Risk Based Work Plan

Risk Based Work Plan Form and Guidelines
Dr Elizabeth Gibson provides an update on the development of Risk Based Work Plans.

The Economic Development and Infrastructure Committee (EDIC) Inquiry into Greenfi elds Mineral Exploration and Project Development in Victoria recommendation and Government response was 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”.

The Earth Resources Reform Steering Committee (ERRSC), Department of Economic Development, Jobs, Transport and Resources (DEDJTR) inclusive of industry representatives, has been established to oversee this work. Whilst the ERRSC has great merit, there are numerous issues with the current Risk Based Work Plan form which remain unresolved.

In its current format it is far too complex for smaller/medium sized sites and it does not yet meet the “Draft Guiding Principles for Reformed Work Plan”, DEDJTR: a stream-lined and simplified process which leads to a reduction in:

Criteria:

• Cost
• Time taken to approve proposals
• Number of Work Plan variations
• Number of duplicative conditions placed by authorities
• Number of VCAT hearings
• Number of reiterations and rewritten Work Plans submitted to DEDJTR
• Number of consultancy reports per Work Plan
• Number of variations sought by DSDBI
• Number of variations sought by operator

The CMPA is concerned about our perception of a lack of consideration towards private capital participants who comprise the majority of the quarrying sector within the extractive industries of earth resources in Victoria.

There appears to be a ‘one size fi ts all’ regulatory approach being championed by DEDJTR, Earth Resources Regulation to accelerate the State Government’s response to the EDIC recommendations.

The CMPA submits this approach is too focused on addressing major issues which have arisen in the larger scale, high value segments of the Victorian earth resources industry. Those mineral resource sectors generate much greater public interest and contain signifi cantly more sovereign risk than  sites producing construction materials through quarrying and  its associated activities utilizing well understood methods, equipment and technologies.

The CMPA is concerned the Risk based Work Plan form, as proposed, has the potential to further complicate and possibly distort the approval process. It could do this through the provision of excessively fine detail which will add further costs and time to the approval process: that is, in the event the approval is ever gained. The mandatory application of numerous environmental and planning thresholds form part of our concerns and frustrations in this context.

The CMPA contends introduction of the Risk Based Work Plan form, as currently proposed, is inconsistent with the State Government response to the EDIC inquiry i.e. “reduction in red tape” and “effective and practicable”.

We are overwhelmingly concerned the small to medium sized private equity quarrying sector of the Victorian earth resources industry, our CMPA members, who currently supply half of Victoria’s construction materials, will be disadvantaged by the implementation of the proposed Risk Based Work Plan.

The risk based Work Plan form is currently available on line.  Information will be sent out to inform Work Authority holders that the risk based Work Plan form is available and new Work Plans or new Work Plan variations must be risk based as of 1 January 2016. Paper based Work Plans will be accepted as long as they are risk based. These will be entered into RRAM (Resource Rights Allocation and Management Business Portal) by Earth Resources Regulation, Department of Economic Development, Jobs, Training and Resources (DEDJTR).

A Work Plan must:

• Identify the risks which the activities may pose to the  environment, to any member of the public, or to land or property in the vicinity of these activities; and
• Specify what the person who proposes to undertake the activity will do to eliminate or minimise those risks as far as reasonably practicable.

The form can be found at:
http://www.energyandresources.vic.gov.au/earth-resources/licensing-and-approvals

The following, for the information of CMPA Members is the excerpt from the DEDJTR website concerning risk based Work Plans.

RRAM is the Resource Rights Allocation and Management  solution which Earth Resources Regulation has developed in consultation with the earth resources industries, to administer and regulate Victorian mining and petroleum tenement activities. Proponents and tenement holders can now access the RRAM Business Portal via the internet to apply for a tenement, complete a work plan, track the status of their application, pay fees and complete their reporting.  The RRAM Business Portal is simple to use, enabling tenement  holders to communicate with Earth Resources Regulation and complete regulatory business transactions via the internet at anytime from anywhere. Please refer to the easy to follow  RRAM user guide (PDF, 3136.9 KB), RRAM user guide (DOCX, 7574.8 KB).

Current and past tenement holders have been pre-registered.

If you have not yet received your user name and log in details please email: RRAM.Support@ecodev.vic.gov.au with the subject:

“Please send my RRAM Business Portal log-in details”.
Please include the following information in your email:

• Your full name;
• Your contact address;
• Your contact phone number;
• Your contact email address;
• If you’re a company employee, the name of the company;
• If you’re an individual, your full name as it would appear on a tenement;
• If you are an agent, the name of your company; and
• All companies must also provide a valid ACN.

If you have not previously held a tenement and wish to apply online, please register by visiting:
https://rram.force.com/CommunitiesLogin

THE CMPA WOULD BE VERY INTERESTED TO HEAR MEMBERS FEEDBACK ON THE NEW RISK BASED WORK PLAN SYSTEM.

 

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