Members would be aware that the PSA provided its initial response to the proposed Natural Resources Access Regulator (NRAR) Change Management Plan (CMP) on 21 June after receiving a number of submissions from affected and non-affected members.

NRAR has provided a response to the PSA submission on 28 June and PSA representatives met with the Chief Regulatory Officer as well as DPE representatives on Monday 4 July to discuss that response as well as pose several further questions from our membership. To see the full NRAR response click HERE.

The take-away responses to the PSA submission from NRAR are:

1. This isn’t a reduction in compliance and enforcement staff proposed in the CMP, in fact it’s an increase.
2. The work to enable and encourage voluntary compliance continues.
3. The core operational functions of NRAR do not change.
4. NRAR has demonstrated effective delivery of advice and guidance to water users who are challenged by minor non-compliance.
5. NRAR seeks to increase the advisory capacity to ensure successful delivery of the NSW Government’s Water Reform Action Plan.
6. Affected staff will be offered an exclusive right to apply for vacant roles at grade in the new structure.
7. All efforts will be made to place affected staff in a role at level in the new structure.
8. The impacts on regionally based staff are minimal.
9. The likelihood is that NRAR will continue to expand rather than contract in terms of head count.

Further to this, NRAR have also provided responses to the operational based questions, both to individuals and also to the PSA. As always these answers have brought up further questions that will require administration.

What else has the PSA asked for?

• Statistics/trends on investigations/non-investigations of reported non-compliance. Whilst there are mandated reporting non-compliance actions in NRAR legislation, the concern is that the methods for illegal extraction will become more covert and will require complex examination by highly trained and experienced officers. Ball park numbers of public non-compliance reports have diminished from more than 120 per month four years prior to approximately 10-12 per month.
• An understanding of the differences in RDs between affected Team Leaders Investigations and Senior Investigators and the subsequent proposed appointment decisions. HR representatives have highlighted some differences in the role which they maintain, does not allow for a direct comparison. Staff have provided a different opinion citing several previous scenarios on the comparison.
• Some understanding of how future investigations work will be administered and arrangements for work currently being performed by deleted roles.
• A reason why there has been little fanfare from Government on this pivot for NRAR. The CRO did, however, point to announcements made at the time of the State Budget.

Members who have further enquiries in relation to the proposed NRAR CMP can contact PSA Industrial Officer Shane Howes at .