Waste Levy Submission
As we get closer to the start date of the waste levy the reality for many operators is starting to sink in. In the past week I have spoken to a number of smaller Mum & Dad operators who have significant concerns that the impact of the levy will see them forced out of business.
Receivers of waste are starting to set prices. These prices are appearing to confirm that the price to dispose of waste is going to double to quadruple for companies such as ours. This will translate to around a 25 – 30% increase in the prices we charge for supplying skip bins.
Its is going to be a challenging time for the waste industry and all Queenslanders as the price of waste increases. Whether we will see REAL change in achieving the intended outcomes is yet to be seen. I suspect that the majority will decide to pay the levy and move on. I do not see any REAL change in how much waste will end up in landfill, at least in the short term.
Until Queensland achieves parity with NSW prices I do not see that this will stop the trucks. Its also important to understand that Yellow Wheelie bin waste and the Chinese Sword Policy has little do do with the majority of waste being levied.
I followed the online lodgment for the submission however it was never included in the Standing Parliamentary Report so I felt I should share my submission. I had also sent this to EVERY Elected Member and only had one response from Robbie Katter’s office.
Response to Proposed Industry Waste Levy 2019
The perspective and relevance of my submission is one coming from a business operating in the skip sector of the waste industry. It’s one of a small business owner that has worked in the waste transport industry (skip bins) for over 25 years. This industry is one of small business owners, Mum & Dad operators providing a waste removal service for a small section of the waste industry in largely household, C&D and C&I waste streams. It is a significant sector of largely small independent operators.
My submission is not complicated by vast amount of analysis of percentages and data, stripping down the movement of waste & recyclables and of how waste is handled locally and internationally. It’s a grass roots perspective of small business in this country and its role in waste transport through the use of skip bins. Highlighting how a waste levy will impact this specific sector.
Having endeavored to read as many reports, submissions and information currently available online such as the QTC Report – Economic opportunities for Queensland’s Waste industry & the State Governments Directions Paper I’m impressed by the information, the statistics and the objectives underlying a waste levy. What I have read fails to recognize the nature of the businesses involved in waste most especially the significant number of small businesses in the skip bin sector that contributes to waste transport. In particular there is a significant oversight of the human element involved in the waste industry. Trying to understand, ‘waste by numbers’ fails to encompass a complete understanding of the waste industry.
Whilst I will expand on it later I want to state from the outset that the reasoning and rationale for a levy along with the clear misunderstanding of the Waste Industry (Transfer Station & Landfill) and the Waste Transport Sector along with the FAILURE of interstate legislation is not a sound reason to impose a waste levy on Queensland Residents & Business.
Having said this I support the introduction of a waste levy that supports the process of a change in behaviors that underlies the reliance on simply throwing away rubbish, if it is based on a fully informed and reasonable rationale. I see this as a community issue and not a business issue, one the Directions paper fails to understand.
I do however oppose the mindset that ‘financial punishment’ is the way to create change and that the Queensland Government is willing to punish Queensland based on the FAILURE of interstate Legislation.
I will also state, and expand later that excluding householders in the process simply places the responsibility onto the business community that has over the past 20 years become increasingly burdened with regulation and compliance issues.
Industry Support for Waste Levy
The waste industry has been at the forefront of educating the public on waste management for many years. Even small changes in policy relating to licensing & various waste type regulations and handling can impact how we as an industry deal with the transport and disposal of waste which inevitable means we need to explain this to customers.
I believe that the Queensland State Government simply sees what comes in the front gate without understanding the how, what, why of how waste is generated. In my 25 + years of operating I have never received information or been approached from any government department in relation to consultation or understanding how waste is generated. The exception in the past number of years is the advent of WRIQ. Through this association the industry has commenced dialogue with the State Government with a focus of engaging the government in regards to reforms that affect our industry. As an industry we have been proactive and supportive of change and reforms. Regrettably whilst engaging with WRIQ I believe that’s at some levels and within some government areas sees WRIQ as an agitator and not respectful that WRIQ represents real businesses, with real people.
I believe that it is important to recognize that the waste transport industry is not the generator of waste but a service provider offering ‘transport solutions for waste management’. It is through the efforts of the waste industry that information is available to relevant government departments to understand and development relevant polices. As an industry we have been at the forefront of managing waste within the guidelines and legislation of the day. The industry has in many ways been the educator to the community where government departments have been more a about implementing or changing policy with little focus on education within the community.
As an industry we are a service provider to the community. In this regard the government needs to work with us ‘not penalize’ us as an industry on the road to reform.
Waste Levy Failure of Policy
“The Lyons Report found that Queensland is being used as a dumping ground for interstate waste. In FY 2017 it was reported that over 900,000 tonnes of waste was transported into Queensland, which was a 61% increase from the previous financial year, stating that Queensland’s waste recovery rate is also lower than most other states”. In no uncertain terms this is “a failure of Policy” in other states not to handle their own waste.
When we speak about lower recovery rates in Queensland are we taking note of the volumes of waste reported in other states that actually come to Queensland and including this in the lower recycling rates achieved in Queensland? Remembering that the final waste coming to Queensland for over the border has had the valuable items removed and does not warrant further processing.
Is this a distortion of the truth? I feel what we are blindly accepting of data that has been misreported for individual gain. I suggest that the Government is not asking enough questions to fully or better understand the state of waste, and we are moving forward in blind ignorance. It also suggests that the higher the levy the more creative companies will be to minimize the cost of disposal locally or interstate.
