Submissions

ASBG's submission deals firstly with the proposed regulatory changes.  The exhumation ban from landfills could be made more practical by the defining exhumation as >5days in the landfill.  The transport ban is considered anti-recycling from landfill sites and should be omitted.  A major issue is the virtual removal of the courts from waste levy disputes on deduction and rebates, replaced with the EPA being satisfied their position is correct.  ASBG opposes this harsh process which virtually removes the court as a method to resolve disputes.  The Construction and Demolition Standard is dealt with secondly.  Unfortunately it is still an unworkable process to spread and tip every load for inspection in the manner the draft Standard proposes.  Many C&D recycling facilities will simply not be able to comply or have log jams of trucks due to a lack of space for such tip and spread actions.  ASBG proposes a pre-checking process, but this would not solve the unworkable elements, of which there are many of this Standard.

ASBG's submission is on the NSW EPA’s: Draft Waste and Resource Recovery Infrastructure Strategy (Waste Strategy).  Key issues raised include:

  • Better ways to encourage recycling, including new grant programs and use of demand pull approaches
  • Support for waste infrastructure identified is required, such as Energy from Waste and planning support issues
  • Impact of the waste levy and failure to invest in local waste infrastructure and need for future landfill capacities for the Greater Sydney Area , as current landfills are likely to fill faster than forecast.

Download the submission on the link below.

ASBG submission largely provided advice and reasoning recommending the Commonwealth expand and increase funding for its work under the National Waste Policy. Consequently, ASBG provided a list of guidance actions for the Commonwealth to consider to address the issues under the inquiry's terms of reference. Key focuses on recycling, the waste levy and methods to reduce the costs to waste generators was provided.  The bunt instrument of the waste levies were discussed with a position they are too high and can lead to perverse outcomes.  Methods to divert waste from landfill were discussed including bans, levies, contamination threats and international market threats.  ASBG considered demand for recycled products were under supported by Governments and further assistance in this area is required.  There are many other points made to progress better measurement and management of wastes.  However, without the support of the NEPC the National Waste Policy will tend to be a weak influence.

ASBG's submission on the draft PFAS (Per-and Polyfluoroalkyl Substances) National Environmental Management Plan recommended the need for a cost-benefit assessment of its impact, striving to optimise the environmental and health outcomes.  Of concern is the ultra conservative standards used for PFOS and PFOA, which are close to that for dioxin. As the PFAS NEMP will undertake a stocktake of PFASs it should take the next steps of assessing the infrastructure required to manage the waste soils and liquids to be generated.  ASBG is concerned there is simply not enough landfills and destruction facility capacity to manage the quantities that are likely to be generated.  A cost benefit study should consider these requirements and encourage innovation and remove planning approval road blocks.  There are issues with remaining stock of PFAs and how these should be managed especially where there is no replacement.  9 recommendations are made in this submission and quite a bit more work required obtaining a reasonable document.

ASBG's submission focused on the extremely broad application of the EPA's Proposed Minimum Environmental Standards in the Scrap Metal Industry (MSSMF). It is designed to capture any site, licensed or not it could capture service stations to steel refineries.  MSSMF will also set a precedent when it is published for many other industrial sites, both large and small, consequently, its design has considerable implications.  It is also considered too prescriptive, whereas ASBG recommends a performance  and risk based approach in managing environmental issues.  The need for roofing, hardstands and prescriptive bunding should be removed as they are contrary to Australian Standards covering dangerous goods.  There are many other issues and details raised.

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