Proposed draft Work Plan – Using on-line RRAM Guidelines for Extractive Industry

By on January 31, 2017

DR ELIZABETH GIBSON, General Manager of CMPA provides comments on the draft Work Plan using on-line RRAM Guidelines.

The CMPA was given the opportunity  to comment  on the Earth Resources Regulation’s  (ERR) draft “Work Plan using on-line RRAM Guidelines for Extractives Industry Projects”, (version 0.6) (Guideline).

Also supplied by ERR, were remarks on how ERR had taken into account the previous submissions from CMPA for earlier versions of the Guideline. It was found that the majority of comments from CMPA have been ignored in particular around notification and variation of Work Plans. This is somewhat disappointing as ERR advocated the risk based Work Plan process to industry on the premise that the notifications step would dramatically reduce red-tape for the industry. Examples of proposed new work that could represent a Work Plan Notification needs to be rethought because it is unnecessarily and incredibly bureaucratic around, for example, reducing noise.

The current examples given by ERR in the Guideline are:

Examples of proposed new work  that  could  represent a Work Plan Notification

  • An amendment to staging of extraction when extraction is entirely within the approved limit of extraction
  • A change in extraction methods – moving from a wet extraction method to a dry extraction method
  • Increasing distance from neighbouring properties
  • Reducing noise by enclosing the processing plant
  • Reducing noise by switching from onsite power generation to mains power
  • Replacing an existing piece of equipment with a new piece of equipment that generates substantially less noise
  • Reducing dust by changing quarry access routes and thus increasing distance to sensitive receptors

Further thought needs to ensure these examples are substantial. The Notification process was strongly advocated to the quarry industry by ERR as the benefit of transitioning to  a  risk  based Work  Plan  (reduction  in  cost/time).  The manner  in  which  the  process  (including  having  to  seek written  confirmation  from  Council  and  referral authorities) and examples of Notification have been written negates any possible benefit to industry.

The lack of a Regulatory Impact Statement for the introduction of risk based Work Plans is also worrying due to the obvious additional  costs  to  industry,  for  example,  there  is now  a requirement for an additional fourteen reports, for example, Preliminary Slope Instability Impact Assessment Report, Blast Management Plan, Radiation Management Plan etc.

Within the Governments Response to the Economic Development and Infrastructure Committee’s Inquiry into Greenfields Mineral Exploration and Project Development in Victoria reference is made  to  “Introduce  changes to  work plan requirements in the minerals regulations that are more risked based and less prescriptive, where such an approach is effective and practicable”.

Firstly, risk based Work Plans were intended for the minerals industry and, secondly, there is little evidence that the format for risk based Work Plans is effective and practicable.

In summary, whilst there has been much industry consultation in the development process (attention is still needed on addressing the extractive industry’s concerns and comments), a  stream lined and  simplified  Work  Plan process  (that is proportionate to the size of the quarry) with greater certainty around approval was being sought by the extractives industry. This has not yet been achieved.

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