Productivity Commission Draft Report on Waste Management

Response by the Tasmanian Environment Centre Inc, trading as Sustainable Living Tasmania

Introduction
Sustainable Living Tasmania is a community education and resource centre, which aims to provide local, realistic and accessible information to help Tasmanians move towards a sustainable future. 

We are commenting on this draft report from the perspective of a community education organisation involved in working with individuals, households, businesses, community groups and schools, to raise awareness about environmental problems, particularly those relating to the urban environment, and to promote sustainable solutions. One of the key issues we work on is waste education, and the promotion of waste reduction, reuse, and recycling. 

Sustainability
Increasingly, scientists, policy-makers, communities, and businesses are waking up to the fact that we are living on a finite planet with finite resources, and that our very existence depends on how we manage those resources. Significant international reports, such as the UN Millennium Ecosystem Assessment Report released in 2005, consistently point to the fact that we need to urgently change our policies and practices to avoid serious environmental degradation that will negatively impact on our lives and those of future generations. The Millennium Report states: 

The changes that have been made to ecosystems have contributed to substantial net gains in human well-being and economic development, but these gains have been achieved at growing costs in the form of the degradation of many ecosystem services…These problems, unless addressed, will substantially diminish the benefits that future generations obtain from ecosystems.

The Report goes on to say:

The challenge of reversing the degradation of ecosystems while meeting increasing demands for services…will involve significant changes in policies, institutions and practices that are not currently under way.

Our experience as an organisation working directly with the community is that people are concerned about these issues and are looking for leadership and direction in moving towards a genuinely sustainable society.

While the Draft Report’s terms of reference offer hope that this document will provide such direction, it fails to do so, and its findings and recommendations are disappointing and demoralising for an organisation such as ours, working at the coal-face of community sustainability education. It is a retrograde document that represents a significant step backwards in the shift towards a more sustainable Australia. 

Terms of Reference
The scope of the inquiry promises to, ‘examine ways in which, and make recommendations on how, resource efficiencies can be optimised to improve economic, environmental and social outcomes’, and that it would include, ‘an assessment of opportunities throughout the product life cycle to prevent and/or minimise waste generation by promoting resource recovery and resource efficiency’ (p. V).

Unfortunately, the draft report fails to adequately address the terms of reference. It only addresses resource efficiencies involved in the disposal of waste. Resource efficiencies can occur at all stages of the product life cycle, and by ignoring the significant upstream issues associated with waste generation, the report concerns itself with a narrow and distorted view of the economics of waste management. 

Recycling
The report concludes that increasing levels of recycling are problematic, and are being pursued for ideological reasons only. 

We agree that recycling is environmentally unsound when the recycling process consumes more resources than it recovers. However, recycling schemes can achieve positive environmental benefits, and wholehearted community support.

For a federal government body to be backing away from recycling not only sends a negative and discouraging message to the large numbers of Australians who have already embraced recycling, but it also limits the further expansion of waste minimisation policies and practices. Recycling is only a small part of the waste minimisation equation. It is the first, and easiest step, with waste avoidance at all stages of the product life-cycle representing the most significant step in the move towards a less wasteful and more resource-efficient society.

Zero Waste
The report is critical of the concept of Zero Waste, stating that it is unworkable and uneconomic to endlessly recycle materials (p. 131). This understanding of zero waste, whereby it can only be achieved by taking recycling levels to 100%, is a distorted one.

The concept of Zero Waste is a whole new approach to waste. It is both an end-of-pipe solution that encourages waste diversion through recycling and resource recovery, and a guiding philosophy for eliminating waste at source and at all points down the supply chain. It aims to reduce consumption and ensure that products are made to be reused, repaired, recycled or composted.

Zero Waste is an aspiration, and a wholly admirable one. It has been embraced by communities, NGOs, local authorities and businesses worldwide. One of the largest corporations in the U.S., Dupont, has committed to the philosophy of Zero Waste and has made significant progress in moving towards this goal. Dupont’s Vice President Paul Tebo, who has won an Environmental Leadership Award for his work, recognises that wasted resources represent lost wealth and that decreasing waste improves productivity and shareholder profits. He has become a recognised leader in the field of ‘sustainable growth’ and predicts that in the future, ‘we’ll no longer be talking about economic, environmental and societal values as being distinctly different…but will see them as integral and interlocking aspects of every business process and activity.’

Conclusion
We strongly feel that this is a very disappointing and potentially damaging document. It threatens to undermine so much of the good work that has been done by Local, State and Federal governments, as well as the private and community sectors, to develop sustainable waste management policies and practices. 

In our opinion, the report needs to be entirely rewritten to comply with the terms of reference. It may be that the Productivity Commission is not the right body to be undertaking such an project, concerned as they are with Microeconomic policy, and that the inquiry should be handed over to a body with the mandate to look at wider environmental and social issues.