Waste 

FNQROC submission on the Transforming Queensland's Recycling and Waste Industry Directions Paper.

…..’Whilst FNQROC and member Councils are generally supportive of the application of a waste levy in principle, it believes there are a number of matters that require a better understanding to the proposal being put forth. It is hoped that consultation on this directions paper will open dialogue and be refined further to take into consideration local, regional and State interests.  

1. Councils within the region are significantly concerned that the application of the levy is selective throughout the State. Whilst it is appreciated that the intent is to apply the levy to the areas of the highest generation of the target waste streams; the practical application and regulation of the cross boundary transfer between the levy/non levy areas is extremely difficult, as evidenced by the Queensland/New South Wales cross border transfer.
2. The document nominates that the initial arrangement is to contribute an annual advance to each of the councils 105% of the levy collected, with any savings generated to be retained by the applicable council. Whilst, in some  circumstances (for those with significant waste stream inflows)  this provides opportunities for local councils to improve business metrics to be able to take advantage, the large majority of the councils within the region simply do not have the inflow capacity to support the change, thereby providing limited benefit.
3. The document identifies that the formula calculating the 105% rebate will be reviewed in future years, providing no surety to councils to develop business cases to allow them to consider any substantial upgrades to take advantage of this opportunity. Details on calculation methodology and length of commitment of this annual advance need to be clarified.
4. It is noted that the increase of $5/year is approximately a 7.14% increase, annually. This is more than triple CPI for the last 3 years, which is considered disproportionate.
5. Whilst it was nominated that a portion of the generated funds will be utilised to administrate, implement and upgrade infrastructure to facilitate the administration of the levy, it also nominates that any excess is to be considered as consolidated revenue for the State.It is considered unacceptable to generate consolidated revenue through the introduction of a levy, at a point wherein limited alternatives  are available to councils to improve the circumstance (i.e. direct funding of regional recycling and reprocessing facility) nor has there been any substantial commitment to such been committed to by the State.At a minimum, it would be reasonable to direct this funding of infrastructure that supports and complies with the end of waste framework, implemented by the State on 8 November 2016.  FNQROC strongly supports the hypothecation of 100% of the levy revenue back into the recycling and waste industry.  It does not support utilising this levy as general revenue for the State.
6. Due to the lack of regional reprocessing ability, the nearest major recyclable reprocessing centres are located in South East Queensland (1200-1700km) from the nodal centre (Cairns) of the FNQROC region. This distance makes it uneconomical for the region to transport feedstock from the region to these recycling markets.It is proposed that a fixed term transport equalisation subsidy be implemented for those Councils who are recycling to make it more equitable for councils to transport these materials to market. To this effect, it would also be a requirement to install infrastructure to rationalise waste volume and increase freight density at each point of collection to allow this freight cost to be minimised.
7. It is requested the State provide further information regarding the implication of the waste levy on the container refund scheme.
8. A key premise of the introduction of the levy is to drive culture change away from the disposal of waste into landfill; however, information from all States is that the introduction of a levy increased the levels of illegally dumped material. To mitigate this, the exemption of all domestic waste from levy design or a State supported compliance regime is necessary.
9. Given the mandate that there will be no direct impact on households, a clearer definition of Municipal Solid Waste (MSW) is required. To satisfy the ‘no household impact’ would require the inclusion of kerbside general waste, kerbside recycling, domestic self-haul to transfer stations and public space waste collection.
10. Given the level of uncertainty surrounding the above items, it is suggested that 6 months is insufficient time for  appropriate consultation and determination on the above to be completed, and further  provides insufficient time to plan, prepare and implement alternative waste management practices in lieu of the above. It is requested that the start date to the scheme be revised to the July 1, 2020.