ASBG supported the general thrust of the draft Clean Air Strategy (CAR) and the ongoing process of improving ambient and local air quality for the people of NSW. While this is supported it must be balanced with NSW being able to provide well-paying jobs, which industry in particularly provides.  A number of issues were raised including:

• Application of new air standards on existing industrial sites - there is a trend to apply newer air standards to existing sites, especially from the Ambient Air Quality NEPM (AAQ NEPM).  However, there are a number of NSW Government policy positions which should prevent this. (see submission for details)
• Air emissions by industry in perspective - In NSW's most stressed n the Sydney Air shed, industrial emissions are a minority, with motor vehicles and wood heaters and BBQ combustion being larger sources.  So why is the CAS focusing on reducing industrial emissions, especially in other cleaner air sheds when the cost-benefit is quite low compared to other source control? ASBG also questioned why industrial NOx emissions i increased by 50% (7.9% to 11.9%) from 2014 to 2018.
• Application of new air standards and policy on new industrial sites - The AAQ NEPM recent new standards on PM, NOx SOx and O3 are the world's tightest.  This will exclude or make very expensive many types of new industrial development, particularly large thermal systems.  ASBG recommends a cost-benefit study be done to identify the types of industry NSW does not want and prefers.
• Concern on the cost impacts of the revised Load Based Licensing scheme (LBL) - The 2016 LBL scheme came with massive cost increases, which could force some sites to close.  ASBG recommended the implementation of LBL on sites should be subject to a similar negotiated process with appeal as applies to Environment Protection Licences.  A negotiated process should avoid many site closures.
• Funding arrangements under the Net Zero Plan (NZP) and other assistance. NZP provides a series of welcome grants and financial packages, which all must focus on reducing greenhouse gases (GHS).  ASBG points out that the CAS is largely focused on local air pollution not global, and there can be conflict such as reducing NOx can increase GHG emissions.  Also the CAS is largely missing any financial assistance to industry to reduce its air emissions, unlike other international schemes where taxes similar to LBL are fully hypothecated to funding industry emission reduction.

Attachments:

ASBG Submission on NSW Clean Air Strategy - April 2021

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