Submissions
ASBG considers the Protocol for the management of asbestos found in C&D recycling facilities, in its current form, to be economically unworkable for the sector. Use of a more flexible and efficient Protocol can provide a basis for a NSW C&D sector wide approach to managing asbestos. The submission provides recommendations on improving the practicality of the Protocol, with an emphasis on further consultation with the C&D recyclers. It is important to prepare a workable document as this Protocol is likely to be the basis for similar documents. An efficient and pragmatic asbestos management process is required to assist in the removal and proper disposal of the material from NSW communities. The full submission is downloadable below.
 ASBG's Submission on Asbestos Management in C&D Recycling | 347 kB |
ASBG has responded to the POEO Amendment Bill 2014 calling for further clarification of the legal term in s128 'practicable means as may be necessary to prevent or minimise air pollution' on non-point sources. Clarification of the meaning of an odour pollution incident which exceeds the material harm threshold is also asked for. ASBG indicated its willingness to participate in developing further guidance on these issues.
The EPA responded to ASBG's letter (see below), indicating that it was a clarification of existing powers and that odour is not an indication of a new focus of control.
| ASBG\'s Response to the POEO Amendment Bill 2014 | 71 kB |
The Australian Sustainable Business Group (ASBG) has responded to the EPA's Draft The Liquid Food Waste Exemption 2011. ASBG is concerned this second draft Liquid Food Waste Resource Recovery Exemption still retains very conservative requirements such as buffer zones for application on farm land. While some improvements have been made over the initial draft, the current draft would still prevent much of Sydney basins' farmland being able to re-use this organic waste stream.
| ASBG\'s Submission on the EPA\'s Draft Food Liquid Waste Exemption 2014 | 100 kB |
ASBG wrote to the EPA to promote the consideration of environmental insurance policies as an alternative or a supplement to bank guarantees in the EPA’s use of financial assurances. An insurance policy can cover all or in part the environmental liabilities that can be covered by a Financial Assurance, with hybrid bank guarantees and insurance polices working together.
The are a number of advantages in use of insurance policies over current practice sureties such as bank guarantees such as much larger liability coverage of unfortuitous events and increased scrutiny and auditing of the sites so covered. The advantage to the site is a lower cost Financial Assurance and the ability to operate at a lower level of risk.
| ASBG’s on Financial Assurances and Environmental Insurance 2014 | 219 kB |
ASBG's submission on the Emissions Reduction Fund Green Paper focused on provision of ideas on how the ERF could be structured. ASBG proposed a model using both absolute and emission intensity baselines as an alternative option for the design of the system. Credits would be paid only if emissions are below the absolute baseline, but any penalties would only apply if both the intensity and the absolute baselines were exceeded. Advantages and disadvantages are discussed. The submission considered a number of issues with ERF and how the ASBG model could reduce administrative costs and potentially better align with international carbon markets. Having a carbon credit market with international trading potential could provide an income for manufacturing sites which are shrinking or considering closure. Click here for pdf of the submission.
| ASBG\'s submission on the Emissions Reduction Fund Green Paper | 263 kB |
