Chair of Taskforce
Offshore Streamlining Taskforce
Department of Industry
Please accept my submission on the Draft Strategic Assessment Report for the
Streamlining Offshore Petroleum Environmental Approvals.
I would like to comment on two aspects.
Aspect 1;
Section 4.5.4 of the Program Report states:
"The revised Offshore Project Proposal must demonstrate that all public submissions
have been adequately addressed, and that any appropriate management or other
measures resulting from the public comment have been considered and adopted."
and
Section 4.3 Offshore Project Proposal Public Consultation, states:
"This consultation should inform the identification of environmental sensitivities, impacts
and risks and the development of environmental performance outcomes for the project."
My concern is that if the criterion of adequately addressing all public submissions is to
have any meaningfulness, then the word "should" in the sentence "This consultation
should inform the identification of environmental sensitivities, impacts and risks and the
development of environmental performance outcomes for the project", needs to be
changed to "must".
It is unreasonable for there to be an expectation of expertise from the public that would
allow for an adequate, indepth understanding of all past, anticipated future and recent
discoveries pertaining to the marine habitat and it's nearby ecosystems that would result
in a fully informed and educated submission. The public must be able to rely on a
legislative requirement stating the proponent must publish, with full disclosure, it's
environmental surveys and discoveries pertaining to the environmental sensitivities as
mentioned.
Aspect 2;
Section 3.2.3 Principles of Ecologically Sustainable Development, states
"One object of the Regulations is to ensure that any petroleum activity or greenhouse
gas storage activity in an offshore area is carried out in a manner consistent with the
principles of ecologically sustainable development, as set out in the EPBC Act."
It then goes on to outline those principles as defined by that Act.
My concern with this is not in the Program itself, but with the Act that this Program is
supported by and, once again, the use of the word "should":
(b) if there are threats of serious or irreversible environmental damage, lack of full
scientific certainty should not be used as a reason for postponing measures to prevent
environmental degradation
(c) the principle of inter-generational equity--that the present generation should ensure
that the health, diversity and productivity of the environment is maintained or enhanced
for the benefit of future generations
(d) the conservation of biological diversity and ecological integrity should be a
fundamental consideration in decision-making
(e) improved valuation, pricing and incentive mechanisms should be promoted.
By using the word "should" these principles become an option, rather than a
requirement. I would very much like to see the word "must" instead of "should". I
believe these principles are of such high importance, forming the core intention of the
Act and cannot be left to a proponents idea of what constitutes the may, or the may not,
of what is required.
In closing, thank you for the opportunity to submit concerns over this Program.
On the whole, I see it as a positive move.
However, full and total disclosure and compliance to requirements needs to be set in
terms that brook no argument or leave avenues for interpretation. The importance of our
largest ecosystem is only just beginning to be understood and indications are leading to
the conclusion that it may, indeed, be the most significant ecosystem on our planet. It's
welfare must not be left to chance, whim or misinterpretation.
Regards
Jan Price
0427 190 490
janprice@westnet.com.au
605/5 Marco Polo Drive
MANDURAH WA 6210