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1、MEMORANDUMTo:Commonwealth of Australia: Department for Sustainability, Environment, Water,Population and CommunitiesCC:From:Heathgate Resources Pty LtdDate:31/10/2011Subject: Consultation paper on cost recovery under the EPBC ActHeathgate Resources Pty Ltd (Heathgate), owner and operator of the Beve
2、rley and Beverley North uranium mines in South Australia, and participant in a number of mineral exploration projects in SA, the NT and WAZ is pleased for the opportunity to comment on the consultation paper on cost recovery under the EPBC Act. Heathgate employs over 100 people directly and uranium
3、exports are typically worth $50-$100M/yr. In 2009 the energy equivalent of our exports allowed the production of electricity while displacing the carbon dioxide output of several very large fossil fuel power stations.From 2006 to 2010, Heathgate was subject to 5 actions under the Nuclear Actionsz, t
4、rigger of the Act, and thus has significant first-hand recent experience to draw upon.The format given in the consultation paper has been followed and comments are limited mainly to the general and environmental impact assessment aspects most relevant to Heathgates business.QuestionsCost recovery (g
5、eneral)Consultation Paper QuestionHeathgate responseWhat are your views on the introduction of cost recovery to reform the EPBC Act, including the proposed benefits that cost recovery would fund?While cost recovery is justified where EPBC is activated to protect an environmental value that would not
6、 be protected by State regulation, almost all of the EPBC-related work triggered by uranium mining is covered by State regulation. Thus EPBC is a 100% unnecessary burden on the industry, and is already a significant burden without cost recovery. Cost recovery on the basis proposed is completely unju
7、stified and will add insult to injury.Cost-recovery is also considered inappropriate as it: Removes the incentive for the Commonwealth to cooperate with States/Territories to reduce duplication (note: for nuclear actions, duplication is 100% as the States/Territories are already required to conduct
8、the same work as they have jurisdiction for environment matters); reduces the independence of the assessment process; adds unnecessary costs at the beginning of a project; encourages the unnecessary enlargement of bureaucracy regardless of the state of the economy; encourages additional work and exp
9、ense for unnecessary additional reviews” (eg management plan review that is already conducted by State authorities).Consultation Paper QuestionHeathgate responseWhat would your expectations be of improved service if cost recovery measures were introduced under the EPBC Act?While there is funding for
10、 improvement (10% levy), there appears to be no identified incentives to improve, and thus there is little possibility of improvement being achieved. In fact, less cost- effective services would produce more revenue providing a positive incentive to continue poor service.What other government fees a
11、nd charges do you have to pay in undertaking your business?What is your experience in dealing with these charges?Mining and exploration lease rentalMining royalties to government and Native Title holdersLicence fees (over $500,000/yr)Payroll taxWater usage fee (for our privately owned and run water
12、supply) Our experience has been that the charges rise much faster than inflation, e.g. radiation licence fees increases of up to 200% in one yearIn what circumstances should fees be waived or reduced for activities being considered for cost recovery under the EPBC Act?Under all circumstances where:
13、EPBC involvement duplicates State regulatory functions that will also be performed; and Where the recipient of the benefit is the tax payer (ie, all EPBC “services stimulated by the Nuclear Actions trigger are justified by the supposed fear of the general public, thus the general public are the bene
14、ficiaries of the services.)Do you have other suggestions for resourcing reforms to this regulatory system?The scope of referrals should be reduced to have more emphasis on only referring matters of genuine importance; why are supermarkets referring expansions of car parks? If only genuinely importan
15、t matters are referred they can be dealt with by a smaller bureaucracy.The Australian Government Cost Recovery Policy requires cost recovery arrangements to be reviewed through a Cost Recovery Impact Statement (CRIS) at least every five years, and this is a public document. Do you consider this time
16、frame is appropriate for review of cost recovery arrangements under the EPBC Act?The appropriate frequency of review depends on the degree of unfairness of the recovery arrangements that are implemented. Clearly an arrangement that includes an outrageous surcharge of 10% for process improvement would need to be reviewed after 2 years of operation after which opportunities for improvement will have been exhauste
