ASBG's submission raises concerns regarding the proposed massive LBL fee increases and calls for such fees to remain the same for existing payers. Use of a abatement-cost-of-damage approach projects fees to increase substantially for certain pollutants, such as 600% for PM. Many proposed changes under LBL are considered and recommendations provided on a range of LBL settings. ASBG supports the use of green-offsets, but finds the proposed recycling of LBL fees a start, but without details suspect of its ability to assist LBL fee paying members. This is a substantial submission with many issues covered. Download the full version attached below.