Submissions

ASBG commented on comment on the Council of Australian Government’s Banning exports of waste plastic, paper, glass and tyres discussion paper.
In general ASBG considered the Waste Export Ban somewhat confusing in how it will achieve the outcomes consistent with the National Waste Policy's circular economy principles. ASBG members indicated the WEB will simply result in much of the exported recyclates being landfilled in the short term. Paper and cardboard is most affected with 1.2 MT being currently exported and with the closure of Australia largest newsprint mill in Albury, about half of old newspapers will only be recyclable overseas.
ASBG recommends modifying the value-adding criteria to recognised bona fide recyclate which has a positive value and meets international standards and country acceptance criteria as being products and not wastes.  This is supported by the Hazardous Waste (Export and Import) Act which defined waste as materials to be disposed of.  The Commonwealth may also play a gatekeeper role where export countries with suspect environmental credentials require additional assessment and approval.

ASBG took the initiative in preparing a submission to the EPA requesting clarification of how the on-site / off-site rule operates.  Put simply this rule means material only becomes a waste once it has been taken off site.  Consequently, materials moved and or stockpiled for clean up, remediation, demolition, unexpected finds etc, are not considered waste and can be further processed and used on site under WHS and Contaminated land management laws not subject to waste laws. Considering the recent findings of EPA v Grafil case and a high variation of its interpretation among various EPA officers there is much confusion over how this rule should operate and where are its boundaries.  For general remediation, earthworks and demolition work, classification of on-site materials as waste would make construction a far more complex, unnecessarily so in ASBG's opinion. The submission identifies what is believed to be the on-site / off-site rule, what is meant by on-site or a site, and where there are many gray areas.  A series of case studies is used to assist the EPA tease out where the boundaries sit.

ASBG submission on NSW's 20 Year Waste Strategy focuses on the current generally NSW policy led legislation and policy actions which are filling NSW landfills faster than ever.  The need for new waste infrastructure is critical especially landfills which offer a safety valve if diversion approaches fail to perform.  Energy from Waste plants are also considered an important component to better managing NSW's wastes into the future.  ASBG also supports greatly expanded recycling, but the end markets for such products must be first identified.  Two key areas that will make a difference is downcycling and reduction of contamination to meet export market requirements.  While recycling back to a raw material is to be encouraged, such actions have in the medium term limited application in NSW.  Recycling also has an environmental limit; when the recycling requires more natural resources than to make it, such collected material is far better off being downcycled including incineration or perhaps landfilled. ASBG also reviewed the Waste Levy and found only 19% is dedicated to waste management. Since business and industry contribute 65% of the levy, a similar percentage of grant moneys should be allocated back in proportion to the levy paid if real landfill diversion is the goal.

ASBG generally is quite supportive of the Consultants reporting on contaminated land: Contaminated Land Guidelines.  A few issues raised included the preferred keeping of the four stages for assessment and remediation of contaminated land rather than going to a seven stage framework.  The three additional stages can be easily incorporated into the main four stages as required additional information.  ASBG considered moving to a seven stage process would confuse many involved in the property sector, insurance agents and financiers than the current four stage framework which is also similar to the US EPA's approach.  There were also a few issues with the need for detailed technical reports for major remediation projects using treatment processes on site.  It requirements were loosely related to a risk based approach, but could lead to excessive details which may not be required or proportional to the risks posed.

Preparation of Queensland’s EfWP is a golden opportunity for Queensland not to go down the narrow path that NSW EPA has with its EfW.  ASBG’s submission was largely about avoiding a one rule fits all approach and permit flexibility in its EfW.  Multiple examples are provided where and MSW style EfW rule set would prevent many innovative and alternative EfW projects getting started.  Manufacturing can often use fuel/raw material additives in thermal process, which ASBG considered can be largely covered by Queensland’s existing End of Waste Codes instrument.

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