Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
November 2012
Beer cans in the Katherine River
Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
1. ABOUT THIS CONSULTATION REGULATION IMPACT STATEMENT
The Northern Territory Government has prepared the Northern Territory Container Deposit
Scheme Mutual Recognition Act Consultation Regulation Impact Statement (CDS MRA RIS)
in order to seek comment from stakeholders and the wider public on a proposal to exempt
the Northern Territory Environment Protection (Beverage Containers and Plastic Bags) Act
2011 from the Mutual Recognition Act 1992 (Cth) and the Trans-Tasman Mutual Recognition
Act 1997 (Cth).
The CDS MRA RIS follows the Council of Australian Governments’ guidelines in the Best
Practice Regulation Handbook and seeks to identify the nature of the problem to be solved,
identify alternative policy options and assess the costs and benefits of these options. It has
been approved for release by the Commonwealth Office of Best Practice Regulation and
provides a valuable means through which government and other stakeholders can consider
policy and regulatory options in a focused way. Stakeholder feedback will inform the content
of a subsequent Decision RIS.
The CDS MRA RIS canvasses both regulatory and non-regulatory approaches, and includes
a status quo or ‘no change’ option (recognising that not all problems have a cost-effective
solution through government action).
OPPORTUNITIES TO COMMENT ON THE CDS MRA RIS
The CDS MRA RIS is subject to a four-week consultation period, and the Northern Territory
Government welcomes feedback on the proposed options for implementation and any other
aspect of the document. The closing date for submissions to the CDS MRA RIS is COB
November
Monday 3 December 2012. If confidentiality is required, please clearly
indicate 2012
this,
otherwise all submissions will be made publicly available.
Email submissions to:
cdsmutualrecognitionris@nt.gov.au
Post submissions to:
CDS Mutual Recognition RIS
Dept Lands, Planning and the Environment
GPO Box 2130
Alice Springs, NT 0871
For further information, please contact the Senior Environmental Officer on (08) 8951 9265.
Additional copies of the CDS MRA RIS can be downloaded at:
www.cashforcontainers.nt.gov.au
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
2. TABLE OF CONTENTS
1.
STATEMENT OF THE PROBLEM ...................................................................................................... 1
1.1.
LITTER AND LITTERING TRENDS IN THE NORTHERN TERRITORY ........................................................ 1
1.2.
THE NORTHERN TERRITORY’S RECYCLING INFRASTRUCTURE ........................................................... 8
1.3.
TRENDS AND BEHAVIOUR CHANGE ..................................................................................................... 8
1.4.
NORTHERN TERRITORY CONTAINER DEPOSIT SCHEME ..................................................................... 9
1.5.
MUTUAL RECOGNITION PRINCIPLES AND THE ENVIRONMENT PROTECTION (BEVERAGE
CONTAINERS AND PLASTIC BAGS) ACT 2011 ................................................................................................ 12
2.
OBJECTIVES OF GOVERNMENT ACTION .................................................................................... 14
3.
OPTIONS TO ADDRESS THE PROBLEM ...................................................................................... 14
4.
3.1.
OPTION ONE – EXPIRATION OF THE TEMPORARY MRA AND TTMRA EXEMPTIONS....................... 14
3.2.
OPTION TWO – NATIONAL PACKAGING RECOVERY SCHEME ........................................................... 15
3.3.
OPTION THREE – PERMANENT EXEMPTION IS GRANTED ................................................................... 15
3.4.
OPTION FOUR – OTHER LESS TRADE-RESTRICTIVE APPROACHES IN THE NORTHERN TERRITORY. 15
IMPACT ANALYSIS ........................................................................................................................... 15
4.1.
4.1.1.
Key Results ............................................................................................................................. 19
4.1.2.
Costs ......................................................................................................................................... 19
4.1.3.
Market and Non-Market Benefits ....................................................................................... 22
4.2.
5.
COST BENEFIT ANALYSIS................................................................................................................... 18
November 2012
INDIVIDUAL OPTION ANALYSES .......................................................................................................... 24
4.2.1.
Option One – Expiration of the Temporary MRA and TTMRA Exemptions ............ 24
4.2.2.
Option Two – National Packaging Recovery Scheme .................................................. 29
4.2.3.
Option Three – Permanent exemption is granted ......................................................... 32
4.2.4.
Option Four – Other less trade-restrictive approaches in the Northern Territory 46
REFERENCES .................................................................................................................................... 51
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
3. STATEMENT OF THE PROBLEM
3.1. Litter and Littering Trends in the Northern Territory
The Northern Territory (NT) faces a significant litter problem. Keep Australia
Beautiful National Litter Index figures for 2009/10 show an average of 70 items per
1000m2, a figure above the national average of 66 items (see Figure 1-1)1.
Items per 1,000m2
05/06
Volume (litres) per 1,000m2
06/07
07/08
08/09
09/10
05/06
06/07
07/08
08/09 09/10
NATIONAL 70
74
68
63
66
8.86
9.68
8.59
7.73
7.55
ACT
-
68
56
56
51
-
7.04
6.06
4.77
3.31
NSW
80
71
77
65
75
14.95
14.69
11.90
12.13 13.43
NT
-
64
60
84
70
-
5.32
7.24
6.00
5.09
QLD
89
86
76
59
76
7.66
7.59
7.44
5.60
5.65
SA
60
61
68
57
54
7.23
11.08
9.55
8.02
7.13
TAS
59
70
61
64
86
5.15
6.68
5.90
9.20
9.04
VIC
71
80
48
43
50
7.87
7.74
4.19
WA
60
83
85
87
71
8.57
12.19
13.06
2.87 4.91
November
2012
11.93 9.44
Figure 1-1: State by State assessment of litter by items and volume per 1000m 2 05/06 – 09/10
A significant proportion of this litter is beverage containers, with 5 of the 12 ‘dirty
dozen’ being container deposit scheme (CDS) related beverage containers (see
figure 1.2)2. In 2007/08 the NT’s total litter count across 76 assessed sites was 934
CDS items (i.e. containers in litter stream that are covered under the NT CDS)
counted; the second highest rate in Australia. In 2008/09, the item count dropped to
631 but increased in 2009/10 to 706 (see Figure 1-3).
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Dirty Dozen - Volume per 1000 Square Metres - Object Sub-Categories NT - 06/07 to 09/10
1.11
1.04
PLASTIC - Other
0.54
PAPER/ PAPERBOARD - Food
container or utensil
0.28
1.33
0.53
0.55
0.43
0.52
1.45
ILLEGAL DUMPING - Total
0.93
GLASS - Alcoholic beverage
container
0.33
0.33
0.34
0.47
0.41
PLASTIC - Non-alcoholic
beverage container
0.58
0.62
0.57
0.35
0.44
METAL - Alcoholic beverage
container
1.96
0.73
0.77
0.28
0.19
0.31
0.34
PAPER/ PAPERBOARD Publication
0.20
0.20
PAPER/ PAPERBOARD - Nonalcoholic beverage container
0.33
0.33
0.19
0.19
0.23
0.13
MISCELLANEOUS - Total
METAL - Non-alcoholic
beverage container
0.19
0.12
PLASTIC - Food container or
utensil
0.17
0.13
0.15
0.19
METAL - Food container or
utensil
0.14
0.16
0.17
0.10
0.0
November 2012
0.5
1.0
1.5
2.0
2.5
Litres
2006/07
2007/08
2008/09
2009/10
Figure 1-2: The Dirty Dozen Volume per 1000 square metres. Object sub-categories
NT 2006/07 to 2009/10
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
November 2012
Figure 1-3: CDS Litter Items by Jurisdiction 2007/08 to 2009/103
The figure of 706 items counted in 2009/10 represented more than 10% of the total
littered CDS items counted across Australia. This is high, considering the NT
represents just 1% of the country’s population. Queensland’s littered CDS items also
represented 10% of the total national littered CDS count, yet Queensland represents
20% of Australia’s population. In contrast South Australia’s population represents
7.4% of the total population, yet its CDS litter items were just 4% of the total littered
CDS items counted across Australia4 (see Figure 1-4).
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Population v CDL litter items
35
30
%
25
20
15
10
5
0
SA
ACT
NT
QLD
VIC
State
TAS NSW
WA
% of CDL litter Items
% of population
Figure 1-4: State by State assessment of CDS litter vs population 2009/10
The NT’s volume of CDS material (see Figure 1-5) increased from 368 litres in
2008/09 to 399 litres in 2009/10. The average volume of litter indicates that the NT
also represents 10% of the total national volume of CDS litter, from 1% of the
national population (see Figure 1.1).
November 2012
Figure 1-5: CDS Litter Volume by Jurisdiction 2008/09 and 2009/105
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
The high incidence of outdoor beverage consumption in the NT is one likely cause of
this exceptionally high CDS item littering rate. Low population density and
geographic isolation of many communities exacerbates the problem of litter
reclamation and makes effective enforcement of existing regulations problematic.
Quantifying the proportion of different types of litter in the overall litter stream is
made difficult by the multidimensional nature of litter. This is no less the case when it
comes to representing beverage containers as a proportion of the total NT litter
stream. Very different estimates can be made using either mass, volume or
individual items per 1000m2. An estimate based on mass suggests beverage
containers represent, at the very least, around 55% of the NT litter stream by
weight6. Alternatively, an estimate based on volume per 1000m2 suggests a
proportion of around 33.9%7. Alternatively, in terms of number of items littered per
1000m2, beverage container litter can be estimated to be as little as 13% of NT litter
due to the inclusion of items such as cigarette butts. Using the same item-based
data but excluding cigarette butts, beverage containers may comprise approximately
25% of all items littered in the NT8.
Impacts of Litter
Litter negatively impacts visual amenity, soil and water quality and levels of wildlife
injury and death (e.g. glass injury and plastics consumption). Litter that is not
recovered and not recycled represents a loss of finite resources.
November 2012
At what point a given quantity of litter brings about a loss of amenity is a subjective
issue. Research suggests the particulars of a given littering event and the type of
litter encountered are important. For example, the report Community Preferences for
Litter Reduction9 noted ‘There are many reasons that litter suddenly intrudes into
conscious thought. It is about a quantum change that suddenly offends. However
this quantum change in the presence of litter is not simply about more volume of litter
per square metre’.
While litter undermines amenity, visual amenity lost to litter may be regained by a
significant quantitative or qualitative reduction in litter rather than a total eradication
of litter. The report Community Preferences for Litter Reduction notes that single
quantitative measures of litter alone (such as weight, or volume/items per 1000m2)
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
are unlikely to capture how individuals attribute significance to litter. For example
glass may elicit a greater response than paper because of the danger it poses to
children and animals when broken. Similarly, litter is particularly disturbing to people
when seen in places that are perceived as natural and environmentally intact. Litter
that is clearly resource heavy and has good potential for recycling also elicits a
stronger negative reaction. The report Community Preferences for Litter Reduction10
notes ‘The most common type of litter noticed by people is food packaging,
especially empty cans and bottles, and food wrappers’.
Beverage containers do not represent the entire NT litter stream. However they
represent a very significant part of it and their particular characteristics make them
exceptionally detrimental to visual amenity.
Visual amenity is particularly significant to the tourism sector. Among Australian
jurisdictions the extent of the NT’s pristine wilderness and ecological diversity is
exceptional. In addition, most tourism in the NT is heavily oriented towards
environmentally based experiences. Indeed, the NT markets its tourism around the
theme of pristine wilderness. Given that visual amenity is an important part of the NT
tourism industry, unsightly litter has significant, negative economic implications.
While littering within the many recreational parks in the NT is low relative to other site
types, it is high on the ‘gateways’ to this site type, such as highways, car parks and
beaches (see Figure 1-6). One would expect the recreational sites themselves to be
less littered, as tourists accessing them (local and extra-NT) would litter
less given2012
November
the reason for visiting is usually appreciation of their wild character.
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Volume per 1000 Square Metres by Site Type - NT
25
CAR PARK
20
Litres
15
10
BEACH
HIGHWAY
OVERALL
RETAIL
5
RESIDENTIAL
INDUSTRIAL
0
NOV.06
SHOPPING CENTRE
RECREATIONAL PARK
MAY.07
NOV.07
MAY.08
Figure 1-6: NT Volume per 1000 sq m by Site Type.
Although there is no current data for the NT regarding links between reduced litter
and impacts on tourism, it is reasonable to expect that the high rate of beverage
container littering in the NT combined with the environmental focus of most NT
tourism will have a significant negative economic impact. There is a common sense
link between environmental degradation and customer dissatisfaction in the tourism
sector. As fact sheets released by Sustainability Victoria note: ‘litter looks bad…litter
negatively affects the image of places, especially tourist locations’11 Other reports
note that ‘Litter makes people feel disappointed in others, disgusted,November
angry and 2012
cautious.’12
In 2008-9 the total gross value of NT Tourism was estimated to be approximately
$1,400 million13.
‘Injury and fatality to vertebrate marine life caused by ingestion of, or entanglement
in, harmful marine debris’ has been listed as a key threatening process under the
Australian Government's Environment Protection and Biodiversity Conservation Act
1999. NT waters contain many of the twenty marine species listed as endangered or
vulnerable in Australia due to the adverse impacts of marine debris, including
beverage containers. In this regard, the high relative rate of littering at NT beaches is
a matter of particular concern (see Figure 1-6).
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Low population density and geographic isolation of many communities also makes
the cost of recovering NT litter high relative to other jurisdictions. Litter is rarely
recovered on remote communities, especially on community outskirts and along
access roads.
Due to remoteness a greater number of landfill sites of smaller size are required in
the NT which leads to inflated land fill costs associated with reduced economies of
scale.
3.2. The Northern Territory’s Recycling Infrastructure
Kerbside and drop-off recycling services are currently available to approximately
46% of the NT’s population, being residents living in Darwin and Palmerston14. The
recycling participation attributed to these dwellings is 75%. It is estimated that only
23% of the total NT’s at-home consumption of beverage containers is recovered for
recycling in the current kerbside and drop-off recycling services offered in Darwin
and Palmerston, while the estimated Australian overall beverage recovery rate of at
home consumption of beverage containers is 62%15.
Low population density and geographic isolation of many communities curtails the
maturing and extension of existing resource recovery infrastructure. Any scheme
aiming to address litter and resource recovery in the NT needs also to consider
positive outcomes for the development of waste management infrastructure.
3.3. Trends and Behaviour Change
November 2012
Surveys show that between 2007/8 and 2009/10 there was a minor downturn in the
number of CDS items littered in the NT. However, between 2008/9 and 2009/10
there has been an increased volume of CDS litter (see Figures 1-2 and 1-3). At the
same time, although there is no emergent upward trend in the numbers of items
located at all site types within the NT, there appear to be an increase in the overall
volume of litter items across site types (see Figure 1-4). It can be concluded that
past regulations did not bring about significant behaviour change in regard to littering
in the NT.
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
3.4. Northern Territory Container Deposit Scheme
In light of the above considerations, the Northern Territory Government (NTG)
investigated the potential for an NT Container Deposit Scheme (CDS).
Under a CDS, a deposit is added to the sale price of a beverage sold in a container.
The deposit is refunded to the consumer after the product has been used and when
the container returned to an approved collection depot. Collection depots then return
the collected containers to relevant CDS Coordinators who then pay the depots the
10c redemption plus a handling fee per container.
In the development of an NT CDS, the key objectives were to minimise
environmental pollution by reducing litter and increasing resource recovery.
Assessments undertaken prior to the scheme’s commencement highlighted that a
CDS in the NT would need to have the following characteristics:

