Issues Paper by chenmeixiu


									   Issues Paper

Inquiry into Victoria’s tourism

    Victorian Competition and Efficiency Commission
                     October 2010

About this issues paper                                             ii
1 About this inquiry                                                 1
    1.1 Who should participate?                                     2
2 The Victorian tourism industry                                    3
    2.2 Contribution of the tourism industry to Victoria            4
3 Regulatory barriers to the development of the tourism industry   11
    3.1 The impact of regulation on the tourism industry           11
    3.3 Priorities for future regulatory reform                    15
4 Opportunities to improve the management of State assets          16
    4.1 What are the ‘state assets’?                               16
    4.2 Public land                                                16
    4.3 ‘Built’ state assets                                       19
5 Aviation policy                                                  19
    5.1 Importance to Victoria                                     20
    5.2 Aviation policy and regulations                            20
    5.3 Scope of issues                                            22

ISSUES PAPER                                                         I
About this issues paper
The aim of this issues paper is to assist those wishing to provide input into the inquiry into
Victoria’s tourism industry. While not intended to limit comment, this paper outlines the
Commission’s preliminary views about the scope of the inquiry and the key issues.
Participants are invited to consider the issues and questions outlined in this issues paper in
preparing written submissions and providing input in other forms.

Key inquiry dates
Submissions due                                                       10 December 2010
Consultation                                               October 2010 to February 2011
Draft report released for further consultation                             February 2011
Draft report submissions due                                                   April 2011
Further consultation on the draft report                                April - May 2011
Final report to government                                                      June 2011

For further information please contact:
Administrative matters                               Ms Robbie Taylor ph: (03) 9092 5800
Other matters                                            Jason Knight ph: (03) 9092 5823
Facsimile                                                                 (03) 9092 5845
Email address                                         

Written submissions should be sent to:

Victorian Tourism Inquiry
Victorian Competition and Efficiency Commission
GPO Box 4379
Melbourne Victoria 3001
Or emailed to:

II                                                    INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
1               About this inquiry
Tourism is a major generator of economic activity in Victoria’s cities and regions,
contributing around five per cent of gross state product and a similar percentage of total
employment. Improving economic conditions in Australia and in the major new
international market of China bode well for the future growth of the industry.
The tourism industry faces a number of major challenges that combined, place a premium
on maintaining a stable and low regulatory burden on tourism businesses. The Victorian
industry faces competition from overseas and interstate tourism destinations and more
recently has been buffeted by the global financial crisis, global terrorism and health threats
and the appreciating Australian dollar.
The State Government and the industry have developed a long term plan for the
development of Victorian tourism. This plan identifies several challenges, including the
need for new private sector investment to cater for the growing demand.
Deficiencies in the way government regulates or manages its assets can impose unnecessary
costs on businesses and impair their ability to compete for interstate and international
tourists and investment. Removing such unnecessary costs improves the competitiveness
of Victorian tourism businesses without undermining the benefits that regulation and other
policies are intended to deliver. This inquiry is about identifying and removing such
unnecessary barriers.
The terms of reference1 note the Victorian Government’s role in supporting the tourism
industry through the provision of quality infrastructure, good road and air access and
strong marketing of Victoria’s attractions, and direct the Commission to focus on three key
(1) State and local regulatory barriers to the development of the tourism industry and the
    creation of new tourist infrastructure.
(2) Opportunities to improve the management of state assets to better meet the needs of
    the tourism industry without compromising their primary management objectives.
(3) The impact of international and domestic aviation policy on the Victorian tourism
    industry and broader economy.
The Commission understands that these terms of reference require a focus on
impediments to the supply of tourism services, underpinned by an understanding of the
demand for those services.
At this stage the Commission anticipates that it will not focus on State Government
involvement in infrastructure investment, support for marketing and events, and
development and maintenance of Victoria’s reputation and brand. The Commission would,
however, reconsider this view if presented with evidence that these areas of State
involvement are impeding the development of Victoria’s tourism industry, and it can be
demonstrated that the issues fit within the terms of reference.

1   The terms of reference are available on the Commission’s website

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The terms of reference note that the Commission’s inquiry is to complement and not
duplicate work undertaken by Commonwealth and State Tourism Ministers under the
auspices of the Council of Australian Governments. In 2009, the Australian Government
released a National Long-Term Tourism Strategy which outlined a set of policy initiatives
designed to facilitate the growth of the tourism industry.2 The Strategy identified facilitating
investment and regulatory reform as one of several priority issues for Federal, State and
Territory governments.
Are there any other substantial studies or developments that the Commission should consider?

1.1           Who should participate?
The inquiry will be of interest to a variety of people and organisations, including:
     tourism businesses (including small and medium size businesses) affected by State or
      local government regulations
     industry and other associations with an interest in the Victorian tourism industry
     local councils and bodies representing councils and their employees
     not-for-profit and community organisations
     government departments and their agencies (including regulatory bodies), especially
      those involved in the tourism industry
     public policy analysts, academics and individuals with an interest in the tourism
      industry or tourism regulation.
The Commission is seeking written submissions from interested individuals and
organisations. Submissions may cover all or some of the issues described in this issues
paper. While the Commission will consider submissions received throughout the inquiry,
submissions in response to this issues paper are invited by 10 December 2010.
Anyone intending to make a submission or merely wishing to be kept informed of progress
should complete the Registration of Interest Form provided on the Commission’s website: The website will be regularly updated to include information on the
consultation process, copies of publications relevant to the inquiry and public submissions.

    How to make a submission
    Anyone may make a submission (in written, electronic or audio form) to the
    Commission. All public submissions will be posted on the Commission’s inquiry
    website and to facilitate this, an electronic version of written submissions (by email or
    on CD) is preferred.
    The Commission develops policies in the light of the Charter of Human Rights and
    Responsibilities Act 2006 (Vic) which recognises that human rights are essential in a
    democratic and inclusive society. It welcomes submissions that draw attention to the
    human rights implications of issues raised in the inquiry. Of particular relevance to

2 Department of Resources, Energy & Tourism, National Long-Term Tourism Strategy (Commonwealth

Government of Australia, 2009).

