University of Wollongong

Related consultation
Submission received

Name (Individual/Organisation)

University of Wollongong

Responses

Q1. How could the purpose in the ARC Act be revised to reflect the current and future role of the ARC?

For example, should the ARC Act be amended to specify in legislation:
(a) the scope of research funding supported by the ARC
(b) the balance of Discovery and Linkage research programs
(c) the role of the ARC in actively shaping the research landscape in Australia
(d) any other functions?

If so, what scope, functions and role?

If not, please suggest alternative ways to clarify and define these functions.

The University of Wollongong (UOW) understands that the ARC Act and its implementation are both being considered at this time. Our responses reflect the outcomes we hope to see realised for the Australian research ecosystem now and into the future. Thus we recommend that the Act not become overly prescriptive, but remain flexible and agile.


ENSHRINING FUNDAMENTAL RESEARCH
While the ARC is responsible for funding a broad range of non-medical research, it is the principal source of Australian research funding for basic research. By its nature, research with immediate translational capacity can additionally seek funding from the private sector and investors who expect a short-term return on capital, but basic research is supported only through public expenditure or philanthropy. ARC funding plays a major role in supporting basic research. When such research is initially funded its ultimate applications and impact are often not immediately obvious; however, basic research offers the most profound and largest scale benefits (e.g., laser technology, computers, LEDs, transistor technology, WIFI). Indeed, truly paradigm-shifting advances occur through technologies, science and discoveries that could never have been thought of based on the understanding, knowledge and ideas that we commanded before the basic knowledge underpinning them was created; they are almost entirely incompatible with research based on direct and discernable applications to existing technology. Hence, whilst the balance between Linkage and Discovery is appropriate, it is critical that the ARC returns to a mission that enshrines fundamental research as the primary purpose of the Discovery scheme, and that it revises the extent to which short-term research priorities and tests of benefit are built into its funding model and selection process. This does not need to be incorporated into the Act, but it should be fundamental to the ARC’s missions and objectives.


PRAGMATIC GOVERNANCE
UOW believes that revision of Commonwealth funding agencies should be considered for a number of reasons. Commonwealth funding bodies each retain bespoke application, budget, and management systems that are not integrated. This often leads to double‐handling of information and opportunities for increased processing errors. The fragmentation can cause confusion for researchers and industry, and requires deep expertise on the part of research managers to negotiate the funding landscape.

The UK is an example of a system of research agencies whose missions and objectives support a healthy national research ecosystem. The UK system has one overarching Council: UK Research and Innovation[1], comprising nine broad, Research Councils. Applications are made to the appropriate Research Council using the Joint Electronic Submission System (Je‐S). The Councils have a Cross‐Council Funding Agreement, with structures and systems that enable them to support research across Council boundaries. This allows co-investment on a case‐by‐case basis and reallocation of applications across Councils with minimum additional workload for applicants. This approach also ensures that the Councils’ structures support and encourage interdisciplinary research “to ensure equality of opportunity for proposals at the interface between traditional disciplines, where many of the major research challenges of our time are located.”[2] This in stark contrast to the Australian situation, where our medical research overlap rules jeopardise the eligibility of applications in areas where disciplines (for example engineering) converge with medical sciences[3].

Whilst it may not be possible to wholly replicate the UK Research Council model in Australia, major efficiencies could be gained from increased collaboration between Commonwealth funding agencies, with the explicit aim to reduce the administrative burden on researchers and universities by integrating application processes, co-funding and grant management systems.


RESEARCH INVESTMENT FOR A STRONGER AUSTRALIA
UOW recommends that the ARC, in collaboration with the NHMRC, MRFF, and Higher Education sector, develop a long‐term investment strategy with the goal of significantly increasing the intensity and scale of R&D in Australia, particularly in fundamental, arts and humanities research and early career researchers, as well as across disciplines.

Research, development and innovation are critical to the prosperity of the Australian economy, yet research investment in Australia is lagging (1.8% of GDP versus OECD average of 2.67%[4]), as well as becoming increasingly politicised. Targeted and government-priority-driven approaches have created undesired tensions with achieving transformative research outcomes that would serve to enable Australia to compete globally in the longer term. Whilst targeted funding has its purpose and an important role to play in the innovation ecosystem and to strengthen the economy, this should not be done at the expense of curiosity‐driven, fundamental research. Many future challenges will be solved using ideas and technologies not yet conceived.

