The PSA has provided its initial response to the NRAR Change Management Plan.  The PSA would like to take this opportunity to thank those members who have provided vital assistance in the detailed preparation of our response despite the communication failures.

What’s in the Submission?

The basis of the PSA submission is that NRAR should think twice about cannibalising compliance and enforcement roles to undertake the questionable reform. The concern is that this is the NSW Government applying a soft touch once again and that community attitudes towards the previous mismanagement of water allocation and extraction haven’t simply changed because the dams are full and the spectre of regional towns running out of water has abated.

For the time being, there has been no metrics provided by NRAR on the numbers or trends of prosecutions, investigations and enforceable undertakings that would predicate the re-allocation of enforcement and compliance resources.

Where to from Here?

The PSA has sought NRAR to review several aspects of its proposed reform including:

1. The proposal to delete Compliance and Regulatory roles in both East and West Regions.
2. The provision of the statistical analysis on the reduced enforcement and compliance need to justify the wholesale reduction of enforcement and compliance resources.
3. The reviewing of the role descriptions of affected staff in the NRAR reform and modification (if required) to accommodate more opportunity for direct appointments to current similar vacant roles.
4. The use of the current vacant roles for the processes of reform instead of cannibalising enforcement and compliance roles.
5. Whether the provision of such support to industry fits within the NRAR remit and if those resources are already undertaken and whether those interactions are best placed outside of NRAR in the agencies that were tasked with those responsibilities by this Government.
6. To consider this reform to be of a sufficient nature that would require the limited advertising based upon the number of affected staff with the potential to become excess.
7. To re-consider the organisation reform as to reduce or eliminate the negative aspects associated to the loss of regional roles.
8. To consider the timelines for the completion of such reform in order for proper levels of consultation on major reform to take place.

The PSA has been contacted by a number of interested third parties seeking commentary from the PSA on the proposed reform.  The PSA will update the membership on our further discussions with NRAR and the answers to the operational questions posed by the membership.

If members have further questions or comments they wish to make, they can be addressed to PSA Industrial Officer Shane Howes .