Submissions
ASBG's Submission on the Child Care Facility SEPP raised concerns on the possible siting of Child Care Facilities (CCF) in industrial zones. While the SEPP does assist in better controlling CCFs being located even in heavy industrial zones, and considers existing industrial users, it fails to consider future industrial development or future site remediation. ASBG recommended that CCFs should not be located in IN1 and IN3, General and Heavy industrial zones due to land use conflicts and health impacts on children. While it may be possible to engineer a CCF to protect it from industrial emissions, the reliability of that protection and the costs would make it a poor choice. Even then environmental controls currently do not consider such barriers that a CCF could employ leading to a land use conflict.
 ASBG Submission on the Child Care Facility SEPP | 662 kB |
ASBG has written to the Minister following the release of the EPA's Approved Methods 2016 version. At issue is the inclusion of the Ambient Air Quality NEPM criteria to be applied to individual sites at the closest receptor. The prior Minister Mr Speakman promised at an ASBG Breakfast in July 2015 that this would not occur, yet it has.
| ASBG's Issues with the Approved Methods 2016 | 481 kB |
ASBG's Submission largely focuses on improving the efficiency of achieving better air quality, as well as considering air pollution’s impacts in perspective with other issues. ASBG has identified a number of issues including:
- Erroneous use of the term No safe level, but should be put into a risk based perspective with contextual information. Use of no safe level implies that only a zero emission is acceptable, which carries considerable cost impacts. Overspending on one health issue can deplete other areas, which can lead to poorer heath and other outcomes.
- Focusing on the main sources of air pollution, which should include an evidence, scientific risk-based approach. Managing the most stressed air pollution locations and focusing controls on the major sources should be the adopted approach; however, this is not always the case.
Download the full submission below.
| ASBG's Submission on Clean Air in NSW 2017 | 1336 kB |
ASBG's submission raises concerns regarding the proposed massive LBL fee increases and calls for such fees to remain the same for existing payers. Use of a abatement-cost-of-damage approach projects fees to increase substantially for certain pollutants, such as 600% for PM. Many proposed changes under LBL are considered and recommendations provided on a range of LBL settings. ASBG supports the use of green-offsets, but finds the proposed recycling of LBL fees a start, but without details suspect of its ability to assist LBL fee paying members. This is a substantial submission with many issues covered. Download the full version attached below.
| ASBG's Submission on the Load-Based Licensing Review 2016 | 1295 kB |
ASBG's submission on Environmental Impact Assessment Improvement Project asks for a one-stop-shop to deal with the multi-agency oversight, especially from both the Department of Planning and Environment (DPEE) and the Environmental Protection Authority. Currently many large licensed sites are subjected to a range of audits and inspections by largely these two agencies which has considerable duplication. Also recommends the recognition of 3rd party audits on Environmental Management Systems if they cover the required scope of the DPEE's independent audits.
| ASBG's Submission on EIA Improvement Project 2016 | 540 kB |