This is a real concern for Australia’s future as an innovative and enterprising nation as demonstrated by ARC Selection Reports for Discovery Projects (DPs)[5] that the funding pool for blue-sky and curiosity research across all non‐medical disciplines has stagnated (even declined taking into consideration inflation), as has the number of applications. Total funds awarded for 2018 DP grants were $225,661,033 with a national success rate of 19%, and 2022 DP grants were $258,691,272 with a success rate of 19%. Over this period the number of DP applications decreased from 3136 to 3095 with a corresponding drop in the total number of projects awarded from 594 to 587.

What is needed for Australia to remain globally competitive is long‐term investment in fundamental science, arts and the humanities. There is a dire need in Australia for predictable, sustainable levels of funding for programs that enable researchers to plan their long‐term career pathways.



[1] https://www.ukri.org/
[2] https://www.ukri.org/funding/how‐to‐apply/applications‐across‐research‐council‐remits/
[3] http://www.arc.gov.au/arc‐medical‐research‐policy
[4] https://data.oecd.org/rd/gross-domestic-spending-on-r-d.htm
[5] https://www.arc.gov.au/funding-research/funding-outcome/selection-outcome-reports/selection-report-discovery-projects-2022#:~:text=Discovery%20Project%20application.-,Summary%20of%20outcomes,Discovery%20Projects%20approved%20for%20funding.

Q2. Do you consider the current ARC governance model is adequate for the ARC to perform its functions?

If not, how could governance of the ARC be improved? For example, should the ARC Act be amended to incorporate a new governance model that establishes a Board on the model outlined in the consultation paper, or another model.

Please expand on your reasoning and/or provide alternative suggestions to enhance the governance, if you consider this to be important.

UOW strongly supports the re-establishment of an ARC Board. The Terms of Reference for such a Board would require review to ensure it is balanced and pragmatic. The composition of the ARC Board should be inclusive and reflect the diversity of the Australian public. This could be achieved by including members who demonstrate:
• a balance between STEM and HASS disciplines, and representation of Indigenous knowledges and ways of thinking;
• experienced researchers (including researchers with expertise in how fundamental research is best supported and conducted);
• an understanding of research translation, including not only short-term industry linkage and immediate translation, but also long-term translation and impact through complex research pipelines;
• a diversity of career levels including early and mid-career researchers.

We would also support that the ARC CEO and Chair of the ARC Board or ex-officio be appointed for their expertise and track record in managing and encouraging research excellence in fundamental as well as applied disciplines, similar to the basis upon which a DVC Research might be selected.

Q3. How could the Act be improved to ensure academic and research expertise is obtained and maintained to support the ARC?

How could this be done without the Act becoming overly prescriptive?

The current system of Executive Directors, who are eminent and highly respected researchers, is well-suited to good governance of the ARC, as is the ARC College of Experts. The ARC could do better in making use of this expertise by consulting with its College, via its Executive Directors, before making significant decisions on changes to funding rules or directions/processes, such as the handling of references to pre-prints in applications.

The current system of peer-review is world's best practice, but it has been compromised in its effectiveness through repeated ministerial vetoes of grants recommended for funding by external reviewers and the College. This has damaged the confidence of potential reviewers that their advice will be heeded, and therefore damaged the ARC's capacity to reliably solicit expert opinions from world-leading researchers.

UOW would support a return to the open forums and public debates for funding guidelines at universities that were common in the early 2000s, to restore open and transparent discussions with end-users and our communities.

Q4. Should the ARC Act be amended to consolidate the pre-eminence or importance of peer review?

Please provide any specific suggestions you may have for amendment of the Act, and/or for non-legislative measures.

UOW suggests that non-legislative protocols be developed to enable the Minister to veto applications, that have been recommended for ARC funding through the peer review process, only under exceptional circumstances. Such a protocol would require the Minister to disclose the reason, and also to define stipulated timings. This is particularly important for Indigenous research that has been peer-reviewed and deemed of national significance and benefit by Indigenous research assessors.

The NIT could be replaced with disclosure statements of any potential aspects of the research that could relate to sensitive areas or national security that must be assessed by an expert panel through a clear and transparent process; this panel could then provide expert advice to the Minister.

