Chapter 2

Key Issues


This chapter examines the key issues raised in submissions in relation to the Bill including Efic's new overseas infrastructure financing power and the application of the Australian benefit test, with particular reference to Efic's due diligence processes for considering projects, transparency and governance matters and Efic's capability and expertise in infrastructure financing. The chapter then discusses matters related to the provision of the additional $1 billion in callable capital and summarises Australian Infrastructure Financing Facility for the Pacific (AIFFP) matters as they relate to the Bill. The chapter concludes with the Committee's views and recommendation.

New overseas infrastructure financing power based on an Australian benefit test

A key change to the Efic Act proposed in the Bill is to extend Efic's mandate to include a new overseas infrastructure financing power based on an Australian benefits test. The new overseas infrastructure financing power will be used by Efic on its commercial account for commercially viable infrastructure project loans as well as allowing it to administer loans for the AIFFP.1

New power needed to facilitate overseas infrastructure projects

Efic explained that granting this new power to finance overseas infrastructure projects based on an Australian benefit test will overcome the limitations of its existing mandate:
Efic's ability to assist in financing infrastructure projects is limited by certain narrowly drafted and inconsistent eligibility “tests” in the Efic Act. These tests require Efic to satisfy specific Australian participation requirements before it can provide certain types of finance.
Such narrow tests do not easily enable the provision of finance for infrastructure projects that offer longer term commercial benefits to Australia or are not centred on immediate or near-term commercial participation by Australian companies.2
DFAT submitted that although multilateral development banks are increasing their lending in the Pacific, 'more financing options are needed to meet the region's varied needs'.3 In addition, DFAT advised that financing from both the private and public sectors is required to 'meet the infrastructure needs of the Pacific and our broader region'.4 For a variety of reasons, commercial banks are 'often unwilling or unable to finance overseas infrastructure' and therefore export credit agencies like Efic can play an important role 'in bridging gaps in financing for infrastructure and supporting companies when other sources of finance are not available'.5 Furthermore:
Bridging financing gaps and attracting private sector finance is where Efic can, and should, play a greater role. These amendments will enable Efic to do this. Australia has an interest in supporting greater economic activity in the Pacific, and promoting greater ties between Australian businesses and the region.6
Submissions expressed support for extending Efic's mandate. The National Australia Bank (NAB) noted that:
…to include financing of productive and sustainable infrastructure projects overseas will serve the dual purpose of contributing to economic growth and development in the region, while also supporting Australian businesses' participation in international opportunities.7
Similarly, the Asian Development Bank noted that the Bill 'will enhance Australia's ability to address the infrastructure needs of the Pacific region by boosting [Efic's] ability to support commercial participation in infrastructure'.8 The submission from the Australia-Papua New Guinea, Australia-Fiji and Australia-Pacific Islands Business Councils argued that the Bill:
…will better enable EFIC and other Australian entities to participate in the financing and development of sustainable infrastructure in collaboration with Pacific regional financing arrangements and of course to be better connected to Pacific national and regional priorities.9
Rhodes Project Services Pty Ltd (Rhodes), an Australian owned company specialising in delivery of social infrastructure throughout the Pacific region, has received support from Efic to pursue projects in Papua New Guinea.10 In its submission, Rhodes noted that Efic support is 'very important in a Pacific environment that is critically lacking capacity and access to finance'. Rhodes argued that increasing Efic's ability to support commercial participation can assist to address the infrastructure needs of the Pacific:
Rhodes believes it is important to support large scale infrastructure opportunities, and SME [small and medium enterprise] related operations concurrently. Supporting all Australian businesses including subcontractors, consultants and suppliers via export finance is a very important step in allowing sustained commercial success, capacity and growth in the region.
Where a business case and appropriate creditworthiness exists, EFIC is a critical link in supporting Australian businesses to win more projects in the region. Access to finance is very restricted to an Australian business seeking revenue generating projects, outside of Australia and even more so when originating in the Pacific. A large risk premium and lack of appetite exists for such project support, even where a strong track record of commercial success and delivery performance exists.11

