comet report
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Evaluation of the
Commercialising Emerging
Technologies (COMET) Program
Report, Findings and
Recommendations
Prepared for the Department of Innovation, Industry,
Science and Research (formerly the Department of
Industry, Tourism and Resources)
April 2008
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ACIL Tasman Pty LtdABN 68 102 652 148Internetwww.aciltasman.com.au
Melbourne (Head Office)Level 6, 224-236 Queen StreetMelbourne=VIC=3000
Telephone (+61 3) 9600 3144Facsimile (+61 3) 9600 3155Email [email protected]
DarwinSuite G1, Paspalis Centrepoint48-50 Smith StreetDarwin NT 0800GPO Box 908Darwin NT 0801
Telephone (+61 8) 8943 0643Facsimile (+61 8) 8941 0848Email [email protected]
BrisbaneLevel 15, 127 Creek StreetBrisbane QLD 4000GPO Box 32Brisbane QLD 4001
Telephone (+61 7) 3009 8700Facsimile (+61 7) 3009 8799Email [email protected]
PerthCenta Building C2, 118 Railway StreetWest Perth WA 6005
Telephone (+61 8) 9449 9600Facsimile (+61 8) 9322 3955Email [email protected]
CanberraLevel 1, 33 Ainslie P laceCanberra City ACT 2600GPO Box 1322Canberra ACT 2601
Telephone (+61 2) 6103 8200Facsimile (+61 2) 6103 8233Email [email protected]
SydneyPO Box 1554Double Bay NSW 1360
Telephone (+61 2) 9958 6644Facsimile (+61 2) 8080 8142Email [email protected]
For further information on this report please contact the Department of Innovation, Industry,
Science and Research.
http://www.aciltasman.com.au/http://www.aciltasman.com.au/http://www.aciltasman.com.au/mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]://www.aciltasman.com.au/ -
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Evaluation of the Commercialising Emerging Technologies (COMET) Program
Exec utive summary iv
Executive summaryLaunched in 1999 and enhanced in 2004, the Commercialising Emerging
Technologies (COMET) program is a competitive grants program that assists
micro and small businesses to commercialise their innovative goods or
services. The programs objectives are to:
increase Australias sustainable economic growth through stimulating thesuccessful commercialisation of Australian innovation
build sustainable and high growth firms by increasing prospects forsuccessful commercialisation of innovations through the attraction of
capital and partners.Tailored support is provided to customers through a network of Business
Advisers and third party Service Providers who assist with activities including:
management development
engagement of mentors
strategic and business planning
market research
market validity
intellectual property strategy
proven technology
capital raising
finding partnerships.
The purpose of this evaluation by ACIL Tasman is to assess the
appropriateness, efficiency and effectiveness of the program. In the course of
the evaluation ACIL Tasman has had extensive consultations with COMET
customers, the delivery network (the National Manager and Business Advisers)
and other stakeholders, as well as key personnel in the Department of
Innovation, Industry, Science and Research, in particular AusIndustry. Wehave greatly appreciated the input from these officials and the advice provided
to ACIL Tasman by the Innovation Australia Board. ACIL Tasmans
quantitative analysis has benefited from the data collected and held on the
COMET program by AusIndustry.
The following provides a brief summary of the evaluations assessment of the
program.
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Exec utive summary v
Appropriateness
Theobjectives of theprogramcontinueto beappropriateas they encompass thebenefits tothefirmand thenation as a whole. Further, they area responseto a verified need thatremains today, to improvethesmall and early stagefirms capacity to commercialisetheirinnovation.
Theobjectives of theCOMET programremain relevant and in ACIL Tasmans viewtheir substancecannot beimproved by amendments. Overall it is clear that stakeholdersarestrongly supportiveof theprogram. In particular it is recognised that thefocus in theobjectives on attractingcapital and partners areseen as integral to thesuccess of theprogramin achievinga widerangeof commercialisation outcomes.
Theremay beoverlap in thedelivery of theCOMET programs Tier 2 assistanceand
Commercial Ready Plus assistancebecausesomeCOMET companies may decidethatTier 1 fundingand Business Adviser assistancehas brought themto a stageof beinginvestment ready and consequently apply for Commercial Ready Plus rather thanaccessingTier 2 COMET funding(wheretherearehigher administrativeandcompliancecosts relativeto theavailablegrant). OnceCommercial Ready Plus becomesfully operational an assessment should bemadeof whether potential Tier 2 grantrecipients haveinstead elected to apply for Commercial Ready Plus.
The COMET program is unique in the combination of its objectives, delivery
model and its target customer base.
The COMET program is an appropriate program for achieving the objectives
of increasing Australias sustainable economic growth and building sustainable
high growth firms. The program aims to address market failures in the capital
market (particularly as investors over-estimate the risks associated with early
stage companies) and information asymmetry (very early stage growth
companies dont know what they dont know).
The majority of stakeholders consulted in the course of this evaluation were
very supportive of the COMET program, with the Innovation Australia Board
and members of the COMET Committee all pointing to the programs success
in achieving a wide range of commercial outcomes for COMET customers.
Consultation with COMET customers also indicated support for the program.
In ACIL Tasmans view the building of sustainable high growth firms is the
more important program objective, as it will in turn lead to increased economic
growth so long as the program leads to additional firms becoming sustainable.
As discussed below, the lack of baseline data makes it difficult to assess if
additionality is being achieved.
On the basis of ACIL Tasmans extensive stakeholder consultation and
analysis we consider that there is no need to change the substance of either
objective.
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Exec utive summary vi
Notwithstanding the concentration of innovation in metropolitan areas, the
COMET program should remain focussed on improving the nations eligiblebusinesses ability to commercialise their innovations. This is the COMET
programs point of difference when compared with general business assistance
and development programs.
Efficiency
Success fees havethepotential to distort Business Advisers behaviour. They should beremoved fromtheCOMET programand thus fromtheprograms eligibilityrequirements. Success fees should bereplaced with a different incentivestructureforBusiness Adviser activities. This incentivestructurewould includea focus on a rangeofoutcomes rather than a singleoutcomei.e. capital raising.
If success fees remain, theeligibility requirements should continueto includethesuccess feerequirement. In this situation, thepolicy on entities related to theCOMET customer company (which areestablished for thepurposeof raisingcapital) that arenot liableto pay success fees to Business Advisers under thecurrentarrangementsshould beaddressed.
COMETs outsourced delivery model is workingwell and key stakeholders (i.e. theBoard and most COMET Committeemembers) consider that COMET should bemaintained as an outsourced model.
The administration of the COMET program has a number of strengths while
there are areas requiring improvement. The model for outsourced programdelivery is widely applauded, with strong support for its maintenance. Several
key stakeholders, including the Innovation Australia Board and members of
the COMET Committee considered that the model should remain outsourced.
For example, the Innovation Australia Boards advice to the evaluation noted
that the outsourced delivery model was fundamental to the programs success.
Further, most members of the COMET Committee supported the outsourced
model, with many explaining that the outsourced model was successful because
of the National Managers and the Business Advisers hands-on experience
with commercialisation. It was argued that this experience brings considerable
value to the program. This value is evident from COMET customers
satisfaction with the overall quality of Business Adviser assistance and Business
Advisers development of their commercialisation skills. However, there is
evidence to suggest that COMET customers were less positive about the
Business Advisers input to the delivery of commercialisation outcomes which
involves third partiessuch as raising capital from business angels or venture
capital funds, borrowing money, licensing, and joint ventures and strategic
alliances. Overall, it is ACIL Tasmans view that the outsourced model is
working well.
To be eligible to apply for a COMET grant, potential applicants must meetcertain criteria. These criteria were reviewed as part of the evaluation and, with
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Exec utive summary vii
the exception of the requirement that the applicant must be prepared to enter
into a success fee agreement with the COMET Business Adviser and theminimum company age criterion, no changes were suggested. In regards to the
age criterion, ACIL Tasman considers that age may not be a relevant or
necessary criterion when it is considered that firms that meet the turnover
criterion may also be more than five years old or have traded for more than
five years (including through related entities). Such would be the case where
an existing company may have a number of innovations under development,
each at different stages of commercialisation potential or generating revenue.
