Inquiry Search
Rec-ID | Code | Recommendation |
---|---|---|
REC325-4339 | 38 - Agency/Department Reporting | The Inspector-General of Emergency Management recommends that Queensland Fire and Emergency Services review and update the State Disaster Risk Report, including re-evaluating the risk of flooding by all types. Queensland Fire and Emergency Services should publish the updated State Disaster Risk Report by 1 November 2023. |
REC325-4327 | 17 - Assets and technology | The Inspector-General of Emergency Management recommends all local governments that offer an opt-in system develop strategies to increase the number of subscribers who elect to use this service. As part of the annual disaster management plan assessment process for the period 2023–2025, the Office of the Inspector-General of Emergency Management will request information from the relevant local disaster management groups to highlight and share innovative practices that have led to an increase in subscription levels for opt-in services. |
REC325-4330 | 38 - Agency/Department Reporting | The Inspector-General of Emergency Management recommends Queensland Fire and Emergency Services review the Queensland Emergency Alert Manual – M.1.174 in its entirety by 1 November 2023. The manual should specifically address the authorising environment, legislative obligations and the capability and complexities of the Emergency Alert system. |
REC325-4330 | 38 - Agency/Department Reporting | The Inspector-General of Emergency Management recommends Queensland Fire and Emergency Services review the Queensland Emergency Alert Manual – M.1.174 in its entirety by 1 November 2023. The manual should specifically address the authorising environment, legislative obligations and the capability and complexities of the Emergency Alert system. |
REC325-4331 | 41 - Emergency Management exercises | The Inspector-General of Emergency Management recommends Queensland Fire and Emergency Services conduct annual exercises with every local disaster management group and district disaster management group to confirm the process for developing, approving and issuing of an Emergency Alert, including the use of pre-formatted polygons and messages. Upon completion of the initial statewide exercise, Queensland Fire and Emergency Services will furnish an exercise evaluation report to the Office of the Inspector-General of Emergency Management by 1 November 2023. |
REC325-4323 | 7 - Inter-agency communication | The Inspector-General of Emergency Management recommends Queensland Fire and Emergency Services adopt measures to achieve a common operating picture between deployed Queensland Fire and Emergency Services assets in disaster management operations by 1 November 2023. |
REC325-4338 | 17 - Assets and technology | The Inspector-General of Emergency Management recommends the Queensland Reconstruction Authority and the Bureau of Meteorology investigate options for the consolidation of ownership, renewed capital and maintenance in the flood warning network in consultation with flood warning infrastructure asset owners. |
REC325-4326 | 17 - Assets and technology | The Inspector-General of Emergency Management recommends Queensland Fire and Emergency Services lead an inter-agency IT system assessment with Queensland Police Service and local governments to identify disaster management systems currently in use and develop options to enhance connectivity and interoperability between systems. Outputs to be considered include, but are not limited to, consideration of requests for assistance (RFA) and the production of situation reports. |
Rec-ID | Code | Recommendation |
---|---|---|
REC324-4310 | 41 - Emergency Management exercises | Task Force Hawk: That, to ensure disaster readiness, Government establish a high-level Government standing committee, Task Force ‘Hawk’, comprising key Cabinet Ministers, Secretaries and Commissioners that meets, trains and exercises to ensure Government is prepared to respond to any emergency. Task Force ‘Hawk’ should resonate with the community in difficult times to ensure the highest level of confidence in Government’s response. |
REC324-4312 | 17 - Assets and technology | Impact to essential services: That, to minimise disruption to essential services, including outages which compromise basic communication coverage, and to ensure access to safe water supply and power during flood events, Government work directly or together with the Australian and other state governments and/or their relevant power and telecommunications regulatory, policy and market bodies to: |
REC324-4319 | 26 - Research | Climate and weather research: That, to enable effective mitigation and adaptation measures in response to changing climate risks, Government establish NSW as a world centre of disaster research and technology development. This should include: |
REC324-4293 | 17 - Assets and technology | Essential services and floodplain infrastructure: That, to minimise disruption to essential services (power, communications, water, sewerage) and to ensure flood infrastructure is fully serviceable before flooding, Government ensure: |
