Submissions

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.

ASBG's submission on Environmental Impact Assessment Improvement Project asks for a one-stop-shop to deal with the multi-agency oversight, especially from both the Department of Planning and Environment (DPEE) and the Environmental Protection Authority.  Currently many large licensed sites are subjected to a range of audits and inspections by largely these two agencies which has considerable duplication.  Also recommends the recognition of 3rd party audits on Environmental Management Systems if they cover the required scope of the DPEE's independent audits. 

ASBG was invited to comment on SafeWork NSW's Managing Asbestos in or on Soils.  This is a significant document which details how to manage asbestos impacted soils also permitting the leave on site in a safe manner as a main option. ASBG has identified a number of improvements including:

  • Increased flexibility and or guidance for innovative removal processes.
  • Allowing alternative methods for the storage of bulk asbestos waste soil stock piles.
  • Managing asbestos contaminated soils in emergency response situations.
  • Means in which to better identify and manage buried asbestos soils on land into the future.

The submission supports the general thrust of the National Standard process, but warns of the need to use high precision in setting risk levels, but not overly cautious resulting from incomplete assessment.  ASBG raises concerns with the overlap with other environmental standards and documents.  As the National Standard will be setting Australia wide standards, these will be by their nature more conservative than site or use specific assessments.  Case in point is the application of Contaminated Land NEPM investigation levels which are very site specific in their risk assessment processes. Hence, ASBG recommended that that if more surgical such as site and use specific risk assessments are used they can replace the more conservative unilateral limits provided for in the National Standard. ASBG also argued that the benefits of difficult to substitute chemicals be considered and balanced with the environmental risks.  The example of fluoridated compounds for fire fighting foam has far superior performance over fluorine free foams.  However, the risk assessment process targets poly fluoridated compounds regardless of their benefits.  

ASBG proposes that Australian carbon credits and associated energy efficiency credits adopt a Blockchain system for transactions.  There are many advantages in the use of a Blockchain system which are discussed in the document.  Overall its adoption should permit lower cost transactions, high inefficiencies and open the door to encouraging other international carbon units to be linked in a similar manner.  The proposal for a Blockchain approach has been sent to the Federal Minister for the Environment, Mr Greg Hunt for his consideration.  The proposal is below.

The Minister response is below, but in summary states that a legislative change would be required as all settlements of carbon trading must be manages by the Clean Energy Regulator.  Additionally the Government's policy is not to permit international transfer of ACCUs.

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