem that community consultation is only
undertaken as a last resort, well after leases have been signed, locations
chosen and decision essentially made; consultation is presently seen by
carriers as just 'one box to be ticked' rather than as a way of actively
dealing with and listening to the concerns of local communities....We believe
that community consultation is essential in the siting of telecommunications
facility [sic], especially at sites close to, or potentially close to,
community sensitive sites.[28]
3.25
Mrs Anthea Hopkins was similarly concerned that at present community
concerns are not always listened to:
Objections received by carriers, from the community or from
councils, carry no weight and the carrier has no obligation (not even under the
revised ACIF Code) to alter their plans in any way in response. Proper
consultation should mean, that not only are communities properly notified and
informed about proposals, and given the opportunity to respond, but that their
responses have some weight in the consultation process, and must be properly
addressed by carriers.[29]
3.26
In response to claims such as these, AMTA opined that the current ACIF industry
code and the revised edition currently awaiting approval from the Australian
Communications and Media Authority (ACMA), provides an adequate framework for
community consultation.[30]
AMTA stated that 'the level of carrier activity associated with the Code
consultation processes and provision of information is significant.[31]
3.27
AMTA estimated that on average 89 stakeholders were notified for each new
telecommunications infrastructure site as part of the consultation process set
out in section 5.5 of the industry code. AMTA asserted that this level of
consultation compares favourably with council development application processes
which consult on average 18 stakeholders.[32]
Complaints process
3.28
The bill proposes to amend the Ministerial Code of Practice to include a
complaints process whereby owners and occupiers of land within 500 metres of a
facility that will emit EME can make a complaint to the ACMA in relation to any
or all of the following:
- the location of the facility; or
- compliance with the ministerial code; or
- compliance with any relevant industry standard.
3.29
Any work relating to the installation of the facility would be suspended
until a complaint is resolved.
3.30
Some submitters to the inquiry argued that the existing complaints
resolution process is deficient.[33]
These submitters were particularly concerned that, in their view, the
complaints process favours carriers over individuals and communities.
Mr Ian Bullock of the Tower Action Group claimed:
Complainants, as we have heard, are made to jump through many
hoops just to get a complaint formally recognised and then carriers simply
provide their evidence and correct their mistakes. This is deemed acceptable.
There is no interrogation of their evidence—it is just accepted as true and
accurate—and, worse, complainants are then told that there will be no investigation
as carriers have supposedly fulfilled their code obligations. How anyone can
deem this as acceptable is, for us, simply beyond comprehension.[34]
3.31
On this basis, there was strong support from community groups for the complaints
process proposed in the bill.[35]
3.32
By contrast, the Communications Alliance argued that the industry code
had reduced the number of complaints made to the ACMA and was therefore an
effective mechanism by which to regulate the installation of telecommunications
infrastructure.[36]
3.33
The ACMA provided the following explanation of the existing complaints
process:
There is a complaints process that is established by the
Telecommunications Act so that people can make complaints to the ACMA. The ACMA
can consider the complaint...The ACMA can make preliminary inquiries. As a
result of those preliminary inquires or simply considering it, they decide
whether to investigate the complaint. We have received complaints that, in
relation to the matters that the ACMA is responsible for, have not been within
our jurisdiction or the scope of the Telecommunications Act. In that case, the
complaint is resolved by the ACMA saying that it is not planning to take any
action because the complaint is not relevant to our jurisdiction. In terms of
resolution, it is really a matter for the ACMA, if it decides to investigate a
complaint, to determine what action, if any, will be taken once it has formed a
view about the matter that was complained about.[37]
3.34
The ACMA also informed the committee that the number of complaints they
have received relating to telecommunications infrastructure has declined from 32
in 2006–2007 to 14 in 2010–2011.[38]
Electromagnetic energy (EME) emissions
3.35
The bill seeks to amend the Australian Radiation Protection and
Nuclear Safety Act 1998 to broaden the functions of the Radiation Health
and Safety Advisory Council.[39]
The additional functions for the council proposed in the bill would include
'reviewing the standard that relates to the limits for human exposure to
radiofrequency fields in the frequency range 3 kHz to 300 GHz'.[40]
Regulation of EME in Australia
3.36
Many submitters to the inquiry were supportive of the proposal in the
bill to require the Radiation Health and Safety Advisory Council to review the
standard for EME from telecommunications infrastructure in Australia. These
submitters mostly cited concerns about potential adverse health impacts
associated with EME from mobile phone towers as the reason for their support.[41]
3.37
In response to these types of concern, Mr Ray McKenzie of AMTA informed
the committee:
In relation to people's concerns around EME, the industry
understands that people have these concerns around health effects and is
committed to addressing those concerns responsibly. We do that by taking advice
in regard to those health effects and also in the way we deploy our networks.