It may also be the case that the innovation process is a relatively new activity,
for a long established business. For these reasons the consultant sees merit in
relaxing the age eligibility criterion as it does not appear to be a good predictorof firm eligibility.
The administration of the COMET program, while effective, appears intensive
when compared with other programs administered by AusIndustry, in
particular with the recently introduced Commercial Ready Plus. It is the
consultants view that the less intensive expenditure controls and lower
reporting requirements in Commercial Ready Plus are more reflective of best
practice. If similar practices could be introduced into the COMET programs
administration it could relieve the burden on AusIndustry, COMET customers
and Business Advisers alike.
AusIndustry has recently completed an efficiency review focussed on
improving efficiencies without materially increasing risk. Importantly, the aim
was to reduce administration on customers, the Business Adviser network, the
National Manager and AusIndustry. The efficiency review made a number of
recommendations to refine the process aligning grants, plans and acquittals.
ACIL Tasman has also suggested changes to the approval and application
processes which have the potential to address a number of issues and concerns
raised throughout the evaluation, namely:
the lack of baseline data to assess the extent of any unmet demand for theprogram and the level of additionality
a role for the COMET Committee in providing technical assistance andadvice
duplication of tasks that can reduce the efficiency of the process and mayinhibit the responsiveness of the program to stakeholders
better management of the pipeline of applications
matching customers and Business Advisers, based on Business Adviserworkload and expertise.
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Exec utive summary viii
Further improvements to the program could be achieved by allowing for more
flexibility in certain areas, including allowing for some variation in the timelimit for program participation in the event of extenuating circumstances.
Business Advisers and some survey respondents have identified certain early
stage commercialisation activities that they feel are necessary to
commercialising an innovation, but which are not currently included as eligible
activities for COMET funding. ACIL Tasman sees merit in increasing the
opportunity for in-house grant expenditure for prototype development and
attendance at trade shows and the like, as these activities could potentially
improve commercialisation outcomes.
The success fee element of the COMET program has come under scrutiny inthe course of this evaluation for a number of reasons. In particular:
Potential COMET applicants who wish to raise capital must be prepared toenter into a success fee agreement with their COMET Business Adviser tobe eligible to apply for a COMET grant.
While success fees align Business Advisers and customers interests inraising capital, there is the potential for a bias in the activities undertakenby the Business Advisers towards only those capital raising outcomes
which pay a success fee.
Survey respondents, when asked about the payment of success fees, were
generally supportive of the payment of a success fee provided there was astrong link between the Business Advisers input and the capital raising.
Some business angels and fund managers that are investing in pre-seed,seed and start-up companies contacted during the course of the evaluation
were concerned that it is inappropriate for the success fee to be paid fromthe capital raised to finance the future development or growth of thecompany.
In recent years other innovation programs (for example, AustralianIndustry Productivity Centres) have adopted different outsourced deliverymodels which do not use a success fee incentive arrangement.
As an incentive mechanism for the COMET program, success fees have been
successful in many respects. Business Advisers are strongly of the view that
success fee payments are an integral part of the compensation they receive for
working in the COMET program, confirming that success fees are
instrumental in attracting and retaining high calibre private sector consultants.
Overwhelmingly the majority of successful applicant companies (70 per cent)
interviewed by ACIL Tasman wanted to raise capital while in the program. For
these companies and for this single outcome, the success fee arrangement
certainly assists in aligning the Business Adviser endeavours with a major
interest of the company. The high proportion of COMET customers wishingto raise capital many reflect the fact (argued by many stakeholders) that capital
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Evaluation of the Commercialising Emerging Technologies (COMET) Program
Exec utive summary ix
raising is an integral part of early stage seed or pre-seed business (i.e. those that
make up the COMET population). Alternatively, it may indicate that a biasexists in the selection of applicants, given the possibility for Business Advisers
to earn success fees from capital raising commercialisation outcomes. ACIL
Tasman has been unable to substantiate whether there is such a bias in the
COMET program, as the necessary baseline data is not available. ACIL
Tasman does, however, consider that an alternative incentive structure which
would focus on a range of commercialisation outcomes for the program rather
than a single outcome (capital raising) would be more appropriate.
ACIL Tasman sees considerable merit in replacing the success fee paid to
Business Advisers with a new remuneration package consisting of a higher
consultancy fee plus incentive payments that are linked to agreed BusinessAdvisers KPIs contained in new Business Adviser contracts with the
Commonwealth. The Business Adviser KPIs could cover all or any of the
commercialisation outcome targets identified under the programs outcome
monitoring, including capital raising, partnerships and alliances.
ACIL Tasman also considers that the value of the National Managers and
Business Advisers consultancy fees should be maintained in real terms.
Effectiveness
TheCOMET programis effectivein improvingtheability of themajority of itscustomers to commercialisetheir innovation as evidenced by thenumber ofcommercialisation outcomes reported to AusIndustry and by thedramaticchangeinsurvey respondents assessment of their ability to commercialisetheir innovation afterparticipatingin COMET.
It is difficult to determinehowCOMET is improvingtheamount of commercialisationactivities undertaken as thereis insufficient data on thecommercialisation activities ofcompanies not participatingin COMET. However, it appears that theprogramisimprovingthequality of commercialisation activities undertaken by many COMETcustomers. This findingis based on:
thecommercialisation knowledgeand skills of companies applyingfor COMET thenumber and typeof commercialisation activities undertaken
theproportion of companies achievingoutcomes.
Thereis evidenceto suggest that theCOMET program, by ensuringCOMETcustomers aredevelopingtheskills necessary to managethecommercialisation process(and hencetheir business), has improved COMET customers potential to besustainableand high growth businesses.
Sincetheprogramcommenced in 1999, thelevel of theCOMET grant has declined inreal terms.
Over the life of the COMET program (up to 30 June 2007) 1,351 participantshave achieved, or are achieving, a wide range of commercialisation outcomes
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Exec utive summary x
including capital raising and partnerships. Significantly, AusIndustry reports
the following: 603 capital raisings
1,138 partnership arrangements, where COMET customers entered intosome form of agreement which could be considered as a partnership,including
415 alliances
143 licenses
580 other partnership agreements
417 innovations taken through to the production stage.
In ACIL Tasmans survey of COMET program participants most respondents
reported that their ability to commercialise their innovation had improved as a
result of participating in the program (seeFigure ES 1.)
Figure ES 1 Ability to commercialise innovation
Before participating in COMET After participating in COMET
Data source: Successful applicant survey.
Further, COMET is improving the quality of commercialisation for many
customers. At a higher level, COMET has improved some customers potential
to become sustainable, high growth companies when employment and annual
sales are considered.
To date over $400 million in capital has been raised by the companies who
have participated in the COMET program. As observed by the Innovation
Australia Board the program has excellent leverage of 6:1 in relation to
investment funds to companies compared to Commonwealth funding. It
appears that no other innovation program has achieved such high leverage.
Because of a lack of baseline data there is insufficient evidence to conclusively
say that the COMET program has contributed to an increase in Australias
sustainableeconomic growth.
As noted previously, the outsourced model is generally considered to be highlyeffective among stakeholders, and integral to the COMET programs success.
Very poor12%
Poor33%
Average40%
Good12%
Very good3%
Very poor1%
Poor4%
Average19%
Good49%
Very good27%
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Exec utive summary xi
Business Advisers were viewed very highly by customers, however more so in
the activities where the outcome was not affected by a third party decision.Similarly, Service Providers were well regarded by COMET customers.
ACIL Tasman considers that there are benefits to be gained from the greater
use of the expertise of the COMET Committee within the program. Further,
as the National Manager position plays a pivotal role in the COMET program,
and has technical and innovation experience in common with the Committee,
ACIL Tasman sees merit in actively strengthening this relationship to the
benefit of the program. For instance greater alignment between program
delivery and program governance could be encouraged by giving Committee
members a role in the assessment of applications. It could also assist the
National Manager to better understand aspects of the Committeesdeliberations.