Enshrining such a process in the Act would generate significant confidence. However, even if it is not enshrined in the Act, the creation of such an expert panel and process, and a clear description of its processes and role would be a significant improvement.

Indigenous applications must be reviewed by Indigenous assessors. Peer review is important and consideration should be given to the appropriateness of assessors, e.g. Aboriginal and Torres Strait Islander assessors for Aboriginal and Torres Strait Islander-related projects. Peer review, with the correct representation of assessors, can enable Indigenous researchers to access greater career opportunities.

Q5. Please provide suggestions on how the ARC, researchers and universities can better preserve and strengthen the social licence for public funding of research?

UOW recognises that the ARC has an important role in strengthening the social license for research funding. We suggest that the ARC more effectively leverage its position through communication and education of the public on the benefits of research, as is currently done by the CSIRO, rather than efforts to convince the public that the ARC is placing stringent criteria on what specific sorts of research will be funded. The ARC should utilise marketing expertise to develop a strategy that addresses this need. They could then undertake the collection of research stories, collaborating with universities, industry, other research organisations, and researchers, to take an active role in advocacy for the critical importance of funding research.

Q6. What elements of ARC processes or practices create administrative burdens and/or duplication of effort for researchers, research offices and research partners?

ARC processes must minimise red tape to ensure that the investment in research is allowed to return its maximum value to the community. This reduction of red tape should occur at all stages of the application, award and grant management life cycle to ensure that maximum time can be spent on research rather than on onerous reporting and compliance.

UOW acknowledges that ARC guidelines, application forms and reporting processes have been modified to try to address a spectrum of feedback and agendas over the years. Now is an opportune time to revisit the underlying intention of these processes, to support Australia’s research and researchers. It should be noted that the ARC's approach to equity and assessing relative to opportunity is commendable and we do not consider this an area for scale-back.


PRE-AWARD
The length of ARC applications is prohibitive and creates unnecessary burden and duplication of effort. UOW would advocate for a ground-up review and redesign of ARC application forms and processes, which have evolved organically and with little thought for the holistic impacts of local changes over many years. Specifically:
• The ARC should not impose requirements of ongoing employment associated with Fellowships; the ARC assesses research only, but universities must have control over the teaching and governance capabilities of their ongoing academic employees. This, in particular, can create inequities between larger universities - which have greater economies of scale and scope for maintaining research-only academic roles - and smaller institutions.
• ARC should consider returning to combined Fellowship and Project applications for both Linkage and Discovery Programs. These could be modelled on the previous ARC Discovery Projects which included postdoctoral (APD, ~Level A), Research Fellow (ARF, ~Level B), Senior Research Fellow (QEII, ~Level C and above) before DECRA and Future Fellows were introduced as separate schemes. As Industry Fellowships now also exist in the ARC Linkage Program there is an opportunity to implement a consistent approach here which would reduce the number of application rounds and create efficiencies across the board in terms of workload for the ARC, ARC College of Experts, assessors, University Research Office, and applicants.
• Partner Investigator details are too onerous and industry requirements have caused significant reputational damage to the higher education system. This has served to undermine the level of industry engagement and trust in collaborating with universities.
• Applications should be shortened. We suggest benchmarking against systems used in Europe and North America. In particular, the track-record section could emulate the US biosketch format.
• As noted in Q1 and elaborated in Q7, the ARC should fully fund the full cost of research, blanket budget cutting of applications (for example, a target 25% budget reduction) has undermined the process.
• The ARC should provide more-comprehensive feedback to unsuccessful applicants.
• The ARC should implement a two-stage application process (similar to the Marsden Fund in New Zealand), where a de-identified (to reduce unconscious bias for gender, ethnicity, institution, etc.) EOI application is assessed and where a proportion that would lead to approximately a 50% success rate on full applications are invited for a full application.
• The ARC could consider funding unspecified Postdoctoral Fellowships that are to be administered (including advertising, applications, assessment etc.) by universities. This would require careful calibration of the funding formula to ensure a good distribution of post-docs across the Australian system, and detailed rules for universities to ensure that the ARC's mission of supporting basic research across all research areas is achieved and is not subverted by the short-term and/or strategic goals of specific institutions. Moreover, this would significantly reduce the ARC's workload.


