To:	Local Government and Environment Committee Bowen House, Parliament Buildings, WELLINGTON
From:	Graeme Galley Trust Manager, Environua Charitable Trust 44 Easton Way Levin 5510 Phone 0275 873 873 [email protected]
Date:	1st September 2006
Submission:	To the Waste Minimisation (Solids) Bill

Organisation
Opening Comments
Waste is an important issue to us because …
Part 2: Waste Minimisation Authority
Part 3: Waste Control Authorities
Part 4: Prohibition on disposal of materials
Part 5: Waste disposal levies
Part 6: Extended producer responsibility
Part 7: Organisational waste minimisation plans
Part 8: Public procurement policy
 

We are a newly formed charitable trust (dec 05). We started 2 years ago as an advisory group to the Horowhenua District Council (HDC), with the task of advising the council on the best ways to promote recycling and divert material away from the landfill. Our advice centered on the establishment of a resource recovery facility (RRF), which would be run by a community group (in this case a trust). Presently we are finalizing plans with the owners of the regions transfer station to build a recovery facility at the transfer station.

Our operation will be behind the gate fee at the transfer station. While plastics, tins aluminum etc are dropped off free of charge, all other material will incur a charge. Midwest, the owners of the transfer station will then pay us, out of the gate fee, for every tonne diverted.

Our income will be made up of a contract with HDC, the diversion Levy from Midwest Disposals LTD and the sale of recovered material to end-users.

We currently have 2 employees

1. The Trust Manager
2. a recycling promotions person

The expectation is that once the RRF is operational, by the end of 2006, we will begin employing additional people through Winz and other government agencies

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In preparation for this submission we have read and considered the summary of the bill and spoken to a number of business associates. Our format is more in line with a series of question and short bullet point comments, rather than a lengthy critique.

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The current level of recycling in the Horowhenua is well down on national levels, yet the potential to divert here is the same as elsewhere in the country. Currently in excess of 20,000 tonnes is going to the landfill. This volume will fill the landfill faster than was originally intended, yet if we achieved a 50% diversion rate, we would have effectively doubled its life and halved potential environmental problems, while securing upwards of 20 full time positions in the district.

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Perhaps its greatest value lies in that it shows to the country that Central Government is taking the issue of waste diversion and recycling seriously and that our environment is a core responsibility of government. It also demonstrates the importance of the waste stream to our environment, our future and to some extent our economy.

1. Is it necessary to establish a separate body, when the Zero Waste Trust already exists? Education, promotion and support are already the core roles of that trust, and they already have public awareness and credibility. If we are looking at waste minimisation, lets not create another layer of Government, when the establishment of a contract could see the Zero Waste Trust take the lead
2. Having a centralized operation should ensure that national figures are comparative, that all areas are represented, and that they have a voice. Problems, or opportunities could be identified, dealt with effectively, and that core messages and systems are replicated nationwide. It should also ensure reporting methods are standardized
3. Priorities should focus on education, promotion and the philosophy that recycling needs to be a way of life

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1. The WCA appears to be the stick, whereas the WMA is the carrot.
2. Would this body usurp the control and responsibility of local councils or would councils be expected to report back to the WCA?
3. Does the creation of this body suggest that the current Local Territorial Authorities (LTA) are failing in their performance?
4. Could the above question also apply to the Ministry for the Environment?
5. Would it not be easier/cheaper to strengthen the LTA's authority, funding; and performance expectations?
6. The licensing of operators is important, particularly for those claiming to be recyclers, and if funds were to be available to the private sector, then only those that are licensed should be eligible
7. Will targets be set nationally or regionally, and could different regions sell their waste credits?

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Material is disposed to landfill, because there is either no end-user, no cost effective means of recovering it, or because it is so contaminated that no-one wants to deal with it. It is unrealistic to think that the need for landfills will ever be negated.

1. Nappies are a prime example; until such time that cloth nappies or disposable plastics are used then a landfill will exist. Equally there are other materials in our society that cannot be recovered. These need to be stored in a safe environment.
2. It may be that for the containment of some products, other material has to be mixed in with them. Would such mixtures still be allowed? Ie offal needs greenwaste to encourage decomposition. Not discounting that Effective Microorganism (EM) may have a place to play in the future.
3. Much more could be recovered from landfills if the material entering them was not contaminated.
4. Fining people/organisations for the disposal of mixed material may be easier to oversee, enforce and encourage
5. Simply banning material, ie creating a law, will not solve the problem-if this was the case drugs would not be an issue in our society.
6. Material will be diverted when there is an economic benefit to do so, be it as a stand alone recovery operation or through Government sponsorship.
7. Material will be recovered when it is economic to do so. This can lead to the situation that as market forces change, then the type of material landfilled will change, not only globally, but also regionally. It could occur that material will be landfilled in one district simply because transport costs are too high for its recovery to be sustainable. A loop hole such as this will be exploited by the market place.
8. Rather than having a landfill, it is conceivable, particularly if separation becomes a cornerstone of societal change that we could end up with facilities known as cell site storage. This is where similar materials are stored together, either for future reclaiming of as an inert mass.
9. Much of the material disposed of originates overseas. Will you be looking to ban the importation of cheap goods into the country?
10. Currently there are markets for some material eg plastics and other processes available eg composting for greenwaste and putricibles. It would appear sensible to ban materials that can be recovered, once systems and processes are in place for their recovery. This puts the emphasis on developing the infrastructure before imposing bans.
11. If banning is to take place a lead in time needs to be instigated. This will allow time for systems to be put in place. This will of course necessitate the advance of funds to develop those systems.