ability to provide reasonable access to communities across the NT, including
as far as is practicable, remote communities;

opportunities for business development, especially recycling and
environmental business in the NT;

responsiveness to community and industry needs, including minimising costs
and maximising benefits to the community and industry; and

November 2012
ability to ensure that waste management arrangements are in place and in
accordance with the principles of waste management including waste
avoidance, reuse, recycling and, where necessary waste disposal.
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
The CDS component of the Environment Protection (Beverage Container and Plastic
Bags) Act 2011 (NT) (the EP(BC&PB) Act) commenced on 3 January 2012. The
Environment Protection (Beverage Containers and Plastic Bags) Regulations 2012
(NT) were also introduced in 2012. The key objectives of the EP(BC&PB) Act
relating to beverage containers are to minimise environmental pollution by
establishing a CDS to:

reduce beverage container litter; and

increase resource recovery, reuse and recycling.
The EP(BC&PB) Act, supported by the Regulations, requires beverage
manufacturers to implement product stewardship by:

developing a contractual relationship with a CDS materials coordinator;

specifying labelling to identify deposit redemption in the NT; and

registering their beverages.
Of the 31,596,443 approved containers sold into the NT during the first quarter
(January to March 2012 a total of 7,952,502 containers were redeemed (returned to
collection depots for a 10 cent deposit).16 These consisted of:

November 2012
3,945,851 aluminium cans amounting to approximately 50 tonnes;

1,247,311 polyethylene terephthalate (PET) containers;

2,448,168 glass containers were redeemed amounting to over 450 tonnes of
glass;

100,535 high density polyethylene (HDPE) containers;

185,963 liquid paper board containers; and

24,674 other containers, including liquid paper board (LPB), aseptic, plastic
and steel containers.
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
This represented:

21.9% return rate across all containers/material types;