Australian benefit test

In accordance with the Bill, when financing overseas infrastructure projects, Efic should 'reasonably' believe the project 'is likely to result in the maximum Australian benefits'.12 During Additional Estimates, officials from Efic explained that the Australian benefit test:
…requires Efic to reach a reasonable belief that, following financing of a transaction, there will be maximum Australian benefits flowing back to Australia, and those benefits may include crowding in of Australian equity and finance institutions, supporting future employment in Australia, supporting export sectors important to Australia, facilitating access of Australian business to new markets, and encouraging future Australian participation in project supply chains.13
Efic emphasised that the Australian benefit test 'has been designed to be broad' to allow Efic to consider a range of potential benefits including looking 'much further into the future in terms of what Australia's benefit may be, as opposed to the actual immediate benefits'.14
According to Efic, the Australian benefit test will enable it to 'more deeply engage in sectors such as telecommunication and power, which deliver both short and long–term benefits to Australian businesses'.15 For example, Efic posited that:
…improved regional internet connectivity in the Pacific will benefit Australia over the longer–term by:
reducing the cost of doing business;
encouraging greater economic integration; and
promoting Australian exports to and investment in the region.16
The broad Australian benefit test will 'enable Efic to finance a wider range of projects across the region'.17 DFAT submitted that the Bill will allow Efic to take account of broader benefits such as:
Greater Australian participation in supply chains.
Access to new markets for Australian businesses.
More Australian jobs, payments, dividends or other financial proceeds from overseas to Australia.
Stronger relationships with our regional partners, especially in the Pacific.18
Austrade supported the reforms proposed in the Bill and in particular the Australian benefit test:
This new approach will ensure that these measures will support our commercial engagement in the Pacific as well as Australian businesses. It will do this in a more flexible manner, and also in a manner more in keeping with the broader objectives of assisting the Pacific such as, for example, allowing labour utilisation and skills transfer to the Pacific islands.19
While the Export Council of Australia (Export Council) was supportive of considering 'indirect benefits when assessing the commercial outcomes for Australia', they emphasised that 'the benefits to Australia should be clear, quantifiable, and proportionate to the financing provided'.20

Issues raised by submitters

While a majority of submissions supported the revised Australian benefit test, the next section summarises some of the issues raised in submissions about the extension of Efic's mandate to include an overseas infrastructure financing power based on an Australian benefit test.

Consideration of recipient countries when assessing projects

When discussing the Australian benefit test, some submissions were concerned that the focus on assessing projects for Australian benefits does not give appropriate consideration to whether the loan and the project will be of benefit to the recipient country.21
However, Efic and DFAT emphasised that when Efic lends to governments, or government guaranteed entities, it carefully assesses the country's capacity to repay the loan and this assessment will continue.22 This credit and country risk assessment process includes:
conducting an analysis of both its public debt and external debt positons to ensure that debt sustainability is maintained; and
adhering to the OECD Recommendation on Sustainable Lending Practices and Officially Supported Export Credits.23
In a supplementary submission, DFAT advised that both the AIFFP and Efic 'will consider the interests of recipient countries including the appropriateness of the infrastructure, the way in which it is procured and its impact on the local community'.24 In addition it was also pointed out that Efic's current due diligence processes 'include debt sustainability analysis and compliance with international economic, financial, environmental and social risk standards', as detailed below.25 Efic has a comprehensive framework of anticorruption policies and procedures and complies with the OECD Council Recommendations on Bribery and Officially Supported Export Credits.26

Efic's due diligence processes

Some submitters raised concerns about the adequacy of Efic's due diligence processes with reference to the provision of loans to projects not located in Australia.27
As noted earlier, Efic's due diligence processes include an assessment of economic, financial, environmental and social risks. In particular, it applies its Policy for environmental and social review of transactions (the Policy) which confirms that Efic:
is bound by the OECD Recommendation of the Council on Common Approaches for Officially Supported Export Credits and Environmental and Social Due Diligence; and
applies the Equator Principles, a globally recognised benchmark used by many financial institutions to manage environmental and social risk in projects.28
The Policy also uses the International Finance Corporation (IFC) environmental and social performance standards as its benchmark. The IFC Performance Standards were selected as Efic’s usual benchmark as they are a widely used and understood global standard. However, where a higher benchmarking standard is applicable to a particular transaction, Efic applies that higher standard.29 Efic recently adopted a short Human Rights Statement, however ActionAid Australia argued that 'this is insufficient to prevent further violations through Efic’s activities'.30
Efic confirmed that if the Bill is passed, the organisation will continue to manage the commercial account in accordance with Australian Prudential Regulation Authority (APRA) guidelines. Efic will continue to charge interest premiums that reflect the underlying risks and also adhere to its existing Board delegation to approve all transactions in excess of $50 million. Efic will also:
…continue to conduct transactional due diligence which covers both the construction and operation of infrastructure, even in circumstances where Efic is only providing a construction linked facility.31

