MRA contributes to the discussion on Australia’s future National Waste Policy

By MRA Consulting Group

Responding to Australian Government Department of Environment and Energy’s request for feedback on priority issues to be considered in future Australian waste management and resource recovery, MRA has prepared a submission to the Updating the 2009 National Waste Policy (NWP) discussion paper.

To foster discussion within the waste industry MRA is making its submission public below. We look forward to your comments and suggestions.

Submission to NWP Discussion paper


1. Avoid Waste

Agreed

  1. Reduce total waste generate per capita by 10% by 2030:
    • Firstly, the target should be on absolute tonnes not per capita. If Government is serious about reducing waste to landfill then per capita is a misleading indicator. Total tonnes to landfill can rise at the same time per capita tonnes are falling.
  2. 10% by 2030 in total tonnes is a more meaningful target (refer later comments on Resource Recovery Streams).
  3. Why index against population growth when the overall target is to avoid waste (it isn’t avoid waste per person)? These become bureaucratic loopholes that future governments will use to wriggle out of meaningful action on waste.
  4. Yes, there should be a target to reduce waste to landfill instead of generation. Refer to the quoted EU Circular Economy Plan which includes the following verifiable and quantifiable targets:
    • Reduce landfill to a maximum of 10% of municipal waste by 2030 (that means 90% diversion of MSW by 2030). The NWP should adopt this.
    • A ban on landfilling of separately collected waste.
    • Promotion of economic instruments to discourage landfilling.
  5. Yes there should be specific targets for MSW, C&I and C&D waste set at 80% diversion from landfill by 2025 based on annual generation rates.
  6. Milestones are weak and unenforceable. They need to be SMART goals as specified in any management text. These are not.
    • “Businesses across the food supply and consumption chain become signatories… by 2019”. Which businesses? How many?
    • Per capita waste generation is not a meaningful metric and allows significant increases in waste to landfill.
    • Food waste halved by 2030 is a worthwhile goal but based on what baseline? 2018? If so what is the baseline tonnage? The National Food Waste Strategy Goals need to be explicit.
    • “Businesses implement actions to avoid waste… by 2020” is meaningless. Which businesses, how many, doing what?
    • “Infrastructure and information sharing is in place… by 2025” is similarly non-quantifiable and does not guide any form of investment or employment.
    • “Targeted consumer education strategies in place… by 2021”. Most State Governments would argue they already meet this goal. But waste generation and waste to landfill is rising in most States. Targets need to be specific and measurable.
  7. What other targets are required to meet the target:
    • Infrastructure investment target based on a gap analysis by 2019.
    • Specific MSW, C&I and C&D sorting infrastructure targets by 2019 and thereafter.
    • Specific market signals to drive diversion from landfill by 2019.
    • Legislative targets at Federal and State levels including use of the NEPM and State levy instruments to drive investment and job creation by 2020.
    • Specific purchasing policy targets for reuse of materials by 2020.
    • Specific Industry Policy for Waste and Recycling sector by 2020.