The Innovation Australia Board, through its various Committees, plays an
important role in the federal governments innovation programs. Program
KPIs for COMET are set by the Boards COMET Committee and are
reported against in annual Strategic Plans. ACIL Tasman has made a number
of suggestions for change to the KPI targets. These suggestions aim to ensure
that the KPI targets reflect the nature of the program correctly. For example, it
is not logical for certain KPI targets to necessarily increase over time as the
number and nature of outcomes obtained by the population in COMET at anypoint in time will depend on the commercialisation needs of that particular
population.
Building COMET customers ability to commercialise their innovation is a
fundamental component of the program. ACIL Tasman therefore also
recommends that consideration be given to the introduction of a new KPI
(and accompanying target) to assist in assessing changes in COMET
customers ability to commercialise their innovations as a result of their
participation in the program.
During the evaluation it was drawn to ACIL Tasmans attention that the realvalue of the grant has declined over time. This is undesirable in view of the
significance of Service Providers to the program and the rise in their fees over
time. ACIL Tasman sees merit in increasing the grant to a level that would
maintain its value in 2004 terms and indexing the grant annually(by either the
consumer price index or preferably by growth in average weekly earnings of
professional managerial adults).
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Summary of Key Findings xii
Summary of Key Findings
Key Finding 1
The objectives of the program continue to be appropriate as they encompass the benefits to the firm and the nation
as a whole. Further, they are a response to a verified need that remains today, to improve small and early stage
firms capac ity to commercialise innovation.
Key Finding 2
The objectives of the COMET program remain relevant and in ACIL Tasmans view their substance cannot be
improved by amendments. Overall it is clear that stakeholders are strongly supportive of the program. In particular it
is recognised that the focus in the objectives on a ttrac ting capital and partners are seen as integral to the success of
the program in achieving a wide range of commercialisation outcomes.
Key Finding 3
There may be overlap in the delivery of the COMET programs Tier 2 assistance and Commercial Ready Plus
assistance because someCOMET companies may dec ide that Tier 1 funding and Business Adviser assistance has
brought them to a stage of being investment ready and consequently apply for Commercial Ready Plus rather than
ac cessing Tier 2 COMET funding (where there are higher administrative and compliance costs relative to the
available grant). Once C ommercial Ready Plus becomes fully operational an assessment should be made of
whether potential Tier 2 grant recipients have instead elected to apply for Commercial Ready Plus.
Key Finding 4Success fees have the potential to distort Business Advisers behaviour. They should be removed from the C OMET
program and thus from the eligibility requirements. Success fees should be replaced with a different incentive
structure for Business Adviser ac tivities. This incentive structure would include a focus on a range of outcomes rather
than a single outcome i.e. capital raising.
If success fees remain, the eligibility requirements should continue to include the success fee requirement. In this
situation the policy on entities related to the C OMET customer company (which are established for the purpose of
raising capital) that are not liable to pay success fees to Business Advisers under the current arrangements should be
addressed.
Key Finding 5
COMETs outsourced delivery model is working well and key stakeholders (i.e. the Board and most COMET
Committee members) consider that COMET should be maintained as an outsourced model.
Key Finding 6
The COMET program is effective in improving the ability of the majority of its customers to commercialise their
innovation as evidenced by the number of commercialisation outcomes reported to AusIndustry and by the
dramatic change in survey respondents assessment of their ability to commercialise their innovation after
participating in COMET.
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Recommendations xiii
Key Finding 7
It is difficult to determine how C OMET is improving the amount of commercialisation ac tivities undertaken as there is
insufficient data on the commercialisation activities of companies not pa rticipating in COMET. However, it appears
that the program is improving the quality of commercialisation activities undertaken by many COMET customers. This
finding is based on:
the commercialisation knowledge and skills of companies applying for COMET
the number and type of commercialisation activities undertaken
the proportion of companies achieving outcomes.
Key Finding 8
There is evidence to suggest that the COMET program, by ensuring COMET customers are developing the skills
necessary to manage the commercialisation process (and hence their business), has improved COMET customers
potential to be sustainable and high growth businesses.
Key Finding 9
Since the program commenced in 1999, the level of the COMET grant has declined in real terms.
Recommendations
Recommendation 1
The COMET programs contrac t management and reporting requirements should be reduced in line with those of
Commercial Ready Plus.
Recommendation 2
Relaxing the eligibility criterion regarding a companys age should be considered because it does not appear to be
a good predictor of firm eligibility.
Recommendation 3
Consideration should be given to increasing flexibility in terms of the eligible activities funded by the COMET grant.
Recommendation 4
In any extension of the program, consideration should be given to reviewing the Business Adviser consultancy fee to
reflec t the growth of income of equivalent professionals since 2004.
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Recommendations xiv
Recommendation 5
In any extension of the program, consideration should be given to replacing Business Adviser success fees with
another incentive mechanism to link the interests of the Business Advisers to those of C OMET customers. A possible
approac h could be as follows: introduce a two tier consultancy fee, with the first tier based on the current
consultancy fee (but indexed to maintain it in real terms). The second tier would be an additional sum, which is paid
on a bi-annual basis based on performance against agreed Business Adviser KPIs contained in new contracts with
the Commonwealth.
Recommendation 6
The COMET Committee should consider reviewing the current KPI targets in the next financial year to ensure that KPI
targets are better aligned with the principles of the program.
Recommendation 7
The COMET Committee should consider the addition of a new KPI that measures the customers ability to
commercialise before and after participating in COMET.
Recommendation 8
In any extension of the program, consideration should be given to increasing Tier 1 and Tier 2 grants, by at least the
CPI but preferably by the change in Average Weekly Earnings (AWE) of professional managerial adults, and adjusted
annually.
Recommendation 9
Consideration should be given to introducing a new application and approval process to:
address the current lack of baseline data
increase the engagement of the C OMET Committee, in particular for their skills and knowledge
minimise duplication of tasks
better manage the pipeline of applications
assist in matching customers and Business Advisers.
