Client: Santos
Skills: Environmental approvals, licence conditions, air quality regulation, benchmarking
Date:  2013

Whilst conditions of approval are an inevitable part of doing business, poorly drafted approval and licence conditions can cause unnecessary regulatory burden with no benefit for the environment.  Santos recently engaged Katestone to review the air conditions contained in one of its approvals.

Katestone’s review identified:

  • Sixteen errors and inconsistencies in the air conditions
  • $400,000 in unnecessary compliance costs for year one and $120,000 per year thereafter

Katestone in collaboration with Santos, developed alternative conditions that were outcomes focused and clear.

Based on Katestone’s review and recommendations, Santos submitted an application to amend conditions to the regulator.  The regulator accepted the proposed amendment, which resulted in the original 39 conditions relating to air being consolidated into 2 conditions. The consolidation of the conditions resulted in better protection for the environment through clear and targeted actions and demonstrable compliance.


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  • Skills ‐ air regulations, emission limits, environmental approvals, licence conditions