This submission follows prior detailed submissions we have made on these reforms. Consistent with our previous submissions on the implementation of the Act dated 1 and 11 June 2020, our focus is on ensuring the guidance materials for the Act are:
- consistent with its requirements;
- appropriate to support its robust administration; and
- in alignment with the intended outcomes of the reform process. While we generally support the Guidance Document, we make some comments below on specific issues.
We support the Guidance Document and the principles that underpin its approach to public participation and stakeholder engagement in the EIA process. However, consistent with our concerns with previous guidance materials that have been prepared for the implementation of the Act, we are concerned that the Guidance Document does not properly substantiate or give adequate interpretive guidance about the statutory provisions of the Act and Regulations – in this case, with respect to community consultation.