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Contents
Executive summary iv
Summary of Key Findings xii
Recommendations xiii
1 Scope of the Evaluation 1
2 Methodology 2
2.1 The consultation process 2
2.1.1 Issues Paper 2
2.1.2 Stakeholder consultation 3
2.1.3 Desktop analysis 6
2.1.4 Comparison of state and industry breakdown in samplegroups 8
2.1.5 Review of Departmental documentation 9
2.2 Referencing 9
2.3 Report outline 10
3 The COMET program 12
3.1 Governance and delivery 12
3.1.1 Governing network 13
3.1.2 Delivery network 14
3.1.3 COMET post-September 2004 15
3.2 Funding 16
3.3 Success fee 17
3.4 Support 17
4 Appropriateness 21
4.1 The COMET program rationale 22
4.1.1 Inception of the program, 1999 22
4.1.2 The current COMET program 24
4.2 Sources of market failure 26
4.2.1 Capital market failure 27
4.2.2 Information failure 35
4.2.3 Additionality 37
4.2.4 Addressing the market failures 40
4.3 Appropriateness of the objectives 46
4.3.1 Macroeconomic objective 47
4.3.2 Microeconomic objective 50
4.3.3 Importance of each objective 51
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4.3.4 Amendments to the objectives 51
4.4 Alternatives to the COMET program 53
4.4.1 Alternative programs 54
4.4.2 State and Territories commercialisation programs 59
4.4.3 Alternative delivery network 62
5 Efficiency 68
5.1 Previous administrative reviews 68
5.2 COMET administrationa snapshot 69
5.3 Administrative costs 71
5.3.1 Comparison with Commercial Ready delivery costs 72
5.3.2 Business Advisers and National Manager administration costs 735.4 COMET program reporting 76
5.4.1 Nature and extent of reporting 76
5.4.2 Grants, assistance plans and reporting 85
5.5 Administrative controls 87
5.5.1 Pre-application controls 87
5.5.2 Application and approval controls 89
5.5.3 Complaint management 93
5.6 Program eligibility, merit criteria and guidelines 94
5.6.1 Eligibility 94
5.6.2 Merit criteria 107
5.6.3 Guidelines 110
5.7 Is the outsourced delivery model appropriate? 114
5.7.1 The history behind the delivery model 115
5.7.2 Roles in the management model 116
5.7.3 Views on the outsourced model 116
5.8 Remuneration of Business Advisers and National Manager 118
5.8.1 National Manager 118
5.8.2 Business Advisers 121
5.9 Co-contribution 130
6 Effectiveness 133
6.1 Effectiveness in meeting objectives 133
6.1.1 Microeconomic objective 134
6.1.2 Macroeconomic objective 158
6.2 Other issues pertaining to effectiveness 163
6.2.2 Measuring outcomes 169
6.3 Effectiveness of the COMET delivery network 175
6.3.1 AusIndustry 175
6.3.2 Business Advisers 176
6.3.3 National Manager 184
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6.3.4 Service Providers 185
6.3.5 Effectiveness of COMET network relationships 190
6.3.6 COMETs promotion in universities 196
6.3.7 COMETs wider promotion 199
7 Alternative options for program delivery 206
7.1 Proposals for alternative applications and approval processes 206
7.1.1 Option One 207
7.1.2 Option Two 211
A Terms of Reference A-1
B Issues Paper B-1
C Questionnaires C-1
C.1 Successful applicants C-1
C.2 Unsuccessful applicants C-15
C.3 Service Providers C-22
C.4 Committee C-24
C.5 National Manager C-26
C.6 Business Advisers C-28
C.7 Business Angels C-30
D Successful applicant survey results D-1E Unsuccessful applicant questionnaire results E-1
F Submissions received F-1
Boxes, figures and tables
Box 1 Regional differences in access to equity 35
Box 2 Global Integration: Changing Markets, New Opportunities 48
Box 3 Commercial Ready and Commercial Ready Plus 56
Box 4 New Industries Development Program (NIDP) 59Box 5 Outsourced delivery in Innovation programs 115
Box 6 Government Innovation Services 189
Figure ES 1 Ability to commercialise innovation x
Figure 1 Geographic distribution of successful applicant survey group (200203to 200607) 5
Figure 2 Industry distribution of successful applicant survey group (200203 to200607) 5
Figure 3 Geographic distribution of COMET customer data used in the 199900to 200102 desktop analysis 7
Figure 4 Industry distribution of COMET customer data used in the 199900 to200102 desktop analysis 7
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Figure 5 Comparative analysis of sample with entire COMET population industry distribution 8
Figure 6 Comparative analysis of sample with entire COMET population geographic distribution 9
Figure 7 Agreements executed by industryinception to 30 June 2007 19
Figure 8 Barriers to commercialisation, 2005, per cent of firms by employmentsize 24
Figure 9 Venture capital investment 2005as a percentage of GDP 30
Figure 10 Venture capital invested by development stage of company 32
Figure 11 COMET and other small companies, barriers to commercialisation 43
Figure 12 Barriers prior to participating in COMET 44
Figure 13 Business R&D intensity 2005percentage of GDP 49
Figure 14 Comparison of Business Adviser time allocationACIL Tasman andHoward Partners Review 74
Figure 15 Distribution of time spent on COMET Administration, e.g. reporting(days per year) 82
Figure 16 Days spent on reporting per annum, 200203 to 200607 83
Figure 17 Aggregate commercialisation outcomes achieved by COMET clients 135
Figure 18 Ability to commercialise innovation 137
Figure 19 Extent of COMETs role in selected commercialisation outcomes andactivities 140
Figure 20 Significance of COMET on business activity 148
Figure 21 Rating of specific Business Adviser services 179
Figure 22 Option Oneproposed enquiry, application and approval process 207
Figure 23 Option Twoproposed enquiry, application and approval process 212
Table 1 Differences in COMET pre- and post-September 2004 13
Table 2 Administrative roles of individuals and groups in COMET program 15
Table 3 COMET agreements executed by state/territoryinception to 30 June2007 18
Table 4 Regional/ Metropolitan Analysis - COMET Agreements executed bystate/territoryinception to 30 June 2007 18
Table 5 Sources of risk, early stage companies 29
Table 6 Private equity investment early stage companies, 2000 to 2006 33
Table 7 Barriers to commercialisation: COMET Survey respondents and ABSinnovative respondents 2005 42
Table 8 Quality of information available outside of COMET 45
Table 9 Quality of professional advice obtained before COMET 45Table 10 AusIndustry commercialisation programs 55
Table 11 State government commercialisation programs 60
Table 12 Comparison of COMET and 2007 Industry Statement programs 63
Table 13 Comparison of program design 64
Table 14 Administration of the COMET program 70
Table 15 AusIndustry innovation programs 71
Table 16 Comparative program delivery costs 200405 to 201011 72
Table 17 Business Adviser time allocationHoward Partners Review 73
Table 18 Breakdown of National Managers activities 75
Table 19 COMET program delivery costs 200405 to 201011 76
Table 20 Contract managementreporting requirements 78Table 21 Average time taken to process Quarterly Reports 80
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Table 22 COMET Customer sentiment on compliance cost of COMET 82
Table 23 Amount of support from Business Advisers in reporting 84
Table 24 Initial enquiry to application approval 87Table 25 Business Advisers source of COMET enquiries 88
Table 26 Average days spent processing applications 92
Table 27 Complaints registered under the new process 94
Table 28 COMET commercialisation outcomes 97
Table 29 Assumed and estimated success fees received, 200506 and 200607 105
Table 30 Reasons for COMET applications being rejected: 1 July 200426November 2007 108
Table 31 Remuneration structure, pre- and post-September 2004 121
Table 32 Average annual full time remuneration earned by selected professionalswhich may have similar qualifications to Business Advisers 122
Table 33 Market salaries 2007 128Table 34 Number of COMET outcomes and number of customers obtainingthese outcomes, 199900 to 200607 135
Table 35 Commercialisation activities undertaken by COMET customers 136
Table 36 Change in ability to commercialise an innovationquantum shift inrating level 138
Table 37 COMETs impactimproving ability to commercialise 138
Table 38 Capital raised by COMET survey respondents 142
Table 39 The impact of the COMET program in relation to improving youropportunity to raise capital 143
Table 40 Proposed and actual expenditure of commercialisation activities200405 to 200607 144
Table 41 Proportion of respondents achieving a commercialisation outcome 146Table 42 Average rankings for economic indicators 148
Table 43 Change in FTEs between application and 30 June 2007 149
Table 44 Influence of COMET on employmentgroup that experienced achange in employment between application and 30 June 2007 150
Table 45 Influence of COMET on employmentgroup that did not experience achange in employment between application and 30 June 2007 150
Table 46 Change in COMET customer employment between application and 30June 2007 151
Table 47 Changes to annual sales revenue between application and 30 June 2007 153
Table 48 Influence of COMET on annual salesgroup that experienced a changebetween application and 30 June 2007 154
Table 49 Change in COMET customer sales revenue between application and 30June 2007 155
Table 50 Proportion of COMET companies that are still active 156
Table 51 Survival of business by employment ranges (per cent) 157
Table 52 Estimated change in COMET companies employment 159
Table 53 Research and experimental development expenditure Australia (byemployment size) 163
Table 54 Government programs accessed by COMET customers, survey findings 165
Table 55 COMET customers accessing one or more AusIndustry grants and theR&D Tax concession 166
Table 56 Changes to COMET Program Key Performance Indicators 170
Table 57 Extent to which AusIndustry provided the skills necessary to
commercialise 176
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Table 58 Extent to which Business Advisers provided the skills necessary tocommercialise 177
Table 59 Overall satisfaction with COMET Business Adviser 177Table 60 Availability and assistance provided by Business Adviser 178
Table 61 Rating of general Business Adviser services 178
Table 62 Weighted respondent rating of specific Business Adviser services 180
Table 63 Customers seeking capital and that raised capitalranking of BusinessAdviser 182
Table 64 Customers seeking capital that did not raise capitalranking of BusinessAdviser 182
Table 65 Extent to which the National Manager provided the skills necessary tocommercialise 184
Table 66 Understanding of the role of the National Manager 185
Table 67 Extent to which Service Providers provided the skills necessary to
commercialise 185Table 68 Rating of the services provided by Service Providers 186
Table 69 Average time allocation by Business Advisers to all activities 197
Table 70 Time allocated by Business Advisers solely to sales activities 197
Table 71 Allocation of time spent by National Manager solely on sales tasks 198
Table 72 Uptake of COMET by public institutions (target vs. actual) 198
Table 73 How companies found out about COMET 199
Table 74 Quality of the content of COMET documentation produced byAusIndustry 200
Table 75 Time spent with Business Advisers prior to application 201
Table 76 Average Weekly Earnings, 2004 and 2006 203
Table 77 Average salaries for selected professionals 203Table 78 Current and proposed application/assessment options 215
Table 79 Administrative roles of individuals and groups in COMET program B-8
Table 80 Assistance, funding and success fees under COMET B-13
Table 81 Comparison of the assessment process under COMET B-14
Table 82 COMET submission providers F-1
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Scope of the Evaluation 1
1 Scope of the EvaluationACIL Tasman was commissioned by the Department of Industry, Tourism
and Resources (DITR) to undertake an independent evaluation of the
Commercialising Emerging Technologies (COMET) program. Subsequently
the name of the Department was changed to the Department of Innovation
Industry, Science and Research (DIISR).1
The purpose of the evaluation is to provide evidence to support any
recommendations for improvements or modifications that may need to be
made to the COMET program to maintain or improve outcomes.
