CHAPTER 2


CHAPTER 2

KEY ISSUES

2.1        Submissions from the ILC and AIATSIS opposed the introduction of ministerial guidelines to govern the ILC's involvement in native-title settlements. However, three other submissions—from the South Australian Government, National Native Title Council (NNTC) and Cape York Land Council—expressed support for the proposed guidelines.

2.2        Other issues raised during the inquiry include:

What is a native-title settlement?

2.3        Although Schedule 4 of the Bill aims to clarify the ILC's role 'in supporting native title settlements' by providing guidance in the exercise of its functions, there is no definition of 'native title settlements' in Schedule 4 or in the ATSI Act, nor is there any significant reference to the Native Title Act 1993 (Cth).

2.4        In its submission, the NNTC—the peak body of Native Title Representative Bodies (NTRBs) and Native Title Service Providers (NTSPs)—provided some commentary on the concept:

It should be acknowledged that the concept of 'native title settlements'—sometimes referred to as 'broader land settlements' or 'comprehensive agreements'—is relatively new. The concept gained traction when the Labor Government came to power in 2007 and shifted the policy emphasis towards building stronger links between native title and Indigenous economic development.

The NNTC's understanding of the term 'native title settlements' derives from earlier Commonwealth Government consultation papers and forums where the term has been used to refer to a settlement resulting in the resolution of one or more native title claims (which may or may not include the recognition of native title rights and interests), along with other non-native title benefits. Examples of non-native title benefits include support for the establishment of a Prescribed Body Corporate, the transfer of freehold land for cultural or enterprise development, training and employment opportunities, co-management of conservation reserves and fishing licences.[1]

Should there be ministerial guidelines?

2.5        The ILC submitted that it did not see the necessity for ministerial guidelines in relation to its involvement in native-title settlements, stating that it already had the 'statutory capacity and policy flexibility to work constructively with governments, Indigenous people and other stakeholders in this area'. However, if there are to be guidelines, the ILC stated that they should not be mandatory. The ILC therefore agreed with the present wording of Schedule 4, which requires the ILC to 'have regard to' the content of any guidelines, thus preserving its statutory independence.[2]

2.6        AIATSIS opposed the introduction of ministerial guidelines as 'inappropriate', noting that interference in the independence of a statutory authority is problematic. This could potentially lead to appropriation of the Land Account 'for other purposes, including subsidising compensation settlements for new acts of extinguishment'. AIATSIS argued that '[e]nsuring that the ILC meets the purposes for which it was established should be achieved by other means'.[3]

2.7                  However, should the amendments go ahead, AIATSIS submitted that the proposed guidelines should be carefully drafted and circumscribed to ensure that they:

2.8        Several other submissions expressed general support for the introduction of guidelines.

2.9        For example, the South Australian Government welcomed the formalisation of the ILC's role in native-title settlements:

The South Australian Government has found that it is through the Native Title claim settlement process [that] claim groups begin capacity building (to develop economically and culturally). Without the provision of freehold land and land management support from the I.L.C., the South Australian Government considers that a vital link to capacity building through Native Title settlement is missing. The provision of land as part of a Native Title settlement package is sought by claim groups to better provide for future generations. This goal may not easily fit with the immediate land use benefits that the I.L.C. requires, meaning the I.L.C. may not enter into negotiations early and with maximum effect.[5]

2.10      For the South Australian Government, the proposed guidelines represent:

...a timely acknowledgment that current I.L.C. practice and policy, informed by legislative guidelines, does not always mesh with the reality of Native Title claim settlement. New guidelines should underpin a more flexible approach and policy than has been evident to date.[6]

2.11      The NNTC also welcomed the proposed amendments. However, the NNTC noted that the extent to which the amendments will facilitate increased ILC assistance for traditional owners will depend on the substance of the guidelines, as well as the willingness of the ILC to review and adapt its program guidelines and approach to regional planning so that any guidelines can have full effect.[7]

2.12      While supportive of the concept of guidelines, the Cape York Land Council noted that it is difficult to determine the potential effectiveness of any guidelines without a better idea of their content and the attitude of the ILC.[8]

Departmental view

2.13      In its submission, the Department of Families, Housing, Community Services and Indigenous Affairs (Department) described the policy context for the proposed guidelines:

The Government considers that native title settlements can assist in closing the gap on Indigenous disadvantage. The Government has initiated a range of reforms to address blockages in the native title system. Native title [settlement] enhances the ability of Indigenous communities to leverage economic development opportunities. Practical benefits can include training, employment and business opportunities for enterprises on land, freehold or other title to land, a revenue stream to build up capital and employment in national parks and other conservation areas.

