Submissions
ASBG has responded to the EPA's Pollution Incident Response Management Plans (PIRMP): Proposed Amendments Under the POEO (General) Regulation 2009.Key issues addressed include:
- Poor consultation and the by-passing of the RIS process for this regulation
- Requirement to publicise PIRMPs on company websites is opposed for security, privacy and commercial in confidence reasons.
- Testing requirements for PIRMPs needs to be clarified and permit simulations and desktop studies where appropriate.
PIRMPs are only one of a number of new changes attached to the POE Amendment Legislation Act 2011. Website lodgement of monitoring data is the next issue for public consultation.
 ASBG's submission on PIRMP Regualtion | 116 kB |
ASBG responded to the NSW EPA's Draft Landfarming: Technical Practice Notes citing the disproportionate emphasis on VOC emissions from such a miniscule source.
ASBG accepts that some landfarming practices may not well run and some controls may be required. However, the landfarming notes require treatability tests to be undertaken for apparently all landfarms. Where VOC emissions are considered by the EPA to be excessive they will need to be controlled using tents, greenhouse enclosures or covers. ASBG is concerned the testing and performance requirements are not specified and acceptance is at the consideration of the regulator.
ASBG calls for a more holistic approach where the notes consider the material to be treated - bio-degradable hydrocarbons - and assess each available and economically viable option. Clamping down on too hard landfarming is expected to simply transfer the problem to landfill or result in abandonment of remediation. Ideally the outcome should be to maximise environmental outcomes than to focus on one treatment type.
| ASBG's response to EPA's Landfarming Notes | 117 kB |
ASBG submission on the Independent Pricing and Regulatory Tribunal’s (IPART) Sydney Water Corporation Price Review 2012 largely focused on the substantial change to trade waste pricing. Key issues and recommendations include:
- The need to ensure continuing productivity gains within Sydney Water
- Welcome price reductions such as for the sewer usage charge, but ASBG is concerned about where the missing revenue will be recovered from.
- ASBG recommends that the substantial changes to trade waste charges a transitional pricing structure to introduce the new trade waste charges over a period of 4 years.
- Using pH as a credit off-set to assist in increasing pH in sewage.
| Sydney Water's darft Trade Waste Pricing Policy | 443 kB |
| ASBG's submission on Sydney Water's Pricining Proposal | 248 kB |
ASBG has responded to the Protection of the Environment Legislation Amendment Bill 2011, which imposes considerable new punitive conditions on business and industry in NSW. Under this Bill companies are required to immediately report environmental incidents of material harm (>$10,000). Changing 'as soon as practical’ to 'immediate' introduces considerable new liabilities, make it very difficult to comply with, will substantially increase compliance costs and may even detract from better environmental protection.
ASBG submission to the Minister appealed for the introduction of a new alternative incident reporting action called 'Serious Environmental Incident'. This new approach will drop the $10,000 harm trigger, but be limited to a list of chemicals and substances which are of community concern. In addition, Serious Environmental Incidents will require immediate reporting or within in one hour. Use of one hour is in line with the O'Reilly Report, which unfortunately was not adopted within the Bill.
The Bill also introduces many new conditions such as:
- Requiring all Licensed monitoring data be posted on company websites.
- Empowering the EPA to undertake health and environmental risk analysis at the reporting company's expense
- Legislating that all Licensed sites develop, train and implement incident action plans.
The Australian Sustainable Business Group (ASBG) commented on the Clean Energy Legislation Package (CELP).
ASBG supports the government’s approach in establishing price on carbon and other greenhouse gases to reduce Australia’s emissions of greenhouse gases. Overall the thrust of the CELP is supported, however a number of concerns also arise. To improve the CELP’s approach ASBG recommended the Government:
- Re-consider the initial set price and fixed trajectory prices favouring a lower start price
- Provide a better transition program from the set price to the floating price and undertake further investigation into this transition.
- Additionally, ASBG is concerned over the risks to the CELPs revenue streams after the price is floated and carbon liable companies can purchase upto 50% of credits from overseas sources.
- Re-evaluate the grant programs to ensure these better reflect and support the lowest cost emissions reduction programs during the long transitional period towards the long term emissions reduction targets. ASBG is concerned the grant and assistance package is too heavily focused on renewable technologies.
- Support for the National energy Savings Initiative.
| ASBG's submission on the Clean Energy Legislative Package 2011 | 222 kB |
