Submissions

Submission on NSW’s draft Major Hazards Facilities Regulation

AEBN raised concerns over the full cost recovery from MHF sites for the operational costs of the government’s MHF Unit. Fees of over $50,000 p.a. were exposed as being inequitable and undermining NSW as a state for investment for major facilities. ...Read More

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. ...Read More

Submission COAG’s Greenhouse Gas Mandatory Reporting Scheme

In a similar process to the NPI COAG is establishing a mandatory greenhouse reporting Scheme. AEBN identified a number of issues for COAG to consider especially the extreme under estimation of the cost to companies in reporting to such a scheme. An estimate by COAG of $2,100 per company was considerably lower than AEBN member feedback of between $40,000 to $50,000 per site! ...Read More

Submission on the Possible Design for a National Greenhouse Gas Emissions Trading Scheme discussion paper

This discussion paper proposes a cap and trade greenhouse gas trading scheme for Australia. While AEBN does not support a trading scheme at this stage, the likely hood of its introduction promoted the submission and recommendations. ...Read More

Submission On the Productivity Commission’s Draft Waste Review Report

AEBN’s largely supports the Productivity Commission’s views on the way in which waste is handled by government policy. However, there is too much momentum behind the current poor waste strategies, which will cost Australian’s more and may also lead to perverse outcomes where environmental harm is increased. ...Read More

Submission On the Water and Energy Savings Plans

AEBN recommended that increased flexibility be the main amendments to the new Water and Energy Savings Plans that applies to site that use over 50 ML/year and 10 GWhrs/year of energy at stationary sources. These plans will over time apply to smaller sites and require many companies to commit to savings targets on water and energy consumption. ...Read More

Submission On the Protection of the Environment Operations Amendment Bill

AEBN recommended keeping the 4 to 5 fold increase in fines levels to a doubling of fines. The 16-fold increase in noise fines should be limited to only where the offensive noise is a health issue. AEBN expressed concern over the proposed Pollution of Land offense, which is extremely broad. ...Read More

Submission On the Assessment of Site Contamination NEPM

AEBN supports some the main issues identified in the discussion paper on the use and abuse of the NEPM. Too often jurisdictions have used the investigation criteria for clean up levels, which in most cases is too conservative. ...Read More

Submission On the National Packaging Covenant Mark II

AEBN is a supporter of the National Packaging Covenant (NPC). The Mark II NPC represents a substantial change especially in…[Read More]

Submission On the 7th Edition Australian Dangerous Goods Code

AEBN’s comments focused on the generic definitions of class 3 flammable liquids, class 8 corrosives and class 9 miscellaneous. AEBN called for simpler means in which to assign a UN NOS number to a waste. ...Read More

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