2.14      In proposing the new ministerial power, the Department echoed some of the original reasons for the creation of the ILC:

The Government considers that there is scope for the ILC to increase its involvement in native title and broader land settlements, particularly where proof of connection is difficult due to historical dispossession such that native title is unlikely to be established or is expected to be limited in geographical area or extent. ILC assistance can provide for claimants to have access to land including land which is of importance to them culturally even though native title cannot be easily demonstrated. Land outcomes in these circumstances can provide an incentive for claimants to settle claims particularly where claims have remained in the system for years because of problems with establishing the requisite levels of connection.[9]

2.15      Further to its submission, the Department also highlighted the criteria governing existing ILC programs:

The criteria governing existing application-based programs administered by the ILC are currently not suited to meeting the needs of claimants and governments in developing settlement proposals. For example, the ILC only provides program funding and resources for land management projects on Indigenous-held land. However, in most cases claimant groups will only be granted land at the conclusion of settlement negotiations. Claimant groups can experience difficulty demonstrating sufficient capacity, or would not be appropriately incorporated as a commercial entity until after their native title claim has been resolved and a Prescribed Body Corporate established, to manage any benefits and interests arising from the claim. Appropriate engagement by the ILC in supporting native title settlements would assist in developing settlement options and assist the claimant group with implementing and managing practical benefits in the settlement.[10]

2.16      In the Department's view, ministerial guidelines would help to:

...clarify and confirm that supporting native title settlements is an appropriate and routine function of the ILC and that its support can be sought at the outset, or at any stage during the settlement process.[11]

2.17      The Department stated that the content of the guidelines themselves would:

...deal with the manner in which the ILC could support native title groups with the resolution or settlement of native title claims. They are expected to include the circumstances under which the ILC could assist, the processes for providing that assistance and what types of assistance could be made available.[12]

2.18             The Department also stated that the ILC had 'indicated its acceptance of the proposed Ministerial power'.[13]

Interaction with existing ILC guidelines

2.19      The ILC expressed the view that the inconsistency provision in proposed new subsection 191I(1A)—giving precedence to the proposed ministerial guidelines over any guidelines made by the ILC Board—is unnecessary, because such a provision 'is only relevant where such rules or guidelines are binding in nature'.[14]

2.20      None of the other non-government submissions made reference to existing ILC guidelines or the possibility of inconsistency between the two types of guidelines.

Departmental view

2.21      The Department advised that proposed new subsection 191I(1A) clarifies that, in the unlikely event of an inconsistency between the ILC guidelines under subsection 191I(1) and ministerial guidelines under proposed section 191HA, the ILC guidelines will have no effect to the extent of the inconsistency.[15]

Guidelines to include trigger for ILC involvement

2.22      Both the NNTC and the Cape York Land Council emphasised the need for a trigger to bring the ILC into native-title negotiations. Since the ILC currently operates on the basis of applications made to it, this requires native-title claimants to have already developed a certain capacity. However, as the South Australian Government pointed out, such capacity is generally developed as the native-title process unfolds.[16]

2.23      In this context, the NNTC submitted:

A current impediment to the ILC contributing to native title settlements is that there is no legislative or procedural 'trigger' for it to become involved in negotiations toward a settlement. Unless the native title party already has a project in train that could be bolstered by the acquisition of freehold land or assistance with land management, it is unlikely that the ILC will have cause to know whether and in what way it might contribute to a settlement.[17]

2.24      Similarly, the Cape York Land Council suggested:

The guidelines should include a trigger for ILC to become involved in negotiations toward a settlement, so that any potential contribution from ILC can be identified by the government parties and native title claimants at an early stage.[18]

2.25      More specifically, the South Australian Government—in the context of its suggestion that involvement in native-title settlement be made a core ILC function—proposed that a request from all parties to a native-title claim should be adopted as a trigger for ILC involvement in native-title negotiations.[19]

Need for consultation

2.26      Several submissions emphasised the need for further consultation on the content of any proposed guidelines, and for the draft guidelines to be made public.

2.27      For example, the ILC suggested that Schedule 4 be amended to require the Minister to consult with the ILC before making any guidelines, and noted that the drafting of the guidelines before the introduction of the Bill 'would have given confidence to stakeholders about the package of innovations and their workability'.[20] The South Australian Government stated that it would like to see the ATSI Act mandate consultation between the Commonwealth and the states before any guidelines are made.[21]

2.28      The NNTC noted the need for consultation as well as effective adaptation by the ILC:

The NNTC notes that any guidelines will not be binding on the ILC and therefore the extent to which these amendments will have any positive effects for Traditional Owners will depend on the willingness of the ILC to review and adapt where necessary its strategic planning, stakeholder engagement and land acquisition and management policies and procedures.

