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Page 1: Draft waste management and resource recovery strategy consultation report · 2019-06-28 · Draft Waste Management and Resource Recovery Strategy, Consultation Report . 1 . Introduction
Page 2: Draft waste management and resource recovery strategy consultation report · 2019-06-28 · Draft Waste Management and Resource Recovery Strategy, Consultation Report . 1 . Introduction

Prepared by: Office of Resource Recovery, Department of Environment and Science © State of Queensland, 2019. The Queensland Government supports and encourages the dissemination and exchange of its information. The copyright in this publication is licensed under a Creative Commons Attribution 3.0 Australia (CC BY) licence.

Under this licence you are free, without having to seek our permission, to use this publication in accordance with the licence terms. You must keep intact the copyright notice and attribute the State of Queensland as the source of the publication. For more information on this licence, visit http://creativecommons.org/licenses/by/3.0/au/deed.en Disclaimer This document has been prepared with all due diligence and care, based on the best available information at the time of publication. The department holds no responsibility for any errors or omissions within this document. Any decisions made by other parties based on this document are solely the responsibility of those parties. Information contained in this document is from a number of sources and, as such, does not necessarily represent government or departmental policy. If you need to access this document in a language other than English, please call the Translating and Interpreting Service (TIS National) on 131 450 and ask them to telephone Library Services on +61 7 3170 5470. This publication can be made available in an alternative format (e.g. large print or audiotape) on request for people with vision impairment; phone +61 7 3170 5470 or email <[email protected]>. July 2019 #31860

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Contents Introduction ................................................................................................................................................................... 1

Background ................................................................................................................................................................... 1

How we consulted ......................................................................................................................................................... 1

Previous consultation .................................................................................................................................................... 2

Statutory review of 2014–2024 Waste Strategy .................................................................................................... 2

Queensland Treasury Corporation targeted consultation ..................................................................................... 2 Directions paper and previous strategy review report ........................................................................................... 2

Draft Waste Management and Resource Recovery Strategy ............................................................................... 2

Who provided a response ............................................................................................................................................. 2

What the responses said .............................................................................................................................................. 3

Introduction ................................................................................................................................................................ 3 Vision ......................................................................................................................................................................... 3

Strategic priority 1: Reducing the impact of waste on the environment and communities ....................................... 7

Strategic priority 2: Transitioning to a circular economy for waste ........................................................................... 8

Strategic priority 3: Building economy opportunity .................................................................................................. 10

Strategy implementation ......................................................................................................................................... 11

Community summary .............................................................................................................................................. 12 Other issues raised ................................................................................................................................................. 13

Waste disposal levy ............................................................................................................................................. 13

Energy from waste policy development ............................................................................................................... 13

Current compliance and regulatory framework ................................................................................................... 13

National harmonisation ........................................................................................................................................ 14

Appendix A - Who made a submission ....................................................................................................................... 15 Local government ................................................................................................................................................ 15

Environment and community groups ................................................................................................................... 15

Industry ................................................................................................................................................................ 15

Community........................................................................................................................................................... 16

Page 4: Draft waste management and resource recovery strategy consultation report · 2019-06-28 · Draft Waste Management and Resource Recovery Strategy, Consultation Report . 1 . Introduction
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Introduction The Department of Environment and Science (the department) undertook public consultation on the draft Waste Management and Resource Recovery Strategy (the draft strategy) from 12 February to 5 April 2019. A total of 75 submissions were received from local government, environment and community groups, industry and the general community.

The draft strategy presents a plan for a better way of managing waste in Queensland. It aims to minimise waste created, maximise the value of the resources used, cut greenhouse gas emissions and leave the environment in a better condition for generations to come. The draft strategy includes a clear vision and three strategic priorities.

This report outlines the consultation process that was carried out in relation to the draft strategy and provides a summary of the feedback on the different sections of the strategy.

Background Led by the department, the draft strategy is the overarching policy document for solid waste management in Queensland.

