ASBG Submission On the DEC's Underground Petroleum Storage Systems Regulation and RIS
ASBG generally supports the thrust of this regulation but wishes a number of areas to be clarified. These include the use of new land pollution provision (s142A) under the POEO Amendment Act and the way in which licenced sites will be covered by the regulation. ASBG was also cautioned the DEC that many smaller sites have underground tanks and may not be aware of the require provisions to mandate ground water monitoring wells and integrity checks on such tanks.
ASBG Submission On the Assessment of Site Contamination NEPM
ASBG supports some the main issues identified in the discussion paper on the use and abuse of the NEPM. Too often jurisdictions have used the investigation criteria for clean up levels, which in most cases is too conservative. ASBG supported the thrust to introduce remediation levels across the NEPM to provide better guidance to its users. ASBG also considers the NEPM is an evolving document that will grow with more research on new and existing substances.

ASBG Submission On the Productivity Commission's Draft Waste Review Report

ASBG largely supports the Productivity Commission's views on the way in which waste is handled by government policy. However, there is too much momentum behind the current poor waste strategies, which will cost Australian's more and may also lead to perverse outcomes where environmental harm is increased. We strongly support the need for better data on all types of wastes and where they go. An example, of the lack of data on waste is the work ASBG has done on contaminated soils sent to landfill and the counter waste minimisation policy regulations, which encourage it. The NSW waste levy is especially criticized as well as the extremely low proportion of revenue that is returned to waste research and evaluation.

ASBG Submission National Pollutant Inventory Variation Submission
ASBG supported the proposed name change for the National Pollutant Inventory (NPI) to the National Emissions Inventory. The main issue addressed was the proposed inclusion of transfers. Transfers include the NPI substances that appear in waste and wastewater streams set to another party who usually treat or dispose of the materials. ASBG considers there are 2 types of approaches to generate NPI data for transfers, both of which are undesirable. As wastes a notoriously variable the use of estimation techniques, based on a handful of analysis will provide meaningless data. If on the other hand NPI data was collected to a meaningful level, this would be very costly and lead to the export of Australian jobs.

ASBG Submission COAG's Greenhouse Gas Mandatory Reporting Scheme

In a similar process to the NPI COAG is establishing a mandatory greenhouse reporting Scheme. ASBG identified a number of issues for COAG to consider especially the extreme under estimation of the cost to companies in reporting to such a scheme. An estimate by COAG of $2,100 per company was considerably lower than ASBG member feedback of between $40,000 to $50,000 per site! Lack of consistency with the Energy Efficiency Opportunities scheme on joint ventures and concern over commercial-in-confidence information and public access via Freedom of Information legislation. COAG recommended that companies can write and be assessed to attain commercial-in-confidence protection, whereas ASBG recommended that protection be automatic.

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