To: |
Local Government and Environment Committee
Bowen House, Parliament Buildings, WELLINGTON
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From: |
Community Recycling Network Aotearoa New Zealand
P O Box 109
Whaingaroa Raglan
PH: 07 825 8246
[email protected]
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Date: |
1st September 2006
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Submission: |
To the Waste Minimisation (Solids) Bill
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Statement: |
I wish to present this Submission and appear in front of the Select Committee. I invite the Committee to come to Whaingaroa Raglan (or closest centre) and witness for themselves a working example of a community in action. I believe a tour around Xtreme Waste Inc Soc of Whaingaroa Raglan will provide them with that opportunity.
Susa Kupa
Coordinator
CRN |
Executive Summary
1. Community Recycling Network - CRN - Who or what are we?
2. The Waste Minimisation (Solids) Bill
Part 2: Waste Minimisation Authority
Part 3: Waste Control Authorities
Part 4: Prohibition on disposal of materials
Part 5: Waste disposal levy
Part 7: Organisational waste minimisation plans
Part 8: Public procurement policy
Part 9: Public Reporting
Part 10: Regulations
Appendices:
1. Signed Up Full Memberships
The Community Recycling Network has been formed to foster the community sector of the waste industry and to share our wealth of experience on matters of national concern in relation to waste; generation, production, reduction, diversion from landfill.
CRN believes that the Waste Minimisation (Solids) Bill provides an opportunity and solid platform for much needed discussion on all matters pertaining to waste.
We welcome this!
Modern society has inherited an ethos that has enabled a 'waste culture' to emerge from the 20th Century. With little regard or foresight into the future our production and waste generation habits have been linear in approach rather than mirroring nature and the environment in which we live, which is cyclical.
Our society and economy are dependent on a healthy environment. The way we deal with waste generated through consumption, manufacturing and processing patterns have a direct bearing on our capacity to live sustainably.
The future of Aotearoa New Zealand is threatened by climate change and biodiversity collapse. Members of CRN believe that we must all take collective and cohesive action and set the necessary procedures in place to ensure the safe future for generations to come.
Waste is a social issue! We generate it on a daily basis yet we seem to have lost our connection with it, with nature, with living as a part of our environment rather than separate from it.
In 2002 Aotearoa New Zealand saw the publication of The New Zealand Waste Strategy Towards zero waste and a sustainable society. This document was a good example of inclusive governance. It built up trust in, and commitment to, our democratic processes and provided guidance to the nation on how to go about addressing the growing waste crisis ever present throughout our beautiful country.
Zero Waste is a movement that sprouted from Aotearoa New Zealand. The movement has taken shape internationally and many countries now look at Aotearoa New Zealand for guidance on how to navigate their way to zero waste.
We are the nation with a very successful internationally marketed 'Clean and Green' brand that cost millions and made millions. The tragedy is if we don't make serious change now in the way we produce and reduce waste, what we will lose will be far more valuable than dollars could ever buy.
This Bill will have consequences for the future that cannot be perceived today. The members of CRN are 'excited' that this opportunity has been presented and we trust that those elected with the privilege of navigating procedures over the next few months will do so with the integrity and honour that has been bestowed upon them by the people of Aotearoa New Zealand.
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Aotearoa New Zealand's Community Recycling Network (CRN) has been established to further strengthen existing and emerging community based groups involved in recycling, reuse, composting, waste reduction and waste education activities.
CRN does this by:
- Providing support to communities dedicated to improving their environment and their local economy by treating waste as a valuable resource
- Acting as the main point of representation and contact for community enterprises actively involved in the waste management and mimimisation sector
- Enabling the community sector to have a stronger voice and role in the future of waste minimisation and recycling in New Zealand
- Fostering working partnerships between its members and local authorities and businesses working towards Zero Waste
- Providing development support and advice to member organisations, particularly in terms of business advice, training, mentoring and market development
Currently, CRN represents 24 community waste enterprises and has 'commonalities' with a further 15 or so community groups associated with waste reduction and waste education activities.
CRN membership is broad spanning the length and breadth of the country from Invercargill to Kaitaia. Our membership organisations differ in length of time established from 16 years (Community Business and Environment Centre - CBEC) to individuals who are yet to formalise their group eg: Greymouth.
Social
CRN membership compiles community enterprises throughout the country who often address more than the simple day to day management of waste. Built with the pillars of quadruple bottom line accounting; social, cultural, environmental and economic, each group make available opportunities to people that other organisations are often unwilling to provide.
This can include skills training opportunities provided to youth or long term unemployed, meaningful work to people with intellectual disabilities or people experiencing mental illness who sometimes find the rigors of full time employment too overwhelming. Community waste groups also frequently offer opportunities for people to volunteer their time and skills and in one of CRN's organisations over 100 volunteers are registered.
This is certainly not to say that people with professional backgrounds do not work for the groups that CRN membership assembles. Successfully managing community enterprise is a fine balance between measuring economic costs with environmental impacts. This kind of work requires business nouse with dexterity in human resource management combined with a passion for environmental preservation. Tertiary qualifications in economics, ecology, engineering, psychology, design, education and business management can be attached to any number of staff who have chosen to work for community waste groups past and present.
Community groups tend to operate on the economic fringes, where commercial operators cannot make the 'rational' economic decision and take on what appears to be a loss making venture. It is extremely difficult to borrow money to establish infrastructure with a business plan that shows only social, cultural and environmental profit. Some groups handle standard materials in areas where distance to markets and low population density make service provision theoretically unviable. Others take on many marginal product lines that in themselves do not turn a 'profit'.
Environmental
The environmental pillar is often an important objective for members of CRN and this includes motivation to divert as much waste from landfill as possible. Xtreme Waste in Whaingaroa Raglan is perhaps one of the best examples New Zealand has of waste diversion with a consistent 70% diversion rate achieved yearly over the last five years.
Cultural
Planting native trees along riparian stripes carrying leachate from landfills to larger water bodies is another example of an emphasis of environmental and cultural preservation important to community waste groups. Monitoring water and soil quality along these streams and in harbour's from where kai moana is taken has indicated surprisingly low levels of toxins evident and highlights significant purification and natural filtration exercised by the planting.
