ASBG was invited to comment on the draft EPA’s Licensing Guidelines: Environmental Risk Levels, an unreleased document. This document was asked for by ASBG for the EPA to prepare. Put simply it is a a document to reward low risk level licence holders by the use of more self regulation on the Environment Protection Licences (EPL). Overall the guidelines are a reasonable attempt to assist low risk licence holders, but could have provided more flexibility especially in monitoring conditions for these licence holders. Also attached is the published EPA ERL Guidelines.

Attachments:

ASBG's Comments on: EPA Guidelines: Environmental Risk Levels

148 kB

ASBG's submission to the Government's UNFCCC’s Taskforce on the post 2020 greenhouse emissions target key include:

• A carbon price using market mechanisms based on either cap-and-trade or base-line-and-credit is required
• The carbon price should follow Australia's main trading partners and its international position
• International carbon credit trading be open and free
• Other issues covered include, taxation, transitional arrangements, baseline, target length and assistance to energy intensive trade exposed industries

Attachments:

Setting Australia's Post 2020 GHG Target'

81 kB

ASBG raised three main issues with the draft National Environment Protection (Ambient Air Quality) Measure (NEPM)

• ASBG questioned the wisdom of having the tightest world limits especially its impact on future planning requirements for industrial sites.
• Use of the no threshold linear health response model ignores the hormesis principle whereby low concentrations can have beneficial health benefits. A paper by the US NIH called into question the much higher US PM2.5 levels as a significant number of US cities showed beneficial health outcomes. The hormesis principle points to an optimal PM2.5 level, rather than continual tightening.
• Contextual information needs to be better communicated with exceedences especially when natural events dominate these.

Click on the link below to read the full submission.

Attachments:

ASBG's Submission on the Ambient Air Quality NEPM

225 kB

New onerous controls and conditions are proposed for licensed sites that are waste facilities, including recycling, storage and processing of wastes. This captures many unintended licensed sites with recycling as a small activity. ASBG main recommendation is for a flexibility arrangement whereby sections of the regulation can be exempted from certain licences, and if necessary includes alternative licence conditions. There are many complex issues with the proposed Regulation ranging from asbestos to weighbridge requirements.

Attachments:

ASBG\'s Submission on the EPA\'s Proposed Waste Regulation 2014

410 kB