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Caroline Le Couteur
ACT Greens MLA
Submission to the draft ACT Sustainable Waste Strategy
For further information Caroline Le Couteur MLA Greens Member for Molonglo GPO Box 1020 Canberra ACT 2601 Tel: 02 6205 0051 Email: email@example.com
Introduction and Summary
The ACT Greens welcome the opportunity to contribute to the ACT Government’s draft waste strategy. We congratulate the Government for producing a draft strategy that is ambitious. In particular we are supportive of: • • • The setting of an ambitious resource recovery target of greater than 90% The ‘streaming and cascading’ approach to waste, which seeks to achieve the highest and best use of resources. Opportunities to manage biosolids more sustainably.
However, we believe there are several areas where the strategy should be strengthened, improved, and revised. In summary, Greens MLAs argue that the strategy should: • • Favour source separation of resources and recycling of materials for their ‘highest use.’ Reassess the value of the third bin collection system for organics and examine the various advantages and options for implementing such a system (including by conducting a collection trial, as per item 3.4 of the Labor-Greens Parliamentary Agreement). Adopt further initiatives for the commercial sector to ensure a higher recovery rate of source separated materials. Introduce public place recycling to maximize the recovery of source separated recyclables from town centres/events etc. Favour windrow composting and anaerobic digestion as the recycling methods for organic resources that will bring the most environmental benefits. Articulate a strategy for separating and recycling toxic materials, including by supporting convenient drop off points for residential wastes such as batteries and CFL globes. Articulate a stronger strategy for reducing the production and consumption of resources and waste. Favour pyrolysis where a suitable feedstock is available to make high quality biochar, and where this will not compromise recycling and highest use recovery. Initially a small plant, targeted to a particular feedstock that has no higher use would be most appropriate for the ACT. Undertake a cost-benefit analysis that includes the long-term environmental benefits of different options. This analysis also needs to include windrow composting (which should not have been excluded by the draft strategy).
• • •
We are also concerned about how the Government will implement this strategy. We wish to emphasise the following: 2
As the draft strategy makes clear. there is a danger that companies will demand contracts that guarantee them a continued feedstock. and there is no time to delay. companies will want to optimise the waste streams entering pyrolysis/gasification technologies to maximise profits. The Government must commit to the principles and targets in the strategy and continually evaluate all actions on them to ensure they are being met. There is a danger that deferring to markets for the major parts of the waste strategy will be to the detriment of the policy outcomes. As a more specific example. which may not always align with achieving the best waste management and sustainability outcomes. The waste strategy will not mean anything unless there is a long period of commitment and follow through. The initiatives should be realized through the budget process as a priority.• The strategy requires a consistent and dedicated implementation effort. 3 . the ACT’s resource recovery rate has stalled and slightly declined. We have made more detailed comments below. As an example: in the area of waste processing. Significant environmental and community benefits come with improved waste management and recycling. Unfortunately. but the biochar by-product may be unstable for long term carbon storage). But this can be to the detriment of environmental outcomes (ie they may produce more electricity. • The Government must make policy outcomes clear before engaging the market. This then interferes with what should be our primary goal: reducing the amount of waste that we produce in the first place. This new strategy should have been prioritised a number of years ago. The Government should start taking comprehensive action to reduce waste and increase recycling without delay. the Greens have seen too many Government plans and strategies that have largely amounted to rhetoric. The efforts made in this area are a significant step toward addressing climate change and resource depletion. The ACT Government has given too little attention to recycling and waste reduction in the last five to six years. Businesses will obviously be focused on profits. • The implementation must be timely. and only engage the market in a way that ensures these outcomes.
It avoids energy and materials use. clean recycling instead of dirty recycling. There is strong evidence that this approach will bring the best results for the ACT in terms of the quality of resources recovered and hence the re-use value of the resources. we make the following points: a) Source separation delivers the best-quality organic material for use in composting or anaerobic digestion.‘Dirty’ vs. under which resources are separated at the source (ie by whomever is creating the waste . ‘Clean’ Recycling A key plank of the strategy in terms of recycling (part 7) is to use a ‘Mixed Residual Material Recovery Facility’ (or ‘dirty MRF’) to sort residual waste.the resident. High quality organic material can be used to enrich soil and this has excellent environmental benefits. or the business). resulting in the highest quality compost/digestate to use in the soil. Source separated organics present the best material for use in composting and anaerobic digestion. The cost-benefit analysis used by the strategy does not recognise these benefits and therefore undervalues the recycling options that produce high quality organic material. and reduces the negative environmental impacts of fertiliser/herbicide/pesticide use. The replacement of chemical/oil based fertilizers. Providing a ‘third bin’ for organic waste is an example of a source separation approach. as well as the best overall environmental benefits. We ask that the Government rethink its preference for dirty recycling. and separate it for recycling (or for further processing). this is likely to achieve a good level of resource recovery. To substantiate this argument. If done using best practice. a very important feature in combating climate change. and would be a significant improvement on the ACT’s current system. This assists in decreasing the use of herbicides and pesticides. This ‘dirty MRF’ approach can be contrasted to a ‘source separation’ approach.1. Briefly. That is. We appreciate that the dirty MRF can receive unsorted waste. Improvement of soil fertility – including the ability to reclaim degraded land and improve food production. these benefits include: • • The ability of enriched soil to sequester carbon. • . ACT Greens MLAs contend that the draft waste strategy should favour a source separation model. usually by separating them into different containers. which sends many materials to landfill.
