Fire service funding submission

October 29, 2003

Reframing Responsibility: the insurance industry’s attempt to “free-ride” on NSW taxpayers

FBEU submission to the
NSW Parliamentary Inquiry into
Fire Service Funding


The Committee has been tasked with preparing a report that evaluates both the current fire service funding arrangements in NSW and possible alternative funding arrangements. These recommendations are required to meet the current and prospective needs of the fire services and as far as possible be cost neutral. They are also required to look at implementation issues and any administrative and compliance issues associated with such recommendations.

Fire service funding arrangements have differing impacts across the community, as do fire services themselves. Discussions on fire service funding arrangements inevitably raise the question: who benefits from the provision of fire services and are these beneficiaries financially liable for the fire services that are provided to them? Upon analysis, it is obvious that different arrangements (or models) have a varied impact on the equity of the funding arrangements, on the proper development of fire services and also the provision of services to the community.

Following a review of interstate arrangements and the pros and cons of various models, the view of the State’s professional firefighters is that funding responsibilities for fire services in NSW should remain with the Insurance Companies and the State Government. However one change to current arrangements is proposed: that Local Governments in NSW should no longer be required to make direct financial contributions to fire services. It is the Union’s view that this and other slight corrections to the existing model will properly target funding responsibilities and maintain high levels of equity and transparency.

The Inquiry’s Terms of Reference provide a useful framework for discussing the issues involved in fire service funding. Before explicitly addressing those Terms of Reference, it is useful to briefly discuss the current systems of funding used by the NSW Fire Brigades and the NSW Rural Fire Service and to outline various methodologies for funding fire services.

Current Funding Arrangements

NSW Fire Brigades

The current approach to fire service funding has been in place since the enactment of the Fire Brigades Act 1884 (NSW). Broadly speaking, prior to this legislation, insurance companies and local government provided and funded fire services in Sydney and some large country centres. The 1884 Act consolidated these services and funding arrangements. It did this by establishing a Board made up of nominees from the insurance companies, the State Government, local councils and a member of one of the volunteer brigades. Insurance companies were relieved of the need to provide fire services directly to the community. They were however required to keeping paying for the clear and unambiguous benefit they received from such services. The funding was split equally between the insurance companies, the state and local governments (ie. 33% each ‘group’)

In 1927, the ratio of contributions was changed – insurance companies were required to contribute 50% of the cost of the aggregate expenditure requirements for any given year. Local Councils were required to make contributions of 25% towards the aggregate expenditure requirements for their respective fire districts. The State Government made contributions for the remaining 25%. In 1949, the rate of contribution was again changed to 75%, 12.5% and 12.5% respectively.

The NSWFB funding arrangements today reflect the incremental development of the previous patterns. Insurance companies are required to contribute 73.7% of the cost of the aggregate recurrent expenditure requirements and the aggregate capital expenditure requirements for any given year. Each insurance company’s contribution is relative to their market share. The majority of insurers choose to pass on such costs to their policyholders in the form of a ‘Fire Service Levy’ rather than absorb these levies as a general cost to the industry.

Local Councils are required to make contributions of 12.3% towards the recurrent and capital expenditure requirements for their respective fire districts. The NSW Government contributes the remaining 14% of recurrent and capital expenditure requirements from consolidated revenue.

Rural Fire Service

Prior to the Bush Fires Act 1949 (NSW) funding of bush fire brigades was ad hoc and relied largely on local government direct support and limited grants from the State Government.

With the introduction of the Bush Fires Act 1949 (NSW), a Bush Fire Fighting Fund was established which essentially paid for the operation of the Bush Fire Committee and Bush Fire Brigades. Insurance companies were required to contribute 50% of the cost of maintaining the Fund. Local Councils were required to make contributions of 25% of the cost of maintaining the Fund for their respective areas. The State Government contributed the remaining 25%. Local Governments also had a major role in servicing equipment and providing other financial support.

The Bush Fires (Amendment) Act 1993 (NSW) changed the funding arrangements for Bush Fire Brigades. It changed the ratio from those stated above to contributions of 73.7%, 12.3% and 14% respectively. More recently with the further centralisation of bush fire services under the Rural Fire Service, the ratios were set at 73.7%, 13.3% and 13% (current contribution rates).

In summary, the long term trend has been for the insurance industry to make the majority of contributions to the maintenance of fire services in NSW.