Transparency and governance

Some submitters also highlighted that details of some of Efic’s decision-making processes are commercial in confidence or exempt under the Freedom of Information Act 1982.32 Other submitters advocated for changes, such as ensuring aspects of Efic's activities are no longer automatically exempt from the Freedom of Information Act 1982.33
As a corporate Commonwealth entity governed by the Public Governance, Performance and Accountability Act 2013, Efic is subject to a range of transparency and governance requirements. In compliance with these obligations, Efic:
publishes an annual report which is tabled in Parliament;
discloses its proposed involvement in transactions with a potential for significant environmental and/or social impacts on its website prior to making a decision. Public input on such projects is encouraged; and
publishes detailed information on its website within eight weeks of a transaction being signed.34
DFAT emphasised the need for Efic, like other financial institutions including banks, export credit agencies and multilateral development finance institutions, to respect the commercial in confidence information of its clients and borrowers:
This means it is not always able to disclose fully detailed transaction information. Efic must safeguard its clients’ legitimate financial or business interests. Without the ability to protect commercial-in-confidence information, Efic would not be able to operate.35

Efic's capability and expertise in infrastructure financing

Some evidence to the Inquiry questioned whether Efic has sufficient capability to undertake activities under the new infrastructure mandate.36 In its submission, Efic reported that its dedicated Corporate, Sovereign and Project Finance team has 'a strong track record of supporting infrastructure and large projects in the region and around the globe'.37 Furthermore, DFAT advised that Efic can 'draw on expert independent advisers when assessing projects' and also:
For many infrastructure projects, where financing is often syndicated, Efic will work with other financiers active in the region, including the Asian Development Bank, the World Bank, other export credit agencies and commercial financers, which bring their skills and experience to project assessment and management.38
In its submission, CCB Envico, a construction organisation that has undertaken projects in the Pacific with Efic's support, noted that the increased focus on the Pacific may require Efic to build on the external expertise it has traditionally utilised.39
At Additional Estimates, Ms Swati Dave, Managing Director and Chief Executive Officer, Efic assured the Committee that Efic has the 'capability in the organisation to do the kinds of transactions that are contemplated' in accordance with the Bill.40 It was noted that additional staff may be required but that 'will really depend on the pipeline: how quickly it builds and whether the pipeline is enough for us to hire more people'.41

Increase in callable capital

As noted in chapter 1, the Bill proposes to increase Efic's callable capital on its commercial account by $1 billion. The next section starts with a brief summary of Efic's existing activity on its commercial account, discusses the implications of the increased callable capital for Efic's operations, and concludes with a discussion on issues raised in relation to the Bill.

Existing activity on the commercial account

Currently, Efic's capital base on its commercial account is approximately $675 million, comprised of $475 million of cash and $200 million of callable capital. Callable capital is an amount specified in the Efic Act 'that the Government will make available to Efic in the event that Efic is (for whatever reason) unable to meet its expected losses or liabilities'.42 Efic's latest annual report confirms that the $200 million of callable capital 'to date has never been called'.43
Efic manages the commercial account in accordance with its Statement of Expectations from the Minister for Trade, Tourism and Investment. Under the Statement of Expectations, Efic is required to manage risk in accordance with guidance from APRA. Taking account of APRA's guidance, the Efic Board 'generally applies an upper limit of 25 per cent of Efic’s capital, for country, sector and non-bank counterparty exposures'.44
As at 31 December 2018, Efic's total exposure under the commercial account was $2.1 billion.45

What will the increase in callable capital mean for Efic's operations?

