ASBG is concerned the RIS grossly underestimates the costs to industry from going from Group 3 & 4 to Group 6 under the sunset arrangements. Costs by the EPA are out by at least a factor of 3 if not more. The costs to industry, in the RIS, also do not consider the impacts of the multiplier effect from industrial employment, where ASBG found data that indicates it is 7.36 times higher.
Additionally, the RIS lumps industry under the GMR, which misrepresents the area contributions of pollutants from industry. In contrast wood heaters are assessed using both the GMR and Sydney air sheds, but no further actions are proposed on wood heaters despite their major contribution to Sydney Particulate Matter pollution.
ASBG recommends the RIS be redone and the options reassessed based on real cost data from industry. It is likely that moving to Group 6 is simply too costly to undertake.
There are two technical errors in the draft Regulation:
• The definition of volatile organic liquid, which replaced “unless” with “and” erroneously changing the current definition.
• The set points for Pressure-vacuum vents at 15 kPa and -0.5 kPa, can be set higher than the tanks’ emergency vent release pressures. This conflicts with AS1940 set a design pressure level for atmospheric tanks as a maximum pressure.
 ASBG Submission on POEO Clean Air Regulation 2022 | 1433 kB |