The vision of the draft strategy is that Queensland will become a zero-waste society, where waste is avoided, reused and recycled to the greatest extent possible. In addition, that strategic investment in diverse and innovative resource recovery technologies and markets will produce high-value products and generate economic benefits for the state.

The Transforming Queensland’s Recycling and Waste Industry–Directions Paper (directions paper) was released for public consultation in June 2018 and feedback from the directions paper helped shape the draft strategy. The draft strategy’s policy direction is also guided by principles set out in the Queensland Waste Reduction and Recycling Act 2011 (WRR Act) and Environmental Protection Act 1994, as well as national polices and strategies.

How we consulted Developing the draft strategy involved several stages of consultation with industry, as well as two formal public consultation stages:

Feb-

Mar

ch 2

017 Statutory

review of 2014-2024 waste strategy (targeted)

Jan-

Augu

st 2

018 Economic

Opportunities for Queensland's Waste Industry (QTC–Targeted)

June

-Jul

y 20

18 Transforming Queensland's Recycling and Waste Industry Directions Paper (public) Fe

b-Ap

ril 2

019 Draft Waste

Management and Resource Recovery Strategy (public)

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Previous consultation The following summarises the various stages of consultation. Relevant documents can be found at www.qld.gov.au/wastestrategy.

Statutory review of 2014–2024 Waste Strategy Under the WRR Act the department is required to undertake a formal review of the current waste strategy. This review process commenced in March 2017 and included specific targeted consultation with key industry and local government stakeholders.

Queensland Treasury Corporation targeted consultation During 2017 and 2018, Queensland Treasury Corporation were engaged by the department to explore the potential economic opportunities that could be realised by reducing waste to landfill and increasing recycling. Detailed consultation with over 65 individual stakeholders across research bodies, waste industry, local government, funding bodies and the community was undertaken to inform the final report.

Directions paper and previous strategy review report On 1 June 2018, the Queensland Government released the Transforming Queensland's Recycling and Waste Industry Directions Paper for public consultation. Appended to the directions paper was the formal review report for the Statutory Review of the 2014–2024 Waste Avoidance and Resource Productivity Strategy. Consultation closed on 29 June 2018 with a total of 100 written submissions received.

Draft Waste Management and Resource Recovery Strategy On 12 February 2019, the department released a consultation draft of the Waste Management and Resource Recovery Strategy for public feedback through Queensland Government's 'Get involved' website.

In addition, industry was engaged with through a number of forums, workshops, as well as the department participating in a podcast for one industry group.

The consultation period for submissions on the draft strategy closed on 5 April 2019. A total of 75 submissions were received.

Who provided a response Responses to the public consultation were received from local government, environment and community groups, industry and general community. Submissions received from peak bodies have been classified based on the group which they represent. For example, the local government peak body and regional group of councils have been classified as local government for grouping purposes.

For the purposes of analysing the feedback, multiple submissions from one respondent were counted as a single feedback response.

Written submissions received

Local government 12

Environment and community groups 9

Industry 25

Community 29

TOTAL 75

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What the responses said A total of 75 submissions were received. The feedback from these submissions is summarised in this report to reflect the sections of the draft strategy.

Introduction The introduction of the draft strategy sets the scene for the rest of the document. It establishes the need for change, outlines foundation measures the Queensland Government has already put in place and provides a high-level overview of the document.

Number of submissions relating to this section by stakeholder type:

Written submissions received

Local government 3

Environment and community groups 2

Industry 2

Community 0

TOTAL 7

Limited feedback on the introduction was provided. Feedback was largely supportive of the foundation measures, especially the ban on single-use lightweight plastic shopping bags, the introduction of the Container Refund Scheme and the Plastic Pollution Reduction Plan. It was also recommended that the Bio-futures Roadmap and Action Plan be included as a foundation measure.

