University of Canberra

Name (Individual/Organisation)

University of Canberra

Responses

Q10. Having regard to the Review’s Terms of Reference, the ARC Act itself, the function, structure and operation of the ARC, and the current and potential role of the ARC in fostering excellent Australian research of global significance, do you have any other comments or suggestions?

University of Canberra welcomes the independent review of the Australian Research Council Act 2001 (the ARC Act) and is pleased to make a submission.

This review is an opportunity for clarity around this important component of Australia’s research landscape.

We are a member of Universities Australia (UA) and support the position set out in Universities Australia’s submission on this matter. University of Canberra has participated in discussions through membership of the Deputy Vice-Chancellor Research group within Universities Australia.

We are a member of the Innovative Research Universities (IRU) and have provided input to their comments.

In this submission we have considered the consultation paper and emphasise key points and areas of concern regarding the Australian Research Council (ARC).

Scope, purpose and governance of the ARC
• UC is supportive of amendment of the ARC Act to clarify the role of the ARC
• UC believes that the ARC’s scope should be restricted to being a primary funder of non-medical research being undertaken by universities and their partner organisations, spanning both basic and applied research.
• As the only funding body that explicitly funds discovery or fundamental research, UC believes that it is essential that the ARC continues to maintain a high proportion of funding in Discovery and DECRA projects.
• UC advocates for the complete discontinuation of ERA. The benefits of the ERA process are indirect and obscure, whilst the costs of undertaking the review exercise are large. ERA preparation has a particularly large burden on smaller universities. While ERA results recognise research excellence, they do not further facilitate or support those areas of excellence, in contrast to similar exercises elsewhere (e.g., UK, NZ). Alternative methods (world university rankings) are now available to provide recognition of excellence at both institution and discipline level, beyond the ARC’s remit of Australia.
• If it is deemed necessary to have assessment of the impact and engagement of research, then UC recommends that this be carried out by an agency/process with the necessary resources and expertise to undertake such an exercise. It is noted that the ARC does not have these resources and expertise. We note also that the ARC contributes a small and decreasing proportion of the total research income for the university sector (18% in 2001 and 14% in 2020), and Category 1 funding (42% in 2001 and 36% in 2020) and accordingly consideration should be given to whether the ARC (suitably resourced) is the best organisation to be engaged to undertake this exercise.
• UC supports UA’s recommendation for the re-establishment of an ARC Board which is advisory to the CEO.
• UC supports UA’s recommendations for amendments to the ARC Act to strengthen the role of the CEO, bringing it in line with the NHMRC in relation to protections relating to appointment, performance, and termination of the CEO.
• UC believes that research track-record should be an important consideration in the appointment of the ARC CEO.

National Interest Test (NIT) and Ministerial veto
• UC supports the proposals from both UA and IRU for protection of the integrity of basic research to be enshrined in legislation in a manner akin to the Haldane principle in the UK.
• UC believes that the Ministerial power of veto should be discontinued. One reason often promulgated for the inclusion of Ministerial veto is national security. However, working with national security agencies and the current UFIT mechanisms, ARC could ensure that any such matters are considered prior to or during the peer review process.
• UC appreciates the changes to the NIT process as indicated in the December 1 announcement. However, the nature and purpose of the NIT remain unclear. A strong indication of this is that some 78% of projects funded across the four most recent ARC programs having been requested to revise their NIT statements, with more than half being asked to do so multiple times. Is the NIT to assist in the peer review process, or is it a public facing statement that can provide assurance of the quality and value of research being funded through the ARC? Along with the IRU, UC advocates for the latter purpose only. Accordingly, UC recommends that the NIT be removed from ARC applications and that the peer review of benefit be conducted as previously. Discovery research must be funded purely on research excellence. Following the peer review process, a statement akin to the NIT for public dissemination would be required for the funded projects only.
• Including the review of impact of previous (ARC) funded research in the evaluation of new funding applications contributes to providing assurance that high-quality research and researchers are receiving funding.

Grant processes
• UC strongly agrees with UA’s comments regarding the onerous nature of the ARC funding process, noting the nature of the application process and the low grant application success rate. We strongly support consideration of a two-stage application process akin to that in operation for New Zealand’s Marsden Fund.
• UC supports the IRU request that all selection report data be made available to applicants at all stages of the process. This data is already available and making it available to applicants will increase transparency in the process and assist in improving the quality of research applications.
• UC supports the investigation of a model for funding the full cost of research but only in the context of increased funding being available and not resulting in fewer research projects being funded.

Other Comments
• UC supports the IRU’s suggestion to increase support for post-doctoral researchers, perhaps through reconfiguration of the DECRA program and/or re-examining the previous ARC Australian Postdoctoral Fellowship scheme.

Submission received

14 December 2022

Publishing statement

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