2                                                            INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
    this inquiry are the cultural rights of Aboriginal persons to the land and waters and
    other resources with which they have a connection under traditional laws and
    The Commission has a strong interest in promoting informed debate on the issues
    arising in its inquiries and accordingly wishes to publish the submissions it receives to
    the greatest extent possible. Nonetheless, materials may be submitted in confidence.
    They must be clearly marked ‘CONFIDENTIAL’, either in part or in full, and
    provide an explanation of the reason for claiming confidentiality. If the Commission
    feels that a claim for confidentiality has not been substantiated, it will contact the
    author to discuss the reason for the claim. If the discussion does not resolve the issue,
    the Commission will return the submission to its author. Confidential materials that
    are accepted will be read only by Commissioners and Commission staff and will not
    be referred to in the Commission’s report.
    The Commission publishes on its website all written submissions unless a claim for
    confidentiality is justified or, in its discretion, the Commission considers that
    publication is not in the public interest. This could be because a submission may be
    defamatory or otherwise unlawful or reflect on an individual or organisation in a way
    the Commission considers an abuse of the process. Contact details will be removed
    from submissions before they are uploaded to the website.
    The Commission's documents, including the unpublished submissions it accepts, are
    subject to the Freedom of Information Act 1982.

2              The Victorian tourism industry
Unnecessary regulation creates an additional cost burden that can reduce the
competitiveness of Victorian businesses. Inadequate regulation or poorly managed state
assets can erode Victoria’s attractiveness to private sector investment, detract from visitor
amenity, and damage Victoria’s reputation. Inappropriate aviation policy can disadvantage
the whole industry by making it more difficult and costly for visitors to get to Victoria,
especially from overseas.
This section sets out a working definition of the ‘Victorian tourism industry’ to help
identify relevant stakeholders and the areas of local and state regulation that are relevant to
the industry.

2.1            The structure and contribution of the tourism
The tourism industry covers a diverse and interlinked set of activities, markets and
participants. The Commission will adopt as a starting point, the standard definition of
‘tourism’ as:
        … the activities of persons travelling to and staying in places outside their usual
        environment for not more than one consecutive year for leisure, business and other

ISSUES PAPER                                                                                    3
           purposes not related to the exercise of an activity remunerated from within the
           place visited. 3
While this definition encompasses a wide variety of activities, the focus of the inquiry will
be guided by key regulatory barriers, discussed in section 3.
In practice, defining the tourism industry is difficult. Many businesses provide goods and
services that are bought by both tourists and residents. Businesses that primarily serve
locals, but are still important to tourists, may not associate themselves with the tourism
industry. People also visit Victoria for a range of reasons, which are not mutually exclusive
(for example business, leisure, visiting friends and family, and education). The industry
therefore consists of many varied types of business and overlaps with many parts of the

2.2             Contribution of the tourism industry to Victoria
On a range of measures, tourism is a significant source of income and employment in
Victoria. In 2007–08, the tourism industry was estimated to account directly for:
       3.2 per cent (or $8.6 billion) of the total value of goods and services produced in
       employment of around 105 000 people.4
It is estimated that tourism indirectly5 contributed a further $7.2 billion in 2007–08 to the
Victorian economy, bringing the total (direct and indirect) contribution to $15.8 billion,
representing 5.9 per cent of the total value of goods and services produced in Victoria.6
Within Victoria, Melbourne and surrounds is a key destination for international and
domestic visitors, although around 50 per cent of total expenditure by domestic visitors
occurs in regional Victoria.7

3OECD, Tourism satellite account recommended methodological framework (Luxembourg: Commission of the
European Communities, 2001), 1.
4 Tourism Victoria, Victorian Tourism Workforce Development Plan 2010-2016 (Government of Victoria, 2010), 6.

Based on Sustainable Tourism Cooperative Research Centre 2009: Tourism satellite accounts 2007-08:
summary spreadsheets.
5 ‘Indirect effects occur through flow-on effects to industries which do not themselves have direct contact
with the visitor but nonetheless supply goods and services attributable as tourism consumption. While direct
effects are considered to be the most appropriate measure for comparing the economic contribution of
tourism with other non-tourism industries, the aggregation of tourism’s direct and indirect effects contribute
to a fuller understanding of flow-on effects of tourism to output and employment within other industries, and
across the economy generally.’: Daniel Pambudi et al., Tourism satellite accounts 2007-08: summary spreadsheets
(Gold Coast, Qld: CRC for Sustainable Tourism, 2009), 2.
6   Tourism Victoria, Economic contribution of tourism to Victoria 2007-2008, November 2009, 1.
7   Tourism Victoria, Regional Tourism Action Plan 2009-2012 (Government of Victoria, December 2008), 41.

4                                                                  INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
2.3              Victoria’s tourism industry
In Victoria, output and employment in the tourism industry is distributed across a wide
range of sectors. Businesses operating in these sectors are all potential stakeholders in this
Figures 2.1 and 2.2 show the composition of tourism output and employment for 18
product and 14 workforce sectors. Major supplier sectors include long-distance transport,
takeaway and restaurant meals, accommodation, and shopping. Major employment sectors
include retail, accommodation, cafes/restaurants, education and ‘other’. Services growth
has been an important part of the Victorian economy, and a substantial portion of the
tourism industry is highly service-oriented (labour intensive).

Figure 2.1                      Composition of Victorian tourism output 2007–088

                                             Motor vehicle maintenance 1%
                                                  Motor vehicle hire 1%     Taxifares 1%
                                                                                Vehicles 1%
                                                 Local transport 1%
                                     Travel agency services 2%

                             Gambling and betting 2%                                            Long distance transport 15%

                Recreation, culture, sports 3%

            Rent on holiday houses 4%

                       Other 4%

              Education 5%

                                                                                                                       Shopping 15%

              Beverages 5%

                           Fuel 7%

                                                                                                 Takeaw ay and restaurant meals
                                  Food products 8%                                                           15%

                                                                   Accommodation services 10%

8   Tourism Victoria, Victorian Tourism Workforce Development Plan 2010-2016, 6.

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Figure 2.2                              Composition of Victorian tourism employment
                                                                          Casinos and gambling 1%
                                                                                Rail transport 1%
                                                                 Other entertainment 2%
                                                       Museums, arts, libraries 2%
                                                 Travel agency services 3%

                                             Pubs, clubs, bars 5%

                                                                                                                        Retail 24%

                             Air and w ater transport 5%

             Road transport and vehicle hiring 5%

                              Manufacturing 8%

                                                                                                                         Accommodation 13%
                                             Education 9%

                                                                                                            Other 12%
                                                                    Cafés, restaurants 10%

