Submissions
ASBG members have been subject to the application of the NSW EPA's Approved Methods for air Modelling. Use of Approved Methods should only be applied at the planning level, but is being more often applied to existing sites. EPA's application on existing sites has been a creeping issue, which ignores the grandfathering provisions on air pollution equipment, assumes hypothetical represent real emissions and hence a need to meet newer air emission assessment criteria with no warning that it is to apply. ASBG wrote a letter asked the EPA to clarify its policy on the use of Approved Methods to existing sites and if used as a default method how it will be applied and interpreted.
 EPA Response on Approved Methods | 1591 kB |
| ASBG Approved Methods Letter 2018 | 610 kB |
ASBG submission is in response to the Review of the National Pollutant Inventory – Discussion Paper. A number of key recommendations were made including:
- Better explanations of contextual nature of each pollutant with diffuse and natural sources,
- Publishing of the error ranges of reported substance emissions to permit scientifically valid conclusions to be made
- Updating of the estimation technique manuals on an ongoing basis
- Move to a two year reporting period with 50% of facilities reporting each year to free up resources
- Diffuse sources be standardised and aligned across all jurisdictions
- Collected advisory information published if a 25% difference occurs from the last emission amount
ASBG also answered the 50 questions in the review paper with further clarification of our position.
| ASBG\'s Submission on the Review of the NPI - 2018 | 916 kB |
Queensland is proposing to introduce a $70/t levy, the largest ever step change in Australia. ASBG recommended this be spread over 4 to 5 years to avoid economic shock to businesses. It also will set up other long haulage of waste incentives out of Queensland to NT, South Australia and levy free areas in NSW. Other main recommendations include:
- Hypothecation of 80% the levy money back to businesses, industry and the waste sector is recommended along with setting up a specialist recycling and resource recovery agency.
- Queensland to work with eastern states to set the waste levy at around $70/t to minimise long haulage of wastes
- Regulated wastes to be capped at $70/t to avoid long haulage of these waste outside of Queensland and clarification of its tracking requirements
- Levy relief for recyclers is welcomed, but needs to be carefully arranged
- Waste to energy approach is supported, but warns against using the NSW approach
| ASBG’s Submission on Queensland’s Recycling and Waste Industry Paper - 2018 | 935 kB |
ASBG's submission is on the NSW Department of Planning and Environment's Remediation of Land State Environment Planning Policy (SEPP) and the Contaminated Land Planning Guidelines.
ASBG considers the draft Remediation of Land SEPP (RL SEPP) to be too much of a jump in tightening and control over the currently well working SEPP 55, which it is to replace. The methodology used for the Category 1 - remeidation works requiring a Development Application is too process and activity based. This is contrary to NSW's Guide Better Regulation which requires the use outcome and risk based approach, which if properly adopted would provide a better level of flexibility, permit innovative solutions, lower costs and better health and environmental outcomes. ASBG provides a number of recommended improvements regarding the table of Category 1 criteria, but is concerned the process has too many flaws. Consequently, formation of a Working Group is recommended.
Category 2 remediation work is too process based, many of such rules are impractical and do not consider the wide variations that occur in remediation work. ASBG provides a table of comments and recommended changes, but many of these are well covered under existing safety and environmental laws and guidelines. Other recommendations cover site auditors, use of terms and its capture of residential lands. Download the submission below.
| Addendum ASBG's Submission on SEPP 55 Review - 2018 | 807 kB |
| ASBG Submission on Review of SEPP 55 2018 | 1069 kB |
ASBG's submission is a response to the Department of Planning and Environment’s Improving Mine Rehabilitation in NSW Discussion Paper, which sets out the planning requirements for mine, quarry and other extractive industry rehabilitation processes over the life of the activity. ASBG considered it difficult to plan ahead to set the final beneficial reuse of a mining void when community attitudes and future plans for the area are likely to change over say 50 years. Consequently, flexibility to accept changes should be incorporated into the planning process. Rehabilitation should also not be time based, rather based on milestones. New opportunities for void filling and re-engineering can appear in the future where a new nearby mine could use its spoil to fill an older mine's void for a set period. A spoil off-set program was recommended. Such innovative approaches to mine ecology should receive the support of both State and Local Governments and encouraged by the planning system. Removal of duplication of multiple reports to different agencies where the reports contain the same information with a few variations was recommended.
| ASBG Submission on Mine Rehabilitation 2018 | 697 kB |
