South Australia Regional Waste Management

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					                  Submission to
           A NATIONAL WASTE POLICY:
              Managing Waste to 2020



                               May 2009




Prepared by: Riverina Eastern Regional Organisation of Councils
             P.O. Box 646
             Wagga Wagga NSW 2650
             Ph: (02) 69 319050 Fax: (02) 69 319040
             email:jbriggs@reroc.com.au www.reroc.com.au
        Riverina Eastern Regional Organisation of Councils
                           Submission
         A National Waste Policy: Managing Waste to 2020

It is with pleasure that we lodge this submission on the National Waste Strategy on
behalf of the REROC Waste Forum which is a sub-committee of the Riverina Eastern
Regional Organisation of Councils (REROC). This submission reiterates the points that
were made by REROC at the Public Consultation which was held in Wagga Wagga on
23 April, 2009.

REROC is a voluntary association of thirteen General Purpose councils and two water
county councils located in the eastern Riverina region of NSW. The members of
REROC are the councils of Bland, Coolamon, Cootamundra, Corowa, Greater Hume,
Gundagai, Junee, Lockhart, Temora, Tumbarumba, Tumut, Urana, Wagga Wagga,
Riverina Water County Council and Goldenfields Water County Council.

All the General Purpose councils are participating members of the REROC Waste
Forum. The REROC Waste Forum is a Voluntary Regional Waste Group and is partially
funded through the NSW Department of Environment and Climate Change. In preparing
this submission we have consulted with our membership.

National Policy translates to Local Implementation

Local government is the primary interface between the community and waste
management services and facilities. Our members wish to remind the Taskforce, in the
strongest terms that policy decisions made on a national basis inevitably trickle down
through the system for implementation at a local level, usually by local government.

National policy does translate into local implementation, by local governments, many of
whom are located in regional and rural locations. Therefore it is important that the
decision-making process at the national level remains alert to policy implementation
implications particularly for regional and rural communities.

Too often our members have found that policy decisions which can be easily
implemented in metropolitan regions, where there are multiple service providers, cannot
be implemented at reasonable cost in rural and regional locations. Fewer service
delivery options means less competition, transportation distances almost always impact
on the financial viability of service delivery and lack of a critical mass of market and/or
product often means that sustainable delivery cannot be achieved.

Our members encourage the Taskforce to include recommendations that recognise the
significant challenges to achieving sustainable waste management alternatives in rural
and regional Australia.


Transportation Issues

The REROC Waste Forum has over the last 10 years considered a number of options
for the reuse and recycling of waste products in our region. Significantly the Forum
undertook a Regional Organics Management Study some 4 years ago, which looked at
all the sources of organic waste within our region and the methods of disposal and
reuse that were taking place.




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One of the primary purposes of the Study was to determine whether there was scope
for a regional facility or facilities that could process the waste for reuse. There were two
outcomes that emerged – firstly there wasn’t sufficient raw material/feedstock available
to support the establishment of a dedicated regional enterprise and secondly even if
there had been sufficient feedstock the cost of transporting the product to a regional
facility was unsustainable.

Our members request therefore that the National Policy recognise the issues of tyranny
of distance in the transportation of waste and the manner in which this can impact on
the effective and efficient delivery of waste management solutions.

Extended Producer Responsibility and CDL

Our members support much stronger provisions in relation to Extended Producer
Responsibility (EPR). Our members’ preferred position is that EPR be mandated as we
do not believe that current voluntary arrangements effectively deal with waste products.

Our members believe that industry will not properly turn its mind to addressing the
waste issue unless there is an economic imperative for it to do so. The failure of the
current, voluntary approach leaves local government to pick up the pieces and the cost
as waste products inevitably find their way to municipal landfills. While industry reaps
the financial benefits generated by the sale of their products, local government wears
the cost. Tyres, e-waste and fluorescent tubes are just some of the examples of
products where disposal has been cost-shifted by industry to local government.

Our members strongly support the introduction of Container Deposit Legislation (CDL)
on a national level. The Forum understands that there are two arguments that are often
raised in relation to the introduction of CDL. The first focuses on the effectiveness of
such schemes on increasing the volume of containers collected for recycling and
second on whether CDL would undermine council kerbside collection initiatives.

