I'll step back a little from my timing criticism. There's no publication date I can see on the Discussion Paper, but pdfinfo says it was created on 15-Nov-2021. And the webpage says "Last updated: 6 December 2021". So, if that's to be believed, the the request for submissions did have a better lead-time. Maybe it just took a while to get to EFA and then to me. And the Government is saying that the consultation process will continue in various forms through 2022, with an eye to legislating in 2023. Maybe there's some Government mailing list we can get on to get notifications about submissions...
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