CHANGE: Include the Queensland Bio-futures 10 Year Roadmap and Action Plan in the Foundation Measures section of the draft strategy.

Vision This section is the foundation of the draft strategy. It establishes a vision for waste management and resource recovery in Queensland, provides targets out to 2050 and outlines the foundation principles of the circular economy and waste hierarchy.

Number of submissions relating to this section by stakeholder type:

Written submissions received

Local government 8

Environment and community groups 8

Industry 19

Community 18

TOTAL 53

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The following table summarises the feedback and the government response.

Respondent Feedback Response

4 Local government

2 Environment and community groups

8 Industry

8 Community

Overall support for the draft strategy. Noted. No changes required.

0 Local government

0 Environment and community groups

0 Industry

1 Community

Do not support the draft strategy. Noted. No changes required.

3 Local government

3 Environment and community groups

3 Industry

3 Community

Support for the vision of a zero-waste society.

One submission suggested the zero-waste definition is inconsistent with the international recognised definition.

Noted. No changes required.

1 Local government

4 Environment and community groups

5 Industry

7 Community

Support for the waste hierarchy principles.

Noted. No changes required.

0 Local government

0 Environment and community groups

2 Industry

0 Community

The hierarchy should reflect the National Waste Policy’s hierarchy.

The hierarchy should reflect the WRR Act’s hierarchy.

Queensland should work with other jurisdictions on a standard waste hierarchy.

The Queensland Government continues to work at with other states and territories and the Commonwealth Government to standardise terminology. This commitment was made in the draft strategy.

No changes required.

0 Local government

0 Environment and community groups

2 Industry

0 Community

It should be clear where energy from waste (EfW) without energy recovery sits in the waste hierarchy.

It’s not clear why the hierarchy separates fuel and energy.

The Queensland Government has clearly stated support for the development of a biofuels industry in Queensland. This is supported, where relevant to waste, in the hierarchy provided in the draft strategy. Whilst this adds further detail, the hierarchy is consistent with the WRR Act.

The directions paper clearly stated that EfW without energy recovery (destruction) is considered to be waste disposal. Further details on the role of EfW will be made clear in subsequent documents.

No changes required.

6 Local government

6 Environment and community

Support the move towards a circular economy for waste. Noted. No changes required.

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Respondent Feedback Response

groups

7 Industry

10 Community

1 Local government

0 Environment and community groups

0 Industry

1 Community

A circular economy needs to be supported by education, to eliminate contamination and to bring the community on the journey.

Noted. The draft strategy and supporting documents identify education as a critical enabler for change.

No changes required.

2 Local government

0 Environment and community groups

0 Industry

0 Community

A circular economy policy is needed.

This policy will ensure recycling continues once EfW is introduced.

An action under the draft strategy and a recommendation by Queensland Treasury Corporation was the development of a position and policy on the role of the Circular Economy.

No changes required.

0 Local government

0 Environment and community groups

3 Industry

0 Community

The Queensland Government’s role in the circular economy should be active. Other’s expressed an interest for the circular economy to be market driven.

The Queensland Government should lead circular economy discussions at the Meeting of the Environment Ministers.

The Queensland Government continues to have an active role in discussions on the circular economy at the Commonwealth level.

No changes required.

0 Local government

0 Environment and community groups

2 Industry

0 Community

The Ellen Macarthur Circular Economy principles diagram in the draft strategy is out of date.

The diagram in the draft was provided by the Ellen McArthur Foundation as a resource.

CHANGE: The diagram used has been change to reflect comments made by stakeholders.

2 Local government

0 Environment and community groups

9 Industry

9 Community

Support for targets established in the draft strategy.

Noted. No changes required.

0 Local government

0 Environment and community groups

3 Industry

0 Community

Specific support was given for the greenhouse gas emission targets.

Noted. The Queensland Government has set a state target to reach zero net emissions by 2050. Reducing the amount of organic waste going into landfill will contribute to meeting this target.

No changes required.

