The MUD dilemma

With multi-unit dwellings on the rise, Waste Management Review speaks with industry and government stakeholders about overcoming the associated waste management challenges.

As populations grow and property prices increase, Australian cities are facing a period of unprecedented shift. While the suburban ideal of a detached residence on a block of land might be aspirational to many, under present-day economic and urban planning conditions, multi-unit dwellings (MUDs) are increasingly becoming the norm.

In 2006, Bill Randolph of the University of New South Wales’ City Futures Research Centre said high-density housing, principally delivered by urban renewal and infill development, is expected to be the main source of future residential growth in major urban cities.

Almost 15 years later and Professor Randolph’s projections seem to be coming to pass, with 2018 Housing Economics Group data showing that MUDs rose from five to 25 per cent of total housing commencements between 1998 and 2018.

Whether this shift is positive or negative is a subjective matter, but data does suggest that high-density properties experience greater than average recycling contamination rates.

Contamination comes down to a number of unique challenges, according to research from the University of Technology Sydney. These include physical barriers such as distance to recycling bins, and social barriers such as a sense of anonymity or lack of responsibility for disposal and recovery.

Responding to these challenges, the Southern Sydney Regional Organisation of Councils (SSROC) initiated a project to improve MUD recycling in 2018. Specifically focused on reducing contamination through waste infrastructure availability and resident facing engagement, SSROC conducted bin audits at 75 MUDs. While University of Technology Sydney evaluations found the project was well delivered, final analysis was unable to detect any impact on recycling behaviour.

Similar issues are equally present south of the border, with the Victorian Auditor General’s 2019 report Recovering and Reprocessing Resources from Waste suggesting that despite growing recognition of the issue, there is limited guidance or direction on MUD waste management from a planning or legislative standpoint.   

Council kerbside waste collection is unavailable to most existing MUDs, the report notes, with private operators sometimes engaged to ensure new and existing MUDs offer recycling collection services.

This is due to insufficient kerbside space for bins, the report suggests, and an incompatibility between the collection infrastructure needed to manage large multi-storey buildings and council equipment.

Furthermore, the report highlights that while councils can influence how much space new MUDs allocate for waste infrastructure through the planning process, they don’t currently require new or existing MUDs’ serviced by commercial operators to offer commingled recycling services.

As such, the report suggests that as the level of MUDs increases, overall recovery rates will decrease.

“Most MUDs have only one waste collection service – for landfill,” it reads.

PLANNING PROVISIONS

In Victoria, much like the rest of Australia, the prevalence of MUDs has grown significantly over the last 10 years, mainly in the CBD and inner metropolitan Melbourne.

According to Sam Trowse, Sustainability Victoria Land Use Planning Project Lead, this growth has typically occurred without specific waste and recycling guidelines for high-density residential development.

“This has created issues for councils and the resource recovery industry in ensuring correct design and management options are implemented to maximise recycling,” Sam says.

He adds that as a consequence, recycling rates are lower in MUDs than in single residential dwellings. Additionally, while some planning tools and other policy guidelines exist across Victoria, Sam says these differ from council to council.

“This can make it difficult for developers and waste management consultants to design waste and recycling systems effectively across different councils, and highlights the importance of seeking early council input into design,” he says.

To address these issues, Sustainability Victoria (SV) developed its Guide to Better Practice for Waste Management and Recycling in Multi-unit Developments in 2019.

The guide, Sam says, focuses on a number of challenges including limited space for infrastructure and collection services, collection contractor requirements and a disconnect between council waste management officers, land use planners and building officers.

“The guide also focuses on emerging themes such as waste generation rates, which enables building designers to understand likely needed storage space and options to increase organics recovery, dependent on the characteristics and size of the MUDs in development,” Sam says.

Another focus is the existence of opportunities for precinct-scale MUDs, such as onsite treatments, like waste-to-energy, and automated waste collection systems such as vacuum waste.

While the guide is extensive and separated into types such as low-rise apartments, mixed use and precinct scale developments, essential requirements include hygiene, system simplicity and indemnity and waste service flexibility.

Examples of design considerations also include adequate storage space for the easy manoeuvring of bins and vehicle access and turning areas free from obstacles.

While they are just guidelines, Sam notes the document was added to the Victorian Planning Provisions in 2020.

“This is a positive move towards reinforcing the guide through land-use planning decision making.

“It also means that developers will need to meet the requirements of the guide when submitting planning permits for MUDs to councils,” he says.

TRICKLE DOWN

According to Mark Smith, Victorian Waste Management Association Chief Executive, MUDs pose an array of challenges to the association’s industry members. The dwellings are problematic, he explains, as there is little consideration of the waste needs of residents, especially in newer builds.

“It’s not uncommon to see beautifully designed buildings that feature elements helping to address energy and water efficiency, but failing on simple considerations like providing space for standard size waste trucks to access the site,” he says.

“MUDs are also great examples of how one or two poor behaving neighbours can have a huge impact on the efforts of the majority, leading to significant contamination issues.”

Recognising that the demographics of MUDs are very different, Mark says in addition to infrastructure concerns, what is often lacking is consistent community education on what goes in which bin. If recent challenges have taught VWMA anything, Mark says, it’s that the community is heavily engaged and passionate about waste management. He adds however that not all communities are afforded the same access to services, which is evident at MUDs.

While the Victorian Government is certainly taking strides in its approach to waste management in MUDs, planning responsibility often falls on council shoulders. As highlighted by Sam, guides and best practice can vary significantly between councils, and as such, harmonised design and education programs can be a challenge.

In an attempt to foster centralisation, the Metropolitan Waste and Resource Recovery Group (MWRRG), which works on behalf of 31 Melbourne councils, developed its “Improving resource recovery in multi-unit developments toolkits” in 2018.

According to Jillian Riseley, MWRRG CEO, the toolkit is designed to help councils adopt and implement waste management considerations into the planning approvals process.

The toolkit features a waste management plan template, guide and checklist, enabling the user to calculate and record the number of bins required for building development, as well as collection frequency and storage management.

“The standard plan template can also be used as a base to customise and reflect council’s servicing capabilities, before providing it to developers to complete and submit with their planning permit application,” Jillian says.

She adds that MUDs can be a challenge for councils due to poorly designed collection areas, varying levels of collection services and limited opportunity for residents to recycle.

Onsite issues, such as inappropriate collection infrastructure or storage and bin and transportation access, can also limit the number and size of bins available to sort different streams of material, Jillian says. Furthermore, she adds that collection services and contracts vary depending on whether they’re provided by council or commercial contractors.

“In turn, this can make it more challenging to educate residents and standardise the type of materials suitable for collection, as well as manage contamination and compaction rates,” Jillian says.

Developed after extensive consultation and independent analysis, the toolkit helps councils align waste management plans with state objectives. “The toolkit helps councils save time and resources, with waste plan requirements able to be checked during the planning permit assessment process,” she says.

“The straightforward assessment list ensures a basic level of consideration for waste and resource recovery before the waste management plan is sent to a specialist waste management officer.”

Since MWRRG developed the toolkit, Jillian says multiple councils have developed their own parallel MUD guidelines.

“Councils are also trialling and implementing waste and recycling programs tailored to MUD residents including onsite composting, food and green waste recycling collection, hard waste services, onsite furniture reuse and new onsite signage,” she says.

Despite a number of positive movements in the MUD space, Mark says the Victorian Government’s recent four-bin announcement might force the state to reexamine its approach to waste management and MUDs.

“While the Victorian Government instituting a four-bin kerbside system is certainly a positive step, it will pose a number of challenges for MUDs, as space for existing infrastructure is already a challenge for bin placement and pick up,” Mark says.

“The VWMA will be working closely with the Victorian Government on the rollout.”

This article appeared in the April edition of Waste Management Review. We look forward to updating industry on this issues as it relates to current circumstances with many people working remotely.

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Export ban exemptions

Despite the export ban commencing July 2020, the Federal Government could allow trade to continue under certain strict conditions. We speak to Trevor Evans, Assistant Waste Reduction and Environmental Management Minister.

In a speech to the first ever National Plastics Summit in Canberra, Prime Minister Scott Morrison pledged to match industry investment in recycling infrastructure dollar for dollar. With Australia’s recycling facilities “under severe strain”, the Prime Minister said government would allocate further funding in the May budget.

“We are working with state and territory governments to identify and unlock the critical upgrades that will lead to a step-change in their recycling capacity. And [we] will invest with governments and with industry on a 1-to-1-to-1 basis,” he said, according to a pre-released speech given to media.