Tourism is a discretionary spending item for consumers and Victoria is competing with
many other tourist destinations in Australia and elsewhere for domestic and international
visitors. While attractions based on well-known assets—such as the Great Ocean Road—
are important, it is notable that the Government has stated that Victoria’s tourism ‘assets
are our sophistication, diversity and reputation for cosmopolitan and cultural
In its 10 Year Tourism and Events Industry Strategy the State Government identified the
following key strengths of the Victoria tourism industry:
        distinctive, consistent and well-targeted advertising highlighting Victoria’s diversity
         within a compact area
        lifestyle experiences associated with Melbourne’s theatres, shopping, world class
         restaurants, cafes, bars and nightlife; as well as Victoria’s ranking as a ‘great place to
         tour by car’, and for ‘boutique wineries’
        regional tourism opportunities arising from Victoria’s diversity, compactness and good
         road networks

9    Ibid.
10Department of Innovation, Industry and Regional Development, 10 Year Tourism and Events Industry Strategy
(Government of Victoria, October 2006), 12.

6                                                                                                   INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
        attractions such as major sporting, cultural and business events
        capacity on direct inbound flights and recent increases in the number of international
         airlines flying directly to Melbourne
        a strong tertiary education sector which has helped to attract large numbers of
         international students.11
The policy setting to enhance the competitiveness of Victoria’s tourism industry should
take into account all these advantages.

2.4               Key characteristics of the industry
Businesses in the Victorian tourism industry cater to visitors who differ by their origin,
purpose of visit, and interests.
Around one third of all visitors to Victoria are interstate or international visitors, yet they
account for two-thirds of total expenditure.12 This does not mean intrastate visitors are
unimportant to the Victorian economy. Around 34 per cent of the industry’s value of
output can be attributed to intrastate visitors. However, increasing the lengths of stay (of
international visitors) and spends per night (of interstate visitors) are considered the key
drivers of Victoria’s growth in visitor expenditure.13
In the year to 30 June 2010, the main purpose of visit for domestic overnight (interstate
and intrastate) and international visitors to Victoria were for holidays or leisure (figure 2.3).
Visiting friends and relatives and visiting for business were the next two most common
purposes for visiting. Notably, business travellers account for a larger proportion of
interstate visitors than intrastate and international visitors. Almost 10 per cent of
international visitors were in Victoria for the purpose of education.

11   Ibid., 9.
12   Ibid., 11.
13   Ibid.

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Figure 2.3                 Domestic (interstate and intrastate) overnight
                           visitors and international visitors to Victoria by
                           purpose of visit (year ended 30 June 2010)14
                          Other, 5%                                                           Other, 3%
                                                            Other, 5%
                                                                                            Employment, 2%

        90%                                               Business, 11%                     Education, 10%

                        Business, 28%
                                                                                             Business, 16%

        70%                                            Visiting friends and
                                                          relatives, 33%

        60%                                                                               Visiting friends and
                                                                                             relatives, 23%
                     Visiting friends and
        50%             relatives, 31%



                                                          Holiday, 51%
                                                                                             Holiday, 46%
                        Holiday, 37%


                         Interstate                        Intrastate                        International

Table 2.1 highlights the most popular activities for domestic overnight visitors and
international visitors to Victoria. International visitors to Victoria, when compared with
international visitors to Australia generally, were more likely to visit markets, museums or
art galleries, history or heritage buildings, sites or monuments, botanical or other public
gardens and go to the casino.15

14Tourism Research Australia, International visitors in Australia: quarterly results of the international visitor survey
(Canberra: Commonwealth Government of Australia, 2010), 17; Tourism Research Australia, Travel by
Australians: quarterly results of the national visitor survey (Canberra: Commonwealth Government of Australia,
2010), 12.
15   Tourism Victoria, Victoria Market Profile - Year Ending December 2008, 2009, 5.

8                                                                       INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
Table 2.1                Top 15 activities of visitors to Victoria (% of
Rank Domestic Overnight Visitors                  % International Visitors                 %
1           Eating out at restaurants             55 Eating out at restaurants             68
2           Visit friends and relatives           44 Sightseeing/looking around            59
3           Go shopping (pleasure)                28 Go shopping (pleasure)                48
4           General sight seeing                  25 Go to the beach                       28
5           Pubs clubs discos etc                 22 Pubs clubs discos etc                 26
6           Go to the beach                       18 Go to markets                         23
7           Going to markets (street, weekend      9 Visit national parks or State parks   20
            or art craft)
8           Bushwalking or rainforest walks        8 Visit museums or art galleries        17
9           Visit national parks or State parks    7 Visit historic buildings / sites      17
10          Visit museums or art galleries         6 Visit botanical or other public       17
11          Attend an organised sporting event     6 Visit casinos                         14
12          Go on a daytrip to another place       6 Visit wildlife parks / zoos /         13
13          Go fishing                             5 Bushwalking or rainforest walks       10
14          Play other sports                      4 Attend Movies/Cinema                  10
15                                                    Go on guided tours or excursions      9

The terms of reference notes that the Victorian Government plays a significant role in
supporting the tourism industry. However, it is critical to recognise that some important
determinants of industry performance are beyond the influence of the Victorian
Firstly, the industry is highly sensitive to external factors including global volatility,
exchange rates, security and terrorism, health scares, and other crises (such as drought,
floods and bushfires).
Secondly, the tourism industry has also been undergoing dramatic change. For example, the
number of overnight visitors from China has grown from 38 584 in 1999 to 160 150 in
2008, representing an average annual growth rate of around 17 per cent.17 The introduction
of low-cost airlines and cut-price domestic airline tickets has also made interstate and

