Each year we bury nearly half a million tonnes of material in Tasmanian landfills (not including concrete rubble, road pavement, glass, bricks, etc.). The majority buried is food and green waste, cardboard and paper, recyclable plastics and other materials that could easily be redirected. Artificially cheap landfill is biasing the market and has created anti-competitive forces that are undermining recycling and resource recovery opportunities and leading to a disproportionate amount of waste that could be redirected. Accurately pricing landfill creates headroom for recyclers to operate competitively and encourages everyone to redirect materials away from landfill.
Accurately pricing landfill to encourage diversion
The City of Hobart has just asked for State Government environmental approval to extend the life of the McRobies landfill to 2030 and to bury another half a million tonnes of material in the valley (view the application). We acknowledge the great work the City has done to improve waste management and their long-term vision for zero waste, however we believe that they should not get environmental approval to increase the life of the McRobies landfill site until burying materials in landfills across Tasmania comes with an accurate and commensurate price (through higher gate fees and a State-wide waste levy) to encourage diversion.
Accurately pricing landfill across Tasmania and creating a level playing field (for privately and publicly owned landfill sites) is the best way to ensure that compostable and recyclable materials are no longer buried in Tasmanian landfill sites.
Currently in NSW it costs $355 to bury a tonne of material at landfill sites ($222 gate fee for the landfill operator and an additional $133 for the State Government as a levy). NSW continues to set the trend for other States. By comparison, in Tasmania it costs around $80 a tonne (unless they are high annual usage customers and then it is cheaper). In the North, an additional $5 levy is also collected.
What is the real cost of this service and who is going to pay for it – ratepayers or landfill users?
Accurately reflecting the true costs of landfilling materials creates the headroom for recyclers to operate competitively and leads to many new business opportunities. It also removes the onus from rate-paying households who currently subsidise big commercial generators like clubs and pubs, retailers and building companies, as well as all past users.
The effect of accurately pricing landfill, like they have done in NSW and other States, has been to drive waste costs for most companies from 1% of operating costs towards 2-3% (MRA Consulting). This may be perceived as a business impost or an opportunity. We see it as the latter.
Landfill gate fees across Tasmania have not been nearly enough to cover the costs of operation, overheads, mobile plant and equipment, labour, contamination monitoring, pollution control, depreciation costs of roads and buildings and other fixed assets. And they certainly do not cover 30-50 year post closure management, long term monitoring and reporting, and importantly replacement of the landfill asset itself. By way of example, rehabilitation of the McRobies site, is estimated to be $6.5 million and millions have recently been spent to reduce leachate affecting surrounding land and waterways (McRobies Strategic Operating Plan).
Your opportunity to express concern
Presented with the opportunity to express concern over waste management in Tasmania, Sustainable Living Tasmania will be submitting a representation relating to the permit application and we encourage you to do so as well.
Any person may make a representation relating to the permit application up to Monday 11 January 2016. The purpose of providing input is to help the EPA Board consider more fully all the environmental impacts of the proposal. Without prompting, it is unlikely that the Board will consider the environmental impacts of not redirecting waste away from landfill. It is likely that they will be more concerned with how the City of Hobart plans to deal with pollution (to air, land and water) that arises due to the burial of materials in the valley.
You need to send your letter to:
City of Hobart
GPO Box 503
HOBART TAS 7001
or email [email protected].
Possible dot points for your letter
1) I would like the City of Hobart and the EPA Board to consider the following points in relation to Council's application for environmental approval to increase the final fill height of the McRobies Gully Landfill in South Hobart, from the currently permitted maximum fill level of 184 metres above sea level (AHD) to 200 metres AHD, and the resultant increase in capacity of approximately half a million tonnes of waste (plus 'cleanfill').
2) I believe that the City of Hobart, as one of the big-six Tasmanian landfills, should not get environmental approval to increase the life of the McRobies landfill site until burying materials in landfills across Tasmania has been accurately priced (through higher gate fees and a State-wide waste levy) to encourage diversion.
