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Monday, 4 July 2016

EPA update - Monetary Benefit Orders from the Court


Increasing the courts power to impose higher financial penalties on environmental offenders

Under section 249 of the Protection of the Environment Operations Act 1997 (NSW) (POEO Act) the court has the power to

“order the offender to pay, as part of the penalty for committing the offence, an additional penalty of an amount the court is satisfied, on the balance of probabilities, represents the amount of any monetary benefits acquired by the offender, or accrued or accruing to the offender, as a result of the commission of the offence.”

Monetary benefits means monetary, financial or economic benefits.

The amount that the court may order an offender to pay is not subject to any maximum amount. However, the regulations may prescribe a protocol to be used in determining the amount that represents the monetary benefit acquired by the offender.

Currently there is no protocol identified in the regulations that deals with monetary benefits.

However, this may be about to change.

The NSW Environment Protection Authority (EPA) is looking to develop a protocol, through consultation with industry in the near future. This will include the creation of a calculator for determining the quantity of the monetary benefit.

This could mean that courts may be able to impose much higher penalties on offenders depending on the circumstances of the offence.

Recent example that may have been caught

In 2015 the NSW Land and Environment Court found that a former waste operator and two of his companies were guilty of offences for the unlawful transportation of waste and for using a property as an unlawful waste facility.

See Environment Protection Authority (Prosecutor); Foxman Environmental Development Services (Defendant); Botany Building Recyclers Pty Ltd (Defendant); Phillip Foxman (Defendant) [2015] NSWLEC 105 at


The commission of these offences caused the Defendants substantial financial gain.

The introduction of a protocol within the regulations may, if drafted appropriately, increase the courts power to impose higher financial penalties on environmental offenders who benefit from the commission of an offence.

At this early stage, there still remains the next important question of what will happen with any money that is obtained through the potential protocol.
If you would like to discuss any aspect of this, please contact Kim Glassborow (Partner) G&B Lawyers on M: 0481 287 528.



G&B Lawyers

Office: Suite 1, Level 1, 229 Macquarie Street, Sydney, NSW 2000

Mail: GPO Box 1849, Sydney, NSW 2001

M: 0481 287 528

E: info@gandblawyers.com.au

W: www.gandblawyers.com.au





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