Review of the load-based licensing scheme
Submission on the Review of the load-based licensing scheme – EDO NSW submission
January 2017 – Download PDF
This is a technical submission structured around the questions asked in the Issues Paper. In our submission, we focus on the role of an effective load-based licensing scheme, pollutants covered by the scheme, and ensuring fees for the scheme are set in a way that will drive pollution reduction.
We also note that there are currently few policies or programs in NSW that adequately regulate cumulative impacts, and many industrial discharges are permitted at levels that are known to be above safe levels for human or environmental health. As a result, the NSW pollution management system, including the load-based licensing scheme, still falls significantly short of ensuring appropriate environmental protection. This review provides an opportunity to address some of these concerns.