ASBG's submission welcomed most of the changes in the draft POEO (General) Regulation 2022. In particular the amendments to the Pollution Incident Response Management Plan testing which currently requires a test redo within 30 days of any pollution incident. This is to be changed to a Material Harm level pollution incident, a win for ASBG from our 2019 submission.
There were four issues with the draft Reg:
- The application fees for Chemical Storage, prescribed waste: ASBG considers the fee for Prescribed Waste Storage licence of $5,402 too high given its simplicity.
- Clarification on the changes to Extractive Industries: This change can capture unintended activities such as site rehabilitation and needs clarifying.
- Clarification on waste storage: Clarification on how the 5t threshold works as well as removing the capture of RRO materials sent to other processing sites, such as concrete and asphalt plants
- Changes to the National Pollution Inventory: EPA to source its quality data for Cat 2 fuels from NGERs using the new Inter-governmental Agreement on data. EPA to develop new emissions estimation techniques with industry input and connection for use by all jurisdictions.