This is ASBG's follow up and more detailed submission on the Public Consultation documents on the EPA's Risk Based Licensing Framework. ASBG takes the step of proposing an alternative set to replace the Administrative Fee Multiplier scheme with an Additive scheme. Also included is a set of additional changes to the EPA's inspectorial frequencies and costs on monitoring and licence conditions based on the site risks. Sites that are considered good performers should receive a higher level of self regulation, where as poor performers have no incentives. See more...