To:	Local Government and Environment Committee Bowen House, Parliament Buildings, WELLINGTON
From:	Marianna Tyler and Stephen Bradford - Householders 24 Greta Street Hamilton Phone: (07) 843 9872 Mob: 029 871 9338
Date:	1st September 2006
Submission:	To the Waste Minimisation (Solids) Bill, we wish to be heard on this submission.

Intorduction
Key Points of this Submission
Part 6: Extended Producer Responsibility
Part 4: Prohibition on the Disposal of Materials
Part 5: Waste disposal levy
Part 2. Waste Minimisation Authority
Part 7: Organisational Waste Minimisation Plans
Part 8: Public Procurement Policy

We have chosen the following order (see 4.1) in which to address the key issues because we believe it makes sense to target the producers and deliverers of non-recyclable, non-reusable and environmentally harmful packaging and consumer goods as a key starting point. If all goods available to consumers were packaged in recyclable, reusable or biodegradable packaging/containers, and all goods delivered to consumers were of good quality, long-lasting and had a positive life-cycle, we would see a substantial reduction in waste to landfill and resource and energy use.

Key parts discussed in this submission include:

• Part 6: Extended Producer Responsibility
• Part 4: Prohibition on disposal of materials
• Part 5: Waste disposal levy
• Part 2: Waste Minimisation Authority
• Part 7: Organisational waste minimisation plans
• Part 8: Public Procurement Policy

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Overview
We strongly advocate the introduction of mandatory programmes that support Extended Producer Responsibility (EPR). Each programme should be focused on a specific product category or priority waste material to encourage competition (or collaboration) within the industry sector to develop more sustainable product design and material management systems.

We see EPR as the vehicle needed to give industry the impetus to find ecologically-friendly alternatives to deliver to consumers. We clearly understand that a voluntary programme such as the 'Voluntary Packaging Accord' is not as effective as it needs to be, nor will it ever be unless it is made regulation. The voluntary packaging accord is also not working toward reducing the use of resources.

While industry will want to try and share/shift responsibility onto the consumer, it seems clear that those creating, selling and making profit from waste should in the first instance be made accountable for it.

Key points
Part 6: 54) (1) Product stewardship programmes may include deposits or fees: We recommend that the fully or partially refundable deposit for product stewardship programmes is compulsory as an incentive for consumers to return their products to the producer. The refundable deposit must be substantial in nature to ensure consumers have sufficient incentive to return products to the producers.

Part 6: 60) (2) Collection of end-of-life products: We agree that EPR needs to provide access to a local facility for the recycling of their product or they must bear the cost of the return of the product to the facility.

Part 6: 60) (5): We do not agree - if a collection facility is not financially viable, the seller of the product must be required by law to operate a facility on their premises. Alternatively, the brand owner may choose to bear the cost of couriering the product to the nearest collection facility.

Container Deposit Legislation (CDL): We believe Container Deposit Legislation (CDL) should be an essential element of the Bill. CDL provides simple and achievable solutions to a number of issues including:

1. a) litter caused by soft drinks, beer, fruit drinks and water bought and consumed away from home, in public areas or at public events. Currently many of these containers end up in public rubbish bins or as roadside litter. The introduction of CDL would see litter literally disappear overnight.
2. b) CDL ensures almost all of these drink containers will go to recycling instead of into landfill as is the case currently

EPR will reduce public costs by shifting costs of end-of-life product management from taxpayers to manufacturers.

EPR provides incentive for producers to design and supply more ecologically sustainable products that provide the greatest functionality and longest life with safe materials and the least use of resources.

Summary:

• A primary function of EPR is the transfer of the costs and/or physical responsibility of waste management from local government authorities and the general taxpayer to the producer.
• CDL is an essential element of the Bill.
• Essential to EPR is its mandate for producers to take back their end-of-life products and create closed looped systems that prevent pollution and the inefficient use of resources.
• EPR provides incentive for producers to create and deliver more sustainableproducts.

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Overview:
We support the prohibition of disposing materials that can be recycled, reused or composted as well as waste that is toxic or detrimental to the land and environment including such things as fluorescent lights, batteries and treated timber.

Key points:
34) Prohibition on disposal:

• There needs to be a recycling facility for prohibited materials at the disposal facility.
• All disposal facilities should have the capacity to also accept recyclable products.

