Submission to the Australian Competition and Consumer Commission

This submission provides some specific comments on various sections of the Australian Competition and Consumer Commission’s (ACCC) Draft Merger Guidelines. Overall, this document represents a significant and important advance over  the ACCC's previous guidelines. It incorporates a modern approach to anti-trust analysis and a clear statement of the type of  evidence an economist would consider in evaluating merger proposals from a competition perspective. My comments here are to address a few remaining specific issues which fall short of the standard that the Guidelines otherwise has adhered to. They are not meant to detract from the overall favourable impression that I have of them.