The Bill aims to increase ACC payments to some categories of persons. It contains a regulatory impact statement (RIS) certified by the Department of Labour that purports to make the case for these proposals. The attached analysis of the RIS by our consultant, Dr Bryce Wilkinson of Capital Economics Limited, finds that it is totally flawed. All the calculations in the RIS relate to transfers not to national economic benefits. It is an extraordinary indictment on the Department of Labour that its policy analysts appear not to know the difference between national economic benefits, which are relevant to the cost-benefit assessment component of an RIS, and transfers, which are not. It is beyond belief that the Ministry of Economic Development, which is supposed to have an audit role for RISs, could have accepted the Department’s analysis.