From the Secretariat

DR ELIZABETH GIBSON, looks at the concerns for the industry surrounding the proposed Risk Based Work Plans.

THE Economic Development Infrastructure Committee inquiry recommendation and subsequent 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” . Whilst the idea has merit, there are several issues with the current proposed draft risk-based Work Plan.

In its current format it is far too complex for smaller sites (although larger than those sites covered by the Code of Practice for Small Quarries) and does not yet meet the “Draft Guiding Principles for Reformed Work Plan”, Department of Economic Development, Jobs, Transport and Resources: a stream lined and simplified process that leads to decreased costs through a reduction in:

• Time taken to approve proposals;
• Number of Work Plan variations;
• Number of duplicative conditions placed by authorities;
• Number and cost 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 DEDJTR;
• Number of variations sought by operator; and
• The unnecessary over use and cost of consultants

The proposed risk based Work Plan format will not lend itself to being a tool for the Quarry Manager to use in the day to day operation of a quarry as occurs with current Work Plans.

The electronic risk based Work Plan form will be made available in April 2015. All Work Plans and Work Plan variations submitted between then and 31 December 2015 (bought forward from 31 December 2016 due to the Hazelwood coal mine fire) will be transcribed by the Department into the electronic form if not submitted electronically. After 31 December 2015 all Work Plans and Work Plan variations must be submitted in a risk based format.

Also of concern is the prospect of risk based Work Plans being applied retrospectively which will lead to the decimation of the small quarry with a loss of regionally based jobs and an increased cost for those using extractive resources. The CMPA Secretariat is actively working to raise awareness on these issues with the Minister for Energy and Resources.

Photo: Batesford Quarry