Environmental Management and Pollution Control Amendment Bill

Ms WEBB (Nelson) – Mr President, I rise to place my comments on the public record regarding the Environmental Management and Pollution Control Amendment Bill 2022.  I must say, I find myself thinking that this is something of an odd bill.  On one hand, at a macro level, it seeks to deliver on an important measure that many in the community have been calling for a considerable amount of time:  an independent Environment Protection Authority.

However, on the other hand, it has all hallmarks of an interim, a stopgap measure, producing an EPA that is not actually as independent as many in the community may have felt they understood to be promised by the Government’s commitment.  Following the gazettal of the State Service (Restructuring) Order (No. 2) 2021 on Friday 26 November last year, the Environment Protection Authority formally separated from the department on 1 December last year and the minister stated during House of Assembly budget Estimates on 8 June, this year, and I quote:

To further support that separation and bring greater transparency to environmental regulation and we are proposing amendments to the Environmental Management and Pollution Control Act, these amendments will further strengthen the independence of the EPA and its statutory assessment and regulatory functions and clarify the powers of the director.

That was in the budget Estimates session from the minister. 

This bill appears to be all that the Government is proposing to progress in order to formalise that independence of the EPA.  I do not believe there are other measures to come and hence, I think there is a sense of disappointment from some key stakeholders and others about the degree to which this achieves the expected outcomes.  The words sounded very positive, but the legislative reform is relatively minimal.

The second reading speech delivered by the Leader for the Government here lists three key areas of reform contained within the bill to deliver the minister’s stated intent, with the contention being that those key areas of reform will, and again, I quote:

…play an important role in protecting Tasmania’s environment.  It will also mean the public can have greater confidence in activities that use the state’s natural resources and oversight of those activities.

The fact there is a loud and legitimate call for a truly independent statutory authority as the state’s EPA is acknowledged by the Government, promising to strengthen the independence of the EPA.  This makes the fact that this bill misses that opportunity to deliver so frustrating and potentially bitterly disappointing for many.  To be clear, the limited parameters by which the Government set itself to work on this reform was of its own choosing.  It could have broadened those parameters and consulted on a comprehensive review to deliver that long‑awaited standalone, statutory independent EPA.  Clearly, that is not to be, or at least not yet.

We are left with having to evaluate this bill against the limited goals the Government has set itself.  Instead of a statutory independent entity, the revamped EPA as envisaged by this bill is described as a state authority by the Government.  It is specifically referred to as a standalone state authority on page 4 of the explanatory paper for consultation draft which was provided with the draft bill.  I asked for clarification on that designation in our briefing on the bill, and was pointed to the State Service Act 2002 for the definition of a state authority. That act defines ‘State authority’ as:

…means a body or authority, whether incorporated or not, which is established or constituted by or under an Act or under the royal prerogative, being a body or authority which, or of which the governing authority, wholly or partly comprises a person or persons appointed by the Governor, a Minister or another State authority, but does not include a Government department. 

I also noted in the Tasmanian Audit Office document titled Reporting by Tasmanian Public Sector Entities, the following description of a state authority:

(e)      A state authority that is not a Government Business Enterprise;

What constitutes a state authority is quite broad.  Any entity that is not captured by one of the other more specific categories will most likely be a state authority. 

Then it quotes the Audit Act definition and goes on further to say this:

This definition is quite all-encompassing, not only capturing many larger specifically created public sector entities, but also the many smaller trusts, boards or management authorities. For example, the Theatre Royal Management Board.

As well as the Theatre Royal Management Board mentioned in the Audit Office document as an example, I heard in the briefing that state authorities also cover entities such as Brand Tasmania, the Integrity Commission, Macquarie Point Corporation; and, possibly, the Port Arthur Historic Site Management Authority, although I note that is referred to as a GBE elsewhere.  In a nutshell, my understanding is that a state authority is a very broad label.  It is basically a catch-all, which indicates that while still under state service management, the entity is not within a department.  It perhaps sits adjacent to any department.

So, calling this new EPA a state authority does not tell us much about its degree of independence, or give us much detail about its characteristics.  On one hand, it should be self‑evident.  However, it cannot be stressed enough that, at the core of securing greater public confidence in our environmental governance and regulation, is the genuine independence of the EPA.  In this regard, as stated by the Environmental Defender’s Office (EDO) in its correspondence to members here on 7 November, this bill is – and I quote:

A missed opportunity to provide for the best practice environmental regulator which given the expansion of industries such salmon farming in our previous coasts and inland waterways is sorely needed to protect the places Tasmanians love.

