Submissions

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.

ASBG comments on the EPA's Illegal Dumping Strategy included:

  • The Strategy avoided discussing high costs of disposal as a main cause of  illegal dumping.  High gate fees are generally the result of the waste levy and tight regulatory controls, which could be lowered.
  • Better enforcement is required but there are gaps in the Regional Illegal Dumping Squads areas across NSW, especially in the greater Sydney area.
  • Illegal dumping was poorly defined with the Strategy limited to only publically accessible land, ignoring private lands and other illegal disposals.
  • Victims of illegal dumping are often required to pay for cleanup costs, of which there is no victim support, for individuals and for businesses.

 

This submission was lodged to Queensland Treasury, which proposes its own Tailored Solution with two surety funds to cover the risks of existing and future mines rehabilitation should a mine become insolvent or similar.  In effect, Queensland Treasury is to become the Financial Assurance 'underwriter', but based on the $167m fund.  ASBG commented that this approach for mines would not fit with other industry sectors for a number of reasons.  Also the US Superfund is an example of what issues can arise when government takes on contaminated land risk, has many lessons to learn from.  ASBG offers a number of improvement areas for consideration.

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