ASBG's submission raises concerns regarding the proposed massive LBL fee increases and calls for such fees to remain the same for existing payers. Use of a abatement-cost-of-damage approach projects fees to increase substantially for certain pollutants, such as 600% for PM. Many proposed changes under LBL are considered and recommendations provided on a range of LBL settings.  ASBG supports the use of green-offsets, but finds the proposed recycling of LBL fees a start, but without details suspect of its ability to assist LBL fee paying members.  This is a substantial submission with many issues covered.  Download the full version attached below.

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