Economic
Because of community involvement we often manage to divert from landfill a higher proportion of waste than any other sector. Our work is aimed at fundamental change and our unique ways of communicating and delivering services to our customers offer real solutions and opportunities for participation in household and business waste reduction. There is a strong sense of association with, and local ownership of, community enterprise.
Because of community involvement we often manage to divert from landfill a higher proportion of waste than any other sector. Our work is aimed at fundamental change and our unique ways of communicating and delivering services to our customers offer real solutions and opportunities for participation in household and business waste reduction. There is a strong sense of association with, and local ownership of, community enterprise.
However, despite one of the NZWS waste minimisation targets stating that 'ninety-five percent of the population will have access to community recycling facilities by December 2005' (pg23 NZWS), very little effort has been done to insure the facilitation of this target at either central or local government levels. Consequently, far less than 95% can presently enjoy the benefits of accessing community recycling facilities and community waste organisations continue to 'struggle' about their business.
Ensuring the overall sustainability of managing a community owned and operated enterprise is an enormous challenge especially when inserting this model of business into a commercial context shrouded in the economic paradigm that is capitalism. Traditionally, industry has placed emphasis on single economic bottom line accounting and with an objective to produce as much as possible motivated almost exclusively by economic benefits. Often this production has been at the cost of the environment.
Increasing pressure of consumerism over the last 50years exacerbated by forces of globalisation has resulted in massive increases in waste volumes. And although it is difficult to judge just how quickly New Zealand's waste problem is growing because of poorly collected data, incomplete dumping statistics and inconsistencies, in the Auckland region where data has been collected since 1983, an increase in waste disposal to landfill can be seen of 73% per person (NZWS).
CRN recognises that the way industry goes about doing its business is changing. That large companies like The Warehouse now report annually using triple bottom line accounting indicates leadership and commitment to reducing environmental impacts imposed through its commercial operations.
Is the drive to 'increase sales' the way to 'zero waste and a sustainable New Zealand'?
Many of our recycle centres on-sell cheaply made unwanted items initially purchased at The Warehouse.
In locations where there are no recycle centres what happens to those unwanted resources?
Mixed waste dumped into landfill 50 years ago is already having imposing negative impacts on our soil and waterways throughout Aotearoa New Zealand. In the future, water will be the most valued resource on Earth. This Bill gives us a chance to correct the legacy we will leave the people of the future if change is not implemented now.
The Waste Minimisation (Solids) Bill provides an opportunity for all producers and managers of waste to address the looming waste crisis evident in the increasing mountains of rubbish growing throughout this country.
CRN believes that this Bill is a timely platform on which to build strategic discussion and performance regarding the future management of waste.
This submission has been composed with contributions from many of the groups CRN represents. In particular seven elected Executive Committee members have guided the composition of this submission.
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CRN supports in principle the establishment of an Authority dedicated to facilitating waste minimisation at a national level. We agree that a Waste Minimisation Authority has the potential to offer real guidance and direction to the swiftly growing industry that has become less about waste management and more about resource recovery.
Given the increased volumes of mixed resources or 'waste' mounting up throughout Aotearoa New Zealand presently, an Authority similar to the Energy Efficiency Conservation Authority (EECA) in organisation or Zero Waste South Australia (a State Government agency created July 2003) may be the direction Aotearoa New Zealand needs to champion a new approach to waste separation and resource recovery in this country.
Until now New Zealand has lacked any real 'authority' responsible for monitoring waste generation and yet our rubbish continues to mount. An official Authority to monitor waste reduction could ensure sturdy implementation of the targets set in the NZWS.
The New Zealand Waste Strategy
The NZWS although receiving its share of 'flack' since its publication, at the time set a new direction for the reduction, resource recovery and better management of waste in Aotearoa New Zealand. Its vision and principles are in keeping with those held by many New Zealanders, that New Zealand become a zero waste and sustainable society in the future and a 'society that values its environment and resources' (pg 19 NZWS).
However, the vision where 'people in such a society would use all resources efficiently and at a sustainable rate', where they would 'no longer regard waste as inevitable, or see it as someone else's problem' may appear to reflect Government's 'renewed commitment' to sustainable development but unfortunately hasn't reflected a commitment to follow-through and turn the vision into reality.
In a report published this year by the Parliamentary Commissioner for the Environment this view is supported when it states, 'no progress has been made by central government since then [2002] to analyse or consult on the use of economic instruments to achieve the targets set in the NZWS' (p7 Changing behaviour Economic instruments in the management of waste).
The report also states in its Summary of key findings that, 'Additional [to the Ministry for the Environment] guidance is needed on incentives that will reduce waste at source and encourage greater responsibility for waste at all stages of a products lifecycle' (p7 Changing behaviour Economic instruments in the management of waste).
Perhaps through the establishment of a national Waste Minimisation Authority this 'follow-though' and 'additional guidance' can finally be implemented and serious reductions of waste will be achieved?
Part 2:8: Functions
CRN supports the overall function of the Authority with emphasis on the achievement of minimising material resource use and waste production.
CRN supports points 1:(a):i through to 1:(a):iv and agrees with (b) that the Authority 'monitor and review the state of waste generation and resource use in New Zealand'.
As already mentioned, nobody really knows how quickly New Zealand's waste problem is growing because As already mentioned, nobody really knows how quickly New Zealand's waste problem is growing because 'information on waste remains poor' and because 'little progress has been made to improve the national coordination of waste data for the purpose of assessing suitable waste policy options, or for evaluating the effectiveness of policies already in place' (p7 Changing Behaviour: Economic Instruments in the Management of Waste). and because 'little progress has been made to improve the national coordination of waste data for the purpose of assessing suitable waste policy options, or for evaluating the effectiveness of policies already in place' (p7 Changing Behaviour: Economic Instruments in the Management of Waste).
Ask any Territorial Authority (TA) employee working in the field of waste minimisation, waste contracts or waste education if they know total tonnages of waste diverted or waste sent to landfill in their TA and it is difficult for them to answer. Many don't even know where to find or how to access this kind of information.
Given that TA's have been instructed with the task to produce Waste Management Plans in keeping with targets set in the NZWS, it is little wonder that in many cases the actual implementation of those targets remains unaccounted for.