REC324-4306 | 6 - Insurance and legal liability | NSW Reconstruction Authority: That, to provide rapid and effective recovery from floods (and other disasters) and to provide maximum mitigation of the impacts of future floods (and other disasters), Government establish a permanent state-wide agency, the NSW Reconstruction Authority (NSWRA) dedicated to disaster recovery, reconstruction and preparedness. The NSWRA should: |
REC324-4308 | 26 - Research | Compound mental helath studies: That, to inform Government policies and programs for mental health and disasters, Government commission a longitudinal study on the effect of consecutive disasters on community mental health. |
Rec-ID | Code | Recommendation |
---|---|---|
REC311-2493 | 41 - Emergency Management exercises | To increase shared understanding of risks and enhance capability integration and collaborative planning, both Local Disaster Management Group (LDMG) participate in the exercising of the Paradise Dam Emergency Action Plan. |
Rec-ID | Code | Recommendation |
---|---|---|
REC297-1253 | 13 - Mapping and data quality | That agencies undertaking flood studies adopt a standardised approach, based on Australia Handbook 7, maintain public ownership of underlying data sets to support future modelling, and ensure open access to these studies. |
REC297-1252 | 13 - Mapping and data quality | That SES uploads current flood studies and plans to the Common Operating Platform as a flood plan layer and that councils, subject to resolving licence restrictions, arrange to have appropriate access. |
REC297-1265 | 13 - Mapping and data quality | That BoM and the Flood Warning Consultative Committee, in consultation with gauge owners, review flood gauges and develop a program to update data used to support hydrologic modelling. This should include reviewing gauge maintenance before and after floods. |
REC297-1263 | 13 - Mapping and data quality | Subject to funding, that the Flood Warning Consultative Committee investigates the hydrological matters and advice received during this Review and detailed in this Report in Sections 4.1.9 and 4.1.11. |
REC297-1262 | 13 - Mapping and data quality | That the Flood Warning Consultative Committee considers the merits of delineating the Ouse River as a separate catchment from the Derwent River Basin. |
REC297-1254 | 13 - Mapping and data quality | That Government: |
Rec-ID | Code | Recommendation |
---|---|---|
REC258-2550 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority introduces grading of Non-Compliance Notices on a scale of seriousness. |
REC258-2548 | 17 - Assets and technology | The Civil Aviation Safety Authority shares the risk assessment outputs of Sky Sentinel, its computerised risk assessment system, with the applicable authorisation holder. |
REC258-2544 | 6 - Insurance and legal liability | The Australian Transport Safety Bureau transfers information from Mandatory Occurrence Reports to the Civil Aviation Safety Authority, without redaction or de-identification. |
REC258-2543 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority reintroduces a ‘use of discretion’ procedure that gives operators or individuals the opportunity to discuss and, if necessary, remedy a perceived breach prior to CASA taking any formal action. This procedure is to be followed in all cases, except where CASA identifies a Serious and Imminent Risk to Air Safety. |
REC258-2540 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority continues to provide appropriate indemnity to all industry personnel with delegations of authority. |
REC258-2557 | 6 - Insurance and legal liability | The Civil Aviation Safety Authority reassesses the penalties in the Civil Aviation Safety Regulations. |
Rec-ID | Code | Recommendation |
---|---|---|
REC238-0813 | 26 - Research | Develop and maintain a comprehensive flood model and flood modelling framework for the Hawkesbury-Nepean Valley. |
REC238-0807 | 26 - Research | Develop a comprehensive road evacuation network model for floods in the Hawkesbury-Nepean floodplain to inform evacuation capacity assessments and strategic transport and land use planning, and to assist with the real-time operational management of evacuation during floods. |
REC238-0804 | 26 - Research | Clarify roles, responsibilities and consider funding options for post-event collection of data and flood intelligence. |
Rec-ID | Code | Recommendation |
---|---|---|
REC199-0416 | 26 - Research | the state establish appropriate arrangements to ensure the capacity to maintain technical expertise for flood intelligence is initiated, including appropriate agreements with commercial experts. |
REC199-0446 | 7 - Inter-agency communication | the state commit to securing effective multi-agency interoperable communications as a high level priority and that all future communications projects and upgrades incorporate compliance provisions mandating interoperability requirements. |
REC199-0460 | 6 - Insurance and legal liability | the state formalise and continue the Emergency Response Legal Advisers Forum. |
REC199-0410 | 17 - Assets and technology | the state take the necessary measures to upgrade existing manual stream and rain gauges and ensure that all future gauges provide a seamless transfer of data from the gauges to the Bureau of Meteorology. |
