Submissions
ASBG has written to the Ombudsman in relation to a Freedom of Information (FOI) request to release Sydney Water's top 50 water users and their consumption going back some 8 years.
In response ASBG pointed out the significant general improvements made in the efficiency of water in the Sydney region, which was collectively as a result of action by industry, grant programs such as Sydney Water's Every Drop Counts program and other government initiatives such as Water Action Savings Plans.
Hence the issue is not the performance of industry in general, but the impact competitors and competing nations could do to Sydney's businesses. The need for confidentiality of resource use data has many justifications including:
- Competitors assessing the production levels of a site for future planning and obtaining additional market share.
- Competitors ascertaining product formulations, recipes, costs and other proprietary information.
- Competitors identifying sensitive resources and entering into price wars during times of supply shortage.
- Countries assessing, by the release of such data, that a local company has been provided with a form of government assistance, thereby launching international court challenges which can lead to trade barriers being established.
 ASBG's Letter on the release of top water users | 104 kB |
ASBG is running a campaign on streamlining the way in which environmental data is supplied to government under reguatlory obligations.
One of the main complaints from environmental managers have is the load of environmental reporting they are required to submit each year. Such reporting is also heavily weighted to the September - December timeframe, permitting little time left for environmental managers to undertake their primary role of environmental improvement.
Members are complain of the level of duplication, inconsistent data, and non-standaisation of report frameworks as well as non-recognition of other reporting systems. In addtion, is the inability of other agencies to access some eachothers' databases.
ASBG recommends the streamlining of the environmental reporting systems to:
- Cut duplication, via standarisation of measurment and data collation with flexibility
- Use of centralised databases for: Emissions - use the National Pollutant Inventory (NPI); Greenhosue - use OSCAR
- Accept cross recognition of other agencies' reproting systems such as EEO reports exempts the need for an Energy Savings Plan to be submitted
- Development of other national databases for waste and perhaps water as well.
ASBG is involved with the Queensland Department of Environment and Resoruce Management in their program to reduce greentape. Attached is ASBG's letter in response DERM's inviation to pursue greentape reduction in Queensland.
| Reducing Greentape in Queensland 2010 | 84 kB |
ASBG’s response to DECCW on the State of the Environment’s claim that:
NOx emissions from industry in Sydney, which increased 49% (6876 tonnes), [2003-2008]
ASBG argues this statement is misleading as it is derived from different data sets, one hard, site data from the 2003 MAQS. The other is an extrapolation of the 2003 data to estimate 2008 emissions.
ASBG also argues the 15% NOx drop and the 23% VOC drop from motor vehicles is inaccurate and contrary to other estimations.
See DECCW's response below.
| ASBG's Response to the SoE's missleading statements | 266 kB |
| DECCW's Response to ASBG's letter | 738 kB |
ASBG Submission On the Water and Energy Savings Plans
ASBG recommended that increased flexibility be the main amendments to the new Water and Energy Savings Plans that applies to site that use over 50 ML/year and 10 GWhrs/year of energy at stationary sources. These plans will over time apply to smaller sites and require many companies to commit to savings targets on water and energy consumption. ASBG identified many reasons to keep the process flexible due to large variations between industries and regulatory impediments to such savings.
| Submission On the Water and Energy Savings Plans | 87 kB |
ASBG comments focused on the generic definitions of class 3 flammable liquids, class 8 corrosives and class 9 miscellaneous. ASBG called for simpler means in which to assign a UN NOS number to a waste. Under current ADG Code requirements any substance must have the tests undertaken before a UN NOS number can be assigned. This is extremely difficult when managing wastes, especially hazardous wastes. A number of minor changes were also recommended largely dealing with hot liquids such as bitumen.
| Submission On the 7th Edition Australian Dangerous Goods Code | 72 kB |
