From: noreply@yoursay.dpie.nsw.gov.au
Subject: Have Your Say DPIE - 20 Year Waste Strategy
Date: 6 May 2020 at 1:33:07 pm AEST
To: info@aloa.com.au

	

Have Your Say DPIE - 20 Year Waste Strategy	

Thank you for your submission of the form 20 Year Waste Strategy through Have Your Say DPIE
1. Do you agree that it is important to transition New South Wales into a circular economy, supported by waste and resource recovery services that are sustainable, reliable and affordable? Unsure  If 'No' please tell us why The circular economy is a logical step at the micro-economic scale, but on a larger scale the economy cannot be circular because of the external inputs. As long as large volumes of material that become waste are imported they cannot be part of the local circular economy unless there is a 'home' for them within the circular economy.  2. Where do you think the New South Wales government should prioritise efforts in improving recycling and resource recovery? Planning for waste and resource recovery infrastructure  3. Do you have other evidence (such as data, reports or specific examples) that can inform the 20-Year Waste Strategy for New South Wales? The Sydney Metropolitan Area relies on two landfills for the disposal of putrescible waste. In the event that either of these landfills closes for legal, financial or natural disaster reasons, the other cannot cope with the additional volume. Further, there is no other properly licenced landfill within 1,000km that can cope with the additional volume of putrescible waste in the event of an unplanned closure. This shortfall is a matter of public health, given the likely disease stemming from stockpiles of rotting putrescible waste.  
Direction 1: Generate less waste

4. What actions by government, industry and the community should be prioritised to avoid and ‘design out’ waste to keep materials circulating in the economy?
For a number of years there has been an extraordinary emphasis on recycling to reduce waste volumes. History has proven that no matter how successful a recycling program performs, the volumes of waste continue to grow as a whole and on a per capita basis.
Perhaps now is the time to focus on avoidance and re-use, that is, focus on prevention of waste rather than the management of materials circulating in the economy.

Option 1.1 State-wide targets 

5. What targets and metrics would be most effective in driving waste avoidance, reuse and the circular economy?
No comment.

6. How can these be implemented so they are most effective?
No comment.

7. What limitations should be considered?
No comment.

8. What additional targets and metrics could be used to drive emissions reductions from the waste system?
In order to minimise emissions, all active putrescible landfills should be required to implement a landfill gas capture program. At the moment many landfills are below the tonnage threshold decided by the Federal Government and landfill gas is liberated to the atmosphere. A landfill gas capture program will not reduce these emissions to zero but will make a significant improvement.

9. What are other opportunities to reduce greenhouse gas emissions from waste, while supporting the economy?
Greenhouse gas emissions are best removed by capturing landfill gas and burning it through a flare. The energy created by landfill gas burning can be captured and used as heat or can drive a turbine to produce electricity. This strategy should improve the support available for such activities.

Option 1.2 Designing out waste

10. How do we better design out waste?
No comment.

11. What priorities should inform product stewardship schemes and extended producer responsibility?
No comment.

12. How do we drive uptake of materials and products with lower life-cycle emissions?
No comment.

Option 1.3 Awareness and behavioural change

13. What are new and innovative ways to engage consumers to reduce waste generation and increase recycling?
No comment.

14. How can these be implemented so they are most effective?
No comment.

Option 1.4 Targets for government agencies

15. Would mandating waste reduction targets and data reporting requirements be effective?
No comment.

16. What issues or limitations should be considered?
No comment.

Option 1.5 Regulatory safeguards

17. What are the key opportunities for improving current waste regulations and regulatory processes in NSW?
NSW is fortunate to have an excellent set of waste regulations and regulatory processes. Rather than trying to improve a system that already exists, more effort should be directed at applying all of the regulations across all of the waste management facilities. Large, well-run facilities should not be the target of the Regulator; small, poorly managed, highly polluting facilities should be the focus of the Regulator.

Direction 2: Improve collection and sorting

18. What actions by government, industry and the community should be prioritised to improve the way waste is collected and sorted to maximise circular economy outcomes and lower costs?
No comment.

Option 2.1 Recovering food and garden organics 

19. What are the key opportunities and challenges associated with mandating food and garden organics source separation?
The widespread collection of food and organic waste is a simple way of reducing waste to landfill. Unfortunately, unless a market for the product from this process can be created, this material will remain unsold in stockpile, and potentially produce the landfill gas that it would have if left in a landfill.
The production of massive amounts of organic material should be contingent on the ability of the market to accept the volume and the price of the product in order that the organics does not reflect the failure of the recycling industry - that is, the ability to produce a product that nobody wants to buy.

20. What other options could be considered for recovery of food and garden waste?
No comment.

21. What are the key opportunities and challenges with reducing emissions from food and garden waste to achieve net zero emissions from organics by 2030?
No comment.

Option 2.2 Standardise collection systems for households and businesses

22. How could collection systems (including bins and drop off facilities) be designed to improve the separation of materials for recycling in your area and/or business?
No comment.

23. Should some sources of waste, e.g. multi-unit dwellings and small business, be considered separately? If so, why?
No comment.

24. What would work best for multi-unit dwellings and small business and why?
No comment.

Option 2.3 Network-based waste drop-off centres 

25. How do we further optimise NSW’s network of waste drop-off centres and collection points?
No comment.

Option 2.4 Waste benchmarks for the commercial sector

26. How can National Australian Built Environment Rating System (NABERS) Waste ratings be used as an effective tool to drive better waste management practices in the commercial sector?
No comment.

