Management plan content guideline

Executive summary of update

This update formalises the Management Plan Guideline, transforming it from raw text into a structured, legally referenced document. The most critical changes include a significant increase in prescriptive detail regarding financial security calculations (Section 8.11**), work health and safety (WHS) obligations (Section 8.7), and emergency management (Section 8.13). The primary intent is to clarify regulatory expectations and standardise submissions by aligning them with international standards like AS/ISO 31000:2018. The most significant practical consequence is the introduction of **Appendix 1, which provides a detailed content checklist for early-stage activities (e.g., metocean and geotechnical surveys). This new appendix establishes a much higher, non-negotiable standard for the content and structure of our initial management plans, requiring immediate updates to our internal templates and processes.

Impacted parties

This update significantly impacts all teams involved in the preparation and execution of management plans, particularly Project Management, Health Safety and Environment (HSE), Finance, and Legal, who are responsible for implementing the new, more prescriptive requirements.

Change Analysis

Reference (Previous vs. Update)	Change Description	Impact Assessment & Rationale
Overall Document Structure*	The guideline has been completely restructured from a plain text document into a formal regulatory guideline. New elements include a document number, a detailed table of contents, numbered sections, footnotes with specific legislative citations, and illustrative figures.	*High Impact. The formal structure increases the document’s legal weight and usability. The direct citations provide clarity on the source of obligations, removing ambiguity. Our internal documents must now mirror this level of professionalism and referencing to be considered compliant.
Section 8.11 vs. Section 8.11**	The section on financial security requirements is significantly expanded. The update provides explicit guidance on the calculation method, requiring a bottom-up costing approach that assumes the Commonwealth undertakes the work. It also introduces a requirement for independent third-party verification and provides a specific DCCEEW contact for administrative processing.	**High Impact. Our previous methodology for calculating financial security may no longer be compliant. We must now account for the “higher cost to the Commonwealth” principle and factor in third-party verification costs and timelines. This will likely increase the calculated security amount and requires immediate review by the Finance and Legal teams.
Section 8.7 vs. Section 8.7*	The guidance on Work Health and Safety (WHS) has been clarified. The update includes a direct quote from Section 226 of the OEI Act to define ‘regulated offshore activities’ and adds a diagram (Figure 3) illustrating the worksite arrangements and the interfaces between the licence holder and other PCBUs.	*Medium Impact. This provides much-needed clarity on the application of the applied WHS provisions, especially concerning contractors and vessel-based work. It reinforces the licence holder’s role in coordinating WHS across all worksites. Our WHS management system descriptions must now explicitly address these interface arrangements.
N/A vs. Appendix 1**	Appendix 1 is a new addition. It provides a detailed table outlining the specific content requirements for management plans covering early-stage activities, such as metocean and geotechnical surveys. It acts as a prescriptive checklist, referencing specific regulations for each content requirement.	**High Impact. This is the most significant practical change. The appendix provides a clear, non-negotiable “roadmap” for early-stage management plan approvals. It reduces ambiguity but also removes flexibility. Our templates for these early-stage plans must be immediately updated to align perfectly with this new structure to avoid submission delays or rejection.

Corrective and preventive actions

Project Management

• Appendix 1:** Immediately update all existing management plan templates, particularly for feasibility and early-stage activities, to align with the new structure and content requirements outlined in **Appendix 1.
• Section 7.3 & 8.1: Revise project scheduling procedures to ensure the ‘timetable for licence activities’ submitted in management plans has sufficient, justifiable flexibility as guided by the update.
• Section 9.2:* Update project milestone trackers to include mandatory notifications to the OIR 30 days prior to commencement and 30 days after completion of activities, as specified in **Regulation 80(2)*.

Health Safety and Environment (HSE)

• Section 8.7:* Review and update the WHS section of the management plan template to explicitly describe the interface management between Simpoli (as PCBU) and all contractors, referencing the model shown in *Figure 3.
• Section 8.13: Review the Emergency Response Plan (ERP) framework to ensure it explicitly addresses the analysis of vessel-based emergencies and interfaces with maritime ERPs, as now required.
• Section 8.13: Develop and schedule a programme of ERP tests and drills that meets the enhanced expectations for monitoring, testing, and demonstrating effectiveness described in the update.

Finance

• Section 8.11: Immediately commission a review of our current financial security calculation methodology to ensure it aligns with the new requirement to calculate the “greatest reasonably credible costs… incurred by the Commonwealth”.
• Section 8.11: Develop a process for engaging and managing independent third-party verifiers for our calculation methods, including this step in project budgeting and timelines.
• Appendix 1: Work with the Project Management team to ensure cost estimates for decommissioning and removal of early-stage equipment (e.g., FLIDAR) are robust and verifiable for inclusion in financial security calculations.

Legal

• Section 8.11:** Review all proposed forms of financial security to ensure they remain compliant with the detailed guidance in **Regulations 109 and 110.
• Overall: Update the internal compliance register to incorporate all specific legislative articles and regulations cited in the new footnotes throughout the guideline.
• Section 10:* Create a standard template for the ‘Management Plan Summary’ that includes all mandatory items listed in *Regulation 77 to ensure timely and compliant submission post-approval.

Government & Regulatory Affairs

• Section 8.2:** Ensure all future consultation reports explicitly address the merit of claims and the effectiveness of adopted measures, as detailed in **Regulation 81(3).
• Section 10:** Establish a process to ensure the public-facing management plan summary is prepared and submitted to the OIR within 30 days of management plan approval, as required by **Regulation 76.

Risks & opportunities assessment

Risks

• Compliance Risk:** The increased level of prescription, especially in Appendix 1 and **Section 8.11, significantly raises the risk of non-compliant submissions if our internal templates, calculation models, and procedures are not updated immediately. The guideline leaves less room for interpretation, making omissions more likely to result in rejection.
• Financial Risk: The revised methodology for calculating financial security, which must be based on the higher costs the Commonwealth would incur, will likely lead to a material increase in the required security amounts, impacting project budgets and financial planning.

Opportunities

• Approval Efficiency:** The new, clear structure and the **Appendix 1 checklist provide a definitive roadmap for creating an approvable management plan for early-stage activities. By aligning our submissions precisely with this guidance, we can potentially streamline the OIR’s assessment process, leading to faster approvals and greater certainty in project timelines.
• Competitive Advantage: By rapidly adopting this best-practice standard, we can demonstrate regulatory maturity and diligence to the OIR, strengthening our reputation and relationship with the regulator.