Submissions

ASBG raised three main issues with the draft National Environment Protection (Ambient Air Quality) Measure (NEPM)

  • ASBG questioned the wisdom of having the tightest world limits especially its impact on future planning requirements for industrial sites.
  • Use of the no threshold linear health response model ignores the hormesis principle whereby low concentrations can have beneficial health benefits. A paper by the US NIH called into question the much higher US PM2.5 levels as a significant number of US cities showed beneficial health outcomes. The hormesis principle points to an optimal PM2.5 level, rather than continual tightening.
  • Contextual information needs to be better communicated with exceedences especially when natural events dominate these.

Click on the link below to read the full submission.

New onerous controls and conditions are proposed for licensed sites that are waste facilities, including recycling, storage and processing of wastes. This captures many unintended licensed sites with recycling as a small activity. ASBG main recommendation is for a flexibility arrangement whereby sections of the regulation can be exempted from certain licences, and if necessary includes alternative licence conditions. There are many complex issues with the proposed Regulation ranging from asbestos to weighbridge requirements.

ASBG considers the Protocol for the management of asbestos found in C&D recycling facilities, in its current form, to be economically unworkable for the sector. Use of a more flexible and efficient Protocol can provide a basis for a NSW C&D sector wide approach to managing asbestos. The submission provides recommendations on improving the practicality of the Protocol, with an emphasis on further consultation with the C&D recyclers. It is important to prepare a workable document as this Protocol is likely to be the basis for similar documents. An efficient and pragmatic asbestos management process is required to assist in the removal and proper disposal of the material from NSW communities. The full submission is downloadable below.

ASBG has responded to the POEO Amendment Bill 2014 calling for further clarification of the legal term in s128 'practicable means as may be necessary to prevent or minimise air pollution' on non-point sources. Clarification of the meaning of an odour pollution incident which exceeds the material harm threshold is also asked for. ASBG indicated its willingness to participate in developing further guidance on these issues.

The EPA responded to ASBG's letter (see below), indicating that it was a clarification of existing powers and that odour is not an indication of a new focus of control.

The Australian Sustainable Business Group (ASBG) has responded to the EPA's Draft The Liquid Food Waste Exemption 2011. ASBG is concerned this second draft Liquid Food Waste Resource Recovery Exemption still retains very conservative requirements such as buffer zones for application on farm land. While some improvements have been made over the initial draft, the current draft would still prevent much of Sydney basins' farmland being able to re-use this organic waste stream.

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