Conducting the evaluation in 2007 is timely and appropriate for a number of
reasons:
It is five years since the last formal evaluation of the program.
The evaluation will assemble data and information to support and justifyany changes to COMET.
The evaluation enables a whole-of-program consideration of issues relatingto the appropriateness, effectiveness and efficiency of the program.
As part of the evaluation, ACIL Tasman has been required to undertake a
number of steps: develop a methodology for undertaking the evaluation that addresses the
Terms of Reference
undertake stakeholder consultations to obtain their information and views
examine relevant departmental files and other program relateddocumentation
collect and analyse all performance data available
analyse the data collected and develop findings and recommendationsaddressing the Terms of Reference
prepare an Evaluation Report which sets out data, findings from analysis ofdata, and recommendations which respond to the Terms of Reference
present progress of the evaluation, and findings and recommendations tothe Evaluation Steering Committee and to the Department.
The full Terms of Reference for this evaluation can be found at AppendixA.
1
We have retained the use of DITR throughout this report given that quotations andreferences in general refer to DITR.
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Methodology 2
2 MethodologyThis evaluation of the COMET program is guided by the Department of
FinancesDoingEvaluations: A Practical Guide.2
Appropriateness. The extent to which the program objectives/desiredoutcomes align with government priorities/policy and client needs
In essence the guidelines require
analysis of the COMET programs:
Efficiency. The extent to which program inputs are minimised for a givenlevel of program outputs, or to which outputs are maximised for a givenlevel of inputs
Effectiveness. The extent to which program outcomes are achievingprogram objectives.
The methodology used to undertake this evaluation is outlined below.
2.1 The consultation process
The consultation process conducted by ACIL Tasman was a major source of
information for the evaluation. The activities undertaken during this process
are outlined below.
2.1.1 Issues Paper
Due to the potential geographic spread of COMET participants and other
relevant or interested stakeholders, ACIL Tasman developed an issues paper
inviting submissions to the review. The issues paper outlined the COMET
program and noted questions for consideration (as outlined in the Terms of
Reference) and is provided at Appendix B.
The issues paper was advertised in TheAustraliannewspaper on 11 August
2007 and housed on the ACIL Tasman website. ACIL Tasman received 10
submissions, comprising: 5 from Service Providers and consultants
2 from members of the COMET delivery network
1 from a COMET customer
1 from an Academic
1 from a Venture Capitalist.
A full list of submission providers can be found at AppendixF.
2 Department of Finance (1994)DoingEvaluations: A Practical Guide, Commonwealth ofAustralia, Canberra.
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Methodology 3
2.1.2 Stakeholder consultation
Perhaps the most critical component of the evaluation process was the
consultation with key stakeholders, which was undertaken through a series of
structured and unstructured consultations. Stakeholders that participated in the
consultation process included: successful COMET applicants, unsuccessful
COMET applicants, all members of the COMET/ICIP Committee (including
the previous Chair of the Committee), the COMET National Manager and
Business Advisers (including past Business Advisers), Service Providers and
Business Angel investors.
Structured interviews
Structured interviews were conducted by phone. The interviews utilised a
survey questionnaire developed by the consultant (which was provided to the
respondent prior to interview) to obtain feedback, opinions and suggestions on
the program from:
105 successful COMET applicants
initially it was planned to undertake 105 interviewsthe number ofinterviews was subsequently revised down to 91 due to time constraints
and the difficulty in contacting applicants (the sample participated inthe program between 200203 and 200607)
20 unsuccessful COMET applicants
initially it was planned to undertake 20 interviews the number ofinterviews was revised down to 14 unsuccessful COMET applicantsdue to time constraints and the difficulty in contacting applicants (thesestakeholders participated in the program between 200405 and 200607).
Survey methodology
As part of the methodology the sample group surveyed were involved in the
program between 200203 and 200607. It was agreed that the participants in
the earlier years of the program had already been analysed as part of the
Howard Review in 2002. For this survey, the sample of successful applicants
aimed to directly reflect the proportion of participants in the program for each
year between 2002-03 and 2006-07. The sample size also aimed to reflect the
industry breakdown and geographic distribution of successful applicants. The
sample group was identified by DITR using these parameters. A copy of the
questionnaire used for successful applicants is provided at Appendix C. It
should be noted due to the nature of some of the survey questions not allsurvey participants provided responses for all questions.
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For the sample of unsuccessful applicants, it was recognised that there may be
considerable difficulties in contacting and obtaining information from theseapplicants from earlier years of the program. Consequently, the sample only
contained unsuccessful applicants between 200405 and 200607. A copy of
the questionnaire for unsuccessful applicants is provided at Appendix C.
The sample pool
The survey sample pool comprised more than the 91 successful and 14
unsuccessful companies. It should be noted that AusIndustry contacted all
companies in the sample pools to satisfy confidentiality issues prior to ACIL
Tasman contacting them.
For the pool of successful applicants, AusIndustry attempted to contact 170
companies. Of these companies:
91 were interviewed
48 could not be contacted by AusIndustry
26 did not want to participate
5 agreed to participate but could not be contacted by the consultant withinthe desired timeframe.
For the pool of unsuccessful applicants, AusIndustry attempted to contact 43
companies. Of these companies:
14 were interviewed
12 could not be contacted by AusIndustry
14 did not want to participate
3 agreed to participate but could not be contacted by the consultant withinthe desired timeframe.
Cha racteristics of the sam ple group
As noted in the survey methodology, the sample group for the successfulapplicant survey was stratified to ensure it provided as accurate as possible
indication of the industry and geographic mix of COMET customers.
With respect to geographic mix, most customers came from the east coast of
Australia (seeFigure 1), with 26 per cent of customers coming from New
South Wales, 24 per cent from Queensland and 19 per cent coming from
Victoria.
The industry stratification of the respondents is shown inFigure 2.Almost half
(49 per cent) of COMET applications were classified as being in the
manufacturing sector, with a further 21 per cent classified as property andbusiness services, and 10 per cent as health and community services.
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Methodology 5
Figure 1 Geographic distribution of successful applicant survey group(200203 to 200607)
Data source: ACIL Tasman analysis of AusIndustry data.
Figure 2 Industry distribution of successful applicant survey group(200203 to 200607)
Data source: ACIL Tasman analysis of AusIndustry data.
NSW
QLD
VIC
SA
WA
TASACT
NT
Manufacturing
Prope rty and business Services
Health and community services
Mining
Cultural and recreational services
Electric ity, gas and water supply
Communication services
Construction
Wholesale trade
Transport and storage
Education
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Methodology 6
Unstructured consultations
In addition to structured interviews, unstructured consultations wereconducted with key delivery and governing agents in the program, including:
all members of the COMET/ICIP Committee (face to face interviews) andone past Chair of the Committee (phone interview)
the National Manager (face to face interview)
16 COMET Business Advisersall current, and 2 previous advisers (faceto face interviews)
5 Business angel investors (phone interviews)
18 Service Providers (phone interviews).
While the interviews were unstructured, they were guided by a range ofquestions that can be found in Appendix C.