REC199-0429 | 13 - Mapping and data quality | the state take into account any outcomes from the Commonwealth Government’s flood mapping reviews in the continual development of the Victorian flood database and to incorporate into the database flood data currently held by Melbourne Water. |
REC199-0458 | 7 - Inter-agency communication | the state ensure: • a common, functional and accessible system be introduced to enable effective Municipal Emergency Coordination Centre and Incident Control Centre communications • a regime of regular Municipal Emergency Coordination Centre exercising is introduced with oversight by an appropriate independent body. Such exercising should include testing of systems utilised for Incident Control Centre and Municipal Emergency Coordination Centre communications • those required to perform Emergency Management Liaison Officer roles have undertaken appropriate training; and • resource requesting arrangements are clarified and documented so that control and coordination functions do not overlap. |
REC199-0408 | 13 - Mapping and data quality | the state, in consultation with Bureau of Meteorology and Melbourne Water, take the necessary action to ensure that all flood warnings issued are linked to the geographical location of the gauge the data was derived from. |
REC199-0420 | 13 - Mapping and data quality | the state establish standards for flood mapping to ensure they are kept contemporary and meet the purposes of landuse risk planning and emergency response. In doing so, maps should extend where appropriate to include Probable Maximum Flood, over a range of Annual Exceedence Probability levels and be explicitly linked to a stream gauge. |
REC199-0452 | 17 - Assets and technology | the state ensure that any new systems and equipment purchased by state emergency management agencies are interoperable with other relevant agencies to the fullest extent possible. This should involve the state establishing a procurement gateway process with input from the Emergency Services Commissioner. |
REC199-0418 | 7 - Inter-agency communication | the state develop an efficient process to ensure that, during flood events, temporary construction of flood mitigation works, such as levees, is controlled so as not to unacceptably impact on flood intelligence. |
REC199-0449 | 7 - Inter-agency communication | the state ensure that interoperable information management practices are developed and implemented by emergency management agencies. Common systems should be utilised to the fullest extent possible. |
REC199-0417 | 13 - Mapping and data quality | the state ensure that regional and local flood plans incorporate all available flood mapping and intelligence, including assessments of levees and flood consequence information. |
REC199-0447 | 7 - Inter-agency communication | the state ensure that common and interoperable resource management systems are developed and implemented by emergency management agencies. Common systems should be utilised to the fullest extent possible. |
REC199-0476 | 6 - Insurance and legal liability | the Department of Planning and Community Development examine strategies to address and clarify insurance coverage of community volunteers in emergency events |
Rec-ID | Code | Recommendation |
---|---|---|
REC187-2923 | 6 - Insurance and legal liability | That home building and home contents insurance should not be made compulsory. |
REC187-2939 | 6 - Insurance and legal liability | That for body corporate insurance policies receiving full discounts, policyholders pay for that portion of the risk retained by the insurer and pay nothing for the remainder of the risk up to $500,000 times the number of units. For properties with a value greater than $500,000 times the number of units policyholders then pay the full cost of the portion of risk exceeding $500,000 times the number of units. |
REC187-2956 | 6 - Insurance and legal liability | That a ‘health warning’ be provided by insurers to the purchasers of home and contents policies that do not include full flood cover or full replacement cover. The health warning should be provided: |
REC187-2928 | 6 - Insurance and legal liability | That there be limitations on the size of the discount available to high-value homes. |
REC187-2944 | 6 - Insurance and legal liability | That the Commonwealth seek reimbursement of some portion of the shortfall from the State or Territory government in whose jurisdiction the flood occurred. |
REC187-2961 | 6 - Insurance and legal liability | That the Insurance Council of Australia repeal clauses 4.3 and 4.4 of the General Insurance Code of Practice, so that claims arising from natural disasters are subject to the same minimum standards as other claims — including the four month time limit for a determination on liability and the nature of the loss/damage with respect to the claim. |
REC187-2933 | 6 - Insurance and legal liability | That discounts be provided, in the same manner as for homes, to home contents insurance policies for eligible properties. |
