Submissions
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 |
The NSW Government tabled in parliament the Protection of the Environment Operations Environmental Monitoring Bill 2010 on 24 September 2010. This bill enables the Environment Protection Authority (EPA) to place a levy on Environmental Protection Licence holders for undertaking additional monitoring.
The bill permits the EPA or the Minister to initiate is own investigation for the need for a monitoring program to consider impact on human health by licensed sites. Licence holders whom the EPA considered appropriate are then hit with a monitoring levy to pay for environmental monitoring programs including:
- The costs of investigating the need for a program,
- The development, implementation, operation and administration of,
- Any costs incurred by the EPA before the commencement of this bill
- Payments by the EPA for services provided by a person undertaking environmental monitoring programs for the EPA
Money collected is then placed into the Environmental Monitoring Fund (EMF) for use by the EPA. Any environmental monitoring will be required to have an independent assessment on its efficacy and its economics.
ASBG’s issues with the bill include:
- Inefficient – handing over the implementation and operation of such monitoring to the EPA rather than the current outcome based approach used in Environment Protection Licences
- Redundant — all the monitoring and more can be legally managed under licence conditions
- Undermines Licensed site’s rights of negotiation and appeal on such issues
- Retrospective — s295Z(4)(a) states … including any costs incurred by the EPA before the commencement of this Part.
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| ASBG's Letter on the POEO (EM) Bill | 115 kB |
Subject to a COAG requirement the Environment Protection and Heritage Council (EPHC) is undertaking a Review of Harmonisation of Environmental Regulation across Australia. This is being run jointly by the NSW and Victorian environmental agencies, of which the Department of Environment, Climate Change and Water invited ASBG to provide comment on the scope of this review. The main issues ASBG put forward for inclusion in the scope of the review includes:
- Environmental reporting; streamlining, duplication reduction and harmonisation.
- Standardisation of: measurement, monitoring, accounting, verification across the following areas:
- Greenhouse emissions
- Air emissions (other than greenhouse)
- Water
- Waste
- Land
- Harmonisation of waste issues including: measurement, data collation, waste management type and improving the design of waste levies.
- Improvements to licenses, authorities and permits.
- National recognition of specific processes and systems which are Nationally recognised as best practice to assist in controversial projects.
- Pathways and timetables to address these issues.
ASBG looks forward to the next phase of this review and the possible processes that can be included to really improve the above issues for members, especially environmental reporting.
| ASBG's Response to EPHC's Harmonisation of Enviro. Regulation | 152 kB |
