September 30, 2022
Department of Industry, Science and Resources
Critical Technology Hub
Cc: Defence Science and Technology Group (DSTG) consultation on Analytics and Metrics for Critical Technologies
The Group of Eight (Go8) welcomes the opportunity to comment on the Consultation Paper on the 2022 List of Critical Technologies in the National Interest (the List). Please note that this submission represents the views of the Go8 as a whole and individual members may also choose to provide a submission. Also note that we are happy for this submission to be published and have no wish for any of it to be treated as confidential.
The Go8 comprises Australia’s leading research-intensive universities with seven members in the top 100 globally. Go8 universities conduct 70 per cent of Australia’s university-based research as part of an annual investment of approximately $7.2 billion in R&D.
This includes world-leading research groups in the almost 80 distinct fields of research listed as underpinning science in the 29 Critical Technology Profiles published to date.
The Go8 raises two key recommendations with respect to Critical Technologies:
- There should be greater clarity in both the definition of a Critical Technology and the stated purpose and use of the Critical Technology List.
- There should be closer coordination between areas of Government working on or with the Critical Technology List and relevant stakeholders.
In framing these recommendations, it is important to note that a Go8 expert working group participated in detailed consultations with the Department of Prime Minister and Cabinet (PM&C) on the development and refining of the original 2021 List. During this engagement process, these two important recommendations were proposed to PM&C.
- There should be greater clarity in both the definition of a Critical Technology and the stated purpose and use of the Critical Technology List
In both the current consultation paper and in the 2021 List, critical technologies are defined in the same, extremely broad terms: Critical technologies are current and emerging technologies with the capacity to significantly enhance or pose risk to our national interest and Australia’s ability to harness the opportunities created by critical technologies has significant impacts on our economic prosperity, national security, and social cohesion.
There is no indication of how specific or narrow the critical technologies should be. For example, should Artificial Intelligence (AI) be a single critical technology or a suite of related critical technologies? Should critical technologies focus on classes of physical devices/technologies such as drones or intangible technologies such as software?
Similarly, there is no clear definition of what is considered to satisfy the national interest or indeed how a critical technology should be seen to map to the national interest by enhancing economic prosperity and social cohesion, or how a critical technology could pose a risk to national security.
The purpose and use of the overarching List in which the critical technologies appear requires clarification, which is lacking in both the 2021 List and the current consultation paper.
In the consultation paper, the stated purpose of the List is as a signal to government, industry and academia of the critical technologies that may have national interest implications. Also … the List does not imply guaranteed prioritization of that there is a real or perceived risk to national security form that technology.
During the current consultation process, Go8 members received conflicting advice that the List will have both a predominantly national security focus and a predominantly economic focus. This simply adds to the confusion. Notwithstanding this, our universities do view the List as aligned to issues of national security.
Indeed, we have already seen the 2021 List being used in a national security context through the recent consultation by the Department of Home Affairs (DHA) on the implementation of the Migration Amendment (Postgraduate Research in Critical Technology – Student Conditions) Regulations 2022.
Additionally, one Go8 member reported having received correspondence from the Australian Research Council (ARC) regarding international engagement and research related to the List.
- There should be closer coordination between areas of Government working on or with the Critical Technology List and relevant stakeholders.
The Go8 notes that there are currently (at least) three parallel Government consultation processes under way:
- the List consultation
- the Defence Science and Technology Group (DSTG) consultation on Analytics and Metrics for Critical Technologies; and
- the DHA consultation on the implementation of the Migration Amendment (Postgraduate Research in Critical Technology – Student Conditions) Regulations 2022.
Discussions with the Go8 have indicated that there is not an adequate level of integration between consultations to deliver a consistent vision and use of the List across Government. As the List does not identify whether critical technologies are included on the list from a national security perspective, there is a danger that the List may not be fit for purpose or may be misinterpreted for the purposes of the migration amendments implementation.
In any case, the DHA is operating from the 2021 List which will soon be superseded. This suggests a lack of proper coordination between arms of Government.
In the short term there will also be a raft of other Government initiatives that potentially require clarity of purpose and use of the List. These include the National Reconstruction Fund with its $1 billion Critical Technology Fund, revitalising the National Science and Research Priorities, the review of the Australian Research Council (ARC) – which funds the majority of non-medical research in Australian universities – and the development of the Universities Accord which will review the framework and funding of universities – including research – and consequently is vital to the development and adoption of critical technologies in Australia.
As an international example of an integrated government approach to CTs it is worth noting the development of the 2020 United States National Strategy for Critical and Emerging Technologies – which included a list of technologies. This list was updated in 2022 through a subcommittee of the National Science and Technology Council involving 18 Federal Government departments and agencies (with a strictly national security focus). Additionally, in August 2022 the US CHIPS and Science Act 2022[1] was passed, legislating a whole of government approach to driving economic prosperity through identified technologies.
While the Go8 does not necessarily suggest this as a template for Australia, it is indicative of the coordinated and whole of government approach that other nations are taking in dealing with critical technologies.
In closing, the Go8 notes that given the nature of these two overarching recommendations it is impossible to make further recommendations as to the inclusion or exclusion of specific critical technologies on the List.
However, the Go8 does commit to continuing to work with all areas of Government to try to bring greater clarity and a truly national approach to the consideration and support for critical technologies in the national interest.
If you would like to discuss further any points raised do not hesitate to contact Go8 Deputy Chief Executive, Dr Matthew Brown at matt.brown@go8.edu.au.
[1] https://www.state.gov/the-passage-of-the-chips-and-science-act-of-2022/