The recent ‘Chinese Sword Policy’ has impacted the viability of recycling ‘yellow wheelie bin’ materials (rightfully so). In 20 years of undertaking this policy we are at a point where the government at state and local level has FAILED to ensure that this aspect of recycling is done correctly. If we are unable to teach people the most basic fundamentals of recycling in 20 years how are we going to achieve this in the next 20 years?
The flow on effect of this is a misguided and ill-informed announcement by the current Queensland Government that we need to bring in a waste levy so we have funds to fix this. This is simply a case of robbing Peter to pay Paul if household waste is not levied. What this says is ‘it’s okay to keep doing what you want at home however when you go to work you need to recycle’.
This MUST be a shared responsibility. It’s simply misguided to think people that cannot sort their household recyclables, come to work and change their behavior. No amount of advertising and education is going to change this. Providing a round robin deal to sweeten the burden for local council’s still leaves them with the same issue. If people are not made responsible they WILL NOT change their behaviors.
The premise of the impending levy was that we needed to deal with the issue of ‘wheelie bin recycling’ so the Government linked this issue to justify a waste levy on the wrong sector roping in the issue of trucks across borders to gain community support (or reduce the back lash?). Linking household waste streams and associate targets is a far cry from the topic of C&D, C&I waste. This is like attempting to convince someone that an apple is an orange (the only common factor is its fruit). It’s the same with waste, linking the household recycling failure to the need to have a waste levy that is targeted to businesses is imposing another tax on business because Government has always believed that business can continue to absorb this or by penalizing them this will create innovation. NSW is testament that this did not and does not occur. Business will simply find creative ways to reduce this avoiding any associated costs, in this case the levy. To assume this is lawful disposal is naive which is supported by the illegal dumping reports in all states.
Reduce, Reuse, Recycle is a wonderful catch cry and appeals to everyone’s sense of saving the planet however what does it really mean and how effective is it or can it be. A point in case is that the waste levy and supporting legislation in other states has FAILED to ensure the outcomes they intended. The fact that trucks keep coming across the border is testament to this. The companies undertaking this accept high gate prices, cull the valuable recyclable components and then simply send the remaining waste to Queensland. Not because we do not have a levy but because these states have failed to manage their own waste and the legislation intended to achieve this.
On the other side of the equation I believe that the ‘FAILURE’ of other states policies has created an opportunity for some Queensland landfills to take interstate waste to the detriment of the Queensland Community. I know others would disagree and in the end its business however landfill is in the public interest and should be managed accordingly. If the policy in the southern states was sound, if markets existed for recycled products we would NOT see the VOLUMES of waste coming to Queensland. The fact is, this waste has already had the valuable recyclables removed and is considered unrecyclable at this point.
In response and incorrectly linking the Chinese Sword Policy and the failure of local contractors to ‘clean and sort’ household recyclable waste (complicated by the failure of this activity) has seen the Queensland Government blindly believe, that to fix this we need a levy. Not because it’s the right answer, more that it’s topical in saving the planet and it’s an opportunity to fill government coffers. It’s also one state following another state blindly a bit like the ‘Pied Piper’ and we all know how that story ended.
Getting back to filling Government scoffers… industry estimates suggest that in the first year of the levy the net figure is $228m the Government seems to think this will be $1.3 billion over 4 years. This appears to be another example of Government misinterpreting data. Of this windfall, how much will actually be spent on education keeping in mind the FAILURE OF EDUCATION with Yellow Wheelie bins!
Of the windfall the Government has stated that 1/3 of this will go into government coffers at a time when the industry will be hurting and many companies in the skip industry that rely on a small sector of the waste stream to survive, will be struggling.
Is the government willing to spend money hand over fist obtaining marketing advice from so called experts at ‘government rates’ to educate the public? Keeping in mind that 20 years of education for ‘yellow recycling bins’ has FAILED. I suspect that the default position is ‘the market will sort itself out’. I think it’s opportune at this point to share an actual example…
At the time of writing many trades are unaware of the actual impact the levy will have on pricing jobs. A recent example of this is… a plumber arrives at a job site and finds that drains are block and needs to dig up John Citizen’s pipework and replace this. This requires a 6 cubic metre bin. The bin has earth, clay, grass pipework and a few shrubs that were in the way. The waste weighs 8.46 tonne.
Recent changes to pricing in May (moving to tonnage rather than metres charges) pushed this bin from $340 to $616 dollars. In 2019 this same bin will cost $1208 (when we add $70 tonne for the levy). This means that a householder will pay an additional $868 to the price of the work being undertaken.
I have been informed that there is no concession to these types of loads due to the high level of work required to handle and stockpile and then move this material to suitable sites. A large proportion of the soil based materials are unsuitable for ‘soil’ manufacturing and need to be transported to hard fill sites at an additional cost.
There is a final aspect of this worth exploring… if we stop to look at the process of ‘kerbside recycling’ we see that local government tenders for the servicing of household waste. This includes the yellow wheelie bin that is the catalyst for the knee jerk response. The tender process in itself forces prices down to levels that means only a certain level of effort can be applied to this waste. Many of the primary tenderers sub contract this to other businesses as it’s an annoying sideline to where they make their real money and that’s household putrescible waste.