Approaches to Fire Service Funding

There are a number of different methods that can be used to collect funds to provide for fire services. The main methods are:

Insurance / Government Funding Approach

This approach is largely reflected in the current system, whereby insurance companies and government bear the costs of fire services. The relative shares can of course vary.

Government Funding Approach

Fire services can be funded through the provision of funds from general government revenues.

Service Delivery Approach

Under a service delivery approach (often erroneously labelled as a service expectation model), a levy is applied to all properties at a flat rate within different areas delineated by the level of service which is deemed to be provided.

Valuation Property Based Approach

Levies, using this approach, are determined in relation to the value of the property to which they apply. (i.e. higher valued properties pay a higher fire service levy).

Risk Based Property Approach

This model applies a levy based on risk classifications of each property and has different levy rates according to the level of risk. This aligns those who are deemed to be most likely to use the fire services with contributions.

Mixed Approach

Some jurisdictions have systems that combine the above funding systems. For example in Western Australia, their system combines a Valuation Property Based Approach and a Service Delivery Approach.

What is the best fire service funding arrangement for NSW?

The Union recommends that the current Insurance / Government Funding Approach should be maintained in NSW. However, the Union acknowledges that changes to fire service operations dictate that the role of local government contributions should be reassessed. The Union proposes that local government should discontinue funding the NSW Fire Brigades and the NSW Rural Fire Service and that the “shortfall” should be made up by the State Government (18%) and the Insurance Industry (82%). The reasons for doing so are elaborated on throughout this submission.

Changes also need to be made to how the insurance industry represents the contributions that they are required to make to policyholders. They currently show on premium notices a Fire Service Levy associated with each policy. Yet this is a self imposed nomenclature which cynically attempts to reframe a cost of business as a tax on individual policyholders. More disturbingly, monies collected as these so called “fire service levies” are not necessarily passed on to the Government to fund the fire services. This problem was identified by the Robson Report in 1994 and again by the Victorian Review earlier this year. Indeed as the later review identified, the Fire Service Levy in Victoria and NSW is not set by any legislation or by government fiat: rather it is set and imposed by the Insurance Council of Australia itself so as to represent a cost of doing business as a tax.1

Accordingly, the legislative arrangements should be changed to either restrict the insurance companies from re-labeling a cost of business as a targeted tax or, if they do identify a proportion of the premium to cover contributions (whatever the label), that all such payments must be separately accounted for. Insurance companies should then be required to forward either their required contribution as determined by legislation or the amount identified above, whichever is the greater.

Notwithstanding that current arrangements (as modified above) do not allow the key beneficiaries (ie. insurance companies & the State Government) from “free-riding”, the Union does acknowledge that ad-hoc free-riding may occur where non insured persons receive fire protection. Accordingly, a regime of charging could be explored for non-insured property owners, which may in turn encourage them to insure.

Matters to be Considered when Evaluating Different Fire Service Funding Arrangements

Under Section 3 of the Terms of Reference, the Committee is required to consider a number of matters when evaluating different fire service funding arrangements. These matters are outlined below and are accompanied by a brief discussion of each point as appropriate.

Impact of current and proposed funding arrangements on decisions by households and businesses to insure (3.a.)

A number of self interested players in the fire service funding debate have suggested that the current Insurance / Government Funding Approach reduces the demand for insurance, as the contributions that insurance companies are required to pay for fire services force them to apply a fire service levy on policyholders which adds to the cost of insurance and therefore reduces demand for such services. They suggest that this in effect compounds the “free-rider” problem.

It is the Union’s considered view that current and possible fire service funding arrangements have little effect on decisions by individuals and businesses to insure. We put this to the Committee on the following basis:

(a) The primary motivation for individuals and/or businesses to insure is to protect against financial loss in the event of some specified and agreed event (eg. fire, theft, loss of business continuity, etc). Economic actors do not focus on one part of a supplier’s cost structure that determine their price (premium). For example they do not disaggregate wages, taxes, fire service contributions, rent or indeed profits when making a decision to consume a service – they look at the overall cost.