16   Ibid., 3, 5.
17   Ibid., 4.

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international travel more affordable, increasing access by non-Victorians to Victoria’s
tourism offerings but also travel by Victorians to other destinations.
Thirdly, there is strong competition from overseas and other Australian tourism
destinations to meet changing consumer preferences. The Victorian Government has
stated that:
           … competition for the tourism and events dollar is fierce and tourists are becoming
           increasingly discerning, constantly in search of new experiences and better standards
           of service. 18
Changing consumer preferences are driving business re-orientation leading to, for example,
increasing specialisation in the accommodation and hospitality markets, such as growth in
niche accommodation, food and entertainment offerings.19 New online technologies are
giving consumers more information, empowering them to purchase directly when selecting
destinations and booking travel, making quality and value for money more transparent and
important for businesses.20
The Commission seeks further input on the key characteristics of the Victorian tourism
industry to assist in understanding how regulation, the management of state assets and
aviation policy in particular, impact on the future development of the sector.
What are the key supply and demand side factors that will influence the future development of the industry
in Victoria? Given these trends, how is the competitiveness of Victoria's tourism industry being affected by
the State government in roles as a regulator (of businesses and more generally), as a manager of ‘state assets’
and as an advocate for aviation policy reform?
As a starting point, the Commission proposes to adopt the broad statistical definition of
the relevant markets for this inquiry, including a wide range of inter-linked products and
services that is consumed by visitors to Victoria and/or produced by Victorian businesses.
Some types of visitors and issues may be outside the realm of what is normally considered
tourism, such as students. At this stage the Commission is treating travel to Victoria by
students as outside its terms of reference, but is open to contrary views and evidence.
Should the Commission adopt a definition of tourism that emphasises holidaymakers and leisure travel (in
accordance with the common understanding of tourism) or should it adopt the broad ‘visitor based’ definition
of tourism (such as those in tourism satellite accounts) which include visitors such as business travellers and

18 Department of Innovation, Industry and Regional Development, 10 Year Tourism and Events Industry
Strategy, 7. Furthermore, the tourism industry is said to be ‘competing not only against overseas travel options
but also against a range of other consumer activities and products.’
19   IBISWorld, Tourism in Australia, Industry Report X0003, August 2010, 11-12.
20   Tourism Victoria, Regional Tourism Action Plan 2009-2012, 6.

10                                                                  INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
3              Regulatory barriers to the development of
               the tourism industry
The terms of reference require the Commission to examine State and local regulatory
barriers to the development of the tourism industry and the creation of new tourism
infrastructure, particularly in localities with substantial growth potential.

3.1            The impact of regulation on the tourism industry
A variety of State and local government regulations21 apply to the operation and
development of tourism businesses in Victoria. The Commission has identified nearly 50
State Acts that may apply to the development and operation of tourism businesses. These
cover areas such as land-use planning, development and use of public land, public health
and safety, and transport. Attachment 1 which provides a list of the principal relevant Acts
is located on the Commission’s website (
Few of the identified areas of regulation are directed solely at tourism, with most applying
to a wide range of individual and business decisions. These broad areas of regulation are
intended to deliver benefits to the community, such as higher standards of public safety,
improved amenity and environmental quality, improved coordination between various land
uses and infrastructure investment, protecting biodiversity and protecting sites of
significant cultural, heritage or environmental value. Whilst particular areas of regulation
may have an impact on tourism businesses, the cumulative impact of multiple areas of
regulation also needs to be recognised.
Given the large number of regulations applying to businesses in the tourism industry, the
Commission intends to focus on areas providing the biggest opportunities for reducing
regulatory burdens without undermining the objectives of the regulations. The
Commission’s early consultations with participants have identified several areas of
particular concern for business:
     Some tourism groups consider that land-use planning regulation and its administration
      is a major barrier to the future development of tourism in Victoria.22 Issues identified
      include the complexity and timeliness of approval processes, as well as specific
      provisions affecting tourism accommodation contained in land-use zones and
     The Tourism and Transport Forum considers that building standards applying to
      hotel accommodation and serviced apartments impose unnecessary construction and

21 Regulation could be defined to encompass government-sanctioned rules and instruments that affect the

behaviour of businesses and individuals. Regulations include primary legislation (Act) and subordinate
legislation (Reglation), but codes of practice, guidelines and standards or procedures set by regulators are also
important forms of regulation.
22 Victoria Tourism Industry Council and Victoria Events Industry Council, Victoria's Tourism and Event
Industry Strategy 2020, September 2010, 33.

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        operational costs on hotel developments, and also distort the incentives to invest in
        these two forms of accommodation.23
       Businesses in the accommodation, cafe and restaurant sectors must comply with food
        safety and liquor licensing regulations and with signage and outdoor dining
        requirements of councils. Dining out is one of the most common activities for visitors
        to Victoria, and there may be scope to reduce unnecessary costs to businesses
        associated with State and local government regulation.
       Transport regulation, and specifically taxi and hire car regulation, is a concern for
        some visitors to Victoria. One study reported that tourism demand accounts for about
        17 per cent of taxi industry revenue in Victoria.24 The taxi and hire car industry is
        heavily regulated in Victoria, and the form of regulation and its administration may be
        unnecessarily adding to the transport costs of visitors to Victoria.
The impact on the tourism industry of regulations relating to public land such as national
and state parks is discussed separately (section 4).
Problems with the design or implementation of regulation can impose several types of
unnecessary cost on tourism businesses and the community generally. For instance,
unnecessary delays in regulatory processes can impose holding and other costs on business.
Unnecessarily strict conditions attached to approvals can also impose costs, and in extreme
cases, deter investment. The design or administration of regulations may also create
uncertainty about the rules or conditions that might apply to new tourism developments,
which can also discourage investment. Some of these unnecessary costs may be felt more
acutely by small businesses, due to their limited ability to spread such costs across a large
customer base.
The impact on tourism businesses of State and local regulation and its administration may
depend on several factors:
       The types of activities undertaken by tourism businesses (for example, whether the
        business provides accommodation, and sells food and alcohol, whether it operates on
        private or public land, and whether it operates tours or provides transport services).
        Box 3.1 summarises the regulatory obligations and direct costs involved in opening a
        bed and breakfast operation in Hepburn Shire.
       How well various State regulators work together in administering regulation. A
        number of state regulators are likely to be important to the tourism industry including,
        the Departments of Planning and Community Development, Environment and
        Sustainability and Transport, as well as state agencies such as Parks Victoria and the
        Environment Protection Authority.
       Given that councils often play a key role in administering State and local regulations,
        issues of coordination between State and local governments may also be important.
       Although the terms of reference refer to State and local government regulation, the
        Commonwealth Government may also regulate some activities undertaken by

23 Tourism and Transport Forum, “Productivity Commission Annual Review of Regulatory Burdens:

Tourism Submission,” February 2010, 8.
24   Essential Services Commission, Taxi Fare Review 2007-08: Final Report, August 2008, 57.

