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									Waste Policy Taskforce
Department of the Environment, Water, Heritage and the Arts
GPO Box 787
Canberra ACT 2601

Sent by email to wastepolicy@environment.gov.au

18th May 2009

Dear Sir / Madam,


This submission addresses a specific waste policy - container deposits - that opens up significant economic
opportunities (new jobs, new infrastructure, valuable resource recovery and new value-added reprocessing
opportunities) while generating nationally significant environmental and social benefits.

Summary of the Key Benefits of a national Conatiner Deposit System (CDS)

Revive Recycling’s submission to the Senate Inquiry (attached) discusses the benefits of increased recycling
of containers and how container deposits (CDs) are the only proven means to achieve high recycling rates.
Moreover it shows how if sensibly planned, they can support and underwrite kerbside recycling including
alternative waste treatment (AWT) plans and reduce the costs to local government, while creating an
infrastructure that can act as a catalyst for other important extended producer rensposibility (EPR) initiatives.

In summary, established technology options combined with a sensibly designed national container deposit
system introduced nationally will:

           a) double container recycling rates from ~40% to ~80%,
                 recovering an additional 6 billion containers annually
                 productively returning an additional >$100 million1 of plastic, aluminium, steel and glass
                 annually into the Australian economy
                 reducing environmental costs by $400-500 million per annum

           b) require no government funding (from state, or local government)

           c) provide the additional infrastructure needed for away-from-home container recycling. This also
              then removes a key obstacle to other important EPR initiatives, providing an infrastructure
              platform and corresponding consumer traffic, that will facilitate other EPR initiatives – e.g. for e-
              waste, household hazardous waste, CFLs, etc.

           d) underwrite kerbside incomes and reduce net kerbside costs and associated financial pressure on
              local government

           e) attract new investment of ~$400 million into Australia and generate an estimated 3000 new local
              jobs in collection and additional reprocessing

    At 2008 prices, when the attached submission to the Senate Inquiry was written.
                                   Revive Recycling Pty Ltd - ABN 90 111 224 018
                            6 / 42-44 Garden Boulevard, Dingley, Victoria 3172, Australia
    T: 03 9558 0344     F: 03 9558 0252 E: info@revive-recycling.com.au W: www.revive-recycling.com.au
This letter’s purpose is to address some high level issues raised by the consultation paper, while referring to
the more detailed case set out or referenced in Revive’s attached submission to the Senate Inquiry into the
Management of Australia’s Waste Streams (May 2008).

The comments below refer directly to the questions in the consultation paper and are numbered accordingly.

1. Are there opportunities to further coordinate, harmonise or streamline approaches to waste management
   across jurisdictions?

There are clear opportunities to harmonise waste management approaches to drive efficiencies and improve
outcomes. This includes recognizing and taking the best of what already exists throughout Australia (and in
comparable markets internationally), and applying it in a coordinated manner to raise overall standards and
outcomes and to benefit from economies of scale.

This is particularly true for extended producer responsibility (EPR) schemes, where
         a national infrastructure that is both efficient and convenient to consumers is essential to providing
         cost-effective take-back and recycling services
         the lack of such cost-effective infrastructure is the single largest impediment to the establishment of
         EPR schemes in many cases
         national approaches provide the necessary economies of scale, a sharing of cost burdens between
         different products covered by EPR (and hence a reduction in costs over alternative approaches) and
         the opportunity to invest in the necessary reprocessing infrastructure and market development (where
         national approaches also ensure that there is a level playing field and minimizes “border” issues

3. Do the current waste management frameworks across jurisdictions:
               deliver an effective regulatory framework?
               provide an appropriate suite of approaches to address waste and resource recovery issues?
               work effectively in conjunction with planning and other environmental legislation?
               provide the right incentives to manage materials, products and waste sustainably and
               need improving, and if so, how could this be done?

In the case of containers, deposits are a long-proven and effective regulatory approach in South Australia (as
well as large parts of the US and Europe) but have so far been ignored by other states despite the obvious
benefits. In many cases individual states, though recognizing the economic and environmental benefits, are
waiting for a national system rather than wishing to go it alone.