Taking into account the level of contamination of wheelie bin recyclables (recently reported in the media) this is a failure of the Queensland Government and Local Councils over the past 20 years to manage a program of recycling at the household level. Noting that these are the people we are expecting to go to work and adopt a new focus on recycling? Government has certainly demonstrated that education in this regard FAILED so how can we now trust the Queensland Government to implement a waste levy and expect it to be successful?
An interesting retrospect – Gene Tunny wrote in August 9, 2017
While Queensland businesses were supportive of the aim to reduce waste and increase the re-use and recycling of resources, they strongly opposed the introduction of the Commercial Waste Levy. Reasons why were important and included:
- Very poor consultation on the Bill with no RIS prepared. The State Government essentially made up its mind that it would be introduced and bulldozed its way in introducing it.
- The levy threatened business viability as many did not have the financial capacity to absorb additional waste costs nor did they have the resources to make changes to their waste practices and systems. With minimal capacity to pass costs onto customers the additional cost affected profitability and viability.
- Outside of South-East Queensland mature waste markets and opportunities for recycling and reuse were limited meaning the levy effectively acted as a tax on all business waste as there was no capacity to recycle in many regional Queensland LGAs.
- The starting price of $35 per tonne was considered too high in light of the significant transition required by industry and the waste sector. Most other jurisdictions when introducing similar legislation did so with a significantly lower transitionary price ($5).
- Business waste reporting requirements were onerous and significantly increased red tape and the regulatory burden.
- Money collected went into consolidated revenue with significant leakage and only a small portion used to improve recycling initiatives with monies instead divvied out to green interest groups or used elsewhere in the State Budget.
- The largest area of concern and hostility was that the Waste Levy unfairly targeted the business community. The exclusion of municipal/household waste from the levy not only unfairly taxed businesses but also created a number of complexities within the legislation which significantly further increased red tape for business and the waste industry.
Looking back at these points it appears nothing much has changed as the government continues to believe that this policy is what we need, come hell or high water regardless of the failure of policy in other states Queensland is going to get a levy.
I believe we need to look more closely at the real results (or FAILURE) that has been achieved in the southern states before heading into a major train wreck. Governments have continually failed to implement policy that in the first instance seemed to be in the public interest. Even when NSW endeavored to fix the ‘trucks across borders’ issue by apply the ‘proximity rule’ it failed.
I can only believe that policy makers and bureaucrats within the walls of government are too far removed from how the real world operates, which reinforces my point of being in the industry for 25+ years without a direct consultation prior to the advent of WRIQ.
I believe that the only reason for imposing the levy on business is the governments concerns of loosing votes. Not implementing a policy that is effective and balanced will simply add to the general viewpoint that government policy makers simply do not enact and implement sound, effective and appropriate change.
I believe that if we allow householders to continue to avoid the full responsibility of recycling that this will simply translate into the workplace. Waste reduction and re-educating the community does not sit individually with the waste industry, industry & business, the government or the community. IT IS A COMBINED RESPONSIBILITY.
To split the responsibility and place it onto only part of the community that governments believe can afford it is misguided and simplistic as inevitably the cost will be passed onto consumers. Consumer responses to the ever increasing cost of living translate directly into wages claims and cost increases to business which get passed on to consumers. In this respect business gets a double dose of costs associated with the introduction of a levy. Consumers have been constantly bombarded with either direct or indirect costs associated with government policy and changes and I believe that the only reason not to include consumers/householders is to save votes. There is no other rational or supportive reason not to do this.
Call a plumber to fix a drain, pay a levy, get the bathroom renovated, pay a levy, get the car serviced, pay a levy, do some landscaping, pay a levy, build a new home pay a levy. There is no escaping the inevitable so we may as well stop complicating the landscape and levy ALL waste.
The continued rhetoric that we need a levy to stop trucks across borders promoted in the media since the initial waste levy announcement over the past weeks is simply stating, “We must penalize Queenslanders for the failure of NSW Legislation” and this is the basis of why we need a levy!
Waste Levy Impact on SMALL BUSINESS
I have operated as a sole trader for 40 years, the past 25 years in the waste transport industry. I am deeply burdened by the onerous and increasing difficulty of operating as a small business. Much of government’s policy inevitable leads to monopolistic businesses to the detriment of small business.
Small business is a fundamental part of the Australian business landscape accounting for a significant portion of the workforce, often being the innovators of new ideas and technology. Due to their size they are more affected by the ongoing burdens of legislation.
In the geographical area I operate in (Brisbane) there are approximately 6-8 multi-national companies (and/or companies running 10 or more trucks) and over 80 small business operators in the mini-skip/bin industry in or within close proximity of Brisbane with 1 to 4 trucks. Beyond this there are countless operators generating waste in businesses such a mowing franchises, rubbish removal businesses, trailer bins, hire a Ute, earthmoving etc. along with operators in other regions throughout Queensland. This is a significant industry by the number of trucks and bins servicing waste management in Queensland.
On entering the ‘skip’ industry in 1993 there were only 6 companies servicing the Brisbane market? The skip industry grew as a direct result of the Mum & Dad operators seeing an opportunity to be self-employed. This demographic has not changed growing continually over the over the 25 years. The number of Mum & Dad operators or self-employed owner drivers outstrips company owned vehicles many times over and then some.