(b) The more abundantly self interested submissions received by the Committee will argue that if the yoke of the “fire service levy” is lifted from the insurance industry, that this group will significantly reduce the premium burden on policyholders. Such an assertion should be tested against both historical experience and recent changes to and events in the insurance industry:

(i) In 1994, Ex Minister for Emergency Services, the Hon. T. Pickering expressed strong misgivings to Parliament about the Insurance Industry’s ability to pass on savings to their policy holders. After discussing some cost saving measures introduced within the fire services he told the House:

“At the same time, because of the funding formula, that reduced the charge against the insurance company [sic]. For three years I reduced the charge against the insurance industry while it increased its charge premiums to the community by about 40 per cent [sic]. I gave that game away as a waste of time, and created within the fire brigade movement a slush fund, or a hollow log as it is often referred to, rather than allow the insurance industry to use this mechanism to increase its charges against the community.”2

The Robson Report came to similar conclusions.

(ii) The demutualisation or privatisation of most insurance companies has introduced an added cost to the industry, that of generating profits for investors. The need to generate same will mitigate against the companies lowering premiums with the abolition of their requirement to properly contribute to fire services.

(iii) the Government Insurance Office of NSW no longer exists as a market correcting mechanism to regulate excess profit taking by the insurance industry. In the absence of such a market correcting device, the Government has no ability to even attempt to influence insurance companies to pass on any savings.

(iv) the “sirens song” of the Green Slip reforms and the insurance industry’s performance in supposedly passing on savings to taxpayers is there for all to judge.

Funding approaches adopted in Queensland and South Australia and soon to come into effect in Western Australia as well as the findings of the Victorian review of fire service funding (3.b.)

Queensland, South Australia and Western Australia have moved (or are in the process of moving) away from the system of fire service funding that currently exists in NSW. Victoria after an extensive and well-considered review looked at the experience in these other States, rejected such approaches and recommitted itself to its current system (which is similar to NSW).

Queensland, South Australia and Western Australia now base their fire service funding approaches on service provision, property valuations or multivariate risk assessment. The Union, after assessing the various options, considers that such approaches suffer from a multitude of flaws.

Firstly, these approaches fail to collect a contribution from the two biggest financial beneficiaries of fire services: the insurance industry and the State Government (who is also the largest self insurer in the State). The Insurance Industry and Government are at the forefront of complaining about free-riders under the current system. No doubt the Committee will be told of the need for wholesale change to the current system on the basis of this problem. Yet any system that moves away from the fundamentals of the Insurance / Government Funding Approach will create a system that has built in large scale free-riders: any change to fire service resourcing must logically lead to a reduced risk for insurance companies. As a consequence, if the insurance companies do not fund this resourcing, then they themselves inevitably become free-riders. Anyone suggesting that they will mitigate their free-ride by passing on those savings to policy holders should bear in mind the Hon. T. Pickering’s criticisms of the Insurance Industry, the Robson Report and the industry’s general reputation for avarice (as discussed above). The State Government is in a similar position, it being the largest property owner in the State and a self-insurer.

In the above circumstances, it is much more logical public policy making to iron out problems of ad-hoc free-riding under the current system rather than create systemic free-riding by the two biggest beneficiaries (financially) of fire services. Rather obvious solutions include economic sanctions against non-insurers (as used in Victoria) and for the NSW Government to review its policy of providing large cash grants to the (deliberately) uninsured after large scale bushfires for what amounts to political gain. This would send the right signals to the community with regards the necessity of insurance (and therefore reduce free-riding). It also gets around the obvious inequity of the uninsured whose property is destroyed in small scale emergencies (ie. one house burning down) receiving nothing whilst a similar uninsured house that is burnt down in a large scale bushfire conflagration is publicly bestowed tens of thousands of dollars.

Secondly, these other approaches fail to take into account measures that insured property owners take to protect their property. Currently, insurance premiums reflect protective measures taken by policyholders. Under fire service funding approaches based on service expectations, property valuations or some multivariate risk assessment, such prudent citizens pay the same levy as more thoughtless persons.

The recent review of Victorian Fire Service Funding Arrangements, 2003 recognised such dysfunctional possibilities:

“It also reduces efficiency because there is less incentive for owners of high fire-risk assets to manage those risks. Most low risk properties that are fully insured are likely to pay significantly more under a uniform rate property levy”.3

Whilst there has been some criticism of the Insurance / Government Funding Approach because of the potential for free-riders, this problem is exacerbated in other systems. In addition to giving the Insurance Industry and Government a free-ride, approaches based on property values give a whole class of citizen a free-ride: persons renting residential, commercial or industrial property do not contribute to the upkeep of fire services, unlike the current system whereby persons with contents insurance indirectly contribute via their insurance company’s contributions. Free-riders are an aberration under the Insurance / Government Funding Approach and can be managed through education (and in some jurisdictions, economic sanctions such as in Victoria). As described above, free-riders are built into other approaches, which by its very nature can only lead to dysfunctional outcomes in terms of equity and efficiency.

