Environmental EPBC Act requires publication of environmental data this will be lost under Program but is crucial to understanding – data the marine environment. 23 Australian Consultation/ Fishing industry is concerned about impacts of offshore activities but lack capacity to respond to petroleum industry Fisheries transparency Environment Plan requests. Management Authority (AFMA) 24 CONF Consultation/ Feedback from stakeholders that they are suffering from this should be considered in review of ‘fatigue’ – transparency Environment Plan consultation requirements. Welcome the opportunity to further discuss with the Department of Industry and NOPSEMA. Decision making Urge consideration of concept of environment requiring full demonstration of ALARP (as for safety) ‘major event” processes while other risks require evidence of management. Environment definition very broad should be limited to exploration and production ‘petroleum activity’ – Regulations Support proposed changes to Environment Plan content requirements, and for more ‘request information’. Review Operator vs titleholder definition requires further consultation (Regulations). Oil Pollution Emergency Plan (OPEP) requirement to quantitatively monitor discharges requires set up time not – possible to implement instantaneously. OPEP responsibility for oil spills from vessels needs clarifying. – Offshore Project Offshore Project Proposal requirement will stop minor activities such as geotechnical surveys, progressing while Proposal under assessment. process Requirement for revision may cause delay if minor marine activities are required which are not anticipated. Opportunities for To achieve effective streamlining the content and stakeholder requirements for Environment Plans (with a Proposal) further should be reviewed to minimise overlap. streamlining Transition Transfer of EPBC Act conditions to NOPSEMA is of interest for discussion. arrangements 25 CONF Consultation/ Seeks maximum consultation for Offshore Project Proposals should be 4 weeks (not minimum). transparency NOPSEMA decision on of consultation is subjective and should be removed. NOPSEMA can view the full ‘adequacy’ text of consultations and response. Cost recovery NOPSEMA needs to be adequately resourced to ensure no delays.
Environmental data EPBC Act requires publication of environmental data – this will be lost under Program but is crucial to understanding the marine environment. 23 Australian Fisheries Management Authority (AFMA) Consultation/ transparency Fishing industry is concerned about impacts of offshore activities but lack capacity to respond to petroleum industry Environment Plan requests. 24 CONF Consultation/ transparency Feedback from stakeholders that they are suffering from ‘fatigue’ – this should be considered in review of Environment Plan consultation requirements. Welcome the opportunity to further discuss with the Department of Industry and NOPSEMA. Decision making processes Urge consideration of concept of ‘major environment event” requiring full demonstration of ALARP (as for safety) while other risks require evidence of management. Environment Regulations Review ‘petroleum activity’ definition very broad – should be limited to exploration and production Support proposed changes to Environment Plan content requirements, and ‘request for more information’. Operator vs titleholder definition requires further consultation (Regulations). Oil Pollution Emergency Plan (OPEP) requirement to quantitatively monitor discharges requires set up time – not possible to implement instantaneously. OPEP – responsibility for oil spills from vessels needs clarifying. Offshore Project Proposal process Offshore Project Proposal requirement will stop minor activities such as geotechnical surveys, progressing while under assessment. Requirement for revision may cause delay if minor marine activities are required which are not anticipated. Opportunities for further streamlining To achieve effective streamlining the content and stakeholder requirements for Environment Plans (with a Proposal) should be reviewed to minimise overlap. Transition arrangements Transfer of EPBC Act conditions to NOPSEMA is of interest for discussion. 25 CONF Consultation/ transparency Seeks maximum consultation for Offshore Project Proposals should be 4 weeks (not minimum). NOPSEMA decision on ‘adequacy’ of consultation is subjective and should be removed. NOPSEMA can view the full text of consultations and response. Cost recovery NOPSEMA needs to be adequately resourced to ensure no delays.
streamlining_offshore_petroleum_environmental_approvals_supplementary_report.docx