AEBN responded to the NSW Department of Environment and Climate Change’s (DECC) document Regulatory Impact Statement Protection of the Environment Operations (General) Regulation 2008. AEBN welcomed the opportunity to comment, however, public comment was for the minimum period.
AEBN is concerned the science used to add new substances and industrial sectors to the POEO General Regulation is flawed. DECC based these changes and expected revenue increases on National Pollutant Inventory data, which is widely know for having errors out by more than 100 times. AEBN recommended the regulation include an exemption clause to permit sites with low ($500) Load Based Licensing fees to be able to discontinue their measurements. Members report to AEBN that LBL measurement costs can be 100s of times higher than the load fee. Load fees below $500 are considered environmentally insignificant and should be discontinued.