PEER REVIEW AND ASSESSMENT
Peer review is essential to the integrity of the research funding system and to ensure rigorous assessment of research grant proposals. However, it comes at a significant cost to the University sector who provide the majority of Australian peer reviewers. We therefore need to ensure that the peer review system makes efficient use of reviewers’ time.
• Introducing a two‐stage application process with a short stage-one EOI would reduce the need to review lengthy applications that are uncompetitive.
• The ARC could explore mechanisms to enable the re‐submission of ‘near‐miss’ grants that were ranked highly and clearly fundable. These grants typically miss out because the annual funding pool can only extend ‘so far down’ the list of fundable projects, yet the grant reviewers and assessment panels have already conducted the due diligence to consider them fundable. The current system typically requires the investigators to rewrite and submit these proposals (often changing application formats each year) and reviewers and panel members then must review these submissions. This is a huge expense to all involved.
• Consideration should be given to the calendaring of all government schemes. With so many schemes being conducted across the NHMRC, MRFF and ARC, little attention is paid to how they might work better together to support the researchers and infrastructure.


POST-AWARD
UOW recommends review of the post-award management of grants by Commonwealth funding agencies, with a view to simplifying these and reducing red‐tape for the research sector. Gains can be made in the post award management of grants. For example:
• Variation documentation and processes required are overly onerous, with no net benefit to researchers or the ARC. Adoption of the same process as the NHMRC, where notification and updating the system, but not approval, is required would significantly reduce the administrative burden on research offices and researchers. In addition, for Partner Investigators and Partner Organisations, a sensible and pragmatic approach to reducing existing bureaucratic processes would restore trust in university collaborative efforts.
• Reporting of grants: The ARC has successfully implemented exception only reporting over the life of the grant. However, final grant reporting remains overly prescriptive and should be revisited to capture essential information only.


TRANSPARENCY OF INFORMATION
Transparency of information should be a cornerstone of a healthy research ecosystem in Australia, yet to date assessment processes and feedback is often withheld by the ARC.

This is a missed opportunity best demonstrated in the 2017-2018 REI assessment, for which the following information is not available: impact case studies that scored low and medium; minutes of panel deliberations; analysis of the assessment robustness across the years; and creation of systemic inequities in panel compositions (through underrepresentation of regional universities and key end users). If we are to ensure that Australian research ‘leaves no-one behind’ then free and open access to information is critical. This also extends to the format of ARC reports that are produced. They should be open to verification, further analyses and scrutiny. Formats like a flipbook or PDF do not support this type of analysis or transparency.

Greater transparency around the assessment of career disruption would also be beneficial. Indigenous researchers in particular, often have significant caring responsibilities and are involved in community roles which can take time away from research.

ARC timelines could also be shared more transparently. For example, providing specific detail on when grant outcomes will be announced, or when scheme guidelines will be released would greatly assist universities with their planning, and also help researchers plan their future application strategies.


COMMUNICATION
The ARC needs to improve communications and relationships with universities. ARC information must be provided to universities simultaneously through formal channels to instill confidence in ARC processes and build trust amongst stakeholders.

Q7. What improvements could be made:

(a) to ARC processes to promote excellence, improve agility, and better facilitate globally collaborative research and partnerships while maintaining rigour, excellence and peer review at an international standard?

(b) to the ARC Act to give effect to these process improvements, or do you suggest other means?

Please include examples of success or best practice from other countries or communities if you have direct experience of these.

The ARC is well positioned to support and advocate for research in Australia across the research spectrum. However, its current structure, processes and schemes (established over 20 years ago now) need to evolve to ensure it is fit-for-purpose, resilient, and adaptable for the next 20 years.

The ARC could consider a number of fundamental changes to safeguard Australia’s research future and address the present existential threat from a changing climate, through the following actions:


I. Increase the quantum of funds: the level of ARC funding is an issue for the sector, having seen no significant increases in the last decade. In order to ensure a sustained and thriving research ecosystem, the full cost of research should be considered.

Australia needs to fully fund research to grow research capacity and capability, including Australia’s ability to attract research leaders, maintain cutting-edge facilities and engage internationally. Government granting bodies typically fund awards at 60‐70% of applicant requests; grants normally exclude the significant cost of researcher salaries, and fellowship salaries fall significantly short of the actual salaries that universities must pay to retain staff. Research block grant (RBG) funding does not fully cover the indirect costs of research activities. The lack of full funding leaves universities to subsidise research from other income, which significantly reduces the capacity of all universities to undertake large-scale research projects. Research should be fully funded either via a dual system or via indirect costs being incorporated into research grants. The lack of RBG funding has also increased universities’ focus on teaching and international student markets, diminishing university capacity for research and industry collaboration.