Monitoring is important, but so too is implementation. CRN does not support endless reports and monitoring with no action to achieve waste minimisation objectives.
Part 2:8: Functions (c) - (e)
Community is concerned that the establishment of a Waste Minimisation Authority could provide a further 'feeding ground' for consultants to write further documentation but with little effect of plan implementation.
Community waste groups have been approached regularly in the past 12months by consultants contracted by TA's (and in some cases government Ministries) seeking complex and detailed information. This concerns us greatly given that we are the holders of the information or 'intellectual property' yet we are not being approached directly by the TA.
Transparency is one of the principles usually imbedded in the kaupapa of community waste enterprise. However the frequency of contact from consultants attempting to 'extract' information from community groups for their own economic gains has meant a 'guarded' response to those approaches has had to be considered.
It is fair to mention that information could have been given directly to the TA had we been approached. Given our sometimes 'compromised' economic status it is also fair to mention that being contracted directly by TAs to write a report would not always be declined if we were given the opportunity.
Consultants are sometimes predatory in their approach to business and TA personnel are sometimes 'naive' in their trust that a 'consultant' is the correct 'authority' from which information is to be sought.
A Waste Minimisation Authority set up to specifically monitor, update, administer, set fees, arrange research and development, approve and monitor producer responsibility programmes, assist with the development of markets for recovered materials as well as update every five years the NZWS is in general a savvy set of suggestions which CRN supports. However, when broken down, CRN has some concerns with the detail.
The above activities, entire purpose, and key objective of establishing a Waste Minimisation Authority would be to ensure that the nation reduces the amount of waste it presently produces. However it would seem that the Bill in its current form focuses solely on the operation of the Authority with little or no consideration / mention into the actual implementation process required to achieve the Authority's objectives.
That there is no mention of 'zero waste' or the waste hierarchy with regards to the Waste Minimisation Authority is of concern for CRN given that zero waste is the goal not only declared on the front cover of the NZWS but is also a philosophy grasped like a ball in the hands of many New Zealanders.
Community's depth of Vision
Waste Minimisation and diversion from landfill are key components of the Waste Hierarchy (Fig. 1) model commonly used to represent the layers of strategies that can be applied in moving towards Zero Waste.
It is a useful tool for developing a set of priorities for taking action. It is an internationally accepted guide with the objective of achieving the optimal environmental outcome.
The waste hierarchy establishes approaches to waste management according to their importance and preference in descending order.
Waste avoidance and reduction are regarded as the most optimal approach. Reuse, recycling and recovery of waste is preferred over the treatment and final disposal (p7 South Australia's Waste Strategy 2005-2010).
The 'big wins' further up the hierarchy can be the ones where it is hardest to establish a directly linked result and can be the most difficult to fund. Primarily this is because considerable effort and innovation must be devoted towards fostering attitudes and behaviours that encourage people to change and adopt resource efficient behaviours (p3 South Australia's Waste Strategy 2005-2010).
Achieving significant progress towards waste avoidance does take time especially when taking into consideration the behaviour of disposing waste to landfill as has been learned and accepted over the generations. We now know that by disposing of waste to landfill we bury many useful resources, preventing ongoing use of the material(s) in one form of another. Fostering sustainable behaviour to assist people to make this change is essential and is something community waste groups do successfully.
Although the waste hierarchy provides an effective framework for dealing with waste, the accepted wisdom that it contains is not being implemented in a holistic, coordinated or effective manner in Aotearoa New Zealand today. There is no mention of it in the Waste Minimisation (Solids) Bill.
CRN strongly believes that it is imperative the Waste Hierarchy be included in Part 2 of the Waste Minimisation Bill. It will be a fundamental tool to assist the Authority with mapping the pathway to sustainable development and a zero waste New Zealand.
Part 2: 8: (e)
The NZWS was developed as a joint exercise between central and local government to provide new direction on waste management. Recognising the complexities of waste and encouraging changes in thinking and behaving towards waste, the Strategy has attempted to hold ground in a field that is constantly changing. Although CRN recognises the Strategy as a 'guiding document' towards sustainable development, we believe that an independent body such as a Waste Minimisation Authority could more objectively monitor and review the NZWS than the Ministry for the Environment which is currently the case.
Presently the Ministry for the Environment holds the task to oversee the implementation of the Waste Strategy. However, although many staff working within the Ministry are clearly motivated by a desire to make change and effect environmental preservation policy, it has occurred to some community waste groups that 'priorities' held by those in leadership positions sometimes lean towards benefiting industry and less about the environment.
An 'independent' organisation like a Waste Minimisation Authority would hopefully shift the workload of administering, facilitating and supporting the implementation of the NZWS from the Ministry for the Environment.
Part 2:9 Powers
CRN acknowledges that if the Authority is to function effectively the detail mentioned in this part of the Bill is acceptable.
Part 2:11: Membership of Authority
It is CRN's understanding that the present structure under which EECA is organised is not working as effectively as was initially envisioned.
Given that the Waste Minimisation Authority as described in the Bill suggests similarities in structure to EECA, CRN has concerns that similar 'challenges' as those currently being experienced by EECA could also appear within a Waste Minimisation Authority.
CRN's 'hesitations' regarding the 'power' held by the Minister come from considering under what criteria would that person be given the direction to act?
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Budgetary constraints have partially facilitated a lack of commitment on behalf of many TAs to prioritise resource recovery strategies, recycling programmes and overall waste minimisation activities throughout the Nation.
Additional to this, central government has needed to 'provide more guidance on the design and implementation of a wider rage of economic instruments for minimising waste' (p7 Changing Behaviour: Economic Instruments in the Management of Waste) to assist TAs with meeting their NZWS targets.
As a result, little is known as to the status of actual implementation of TA waste management plans, their regional cohesions, how they are monitored or to what effect.
CRN therefore supports the establishment of Waste Control Authorities and the replacement of waste management provisions in Part 31 of the LGA 1974.
Part 3: 20: (2)
We see benefits in TAs joining together to form joint Waste Control Authorities as this would not only promote regional waste minimisation practices and alliances but also add strength in information sharing opportunities between Territories with the overall aim of reductions in waste.