REC187-2950 | 6 - Insurance and legal liability | That the Commonwealth engage with the insurance industry and the States and Territories in planning for the future coordination of charitable and government payments to individuals to assist with recovery after future natural disasters. |
REC187-2966 | 6 - Insurance and legal liability | That the Commonwealth and State governments provide funding for legal advice and assistance with insurance disputes following natural disasters. |
REC187-2922 | 6 - Insurance and legal liability | That all home building insurance policies include flood cover. |
REC187-2938 | 6 - Insurance and legal liability | That for home building insurance policies receiving full discounts, policyholders pay for that portion of the risk retained by the insurer and pay nothing for the remainder of the risk up to $500,000. For properties with a value greater than $500,000 policyholders then pay the full cost of the portion of risk exceeding $500,000. |
REC187-2955 | 6 - Insurance and legal liability | That, in endorsing the Government proposal for a Key Facts Statement, the Key Facts Statement list replacement cover and all natural disaster events, identified as ‘standard cover’ in the Insurance Contracts Regulations 1985. That insurers issue a Key Facts Statement to policy holders with all new policies written and all policy renewals on an annual basis. |
REC187-2927 | 6 - Insurance and legal liability | The levels of the discounts and the phasing out periods be reviewed from time to time. |
REC187-2943 | 6 - Insurance and legal liability | That the Commonwealth Government guarantee payment of claims from the reinsurance pool by ensuring that, whenever a funding shortfall occurs in the pool through claims exceeding the funds held in the pool, the Commonwealth would meet the shortfall. |
REC187-2960 | 6 - Insurance and legal liability | That the Insurance Council of Australia amend the Code of Practice to impose a four month time limit (subject to exceptional circumstances) to make a determination as to liability and the nature of the loss or damage with respect to a claim. That, should a claimant not receive a determination within the four month period, the claim be automatically escalated to an internal dispute resolution complaint and the insurer notify the Code Compliance Committee of the breach of the Code. |
REC187-2932 | 6 - Insurance and legal liability | That all home contents insurance policies include flood cover. |
REC187-2949 | 6 - Insurance and legal liability | That all home, contents and home unit insurance policies cover the policyholder for storm surge, tsunami and landslide, where the storm surge, tsunami or landslide is the result of another event that is covered under the policy and regardless of whether the insured property directly suffers damage from the underlying insured event. |
REC187-2965 | 6 - Insurance and legal liability | That ASIC conduct a review of the General Insurance Code of Practice three years after the amendments recommended to the Code in this Review are implemented, in order to assess the effectiveness of the Code with a view to determining whether an ASIC Regulatory Guide for claims handling should then be introduced. |
REC187-2921 | 6 - Insurance and legal liability | The Commonwealth Government guarantee the payment of claims by ensuring that, whenever a funding shortfall occurs in the reinsurance facility through claims exceeding the funds held in the facility, the Commonwealth would meet the shortfall and the Commonwealth would seek reimbursement of a portion of the shortfall from the State or Territory government in whose jurisdiction the flood occurred. |
REC187-2937 | 6 - Insurance and legal liability | That flood premium discounts be delivered through a model that requires insurers to retain and price a portion of the risk with the remainder to be ceded to the reinsurance facility at a discounted reinsurance premium. |
REC187-2954 | 6 - Insurance and legal liability | That subsection 35(2) of the Insurance Contracts Act 1984 be amended so that policyholders are not deemed to be clearly informed of a deviation from ‘standard cover’ by simply being provided a copy of the insurance policy or product disclosure statement. |
REC187-2926 | 6 - Insurance and legal liability | That flood premium discounts be provided for home building insurance for eligible homes: |
REC187-2942 | 6 - Insurance and legal liability | That a flood risk reinsurance facility, or reinsurance pool, be established which would have two primary functions: |
REC187-2959 | 6 - Insurance and legal liability | That every APRA-authorised general insurer adopt and comply with the General Insurance Code of Practice. |
REC187-2931 | 6 - Insurance and legal liability | That the definition of a home for the purposes of flood cover and flood premium discounts be any building for which a homeowner purchases a home insurance policy. |
REC187-2948 | 6 - Insurance and legal liability | That: |
REC187-2964 | 6 - Insurance and legal liability | That the Insurance Council of Australia amend the General Insurance Code of Practice such that the General Insurance Code Compliance Committee: |
REC187-2920 | 6 - Insurance and legal liability | That a system of premium discounts be introduced in order that most purchasers of home insurance, home contents and home unit insurance policies in areas subject to flood risk be eligible for discounts against the full cost of flood insurance. |
