Submission On the Review of the Protection of the Environment Operations (General) Regulation

The DEC invited AEBN to provide preliminary views leading up to the main review of the POEO (General) Regulation 1998 next year. The POEO (General) regulation is the primary law that enables the Load Based Licensing Scheme.

AEBN’s submission recommends, among others, that a new approach to air pollution issues should be implemented, attacking peak levels rather than continue to tightening industry emissions and taxes. Also recommended is a $10,000 threshold, above which current LBL measurement practices be used. However, below $10,000 cheaper estimation techniques be used as it is common for measurement to cost more than the load fees.

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