In summary, EDO’s key submissions are as follows, with more detail below.

1. In general, the introduction of code managed environmentally relevant activities (ERAs) is not supported, where there are already sufficient, fast pathways to environmental authorities (EAs) through existing provisions and risks arise in deregulating activities in this way. However, if those amendments proceed, proponents operating under ERA codes should be required to register with the Department of Environment, Tourism, Science and Innovation (DETSI) and that register should be made publicly available to ensure clarity for all in how the proponent’s activities are regulated.
2. Public notification on terms of references (TOR) for environmental impact statements (EIS) should be retained, to assist in ensuring that site specific and unique environmental impacts of projects are properly assessed and considered.
3. Recognising the future public cost arising from non-use management areas (NUMAs), we strongly recommend that public interest evaluations for progressive rehabilitation and closure plans (PRCP) framework are retained. This will ensure an independent review of proposals to leave NUMAs occurs, and that NUMAs are only being proposed if it is in the public interest to do so. The independent review helps in protecting against weakened regulation through regulatory capture.
4. The provisions relating to allowing extensions for fulfilling residual risk requirements obligations should not proceed. If the proposed reforms do proceed, at a minimum the proponent should be required to fulfil some criteria justifying why an extension is needed (including consideration of the public interest) and there should be a limitation on the length of the extension period of 6 months.
5.  We welcome the introduction of powers to direct proponents with no PRCP schedule or rehabilitation conditions to carry out rehabilitation. Regular 3 yearly auditing of proponents’ compliance with rehabilitation goals should be maintained, with an exception for proponents who do not yet have any rehabilitation requirements.
6. We hold concerns with respect to the amendments which permit the administering authority to consider historical context and constraints of operations, and practicality of applying best practice management when assessing whether a proponent’s methodology achieves best practice management under PRCPs. All proponents undertaking mining activities should be held to contemporary standards.
7. We welcome amendments enabling single integrated permits to operate across tenures under the Forestry Act 1975 (Qld), Marine Parks Act 2004 (Qld); the Nature Conservation Act 1992 (Qld) (NC Act) and the Recreation Areas Management Act 2006 (Qld) (RAM Act) to the extent they do not remove existing protections. Accordingly, when making decisions with respect to integrated permits, the Bill should ensure that any existing requirements to consider factors under the relevant Acts are maintained. This will ensure any protected matters are appropriately considered when permitting commercial activities in recreation areas.
8. Amendments lengthening the timeframes for preparing underground water impact reports should not proceed as the current 3 yearly cycles are appropriate and longer period risks delays in actioning impacts to bores.
9. We welcome the proposed amendments to the Water Act 2000 (Qld) (Water Act) which strengthens landholder rights with respect to impacts from resource activities. These amendments will afford landholders greater access to justice which in turn will lead to better public interest outcomes in water management.