Risk analysis and management

The following table provides a high level risk assessment related to implementation and operation of the Framework consistent with option three.

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Risk Management

Inability to engage appropriate decision making body and confirm implementation of the Framework

Consultation with the view of partnership with stakeholders in state and territories to assist with engagement and representation with decision making body.

Ongoing confusion regarding the scope or operation of the Framework

Develop clear presentation materials explaining the scope and operation of the Framework.

Present the results of the final business case to key stakeholders, along with detail of the cost recovery model.

Produce clear briefing material for stakeholders, including material suitable for Ministerial briefing.

Cannot find an appropriate home for the Framework administration functions

Consultation with potential Framework administration hosts to determine their expectations, requirements and resources. Ensure effective and collaborative engagement with DSEWPaC throughout development of next steps.

Consider feasibility of alternative hosts for administration functions, including:

 State or territory agencies or regulators

 Standalone organisation

 Standards Australia

 National Water Commission

 National Health and Medical Research Council

 Australian Water Recycling Centre of Excellence

 Bureau of Meteorology

 Department of Health and Ageing Start-up funds are difficult

to secure

Clearly articulate the benefits of the framework including outcomes of the business case to potential funding bodies.

Discuss potential for contributions to start-up funding with states and territories.

Discuss the possibility of seed funding with the Australian Water Recycling Centre of Excellence.

Develop detailed implementation plan, including development of a cost-sharing model, which details the fee structure, the service or product being provided to participants, estimates of revenue from validations, and estimates of cash and in-kind resources required from states.

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Risk Management

Inability to agree on validation protocols

Establish clear roles and responsibilities for the RSG. Including terms of reference, membership commitments and governance

arrangements.

Governance arrangements for RSG should include process for determining validation protocols, including management of divergent view and disagreements.

Ensure the RSG has sufficient resourcing. Cost sharing or cost-

recovery model cannot be agreed

Develop detailed implementation plan, including development of a cost-sharing model that has industry and government support before putting to decision making body.

Undertake consultation during development of the model. Engage a third party to assist with facilitation, advocacy consultation and/or negotiation.

Perception by proponents that existing schemes were approved under more (or less) conservative protocols prior to Framework

implementation

Develop detailed implementation plan with consultation with states and territories, and existing scheme proponents.

Ensure all stakeholders are actively involved in the RSG. Encourage jurisdictions to incorporate 5 or 10 year reviews of existing approvals into their validation requirements.

Perception that a national Framework removes ability of states and territories to regulate schemes

effectively

Ensure states and territories are engaged regarding implementation and the scope of the Framework.

Ensure states and territories understand that they will continue to maintain regulatory responsibility for total recycled water scheme and water treatment system approvals.

Risk that staff working on Framework administration do not have sufficient subject matter expertise, and/or transience of staff impacts on framework delivery.

Place the framework administration role in an organisation with some familiarity with water quality issues.

Ensure the administration and governance arrangements are robust, and functions are well defined so that they can be maintained even in the presence of transience.

Ensure the RSG are responsible for making decisions related to technical matters and protocol development is outsourced where necessary.

Develop an effective business plan to manage these issues. Machinery of Government

changes impact on implementation of the Framework

Ensure adequate planning is put in place, including realistically estimating required timeframes.

Ensure briefing materials are effective and clearly demonstrate the benefits of the Framework, and the timeframes and path critical elements for implementation.

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Risk Management

The Water Thematic Oversight Group does not support implementation

Undertake additional advocacy consultation to present the results of the business case to WTOG representatives and gain a better understanding of any concerns or needs they may have in relation to implementation.

Develop Q&A’s and back pocket brief for WTOG and DSEWPaC around potential points of risk or concern.

Resources not available to complete detailed

implementation work

Discuss the potential for funding with the Centre.

Discuss with states and territories and the Commonwealth. Discuss with industry representative bodies.

The RSG are insufficiently resourced to develop protocols in a timely fashion

Undertake detailed implementation planning including developing cost-sharing or recovery models that can sufficiently resource protocol development.

Develop priorities for protocols based on needs of states and territories and projections for future validation demand.

Prioritise protocols for accepting existing validations (eg those done overseas) which may take less time and resources to review and implement.

Existing and large scale technology providers may gain a ‘first-movers’ advantage on the national database

Under existing arrangements there is already an entrenched advantage for validated technologies.

With implementation of the Framework and an efficient and equitable cost-recovery model, competition will increase due to decreased validation costs.

A detailed implementation plan should however address the specifics of the cost-recovery model to ensure it is not discriminatory or anti-competitive.

Flood of applications to place technologies on the database swamps the framework administrator and results in delays or other problems

Prepare detailed implementation plan that addresses this issue. Include staged implementation, such as ordering groups or types of technologies that will be placed on the database over time.

Communicate these plans to stakeholders and industry.

RSG does not result in the ‘right’ membership – ie people with the right technical expertise.

Ensure a collaborative and consultative approach to developing the detailed implementation plan, and the terms of reference and membership of the RSG.

Ensure consultations with existing experts on validation in states and territories and consult the project steering committee and the Centre.

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