ATTACHMENT C
CONSULTATION PROCESS AND ADDITIONAL FEEDBACK
1
DEVELOPMENT OF THE CONSULTATION RIS
Engagement with key stakeholders began directly following the July 2010 decision by environment
ministers to develop a Consultation RIS. In August 2010, the Australian Packaging Covenant Council
(APCC) was informed of the RIS development process and has received regular updates at meetings
held quarterly.
Initial one-on-one consultation sessions took place between September and November 2010 with the
Australian Council of Recycling, Boomerang Alliance, Coca-Cola Amatil, Fosters Group, Keep Australia
Beautiful, Lion Nathan Limited, Visy and Westfield Group. There were differing views on whether the
RIS should only consider beverage containers or whether, consistent with the EPHC position, it should
consider a broader packaging scope. This reflected strong views for and against CDS and the RIS
process being seen as a means to determine the costs and benefits of implementing a national CDS. In
November 2010, environment ministers noted that they were pleased that a number of stakeholders
had been engaged in preliminary discussions on the potential scope of the RIS. Ministers also agreed
that “consistent with Ministers’ July 2010 decision, the focus of the RIS should not be solely on
beverage containers but more broadly about litter reduction and resource recovery” (EPHC 2010c).
A stakeholder workshop in Sydney on 2 December 2010 ensured broad input at an early stage, with
around 50 representatives from industry, government and environment groups attending. The
workshop sought further data on packaging waste and its impacts, and input on related market
failures to inform the draft problem statement. A key finding was that there is limited data on
packaging waste in Australia and the sources of packaging related market failures are not all identified,
although knowledge of environmental impacts and feasible options to address those impacts is sound.
Little additional data was received.
Some stakeholders provided further written feedback: the Australian Packaging Covenant, Local
Government and Shires Association of New South Wales, National Association of Retail Grocers of
Australia, National Packaging Covenant Industry Association, Revive Recycling and Total Environment
Centre (also a member of Boomerang Alliance).
A second stakeholder workshop in Melbourne on 18 July 2011, with around 40 representatives from
industry, government and environment groups, refined and scoped the regulatory options for
consideration. Stakeholders were invited to submit detailed proposals of options for inclusion in the
RIS. The Boomerang Alliance, in their development of option 4a (Boomerang Alliance Container
Deposit Model), and the Packaging Stewardship Forum (in partnership with Keep Australia Beautiful) in
their development of option 2b (Industry Packaging Stewardship), worked closely with officials and the
consultants. Further consultation also took place with the Australian Packaging Covenant, Clean Up
Australia (also a member of Boomerang Alliance), the Local Government and Shires Association of New
South Wales and the National Packaging Covenant Industry Association.
FORMAL STAKEHOLDER CONSULTATION PERIOD
The Consultation RIS was released on the SCEW website on 7 December 2011 for a four month period.
Eleven public consultation sessions were held in capital cities and three regional centres during
February and March 2012. In total around 250 people attended the sessions. Each session consisted of
a two hour public forum, including a presentation on the economic analysis, followed by 30 minute
bilateral meetings with interested stakeholders.
The closing date for stakeholder submissions was 30 March 2012. A total of 197 substantive
submissions were received, including eight confidential submissions and four late submissions.
Submissions were received from a diverse range of stakeholders (see Figure 1). A list of stakeholders
who provided non-confidential submissions and a Consultation Summary Report is available on the
SCEW website (see Attachment J)1. The majority of substantive submissions (94 per cent) did not
discuss the details of specific options in the Consultation RIS, instead stating overall positions and
preferences (Attachment J, p. 4). In addition, around 3,000 campaign submissions were received,
which comprised a pro forma email generated online and expressed support for a national CDS.
FIGURE 1: COMPOSITION OF SUBSTANTIVE SUBMISSIONS BY STAKEHOLDER TYPE
Packaging
industry, 6
Other Industry,
9
Waste &
recycling
industry, 5
Local
Government,
35
Food, beverage
& retail
industry, 10
Individuals, 119
State
Government
, 2 NGOs,
10
Gov/industry
rep body, 1

Source: Consultation RIS Consultation Summary Report, Attachment J.
2
DECISION RIS CONSULT ATION
On 24 August 2012, environment ministers agreed to develop a Decision RIS to undertake a more
detailed analysis of the options, including regional and other distributional impacts. Stakeholder
feedback on the Consultation RIS also led to environment ministers agreeing to the inclusion of three
new options in the Decision RIS:
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1
Option 2d: Beverage Container Stewardship—reflecting interest in a non-CDL approach to
beverage sector product stewardship
Option 2e: Extended Australian Packaging Covenant—reflecting strong industry support for the
current APC co-regulatory model
Option 4c: South Australian Container Refund Model—reflecting strong support for the SA
model of CDS.
See: http://www.scew.gov.au/consultation/packaging-impacts-consultation-regulation-impact-statement-ris.