27. What opportunities and challenges do you anticipate if the NSW Government were to introduce minimum NABERS Waste requirements for the buildings it leases and owns?
No comment.

28. Are there opportunities to roll out similar requirements to other sectors?
No comment.

Option 2.5 Innovation and ‘waste-tech’ 

29. What are the key barriers to innovation in the waste and resource recovery sector?
The principle barrier to innovation in the waste industry is the difficulty in obtaining planning approval for new waste management facilities.

30. How can the NSW Government help to foster innovation and partnerships in waste management?
A vital component of the Waste Strategy is to identify the types of waste management facilities required into the future and identify the possible locations for such facilities. The NSW Government must embark on a partnership with industry to achieve this outcome on an urgent basis.

Option 2.6 Joint local council procurement

31. How can local councils best be encouraged or supported to collectively procure waste services?
No comment.

32. What are the key issues that should be considered?
No comment.

Option 2.7 Combining commercial and industrial waste collection services

33. What are your views on the opportunities and challenges of combining commercial and industrial waste streams?
No comment.

34. What are your views on the potential solutions of creating commercial waste zones, or combining municipal solid waste and commercial and industrial waste collections?
No comment.

35. What are your views on the right settings for these waste levy parameters?
No comment.

36. What other price-based incentives should be considered?
No comment.

37. Which would work best in practice?
No comment.

Direction 3: Plan for future infrastructure

38. What actions by government, industry and the community should be prioritised to ensure that infrastructure for managing waste is effectively planned, retained and managed?
A vital component of the Waste Strategy is to identify the types of waste management facilities required into the future and identify the possible locations for such facilities. The NSW Government must embark on a partnership with industry to achieve this outcome on an urgent basis.

Option 3.1 Long-term waste and resource recovery infrastructure needs

39. What data and information needs to be included in a waste infrastructure needs assessment to ensure it will effectively support planning and investment?
The best available data should be used to develop a waste infrastructure need assessment. This data is available from the NSW Government that collects the waste levy and therefore knows how many tonnes of waste are collected in NSW and from where.
Other data should be provided by those industries that are active in their fields, such as recycling, construction and demolition waste, organic processing to name a few.

40. What role should the NSW government, local councils and industry play in meeting landfill and recycling capacity needs?
The NSW Government should be providing the strategic envelope to allow industry and local councils to develop the infrastructure that serves the strategy. The strategy should identify the types of waste management facilities required into the future and identify the possible locations for such facilities. Industry and councils can then construct the landfill and recycling capacity that fits in with the strategy and satisfies the needs of their connunity and customers.

41. How can government and industry better encourage innovation in waste infrastructure, to ensure it is sustainable, adaptive and responsive over time?
No comment.

42. What are the barriers and opportunities to reducing greenhouse gas emissions from waste collection, processing, recovery and disposal?
From a disposal perspective, the great opportunity is to ensure that all gas emitting landfills install a gas collection system and a flare (to burn the gas). A further opportunity is to ensure that those disposal facilities generating sufficient gas to produce electricity are properly rewarded for their gas emission reduction.

43. What are the barriers and opportunities to improve waste transportation and logistics issues?
No comment.

Option 3.2 Place-based developments

44. What are the key opportunities and barriers to developing place-based waste infrastructure?
No comment.

45. What would a modern waste precinct look like and where is NSW could this work?
A modern waste precinct, properly managed, could work anywhere in NSW. If properly managed and regulated it would have no impact on its environment or community.

46. What is the role for government in achieving the desired outcomes and what are the most effective levers it can apply?
No comment.

Option 3.3 Making it easier to do business 

47. What mechanisms could be used to improve regulatory and financial certainty for investors and how could these be implemented?
No comment.

48. What are the priority measures that could be introduced to make it easier to do business?
No comment.

Option 3.4 Innovative financing models

49. What are your views on the opportunities for innovative financing models in the waste and resource recovery sector?
No comment.

50. How can government best facilitate investment in infrastructure and services that contribute to circular economy objectives?
No comment.

Direction 4: Create markets

51. What actions by government, industry and the community should be prioritised to grow sustainable markets for recycled materials?
No comment.

Option 4.1 Recycled content in government procurement

52. What are the main challenges and opportunities for using recycled content in state and local infrastructure projects and major development areas?
No comment.

53. Should procurement targets be established and what is the best way to develop and implement them?
No comment.

Option 4.2 Standards for recycled content and materials

54. What are the priority areas that standards and certifications should focus on?
No comment.

55. How critical do you think standards and certification are to developing markets for recycled content?
Standards and certification are interesting, but it is the market that determines both the quality of the product and the price. If "Rolls Royce" standards are developed and the market only wants to pay for a "Mini Minor" then the standards are redundant.

Option 4.3 Match suppliers with markets

56. How can industry and government best work together to foster partnerships and address information barriers to the uptake of recycled materials?
No comment.

Option 4.4 Best-practice regulatory environment for energy from waste projects

57. Are there policy and regulatory improvements that can be made to facilitate innovation and market development in the energy from waste sector, that do not compromise best practice environmental standards?
No comment.

58. Are there any other views, ideas or feedback you would like to provide?
The Australian Landfill Owners Association in deeply concerned about the lack of future landfill space available to accept Sydney's putrescible waste. We believe this matter became critical once the Eastern Creek Landfill was closed, and continues to be so. We have expressed our concerns to the Minister and leading officers in both the EPA and Department of Planning.
We are hopeful that one outcome of the strategy is to recognise the importance of landfill and the need to plan for it into the future in the absence of a better, safer and affordable method of disposal.

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Australian Landfill Owners Association

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Waste or recycling industry

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