2. Improve Resource Recovery

Agreed

  1. Proposed target:
    • A national target of an 80% recovery rate from all resource recovery streams by 2030.
      1. What is a resource recovery stream? Does this mean 80% diversion of waste to landfill. If so it is consistent with many State strategies (if a little weaker). The target needs to be specific and measurable.
  2. Different targets:
    • Yes, specific targets for MSW, C&I and C&D diversion from landfill are needed
  3. Milestones:
    • What is a prioritisation framework. We have had a NEPM for 15 years on Product Stewardship. We need an EPR target list that the government sticks to and implements. Products come on and off the list seemingly at the whim of the Government of the day. There should be an agreed list that is implemented. For example batteries are on the list now but only Lithium batteries are being considered. The real issue is single use batteries (NiCad) but the major battery makers are not willing to participate. The NEPM must be used to drive EPR reform.
    • “Current EPR schemes be reviewed…by 2020”. We have had multiple reviews. We need a list that the Federal Minister agrees to and implements with the support of the States.
    • “Findings and recommendations of the PSA review be implemented by 2020”. If it includes a specific list of products and actions then agreed.
    • “Photovoltaic panels and batteries… by 2020”. Agreed if it includes single use batteries and not just Li batteries. What about all the other necessary products: LDPE single use packaging, cigarette butts, mattresses, e-waste, etc?
    • “100% packaging designed to be recyclable… by 2025”. Agreed but just because it is recyclable does not mean it will be recycled. There needs to be a specific target for recycling of these materials by 2025 which includes NEPM enforceable undertakings and penalties.
    • Policy and Regulation – yes prioritisation of transport of waste, EfW, Levy and Regulations for waste would be useful. Reclassification of waste across all of the jurisdictions is difficult and will divert resources. This should be a subservient objective to the others.
    • Priorities for common national standards and specifications – for what? Recyclable products? If so yes but it should be done by mid 2019 and is not a difficult task.
    • Common approach to classifications for data and reporting is worthwhile but again is a subservient priority as it will consume a lot of resources and may require States to amend planning and legislative schemes. This is unlikely. The Federal Government should align its reporting to the majority system used by the States. This means not including Fly Ash, Hazardous waste in general waste data and not discounting gas capture from landfill disposal tonnages (as the Commonwealth alone does). MRA has written on this elsewhere.
  4. Other actions:
    • Infrastructure needs assessment to achieve the target.
    • Market mechanisms required to achieve the targets.
    • Bans on materials to landfill to achieve the targets.
    • Infrastructure investment mechanisms particularly for FOGO, MSW, C&I and C&D mixed waste sorting, EfW, PEF/RDF and processing technologies.
    • Consistent planning schemes and approvals pathways for waste infrastructure.
    • Planning mechanisms to protect existing waste infrastructure from encroachment.
    • Government purchasing policies to create market pull.
    • Meaningful national targets to drive State /LG reform.
    • National Carbon and Emissions targets that drive recovery of materials to the Circular Economy and emissions reductions.
  1. Who should be responsible?
    • All governments need to have a consistent approach to targets, regulatory and market mechanisms.
    • Business and community will invest and act when Government is clear on the objectives and targets. It is the right and proper role of Government to set the strategic direction. Once set Governments need to ensure the right policy mechanisms are in place to allow business and the community to invest and engage.

3. Increase use of recycled material and build demand

Agreed

  1. Target:
    • Agreed target. This will require legislation.
  2. Other targets:
    • EPR schemes need to be legislated via the NEPM for specific materials.
    • Minimum standards for commercial and construction sorting of 80% recovery.
  1. Strategies and milestones:
    • “Recycled content by 2020” – agreed. What streams, what targets?
    • “National waste account” – agreed.
    • “30% recycled content in purchased goods” – agreed. Needs to be specific.
    • “Review regulatory barriers by 2020”. Should be mid 2019. It is simply a review.
    • “Innovation in resource recovery and manufacturing” – is not specific. Needs clarity.
    • “National standards” – agreed. Glass, plastic, fibre etc.
    • “National Packaging Targets” – agreed but backed by the NEPM regulations and enforced.
    • “Standardised national product labelling” – must be mandated across all businesses.
    • “Sustainable procurement policy for businesses” – will permit free-riders unless backed by regulation.
    • “30% recycled content in goods purchased by business” – how will this be enforced? It requires a NEPM to ensure free-riders are limited.
  2. Other actions:
    • Grants by Governments based on landfill levy raisings.
    • Increase the landfill levies to a consistent $100/t in real terms across all States (ex. NSW).
    • Maximum hypothecation.
    • Plan reprocessing infrastructure – what, when and where.
  3. Who should be responsible?
    • MEM needs to set the policy and regulatory framework. Industry will then invest.

