21 March 2006

The Commissioner,
Waste Generation and Resource Efficiency Inquiry
Productivity Commission
Locked Bag 2, Collins Street East,
MELBOURNE  VIC  8003

Dear Commissioner,

WSN Environmental Solutions – Further Submission

Several submissions to the Inquiry have referred to WSN Environmental Solutions. In this context, WSN wishes to emphasise the following points:

1.	WSN operates modern facilities and is subject to modern regulatory requirements.
2.	WSN is required to operate within the Competitive Neutrality Framework established by COAG and the NSW Government. WSN receives no taxpayer subsidies, has an independent Board, and pays tax equivalent payments and dividends to its shareholders.
3.	WSN is confident that all its actions in the municipal waste market are compliant with trade practices legislation.
4.	WSN’s recycling rate for the recyclables stream is similar to other industry players. In fact, WSN is leading the industry in recovering additional recyclables from the putrescibles waste stream, and is the sole provider of a range of other resource recovery services (eg paint).
5.	WSN’s record is available via our Annual Report, which includes independently audited Sustainability Indicators, compliant with the Global Reporting Initiative – a transparency unmatched by any other waste or recycling company in Australia.
6.	The method by which councils contract for waste services is entirely a matter for councils (subject to any required ACCC authorisations). In this context, WSN supports councils’ rights to tender in a way that suits them and understands that appropriate approvals from the ACCC have been obtained as required. All industry players are able to put forward their concerns at ACCC hearings and in written submissions.
7.	Landfill prices in Sydney are significantly higher than anywhere else in Australia and this, therefore, ought to encourage recycling over disposal more than elsewhere in the country.

We appreciate the opportunity to place our points on record.

Yours sincerely,

Ken Kanofski
Chief Executive Officer