Members here may recall that the Legislative Council Subcommittee Report on Finfish Farming in Tasmania presented findings and strong recommendations relating to environmental governance, including the need for independent, transparent and accountable regulation of the finfish industry by an independent EPA.  We heard a resounding call for that, in the evidence presented through that inquiry.  Clearly, the independent, transparent and accountable regulation called for in relation to finfish farming is required just as much across other industries and activities in this state.

It would be helpful for the Leader to clarify what is specifically meant when the Government describes the EPA under the provisions of this bill as ‘independent’.  What are the specific ways this new model has a greater degree of independence than the previous model in exercising the functions and powers that have been and continue to be the legislated functions and powers of the EPA board and the EPA director?  The minister’s second reading speech states that one of the key things the bill does is to complete the legal separation of the EPA from the Department of Natural Resources and Environment.  Further, the second reading speech closes with:

The bill provides the legal foundation for a contemporary, proactive approach to these matters in line with equivalent national legislation.

I would like the Government to explain the difference between ‘legally separate’ and ‘independent’ – if there is one.  Also, is establishing a legally separate EPA the first step towards a fully independent agency such as an independent statutory authority, or something equivalent to what we might see in some of those independent EPAs in other jurisdictions?

Moving on, as noted in the EDO’s submission to the consultation on the draft bill earlier this year, the mere existence of an independent EPA does not in itself guarantee the environment will be better protected, nor that development will be appropriately regulated without undue external influence.  The EDO warns in that submission that an environmental regulator established without sufficient independence mechanisms, a lack of clear legislative criteria for decision-making, and with a specific focus on realising economic objectives, can lead to significant resource expenditure without corresponding improvement to environmental governance outcomes. 

To be effective at truly improving environmental governance and environmental outcomes, an independent Tasmanian EPA must implement a comprehensive suite of strong governance measures.  To inform ourselves on that point, I look to the national Environmental Defenders Office best practice EPA report, which outlines nine elements of strong governance.

These nine elements state that all EPAs should have the following:

Recommendation (1): Duty to develop and act in conformity with Cultural Protocols which are based on First Nations Lore, and to uphold international recognised First Nations rights of free, prior and informed consent and self-determination.

Recommendation (2): All EPAs in Australia should be underpinned by environmental justice frameworks that:

• • acknowledge and address environmental racism;
  • meaningfully define environmental justice;
  • legislatively enshrine mechanisms to achieve environmental justice; and
  • have a proper foundation in principles of human rights under international law.

Recommendation (3): A clearly defined role and duties to ensure objectives are achieved

Recommendation (4): An EPA should be established as an independent statutory authority that has:

• • a clear independent governance structure, supported by a Board to provide strategic advice and direction;
  • freedom from ministerial influence or being overridden by other agencies; and
  • policies and procedures to manage conflicts of interest.

Recommendation (5): An EPA should be accountable to the public, which includes:

• • well-defined and clear criteria for decision‑making;
  • mechanisms to review decision-making, including open standing for judicial review and merits review;
  • the regular publication of State of the Environment Reports; and
  • powers to scrutinise performance, both of the government and itself

Recommendation (6): Transparency in decisionmaking through disclosure and community engagement to support accountability.

Recommendation (7): Sufficiently empowered to protect the environment and human health.

Recommendation (8): Sufficient and certain funding to fulfil their functions.

Recommendation (9): Relevant expertise to support decision-making that is science-based and provides for First Nations justice and environmental justice broadly.

Mr President, that is a lengthy list but it is important that this is worked on at a national level to identify the nine elements that need to be there to ensure there is strong governance in an independent EPA.  When evaluated against those required elements of an independent EPA, I believe this bill falls short – considerably. It is beyond the scope of the debate to go into exhaustive detail of what I believe are missed opportunities here, but I will focus on just a couple of key areas.

An independent EPA should be underpinned by an environmental justice framework, according to those elements laid out at a national level by the EDO, to ensure that equality in environmental protection is there, and it is not provided for here in this bill.  A key related absence here is any inclusion of a need to develop and acting conformity with cultural protocols developed by the Tasmanian Aboriginal community, and to uphold internationally recognised First Nations rights for free, prior, and informed consent and self-determination.  I am interested to hear from the Government what consideration was given to the inclusion, or reference to, some form of environmental justice framework alongside the establishment of an independent EPA.