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1. $25/toone x 20,000 tonnes currently landfilled (in the Horowhenua) equals $500,000. If we are successful in diverting 50%, we have effectively cut our income in half. Aiming for zero waste will therefore give the recycling industry no funds to recycle with-hardly a policy of sustainability.
2. Furthermore the idea that only residual will attract the levy is counterproductive. As the level of recycling rises, so the cost of processing increases, yet funds will be diminished, as per the previous comment
3. It would not be inconceivable that recycling companies will aim for a level of recycling that is self-supporting and not seek to advance beyond this
4. Perhaps it would be better to see this as a temporary measure and in conjunction with this ensure producers/manufacturers are building into their products a recycling cost component
5. In the interim; recycling operations should be set behind a gate fee, rather than in front of it.
6. This will not only generate an income directly linked to the recovery of material, but will also show the general public that the charges are going into resource recovery, rather than into the coffers of some large Multi-National.
7. The current perception by the general public is that all recycling should be free. The reality is that costs to recover material can be as much, if not more, than the costs to dump it into a hole somewhere. Yet this is not represented in a residual levy. (note- the comment is based on transport and processing costs, not the storage and maintaince component of landfilling or the potential environmental costs associated with any long term storage.)
8. By establishing a charge earlier in the process, the message of user pays is re-enforced and consumer responsibility is introduced
9. The cost of recovery is then shared by all consumers and so the amount charged could be reduced (30,000 people-current Horowhenua population-paying $17.50 annually would generate the same income as a residual levy), without the need to alter as tonnages decrease.
10. Collections of the levy via the gate will be more direct. A percentage can be sent for central operations, while those directly involved will have first access to funds as they are needed
11. In any contestable system there are going to be winners and losers. What safeguards will be put in place to ensure the lions share of funds are not given to the major players, or the big cities, just because they can argue their case stronger than small or fledgling operations?
12. In the Horowhenua region there is one regional council, one district council, various waste and recycling companies, and ourselves-a trust. What mechanisms will be in place to ensure we are not disadvantaged when it comes to accessing those funds?
13. Would funds have to be applied for annually?-and if so how can any long term financial forecasting take place?
14. The trust would like to see funds made available for capital costs, leasing on plant and buildings, research and development and the establishment of secondary industries along with wages
15. HDC currently contribute $50,000 to the trust annually. What safeguards will be in place to ensure any council does not decrease their own commitment because this super fund is being generated?
16. If those business/community groups involved in the recycling industry had more direct access to the funds, then they could reward those consumers recycling with vouchers, tokens, gifts, discounts, or even cash on the spot. A grander view of container deposit legislation principles.
17. This would give an immediate reward to consumers and place the recycling industry in a positive light.

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1. This ultimately will be consumerism paying for its wastage, which is good.
2. It will also ensure that even if people don't want to recycle, by purchasing an item, they are contributing to the cost of its recovery
3. This principle can reinforce the message that having already paid for its disposal, then the consumer might as well do the right thing. This concept may decrease the amount of fly tipping
4. With a fund based on purchases, monies will be in place before the product is ready to be recycled, rather than after it has been processed
5. A voluntary accord is not a level playing field, and is open to abuse. Compulsory targets and expectations will ensure certainty for businesses and again show to the nation that recycling is an important facet of our lives

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1. This should be part of any business plan, but should not be onerous
2. Has the introduction of Health & Safety procedures made a difference to the workplace and if so how much of a difference? What lessons can be learnt or frameworks adapted to achieve the aims of a waste minimisation plan?
3. Central government needs to lead by example and instigate these plans before expecting businesses to

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1. This will only work when recycled products are as cost effective as new material, otherwise the Government opens itself up to accusations of sponsorship, and supporting poorly performing industries,
2. The expectation should be that every attempt is made to procure recovered or recycled material.
3. Would this also be included in contracts with third parties and national embassies around the world?

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Environua trust exists, in part, because our local council saw it was not going to meet its compliance obligations. This re-enforces the view that waste initiatives need to be mandated before they are taken seriously. We are also of the opinion that requirements and expectations do not in themselves solve or even help a situation. Our local landfill is often embroiled in controversy because different parties have different interpretations of the same situation. Enforcement and regulation are not the panacea for waste diversions. They are, at best tools only.

To make a difference requires a conscientious shift of thinking by the nation. All businesses, individuals and decision makers need to accept that they are part of the waste stream-either they are part of the solution, or part of the problem.

It is all very well using recycled and recovered material, but the processes involved to capture this material costs money. This concept seems to have got lost amongst the arguments of why, and how. If the processes of education and resources recovery were financially stable, then greater recycling would take place and subsequent reduction in landfilling would occur. It is imperative therefore that the over-riding goal of this bill is the creation of a fund for education and the development of recycling operations, in preference to the creation of another governing organisation.

Producers, manufacturers, importers and even retailers need to include in their sale price an amount for the safe recovery of materials that made up that product. Waste industry groups, recycling operators (be they private or community based), are integral to any success. Their business objectives need to align themselves more with the promotion of recycling rather than the disposal of material that has not got an easily accessible financial market.

In much the same way that the vast majority of people now accept the need to use a seat-belt when driving (ie this is now a habit and a way of life), those same people now need to accept the need to separate material out of their own waste-stream, as soon as possible, and to deliver it to the right places, and that a fee may be due for the safe recovery/recycling of said material.

Decision makers need to accept that they must lead by example and practice what they are preaching. They also need to ensure the systems are in place, both restrictive and prescriptive, to allow all parties to not only work together but to succeed individually.

The bills final version needs to promote the message that recycling is a core component of any countries infrastructure. This philosophy needs to be reflected in the Bills focus on education, system integration and penalties.

This bill is a good first step and its introduction has the potential to make a big difference. We congratulate the MP involved for promoting this cause.

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