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Respondent Feedback Response

1 Local government

1 Environment and community groups

1 Industry

7 Community

Targets are under ambitious.

Noted: The work underpinning the target setting suggests that these are stretch but achievable targets that would position Queensland with leading jurisdictions in Australia and around the world. The WRR Act requires the draft strategy be reviewed every three years, so there will be opportunities to review performance against the targets.

No changes required.

3 Local government

0 Environment and community groups

1 Industry

1 Community

Targets are over ambitious.

Noted: The work underpinning the target setting suggests that these are stretch but achievable targets that would position Queensland with leading jurisdictions in Australia and around the world. The WRR Act requires the draft strategy be reviewed every three years, so there will be opportunities to review performance against the targets.

No changes required.

0 Local government

3 Environment and community groups

0 Industry

3 Community

Targets should be headline targets for 2030.

Noted. Experience from the inter-jurisdictional review to inform the targets suggests that each progressive step becomes more challenging and requires more investment. It is expected that significant gains will be made between 2019 and 2030.

No changes required.

1 Local government

10 Environment and community groups

4 Industry

4 Community

Confusion around targets not adding up and the household waste reduction target.

The paper, Key Performance Indicators for Queensland's Waste Strategy, provides clarity in the derivation of targets to inform the draft strategy. It is noted that further clarity can be provided in the draft strategy.

The household waste reduction target is designed to reduce the amount of waste produced, whether recycled or sent to landfill. The recycling target is designed to ensure that a greater proportion of waste that is produced is recycled. EfW may be suitable for the 25 percent of waste that cannot be recycled by 2050.

CHANGE: Clarification will be provided around how the targets add up, including a clear explanation of how EfW fits into the target structure.

CHANGE: Target to reduce household waste will be amended to a ‘waste generation’ target.

CHANGE: Waste going to landfill target changed to ‘diversion from landfill’ target.

2 Local government

0 Environment and community groups3 Industry

0 Community

Further information about how the targets were arrived at, including inclusion of baselines.

Further information is needed on how waste reduction target targets are to be achieved.

Significant detail is provided in the QTC paper Key Performance Indicators for Queensland's Waste Strategy on how the targets were derived.

Baseline data will be included in the final strategy, noting that these data are reported annually in the Recycling and Waste in Queensland Report 2018.

The draft strategy provides the overarching framework within which a series of action plans and programs sit. These will provide the detail to support achievement of the waste reduction targets, and other targets included in the draft strategy.

CHANGE: Baseline data from the Recycling and Waste in Queensland 2018 report will be included for each target.

5 Local government

2 Environment

Waste reduction targets should include commercial and industrial (C&I) and

The introduction of the waste disposal levy will provide a significant fiscal incentive for producers of high volume C&I and C&D waste to recycle more and landfill less. As stated in the paper Key

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Respondent Feedback Response

and community groups

4 Industry

0 Community

possibly construction and demolition (C&D).

Performance Indicators for Queensland's Waste Strategy these waste streams are sensitive to macro-economic conditions (e.g. house building) and as such, targets on overall waste produced may have limited value. Alternative targets may be considered during future reviews under the WRR Act.

No change required.

Strategic priority 1: Reducing the impact of waste on the environment and communities Strategic priority 1 seeks to reduce the impact of waste on the environment and communities. To achieve this, key actions for Queenslanders, the Queensland Government, local government and the waste management and resource recovery sector are outlined.

Number of submissions relating to this section by stakeholder type:

Written submissions received

Local government 10

Environment and community groups 5

Industry 15

Community 11

TOTAL 41

The following table summarises the feedback and the government response.

Respondent Feedback Response

0 Local government

1 Environment and community groups13 Industry

4 Community

Support for the Queensland Government to establish a clear environmental regulatory and compliance monitoring framework that supports efficient operation of the market to protect the environment and human health from waste crime, and provide a level playing field for all market participants.