4. Better manage material flows

Agreed

  1. Targets – agreed.
    • It is unclear what “problematic and unnecessary plastics” are. Single use plastic packaging? Food packaging?
  2. Other targets:
    • C&I sorting and recovery target.
    • C&D sorting and recovery target.
    • Specific stream targets for problematic streams such as batteries, gas bottles, etc.
  3. Strategies and milestones:
    • Targets for problematic single use plastic – very motherhood. Which plastics? How?
    • Prioritise by 2020. This should be done first and by early 2019.
    • 100% microbeads phased out. If they are causing pollution now (which they are) they should be banned under existing regulatory measures e.g. POEO in NSW. Why have a 5 year phase out for one polluting activity and not for others. There are many substitutes already known. Industry will always take the phase out option if offered by Government. Ban from mid 2019.
    • Problematic unnecessary single use plastic packaging phased out through redesign etc by 2025. This is unenforceable and subject to interpretation. What does Problematic mean? Which plastics? Meaningless as an action or a target.
    • Chemical regulation – agreed. But what does the milestone mean. Cannot be defined never mind measured and enforced.
    • Better manage import etc. of hazardous substances? What problem is this trying to fix. There are already regulations for the import and export of hazardous waste. This needs to be specific.
    • Reduce exposure to chemicals and waste etc. – agreed. What? Needs to be specific.
    • Review Haz waste framework by 2020 – agreed.
    • Identify priority hazardous substances national plans – agreed.
    • Divert batteries from landfills through product stewardship – agreed but why only batteries? Why not all other hazardous waste streams including soil injection of liquid wastes, sewer discharge of metals and paint, plasticisers in the environment, PFAS etc.
    • Businesses across the supply chain become signatories to voluntary food waste reduction by 2019. This is not sufficient. MEM should adopt a ban on commercial organics to landfill by 2019 along the lines of Seattle or San Francisco and most European jurisdictions. If a food generator (restaurant etc) generates more than 300kg per week then they must have a dedicated food collection service.
    • “Work underway to better manage organics material by 2020”. This is a target that can neither be measured nor enforced. Specify FOGO collections, C&I food collection services. Specify the Percentage Diversion expected for each stream by 2020.
    • “25% reduction in organic waste sent to landfill by 2025”. The goal is right but the target is too weak. 50% would be readily achievable with MEM guidance and action.
  4. Other actions:
    • Again the NWP needs to encompass the main issues facing waste in 2018. This document needs to address:
      1. Organics diversion from landfill.
      2. C&I sorting systems.
      3. C&D sorting systems.
      4. PEF and RDF.
      5. EfW.
      6. Market based signals to drive recycling and diversion from landfill.
      7. Emissions controls from existing landfill stock, future emissions reductions.
      8. Planning and approvals.
      9. Statutory nature of waste management as an essential service.
      10. Coordinated planning via agreed governance arrangements between the States and Commonwealth.
  1. Who should be responsible?
    • MEM needs to agree and set a policy direction for waste and recycling in Australia.
    • The absence of a clear strategic direction means different jurisdictions are going in completely different directions and at different speeds.
    • European systems such as bans on organics to landfill need to be implemented along with regulatory drivers to ensure reuse happens. Laisse faire management of waste has had its day. It is time for government to step up and drive the process. Industry has been calling for government action and direction for over two decades. Governments have largely failed to take up the challenge.

5. Improve information

Agreed

  1. Target – agreed. However the methods used by the Commonwealth do not match those of most States and need to be regularised (via a smart portal and not trying to redefine all waste classifications in the country).
  2. Other targets.
  3. Strategies and milestones:
    • Biennial National Waste Reports – agreed.
    • Options for production of infrastructure trade and market info. This does not need an options study. It is obviously required and should be implemented. This should include an independent commodity value index which can be adopted in Council MRF contracts to reflect international commodity prices.
    • Data and reporting improvements by 2020. This is not a target. Needs to be specific.
    • Review existing recycling data collection methods by 2020. Should be done by 2019.
    • Analyse barriers for goods containing recycled content by 2018. Agreed.
    • Improve support for innovation by 2025. Agreed but again should be 2020.
  4. Other actions:
    • Commonwealth should adopt reporting protocols of major States.
    • Stop reducing tonnages to landfill based on gas capture rates (illegal in all States).
    • Stop including Ash and Haz waste in national data. These are outside all major State waste protocols.
    • Agree standard data sets to be reported by local government and States.
    • Require mandatory weighbridge data from all licenced sites in Australia (including recycling facilities).
    • Introduce another category of EPA licence for small facilities (below the existing licensing threshold) requiring mandatory reporting of tonnages. This will provide a comprehensive waste reporting and data-base system for Australia at low cost.
    • Fund the ABS to develop a long term waste dataset. State reporting in currently haphazard and often late or incorrect.
    • Eliminate the 4 year lag between actual and reporting.
  5. Who should be responsible?
    • MEM and State EPA’s.