The Bill proposes to increase Efic's callable capital on its commercial account by $1 billion to $1.2 billion and as a consequence will increase Efic's total capital base to approximately $1.675 billion.46
Efic explained that the additional callable capital would give it increased flexibility in their operations as it will 'allow the Efic Board to establish higher individual, or country exposure limits'.47 The additional capital will mean:
Efic’s upper financing limit for individual or country exposures could reach a more impactful maximum of $420 million (approx.), compared with the current upper limit of between $160 to $170 million.48
Efic pointed out that the additional capital will enable its Board to 'set individual maximum exposure limits that are more in line with other ECAs [export credit agencies] within the region' as Efic's current lending capacity is low compared to its counterparts.49 DFAT also noted that compared to Efic, other financiers have larger capital bases and can offer much larger amounts for infrastructure deals.50
Efic also noted it is already approaching the upper limit for country exposures to countries such as Papua New Guinea and Sri Lanka under its existing capital base.51 According to DFAT, the increase in callable capital is 'vital' to enable Efic to continue providing finance to those counties where it is approaching its lending limits and will secure Australia's 'credibility and flexibility as an infrastructure financier'.52
The Export Council submitted that 'Efic has a strong track record as a responsible lender' and the increased callable capital 'will increase its ability to support Australian businesses, particularly in countries where it is nearing its lending limits'.53
DFAT acknowledged that even with the increase in callable capital, 'Efic's total capital will still be modest compared to its international peers' requiring Efic 'to be selective when considering which projects to finance'.54 It was DFAT's view that without the capital increase 'Efic’s ability to provide finance for infrastructure projects will continue to be constrained, and its ability to use its infrastructure power would be limited'.55
Austrade supported the increase to callable capital which 'will allow Efic to offer more meaningful participation in projects which are generally larger than Efic's core business to date'.56
The Australia-Papua New Guinea, Australia-Fiji and Australia-Pacific Islands Business Councils noted that the increase in callable capital, as well as the introduction of the Australian benefit test, will enhance 'Australia's relevance and relationships across the Pacific region' and expand the range of projects that Efic can support.57

Issues raised by submitters

Some submissions expressed concern about the additional capital that will be available, including whether there was a demonstrated need.58
However, other submissions, such as the ANZ, highlighted that overseas ECAs are typically able to support higher value transactions than currently available to Efic:
In ANZ’s experience, the amount of support Efic provides to individual projects and transactions is, on average, markedly lower than the support typically provided by overseas ECAs to foreign transactions and projects…
Providing Efic with access to additional capital to increase its support capacity for individual transactions and projects will ensure it keeps pace with and, where required, can compete with other ECAs.59

Australian Infrastructure Financing Facility in the Pacific

As well as enabling Efic to use its commercial account for commercially viable infrastructure project loans, the new overseas infrastructure financing power will allow Efic to administer AIFFP lending. In its submission, DFAT explained:
In order to be operational by 1 July 2019, the AIFFP has sought to build on existing experience within government on infrastructure financing. The AIFFP will draw on established processes and use the Government’s National Interest Account, administered by Efic, to manage loans. This minimises the need for new or complex bureaucratic architecture while the AIFFP is established.60

Concerns about Efic's role to administer the AIFFP

The development and design of the AIFFP and Efic's anticipated role was discussed in evidence to the inquiry. A view put to the Committee in several submissions was that the relationship between Efic and the AIFFP remains unclear.61
Submissions also suggested that Efic should not be the administering agency for the AIFFP.62
DFAT provided further information about how DFAT and Efic will work together regarding the AIFFP. DFAT will manage the AIFFP and 'assessments of the development merits of projects will be undertaken by DFAT and the AIFFP Board'.63
With respect to Efic's role, DFAT advised that 'Efic will not be responsible for decision making for AIFFP infrastructure loans'.64 Efic's role will be to:
…provide technical and expert financial advice (such as credit assessment and loan structuring), portfolio management and operational support to the AIFFP. Efic will draw on its longstanding experience in financing projects in emerging markets.65
Ms Dave, Efic emphasised that Efic will not be involved in decision making about the AIFFP as 'that is something that DFAT will be responsible for'. However, Ms Dave noted that Efic 'will help the AIFFP in terms of operationalising' the facility because that is where Efic's capability lies.66 On the question of what level of interaction there will be between the two agencies about the AIFFP, Ms Dave advised the Committee at Additional Estimates:
There may be situations or there may be projects where it's appropriate for Efic to provide some commercial financing and the AIFFP to provide some blended financing or some grant financing. So you could have co-financings. That's one where there might be interaction.67
Efic informed the Committee that it is working with DFAT to determine what advice and operational support will be required to assist with decision making processes and the provision of advice and support 'will be the subject of a formal Service Level Agreement between DFAT and Efic'.68

Other provisions

Name change

A small number of submitters explicitly discussed the proposed name change and indicated their support.69 The Export Council noted that Export Finance Australia 'is a much simpler name that more accurately conveys the services [Efic] provides'.70 Furthermore, the Export Council recommended that, as the name change will require a major rebranding exercise, the Government should lower its required dividend for the current and next financial years to 'adequately fund this exercise'.71

