ASBG responded to the on-line questions put forward on the 20 year waste strategy, clarifying and repeating many of its prior positions on such issues.  Designing waste out of products requires good recycling infrastructure first before such actions can be commenced. Given the current high turmoil in recycling such design is very difficult for many products.  Also requiring change is the low tolerances set for recycled products, with the presence of asbestos cited as an example which is very difficult to demonstrate.  ASBG calls for a more cooperative balance between recycling and environmental protection enforcement and clearer pathways for reuse and recycling of wastes which replace raw materials in processes. NSW also requires a new planning and operational pathway for innovative waste infrastructure as the current system works strongly against such development. Also the planning system needs to better address the NIMBY syndrome which affects all levels of waste infrastructure Need for better recycling of waste levy moneys back into the waste generation and management sector, noting businesses pay about 65% of the waste levy. NSW's Energy from Waste Policy requires to be rewritten and broadened to include a wide variety of EfW processes and to also make it more cost effective and minimise its obstructional requirements.

ASBG discussion and recommendations on the Financial Assurance (FA) Policy and Guidelines commenced with the inclusion of the risk of financial stability, where sites which can internally financially cover known risks and are not of a very-high environmental risk should be considered a medium risk for requiring a FA.  ASBG is concerned the risk based approach, while good in principle is too blunt and inflexible as one small clean up or penalty notice can place a site into the high risk category making a FA likely.  Application of the Cost Estimate Guidelines is expensive and is estimated to cost similarly to a $1.5 m FA for the first year.  Consequently, only FAs above $1.5m should use the guidelines and other means used for lower valued FAs. EPA should also encourage a voluntary approach to rectify environmental issues similarly to that used in voluntary Management Proposals used for contaminated land remediations.

ASBG recommended special treatment of the non-C&D recycling sector, as they are in a financial squeeze.  Waste levy moneys could be used to assist in any FA requirements placed on this sector.

Other issues were also discussed including consistent definitions and use of terms under the financial and insurance sector and clarification of the use of insurance policies as FAs.

ASBG wrote to the EPA in relation to concerns that members could not comply with their PIRMP and other training and testing requirements due to internal  COVID19 risk controls.

The EPA has since sent a general email to all sites holding Environment Protection Licenses requesting those who cannot meet their environmental obligations due to COVID19 issues to email the EPA.  Cases will be considered on a case-by-case basis.

Addressing consistency and balances of Authorised Officers and Enforcement Officers of environmental law is a challenge for the NSW EPA.  The draft Powers and Notices Guidelines is a welcome improvement over prior guidelines which form a basis for Officers to reasonably and effectively carry out their duties.  ASBG makes a few minor recommendations to the draft Guidelines, but is more concerned with the entire process where large variations between officers and regions occurs and the poor behaviour and knowledge that some take into the field. 

ASBG prepared a submission on the Council of Australian Government’s (COAG) Consultation Regulation Impact Statement Phasing out certain waste exports (RIS).  This is the second submission and one that focus on the RIS document.

ASBG considers the RIS is non-compliant with COAG's Best Practice Regulation: A Guide for Ministerial Councils and National Standard Setting Bodies. Specifically this consultation RIS provides no economic nor risk assessment which can be reviewed nor does it show how the Waste Export Ban benefits Australia. Consequently, ASBG recommends an economic and risk assessment be undertaken and the RIS redone with public consultation.

ASBG identified costs associated with WEB placed on paper exports which resulted in a net loss of $275 million p.a. Australia simply does not have the paper recycling mills to accept many paper and cardboard types which can only be served by overseas mills. Also Australia has neither the supply nor the required approximately $1b CAPX to build specialised paper mills which can operate commercially selling its excess into the export market.  Note Australia simply does not have the manufacturing base to absorb the quantities of recyclates which a large proportion is sourced from our imports.

ASBG recommends a third option be included in the RIS: Use a gate keeper (Basel Convention) approach to screen recyclates for export.  This should cover the issue of prevention of environmental and health harm caused by exported Australian recyclates.  This additional option should be included in the redo of the RIS.


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