Submission to the Department of Water and Environmental Regulation on implementing Part IV cost recovery

WA is well-known as a stable and attractive place to invest and operate compared to competing jurisdictions with similar mineral and energy resources. As a predominately export-based economy that cannot set the price for its products, a critical element for attracting and maintaining investment is a stable cost of doing business across the life of a project.

The quantum of costs for Part IV assessments under the proposed model are orders of magnitude greater than comparative cost recovery pricing models. For example, assessment costs for approvals under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) exist in the average range of $20,000 to $50,000 – ten (10) times less than costs proposed to be recovered for Part IV approvals. While it is acknowledged that these assessment processes do differ, some elements and assessments from both schemes are comparable given indicative order of magnitude cost for delivery of government services. The proposed Part IV costs are drastically higher and are not reflective of cost recovery for proportional effort.