REC187-2936 | 6 - Insurance and legal liability | That the questions of flood cover as standard in small business policies and access to discounted premiums for small business policyholders should be revisited once the recommended arrangements for homes, home units and home contents are in place. |
REC187-2953 | 6 - Insurance and legal liability | That all home building insurance policies providing sum insured cover be modified by the end of 2014 so as to include replacement value cover in the event of total loss of the home. That during the transition period insurers consider how the design features of home building replacement value policies should respond following a natural disaster, including the conditions under which cash settlements are to be offered and finalised. |
REC187-2925 | 6 - Insurance and legal liability | That the following five principles underpin the design of a system of premium discounts: |
REC187-2941 | 6 - Insurance and legal liability | That homes at high and extreme risk of flood be provided with discounts initially and that they be assessed regularly for mitigation work already undertaken and the potential for further mitigation. |
REC187-2958 | 6 - Insurance and legal liability | That, in order to give general insurance policyholders the same legal remedies as other consumers, unfair contract terms laws be applied to general insurance. |
REC187-2930 | 6 - Insurance and legal liability | That flood premium discounts be provided, in the same manner as for homes, to the bodies corporate of eligible properties, and on the same basis as for detached homes. |
REC187-2947 | 6 - Insurance and legal liability | That the Agency charge insurers a small administrative fee for each policy ceded to the reinsurance facility. |
REC187-2963 | 6 - Insurance and legal liability | That the Insurance Council of Australia amend the General Insurance Code of Practice to require that: |
REC187-2919 | 6 - Insurance and legal liability | That all home insurance, home contents and home unit insurance policies include flood cover. |
REC187-2935 | 6 - Insurance and legal liability | That flood premium discounts not be provided to small businesses and that the reinsurance facility not offer reinsurance for small businesses. |
REC187-2952 | 6 - Insurance and legal liability | That lending institutions remind mortgagors annually of their obligations to hold home insurance and of the risks of under-insurance in order to minimise non-insurance and under-insurance of homes. |
REC187-2968 | 6 - Insurance and legal liability | That the Government give priority to introducing legislation necessary to ensure that all home, contents and home unit insurance policies include flood cover and to establish a new national agency for flood risk management and flood reinsurance purposes. |
REC187-2924 | 6 - Insurance and legal liability | That whenever flood cover is included in home building insurance policies: |
REC187-2940 | 6 - Insurance and legal liability | That for home contents insurance policies, policyholders pay for that portion of the risk retained by the insurer and pay nothing for the remainder of the risk up to $100,000. For contents with a value greater than $100,000 policyholders then pay the full cost of the portion of risk exceeding $100,000. |
REC187-2957 | 6 - Insurance and legal liability | That the Commonwealth Government introduce a standard definition of flood in the form proposed in the ‘Reforming flood insurance: Clearing the waters’ consultation paper. |
REC187-2929 | 6 - Insurance and legal liability | That all home unit insurance policies include flood cover, in the same manner as for homes. |
REC187-2945 | 6 - Insurance and legal liability | That to facilitate flood risk information being made publicly available, Commonwealth, State and Territory governments grant indemnities to the providers of flood risk information if the information is obtained and provided in good faith and in the absence of any gross negligence. |
REC187-2962 | 6 - Insurance and legal liability | That the Insurance Council of Australia amend clause 4.5 of the General Insurance Code of Practice to extend the time within which claimants in natural disasters have the right to make further claims or lodge reviews after the finalisation of an initial claim to seven months from the date of the relevant natural disaster, regardless of when the initial claim was finalised. |
REC187-2934 | 6 - Insurance and legal liability | That all insurers offering small business insurance be obliged to include flood cover on an opt-out basis, instead of an opt-in/opt-out basis as at present, in all of their small business package policies. |
REC187-2951 | 6 - Insurance and legal liability | That access to insurance be enhanced through the development of alternative payment options, in particular: |
REC187-2967 | 6 - Insurance and legal liability | That the current formula for the cost of rebuilding of State and Territory assets under the Natural Disaster Relief and Recovery Arrangements be changed to expenditure before any insurance recoveries by the State or Territory rather than net of any insurance recoveries. |