II. Consider fundamental changes to Australia’s funding body structures: such as whether to combine the ARC and NHMRC as in the USA model, or split them more, such as in the UK model.

UOW recommends that the ARC consider consolidation of competitive research grant mechanisms across funding agency boundaries, and integration of research grant application and management systems. This would increase efficiency and transparency and reduce administrative burden within the research sector.

This would also address the current gap between agencies; that is, the medical-research overlap. It is not practical to maintain two agencies that do not co-fund the grey area between them. This is a significant inefficiency. Reduction of fragmentation and duplication in Australia’s research funding systems by revisiting the ARC’s Medical Research Policy to derive an outcome where co-investment between the NHRMC and ARC is facilitated.

Smaller procedural changes could also be adopted and adapted such as those demonstrated by the US National Science Foundation with:
1) shorter ROPE sections that focus on the project at hand, not length of career (much easier for authors and reviewers, and much more effective, with less bias introduced);
2) finer-grained, more-expert panels where experts at least vaguely in the field discuss the proposal and provide summary feedback (for comparison: the NSF has specialised panels for each of a number of sub-disciplines of mathematics; the ARC has a single panel for Mathematics, Physics, Chemistry and Earth Sciences);
3) program managers who communicate with applicants, let them know what was unsuccessful, and want them to improve and obtain funding in the future (e.g., US agencies like NOAA, NASA);
4) budget devolved to universities to hire US-style post-docs- with a small research grant for each post-doc for research.

Other considerations from international funding agencies or previous schemes:
5) a small honorarium paid to external assessors to achieve a higher rate of response and more detailed responses, making it consistent in its approach with the majority of international funding agencies;
6) longer funding cycles to facilitate research outcomes and reduce administrative burden;
7) utilising peer review to decide all fundable projects and then apply an equity, diversity and inclusion (EDI) lens to ensure the NCGP system progressively moves to greater EDI. For example, the ARC could fund the Top 10% of applications, and then target a proportion of fundable applications to address diversity targets for Australian-funded research.

Q8. With respect to ERA and EI:

(a) Do you believe there is a need for a highly rigorous, retrospective excellence and impact assessment exercise, particularly in the absence of a link to funding?

(b) What other evaluation measures or approaches (e.g. data driven approaches) could be deployed to inform research standards and future academic capability that are relevant to all disciplines, without increasing the administrative burden?

(c) Should the ARC Act be amended to reference a research quality, engagement and impact assessment function, however conducted?

(d) If so, should that reference include the function of developing new methods in research assessment and keeping up with best practice and global insights?

Universities devote significant resources to provide information for various Government research data collections (e.g., annual Higher Education Research Data Collection; bi‐annual Australian Bureau of Statistics R&D Expenditure Survey, Higher Education Student Data Collection etc.), and a plethora of different university rankings.

The Review accurately points out that ERA was created to serve a specific purpose which has now been realised and that the program captures data that was significantly outdated and redundant. Higher education institutions, including UOW, welcomed the postponement of ERA2023 to enable better investment of time and resources to research and teaching.

UOW supports the ARC’s suggestion to employ a more transparent, data-driven approach for the next iteration of ERA, and looks forward to contributing to the consultation to shape the new methodology. Ideally ERA would benefit the following key groups:
• the ARC, by providing insights on the return on their investment in high-quality research;
• Universities, by being allocated funding based on their performance, and promoting their excellent results in various disciplines with potential collaborators;
• Researchers, to help them promote their achievements in grant applications and plan their careers using data to identify potential research partnerships and synergies;
• Australia’s reputation as a research-intensive nation, keen to collaborate with others on a global scale.

In the REI Assessment, the Australian Government mirrored similar overseas assessment processes (e.g., UK REF), but without the important driver of associated funding. Again, as alluded to in the Consultation paper, research impact takes, on average, 20 years to be realised. The application of a defined timeframe by a single Field of Research code is at odds with the reality of research. In addition, income metrics are a very poor surrogate indicator of engagement, because much of universities’ role in engagement is via community engagement through outreach activities rather than income-generating streams. This time-consuming and costly exercise takes resources away from effecting impactful research outcomes for the public good.

