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Summary of submissions on Martin Ward's waste levy report

This paper provides a summary of the submission received in April on Martin Ward’s report on reviewing positions and possibilities on the idea of a waste levy.

The submissions come in three categories:

  1. The Packaging Council and its members
  2. Waste Management and Recycling Companies
  3. Other sources

For convenience, the summary of submissions is ordered into these three categories.

In category 1, submissions were received from:

  • Packaging Council of New Zealand (Inc)
  • Griffins Food Limited
  • Sonoco New Zealand Ltd
  • S.C. Johnson & Son Pty Ltd
  • Sellagence Limited
  • Paperlinx Merchanting
  • Aperio Group (NZ) Ltd
  • Tetra Pak
  • Office Max
  • Amcor Australasia
  • Kensington Swan, Lawyers

In category 2, submissions were received from:

  • Carter Holt Harvey Limited
  • Waste Management New Zealand Limited
  • EnviroWaste
  • Visy Recycling

In category 3, submissions were received from:

  • Stuart Gane, Manukau City Council
  • Brian Smith
  • Warren Snow, Envision
  • Trevor Johnston, The Warehouse Limited
  • David W King
  • Jenny Lux
  • Jeff Seadon
  • John Lawson
  • Sheryl Stivens, Wastebusters Trust Canterbury
  • Susan Coutts, Community Recycling network, Wanaka
  • Robin Martin, CEO, Plastic New Zealand

Summary of points made by the Packaging Council and other category 1 submissions

  1. Packaging Council signed up to the Packaging Accord on the basis that it is a voluntary scheme and that government would consider regulation if the voluntary approach is not sufficient. The Council considers therefore, that packaging waste should be excluded from any levy.
  2. The product stewardship discussion paper indicated that before regulation is considered, the area targeted for regulation would have to be identified as a priority area. The Ward report does not clearly identify which wastes are priority wastes.
  3. The submission quotes the 2001 Tax Review as not being in favour of a tax on solid waste and wonders what has changed.
  4. Critical of the ‘one size fits all’ approach in the report and that this takes no account of the relative environmental impact of different types of waste.
  5. Say the report assumes all waste goes to landfills or clean fills “which is not the case”.
  6. Considers the RMA consents cover the environmental costs of waste disposal and that further intervention by way of a levy is unjustified.
  7. Concerned about misuse of the levy and subsidising of otherwise uneconomical recycling.
  8. If a levy is applied to ‘priority’ wastes, it should be national, rather than local or regional.

Summary of points made by waste and recycling companies and other category 2 submissions

Carter Holt Harvey

  1. General concern about ‘inappropriate’ regulation that could work against the government’s waste management objectives.
  2. A landfill levy may be justified in circumstances where landfill costs are not fully internalised through RMA conditions.
  3. Does not support local or regional waste levies and considers the idea of levying or ‘taxing’ materials destined for recycling will create a disincentive to recycle and is the ‘principal’ problem with the waste levy initiative of the North-West Alliance.
  4. Accepts an increase in disposal costs could motivate waste reduction and more recycling.
  5. Concerned about levy revenue cross-subsidising activities, or creating a disincentive to commercially driven recycling activities. For instance, levies collected on solid waste being used to subsidise high-cost collections for green and kitchen waste or used to support activities that are in competition with paper recycling.
  6. The use of regulation to impose a levy can be seen as conflicting with the voluntary approach in the Packaging Accord.

Waste Management New Zealand

The submission included several comments correcting or clarifying statements in the report. The comments on the substantive issues raised in the report included:

  1. Territorial authorities provide services in competition with the private sector and any regulatory regime should apply equally to both the private and public sector.
  2. Concerned about the scope of use of levy revenues and that the use of such revenue should not undermine private sector activities.
  3. The information requirements (and associated costs) of local levies, such as those of the North-West Alliance, are very high and thus present a strong incentive to avoid.
  4. Objects to any suggestion that a national levy could be ‘overlaid’ on a local levy.
  5. Strongly prefers levy revenues being administered centrally according to strict waste minimisation criteria. Prefers a central government body but considers a body representative of all sectors might be an alternative (a trust?).
  6. General concern about the scope of things supported by waste levy revenue. Supports funds being directed towards commercial recycling/cleaner production. Worried about cross-subsidisation.
  7. Does not support levy funds being used to monitor or reclaim historic landfills.
  8. Suggests any levy should also be collected on incinerators and other facilities of final disposal.
  9. Considers any levy legislation should spell out that the levy is a “generator legal obligation” to ensure that the “levy charge is shot home to the waste generator”.

Visy Recycling

  1. As Australasia’s largest glass recycler, Visy is primarily concerned about the impact of the levy on glass recycling.
  2. Points out that there is a large and growing amount of glass not being recycled even if a new oven is built by OI Glass.
  3. Some glass surplus to New Zealand’s needs is exported but transport cost is a major barrier and makes recycling of glass from distant centres (such as Invercargill and Dunedin) uneconomic. Only foreseeable practical long term use for used container glass is to recycle back to OI in Auckland for remanufacture as a new product.
  4. Concerned about lack of consultation with affected industries. Concerned about the impact of levies on other policies, such as product stewardship, the absorption of levy revenue into the Consolidated Fund, and the need to for levies to reflect the environmental impact of different types of waste.
  5. Visy strongly supports a ‘polluter pays’ approach rather than an ‘end user pays’ approach and provides reasons why such an approach is preferred.

Summary of points made in category 3 submissions

  1. Stuart Gane’s submission supported a national approach to waste levies with a levy being charged at the point of disposal and most of the revenue being distributed to councils and being used for waste reduction activities.
  2. Brian Smith’s submission contained general information on recycling from a UK newsletter.
  3. Warren Snow’s submission considered a regional approach to waste levies could work if designed properly and would be preferable to a national approach because there is less chance of ‘capture’ by vested interests and because decentralisation is important. Three broad regions were suggested.
  4. The submission from Trevor Johnston focused on the question whether a national levy that could support product stewardship schemes might be preferable to separate levies funding individual schemes.
  5. David King’s submission supported the concept of a waste levy and criticised Christchurch City Council’s decision not to process ‘compostable’ waste.
  6. Jenny Lux’s submission supported the idea of a national waste levy and the revenue supporting waste minimisation.
  7. Jeff Seadon’s submission stated that the Ward report gave the impression that a waste levy was a fait accompli and was concerned that the idea of a levy was being approached from too narrow a point of view. The submission suggested consideration should be given to extending the idea of a levy to waste water and (later) to air emissions. The submission also commented on the impact a national levy could have on existing local levies (Christchurch) and the composition of a well balanced group to further consider the levy proposal further.
  8. John Lawson thought that as a means of putting a cost on the environment detriment of landfills, a levy was preferable to doing nothing but was concerned whether the levy could be sheeted home to the residential generator of wastes. The submission raised the question of a levy encouraging fly tipping and it supported revenue being used to improve recycling.
  9. The submission from Wastebusters Canterbury supported the concept of a national waste levy and considered it should be 100 per cent available for waste minimisation. The submission also argued that those parties with interests in landfills should not be involved in the administration of levy revenue.
  10. The submission from the Community Recycling Network in Wanaka supports the establishment of a levy and a fund to support waste minimisation activities. The submission expresses views on the administration of the fund and argues that the establishment of a waste levy should not preclude the development of legislation covering product stewardship and container deposit schemes.
  11. Robin Martin, in the submission from Plastics New Zealand, stated that a waste levy will impact on its members and it wants to play an active role in the development of any waste levy proposals. A specific request was made to send any proposals to Plastics New Zealand and invite the organisation to any upcoming meetings.