Good point however this is untrue.
The procedures manual was first published December 13, 2016, and was revised on 30 March 2020 due to
'In the current version (3.0), section 1.2.1 and 3.1.2.2 adds the relevant procedures for the Index of Marine Surveys for Assessments requirements, and the new Index of Biodiversity for Assessments Submission Portal process. Section 1.2.1, 3.1.1.1, 3.1.2.2, 3.1.4, and 4.2.3.2 have been updated to reflect the updated Guidance for Mine Closure process and requirements, and section 3.1.1.1 and 3.1.2.2 have been updated to reflect the requirement that proposals in the Pilbara IBRA Region, the EPA may require preparation of an Impact Reconciliation Procedure.'
https://www.epa.wa.gov.au/procedures-manual
Additionally they would have had to disclose the extended timelines in the document due to COVID however theres no mention of that
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