Part 3: 21: (a)
Promoting effective and efficient waste minimisation and management in accordance with the NZWS would only strengthen individual TA commitments to meeting their targets. Additional to this, where guidance has been lacking from central government in the past, the establishment of dedicated waste minimisation units within TAs would hopefully ensure that there was budget and sufficient staff available to facilitate this function.
Part 3: 22: Waste minimisation and management plans
Although these requirements are far more prescriptive than the current general requirements for waste management plans, CRN believes that the level of detail will provide Waste Control Authorities with a clearer direction towards meeting NZWS targets.
As well it will assist in Control Authorities annual reporting to the Waste Minimisation Authority on quantity and types of reuse, recovery, recycling, treatment and disposal of waste in their territory.
Part 3: 22: (d) - (f)
Requiring the separation at source of organic waste, reusable, recoverable or recyclable wastes (including also residual waste) will further enable the gathering of precise information so necessary for future waste minimisation initiatives.
What our experience of managing community recycling facilities has taught us is that waste separation is essential to ensure that the integrity of individual 'wastes' / resources is maintained, for example, construction and demolition (C&D) wood.
Wood - reusable, recoverable or recyclable?
When an excess wood resource is produced from a C&D site its value can be maintained when it is separated on-site into length and type. This separation enables ease of access to it by others who can reuse it and who therefore divert this valuable resource from landfill.
Presently the traditional practice of excess wood 'disposal' on a C&D site is to incrementally (throughout the duration of the job) load it / throw it into a skip bin where it is also mixed with other building materials like building paper, plaster, nails, concrete, iron off-cuts, tiles, wires, rock etc, as well as day-to-day on site workers consumableswastes ie: beverage containers.
And although in recent years we have seen the completion of pilot studies and provisional guidelines set by the building industry to ascertain best practice waste management for building sites, CRN believes that the 'provision for waste separation at source' as written in the Bill will go further to ensure that.
Environmental impact of burying organic materials
Separation at source and the complete ban of organic waste buried in landfills is essential if we are to follow through with our commitment to international conventions such as the Kyoto Protocol (ratified in February 2004) which has indirect implications for waste minimisation and its impact on climate change.
Waste audits completed by WasteNot Consulting of Auckland have revealed that 48% of the average Auckland household's rubbish bin (intended waste to landfill) is organic. It is fair to apply this average across New Zealand giving us an understanding that almost half of household waste could be composted.
Methane
When organic matter is deposited and buried in landfills methane (CH4) is emitted as a result of the decomposition of those organic wastes. Methane is a harmful greenhouse gas that contributes to climate change.
Leachate
Rainwater percolating through the landfill combined with the break down (decomposition) of garden rubbish and kitchen scraps contribute to a liquid called leachate. In old landfills, leachate can escape and contaminate surface and groundwater. In modern, well-managed landfills, it costs a lot of money to collect and treat leachate (www.zerowastetrust.co.nz).
Landfill
Kate Valley near Christchurch and Hampton Downs (between Hamilton and Auckland) are the only two landfills in the country which can offer the latest in landfill construction technology. With the total construction costs estimated to be around $21.6million for Kate Valley, it could be fair to say that 21st Century landfilling is not the most cost effective for Canterbury rate payers especially when up to 70% of that 'waste' could have been diverted.
Additional to construction costs, the maintenance of Kate Valley Landfill will continue to rise unless serious waste reduction measures are implemented throughout the Canterbury region and surrounds. The ongoing collection, transport (estimated between 8 and 18 per day tanker sized trucks) and deposition of leachate alone (discharged to the Christchurch sanitary sewerage system) will have long term environmental impacts that can not be calculated today.
In a report written in 2002 on behalf of Transwaste Canterbury Limited it is stated that, 'leachate is similar to sewage in terms of the effects on the existing sewage environment' (pg 34 Proposed Canterbury Regional Landfill at Kate Valley, Leachate Treatment and Disposal 2002).
Although CRN can accept that leachate might be similar to sewage when considering the overall 'wear and tear' on plant, CRN does not agree that leachate is similar to sewage when considering the long term and immediate environmental and cultural impacts of discharging leachate into waterways, albeit indirectly via a sanitary sewage system.
Leachate contains heavy metal concentrations of arsenic, cadmium, chromium, copper, lead, manganese, mercury, nickel and zinc (pg 35 Proposed Canterbury Regional Landfill at Kate Valley, Leachate Treatment and Disposal 2002).
Who knows the long term effects of continued discharge of these metals into waterways?
Organics diverted from landfill benefit us in many ways. Less harm is caused through reduction of methane and leachate, void space is preserved in landfills and our soils mineral, trace element and organic content are replenished when we return organics as mulch or compost.
Long term, multi value initiatives such as the design, development and delivery of systems for collecting and processing organic wastes should be given more of a main concern than is presently prioritised. CRN hopes this Bill will provide that opportunity.
Markets
Indeed, this Part of the Bill offers very little suggestion / consideration regarding markets and the economic delivery of these products once separated at source, diverted from landfill and re-entering the economy in another form (as reusable or recycled into other product).
What implications will developing sophisticated composting facilities to generate a saleable product have on present markets for fertiliser products?
How will international companies respond when more and more New Zealand farmers switch-on to purchasing locally brewed 'fertiliser' / compost made from the very materials that grew from the same soil on which they conduct their farming activities?
Who will buy / use reusable building materials?
What does the recently reviewed Building Code say about the use of reusable building materials in construction and how will this effect markets for materials that are separated at source and diverted from landfill?
CRN suggests that more detail is required in the Bill regarding the strategic implications of this Part of the Bill.
Part 3: 23: Powers in respect of waste minimisation and management
If the specifics are broken down into detail such as every collector, transporter, transfer station operator and disposal facility operator requiring a licence (Part 3 : 22 : (c)) to manage waste, CRN believes that this will only assist with the development of effective systems for the collection of data and waste stream information which is currently lacking.
Licensing will provide income to Waste Control Authorities as well as opportunities for Authorities to implement 'regulation' on operators applying for a license. This will also assist in TAs gaining further understanding of the waste stream within their territory and enable strategic planning for future waste minimisation initiatives based on information collected through licensing.