Noted. No changes required.

5 Local government

4 Environment and community groups

7 Industry

3 Community

Support was given for the Queensland Government to roll out well-funded, strategic and long-term community education.

It was suggested that this could be delivered in partnership with local government. Key areas for focus are increasing recycling, decreasing food waste and decreasing contamination.

Noted. The draft strategy identifies waste education as a key enabler for improving outcomes in both reducing the amount of food waste and reducing contamination within recycling bins. The Queensland Government is committed to working with the existing education network, where appropriate, to implement future education programs.

No changes required.

1 Local government

Support for the development of a litter and illegal dumping

Noted. No changes required.

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Respondent Feedback Response

0 Environment and community groups

1 Industry

2 Community

plan for Queensland and supporting actions.

0 Local government

0 Environment and community groups

2 Industry

0 Community

Support for the proposed audit of landfill infrastructure. Audits were also recommended for non-landfill infrastructure.

Noted. No changes required.

5 Local government

0 Environment and community groups

2 Industry

0 Community

Landfill bans and landfill closures should be well planned and strategically delivered.

Concern landfill bans put the onus on the operator rather than those generating the waste.

Noted. The potential introduction of landfill disposal bans will require careful consideration and a regulatory impact assessment. Where landfill bans are recommended, they will form part of a broader policy response which requires market development, education, and sufficient time for operators and waste producers to consider behavioural change prior to a ban commencing.

No changes required.

Strategic priority 2: Transitioning to a circular economy for waste Strategic priority 2 is about transitioning to a circular economy to support higher recycling and recovery rates, driven by world-class industry and technological advances. To achieve this, key actions for Queenslanders, the Queensland Government, local government and the waste management and resource recovery sector are outlined.

Number of submissions relating to this section by stakeholder type:

Written submissions received

Local government 8

Environment and community groups 1

Industry 15

Community 7

TOTAL 31

The following table summarises the feedback and the government response.

Respondent Feedback Response

4 Local government

0 Environment and community groups5 Industry

3 Community

Queensland Government should support and develop further product stewardship and extended producer responsibility initiatives.

Noted. In 2018 the Queensland Government introduced the state Container Refund Scheme. The Queensland Government is currently leading work on developing a national approach to product stewardship for batteries, as well as contributing to the development of a scheme for photovoltaic panels. The directions paper committed the Queensland Government to develop state-based product stewardship schemes where there is no national scheme, and where there is clear demand.

No changes required.

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Respondent Feedback Response

2 Local government

0 Environment and community groups

3 Industry

6 Community

The Queensland Government needs to act to reduce product packaging.

Support for a specification code for minimum recycled content in packaging and products.

Pressure should be placed on suppliers to reduce packaging.

Plastics should be limited/phased out. However, this should not compromise food waste and food safety.

Noted. The Queensland Government is actively engaged with the Australian Packaging Covenant Organisation supporting the target for all packaging to be recyclable, reusable or compostable by 2030.

The Queensland Government will also consider, through action plans under the draft strategy, the role of state government procurement in driving increased uptake of recycled content, where specifications or standards allow so.

The Queensland Government is also developing a Plastic Pollution Reduction Plan to drive the reduction of use of problem plastics, as well as encouraging the development of a plastics recycling industry in Queensland.

No changes required.

2 Local government

0 Environment and community groups4 Industry

1 Community

Support for the Queensland Government to collect and amalgamate data to address knowledge gaps, and inform reporting and decision making.

Noted. No changes required.

2 Local government

0 Environment and community groups

6 Industry

2 Community

Action is needed on problem wastes.

Waste identified in the submissions include liquid waste, organic waste, glass, tyres (mining tyres need careful consideration), solar panels, construction and demolition waste, bulky waste, timber waste, e-waste, textiles and batteries.