Mr President, if we look at the element of defined principles and role, arguably, this bill misses the opportunity to provide the EPA with a clearly defined role and duties to ensure objectives are achieved.  A quick canvas of EPAs around the nation reveals that many have a clear set of principles or objectives outlined upfront in their respective establishing legislation.  These boost public confidence – something this Government has stated it is keen to foster here as well – by providing clear criteria and expectations against which the EPAs actions can be directed, seen, and evaluated.  In some interstate cases, it is clear that the inclusion of legislated principles and objectives replaces any equivalent ministerial statement of expectations.  In fact, when it comes to principles and objectives, I wonder where we can find it plainly stated in this legislation – or the primary legislation – that it is the primary responsibility of the EPA Board and EPA director to protect the environment and human health consistent with the human right to a healthy and safe environment, which we will recall was one of those elements the EDO at the national level, considered essential for an independent EPA entity.

It should go without saying the EPA should be independent from ministerial influence, that of other government agencies or industry capture.  However, to protect both the public interest and the EPA itself, this independence from ministerial influence should be clearly codified in legislation.  We can all see from this bill it will not be entirely the case for Tasmania’s EPA.  The role of the minister is still heavily entwined through the governance model; from the statement of expectations, through to making, amending, and revoking the environmental standards.  What consideration was given to a model, such that we might see in another jurisdiction, where there is less involvement through the governance elements of ministers.

The Government’s second reading speech mentions providing certainty on the role of an independent EPA Director.  I have some questions regarding the independence of the EPA Director under this model, particularly given the requirement to Section 18 of the principal act that states:

Director Environment Protection Authority

The Governor may appoint a State Service officer or State Service employee to be Director, Environment Protection Authority and that person holds office in conjunction with State Service employment.

That is in the principal act and I do not believe it is being amended by this bill.  The EPA director is going to be State Service officer, holding the office in conjunction with State Service employment.  I note that is different to some of the other statutory positions we have in this state such as the Auditor-General, the Anti-Discrimination Commissioner, the Chief Integrity Commissioner.  They are all a bit different in their establishing legislation, but the common factor is that they are not – I do not believe – State Service employees in their roles.  Can the Government provide an explanation on the nature of the director EPA position under this model?  Is it analogous to any other statutory positions we might look to in other areas?  How is it consistent with the commitment of delivering an independent EPA if the director is a State Service employee or officer – basically an employee of the government?  Is this an arrangement that corresponds to other jurisdictions for their equivalent positions?  Is it a model we can look to elsewhere?

I also note the bill misses the opportunity to provide the EPA Board with a role in appointing or providing oversight of, the performance of the director’s functions and powers under the act.  In Victoria, under their model the EPA Board has the power to do the appointing, and provide the oversight of the CEO of the Victorian EPA.  That role is equivalent to our director’s role.  Can the Government provide an explanation, as to why the EPA governance structures were not addressed in this bill in terms of the relationship between the board and the Director?  For example, why is the board not responsible for the employment, appointment, or supervision of the director?  Or, perhaps I have misconstrued that and there is more of a direct role there.  Perhaps, the Government could provide an explanation?

Similarly, there was an opportunity in this bill to detail the EPA director’s functions or powers quite explicitly.  Just as section 14 of the principal act details the EPA Board’s functions and powers, we do not seem to have an equivalent description of the EPA director’s functions and powers.  I note that section 8 of this bill which inserts section 18A – Independence of the Director – into the legislation, specifies the instances in which the director is not subject to direction from anyone in relation to specific decision-making powers and it lists the types of decisions the director has independence within.  In a way, section 18A that is being inserted with that list, becomes a de-facto list of the director’s functions and powers, but it is not necessarily presented as a clear and exhaustive list of those functions and powers.  I am not clear as to why there is not a straightforward articulation of those and perhaps the Government could provide an explanation of why that is not the case?

Significantly, I also note the bill fails to provide a process for the management of any arising conflicts of interest of the director.  We would all recognise this as a critical aspect of any system of good transparent governance.  Certainly, some of those other statutory roles mentioned earlier have something specific in there establishing legislation that deals with conflicts of interest, and we have seen it before in other legislation for particular entities or roles.