As such the present approach could clearly be improved through national adoption of a system that shares the
fundamental approach of South Australia (e.g. container coverage and deposit value) but also improves the
system in terms of transparent and efficient coordination, and the adoption of enabling technologies that can
further improve consumer engagement and convenience, and system costs and efficiency (see Section 4 of
attached document).

Incentives are vital to optimal outcomes. In particular these need to be focused at consumers, rather than just
downstream waste handlers, since it is at the consumer level that key purchase and disposal choices are
made. For example, landfill levies are useful in providing an incentive for materials recovery facilities and
others to divert certain low value, high volume materials and can drive investment in alternative processing
infrastructure. However, if consumers are not incentivised to recycle, the material in question may never
reach the MRF or recycling centre, or may be disposed of in a way that is uneconomical to separate and
recycle (a key problem with current away-from-home recycling of containers, as well as for a large variety of
wastes that are suited to EPR – e.g. e-waste, household chemicals etc.).

Consumer incentives drive better waste disposal / recycling decisions. A classic example is the use of
container deposits to incentivise good recycling behaviour, including for away-from-home recycling. Landfill

levies or ADFs do very little to increase away-from-home recycling not just because they are too blunt, but
because they do nothing to influence the initial disposal decision and hence cannot change basic problems
with low volumes of material collected and/or contamination.

Education typically only goes so far, and reaches only certain sections of the community, whereas economic
incentives are far more universal in their effect.

Finally such incentives are even more useful when they reflect the externalities of the decisions in question –
e.g. the environmental and social costs of not recycling vs recycling and avoiding virgin production.

4. In the 1992 National Strategy for Ecologically Sustainable Development, COAG endorsed the strategies
   and objectives for a national approach to waste management (Appendix A). Looking ahead to the next
   decade, how could these strategies and objectives be updated to provide the basis for a national waste
   policy that responds to current and future challenges and opportunities?

In general, there too often remains a focus on waste management rather than true environmental
sustainability, and reliance on overly simplistic measures of success such as overall waste diversion from
landfill. This ignores the enormous variation in lifecycle impacts of different material streams, and the
relative benefits of avoidance, re-use and recycling. It also means that avoided upstream benefits (such as
avoided virgin production) are often ignored. In terms of true sustainability benefits, tackling a relatively
small component of the waste stream with major impacts over its full lifecycle (via avoidance or recycling
for instance) may significantly outweigh the tackling of large volume waste streams with relatively low
impacts or low ability to offset upstream impacts through recycling.

Greater discrimination of impacts and benefits among waste streams, approaches that consider full lifecycle
impacts (from cradle to grave and back to cradle) are essential for a truly holistic approach that seeks to
create closed loops in which maximum value is extracted from recycled resource streams (preferably without
significant loss of quality).

5. What waste issues would most benefit from a national approach? What strategies could be considered
   and how could the need for local solutions be integrated with a national approach?

EPR schemes are particularly well suited to and assisted by a national approach. Such an approach provides
the opportunity for the necessary reprocessing infrastructure to be shared across states and and provides
sufficient volumes for market development (local markets often have not yet been established because
materials are not available in sufficient quantity or quality to encourage the investment in the necessary

Among these, rigid containers should be considered as a priority waste stream because:
    they are a high value resource, of which approx 60% is currently wasted
    they are relatively homogenous and easy to recycle with established markets – a “low hanging fruit”
    they have relatively high environmental lifecycle impacts in terms of air emissions (greenhouse gases,
    smog precursors) and energy consumption, and their recycling offsets the majority of these providing
    significant environmental cost savings
(see Section 2 of attached submission to the Senate Inquiry)

In addition, container deposits are not only an effective EPR scheme in themselves but the unredeemed
deposits fund an infrastructure that can be leveraged and provide a foundation for other EPR programs (see
answer to Q8 below). Because of the deposit incentive and the fact that containers are widely and frequently
consumed throughout the community, container collection points provide an ideal location for the additional
collection and recycling of other materials (the make up of which may vary according to local consumption
patterns and markets).