Administrative efficiency is another important consideration. The current arrangements are already in operation and are well understood by the insurance industry and persons administering the system. By removing local government from contributing to the fire services, administration will be even simpler. On the other hand, levies imposed via the other approaches necessarily involve the creation of new bureaucratic mechanisms, quite often involving the State imposing arcane and arbitrary distinctions between citizens and their properties. In South Australia administration costs have soared – between 10-12% of revenues collected are being lost in collection costs.4

If such a revenue / collection cost ratio applied in NSW, it would deny the State funds equivalent to the cost of maintaining most permanently manned fire stations in regional NSW.

For example, in Queensland, each property is classified by usage and location. Local Government is required to therefore assess each property and classify it with a particular charging code chosen from the hundreds outlined in numerous administrative guides. The administrative awkwardness of such an approach is revealed by the provision for additional collection fees to be charged by local government for undertaking this role. The potential for such arrangements to be twisted into income generating arrangements is illustrated by the NSW Local Government Association’s recent rather cynical change of heart with respect to collecting fire levies as an agent of the State Government. After opposing a levy of households in the mid 1990s, this year they proposed:

“[…] that councils collect the fire services property levy on a fee for service basis. Based on the experience in other states the commission would be expected to be in the range of 4% to 5%.”5

Implications of any changed fire service funding arrangements for the role of local governments in funding and facilitating the provision of fire services, particularly in rural NSW (3.c.)

Unlike the insurance industry, Local Government in NSW does not stand out as a significant beneficiary of fire services. It has never been involved in the NSW Fire Brigade operations and in more recent times has taken a back seat to the NSW Rural Fire Service in terms of the operations of bushfire brigades across the State. The relatively recent transfer of Fire Control staff from Local Government to the Rural Fire Service exemplifies this move away from Local Government involvement and control.

As a consequence of these changes, Local Government (and therefore ratepayers) should be relieved of directly contributing to the costs of running the State’s fire services. The nexus between fire service funding and local government is an historic nexus only. This sharply contrasts with the strong nexus between insurance companies and fire service funding and the obvious need for State Government involvement as discussed below.

State government’s contribution to funding the fire services (3.d.)

Clearly as the primary financial beneficiary of fire services, the insurance industry should be the main financial contributor to fire services in NSW. However, the State Government should also be required to make direct contributions on the basis that it is the largest property owner in the State and it acts as a self insurer. If the State Government used the services of insurance companies to insure its various assets, then it could be argued that all of the burden should fall with the insurance industry. Countering that latter view is the compelling argument that the State Government has a clear responsibility to represent the collective needs of the people of NSW through the provision of fire and other emergency services. Those many needs range from a more stable investment environment to a safer and therefore more secure populace.

Modelling of the impact of the proposed funding arrangements on taxpayers to assist in determining proposed funding arrangements (3.e.)

On the assumption that Local Government will pass on to ratepayers the savings generated by its removal from funding fire services, then that reduction will more than offset the impact on taxpayers of the additional cost of the Union’s proposed increase in the State Government’s contribution rate.

Non consideration of general taxation issues such as the GST and stamp duty on insurance unless these issues affect the operation of fire services funding arrangements (3.f.)

The only comment that the Union wishes to make on this issue is to reject the assertion that consumers are being taxed on a tax on a tax, with respect to contributions that insurance companies are required to make under the Fire Brigades and Rural Fires Acts. These required contributions are not a tax on individual policy holders. Rather they represent a general cost of doing business for the insurance companies.

Outcomes Required from Proposed Fire Service Funding Arrangements

In the Terms of Reference, the Treasurer also identified some broad outcomes that he wanted to achieve from any proposed funding arrangements. First, he wanted to ensure, to the maximum extent possible, that all those that benefit from the provision of fire services contribute to funding the fire services (4.a). To broadly match funding contributions to the level of service provided to the taxpayer and/or the risk of fire affecting each taxpayer was another desired outcome (4.b.). He further requested that any proposed funding arrangements would be difficult to avoid through changed taxpayer behaviour (4.c.) and would provide a stable base for funding fire services (4.d.).

