Submissions

ASBG's submission on the NSW Government's proposed Container Deposit Scheme (CDS) discusses the costs and impacts of such a scheme.  If a CDS is implemented it will be necessary to assist kerbside recycling from a new competitive market force.  Careful design and operation of the CDS is required with preference given to a 3rd party operative with controls on it.  See the full submission below.

The Draft Industrial Noise Guidelines (ING) are an upgrade of the current Industrial Noise Policy in which ASBG had considerable input in 2000. The ING changes represent generally a welcome set of more flexible arrangements on the INP. ASBG called for better descriptions of the way the ING will operate due to poor understanding and miss-understanding of noise pollution measurement and control. There were a few other recommended changes, which can be viewed in our submission, downloadable below.

ASBG responded to the proposed reforms to NSW's Environmentally Hazardous Chemicals legislation. Support was given for the majority of the reforms. However, there are issues with the timing of the reviews of the Chemical Control Orders (CCO), when very out dated national waste management plans still exist. ASBG recommended the NSW law look to our ratified conventions, including the Stockholm Convention when reviewing the CCOs. Click below for the full submission.

ASBG was invited to comment on the draft EPA’s Licensing Guidelines: Environmental Risk Levels, an unreleased document. This document was asked for by ASBG for the EPA to prepare. Put simply it is a a document to reward low risk level licence holders by the use of more self regulation on the Environment Protection Licences (EPL). Overall the guidelines are a reasonable attempt to assist low risk licence holders, but could have provided more flexibility especially in monitoring conditions for these licence holders. Also attached is the published EPA ERL Guidelines.

ASBG's submission to the Government's UNFCCC’s Taskforce on the post 2020 greenhouse emissions target key include:

  • A carbon price using market mechanisms based on either cap-and-trade or base-line-and-credit is required
  • The carbon price should follow Australia's main trading partners and its international position
  • International carbon credit trading be open and free
  • Other issues covered include, taxation, transitional arrangements, baseline, target length and assistance to energy intensive trade exposed industries

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