Hobsons Bay City Council Submission Product Stewardship (Television and Computers) Regulations 2011 October 2011 Product Stewardship (Television and Computers) Regulations 2011 – exposure draft HOBSONS BAY CITY COUNCIL SUBMISSION October 2011 This submission discusses the Council’s key concerns with the exposure draft of the Product Stewardship (Televisions and Computers) Regulations 2011 (the Regulations). The Council has participated in consultation activities of the Department of Sustainability, Environmental, Water, Population and Communities (the Department), attending sessions on 17th April and 14th September 2011. The Council appreciates the opportunity to submit to the Department. The submission comprises a summary of key observations and issues, key facts about Hobsons Bay and its waste and litter profile relevant to television and computer recycling and conclusions. Key observations and issues Costs, amenity and environmental impacts of end of life televisions and computers are currently borne by the Council through inappropriate disposal and collection of this dumped waste or via hard waste collections. Other Council’s incur the cost through transfer station or landfill operations of which Hobsons Bay City Council does not operate. The National Televisions and Computer Recycling Scheme (the Scheme) and Product Stewardship (Televisions and Computers) Regulations 2011 (the Regulations) primarily focus on Industry responsibility to establish services and fully fund the Scheme. This is supported by the Council. The detail of the Scheme and Regulations are satisfactory and it is welcomed that the Industry is also supportive of the co regulatory product stewardship scheme. The introduction of a materials recovery target is also an improvement. However, the Scheme still lacks clearly defined roles and responsibilities of local government. The Department of Sustainability, Environmental, Water, Population and Communities (the Department) has provided advice that the local government participation is voluntary and that they may choose to partner with industry in the implementation of the Scheme. The Scheme or Regulations also lack detail on the mechanism for local government to fully cost recover those impacts experienced by local government through hard waste collections, transfer station and landfill operations where televisions and computers are collected or received for recycling or disposal. This is the case for councils who may or may not enter an agreement or contract with an Arrangement Administrator. Due to local government’s role in household waste management and the long history of some Council’s providing take back events or collection services for a variety of end of life products, it 1 Hobsons Bay City Council Submission Product Stewardship (Television and Computers) Regulations 2011 October 2011 is important that the Council seeks opportunity for involvement in the Scheme whether within an agreement with an Arrangement or otherwise. The Product Stewardship Australia (PSA)/ Australian Information Industry Association (AIIA) (PSA-AIIA), have developed interim industry standard for the collection, transport and recycling of end of life (EOL) televisions and computers (the Industry Standard). Industry Standards are likely to impose obligations on councils as potential collectors, stores and transporters of televisions and computers. The lack of clear local government roles and responsibility, the voluntary nature of local governments’ involvement and the PSA-AIIA’s intentions, are likely to mean Councils will need to enter agreements with Arrangement Administrators. Further concerns of the Council, yet to be fully assessed and a way forward established, centre around these possible agreements and contracts with Arrangement Administrators such as the PSA-AIIA’s and the effect of an Industry Standard on Council services. These include the following: Reporting requirements of councils to the Arrangement Administrator A fair, reasonable and easily accountable cost recovery model that enables councils to recover costs for hard waste collection services, drop off services at transfer stations and landfills, any infrastructure establishment or upgrading costs and include administration and transportation costs. Liability under the Regulations of councils that have entered an agreement or contract with an Arrangement Administrator. The Council seeks no liability under the Scheme or regulations. Being one of few Councils that do not operate a transfer station or landfill, and being “left out” of discussions with Arrangement Administrators whose priority is to establish Arrangements that centre around Councils that do have existing drop off infrastructure The Council has expressed interest in establishing a national network of drop off points to provide convenient TV and computer recycling services to the community. To date this has been by completing a survey of the Product Stewardship Australia and the Australian Information Industry Association. Interest was expressed through the highlighting of the Council’s depot as a possible drop off