The announcement came just three months ahead of the first round of export bans – with glass waste set to be banned by July 2020 – and serves as a sign that government has listened to industry calls for market intervention.

Since late 2019, the Federal Government has been undertaking extensive industry consultation, as required by COAG Regulation Impact Guidelines. As per the export ban Regulation Impact Statement (RIS), the aim of consultation is to determine the relative costs and benefits of regulatory and non-regulatory options under consideration.

Under proposed regulatory options, the ban’s implementation could take two forms: federal legislation or export restrictions. While federal legislation is conceptually straightforward, option two is more complex, with exports operating under permit systems and accreditation or supply chain assurance.

Exemptions to the ban could be considered, the RIS suggests, where continued export promotes circular economy principals, or materials have established industrial uses and end markets. Moreover, the RIS highlights materials originating from clean, well sorted steams, such as container deposit schemes or single source separation, as possible candidates for exemption.

While it could seem like a loophole to some, according to the RIS, allowing materials that meet certain standards to be exported reflects the variability of challenges facing each waste stream, as well as differences in infrastructure across states and territories.

According to Trevor Evans, Assistant Waste Reduction and Environmental Management Minister, material stream complexity, paired with an understanding of the challenges associated with broad policy decisions, has been a central focus of ban consultation.

“While we use the language of export bans, in essence, what we’re really interested in doing is allowing trade to continue if it meets certain strict criteria,” Trevor says.

“These aren’t clunky blanket bans; they are very targeted. The Federal Government is interested in the quality of material that might go offshore, and if certain quality conditions and eligibility criteria are met, operators may be granted permission via permits.”

While the exemption eligibility criteria is largely finalised, Trevor says discussion is still taking place around specific material definitions.

“The intention of government is to target these bans at mixed or contaminated streams, especially plastics. And that is actually quite a detailed conversation when it comes to individual polymer types, or different types of carboard, paper and pulp,” he says.

According to Trevor, under the restriction system, the Federal Government would have the ability to permit, audit and inspect all operators engaging in export. Once the ban is officially in force, he says policing responsibility will likely fall on the Federal Environment Department.

“Assuming the permitting process is indeed the model that’s followed, the exact drafting of the scheme would then be finalised inside parliament, and it’s likely that the Department of Environment could be in charge of that permitting process,” he says.

MATERIAL PRIORITIES

In January, the National Waste & Recycling Industry Council (NWRIC) called for a ban exemption for clean, high grade paper and cardboard.

Citing an export market worth more than $230 million annually, Rose Read, NWRIC CEO, said recycling services could fail without export capacity. Ms Read also noted that Australia does not currently have the capacity to locally remanufacture all the paper and cardboard it generates.

Ms Read’s comments reflect a common industry concern that material definitions are too broad, and that while banning some products, such as whole baled tyres, is appropriate, banning others, could be counterproductive.

When asked about these concerns, Trevor notes that significant refinements have been made to the definitions initially proposed at the November 2019 Meeting of Environment Ministers.

“The changes have been around paper and pulp, and really targeting the bans at where we believe the true issues and challenges lie, and not to get in the way of other export streams that are well sorted and pose no environmental threat,” he says.

At the next COAG meeting on 13 March, Trevor expects the government will announce final definition and timeframe decisions. He adds that details around how the government plans to co-invest in new facilities is also likely to be announced, a view already alluded to at the National Plastic Summit.

“There are very big challenges across some of these product streams, and one of the biggest is that in some areas, such as mixed paper and plastics, there aren’t many facilities or onshore capacity at the moment,” Trevor says.

“That’s the main reason the bans are staged in their implementation. The timeframes are tight mind you, but they’re deliberately tight because we want to bring the bans in as soon as we practically can.”

Responding to Sustainable Resource Use’s January Recycling Market Situation Summary Review, Trevor suggests that in some cases, Australia’s onshore reprocessing capacity will need to increase by “many multiples”.

The review, which suggests Australia may need a 400 per cent increase in plastic throughput to sustain domestic markets, highlights global markets for recyclable materials as volatile.

“One of the main motivations for the Federal Government being willing to co-invest and create better policy frameworks, is that we want to see a huge onshoring of recycling capacity,” Trevor says.

“We want to see that as soon as possible because of the great environmental and economic impacts and quite frankly, because it’s going to create jobs, especially in areas of Australia where we need them most, and that’s in regional cities and outer suburban areas.”

SHADOW BAN

Since the ban was announced, the appropriate level of government investment has been hotly debated. Multiple stakeholders, including Ms Read, have cautioned that in the absence of robust infrastructure investment, the regulatory measure is likely to fail.

Trevor’s Labor counterpart, Shadow Assistant Environment Minister Josh Wilson, shares similar sentiments, telling Waste Management Review that the Federal Government is not doing enough to deal with the reality Australia faces. It should be noted that Josh spoke to Waste Management Review prior to Mr Morrison’s plastic summit announcement.

“All the government has done so far is essentially put out a timetable, and it’s not clear at all how we’re going to meet that timetable,” he says.

“If you take mixed plastics, which we are supposed to stop exporting by the middle of next year, it’s very hard to see how that can be achieved when the level of plastic recycling and reprocessing is lower in Australia now than it was in 2005.”

In regard to infrastructure investment, Josh describes the Federal Government’s current approach as “hands off, help yourself.” The Australian Recycling Investment Fund, he adds, is insufficient, with new policy measures and resources needed to ensure the ban’s success.

“The Australian Recycling Investment Fund is not new or additional money, it’s $100 million dollars earmarked in the Clean Energy Finance envelope,” Josh says.

“The money was already being applied for recycling projects, and its loan funds, not direct funds. So, the idea that it’s direct funding that will change and improve the situation for infrastructure investment just isn’t true.”

When asked to respond to the Shadow Minister’s comments, Trevor notes that as part of the Federal Government’s plan to tackle plastic waste and halve food waste by 2030, the Recycling Investment Fund addresses broader issues than those of the ban.

The fund is designed to finance eligible large-scale commercial and industrial projects, typically requiring $10 million or more of Clean Energy Finance Corporation debt or equity capital. As opposed to general infrastructure investment, the Australian Recycling Investment Fund is focused on emerging technology.

“The Clean Energy Finance Corporation has existed for many years. Part of the reason why we’ve given them responsibility for administering the Recycling Investment Fund is their proven track record of making very sound business investment decisions in new facilities and new technologies,” Trevor says.

He adds that he expects the Australian Recycling Investment Fund to be entirely spent. Another concern for Josh is Australia’s tyranny of distance, and whether investment decisions will consider the needs of the entire country.

“I have portfolio responsibility for Australia as a whole in the waste space, but I am a Western Australian,” he says.

“If there’s additional reprocessing capacity located in the eastern states, what happens to a jurisdiction like Western Australia that would face the transport costs of taking our mixed plastics and other recyclables to those centres?”

Trevor explains that all the states and territories have been invited to approach the Federal Government with ideas and solutions.

“As you’d expect, each of the states are in a different position in terms of what their present offerings are. And each of them has natural views about the direction they’d like to take industry,” he says.

“We’ve received a lot of those proposals already and are going through the process of seeing where we can co-invest. But we’re also mindful that we need to have a national solution and will go through a common sense checking process to make sure there isn’t any duplications, or indeed any gaps.”

You can read the full article in the May edition of Waste Management Review. 

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Co-locating trust: social licence and WtE

Waste Management Review examines the implications of the social licence to operate in the emerging Australian waste-to-energy market.

In November 2019, Craigieburn residents on Melbourne’s urban fringe called on Hume City Council to reject a proposed waste-to-energy (WtE) facility in the suburb. The calls came amid concerns the plant would produce hazardous emissions, causing air pollution.

Katherine Lawford, No Toxic Incinerator for Hume spokesperson, said the community was upset, citing concerns the plant would lead to large volumes of waste transported into Melbourne for incineration.

The group was also apprehensive, Ms Lawford said, that the plant would undermine recycling efforts and encourage wastefulness. At the time of writing, there was no publicly accessible information on whether the proposed facility would use incineration or gasification technology.

While the Craigieburn facility’s fate is uncertain, No Toxic Incinerator for Hume’s concerns are not novel, with similar protests occurring across the country. Negative public reactions to WtE therefore foreground issues of residential encroachment, misunderstood technology and social licence to operate (SLO).

SLO, which evolved from broader concepts of corporate responsibility, centres on the idea that a business needs not only appropriate government or regulatory approval, but also a “social licence”. First used by Jim Cooney, an executive of international mining company Placer Dome, at a 1997 World Bank Meeting, SLO grew rapidly in use and pervasiveness. The term is now commonplace across a wide range of sectors including resources, farming, forestry and waste.