It can also mean that additional information, statistics and data could be collected by Waste Control Authorities through the licensing process. 'Good waste data is essential for identifying waste problems and the appropriate measures to deal with them' (p7 Changing behaviour Economic instruments in the management of waste).
Licensing could also provide opportunities to regulate health and safety measures which are important when considering the management of toxic and hazardous waste and place of treatment or final disposal. This could be especially beneficial given that present management of this waste remains partially accounted for in different locations around the country.
For example, the management and 'disposal' of asbestos presently has a series of national policy procedures placed upon it and only licensed handlers are qualified to manage asbestos. However, attempting to obtain information with regards to the management specifics of this product can vary from region to region. Also, it is common knowledge amongst landfill managers that the placement of asbestos (or other hazardous wastes) in 'specially located' positions within a landfill plan can likely be compromised by more 'relaxed' landfill managers.
Indeed, not all landfills in operation today have the latest in 21st Century landfill liner technology and this can sometimes promote a 'relaxed' attitude regarding the overall effectiveness of 'special waste' placement and management ie: 'What's the point? Toxic leachate will penetrate into waterways anyway… '
Part 3: 24: Bylaws
Given the outcome and consequential economic implications for Christchurch City Council as a result of two major waste companies initiating a judicial review questioning the power of Territorial Local Authorities, CRN in principle supports this Part of the Bill.
Part 3: 26: Assessment of organisational waste minimisation plans
In CRN's view this Part of the Bill as it is written will impose excess administrational implications on TA's and some councils will struggle to meet Part 3: 26: (b) 'accept or reject the plan within 20 working days of receiving an organisational waste minimisation plan'.
Part 3: 29: Waste Control Authority to establish dedicated waste minimisation unit
CRN supports this Part of the Bill. Units specifically dedicated to minimise waste can focus on doing just that and with the detail specified in this Part of the Bill, waste minimisation units will form an important part in working towards a 'sustainable New Zealand'.
Part 3: 30: Requirement for Waste Control Authorities to report to the Waste Minimisation Authority.
CRN supports this Part of the Bill.
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CRN supports developing prohibition options on dumping of reusable and recyclable products and believes that this will be effective in reducing waste and diverting waste from landfill.
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Imposing a levy on the disposal of residual waste so as to discourage its generation and to provide funding to support processes, systems, and products that minimise resource use and waste production is one way forward to zero waste and a sustainable New Zealand.
Recently when the Minister for the Environment requested he be advised by his staff to assist him with making an informed decision regarding waste levies - to have or not to have? it was encouraging to see a good number of stakeholders offering their suggestions, attempting to seek a solution and indicating their acceptance that there is a growing waste crisis in Aotearoa New Zealand today.
In 1996 when staff from the Organisation for Economic Co-operation and Development (OECD) came to New Zealand to look closely at the country's environmental performance (measured with other OECD countries), waste management was identified as an issue that came under considerable criticism (pg 10 Changing Behaviour: Economic Instruments in the Management of Waste).
Since then and despite the NZWS stating 'our challenge is to break the strong link between economic development and waste generation' (pg 16 NZWS), when the OECD team of experts and staff returned to New Zealand in 2005, they saw very little implementation of the NZWS or an indication from MfE that work on the use of economic instruments in the management of waste was a priority.
New Zealand's economy is booming! With the lowest unemployment rate in years, property prices increasing (despite rising interest rates) and Minister for Finance Dr Michael Cullen repeatedly telling us to slow our spending, still, the New Zealand economy is 'performing well' (pg 9 Economic Development Indicators 2005, Ministry of Economic Development).
On the basis of gross domestic product (GDP), when measured next to other OECD countries, New Zealand bumped up a notch in 2005, higher than in previous years. 'The growth rate of our per capita GDP has improved and over the last five years has been running above the OECD average' (pg 9 Economic Development Indicators 2005, Ministry of Economic Development).
Figure 2 Economy & Waste Production
'The relationship linking economic growth and waste production needs to be decoupled if such growth is to be sustainable' (pg 10 Changing Behaviour: Economic Instruments in the Management of Waste).
Waste Levy - an Economic Instrument
Given that 'economic instruments have been widely used in other developed countries as a means of tackling the growing problem of waste generation linked to economic growth' (pg 11 Changing Behaviour: Economic Instruments in the Management of Waste), CRN strongly believes that there is real potential for economic instruments to have a similar effect here.
Although waste levies are one way of introducing an economic instrument to affect waste minimisation, CRN does not envision that this would be the only measure considered by the Select Committee. CRN anticipates that the Waste Minimisation (Solids) Bill will provide the opportunity for a range of economic instruments to be considered to encourage better design, manufacture and durability of products produced in the first instance.
Part 5: 38: Disposal Facility
Firstly, CRN would like to gain clarification of the definition 'disposal facility'. Would this include every Refuse Transfer Station in the country? Where would the Auckland International Airport Incinerator (located in Manukau City) fit into Part 5: 38: of the Bill where it states 'every disposal facility must operate a weighbridge to weigh the material received by it for disposal'?
We can see two 'challenges' here given that many CRN members operate 'disposal facilities' but do not operate / own weigh bridges.
As already mentioned, community groups tend to operate on the economic fringes, where commercial operators cannot make the 'rational' economic decision and take on what appears to be a loss making venture. As a result is extremely difficult for community waste groups to borrow money to establish infrastructure with a business plan that shows only social, cultural and environmental profit. Some groups handle standard materials in areas where distance to markets and low population density make service provision theoretically unviable. Others take on many marginal product lines that in themselves do not turn a 'profit'.
Lack of resources like a weigh bridge have usually meant that community groups operating recycle centres, recovery parks or refuse transfer stations have had to use alternative methods in which to measure residual waste destined for landfill.
Given that a number of TA's around the country have not made it a priority to support CRN members to establish weigh bridges at their premises (some have of course), CRN questions the ability for this Part of the Bill to be implemented given the economic implications associated.
Part 5: 39: Returns of waste received
Allowing for every disposal facility in the country to have access to a weigh bridge, CRN supports this Part of the Bill and can see that it would be beneficial in the overall collection of data so necessarily required.
