Hi Ian,
A few comments. If they extended the public consultation period that is a good thing. They have no obligation to do that at all if they do not wish to. So that doesn't give you much of an argument at all.
Second, you cannot just meet with freedom of information officers and ask for "leads". You need to ask for specific documents. And they need to be documents that do not fall within one of the long list of exemptions for NOT releasing a document. You might like to take a closer look at the FOI Act before you meet with them.
[url="http://www.dms.dpc.vic.gov.au/Domino/Web_Notes/LDMS/PubLawToday.nsf/a12f6f60fbd56800ca256de500201e54/7a4b0aa4f2def080ca256fd5000d4e32/$FILE/82-9859a056.pdf"]http://www.dms.dpc.vic.gov.au/Domino/Web_N...82-9859a056.pdf[/url]
Here is the section you need to look at.
If you suspect that "form letters" were received by commercial interests then you could ask the FOI officers to provide access to those submissions (with personal information removed). However, if there are scores of submissions then the request might be classes as a "voluminous request" (i.e. too big) and will be denied.
You could approach the Scrutiny of Acts and Regulations Committee (SARC) and ask them to pay special attention to these Regulations. However, even if they decide the regulations were not made with inadequate consultation or that they are inherently unfair, it is very unlikely they would recommend that the regulations would be disallowed by Parliament. Look at their website and the Alerts they publish. The worst that generally happens is that they send a letter to the relevant Minister and point out the flaws. This has no practical affect other than embarassing the Minister.
So basically what I am saying, is that the regulations will be made, regardless of your efforts. You may however be able to stir things up a bit and cause a bit of embarassment which may perhaps be a valuable achievement in itself.
Let us know how you go,
Cheers, Glen
A few comments. If they extended the public consultation period that is a good thing. They have no obligation to do that at all if they do not wish to. So that doesn't give you much of an argument at all.
Second, you cannot just meet with freedom of information officers and ask for "leads". You need to ask for specific documents. And they need to be documents that do not fall within one of the long list of exemptions for NOT releasing a document. You might like to take a closer look at the FOI Act before you meet with them.
[url="http://www.dms.dpc.vic.gov.au/Domino/Web_Notes/LDMS/PubLawToday.nsf/a12f6f60fbd56800ca256de500201e54/7a4b0aa4f2def080ca256fd5000d4e32/$FILE/82-9859a056.pdf"]http://www.dms.dpc.vic.gov.au/Domino/Web_N...82-9859a056.pdf[/url]
Here is the section you need to look at.
If you suspect that "form letters" were received by commercial interests then you could ask the FOI officers to provide access to those submissions (with personal information removed). However, if there are scores of submissions then the request might be classes as a "voluminous request" (i.e. too big) and will be denied.
You could approach the Scrutiny of Acts and Regulations Committee (SARC) and ask them to pay special attention to these Regulations. However, even if they decide the regulations were not made with inadequate consultation or that they are inherently unfair, it is very unlikely they would recommend that the regulations would be disallowed by Parliament. Look at their website and the Alerts they publish. The worst that generally happens is that they send a letter to the relevant Minister and point out the flaws. This has no practical affect other than embarassing the Minister.
So basically what I am saying, is that the regulations will be made, regardless of your efforts. You may however be able to stir things up a bit and cause a bit of embarassment which may perhaps be a valuable achievement in itself.
Let us know how you go,
Cheers, Glen