12                                                                INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
       Victorian tourism businesses. The inquiry provides some opportunity to highlight
       areas of Federal regulation that could be improved, particularly in the area of aviation
The Commission invites participants to identify the main areas of state and local regulation that are
impeding the development of the tourism industry and the creation of new tourism infrastructure. Given the
number of regulations applying to tourism businesses, what are the priority issues and why?
In what ways is State and local regulation affecting the development of the tourism industry? To what extent
are any problems caused by the regulations or their administration by State and local governments?
To help understand the impact of state and local regulations on the tourism industry, the
Commission intends to undertake a number of case studies. Participants are invited to
provide examples of tourism business activities, including the development of tourism
infrastructure, which have been impeded or enabled by state and local regulation.

   Box 3.1            Opening a bed and breakfast business25
   In the final report of an inquiry into the impact of regulation on regional economic
   development, the Commission reported on the regulatory obligations and costs of
   opening a number of different types of business. One example, relevant to tourism
   involved opening a bed and breakfast (B&B) operation in the Hepburn Shire.
   The State and local government regulatory obligation identified included:
         registering a business name
         registering for GST and an ABN
         obtaining a planning permit
         registering for WorkSafe
         registering as a food premises
         registering as a prescribed accommodation
         obtaining a liquor licence
         obtaining a signage permit.
   In 2005 the Commission estimated that the up-front costs of meeting these
   regulatory obligations (time cost plus any fees and charges) would total around
   $2 100. In addition, there could be additional costs such as holding costs associated
   with delays in approval processes, the costs of time spent on routine inspections, and
   the costs of making modifications to the B&B that are necessary to meet licence or
   registration conditions.

3.2            Efforts to address regulatory burdens
Recognising that State and local government are continually seeking to identify and address
problems with regulation and its implementation, the Commission intends to have regard

25 VCEC, Regulation and Regional Victoria: Challenges and Opportunities, Final Report (Melbourne: Victorian

Competition and Efficiency Commission, June 2005), 460-467.

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to recent reforms to areas of regulation relevant to tourism. Where these reforms fall
within the terms of reference they will be taken as dealing with the matters covered by the
reforms, unless the Commission considers circumstances have changed since the reforms
were made, or new information has come to light. Examples of initiatives developed or
implemented in Victoria include reforms to regulations (in areas such as land-use planning
and food regulation), investment in regional strategic planning to identify growth
opportunities and threats, actions aimed at improving state and local government
coordination, and investment facilitation by government agencies to help businesses
navigate regulatory approval processes.
Other jurisdictions have also been looking at ways to eliminate unnecessary regulatory
barriers to the development of the tourism industry and the creation of new tourism
infrastructure: for example, in the context of the National Long-Term Tourism Strategy
endorsed by the Tourism Ministers' Council and the actions under the Work Plan.26 The
Commission invites input on approaches in other jurisdictions that have been tried and the
benefits and costs of these initiatives.
Are there examples in other Australian jurisdictions where regulatory barriers to the development of the
tourism industry and the creation of new tourism infrastructure have been successfully identified and
addressed? What lessons, if any, are relevant for Victoria?
Finally, although there may be regulatory barriers to the development of the tourism
industry and the creation of new tourism infrastructure, other factors may have a much
bigger impact on the future development of the industry in Victoria. Some of these factors
were outlined in section 2.3 above. Industry surveys provide conflicting evidence on the
significance of regulation as an impediment to the future development of the Victorian
tourism industry. A recent survey of 100 tourism and tourism-related businesses in Victoria
asked businesses to identify the importance of various issues perceived as constraining
business performance during the August quarter, 2010. According to the survey:
           State Government regulation was identified as a ‘significant’ or ‘critical’ constraint
           by 31 per cent of respondents. Respondent sentiment was similar across the State,
           with 30 per cent of metropolitan respondents, 29 per cent of regional respondents
           and 32 of rural respondents highlighting it as a constraint. 27
The survey also identified local government regulation as a constraint for tourism
businesses, with 25 per cent of respondents indicating that local government regulation
represented a significant or critical constraint.
On the other hand, a recent report on the tourism industry by IBISWorld argued that the
level of regulation surrounding tourism activity is varied across industry sectors (with
airlines an example of a highly regulated industry), but that it is low compared to other
industries. The report also identified a trend of increased regulation in areas such as liquor
licensing.28 This highlights the importance of placing the existence of regulatory barriers in

26   Department of Resources, Energy & Tourism, National Long-Term Tourism Strategy.
27    Victorian Tourism Industry            Council,   “Survey   of   tourism   performance   and   outlook
August quarter 2010,” August 2010.
28   IBISWorld, Tourism in Australia, 28.

14                                                               INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
a broader context of the various factors likely to affect the future development of the
tourism industry.
Compared with the other factors influencing the development of the tourism industry, how important are
regulatory barriers?

3.3                Priorities for future regulatory reform
There have been several national and state attempts to identify and address regulatory
barriers to the tourism industry. The National Long Term-Tourism Strategy, for example,
identified opportunities to support the development of Australia's tourism industry. One
identified priority was facilitating regulatory reform to ensure Australia remains
internationally competitive.29 The Strategy also proposed establishing an Investment and
Regulatory Reform Working Group, comprising Commonwealth, State and Territory
officials and Chaired by Tourism Victoria, to develop a work program for identifying and
addressing regulatory reform priorities. Specific priorities that were subsequently identified
by the Working Group included:
        a review of regulatory barriers to identify key priorities
        preparation of a report demonstrating whether tourism investment faces particular
         disincentives arising from the Australian regulatory framework
        development of tourism definitions for planning schemes to assist development
In Victoria, a recent industry reform agenda jointly released by the Victorian Employers'
Chamber of Commerce and Industry (VECCI) and the Victorian Tourism Industry
Council called for the State Government to:
        Commit to an ongoing reduction in the planning and regulatory burden to support the
         vibrancy and diversity of the tourism and events industry, particularly small businesses.
        Address current barriers to private sector investment by improving the transparency
         and timeliness of applications and reduce administration and related business ‘search’
        Assess the viability of enhanced ‘series licences’ to reduce the need for and cost of
         multiple licences for single activities or events, and where repeat licences are needed
         for regular events or activities.
        Review OH&S regulations as they relate to event construction to ensure that only
         relevant events or event staff are incorporated in the definition of ‘construction’,
         therefore reducing the regulatory burden on organisers of low risk events.30
Where are the opportunities for reducing the regulatory burdens on the tourism industry? How would they
impact on tourism businesses and the community more broadly, and on the effectiveness of the regulations?

