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.

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