n3 5 .• • • • The potential to reclaim saline-sodic soils. The lack of consistency in the organic material coming from a dirty MRF requires it to be assessed on a ‘batch by batch’ basis and requires very high levels of quality assurance. 2010.com. Soil improvement is a valuable action that individual States and Territories can take when many climate change strategies operate on a federal or global stage.au/documents/SoilPolicy-Discussion-Paper-Oct08_000.pdf) 4 Above.pdf) 3 National Committee on Soil and Terrain (DAFF). One of our main food security challenges is our increasing land degradation and soil fertility decline. and maintains the ability of soil to continue producing food. August 2008. Opportunities for the ACT as an individual jurisdiction to make a significant contribution to mitigating climate change.au/wpcontent/uploads/FoodSecurity_web. reduces the erosion of soil. those nutrients are permanently removed from the natural system. The above benefits are particularly important in the context of growing food security and soil problems in Australia and worldwide. This is made clear in the independent 2008 Wright report on waste technologies. While some compost from these facilities can be used for rehabilitation of degraded land. it is generally not usable for food growing due to contamination problems. which concluded that alternative waste technologies (AWT) using resources from mixed residual waste ‘is still to be reliably and 1 This argument was presented by Tim Flannery : Tim Flannery. By turning organic matter into low grade compost.1 Producing high quality organics adheres to the principle of valuing ‘waste’ as a resource. 25 May 2010 2 PMSEIC.’ 4 Dirty MRFs have problems creating good organic matter Our understanding is that dirty MRF facilities in Sydney have serious difficulties producing a usable compost product from the processed organic waste.3 Organic matter plays a critical role within soils and ‘improving soil carbon levels and moisture-holding capacity is also a critical objective at a wider landscape level from both a greenhouse and a water management perspective. Producing high quality compost returns nutrients to the natural system. (http://www. which reduces the need for irrigation. They have struggled to obtain ‘compost certification’ for the product and have had problems with contamination and poisoning.chiefscientist.triplehelix. Speech to Darwin Writers Event. it maximises the potential for resource reuse rather than allowing contamination and ‘downcycling’ of resources into low grade products.2 The services provided by soils are irreplaceable and invaluable and they are ‘a fundamental requirement for the future prosperity of Australia’. (http://www. Managing Australia’s Soils: A policy discussion paper. Now or Never. Engineering and Innovation Council. Australia and Food Security in a Changing World. keeping it as a closed loop.gov. forestry applications or landfill rehabilitation. The Prime Minister’s Science. or even electricity. produces better food.
pdf) 6 . AWTs as applied to source separated materials such as organic wastes ‘are well-proven and viable technologies’. and include further discussion about soils. 2008. cheap. b) The strategy does not consider wind-row composting as an option The strategy and accompanying documents do not include ‘out of vessel composting’ (ie windrow composting) as part of the analysis and modelling. Recommendation: The strategy should also prioritise using waste management options which improve soils in the ACT. and numerous other cities around the world. biochar etc). including the inability to produce high quality organic matter.environment. Corkhills at Mugga Lane currently uses a version of windrow composting to process garden waste. It is an excellent and viable method of treating organic waste (both food and green waste that has been source separated).independently verified to deliver sustainable and significant reductions in waste to landfill and products that are readily saleable on diverse and robust markets. as they suffer major issues if they do not have a high quality organics as their feedstock. It is a simple. (http://www. Recommendation: The strategy should articulate and assess the various problems with dirty MRFs.5 The organic matter produced by the dirty MRF will not be ideal for use in the AWTs described in the strategy. As is made clear in UNSW’s ‘Life Cycle Inventory and Life Cycle Assessment’ of windrow composting systems: ‘The study clearly 5 Wright Corporate Strategy. It is the system that is being used in other jurisdictions that are source separating organics – such as Goulburn.gov. biological processing of organic materials that produces compost products for use as soil conditioner and topsoil additive. South Australia. It should been included in the strategy and modelling.’ In contrast though. non-intensive method. AWT Update for ACT NoWaste. that this will cause the AWTs to perform poorly and to produce a low quality end product (digestate. The Greens are concerned that if the Government decides to pursue AWTs and to use a feedstock derived from a dirty MRF. Recommendation: The strategy should favour source separation of organic material (through a third bin approach) and it should provide detail on the environmental benefits of producing high quality organic compost. Windrow composting is aerobic. It would waste the opportunity to produce high quality organic matter and we would lose the important benefits from all the applications listed above.act. and some food waste. Organic materials are piled in long piles and periodically turned. Using a dirty MRF will produce organic matter that is not very valuable or useable. hot.au/__data/assets/pdf_file/0020/151373/Alternative_Waste_ Technologies_ATT_2. and the problems with using the organic matter in AWTs.
such as reduced soil erosion. which would be significantly cheaper. the costing of the third bin option includes the cost of constructing a facility to collect the waste. In addition. whereas the ACT Government modelling does not. and plastics) and composting/anaerobic digestion (for biodegradable waste) gives the lowest net flux of greenhouse gases. improved carbon sequestration. excluding windrow composting specifically distorts the comparisons of economic costs. including by providing detail on its significant environmental.nsw.au/resources/warr/2006400_org_lcassesswindrowsys.7 By failing to assess windrow composting and its considerable environmental benefits. etc. (note the study considered a range options including incineration.pdf). as well as how its use will improve the cost-per-tonne figure of a third bin system. for Department of Environment and Conservation NSW Wales. University of NSW. the ‘cost-per-tonne’ figure for a third bin collection system is inflated.environment. the strategy and accompanying material skews the overall costbenefit assessment in favour of co-mingled processing. (http://ec. It does not consider windrow composting. Much of this benefit is achieved when quality composted products are applied to soils to quality composted products are applied to soils to enhance soil health. AD) 7 . 2006 (http://www.gov. and cost benefits. Modelling the ‘cost-per-tonne’ figure of a third bin system that uses window composting would make the third bin option a lot cheaper.pdf) 7 AEA Technology for the European Commission. Because of this. compared with other options for the treatment of bulk MSW. Recommendation: The strategy should consider windrow composting as an option for processing organic material. July 2001.eu/environment/waste/studies/pdf/climate_change.’6 The UNSW study takes into account the post-application impacts of composting systems. the strategy does not account for the full environmental benefits of the other slower composting methods 6 Recycled Organics Unit. pyrolysis. fertility and productivity. In the consultant’s analysis. Life Cycle Inventory and Life Cycle Assessment of Windrow Composting Systems. pyrolysis. metals. Waste Management Options and Climate Change: Final Report. textiles. because windrow composting is suited to source separated material. The EU concluded similarly when it assessed the best waste management options in terms of climate change: [S]ource segregation of MSW followed by recycling (for paper. management. gasification.europa. and anaerobic digestion. c) The modelling does not account for the extensive environmental benefits from source separation/composting As well as overlooking windrow composting.demonstrates that this approach offers substantial benefits to the environment. with reference to in-vessel composting.
