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.
