Things to know
Firstly, this is not the final decision point. The guidelines will be given to the proponent to steer the preparation of an Environmental Impact Statement (EIS) in the form of a Development Plan and Environmental Management Plan (DPEMP). The draft EIS/DPEMP document will take between 6 and 18 months to be prepared and then will go to the EPA before being published on the EPA website. Following the public comment period (42 days), the final EIS/DPEMP, and any public comment submissions, will be assessed by the EPA, with recommendations sent to the West Coast Council and Federal Environment Minister for what we hope is a rejection.
While this is an early point in that process, it is important that the guidelines identify all of the things that need to be included in the EIS/DPEMP. You can’t assess what isn’t reported on.
You can find the draft guidelines here MMG Australia Limited, South Marionoak Tailings Storage Facility, Rosebery - Draft EIS Guidelines
How to make a submission
In making a submission, it is important to remember that, at this point, we are only making comments about the draft guidelines.
- Are the guidelines clear?
- Are they strong enough?
- Do they seek all of the necessary information?
- Do they describe acceptable methodologies?
It is helpful to refer to specific sections of the draft guidelines rather than general comments and to be clear in your suggested additions or amendments. You don’t want your comments to be misrepresented or misunderstood.
It is also important not to get sidetracked into commentary about the approval of the project. That is an argument for after the EIS/DPEMP is produced, and the EPA cannot legally consider arguments not related to the draft guidelines at his point.
Below is the submission Bob Brown Foundation made to the EPA. You can edit our submission, add new points, or write a submission completely from scratch and submit it below.