ASBG comments on the EPA's Illegal Dumping Strategy included:

  • The Strategy avoided discussing high costs of disposal as a main cause of  illegal dumping.  High gate fees are generally the result of the waste levy and tight regulatory controls, which could be lowered.
  • Better enforcement is required but there are gaps in the Regional Illegal Dumping Squads areas across NSW, especially in the greater Sydney area.
  • Illegal dumping was poorly defined with the Strategy limited to only publically accessible land, ignoring private lands and other illegal disposals.
  • Victims of illegal dumping are often required to pay for cleanup costs, of which there is no victim support, for individuals and for businesses.


This submission was lodged to Queensland Treasury, which proposes its own Tailored Solution with two surety funds to cover the risks of existing and future mines rehabilitation should a mine become insolvent or similar.  In effect, Queensland Treasury is to become the Financial Assurance 'underwriter', but based on the $167m fund.  ASBG commented that this approach for mines would not fit with other industry sectors for a number of reasons.  Also the US Superfund is an example of what issues can arise when government takes on contaminated land risk, has many lessons to learn from.  ASBG offers a number of improvement areas for consideration.

ASBG's Submission on the Child Care Facility SEPP raised concerns on the possible siting of Child Care Facilities (CCF) in industrial zones.  While the SEPP does assist in better controlling CCFs being located even in heavy industrial zones, and considers existing industrial users, it fails to consider future industrial development or future site remediation.  ASBG recommended that CCFs should not be located in IN1 and IN3, General and Heavy industrial zones due to land use conflicts and health impacts on children.  While it may be possible to engineer a CCF to protect it from industrial emissions, the reliability of that protection and the costs would make it a poor choice.  Even then environmental controls currently do not consider such barriers that a CCF could employ leading to a land use conflict.

ASBG has written to the Minister following the release of the EPA's Approved Methods 2016 version.  At issue is the inclusion of the Ambient Air Quality NEPM criteria to be applied to individual sites at the closest receptor.  The prior Minister Mr Speakman promised at an ASBG Breakfast in July 2015 that this would not occur, yet it has.

ASBG's Submission largely focuses on improving the efficiency of achieving better air quality, as well as considering air pollution’s impacts in perspective with other issues. ASBG has identified a number of issues including:

  • Erroneous use of the term No safe level, but should be put into a risk based perspective with contextual information. Use of no safe level implies that only a zero emission is acceptable, which carries considerable cost impacts. Overspending on one health issue can deplete other areas, which can lead to poorer heath and other outcomes.
  • Focusing on the main sources of air pollution, which should include an evidence, scientific risk-based approach. Managing the most stressed air pollution locations and focusing controls on the major sources should be the adopted approach; however, this is not always the case.

    Download the full submission below.

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