25.17% redemption rate across all containers/material types; and

approximately $800,000 paid out in deposits.
While the scheme is in its infancy, monthly figures from four collection depots
operating across the first four months of 2012 suggest an exponential expansion in
the rate of participation in the scheme (see Figure 1-5). This rapid growth in
participation indicates significant behaviour change in the NT in regard to personal
responsibility for used beverage containers.
To be redeemable under the NT CDS beverage containers have to have been
bought after commencement of the scheme, that is, on or after 3 January 2012.
Beverage containers must have unobscured labels attached in order that the
purchase date can be verified. This requirement provides confirmation the figures
provided for the first quarter of the scheme’s operation are not skewed by beverage
containers stockpiled prior to the scheme’s commencement.
November 2012
www.nt.gov.au
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Figure 1-6: NT CDS: Monthly Returns, First 4 Months of Scheme Operation from Four Prominent
Collection Depots.
The introduction of a CDS is undoubtedly having an impact on existing kerbside
recycling in Darwin and Palmerston. However, while a significant proportion of
beverage containers will naturally be directed away from kerbside recycling, not all
will be. While operators’ collection costs will be reduced, they will receive a
substantial benefit from the redemption of those beverage containers still collected at
the kerbside. It is anticipated that the two systems will successfully operate in
tandem.
3.5. Mutual Recognition Principles and the Environment Protection (Beverage
Containers and Plastic Bags) Act 2011
The Mutual Recognition Act 1992 (Cth) and the Trans-Tasman Mutual Recognition
Act 1997 (Cth) (MRA and TTMRA respectively) apply as laws of the NT by virtue of
the Mutual Recognition (Northern Territory) Act (NT) and the Trans-Tasman Mutual
Recognition Act 1998 (NT) respectively.
In relation to goods, the MRA and TTMRA apply the ‘mutual recognition principle’.
The mutual recognition principle, as explained at section 9 of the MRA, provides that
goods produced in or imported into the first State, that may be lawfully sold in that
State, may, by virtue of the MRA, be sold in the second State. The Trans-Tasman
mutual recognition principle as explained at section 10 of the TTMRA is that goods
2012
produced in or imported into New Zealand, that may be lawfully soldNovember
in New Zealand,
may by virtue of the TTMRA be lawfully sold in an Australian jurisdiction.
These acts also provide that sales of goods to which the principle applies do not
require compliance with further requirements of a type set out in the Acts that might
otherwise be required under the laws of the importing jurisdiction. These include
quality or performance standards, inspection requirements or, most relevant to the
NT CDS, labelling standards.
The NT CDS component of the EP(BC&PB) Act requires all beverages sold in the
NT to carry a label alerting the purchaser to the availability of 10c redemption in the
NT if bought there. This provision was designed to conform to the statutory
exemptions available under the mutual recognition legislation and it is considered
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
that the CDS is not constrained by either the MRA or TTMRA. Nevertheless, to put
the matter beyond doubt and to provide certainty for business and consumers, the
NT is taking the necessary steps to secure permanent exemption of the CDS from
the operation of the MRA and TTMRA.
The Mutual Recognition and Trans-Tasman Mutual Recognition Schemes make
provision for specific goods or laws to be permanently exempted from their scope by
their inclusion in schedules to the MRA or TTMRA. However, the process for adding
permanent exemptions is lengthy, requiring the support of the relevant Ministerial
Council to seek unanimous agreement of Heads of Government (COAG) to the
exemption, the making of regulations by the Commonwealth to amend the relevant
Schedules to the MRA/TTMRA and the prior signification of consent to the
amendments by all jurisdictions by Gazette notice (in some jurisdictions, i.e. Qld, an
Act of Parliament may also be required).
Because the permanent exemption process is lengthy, the mutual recognition
schemes also allow individual jurisdictions to unilaterally invoke temporary
exemptions from application of the mutual recognition principle. Temporary
exemptions have a limited life of twelve months (including in aggregate) and cannot
be extended. Their purpose is to enable an exemption to be immediately applied
while the process for gaining a permanent exemption is pursued.
Regulations have been enacted in the NT to temporarily exempt the EP(BC&PB) Act
to the extent that it relates to regulated containers from the mutual recognition
November 2012
principle as applied to goods under the MRA and TTMRA. The Regulations include
sunset provisions for their expiry twelve months after commencement. The
temporary exemption for beverage containers expires on 3 January 2013.
The EP(BC&PB) Act makes provision for beverage companies to transition to a
CDS: beverage manufacturers and importers have been given a two year period
over which to make the required changes to their labels. The reason for this is to
minimise the inconvenience and cost incurred by those companies in doing so.
Giving these companies two years to make the minor alteration to labelling required
(‘alteration’ because similar labelling is already required by the South Australian
CDS) means they will be able to synchronise it with other unrelated labelling
alterations they themselves require as a matter of course.
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Since the introduction of the CDS many beverage companies, but not all, have made
label changes. It is not clear as to whether or not a lack of across-the-board
compliance to date has impaired the growth of the scheme. It may be that start-up
promotions of the scheme by the NTG have made up for a shortfall in labels during
this transition period.
There are no further transitional provisions relating to the scheme more broadly.
This Consultation RIS supports the application for permanent exemption of the
EP(BC&PB) Act from the mutual recognition legislation.
4. OBJECTIVES OF GOVERNMENT ACTION
The key objectives of government action are to:
 reduce litter;
 efficiently reduce the negative amenity and environmental impacts of litter in
line with community expectations;
 increase resource recovery and facilitate waste management infrastructure
development; and
 facilitate greater corporate responsibility for the full life-cycle of beverage
containers.
5. OPTIONS TO ADDRESS THE PROBLEM
November 2012
As part of the RIS process, it is necessary to describe and consider different options
that can be implemented to achieve the government’s stated objectives. Below are
four options for achieving the stated objectives. The detailed analysis of each of
these options is provided in Section 4.2.
5.1. Option One – Expiration of the Temporary MRA and TTMRA Exemptions
In the event that the temporary exemptions to the MRA and TTMRA expire, it is
expected that the CDS will continue to operate as it currently does in accordance
with the provisions of the EP(BC&PB) Act. In this case the outcome would be that of
Option 3 below. However, some stakeholders have stated that they believe some
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
sections of the EP(BC&PB) Act are open to legal challenge. A successful legal
challenge could render the NT CDS less effective or ineffective in achieving its
objectives.
5.2. Option Two – National Packaging Recovery Scheme
This option links directly to the current national process investigating options for
regulating the impacts of packaging, including an option of a national container
deposit scheme being carried out by the COAG Standing Council on Environment
and Water (SCEW). This process is set out in the Packaging Impacts Consultation
Regulation Impact Statement (CRIS)17. A Packaging Impacts Decision Regulation
Impact Statement (DRIS) is pending on this. Analysis of a National Packaging
Recovery Scheme option is limited as the Packaging Impacts Decision RIS is still
being prepared.
5.3. Option Three – Permanent exemption is granted
Granting of a permanent exemption from the MRA and the TTMRA will result in the
EP(BC&PB) Act continuing to achieve its objectives.
5.4. Option Four – Other less trade-restrictive approaches in the Northern
Territory
A number of other options for addressing litter reduction and increasing recycling in
an NT context are discussed.
November 2012
6. IMPACT ANALYSIS
The purpose of impact analysis in a Consultation RIS is to present indicative
information for public consultation relating to:

the estimated net economic impacts of the regulatory and non-regulatory
options being considered by governments;

the impacts on different groups within the community that are likely to be
affected by the options;

the risks associated with each option; and
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Northern Territory Container Deposit Scheme
Mutual Recognition Act

Consultation Regulation Impact Statement
any effects they may have on competition.
Groups within the community expected to be affected to varying degrees include:

households/consumers (in all jurisdictions including the NT and New
Zealand);

businesses (in all jurisdictions including the NT and New Zealand) including:
-
beverage manufacturers;
-
beverage importers and exporters;
-
retailers;
-
the waste management industry, including existing CDS collection depots;

the NT Government and NT local government;

the Australian tourism sector; and

the NT, NZ and Australian broader community generally.
This section provides an analysis of the effectiveness and efficiency of each option in
achieving the NT’s environmental objectives. The analysis involves approximate
estimates of costs and benefits based on assumptions. The assumptions around
household and business participation costs and benefits in particular contain some
November 2012
uncertainty.
In many instances, where indicated, estimates are based on those presented in the
SCEW’s 2011 Packaging Impacts Consultation Regulation Impact Statement
(Packaging Impacts CRIS).18 The results presented in that document are generally
expressed in present values, meaning costs and benefits across a 25-year
assessment period (2011 to 2035) were converted to 2011 dollars using the
standard discount rate of 7%. Sensitivity testing was also undertaken to test the
impacts of changing key assumptions and inputs to the analysis.
In order to undertake a cost-benefit analysis on the options, the Packaging Impacts
CRIS estimated the projected packaging recycling and litter reduction performance
for its base case and each option. As described in detail in the Packaging Impacts
www.nt.gov.au
16
Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
CRIS’s Attachment C: Cost Benefit Analysis (Attachment A to this Consultation RIS),
these projections were developed based on past recycling and litter trends and a
professional assessment of the likely impacts of the initiatives identified for each
option.
The packaging consumption projections presented in the Packaging Impacts CRIS
were based on population projections and historical packaging consumption growth
rates. Between 2003 and 2010 packaging consumption in Australia increased at
51% of the rate of population growth. For this analysis the ratio of packaging
consumption growth to population growth was assumed to be 51% from 2011 to
2015, 50 per cent from 2016 to 2020 and 49% from 2021 to 2035. The ratio
decreases marginally over time due to increased lightweighting of packaging.
Recycling projections presented in the Packaging Impacts CRIS were developed by
Wright Corporate Strategy (WCS) by consumption location (at-home versus awayfrom-home) and for each product type (beverage containers, non-beverage
packaging) based on:

