Setting and reviewing standards

Scheduled Premises Regulations review discussion paper (2015)


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In response to the discussion paper (publication 1613), stakeholders provided feedback on the content and design of the Regulations, as well as commenting on EPA’s administration of them. The feedback we received was used by DELWP and EPA to inform the development of the 2017 version of the Regulations.

Key comments included the following:

  • When asked which currently scheduled activities were most important for works approvals, licences and financial assurances, the most common responses were landfills (A05); prescribed industrial waste management (A01); waste to energy (A08); chemical works (G01); contaminated sites – onsite soil management (L02); and long-term management (L04).
  • Conversely, different stakeholders suggested that various activities may no longer warrant works approvals or licences, on the basis that they are now being managed more effectively or involve lower risks than they did in 2007.
  • The rationale for requiring financial assurances from government entities (water corporations, councils) and from entities required to provide similar assurances under other legislation was questioned.
  • Most respondents thought that emission levels and pollution events would increase if works approvals, licences and financial assurances were no longer required.
  • Local government stakeholders expressed concern about any potential additions to their existing obligations.
  • Several organisations sought more clarity on the application of exemptions.
  • Concerns were expressed about the length of time, complexity and cost of obtaining a works approval, particularly for modification works that will provide better environmental outcomes.
  • Different respondents advocated that different, additional activities should be licensed, such as those with potential noise impacts (such as airfields or wind farms), or those that present emerging or diffuse pollution risks (such as unconventional gas, animal husbandry and service stations).
  • Stakeholders noted the need for clarity in the respective roles of EPA (under the Environment Protection Act) and local councils under the Victorian planning system, and similarly the need to avoid duplication with other regulators (such as for earth resources regulation).
  • There was more support than opposition for the idea of introducing tiered licence conditions. Views on the idea of introducing a site-specific fee component were more mixed.

Those providing comments had the choice of making them publicly available (with anonymity for the author in some cases) or keeping them confidential. If a person requested anonymity, identifying details have been removed. If confidentiality was requested, the submission has not been published. Some parts of the comments have been redacted (blacked out) for privacy reasons.

Comments from organisations

Comments from individuals

Page last updated on 20 Oct 2016