Part 5: 40 - 41 Imposition of levy / Amount of levy
CRN agrees with this Part of the Bill where it is stated that a levy may be set at different rates for different types of waste.
We can think about waste by weight, by volume or in term of harm done. Tonnage has the advantage of simplicity of operation, however all materials are not equal in term of the space they take up in a landfill. By volume, one tonne of PET or polystyrene diverted from landfill is far greater than one tonne of concrete.
This is also the case when differentiating between wastes on the basis of environmental impact. The toxicity and biodegradability of different wastes are environmental issues that must be considered when proposing to implement waste levies. The same levy should not be applied to one tonne of concrete as to one tonne of electronic scrap because the environmental impact is markedly different. Industrial hazardous waste should not be charged by tonne the same as household waste.
CRN supports further discussion around this Part of the Bill so that Waste Minimisation Authority staff, the Minister and Board is not given the sole responsibility to implement the right criteria when determining details pertinent to setting a waste levy.
CRN supports Part 5: 41: (1) of the Bill and believes that annual establishment of the levy charges following evaluation of the effectiveness of the level will be a good way to monitor the overall implications of landfill levies.
Part 5: 44 Use of levy
As it is written in the Bill, CRN finds the three scales Part 5: 44: (1): (a) - (e) too descriptive, prescriptive and all together limiting.
This Part of the Bill lacks innovation and requires more discussion to tease out the restrictions that may, if no change is made to this Part, tangle all businesses, public and community organisations with the administrational detail required to develop waste minimisation plans and initiatives.
When will the actual on the ground waste minimisation take place if we are all tied up in developing plans to do so?
Part 5: 44: (2)
CRN supports this Part of the Bill and welcomes further elaboration and discussion regarding possible waste to energy partnerships with the Energy Efficiency and Conservation Authority (ECCA).
Part 5: 45 Evaluation of effectiveness of levy
CRN supports this Part of the Bill.
Although Morgan Williams, Parliamentary Commissioner for the Environment, states in his preface to the recently published report Changing Behaviour: Economic Instruments in the Management of Waste, 'in New Zealand we seem to be somewhat fixated on voluntary measures [as policy tools for changing behaviour]' (pg 5), David Benson-Pope, Minister for Environment insists that 'the voluntary Packaging Accord is still on track to reach its targets' (http://www.beehive.govt.nz/DocumentID=26444).
Extended producer responsibility (EPR) or 'product stewardship' is the term used to describe an approach whereby producers, importers, brand owners, retailers, consumers and other parties involved in the life cycle of a product accept a responsibility for the environmental impacts of the products through their life cycle (pg 3 Product Stewardship and Water Efficiency Labelling).
CRN has been disappointed in the past with the way the Ministry for the Environment has managed its approach to providing guidance to reach NZWS targets and believes that industry led voluntary EPR approaches alone are not effective tools in which to implement waste minimisation practices.
CRN welcomes this Part of the Bill to facilitate open discussion regarding EPR, NZWS targets, the Voluntary Packaging Accord, Container Deposit Legislation (CDL) and economic instruments.
Part 6: 48: Purpose
In nature there is no waste as everything is reintegrated through natural recycling processes when opportunities to utilise accumulated wastes are quickly taken up by other organisms. Outside of nature, the highest volume of waste comes from human industrial activity.
Natural systems are based on continuous cycles. In the last 150 years our society has valued and prioritised production and distribution in keeping with a linear approach. Resources have traditionally been undervalued largely due to the extremely short time frames used to organise decision making (fossil fuels) but also due to ignorance. The last 100 years especially have seen human industrial activity extract more resources and manufacture more waste than in all prior years of human industrial activity (Thom Hartmann - The Last Hours of Ancient Sunlight).
A focus on waste minimisation and diversion alone is not broad enough in scope to effect any real change regarding consumer behaviour and expectations, or production /manufacturing systems. CRN members are of the opinion that effective waste minimisation will be achieved only if a 'whole' approach to it is implemented, one that includes looking at the generation of waste in the first instance.
EPR requires producers of goods to take responsibility for their products throughout the lifecycle of those products. However, when a product is devalued and labelled 'waste' it has less attraction for anyone, including manufactures, importers or brand owners.
When a consumer makes a purchase ie: beverage contained in a #1 labelled Polyethylene Terephthalate (PET) plastic bottle, usually their key focus is on the content of that bottle rather than the bottle itself.
Since the 1970s when Aotearoa New Zealand removed the container deposit system or bottle returns on beverage containers, there has been little or no incentive for consumers to take any regard or responsibility for the end of the life of that bottle. Until very recently (August 2004 signing of the Voluntary Packaging Accord) beverage manufactures have made no independent attempt to extend their producer responsibility beyond sales.
Over the years, and since the beverage manufacturing market became bigger and more competitive, it has become increasingly acceptable for consumers to 'dispose' of their 'resources´ (PET plastic bottles) into rubbish bins destined for landfill.
As a result, thousands of tonnes of valuable resource that could have been either reused or recycled has been buried in the ground.
If 'separation at source' measures had been put in place years ago throughout the country and product buried strategically and with a map indicating their landfill location (as Innovative Waste Kaikoura has practiced in the first years of this Century), retrieving those resources at a later date when their value is better recognised would be less labour intensive. In future 'landfill mining' will be part of the legacy we leave for our children.
More value needs to be placed on the product during its manufacturing so that the energy unit invested at the beginning of its lifecycle can be maintained and so too its integrity, or value.
The resource recovery system is the withered limb that attempts to move resources back around into the loop, or back into the nature cycle where 'wastes' can be re-valued and either reused or recycled into another useful 'thing'.
However, although community waste enterprises divert more waste from landfill and therefore recover more resources back into the loop than any other sector, we believe that resource recovery is only the action at the bottom of the cliff. If our society was more 'savvy' we would have implemented, like other OECD countries, more suitable systems in which waste minimisation was the first point of consideration in the manufacturing process rather than the last.