I want to understand why the Government has failed to address that in this legislation, and in its absence from the legislation, what would be the arrangements for the identification, the documenting, and the transparency on managing conflicts of interest that may arise in relation to the director? 

It is also worth noting the national EDO report on effective independent EPAs I talked about earlier, states under that recommendation five, as an accountability mechanism to ensure responsibilities are discharged with integrity in the public interest, that a state of the environment report should be published regularly by the EPA.  I find it astounding, given the recent controversy over Tasmania’s missing State of the Environment Reports that there does not appear to be any consideration provided while developing this bill to finally house the State of the Environment Report within the further independent EPA.  Particularly, since the recent announcement by the Planning minister, Mr Ferguson.  That announcement carefully states that the Tasmanian Planning Commission has so far only been directed to reduce the next state of the environment report in 2024, leaving open where the responsibility for any future state of the environments reports will lie. 

Interestingly, with the Northern Territory aside as the only jurisdiction without a requirement to produce a state of the environment report, we can look to other jurisdictions and see in New South Wales, Western Australia and South Australia, where they have state of the environment reports all as responsibilities of their respective EPAs.   In the case of Victoria, they have it with their Commission for Environmental Sustainability.  Queensland locates state of the environment reporting responsibilities with their Department of Environment and Science.  But their EPA is certainly a common location for that responsibility.

I do wonder whether this bill is a missed opportunity to signal that the uncertainty over our state of the environment reporting in Tasmania has been resolved once and for all, by allocating that responsibility for producing the report with this new, independent EPA.  Then, of course, what would follow would be an assurance of adequate funding and capacity to undertake that task one would hope.  It may well be that that comes to pass in time and it is just that, decision-making on it has not been able to be completed within the time for bringing this bill forward.  This may well be the case, we may find at some stage down the track that responsibility does arrive at the door of the EPA as configured under this bill.

As we all know, independent statutory entities must still be accountable to the parliament and to the Tasmanian public.  While there is some provision in the bill for the EPA director to publicly release information and data in a more transparent way, reporting to the public and director of the EPA itself seems to be fairly light on.  For example, currently the minister is required to issue a statement of expectations to the EPA every two years.  Clause 6 of this bill, Section 15 amended, now intends to extend that time frame out to five years.

Now there is some debate, about whether there even should be a ministerial statement of expectations given to a truly independent statutory agency.  Perhaps, a truly independent entity should not be subject to ministerial direction in that.  However, given the model we have presented, I would be interested to hear what consideration the Government gave to a fully independent EPA that would not be subject to ministerial statements of expectations, as per some of those interstate jurisdictions.

Of course, it could be argued in the absence of a clear set of principles informing the EPA’s actions and priorities, the statement of expectations from the minister remains a form of parliamentary accountability.  However, the point here is that extended time frame from two years to five years potentially leaves concerns over the risks of those expectations becoming outdated, but while still remaining in effect.  I understand they can be brought forward and reviewed at an earlier stage, but it is interesting because it is worth noting that the most recent ministerial statement of expectations that we have, and then the EPA Board’s corresponding statement of intent against that statement of expectations, appears to be expired – so we are currently outside of a period that was defined as being covered by the current statement of ministerial expectations.

Two that I found available on the EPA’s website are for the years 2016‑18, and more recently, 2019‑20.  Here we are in 2022.  If the Government is finding it difficult to keep up with the current requirement, I wonder whether it is mere expediency that the requirement has been amended in the bill, and extended out to five years to give a bit more breathing room, rather than for any policy reasons.

I would like to hear from the Government if there are policy reasons for a five‑year time frame from ministerial statements of expectations in the bill, or whether that is predicated on practical matters – that five‑years is easier to achieve, given that we currently find ourselves outside of a two‑year requirement.

Recognising the important role this bill is intended to play in protecting Tasmania’s environment, and the central priority of managing and mitigating the impact of climate change ‑ which we have recently acknowledged, in the passage of the review to the Climate Change Act of Tasmania – I wondered why there is no connection made here between the two.  As raised by some stakeholders, there would seem to be an opportunity in relation to clause 17, Part 7, division 1B, inserted, by expanding new clause 96P, in relation to proposed new environmental standards.

I ask the Government, what consideration was given to requiring that environmental standards developed under this act, are consistent with any Climate Change Action Plans or any Sector-Based Emissions Reduction and Resilience Plans under the Climate Change (State Action) Act 2008.