capital intensive strategies that involve alternative technology facilities. not only in terms of environmental benefits. the consultant’s modelling (see table 5.(in-vessel composting. But the modelling only accounts for this in economic terms – by attributing RECs – and ignores the environmental benefits. Nor is the environmental benefit of displacing greenhouse gases.mass. a study by the Tellus Institute for the State of Massachusetts concluded that: Our review of the LCA (life cycle analysis) literature and our modelling outputs confirm that.gov/dep/recycle/priorities/tellusmmr. the significant benefits that high quality organic material has on soil and food production are not factored in. but also in terms of costs and certainty. anaerobic digestion). n9. Again. concluding that ’their likely need for long-term contracts to ensure an adequate feedstock waste stream may limit the future flexibility of the state’s overall materials management efforts. waste diversion through recycling and composting is the most advantageous management option from an environmental and energy perspective. Losing the ability to be flexible in our waste management is a real danger and could thwart the opportunity to achieve the high levels of resource recovery proposed in the strategy. and unfairly disadvantages composting systems in comparison to alternative technologies. December 2008 (http://www.doc) 10 Above.9 The study goes on to point out problems with the more complex. As UNSW’s ‘Life Cycle Inventory and Life Cycle Assessment’ points out: “the exclusion of total environmental impact criteria from [Life Cycle Analysis] devalues the key environmental benefits resulting from compost application. n6 Tellus Institute. proven methods of waste management (source separation and composting) instead of more complex. 9 8 8 . The Government must not treat the analysis and cost-benefit studies accompanying the waste strategy as conclusive. allows waste-to-energy technologies to create more electricity (thus reducing GHG emissions by creating ‘cleaner’ electricity). this makes the third bin option underperform in the overall cost benefit assessment.’10 We agree that there are considerable advantages to pursuing simpler.1) shows that using cleaner organics. For example. The work of other consultants suggests that source separating and composting will provide the best overall sustainability benefits. after source reduction. which have been separated through a third bin rather than a dirty-MRF. Assessment of Materials Management Options for the Massachusetts Solid Waste Master Plan Review. capital intensive technology such as a dirty MRF. For example.”8 This occurs throughout the strategy in many ways. It must factor in the significant environmental benefits that are not included in the modelling. Above. For example.
For example. it is not clear whether the estimated costs those of the most efficient and well-thought-out third bin collection service. whereas the technology providers are likely to have underestimated the cost for which they can build a facility and provide a service. and there are many ways in which such a system could work. and the ‘cost per tonne of capacity’.11 It is likely that TAMS has supplied a conservative (expensive) estimate. It should reassess their accuracy for use in a reworked cost-benefit analysis. It is often the case that the costs of the final project end up being much more expensive than those originally suggested by a contractor. the reasons listed are unconvincing. when a third organics bin is introduced.Recommendation: The strategy must account for the wider environmental benefits of source separation/composting in its analysis. Recommendation: The Government should publish the full costings of – and assumptions made about . It is also not clear whether the third bin costings include collection of a third bin from commercial properties. But the figures for the other options . But from the data provided. significant savings could be made by reducing the collection frequency of the existing landfill bin. and is overly focused on potential problems with this system. with all relevant assumptions. Cost savings are often overlooked in assessments of third bin systems. 11 See ‘Methodology’ section of the URS Supplementary Economic Report. e) The strategy overemphasizes potential problems with source separation and a third bin While the draft strategy does not favour using a third bin model in Canberra. and the Government should reassess which methods of waste management actually provide the greatest cost/benefits. the Government must publish a breakdown of how TAMS has determined the costings for the capital expenditure. or at least inappropriate for a comparative analysis.such as the dirty MRF . d) The third bin option should be re-costed The costing for a third bin that is used in the modelling may be inaccurate. The consultant’s modelling determined the cost of delivering a third bin service by adopting figures provided by TAMS.come from the suppliers of the technology. how this has been costed. 9 . In addition.the third bin collection. The strategy takes an overly pessimistic view of people’s ability and willingness to source separate effectively. if a fee-for-service was factored in etc. for a third bin system.
