3.110 A number of stakeholders pointed out that the ALRC’s Inquiry is just one of a number of inquiries into different aspects of the native title system, and suggested that this is both wearying for participants in the system, and not conducive to systematic reform.
3.111 Nick Duff has identified 11 native title law reform activities since 2007. This places a significant burden on stakeholders, particularly native title representative bodies and service providers. Central Desert Native Title Services said
Participation by native title parties in multiple and sometimes overlapping reviews or consultations is time consuming and costly and often without any positive outcome. It creates a feeling of cynicism and pessimism within the native title sphere and a reluctance to participate in ‘another review’. 
3.112 The Association of Mining and Exploration Companies raised a broader concern about the lack of clear strategic direction by governments, and said there is a ‘need for Government to develop and articulate an overarching native title strategy including a coherent long term plan for legislative and regulatory reform in this area’.
3.113 The National Congress of Australia’s First Peoples noted that the ALRC Inquiry addresses ‘limited issues’. It supports ‘a comprehensive review of the Act by the Attorney-General’s Department, designed to achieve implementation of the rights set out in the UN Declaration of the Rights of Indigenous People’.
3.114 The Social Justice Commissioner has called for a comprehensive and independent review of the native title system, considering the burden of proof, extinguishment, the future act regime and other matters, in 2010 and 2011.
3.115 Goldfields Land and Sea Council said that there are ‘a range of issues demanding attention that have not been included in the terms of reference for the current review, including extinguishment and the right to negotiate’.
3.116 There are also significant post-determination challenges to be addressed, including the effectiveness and funding of prescribed body corporates (PBCs). The Deloitte Review of Native Title Organisations and the Taxation Working Group addressed some of these issues, but again it is not clear that these activities formed part of a coherent long-term plan for reform.
AIATSIS, Submission 36; See further Nick Duff, ‘Reforming the Native Title Act: Baby Steps or Dancing the Running Man?’ (2013) 17 Australian Indigenous Law Reporter 56.
Central Desert Native Title Services, Submission 26.
Association of Mining and Exploration Companies, Submission 19.
National Congress of Australia’s First Peoples, Submission 32.
Aboriginal and Torres Strait Islander Social Justice Commissioner, ‘Native Title Report 2011’, above n 144, 19–20; Aboriginal and Torres Strait Islander Social Justice Commissioner, ‘Native Title Report 2010’ (2010).
Goldfields Land and Sea Council, Submission 22.
Deloitte Access Economics, above n 59.
Australian Treasury, ‘Taxation of Native Title and Traditional Owner Benefits and Governance Working Group: Report to Government’ (2013).