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.

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