location for permanent or regular take back events. It is important that the industry consult and work the Council on proposed Scheme Arrangements and developing well informed comprehensive community engagement program that includes consistent messaging. The Council is working with other Councils with the intent of collaborating with the Metropolitan Waste Management Group (MWMG) to assist the establishment and delivery of a suggested local government approach. The aim is to establish coordinated ‘best practice’ approaches to the Scheme that: 2 Hobsons Bay City Council Submission Product Stewardship (Television and Computers) Regulations 2011 October 2011 establishes a reasonable spread of services across metropolitan Melbourne that are accessible to diverse communities including the disabled or frail establishes and manages the liability including reporting requirements, of a council either operating within or out of an agreement or contract with an Arrangement Administrator protects the interests and positive community perception of the Councils ensures safety of their contractors, staff and community contributes expertise to the development of community engagement and promotional programs seeks to fully recover costs incurred by local government including those incurred for collection and transport of televisions and computers and maintenance of upgrade of existing drop off facilities or the establishment of new drop off facilities advocates for broadening products recovered and recycled under the Scheme About Hobsons Bay and its waste and litter profile Hobsons Bay City Council (the Council) is situated 10 kilometres from the central business district (CBD) with a 22 kilometre bay frontage onto Port Phillip Bay, covering an area of 66 square kilometres. The forecast population in 2011 for the municipality is 87,050 residents. The Council provide a range of waste and litter services to the community of Hobsons Bay. Of relevance to the topic of the National Television and Computer Recycling Scheme are the Council’s kerbside hard waste collection services and municipal cleansing services. Hard Waste Collections service profile The Council’s at call hard waste collection service was introduced in August 2003, and is available on a weekly basis on a regular waste collection day from up to 10 metres from the front property boundary. Householders are able to have one collection per financial year. In June 2011, the Council introduced a contract whereby recycling of hard waste was required. Previously land filled, the Council now recycled approximately 33 per cent of wood, 21 per cent of metal, 14 per cent of metal and 592 mattresses are recycled. Last financial year (10/11) the Council collected 750 tonnes of hard waste. For June, July and August 2011 the Council collected 275 tonnes of hard waste. An average of approximately 68 per cent recycled is a pleasing result compared to the previous contract that only recycled mattress. Timber is mulched and shredded into woodchips and used in landscaping. Metal is shredded and reused in construction products such as mesh for concrete. Bricks and concrete are crushed used for road base or if undamaged used in landscaping. Mattresses have steel and timber removed and recycled. From 22nd July to 31st August 2011, the Council has been collected 300 items ewaste as part of the hard waste collection service. The actual number of each type of item is unavailable at this time but it is estimated that 100 televisions per month are collected. This is similar to experiences of other Councils. Metal from ewaste is recycled. 3 Hobsons Bay City Council Submission Product Stewardship (Television and Computers) Regulations 2011 October 2011 The Council’s budget for collection, recycling and disposal of hard waste is approximately $271,000 each year (2011/2012 budget) and is subject to fluctuate with tonnes collected and number of collections. Municipal cleansing services profile The Council provides street cleaning, litter bin collections, loose litter and dumped waste removal, beach cleaning and seaweed removal and clearing of stormwater traps. Televisions and computers are often collected as dumped waste and are land filled. Approximately 520 televisions and computers are collected each year. The Council’s budget for collection and disposal of litter including dumped waste is approximately $558,000 each year (2011/2012 budget) and is subject to fluctuation with tonnes collected. Conclusion The Council appreciates the opportunity to submit to the Australian Government its feedback on the Regulations. This submission has discussed key observations and issues of the Council, key facts about Hobsons Bay and its waste and litter profile relevant to television and computer recycling and conclusions and the Councils aim to work with other councils and the Metropolitan Waste Management Group to establish coordinated ‘best practice’ local government approaches to the Scheme. Primarily the Council is supportive of the Scheme and Regulations that provides for Industry responsibility to establish services and fully fund the Scheme. 4