29   Ibid., 8-9.
30  Victorian Chamber of Commerce and               Industry,   “2010    State   election:   the   tourism
and events industry agenda,” September 2010.

ISSUES PAPER                                                                                          15
4             Opportunities to improve the
              management of State assets
The terms of reference require the Commission to report on opportunities to improve the
management of state assets to better meet the needs of the tourism industry without
compromising their primary management objectives.

4.1           What are ‘state assets’?
The term ‘state assets’ is not defined in the terms of reference, but could be defined
broadly to include publicly owned assets or ‘tourism infrastructure’ in the following
    Environmental or ‘natural’ assets, such as Victoria’s national parks, marine parks and
     reserves and visitor facilities (e.g. the Great Ocean Road, Phillip Island, Port Phillip
     Bay, Wilson’s Promontory, the Grampians, the High Country, the Otways).
    Built or ‘hard’ assets, such as Victoria’s transport infrastructure (airports, major roads,
     rail, and ports), convention centres, stadiums, tourist precincts, zoos, museums,
     galleries and theatres. Many of these assets are also built on public land.
    Intangible or ‘soft’ assets, such as Victoria’s tourism ‘branding’ and other intellectual
     property, investments in reputation and goodwill (e.g. Brand Victoria, Destination
     Melbourne, the ‘Jigsaw’ campaign), and certain major events.
    Institutions or ‘public partnership’ assets, such as Tourism Victoria, the collaborative
     network of regional, state and national tourism organisations that market destinations,
     facilitate investment, undertake research, develop policy and strategy, and coordinate
     local tourism industry initiatives.
In principle, public assets are provided or managed by the state because of market failure
or some social or environmental policy objective. For the purposes of item 2 of the terms
of reference, the Commission will focus primarily on the tangible assets—both ‘natural’
and ‘built’—that are owned or managed by the state.
What are the ‘natural’ and ‘built’ state assets that are most important for the Victorian tourism industry?
How will the management of these state assets affect the development of Victoria’s tourism industry?

4.2           Public land
Nature-based tourism is perceived to be an important and growing area for the tourism
industry in Victoria:
        Nature-based tourism is an important subsector. According to estimates generated
        by Ernst and Young on behalf of Parks Victoria, nature-based tourism generates

16                                                            INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
            $2.6 billion per year (GSP), and 41,200 jobs (one quarter of Victoria’s total tourism
            Nature-based tourism is a growth market in Australia, but Victoria lags
            competitively. Victoria has the natural assets to compete effectively in this segment
            but requires infrastructure investment, investment attraction and product
            development, as well as advertising and promotion.32
How the Victoria Government manages its assets in the form of public land, which
accounts for around 40 per cent of Victoria’s land area, can clearly have a significant impact
on the development of Victoria's tourism industry.
Public land is all land owned and controlled by the State of Victoria. Uses of public land,
including by the tourism industry, are governed by a complex array of primary legislation
and regulation. This regulation establishes types of public land such as national and state
parks, wilderness parks, state forests, alpine resorts, crown land reserves, coastal crown
land reserves, metropolitan parks and coastal waters.33 Uses of public land are regulated to
achieve economic, environmental and social objectives, such as:
        ensuring biodiversity
        providing ecological services
        conserving remnant natural environments
        safeguarding places of cultural significance
        providing recreational and health benefits to the public
        enabling indigenous people to maintain their connection to the land
        providing resources for the community (such as timber products).
There are trade-offs among these different objectives. Many of the destinations that are
attractive for tourism activities and ventures in Victoria are located on public land. These
tourism activities therefore depend on access to provide recreational and other activities to
tourists, and in some cases, to build infrastructure such as accommodation. Such activities
may be prevented or restricted by current policy or regulation. Current policy, for example,
provides that:
            … major new tourism facilities to service visitors to national parks and other areas
            managed under the National Parks Act 1975 will be sited outside the parks except
            where … there is community and stakeholder support. Any such facilities within
            national parks will be owned and developed by the Government. On other public
            land a range of approaches to deliver major recreation and tourism facilities will be
            considered including: development and operation by Government; development

31 Victoria Tourism Industry Council and Victoria Events Industry Council, Victoria's Tourism and Event
Industry Strategy 2020, 6.
32   Ibid., 33.
33In addition, activities and developments on public land may also be subject to Victoria’s planning system
including, for example, the provisions governing clearing of native vegetation.

ISSUES PAPER                                                                                           17
           and operation by private sector tenants; joint ventures; or a combination of these
Several government organisations are responsible for advising on policy and the
administration of regulations relating to public land. The Department of Sustainability and
Environment (DSE) is the main steward of the various types of public land in Victoria,
including crown land reserves, state forests, unreserved crown land, national parks, state
parks and marine parks and sanctuaries. Parks Victoria is responsible for managing
protected areas such as national, state, wilderness and other parks as specified in the
National Parks Act. These assets total more than 4 million hectares (about 17 per cent of
A recent report by the Transport and Tourism Forum pointed to several infrastructure and
regulatory constraints that may limit the potential development of nature-based tourism,
       the quality of physical infrastructure such as car parks, roads, trails, viewing platforms,
        signage and other facilities to support visitation
       regulatory constraints such as restrictions on visitation capacity and investment in
        visitor facilities, nature-based attractions and accommodation.35
DSE (Public Land Division) has commenced a review of Sustainable Recreation and
Tourism on Victoria's Public Land Policy.36 The Commission will consult with DSE on
issues relevant to the terms of reference.
What are the key issues for the tourism industry in relation to the management of existing state natural
How, if at all, do Victoria's arrangements for managing public land advantage or disadvantage state
tourism activities relative to other jurisdictions?
What processes are in place to assess the economic, environmental and social trade-offs arising from the
development of tourism infrastructure on different types of public land? Is there scope to improve these
processes and if so, how? Are there examples of innovative processes in other jurisdictions that could be
applied in Victoria?
What would be the advantages and disadvantages of greater involvement of private sector and not-for-profit
organisations in the development and management of the State’s natural assets? What barriers exist to such
involvement and how do they affect the tourism industry? What would be the advantages and disadvantages
of removing these barriers?
Are there opportunities to improve the management of public land that would benefit the tourism industry
without undermining the primary management objectives? What experience in Australia or elsewhere can
usefully inform an assessment of improvement opportunities?

