13 February 2015

The Sunshine Coast Regional Council

Locked Bag 72

Sunshine Coast Mail Centre 4560

[email protected]

Dear Madam/Sir

Thank you for the opportunity to make comment on the Sunshine Coast Council Draft Sunshine Coast Waste Strategy- Waste Reduction and Recycling Plan 2015 – 2025.

The Sunshine Coast Environment Council (SCEC) is the peak regional environmental advocacy group on the Sunshine Coast. Established in 1980, it currently represents 50 community groups working on conservation and sustainability with a combined membership of over 15,000 individuals.

Given the 10 year time horizon of the Strategy, the document is not ambitious in tackling waste reduction as a core driver. For example, Nambour landfill is anticipated to be full during the life of this plan. Also, as discussed below, major changes such as a price on carbon and a waste levy will inevitably occur over the life time of the Strategy. It is imperative that this Strategy be reviewed regularly and meaningful targets publicly reported on annually.

Overview / Drivers / Current Performance

1. The first key point to note is that Council’s implementation of actions under the previous strategy has been very poor, with little material progress made on key infrastructure or community education requirements. No analysis of the poor delivery of the previous strategy outcomes has been given. In our opinion, it was the lack of understanding and ‘buy- in’ by the community together with a lack of funding allocations for initiatives that resulted in key actions failing to be implemented. This lack of coherent action culminated in the ‘green bin’ debacle that set waste management practice (and community education and involvement, in particular) on the Coast back many years.

2. Critics of the previous strategy cited it as too ambitious and with the subsequent removal of a number of the key drivers, such as a price on carbon and the State imposed landfill levy, too difficult to achieve in practice. However, this altered political climate was always going to be a temporary perturbation, rather than a longer term trend (as evidenced clearly by the recent State election) and Council was, remiss at best and negligent at worst, to allow the momentum for improved waste and resource management on the Coast to stall.

3. In this regard, there are some solid foundations on which to rebuild the necessary program – the Sunshine Coast community produces less waste per capita than the State average (about half) and the Coast’s management of a number of specific, potentially problematic waste streams (mattresses and e-waste) shows that it has the ability to lead practice in the State. A clear example of the lack of ambitious targets is demonstrated with a Key Performance Indicator Evaluation p34 is only to “Ensure annual per capita generation of waste is less than 1.8 tonnes” when it is presently 0.83 tonnes. An effective target should aim to further reduce this figure.

4. The first priority of the new strategy should, therefore, be to redouble efforts to address these poor performance issues and get the region that purports to be “Australia’s most sustainable” back on track and show leadership in this service area (one of local government’s most important responsibilities).

5. Unfortunately, far from addressing these performance issues, the proposed new strategy represents purely a ‘holding pattern’ – it is not a strategy for responding to future needs (which will certainly arrive within the time period of the strategy and probably sooner).

6. In this regard, the lead time required to establish the new infrastructure (‘soft’ and ‘hard’) will mean that that Council will be inadequately prepared to respond to these future needs, because of a refusal or inability to prepare adequately now.

7. Table 4 – Sunshine Coast Council waste statistics p16 shows the present situation for various waste streams generation, landfilled and recycled.

 Municipal Solid Waste (MSW) present 35% diversion moving to 55% diversion

• Commercial and Industrial (C&I) present 23% moving to 55%
• Construction and Demolition (C&D) present 34% moving to 80%

Given the present poor base rate, some of these diversion targets are going to require a 250% improvement over the next decade. It is not clear within the document as to what actions are to be implemented to achieve the diversion targets.

A good example is C&I. As Council has a monopoly over the provision of this service, it therefore has a duty to provide a best practice model. An example of an action in this area which may assist achieve the diversion target would be to provide a free waste reduction audit on all Council’s commercial and industrial customers and assistance to implement the results.

Table 4.2 Actions and the Objectives fails to provide actions directly linked to achieving the Diversion Targets.

