The Australian Centre for Excellence in Antarctic Science

Name (Individual/Organisation)

The Australian Centre for Excellence in Antarctic Science

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 ARC is the only funding body for blue skies non-medical research in Australia. As such Discovery style research must be protected from erosion and short term transfer to linkage programs.

The ARC should be encouraged and have the ability to identify, in consultation with universities and government, areas of thematic priority and specific funding dedicated to such programs. At present this largely occurs within the SRI scheme under the Ministers direction. Durations of programs should be flexible depending on the nature and scale of the need.

The ARC should have explicit ability to form bilateral or multilateral partnerships with other nations, including forming joint funding schemes, where clear benefit to international partnership exists. An excellent example of this occurring is the joint NSF-NERC program, with one example focuses on sustained research in an area of challenging logistic and scientific endeavour where international cooperation would allow for significantly enhanced progress in understanding global sea-level risks from West Antarctica.

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.

The governance model of the ARC should be revised to create a board which reports to the Minister and the CEO reports to the Board. This replicates the setup of similar agencies overseas, such as the UK research councils.

The ARC Board would benefit from inclusion of experience from overseas funding agencies. Such experience would allow ARC to ensure it is operating with world’s-best practice.

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.

The ARC must fund the world’s best research, and the gold standard in testing the validity, robustness and quality of ideas is peer review. It is difficult to see this changing in the coming decades and hence it seems appropriate to legislate peer-review as pre-eminent to protect free enquiry and fundamental research, except in the case of national security or similar exceptional situations. Governments may influence funded research through establishing thematic areas of research or national priority areas.

Short expression of interest rounds have been suggested as a way to reduce peer review burden. Such assessments could only approach the standard of full proposal peer review if the ARC peer review college were dramatically expanded in its breadth of expertise. Anything other than a major expansion would reduce expressions of interest applications to populist areas of research, such as may make the front page of the newspaper.

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

Prior to the National Interest Test, a public summary was prepared for all applications. The creation of the NIT appears to be in reaction to poorly worded summaries and, at times, ideological views of the Minister. The multiple iterations of NITs to provide an appropriate level of readability and expression of national interest suggests that a subjective approach to NITs is not workable. A public summary that passes a standardised and automated readability/plain English test at a specified reading level removes this subjectivity while providing the public (and the government) important high-level understanding of the work to be undertaken and its value.

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

The time from proposal submission to grant commencement is far too long, including by international standards. SLower-than-competitor review to commencement periods competitiveness and creates difficulty in retaining world-leading expertise. Fixed announcement dates will assist but further action is possible. The length of the ARC review-to-approval cycle should be benchmarked regularly against other nations and an review undertaken of international best practice. The length of the ARC award-to-commencement period should be tabulated by ARC for each University and summarised publicly. ARC should consider if there are ways to work with universities to speed up the process of award-to-commencement. UK research councils allow spending immediately upon receipt of the award letter, without formal agreements in place, and the obstacles to this should be explored to improve commencement speed. Standardised agreements between all Australian universities should be explored, reducing much-duplicated legal effort and delays.

Science and Research priorities have long been problematic since it is not clear what the intent is in the context of the ARC funding rounds. If there are areas where research effort is required or capacity is needed, these should be identified in explicit thematic funding rounds. The recent shift to being able to identify, in free text, a particular government policy gives welcome recognition that many policies exist in government.

In providing strict rules for formatting documents, research offices are bound to following them to the letter (literally). Minor changes between rounds, sometimes in formatting and wording of templates, creates rounds of reviews and edits for no gain but with substantial administrative overhead.

Translating complex budget spreadsheets, via manual entering into RMS, is burdensome, especially for large and complex centres such as in the Linkage program.

Pre-prints, appropriately identified, should be a valid source of information.

The ARC should reconsider the value of tabulating in-kind support for grants as any tabulation then creates further administration in reporting, and for external partners this is almost impossible to achieve. Tabulating in-kind support results in perverse outcomes, including non-participation of PIs in research which they would otherwise collaborate in, or in gaming to maximise the apparent contribution. It is interesting that the conventional FTE for a CI in Australia (20%) is factor 2 greater than in the UK (5-10%) or US (1 month/yr) indicating that the values associated are being inflated in Australia for some perceived gain.

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 volume of paperwork for an ARC application is disproportionate to competitor nations. A typical ARC proposal is factor 2-3 longer than a US or UK proposal. The volume of information required on individual researchers is particularly high compared to other countries where a 2page CV and a short summary of the contribution of each researcher to the particular proposal is sufficient (UK NERC). The ROPE, while well intentioned, in trying to normalise against opportunity, has clearly not worked and best practice review is required. The proposal for our Centre was 1389 pages long – of course nobody would have read it in full.

The paperwork burden for international researchers is entirely disproportionate to international norms. This results in some overseas collaborators declining to participate in research or additional workload for domestic researchers in preparing ROPE sections on their behalf. The international norm is a letter of support outlining the contribution, quantifying in some cases the FTE contribution.

ARC relies very heavily on researcher track record to make decisions around grants. This may stem from the lack of breadth of knowledge in ARC panel of experts. Reducing ROPE paperwork, and less reliance on track record than ideas, will likely require more panels, and indeed ARC has a very small number of panels by international standards given the breadth of research covered. The approach to panel makeup should be benchmarked internationally.

ARC currently seeks reviews from international researchers but requires of them first to give legal agreement. This is disproportionate level of legality to the approach taken by other countries which does not require legal agreement. Legal agreement is a deterrent and its use should be reviewed.

It is common practice internationally for researchers to suggest reviewers for this proposal or similar ones and ARC should consider requesting this information in grant submission as an optional category.

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?

Overall, the ARC should be required to benchmark activities and procedures against international agencies on a regular basis. This will prevent ARC from drifting into disproportionate bureaucracy and unwieldy procedures. Best practice from ARC will also benefit overseas agencies.

Submission received

13 December 2022

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