Environment ministers stressed the importance of senior officials consulting with key stakeholders on
the design elements of new options and modelling assumptions (SCEW 2012b, p. 1). Two stages of
consultation were subsequently conducted during development of the Decision RIS.
STAGE 1
Meetings with key stakeholders in November and December 2012 refined and confirmed design
details of the stakeholder options (2b—Industry Packaging Stewardship and 4a—Boomerang Alliance
CDS) and informed the development of new options (2d, 2e and 4c). Stakeholders consulted during
Stage 1 were:
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Australian Beverages Council
Australian Food and Grocery Council
Australian Local Government Association
Australian National Retailers Association
Boomerang Alliance
Keep Australia Beautiful
National Packaging Covenant Industry Association
Packaging Council of Australia
Packaging Stewardship Forum.
Additional written feedback was received from the Australian Food and Grocery Council/Packaging
Stewardship Forum, Boomerang Alliance, Keep Australia Beautiful, and the National Packaging
Covenant Industry Association.
STAGE 2
A stakeholder workshop on 14 March 2013 in Sydney discussed distributional impacts and key
modelling assumptions for all Decision RIS options and the base case. In total, 40 stakeholders
attended the workshop and a broad range of stakeholder groups were represented (see Figure 2).
FIGURE 2: COMPOSITION OF STAKEHOLDER ATTENDANCE AT DECISION RIS WORKSHOP
Local
Other Industry,
Retail, 2
Waste &
Recycling
Industry
State
Government,
Food and
Beverage
Packaging
NGOs
Consultan
Source: Decision RIS workshop attendance records.
Marsden Jacob Associates (MJA) (working with Warnken ISE) provided an overview of the proposed
modelling approach for the CBA and received stakeholder feedback on key assumptions.
Additional submissions from the Boomerang Alliance, National Packaging Covenant Industry
Association, Vinyl Council of Australia, Western Australian Local Government Association and two
confidential submissions were passed to MJA for use in finalising the assumptions for the CBA.
3
ADDITIONAL DECISION RIS FEEDBACK
Some submissions identified the need to issues in the current kerbside system, through investment in
updated sorting and processing technology to improve recycling rates and glass recovery from comingled recyclables. While the Decision RIS recognises that improvements can be made in both
municipal and commercial/public place settings, the strong public place consumption driver of litter
and identified barriers to recycling in the C&I sector in particular indicate the impacts are greatest in
the away-from-home sector.
A submission from the tobacco industry noted the importance of nationally consistent anti-littering
enforcement to underpin education and infrastructure efforts. The options modelled in the DRIS do
not include specific national anti-littering regulations, however under all the options it is expected that
a national approach to litter reduction would be strengthened.
CONTAINER DEPOSIT SCHEMES
A number of individuals who favoured CDS indicated that packaging producers and brand owners,
rather than consumers, should bear the costs of such a scheme.
Submissions from local government were mixed in relation to CDS. One third of state/local
government submissions (including local government representative organisations) supported at least
one of the CDS options (SCEW 2012a, p. 10), albeit with many noting that the costs of a CDS should be
borne by the packaging industry rather than ratepayers. The Local Government Association of
Queensland submission put a contrary view, based on a detailed CBA of the potential impacts of CDS
on Queensland councils, which would bear higher costs than estimated in the Consultation RIS (LGAQ
2012). Local government attendees at the Albury and Darwin public forums also expressed concerns
about the potential negative impacts of a CDS on councils in relation to existing waste services
contracts.
The majority of industry submissions did not support CDS options, considering them expensive and
leading to increased regulatory burden on the beverage industry. Submissions also suggested that the
costs associated with a CDS would result in higher consumer costs, which would ultimately impact
employment in the beverage and grocery supply chain. As mentioned in Chapter 5, the Decision RIS
modelling has accounted for the cost impacts of CDS options raised by stakeholders, based on
observable evidence, but has not analysed claims of net job creation or loss under the options.
One waste and recycling industry submission commented that CDS options would require new
infrastructure that competes with existing kerbside and MRF infrastructure and stated a preference for
policies that promote investment in new infrastructure which builds upon existing assets.
A submission from the NT Government supported CDS and said that costs would be lower for CDS
options if they were modelled on the industry-based models applied in SA and the NT. However, a
confidential submission noted that the introduction of the NT CDS has resulted in fewer recycling
materials being collected from some remote communities due to existing free back loading
arrangements being replaced with commercial arrangements.
A submission from the SA Government identified benefits of its CDS, including high beverage container
recycling, reduced beverage container litter, co-benefits of increased recycling of other products and
providing income to disadvantaged people and community groups. It noted that it is unlikely that the
other options presented in the Consultation RIS could match the beverage container recycling rate
that can be achieved with a CDS. This assumption was accepted based on evidence of SA scheme
performance, albeit with the associated assumption that other options achieve recycling outcomes
across a broader range of packaging materials. One confidential submission from the recycling industry
described the SA CDS as unnecessarily complex and said there are high costs associated with the
scheme as a result.