In many ways the earthmoving industry mirrors the skip industry because of the high volume of smaller and independent operators. There is a substantial segment of this industry that focusses on site cleans and smaller jobs which increases the point of the volume of Mum & Dad and smaller family based businesses involved in the transport and handling of waste.
The skip sector relies heavily on households and builders for work. In particular the increased cost of providing bins to householders will see a decline in the use of bins. This sector of the industry that has grown steadily over 30 years is going to be devastated without consultation or understanding that this sector of the waste industry is different to other transport models or waste streams.
MSW
MSW represents a significant percentage of waste in the overall tonnages/volumes of waste generated. It also poses the greatest environmental issue once placed into landfill when compared to C&D and C&I waste streams.
Household putrescible waste requires GREATER resources and management from a landfill perspective and provides almost zero ability for any form of recycling. It’s also significantly higher if not the highest level of potential environmental concern yet is not levied. The only possibility for this waste stream is Waste to Energy options (WtE) and in 30 years of a levy in NSW this has not eventuated. This is a FAILURE of policy and FAILURE of those entrusted to manage this.
The treatment of MSW in the levy is designed to side step the issue of making the whole community responsible for waste reduction. This is flawed in several respects – as I mentioned earlier, simply a way of not alienating the voting public. Providing a ‘round robin deal’ to sweeten the burden for local council’s still leaves them with the same issue. If people are not made responsible they WILL NOT change their behaviors.
Another point in the application of a levy under the MSW is the issue of council ‘kerbside cleanups’. If this activity is exempt from the levy then what motivation is there for residents to recycle or reduce what they throw out?
Collecting waste through kerbside cleanups does not change behaviors it simply continues to reinforce that a levy is ineffective and the responsibility of someone else not the individual.
MSW will require an attitude change by local Councils and the State Government as to date whilst these technologies have been available no councils have considered a complete commitment or investment in this.
It important at this point to reemphasize that C&D & C&I, along with general household clean ups such as old furniture, household goods, and garden waste requires a very different solution to MSW, most especially wheelie bin waste. I feel that the Directions Paper does little to consider these very different aspects of waste streams.
Waste Levy – Illegal Dumping
In a levy environment pricing will change to a ‘tonnage based system’ from what has been a ‘metre based system’. I believe what will occur as a direct consequence of a levy is firstly an increase in illegal dumping.
The NSW Illegal Dumping Report in 2015 reported showed that 64% of illegal dumping was household waste. These are the same people that struggle to manage their wheelie bin waste.
A point I’ve on several occasions is, how we are going to change behaviors when householders are not directly affected by a levy. The report noted, a third (35%) of the community and over a quarter (27%) of waste producing businesses had dumped waste illegally in the last year, most of which was on the kerbside. One in 10 (11%) in the community had illegally dumped waste elsewhere.
This issue exists in all jurisdictions that have a waste levy. A simple internet search reveals an overwhelming number of reported illegal dumping issues and these states inability to curb it. What is needed in all states is an appropriate level of levy that allows for the re-education of ALL residents and not a ‘penalty price level’ that actually creates what is trying to be avoided.
I believe that as the price of waste goes up there will be more and more illegal dumping occurring. One area of concern for the skip sector is the loading of waste into skip bins on site by neighbours and adjoining building sites. In a tonnage based system this will mean that the ‘customer’ paying for the bin will carry the cost of illegal dumping into the bin they pay to hire.
One aspect perhaps not evident from people outside the industry is as the price of waste goes up the motivation to AVOID PAYING increases. Continuing to use PENALTY as a motivator to change behaviors will only INCREASE avoidance. The higher the cost of waste, the greater the motivation to avoid it.
The report highlighted Local government experiences of illegal dumping A quantitative survey of members of NSW local government authorities (LGAs) was conducted to explore the nature and extent of the issue of illegal dumping. Over 8 in 10 respondents from local government (81%) felt that illegal dumping in their area was a major or moderate problem. It noted that the proportion of incidents involved various types of waste. Household furniture was the most common type of waste dumped, followed by domestic and green waste. Again this evidence overwhelmingly supports that allowing householders to avoid the levy will not support change in behaviors.
More than half of the responding LGAs had noticed an increase in the illegal dumping of household waste (54%) and asbestos (52%) in the past five years. Bushland, vacant lots and the roadside were thought to be the most common places for illegal dumping to occur. Householders, small businesses and large businesses were all identified as dumping waste illegally. Overall, householders were seen as the most likely to dump almost all types of waste.
Given the short lead time for submissions I am concerned that this aspect has not been adequately considered.
Grey Economy
A review of the rubbish removal classification in local newspapers highlights the level of small micro operators that largely operate outside of any licensing or financial reporting requirements creating a grey economy. These operators take waste to tips as local residents. Will these types of businesses be allowed to continue to operate outside of the new levy? These operators impact directly on the viability of the waste transport industry. These operators often work without a registered business, do not pay GST and taxes and reduce the price of waste transport to a level that is no longer viable for licensed operators. Allowing this situation to continue will not create a level playing field and will continue to destabilize the industry at a time where greater stability will be required.
In addition to this there is a new product/trend and emerging market segment using ‘skip bags’. This innovation demonstrates how easy it is to get into the waste industry. The low barrier of entry which includes the lack of licensing is a destabilizing influence. This unlicensed competition reduces the potential for current and successful companies to continue to invest in equipment and infrastructure that is needed to successfully deal with a waste levy.
