Approvals to Operation
Seminar @ Katestone
July 31, 2013
Why are we here?
Condition: Water truck must be
located on site at all
times
Compliance with
condition?
Check!
Changes to Regulations
Environmental Protection (Greentape
Reduction) and Other Legislation
Amendment Act 2012
(the Greentape Reduction Act)
Aim: Introduce an integrated approval
process for ERAs that is proportional to
environmental risk
Regulatory Strategy
• Improved application process by developing
eligibility criteria and standard conditions for:
– Petroleum exploration
– Petroleum pipeline
– Petroleum survey
• Streamlined approvals process
• Focus is on
– Outcomes, not process
– Compliance and enforcement
“We will take you at your word” Greentape Reduction Training by EHP
“We will no longer hold your hand”
Rachel Burgess-Dean
Director Energy Regulation and Implementation
Energy Resources and Enforcement Branch
Environmental Services and Regulation
“EHP will no longer be challenging ability to comply with
a particular condition”
Source: Department of Environment and Heritage Protection’s Regulatory Strategy
Applications
Applications Pre-lodgement
meeting
Write application
Lodge application
with Department
Refused Request for
information Approved
“Poor” application “Nearly there” application “Good” application
Approved Conditions
OR
Do not rely on,
At discretion of EHP
Conditions
Outcome
focused
Set based on:
• Application type
(standard application =
standard conditions)
• Information supplied in
the application
(if management of risk not
demonstrated conditions
may be onerous)
Approach
based on
risk
Responsibility EA holder to work
out how to meet condition
Conditions may be influenced
by the person setting them
Reasonable
conditions
Onerous
conditions Random
Why not just accept conditions?
• Thirty party audits
• Plan of operations
• EHP’s compliance strategy
• Enforcement tools
• Non-compliance register
• Effort
Public perception R
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P
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A
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N
P
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B
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Let’s look at some
conditions
Case studies
Facility 1
Petroleum lease
Pipeline licence
ERA 9
ERA 15
Authority took effect May 2013
Facility 2
Petroleum lease
Pipeline licence
ERA 14
ERA 15
Authority took effect June
2013
Facility 3
Petroleum lease
Petroleum facility licence
ERA 10
ERA 14
ERA 15
Authority took effect April
2013
Facility 1
Facility 2
Complaints
monitoring
Facility 3
What is the monitoring
being compared to?
If no outcome, why
monitor?
Complaints
monitoring
Summary of conditions
Facility 1
ERA 9
ERA 15
13 conditions
Cost =
$12,000
(every 2 years)
Effort = Low
Facility 2
ERA 14
ERA 15
36 conditions
Cost =
Every year $80,000
One off $400,000
Verification $55,000
Additional stacks $600
Effort = high
Facility 3
ERA 10
ERA 14
ERA 15
23 conditions
Cost =
Every year $18,000
Verification $55,000
Additional stacks $600
Effort = medium to high
