AEBN raised concerns over the full cost recovery from MHF sites for the operational costs of the government’s MHF Unit. Fees of over $50,000 p.a. were exposed as being inequitable and undermining NSW as a state for investment for major facilities. This is in contrast to Queensland which charges no fees and Victoria which costs at least 70% of the proposed NSW fees. AEBN proposes a simple 2 level approach consisting of:
- An initial flat fee set at about half of the average costs
- Estimated additional hours based on an assessment of the MHF site on an annual basis
As an hourly rate will apply to most sites, a cap on the maximum fee levels would also be required to provide confidence that a blank cheque will not be required. Implementation of the MHF regulation should consider the poor progress on the development of all the guidelines and support documentation. A change in the period of grace for MHF implementation is considered appropriate, and AEBN suggests adding 6 month to the time frame.