The Next Generation’s (TNG) failed 2018 WtE proposal, lodged by Dial A Dump Industries’ Ian Malouf, worked to gain SLO, but in the end, what went wrong is a matter that cannot be conclusively defined. The proposal, which sought to build and operate a large-scale combustion facility in Eastern Creek, Western Sydney, led to widespread public protest.

The proposal placed the facility strategically close to the NSW power grid, with Mr Malouf offering to supplement free power for 1000 homes.

As reported by Waste Management Review in 2018, TNG also conducted multiple presentations to council and officers, two public exhibitions, 8000 DVDs and pamphlet drops delivered door to door, and online, radio, news and television promotion during consultation.

It’s worth noting that the plant was to be co-located with the Genesis Xero Waste Recycling Facility, meaning residents were potentially already accustomed to living near waste and resource recovery operations. The idea of co-location is highlighted by CSIRO’s Engaging Communities on Waste Project as a useful mechanism to drive greater community acceptance.

In spite of these factors, protest persisted, with Mr Malouf’s application referred to the NSW Independent Planning Commission for determination in April 2018, following 949 public objections. The commission rejected the proposal in July, citing, among other objections, that the project was not in the public interest.

CHANGING ATTITUDES 

According to Sustainability Victoria’s 2018 Resource Recovery Technology Guide, waste and resource recovery facilities represent some of the most contentious land uses operating in Australia today.

For waste and resource recovery planning in Victoria, communities must therefore be involved in determining waste and resource recovery priorities and have opportunities to participate in decision-making and long-term planning.

“Stakeholders have different contributions to make and different involvement needs at each stage of the decision-making process,” the guide suggests.

“At different stages, involvement may take the form of sharing information, consulting, entering into dialogue with certain parties or providing opportunity for stakeholders to deliberate on decisions.”

According to Mark Smith, Victorian Waste Management Association Executive Officer, contention around waste facility land use stems from a lack of understanding of the role waste management plays in society and the technologies employed.

“While working with Sustainability Victoria in 2016, I was involved in social research with CSIRO that looked at community attitudes and perceptions about the sector. After surveying 1212 Victorians, we found that there are a number of factors that can build or improve SLO, including better community understanding of how the sector contributes to Victoria’s lifestyle and economy, and also governance (controls and oversight) arrangements by regulators.”

Government often views SLO, Mark says, as something an individual site or operator needs to secure. He would argue, however, that SLO exists on two levels  – the industry as a whole and individual sites – with both occupying a shared space with government.

“I’d also argue that government does not clearly understand its role in building public confidence in the sector,” he adds.

Mark says that with recent developments such as the export ban, the waste sector will require significant infrastructure upgrades and expansion.

“This expansion can’t and won’t happen if the private sector, who own and operate the bulk of assets in Australia, continue to encounter barriers to investment, such as communities slowing down development,” he says.

“We do occupy a shared space with government, so I think it’s important for government to reflect on their role and responsibility in building SLO and educating the public, especially around WtE.”

Similar concerns are referenced in Victoria’s Waste Education Strategy report, released in 2016. In the report, Environment Minister Lily D’Ambrosio suggests that despite investment in waste education, success in addressing critical long-term issues has been inconsistent across state and local government, industry, schools, community organisations and third-party providers.

To address this, and facilitate greater instances of SLO, the strategy proposes increasing the Victorian community’s perception of waste management as an essential service.

As part of this strategic direction, Ms D’Ambrosio said the state government would work with the waste industry to help them engage local communities and encourage best practice approaches to community engagement.

CSIRO’s latest research, an update on Mark’s aforementioned 2016 project, also formed part of this strategy.

The 2019 project, titled Changes and perceiptions in Victorian attitudes and perceptions of the waste and resource recovery sector, surveyed 1244 Victorians living in metropolitan and regional Victoria. Respondents were asked for their views on living near WtE facilities, as well as waste and resource recovery complexes – including possible impacts, benefits and trust.

CSRIO identified eight key factors that drive social acceptance in the waste sphere, which were fairness and equity, governance, quality of relationships, trust in the sector, impacts to wellbeing, benefits of wellbeing, attitudes about waste and knowledge.

Andrea Walton, CSIRO Resources and Communities Team Leader, says urban growth, particularly in outer suburbs surrounding waste sites that previously had a significant buffer, bring local communities and waste sites into closer proximity.

“Population growth puts more pressure on the waste management system through the generation of increased waste volumes. Effective forward planning of waste management has become an expectation of citizens, partly because they view waste management as an essential service,” Andrea says.

“This type of planning builds trust in the sector and contributes to people’s social acceptance of the need for different types of activities and infrastructure to manage our waste.”

SLO has therefore become more pertinent, Andrea says, forming a basis for the approval of new sites, new technologies and the ongoing operation of existing sites.

When asked why CSIRO chose to include WtE in its updated research – WtE was excluded in the initial 2016 report – Andrea says while WtE is not a new technology globally, it is new to Australia.

As such, CSIRO thought it important to understand what Australians thought about WtE and what underpinned those attitudes. CSIRO found that overall, acceptance of living near a WtE facility was low, but significantly higher than acceptance of living near a waste and resource recovery complex that included landfill.

“People support the avoidance of waste and see landfill as the least preferred option for managing waste material. Negative views about living near a landfill mean relatively higher support for WtE. It’s important to note however that support for living near a WtE facility was still modest,” she says.

Perceptions of impacts were also lower for WtE than for a waste complex, with societal benefits assessed more favourably. Moreover, residents viewed WtE as potentially fairer when considered on a broader societal level, provided the burden to local communities was offset by benefits, such as local councils being paid accordingly.   

According to Andrea, a key challenge to achieving SLO is public access to information. CSRIO’s research shows a link between higher knowledge levels and increased social acceptance. That said, self-reported overall knowledge is low, suggesting opportunities for improvement.

“Effective community engagement is fundamental to this process as is communicating with local communities about how these sites are governed and the context of the state’s overall planning and strategies for waste management,” Andrea says.

She notes, much like Mark, that this process needs to involve both government and industry stakeholders.

“Done well, these initiatives help to improve trust in the sector and ultimately more acceptance of a waste operator’s activities. However, this sort of interaction has to be genuine and meaningful to local communities,” she says.

NEXT STEPS FOR EASTERN CREEK

In October 2019, Cleanaway and the Macquarie Capital Green Investment Group announced plans to co-invest and co-develop a WtE plant in Eastern Creek, not far from Mr Malouf’s proposed 2018 site.

According to Mark Biddulph, Cleanaway Head of Corporate Affairs, the proposed facility aims to divert up to 500,000 tonnes of non-recyclable waste from landfill, and use it to generate electricity for more than 65,000 homes and businesses. He adds that the proposal is still in the early stages of the approvals process, having only recently received the Secretary’s Environmental Assessment Requirements.

Despite this, Cleanaway hosted a community workshop in November 2019, with the aim of engaging a broad cross section of the community to seek questions, ideas and feedback. Further community engagement will take place throughout 2020.

“Cleanaway is committed to involving the Western Sydney community in the development process and engaging with them often and openly,” Mark says.

Should the facility be approved, Mark says Cleanaway is looking forward to setting up a visitor and education centre onsite to encourage further knowledge sharing. He adds that Cleanaway also plans to invest in a number of local community programs.

“Building trust and SLO within the Western Sydney is critical to Cleanaway. To do this we’re committed to ongoing engagement, transparency and best practice operations that reflect and align with sustainable waste management,” Mark says.

“It’s essential to bring the community with us on the journey.”

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Bans at the border

With the first wave of export bans set to commence in July, Waste Management Review speaks with industry stakeholders about investment expectations and the globalised waste economy. 

When the Federal Government announced it would ban waste exports in August 2019, China’s National Sword was old news for most in the resource recovery sector.

While its consequences were still being felt, many industry stakeholders had grown tired of government platitudes about the circular economy.

The Council of Australian Government’s announcement therefore functioned as a jolt – a suggestion to industry that government was finally listening to calls for state intervention.

Praise was quick, with both the Australian Council of Recycling (ACOR) and the Waste Management and Resource Recovery Association (WMRR) releasing statements highlighting the ban as a step towards a sustainable domestic recycling industry.

Despite widespread support for the ban as a concept, many, including ACOR and WMRR, cautioned that for it to be successful, it would need to be backed up by analogous infrastructure investment.