The NNTC would welcome an opportunity to work with the ILC and relevant Commonwealth departments in the future to ensure the proposed amendments can deliver positive outcomes in this regard.[22]

2.29      The Cape York Land Council also called for further consultation with Indigenous interests about the form of the proposed guidelines.[23]

Departmental view

2.30      In its submission, the Department advised that there would be more detailed consultation with the ILC and other stakeholders as the legislative process proceeds.[24]

Compensation

2.31      The NNTC submitted that there should continue to be compensation for the surrender or extinguishment of native-title rights, or for withdrawal of native-title claims, and that citizen rights should not be substituted for compensation:

This challenge does not rest solely with the ILC, but rather with all government parties seeking to resolve native title claims via negotiated settlement. Government parties must adequately compensate Traditional Owners for the loss or impairment of native title rights and interests, including procedural rights. Referring native title parties to existing programs and services available to other Australians, without special regard to the unique circumstances of native title claimants and the often time critical nature of settlement negotiations will not result in faster or better quality native title outcomes.[25]

2.32      Similarly, the Cape York Land Council urged that:

Any contribution by ILC to a native title settlement should not replace the obligation of government parties to compensate the native title holders for loss or impairment of their native title rights and interests.[26]

2.33      AIATSIS also submitted that any guidelines should not be used to compensate for future extinguishment of native title or other Indigenous interests in land.[27]

Regional planning

2.34      The NNTC underlined the importance of renewing the ILC's regional-planning processes to enable the ILC to respond quickly and effectively to the needs of native-title groups:

The NNTC submits that in recent years, the regional indigenous land strategies produced by the ILC have deteriorated in quality and it is not clear from publicly available documents what efforts have been made in terms of proactively and systematically engaging relevant stakeholders in their preparation.[28]

2.35      According to the NNTC, the engagement of the ILC at regional levels has declined since the abolition of ATSIC in 2005, and will need to be re-established if guidelines for native-title settlements are introduced:

In order for the ILC to support native title settlements, mechanisms for regional engagement will need to be re-established and adequately funded. Such mechanisms have the potential to contribute to a more collaborative approach whereby NTRBs/NTSPs can work with the ILC and government parties to identify aspirations for land acquisition and management early in negotiations and work together towards culturally and economically sustainable outcomes for native title groups.[29]

2.36      The Cape York Land Council also expressed concerns in this area:

Consideration must be given to effective regional planning, carried out between ILC, government parties and Indigenous representatives, to enable native title groups to identify potential benefits at an early stage.[30]

2.37      The Cape York Land Council reported some recent negative experiences with the ILC, namely, the ILC's reluctance to fund further acquisitions on Cape York until existing ILC-purchased properties there are making a financial return. In the Cape York Land Council's view, consideration of each application to the ILC should be on its own merits.[31]

Timeframes for ILC involvement and divestment

2.38      Although the requirement for the ILC to divest land within 'a reasonable time'[32] has not inhibited the ILC from a strategic move towards longer divestment timeframes, submissions by both the South Australian Government and the Cape York Land Council expressed concern that this provision might constitute an obstacle to the longer timeframes involved in native-title negotiations.

2.39      The South Australian Government accordingly recommended an amendment to Schedule 4 to ensure that the timeframes associated with legislative requirements, as well as those associated with ILC land-acquisition programs, are appropriate and flexible. This would permit native-title settlement negotiations to incorporate strategic land purchases by the ILC.[33]

2.40      Further:

It would also be useful if an amendment [is] made to [paragraph 191D(3)(b) of] the ATSI Act...to enable the particular circumstances of Native Title claims settlement negotiations to be taken into account in assessing what is a reasonable time to dispose of land acquired by the I.L.C. for the purpose of making a land grant.[34]

2.41      The Cape York Land Council expressed its concerns more broadly:

The guidelines need to provide realistic timeframes for finalisation of any contribution, so that there can be certainty of benefits in any proposed comprehensive settlement.[35]

Appropriate ILC functions

2.42             The South Australian Government, although supportive of the proposed amendments, submitted that involvement in native-title settlements should be made a core legislative function of the ILC, rather than a matter for the ILC Board to 'have regard to' through ministerial guidelines:

[T]here remains a fundamental concern that whilst the proposed amendments seek to provide a clear direction to the I.L.C. about what it is to consider when it chooses to support Native Title settlements, assistance with Native Title settlement is not mandated as a core function of the I.L.C. So, even if the proposed amendments are accepted, the I.L.C. can continue to perform its core functions without being obliged to consider whether it will participate in Native Title settlement by reference to the proposed new statutory guidelines.