Committee view

The Committee notes the Bill further demonstrates the Australian Government's ongoing commitment to broaden its engagement in the Pacific. As highlighted in this Inquiry and others, the infrastructure needs of the Pacific are significant and will require a range of funding and financing options.
The Committee acknowledges that the $1 billion increase to Efic's callable capital on its commercial account will give Efic greater flexibility to conduct its operations. Importantly, while continuing to adhere to APRA guidelines, it will allow the Efic Board to set higher individual or country exposure limits which will ensure Efic is more in line with its international export credit agency counterparts. The Committee was reassured to note that although increased individual or country limits will be available to Efic, they will not be uniformly applied. The Board will continue to assess limits against the commercial viability of projects on a case by case basis. Furthermore, while the capital available to Efic will be increased, there will be no increase to the existing $6.5 billion Commonwealth maximum liability as set by the Export Finance and Insurance Corporation Regulations 2018.
The Committee supports the intent of the Bill to build on Efic's existing mandate to support overseas infrastructure projects that meet the requirements of the Australian benefit test. This broad test will mean that Efic can take account of both direct and indirect benefits for Australia and Australian businesses when considering overseas infrastructure projects. Importantly, broad indirect benefits such as building stronger relationships with our regional partners will be considered as part of the Australian benefit test.
The Committee notes that some submissions expressed concern that the focus on Australian benefits may not allow for sufficient consideration of the interests of recipient countries. More broadly, some concerns were raised about whether Efic's due diligence and project assessment processes are sufficient to enable it to meet the requirements of its new mandate. However, the Committee was assured by DFAT that the interests of recipient countries will be considered, including the appropriateness of the infrastructure, the way it is procured and its impact on the local community. In addition, the Committee is aware that Efic applies robust due diligence processes to its operations including analysing debt sustainability and compliance with international economic, financial environmental and social risk standards. It will be important for Efic to continue to apply its sound due diligence processes when considering projects both on its commercial account and when administering loans for the AIFFP. This will ensure Efic continues to uphold best practice environmental and social standards in its transactions.
While some submissions raised concerns about the level of expertise and skill in Efic to undertake its new role, the Committee acknowledges evidence from Efic in their submission and at Additional Estimates emphasising their institutional expertise to finance international loans and the broad capability of their officers. In addition to existing capability, the Committee was advised that Efic can also draw on expert independent advisers when assessing projects.
While the Committee recognises that the Bill is focused on Efic's infrastructure capabilities, the fact that the expanded mandate will enable Efic to administer loans for the AIFFP raised some questions for submitters about how Efic and DFAT will work together to administer the AIFFP, as well as the broader design and operation of the AIFFP. The Committee notes evidence from both Efic and DFAT clarifying their roles which will utilise their organisations' respective strengths and expertise.
On the broader matters of the AIFFP, the Committee welcomes and supports the consultation being undertaken by DFAT with a range of domestic and international stakeholders to inform the design of the AIFFP as well as to ensure the new facility supports the development priorities of Pacific countries and Timor Leste.