This contrasts to the ‘high’ and ‘moderate to high’ risks of other options. Above n5. (http://www.The strategy notes concerns about smell. Enclosed/covered composting of source separated organics receives the same rating. they are also likely to become proficient at using a third bin. Goulburn. These jurisdictions are finding solutions to challenges presented by smell. etc) as well as in many cities throughout Europe and the US. and better evidence and experience in how to run information campaigns. Canberra is in the highest percentiles for education and public participation. We can use the lessons from that trial. ACF’s Sustainable Cities Index 2010. p34) See the 2010 Keep Australia Beautiful study. In the review. for example. pests.14 The evidence does not support the assertion that Canberrans will not participate in or correctly use a well run organics source separation system.12 The strategy’s approach also undervalues how good the Canberra community is at recycling. and odour. achieving effective separation of organics. The Wright review of AWTs confirms that there is a low risk of adverse events occurring when using a source separation/composting strategy. an excellent record of keeping litter levels low.org. Port Macquarie. We would submit that these issues can be overcome.au/files/NLI/NLI%20homepage/0910%20Reports/100923_4_mtr_nli_091 0_report. We now have more advanced systems. (http://www. pests etc.org. open windrow composting of source separated organics receives a ‘low-moderate’ risk that an adverse event will occur.13 and excellent levels of education and community participation. messiness and contamination as the prominent reasons for not favouring source separation of organic waste. This is happening in Australia (South Australia. managing contamination. such as the ‘composting of organics from mixed residual waste’ (ie a dirty MRF). Evidence suggests we are the right type of city to achieve good outcomes from a third bin system. Just as Canberrans grew better at using their kerbside recycling. product quality and application. The trial of organics collection that was run in Chifley achieved a 90% participation rate and low contamination rates.pdf) 14 See. These moderate and high risks include commissioning delays. where Canberra had the lowest rate of litter per square km. and they are also using open windrows to compost the collected organics.pdf) 10 . including compostable bags. 12 13 AWT Update for ACT NoWaste. willingness of people to participate. Our city has excellent levels of domestic recycling. But this could be improved on today. We note that many other jurisdictions are running successful organics third bin programs.acfonline.au/uploads/res/2010_ACF_SCI_City_Fact_Sheet_-_CanberraQueanbeyan.kab. and a ‘low-moderate’ ‘consequence level of the adverse event’.
contamination in food waste collected from kerbside appears to be very low and cause no problems at composting facilities. Laws to support organics recycling Another option that has not been explored in relation to third bin collections is the opportunity to use a regulatory framework to support higher levels of compliance and participation. San Francisco turns all of the source separated food waste it collects into compost. recycling and rubbish services for the tenants.pdf) 18 See the San Francisco City council site. and black for landfill waste.18 The scheme is supported by warnings and potentially fines for failing to sort waste correctly. Property owners and managers are required to provide composting. Recommendation: The strategy must rework its assessment of the third bin collection system.lakemac. Co-Collection of Domestic Food Waste and Garden Organics: The Australian experience.org/our_programs/interests.com. Japan. December 2010. Collecting the bins weekly is likely to make a significant improvement to the amount of organics collected. which is then sold to farms and vineyards around the region. However. (http://www. For example.au/resources/warr/200722_cocollectionorganics. the collection occurs only monthly (Goulburn) or fortnightly (Condobolin). A key reason that people still put organics into the landfill bin is that they want this material to be collected quickly. residents sort recyclables into ten different categories and they have had spectacular success.gov. The laws allow property owners/managers to apply for a waiver for all or portions of the mandatory recycling laws based on lack of adequate storage space at the property.Other trials around the country have also achieved low contamination rates. to properly label the containers and to educate the tenants. We understand the government has investigated third bin collection systems run through the City to Soil program and has noted that they collected approximately 50% of the total organics that were in the residential stream.nsw. green for organics. 16 Lloyd Consulting. The Goulburn and Condobolin trials have very close to 100% participation and very low contamination rates. This is being done elsewhere. San Francisco has legislation that requires every residence and business in the city to have three waste bins: blue for recycling.au/downloads/Review%20of%20Best%20Practice%20Waste%20 Management%20Alternatives. Eg Berridale trial achieved contamination levels on average of only 0.15 In cities such as Yokohama. 2007 (http://www.03% with 78% participating in the trial. p30 (http://www.html?ssi=3&ti=&ii=236) 15 11 .pdf) 17 Department of Environment and Conservation NSW.16 As the NSW Department of Environment and Conservation’s report on collection of organic waste points out: “when accompanied by a well designed collection system and adequate community education. Review of “Best Practice” Waste Management Alternatives. for Lake Macquarie City Council. taking into account the advantages of source separation.”17 We would also emphasise that the collection of a third bin for organics needs to occur at least weekly. it is significant that in City to Soil.environment.sfenvironment.
and if it had been conducted as promised it would have supplied very valuable information to inform the draft waste strategy. Recommendation: The Government should conduct a trial of organic waste recycling at high-density residential developments (as set out in the LaborGreens Parliamentary Agreement). This stops resources being ‘downcycled’ to low grade products. We recommend that the Government conduct a trial of organic waste recycling at high-density residential developments (as set out in the LaborGreens Parliamentary Agreement). and organics are all much more valuable when they are source separated compared to when they are processed through a dirty MRF. . because it can be used to make higher quality products. However the source separated material also has a higher environmental value. which hastens their journey towards landfill.and the various options for implementing such a system successfully in the ACT – such as the opportunity for weekly organic collections and the opportunity for supporting regulations. Source separated materials have a higher dollar value. and use the information to inform its waste strategy. f) Lack of information on third bin / composting It is clear that the Government needs further information about how a third bin/composting waste service would operate in Canberra. further demographic analysis of Canberra would assist the Government to determine the popularity and effectiveness of a third bin system in Canberra. It would also allow a variety of composting methods to be trialled.before committing to large expenditure on any particular technologies. Recommendation: The Government should consider augmenting its waste strategy with further work and research on how a third bin system could operate in Canberra. ’Downcycling’ materials or sending them to landfill breaks the recycling loop. This would provide valuable information about the efficacy of such a system. paper. We note that this agreement item is overdue. and about the attitudes of Canberrans toward the system. including by engaging the public. with many materials worth double or more when source separated. The consultant’s modelling backs this up. it should not be dismissing this option in favour of the dirty MRF approach. Without this information. glass.such as windrow composting . compared to being processed in a ‘dirty’ way. g) Source separation produces the best quality material for recycling and reuse Recyclable materials like plastic. In addition. and increases the need to 12 .