a range of identified initiatives (including the time period over which each
initiative was assumed to operate);

packaging industry plans and targets;

experience in other jurisdictions; and

assumptions about the maximum achievable recycling rate by product or
November 2012
material.
Due to the lack of data on actual litter quantities at a national level, litter projections
presented in the Packaging Impacts CRIS were developed based on an estimate of
the proportion of packaging that could be available to be littered (that is, packaging
that is currently not recycled and is consumed in an away-from-home setting). This
was estimated to be around 1 million tonnes in 2010. Total litter per annum was
estimated to be between 40,000 to 160,000 tonnes, which is between 4% and 16%
of total packaging that is available to be littered (details of how this range was
calculated was set out in the Packaging Impacts CRIS’s Attachment C: Cost Benefit
Analysis, Attachment A to this Consultation RIS). The core assumption for the
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17
Northern Territory Container Deposit Scheme
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Consultation Regulation Impact Statement
Packaging Impacts CRIS base case was that litter volumes would represent 6% of
packaging available to be littered, representing around 60,000 tonnes in 2010, which
was assessed by WCS to be the most reasonable estimate within the above range.
Litter projections were presented in the Packaging Impacts CRIS on a per tonne
basis to ensure consistency with collection and recycling projections.
For further discussion of assumptions made in the Packaging Impacts CRIS, see the
Cost Benefit Analysis of the Packaging Impacts CRIS at Attachment A.
6.1. Cost Benefit Analysis
The following parameters apply across all options:

Base year of the appraisal: all monetised values are expressed in 2012
dollars; and

Evaluation period: 25 years, from 2012: the total period of evaluation needs to
be long enough to capture all potential costs and benefits of the proposal. All
options are assumed to begin in 2012. 25 years is used to maintain
consistency with the current Packaging Impacts CRIS process.
Net Present Value (NPV) is calculated by subtracting estimated costs over the
evaluation period from benefits. A positive NPV indicates that an option would result
in a net benefit to the Australian economy, whereas a negative NPV suggests that an
option would impose a net cost.
November 2012
As mentioned, a number of estimations have been based on those given in the
CRIS. Generally, estimations based on the Packaging Impacts CRIS pertain to costs
and benefits for Option 4(A) of the Packaging Impacts CRIS, the Boomerang
Alliance Container Deposit Scheme. This is necessary because in certain areas,
relevant NT data is held by stakeholders such as industry, rather than the NT
Government.
Estimates given in the Packaging Impacts CRIS pertain to a national analysis.
Where they have been used as the basis for NT estimates, adjustments have been
made on the basis of the NT’s proportion of national population (approximately 1%).
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
6.1.1. Key Results
Table 4-1 summarises the key findings of the cost benefit analysis. The approximate
estimations of costs and benefits for permanent exemption (Option 3) return a net
benefit.
Options
Costs
Option 1
Option 2
Option 3
Option 4
Expiration of the
National
Permanent
Other less trade-
Temporary MRA and Packaging
exemption is
restrictive
TTMRA Exemptions
Recovery Scheme
granted
approaches
To be ascertained
pending
$21,095,00
various /
Packaging
indeterminate
Impacts Decision
RIS
Market Benefits
To be ascertained
pending
$41,390,000
Packaging
various /
indeterminate
Impacts Decision
RIS
Non
Market To be ascertained
Benefits
pending
$8,010,000
Packaging
various /
indeterminate
Impacts Decision
RIS
Net
Present To be ascertained
Value
Pending
$28,305,000
Not applicable
Packaging
Impacts
November 2012
Decision RIS
Table 4-1: Key Results (over 25 years)
6.1.2. Costs
Households, businesses (beverage manufacturers and importers / exporters), and
the waste management industry, including CDS materials coordinators and collection
depots, and governments are assumed to incur certain costs associated with the
options. The following provides a summary of these costs.
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Scheme design and implementation costs incurred by government include the
following:

designing and implementing the regulation and making regulatory
amendments;

communicating the operation of the scheme to households and businesses;
and

administering the regulation on an ongoing basis, including costs related to
compliance and enforcement.
Scheme operation and compliance costs incurred by industry include:

reporting requirements and updating labels;

establishing industry-run organisations responsible for the operation of the
scheme;

establishing infrastructure; and

operating costs.
Collection, transport and recycling costs include avoided costs relating to preexisting recycling arrangements. This is chiefly the costs to:

November 2012
transport materials from collection infrastructure to existing recovery/recycling
facilities;

sort/process material delivered to existing recovery/recycling facilities; and

landfill residual material that may be rejected due to contamination.
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
Table 4-2 provides a summary of the annual costs for all of the considered options.
Options
Option 1
Option 2
Option 3
Option 4
Expiration of the
National
Permanent
Other less trade-
Temporary MRA
Packaging
exemption is
restrictive
and TTMRA
Recovery Scheme
granted
approaches
Exemptions
Scheme design
To be ascertained
pending
and
Packaging Impacts
implementation
Decision RIS
Scheme
various /
$7,875,000
indeterminate
$40,000,000
operation and
compliance
–$27,230,000
Collection,
transport,
process at
Material
Recycling
Facilities
Household
$4,500,00
November 2012
participation
costs
Total Costs
To
be
ascertained
pending
Packaging
$21,095,000
various /
indeterminate
Impacts Decision
RIS
Table 4-2: Summary of costs for all options (over 25 years)
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Northern Territory Container Deposit Scheme
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Consultation Regulation Impact Statement
6.1.3. Market and Non-Market Benefits
The following market benefits for each option were included in the analysis:

Market value of resources: The financial market value of recovered resources
that are diverted from landfill or the litter stream, including premiums for
segregated and cleaner material streams;

Avoided operating costs of landfill: the avoided direct costs associated with
operating landfills due to diverting material from landfill, including the
opportunity cost of land, and other ongoing costs;

Avoided costs of litter clean up: the avoided direct costs to the government for
the range of services they provide that contribute to litter prevention including
municipal litter services, street sweeping and litter clean up services;

Economic benefit to NT’s tourism sector.
The following non-market benefits for each option were presented in the analysis:

Broader environmental and amenity benefits, including the public’s perceived
benefit from fulfilment of civic duty.
An estimate for the value of these non-market benefits has been derived from the
November
Packaging Impacts CRIS. In turn, the Packaging Impacts CRIS estimate
derives 2012
from a 2010 PricewaterhouseCooper (PwC) study that surveyed households’
willingness to pay for increased packaging recycling and reduced litter, in order to
attempt to quantify non-market values. The study found that households were willing
to pay on average $2.77 per year for every 1% increase above current national
levels of packaging recycling with lower and upper 95% confidence interval of $2.19
and $3.77. The willingness to pay value for increased recycling ascribed to the
Packaging Impacts CRIS Boomerang Alliance CDS Option has been applied here,
using the upper 95% confidence interval. The upper level was used in line with the
current high uptake of CDS in the NT, as discussed in section 1.5 above (see also
Figure 1-5). The Packaging Impacts CRIS estimate has been adjusted in line with
NT’s proportion of national population (approximately 1%).
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
This willingness to pay figure has been presented in the analysis to allow for these
non-market aspects to be taken into consideration. However, in the analysis an
explicit differentiation has been made between ‘market’ and ‘non-market’ benefits.
This is because there is a heightened uncertainty around the non-market figure:
there is possibly an element of double counting (as survey participants may have
considered market values associated with packaging when estimating their
willingness to pay).
Table 4-3 summarises the market and non-market benefits for all the considered
options.
Options
Option 1
Option 2
Option 3
Option 4
Expiration of the
National
Permanent
Other less trade-
Temporary MRA
Packaging
exemption is
restrictive
and TTMRA
Recovery
granted
approaches
Exemptions
Scheme
To be ascertained
Pending National
$4,630,000
various /
Market Benefits
market value of
resources
Packaging
indeterminate
Impacts Decision
avoided landfill
RIS.
$620,000
operating costs
avoided litter
$1,140,000
clean up
benefit to NT
$35,000,000
November 2012
Tourism sector
Non-market Benefits
environmental
$8,010,000
and amenity
benefits
Total Benefits
To be ascertained
Pending
$49,400,000
Decision RIS
various /
indeterminate
Table 4-3: Summary of Market and Non-Market Benefits (over 25 years)
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
6.2. Individual Option Analyses
6.2.1. Option One – Expiration of the Temporary MRA and TTMRA Exemptions
In the event that the temporary exemptions to the MRA and TTMRA expire, a
number of outcomes are possible. These range from the NT CDS continuing
unimpaired (and the estimation given as the net benefit for Option 3 results), through
various degrees of impairment, to the outright demise of the EP(BC&PB) Act (with
the waste management industry suffering some loss of investment to date). These
possibilities are discussed below.
Although it is expected the first of these possibilities (that the CDS will continue to
operate as it currently does in accordance with the provisions of the EP(BC&PB) Act)
is most likely, the NTG considers it prudent to seek permanent exemption as a
means of eliminating the risks associated with the alternative outcomes.
The possible scenarios are:
1. The NT CDS continues to operate as it currently does. This is considered the
most likely outcome. In this scenario:

all beverage companies continue to comply with the EP(BC&PB) Act;

some beverage companies consider it possible that sections of the
November 2012
EP(BC&PB) Act are inconsistent with the MRA or TTMRA. In particular,
that the requirement that they change labels may be unenforceable;

nevertheless, beverage companies who have already changed their
labels maintain them, those who have not yet done so go ahead and
change labels at the most opportune time;

beverage companies do so because they wish to be regarded as good
corporate citizens and do not wish to receive negative environmental
publicity resulting from not complying with a scheme popular with the
NT community; and
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24
Northern Territory Container Deposit Scheme
Mutual Recognition Act