Rose Read, National Waste & Recycling Industry Council (NWRIC) CEO, for example, suggests the regulatory measure will fail if not supported by market investment for plastics and paper. Rose adds that while the export ban’s intent is noteworthy, its achievability is seriously constrained without parallel support.

Similar concerns have been expressed by multiple stakeholders, highlighting a schism between regulatory measures and industry viability.

Mike Ritchie, MRA Consulting, for instance, argued that the Federal Government should introduce recycled content rules for domestic manufacturing. Likewise, Gayle Sloan, WMRR CEO, said the ban should be supported with mandated government procurement.

Following the Meeting of Environment Ministers in November, the Federal Government announced a nationwide timeline agreement.

Ministers agreed on a phased approach, with glass banned by July 2020, mixed waste plastics by July 2021 and whole tyres, including baled tyres, by December 2021.

Additionally, remaining waste products, including mixed paper and cardboard, will be banned by no later than 30 June 2022.

Of the timeline, Rose says the plastics and paper enforcement dates are unrealistic, particularly given the packaging industry is only working to achieve 30 per cent recycled content by 2025.

“We are very concerned that the regulatory focus is being crudely placed at the end-of-pipe, and not at the source of the issue, i.e. brands and producers,” she says.

“Currently, there is no regulation requiring manufacturers or the packaging industry to achieve these targets or penalties if they don’t. This is far from equitable.”

According to Rose, APCO’s packaging targets need to be brought forward to 2022 and mandated under the Product Stewardship Act – as proposed under senator Whish-Wilson’s Product Stewardship Amendment (Packaging and Plastics) Bill 2019.

“This is essential to ensure all packaging manufacturers, brands and retailers meet their producer responsibilities,” she says.

“It will create markets for locally recovered plastics, glass and paper and will remove problematic packaging, including plastics and composite materials, that can’t be recycled due to lack of technology or markets.”

Rose adds that given the ban’s intent, to prevent environmental and human harm, the Federal Government should consider banning whole crushed car bodies, white goods and waste motor oils exports.

“The NWRIC believes the current export of these materials is having substantial impacts on the environment and human health overseas, due to poor recycling and uncontrolled practices similar to that for whole baled tyres,” she says.

“These wastes are being harvested or burnt, with many of the by-products dumped or emitted, polluting the environment and putting human health at risk.”

Rose adds that Australia has the capacity to process these materials locally.

“Currently in NSW, steel mills are importing scrap from interstate and New Zealand to meet their feedstock needs, while whole car bodies are being exported to the Middle East and Asia,” she says.

Alternatively, the NWRIC does not support the banning of single resin/polymer plastics that have been processed, nor the banning of baled paper and cardboard.

“Both these recyclates have legitimate overseas markets, clearly demonstrating they are value added products that will not have a negative impact on human health or the environment,” Rose says.

FREE TRADE?

While concerns over implementation are common, the ban as a concept has been largely well received.

John B Cook, from John B Cook & Associates, however, suggests a blanket ban on exports is counterproductive. He adds that much of the material domestic materials recovery facilities receive is packaging produced from overseas.

“We’re in a situation now where glass bottles are being imported from Singapore. If we are importing packaging from overseas, we shouldn’t say, well you can’t send the packaging back and complete the loop,” he explains.

John admits that while recovered resources are a credible commodity, waste is a difficult industry.

“The market has failed in relation to waste. It [was] thought landfill was an inexpensive, easy option, and we’ve been dealing with that ever since.

“That said, we’re now moving away from a disposal culture. People want a circular economy, they want recycling, plus they don’t want to live next to landfills. So the market failed, and the reality is government intervention is required.”

John says however that the devil is in the detail. He adds that while there should be a ban on exporting “garbage”, completely closing the borders is unsustainable.

“Contracts need to be developed that ensure we are adding value and recovering resources instead of exporting dirty plastics, which we seem to have been doing,” he says.

“We should be washing and processing the material here and exporting bales or pallets at low contamination levels.”

The Federal Government also needs to facilitate market development, John says. He adds that while those markets are developing, exports need to occur to a specification that is adhered to.

The idea of sustainable exports, John says, works in tandem with developing domestic recycling markets. He suggests investment in the infrastructure and technology required to produce high-grade pure materials for exports has a flow-on effect.

That said, lack of federal investment is a central industry complaint surrounding the ban.

While it’s too soon to tell, the Federal Government’s recently opened $100 million Australian Recycling Investment Fund might alleviate these concerns.

Speaking with Waste Management Review in June last year, Assistant Waste Reduction Minister Trevor Evans said the fund was designed to support recycled content product manufacturing.

Administered by the Clean Energy Finance Corporation, Minister Evans said the government will provide guidance about the mandate and how to best invest in new industry.

While the fund was announced in May 2019, applications didn’t open until December. This followed criticism from Labor Assistant Environment Spokesperson Josh Wilson, who said the Federal Government was not doing enough to support the export ban or build the National Waste Strategy.

“We know the so-called recycling investment plan is predominantly bulked out with prepackaged or repackaged funds,” Mr Wilson said.

“The hundred million dollars in the Australian Recycling Investment Fund consists of nothing more than a fresh label on existing clean energy finance moneys.”

Rose says while the NWRIC welcomes the Australian Recycling Investment Fund, its investment criteria means it will only be capable of supporting a few major infrastructure projects.

“Smaller projects, for example those less than $10 million, won’t have access to the fund directly, but will have to seek loans through the Clean Energy Finance Corporation’s aggregate programs,” she says.

A GLOBAL PROBLEM

Despite ban conversations understandably centring on Australian markets, Michele Acuto, Melbourne University Global Urban Politics Professor, says industry and government need a global perspective.

Drawing on research from the World Economic Forum, Michele says retreating into an export ban is paradoxical to the notion of a circular economy.

“The problem with the ban is that it’s similar to immediate conversations after China’s restrictions. The rhetoric is quite nationalist, and more explicitly, about domestic solutions to an international problem,” he says.

“I want to be very clear that I’m not saying Australia doesn’t require strong infrastructure investment – but we do need to be thinking in terms of a global circular economy.”

The ban, he says, is diametrically opposed to this approach, and a recognition of waste as a global series of networks and industries.

The World Economic Forum suggests to create a global circular economy, system change needs to enable blended financing models, particularly in developing countries, policy framework adjustments and public-private collaboration.

For instance, Michele suggests a more collegial and strategic relationship between Australia and its neighbours could move global networks in the right direction.

He adds that while there is little agreement on waste definitions between Australian states, let alone sovereign bodies, the Federal Government should attempt to work in tandem with Malaysia, Thailand and Vietnam.

“We’ve turned another opportunity for leadership into a statement of inward policy. It’s very tit for tat and smells like 1980s Cold War policy. There’s an ocean of difference between the ban and a strategically based national plan,” he says.

The World Economic Forum suggests similar, albeit more controversial, solutions. Recycling is linear, the NGO argues, and out of touch with the extended lifecycle goals of a circular economy.

Reusing, redistributing and/or remanufacturing strategies are the preferred approach, it argues.

Additional points include moving away from activities that devalue materials, relocalising and resizing activities closer to consumers, and developing strategic partnerships with service providers.

While it’s hard to argue against future-focused attempts to restructure our approach to waste and consumption, the challenges of today still require action.

At a recent meeting with Federal Environment Minister Sussan Ley, the NWRIC members discussed how to build local demand for recovered materials for packaging, products and infrastructure.

According to Rose, new obligations must extend beyond the waste and resource recovery sector to include organisations importing products to Australia.

“A circular economy requires all parts of the supply chain participate,” she says.

This article was published in the February edition of Waste Management Review. 

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Six bins? Infrastructure Victoria’s interim waste report

Waste Management Review speaks with Infrastructure Victoria about its recent waste report and potential recycling solutions for the state.

When the Meeting of Environment Ministers agreed to ban waste exports from 1 July 2020, the Victorian Government called for an urgent national funding plan.

Environment Minister Lily D’Ambrosio requested that the Federal Government provide infrastructure investment to ensure the “fast approaching ban” did not result in stockpiling.   

Given the current status of Victoria’s untouched half-billion-dollar Sustainability Fund, some industry observers questioned the appropriateness of Ms D’Ambrosio’s request.

That said, in light of the state’s resource recovery challenges, the environment minister’s concerns were not unfounded.

Stockpile anxiety is particularly pertinent to Victoria, with DELWP figures revealing more than 100 recycling facility fires occurred in the state over the past 10 years. The largest fire cost Victoria over $110 million.

