Submissions
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 |
ASBG supports the thrust of the proposed New Planning System for NSW (the White Paper), but considers it could go further in providing planning certainty especially for major projects and controversial developments. ASBG is concerned that waste infrastructure will still face considerable planning problems under the proposal as could other similarly controversial developments. A range of ideas is provided to reduce the adversarial process that planning has become, and to bring back increased conciliation and better negotiation processes.
| ASBG's Submission on NSW's New Planning System 2013 | 167 kB |
ASBG's submission splits the EPA's Proposed Risk Based Environmental Regulatory Framework into the increase of administrative fees and the Risk Assessment Process (RAP). ASBG calls to minimise the increase in fees due to the current economic circumstances faced by most Licence holders, especially manufactures. On the RAP ASBG makes 6 recommendations calling for:
- More than the 3 risk ranks proposed especially for larger sites
- Consultation on the RAP tool and the overall process before the RIS is prepared
- A negotiation and dispute resolution process for the RAP tool outcomes
- Clarity on the impact on licence conditions for risk rankings ranging from more self regulation to increased inspections and conditions
- Concerns over the Operator Performance Multiplier, recommending an additive approach rather than a multiplier.
| ASBG's Submission on EPA's Risk Based Licensing Framework | 155 kB |
