Submission National Pollutant Inventory Variation Submission

AEBN supported the proposed name change for the National Pollutant Inventory (NPI) to the National Emissions Inventory. The main issue addressed was the proposed inclusion of transfers. Transfers include the NPI substances that appear in waste and wastewater streams set to another party who usually treat or dispose of the materials.

AEBN considers there are 2 types of approaches to generate NPI data for transfers, both of which are undesirable. As wastes a notoriously variable the use of estimation techniques, based on a handful of analysis will provide meaningless data. If on the other hand NPI data was collected to a meaningful level, this would be very costly and lead to the export of Australian jobs.

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