2.57 The Committee recommends that the Bill be passed without amendment.
Senator the Hon Eric Abetz

  • 1
    DFAT, Submission 9.1, p. 4.
  • 2
    Submission 8, p. 3.
  • 3
    DFAT, Submission 9, p. 4.
  • 4
    Submission 9, p. 4.
  • 5
    DFAT, Submission 9, p. 4.
  • 6
    DFAT, Submission 9, p. 4.
  • 7
    Submission 11, p. 2.
  • 8
    Submission 16, [p. 2].
  • 9
    Submission 21, p. 1.
  • 10
    Efic, Annual Report 2017-2018, pp. 73–74; Rhodes, Submission 4, p. 2.
  • 11
    Submission 4, pp. 2–3.
  • 12
    Proposed subsection 8(4).
  • 13
    Mr John Hopkins, Chief Operating Officer and General Counsel, Efic, Proof Estimates Hansard, 21 February 2019, p. 117.
  • 14
    Mr Hopkins, Proof Estimates Hansard, 21 February 2019, pp. 117–118.
  • 15
    Submission 8, p. 4.
  • 16
    Submission 8, p. 4.
  • 17
    DFAT, Submission 9, p. 5.
  • 18
    Submission 9, p. 5.
  • 19
    Submission 23, [p. 3].
  • 20
    Submission 14, [p. 2].
  • 21
    World Vision, Submission 7, [p. 2], Action Aid, Submission 13, [pp. 5–6]; The Australia Institute, Submission 15, p. 2; ACFID, Submission 20, [pp. 3–4]; Development Policy Centre, Crawford School of Public Policy, ANU, Submission 17, p. 7; The McKell Institute, Submission 6, p. 4.
  • 22
    Efic, Submission 8, p. 6; DFAT, Submission 9, p. 8.
  • 23
    Efic, Submission 8, p. 6.
  • 24
    Submission 9.1, p. 1.
  • 25
    Submission 9.1, p. 1.
  • 26
    DFAT, Submission 9, p. 9.
  • 27
    Oxfam Australia, Submission 18, pp. 3–4; The Australia Institute, Submission 15, p. 5; Jubilee Australia, Submission 12, p. 6; ActionAid, Submission 13, pp. 4–5.
  • 28
    Efic, Submission 8, p. 6.
  • 29
    Efic, Submission 8, p. 6.
  • 30
    Submission 13, [p. 3].
  • 31
    Submission 8, p. 6.
  • 32
    ACFID, Submission 20, pp. 5–6.
  • 33
    Jubilee Australia, Submission 12, p. 7; Oxfam Australia, Submission 18, p. 3.
  • 34
    DFAT Submission 9.1, p. 3.
  • 35
    Submission 9.1, p. 3.
  • 36
    World Vision Australia, Submission 7, [p. 3]; International Women's Development Agency, Submission 10, [p. 3].
  • 37
    Submission 8, p. 2. Annexure 1 of Efic's submission provides examples of projects and transactions supported by Efic.
  • 38
    Submission 9.1, pp. 2–3. See also: Efic, response to Additional Estimates 2018–19 question on notice, no. 28.
  • 39
    Submission 22, [p. 1].
  • 40
    Proof Estimates Hansard, 21 February 2019, p. 116.
  • 41
    Proof Estimates Hansard, 21 February 2019, p. 116.
  • 42
    Efic, Submission 8, p. 5.
  • 43
    Efic, Annual Report 2017–2018, p. 91.
  • 44
    Efic, Submission 8, p. 5.
  • 45
    Efic, Submission 8, p. 5.
  • 46
    Efic, Submission 8, p. 5.
  • 47
    Submission 8, p. 5.
  • 48
    Submission 8, p. 5.
  • 49
    Submission 8, p. 5.
  • 50
    Submission 9, p. 6.
  • 51
    Submission 8, p. 5.
  • 52
    Submission 9, p. 6.
  • 53
    Submission 14, [p. 2].
  • 54
    Submission 9, p. 6.
  • 55
    Submission 9, p. 6.
  • 56
    Submission 23, [p. 4].
  • 57
    Submission 21, p. 1.
  • 58
    The McKell Institute, Submission 6, pp. 7–8; Oxfam Australia, Submission 18, [p. 4].
  • 59
    ANZ, Submission 19, p. 3. Other submissions also supported the callable capital increase including: Oil Search, Submission 1, p. 2; ESS Weathertech, Submission 2, [p. 1]; Aspen Medical, Submission 3, p. 2; CCB Envico, Submission 22, p. 1.
  • 60
    Submission 9, p. 7.
  • 61
    World Vision, Submission 7, [p. 4]; Jubilee Australia, Submission 12, p. 2, Development Policy Centre, Submission 17, pp. 7–8; ACFID, Submission 20, p. 8.
  • 62
    World Vision, Submission 7, [p. 4]; Jubilee Australia, Submission 12, pp. 11–13; ActionAid Australia, Submission 13, [p. 4]; ACFID, Submission 20, [p. 6]; Dr Susan Engel, Submission 5, p. 1.
  • 63
    Submission 9.1, p. 4. DFAT also provided further information about how risk analysis is informing the design process for the AIFFP; response to Additional Estimates 2018–19 question on notice no. 78.
  • 64
    Submission 9.1, p. 4.
  • 65
    Submission 9.1, p. 4.
  • 66
    Proof Estimates Hansard, 21 February 2019, p. 118.
  • 67
    Proof Estimates Hansard, 21 February 2019, p. 119.
  • 68
    Efic, response to Additional Estimates 2018-19 question on notice no. 22.
  • 69
    See for example, ESS Weathertech, Submission 2, [p. 1].
  • 70
    Submission 14, [p. 1].
  • 71
    Submission 14, [p. 2].

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