or to save on landfill. source separated materials. which are used to make new products. As the Wright Report points out. due to the low quality products recovered from a dirty MRF. where a lack of sufficient quality recycled material means that Australia imports a large amount of writing and printing paper. recyclers also face problems with achieving effective economies of scale and increased processing costs 19 AWT Update for ACT NoWaste. This approach must be supported by facilitating opportunities for source separation wherever possible. Source separation and ‘clean’ recycling is the best way to do this. The Greens support the concept of reusing materials to their highest use. Reusing recyclable material for its highest use ultimately saves resources and greenhouse gases by saving on virgin materials. Without good. a dirty MRF in the ACT is likely to receive considerable amounts of unseparated recyclable material from bins in public places and the commercial sector.including in the commercial sector. should not be outcomes that override the overall environmental benefits of recycling and of using recyclables for their ‘highest use’. We also recommend that the modelling explain how these conclusions were reached. and in public places (ie through public recycling bins). and how this is impacted by a move towards ‘dirty’ recycling. The strategy should model a scenario where the maximum amount of clean recyclables is captured – including from public places and the commercial sector. The consultant’s study makes an estimation of the net benefits of recycling. It would be a waste for these recyclables to be ‘dirtied’ in a dirty MRF. and what assumptions were made. rather than the resources actually recovered. we would point out that under the current Government proposals. the real value of dirty MRF operations appears to lie in the saved landfill space and levy or fees charged to dispose of the waste. compared to using virgin material and it suggests that a dirty MRF would save the most CO2e in the long run.19 This is of concern. Above n5 13 . Presumably it does this because it assumes that the dirty MRF will capture the most items for recycling.create new products from raw materials. they are much more valuable if they are source separated and recycled ‘cleanly’. Without access to clean. In particular. for example. a desire to earn money from levies. or landfill costs. source separated materials. domestic recycling companies need to augment their systems with imported material. this is only because there is not sufficient source separation infrastructure in place. Capturing all of these ‘clean’ recyclables would certainly save more virgin materials and be more environmentally sound in the long run. The strategy does not have any discussion about the recycling industry in Australia (or the ACT). However. This is a problem with recycled paper.
with a view to solving any issues that arise. 7 September 2010. and the benefits that come from this. the initiative has the advantage of being very visible. This is now also an overdue agreement item. 22 Jon Stanhope MLA. This would minimise inefficient transport costs. According to the Government. People are able to recycle very well in a domestic situation and this should transfer effectively to public places. EPIC and Australian Food and Grocery Council working together for sustainability.20 Greens MLAs would like to see the recycling sector in the ACT expand and prosper.22 The bin designs were also effective in achieving source separation. stadium and sporting venues. as well as boosting our local waste industry. Public place recycling To support the best source separation of materials. the results of the 2007 trial of the bins were ‘positive enough to justify continued use of recycling bins in Glebe Park’. Above. We would like to see local industries established and supported to process more of this material locally. festivals. 26 March 2009. Answer to Question on Notice 87. 2009: Hansard Debates. 2009 (http://www. South Australian Recycling Industry Investment Review. and there are options for improving the design further. We believe this is achievable. A street level recycling programme should also extend recycling to shopping centres.sa.gov.associated with contaminated materials. which helps in terms of Rawtec Ltd (for SA Zero Waste). n22 20 14 .pdf) 21 Andrew Barr MLA.’21 The recycling bins in Glebe Park have also been effective. It may be advantageous to begin this programme in a few trial areas – Civic would be a good start . and other places where recyclables can be collected. transport sites.23 As well as having the benefit of diverting recyclables from landfill. with minimal contamination. Media Release. as a key part of a shift toward a local green economy. We agree with the comments of the Packaging Stewardship Forum in relation to the bins installed at EPIC last year: ‘Through well placed infrastructure.au/upload/resources/publications/reuse-recovery-andrecycling/Recycling%20Industry%20Investment%20Review%20Part1_3. Through the Parliamentary Agreement with the Greens. good promotion and our call to action to “Do the Right Thing Use the Right Bin” we have shown we can deliver effective away-from-home recycling systems in public places.zerowaste. events. the Government agreed to install street level recycling bins in town centres within 12 months. The initiative is reportedly working well at event venues such as EPIC. From there the initiative can be extended to all town centres. most of the ACT’s recyclable materials are trucked interstate for processing. we recommend introducing recycling infrastructure into public areas. At present. 23 Jon Stanhope MLA. The goal should be for street level recycling in the ACT to be as reliable and consistent as kerbside recycling. such as contamination.
2. in fulfilment of its Parliamentary Agreement with the Greens. and plastics) and composting/anaerobic digestion (for biodegradable waste) gives the 15 . source segregation of MSW followed by recycling (for paper. As noted above. and favour source separating non-organics (plastic. metals. These technologies require a feedstock of organic material.such as pyrolysis. glass. and helps improve the recycling results achieved in all areas of society. as evidenced by a number of other reviews of waste management options. or play. Processing using alternative waste technologies (AWT) The strategy refers to the use of alternative waste technologies (AWT) . Recommendation: The strategy should support the principle of ‘highest use’ of materials. gasification and anaerobic digestion – to improve waste recovery. We believe that this is probably best done using windrow composting or anaerobic digestion and that this is the best approach for dealing with the considerable organic fraction of Canberra’s waste streams. work. This material is then most value when it is converted into high quality. It is also an advantage to take a consistent approach to recycling right across the city. This also appears to be the best approach in terms of climate change. Recommendation: The strategy should reassess the overall ‘life cycle emissions’ generated by different waste management options – in particular it should note that source separation will save many emissions compared to a dirty MRF when effective source separation infrastructure is in place.education and attitudinal change. nutrient rich compost (or digestate). The Government may find that public place recycling helps make recycling more of a ‘way of life’. A study of these options prepared by the EU concluded. and how different waste options will affect these opportunities and industries. for example: The study has shown that overall. textiles. Recommendation: The Government should introduce recycling infrastructure into public areas. paper etc). we are supportive of using source separation to recover organics. so that people will recycle whether they are at home. Recommendation: The strategy should include a discussion of opportunities for recycling industries in the ACT and Australia. school.
