Submissions

ASBG's submission splits the EPA's Proposed Risk Based Environmental Regulatory Framework into the increase of administrative fees and the Risk Assessment Process (RAP).  ASBG calls to minimise the increase in fees due to the current economic circumstances faced by most Licence holders, especially manufactures. On the RAP ASBG makes 6 recommendations calling for:

  • More than the 3 risk ranks proposed especially for larger sites
  • Consultation on the RAP tool and the overall process before the RIS is prepared
  • A negotiation and dispute resolution process for the RAP tool outcomes
  • Clarity on the impact on licence conditions for risk rankings ranging from more self regulation to increased inspections and conditions
  • Concerns over the Operator Performance Multiplier, recommending an additive approach rather than a multiplier.
TThe EfW Policy preparation was an achievement in itself given the prior opposition to it in the past. Consequently, the EfW Policy still has a way to go. ASBG finds it in contradiction to the WAR Act's waste hierarchy due to the gold plating of the environmental conditions, beyond world's best practice and the requirement for resource recovery to be undertaken upstream before being acceptable in the EfW facility. This is particularly concerning as landfills, EfW's main competitor, has no such conditions nor gold plating yet sits lower in the waste hierarchy.

ASBG submission on the EPA's Requirements for Publication of Pollution Monitoring Data is split into two main areas.  Firstly is the strong message ASBG's members wish to send to the NSW Government that the scheme be wound back to only include exceedences of monitoring limits with explanations when these occur.  The second part lists issues with the Requirements details such as use of other electronic formats other than Word or Excel, the removal of date of data obtained and date published, use of monthly data ranges and other issues affecting Environment Protection Licence holders.

ASBG prepared a submission for the Independent Pricing and Regulatory Tribunal (IPART) Review of Licensing in NSW.  A key focus is on Environment Protection Licences (EPL) and ways and means in which to improve their efficiency.  Some of the recommendations included:

  • Use of a risk index approach which is publically available and calculable to categorise licences in to various levels and set monitoring and licensing frequencies.
  • Adopt the Victorian Corporate licence system or similar to improve the administration efficiency for multiple sites operated under one entity.
  • Reveiw add-on ad hoc addtional requirements to EPL holders to remove excessive red tape.
  • Incorporation of the Environmentally Hazardous Chemicals Act 1985 licence componants into the Protection of the Environment Operations Act licenses.

The submission provides an number of detailed discussions and examples of red tape in environmental and related licensing.

ASBG has prepared a list of ideas to improve the efficiency of environmental regulation in NSW.  It contains 11 key points focusing on a range of issues including improving the consultative process which has deteriorated and the relationship between businesses and the regulator in forming better regulation which achieves higher environmental outcomes in a more efficient and lower cost manner. There are many more issues covered.

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