Meaningful actions to address this omission need to be provided and these reworked actions need to be reported on annually to show progress toward the achievement of the diversion targets.

Relationship to State Government and Neighbouring Local Government 

1. To some extent, the limitations of the proposed strategy very much reflect the recent, manifestly inadequate State Government’s ‘industry led’ waste strategy that omits key economic instruments, including such as landfill levy and container deposit and provides very little in the way of specific implementation actions and mechanisms.

2. It is, in fact, a clear opportunity for a region that purports, as mentioned above, to be “Australia’s most sustainable” to provide some ‘bottom up’ leadership to the State, particularly with the advent of a possible new government looking for fresh ideas and energy.

3. Council’s new strategy must, therefore, explicitly include a call for the State to update and modernise its current waste strategy, including the (re)introduction of key economic instruments – a landfill disposal levy, which should include MSW, and a container deposit scheme.

4. Noosa Council has recently embarked on a major waste and resource management review, with a particular emphasis on organic wastes and community participation in decision-making. It will be important to align the Sunshine Coast strategy with these initiatives.

Principles

1. The cornerstones of current day, modern waste and resource management practice include:

1. Diversion and beneficial reuse of the majority of organic materials from the waste stream sent to landfill.
2. Well-resourced consumer awareness, education and support for waste avoidance, reuse and recycling.
3. Removal of perverse economic disincentives to improved waste and resource management (e.g. need for an effective levy on landfill disposal).
4. Implementation of effective producer responsibility arrangements (e.g. container deposit and e-waste collection schemes).
5. Continued improvement in recycling rates, with particular emphasis on the commercial and construction sectors.
6. The effective management of legacy facilities, including carbon liabilities.

Specific Issues

1. Organics – The proposed action to expand the optional garden waste service by 5% annually and the complete absence of a domestic food waste diversion program are manifestly inadequate and far from even currently accepted best practice and clearly needs to be seriously reconsidered. At a minimum, an examination of organic waste separation, collection and processing and complementary home composting educational support need to be included as they represent the starting point for any modern society. This fundamental omission must be addressed, as a priority.

2. Consumer education and awareness – Community and business engagement will be one of the key ‘planks’ of future waste and resource management practice. ‘Least cost planning’ principles and analytical methodologies, along with improved consumer marketing and social media engagement tools provide a clear avenue for dealing with waste generation / avoidance ‘at source’. Understanding and deciding on options for improved waste management have been significantly enhanced through such programs (e.g. “Love Food Hate Waste” campaigns in the UK and in NSW). As opposed to the ‘green bin debacle’ mentioned above, such programs can result in residents indicating their preparedness to pay for improved service if they understand the economic and environmental benefits that will be achieved. However, such behavioural change campaigns are often unsuccessful unless they are well resourced and targeted.

• Education Program (3.5 at p26) has a target of a 5% annual increase in the delivery of the program to the community. What analysis of the education program has occurred on achieving waste reduction or at the very least, in improving recycling rates and reducing contamination?

Table 11. Objective 2. p30 is a set of actions ensuring the maintenance of the status quo. The Objective 2: Ensure the community is well informed and satisfied with waste management services should include the community also being meaningfully engaged and being part of the solution through involvement. This fundamental omission must be addressed, as a priority.

3. Perverse economic disincentives – As discussed under State Government comments, above, the proposed strategy must explicitly call for the removal of perverse economic disincentives to modern, effective waste and resource management through the introduction of key economic instruments including the reintroduction of a landfill disposal levy.

4. Producer responsibility – As discussed under State Government comments, above, the proposed strategy must explicitly call for the removal of perverse economic disincentives to modern, effective waste and resource management through the introduction of key producer responsibility programs including a State wide container deposit scheme.