Consultation Regulation Impact Statement
beverage companies amortise the costs of the scheme through very
small price rises nationally.
Under this scenario, the costs and benefits for Option 1 would be similar to
those of Option 3 (permanent exemption).
2. To some indeterminate degree, the functioning of the NT CDS is impaired.
The NT CDS runs less efficiently due to enforcement issues relating to the
application of mutual recognition. In this scenario:

some, or all, beverage companies consider sections of the EP(BC&PB)
Act to be inconsistent with the MRA or TTMRA. In particular they hold
the view that the requirement that they change labels is unenforceable;

some or all beverage companies decide not to comply with the
EP(BC&PB) Act;

they do not maintain already changed labels, or do not change labels
within the two year timeframe;

their decision to do so survives a legal challenge;

the NT CDS continues, but without the benefit of all beverage
containers bearing the required labelling;

the existence of the scheme is widely known to Territorians
and
November
2012
ongoing information about the scheme (and which beverage containers
are redeemable) is made known to the community through other forms
of publicity; and

the objectives of the EP(BC&PB) Act continue to be realised but with
some degree of reduced effectiveness.
The extent of this impairment cannot be known at this point in time. The
degree of lost efficiency might be measured in terms of reduced net benefit. A
10% reduction in efficiency might result in a given reduction in net benefit.
3. The scheme becomes entirely unenforceable. Under this scenario:
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Northern Territory Container Deposit Scheme
Mutual Recognition Act

Consultation Regulation Impact Statement
all beverage companies consider sections of the EP(BC&PB) Act to be
inconsistent with the MRA or TTMRA. In particular they hold the view
that the requirement that they change labels is unenforceable;

a legal challenge results in all aspects of the EP(BC&PB) Act being
deemed entirely unenforceable;

no beverage companies comply with the EP(BC&PB) Act; all beverage
companies terminate their contracts with coordinators and depots;

the EP(BC&PB) Act’s objectives are not realised; and

the waste management industry investment in infrastructure to support
the NT CDS may not be fully recovered.
To fully explore this option and its possible impact on the waste management
industry, the waste management industry’s capital expenditure to date on NT
CDS infrastructure needs to be ascertained.
Table 4-4 summarises the cost / benefit analysis for Option 1.
Costs
scheme design and implementation
to be ascertained
scheme operation and compliance
collection, transport, process at recycling facilities
November 2012
household participation costs
Market Benefits
market value of resources
to be ascertained
avoided landfill operating costs
avoided litter clean up
benefit to NT Tourism sector
Non-Market benefits
environment and amenity
to be ascertained
NPV
to be ascertained
Table 4-4: Cost and benefit analysis for Option 1.
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
OPTION ONE – CONSULTATION QUESTIONS FOR STAKEHOLDERS
Beverage Industry in all Australian and NZ Jurisdictions
To what extent do stakeholders from the beverage industry intend to comply with the
Act if a permanent exemption is not granted?
Will stakeholders from the beverage industry:

not label beverage containers, as stipulated by the Act?

revert to old labels if changed already?

not comply with other aspects of the Act? If not, which aspects?
If stakeholders from the beverage industry do not comply with labelling requirements
or other requirements of the Act:

what costs will they avoid?

what benefits will they lose?
What alternative steps would beverage industry stakeholders introduce to remediate
the littering in the NT of beverage containers they have manufactured?

what would be the costs and benefits of this alternative program?
Waste Management Industry and Collection Depots in the NT and other
November 2012
Jurisdictions
What would the impact be on the waste management industry if stakeholders from
the beverage industry failed to comply with some or all aspects of the Act?
How much have the waste management industry and collection depots invested to
date in NT CDS infrastructure?

would this investment be lost if the beverage industry failed to comply with
labelling requirements alone?

would this investment be lost if the beverage industry failed to comply with
other requirements of the Act?
What would be the impact on the market value received from resources recovered
through the scheme if the beverage industry failed to comply with some or all
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27
Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
requirements of the Act?
Local Government
If stakeholders from the beverage industry do not comply with part or all of the Act,
how would litter recovery costs be impacted?
What would be the impact on avoided landfill operating costs?
How would kerbside recycling be impacted?

in terms of viability?

in terms of reduced costs due to less beverage containers collected?

in terms of composition of existing services?
Households/Consumers in all Australian and NZ Jurisdictions
If stakeholders from beverage industry do not comply with part or all of the Act, how
would household participation costs be impacted?
What would be the impact on benefits associated with environmental and amenity
improvements?
Tourism Industry in the NT, other Jurisdictions and NZ
If stakeholders from the beverage industry do not comply with part or all of the Act,
what would be the impact on the NT Tourism sector?
November 2012
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Northern Territory Container Deposit Scheme
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6.2.2. Option Two – National Packaging Recovery Scheme
This option is currently the subject of the SCEW’s National Packaging CRIS. The
consultation process may lead to analysis modification. Until the results of the
Decision RIS are known, full analysis here is not possible.
The Packaging Impacts CRIS explores a limited number of measures that have the
potential to increase packaging resource recovery rates and decrease packaging
litter. The objectives of the considered government actions were to:
 reduce packaging waste and increase packaging resource recovery;
 reduce the need to landfill recyclable packaging materials;
 reduce the negative amenity, health and environmental impacts of packaging
waste and litter in line with community expectations; and
 promote a consistent national approach to regulating packaging.
Options considered were:
 Option 1: National Waste Packaging Strategy
 Option 2: Co-regulatory Packaging Stewardship, with three specific suboptions:

2 (a): the Australian Packaging Covenant replaced by November
co-regulation 2012
under the Product Stewardship Act 2011

2 (b): Industry Packaging Stewardship

2 (c): Extended Packaging Stewardship
 Option 3: Mandatory Advance Disposal Fee
 Option 4: Mandatory Container Deposit Scheme, with two specific sub-options:

4 (a): Boomerang Alliance CDS

4 (b): Hybrid CDS
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Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
The key results of the cost benefit analysis (CBA) showed that:
 all options result in an overall increase in recycling by 2035;
 Option 2 (a) is the only option that has a positive NPV;
 all other options were assessed in the CBA as having negative NPVs and
benefit costs ratios (BCR) lower than 1. This suggests that for these options,
the market costs are greater than the benefits;
 Options 1 and 2 (b) involved relatively low costs and benefits and result in small
net costs to the economy, whereas Options 2 (c) and 3 involve higher costs and
benefits and result in larger net costs; and
 Options 4 (a) and 4 (b) were the highest cost options. While these options have
high resource recovery benefits, due to a price premium from materials
collected through a CDS, these benefits are lower than the overall higher costs.
In 2010 a study of households’ willingness to pay for increased packaging recycling,
to quantify non-market values such as environmental benefits or a feeling of civic
duty was undertaken. In Table 4-5, the willingness to pay values for increased
recycling are applied across the options being assessed, using the point estimate
and lower and upper 95% confidence interval limits. The figures below were
presented alongside the CBA results to allow for these non-market aspects to be
taken into consideration in assessing the overall costs and benefits November
of the options.2012
Option 1
National
Waste
Packaging
Strategy
Option 2 (a)
Coregulation
Option 2 (b)
Option 2 (c)
Option 3
Option 4 (a)
Industry
Packaging
Stewardship
Extended
Packaging
Stewardship
Mandatory
Advance
Disposal
Fee
Boomerang
Alliance
CDS
Option
4 (b)
Hybrid
CDS
Lower
estimate
$234
$233
$422
$689
$689
$465
$465
Point
estimate
$296
$295
$534
$871
$871
$588
$588
Upper
estimate
$403
$402
$727
$1,186
$1,186
$801
$801
Table 4-5: Summary of Willingness to Pay (for Increased Recycling) Benefits ($ Millions)
OPTION TWO – CONSULTATION QUESTIONS FOR STAKEHOLDERS
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Northern Territory Container Deposit Scheme
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Beverage Industry in all Australian and NZ Jurisdictions
Do stakeholders from the beverage industry support a National Packaging scheme
over a NT CDS?
Do stakeholders from the beverage industry support a National CDS over a NT
CDS?
Waste Management Industry and Collection Depots in the NT and other
Jurisdictions
Do stakeholders from the waste management industry and collection depots support
a National Packaging scheme over a NT CDS?
Do stakeholders from the waste management industry and collection depots support
a National CDS over a NT CDS?
Local Government
Do stakeholders from local government support a National Packaging scheme over a
NT CDS?
Do stakeholders from local government support a National CDS over a NT CDS?
Households/Consumers in all Australian and NZ Jurisdictions
Do households and consumers support a National Packaging scheme over a NT
CDS?
Do households and consumers support a National CDS over a NT CDS?
Tourism Industry in the NT, other Jurisdictions and NZ
November 2012
Do stakeholders from the tourism sector support a National Packaging scheme over
a NT CDS?
Do stakeholders from the tourism sector support a National CDS over a NT CDS?
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31
Northern Territory Container Deposit Scheme
Mutual Recognition Act
Consultation Regulation Impact Statement
6.2.3. Option Three – Permanent exemption is granted
The granting of a permanent exemption from the MRA and the TTMRA will result in
the EP(BC&PB) Act continuing to achieve its objectives. Table 4-6 summarises the
costs and benefits for Option 3.
Description of Costs / Benefits
Value
Costs
scheme design and implementation
$7,875,000
scheme operation and compliance
$40,000,000
collection, transport, process at material recycling
–$27,230,000
facilities
household participation costs
$4,500,000
(total costs)
($21,095,000)
Market Benefits
market value of resources
$4,630,000
avoided landfill operating costs
$620,000
avoided litter clean up
$1,140,000
benefit to NT tourism sector
$35,000,000
(total market benefits)
($41,390,000)
Non-market Benefits
willingness to pay calculation
$8,010,000
(total non-market benefits)
NPV (Net Present Value = benefit minus cost)
($8,010,000)
$28,305,000
Table 4-6: Cost and benefit analysis for Option 3
November 2012
Scheme design and implementation costs
Scheme design and implementation costs to the NTG over 25 years (chiefly
enforcement) will amount to approximately $315,000 per annum, as has been set out
in the current NTG’s CDS implementation budget.
Scheme operation and compliance costs
The majority of the costs of Option 3 are borne by beverage manufacturers and
importers. The jurisdictional breakdown for these companies is as follows:

56 NSW
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32
Northern Territory Container Deposit Scheme
Mutual Recognition Act

47 Vic.

29 SA

10 Qld

9 WA

1 NT

1 USA

0 NZ
Consultation Regulation Impact Statement
Beverage manufacturers/importers have the option to pass costs on to
consumers/households exclusively in the NT or to amortise the costs across all
jurisdictions in which they sell their products.
It is not known to what extent beverage companies have passed on costs directly
associated with the NT CDS to consumers via price rises. Operating costs have
therefore been credited to beverage manufacturers rather than households /
consumers.
Because the NT CDS is a market-based and operated program and because the
costs relating to the operational implementation are borne in the first instance by the
beverage industry, such cost data is not available to the NTG. In response to this,
November 2012
the cost nominated here is an indicative estimate only based on and consistent with
the assumptions used in the Packaging Impacts CRIS for the Boomerang Alliance
(BA) option.19
The BA cost model adopted the conventional approach to estimating the cost of CDS
arrangements whereby estimates are made of the various cost elements on a per
container basis. Further, consistent with current normal practice for estimating costs
for CDS arrangements in Australia, there was no separation of capital and operating
costs. Instead one unit cost is used and is fully inclusive of both capital and operating
costs. The model contains the following elements:

service areas – such as the cost to consolidate containers, the cost of
transport, the cost of RVMs etc;
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
Consultation Regulation Impact Statement
localities for services – such as kerbside, RVM sites, regional depots and rural
and remote depots etc; and

unit costs – the cost per container for delivery of the relevant service at the
designated locality, as a fully inclusive capital and operating cost.
In the BA model, detailed supporting estimates were provided of the distribution of
containers throughout the system covering the number of containers likely to present
for re-aggregation at each of the localities where services are provided. Using this
data, the BA model estimated the cost to deliver CDS services at each of the
localities and to aggregate the containers to centralised locations for reprocessing.
The value adopted for Option 4(a) was 4.5 cents/container and 6.0 cents/container in
rural and remote locations. Co-ordination across the system was 0.4 cents/container,
baling and transport from collection centres, RVMs and rural and remote collection
points to hubs (urban and rural) was 0.72 cents/container, and rural and remote
transport from hubs to reprocessors was estimated at $106.30 per tonne. These
estimates are based on the economic costs of the CDS infrastructure (i.e. include
capital and operating costs) and exclude the payment of financial incentives to rural
and remote infrastructure operators.
These costs are consistent with the 4.0 cents/container handling cost used by BDA
Group and WCS in the Beverage Container Investigation20. Further, the above
handling costs are in line with the 4.25 cents/container depot handling fee estimate
November 2012
proposed by Stefan Gabrynowicz in his 2009 paper on the South Australian CDS21.
These estimates are higher than estimates of current industry costs for the South
Australian scheme. The South Australian Environment Protection Authority estimates
South Australian costs to be at 4.25 cents/container22. A CDS in the NT requires
development of more infrastructure and therefore NT costs are estimated to be
higher than the SA scheme’s costs.
The costs of changing beverage container labels to reflect the scheme’s operation
from reading: ‘10c refund at collection depots when sold in S.A.’ to ‘10c refund at
SA/NT collection depots in State/Territory of Purchase’ does not represent a cost
significant enough to register. The national beverage industry must already comply
with the South Australian CDS. Only a simple modification is required to existing
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labelling. A two year transitional period has been granted under the Act. The
national beverage industry can therefore make the change at a time when other
labelling changes are already scheduled for processing. Administrative costs
associated with management of deposits and handling fees collected and paid to
CDS materials coordinators and administrative costs associated with reporting on NT
sales to CDS materials coordinators will represent a negligible increase on
administration costs already borne for this purpose in relation to the SA CDS.
Considering all these factors, annual operation and compliance costs for Option 3
are estimated at approximately $40,000,000 over 25 years. This estimate is
essentially an adjustment of the Packaging Impacts CRIS Boomerang Alliance
option estimate, in line with NT’s proportion of national population. It also considers
factors such as the negligible costs associated with label changes.
Collection, transport, process at material recycling facilities
CDS operating costs are offset to a certain extent by avoided cost of collection,
transport and recycling as a result of beverage containers being diverted away from
existing recycling systems. The Packaging Impacts CRIS estimated costs associated
with household kerbside collection to be $187/tonne and those associated with
commercial and industrial sector collection to be $26/tonne to collect and transport
used packaging from accumulation points such as recycling bins to material recovery
facilities. For further details, see the Cost Benefit Analysis Report from the
Packaging Impacts CRIS at Attachment A.
November 2012
Using the figures employed by the Packaging Impacts CRIS for the Boomerang
Alliance CDS option and adjusting it in line with NT’s proportion of national
population, it is estimated that beverage container redemption under an NT CDS will
lead to avoided collection, transport and recycling costs for local governments and
commercial businesses. These avoided costs equate to around $27,230,000 over
the 25 year period.
As noted above, it is estimated that only 23% of the total NT at-home consumption of
beverage containers is recovered for recycling in the current kerbside and drop-off
recycling services offered in Darwin and Palmerston, while the estimated Australian
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overall beverage recovery rate of at home consumption of beverage containers is
62%23.
While the NT’s recycling infrastructure requires further maturation, it is likely to have
costs far greater than in other jurisdictions due to the absence of economies of scale
and increased inter-urban and inter-state/territory transport costs. There is therefore
some degree of uncertainty around this figure.
A CDS will impact existing kerbside recycling. While a significant proportion of
beverage containers will be directed away from kerbside recycling, not all will be.
Collection costs of kerbside collection will be reduced; however, operators will
receive a substantial benefit from the redemption of beverage containers they still
receive. In this way it is anticipated that the two systems will successfully operate in
tandem.
Household participation costs
A figure of $4,500,000 has been provided against this sector. This estimate is an
adjustment of the Packaging Impacts CRIS Boomerang Alliance CDS estimate, in
line with NT’s proportion of national population. A variety of key assumptions in the
Packaging Impacts CRIS analysis centred on vehicle operating costs, in-vehicle
travel time, accumulation time and container deposit redemption time. For further
details, see the Cost Benefit Analysis Report of the Packaging Impacts CRIS at
Attachment A.
November 2012
In the NT it is likely to be significantly less than this because household participation
costs associated with travel to depots can be made inconsequential by households
incorporating this travel into other existing trips. While this may be difficult in southeastern jurisdictions due to urban sprawl and congestion, travel within the NT urban
and remote centres may be of greater distances but is highly convenient.
Furthermore Reverse Vending Machines in the NT allow incorporation of redemption
of containers into existing shopping trips. Given these factors, there is a significant
degree of uncertainty to this figure.
Market Benefits
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Option 3 generates resources that can be sold on the recycle market. The quality is
high due to low contamination. Consistent with the methodology employed in the
Packaging Impacts CRIS Boomerang Alliance CDS option and in line with NT’s
proportion of national population, estimates as to the market value of resources
under the NT CDS amount to approximately $4,630,000 over 25 years. The
Packaging Impacts CRIS estimates were based on assumptions as to the mediumterm prices of packaging materials, which range between $30 and $1,560 per tonne
depending on the material. The Packaging Impacts CRIS estimates factored in a
price premium for certain materials collected through a CDS due to the reduced
contamination of kerbside materials under CDS. For further details, see the Cost
Benefit Analysis Report of the Packaging Impacts CRIS at Attachment A.
Consistent with the methodology employed in the Packaging Impacts CRIS
Boomerang Alliance CDS option and in line with NT’s proportion of national
population, estimates of the avoided landfill operating costs due to the NT CDS
amount to approximately $620,000 over 25 years. The Packaging Impacts CRIS
estimates were based on assumptions around the private costs of landfill, including:

the opportunity cost of land;

land purchase;

the approval process;

equipment and buildings;

construction costs such as excavation and lining of landfill bases to minimise
November 2012
leaching;

on-sight gas recovery and flaring;

fencing and other measures to prevent waste from being blown into
neighbouring properties;

operational costs like fuels and materials;

monitoring and reporting;

capping landfills and landscaping;
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Northern Territory Container Deposit Scheme
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
rehabilitation and aftercare;

employee costs; and

contractors costs.
Consultation Regulation Impact Statement
For further details, see the Cost Benefit Analysis Report of the Packaging Impacts
CRIS at Attachment A.
Consistent with the methodology employed in the Packaging Impacts CRIS
Boomerang Alliance CDS option and in line with NT’s proportion of national
population, estimates as to avoided litter clean up are approximately $1,140,000
over 25 years. A key assumption in the Packaging Impacts CRIS is that the cost per
anum per person for litter services in Victoria ($13.90) is similar to other jurisdictions.
The analysis reduces litter clean up costs in proportion with the percentage reduction
in litter tonnes relative to the base year and packaging litter as a proportion of all
litter. For further details, see the Cost Benefit Analysis Report of the Packaging
Impacts CRIS at Attachment A.
Benefit to Northern Territory Tourism sector
It is reasonable to expect that the high rate of beverage container littering in the NT
combined with the environmental focus of most NT tourism will have a negative
economic impact. There is a common sense link between environmental degradation
and customer dissatisfaction in the tourism sector. As fact sheets released by
November 2012
Sustainability Victoria note, ‘litter looks bad…litter negatively affects the image of
places, especially tourist locations’24. Other reports note that ‘Litter makes people
feel disappointed in others, disgusted, angry and cautious.’25 Such feelings do not
engender a satisfying tourist experience.
Most tourism in the NT is heavily oriented towards environmentally based
experiences; indeed, the NT markets its tourism around the theme of the NT’s
pristine wilderness.
As discussed, CDS items may amount to over 55% of NT litter as a whole in terms of
weight. Quantifying the proportion of different types of litter in the overall litter stream
is made difficult because of the multidimensional nature of litter. However, it is clear
that removal of beverage containers from the litter stream would not represent the
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end of litter as a whole. Yet, the impact on amenity of litter is also subjective:
different types of litter generate different responses. As discussed in Section 1.1,
research suggests beverage containers generate a response that may be
disproportional to the portion of the litter stream they represent26. In other words,
littered beverage containers more readily illicit feelings of lost amenity than other
types of litter.
The introduction of a CDS is likely to bring about behaviour change which may have
flow-on affects in terms of the littering of non-CDS articles.
In 2008-9 the total gross value of NT Tourism was estimated to be approximately
$1,400 million. Representing the benefit of significant litter reduction (derived from
the removal of beverage containers from the litter stream) with a monetary figure is
difficult. A very conservative benefit of 0.1% of tourism’s value to the NT economy is
proposed here. This translates to a benefit of approximately $1,400,000 per annum.
This figure is an indicative estimate; the significant degree of uncertainty around it is
acknowledged.
Non-Market benefits
These benefits cover broader environmental or amenity benefits, or feelings of
fulfilled ‘civic duty’. They are estimated on the basis of the ‘willingness to pay’
research cited in the Packaging Impacts CRIS.
High initial return rates given the NT CDS has only commenced on 3November
January 2012
2012
suggests that the NT CDS is having a significant impact on recycling levels in the
NT. Figure 1-5 (Section 1) represents monthly figures from four collection depots
operating across the first four months of 2012 which suggest an exponential
expansion of the rate of participation in the scheme. There is a likelihood this rate of
growth will continue in the near to medium term. For this reason non-market benefits,
derived from ‘willingness to pay’ research cited in the Packaging Impacts CRIS, have
been included alongside market benefits here. The significant impact of the NT CDS
is estimated to translate into an NT benefit of approximately $8,010,000. This
estimate is an adjustment of the Packaging Impacts CRIS Boomerang Alliance CDS
option estimate, in line with NT’s proportion of national population.
National Impacts
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The following analysis considers the costs and benefits of Option 3 at a national
level, that is, in terms of the impacts on individual jurisdictions and the Australian
Government. Because there are no beverages imported from New Zealand into the
NT, that jurisdiction receives no impacts.
The scheme design and enforcement costs are borne exclusively by the NT
Government.
The impact of scheme implementation and compliance costs on each Australian
jurisdiction is dependent on how costs are ultimately borne. The beverage industry is
believed to currently amortise its costs relating to the SA CDS nationally, by
adjusting beverage prices commensurate with handling fees paid in SA consistently
across all jurisdictions. The national beverage industry may choose to similarly
amortise costs borne relating to the NT CDS nationally. In this case consumers in all
jurisdictions would bear costs equally.
Alternatively, beverage industry costs might be fully or partly passed on to NT
consumers exclusively; or the beverage industry might choose to bear the costs
relating to the NT CDS itself.
The benefits that come from the market value derived from the resources collected
falls exclusively to those who control the end fate of the product collected. This
currently falls to the five CDS Coordinators currently operating in the NT.
The avoided externality costs (e.g. landfill operating costs) exclusively
benefit the 2012
NT
November
Government and NT local governments.
The avoided costs of litter clean up benefit the NT Government and NT local
governments.
In terms of non-market benefits and benefits to tourism marketability, these are
enjoyed exclusively by NT households and the NT tourism industry.
The national costs of Option 3 are set out in Table 4-7. The national benefits of
Option 3 are set out in Table 4-8.
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National Impacts – COSTS
Scheme design and
Scheme operation and compliance
enforcement
NT
Yes. Entirely
–
–
–
–
Yes. Beverage companies nationally: the number of beverage
Government
Australian
Government
Beverage
Industry
companies located in each jurisdictions is as follows: 56 NSW;
47 Vic.; 29 SA; 10 Qld; 9 WA; 0 Tas.; 0 ACT; 1 NT; 1 USA; 0
NZ.
Costs to jurisdictions will be proportional to the number of
companies based there and the value of those companies’ sales
in the NT.
There are no NZ beverage companies that sell products in the
NT.
Retail Industry
–
–
Waste
–
–
–
Yes. (Higher if beverage industry passes costs on through price
Management
Industry
NT house
holds
increases.)
exclusively
National house
–
holds
Nil (unless beverage industry passes costs on through price
increases)
November 2012
(including the
NT)
Table 4-7: National Impacts of Option 3: Costs
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National Impacts – BENEFITS
Market Value
Avoided
Avoided
Enhanced
Non-market benefits
of
landfill
litter
conditions for
Resources
operating
clean up
tourism
Shared with
Shared
–
–
NT Local
with NT
Gov
Local Gov
Yes. Shared
Yes.
–
–
with NT Gov
Shared
costs
NT
–
Government
NT Local
–
Government
with NT
Gov
Australian
–
–
–
–
–
–
–
–
–
Government
Beverage
Industry
Retail Industry
–
–
–
–
–
Waste
Yes. Value of
–
–
–
–
Management
material sold
–
–
Industry
NT house
–
Yes. environmental
holds
National house
and amenity benefit
November 2012
–
–
–
–
–
–
–
–
Yes. Significant
–
holds
(including the
NT)
NT Tourism
industry
economic gain
from increased
amenity.
Table 4-8: National Impacts of Option 3: Benefits
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OPTION THREE – CONSULTATION QUESTIONS FOR STAKEHOLDERS
Beverage Industry in all Australian and NZ Jurisdictions
What do stakeholders from the beverage industry estimate the operation and
compliance costs of a NT CDS to be (in the longer term, if the NT CDS is granted
permanent exemption from the MRA and TTMRA)?

please respond to the indicative costs supplied here;

please provide your estimated costs and any evidence to support your
assertions, including sales figures;

please indicate costs over a 25 year period;

please consider costs for the following:
o reporting requirements and updating labels;
o establishing industry-run organisations responsible for the operation of
the scheme; and
o operating costs.
Please indicate any operation and compliance costs/issues not considered in this
discussion of Option 3.
Please also list benefits of the NT CDS flowing to stakeholders from the beverage
November 2012
industry.

