Appendices Appendix 6.1 Summary of written submissions Submission Stakeholder Theme Issues identified/ Comments Number Name 01 Jan Price Decision making Sees the Program as positive. processes Use of is weak compared to in terms of consideration of consultation outcomes in risk assessments ‘should’ ‘must’ etc. and in application of principles of ecologically sustainable development. (Strategic Assessment Report (SAR) Section 4.3). 02 Social Separate policy Currently response actions under the National Marine Oil Spill Contingency Plan are exempt from the EPBC Act. Resources issues Asks whether the exemption will remain and what the implications are for oil spill response. 03 Environmental Adequacy of Suggests that standard of protection of Commonwealth marine environment and Commonwealth land be higher than Defenders environmental it should be of degraded ecosystems. ‘maintain’ ‘improvement’ – Office WA protection Queries NOPSEMA qualifications and capacity to inspect. (EDO WA) Compliance and Concern about the level of monitoring and enforcement and funding of that. Inspectors should be qualified, enforcement independent and have coercive powers. Consultation/ Period of Offshore Project Proposal consultation not long enough, considering potential magnitude of environmental transparency impacts suggest s 60 days. – Level of discretion creates uncertainty concerned representative groups should be able to register to receive – notification for all applications. Notification on Environment Plans should be broadened interested parties must be consulted and those comments – must be considered by NOPSEMA. Clarification is required about reports and whether they will be published is the the same as the – ‘annual plan’ Suggests that Annual Report must be published. ‘annual report’? Cumulative Ongoing review of cumulative impacts under Offshore Project Proposal and Environment Plan is required. impacts Decision making impacts should be defined. ‘Acceptable/unacceptable’ processes Offshore Project There should be a provision for a final rejection of a project. Need a clearly unacceptable decision (areas where Proposal environmental impacts so high that project can never proceed). It is suggested that proponents could continually process resubmit Offshore Project Proposal to postpone removal of tenure rights. Reporting Operators should report all environmental damage, not just and ‘moderate significant’.
Appendices Appendix 6.1 Summary of written submissions Submission Number Stakeholder Name Theme Issues identified/ Comments 01 Jan Price Decision making processes Sees the Program as positive. Use of ‘should’ is weak compared to ‘must’ in terms of consideration of consultation outcomes in risk assessments etc. and in application of principles of ecologically sustainable development. (Strategic Assessment Report (SAR) Section 4.3). 02 Social Resources Separate policy issues Currently response actions under the National Marine Oil Spill Contingency Plan are exempt from the EPBC Act. Asks whether the exemption will remain and what the implications are for oil spill response. 03 Environmental Defenders Office WA (EDO WA) Adequacy of environmental protection Suggests that standard of protection of Commonwealth marine environment and Commonwealth land be higher than ‘maintain’ – it should be ‘improvement’ of degraded ecosystems. Queries NOPSEMA qualifications and capacity to inspect. Compliance and enforcement Concern about the level of monitoring and enforcement and funding of that. Inspectors should be qualified, independent and have coercive powers. Consultation/ transparency Period of Offshore Project Proposal consultation not long enough, considering potential magnitude of environmental impacts – suggest s 60 days. Level of discretion creates uncertainty – concerned representative groups should be able to register to receive notification for all applications. Notification on Environment Plans should be broadened – interested parties must be consulted and those comments must be considered by NOPSEMA. Clarification is required about reports and whether they will be published – is the ‘annual plan’ the same as the ‘annual report’? Suggests that Annual Report must be published. Cumulative impacts Ongoing review of cumulative impacts under Offshore Project Proposal and Environment Plan is required. Decision making processes ‘Acceptable/unacceptable’ impacts should be defined. Offshore Project Proposal process There should be a provision for a final rejection of a project. Need a clearly unacceptable decision (areas where environmental impacts so high that project can never proceed). It is suggested that proponents could continually resubmit Offshore Project Proposal to postpone removal of tenure rights. Reporting Operators should report all environmental damage, not just ‘moderate and significant’.
streamlining_offshore_petroleum_environmental_approvals_supplementary_report.docx