Maximise the extent to which those that benefit from the provision of fire services contribute to funding the fire services (4.a)

As indicated in the above discussions, the dominant beneficiary of fire services in NSW is the insurance industry and its constituent companies.

This is not surprising. Up until 1884 all fire brigades set up in NSW were funded and managed by insurance companies acting collectively. Indeed the last insurance brigade (the Salvage Corp) was not abolished until a few years before World War I.

In his major work on demand for fire services in Sydney, Dr Colin Adrian stated:

“A more viable and less costly alternative by which the individual can express his demand for fire protection is in an indirect manner: the purchase of insurance against fire loss and damage. […] An additional advantage for the majority of the community is that premiums are based on the degree of fire risk that individuals and properties represent. […] A further advantage which may accrue to the individual is that some portion of his contribution to fire insurance companies may result in improved fire protection. […] Fire insurance company profits represent the difference between premiums collected and monetary compensation paid out, and thus, to the extent that fire services prevent loss and damage, monetary compensation is minimised and profits maximised.”6

After pointing out that insurance companies funded 75% of fire services through contributions, which represented 15%-25% of their premium income, Adrian continues:

The extent of this funding reinforces that the most dominant, direct ‘demander’ of fire protection is not the individual nor the community but rather fire insurance companies. Whilst monetary compensation can never totally recompense for the loss of life, treasured and sentimentally-valued belongings, much of the community’s demand for fire protection is appeased by the comfort of a fire insurance policy. This, when looking at the demand side, fire insurance companies have a direct monetary incentive for involvement and influence on the spatial provision of fire services.”7

More recently, the Victorian Department of Treasury and Finance (2003) reaffirmed that the insurance industry was the primary beneficiary of fire services:

“Insurers benefit from the extinguishment and containment of fires as this directly reduces insurance payouts, and from greater certainty when assessing fire risk. The longer term impact of reduced fire losses, resulting from the provision of fire services, directly benefits the commercial returns to insurance companies. The benefit is realised through their capacity to price fire risk at a lower rate and thus improve the affordability of insurance policies.”8

After briefly touching on the historic role of Victoria’s insurers as fire service providers they state:

“The benefit to, and nexus between, insurers and the Fire Services remains today.”9

Of all the possible approaches, the only one that provides any nexus between fire service funding and the insurance industry is the Insurance / Government Funding Approach. All of the systems that levy individuals or businesses turn the insurance companies into free-riders: primary beneficiaries of fire services without any requirement to contribute to their funding. Put simply, the nexus between fire service funding and the insurance industry cannot be broken without giving the primary beneficiary a free-ride at the direct expense of the taxpayers (and voters) of NSW.

Broadly match funding contributions to the level of service provided to the taxpayer and/or the risk of fire affecting each taxpayer (4.b.).

As indicated in the previous section (4.a), the primary beneficiaries of fire services are the insurance companies operating in NSW. As such, focusing on individuals and businesses (ie. taxpayers) skews the focus away from them and inevitably produces a system that in turn delivers disturbing inequities (ie. the primary beneficiaries get a free-ride) and an appalling lack of transparency (ie. the primary beneficiaries are not even part of the system).

As such we call on the Committee to concentrate on 4.a, as a focus on taxpayers as direct contributors will lead to dysfunctional public policy outcomes and give the insurance industry a free-ride.

Proposed funding arrangements should be difficult to avoid through changed taxpayer behaviour (4.c.)

Whilst acknowledging that there are issues with ad hoc free-riders under the current Insurance / Government Funding Approach, it must be said that these minor flaws can be fixed with limited modifications to the current system so as to avoid individuals / businesses not making any direct or indirect contribution to fire service provision.

However, the question has to be asked: Why would you adopt a system of fire service funding that let the primary beneficiary of fire services (ie. the insurance industry) completely avoid any contributions rather than simply address the relatively minor and ad hoc problem of non insurers under the existing system? This was the issue that faced the recent Victorian Review: they chose the latter, more equitable approach notwithstanding the plethora of self interested tracts that were submitted by the Victorian insurers and so called ‘community alliances’ that they had created.

Provide a stable base for funding fire services (4.d.)