Noted. The draft strategy identifies plastic, organics (including food) and C&I wastes as being the highest priorities. Textiles, tyres and e-waste are also identified as priorities. The draft strategy commits to the development of waste action plans for problem wastes, which will be developed in collaboration with stakeholders on a progressive basis. It is expected that liquid wastes will be dealt with (to a certain extent) through individual action plans.

No changes required.

0 Local government

0 Environment and community groups

1 Industry

4 Community

Support for the Queensland Government to work with local government to optimise collection services for recycling and organics recovery from households.

Noted. No changes required.

2 Local government

0 Environment and community groups

0 Industry

0 Community

It is not possible for local government to develop consistent messaging in delivery of services between councils. The State Government should do this.

Noted. Councils own and operate their own contracts for waste collection services, and these are dependent on individual contracts they may have with the waste industry. Collection services are dependent on a number of factors, including the type of settlement, proximity of treatment or recycling facilities, and the volume of available waste. It remains appropriate for councils to provide detailed messaging around recycling services.

No changes required.

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Strategic priority 3: Building economy opportunity Strategic priority 3 is about building economic opportunity to stimulate investment and market development in the waste management and resource recovery sector and support economic and jobs growth. To achieve this, key actions for Queenslanders, the Queensland Government, local government and the waste management and resource recovery sector are outlined.

Number of submissions relating to this section by stakeholder type:

The following table summarises the feedback and the government response.

Respondent Feedback Response

5 Local government

0 Environment and community groups

5 Industry

0 Community

Support for the department to develop a state-wide infrastructure planning framework and regional infrastructure plans.

Both concern and support was given for the Queensland Government to develop waste precincts.

Noted. No changes required.

5 Local government

0 Environment and community groups

3 Industry

2 Community

Queensland Government should take the lead procuring recycled content products and materials.

Queensland Government should mandate mandatory procurement targets across all government agencies.

The department should work with the Department of Transport and Main Roads to ensure confidence, safety and quality of recycled content in road surfacing.

Price signals need to be imposed on virgin products to stimulate recycling.

Noted. The draft strategy makes a commitment for the Queensland Government to explore driving the uptake of recycled material through purchased goods and services. This would consider the role of other government departments in driving these changes. A major consideration would be the development of specifications or standards that allow replacement of virgin material with recycled content. A price signal on virgin products has not been considered at this time.

No changes required.

4 Local government

1 Environment and community groups

5 Industry

1 Community

Support for Queensland Government to investigate (and support) alternative end-uses and markets for recycled materials.

Stimulate market development for recycled products.

Establish a market development agency for all products from organics to plastics.

Noted. The Queensland Government, led by the Department of State Development, Manufacturing and Planning is preparing a Resource Recovery Industries 10-Year Roadmap and Action Plan (the Roadmap). The aim of the roadmap is to stimulate industry development for industries that use recycled content, and to enhance the marketability of the recycling sector. The roadmap will link back to the waste action plans to ensure regulatory and other legislative drivers (e.g. policy or landfill disposal bans etc.) are appropriately aligned to provide the push of material into these markets.

No changes required.

Written submissions received

Local government 10

Environment and community groups 2

Industry 11

Community 2

TOTAL 25

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Strategy implementation As well as direct feedback on the draft strategy itself, a range of feedback was also received on how the draft strategy should be implemented.

Number of submissions relating to this section by stakeholder type:

Written submissions received

Local government 3

Environment & community groups 2

Industry 5

Community 5

TOTAL 15

The following feedback was received on implementation of the draft strategy:

Respondent Feedback Response

0 Local government

1 Environment and community groups

3 Industry

3 Community

The draft strategy and action plans should be scheduled, monitored, evaluated and reported on over time.

Noted. Clarity of implementation schedules for action plans, and ultimately actions under the draft strategy is important to provide certainty to industry and allow sufficient time to adapt. Monitoring of progress of strategy implementation will be a critical part of measuring performance of sectors, and will provide critical information when policy and legislation is periodically reviewed.

No changes required.

