Argumentative points, as seen by CoCA, are:

1. No evidence of the need for increased regulation and increased costs on celebrants will be passed onto 70% of the marrying public (undesirable, unfair, etc.)
2. No guarantee they’ll improve marriage services (further regulation being counterproductive & undesirable) NOR, in themselves, ensure professional, knowledgeable & legally correct services.
3. The Bills are discriminatory in that they are applied to Commonwealth registered celebrants and not to celebrants said to be, “regulated” by States & Territories (arguably these are not effectively regulated seeing they have little or no appointment criteria and no ongoing training)
4. Deregistration (not on the basis of poor performance) for non-payment of annual fee could give rise to AAT and other appeals and also discriminate against couples choice of celebrant.
5. The main reason stated in justifying the fee is to conduct celebrant reviews when, at the same time, the Department is ceasing the 5 yearly reviews!
6. Bills can be seen as revenue raising despite claims to the contrary.
7. The Bills do not require any cost-cutting or non-duplication of services on behalf of the Department, but instead allow ever increasing levies on celebrants.
8. The Bills contribute to celebrants’ existing burden of working unusual hours, under often any and every condition and impose unreasonable additional costs on income deprived celebrants by way of annually renewable appointments plus costs of ongoing professional development, etc.
9. The Bills remove 40 years of lifetime appointments replacing them with annually renewable appointments contributing to a greater turnover of celebrants where more experienced celebrants are replaced by people with less experience.
10. The Department originally proposed an annual fee of $600 and when celebrants said the amount was outrageous, reduced it to $240 without explaining it could revert to $600 (only discovered when Bills made available).
11. Exemptions from the annual fee may be made to celebrants in ‘remote’ locations when, in fact, all celebrants battle to make ends meet with average annual number of weddings per celebrant being 6 (in 2003 average was 30 weddings per annum per celebrant).

12.    The Bills permit ongoing automatic appointment or rejection of new celebrants, within 3 months of application, thus maintaining the unworkable policy of appointing limitless numbers of celebrants. (Not strictly related to the Bills, but a point worth making).

13.    Neither do the Bills extend the now expired cap on appointments allowed in Sec 39(E), but contribute to exacerbating the oversupply of celebrants. (Again not strictly related to Bills, but worth considering).

Associations and individual celebrants wishing to make submissions are reminded to ensure points relate directly to matters raised in the Bills or introduce links or arguments showing the relationship to matters raised in the Bills.

The CoCA website gives further insight into the issues being raised, a number of other considerations and asks all celebrants in their own submissions to support the CoCA position on:

http://www.coalitionofcelebrantassociations.org.au/campaign-now/