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What Are the Penalties for Polluting?

Up to K250,000 for a company causing serious environmental harm, and up to five years’ imprisonment for an individual. No intention has to be proved — and a continuing breach adds a further penalty for every day it lasts.

The environment law series, no. 23 · Enforcement, orders and offences · 6 min read

The Environment Act 2000 carries the heaviest financial penalties of any Papua New Guinean statute covered on this site. This article collects them.

The harm offences

Offences of causing environmental harm
SectionOffenceCorporationOther personDefault
11Unlawfully causing serious environmental harmK250,000K125,000 or 5 years, or bothK15,000
12Unlawfully causing material environmental harmK100,000K50,000 or 2 years, or bothK5,000
13Unlawfully causing environmental harm by noise, dust, odour, electro-magnetism or litter, or an unhealthy, offensive or unsightly condition from a contaminantK20,000K2,000
8(2)Failing to notify the Director of unlawful serious or material harmK100,000K50,000 or 2 years, or both

The tiers are set by the definitions of environmental harm: material harm at loss or damage of K10,000 to K100,000, and serious harm above K100,000 or where the detriment is irreversible, high-impact or widespread.

Permit and activity offences

Permit-related offences
SectionOffenceCorporationOther person
44(1)Carrying out a level 2 or 3 activity without a permit, or a change or expansion that becomes oneK100,000K50,000 or 2 years
44(4)Interfering with a right conferred by a permit or with the holderK50,000 or 1 year, or both
45(4)Failing to apply for a permit after a noticeK20,000K10,000
49Carrying out preparatory work without registering the intentionK20,000K10,000
73(1)Carrying out an activity while a permit is suspended or cancelledK250,000K125,000 or 5 years
73(2)Breaching a permit conditionK100,000K50,000 or 2 years

Orders, directions and information

Offences relating to orders and information
SectionOffenceCorporationOther person
102Failing to comply with an Environment Protection OrderK250,000K125,000 or 5 years
104Failing to comply with a Clean-up OrderK250,000K125,000 or 5 years
107Failing to comply with an Emergency DirectionK100,000K50,000 or 2 years
108(4)Failing to comply with a notice requiring informationK100,000K50,000 or 2 years
114Knowingly giving false or misleading information in a material particularK100,000K50,000 or 2 years
110Interfering with monitoring equipmentK50,000 or 2 years, or both
115General penalty where no specific penalty is providedK50,000
Section 114 is very wide

It covers false or misleading information in a permit application; an application to vary, amend, renew, transfer or surrender; any report or information required under the Act, a Policy, the Regulation or a permit; an inception report or environmental impact statement; a submission or representation in public review; a submission to the Council; an application to approve an environmental improvement plan; an environmental audit or investigation; and a representation as to why a permit should not be cancelled.

It applies to any person — including someone making a submission during public review, not only the proponent.

Water and other offences

Water-related and other offences
SectionOffenceMaximum
80(2)Permanent installation by a person taking water under the public rightK50,000 / K25,000 or 1 year
81(3)Taking more water than the quantity specified in the Director’s noticeK50,000 / K25,000 or 1 year
81(5)Building works obstructing the flow of a watercourse or lakeK100,000 / K50,000 or 2 years
87(14)Failing to pay compensation within the time determinedK100,000 / K50,000 or 2 years
88(2)Obstructing a person authorised to carry out an official investigationK25,000 or 1 year
95(4)Contravening a drought noticeK50,000 / K25,000 or 1 year

Section 117 — no intention need be proved

Section 117

Subject to any express provision to the contrary, it shall not be necessary to prove any intention or other state of mind in order to establish the commission of an offence against this Act.

Sections 11(2), 12(2) and 13(2) say the same thing for the harm offences specifically. The exceptions are the offences that use the word “knowingly” — section 114 (false information) and section 78(g) (knowingly causing a contaminant to enter water).

Section 116 — continuing offences

Section 116

Where an offence is committed by reason of a continuing act or omission, the person is liable to:

(a) the penalty provided for that offence; and

(b) an additional penalty for each day on which the act or omission continues — the amount provided for that offence, or, where none is provided, up to one-fifth of the maximum penalty for each day.

This is where the numbers become very large. A corporation in continuing breach of an Environment Protection Order faces the K250,000 maximum plus a daily default penalty of K15,000 for as long as the breach lasts.

The defences, and their notice requirements

  • Section 10(2) — the act was lawful and the person complied with the general environmental duty. Written notice of intention to rely on it must be given to the Director at least 14 days before the hearing, or the defence is not permitted (s 112).
  • Section 111 — the action occurred in an emergency to prevent danger to life or limb not arising from the person’s own negligence, and the Director was notified in writing as soon as reasonably practicable. Notice of intention to rely must be given within seven days of service of the proceedings.
  • Section 113 — a permit holder is not liable to a penalty where he proves compliance with the permit conditions, or with a Protection Order, Clean-up Order or Emergency Direction relating to the acts charged.

What a court can order beyond the fine

  • Section 105 — the Director may do the clean-up work and recover the reasonable costs as a civil debt, with interest after 28 days. There is no cap on this.
  • Section 128forfeiture of items on conviction.
  • Section 129damages and recovery of costs on conviction.
  • Section 130 — the court may order action to minimise environmental harm.
  • Section 126liability of corporate officers.
  • Section 72suspension or cancellation of the permit, for which a conviction is itself a ground.
The fine is rarely the biggest number

For a significant incident the real exposure is the combination of uncapped clean-up cost recovery under section 105, daily additional penalties under section 116, compensation under section 87, and the loss of the permit under section 72.

Who prosecutes

Under section 16(1)(e) the Director may enforce the Act, including permit conditions, and institute proceedings for breach. Section 124 governs the institution of proceedings, section 125 service, and section 127 evidence — including the evidentiary use of analysts’ certificates and records. See how prosecutions are brought.

Sources

Check the section yourself

Before relying on anything here, read the current text of the Environment Act 2000 and check for later amendments. If a decision matters to you, get advice — start with the Office of the Public Solicitor, or find a firm in the law firms directory.

Disclaimer: This article provides general information about Papua New Guinea law and does not constitute legal advice. Laws may change, and their application depends on individual circumstances. You should obtain professional legal advice for your specific situation. Read the full disclaimer.