If the levy is not applied across the board with appropriate and scaled licensing for different sectors I believe we will see a proliferation of operators working ‘under the radar’ by acting as local residents whilst actually operating commercially. There is already a significant portion of waste being handled in this way.
Licensing
For every building site that utilizes a bin there is another site using a cage or simply piling the rubbish up in a corner. These companies then utilize a bobcat operator to do the cleanup. In the past these operators were not required to hold a waste transport license. For a levy to be fair it needs to create a level paying field where all companies working in all sectors of the waste industry and different waste streams are held accountable for the waste they are transporting.
I believe that the level of small business operators in Queensland in industries that transport waste as opposed to generating the waste is almost beyond the possibility of an accurate count. It is these businesses that will be the most affected by a levy if it is not implemented correctly. The underlying reason for a levy is to ‘force recycling and reuse’ of waste streams. To undertake this activity requires additional investment and licensing. The issue of licensing is designed to force out smaller operators regardless of whether they are capable of undertaking this activity or not.
Another relevant point is what happens in the situation of a mowing company that completes work for householders which often includes a component of rubbish removal or a privateer that does waste collection on part time basis that goes to the local tip posing as a local resident. Will these operators require licensing and how will they be included into a waste levy. I suspect as I noted above there will be a proliferation of unlicensed operators in the ‘grey economy’.
I am strongly convinced that the mismanagement of the introduction of a waste levy will see many smaller licensed operators struggle to survive both financially and under the onerous burden of how to manage and implement the proposed changes at the small and micro business level. The only reason to ignore this situation is the long held view that Government Departments prefer to deal with a few larger operators than having to manage an industry as large and fragmented as the one that currently exists.
One Size Fits All
Over the past few years there has been a reduction in landfill sites within Brisbane and surrounding Councils regions. This has given rise to an increasing number of ‘waste transfer sites’. This in itself pushes up the cost of waste as it requires additional handling and transport to larger landfill sites.
These sites often undertake an initial sorting and recycling activity to remove soil products, green waste, concrete and recyclable metals (i.e. steel, copper, aluminum etc.) that have existing uses and markets. These are the easiest and most financially viable products. This activity in itself reduces the waste volume by 50%.
The establishment and licensing and requirements of ‘Waste Transfer Stations’ are a one size fits all regardless of the fact that the majority of operators are classified as small businesses. At the present time there are only a handful of companies doing this and from my knowledge this activity is a significant burden that barely breaks even. As recently as May this year one of the largest companies providing this type of service came out with a significant change to charging stating that their facility is failing (after 30 years of operation) as they move from landfilling to sorting and transferring of waste.
In a levy environment more changes to current legislation surrounding waste recycling and consolidation facilities MUST be done, not just considered. There is a real need for more relevant licensing for recycling facilities at the micro level. Smaller consolidation & recycling facilities provide a significantly lower environmental impact than large scale facilities. In ALL states that operate under the impost of a levy more companies operate outside of the legislation than within due to this SPECIFIC point.
Whilst not all operators would consider establishing a resource recovery/recycling facility the number of companies in a position to do this or would consider this makes my point of implementing relevant licensing fundamental to supporting the transition to a levy.
When more than 80% of the operators in the waste industry are Mum & Dad operators or owner drivers there is little hope that they can actively participate in the sorting and recycling of waste leaving an established industry at the mercy of large monopolistic companies that will endeavor to gain market dominance?
In all states appropriate planning, available land and zoning issues makes it difficult to establish the level and sophistication of facilities required to achieve the Governments altruistic vision of what waste recycling is.
Referencing an article in the ‘Inside Waste Magazine’ – Issue 84 (Page 18) it becomes apparent that the very State Governments that are forcing the levy on the community have significant shortfalls in supporting outcomes for a successful waste levy. How can we trust that Queensland Government will do any better when the foundation of our reasoning is to stop a failed NSW levy?
Nett Environmental Gain
The objective of a sound waste policy is to achieve a measurable, overall gain. Achieving these nett gains has benefits for society and is more than simply outweighing losses with gains. It requires doing everything possible and involves stakeholders working as partners not as opposition. Nett gain should bring long-lasting and meaningful benefits for our environment, society and economy. My concerns are that I have no confidence in the government and bureaucrats to achieve this when the very people that are writing this policy have never been to a landfill albeit that I am led to believe this may have occurred during the writing of this submission. To truly understand waste you need to get out and have a look, ask questions and built knowledge and understanding. Sitting in an office crunching numbers and reading distorted truths will fail the outcomes intended.
I have concerns that there is no mention of the negative impacts of recycling that have been considered or mentioned in the hard push to establish a levy by 2019. An oversight when no diligence is put into what appears from the outset to simply be just a good idea overshadowed by a $1.3b windfall?
The reduction of disposal site options in recent years has impacted on how some waste types have been handled often requiring travel of greater distances to disposal facilities. This in itself creates an environmental issue of more trucks on the road and the associated waste & pollution that comes with running trucks.
I briefly touched on the need to travel greater distances and run additional trucks to manage the same volumes of waste. The additional equipment required to manufacture new trucks and processing equipment, to process and recycle waste comes at an environmental cost. Along with the increase in trucks & equipment the environmental impact of the running and associated maintenance of these trucks and equipment also has an impact on the environment.