We all know that our environment, our entire ecosystem, our biodiversity, and ultimately our health and our economy is experiencing its biggest threat, posed by climate change.  I am not sure why we would, in some sense, defy logic and probably also community expectations, to be progressing and codifying a legally separated EPA which has a very significant environmental focus without linking it to the efforts we have in other areas and through other legislation to counter climate change.  Perhaps the Government could provide some commentary on why there is no explicit link.

Further on the issue of environmental standards, I would like to have some explanation of the review time frame in the Bill.  The new Section 96W in the bill proposes a review of any environmental standards made within the six‑month period beginning on the 10^th anniversary of the date that any such standards came into effect.

Environmental standards are pivotal to this bill and to the effectiveness of the EPA.  It is very pleasing that they are going to be part of the mechanisms by which we regulate and monitor and protect our environment.

Currently it is proposed that the Environmental Standards will only be reviewed every 10 years.  That gives me pause.  A decade between reviews of such fundamental elements of our proposed environmental regulatory framework is not consistent with requiring persons engaging in polluting activities, to make progressive environmental improvements.

For example, as one of the functions, it has the potential to lock in outdated standards or practices, or even just slide into outdated standards and practices.

I do not know that it is consistent, either, with the intent of bringing greater transparency to environmental regulation that the minister promised during the House of Assembly Budget Estimates hearing on 8 June this year.

It also does not invite the community to hold, and I quote

… greater confidence in activities that use the state’s natural resources and oversight of those activities.

As espoused in this bill’s second reading speech.

The only rationale I have heard thus far about this timeframe of ten years, is that the environmental standards are somewhat equivalent to regulations, which generally have a ten‑year review period applied to them.

On matters relating to environmental protection, especially in the context of rapid impacts of climate change, it would seem advisable to have a review period shorter than a decade.  A five‑year review is potentially more consistent with other major reviews that we have recently established in legislation, including in the new Climate Change Act, with the Climate Change Action Plans, the Statewide Climate Change Risk Assessments, and the Sector-Based Emissions Reduction and Resilience Plans, all being set with five‑year review periods in that legislation.

Before the break, I was speaking about the five year, or about the 10-year review period for environmental standards and questioning the rationale for that, given there are five-year reviews in other legislation we have recently passed.  I would appreciate a policy explanation from the Government for the 10-year review period for environmental standards in the bill.  I am open to being provided with a clear rationale for that 10-year period, but I have also prepared amendments that would reduce the period between reviews to five years which I may bring through should we get to the Committee stage.

In addition to what looks like an unnecessarily long period between reviews of the environmental standards, I also consider it is hard to see why this review would occur behind closed doors – it seems – without involving consultation with the community or regulated industries.  Perhaps it does?  It is not specified in the legislation that has to occur.

It is also of concern that there does not appear to be clear and transparent criteria by which the minister considers whether to amend or revoke the environmental standards.  I am wondering about the absence of those, and whether there would be such criteria somewhere ‑ perhaps not in the legislation but elsewhere – so we could understand how, for example, the decision is made about whether to amend or revoke.

I do not consider it appropriate or desirable to cobble something in the form of an amendment, to try to insert that sort of thing into this bill, and I have not done so.  There are some serious concerns about the omission of such evaluation criteria behind the decision‑making, and I want to hear more about that from the Government to allay those concerns.  If such criteria are to be developed, putting them into the public domain in a different way might be something the Government would consider – not necessarily within the legislation – and if that is the case the Government could explain where that could be found at a later date.

I have another potential amendment that I may bring, should we get to the Committee stage, which also seeks to improve transparency and community confidence in line with the bill’s intent.  It is in relation to the technical standards which the bill proposes as the responsibility of the EPA director.  While I have just spoken about the decade-long period between environmental standards reviews being potentially too long, that is certainly better than none at all.  It appears that the legislation does not provide for a review period legislated for technical standards.  I do not see that in the bill; perhaps I could be pointed to where it might be?  I want an explanation from the Government as to why such a review period is legislated or mandated.  If there is to be a review period, I want to understand what that would be and what the process would be.  Depending on the information provided, that would help me understand whether I wish to move amendments if and when we get to the Committee stage.  I would have thought that there are some natural synergies between the review periods for the technical standards and the environmental standards, and they should be linked together.