 This potentially allows cost sharing across a number of EPR programs, and hence reduced costs for any one
of these. It also provides a ready infrastructure for new EPR programs to plug into.

6. Are there waste management initiatives in operation overseas that could apply in the Australian context?
   If so, which ones and why?

Yes. Container deposits are widely used overseas in 11 US states and various European countries and achieve
recycling rates mainly in the range of 70-95%. (see Section of 2.5 of attached Senate Inquiry Submission)

Deposits are working side by side, and supporting municipal kerbside programs in major markets such as
California, Germany, and Canada. Other systems (e.g. British Columbia) already provide models of how
CDL infrastructure can drive additional material recycling and EPR initiatives.

There is much to be learnt from both system design and from the technologies being applied (such as reverse
vending machines), but there is also a strong case for adapting overseas approaches to local needs and
conditions (e.g. the use of RVM technology outside of retailers in self-contained Automated Recycling
Centres – see Section 4 of attached document).

7. Australia needs to safely manage hazardous waste and waste containing hazardous materials over the
   long term.
               Are there any changes to current arrangements that would improve Australia’s capability to
               safely manage hazardous waste, for example in regard to adequate infrastructure or
               disclosing the contents of goods and substances?

EPR approaches are vital in addressing hazardous waste, including for hazardous wastes arising from
consumer products but not currently classified as hazardous and channeled through normal kerbside and
other municipal collections due partly to lack of alternative end-of-life options.

Convenient, consumer-focused infrastructure is a critical component of an effective approach. As mentioned
above, container deposit legislation can play a constructive part by providing an infrastructure foundation for
this - e.g. see the concept of drive through recycling centres (DTRCs) developed in NSW and the “hub and
spoke” approach advocated by the Boomerang Alliance, both of which lend themselves to CDL and to a
broader EPR platform (see answer to Q8 below).

Addressing hazardous waste streams is important not only to avoid negative health and environmental
impacts, but also to ensure that such materials do not adversely affect the quality and marketability of other
materials recovered from the waste stream. The example of organics is a good illustration. Contamination of
the organic stream with persistent organic pollutants and other household products limits the use of organics
in closed loops for agricultural use, due to the potential for the build up of harmful toxins. This in turn means
that organics need to be source separated in order to meet appropriate standards and attract reasonable selling
prices, which in turn affects the commercial viability of organics recycling.

Small amounts of contaminants can affect the quality and salability of large volumes of resources. On the
other hand if such contaminants were better regulated and alternatives provided for their disposal (e.g. at
recycling centres as described below under Question 8) then such problems could be minimized.

8. There are a number of approaches to product stewardship operating in Australia.
               What, if any, role is there for a national approach and what would be the costs, benefits,
               opportunities and focus of such an approach?
               What models might work in Australia?

EPR and product stewardship approaches enable high value, or high impact waste streams to be effectively
managed throughout the supply chain and post-consumption. They also provide opportunities to separate
materials after consumption in order to process separately and/or to prevent contamination and maximize

As mentioned in the consultation paper, such approaches are growing rapidly overseas and are increasingly
being adopted in Australia also. EPR approaches are particularly well suited to a wide variety of wastes that
are presently not adequately addressed. These include, for example, e-waste, brown and white goods, CFLs,
batteries, and household chemicals.

A suggested model that has a lot of merit and provides significant flexibility and opportunity for low-cost
expansion once established, is the idea of drive through recycling centres (DTRCs). These are established in
conveniently accessible locations for consumers (public and businesses) to bring a wide variety of waste
products for recycling (and or repair, resale). A network of such centres then provides an infrastructure
platform for the development of a range of product stewardship and EPR initiatives.