Over the past few years the congestion on Brisbane roads has resulted in a 30% decline in the productivity of skips trucks in my business. What I was able to achieve with 4 trucks now requires 6 trucks. The recent opening of the tunnels, the additional gateway bridge and road upgrades has done little to alleviate this. Congestion has added an increased cost to transport waste. The impost of these other issues along with a levy reduces the viability of being in the waste transport industry.
Overall I feel there are significant negative impacts of a levy that are not outweighed by the benefits. Regrettably due to the limited time to complete a submission I am unable to explore this adequately.
Waste to Energy – WtE
Waste to Energy solutions exist however none of them provides the ideal outcome for the environment. There is always some form of shortfall and as I mentioned there appears to be no mention or consideration of nett environmental gain as perhaps it does not exist, but in the minds of politicians. Perhaps blind faith is more important than fact?
The sheer cost of establishing WtE means that only a few large businesses might be in a position to consider this. The Capital Recycling Solutions in Canberra was touted as a $200m investment. This in itself is likely to translate to exceptionally high gate costs for waste disposal. My concerns in this regards are that it can only become a reality in a monopolistic waste environment due to the significant costs.
WtE technology is an energy recovery process that converts chemicals from waste residues into practical forms of energy like electricity, heat or steam. As of now, thermal conversion techniques lead the market among WtE technologies. Unfortunately MSW has really low calorific value and directly incinerating it will not generate adequate thermal energy which goes back to my earlier point of achieving a Nett Environmental gain.
Combustion/incineration is still the major type of technology used whilst other techniques are lagging behind. Again this appears to be USE THE EASIEST OPTION AVAILABLE (sound like trucks across borders).
There are obstacles to the establishment of these technologies. The overwhelming attitude of Australians is one of ‘Not In My Back Yard’. The recent proposed project in Canberra is testament to the opposition to this type of facility. If we look closer to home a case in point is the residential development of land that has been encroaching on the landfills at Swanbank – New Chum areas for many years and this issue is becoming more and more relevant as houses are built closer and closer to the landfills.
As I noted above the types of waste that would be directed to WtE is generally very low and inefficient source of energy and to make such a plant viable means that more energy (i.e. gas/coal) is put in to actually incinerate the waste. The reliance on a fuel source to run these types of plants makes my point of a nett environmental gain more relevant.
The Direction paper clearly demonstrates the lack of confidence the Government has in regards to WtE as a solution for residual waste streams.
The two factors of nett environmental gain and town planning along with government support to ensure WtE plants can actually be built in areas relevant to the volumes of waste being generated and transported is a major concern in regards to a successful waste levy. There must be an acknowledgment of the volumes of waste that are residual to any effective recycling.
The Government is ignorantly hopeful that private industry sees an opportunity and steps in, at a time when the levy itself makes it financially impractical to the majority of companies currently in the waste industry. The handful of significantly large companies or new entrants that might consider this investment will have a monopolistic position in controlling waste.
In over 30 years of waste levies in other states there has been limited or no investment in WtE solutions. Of the few that have occurred they are associated with larger successful industries such as Cement Production (SA) or Sugar Mill Industry (which is in QLD that does not have a levy) for a specific situation.
To be able to truly achieve the outcome intended ALL THE MONEY FROM THE LEVY SHOULD BE DIRECTED TO FINAL SOLUTIONS FOR WASTE. To achieve the investment required the levy must be returned to support and create innovation. I’d suggest that if this had occurred in NSW the state of waste in NSW and QLD would be very different.
In view of the fact there are almost no WtE plants established of any consequence I fail to understand that state governments that have a waste policy based on a waste levy and have not ensured that after significant periods of time the outcomes they intended have not been achieved nor do they see themselves accountable for the lack of outcomes.
This is not an industry issue, it’s a community issue and the fact that Governments need to intervene and legislate validates this comment and means that they should ensure the outcomes are achieved.
What is evident in all states that have a waste levy is that legislation has been enacted and Politicians and Government Departments have simply walked away and ignored the intended outcomes.
The very fact that the Queensland Government is going to take 1/3 of the levy and place into government coffers is indicative of a ‘Pied Piper’ approach one that has FAILED TO WORK in all states. The LEVY MUST BE RETURNED to drive investment and innovation. If we are going to follow the other states blindly, let’s not make the same mistakes!
Industry Funding
The announcement of a $100 million funding program to work with business and local councils to develop a high-value resource recovery industry misses the mark. The three areas of focus that underpin this are out of the reach of the smaller companies I referenced earlier. In regards to a dollar for dollar commitment $200 million is a FAR cry of what is needed to achieve the dreams of the Government. Again this funding is targeted to large business to the detriment of small business. This trend continues unabated in this country in all aspects of Government Policy.
The Government suggested that a significant number of ‘waste to energy’ plants are a preferred pathway to reducing waste. The recent ‘waste to energy’ plant touted for Canberra has now been officially withdrawn ‘Capital Recycling Solutions director Adam Perry says they have no plans now to build the incinerator on Ipswich Street in Fyshwick or any other site in the ACT, after coming to the conclusion the government would never approve it’ based on the negative opinions of parliamentarians along with mounting local opposition.
This plant was a $200 million investment which makes the $100 million dollar for dollar ‘grant fund’ insignificant.