As indicated previously, systems that rely on the levying of taxpayers have hefty administrative costs, as high as 10-12% in South Australia. High administrative costs can only be a destabilising influence on the fire service funding base.

The current system in NSW on the other hand is very stable in that is has been incrementally developed over almost 120 years. Furthermore its low administrative costs only add to this stability.10

Funding Major Bushfires (5.)

The Committee was tasked with considering appropriate funding arrangements for meeting the extraordinary costs associated with fighting major bushfires. The Terms of Reference require the Committee to examine the possible development of a fire fighting reserve – funded by a fire service levy – to assist in meeting future extraordinary costs associated with major bushfires.

The Union opposes the setting up of such additional funding arrangements. In the era of risk management and more responsible long term budgeting, its seems odd that the Government would suggest that the NSW Fire Brigades and the NSW Rural Fire Service could not set contributions from insurance companies and government based on long term trends. Notwithstanding the hyperbole that seems to accompany any major urban/bushland interface conflagration, it is possible for the services to make financial and logistic contingency for major bushfires without applying a fire service levy on the general public for that purpose. In recent heavy fire seasons, additional financial burdens have affected the fire services. However, these burdens have come from the ad hoc nature of public policy making in the area (eg. the somewhat panicked utilisation of the Erickson Air-Crane Helitankers). Rather than make the funding system match this level of adhocracy, the decision-making processes should be more systematic and build contingency for large-scale bushfires into the regular policy making and funding processes.

Union Recommendations and Position

As outlined in the section titled “What is the best fire service funding arrangement for NSW?”, equity and efficiency dictate that the current Insurance / Government Funding Approach should be maintained in NSW with the minor change of removing local government from the funding equation. As the insurance industry is the primary and dominant beneficiary of fire services, it should continue to bear its fair share of the burden. As such the Union recommends that the insurance industry should pay 82% of required contributions, with the State Government making up the rest (18%). In other words, the system at worst requires minor tinkering rather than the wholesale reform advocated by various other parties.

Ad-hoc free-riding within the current system can be addressed by giving the uninsured clear signals (ie. economic sanctions and eradicating mixed messages by the Government after major bushfires) rather than replacing it with a system that allows the major financial beneficiaries of fire protection (ie. the Insurance Industry and the State Government) to free-ride on the community. Other levy-based approaches that may be suggested to the Committee will invariably break the nexus between the benefit that insurance companies get from fire services and their funding, as well as leading to overly complex and costly administrative systems.

The Union is not alone in adopting this view. Earlier this year, Department of Treasury and Finance officials in Victoria came to the same conclusion, after considering the views of all interested parties. The Victorian Review has much to recommend it and is endorsed by NSW firefighters.

It should be noted that the Union will stridently resist any regressive attempt to change the current approach to fire service funding that is inequitable and/or that shifts the burden of funding away from it belongs – with the Insurance Industry and the State Government. It will interpret any such development as a de facto poll tax on the citizens of NSW and will actively campaign against it on that basis.

In conclusion, the current “outcry” over the so called “Fire Service Levy” has largely been generated by the sheer avarice of the Insurance Industry operating under the cloak of (self proclaimed) broad based coalitions. There is certainly no clamour for reform by the populace at large. The Union calls on the Committee to look beyond the self interest of those groups calling for change and to maintain the current system which serves the people of NSW well.


1. Robson, K. (1994) Re view of the Funding Arrangements for the Fire Service of New South Wales, unpublished report to the Minister for Police and Emergency Services; Department of Treasury and Finance (Victoria) (2003), A Review of Victorian Fire Services Funding Arrangements, Melbourne, p. v, pp.22-23.)
2. NSW Legislative Council, Hansard, 19 November 1993, p.5769.
3. Department of Treasury and Finance (Victoria) (2003).
4. Parliament South Australia (2003) Final Report Emergency Services levy 2002-2003, p9.
5. NSW Local Government Association (2003) Local Government’s Role in the Provision of Fire Services in NSW – A Discussion Paper, Sydney. P.37.
6. Adrian, C. (1982), Evaluating the Provision of an Impure Public Good: Fire Services in the Sydney Area, PhD Thesis, UNSW, Kensington, pp.93-94.
7. ibid. p.95.
8. Department of Treasury and Finance (Victoria) (2003), p.11.
9. ibid.
10. ibid. p.99. The Victorian Review found administration costs in NSW to be minimal.



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