Submissions

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.

ASBG supports the overarching principles of the proposed changes to the National Environment Protection (Ambient Air Quality) Measure (AAQ NEPM), but identifies a number of issues with the approach and future directions especially how the AAQ NEPM will be used.  A key issue is that AAQ NEPM standards are routinely incorporated in jurisdictional planning and operational conditional policies. When inserted they are often applied as impact limits on industrial sites, not as ambient standards as the NEPM requires.  Application is not limited to new sites, but is increasingly being applied to existing sites, ignoring grandfathering, which has been a cornerstone of air pollution control in the past.  ASBG considers this practice, which considerably tightens the standards, needs to be recognised and considered in the AAQ NEPM variation.  An effort was made to identify the way in which the AAQ NEPM standards are enforced with industrial sites being subject to the tightest application, in contrast to for example wood heaters which are barely addressed as a pollution source. Also addressed is the exemption of prescribed burns which is increasingly being identified as a double standard.

ASBG prepared its submission on the draft Guidelines: Pollution Incident Response Management Plans (PIRMP). Overall the Guidelines are an improvement over the current version with a much clearer set of what is expected from PIRMPs well explained. However, a major issue was raised with the literal interpretation that any pollution incident should result in retesting and updating of the site's PIRMP within 30 days. ASBG considers the Guidelines are an opportunity to interpret the meaning of s98E(2)(b) POEO (General) Regulation to mean incidents that are Material Harm. Another related issue is interpretation of what should be involved in a PIRMP update. ASBG argues the PIRMP is primarily an incident response plan and should only deal with upstream risk issues limited to management practices and not engineering and process changes.

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