The Boomerang Alliance’s proposed “hub and spoke” model for container deposit infrastructure builds on
the DTRC idea:
       Hubs will be centrally established to collect containers directly from the public and also to
       consolidate and administer collections from a number of “spokes”.
       “Spokes” are smaller convenient recycling points for containers (such as the Automated Recycling
       Centres shown in Section 4.2 of the attached submission to the Senate Inquiry). These are
       established in accessible, high traffic locations such as shopping centre or supermarket car parks,
       and open extended hours. Spokes provide a convenient point to recycle containers (and potentially
       other high-turnover, frequently consumed items) at locations that consumers are already visiting
       Hubs act as the coordination points for the spokes but can also handle a broader range of materials
       and expand into the collection of other waste streams, forming a vital collection infrastructure
       network for EPR and product stewardship initiatives, much like DTRCs.
       The large volume of containers brought for recycling, combined with the deposit incentive, ensure
       regular public visits to both the hubs and spokes and helps to educate and encourage participation in
       other recycling / EPR programs. Indeed it is interesting to note that several collection depots
       established under South Australia’s CD system, are already demonstrating similar initiatives,
       handling scrap metal, car batteries, and e-waste.

CDL funds the initial hub and spoke infrastructure which can then be expanded, under cost-sharing models
between various EPR programmes. This approach provides a means to lessen costs of any one scheme and
provides an infrastructure platform that makes it relatively easy to add new industries / products as the need
arises. It also minimizes consumer travel (by providing single convenient locations for multiple
products/wastes) and helps optimize logistics.

Implementation on a national scale brings additional education and communication benefits, ensuring a
single coherent message no matter where in Australia an individual or business is based, and ensuring
education and communication programs enjoy economies of scale.

10. What fundamental data sets does Australia need to collect to better inform waste management policies,
    practices, investment, business operations and to assess and manage risk?

It is important to collect data on waste quantities (e.g. in units of mass) by material type and by the major
constituent parts of each material type – e.g. not just aluminium quantities, but also quantities of aluminium
cans. This recognizes that the strategies for dealing with aluminium cans are very different from, say,
aluminium window frames; or, for example, the approaches to polyethylene bags are very different from
those needed for polyethylene containers.

This then allows tracking of material constituents and measuring the success of specific strategies, rather than
lumping materials all together, where successes in some areas can offset failures in others.

11. What, if any, place should there be for approaches that seek to avoid waste through changes in design,
    production processes and transport?

This is an important area, in terms of improving the options for closed loop recycling, and particularly in
terms of minimizing and restricting hazardous waste as well as waste that can adversely affect the ability to
effectively recycle other waste streams (e.g. the organic waste stream, as mentioned in Q8 above).

Greater emphasis (including potential regulation) on product design, including encouraging green design or
“design for disassembly” is a key area for future consideration. Such approaches facilitate more economic
means to recycle and re-use, conserving resources and avoiding virgin material production and the various
environmental impacts that accompany these (e.g. greenhouse gas emissions; solid, liquid and other gaseous
emissions; water consumption; deforestation and loss of habitat etc.).

12. What changes could be made to improve management of the municipal waste stream and those of the
    commercial and industrial sector and the construction and demolition sector?

CDL provides incentives for containers to be recycled wherever they are consumed. As importantly the
infrastructure they provide – e.g. a hub and spoke model – provides a convenient platform for the collection
and recycling of many other waste streams and the implementation of a wide range of EPR programs. These
include providing convenient collection infrastructure for batteries, compact fluorescent lamps (CFLs), e-
waste (mobile phones, computers, TVs etc.), white goods, furniture, oils, household chemicals etc. as
described above.

13. Landfill is currently the primary means of waste disposal. What, if any, changes need to be made to
    manage Australia’s waste stream in the long term given current trends in the volume and nature of the

A greater focus needs to be placed on closed loop systems and sustainability, rather than simple end of life
management to which landfill is presently too often the lowest cost solution (due to large externalities
throughout product lifecycles).

Such a focus involves changes throughout a product lifecycle including better product design at the front end
(for example, design for disassembly and re-use/recycling), and a combination of consumer incentives and
convenient collection infrastructure at the rear end (e.g. with the aim of making recycling as convenient and
commonplace as shopping).

14. Reducing the amount of organic waste sent to landfill has the potential to contribute to reducing
    greenhouse gas emissions as well as other potential environmental and economic benefits. What are the
    benefits and opportunities, costs and disadvantage of increased diversion and/or recycling of organic

Major benefits can be realized in terms of both avoided methane emissions, and the generation of renewable
energy (from captured methane) as well as the production of compost / soil amendment products. This allows
a closed loop recycling of nutrients back to our soils, improving soil health, organic (and hence carbon)
content, and lessening requirements for chemical fertilizers.