In relation to the first argument our members consider that CDL schemes can assist in
increasing the volume of containers collected for recycling. One only has to compare
NSW where there is no CDL with South Australia where CDL has been operating since
the mid-1970’s. NSW has a recycling rate of around 40% for beverage containers, while
South Australia, has a rate of between 70-80%. Our members believe that the addition
of a real economic return for the collection of the containers will greatly reduce the
number of containers going to landfill.

We also believe that the introduction of CDL will support rather than undermine council
kerbside collections. The value of the unredeemed deposits from containers would
assist in making collections financially viable. In rural and regional areas recycling
initiatives are regularly delivered by volunteer community groups and/or supported
employment programs. Indeed, across our region the primary receivers of collected
recyclables are the locally-based supported employment programs. The operation of
these organisations are very vulnerable to the fluctuations in world market prices for the
materials they collect.

The introduction of CDL would provide a regular and consistent income stream that
could underpin the sustainability of these organisations. For example Tumut Shire
Council currently provides funding assistance of approximately $70,000 p.a. to its local
supported employment program to run a community recycling project. Council is
concerned that this level of contribution is not sustainable in the longer term. If CDL was
introduced then this funding could be partially replaced through the redemption of
deposits for the containers collected.



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Recognition of the Challenges of Adopting Innovative Waste Management
Strategies in Regional and Rural Areas

Our members encourage the Taskforce to include in the National Policy initiatives that
will support key stakeholders including regulators and government agencies working
together to deliver innovative responses to waste management.

As stated above there are a unique set of issues that confront the introduction of
Alternative Waste Technologies (AWTs) into rural and regional locations. In addition to
those outlined above is the problem of “thin” markets; that is markets that do not have
the critical mass necessary to support the introduction of high end waste technologies.

The REROC Waste Forum regularly works with our member councils and other key
regional stakeholders to identify innovative approaches to waste management issues.
For example we are currently working with Charles Sturt University on a Closed Loop
Organics Recycling project which will result in a low-tech model for organics recycling
that can be transferred to small communities.

The Forum’s Yours2Take project, www.yours2take.com.au an on-line resource
exchange project, is another example of how regional communities can embrace
innovative solutions to waste management. The project, which was launched in March
2008, enables users to give away items for which they no longer have use for to
someone who wants it. The site has over 3,300 registered users and receives
approximately 8,000 “hits” per month.

Our members would value the inclusion of frameworks that encourage greater
networking between stakeholders and agencies to provide stronger support, including
financial support, for the introduction of waste technologies and solutions that are
appropriate and sustainable in thin markets.

Recognition of the Challenges faced by AWT Enterprises operating in Rural and
Regional Areas

Across the REROC region, businesses have introduced innovative responses to waste
management issues. The region has enjoyed some significant investments by
businesses that have resulted in the establishment of AWT enterprises such as the
Southern Oil Refinery and Renewed Metal Technologies.

The establishment of these types of enterprises in rural and regional areas is not only
good for the environment it is also good for the economy. However, in our experience it
takes time for these types of businesses to reach a critical mass and become financially
viable. As stated above the tyranny of distance and the consequent cost of transport
can have significant negative impacts on the sustainability of such businesses.

Our members encourage the Taskforce to consider policy initiatives that support the
development of such businesses in rural and regional areas.

Consultation and Engagement with Key Stakeholders and the Community

Our members congratulate the Taskforce on its decision to host a regional consultation
in Wagga Wagga. The consultation provided our members and the general community
with a valuable opportunity to provide input into the national planning process.




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We encourage the Taskforce and the Department to continue to consult widely on the
development of the Plan as it is only through a genuine consultative process that waste
management issues can be successfully addressed.

We also encourage the Taskforce to include in the Plan provision for regular reviews to
ensure that the goals and targets set are being met. Our members would also support
the identification of opportunities with the Plan to hold consultations with key
stakeholders such as local government in order to ascertain how policy is translating
into effective, on-ground delivery.


Conclusion

Our members look forward to a cohesive, national approach to the issue of waste
management. We strongly support the development of a National Policy that
recognises the special challenges faced by regional and rural Australia to provide best
practice, innovative responses to delivery of waste management services and solutions.

Our members again express their thanks for the opportunity to participate in the Wagga
Wagga consultation and we look forward to participating in further consultations in the
future as the National Policy is developed.




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