The collapse of SKM Recycling is another factor, with the state’s infrastructure capacity called into question after 33 Victorian councils were forced to landfill their recycling.

Within this context of “crisis”, the state government asked Infrastructure Victoria (IV) to examine the sector through an infrastructure lens. The task: provide advice to government on how to best support changes to resource recovery in the state.

Following extensive community and industry consultation, IV released an evidence base report in October 2019. Final advice will be provided to government in April 2020.

Despite the report’s 36 pages, mainstream media almost universally ran with one “recommendation” following its release: introducing a six-bin kerbside system.

Victorian Government Opposition Leader Michael O’Brien even told ABC radio that despite liking many of IV’s suggestions, “six bins sounds a bit novel”.

According to Elissa McNamara, IV Resource Recovery & Recycling Advice Project Director, however, IV never suggested six bins.

What IV did highlight, she says, was a link between high-performing resource recovery jurisdictions and greater household separation.

“To be clear, this report doesn’t make any recommendations. We will be making recommendations in April.

“What we have put out is potential actions and early findings for government.”

COMMINGLED MESSAGES

The Victorian Government’s stated waste policy objectives include reducing waste to landfill and minimising the impact of waste disposal on human health and the environment.

Evidence from reports commissioned by IV, however, show waste sector outcomes are falling short of these objectives.

Identified problems include steadily increasing waste generation rates, inefficient recycling data, reliance on exports, waste stockpiling and illegal dumping.

Market concentration is another problem, Elissa says, with the closure of SKM Recycling highlighting an overreliance on one company to manage Victoria’s waste.

“In Victoria, SKM had roughly 50 per cent of the kerbside commingled market, and their business model was based on exporting and minimal importing. As a result, investment in reprocessing or selling to local markets in a way that adds value was quite limited,” Elissa says.

To arrive at these and other conclusions, IV examined resource recovery approaches in other jurisdictions, and investigated potential market design solutions, infrastructure gaps and new pathways for recyclable material.

“We conducted interjurisdictional scans to assess what our neighbours are doing, importantly South Australia and NSW, but also looked at high-performing jurisdictions overseas,” Elissa says.

High-performing jurisdictions include Wales, South Korea, Germany, the United Kingdom and the Netherlands.

“There were some common lessons for Victoria underpinned by one clear theme: a proactive government,” the report reads.

In all five cases, IV identified long-term commitment, coordination and collaboration, mandatory measures from government, complementary interventions across the value chain and a range of evolving policies.

In addition to interjurisdictional scans, Elissa says IV undertook extensive market analysis.

IV engaged the University of Melbourne’s Centre for Market Design to assess incentives influencing each market transaction.

This included the effect of regulatory settings and the role of price signals and applied market design principals.

The Centre for Market Design suggests that in the “decentralised waste economy”, major decisions and transaction points are spread across the waste lifecycle.

“In the context of the Victorian waste sector, observed outcomes are determined by the interplay between the legislative and regulatory environment, on the one hand, and the decentralised, self-interested decisions of producers, consumers and processors of waste, on the other hand,” the report reads.

“In decentralised economic systems, such as the waste economy, alignment problems are common because the motivation of businesses and households does not necessarily accord with those of government.”

BEYOND THE BIN

IV is considering the types of intervention that may be needed, Elissa says, and is conscious that further government and industry collaboration is required.

“Consideration of waste infrastructure investment needs to be undertaken in the context of policy settings across the waste chain that drive behaviour change and support the development of end markets for recycled materials,” the report reads.

Among a number of potential actions, IV suggests that initiatives to disincentivise the use of virgin materials have the potential to create stronger recyclate end markets.

“Government procurement at all levels, whether that’s Commonwealth, state or local, can choose to use their procurement power to look not just at the absolute bottom line in terms of cost, but also social and environmental outcomes,” Elissa says.

She adds that it’s the choice of individual governments to decide to what extent they want to use procurement to achieve environmental outcomes, noting other mechanisms are available.

“Governments could look at other levers like taxes or a ban on virgin material, but because of trade, any mechanism like that would need to be considered by the most appropriate level of government,” Elissa says.

She says that while Victoria could tax or ban virgin material, the state government would need to consider trade implications.

“It’s also about considering whether or not the environmental and social externalities associated with virgin material extraction are being appropriately priced relative to recycled material,” she says.

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How confident are you in recycling?

The Australian Council of Recycling has launched a new industry survey to provide an up-to-date measure of confidence in the sector and support better decision making. 

The recycling sector employs around 50,000 people. While this is indicative of the sector’s success to date, an unrivalled opportunity exists to increase that number exponentially.

Australia is one of the wealthiest countries in the world per capita and with that affluence comes increased waste generation. Currently, the sector accounts for 0.5 per cent total employment, with Australia ranked 17th in the world in recycling.

But as a vital part of the economy, recycling can punch above its weight with the right support. The Australian Council of Recycling (ACOR) has been supporting the businesses that collect, sort and remanufacture materials into value-added products.

These are the businesses getting their hands dirty to beneficially manage materials from the residential, commercial, industrial and infrastructure sectors.

The Council of Australian Government’s (COAG) ban on select waste exports, in addition the upcoming NSW Government’s 20-year waste strategy, national container deposit schemes and updated infrastructure recyclate specifications, highlight the regulators’ appetite for reform. Nevertheless, quality data is a barrier to understanding.

It’s why ACOR has explored the gaps and discovered that the missing piece of the data puzzle – an understanding of business confidence. While organisations such as NAB run monthly business confidence surveys, there has not in recent times been a measure of confidence for Australia’s recycling sector.

Such datasets would prove useful for federal, state and territory and local government regulators, and help inform decision-making to supercharge the recycling sector, instead of it being stymied by outdated regulation.

According to ACOR CEO Pete Shmigel, understanding the recycling sector’s place in the overall economy is vital.

“We don’t do enough to gauge our own performance and trends and share that information with the public and decision-makers. Hopefully, the survey helps claim that opportunity,” Pete says.

He says the survey is a first of its kind.

“There’s lots of work about where the industry is at in terms of environmental performance, especially in ‘tonnage’ terms, for example how much we manage and various recycling rates. There’s less information about the economic side, such as business confidence going forward. That’s a key difference for this survey.”

Pete says that a schism between communications surrounding the so-called “waste crisis” and industry’s perceptions of the sector has created confusion.

“In all the media hype of the last few years, there’s been a fair bit of ‘blurring’ of different recycling markets. The reality is that while kerbside has its issues, we’ve been powering along in C&I and C&D with more than $500 million in investment in the last two years,” Pete says.

He says that interestingly, some businesses are integrated across these streams and have therefore been successfully hedging.

“Good decision-making requires a detailed understanding of the differences in our streams of activity.”

With COAG’s ban on waste exports and kerbside recycling undergoing dramatic changes, Pete says it’s important more now than ever that industry has the confidence to invest at scale and the right market signals.

“Domestic sustainability will require significant investment from many players, and that is assisted by industry insights.

“We’re literally only months away from the COAG ban being in place – on top of existing Asian pressures and in addition to further moves the Asians are likely to make. I’m hopeful that the survey gives us a better sense about how affected businesses and their supply chains are feeling about these very significant structural changes about to come down the pipe.”

The survey is broken down into MSW, C&I and C&D and allows respondents to answer various questions about whether they feel confident in their operations. Likewise, the survey covers government support and allows users to rank the issues most important to them.

To participate in this leading industry survey click here

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Acquisitions in the spotlight part three: SUEZ

Waste Management Review talks to some of Australia’s largest waste management companies about the role of scalability in the future of the waste sector. 

This article is the third in a three part series featuring Bingo Industries, Cleanaway, Corio Waste Management and SUEZ. 

SUEZ Australia and New Zealand has developed its own action plan internally. It focuses on circular economy and driving partnerships and innovation across new technologies.

CEO Mark Venhoek calls for a fundamental change in the market through new infrastructure with WtE one part of the bigger solution underpinning broader initiatives.

As part of this paradigm shift, he wants the packaging sector, federal government and state and territories to step up and show more leadership in taking responsibility for their material processing.

When it comes to the broader structure of the industry, Mark says it’s not for SUEZ to comment on the specifics of others out there, but strong leadership is key.

“I do believe if you have a strong sector with various leaders it’s probably easier to make some changes.

“We have quite a bit of industry fragmentation around the industry but I guess the leadership for me is so not so much about market share or revenue, but what the changes we are going to make in terms of say, building new infrastructure and innovation.”