It says that: the Government wishes to encourage more consideration of the use of anaerobic digestion (AD) both by local authorities and businesses…Our recent research has suggested that AD has significant environmental benefits over other options for food waste and may be particularly cost effective for food waste if separately collected. Toronto is now building a complementary facility to convert the biogas into methane fuel for city vehicles. is now undertaking such a project. digestate. According to the consultant’s report.asp?storyid=1109479) 25 24 16 . Waste Strategy for England 2007.gov. Toronto Leads With Anaerobic Digestion. We recommend that the strategy also includes a discussion of how anaerobic digestion could be used to process source separated organic waste and potentially produce biogas that could fuel public transport (or waste collection vehicles).com. 2007. we support the creation of high quality compost.uk/environment/waste/strategy/strategy07/documents/waste07-annexe.au/storyview. It is much better used in soil and agriculture.lowest net flux of greenhouse gases. This is approximately equivalent to the electricity needed to power 3000-4000 of Canberra’s 125.and is suitable for source-separated organic material.000 homes. Using high quality organic material to create electricity permanently removes this material from the natural biological cycle.insidewaste. and would produce about 30. The final compost from the process also meets the highest compost grading.000 MWh of electricity per year. solar power is European Commission Report. While energy creation does have value. and maintaining a circular system of recycle and reuse.defra. $5-8million in annual running costs. Annex E.25 We would also point out that anaerobic digestion is quite well developed in terms of the technology – certainly more tested than pyrolysis and gasification . or biochar above the creation of electricity. compared with other options for the treatment of bulk MSW. Food and Rural Affairs. We note that according to the consultant. with a participation rate of over 90%.24 The UK Government’s study on waste management options similarly favours the use of source separation and anaerobic digestion. bringing all the benefits listed above. On raw figures. (http://www. Above n7 Department for Environment. 2 March 2010. Canada.pdf) 26 Inside Waste Weekly. building a pyrolysis or gasification plant would cost $40 .$70million in upfront capital. it is still using up valuable resources in a linear system. (http://www.26 When it comes to waste-to-energy technologies. it is significantly cheaper than pyrolysis or gasification in terms of both capital costs and ongoing costs. The city collects source separated organics from approximately 2 million dwellings (interestingly it also accepts soiled nappies). Toronto.000-35.
If used wisely they can have recycling and energy benefits. the creation of unwanted by-products. based on sound health and environmental standards. particularly those that are operating using municipal waste. However. however. lost opportunities for carbon sequestration and soil improvement. even before factoring in the negatives of using waste streams to create electricity (eg.000 tonnes of biosolids. loss of resources that can be recycled such as paper. We therefore have some doubts about whether commercial scale pyrolysis and gasification plants can meet claimed projections. The ACT should develop a standard. renewable resource). concerns remain about them forming organic compounds and trace constituents. the production of unwanted organic compounds and trace constituents is ‘minimized’. we note that there are limited real-world examples of these technologies. Without source separation. 17 27 . etc). It is also of concern that these some of these pollutants are produced even when the systems use relatively uniform feedstocks.markedly cheaper than this27. Although we understand most of the contaminants can be thermally converted. The production of any amount of these toxic pollutants is problematic. See: Parsons Brinckerhoff Australia Pty Limited for ACT Government and ACTEW AGL. it does appear to be a very useful area for exploration for processing the ACT’s annual 38. less stability in supply) or the benefits of using solar power (eg. meaning that projections of their success are based on estimates and vendor claims as opposed to actual data. Electricity can. which are a pollution problem. The study identifies a 22MW solar thermal plant for the ACT that can supply about 10000 Canberra homes for $140million with approx $2M annual operating costs. September 2008. we do have concerns about some of their limitations and uncertainties. and to create useful outputs. A further risk associated with using pyrolysis/gasification technology to produce energy on a large scale is that the system will be optimised for this output. as biochar as a by-product of this type of energy is likely to be too unstable to store carbon in the long-term. in order to maximize profits. We note that the consultant reports that in pyrolysis and gasification. We also note that the ACT does not have an air emission standard that would apply to pyrolysis or gasification. This will likely be to the detriment of the resulting biochar. and does not compromise overall recycling and or the highest value use of materials. and it should not pursue any technologies that cannot meet this standard. In particular. Solar Power Plant Pre-feasibility Study. Provided the technology can meet a high standard. the feedstock of pyrolysis/gasification will contain contaminants (plastics. be a useful by-product from a pyrolysis or anaerobic digestion process which is customised to creating the best organic material. We agree that pyrolysis and gasification are likely to have significant benefits over incineration in terms of their ability to minimize pollution. the use of a clean.
