ASBG submission on the EPA's Requirements for Publication of Pollution Monitoring Data is split into two main areas.  Firstly is the strong message ASBG's members wish to send to the NSW Government that the scheme be wound back to only include exceedences of monitoring limits with explanations when these occur.  The second part lists issues with the Requirements details such as use of other electronic formats other than Word or Excel, the removal of date of data obtained and date published, use of monthly data ranges and other issues affecting Environment Protection Licence holders.

Attachments:

ASBG's Submisison on Publication of Monitoring Data 2013

324 kB

ASBG prepared a submission for the Independent Pricing and Regulatory Tribunal (IPART) Review of Licensing in NSW.  A key focus is on Environment Protection Licences (EPL) and ways and means in which to improve their efficiency.  Some of the recommendations included:

• Use of a risk index approach which is publically available and calculable to categorise licences in to various levels and set monitoring and licensing frequencies.
• Adopt the Victorian Corporate licence system or similar to improve the administration efficiency for multiple sites operated under one entity.
• Reveiw add-on ad hoc addtional requirements to EPL holders to remove excessive red tape.
• Incorporation of the Environmentally Hazardous Chemicals Act 1985 licence componants into the Protection of the Environment Operations Act licenses.

The submission provides an number of detailed discussions and examples of red tape in environmental and related licensing.

Attachments:

ASBG's Submission to IPART - Licensing Review

266 kB

ASBG has prepared a list of ideas to improve the efficiency of environmental regulation in NSW.  It contains 11 key points focusing on a range of issues including improving the consultative process which has deteriorated and the relationship between businesses and the regulator in forming better regulation which achieves higher environmental outcomes in a more efficient and lower cost manner. There are many more issues covered.

Attachments:

ASBG’s Ideas for Improving NSW’s Environmental Framework

55 kB

The Environment Protection Authority (EPA) draft revised Excavated Natural Material Resource Recovery Exemption (ENM Exemption) is attached.  The draft contains a number of welcomed amendments to the ENM exemption including:

• Reduced sampling frequency for smaller volume materials
• Removal of chlorinated hydrocarbons
• Changes to metals and pH levels
• Introduction of individual BTEX concentrations
• Use of hot spot separations for in-situ sites

ASBG has prepared a submission which asks for faster and lower cost assessment of ENM materials at smaller quantities, i.e. < 500t. Recommended approaches include

• On-the-spot testing by human senses and field testing equipment
• Use of a reduced set of chemical testing where history can demonstrate certain tests are not required
• Use of third parties to undertake on-the-spot testing for smaller ENM quantities
• Use of maps to identify areas where certain testing must be undertaken and others where less testing is needed
• A scientific testing criteria for asbestos

Attachments:

ASBG's Submission on the ENM RRE Review 2012	137 kB
Draft ENM Exemption Review	695 kB