He says the fundamental changes required in the marketplace will not necessarily be supported by the size of one’s business, but strong leadership in areas such as safety and compliance.

Importantly, long-term visibility by the regulator and certainty of volumes is required to commit to sites and large-scale capital investments such as in WtE. In this vein, decisions such as the mixed waste organics ban in NSW are not helpful and undermine planning and confidence. 

Mark says a WtE solution could support markets such as plastics that have fallen victim to the laws of supply and demand or don’t meet contamination standards.

“It would be a very good support and potential backup plan to ensure those volumes don’t end up in a landfill,” he says.

He says that SUEZ Australia and New Zealand is looking at a range of WtE projects. Some that have already been announced include the East Rockingham facility in WA as well as a joint venture with Australian Paper in Victoria. 

With the growth of population and the fact that planning new facilities can take five to 10 years, SUEZ is also committed to expanding its Elizabeth Drive Landfill in NSW.

“In the interim, typically in the NSW, Sydney and greater region, we’ll still have a level of dependency on landfill I’m afraid, and a result of that we will have to expand that facility. It’s in the interest of the public to be able to secure a proper outlet.”

Mark says that resource recovery parks such as Lucas Heights are likewise only one part of the solution, covering only a small percentage of Sydney’s waste and not the residual stream. 

“It will solve part of the problems that we might have but only on a small scale,” he says. 

“Most of those facilities are capable of treating a small percentage of the waste that is being generated even if there are niches, so you need solutions for the mainstream volumes.”

Mark says that where relevant, SUEZ will partner with companies that have an appropriate site and permit and align with the company’s vision and strategy. In some cases it may also reduce investment uncertainty, he adds.

SUEZ is driving a number of unique projects overseas. The company has opened one of Europe’s most advanced packaging sorting facilities for lightweight packaging in Ölbronn, Germany with an annual processing capacity of 100,000 tonnes.

In this case, Mark says the commercial environment in Germany is conducive to building a facility on a long-term contractual basis.

“There’s nothing stopping us from opening these kinds of facilities,” he says. 

“If I look at the one in southern Germany, it is the most modern across the globe but it is governed by a very special system around the Green Dot, meaning plastics, paper, cardboard and metal are collected separately and treated by these levels of infrastructure.”

In the Bang Phli district near Bangkok, the company plans on building a recycling plant that turns plastic waste into circular polymers, strengthening its presence in South-East Asia.

Mark says that in Bangkok, there is not nearly the level of scalability of Australia to support the conditions.

In terms of whether a four-bin system of food and glass could be the answer to Australia’s recycling concerns, he says that anything that can be done to support source separation at a higher level would make an impact on generating better quality raw materials.

“We are very supportive of the COAG initiative [waste ban] and planning they put ahead, but I do believe we can do it,” he says.

“There will be a bit of pain in the coming years, but I am also sure with collective passion and energy, we can see some magnificent outcomes.”

Click here to read part one and two

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Acquisitions in the spotlight part two: Cleanaway

Waste Management Review talks to some of Australia’s largest waste management companies about the role of scalability in the future of the waste sector. 

This article is the second in a three part series featuring Bingo Industries, Cleanaway, Corio Waste Management and SUEZ. 

With more than 300 sites, 115 prized infrastructure assets and around 6000 employees and 4950 vehicles, Cleanaway is Australia’s largest waste management company. 

At the heart of its approach to scaling up and supporting Australia’s recycling woes is Cleanaway’s Footprint 2025 strategy – a plan to significantly grow its infrastructure by 2025. Launched in 2015, Footprint 2025 continues to expand.

It’s already done so in 2019 with a new waste transfer station and resource recovery facility in Sydney licensed to process 300,000 tonnes of putrescible waste per annum. In addition, its recent infrastructure moves also include a new South East Melbourne Organics Facility, a 50 per cent stake in ResourceCo’s process engineered fuel facility in Sydney and a transfer station in Perth.

Official data on market share is difficult to come by, but CEO Vik Bansal estimates the company controls around the mid to high 20 per cent of the total waste management market.

Its annual report shows the integration of Toxfree is on track to achieve a $35 million synergy target by June 2020. Cleanaway’s acquisition of Toxfree in 2018 was unopposed by the ACCC and concluded that increased vertical integration would be unlikely to substantially lessen competition due to competitive constraints imposed by alternative suppliers.

The official review shows customers can and do disaggregate contracts if they are dissatisfied with pricing and/or service levels. Likewise, there are other large suppliers present in multiple waste streams and geographical areas throughout Australia.

Cleanaway’s net revenue, which represents gross revenue less landfill levies collected and passed through the customer, increased by 35 per cent in 2018-19 to $2.11 billion compared to the prior corresponding period. Its growth was driven by a combination of organic growth and the Toxfree acquisition.

“We have spent about $150 million building prized waste infrastructure across the country which includes transfer stations, resource recovery centres, used oil refinery and liquid, hazardous and non-hazardous waste processing facilities organically and via the acquisition of Toxfree,” Vik says.

Its earnings before interest, tax, depreciation and amortisation increased 34 per cent to $433.7 million in 2018-19 due to improved profit performances across solid waste services, industrial and waste services and liquid waste and health services. In its annual report, Cleanaway highlights itself as having an excellent balance sheet with debt ratios well within banking covenant requirements.

The annual report declares volatility in the commodities supply chain has led to increased sorting costs and instability in commodity pricing. Vik has often maintained Australia’s recycling crisis presents an opportunity rather than a threat to the viability of the sector.

“It is the right thing for the waste industry in Australia and in general. There is something not right about waste going to developing countries and them sorting it out. We just don’t want that to happen,” Vik says.

He says that being a publicly listed entity places additional pressure on Cleanaway as a company, but it’s a challenge it is pleased to take on.

“Because we are a listed entity and have to go to market every six months, our changes become a lot more visible than an international subsidiary or a company which is not listed,” he says.

The positive side effect of market fluctuations is that Cleanaway has fast-tracked much of its Footprint 2025 strategy to support the local marketplace.

Following the collapse of SKM Recycling Group, Cleanaway Waste Management acquired the senior secured debt in the group for around $60 million with the exception of its glass recovery services business. This includes the property, plant and equipment from a network of five recycling sites, comprising three materials recovery facilities (MRFs), a transfer station in Victoria and a MRF in Tasmania. SKM also has two sites in South Australia.

KordaMentha have been appointed the receivers of the group. At the time of Waste Management Review’s interview with Vik, Cleanaway was looking to acquire the assets and return them to a sustainable footing as part of the sale process being undertaken by the receivers.

Prior to the publication date, Cleanaway was successful in its bid for SKM assets with completion of the process on track for the end of October. One of its sites in the network includes an advanced plastic sorting facility in Victoria.

Commenting on the acquisition, Vik said significant progress had been made in clearing waste stockpiles from the sites, repairing plant and equipment and bringing the sites to required safety, environmental and operational standards.

“We expect to gradually restore operations in Victoria over the coming months,” he said.

Speaking to Waste Management Review, Vik agrees some systematic changes are needed to support the future viability of the industry. However, he concedes collection will be difficult to consolidate due to the low barriers to entry.

“There is something fundamentally wrong about the industry structure. Aside from Visy, there is not even a single big waste management player which is upstream and vertically integrated. There is not even a single big waste management player in commingled recycling in Victoria.

“China’s National Sword has triggered the industry structure to go back on a balanced, even, long-term sustainable footing and hence our interest in SKM assets.”

“A company like Cleanaway cannot have a Footprint 2025 strategy flowing through without commingled assets in Victoria. That is part and parcel of a vertically integrated waste management company.”

It was speculated that Cleanaway was interested in buying SKM’s glass recycling business not covered by the receivership. Vik says that while Cleanaway was initially interested in this, the acquisition is now in doubt given the scale of glass stockpiles.

Instead, should Cleanaway acquire SKM’s assets, Vik says Cleanaway will look at building its own glass beneficiation plant.

He says that Cleanaway’s future focus will be to become a downstream processor.

“We see ourselves investing in plastic pelletising and going downstream on glass crushers,” Vik says.

Vik says that Cleanaway’s view is that Australia needs to move to a harmonised national four-bin system with mandatory FOGO and glass bins the key to improving commodity value.

“We are ready to invest a lot more in different parts of the country if we can see that certainty of policy and harmonisation,” he says, adding there is a fair amount of Footprint 2025 still to be revealed.

Likewise, he says that whenever Cleanaway invests, it looks at the entire value chain, including location, policy framework and its total market share.

Vik says that each state should have a container deposit scheme but recognises it might be difficult to harmonise all at a national level.