5. Commercial and construction wastes – These wastes represent a significant proportion of the overall waste stream and the composition of these materials is such that virtually all can be considered as candidates for diversion from landfill. The strategy reflects current State Government targets for such diversion but provides no clear and specific actions that will demonstrably achieve these targets (see comments under Major Actions Required, below).

The Sunshine Coast, with its large tourist and dining establishments and facilities, provides a major opportunity for implementation of large and small scale commercial food waste collection, processing and beneficial reuse operations and boutique diversion / recycling services for bottles. Such operations also provide an excellent opportunity for the coast to promote its ‘naturally refreshing’ credentials to its tourist visitors. As such, it has the potential to be an important ‘cog’ in the public education and awareness program discussed above. The proposed strategy must include specific actions in this regard.

6. Recycling – The proposed strategy sets an unambitious target to improve recycling rates, in comparison to accepted best practice and provides no clear implementation actions to achieve even the modest targets included. The strategy also omits any specific actions or targets for improved public place recycling. This is particularly important for local economies that rely heavily on tourism, such as the Sunshine Coast. It is also a very important ‘cog’ in the public education and awareness program, as discussed above. This omission should be specifically addressed.

7. The Land Fill Gas (LFG) capture rate of 40% by 2020 is not a stretch target and will potentially leave Council and ratepayers exposed to the inevitable price on carbon which will occur.

8. There is no mention of environmental/carbon offsets

9. There is no reference to the Emissions Reduction Fund (ERF)

10. There is an unacceptable lack of climate change risk assessment to infrastructure

11. There is no adaptation strategy or contingency for major event

12. With the lack of innovation or commitment to carbon reduction demonstrated in the draft, the Sunshine Coast Council won’t achieve its aim of carbon neutrality by 2020

 Major Actions Required

1. The Sustainability Park which was to be the location for a number of key waste diversion and processing activities / businesses has been completely omitted from the proposed strategy. It has not been replaced with an effective alternative mechanism for achieving the ‘on the ground’ implementation of strategy targets. This omission needs to be addressed as a matter of priority.

2. The strategy provides no adequate plan for implementing Advanced Waste Treatment (AWT). There is mention of a feasibility study for AWT being undertaken early in the strategy timeline (years 1 to 3), however, such investigations have already been completed by many Councils across Australia and were to have been completed as part of the previous strategy. With the likely reintroduction of a landfill disposal levy and a price on carbon, the low likelihood of community acceptance of new, large scale landfills and diminishing existing landfill capacity and the lead time required for the procurement of such infrastructure, Council should be in a position to progress this action as a priority, at the commencement of the strategy. Otherwise, as outlined in the Overview comments, above, Council will very quickly find itself running out of time to respond to these future infrastructure requirements.

3. As a general comment, it is not clear how the proposed Actions outlined in the strategy will impact / deliver on the strategy’s stated Objectives / KPI’s. It is also unclear whether the financial, organisational and technical resources required to implement the Actions are available and whether these will deliver on the specified Objectives. In order to assess these relationships and hence the likely effectiveness of the strategy, modelling of the specific contribution of each Action to each Objective is required.

For example, as mentioned previously;

1. How will a 5% annual increase in school and community group participation deliver the target diversion of organic wastes?
2. How much will the Action cost?
3. Is that funding available?
4. How does investment in that Action compare to investment in other Actions in terms of relative benefit / achievement of the stated Objectives?

4. In a fast growing area with an increase in higher density multiple dwellings, the waste strategy needs to ensure that new developments are required to have adequate waste collection and recycling systems.

5. The inclusion and implementation of climate change risk assessment and adaptation strategies, as a priority

6. ERF opportunities should be investigated – including emission reduction methodology

7. Emission abatement strategies should be aggregated

8. SCEC encourages more dedicated investigation and integration with the Economic Development Strategy to maximise the economic opportunities of effective waste and resource management

Due consideration of our submission and opportunities to discuss further is appreciated.

Yours sincerely,

Narelle McCarthy

Liaison & Advocacy