Submissions
Preparation of Queensland’s EfWP is a golden opportunity for Queensland not to go down the narrow path that NSW EPA has with its EfW. ASBG’s submission was largely about avoiding a one rule fits all approach and permit flexibility in its EfW. Multiple examples are provided where and MSW style EfW rule set would prevent many innovative and alternative EfW projects getting started. Manufacturing can often use fuel/raw material additives in thermal process, which ASBG considered can be largely covered by Queensland’s existing End of Waste Codes instrument.
 ASBG\'s Submission on Queensland’s Energy from Waste Policy - August 2019 | 743 kB |
ASBG supports the overarching principles of the proposed changes to the National Environment Protection (Ambient Air Quality) Measure (AAQ NEPM), but identifies a number of issues with the approach and future directions especially how the AAQ NEPM will be used. A key issue is that AAQ NEPM standards are routinely incorporated in jurisdictional planning and operational conditional policies. When inserted they are often applied as impact limits on industrial sites, not as ambient standards as the NEPM requires. Application is not limited to new sites, but is increasingly being applied to existing sites, ignoring grandfathering, which has been a cornerstone of air pollution control in the past. ASBG considers this practice, which considerably tightens the standards, needs to be recognised and considered in the AAQ NEPM variation. An effort was made to identify the way in which the AAQ NEPM standards are enforced with industrial sites being subject to the tightest application, in contrast to for example wood heaters which are barely addressed as a pollution source. Also addressed is the exemption of prescribed burns which is increasingly being identified as a double standard.
| ASBG's Submission on the AAQ NEPM Variation - August 2019 | 937 kB |
ASBG prepared its submission on the draft Guidelines: Pollution Incident Response Management Plans (PIRMP). Overall the Guidelines are an improvement over the current version with a much clearer set of what is expected from PIRMPs well explained. However, a major issue was raised with the literal interpretation that any pollution incident should result in retesting and updating of the site's PIRMP within 30 days. ASBG considers the Guidelines are an opportunity to interpret the meaning of s98E(2)(b) POEO (General) Regulation to mean incidents that are Material Harm. Another related issue is interpretation of what should be involved in a PIRMP update. ASBG argues the PIRMP is primarily an incident response plan and should only deal with upstream risk issues limited to management practices and not engineering and process changes.
| ASBG\'s Submission on the Draft PIRMP Guidelines 2019 | 822 kB |
ASBG supported many of the strategy's positions, especially its support for Energy-from-Waste with some reservation on the ability to achieve these. For example, there are ambitious targets for C&D waste and other recycling streams. However, there is little to tackle minimisation of contamination especially from waste generators including residential and kerbside. Business are considered for contamination attention, but no other generators are directly considered. The targets expressed are vague, but are set to 2050 which is well into the future.
| ASBG’s Submission On Queensland’s Draft Waste Management And Resource Recovery | 1005 kB |
ASBG's submission calls for NSW Fire and Rescue's document Fire Safety in Waste Facilities (FSWF) to firstly recommend the use of a fire study and provide area topics in which such a study can be made. There are many issues and recommendations on FSWS, but the most glaring is the excessive separation distances required for combustible waste. It is around 3 times larger than used for diesel storage. These distances were taken out of context from a UK document which based its distances on the premise there were no other fire controls used.
Application of FSWF can also apply to existing sites, but there is no consideration of issues affecting existing sites such as land surface available. Retrospective application of new standards to old sites is also poorly addressed and requires a reassessment of how new fire controls can in part be applied to existing sites, like with older buildings. EPA has also included its own requirement for a minimum of 4 hours of fire water storage in worst case scenario. This again is excessive and requires reconsideration and justification based on evidence this will provide a cost effective solution.
| ASBG's Submission on Fire Safety in Waste Facilities 2019 | 1028 kB |