2.1.3 Desktop analysis
It was observed that a review in 2002 by Howard Partners analysed the
stakeholders from this period, consequently it was decided not to interview this
group. To obtain necessary customer data from the earlier years of the
program, a desktop analysis of AusIndustry data on 75 successful applicants
who entered the program over the period from 19992000 to 200102 was
conducted. The sample size reflects the same proportion of successfulapplicants for this time period as was used in the successful applicant survey.
Information (identical to that obtained for this 19992002 sample) was also
analysed for the successful applicant survey sample.
Cha racteristics of the sam ple
As noted, the sample group for the successful applicant survey was stratified to
ensure it provided as accurate as possible indication of the industry and
geographic mix of COMET customers. A similar approach was used with the
desktop analysis.
Similar to the successful applicant survey group representing customers from
200203 to 200607, most customers came from the east coast of Australia.
For this group however, 27 per cent were sourced from Queensland and 24
per cent from New South Wales. A further 20 per cent were from Victoria (see
Figure 3).
While demonstrating similar industry traits to the 200203 to 200607 group,
the industry breakdown was slightly different for the 19992000 to 200102
group (seeFigure 4). Manufacturing only represented 39 per cent of customers
(compared to 49 per cent), and property and business services represented
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Methodology 7
35 per cent of applications. Communication services was the third largest
group, representing 9 per cent of applications.
Figure 3 Geographic distribution of COMET customer data used in the199900 to 200102 desktop analysis
Data source: ACIL Tasman analysis of AusIndustry data.
Figure 4 Industry distribution of COMET customer data used in the199900 to 200102 desktop analysis
Data source: ACIL Tasman analysis of AusIndustry data.
Further, a review of a number of key questions from a sample of program
completion questionnaires submitted by COMET customers upon exiting the
program was also undertaken.
QLD
NSW
VIC
SA
WA
ACT
TAS
NT
Manufacturing
Property and business Services
Communication services
Transport and storage
Education
Health and community services
Cultural and recreational services
Mining
Electri city, gas and water supply
Construction
Government Administration and
Defence
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Methodology 8
2.1.4 Comparison of state and industry breakdown in samplegroups
A comparison of the industry sectors represented in the successful applicant
survey sample and the 1999-00 to 2001-02 desktop analysis sample with the
entire COMET program population shows that despite best efforts there is
over representation of some sectors and under representation of other sectors.
This is particularly evident in the manufacturing sector and the property and
business services sector in survey sample (seeFigure 5).
When the state breakdown is considered, there is greater representation among
the groups (seeFigure 6).
Figure 5 Comparative analysis of sample with entire COMET population industry distribution
Data source: ACIL Tasman analysis of AusIndustry data
0
5
10
15
20
25
30
35
40
45
50
Manufacturing
Propertyand
BusinessServices
CommunicationServices
HealthandCommunity
Services
Agriculture,
Forestry
andFishing
Electricity,G
asand
aterSupply
TransportandStorage
Construction
Education
Mining
Culturaland
RecreationalServices
FinanceandInsurance
WholesaleTrade
GovernmentAdministration
andDefence
PersonalandOther
Services
RetailTrade
Accommodation,
CafesandRestaurants
%
All customers
2003 to 2007
sample group
1999 to 2002
sample group
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Methodology 9
Figure 6 Comparative analysis of sample with entire COMET population geographic distribution
Data source: ACIL Tasman analysis of AusIndustry data.
2.1.5 Review of Departmental documentation
The final component of the evaluation was a review of relevant documentation
housed within the DITR on the COMET program.
2.2 Referencing
As outlined in Section2.1,ACIL Tasman has used results from the analyses of
multiple data and sample sets. This data is used throughout this report to
substantiate claims and present views. The following referencing is used
throughout the document:
successful applicant survey - the survey of the 91 COMET customers
Business Adviser survey - informal survey of 14 Business Advisers
Business Adviser consultation - additional information obtained from theBusiness Advisers
National Manager survey - informal survey of the National Manager
AusIndustry database - data retrieved by AusIndustry from its internaldatabase at the request of ACIL Tasman
program completion questionnaires - data extracted from a sample of 135completion questionnaires submitted by customers. As there weredifferences in the questions asked by AusIndustry, the results of thesequestionnaires were grouped into three time periods Version 1 (December2002), Version 2 (September 2005) and Version 3 (January 2006)
random sample of COMET customer data 19992007. - background
information from the AusIndustry database on the 91 COMET customersinterviewed that participated in the program between 200203 and 2006
0
5
10
15
20
25
30
NSW QLD VIC SA WA TAS ACT NT
%
All customers
2002-03 to
2006-07 sample
group
1999-00 to
2001-02 sample
group
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Methodology 10
07 and a random sample of 75 customers participating in the programbetween 199900 and 200102
AusIndustry information - general information obtained from AusIndustrypublications
successful applicant sample pool. the 170 companies contacted byAusIndustry (or that AusIndustry attempted to contacted) requestingparticipation in the successful applicant survey
COMET Strategic Plans the program strategic plans developed by theCOMET/ICIP Committee.
2.3 Report outline
Chapter 3 presents a brief description of the COMET program. Chapter4
considers the appropriateness of the program. Chapter5 considers the
programs efficiency. Chapter6 considers the programs effectiveness and
finally Chapter7 considers alternative options for delivery. These chapters
report findings and provide recommendations as issues arise. The full set of
findings and recommendations are reported in the Summary to this report.
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The COMET program 12
3 The COMET programThe COMET program was established in November 1999 and is part of a suite
of business assistance programs delivered by AusIndustry. AusIndustry is a
division of the Department of Innovation, Industry, Science and Research
(DIISR) and is the Australian Governments agency for delivering products,
services and information that support innovation, industry, science and
research.
The programs objectives are to:
increase Australias sustainable economic growth through stimulating thesuccessful commercialisation of Australian innovation
build sustainable and high growth firms by increasing prospects forsuccessful commercialisation of innovations through the attraction ofcapital and partners.
The COMET program is a merit based assistance program that aims to
increase the commercialisation of innovative products, processes and services
by providing individuals, early stage growth companies and spin-off companies
with a tailored package of support to improve their potential for successful
commercialisation.
An enhanced version of the COMET program was launched in September
2004, providing additional funding and an enhanced focus on regional areas
and public sector research. The differences between the original and enhanced
versions of the program are outlined inTable 1.COMET has been extended
until June 2011 with additional funding of $100 million as part of the
Australian Governments innovation statement,BackingAustralias Ability
BuildingOur Futurethrough Scienceand Innovation3
3.1 Governance and delivery
. More than 1,000 companies are
expected to benefit from the extended program.
The COMET program is delivered by DIISR with the assistance of the
Innovation Australia Board (the Board) (previously the Industry Research and
Development Board) and its COMET Committee.
The COMET program is delivered by AusIndustry with assistance from an
outsourced network of Business Advisers, who are lead by a National Manager.
3 Australian Government,BackingAustralias AbilityBuildingOur Futurethrough ScienceandInnovation, 2004, p.5.
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Service Providers are third party agents engaged by successful applicants to
provide specialised assistance necessary to commercialise an innovation.
Table 1 Differences in COMET pre- and post-September 2004
COMET pre-Sept 2004 COMET post-Sept 2004
Tailored Assistance
for Commercialisation
(TAC)
Management Skills
Development
Types of
assistance
offeredunder
COMET
Strategic andbusiness planning
Market research
Sound managementteam
Intellectual property
strategy
Proven technology
Working prototypecompletion
Assist with findingcapital, joint ventures
Participation in approved
management skillsdevelopment courses.
Management development
Engagement of mentors
Strategic and businessplanning, including an exportstrategy if appropriate
Market research
Market validity
Intellectual property strategy
Proven technology
Working prototype completion
Assist with finding capital,joint ventures
Grant
Funding
Up to 80% of agreedcost of agreed TACplan. Funding cappedat $100,000.
Up to 80% of the cost ofparticipating in approved
courses and/or up to 50%of cost of engaging amentor. Funding cappedat $5,000.
