ASBG supports the overarching principles of the proposed changes to the National Environment Protection (Ambient Air Quality) Measure (AAQ NEPM), but identifies a number of issues with the approach and future directions especially how the AAQ NEPM will be used. A key issue is that AAQ NEPM standards are routinely incorporated in jurisdictional planning and operational conditional policies. When inserted they are often applied as impact limits on industrial sites, not as ambient standards as the NEPM requires. Application is not limited to new sites, but is increasingly being applied to existing sites, ignoring grandfathering, which has been a cornerstone of air pollution control in the past. ASBG considers this practice, which considerably tightens the standards, needs to be recognised and considered in the AAQ NEPM variation. An effort was made to identify the way in which the AAQ NEPM standards are enforced with industrial sites being subject to the tightest application, in contrast to for example wood heaters which are barely addressed as a pollution source. Also addressed is the exemption of prescribed burns which is increasingly being identified as a double standard.
 ASBG's Submission on the AAQ NEPM Variation - August 2019 | 937 kB |