'Recycling is only a staging post along the way [to a zero waste society]. Implementing strategies [from the waste hierarchy] and steps that follow will progressively shift the emphasis from recycling toward a culture where waste avoidance and reduction and accepted lifestyle choice and the usual way of doing business for South Australians' (pg 8 South Australia's Waste Strategy).
It is fair to remember that resource recovery has not been the core business of drinks manufacturing, for example. By removing legislative tools like CDL, this simply gives manufactures more freedom to add unrestricted growth to their business and product sales. This is good for business, and good for economic growth, but we know that the challenge of our times is to 'break the strong link between economic development and waste generation' (pg 16 NZWS).
If an economic instrument, like a tax or a deposit was placed upon a product at the point of manufacture or purchase, then producers and consumers both would have an investment or incentive to 'cash in' their return on that product. Presently there is very little incentive for either members of society (producers and consumers) to extend their responsibility to the full lifecycle of the product in their hands.
In New Zealand most of the major primary production industries have benefited from decades of government support in the form of grant programmes, funding support for research and development corporations, university research programmes and cooperative research centres. Compared to this, apart from the NZWS and attempts at voluntary product stewardship programmes the level of industry development support for waste minimisation and resource recovery has been negligible.
Expecting producers to take voluntary responsibility for their product beyond point of sale, as MfE has done through fostering product stewardship programmes like the Voluntary Packaging Accord, is naïve.
Part 6: 49: Brand-owners to take responsibility for products
CRN supports this Part of the Bill.
However, further definition on 'brand-owner' is required for full effect to be taken of this Part of the Bill.
Does a brand-owner include 'importer'?
How will the Waste Minimisation Authority ensure that importers of product will be 'registered' or otherwise 'licensed' to import in keeping with this Part of the Bill?
How will this Part of the Bill act to ensure that the importation of goods, rejected by other countries, will be monitored for 'qualification to a product stewardship programme'?
Electrical Waste
CRN members operate kerbside collection contracts, resource recovery parks and recycle centres. We are used to the frequency of receiving products never seen before and for which we have no markets.
In our experience, recent years have seen an increase in the receipt by us of 'crap' electronic products for example that are 'affordably' available at large well known stores throughout the country.
The increase in brand new but broken electronic products coming through our centres is alarming!
With one year warranty's often these products break within the year and are returned and exchanged for another of the same item. Because of their country of origin (namely China or Taiwan) and the conditions under which they have been manufactured, these products have no market in New Zealand for repair and inevitably end up in our centres or in landfill.
We believe Aotearoa New Zealand 'has become a dumping ground for 'crap' electronic products' (Rick Thorpe from the documentary 'revolution with no guns'). Where other countries have more stringent 'quality control' measures in place on the importation of goods, Aotearoa New Zealand has little or no measures. As a result, when other countries reject product based on legislative criteria it has in place, Aotearoa New Zealand welcomes these products.
Fisher & Paykel
CRN commends Fisher & Paykel (F&P) for taking a world wide lead on developing their products in keeping with their own extended producer responsibility programme. Many of CRN members receive F&P products into their centres and, using spare parts and electronic expertise, rebuild white ware and on-sell to customers.
This branch of our operations is an example of community waste enterprises achieving more than simple resource recovery.
Not only do we divert white ware from landfill, but we also offer training in electronics programmes to staff before selling goods at an affordable price to those families who may otherwise not be able to afford them brand new.
The simplicity of F&P products, including their easy-to-read labelling means, when broken or in need of repair, this can easily be achieved in most of our centres throughout the country. This is an example of functional EPR and works well in the 'Buy New Zealand Made' context, made local by local.
Manufactures like Fisher & Paykel are an exceptional example of New Zealand company champions. However, their leadership has not been a key driving factor for all other companies to follow their lead.
Part 50 - 53 Brand-owner and product stewardship organisation to confirm chain of responsibility for product / Notice to be given of consideration of need for a product stewardship programme / Approval of product stewardship programmes
CRN agrees with the intent of these Parts of the Bill but recognises changes will be made to them including the detail.
Part 54 Product stewardship programmes may include deposits or fees
'Evidence shows that economic instruments can be effective in reducing waste' (pg 7 Changing Behaviour: Economic Instruments in the Management of Waste').
'Using economic instruments to improve the management of waste is common in other OECD countries' (pg 7 Changing Behaviour: Economic Instruments in the Management of Waste').
'When properly designed and implemented, economic instruments encourage waste reduction' (pg 7 Changing Behaviour: Economic Instruments in the Management of Waste').
CRN believes that brand-owners should not be left to voluntarily impose a fully- or partially-refundable deposit or a non-refundable fee on the purchase price of their products (Part 54: (1)).
In our experience this does not work as a way forward to encouraging industry waste reduction practice. The Voluntary Packaging Accord (2004 - 2009) illustrates that waste minimisation is not effective when industry is left to voluntarily reduce waste.
The Voluntary Packaging Accord is an example of a 'partnership' process between industry and the Ministry for the Environment which has benefited industry (and perhaps MfE?) yet not minimised waste.
Some of the targets set in the Accord were less than current recovery rates, meaning that sector had reached their target even before signing the Accord.
The community sector of the waste industry was 'shut out' of any Accord talks prior to the signing in August 2004 despite repeated requests for to be part of the process.
CRN did not support the signing of the Accord and is little surprised that the Accord is not working effectively as the glass crisis indicates.
However, the Packaging Accord has seen some never before cohesion between brand-owners and the Environmental Beverage Action Group (EBAG) is an example of this.
EBAG
Consisting the major beverage container producers, manufacturers and distributors in New Zealand namely: Alto Plastics, Amcor PET Technologies, Coca-Cola Amatil, DB Breweries, Fonterra Co-operative, Foodstuffs, Frucor Beverages, NZ Juice & Beverage Association, Visy PET together with representatives from Ministry for the Environment, Local Government New Zealand, the Packaging Council of NZ, Plastics NZ, Wasteminz and Recycling Operators of New Zealand, EBAG is one of the few sector group signatories of the Accord to collaborate in an attempt to meet targets they have agreed to.
However, as mentioned, resource recovery is not the core business of any of the above mentioned groups (save RONZ). This has meant that, although individuals representing their companies are experts in their given fields, their ability to minimise waste and strategise a pathway to EPR implementation is compromised.
