Standards, compliance and planning

About the earned autonomy pilot program


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Environment Protection Authority Victoria (EPA) introduced a pilot program to test the concepts of earned autonomy with existing EPA-accredited licence holders and eligible businesses from the Victorian water industry. Lessons from the pilot will inform the development of a long-term model.

The pilot program ran during 2015–16 in parallel with the current EPA statutory accreditation program (under s26 of the Environment Protection Act). The administrative arrangements under the statutory accreditation program were only available to existing EPA-accredited licence holders.

A tiered approach to incentives

The concept of a tiered approach to earned autonomy recognised that increased earned autonomy rewards can be afforded to better performers. The tiers were to give industry an incentive to raise their environmental performance and incorporate the principles of environmental citizenship into their business.

Tiering was informed by an assessment of licensees’:

  • environmental citizenship
    • accessibility, participation and responsibility
    • environmental equity and restorative justice
    • environmental leadership
  • environmental performance
    • compliance rating
    • site management
    • community engagement.

Table 1 lists the proposed benefits for each tier – further benefits were explored during the pilot program.

Table 1: Benefits

Rewards Proposed pilot program benefits (short-term) Potential post-pilot benefits (long-term) Tier 1 Tier 2 Tier 3
Public recognition Promotion of tier 1 on EPA website Promotion of tier 1 in EPA annual report and on EPA website Yes No No
Promotion of tier 1 with relevant industry associations with intention to develop ‘kudos’ for top tier businesses Yes No No
Awards and networking Annual gala dinner with peers Yes Yes Yes
Fee incentive Not available Scaled fee reduction (subject to regulatory change) Yes Yes Yes
Earned autonomy More streamlined approvals process Yes Yes No
Better environmental performance = fewer planned EPA inspections (in line with EPA’s Licensed Operator Risk Assessment model) Yes Yes Yes
Pilot program participants will be encouraged to apply for amendments to licence conditions that enable innovation Yes Yes Yes

The application process

Determining eligibility for the pilot program was a two-stage process.

Stage 1

EPA identified the high performers amongst existing accredited licensees and the water industry and invited them to apply to take part in the pilot program. Those wishing to apply submitted information demonstrating how they applied the principles of environmental citizenship in their performance, activity and plans for future improvement, and include examples.

Stage 2

We assessed each application and engaged with local community representatives and groups relevant to that application. EPA then informed applicants of the status of their application.

Through the pilot application process we established thresholds for entry to each tier.

Pilot program assessment criteria

EPA assessed the information in completed application forms against the performance measures outlined below. Our assessments took into account differences in site activity, location, proximity to receptors and so on between applicants. We did this to ensure a fair assessment was applied to each application.

EPA bases its assessments only on questions that were relevant to each business. We validated the information provided in the forms with our regional offices and local community representative(s).

Accessibility, participation and responsibility

  1. Business has a complaints handling procedure and encourages affected neighbours to contact them directly and they act to fix the issue promptly.
  2. Lodges its own pollution reports and licence breaches through EPA’s Customer Service Centre.

Further explanation of performance measures

  • Handles complaints effectively (clear process, contact details, log book of calls, timely response to complaints).
  • Informs community of incidents (proactively).
  • Forms networks, groups, forums with community where there is high interest or concern.
  • Uses engagement officers in appropriate situations.
  • Is inclusive of a full range of community in its engagement efforts.

Environmental leadership

  1. Provide intelligence to EPA about issues on the horizon in their sector on which EPA might need a policy or position.

Further explanation of performance measures

  • Is proactive on sector-wide issues and works with EPA to resolve.
  • Participates in local environmental improvement opportunities (working with community to solve local problems).
  • Develops and maintains ongoing forums to involve community in decision making.
  • Undertakes proactive and early engagement with EPA on forward plans and approvals (for example, works approvals).
  • Uses strategic planning and takes opportunities to improve environmental outcomes valued by community.
  • Is active in industry association.
  • Has a commitment to best practice.
  • Uses environment officers in appropriate situations.
  • Has a willingness to consider beyond-compliance activity.

Environmental equity and restorative justice

  1. If incidents occur, participate proactively and honestly in restorative processes with community (for example, restorative conferencing).
  2. Form networks to address issues where there is high community concern about ongoing cumulative impacts and/or go beyond baseline regulatory requirements.
  3. Participate in local environment improvement opportunities, such as neighbourhood environment improvement plans.

Further explanation of performance measures

  • Fixes issues promptly.
  • Meets with community following an incident or impact (for example, restorative conferencing).
  • Involves community in the  development of appropriate restorative justice measures.
  • Has both immediate and long-term inclusion of and commitment to community.

Program objectives

The new program is the result of a major commitment of EPA’s Approvals review final report (publication 1521). This was to develop an alternative program to encourage, recognise and reward excellence in environmental performance across all EPA licensees. By offering tiered benefits to high-performing Victorian businesses, the program will give industries incentives to raise the standards of environmental performance.

The objectives of the earned autonomy pilot program are consistent with EPA’s approvals review commitments and input from stakeholder consultation.

EPA has worked with stakeholders to develop a program that:

  • encourages, recognises and rewards superior environmental performance across all licensees
  • provides assurance to a range of stakeholders – including but not limited to internal management of licence holders, community, financiers and insurers – that the business is a strong performer in meeting or exceeding compliance obligations
  • encourages, recognises and rewards licensees that demonstrate environmental citizenship, stakeholder participation, restorative action and environmental leadership
  • offers a tiered approach to afford businesses earned autonomy and public recognition relative to their performance rating
  • compares industries like for like.

The pilot program will inform the development of a long-term model.

Pilot program design

The pilot program uses a model of compliance plus licensee excellence. It is being offered to existing EPA-accredited licence holders and eligible water industry licence holders. The long-term vision is to offer the program to all EPA licence holders.

The program assessment criteria are based on licence holders’ environmental performance and how they have applied the principles of environmental citizenship into their business. Environmental citizenship, the core of EPA’s operating model (see Figure 1), is the interdependent relationship between EPA and the Victorian community and our joint responsibility to actively protect our local environments across the state.

Figure 1: Environmental citizenship as the core of EPA’s operating model


Earned autonomy benefits will be tiered and awarded based on an assessment of environmental performance and how they have applied the principles of environmental citizenship into their business. Licence holders will be assigned to tiers as follows: Tier 1 (top performers), Tier 2 (great performers) and Tier 3 (good performers).

Page last updated on 10 Feb 2017