ASBG responded to the EPA's Environmental Guidelines: Publication of Monitoring Data which was legislated under the Protection of the Environment Legislation Amendment Act 2011. Under this legislation  Environment Protection Licence (EPL) holders with websites must publish their monitoring data or provide data to the public on request.

The Guidelines provide details of what is required in terms of presentation of monitoring data.  A key concern is the need for all the underlying data from an EPL  holding site.  Provision of such details, the explanation of why 'limits' can be legally exceeded due to measurement and other reasons will cause considerable confusion for the public and the media.  This will make the EPA's job of protecting the environment from a scientific basis more difficult.  ASBG considers exception reports should be sufficient to identify the issues the vast bulk of the public wishes to know. 

Attachments:

ASBG's Submission on Publication of Monitoring data

123 kB

ASBG has responded to the EPA's Pollution Incident Response Management Plans (PIRMP): Proposed Amendments Under the POEO (General) Regulation 2009.Key issues addressed include:

• Poor consultation and the by-passing of the RIS process for this regulation
• Requirement to publicise PIRMPs on company websites is opposed for security, privacy and commercial in confidence reasons.
• Testing requirements for PIRMPs needs to be clarified and permit simulations and desktop studies where appropriate.

PIRMPs are only one of a number of new changes attached to the POE Amendment Legislation Act 2011.  Website lodgement of monitoring data is the next issue for public consultation.

Attachments:

ASBG's submission on PIRMP Regualtion

116 kB

ASBG responded to the NSW EPA's Draft Landfarming: Technical Practice Notes citing the disproportionate emphasis on VOC emissions from such a miniscule source.

ASBG accepts that some landfarming practices may not well run and some controls may be required.  However, the landfarming notes require treatability tests to be undertaken for apparently all landfarms.  Where VOC emissions are considered by the EPA to be excessive they will need to be controlled using tents, greenhouse enclosures or covers.  ASBG is concerned the testing and performance requirements are not specified and acceptance is at the consideration of the regulator.

ASBG calls for a more holistic approach where the notes consider the material to be treated - bio-degradable hydrocarbons - and assess each available and economically viable option.  Clamping down on too hard landfarming is expected to simply transfer the problem to landfill or result in abandonment of remediation.  Ideally the outcome should be to maximise environmental outcomes than to focus on one treatment type.

Attachments:

ASBG's response to EPA's Landfarming Notes

117 kB

ASBG submission on the Independent Pricing and Regulatory Tribunal’s (IPART) Sydney Water Corporation Price Review 2012 largely focused on the substantial change to trade waste pricing. Key issues and recommendations include:

• The need to ensure continuing productivity gains within Sydney Water
• Welcome price reductions such as for the sewer usage charge, but ASBG is concerned about where the missing revenue will be recovered from.
• ASBG recommends that the substantial changes to trade waste charges a transitional pricing structure to introduce the new trade waste charges over a period of 4 years.
• Using pH as a credit off-set to assist in increasing pH in sewage.

Attachments:

Sydney Water's darft Trade Waste Pricing Policy	443 kB
ASBG's submission on Sydney Water's Pricining Proposal	248 kB