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SLR-0247-Yarra Ranges Council

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SLR-0247-Yarra Ranges Council SLR-0247 Yarra Ranges Council Enquiries: redacted PO Box 105 Telephone No: redacte Lilydale Vic 3140 d DX 34051 Call 1300 368 333 Fax 03 9735 4249 31 October 2019 [email protected] www.yarraranges.vic.gov.au Private & Confidential EPA Victoria Attention: Director of Policy and Regulation GPO Box 4395 Melbourne Victoria 3001 Dear Mr.Keely, Yarra Ranges Council welcomes your engagement in the review of the ‘Environment Protection Regulations’. Council has given consideration to and responses as attached to the relevant proposed amended changes and impacts as outlined in ‘Environment Protection Regulations – Exposure Draft’ provided by the Environment Protection Authority Victoria (EPA). Council will continue to support amendments to current legislation to improve public health and wellbeing outcomes for the community and the environment. We appreciate the opportunity to have our feedback included as part of the implementation for the final regulations. If you have any further questions or comments in relation to our feedback, please contact redacted or redacted . Yours sincerely, redacted ABN 21 973 226 012 Yarra Ranges Shire Council SLR-0247 Please find below Yarra Ranges Council response to ‘Environmental Protection Regulations - Exposure Draft’. Contaminated Land Yarra Ranges Council is supportive of the recommendations by the Municipal Association Victoria (MAV) in regards to the proposed regulations, with consideration to be given to the following: - The impacts on Councils with larger land sizes and/or complex urban and agricultural settings to improve decision making and reduce the risk of liability in the prevention, mitigation and management of contaminated land (retrospectively and newly proposed sites). This will include additional financial and resource impacts inclusive of but not limited to recognition of lost historical records, record keeping with links to geographic information systems (GIS) and the availability of specialist legal advice when required. Noise Yarra Ranges Council is supportive of the recommendations by the MAV in regards to the proposed regulations, with consideration to be given to the following: - Management of public education and promotion of responsible authorities in relation to nose complaint types. - Improved promotion of available EPA training resources, equipment and support to authorised council officers. Air Yarra Ranges Council is supportive of the recommendations by the MAV in regards to the proposed regulations, with consideration to be given to the following: - Recommend not to include PM1 as a pollutant particle, due to a lack of scientific evidence to support an additional regulatory measure. Further research is required to determine the characteristics of exposure to PM1, in addition to the independent health effects from PM1 from other pollutants such as PM2.5. Litter Yarra Ranges Council is supportive of the recommendations by the MAV in regards to the proposed regulations, with consideration to be given to the following: - Council would like to clarify the primary authority on this matter. It is suggested that all reported breaches and/or infringements would be processed through a central authority to maintain a consistent approach, and prevent repeat breaches being handled by multiple authorities depending on who dealt with the matter originally. SLR-0247 Plastic Shopping Bag Ban Yarra Ranges Council is supportive of the recommendations by the MAV in regards to the proposed regulations, with consideration to be given to the following: - Council would like to clarify the expectation on Council Authorised Officers being expected to enforce and/or report to EPA on plastic shopping bag ban breaches (e.g. Environmental Health Officer as part of routine food inspections). Waste Yarra Ranges Council is supportive of the recommendations by the MAV in regards to the proposed regulations, with consideration to be given to the following: - Section 83 requires an application for approval of electronic system for recording or providing transaction details in relation to priority waste, due to the existing systems in place within Council was ask that existing systems in place that meet these requirements and/or are used to transact with other Authorities in a like manner be exempt from an additional application process. - Clarification of Section 60(b) relating to industrial waste ‘…collection of kerbside waste by or on behalf of a council or a Waste and Resource Recovery Group’ to include transfer to and/or from waste and resource recovery facilities utilised by Council. Inclusion of this would prevent additional cost and management burden on a relatively low-risk waste stream. On-site Wastewater (Septic tanks) Yarra Ranges Council is supportive of the recommendations by the MAV in regards to the proposed regulations: - Yarra ranges council is supportive of the inclusion of Option 3 proposed by MAV requiring renewal of permits as it is current expectation of Council that initial approval of applications to operate on-site wastewater (septic tanks) does not extend to all future applications with the below consideration(s): - Addition of on-site wastewater (septic tanks) permit renewal for Councils with large areas and/or high volumes of septic tanks would incur substantially increased costs due to the need for inspections to be conducted. - Under this option Council would be required to initiate a renewal process from implementation of this recommendation, resulting in an ongoing high resource impact every 5 years, it is proposed that renewal cycles for existing septic tanks be completed at 5 year intervals from the original application/installation date to better distribute workload on relevant Council officers. .
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