For companies:
* Tier 1: 80% of eligibleexpenditure (20% owncontribution). Funding cappedat $64,000.
* Tier 2: 50% of eligibleexpenditure (50% owncontribution). Funding cappedat $56,000. Fundingconditional on progress afterTier 1.
For individuals:up to $5,000for management skillsdevelopment.
Capital
raising
success fee
25% (subject toagreement) and only
payable whereCOMET supportexceeded $20,000.Success fee capped
at $100,000 percustomer.
2% and only payable whereCOMET support exceeds$20,000. Success fee cappedat $100,000.
Data source: COMET Customer Information Guides
3.1.1 Governing network
The Board is an independent statutory authority that, through various
committees, assists in the administration of Australian Government innovation
programs. COMET is one of 16 programs that the Board administers. Housed
within the Board is the COMET/Industry Cooperative Innovation Program
(ICIP) Committee(the COMET Committee), which is tasked with the ongoing
oversight of the program. The Chair of the COMET Committee sits on theBoard. The primary functions of the Committee are:
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oversighting and endorsing program guidelines and other key governancedocuments prior to consideration by the Board
reporting to the Board on program performance
advising the Board (and through it DITR) on issues and options relating tothe longer term direction of the program for possible input into the policydevelopment process
reviewing progress of the Operational Plan on a quarterly basis andsubmitting reports to the Board for consideration.
The COMET Committee is not involved in day to day management andconsideration of applications.
Committee members are required to have qualifications and experience incommercial and technical fields.4
The Innovation Australia Board Delegate (the Board Delegate) is located
within AusIndustry and is responsible for assessing applications against the
merit criteria.
A Program Delegate is also located within AusIndustry and has financial
oversight of the program.
3.1.2 Delivery network
AusIndustry is the program delivery agent for the Australian Government.
AusIndustry is responsible for the delivery of COMET.
AusIndustry engages a delivery network comprising a private sector consultant
National Manager and private sector COMET Business Advisers to assist in
the delivery of the program.
The National Manager has the primary role of oversighting some of the
functions involved in administering the program. Key activities include:
making recommendations on applications to the Board Delegate
assisting with the management of Business Advisers including reporting toAusIndustry on their performance
ensuring success fee arrangements are in accordance with programparameters
assisting in the development and reporting of the programs OperationalPlan.
A network of Business Advisers (currently 14) plays a central role in assisting
customers through the commercialisation process. Customers receive initial
4 http://ausindustry.gov.au/library/IRD_Chap4_web20070104022857.pdf.
http://ausindustry.gov.au/library/IRD_Chap4_web20070104022857.pdfhttp://ausindustry.gov.au/library/IRD_Chap4_web20070104022857.pdfhttp://ausindustry.gov.au/library/IRD_Chap4_web20070104022857.pdf -
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The COMET program 15
support in the application stage, however if they are successful they are
provided with advice and guidance from the Business Adviser during thecommercialisation process. The services of a Business Adviser are part of a
customers participation under the COMET program and are free. Business
Advisers can provide advice on raising capital from business angels or venture
capital funds, borrowing money, licensing, and joint ventures and strategic
alliances.
Business Advisers may assist successful applicants in engaging third-party
Service Providers that will help with the requisite knowledge and practical skills
in business management and commercialisation. Successful applicants use
COMET program grants to pay for the guidance and assistance provided by
the service providers.
3.1.3 COMET post-September 2004
With the launch of the enhanced COMET program in 2004 came a change to
some of the delivery and governing groups.Table 2 briefly outlines the roles
and functions of the delivery and governing networks pre and post September
2004.
Table 2 Administrative roles of individuals and groups in COMET program
COMET pre-Sept 2004 COMET post-Sept 2004
Individual/Group Role Individual/Group Role
IR&D Board
Responsible for program outcomes. TheIndustrial Research and Development(IR&D) Board receives directions from theMinister for Industry, Tourism and Resourcesunder the Industry Research andDevelopment Act 1986.
Innovation
Australia
Board
Responsible for program outcomes.Innovation Australia receives directions fromthe Minister for Industry, Tourism andResources under the Industry Research andDevelopment Act 1986.
COMET
Committee
Established in 2002. Sub committee of theIR&D Board and is charged with oversight of
the program
COMET /ICIP
Committee
Established in 2002. Sub committee ofInnovation Australia Board and is charged
with oversight of the program.
IR&D Board
Delegate
Involved in approvals process. Employee ofDITR. Makes final decision on applications.
Innovation
Aus tral ia
Board
Delegate
Involved in approvals process. Employee ofDITR. Provides assessment of merit to theProgram Delegate.
Review Panel
Consists of two National Managers and oneIR&D Board delegate. Involved in approvalsprocess.
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COMET pre-Sept 2004 COMET post-Sept 2004
Individual/Group Role Individual/Group Role
Two National
Managers
Manage the delivery of the program.Involved in approvals process.
One National
Manager
Assists AusIndustry manage the delivery ofthe program including makingrecommendations to AusIndustry onapplications, assessing the performance ofBusiness Advisers and ensuring success fee
arrangements are in accordance withprogram parameters.
10 Business
Adv isers
Assist in the preparation of applications.Assess the applications and makes arecommendation to the Review Panel
through a National Manager
14 Business
Adv isers
Assist in the preparation of applications.Assess applications and makes arecommendation to the Program Delegate
through the National Manager.
AusIndustry Administers the COMET program. AusIndustry Administers the COMET program.
ProgramDelegate
Involved in approvals process. Employee ofAusIndustry. Makes final decision on
applications.
3.2 Funding
The amount of financial assistance available under COMET is capped at
$120,000 (exclusive of GST) per customer. Financial assistance to individuals is
limited to a maximum of $5,000 (exclusive of GST) for the purpose of
management skills development. There is no minimum COMET grant size.
COMET financial assistance is available through a two-tier funding structure: Tier 1. Grant value of up to $64,000 (exclusive of GST). The rate of
assistance is available at 80 per cent of the eligible expenditure
Tier 2. Grant value of up to an additional $56,000 (exclusive of GST).The rate of assistance is available at 50 per cent of the eligibleexpenditure.
COMET funding is used to subsidise a successful applicants access to service
providers for activities that have been agreed by a Business Adviser. This can
include assistance in one or more of the following areas:
management development including participation in approved managementskills development courses
engagement of non-executive directors or mentors
strategic and business planning, including an export strategy if appropriate
market research
market validity
intellectual property strategy
proven technology (including finalising working prototypes).
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3.3 Success fee
The COMET program is unique in that it adopts a success fee structure as
payment for assistance that culminates in a capital injection for the COMET
recipient. The success fee payable to the Business Adviser intends to reflect the
time, effort and expertise of the Business Adviser in putting the COMET
recipient in a position that is attractive to investors.
The success fee is currently 2 per cent of the amount of capital raised, with a
cap at $100,000 (exclusive of GST) per customer. COMET recipients must
have received funding of at least $20,000 (exclusive of GST) to be liable to pay
a success fee.
The success fee is payable on capital that is received within two years of a
companys commencement date as outlined in the COMET Grant Deed. This
requirement also applies to those customers that end their participation in
COMET before they complete their Assistance Plan. Business Advisers are
also permitted to enter into a post-COMET private arrangement with
customers, but not for three months after the customer completes the
program.
Success fee agreements are finalised between the customer and their Business
Adviser prior to execution of the COMET Grand Deed. The National
Manager has oversight of the agreement by ensuring that they are consistent
with the program parameters. The Australian Government plays no part in the
success fee agreement.
3.4 Support
Since its inception, COMET has supported companies in all Australian states
and territories. While the breakdown of states and territories by agreements
executed demonstrates that more companies on the east coast are benefiting
from COMET (referTable 3), this is to be expected given the population base
of the leading states, i.e. New South Wales, Queensland and Victoria.
An important observation is that the proportion of projects coming from each
state/territory is closely linked with the proportion of decision funding
distributed. For example, New South Wales comprised 26 per cent of total
projects and received 28 per cent of total funding; Queensland comprised 26
per cent of total projects and received 22 per cent of funding. This implies that
the geographic distribution of funds is fairly representative of the where the
projects being assisted are located.
