ASBG's submission splits the EPA's Proposed Risk Based Environmental Regulatory Framework into the increase of administrative fees and the Risk Assessment Process (RAP).  ASBG calls to minimise the increase in fees due to the current economic circumstances faced by most Licence holders, especially manufactures. On the RAP ASBG makes 6 recommendations calling for:

• More than the 3 risk ranks proposed especially for larger sites
• Consultation on the RAP tool and the overall process before the RIS is prepared
• A negotiation and dispute resolution process for the RAP tool outcomes
• Clarity on the impact on licence conditions for risk rankings ranging from more self regulation to increased inspections and conditions
• Concerns over the Operator Performance Multiplier, recommending an additive approach rather than a multiplier.

Attachments:

ASBG's Submission on EPA's Risk Based Licensing Framework

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