Documentary Method

Understanding the Record

This page explains the documentary method used throughout the record: identify the governing requirement, determine the role and authority of each source, examine the available evidence, identify any documentary gap, record the question raised and response received, and state the current documentary position without substituting an administrative conclusion for a regulatory finding.

Reading position: The Glossary explains the terms. The Framework identifies the governing instruments and documentary hierarchy. This page explains how those requirements are tested against the available record and how the limits of that record are stated.
Purpose

Why the method matters

The method allows an independent reader to begin with the obligation, distinguish the role of each document, follow the evidence chronologically and see precisely what remains established, disputed or unexplained.

1

Begin with the central question

The Start Here page introduces the central question: whether the available documents demonstrate how the wind farm’s planning, technical and regulatory obligations were addressed.

2

Identify the governing requirement

The Glossary explains defined terms, while the Framework identifies the legal, permit and technical instruments against which later reports and responses are read.

3

Follow the documentary pathway

Issue pages such as K15aa and SAC separate requirements, source documents, documentary gaps, questions, responses and the current position so different evidentiary functions are not conflated.

Hierarchy

The documentary hierarchy

The record follows the governing and evidentiary hierarchy. Each later report, letter or decision is read according to its documentary role and against the instrument or requirement that preceded it.

Locked methodology

How each issue page should be read

Every substantive issue page follows the same six-step sequence. The sequence preserves the distinction between an obligation, evidence said to address it, any remaining documentary gap and the response of the relevant organisation.

1

Requirement

Identify the operative condition, incorporated standard, endorsed method, timing requirement or reporting obligation, using exact source wording where that wording controls the issue.

2

Available evidence

Identify the source documents, technical reports, correspondence, disclosures and decisions that are capable of addressing the requirement, and state the documentary role of each.

3

Documentary gap

Identify what the available record does not establish, reconcile or explain. A documentary gap is stated as a limitation of the available evidence, not automatically as proof of non-compliance.

4

Question raised

Record the precise question put to the operator, consultant, auditor, regulator or other organisation, together with the date and documentary context in which it was raised.

5

Response received

Publish or accurately summarise the response received, distinguishing a substantive answer from acknowledgement, general assurance, referral, partial response or no response.

6

Current documentary position

State what can presently be established from the disclosed record, what remains unresolved and whether any later document has materially changed the position.

Important: The record does not make regulatory, legal or technical findings. It documents the governing requirement, the evidence available to address it, the limits of that evidence and the responses received. The authoritative source remains the relevant permit, standard, endorsed plan, decision or original document.
Verification

Follow the evidence

Documentary verification asks whether an independent reader can follow the required pathway from the governing instrument to the evidence said to satisfy it. It does not treat the existence of a report, approval or assurance as self-proving.

What material carries evidentiary weight?

Relevant material includes planning permits, endorsed plans, incorporated standards, technical reports, monitoring data and summaries, auditor material, agency correspondence, public meeting records, FOI decisions, disclosed emails and dated Trustee records. The weight of each item depends upon what it was created to establish.

Where the available record is incomplete, the page identifies the missing step or unresolved inconsistency in restrained terms. It does not fill the gap through assumption, later recollection or a document prepared for a different purpose.

What the record does not do

The record does not substitute its own conclusion for a regulator, court, environmental auditor or qualified technical decision-maker. It also does not treat silence as admission, a disclosed gap as conclusive proof that no document exists, or a general statement of compliance as a substitute for the underlying documentary pathway.

FOI and agency records

Why Freedom of Information matters

Freedom of Information material helps define the agency record available for examination: what was located, released, withheld, described as not held, or left unresolved through the decision and review process.

Disclosure defines the available record—not the whole factual universe

A disclosed record is the material made available at a particular point in time. A “no documents held” position is relevant evidence about the agency search and custody record, but it is stated according to the decision actually made and is not expanded beyond that documentary effect.

How agency material is reconciled

Agency and FOI material is compared with the governing framework, technical reports and later reliance statements. This can identify where an agency located the document needed to complete a pathway, where it relied upon different material, or where the available response did not identify the instrument, approval or evidence required to explain the issue.

Reading discipline

How documentary statements are expressed

The wording used throughout the record reflects the strength and limits of the underlying evidence.

A

Established by the record

Used where a dated source document directly records the fact, requirement, decision, statement or event described.

B

Not identified in the available record

Used where the disclosed and assembled material does not reveal the document, authority, reconciliation or evidentiary step being examined.

C

Remains unresolved

Used where a question has been raised but the response, disclosure or later material does not presently provide a complete documentary answer.

Interpretive limit: These expressions describe the present documentary position. They do not convert an absence from the available record into a conclusive finding about events or documents outside that record.

Before moving into the evidence

Use this page before moving into the issue records. Where a term is unfamiliar, return to the Glossary. Where an obligation requires context, return to the Framework. Where a proposition matters, follow the cited source and consider the document’s date, purpose, status and place in the governing hierarchy.

Document lineage example

Pre-construction acoustic assessments

The pre-construction acoustic pathway demonstrates how the record reads successive technical documents: identify each document’s purpose and status, preserve its chronology, record later references to it, and distinguish document availability from any conclusion about whether a separate instrument, approval or assessment exists.

Two connected pathways

Technical evidence and agency records

The administrative record can be read through two complementary pathways. The technical pathway follows governing instruments, assessments and verification material. The agency pathway follows the authorities that received, held, relied upon, disclosed or responded to that material.

Technical and evidentiary pathway

Planning Permit, NZS 6808, NCTP, pre-construction assessments, post-construction assessments and Environmental Auditor material.

Government and regulatory pathway

EPA Victoria, DTP, Moorabool Shire Council and AEIC correspondence, reliance records, FOI decisions and current documentary position.