In regard to the advice we take, we do not pretend to be an authority on health
effects. We look for experts and national and international authorities such as
the World Health Organisation and also the Australian Radiation Protection and
Nuclear Safety Agency...who provide us with advice regarding health effects...In
relation to the way we deploy our networks, again, all our networks are
deployed in accordance with strict science-based safety standards, and the
safety standards are those adopted by the Australian Radiation Protection and Nuclear
Safety Agency—which I will abbreviate to ARPANSA. Their limits are based, in
effect, on the World Health Organisation's own standard, the International
Commission on Non-Ionising Radiation Protection, or ICNIRP. So we deploy all
our networks in accordance with those standards.[42]
3.38
ARPANSA advised the committee that the EME from telecommunications
infrastructure:
...must comply with safety limits imposed by the Australian
Communications and Media Authority (ACMA) in the Radiocommunications Licence
Conditions (Apparatus Licence) Determination 2003...The safety limits in
this document are based on the ARPANSA Radiation Protection Standard -
Maximum Exposure Levels to Radiofrequency Fields - 3kHz to 300GHz. [43]
3.39
The ARPANSA 'Radiation Protection Standard – Maximum Exposure Levels to
Radiofrequency Fields – 3 kHz to 300 GHz' (the Australian standard) provides
the following EME exposure limits for the general public:[44]
Basic restrictions
for whole body average specific absorption rate (SAR) and spatial peak SAR
Exposure category
|
Frequency range
|
Whole-body average SAR (W / kg)
|
Spatial peak SAR in the head and torso (W / kg)
|
Spatial peak SAR in limbs (W / kg)
|
General public
|
100 kHz–6 GHz
|
0.08
|
2
|
4
|
3.40
During the course of the inquiry, ARPANSA informed the committee that it
was not responsible for ensuring carriers comply with the Australian standard
for EME emissions from telecommunications facilities, but rather that this
responsibility lies with the ACMA:
We do not do the surveys to assess compliance. We are not the
regulator. The Australian Communications and Media Authority is the regulator.
They are the one that issues the licences. It is formally their act and licence
conditions that the carriers are required to follow. They adopt our standard as
the basis of their regulation. We are not the regulator of this matter. The
survey we do is to provide public information about actual exposures and
particularly to compare them with the EME reports, that you will have heard of
already today, which provide a theoretical prediction. We do the measurements,
doing our best to find the maximum exposure, to show comparisons with those EME
reports. We do not do it to show technical compliance with the act or the
regulations.[45]
3.41
Mr Mark Loney of the ACMA explained the ACMA's role in regulating EME emissions
from telecommunications facilities:
The ACMA is responsible for the actual compliance by
radiocommunications transmitters of licence conditions. I should point out, and
it is relevant to this bill, that EME levels are regulated by the ACMA, as the
spectrum manager, under the Radiocommunications Act. ARPANSA has made the
health exposure standard and the ACMA has taken the health exposure standard
and the limits established in the health exposure standard and incorporated
them into conditions of licence for radiocommunications licences issued under
the Radiocommunications Act. Those limits, as I said, based on the ARPANSA
standard, apply to all radiocommunications transmitters that operate in
Australia, including base stations for mobile phone networks.[46]
3.42
DBCDE and the ACMA clarified that carriers are required to provide a
predictive report, which is completed 'in advance of the construction of the
facility so that the community knows what the EME exposure levels will be'.[47]
DBCDE explained that the predictive reports are 'prepared according to a
methodology produced by ARPANSA and in a format approved by ARPANSA'.[48]
3.43
DBCDE further advised the committee that:
ARPANSA has checked its methodology for predictive reports by
conducting surveys of base stations in 1999, 2003 and 2007-12. The 2003 survey
was published in the journal Bioelectromagnetics in 2006 [Bioelectromagnetics
(2006) 27:73-76]. That survey showed the predicted exposure levels for all
sites measured exceeded the actual measured exposure values.[49]
3.44
The ACMA indicated that it had received 'a small number of complaints or
inquiries about whether particular installations have complied with the EME
limits'.[50]
In relation to these complaints, Mr Loney stated:
I am not aware of any case where the subsequent ACMA inquires
and measurements have resulted in us identifying a site that was operating
beyond the limits specified in the licence conditions. They are, as I mentioned
before, based on the human exposure standard made by ARPANSA. The ACMA also
conducts a program of site audits, where we go to radiocommunications sites and
look for compliance issues.[51]
3.45
In response to queries about the compliance of telecommunications
facilities with EME emission standards, the committee was informed that of
approximately 18 000 telecommunication installations in Australia, the
ACMA had audited 474:
With regard to compliance with EME licence conditions, the
ACMA conducted an audit program between 2006 and 2008 that involved the
auditing of 474 sets of EME records held by licensees. It is a condition of a
licence that licensees hold records that demonstrate compliance with the EME conditions
that apply to apparatus and spectrum licences.[52]
International EME emission standards
3.46
During the course of the inquiry, there was some discussion about the
Australian standard for EME emissions in comparison to standards used
internationally. In particular, the standard in Switzerland was raised by some
submitters. For example, Ms Anna Castellano of No Towers Near Schools stated:
Last year the Council of Europe said that non-ionising
radiation, which is in fact EMR, used in telecommunications:
"... appear to have more or less potentially harmful,
non-thermal, biological effects on plants, insects and animals, as well as the
human body when exposed to levels that are below the official threshold values...One
must respect the precautionary principle and revise the current threshold
values; waiting for high levels of scientific and clinical proof can lead to
very high health and economic costs, as was the case in the past with asbestos,
leaded petrol and tobacco".