However such approaches can be undermined by contamination from other products – e.g. glass, household
chemicals etc. Effective EPR approaches need to be targeted to materials such as these that are not only
important to recycle or dispose of safely in themselves, but which have the potential to have far-reaching
consequences on the recyclability (and/or the end value) of other waste resource streams. Container deposits,
and its associated infrastructure, provides opportunities to implement such approaches.

15. What, if any, changes are needed to the way e-waste is managed?

A widespread and more high-profile collection infrastructure will be key to ensuring a major step up in e-
waste recovery and recycling. Again, a CDS infrastructure can provide an effective backbone for such an
approach, avoiding the need for setting up multiple separate collection infrastructures for e-waste, and any
other EPR schemes.

ADF, as suggested in the consultation paper, provides half the solution: funding for collection and recycling.
However a deposit on electronic goods (refundable either in full or part) would likely be a better solution in
that it can provide both the funding required for collection and recycling and the incentive to ensure the items
are actually brought in for recycling and in adequate volumes.

16. The Carbon Pollution Reduction Scheme will apply to emissions from landfill.
        Are there related approaches that would complement the scheme and thus contribute to meeting the
        emissions targets and the timeframes set in the Australian Government’s climate change policy?

The CPRS covers only one part of waste disposal and really does not address resource recovery (including
upstream avoidance of greenhouse emissions). There may be some relatively minor impact on recycled
material prices by virtue of a carbon price boosting costs for virgin material production. However in the case
of containers (and a range of other materials), the key to greater recycling is accessing the material in a
format that is economic to transport and sort, and providing the consumer incentive to provide the material in
such a format.

The CPRS will certainly not be a fix-all in relation to climate impacts, let alone other environmental impacts.
Moreover it is important to recognize that far more targeted approaches to the various individual parts of the
waste stream are also necessary and can have far-reaching climate and other environmental and economic
benefits (e.g. in terms of avoided upstream impacts from extraction and manufacturing). One study2, for
example, suggests that that the introduction of container deposits in Australia could save over 1.7
million tonnes CO2e per annum – a huge saving and the equivalent of taking approximately 350,000
cars off the road.

17. What are the opportunities to reduce water and energy use through the way waste is managed?

Primarily, reductions in water and energy usage are achieved by reducing waste in the first place or offsetting
virgin production upstream through recycling or re-use. A sustainable, closed-loop approach recognizes that
in the vast majority of cases reduced wastage, or increased re-use and recycling avoids upstream extraction
and manufacturing impacts including not only water and energy consumption but also air, liquid and solid

18. In what ways can waste management and resource recovery (including recycling, re-processing, re-
    manufacturing) industries add further value to the economy and create employment?

In a truly sustainable paradigm industry and consumer patterns will be restructured away from linear material
flows (from mine to product to landfill), towards cyclic, closed loop flows (from recovered resources to
product and back for further recovery) via the resource recovery industry. Under such an arrangement the
waste management and resource recovery sector takes on an equivalent scale and importance to today’s
extractive industries – mining, forestry etc., which gives some indication of the growth potential for this
sector of the economy.

In the specific case of CDS, a national system will create very substantial economic value (see Sections 4.2
and 7 of attached submission to the Senate Inquiry):

    Warnken ISE, “Carbon Value Proposition of Container Deposit Recycling” 2007

          diversion of wasted resources to productive economic use (with financial value of >$100 million)
          job creation in collection infrastructure and re-processing – approx. 3000 direct and indirect jobs
          created nationally
          reduced kerbside costs – reduction in local government costs nationwide of >$100 million per annum
          reduced environmental costs to society at large – quantified at $400-500 million per annum
          platform for additional EPR and other collection programs, that can derive substantial cost-savings
          and accessibility from an existing CD infrastructure

If I can be of any assistance with additional information please do not hesitate to contact me.

Yours faithfully,

Markus Fraval

Chief Executive Officer

L National Waste Policy submission 18-5-09


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