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A Work Plan Template

By on May 13, 2013

DR ELIZABETH GIBSON, General Manager CMPA comments on the development of a Work Plan Template.

CMPA arranged a meeting on 7 August 2013 at Northern Quarries (Conundrum Holdings) with John Mitas General Manager Minerals and Extractive Operations, Department State Development Business and Innovation (DSDBI) to give consideration to a WorkPlan Template.

There were eighteen people at the meeting (including seven quarries). The CMPA is looking for the reduction of red tape for the construction material processors industry to enable investment in the State of Victoria. Work Authorities and variations approval being a lengthy, expensive and drawnout process with no security of outcome.

John Mitas said that the government was open for business and understands the value of the extractive industries. Th e government is implementing the recommendations, including changes in regulation, as outlined in the government response to the Economic Development and Infrastructure Committee “Inquiry into Greenfields mineral exploration and project development in Victoria” (EDIC Inquiry).

The Work Plan should be streamlined and state the requirements first off and not require redrafting four or five times. Once the Work Plan is acceptable, then statutory referrals are made to relevant government departments within thirty days. The Planning Authority should no longer have to undertake referrals.

The Guidelines and Work Plan template should be tailored to the industry. The Work Plan template should lead to a consistent approach across the state and should be streamlined in the confines of the regulation. The EPA works approval template was distributed as an example but CMPA is concerned with this template due to it currently being under redevelopment because of issues arising out of a public review.

ISSUES

Investment

  • The industry wants to invest in the State but the risk is too high, hence, the lack of investment.
  • The regulatory risk/burden for new Work Authorities/variations is too high.
  • The investment in obtaining a Work Authority can be greater than the value of stone in the ground.
  • Sovereign risk of investing is too high, where it can take at least two years for a Work Authority with no certainty of outcome. This also flows through to rehabilitation bonds.
  • The risk of no return is too high for family capital.

Planning Permit

  • The real test/risk is obtaining the planning permit which is open to public scrutiny which can adversely influence councillors.
  • Sound decision making is unduly influenced by politics.
  • The Work Plan is coupled to the planning permit. The Planning Practice notes need to state that there is a clear separation between the Work Plan and the planning permit.
  • The planning permit is for use of the site only and includes access.
  • There should be strong guidance that councils can accept.

Work Authority

  • The Work Authority wording is not in line with guidance notes.
  • The Work Authority is issued at the end of the process but it should be issued at the beginning of the process to give the Work Authority applicant and future referral agencies a clear understanding of the power and responsibilities held by DSDBI.

Work Plan

  • The Work Plan details the operation of the quarry. A secondary document could be used for the referral authorities.
  • There is a lack of cohesion between the referral authority and DSDBI.
  • The current guidelines for the development of a Work Plan are no longer applicable.
  • The referral authorities are often contradictory and/or overlapping.
  • There are inconsistent requirements between regions and even within a region. There needs to be a more stringent set of internal guidelines for the department.

Work Plan Variations

  • Small changes to operations can give rise to Work Plan variations.
  • If the variation has no off-site impact then a Work Plan variation should not be required.

CONCLUSION

There was a general feeling that the future of the industry was bleak. The proposal for a Work Plan template in addition to a review of guidelines was generally accepted, however, it is unlikely to remedy all the issues as outlined above.

This is even with the government response to the EDIC Inquiry. The CMPA will pursue the issues raised with the Energy and Resources Minister, the Hon Nicholas Kotsiras. The CMPA intends to hold a Workshop for members on the development of a Work Plan Template.

DSDBI has set up a Review of Work Plan Approvals Steering Committee with industry representatives including CMPA to:

  • rationalise the content of the work plan to focus on risk and risk mitigation;
  • minimise the iterations currently required for the work plan to be of an acceptable standard;
  • provide for a consistent approach in the assessment of work plans by DSDBI; and
  • reduce the time to assess and finalise work plans.

CMPA hopes to report on progress with Work Plans in the next issue of Sand & Stone.

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