3) Large quantities of food and green waste (26%), cardboard and paper (10%), building material (21%), recyclable plastics (9%) and other recyclable materials are currently being buried in Tasmanian landfills (source NTWM Landfill audit 2011). These materials could easily be diverted, rather than create unnecessary long-term pollution to land, air and water.
4) A number of Councils collect or will collect green waste and plan to collect food waste in the future. This is not an adequate solution as there is uncertainty as to when they will be able to implement food waste collection. Both food and green waste need to be diverted as soon as possible. The State Government will need to plan for increased commercial composting capacity.
5) The environmental impacts of a landfill site go beyond pollution to land, air and water in the immediate area. They are also present in the resources wasted and lost opportunity. Approximately 426,000 tonnes of materials has been buried in Tasmanian landfills each year since 2007, the majority has been compostable, reusable or recyclable (source: EPA Annual Report 2013/14, WAC Tasmanian Waste Review 2014).
6) Based on the mainland trend of a $133 landfill levy, a Tasmanian waste levy should be introduced incrementally to a comparable amount over the coming five years, this will provide time for recycling businesses to establish. The effect of accurately pricing landfill, like they have done in NSW and other States, has been to drive waste costs for most companies from 1% of operating costs towards 2-3% (The State of Waste 2015, MRA Consulting). This may be perceived as a business impost or an opportunity. I see it as the latter. Accurately reflecting the true costs of landfilling materials creates the headroom for recyclers to operate competitively and so leads to many new business opportunities. It also removes the onus from rate-paying households who effectively subsidise big commercial waste generators like clubs and pubs, retailers and building companies, as well as all past users. A token $20 levy is not an option, effective waste diversion relies on strong cues.
7) Contrary to the mainland States, reporting on quantities of construction and demolition waste materials such as concrete rubble, road pavement, glass, bricks, etc. is currently not required under the Tasmanian Waste Classification System (source: EPA Annual Report 2013/14). I believe that these materials need to be reported and must be included in the State-wide waste levy, so that they can be better managed. They currently do not attract a gate fee but represent significant amounts of embodied energy and should be directed to reuse schemes.
8) Currently approximately 40% of the weight received at Derwent Park Materials Recycling Facilities is glass. 75% of used glass packaging ends up in various landfills around the State (only 25% is used in bricks and as road base, and none is made back into glass). The low and misleading reported kerbside recycling bin contamination rates (e.g. 7% in Southern Tasmania) need to be corrected to more accurately reflect the true outcome of the communities recycling efforts (and associated costs).
9) As per the objectives of the Resource Management and Planning System of Tasmania, I believe that it is important "to promote the sharing of responsibility for resource management and planning between the different spheres of Government, the community and industry in the State". As evidenced by the large quantities of compostable and recyclable resources being buried throughout Tasmania, the community and industry spheres need the assistance of the Government sphere (through a waste levy) to more responsibly manage waste.
10) As per the Environmental Management and Pollution Control System, I believe that it is important to achieve the following objectives from that System (Schedule 1 Part 2):
(b) to prevent environmental degradation and adverse risks to human and ecosystem health by promoting pollution prevention, clean production technology, reuse and recycling of materials and waste minimization programmes; and
(d) to allocate the costs of environmental protection and restoration equitably and in a manner that encourages responsible use of, and reduces harm to, the environment, with polluters bearing the appropriate share of the costs that arise from their activities; and
(e) to require persons engaging in polluting activities to make progressive environmental improvements, including reductions of pollution at source, as such improvements become practicable through technological and economic development; and
(g) to control the generation, storage, collection, transportation, treatment and disposal of waste with a view to reducing, minimizing and, where practicable, eliminating harm to the environment; and
(k) to co-ordinate all activities as are necessary to protect, restore or improve the Tasmanian environment.