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Overview:
We support the waste disposal levy but ask that consideration be given to the way in which the waste to landfill is measured. Is it best to measure this waste by weight or is it more viable to measure it by volume? Is weight, as a measurement, being used in the Bill because most waste entering landfill is heavy industrial waste and therefore this is the waste that needs to be targeted?

It is also unclear how exactly the levies will be allocated and whom will bear the costs.

Key points
38) Disposal facilities to have weighbridges: We would like further explanation and consideration to be given to the way in which waste received from operators is measured. Is the cost of installing weighbridges at disposal facilities an economically viable option? We believe measurement of waste should be based on the volume of waste rather than by the weight of waste. It is the volume of waste that we should be trying to reduce.

Every disposal facility must include a recycling area in which credit can be given for recyclable material.

The cost to the consumer for rubbish bags needs to increase so as to serve as a disincentive to 'fill-up' the rubbish bag and as an incentive to produce less household waste encouraging reuse and recycling practices.

All household rubbish bags sent to landfill should be perforated to enable egress of air from the bag and ensure maximum compaction of waste in landfill. Consideration should also be given to introducing biodegradable plastic rubbish bags.

As household commercial operators cannot be accountable for the volume of rubbish produced by households, contracts should be issued by tender and there should be no penalty placed on the collectors for the volume of waste collected, but there should be some kind of incentive given to separate further before going to landfill. The penalty should be with the consumer, as a way of encouraging minimisation of landfill waste produced in the home.

Caution needs to be taken in the way this is introduced as we do not want to see increased roadside dumping or dumping in gullies and farms.

Summary:

• Further explanation and consideration needs to be given to the weight verses volume measurement of waste to landfill.
• There needs to be disincentives to householders such as an increase in the cost of rubbish bags.
• Caution needs to be taken with the implementation and monitoring of disincentives such as increased costs of rubbish bags so as not to increase roadside dumping or burning of rubbish.
• There needs to be further clarification of who bears the costs of the waste levies.

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Overview
We support the establishment of a Waste Minimisation Authority to manage the revenue received from waste levies and to distribute these funds into appropriate areas that will support and drive New Zealand's waste minimisation strategy.

Key points:
Part 2:8 Functions (i) & (j): We suggest that the governing board of the authority is required to create a sub-committee charged with investigation of international waste minimisation strategies and the development of these strategies for use in Aotearoa.

We suggest that the board is required to create a sub-committee charged with developing and providing educational resources and products describing the waste minimisation strategy and that these resources be made available nationwide.

Part 2:11 Membership of Authority: We agree that the governing board of the waste authority should be made up of no fewer than ten members. This is important for the authority to have a good representation across a variety of areas such as community, business and public sector.

Part 2:12 Eligibility for appointment as member of Authority: The Bill gives no consideration to appointing iwi representatives nor does it state anywhere in the list of eligibility for appointment that knowledge and experience of Te Tiriti o Waitangi, tikanga Maori and kaitiakitanga be considered. We strongly suggest that these be added to the list before the Bill is passed.

We would like to see the Authority work collaboratively with existing community operators. Investment should be made by the Authority to assist these operators to build the capabilities they need to continue doing the work they.

Summary:

• We suggest a sub-committee be charged with researching international waste minimisation strategies.
• We suggest a sub-committee be charged with developing and providing educational resources and products describing the waste minimisation strategy.
• We suggest that there be at least one iwi representatives appointed to the authority and that added to the list of 'Eligibility for appointment as a member of the Authority' be knowledge and experience of Te Tiriti o Waitangi and tikanga Maori.


• The Authority should recognise the exceptional successes and results community operators have achieved already and invest funding and support into building the necessary capabilities in these community operations rather than 'recreating the wheel'.

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Overview:
We support that public and private sector organisations should adopt and actively put in place an organisation-specific waste minimisation strategy/plan.

Funds received from waste levies could go towards the development of an organised framework that organisations can follow as well as towards the development of monitoring and measurement systems.

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Overview:
We support the public procurement policy and see it as a valuable statement illustrating the public sector's commitment to minimising waste. Furthermore, such policy supports the development of new industries and markets delivering goods that are ecologically-friendly, sustainable and made of recyclable or reusable materials.

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