34Department of Natural Resources and Environment, Policy for Sustainable Recreation and Tourism on Victoria's
Public Land (Government of Victoria, 2002), 10.
35   Tourism and Transport Forum Australia, “Tourism Infrastructure Policy and Priorities,” October 2008.
36Department of Natural Resources and Environment, Policy for Sustainable Recreation and Tourism on Victoria's
Public Land.

18                                                              INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
4.3              ‘Built’ state assets
The state owns and, in some instances, manages built assets that form important parts of
the tourism supply chain. These include, for example, airports and transport linkages,
convention and exhibition centres, heritage and cultural buildings, cruise shipping facilities,
park and reserve facilities, public precincts, attractions and recreation assets.
There are different mixes of private and public ownership and management in these types
of assets. While accommodation is predominantly privately owned and managed, the
provision of public assets can provide the necessary supporting infrastructure for tourism
accommodation investment and development. According to the Tourism and Transport
Forum, for example, ‘Public investment in convention and exhibition infrastructure is
critical to providing certainty for private investment in supporting city accommodation and
venue space.’37 Similarly, the industry is said to rely on built assets such as stadiums,
museums, heritage sites, urban parks and precincts to ‘provide the infrastructure for
tourism attractions’ and ‘the platform for events, exhibitions and tourism drawcards which
are typically operated by the non-government and private sector’.38 Inefficiencies in the
way these assets are managed (including, for example, how well they are operated and
whether they are adequately maintained) can have negative impacts on Victoria’s tourism
Consistent with the approach to ‘natural’ state assets, for the purposes of item 2 of the
terms of reference, the Commission proposes to focus primarily on the management of
existing state built assets, rather than the development of new state assets.
What ‘built’ state assets are of most importance for the Victorian tourism industry? In what areas is the
management of built state assets having an adverse effect on the development of the tourism industry? What
alternative models for state ownership and management of these assets that might be considered to better
serve the tourism industry, without compromising benefits to the broader community?

5                Aviation policy
The terms of reference require the Commission to report on ‘the impact of international
and domestic aviation policy on the Victorian tourism industry and the broader economy,
and any implications for policy positions that the Victorian Government might adopt in its
own right or present to the Commonwealth Government’. Given the important role that
aviation plays in the Victorian economy, implications for other sectors of the economy will
need to be taken into account by the Commission in responding to this term of reference.

37   Tourism and Transport Forum Australia, “Tourism Infrastructure Policy and Priorities,” 4-6.
38   Ibid., 6.

ISSUES PAPER                                                                                          19
5.1               Importance to Victoria
Given the geographic characteristics of Australia it is no surprise that aviation plays a key
role, not only in the tourism industry (where 99 per cent of inbound tourists arrive by air39)
but also in the broader economy through its role in the transportation of time critical goods
across state and national boundaries.
Melbourne airport is Australia's second largest airport40 with around 24.5 million
passengers travelling through the airport in 2008–09. Of this, 20 per cent (4.8 million) were
international passengers, 61 per cent (15.1 million) inter-capital passengers and 19 per cent
(4.5 million) regional passengers. Passenger movements have increased annually by 5.7 per
cent since 1991–92 due to a combination of the introduction of low-cost domestic
passenger services and the opening of new domestic routes to and from Melbourne. By
2029–30 passenger movements through Melbourne airport are forecast to increase to 57.7
million.41 Avalon (with over 1 million passengers using the facility each year), Essendon,
Mildura, Moorabbin and Portland also contribute to the movement of passengers. Inbound
passengers to selected Victorian airports are shown in table 5.2.
Does international aviation policy impede the development of the Victorian tourism industry? If so, how
does it impede the industry and which areas are most affected?

Table 5.2                 Inbound passengers to selected Victorian airports
Airport                  Inbound domestic        Inbound regional        Inbound international   Total inbound
Melbourne                      9 524 720                  293 182                  2 445 566      12 263 468

Mildura                            16 041                  78 079                           0          94 120
Moorabbin                                 0                  6 347                          0           6 347
Portland                                  0                  5 740                          0           5 740

5.2               Aviation policy and regulations
Current aviation policy is reflected in the National Aviation White Paper,43 which brings
together such matters as:

39Department of Infrastructure, Transport, Regional Development and Local Government, National Aviation
Policy White Paper: Flight Path to the Future, 2009, 31.
40   It is also Australia's only curfew free international airport.
41 Bureau of Infrastructure, Transport and Regional Economics (BITRE), Report 117: Airport movements through
capital city airports to 2029-30, April 2010, 38.
42Regular public transport operations only: Bureau of Infrastructure, Transport and Regional Economics
(BITRE), “Airport Traffic Data 1985-86 to 2008-09 (xls format),” 2009.
43 Department of Infrastructure, Transport, Regional Development and Local Government, National Aviation

Policy White Paper: Flight Path to the Future, 2009.

20                                                                    INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
       aviation safety
       security
       international, domestic and regional aviation
       industry skills and productivity
       consumer protection
       airport infrastructure (including economic regulation)
       aviation emissions and climate change
       noise impacts.
The terms of reference refer specifically to ‘international and domestic aviation policies’,
which operate under different regulatory arrangements.
   International aviation is governed by a series of bilateral treaties between various
    governments, which determine the level of market access for countries’ respective
    airlines. Air service agreements set out such things as the number of flights that the
    airlines of two countries can operate, cities that they can serve, and rights to operate
    within the other country.44
   In 1990 the Australian Government amended the regulation of domestic aviation by
    abolishing the long-standing ‘two airlines policy’, which had regulated capacity, fares
    and routes flown on all interstate services. Domestic aviation is now serviced by four
    interstate carriers––Qantas, Jetstar, Virgin Blue and Tiger Airways.45
The Australian Government is responsible for air navigation, aviation safety and security,
and regulates the planning approval process for leased federal airports, including
Melbourne. Key legislation supporting these roles are:
       Air Navigation Act 1920 (Cth) (which gives affect to the 1944 Convention on
        International Civil Aviation)
       Airports Act 1996 (Cth)
       Airspace Act 2007 (Cth)
       Air Services Act 1995 (Cth)
       Aviation Transport Security Act 2004 (Cth)
       Civil Aviation Act 1988 (Cth)
       Civil Aviation (Carriers’ Liability) Act 1959 (Cth)
Other institutions that play a key role in the aviation industry are listed in box 5.2.