...it has become increasingly apparent that the I.L.C's role in providing equity into the Native Title system can better be achieved by remoulding it as a key player in settlement negotiations, particularly in claims over land where mining will not take place, or where a Native Title determination is limited in its coverage by underlying extinguishment.[36]

2.43      The South Australian Government also made the point that, if this fundamental amendment were made, the ILC would then be required to include assistance for native-title settlements as part of the National Indigenous Land Strategy. The amendments in Schedule 4 currently provide encouragement to the ILC to participate in native-title settlements, but would not by themselves ensure that the ILC does so. The South Australian Government's suggested amendment to Schedule 4 would place native-title settlement at the core of the ILC's role, supported by guidelines.[37]

Other matters

2.44      The Cape York Land Council, in addition to its other comments, submitted that:

Committee view

2.45      The committee acknowledges the importance of ensuring that the significant amount of taxpayer funding invested in the ILC achieves its goals of providing economic, environmental, social or cultural benefits to Indigenous persons through land holding. Schedule 4 of the Bill aims to increase the effectiveness of the ILC by making it subject to ministerial guidelines inasmuch as it supports native-title settlements, and the committee supports the intention to involve the ILC more effectively in the resolution of native-title claims.

2.46      However, in the committee's view, there are two ways in which the drafting of Schedule 4—principally in relation to item 1—could be improved to help it achieve its intended purpose.

2.47      Firstly, there is some ambiguity in proposed new subsection 191F(2A), which may not help it to achieve its aim. The wording, 'to the extent that the Indigenous Land Corporation performs its functions in supporting native title settlements', could be read as if the ILC already has a specific function to support native-title settlements, which is not the case. If the wording were inverted to read 'to the extent that the Indigenous Land Corporation supports native-title settlements when it performs its functions', this ambiguity might be avoided and Schedule 4 might be more effective.

2.48      Further ambiguity arises from the lack of any definition of 'native title settlements' in Schedule 4 or in the ATSI Act (which has, besides, only a fleeting reference to the Native Title Act). The committee considers that the inclusion of a definition of the term 'native title settlements', or at least a reference to the Native Title Act, would potentially increase the effectiveness of the legislation.

2.49      In relation to the inconsistency provision in item 3 of Schedule 4 (proposed new subsection 191I(1A)), although the ILC opposed it as unnecessary, the committee takes the view that the provision will assist in giving precedence to ministerial guidelines over any guidelines that the ILC has made or may make.

2.50      It is also the committee's view that several issues raised in submissions could be addressed in the content of the proposed guidelines. For example, the committee supports the calls for the creation of a trigger to involve the ILC in native-title settlements, and especially the suggestion of the South Australian Government that a request for ILC involvement by all parties to a native-title claim would be a suitable trigger. The guidelines could also state that the longer timeframes involved in native-title settlements should be taken into account when determining what is a 'reasonable time' for the ILC to divest land to Indigenous corporations.

2.51      Since the ILC acknowledges that it already has some involvement in native-title settlements, the committee believes that ministerial guidelines that include a trigger for ILC involvement will ensure that Schedule 4 achieves its aim. A change of function for the ILC, as preferred by the South Australian Government, would then be unnecessary.

2.52      The committee also echoes the calls by several submissions for wider consultation on the content of the proposed guidelines. The committee notes that, in addition to any consultation that occurs during the drafting process, the guidelines will be a disallowable instrument, so that there will be an opportunity for further parliamentary scrutiny before they come into effect.

2.53      Ultimately, the effectiveness of the measure proposed in Schedule 4 will depend on the clarity of the legislation and—in the words of the NNTC—the 'willingness of the ILC to review and adapt where necessary its strategic planning, stakeholder engagement and land acquisition and management policies and procedures'.[39] The committee calls on the ILC to take the opportunity afforded by this legislation to increase its involvement in native-title settlements, and considers that attention to more focussed regional planning should be an early priority in this process.

2.54      In view of the above comments, the committee makes the following recommendations.

Recommendation 1

2.55      The committee recommends that the measure contained in Schedule 4 of the Bill be clarified by:

Recommendation 2

2.56      The committee recommends that the Australian Government consult more widely with stakeholders, and release any draft ministerial guidelines, before proceeding with the measure contained in Schedule 4 of the Bill.

Recommendation 3

2.57      Subject to the preceding recommendations, the committee recommends that the Senate pass the measure contained in Schedule 4 of the Bill.

Senator Trish Crossin

Chair

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