He says this system would then become best practice through better education, investment in infrastructure and manufacturer and consumer acceptance of recycled material as the final piece of the circular economy puzzle. 

Footprint 2025 is going from strength to strength as Cleanaway in October announced a joint venture with Macquarie Capital’s Green Investment Group to develop a waste-to-energy (WtE) project in Western Sydney.

A site has been acquired for a potential facility in Eastern Creek and an environmental impact statement is being prepared and released for public consultation early next year. The site is expected to cut Western Sydney’s annual landfill volumes by 500,000 tonnes – almost a third of the red bin waste generated per year in the local area.

CONSOLIDATION DEBATE

Trevor Thornton is a lecturer in hazardous materials management at Deakin University and has prior experience with the Environment Protection Authority Victoria.

He says the metropolitan areas certainly benefit, but one concern would be whether the same level of service is afforded to regional areas.

“I’ve heard some issues about large companies that get a statewide contract but just outsource a lot of the more distant rural areas under their banner, but they don’t get the same service to the client.

“But I think in the main, if you’ve got five or six companies offering the complete service, I think that’s a good thing.”

Likewise, he believes the purchase of ailing companies such as SKM can only be a good thing, and that if additional oversight is required, that would be a matter for the ACCC.

He says the trend towards consolidation in Australia would mirror that of other more populous nations such as the US, Canada and parts of Europe.

Corio Waste Management CEO Mathew Dickens

Mathew Dickens, CEO of Corio Waste Management, a family-owned business focused on waste collection and organic waste treatment based in Geelong, sees an opportunity from consolidation to compete with the major players.

“Consolidation does lead to less competition, but it can also mean the acquirer has more to lose as you have most of the market share and that can only go in one direction, but for companies my size it creates opportunity,” he says. 

Mathew says with further consolidation, Corio can aim to compete on service standards, respond quickly to changing customer requirements and provide a point of difference as a family-owned business.

“From a customer perspective it [further consolidation] would mean less choice and higher prices, and that’s not a problem for us as we don’t compete on the basis of price. We know what our costs are because we measure and analyse them all the time,” he says.

He says that Corio tends to focus on what it can offer in terms of variety and frequency of service, collection standards and customer service.

Mathew says the recent consolidations are nothing new but rather history repeating itself in an industry cycle where consolidation inspires new entrants into the industry.

In the US, integrated companies such as Waste Management Inc, Clean Harbors, Republic Services and Advanced Disposal dominate the market.

Mathew points out that Republic Services is an example of smaller operators merging to become a larger organisation, a trend that could always repeat itself locally.   

Republic Services is one of the largest providers of non-hazardous solid waste and owns around 207 transfer stations and 190 landfills, according to Superperformance SAS data.

He says there will still be room for niche, specialised operations that handle smaller volumes.

“If there is going to be a remanufacturing industry that’s developed onshore, you need to spread that risk,” he says.

Mathew says that Corio remains focused on growing its organic waste collections in Geelong and Melbourne treated at its composting facility
based in Shepparton.

“We want to build tunnel composting facilities in other regions in Victoria. It relies on government contracts, but we’re confident we can make it happen,” he says.

Next week’s instalment features an interview with SUEZ CEO Mark Venhoek. 

Click here to read part one

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What happened to MWOO?

One year on from the NSW EPA’s ban on mixed waste organic material, Waste Management Review speaks with key industry stakeholders about resource recovery exemptions.

When the NSW EPA banned the restricted use of mixed waste organic material (MWOO) in October 2018, industry reaction was swift.

The ban’s 24-hour notice period was deemed particularly controversial, with council planning and tender processes instantly altered.

The EPA’s apparent lack of transparency was also criticised, with claims industry had little access to the EPA’s internal research, or knowledge of the decision-making process.

While a Technical Advisory Committee Report was prepared in April 2018, it was withheld from the public for five months. Then Environment Minister Gabrielle Upton said withholding the report illustrated poor judgement on the EPA’s behalf.

The report’s eventual release did little to alleviate industry’s concerns. Speaking with Waste Management Review in October, an industry stakeholder, who wished to remain anonymous, said the report lacks reference to data that supports its baseline scientific assertions.

“While the report makes reference to multiple studies, those studies aren’t cited and industry hasn’t been granted access to the EPA’s research,” the stakeholder said.

Additionally, the stakeholder said industry engagement in the lead up to the decision was poor, with no formal consultation period or submissions process.     

The decision was also deemed controversial due to the NSW Government consistently advising that the state had a shortage of alternative waste treatment facilities (AWT).

In a joint letter to Ms Upton, the Waste Management Association of Australia, the Australian Organics Recycling Industry Association, Waste Contractors Association of NSW, Australian Council of Recycling and the Australian Organics Recycling Association said several existing long-term AWT contracts had been compromised by the decision.

RED BIN REPORT

MWOO, which predominantly consists of household waste organics and has traditionally been used as compost, was banned for use on agricultural land, plantation forests and in mining rehabilitation. It is worth noting the ban excludes land application of compost derived from source separated FOGO.

According to a 2006 NSW Environment and Conservation Department Report, titled Recycled Organics in Mine Site Rehabilitation and authored by Georgina Kelly, MWOO improves soil structure, moisture retention and soil aeration. The report also asserts that MWOO is a rich nutrient source that facilitates rapid micro flora and fauna regrowth.

On agricultural land the material serves a similar function, acting as a soil amendment, topsoil substitute and fertiliser.

Despite two decades of widespread use, the EPA’s Technical Advisory Committee Report argued that MWOO had limited agricultural or soil benefits.

“It is clear the current use of MWOO on broadacre agricultural land, with application rates restricted to 10 tonnes per hectare, could not be classified as beneficial reuse in terms of improved crop production or beneficial effects on soil chemical or physical quality,” the report reads.

“Higher and/or repeat application rates are needed for the material to have any significant effects on crop growth and quality and on soil chemical and physical quality.”

The report also suggests that higher MWOO application rates run the risk of greater soil contamination by metals, persistent organic chemicals and physical contaminants.

The report lists one site visit, conducted 22 September 2017, where visible waste streams including nappies, plastic and clothing were found in high proportions – the specific site and/or operator is not named.

According to the anonymous stakeholder, further research should have been conducted, including more site visits and sustained onsite testing.

In laboratory and glasshouse experiments referenced by the report, the effect of MWOO, and specifically ground glass, was examined on earthworm avoidance, rhizobium nodulation and clover and carrot growth.

Ground glass is commonly found in MWOO as processing employs grinding to meet physical contaminant limits.

While no adverse effects were observed for earthworm behaviour, rhizobium nodulation and clover growth, glass particles were seen to adhere to the surface of carrot tubers, at an application rate equivalent to 25 tonnes per hectare.

“While this application rate is above current 10 tonnes per hectare agricultural guidelines, if regulations were to change (to allow the beneficial effects of MWOO to be realised) it is possible that more MWOO would be applied, making this a real concern,” the report reads.

“The fact that glass is permissible in MWOO used on agricultural land requires that this issue be either further considered experimentally, or the risk avoided by more effective glass removal.”

The stakeholder questioned the carrot experiment’s inclusion in the report, given MWOO was already banned around crop harvesting. They also raised concerns over the anonymity of the technical advisory committee, and said industry had a right to know who was consulted on the decision.

When asked what the EPA could do to ease industry concerns, the stakeholder said that at a minimum, the EPA should revoke the material’s ban in mining rehabilitation.

They added that the EPA’s ability to change regulatory standards with a stroke of a pen had caused significant hesitation around private sector investments.

“If I had money to invest in resource recovery, I wouldn’t be spending it in NSW,” the stakeholder said.   

On 16 October, the NSW EPA opened public consultation on the future use of MWOO and a proposed $6.5 million AWT transition package.

In an associated position statement, the EPA reiterated its original MWOO position and stated further research had been undertaken to assess future controls.

Consultation closes 28 November.

RESOURCE RECOVERY EXEMPTIONS

The use of MWOO has been restricted since 2010, including processing and distribution regulations and limits on its use for urban and domestic purposes. Specifically, EPA regulations restrict the material’s use near crops harvested below the soil surface.

Within those restrictions however was a Resource Recovery Exemption Order allowed MWOO in some land applications under specific conditions, based on its then status as beneficial or fit-for-purpose.

In a statement released at the time, then EPA Acting Chair Anissa Levy said the MWOO exemption was made on the basis that the material provided a beneficial reuse solution for waste. The revocation was made in 2018 because the material no longer met those requirements, she said.