It must also be clear, that a couple of those amendments that I have just mentioned, and which I may seek consideration of during the Committee stage, do not address all identified concerns and shortcomings of this bill.  I do not believe it would be appropriate for me to cobble together amendments to try and meet those concerns, though I hold those concerns; it needs a more significant review and potentially a rewrite.  I draw attention to recent commitments placed on the public record by Government regarding a more comprehensive review of the Environmental Management and Pollution Control Act 1994.   Those statements on the public record include one from the minister from Tuesday 25 October 2022, where the minister said:

As I have noted previously, the Government has flagged an intention to conduct a more comprehensive review of the principal act in due course.

He also said:

We know our act, overall, needs some review, housekeeping and bringing up to date.

Further:

My suggestion for them would be that the full review of the act provides the scope to do that at a point in the future.

Those sentiments appear to be in accordance with what we would have seen in the Tasmanian EDO’s submission to the draft bill, as well as their latest correspondence of 7 November to all members in this place, which stresses that we consider and:

… support EDO’s recommendations for a thorough and independent review of the Environmental Management and Pollution Control Act 1994 to determine whether the act is consistent with best practice in modern environmental regulation.  [TBC]

Given the minister’s recent reiteration, on the public record, of some future intent to undertake the requested review, I have a fairly specific question for the Leader.  Can the Leader provide a firm commitment from the Government on two things:

(1)     confirm that a comprehensive and fully consulted review of the Environmental Management and Pollution Control Act 1994 is to be undertaken within this term of Government;

(2)     confirm whether such a future review will involve further consideration of the independence, purpose, structure and governance of the EPA, no matter the potential passage of this bill, this week, in this place?

I want to hear about those two things in relation to a broader review. 

Mr President, it would be beneficial for our understanding of where and how this – as I have described it – relatively limited revamp of the EPA as set out in the bill before us fits within an overall, longer term legislative reform plan or reform plan that the Government has in this space.

I would also appreciate a description from the Government of where, under the changes proposed in the bill, and this new model for our EPA, are review matters.  Who can appeal any EPA decision under this model?  To whom can they appeal decisions?  Where is that process documented?  I seek clarity about how those mechanisms work under the new arrangements.

As I was looking at this bill, and then referring back to the principal act, I noted – and we have discussed this in relation to another bill today – that there is binary gender language in the principal act; a number of occasions where he/she is mentioned.  It was pleasing to have the commitment from the Government earlier today, to potentially look at making it a matter of course that as we are considering amending primary legislation, we update –

Mrs HISCUTT – For clarity, I made a commitment that I would ask the Premier to have a look at it.

Ms WEBB – Put it to the Premier.  Thank you.  Indeed.  That is as much as you can do, and we appreciated it.  It seems a good idea that it becomes a matter of course, as we are amending existing bills.

Ms Forrest – It could reduce the number of amendments that we put forward.

Ms WEBB – We have amended them in some legislation, but it is messy if we have to do it ourselves.  It would be great to have it built into every process as it comes through.

Mr President, I acknowledge that the Government put this bill out for public consultation and 11 submissions were received.  One of them was a comprehensive submission from the EDO, and I have referred to a number of matters raised in that submission.  As we can see, from correspondence members would have received from them, they remain frustrated that some of their feedback does not appear to have been taken on board, although some minor changes were made in response to it.   

It is worthwhile to have expert external input like that, and for us to continue to inform ourselves from those external sources.  I know that the EDO locally has expertise from staff members who have worked in EPAs in the other jurisdictions, for example, so this was something of particular understanding for them.

To conclude, it is worth noting that the legal separation of the EPA from the department is a positive step forward towards full and effective independence.  I consider there is still some distance to travel on that path.  Further, there are some positive attributes to the bill before us which we can acknowledge as improvements on what had previously been in place. 

However, it would be remiss of us to ignore the detailed and considered feedback from legal professionals who work in that space on a continual basis, as mentioned.  The parameters set by the Government for this reform were fairly narrow and modest.  While I do not agree with the setting of such a limited reform for something that is so long awaited and of such consequence for our state, so critically urgent given the pressures on our natural environment, I can but hope that this legislative confirmation of the legal separation of the EPA from the department is a harbinger of further, timely, comprehensive review and reform down the track. 

On that, I note the bill, and am interested in further discussion should we get to the Committee stage.

 

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