1 Local government

0 Environment and community groups

1 Industry

1 Community

The action plans are required and should be expedited to ensure the draft strategy targets and objectives are met.

Noted. The action plans form a critical part in delivering the draft strategy. The implementation of action plans requires considerable interaction with industry and other stakeholders.

No changes required.

1 Local government

0 Environment and community groups

0 Industry

1 Community

Clarity in investment in the waste industry and innovation is required.

Noted. Clarity was provided in the budget papers for the period to 2012–22. Proceeds from the waste levy will be used for waste programs, environmental priorities and community purposes. Between 2018–19 and 2021–22 it is expected that over 70 percent of revenue generated through the levy will be allocated to advance payments to councils, scheme start-up and operational costs, industry programs and other environmental priorities. It is not considered appropriate for this detail to be provided in the draft strategy.

No changes required.

2 Local government

0 Environment and community groups

0 Industry

0 Community

The economic impacts to the community should be considered when rolling out the draft strategy.

Noted. The draft strategy aims to drive the economic benefit of recycling by increasing the number of jobs and the size of the economy in these areas. Action plans and other policy measures will consider the variability in the geography of Queensland and look to provide regional solutions where it is viable to do so.

No changes required.

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Respondent Feedback Response

0 Local government

0 Environment and community groups

1 Industry

0 Community

The draft strategy should be frequently reviewed and updated.

Noted. The WRR Act stipulates a review of the draft strategy is required at least every three years. This is an appropriate period to consider the performance of the draft strategy. It is noted that the WRR Act is due to be reviewed by 2021.

No changes required.

Community summary The community summary was a supplementary document created to engage the community on the draft strategy. It provides a snapshot of the draft strategy and includes five actions for community members to contribute to the outcomes of the draft strategy.

Number of submissions relating to this section by stakeholder type:

Written submissions received

Local government 1

Environment and community groups 2

Industry 1

Community 5

TOTAL 10

The following feedback was received on implementation of the Community Summary:

Respondent Feedback Response

0 Local government

1 Environment and community groups

0 Industry

2 Community

Support for the community summary. Noted. No changes required.

1 Local government

2 Environment and community groups

1 Industry

3 Community

Five simple actions are appropriate starting point for change.

Noted. No changes required.

0 Local government

1 Environment and community groups

1 Industry

2 Community

Agree there is room for Queensland to improve its waste management performance.

Noted. No changes required.

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Other issues raised Consultation was requested on the draft strategy and community summary, and supporting documents during this period. A number of submissions were made in relation to issues linked, but not directly referred to in the documents released for consultation. Each of these issues are outlined below:

Waste disposal levy Feedback on the waste disposal levy (levy) as a driver to increase recycling was overwhelmingly positive. Most respondents that mentioned the levy, opposed the levy rebate to householders as it is an ineffective price signal to the community to reduce waste and does not provide certainty for industry for the management of municipal solid waste into the future.

Several issues with the introduction of the levy were flagged, including likely increased incidences in illegal dumping, increased stockpiling and unregulated burning. It was suggested that financial assurances are put in place for stockpiling on non-landfill facilities.

It was suggested on a number of occasions that levy rebates should be tied to key performance outcomes and that the levy should be reviewed and increased to ensure its effectiveness as a driver for recycling and to meet the draft strategy targets. It was also suggested that all levy spending should be reported on in terms of performance. Others highlighted a need for consistent pricing of the levy across jurisdictions.

There was also significant feedback and ideas shared on how the levy funding should be spent. There was general support for the proposed 70 percent of funding going back to resource recovery and environmental programs. Support was given for the Resource Recovery Industry Development Program, the Transport Assistance Package, ecoBiz and Biofutures Fund.

Energy from waste policy development Feedback was received both in support of and against EfW.

Feedback for EfW positioned it as an important element of the waste hierarchy, that the EfW policy should be expedited to ensure certainty for industry and that it should be used as an alternative to landfilling for residual material.