we recommend that the Government should not rely on gasification and pyrolysis for large scale processing. 18 . Recommendation: The strategy should include an assessment of the environmental benefits of creating electricity through AWTs compared to using the organic material for soil improvement. very little work has been reported in the literature on the yields and properties of biochar relevant to agronomic or environmental management applications … Advances in biochar production will require both basic research to understand the mechanisms of biochar formation and demonstration projects to prove the technical and economical feasibility of large-scale biochar production. It continues to contribute approximately 100000 tonnes of waste to landfill every year (compared to approximately 70000 tonnes from the household sector and 27000 tonnes from construction and demolition). “Biochar Production Technology” in Johannes Lehmann and Stephen Joseph (eds). If these are used in gasification or pyrolysis technologies. but should first be used on a small scale using carefully selected feedstocks (including biosolids). Recommendation: Any AWTs should use source separated organics for feedstock. Commercial waste is probably the most problematic area of waste management. which would apply to AWTs such as pyrolysis or gasification. the aim should be to create the highest quality biochar for use in soils. Recommendation: The strategy should support source separation to recover organics. p143. Recommendation: The ACT should develop an air emission standard based on strict health and environmental principles. Commercial Waste The draft waste strategy does not give enough focus to the problem of commercial waste.28 Given these problems and uncertainties. nutrient rich compost or digestate. Biochar for Environmental Management. 28 Robert Brown. 2009. Recommendation: Pyrolysis and gasification should not be relied on as large scale solutions.As Robert Brown points out in Biochar for Environmental Management in relation to modern pyrolysis and gasification technologies: Despite these several possibilities for producing biochar. 3. which can then be used as high quality. It seems more appropriate that they first be used on a small scale using carefully selected feedstocks that can not be uses with higher environmental value.
It is not made clear in the strategy. It is expected that the small office based business sector which has similar waste production to households – could already comply quite easily. and exemptions for businesses due to physical limitations.3 in the Labor-Greens Parliamentary Agreement asks for this solution. such as those enacted in San Francisco (discussed above). We note that the outstanding item 3. The programme may need to be supported with laws. then Government assistance will be needed to encourage and facilitate this. We think the strategy should take a firmer approach to commercial waste. This has been the approach for many years. or may be suited to a private contractor (indeed private contractors may be interested in providing a collection service because of the value of source separated material). There are challenges to this system. Any source separated commercial waste will then go to this clean MRF. To assist this process. 19 . If the Government continues to merely rely on businesses to source separate voluntarily. which include potential fines for non-compliance. The service to business could be provided by government. Any unseparated commercial waste will continue to go to landfill. The service could involve some cost recovery measures for the service or for businesses that require more or larger bins than a standard. Whichever strategy is used to address commercial waste. strategies for dealing with multiple tenants in single buildings. They have not compensated for the difficulties of any business changes required or finding recycling providers. or to any future dirty MRF. This should involve a program of source separation for businesses. Government assistance and interaction will be required. the MRFs will be priced to encourage businesses to source separate. possibly supported by new regulations. We recommend the strategy investigates how Government can provide businesses with a system to collect source separated material. Price signals already encourage businesses to recycle but this still has not achieved good results. Recommendation: The strategy should support stronger action to address waste coming from the commercial sector. but our understanding is that the current proposal to deal with commercial waste is for the Government to build a clean MRF to accept commercial waste. and the Government’s BusinessSmart/ OfficeSmart programmes will continue to encourage businesses to recycle. including organic waste. The proposed strategy still relies on the commercial sector to take action to separate waste and recycle. but we believe they can be overcome. We also recommend improved funding and commitment to the Business/ OfficeSmart programme. Recommendation: The strategy should emphasise the importance of adequate funding and resourcing for a government unit to work with the commercial sector around waste management.
recycling and disposal in Australia made this clear. last year technology a technology provider wrote to ACT MLAs promoting technology that supposedly can convert asbestos into inert material to use as road base. such as batteries and compact fluorescent light globes. Drop off points for fluorescent globes and batteries should be set up in central locations such as libraries. and transported to a central location at Mugga Lane or Mitchell for recycling. Toxics We are not satisfied that a case has been made to show that dirty MRFs can separate out contaminants from an unseparated municipal stream. Recycling and Disposal in Australia. As an example. unless systems for collection and reprocessing can be established”. It is being done by other Australian local councils. Analysis of Battery Consumption. Battery drop off points could be in the same locations. potentially sealing them in bags before placing them in the box. such as glass shards. and are recycled instead. The quantity of batteries and light tubes diverted is likely to be much greater if there are convenient drop off locations throughout Canberra. 29 Warnken Industrial and Social Ecology Pty Ltd. Boxes could then be collected when they are full. It is important that these contaminants do not end up in the end product from a dirty MRF. We are concerned about toxics like mercury and cadmium. customer service staff could accept the globes and place them in the box. Private companies also deliver and collect ‘drop off’ boxes for these items. the majority of domestic batteries and compact fluorescent light globes are put into the landfill bin.4. This is a simple and cheap initiative. 20 . as well as general contaminants.29 This can be done by setting up convenient drop off recycling points for these toxic items. the city Greens office collected around 200 fluorescent bulbs and tubes and 1000 batteries at a single drop off point with minimal publicity. p10 30 Between July and October 2010. A prime contributor to this problem is the lack of convenient options for recycling these items. The 2010 analysis of battery consumption. November 2010. The draft waste strategy has given limited attention gives to contaminants – toxic ones. This would allow them to be supervised – for example. and to assess whether any of the new technologies are likely to be viable in the ACT. concluding: “Handheld batteries of all chemistry types are most likely to end up in landfill. government shopfronts or willing businesses. The ACT Greens held a trial of battery and light globe collection out of the ACT Greens office for a number of months in 2010 with excellent results. Currently. It recommends the “prevention of batteries from entering the mixed urban waste stream”. for Australian Battery Recycling Initiative. which are obviously a problematic material in any compost. such as asbestos.30 We would also like to see the strategy address other hazardous materials.
