Guidance for ECA Submissions

Guidance For Input Into ECA Submissions

The ECA is regularly invited to provide input to WA government consultation processes on a variety of policy, guidelines, and strategic direction.  We also participate in stakeholder reference groups on behalf of our members.  The following principles guide our input into these processes:

  1. The ECA’s primary role as a stakeholder is to provide advice on whether policy and guidance material is workable.  As practitioners we have detailed experience in the practical application of policy and guidance and this experience should be used to provide advice to government on the clarity and ease of use of any policy and guidance.  Submissions should therefore address the following questions:
    a.     Are requirements clear? Are there any aspects of the guidance that could create confusion?
    b.     Are the requirements overly prescriptive?  Do they allow for innovation and continual improvement?
    c.     Are requirements fair and reasonable?
    d.     Could there be unintended consequences?
    e.     Does guidance sufficiently cover all scenarios?
    f.      Is the information presented likely to achieve the stated objectives?
  2. The ECA membership includes technical experts that can also provide specific advice around the technical content of policy and guidance.  Therefore, submissions may address the question; Is the scientific basis of the policy and guidance technically sound?
  3. ECA submissions should not advocate either for, or against, development.  ECA members represent a broad cross section of the political spectrum and members are welcome to make individual submissions on these issues.
  4. ECA submissions should not be based on single project issues.  Case studies are welcome, but only where they provide an example of a broader issue.
  5. All ECA submissions will be made available to the ECA membership and may be made public.
  6. ECA will not always provide a submission when invited.  The decision on whether to prepare a submission will be made by the Committee based on the level of interest from members.
  7. The ECA Committee should approve all submissions made on behalf of the ECA, with regard to this guidance.

The above guidance is based on relevant aspects of the ECA’s Charter, Code of Conduct and other relevant Policy and Guidance.  This should be used by the ECA members and Committee when making submissions on behalf of the ECA.