Feedback against EfW said it does not form part of the circular economy, that it does not protect the environment, it has significant pollution and health risks, that it undermines recycling and that it is not necessary to meet the targets established in the draft strategy.

Some proposed that the levy should be imposed on EfW facilities as although it is an alternative to landfill, on the waste hierarchy it is marginally higher than waste disposal. Others commented that too much emphasis has been placed on EfW and not enough on higher order recycling. Specific feedback was also received on the types of technologies that should be considered by an EfW policy.

Concurrently, the department is preparing a discussion paper on the development of an EfW policy. This discussion paper will be released for public consultation in mid-2019, and as such, a formal response to the comments provided on the draft strategy is not appropriate. The feedback received will be considered in development of the EfW policy.

Current compliance and regulatory framework Significant feedback was provided about the current regulatory framework. A number of areas were proposed for improvement. A large number of industry stakeholders commented that regulatory framework needs to extend beyond landfill operations to ensure a level playing field. Others mentioned that there are several unlicensed facilities or facilities with poor practices, which need to be addressed to ensure a level playing field is established. Feedback was also received about the Environmentally Relevant Activities and the End of Waste Framework. The draft strategy commits to reviewing and updating waste related legislation and regulation periodically, and to reduce the impact on industry and communities from waste crime. Further refinements to the existing frameworks will be considered as necessary.

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National harmonisation Commenters highlighted the need for harmonisation of waste and recycling practices and processes across Australia. These harmonisation measures which respondents requested the Queensland Government’s support on include:

• waste and recycling targets, including food waste • proximity principles • waste disposal levies • waste tracking • minimum environmental standards and accounting for landfills • national materials recovery facility standards • standardised packaging requirements • standardise the waste hierarchy • policy and legislation • messaging.

The Queensland Government continues to work with the Commonwealth Government and other states and territories to prepare the action plan to implement the National Waste Policy, as well as on numerous inter-jurisdictional working groups looking at product stewardship and targets, as well as specific working groups for packaging and the circular economy. The draft strategy commits to continuing to work at this level, whilst also driving a state-wide agenda consistent with the National Waste Policy.

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Appendix A - Who made a submission Local government City of Gold Coast

Goondiwindi Regional Council

Hinchinbrook Shire Council

Ipswich City Council

Local Government Association of Queensland

North Burnett Regional Council

North Queensland Regional Organisation of Councils

Redland City Council

Rockhampton Regional Council

Scenic Rim Regional Council

Sunshine Coast Council

Western Downs Regional Council

Environment and community groups Boomerang Alliance

Capricorn Conservation Council

Healthy Land and Water

Ipswich Residents Against Toxic Environments (IRATE)

Magnetic Island Community Development Association

Queensland Conservation Council

Sunshine Coast Environment Council

Wide Bay Burnett Environment Council

Wildlife Preservation Society of Queensland

Industry Australian Battery Recycling Initiative (ABRI)

Australian Food and Grocery Council (AFGC)

Australian Industrial Ecology Network (AIEN)

Australian Landfill Owners Association (ALOA)

Australian Pork Limited (APL)

Australian Sustainable Business Group (ASBG)

BMI Resource Group

Cement Concrete and Aggregates Australia (CCAA)

Centre for Air Pollution, Energy and Health Research

Chamber of Commerce and Industry Queensland

Cleanaway

Earth Offset

Gladstone Ports Corporation

JJ Richards

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Mil-tek

MRA Consulting

News Media Works

National Waste Recycling Industry Council (NWRIC)

Plastics Industry Pipe Association of Australia (PIPA)

Queensland Farmers Federation (QFF)

Queensland Resource Council

Remondis

SUEZ

Waste Management and Resource Recovery Association of Australia (WMRR)

Waste Recycling Industry Association of Queensland (WRIQ)

Woolworths Group

Community A total of 29 submissions were made by members of the Queensland Community.