Submissions
ASBG prepared this submission on the POEO Amendment (Asbestos) Waste Bill 2018 which was not publically made available. It contains a single change which is of concern, proposing the new s241(f) the presence of the asbestos in the environment, under the POEO Act. ASBG is concerned this sets a precedence for the use of the unscientific application of the mere presence of asbestos in waste, rather than the use of a risk-based approach as applies to all other environmental contaminants and pollutants. ASBG recommended its removal and the use of a due diligence defence against asbestos waste offences given their maximum fines the same as Tier 1 offences for negligence. Other recommendations include developing other risk based approaches to asbestos waste where the measurement method AS4964 cannot be applied and provide waste levy to victims of illegal asbestos dumping and illegal contamination from illegal asbestos management.
 Ministers Response | 923 kB |
| ASBG's Submission on Asbestos Waste Bill 2018 | 944 kB |
ASBG strongly recommended the rebate for recyclers be proportionally paid on the quantities of recycled product sold, rather than claim the discount at landfill gates. Other positions were on the heavy administrative burden on landfill gates and related issues to fraud which accompanies waste levies.
| ASBG Queensland Waste Levy Submission 2018.pdf | 856 kB |
ASBG submission in general supported most of the changes proposed under the National Waste Policy, with a few exceptions. Striving for an average 30% recycled content across all recycled products is poorly defined. While it can work for a set of recycled materials, there are limits to its application to C&D products and engineered fill. It has also caused issues in North America where it has been introduced. Consequently it is no supported in its current context. ASBG points out the repeated need for a standardisation of the definition and measurement of waste across Australia, which has been on the table since 2009 with little to show. There are many other listed issues which should be included and expanded in the National Waste Policy, especially considering China's National Sword impacts. Much of the proposals are considered aspirational rather than to be firm targets, which on this basis are acceptable.
| ASBG's National Waste Policy Submission 2018.pdf | 878 kB |
ASBG members have been subject to the application of the NSW EPA's Approved Methods for air Modelling. Use of Approved Methods should only be applied at the planning level, but is being more often applied to existing sites. EPA's application on existing sites has been a creeping issue, which ignores the grandfathering provisions on air pollution equipment, assumes hypothetical represent real emissions and hence a need to meet newer air emission assessment criteria with no warning that it is to apply. ASBG wrote a letter asked the EPA to clarify its policy on the use of Approved Methods to existing sites and if used as a default method how it will be applied and interpreted.
| EPA Response on Approved Methods | 1591 kB |
| ASBG Approved Methods Letter 2018 | 610 kB |
ASBG submission is in response to the Review of the National Pollutant Inventory – Discussion Paper. A number of key recommendations were made including:
- Better explanations of contextual nature of each pollutant with diffuse and natural sources,
- Publishing of the error ranges of reported substance emissions to permit scientifically valid conclusions to be made
- Updating of the estimation technique manuals on an ongoing basis
- Move to a two year reporting period with 50% of facilities reporting each year to free up resources
- Diffuse sources be standardised and aligned across all jurisdictions
- Collected advisory information published if a 25% difference occurs from the last emission amount
ASBG also answered the 50 questions in the review paper with further clarification of our position.
| ASBG\'s Submission on the Review of the NPI - 2018 | 916 kB |
