This body matters to the database out of proportion to how often it appears. It is rarely the first approval a project needs and almost never the last, but where it is triggered it commonly becomes the longest single step in the chain -- and, unusually, it is a step running on a clock the state process cannot see and does not coordinate with.

Two structural features are worth recording separately from any argument about whether the assessment itself is worthwhile.

First, the statutory clocks are expressed in business days and stop whenever the department requests further information. A twenty business day decision is about a calendar month at best, and considerably longer whenever the clock is stopped. Statutory time and elapsed time are not the same quantity here, and only elapsed time is what a proponent experiences.

Second, the department has been audited on timeliness. The Auditor-General found in 2020 that administration of referrals, assessments and approvals was not effective, and that statutory timeframes were met in 19 per cent of cases in the fourth quarter of 2019. Reported performance after subsequent funding was substantially better, at 87 per cent. That range -- 19 per cent to 87 per cent on the same statutory clock, with the law unchanged -- is the strongest evidence in this database that a large share of approval delay is a resourcing and queueing question rather than a legislative one.

Anyone proposing to fix environmental approval delay by amending the Act has to explain that range first.