The fact that Premier Annastacia Palaszczuk on her trade mission to the US earlier this month, in Boston in a bid to encourage more private renewable investment in Queensland is a slap in the face for local business irrespective if it creates some short term employment.
NSW has had a waste levy since the 80’s without any accountability to return this to industry to encourage innovation and development of alternative technology. The fact that the NSW government is willing to PUNISH its residents then allow companies to CHEAT the system and transport interstate makes it paramount that if Queensland is to be accountable to ensuring a successful waste levy the funds must be returned to advance the intended outcomes and be managed by an independent body. To steal 1/3 of the revenue stream is simply following NSW blindly and will most likely see rubbish being dumped on the side of the roads or in bushland.
Combined Developments
There are a significant proportion and increasing number of developments that combine both commercial and residential occupancy. Will the combined nature of some Body Corporate developments be seen as a commercial scenario? A Body Corporate is a commercial business often having an ABN and being registered for GST and run commercially as opposed to a residential home.
Many front lift trucks servicing these developments pick up a combination of residential and commercial waste in a localized area. It is not efficient to split these runs/loads. To do so would add significant costs and increase the number of trucks in an already congested road network. Where trucks are undertaking the pickup of ‘mixed’ loads how will this be differentiated when a front lift truck collects a percentage of business bins and a percentage of household bins? From my experience any concessions in these situations leaves a door open to exploitation and an opportunity to circumvent the levy.
Building & Construction
From my experience the estimate of the additional cost for the construction of a dwelling will rise significantly.
The average 4 bedroom house generates approx. 50 cubic metres of rubbish at an estimated weight around 32.5 tonne (@650kg/m3). These bins often contain a high level of air space. This does not account for bulk soil removed during site preparations and the final site clean. Based on current disposal rates the cost for disposal is $1365. When we add in the $70 a tonne waste levy this figure increases to $3640 being a 167% increase (we as tax collectors need to collect).
Whilst a number of recycled products such as drainage gravel (recycled concrete) can be used on building sites I believe that any increase in demand for these products is adequately supplied at the current recycling level. Reliable and available stockpiles of these products and the increase number of companies doing this are testament to this.
Whilst I have limited knowledge of pricing and ordering of building materials my view from operating in this environment is that much of the saving associated with construction through the reduction in ordering materials due to innovative construction ideas and techniques has already been achieved leaving little room for this to be seen as a means to reducing waste. A point in case is framing and roof trusses which are largely prefabricated and arrive onsite with little or no waste.
A final point relevant here is the potential for a landfill ban on timber. In my experience all construction timber has been chemically treated in some form or another. If we were to remove this from the waste stream and recycle it, what products could it be made into? Does it pose potential issues as a result of these treatments? A point in case is CCA treated pine that in recent memory came under scrutiny and resulted in it being removed in childcare centers, council parks etc. etc.
In addition to this if it was used to mulch and decompose for soil manufacture these chemicals end up in the soils, potting mixes etc. and potentially the vegetables people grow at home!
My enquiry into timber & green waste in the other states where mulching is the solution for green waste and timber there are significant stockpiles which in itself creates an environmental issue one often scrutinized by Department of Environment and Heritage Protection here (having spoken with soil manufacturing businesses in Queensland). Even if we burn this timber what potential is there for the chemicals to enter the atmosphere highlighting the issue of WtE sites being close to residential areas?
In my experience I believe the levy will add to building costs not reduce it in spite of preconceptions that there will be opportunities to benefit.
Oversupply of Product
Another point that appears to have been over looked in the discussion is that as more companies undertake recycling and processing of waste there will be an inevitable ‘glut’ of product on the market. This will work against the investment required to undertake this activity. As I mentioned in the previous section there are currently significant stockpiles in other states which in itself creates other environmental issues. Even in Queensland without a levy we have stockpiles and often this product is given away free just to reduce the volume sitting on site.
Exposure to Debt
Waste transport companies simply provide a service for transport and are not generators of waste in context of what will be levied. What will occur if companies go into liquation after our services are provided and the waste is disposed of? It is an unfortunate element of the waste transport industry that it’s vulnerable to building companies going into liquidation on a more than regular basis. If the generator of the waste is responsible and we are acting as transporters of waste and are simply ‘a tax collector for the government’ what relief will be available.
Based on current figures and information the cost our services will double to quadruple once the levy commences. The exposure to debt grows exponentially remembering that the number of smaller operators outstrips the multinational companies many times over. As a levy collector the government is exposing small (and large) businesses to a financial impost without any relief when the inevitable occurs.
No business should be impacted by being a tax collector. It’s one thing to deal with a 10% GST however a 166% increase in a cost is beyond a significant burden to businesses.
In Conclusion
I believe we need to seek to understand how other countries have managed the process of waste reduction through levies as I believe that the models and experiences in other states of Australia have fundamental flaws.
In view of the impending levy (which the industry has been aware of for some time, no surprise to us) I researched prices in NSW and Victoria. When you look at the price of bins in NSW what is evident, is that prices have simply doubled (or more).
I suspect that if the time was taken to survey various sectors of waste generators you will find that they have decided to pay the levy and not bother to change their behavior which leads me to my next point.
