Submissions
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 |
This is ASBG's follow up and more detailed submission on the Public Consultation documents on the EPA's Risk Based Licensing Framework. ASBG takes the step of proposing an alternative set to replace the Administrative Fee Multiplier scheme with an Additive scheme. Also included is a set of additional changes to the EPA's inspectorial frequencies and costs on monitoring and licence conditions based on the site risks. Sites that are considered good performers should receive a higher level of self regulation, where as poor performers have no incentives. See more...
| ASBG's Submisson on the Risk Based Licensing Framework Public Consultation | 300 kB |
The Australian Sustainable Business Group (ASBG) has responded to the EPA’s Amendments To The Raw Mulch Exemption 2008, The Food Waste Exemption 2009 & The Food Waste Compost Exemption 2008. ASBG is concerned the Liquid Food Waste Resource Recovery Exemption is very risk adverse and is not practical or workable in its current form. It sets much tighter environmental standards than used for spray irrigation of effluent, which can contain far higher contaminate levels than liquid food waste does. ASBG recommends the EPA undertake consultation with the industry sector using these exemptions and appropriate experts to develop a more practical set of exemptions than those proposed.
| ASBG's submission on the Draft Food and Related Waste Exemptions 2013 | 107 kB |
ASBG's submission on the Inquiry Into Management and Disposal of Waste on Private Lands focuses on illegal dumping onto private lands. A few case studies where cited where members were confronted by buck passing by the three agencies, EPA, Council and Police in relation to illegally dumped waste. Additionally, in many cases where illegal dumping has occurred, the site owner victim ends up footing the bill to properly dispose of the waste material. ASBG proposed a number of ideas including:
- Improved Policing of illegally dumped waste
- Make it easier to report and have firm follow up action with clean up costs secured back to the dumper
- Working with the NSW Government to report such incidents, supported by Government guidelines.
| ASBG's submission on the Inquiry Into Disposal of Waste on Private Land | 107 kB |