This resonates with communities. This is what is going to
happen to us in the future. There are more and more of these base stations all
over the country, constantly.
The council goes on to recommend a threshold of 0.1 microwatt
per centimetre squared. Let us remind ourselves once more that the ARPANSA
limit is 450. We know of nine countries in Europe who have adopted the
precautionary approach and have already lowered their EMR levels; Switzerland
comes to mind.[53]
3.47
In regards to the EME emission standard in Switzerland, Dr Lindsay Martin
of ARPANSA commented:
I understand it was generally as a response to community
concern. They have also done that in the extremely low frequency area as well.
I believe that was partly to facilitate the deployment, by clarifying, by
reducing a level, and avoiding the need to do a case-by-case assessment of many
examples. That is why they introduced a precautionary level...Clearly, in some
cases a particular person who made that decision may have seen a scientific
paper and acted on it—I cannot possibly know that—but I am not aware of any
particular evidence that scientists in these countries have put forward that
says, "We need this level because of this particular effect, this particular
scientific background".[54]
3.48
ARPANSA also provided the committee with an international comparison of
EME exposure limits for the general public.[55]
These limits for selected countries are outlined below.
Exposure limits
for the general public for electromagnetic fields in inhabited areas in member
states of the European Union and selected industrial nations outside the
European Union[56]
|
50 Hz
|
900 MHz
|
1800 MHz
|
|
Electric field strength
|
Magnetic flux density
|
Electric field strength
|
Magnetic flux density
|
Equivalent plain wave power density
|
Electric field strength
|
Magnetic flux density
|
Equivalent plain wave power density
|
|
V / m
|
µT
|
V / m
|
µT
|
W / m2
|
V / m
|
µT
|
W / m2
|
France
|
5000
|
100
|
41
|
0.14
|
4.5
|
58
|
0.20
|
9
|
Germany
|
5000
|
100
|
41
|
0.14
|
4.5
|
58
|
0.20
|
9
|
Hungary
|
5000
|
100
|
41
|
0.14
|
4.5
|
58
|
0.20
|
9
|
Sweden
|
-
|
-
|
41
|
0.14
|
4.5
|
58
|
0.20
|
9
|
United Kingdom
|
-
|
-
|
41
|
0.14
|
4.5
|
58
|
0.20
|
9
|
Australia
|
5000
|
100
|
41
|
0.14
|
4.5
|
58
|
0.20
|
9
|
Switzerland
|
-
|
1
|
4
|
-
|
-
|
6
|
-
|
-
|
USA
|
-
|
-
|
-
|
-
|
6
|
-
|
-
|
10
|
Potential costs and unintended consequences
3.49
A number of submitters discussed potential costs and unintended
consequences associated with the bill if it were enacted. The
telecommunications industry identified costs associated with increased
administration and 'sub optimal' network performance and maintenance.[57]
Local government was concerned that there may be 'unintended consequences in
terms of additional burdens and costs falling on councils'.[58]
3.50
Crown Castle felt the bill would create 'considerable uncertainty for
the wireless telecommunications industry at a time when critical investment
decisions are being made' as well as '[a]n uncertain regulatory environment'
that would increase '...the cost of equity associated with bidding for spectrum
and, therefore, reduces the bid price and the ultimate returns to taxpayers on
that valuable community asset'.[59]
3.51
As discussed earlier in this chapter, AMTA and Telstra believed the bill
would impose significant costs on the telecommunications industry. AMTA,
quoting analysis by Deloitte Access Economics, claimed the bill would have an
overall annual cost of $2.2 billion comprising $2.06 billion per annum of
additional administration costs, $132 million per annum arising from a
sub-optimal network outcome and $14 million per annum reflecting the delay to
required facility construction, upgrade or maintenance.[60]
3.52
AMTA continued:
AMTA fails to see what, if any, benefits the Bill would
deliver over the existing regulatory requirements. Indeed, it would impose a
range of costs on industry, the community and local governments and result in
unintended consequences that could lead to less community consultation and not
more as the Bill intends.[61]
3.53
Mr Adrian Beresford-Wylie, Chief Executive Officer of the Australian Local
Government Association (ALGA) cautioned that:
We are flagging that [potential cost impacts are] something
that always needs to be considered in terms of regulatory responsibilities
being placed on local government or when their responsibilities are expanded—although,
as our discussion has turned to, community consultation and issues like this
are a responsibility of local government anyway. Therefore it is just ensuring
that local government is appropriately resourced, which really relies on a
state government.[62]
3.54
DBCDE concurred that the changes proposed in the bill would likely 'place
a significant administrative burden on local government planning department
resources' and:
...may delay premises connections to networks, including where
a service has been requested in fulfilment of the Universal Service Obligation (USO).
