The Minerals Council of Australia, Victorian Division (MCA) welcomes the opportunity to make a submission to the Standing Council on Energy and Resources the Draft National Harmonised Regulatory Framework for Coal Seam Gas (‘CSG Framework’).

The MCA represents Australia’s exploration, mining and minerals processing industry, nationally and internationally, in its contribution to sustainable development and society. MCA member companies produce more than 85 per cent of Australia’s annual mineral output. The MCA’s strategic objective is to advocate public policy and operational practice for a world-class industry that is safe, profitable, innovative, environmentally responsible and attuned to community needs and expectations.

The Victorian Division of the MCA represents the interests of member companies operating, exploring and providing services to the industry in Victoria.

Policy positions of the Victorian industry are one and the same as the entire Australian minerals industry. The MCA operates on a platform of national consistency and therefore considers that minerals operations in all jurisdictions should be subject to the same polices and legislative frameworks across the country.

The MCA has established a strong record for leadership in environmental leading practice in minerals development. Members of the MCA have a long-standing commitment to sustainable development, including the responsible stewardship of natural resources. Whilst the effective footprint of mining projects is relatively small, many companies own or manage large tracts of land associated with their projects.

This commitment to continuous improvement in minimising the industry’s environmental impacts is a fundamental plank of the industry’s broader commitment to sustainable development. This is demonstrated by the MCA’s requirement that member companies are signatories to Enduring Value – the Australian Minerals Industry Framework for Sustainable Development, which commits members to continuous improvement in their environmental performance, beyond regulatory requirements.

The CSG Framework rightly acknowledges the shared commitment to multiple and sequential land use, a long held tenet of the MCA. It also highlights the critical importance of merit based land access and decision making through the utilisation of the best available science, and more regional approaches to assessing projects. The MCA therefore acknowledges the work of the Independent Expert Scientific Committee on Coal Seam Gas and Large Coal Mining (IESC) as an advisory body.

While landscape scale assessments are supported, these may require significant investment and take many years to complete. In the interim period, it is important to ensure that project assessment and approvals within these regions can continue to be based on ‘best available science’ and are not unduly delayed by bioregional assessment processes and the inappropriate application of the precautionary principle beyond existing legislative application under the Environment Protection Biodiversity and Conservation Act (EPBC Act).

This submission is made in the context of the Victorian industry and regulatory frameworks.

Overall the MCA is broadly supportive of the 18 Leading Practice Principles for CSG Operations which the CSG Framework has set out as its guiding principles. However, how these principles are adopted – i.e. through legislation, codes or guidance, will require significant consideration. For example, it is not practicable to apply a number of the principles at a licence application stage or for licences that allow exploration only.

The regime in Victoria provides a robust merit based approach underpinned by risk management and incorporating the principles of sustainable development, therefore singling out a particular commodity such as CSG is not necessary. In the event that reform is proposed as a result of the national harmonised regulatory framework for CSG, COAG principles of best practice regulation must apply (

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