“Be clear” when submitting to the EES

By Lachlan Ellis

The ‘EES review’ for the Western Victoria Transmission Network Project (WVTNP) is still a way off, but a DELWP staff member and an experienced barrister have provided a range of tips on how to prepare.

DELWP Senior Impact Assessor Jack Krohn and barrister Louise Hicks spoke at the latest online community session hosted by Moorabool Shire Council on Wednesday 9 March, titled ‘Preparing a submission to an Environment Effects Statement (EES) public review’.

As the title suggests, once AusNet completes its EES, the community will be asked to submit any concerns or queries they have about it.

Mr Krohn said that in a sense “we’re getting ahead of ourselves” by discussing the review already, but it was important to talk about it now to “demystify what comes ahead”.

“I stress that authorisation for exhibition is not in any sense either the Department or the Minister expressing a view about whether the project is a good project, or the right project…it’s simply about whether this is an adequate response to say ‘yes, this should go out and people should be given the opportunity to comment on it’,” he said.

“Ministerial guidelines say an EES will usually be exhibited for 20 to 30 business days. In August 2020, the Planning Minister specified an exhibition period for this EES of 30 business days, that may be reviewed at his discretion.

“The exhibited EES is a package, it will include a Main Report, commonly 2 to 3 volumes, Technical Appendices which are the final reports of the various specialist consultants…all of the substance ought to be in the Main Report. You may also wish to look at any attachments such as a mapbook.”

On participating in the submission process itself, Ms Hicks encouraged those who wished to make submissions to be brief but thorough.

“The core of the submission has to be relevant to the nature of the inquiry…you get that from the terms of reference. Keep that by your side when you’re writing your submission and think, what has the inquiry been asked to consider?” she said.

“Another bitterly learnt experience from my years of writing submissions is, for goodness sake, be clear. A point isn’t made better with expressions or provisos. Cut through all the nonsense and be clear on the point. You can often practically achieve that, by putting headings in your submission.”

Following Mr Krohn and Ms Hicks’ statements was a live Q&A, with questions sent in both prior to the meeting and in the text box on-screen.

A vital point for anyone wishing to make a presentation at the hearing for AusNet’s EES – which will most likely be held online – was to make a submission to Engage Victoria.

“You can make a submission and you don’t have to choose to be heard, but if you don’t make a submission, you will not have the opportunity to be heard,” Mr Krohn said.

“If you have not made a submission, you will not be invited to speak at the hearing.”

Mr Krohn also encouraged people who are curious about how the EES review process works to check out the ‘Suburban Rail Loop East’ project on Engage Victoria’s website, which is currently undergoing an EES review.

“On the Engage Victoria platform there will be a timetable that says who will be speaking each day and which witnesses they’ll be calling. You will be able to find out, right, I know when my submission’s going to be, because that’ll be stated in the timetable,” Ms Hicks added.

Missed the meeting? View the 90-minute recording of the meeting, visit the Moorabool Shire Council YouTube channel and click ‘Preparing an EES submission community session recording’.

To read the full story – Simply click on the following link

https://issuu.com/themooraboolnews/docs/mn_2022-03-15/11

in the 15 March 2022 edition
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pick up a paper around your town.