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Guide for Preparing a Public Submission


Introduction

The public is invited to comment on documentation submitted to the Board of the Environment Protection Authority for assessment under the Environmental Management and Pollution Control Act 1994(EMPCA).

This documentation is prepared by the project proponent and typically consists of either a Development Proposal and Environmental Management Plan (DPEMP) or, for smaller projects, an Environmental Effects Report (EER).

The EPA Board is required under section 74(6) of the EMPCA to provide an opportunity for public consultation on the project before the assessment process is complete.

Public consultation can occur at two stages in the assessment process:

  1. Scoping Phase: Draft DPEMP Project Specific Guidelines may be advertised for comment where a project is subject to a very high level of public interest.
  2. Mandatory public comment period: The permit application and supporting documentation (including DPEMP or EER) must made available for perusal for a period specified in legislation.

Persons wishing to make a submission in relation a proposal that has been advertised for public comment should refer to the guidance provided below. Documentation advertised for public comment will be made available here.


Why make a submission?

By making a submission, you can express your opinion of the project, contribute knowledge and make suggestions.

You may have useful information which is not known to others, especially if you live or work in the area of the proposed project.

Your submission can help in the assessment of the accuracy and suitability of the proponent’s documentation on the project.

Your submission will assist in the preparation of an Environmental Assessment Report which will contain recommendations on the project to the EPA Board.


Group submissions

If you prefer not to write your own comments, you may wish to consider joining a group interested in making a submission on similar issues. Joint submissions reduce the workload for individuals, as well as increase the pool of ideas and information. If you form a group, the names of participants should be indicated on the submission.

Please note that a group submission prepared and signed by one person is considered to be a single representation. Everyone who wants to be considered as a representor should provide their contact details and sign the representation.


What to say in a submission

A submission may be as long or a short as you like. In your submission you may agree with, or disagree with, or comment on the issues raised in the DPEMP or EER. It helps if you provide reasons for your conclusions, and provide relevant supporting data.

Here are some questions that you may like to ask yourself when reviewing the DPEMP or EER.

  • Does the document clearly describe the project and the existing environment?
  • Does it identify the environmental issues that you consider important?
  • Are the management measures committed to by the proponent adequate to control any environmental impacts?
  • Is there recorded or anecdotal local knowledge of the environment which could help in understanding any potential environmental impacts?
  • Is there any other information that is incorrect or missing from the document?
  • Could the project be improved in any way? Can you think of any alternative solutions or other ways of managing environmental impacts?

Making your submission effective

Here are some points to help make your submission more effective.

  • Find out about the project before making your submission. This can involve talking to others, or reading available material from newspapers, libraries or the proponent.
  • Be brief, simple and clear. Organise your thoughts logically.
  • Be specific, rather than general in your comments.
  • Where possible, relate your comments to specific sections of the DPEMP or EER. Preferably, each comment should include a reference to the relevant section of the DPEMP or EER.
  • Use dot points and headings to help organise your ideas.
  • Use photographs, maps or sketches where appropriate.
  • Be constructive in your comments, such as by identifying additional potential impacts, or options for avoiding, mitigating or managing impacts.
  • Attach any factual information you may wish to provide, such as scientific reports. Make sure your information is accurate.
  • Include a summary of the main points if your submission is longer than a few pages.

Things to remember

When making your submission remember to include:

  • Your name;
  • Your address;
  • The date you made the submission.

Do not think that you are only one voice and you won’t make a difference. Past experience has shown that one well-reasoned submission which raises a valid concern or offers a constructive suggestion can be very helpful and important to the assessment process.

Each submission is important in its own right, but those submissions that present reasons for concern and offer good information and suggestions are of most use.

It is equally important to comment on parts of a project that are positive or offer new opportunities for local communities.


Confidentiality

All submissions received will normally be treated as publicly available.

Under section 74(7) of the EMPC Act, the EPA Board has an obligation to publicly disclose all information relating to the environmental impact of the proposal, except where there is a legitimate commercial, national security or environmental reason for confidentiality. As a result, the EPA Board may publicly disclose all or part of a submission.

If you wish your submission to be considered as confidential, then this should be requested in the submission, along with the basis upon which the request is made.


What happens next?

Your submission will be read by the officer preparing the Environmental Assessment Report for the EPA Board. The relevant issues raised in all public submissions will be summarised, grouped together and sent to the project proponent. The proponent will be asked to provide a response to all relevant public submissions, and may modify the project to address your concerns.

An Environmental Assessment Report will then be prepared containing recommendations on the project to the EPA Board. These recommendations will be based on the assessment of the proponent’s documentation, public submissions and other specialist advice.

The report will include a summary of the relevant issues raised in public submissions and should allow you to see how your concerns were taken into account.

Everyone who makes a submission will receive notification of the EPA Board’s decision on the project. The Environmental Assessment Report will be published on the Agency’s web site.

Assessments Section
GPO Box 1751
Hobart TAS 7001
Phone: 03 6165 4599 Fax: 03 6173 0254
Email: EPAenquiries@epa.tas.gov.au