Recommendation: The strategy should specifically address hazardous wastes. Recommendation: The strategy should recommend the source separation of CFL globes and domestic batteries via convenient. Relevant strategic and accountability indicators should be developed to reflect this framework.ashx) 31 21 . Downsizing living spaces – requires less consumption of furnishings and appliances over the longer term (carpets are an especially difficult material to recycle) Improving the sustainability of building materials – including by using materials that are recycled and are recyclable.au/en/Solutions%20and%20Tips/Case%20Studies/~/m edia/D91EE228DB2F4B97B75C888309C776D0. 5. providing quality drinking fountains in key places is likely to reduce the use of plastic water bottles. Any waste prevention programmes will be much more effective when they are part of an overall. and we are large consumers and wasters. This aspect is particularly relevant to the ACT. We believe this area of the strategy should be further developed. This part of the strategy should give more focus to value and lifestyle changes. and indicators translated into budget and annual reporting documents. and that there could be more focus on sustainable consumption initiatives.31 • • Information from Bottled Water Alliance. as we have a very large eco-footprint. Some examples of how the overall Government framework could be adjusted to support the waste strategy are: • • • Continued education programs through the Australian Sustainable Schools Initiative and generally. Since Manly Council installed new quality drinking fountains. central drop off points established by the Government. garbage collection volumes in the areas with fountains have decreased 30-40% (an estimated 50% of this is plastic bottles). Providing services that will have the effect of reducing waste creation.com. Waste avoidance a) Reducing consumption We strongly agree the strategy needs a focus on ‘generating less waste’. For example. (http://www. reinforcing framework and the strategy needs to articulate how waste prevention strategies and programmes will be integrated into a consistent Whole of Government framework. Effective implementation of these initiatives will involve many ACT Government portfolios.bottledwateralliance. Designing buildings and neighbourhoods to assist people use resources more sustainably.
It provides an incentive for households and businesses to 32 ACT Standing Committee on Public Accounts.us/lq/pubs/docs/sw/WPSBkgd07. ACTPLA. The strategy should reflect the recent recommendations of the ACT Public Accounts Committee.pdf) 22 . As more types of recycled material become available on the market. For example. It is important that product stewardship relates to both the packaging of the product. November 2010. such as DECCEW. some local councils charge less for smaller bins.33 Instead of charging a fixed price for unlimited waste collection. These agencies need to operate as part of an integrated government waste prevention programme. The strategy should give more attention to the issue of product stewardship. the PAYT scheme bases fees on the amount of waste – similar to the way that electricity or water is charged.”32 This is also another area requiring Whole-ofGovernment coordination.parliament. instead of deferring to national schemes of product stewardship. LAPS and DET. undertake its own mandatory producer or retailer responsibility schemes. as well as the contents of the products themselves.au/downloads/reports/PAC13%20ACT%20Gov%20Procurem ent. One example is the ‘Pay As You Throw (PAYT) initiative. 2006. Government purchasing should focus on products which use recycled content and which are recyclable. c) Incentives for behavioural change The strategy should explore how economic initiatives . This occurs in a number of US states. Inquiry Into Government Procurement. p44 (http://www.or. Waste Prevention Strategy – Background Paper #7: Other States and International Efforts. it becomes easier for companies to use these waste products. TAMS. and it could collect fees for the service at the point of sale. which said that “government procurement policies and practices can play a significant role in promoting sustainability” and “the purchasing power of government has the potential to act as a major influence on the development of more sustainable products and services.pdf) 33 Tellus Institute. rather than raw materials. for Oregon Department of Environmental Quality.such as fees or taxes .gov.These initiatives require coordination and cooperation with multiple Government agencies. the strategy should identify options for the ACT to take unilateral action in situations where federal action is slow or too weak.deq. (http://www. b) Product stewardship/ packaging reduction Unrecyclable products and packaging cause a problem for the ACT when it comes to recycling. it could require the collection and recycling of certain goods (such as e-waste) on behalf of either industry or retailers.may be part of the mix of waste avoidance initiatives.act. The ACT Government could.state. In particular. Closing the production loop in this way should be a high priority in areas like government procurement. In Victoria. if it desired. as well as products with minimal packaging.
gov. and the frequency of collection. As part of this investigation. and other organisations.vic. for example. ACT Greens MLA for Molonglo.pdf) 23 . Smaller bins. Recommendation: The strategy should propose initiatives for avoiding the use of resources in the first place. produced on average 402 kg of garbage per household per year. This represents 45% more garbage produced per household per year.reduce waste. Currently. I look forward to seeing the Government’s response to this and other submissions. Recommendation: The strategy should focus more on waste avoidance.sustainability. and articulate an overall. businesses.27 (http://www.au/resources/documents/Vic_Local_Government_Annual_ Survey_2008-09. p. and it should be investigated for use with ACT collection services (alternatively. On behalf of ACT Greens MLAs 34 Sustainability Victoria. for example the provision of more drinking fountains to reduce the use of plastic water bottles. Indicators from this strategy should be translated into budget papers. Recommendation: The strategy should identify options for the ACT to take unilateral action in situations where federal action is slow or too weak. so too does the waste produced from the household. there could be a flat fee up to a certain amount and anyone needing extra may have to start paying fees). Recommendation: The strategy should investigate ways to ‘close the production loop’ through government procurement. Surveys conducted in Victoria over the past nine years have also consistently shown that as household bin sizes increase. we also recommend the strategy consider whether useful adjustments can be made to the size of household waste bins. compared to the 240L which yielded 583 kg per household. coordinated Whole of Government strategy for implementing waste avoidance programmes. Victorian Local Government Annual Survey 2008–2009. I would be happy to meet and discuss any issues in this submission further. households often fill their recycling bin before it is due for collection and then start place recyclables into the landfill bin. such as the 80L bin. Caroline Le Couteur. reinforced with education and engagement of residents.34 Economic initiatives such as PAYT are examples of strategies that must be part of a coherent programme. Thank you for the opportunity to comment on the draft waste strategy.
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