Resource Recovery Exemption Orders are made under clauses 91 and 92 of the 2014 Protection of the Environment Operations (Waste) Regulation Act.

According to Ross Fox, accredited specialist in planning and environmental law and Principal Lawyer Fishburn Watson O’Brien, the act was constructed to ensure orders and exemptions can be made, changed and revoked easily. He says while this has benefits, namely the ability to act swiftly in the face of environmental hazards, it also lends itself to overreach.

“What is arguably one of the act’s strengths is also one of its greatest weaknesses. It’s not clear why there is no specific testing process set out in the act, but it’s certainly a matter of concern for my clients and the industry generally,” Ross says.

He adds that there is no transparent framework for the revocation process when an order or exemption involves the waste industry.

“The sector is also concerned that decisions can be made without public access to the information the EPA has, and without the opportunity to raise concerns,” he says.

While the legislative framework for Resource Recovery Orders and Exemptions hasn’t changed significantly over the past 10 years, Ross says current conversation around the issue are a sign of a maturing waste industry.

He adds that while in some cases there may be cause to revoke or amend exemptions, the EPA should be required to establish, and in some cases publicise, their argument for revocation.

“Those who are operating pursuant to an order are entitled to a fair process, and a clear path to be followed by all parties to minimise the impact of that revocation to the extent that it’s possible.”

Mirroring the view of the anonymous stakeholder, Ross suggests the ease in which Resource Recovery Exemptions can be revoked has created a high degree of risk for investors.

“Operators are thinking: why should I invest hundreds of thousands of dollars in a piece of equipment that can produce material up to today’s specifications, when Resource Recovery Exemption legislation allows those specifications to be changed tomorrow?” he says.

“If the degree of risk is too great then it will discourage investment in resource recovery, which will have a negative impact on NSW meeting its resource recovery targets.”

FLOW ON EFFECTS

Christopher Malan, ELB Equipment Managing Director, says the MWOO ban has had a negative effect on organic diversion rates, and increased the amount of material sent to landfill.

“In addition to the direct effects felt by NSW recyclers engaged in mixed waste organics recycling, processors from other states have expressed displeasure over the likelihood of similar measures in their state or territory,” Christopher says.

“This has created uncertainty in the segment and slowed investment in the sector.”

Christopher says that while ELB is committed to organics recycling, the MWOO issue far exceeds the capabilities of efficient processing.

“Given the breadth of the issue caused by the removal of the exemption relates to the source of the waste rather than the recycling methodology or output product, there is little that we have been able to offer from a technical perspective to assist the industry,” he says.

Despite this, Christopher is optimistic and says the NSW Government, EPA and local councils should work together to address the problem.

“All parties can agree that recyclable resources, such as organics, should not be going to landfill,” he says.

“It is our hope that a review of organic waste handling assists in eliminating organic waste sent to landfill.”

Rose Read, National Waste and Recycling Industry Council CEO, says the MWOO ban has closed markets for five operating mechanical biological treatment facilities in NSW.

“Collectively, these facilities produce in excess of 150,000 tonnes of mixed waste derived organics per year. So far, the NSW EPA has provided landfill levy exemptions for these facilities,” she adds.

Furthermore, Rose says the MWOO ban has created uncertainty and confusion within both the processing industry and users of processed organics.

“It is critical that clear specifications are urgently agreed upon by regulators, processors and the final end users of the material on what is acceptable for the agriculture, forestry and site rehabilitation markets,” she says.

“These specifications should be based on best available science. Without this clarity, industry cannot develop infrastructure and technology to meet the user’s needs, and the state government will not be able to meet its recycling targets.”

According to Rose, industry is asking for an amended Mixed Waste Resource Recovery Order to be reinstated, that clearly defines outputs and applications.

“To deliver on these outputs, industry will need financial assistance to upgrade these facilities to deliver the required resource recovery outcomes,” Rose says.

“Industry will also need to transition these assets in the medium to long term, so they can continue to provide the desired resource recovery outcomes and market specifications for NSW.”

Rose says industry is also requesting that the NSW EPA insert a formal process within its waste regulations that ensures current and future Resource Recovery Orders and Exemptions cannot be amended or revoked without timely consultation and a detailed assessment with all relevant stakeholders.

Charlie Emery, Australian Organics Recycling Association Director and NSW Chair, urged similar action in a submission to the NSW Environment Minister, addressing the state’s proposed 20-year waste and resource recovery strategy.

In the submission, Charlie called for the creation and enforcement of consistent regulatory standards for organics processing.

“Waste cannot always be a waste. At some point after beneficial processing it must become a resource,” the submission reads.

This article was published in the November 2019 issue of Waste Management Review. 

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Looking to 2020 and beyond: APCO

Australian Packaging Covenant Organisation (APCO) CEO Brooke Donnelly provides an overview of some of the collaborative, sector-led projects that are helping to scale up the circular economy for packaging here in Australia.

The Collective Impact Model is at the heart of APCO’s work – a framework that engages a diverse range of participants who share the common interest of finding a new and sustainable approach to packaging.

This year a critical part of our focus has been to apply this approach at the sectoral level, by establishing and delivering a range of industry-led projects that can help highly motivated and willing sectors to address their unique packaging challenges.

APCO’s work with the wine industry began in 2018, with a two-day workshop at the Dorrien Estate to explore the impact of the 2025 targets for people working on the ground in the industry.

Combining site visits to packaging suppliers, retail operations and recycling plants, the session was designed to help participants see first-hand the entire packaging journey. By involving the complete value chain – including packaging suppliers, retailers, and wine producers and distributors – participants were able to recognise their stakeholders’ different needs and challenges, and identify any gaps in their own operations.

The most significant outcome of the day was the commitment to keep working together – and the Wine Industry Sustainable Packaging group has continued to meet regularly to explore the industry’s unique sustainable packaging challenges and potential solutions.

The group also agreed to work towards the delivery of several packaging-focused projects, including a pilot regional waste drop-off facility in the Barossa Valley, and greater data transparency, to help monitor the industry’s progress towards the 2025 Targets.

Also agreed was the plan to develop an industry-specific sustainable packaging guideline, and in October this year APCO and the Wine Industry Working Group launched the new resource together in the Barossa Valley.

Diarmaid O’Mordha, Quality and Sustainability Manager at the Endeavour Drinks Group, has been fundamental to the working group’s success. He explained that collaboration – often between unlikely partners – has been at the heart of the project.

“The idea was to set up a neutral, non-competitive space so we could develop a shared industry vision, with APCO leading,” says Mr O’Mordha.

“Working together, the industry can drive change from within, avoid the duplication of efforts, develop a platform to share information and set baselines to measure progress.”

“APCO were fantastic in connecting everyone – we couldn’t have done it without them. We were working with people in our industry we wouldn’t normally collaborate with because of commercial competition. But, with APCO’s role we were able to see ourselves as one ecosystem that everyone could benefit from – they helped put everyone at ease,” says Mr O’Mordha.

Food Services Industry

The food services sector has been another area of focus for APCO in 2019.

It’s an industry that’s undergoing a system-wide transformation globally, as businesses navigate challenges like growing public awareness around plastic waste. That’s alongside the tide of new packaging materials and operating models disrupting the way consumers engage with food service. At a policy level, many Australian jurisdictions are also considering state-wide bans on single use plastics. Businesses have been scrambling to adapt to the changing landscape, and navigate challenges like misinformation and the risk of greenwash in an effectively unregulated market.

They are all issues APCO has sought to help address with the Food Services Packaging Sustainability Guidelines, a new resource launched in October.

The guidelines were developed following extensive industry consultation, including a workshop hosted at the Qantas Campus in Sydney that brought together industry, government, and community stakeholders from across the country.

Designed through the lens of the waste hierarchy and incorporating practical case studies, the new resource will provide food service businesses with a step-by-step framework for navigating this rapidly changing industry, and support food service providers to begin making the change, while offering informed advice and tips on how to avoid making the wrong choices.

Looking to 2020, APCO has working partnerships in place with two highly motivated sectors within Australia, the dairy industry, represented by Dairy Australia, and the nursery industry, in collaboration with Greenlife Industry Australia.

Engaging sectors that are highly motivated, willing and able to address packaging sustainability will be key to progressing towards the transition to a circular economy for Australian communities.

By working together and combining material volumes, the model helps industry and government to scale up solutions and create economic tipping points to ensure solutions deliver viable interventions that are embedded as part of the institutional approach required.

The Food Services Packaging Sustainability Guidelines is available to download on the APCO website.

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