Workshop on the development of a risk-based Work Plan application
Dr Elizabeth Gibson, General Manager CMPA, reports on the DSDBI Workshop.
FOLLOWING on from the article in Sand & Stone Issue 72, a workshop was held at the Stamford Plaza Hotel in Melbourne to progress the development of a risk-based Work Plan application (formerly template).
Representatives were there from the mining industry and for the extractive industries CMPA (Garry Cranny, Basil Natoli, Peter Barro and Elizabeth Gibson) and CCAA representatives.
There was also good representation from Earth Resources Regulation (DSDBI). Jacobs – SKM were the successful tenderers and facilitated the day.
The objectives for the workshop were:
- Learn about practices from other jurisdictions and regulators that could be applied to Victoria’s work plan form (preparation and lodgement)
- Create shared appreciation and understanding of the work plan reform process
- Commence the design of the risk based work plan form and supporting guidance
- Identify key work plan and guidance issues that need to be resolved during subsequent phases of this project
After the introduction there were presentations made that were examples of regulatory risk based application processes. A presentation was made by the Environment Protection Authority, Victoria (EPA) of the Approvals Reform Implementation by Carmel Vlachos and Claire Flatley. Industry comments concerning the original EPA Approvals process sounded very familiar:
- is excessively demanding, complex and lengthy,
- better guidance needs to be given to applicants as to the type and amount of information needed and
- EPA raising new issues ‘at the last minute’.
The EPA detailed the transformation process to a more streamlined, transparent and predictable outcome with red tape reduction that still filled the regulatory requirements. However, it is an ongoing process.
A presentation was given by Greg Marshal, the Department of Manufacturing, Innovation, trade Resources and Energy, SA government titled “Mining Assessments and Approvals in SA”.
The legislation is somewhat different in SA with quarries being classed as ines and there is no referral to the planning authorities. Whilst the approval process for the Work Plan equivalent is 3 months, industry has a number of issues:
- the length of the Work Plan that can run into hundreds of pages,
- previously the Work Plan could be completed in house but now has to be carried out by consultants and
- there has been an increase in red tape.
After lunch the participants were divided into four groups (2 quarries based and 2 mines based) to “road test” a high level risk based process for preparing, lodging and assessing a Work Plan.
For quarries there were two scenarios one low risk site and one high risk site. the aim being to identify the Work Plan form design challenges. The Workshop concluded with a summary by the consultants.
The next step in the process being for the consultants to take and collate the Workshop outcomes and produce a risk based Work Plan form that will be tested with real quarries.
The consultants will have visited the CMPA at the Wallan Library meeting room in early May 2014 to try out the draft Work Plan form with Chris Ryan (Chris Ryan Earth Moving), Sarah Andrew and Ron Kerr (Conundrum Holdings), Basil Natoli and Cameron Black (Bell Cochrane and Associates) and Garry Cranny (Dandy Premix).
The CMPA’s view is that any new process should not constitute a barrier to entry, especially for small operators and should:
- Reduce the time taken to approve proposals
- Reduce the number of duplicative conditions placed by authorities
- Reduce the number of VCAT hearings
- Reduce the number of reiterations and rewritten Work Plans submitted to DSDBI
- Reduce the number of consultancy reports per Work Plan
- Reduce the number of variations sought by DSDBI
- Reduce the number of variations sought by operator.
In participating in the process CMPA is always considering Members interests and the Government’s emphasis on reducing red tape.
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