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Table 3 COMET agreements executed by state/ territoryinception to 30June 2007
State No of Projects Percentage of Total
Projects
Decision Amount ($) Percentage of
Total Decision
Amount
NSW 355 26% 23,112,767 28%
QLD 349 26% 18,642,688 22%
VIC 260 19% 18,350,137 22%
SA 191 14% 10,574,080 13%
WA 133 10% 8,002,699 10%
TAS 33 2% 1,678,132 2%
ACT 30 2% 1,987,200 2%
NT 10 1% 603,160 1%
Total 1,361 100% 82,950,863 100%
Data source: AusIndustry information
With respect to the geographic breakdown within these states, COMET also
appears to have shared its resources among metropolitan and regional
companies in most states (seeTable 4). While the number of projects executed
in particular country regions is much smaller than others (e.g. 61 projects in
country New South Wales compared to five in country Western Australia),
these results can again be expected given the population base across the
different locations.
Table 4 Regional/ Metropolitan Analysis - COMET Agreements executedby state/territoryinception to 30 June 2007
Region No of Projects Percentage of
Total Projects
Decision Amount
($)
Percentage of
Total Decision
Amount
ACT 30 2.2% 1,987,200 2.4%
MetroSydney 294 21.6% 19,389,867 23.3%
CountryNSW 61 4.5% 3,722,900 4.5%
MetroDarwin 9 0.7% 538,360 0.6%
CountryNT 1 0.1% 64,800 0.1%
MetroBrisbane 209 15.3% 11,039,063 13.3%
CountryQLD 140 10.3% 7,603,625 9.2%
MetroAdelaide 173 12.7% 9,602,880 11.5%
Country SA 18 1.3% 971,200 1.2%
MetroHobart 17 1.2% 854,292 1.0%
CountryTAS 16 1.2% 823,840 1.0%
MetroMelbourne 227 16.7% 15,964,777 19.2%
CountryVIC 33 2.4% 2,385,360 2.9%
MetroPerth 128 9.4% 7,699,659 9.3%
CountryWA 5 0.4% 303,040 0.4%
Total 1,361 100% 82,950,863 100%
Data source: AusIndustry information.
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Similar to the state/territory breakdown, the proportion of projects located in
either regional or metropolitan areas appear to get a representative proportionof funding (e.g. metropolitan New South Wales had nearly 22 per cent of
projects and received just over 23 per cent of total funding, country New
South Wales had 4.5 per cent of projects and received 4.5 per cent of total
funding).
COMET support is spread across a range of industries, with the highest
representation in manufacturing (35 per cent of total projects) and property
and business services (35 per cent)seeFigure 7.
Figure 7 Agreements executed by industryinception to 30 June 2007
Data source: AusIndustry data.
Manufacturing
Property and Business Services
Communication Services
Health and Community Services
Agriculture, Forestry and Fishing
Electricity, Gas and Water Supply
Transport and Storage
Construction
Education
Mining
Cultural and Recreational Services
Finance and Insurance
Wholesale Trade
Government Administration and Defence
Personal and Other Services
Retail Trade
Accommodation, Cafes and Restaurants
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4 AppropriatenessThis chapter considers the appropriateness of the COMET program by
examining the extent to which program objectives and desired outcomes align
with government priorities, policy and client needs. The assessment follows the
Department of Finances evaluation guidelines.5
The terms of reference asked ACIL Tasman to consider the ongoing
appropriateness of the program after seven years of operation including:
Q1. Is the COMET program still an appropriate initiative given its objectivesand the current business environment?
Q2. Are there alternative means by which the program objectives could beachieved, including through alternative programs?
Q3. Is the market or institutional failure(s) which justified the program still inplace? Does the COMET program address these identified market orinstitutional failures (if any)?
Q4. Are the program objectives still relevant or do they require amendmente.g. should the objective of the program include development ofmanagement skills or to assist investment readiness of a COMETcompany? Should any one objective be more important than others?
Q5. Was the COMET program appropriate at the time of inception?
In reporting our findings, we have addressed these questions in the following
sections of this report, given that some of the questions in some aspects
overlap.
Section 4.1 Addresses the rationale for the COMET program, and whether it
was appropriate at the time of its inception (Question 5) and
whether it is still appropriate (Question 1).
Section 4.2 Considers the evidence of market failure justifying the program
and whether the COMET program addresses these failures(Question 3).
Section 4.3 Considers whether the program objectives are still relevant, and
whether amendments are required (Question 4).
Section 4.4 Considers whether there are alternative means to achieve the
same COMET objectives (Question 2).
5 Department of Finance (1994)DoingEvaluations: A Practical Guide, Commonwealth ofAustralia, Canberra.
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4.1 The COMET program rationale
4.1.1 Inception of the program, 1999
Innovation was prominent on the national agenda in the later years of the
1990s. The Department of Industry, Tourism and Resources (DITR) explained
the context for the Australian Government establishing the COMET program
in its submission to the Productivity CommissionsInquiry into PublicSupport for
Scienceand Innovation,in December 2006.
The Commercialising Emerging Technologies (COMET) program was established to
address a gap identified by private fund managers when the IIF [Innovation
Investment Fund] program was established that most early-stage firms were not
investment-ready because they suffer from a poor grasp of the realistic market
opportunity for their product and/or limited understanding of intellectual property
and general business management skills. These high risk factors make it very difficult
for venture capital funds to undertake due diligence and feel confident in the
prospects for the business.6
The introduction of the COMET program took place at a time when policy
attention was focussing on innovation and its critical role in underpinning
sustainable economic growth.
In announcing the COMET program in November 1999 the Minister for
Industry Sciences and Resources succinctly described the need for the
program:
Currently many Australian companies with innovative product, service and process
ideas fail to successfully commercialise their knowledge through lack of access to
equity funds and the commercial knowledge that venture capital offers companies
with good ideas and products.7
Through the COMET program, the Government aimed to maximise the
potential of these companies to successfully commercialise by getting
successful applicants to a level at which they might be able to attract equity
capital to fund their own expansion, and/or to provide them with the skillsnecessary to manage the firm and the commercialisation process. According to
the Minister:
6 DITR, Submission 93, to the Productivity CommissionsInquiry intoScienceand Innovation
(September 2006), p. 30.7 Media Release 99/378, Senator Nick Minchin, Minister for Industry, Science and Resources,
17 November 1999.
Need for the program
because small firms lacked
access to equity funds and
commercial knowledge
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Specific strategies will generally focus on areas such as developing a sound
management team, a proper business plan and market research, all of which are
required to compete for capital.8
The Australian Government considered that there would be benefits both to
the firm and the nation as a whole, from increased commercialisation of
innovation.
COMET will benefit both individual companies and the country as a whole, as it will
ensure that Australia continues to produce new products and services which are
critical to our national growth and future prosperity.9
The COMET objectives have since been refined, to the following:
to increase Australias sustainable economic growth through stimulating thesuccessful commercialisation of Australian innovation
to build sustainable and high growth firms by increasing prospects forsuccessful commercialisation of innovations through the attraction ofcapital and partners.
The venture capital sector was amongst the 100 stakeholders consulted during
the development of the COMET program. This sector identified six factors
contributing to investment readiness and which were incorporated into the
COMET program. These factors appear in the current COMET Grant
Application Form, and a company applying for COMET is asked to identifywhich of the six factors are a strength or a need. These factors are a mix of
knowledge, skills and technological development, comprising:
proven technology
working prototype
management/team skills
market research
business planning
intellectual property strategy.
The initial COMET program budget was for $30 million over three years.
Given that the Government undertook extensive consultations prior to
introducing the COMET program, and based the design of the program on
identified needs, in ACIL Tasmans view the introduction of the COMET
program was an appropriate response to address a verified market need.
8 Media Release 99/378, Senator Nick Minchin, Minister for Industry, Science and Resources,
17 November 1999.9 Media Release 99/378, Senator Nick Minchin, Minister for Industry, Science and Resources,
17 November 1999.
COMET objectives, Ministerial
Directions, 2006
At the time