44 Department of Infrastructure, Transport, Regional Development and Local Government, National Aviation

Policy Green Paper (Canberra: Commonwealth Government of Australia, December 2008), 99.
45   Ibid., 121.

ISSUES PAPER                                                                                        21
     Box 5.2        Institutions
        International Air Services Commission –– the Commission determines the outcomes
         of applications by existing and prospective Australian airlines for capacity and
         route entitlements available under air services arrangements. These
         determinations allocate the available capacity on a route to one or more carriers
         and set conditions, where these are considered appropriate. In allocating
         capacity, the Commission assesses the merits of claims by applicants under
         specified public benefit criteria. These criteria are detailed in Policy Statements
         issued, from time to time, by the Minister. (
        Civil Aviation Safety Authority (CASA) –– CASA's primary function is to conduct
         the safety regulation of civil air operations in Australia and the operation of
         Australian aircraft overseas. It is also required to provide comprehensive safety
         education and training programmes, cooperate with the Australian Transport
         Safety Bureau, and administer certain features of Part IVA of the Civil Aviation
         (Carriers' Liability) Act 1959 (Cth).
        Airservices Australia –– a government-owned corporation providing safe and
         environmentally sound air traffic control management and related airside
         services to the aviation industry. (
        Australian Competition and Consumer Commission (ACCC) –– responsible for
         administering a number of measures under the Airports Act and the Trade
         Practices Act 1974 (Cth) (including arbitrating access disputes where airports are
         declared services / facilities). These responsibilities include prices monitoring,
         quality of service monitoring and collecting and publishing information on
         financial performance. The ACCC is also responsible for assessing proposals by
         Airservices Australia to increase charges for terminal and en route navigation
         services as well as aviation rescue and fire fighting services. The ACCC has no
         specific role in relation to airlines. However, the general provisions of the Trade
         Practices Act apply to airlines. (
The Victorian Government does not have a significant role in the direct regulation of the
aviation industry. However, for those airports not owned by the Commonwealth46 the
Victorian Government advises airport operators and local governments on the appropriate
use of the Victorian planning provisions covering aerodrome environments.

5.3          Scope of issues
International aviation policy, together with domestic and regional aviation policy (and
associated regulatory arrangements) is likely to play an important role in both the Victorian
tourism industry and broader economy. The importance of international aviation policy is
highlighted in the Victorian Government’s 10 Year Tourism and Events Industry Strategy,
which states:

46 Key Victorian airports are owned by the Commonwealth, the Department of Defence and by local


22                                                     INQUIRY INTO VICTORIA’S TOURISM INDUSTRY
        70% of Victoria’s tourism growth over the next decade is forecast to come from
        international markets, so increasing the number of direct international flights to
        Melbourne is obviously crucial to our tourism success.47
Increasing the number of international flights into Victoria also increases the capacity to
export and import goods to and from overseas markets, which can assist in the future
growth of the Victorian economy. Air service agreements and the process for negotiation
of these agreements appear to be an important area in which the Commission should focus
its inquiry.
To what extent do air service agreements or other Commonwealth aviation policies impede the growth or
potential growth of Victoria’s tourism industry? Which of these policies are responsible for this and how do
they affect the industry?
How significant is the impact of these policies on the industry?
What is the rationale for these policies and how could their adverse impact be eliminated or reduced?
The capacity of airports to accommodate future growth in passenger numbers will affect
the tourism industry. However, recent research suggests that airport capacity may not be a
key issue that is currently adversely impacting on the tourism industry in Victoria.48
The Commission currently considers that airport capacity is unlikely to be a key focus of its
inquiry into international and domestic aviation policy. However, it may reconsider this
view if it is presented with evidence that suggests that this is an area that warrants further
There may be other aspects of aviation policy that could be considered in the context of
the Commission’s inquiry. However, several issues (in addition to ‘access to priority
international markets’ and ‘pursuit of open skies policy’) have recently been considered in
the development of National Aviation Policy including:
   recognition of other users of aviation services (e.g. air freight, regional development,
    community services)
   aviation emissions
   importance of regional airports and associated funding arrangements
   federal, state and local government planning integration
   appropriate zoning of developments close to airports which are compatible with
    airport operations.
The Victorian Government provided a submission as part of the development of the
National Aviation Policy. Key aspects of the Victorian Government submission are
provided in box 5.3.

47Department of Innovation, Industry and Regional Development, 10 Year Tourism and Events Industry Strategy,
48 S Driml et al., Tourism investment in Australia: a scoping study (Parkwood, Qld: CRC For Sustainable Tourism,

2010), 37.

ISSUES PAPER                                                                                                23
     Box 5.3           Victorian Government submission to National
                       Aviation Policy Issues Paper49
     The submission to the National Aviation Policy Issues Paper by the Victorian
     Government focused on several key areas.
        International air services. The negotiation of bi-lateral air service agreements and
         whether negotiation priorities are sufficiently integrated with broader trade and
         investment priorities was raised as an issue. The importance of greater
         engagement with international multilateral aviation groupings to promote
         regional liberalisation was also raised.
        The regional package. It was noted that Avalon airport should be granted
         ‘Regional Package’ status that would place Avalon on equal footing with other
         gateways that have internationally capable regional airports complementing
         capital city airports.
        Airport planning and development. The submission cover land use planning and
         the development approvals at major airports, non-aeronautical development on
         airport sites, future airport needs (Melbourne, Avalon and regional airports), air
         traffic management, customer and community protection (noise and curfews)
         and consultation.
     Disability standards, aviation security, skills and training and emerging technologies
     were other areas covered by the Victorian Government submission.
What should the Victorian Government be doing to eliminate or reduce any adverse impacts of aviation
policy on the tourism industry?

49 Government of Victoria, Submission by the Victorian State Government, National Aviation Policy Statement, Issues

Paper, July 2008.

24                                                                INQUIRY INTO VICTORIA’S TOURISM INDUSTRY

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