This response was to the draft guidelines which were the result of earlier engagement by the EPA which the CWA had contributed to: https://concernedwaterwaysalliance.org/cwa-submission-on-epa-industry-engagement-for-development-proposals/
While the CWA welcomed the intent of EPA Victoria’s draft pre-application engagement guidance and its commitment to early, transparent, and risk-based community engagement, and acknowledged that some of the CWA's initial input had been picked up in the EPA's draft, we've again urged the EPA to expand the scope of engagement beyond the pre-application phase to include post-approval monitoring and long-term accountability—especially for high-risk or long-duration projects that affect waterways. We also recommend increasing notification distances to account for downstream impacts, strengthening requirements for clarity around legal duties, mandating the real-time publication of environmental monitoring data, and prioritising the voices of informed, place-based community groups with deep local knowledge.
https://engage.vic.gov.au/how-should-industry-engage-on-development-proposals