Mostly, what has been achieved is further 'sales and marketing' opportunities by EBAG members.
Indeed it would appear that EBAG is on a track in an attempt to follow through with commitments made to the Packaging Accord. 'EBAG has two main objectives. Firstly, to ensure all beverage containers can be recycled in New Zealand and secondly, to identify and implement methods to improve the collection rates of beverage containers for recycling' (http://www.packagingaccord.org.nz/EBAG.php).
CRN suspects that a third objective has not been disclosed to the New Zealand public. To ensure that container deposit legislation is not implemented in Aotearoa New Zealand.
CDL
Container deposits are not new or foreign to those of us who were around in the 1970s for we had a system whereby a small deposit was placed at point of purchase on every beverage container. This was a system that worked well in the recovery of product (which were washed and refilled before re-sale) and provided massive fund raising opportunities for groups like the Scouts and Girl Guides. At the same time this system removing litter of beverage containers and reduced waste to landfill.
In South Australia (SA) CDL has been in place since 1975 (expanded in 2003) and provides a solid infrastructure for recycling and resource recovery. It subsidises kerbside collection, provides financial incentives to recycling and provides SA with the highest return rate for beverage containers in the whole of Australia (Vaughan Levitzke, Chief Executive Zero Waste South Australia).
Recovery rates in SA for beverage containers include:
- Cans 86% - 92%
- PET 74%
- Glass 86%
Our own Voluntary Packaging Accord targets are set at:
- Cans 65%
- Plastics packaging 23%
- Glass 55%
CDL in SA removes unsightly beverage container litter resulting in reduced local government clean up costs and encourages community groups to 'adopt a road or street'. By adopting a street and collecting any beverage container discarded, community groups can provide for themselves a solid and consistent income stream through collecting the deposit already paid down on the container (Vaughan Levitzke, Chief Executive Zero Waste South Australia).
Given the continued success of CDL in South Australia and the commitment indicated by Western Australia to introduce a deposit system in the near future (CDL pamphlet - Government of South Australia), combined with a historical 'relationship' with CDL, CRN is of the opinion that the introduction of CDL in this country would offer an additional tool to achieve waste minimisation.
CRN strongly advocates that the Select Committee review this Part of the Bill and introduce CDL.
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CRN is of the opinion that this Part of the Bill is in keeping with the rest of the Bill but will require considerable review given the changes the Select Committee process will provide.
In principle waste minimisation plans are good. However, CRN would be concerned that over emphasis on administering waste minimisation plans within every business or public organisation may deter action actual waste reduction practices.
The issuing of building permits for example, by Waste Control Authorities on the proviso that a constructive waste minimisation or zero waste plan has been sited CRN would recommend.
Part 7: 66 Public event organisers to have waste minimisation plans
CRN is in support of this Part of the Bill and think it is timely that mention of waste minimisation at events is given to the waste debate.
Some of our groups have had successful experiences at managing zero waste at events. Xtreme Waste of Whaingaroa has perhaps had the most experience having fine-tuned it's management to 80% resource recovery at the yearly Soundsplash Eco Reggae Festival (Motherland Collective aka Cornerstone Roots, Raglan).
Events like Pacifika, Exotica and the Grey Lynn Festival in Auckland and The Field Days at Mystery Creek all generate thousands of tonnes of waste to landfill. Based on the Raglan Reggae Festival partnership between Xtreme Waste and Motherland Collective, CRN can confidently say that up to 80% of the wastes created at the above mentioned events could all have been recycled or diverted from landfill.
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CRN supports recent developments in which the Ministry for the Environment has worked to establish the 'Govt3' programme within its own premises and with Ministerial directive for it to be implemented across the board and throughout all government offices and ministries in Wellington.
CRN supports this Part of the Bill and suggests that Govt3 be implemented throughout the country and into TAs and all other public organisations.
This would be especially good for generating local markets and at the same time in minimising large quantities of waste.
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CRN supports this Part of the Bill.
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CRN supports this Part of the Bill.
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At the end of May 2006, there were 24 signed up full members - 11 in the North Island and 13 in the South Island. These members are listed below:
| North Island |
|
Arohena Community Trust |
Te Awamutu |
Awhitu Peninsula Landcare Trust |
Waiuku |
CBEC |
Kaitaia |
Clean Stream Northland |
Kaitaia |
Environmental Education for Resource Sustainability Trust (EERST) |
Tauranga |
Environua Trust |
Levin |
Helensville Enterprise Trust |
Rodney |
Panguru Development Trust |
Northland |
Seagull Centre Trust |
Thames |
Te Runanga O Te Rarawa |
Kaitaia |
X-treme Waste |
Raglan |
Total North Island |
11 |
| South Island |
|
Ahuriri Resource Trust |
Otematata |
Buller Community Development Company (Westport) |
Westport |
Central Otago WasteBusters (Alexandra) |
Central Otago |
Innovative Waste Kaikoura |
Kaikoura |
Kaikoura Wastebusters Trust |
Kaikoura |
Remarkable Recyclers Ltd |
Wanaka |
Southland Community WasteBusters Trust |
Winton |
Southland Enterprises Inc |
Invercargill |
The Blue Door Inc |
Blenheim |
Waitaki Resource Recovery Trust |
Oamaru |
Wanaka Wastebusters |
Wanaka |
Wastebusters Trust Canterbury |
Ashburton |
Workcentre Waste Solutions Trust |
Takaka |
Total South Island |
13 |
Total of 24 groups as at 31st May 2006.
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a documentary about community waste enterprises.
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Changing Behaviour: Economic Instruments in the Management of Waste
Parliamentary Commissioner for the Environment 2005
Economic Development Indicators 2005
Growth through Innovation
Ministry for Economic Development
The Treasury
Product Stewardship and Water efficiency Labelling 2005
New Tools to Reduce Waste - Discussion Document
Ministry for the Environment
Proposed Canterbury Regional Landfill at Kate Valley Leachate Treatment and Disposal 2002
Pattle Delamore Partners LTD
South Australia's Waste Strategy 2005-2010
Zero Waste SA
Government of South Australia
The New Zealand Waste Strategy 2002
Ministry for the Environment
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