Submissions
ASBG has responded to the Protection of the Environment Legislation Amendment Bill 2011, which imposes considerable new punitive conditions on business and industry in NSW. Under this Bill companies are required to immediately report environmental incidents of material harm (>$10,000). Changing 'as soon as practical’ to 'immediate' introduces considerable new liabilities, make it very difficult to comply with, will substantially increase compliance costs and may even detract from better environmental protection.
ASBG submission to the Minister appealed for the introduction of a new alternative incident reporting action called 'Serious Environmental Incident'. This new approach will drop the $10,000 harm trigger, but be limited to a list of chemicals and substances which are of community concern. In addition, Serious Environmental Incidents will require immediate reporting or within in one hour. Use of one hour is in line with the O'Reilly Report, which unfortunately was not adopted within the Bill.
The Bill also introduces many new conditions such as:
- Requiring all Licensed monitoring data be posted on company websites.
- Empowering the EPA to undertake health and environmental risk analysis at the reporting company's expense
- Legislating that all Licensed sites develop, train and implement incident action plans.
The Australian Sustainable Business Group (ASBG) commented on the Clean Energy Legislation Package (CELP).
ASBG supports the government’s approach in establishing price on carbon and other greenhouse gases to reduce Australia’s emissions of greenhouse gases. Overall the thrust of the CELP is supported, however a number of concerns also arise. To improve the CELP’s approach ASBG recommended the Government:
- Re-consider the initial set price and fixed trajectory prices favouring a lower start price
- Provide a better transition program from the set price to the floating price and undertake further investigation into this transition.
- Additionally, ASBG is concerned over the risks to the CELPs revenue streams after the price is floated and carbon liable companies can purchase upto 50% of credits from overseas sources.
- Re-evaluate the grant programs to ensure these better reflect and support the lowest cost emissions reduction programs during the long transitional period towards the long term emissions reduction targets. ASBG is concerned the grant and assistance package is too heavily focused on renewable technologies.
- Support for the National energy Savings Initiative.
 ASBG's submission on the Clean Energy Legislative Package 2011 | 222 kB |
ASBG responded to the Discussion Paper, Proposed changes to the Energy Efficiency Opportunities (EEO) program assessment and reporting requirements with clarification of the second cycle.
Overall ASBG was disappointed with the discussion paper as it proposed further expansion of the Key Elements and other compliance requirements under the EEO program. Streamlining not increasing the burden should have been the outcome of this review. EEO is already an inefficient and costly way to achieve its energy efficiency outcomes. ASBG believes the proposed additional complexity will do far more to add to compliance costs than serve to identify viable projects. Adding further complexity will undermine the value of the program to businesses and organisations.
Members consider the EEO program is good at identifying cost effective energy efficiency opportunities, but is very inefficient in its process of finding and evaluating viable opportunities.
A number of suggested improvements were provided such as undertaking economic viability vetting of projects at the start to remove unnecessary documentation and processes. Also removing the disincentive where the documentation proportionally increases with the number of energy savings projects identified.
ASBG recommended replacing the current set of proposals with a process of streamlining the EEO system with full consultation from the reporting companies.
| ASBG Sub EEO Review 2011 | 136 kB |
This submission covers DECCW's NSW Waste Avoidance and Resource Recovery Strategy, Discussion Draft: Strategic Directions and Implementation Plan 2011–2015 (the Plan). and also the recently released Richmond Review of Waste.
ASBG also includes attached to this submission our NSW Waste Policy which specifies our members views on the future direction of the management of wastes in NSW.
Overall the Plan left out many of the Richmond reviews enhancements, which were largely supported by ASBG. In addition ASBG supplemented and identified additional issues captured by the Richmond review. It is anticipated that most of the Richmond review and ASBG recommendations will be taken into full consideration. Other Key points raised includes:
- Need for improved consultation with business — a separate stakeholder.
- Examples are provided where red tape dumping can be reduced by further discussion with businesses.
- The need for more certain planning outcomes for waste infrastructure, e.g. special planning zones for landfills, Energy-from-Waste (EfW) plants and other waste infrastructure.
- The need for new landfill capacity.
- Support for a national one-stop-shop on standard waste data, collection, measurement and definitions.
- Issues with the waste levy including:
- Little allocation of levy moneys back to support waste management.
- Its negative impacts on the recycling industry and this sector’s need for a support program to counter the impacts of the increasing levy.
- Interstate cross boarder movement of wastes driving other jurisdictions to increase their levies to match or exceed NSW raising further economic inefficiencies in waste management.
- Increased support from levy funds for waste streams in proportion to their levy revenues.
| ASBG's Submission on DECCW's Waste Plan 2011-15 | 622 kB |
The Environment Protection and Heritage Council (EPHC) invited submissions on the largest change in over 10 years on the Assessment of Contaminated Sites National Environment Protection Measure (ACS NEPM). The changes are a doubling of the current ACS NEPM which is the most comprehensive and complex NEPM.
ASBG raised a number of issues which are summarised as:
- Consultation on the NEPM its Schedules and supporting documentation
- Overview of the impact of the total changes on businesses including:
* Sampling and investigation implications
* Risk assessment
* Auditor implications - Aesthetics its reference and usage.
ASBG's main recommendations focused on improved education about the NEPM, the expected increased demand for site auditors and clarity issues in the application of asethetics in site assessment.
| ASBG Submission on the ACS NEPM | 161 kB |
