Matt Kean

TALKING RUBBISH: A waste industry lifer said to me the other day: “A lot of forests have died in the name of government waste strategies.”

I guess in a contemporary setting that would be digital downloads, but his point is still an interesting insight. Namely, there’s a certain predictability. 

The waste and resource recovery industry has historically looked to public policy to address a variety of long-term issues: weak markets for much recyclate and recycled content product; difficulty in accessing sites and getting planning approvals for sites; missed opportunities in key waste streams like food and garden organics (FOGO); public under-investment in environmentally necessary but economically marginal infrastructure, and; regulatory uncertainty. 

That’s only naming a few of the aspects that the waste and resource recovery industry continually makes representations about to its partner environment protection agencies and relevant ministers.

Inevitably, the pressure in the policy pot builds up. A government of the day, often with limited “corporate memory” of what has come before it, decides the best way to let off some steam is to “do a strategy”. 

It seems that sometimes it’s easier to look at the big picture, and divert stakeholders’ attention to the long-term, than grapple with the hard economic and technical intricacies of specific shorter-term problems that need solutions.

But I’ve learned over 25 years that the waste minimisation and resource recovery industry’s DNA is also inherently optimistic. We’re chronic problem-solvers who believe that the right combination of ingenuity, infrastructure, and involvement can actually successfully divert more from landfill and deliver environmental benefits.

As a result, even though there might be every reason to be cynical about strategies by governments, most in the sector remain hopeful about them and their ability to deliver better results. We want them to work.

It’s through that kind of prism – a mix of healthy scepticism and enthusiastic can-do – that many in the sector have been looking at the new NSW Waste and Sustainable Materials Strategy 2041 that was released by Matt Kean, the NSW Minister for the Environment, in June (after some three years in the baking). 

For example, the Waste Management and Resource Recovery Association (WMRR), one of the sectors peak bodies, commended “the government for embracing the actions needed for NSW to transition to a true circular economy, including a shift towards material management that places strong emphasis on sustainable design.”

WMRR’s chief executive officer Gayle Sloan particularly noted the strategy’s commitments on reducing plastics and FOGO waste, and she was backed in by individual industry players, like Cleanaway, on those specific counts.

We’re a few months down the track now and the sector has had further time to reflect.  One very keen and independent observer of government waste strategies over the decades has been Mike Ritchie, the CEO of MRA, a sustainability consultancy that works with both private and public sector organisations, and a former industry and government senior executive. Ritchie sees some upsides and not-so-upsides in the draft. He told Talking Rubbish:

“The strategy has some great elements, including mandated household FOGO collection by 2030, mandated commercial FO collection by 2025, bans on single use plastic and mandated landfill gas capture. These are meaningful changes. Policies for government procurement of recycled product will also drive market demand.

“The strategy also sets an 80 per cent diversion from landfill target by 2030. That is in nine years’ time. It takes five to six years to get any major waste infrastructure approved and running in NSW, with many projects effectively requiring court cases too. 

So, if we are currently at 65 per cent diversion, the big question is: how do we get to 80 per cent diversion? The maths currently suggests we will fall well short.

“For example, on current trajectories, it will take 123 years to achieve the Municipal Solid Waste (MSW or householder materials) target at the rate we are going. The mandated FOGO and Commercial FO will help, but not in time. Commercial & Demolition (CD or building site materials) may never get to 80 per cent because recycling rates have been trending downwards.

And that’s in the following unavoidable context: it’s been estimated that Sydney will run out of general landfill capacity by 2028 – seven years’ time – and putrescible landfill by 2036. There’s an urgency to this set of problems,” Ritchie said. 

For Ritchie and others, what’s NOT in the strategy is problematic.

“There’s a fair bit of surprise that, in the three months since the strategy’s release, further announcement of even bigger “off-strategy” changes (that have real implications) have been made.

“That includes the revocation the Recovered Fines General Order and Exemption (GOE) which is a massive decision. It theoretically means that 30 per cent of everything in a construction bin – or 1.5 million tonnes of dirt, rubble and sand – can no longer go to its current process of being sorted, screened and sent back to building sites as fill replacement. 

Ritchie says it’s understandable that the EPA is trying to crack down on a few unscrupulous players who were allegedly exploiting the GOE to get rid of contaminated soils, but he doesn’t think we should close down legitimate environmental and business practices. 

“It’s good that the EPA has left the ‘fines’ door somewhat ajar with a proposal for new Specific Orders and Exemptions (SOE) that apply to an individual company (rather than all companies). But the EPA will need to reconsider the proposed ban on skip bin fines for all players. Reputable companies should be able to obtain a SOE for their skip bin fines product subject to quality requirements. Hopefully, we can develop benchmark SOE’s which allow quality operators to continue, whilst weeding out others,” Ritchie said. 

Another “off-strategy” recent development of concern to industry players is the announcement of new energy-from-waste policy settings which have the de facto effect of banning such facilities – normal in European capital cities – in Sydney, and limiting them to only Lithgow, Goulburn, Parkes and the Richmond Valley. 

While he can understand the government’s intentions (of putting the first EfW plants in regional areas that want the jobs and the development), it is hard to reconcile with the ambitious objectives of the strategy.

“How will we fill a three million tonne per year gap in landfill availability in only seven years when the two most mature EfW proposals have just been disqualified?

“Achieving targets requires infrastructure and capital investment. Infrastructure and capital investment require some certainty about the rules of the road. 

“You can understand the Government’s intentions on fines and waste-to-energy, but they certainly don’t help achieve the Strategy’s targets and the other benefits that flow from them to the community and the environment.

“I strongly urge the minister Matt Kean to ensure the strategy’s implementation includes more consultation and guidance to industry, on how the government will achieve its objectives,” Ritchie said.

Pete Shmigel is a writer who is in recovery after 25 plus years of executive roles in politics, major corporates, consulting, charitable NGOs and the resource recovery industry. He likes bikes and has decided to recycle and repurpose them through the new start-up, Revolve Recycling. Some of his consulting work includes with MRA

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