SUBMISSION TO NT EPA ON DRAFT GUIDELINE FOR PREPARING A NOTICE OF INTENT

Feedback on the Draft Guideline for Preparation of a Notice of Intent

The Minerals Council of Australia Northern Territory Division (MCA NT) welcomes the opportunity to provide comment on the Northern Territory Environment Protection Authority – Draft Guideline for the Preparation of a Notice of Intent (NoI).

The MCA is the peak industry organisation representing Australia’s exploration, mining and minerals processing industry, nationally and internationally, in its contribution to sustainable development and society.  The MCA’s strategic objective is to advocate public policy and operational practice for a world-class industry that is safe, profitable, innovative, and environmentally and socially responsible, attuned to its communities’ needs and expectations.

The Australian minerals industry is committed to environmental regulation that is both efficient in its operation and effective in achieving desired outcomes. Accordingly, the MCA strongly supports the periodic review and improvement of environmental impact assessment to achieve this.  The drafting and public review of the Northern Territory Environment Protection Authority’s Guideline for the Preparation of a Notice of Intent exemplifies the Government’s commitment to continual improvement and is to be commended.

The draft Guideline specifies the range and scope of information the EPA needs to determine if a proposal requires formal assessment under the Environmental Assessment Act (NT), and, if so, at which level: NoI, Public Environmental Report or Environmental Impact Statement.  It will benefit both proponents and the NT EPA by

Ensuring proponents can target and provide all essential information in the NoI and thus avoid costly delays associated with having to respond to requests from the NT EPA for further information; and
Ensuring the NT EPA has all the information it requires to determine the appropriate level of assessment for each proposal, so that it can provide timely advice to the proponent.

An efficient and effective EIA process increases business confidence and enhances Australia’s reputation as an investment destination for responsible development, while upholding environmental standards.

Summary of MCA NT comment on the Draft Guideline for the Preparation of a Notice of Intent

The MCA NT has completed its review of the Draft Guideline and included its detailed feedback in the NT EPA’s Submission Form (Attachment A).  Overall, the document is clear, well-organised and easy-to-read, all of which would assist our members in providing adequately complete NoIs that ‘get it right’ the first time. Comments in the form identify the relatively few instances where existing wording is ambiguous, inaccurate or imprecise, and suggests alternative wording to avoid these issues.

We have also provided editorial comment on the document itself (tracked changes) to address typographical, spelling, grammatical and other errors to improve the overall quality of the document that can be viewed here.

Once again, the MCA commends the NT EPA on preparation of a revised Guideline for preparation of Notices of Intent and appreciates the opportunity to provide feedback.

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