Furthermore, they may limit carriers’ land entry powers to the extent they are inconsistent
with state or territory legislation. This may affect the ability of carriers to
effectively maintain their existing networks, including fixed line and backhaul
networks. If the bill were enacted, it may therefore be necessary to review
certain existing consumer protection regulation, such as the USO and Customer
Service Guarantee, to ensure that the timeframes for connection and repair of
services allow for the relevant approvals to be received.[63]
3.55
The department also identified other unintended consequences of the
bill, including:
- extension of the application of Schedule 3 resulting in the capture
of organisations that install private networks such as other utilities, police,
emergency services organisations, defence organisations, broadcasters, taxi
services and potentially some local councils, community organisations such as
surf clubs and individuals installing devices in their home;
- amending the definition of "tower" which may prevent
the installation of most radiocommunications antennae under Schedule 3 of the
Act 'thus inhibiting the deployment of radiocommunications equipment generally
to both transmit and receive';
- amending the maintenance clause which may result in activities
such as changing the visible light emitted, replacing defective indicator
lights on an electronic panel or infrared radiation emitted by a warm object
being excluded from the Schedule 3 immunities;
- extension of the notification period which could delay
infrastructure roll-outs and maintenance, particularly in unforeseen
circumstances; and
- requiring a carrier to prepare a Local Telecommunications Network
Plan and making this plan publicly available which 'may have significant
implications for critical infrastructure protection'.[64]
Committee view
3.56
The committee is sympathetic to the concerns voiced by communities when
they are faced with the prospect of a telecommunication infrastructure
development in their region. The information provided during the course of this
inquiry demonstrates the difficulties some communities encounter when seeking
to engage in planning and development processes, and how these processes can
make individuals and communities feel disempowered and frustrated.
3.57
The committee was heartened, however, by advice from the
telecommunications industry and the industry regulatory about improvements that
have been made to the industry code of conduct in response to the concerns and
experiences of individuals and communities. The committee was equally pleased
to hear that community representatives had participated in development of the
revised industry code. The revised code, Industry Code C564:2011 Mobile Phone
Base Station Deployment, is due to come into effect on 1 July 2012. The
committee trusts that the telecommunications industry will fully comply with the
revised industry code, as well as all other applicable regulations, and will
strive to improve its relationships with affected communities through
considered, transparent and effective consultation practices. Failure to
improve community engagement as a result of the changes to the industry code
could require further legislative amendments to ensure the community is and
feels part of the process, and has access to real and effective communication
and consultation processes.
3.58
That said, the committee recognises consumer demand for improved
telecommunication services, particularly wireless services, and that this
requires the installation of telecommunications infrastructure. As mentioned
above, this places obligations on carriers with respect to consultation and
community engagement and, in the committee's opinion, it also requires
consumers—including those in regional and rural Australia—to acknowledge that
telecommunications infrastructure must be built in their area if they are to
access these services.
3.59
With respect to EME emissions from telecommunications installations, the
committee notes that an apparently low number of these installations are
audited by the ACMA. Whilst recognising resource limitations, the committee
urges the ACMA to conduct regular audits of telecommunication installations to
ensure, and give confidence to communities, that these installations are
compliant with Australian EME emission standards.
3.60
The committee acknowledges the potential costs and unintended
consequences associated with the bill as identified by various submitters. It
is the committee's view that these costs and unintended consequences suggest
the bill is impractical and would not effectively resolve the concerns it is
seeking to address. On that basis, the committee recommends that the bill not
be passed.
Recommendation 1
3.61
The committee recommends that the bill not be passed.
Senator Doug Cameron
Chair
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