Following on from communications & discussions with large facilities here I believe we will see the same thing occur here at half the waste levy charged in NSW. The receivers of waste in Queensland are not ready or capable of handling recycling of waste at the commencement rate to adequately find a new market price that represents an appropriate increase to cover the levy. What we will see is price gouging to the detriment of Queenslanders and the Waste Transport Industry.
My view of this is supported by the increase in interest from companies from the Southern States to move into Queensland if a waste levy occurred. These are the same companies that have been sending waste to Queensland. They understand a levy and understand the increased percentages they can gouge from a waste levy, again to the detriment of Queenslanders and the Waste Transport Industry.
At this point in time sites in Queensland accepting waste from interstate have a high sense of the value of the ‘air space’ based on the levy environment in other states and the prices these companies are willing to pay. The higher the levy goes in these states and the more these operators are willing to pay the higher this feeling of worth increases. Notwithstanding I understand the commercial factors of this, however at this point in time this is to the detriment of Queenslanders. It’s like a Dutch action to see who will pay the highest price. This point is validated by the attitude and pricing changes in the past months by waste receivers in Queensland. Along with declining air space and an abundance of interstate waste and a State Government unwillingly to encourage more landfills in light of current events.
I’d suggest that the Government has not adequately qualified the metrics of interstate transport of waste and I’d suggest that a $70 tonne levy will only have a minor effect on the cost to transport interstate and not be the deterrent that the government believes.
Whilst we are blindly attempting to play catchup with other States that have not managed to achieve the outcomes they intended the $70 commencement price is a SIGNIFICANT price point. Other states HAVE had decades to absorb a levy and accept and adapt to a levy pricing structure. What the Queensland Government is doing is dropping the industry directly into the fire.
A review of the operations in other states shows that the waste transport industry has evolved into a waste processors and recyclers industry. In order to make a margin for the transport of waste and to remain competitive (as a result of market forces to do so, along with competition from the seedy part of town) legitimate operators need to minimize disposal costs. This is achieved through recycling, reduction and consolidation by removing the ‘easy items that represents a ROI for the effort’. The remaining waste has simply been taken to the lowest price disposal option.
The waste transport industry in no longer a transport industry we are having to adapt and become a processor of waste which has been placed upon us by changes in government policy over a number of years not just the recent proposed changes. As an industry we are not opposed to this but it appears that many government departments through attitude or policy deal with us as an industry as if we were environmental vandals whilst we are simply providing a ‘transport service’ to waste generators, not withstanding rogue operators that occur in many industries.
As professional operators and in support of our industry in Queensland we created the Waste Transporters & Recyclers Association of Queensland now WRIQ in order to bring together professionally operated companies and create and adopt a code of conduct to work within current and future legislative framework.
The government has an opportunity to work with us as an industry to achieve sustainable outcomes through a respectful and supportive relationship.
As a final point I believe that allowing a large part of the community to simply keep doing what they are doing (not doing!) erodes the purpose of the very reason for having levy which is to re-educate. Change can only occur through education and knowledge. Using ‘money, penalty and financial punishment’ as a fundamental tool for forcing change is outdated and an impost on the Australian way of life as is expecting business to carry the burden of change.
To take money from an industry that will be ‘hurting’ and redirect this away from direct input into innovation and new technologies in the waste industry is following in the failure of policy in the other States.
To simply say that other states have survived a levy would be easy statement to be made as this is underpinned by the continual volumes of waste being trucked from southern states. It’s a FAILURE OF POLICY and this is the foundation on which Queensland is going to base a levy.
My call to the Minister
I realize my submission may on occasions have been to the point, emotive, occasionally bordering on sarcastic, sometimes interesting in exploring a different point of view however in the end it has one message…how can we trust a government to manage a waste levy policy, one that has not been proven to work from the delivery of waste to the final sale of recycled products in all but a few waste streams. There are limited examples that recycling processes leads to the development of new products or technology to handle and process waste, most especially the residual waste streams. It’s called waste for a reason and that is that there is not financial reward and nearly zero markets for products as a direct result of a waste levy in any state that did not exist prior to a levy. Even the FAILURE to achieve WtE opportunities is all but nonexistent. If a sound and correctly managed Waste Policy and legislation has not worked after 30 years of levies (NSW) we would not be in this situation.
I also suspect the Minister will not consider all the aspects and provide a detailed reply; more likely subrogate this to an underling to respond who will give me nearly as much bureaucratic mumbo jumbo as they can muster. I know this because; this is how I have experienced Ministers at State and Local Government recently and in the past.
Legislation and change ‘benefits and fails’ the community in equal proportions. At time when we should be aiming to achieve greater outcomes than in the past my deepest concern is ‘not enough questions have been asked’. There has not been sufficient investigation to implement a sound robust waste policy. The directions paper only recognizes the justification of a levy and not the practicalities nor the impact on the waste industry and the significant number of small business operating in the industry.
The willingness and enthusiasm on railroading this change as soon as practical is testament to this.
My challenge to the Minister is to provide consideration of all valid points and respond accordingly. Only then would I understand that the State Government has an understanding of the impact on small business. I have little doubt that large businesses will continue to respond to government legislation to the detriment of small business in this country.
The limited time frame the government has allowed for submissions is systemic of a government not interested in public opinion. The time frame does not allow adequate time to read, absorb and develop responses to the quality required for such a change that will fundamentally impact every single Queenslander for years to come.
Robert Gross (Owner)
Handybin Waste Services