Published name
3. Is the consultation process provided in the proposed Regulations appropriate?
3.1 What changes (if any) do you recommend?
Please consider the following questions in drafting your response to question 3.1:
a. Is it appropriate for licence holders to consult representatives and representative bodies where these bodies could reasonably be regarded as representing the interests of individuals, persons, organisations, groups or communities?
b. Is it appropriate for the same consultation requirements to apply to all types of projects (for example, for research and demonstration projects compared to commercial projects)? If not, what changes do you recommend?
c. Do you consider the proposed stakeholder engagement strategy described in the management plan, but separate to the management plan, to be adequately flexible and appropriate? If not, why, and what might be an alternative approach?
d. Do you agree with the list of information that must be described in the management plan in relation to the stakeholder engagement strategy? Should any other matters be described?
a) It is not adequate or appropriate for proponents to consult with representative bodies. Good practice community engagement ensure that both individuals and organisations have standing and must be engaged with, to ensure all views are considered.
c) The proposed stakeholder engagement approach provides excessive discretion for proponents and inadequate guidelines.
Recommend that standards and protocols for community be defined in the regulations, including mechanisms for transparent/accountable evaluation and reporting on community engagement: who was consulted, how, what concerns were articulated, how proponents respond to and resolve these concerns, etc.
These standards and protocols should ensure that stakeholder engagement begins at the earliest possible stage in the life of the project, for the same reasons that apply to regulations that require early engagement with regulators during designate notification stage.
The consultation paper refers to stakeholder 'claims' in place of 'concerns'. Recommend the regulations refer to 'concerns' - to respect that different views are equally legitimate.
The stakeholder engagement approach would be strengthened by requiring continuous engagement throughout the life of any infrastructure. This should include transparent mechanisms for complaints to be reported, investigated, remedied and reported on.
5. There is strong public interest in enabling public access to relevant and reliable information on OEI projects. Are management plan summaries an efficient and effective way to make information available to the community?
5.1 What are your concerns and how can they be addressed?
Stakeholders must be able to access full management plans. Summaries serve no useful purpose and only limit right to know.
6. Do you think alternative approaches of publishing management plans in full (with necessary redactions), or requiring licence holders to publish management plans themselves is more efficient or appropriate than the current approach in the proposed Regulations?
6.1 What are the reasons for your answer?
Stakeholders cannot meaningfully engage, on equal terms to proponents, without full access to management plans, including arrangements to respond when impacts are not effectively mitigated.
Would you like to upload a submission as part of this consultation?
