Submissions
ASBG’s response to DECCW on the State of the Environment’s claim that:
NOx emissions from industry in Sydney, which increased 49% (6876 tonnes), [2003-2008]
ASBG argues this statement is misleading as it is derived from different data sets, one hard, site data from the 2003 MAQS. The other is an extrapolation of the 2003 data to estimate 2008 emissions.
ASBG also argues the 15% NOx drop and the 23% VOC drop from motor vehicles is inaccurate and contrary to other estimations.
See DECCW's response below.
 ASBG's Response to the SoE's missleading statements | 266 kB |
| DECCW's Response to ASBG's letter | 738 kB |
ASBG Submission On the Water and Energy Savings Plans
ASBG recommended that increased flexibility be the main amendments to the new Water and Energy Savings Plans that applies to site that use over 50 ML/year and 10 GWhrs/year of energy at stationary sources. These plans will over time apply to smaller sites and require many companies to commit to savings targets on water and energy consumption. ASBG identified many reasons to keep the process flexible due to large variations between industries and regulatory impediments to such savings.
| Submission On the Water and Energy Savings Plans | 87 kB |
ASBG comments focused on the generic definitions of class 3 flammable liquids, class 8 corrosives and class 9 miscellaneous. ASBG called for simpler means in which to assign a UN NOS number to a waste. Under current ADG Code requirements any substance must have the tests undertaken before a UN NOS number can be assigned. This is extremely difficult when managing wastes, especially hazardous wastes. A number of minor changes were also recommended largely dealing with hot liquids such as bitumen.
| Submission On the 7th Edition Australian Dangerous Goods Code | 72 kB |
ASBG generally supports the thrust of this regulation but wishes a number of areas to be clarified. These include the use of new land pollution provision (s142A) under the POEO Amendment Act and the way in which licenced sites will be covered by the regulation. ASBG was also cautioned the DEC that many smaller sites have underground tanks and may not be aware of the require provisions to mandate ground water monitoring wells and integrity checks on such tanks.
ASBG supports some the main issues identified in the discussion paper on the use and abuse of the NEPM. Too often jurisdictions have used the investigation criteria for clean up levels, which in most cases is too conservative. ASBG supported the thrust to introduce remediation levels across the NEPM to provide better guidance to its users. ASBG also considers the NEPM is an evolving document that will grow with more research on new and existing substances.
| Submission On the Assessment of Site Contamination NEPM | 62 kB |