Rec-ID | Code | Recommendation |
---|---|---|
REC158-3430 | 17 - Assets and technology | That the nominated marine safety authority is responsible for development of a declared asset system and is required to ensure that port/channel managers utilise and maintain the declared asset system. |
REC158-3429 | 38 - Agency/Department Reporting | That the nominated marine safety authority is required to ensure that incident notification and data recording requirements for Victorian commercial ports are consistent and adhered to. |
REC158-3428 | 38 - Agency/Department Reporting | That the nominated marine safety authority, in consultation with the Emergency Services Commissioner and senior emergency services personnel, is responsible for monitoring the implementation and auditing against appropriate performance standards, risk management guidelines and good practice guidelines. |
REC158-3432 | 17 - Assets and technology | That port/channel managers are required to ensure, through service agreements, licensing, direct acquisition or other means as appropriate, the availability of the critical Level 1declared assets. |
REC158-3431 | 17 - Assets and technology | That port/channel managers are required to identify in the declared asset system (in conjunction with the emergency services) critical Level 1 declared assets and other Level 2 declared assets, that may be required in support of a marine emergency within the port, and that identified resource availability, accessibility and call out time is recorded. |
Rec-ID | Code | Recommendation |
---|---|---|
REC149-3138 | 38 - Agency/Department Reporting | The current KPI measures used by the Regulator and industry need to be reassessed and the performance indicators need to be related to the risk profiles of the industry. The industry needs to develop the indicators, which need to be agreed and measured by the industry in discussion with other stakeholders. The KPI's selected should be published in comparison with the worldwide offshore industry and with other industries. NOPSA should continue discussions with Australian Safety and Compensation Council (ASCC) with a view to adopting their goals. |
Rec-ID | Code | Recommendation |
---|---|---|
REC121-3697 | 38 - Agency/Department Reporting | All train drivers’ defects reports should be entered by RailCorp into a computerised record and tracked to finalisation. |
REC121-3724 | 13 - Mapping and data quality | The ITSRR should establish a data and information management system, containing all data and information that it requires, to continually monitor the safety of the New South Wales rail system. |
REC121-3776 | 38 - Agency/Department Reporting | The Minister for Transport Services should retain, independently of ITSRR, safety auditors to provide a report to the Minister confirming or qualifying the contents of each such ITSRR quarterly report. |
REC121-3673 | 41 - Emergency Management exercises | Regular field training exercises should be conducted by RailCorp with the emergency services to ensure that the incident command system and rail displan are able to be fully implemented as quickly as possible and are reviewed and improved. |
REC121-3723 | 38 - Agency/Department Reporting | All ATSB accident investigation reports should be made public. |
REC121-3775 | 38 - Agency/Department Reporting | The Minister for Transport Services must table in Parliament, each such quarterly report by ITSRR. |
REC121-3656 | 17 - Assets and technology | Satellite telephones should be provided by RailCorp to all rail commanders at any emergency. |
REC121-3722 | 38 - Agency/Department Reporting | The ATSB should deliver any report of any such rail accident which it investigates to the Board of any rail organisation involved in the accident, ITSRR and the Minister for Transport Services. |
REC121-3774 | 38 - Agency/Department Reporting | The ITSRR must provide a quarterly report to the Minister for Transport Services on the progress made by RailCorp in implementing these recommendations, including: |
REC121-3712 | 38 - Agency/Department Reporting | RailCorp and ITSRR should co-operate with national programs for the collection, collation, trend analysis and dissemination of safety critical information. |
REC121-3729 | 38 - Agency/Department Reporting | All reports of the Chief Investigator of OTSI should be delivered, upon completion and without being reviewed, to ITSRR and the Minister for Transport Services. |
REC121-3703 | 6 - Insurance and legal liability | Alcohol and drug testing should be mandatory for any train driver or guard involved in any accident or incident. |
REC121-3725 | 13 - Mapping and data quality | The data and information management system should be compatible with any data and information management system established by the ATSB for the designated interstate rail network, provided that the establishment of a compatible system does not reduce the amount or quality of the information obtained by ITSRR below the optimum levels which it needs to conduct trend analysis, and otherwise properly manage the safety of rail operations in New South Wales. |