The arbitrary nature of the ERA and REI program’s requirements and disruption to the sector has negligible benefit to universities, to researchers or to the Australian public. Universities should not be required to subsidise these costly and largely questionable exercises, particularly when the majority of necessary data is already available in the public domain. Cessation of ERA and REI would also save ARC resources that could be redeployed in the direction of advocacy for the value and impact of research.

Q9. With respect to the ARC’s capability to evaluate research excellence and impact:

(a) How can the ARC best use its expertise and capability in evaluating the outcomes and benefits of research to demonstrate the ongoing value and excellence of Australian research in different disciplines and/or in response to perceived problems?

(b) What elements would be important so that such a capability could inform potential collaborators and end-users, share best practice, and identify national gaps and opportunities?

(c) Would a data-driven methodology assist in fulfilling this purpose?

UOW commends the ARC’s efforts in the evaluation of research excellence and impact to date. However, the key requirement here is for the ARC to maintain transparent records and track the impact of the research that it funds. Researchers frequently relocate between universities or from country to country. Universities do not have the infrastructure or the ability to track them and their work over time.

In addition, the precarious nature of research outcomes and uncertainty of the research trajectory means that evaluation of impact serves to embed the fallacy that analysing what research has had impact in the past, can be used to predict future outcomes and research. This is particularly challenging in the fundamental science and philosophical disciplines where evaluation over a given time frame can undermine the importance of the research.

We concur with the sentiment in the consultation paper:
“there is no doubt that ERA has been tremendously effective in shifting the focus of Australian research from an emphasis on quantity to quality of outputs, particularly in its early iterations, but it can be argued that ERA has achieved its initial purpose and that the time and resources involved may be better re-directed to other evaluation needs”.

Better utilisation of ARC expertise in evaluation could be realised by instead asking how the ARC can best advocate and support Australian research excellence and impact.

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?

The University of Wollongong (UOW) welcomes the opportunity to make a submission to the Review Panel Consultation paper on the Review of the Australian Research Council. Our responses have addressed how the benefits derived from this timely review to the Australian Research Council Act 2001 (the ARC Act) and the way it is interpreted by the ARC will serve the Australian public well, now and into the future.

Basic, strategic basic and applied research are all essential parts of a productive and innovative research system that contributes to Australia’s economic, social and environmental prosperity. However, the pipeline of ideas that derive from basic research is funded solely through the ARC.

In the spirit of fostering excellent Australian research, we recommend that the ARC:
• Address panel gender representation through the establishment of equity requirements for both grants submission and success rates at a panel level;
• Build capacity and support Early- and Mid- career researchers by implementing an Observer Program for all types of grant reviews;
• Accelerate solutions to, and understandings of, administrative burden by offering a program of secondment opportunities between university and ARC professional staff.

In addition, although outside the scope of this Consultation, UOW would strongly support the ARC to consider:
• Restoring integrity into the grant review process through funding the full cost of research, in particular by discontinuing arbitrary percentage targets for budget cuts within schemes;
• Acknowledging that Indigenous research processes are different from other research, and considerations need to be made to ensure the integrity of the research can be maintained within the context and constraints of ARC programs. For example, translation of different languages to English is challenging especially in the face of language rejuvenation for many Indigenous communities. Also, funding to employ Indigenous community should be in the context of capacity building in the community and be substantial, rather than tokenistic.
• Protecting the Indigenous Discovery scheme to enable Indigenous Researchers to more fully benefit. For example, loosening restrictions on how many Discovery projects an Indigenous researcher can be CI on would enable more collaboration and capacity building. In addition, the tokenistic inclusion of Indigenous researchers on other grants is concerning and recognition within other grant schemes of additional implications for Indigenous research and researchers (e.g. Linkage Projects and the barriers for dollar-for-dollar community partnerships with Indigenous communities) is sought.


UOW would welcome further opportunities to elaborate upon, or further clarify, the matters raised within this submission. To do so, please do not hesitate to contact the Deputy Vice-Chancellor, Research and Innovation, Professor David Currow.

Submission received

14 December 2022

Publishing statement

Yes, I would like my submission to be published and my name and/or the name of the organisation to be published alongside the submission. Your submission will need to meet government accessibility requirements.