The sharpest gap between a legislated clock and a published expectation in this database.

Section 19 of the Environment Protection (Sea Dumping) Act 1981 provides that the Minister must grant or refuse to grant a permit within 90 days after the application is made. The department that administers it advises applicants that applications may take over 12 months to assess depending on complexity, and to plan well in advance of when the activity is proposed.

Neither statement is wrong. The section itself provides for a longer period where the EPBC Act assessment provisions apply, and the clock in practice runs from a complete application. This site has recorded the same mechanism in rail accreditation, where ONRSR's six months may be formally re-set, and throughout the environmental approvals work.

The problem is what a proponent is left with. A dredging campaign is seasonally constrained, involves chartered vessels booked far ahead, and sits on the critical path of a port project. The planner has a number in an Act that is four times shorter than the department's own expectation, a qualitative warning about complexity, and no published distribution of actual outcomes at all.

That is not a fast process or a slow process. It is an unplannable one, and unplannability has its own cost — contingency, sequencing decisions made on guesses, and campaigns scheduled to the pessimistic case.

What should change, and none of it requires amending the Act:

1. Publish elapsed times for sea dumping permits — median and 90th percentile, by permit type, distinguishing capital dredging from maintenance dredging, and distinguishing time on the department from time waiting on the applicant.
2. Publish stop-the-clock events. If the 90 days is routinely extended by the EPBC interaction or by requests for further information, say how often and for how long. A statutory period that is nearly always extended should be visible as such.
3. Then consider whether 90 days is the right number. A statutory timeframe that is met by extension rather than by performance is not doing the work a statutory timeframe is for. It may be that the honest figure is longer — and a realistic published clock is worth more to a proponent than an aspirational one.

Zero days saved, and that is the point. This is the ninth proposal on this site that saves no time and makes something visible, and the pattern has held every time: the domains where delivery improved are the domains where somebody first published a number.

Who acts: the Commonwealth, on its own data, without legislation.