What is the market value of recovered resources sold to date under the NT
CDS?

Please state the value of other benefits.
To what extent are costs incurred by stakeholders from the beverage industry being
passed onto consumers in the form of beverage price rises?
If costs incurred by stakeholders from the beverage industry are being passed onto
consumers in the form of price rises, are these being passed on to NT consumers
alone or Australian consumers as a whole?
If costs incurred by stakeholders from the beverage industry are being passed onto
consumers in the form of price rises, what arguments have been considered
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Northern Territory Container Deposit Scheme
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favouring this course of action?
Waste Management Industry and Collection Depots in the NT and other
Jurisdictions
What do stakeholders from waste management industry including collection depots
estimate the impacts of a NT CDS to be (in the longer term, if the NT CDS is granted
permanent exemption from the MRA and TTMRA)?

please respond to the indicative costs supplied here;

please provide your estimated costs and any evidence to support your
assertions; and

please indicate estimated costs over a 25 year period.
In particular, please supply data around:

capital investment in NT CDS infrastructure to date;

future capital investment in NT CDS infrastructure;

the market value of resources recovered to date under the NT CDS; and

the value of unredeemed beverage containers collected to date.
Local Government
What do stakeholders from local governments estimate the impacts of a NT CDS to
be (in the longer term, if the NT CDS is granted permanent exemption from the MRA
and TTMRA)?
November 2012

please respond to the indicative costs and benefits supplied here;

please provide your estimated costs and benefits and any evidence to support
your assertions; and

please indicate estimated costs and benefits over a 25 year period.
In particular, please supply data around:

reductions in litter recovery costs;

reductions in landfill costs;

the operating cost of existing waste collection, transport and processing at
material recycling facilities;

the reduction in these costs since the NT CDS began operations;
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Northern Territory Container Deposit Scheme
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
the market value of resources recovered from processing at existing recycling
facilities;

the overall viability of existing recycling facilities; and

the viability of existing kerbside collection in Darwin and Palmerston.
Households/Consumers in all Australian and NZ Jurisdictions
What do households and consumers estimate the impacts of a NT CDS to be (in the
longer term, if the NT CDS is granted permanent exemption from the MRA and
TTMRA)?

please respond to the indicative costs and benefits supplied here;

please provide your estimated costs and benefits and any evidence to support
your assertions; and

please indicate estimated costs and benefits over a 25 year period.
In particular, please supply data around:

household participation costs; and

environmental and amenity improvements.
Tourism Industry in the NT, other Jurisdictions and NZ
What do stakeholders from the tourism sector estimate the impacts of a NT CDS to
be (in the longer term, if the NT CDS is granted permanent exemption from the MRA
and TTMRA)?
November 2012

please respond to the indicative costs and benefits supplied here;

please provide your estimated costs and benefits and any evidence to support
your assertions; and

please indicate estimated costs and benefits over a 25 year period.
In particular, please supply data around:

value of a significant drop in litter to the tourism market.
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Northern Territory Container Deposit Scheme
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6.2.4. Option Four – Other less trade-restrictive approaches in the Northern
Territory
In assessing the regulatory impact of a number of options to achieve its objectives
within the NT, the NTG considered a range of options. The conclusions the NT drew
as to the suitability of these options is reviewed here.
Litter Abatement Programs
Litter abatement programs result in the costs associated with littering continuing to
be borne largely by government rather than those responsible for producing or the
dropping the litter. Community grants, financed by government and potentially
industry groups would be the major mechanism to fund litter abatement programs.
Education Campaign
Education encourages behaviour change within the community. If implemented as a
stand alone option, outcomes are uncertain and are likely to be less effective where
waste management infrastructure is undeveloped. Any outcomes are not sustainable
over time as experienced at the national level. This option is best viewed as a
complementary approach – an important part of any new litter management scheme
or regulatory approach, including a CDS. A new and reinvigorated education
campaign would require additional government funds.
Strategic Grants to Community, Industry & Local Government November 2012
This approach has been used to address waste and litter in the NT since 2003.
While many projects have been funded, outcomes are unclear. Some localised
success has been achieved, but it has not been able to deliver comprehensive and
sustained outcomes across the NT.
Extended Kerbside/Drop-off Service
There is little doubt that extended or improved kerbside waste collection is of value in
increasing recycling rates and in this context is an important component of a broader
waste and recycling program for the NT.
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Northern Territory Container Deposit Scheme
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Currently kerbside recycling is available only to residents of Palmerston and Darwin
councils. A limited number of waste disposal sites offer drop off facilities for
recyclable products. A Kerbside/Drop off service could be extended to operate a
Kerbside service in other major NT centres and new drop off services in regional
areas.
This option would increase resource recovery but doesn’t address away-from-home
litter. It would not require new legislation; however, increased costs associated with
this option have led to NT councils (beyond Darwin and Palmerston) being resistant
to implement. Implementation would lead to additional costs for local government,
business and residents, with full coverage of the NT unlikely.
Improved Recycling - Public Places & Events
This option involves targeting the volumes of beverage container waste in public
places and at events. While it has potential to efficiently address litter volumes in
specific concentrated areas it does not address broad scale littering across the NT
and is unlikely to significantly reduce litter volumes. It does not provide an incentive
to the community to recover litter.
Improved Recycling - Workplaces
Improved recycling opportunities within NT work places will address access to
infrastructure however this option will have no impact on litter. This option does have
a valid role in improving recycling opportunities in the NT.
November 2012
Residual Waste Processing System
Residual waste processing systems lead to increased recovery of packaging
material, such as beverage containers, from mixed waste streams. They are
valuable in commingled kerbside collection to maximise the recovery of potentially
valuable resources. Acceleration of the introduction of mechanical and biological
process plants to expand resource recovery would increase the recovery of inert
material such as plastics, glass and metals (such as beverage containers). These
measures involve considerable infrastructure and are suitable as a national
measure, potentially using cost sharing arrangements. This technological approach
has the potential to substantially increase the recovery rate for inert material from
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Northern Territory Container Deposit Scheme
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both commingled kerbside collection and from the general waste stream. However,
this approach will have no impact on litter reduction.
November 2012
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Northern Territory Container Deposit Scheme
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OPTION FOUR – CONSULTATION QUESTIONS FOR STAKEHOLDERS
Beverage Industry in all Australian and NZ Jurisdictions
How do stakeholders from the beverage industry regard the alternative schemes
discussed in this option?

could any of the schemes provide a significant benefit? If so, at what cost, and
to whom;

please provide any estimated costs and any evidence to support your
assertions; and

if possible, please indicate costs over a 25 year period.
Please describe any commendable schemes not considered in this option.
Waste Management Industry and Collection Depots in the NT and other
Jurisdictions
How do stakeholders from the waste management industry including collection
depots regard the alternative schemes discussed in this option?

could any of the schemes provide a significant benefit? If so, at what cost, and
to whom;

please provide any estimated costs and any evidence to support your
assertions; and
November 2012

if possible, please indicate costs over a 25 year period.
Please describe any commendable schemes not considered by this option.
Local Government
How do stakeholders from local government regard the alternative schemes
discussed in this option?

could any of the schemes provide a significant benefit? If so, at what cost, and
to whom;

please provide any estimated costs and any evidence to support your
assertions; and
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Northern Territory Container Deposit Scheme
Mutual Recognition Act

Consultation Regulation Impact Statement
if possible, please indicate costs over a 25 year period.
Please describe any commendable schemes not considered in this option.
Households/Consumers in all Australian and NZ Jurisdictions
How do households and consumers regard the alternative schemes discussed in this
option?

could any of the schemes provide a significant benefit? If so, at what cost, and
to whom;

please provide any estimated costs and any evidence to support your
assertions; and

if possible, please indicate costs over a 25 year period.
Please describe any commendable schemes not considered by this option.
Tourism Industry in the NT, other Jurisdictions and NZ
How do stakeholders from the tourism industry regard the alternative schemes
discussed in this option?

could any of the schemes provide a significant benefit? If so, at what cost, and
to whom;

please provide any estimated costs and any evidence to support your
assertions; and

if possible, please indicate costs over a 25 year period.
November 2012
Please describe any commendable schemes not considered by this option.
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Northern Territory Container Deposit Scheme
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7. REFERENCES
1
McGregor Tan Research September 2010. Container Deposit Legislation (CDL) Items from the 2009/10 KAB
National Litter Count
2
ibid
3
ibid
4
ibid
5
ibid
6
Approximate estimate based on raw data in McGregor Tan Research September 2010. Container Deposit
Legislation (CDL) Items from the 2009/10 KAB National Litter Count; and, NT Government 2011. Report for
Environment, Heritage and the Arts Division. Department of Natural Resources, Environment, The Arts and
Sport. Northern Territory Government Project No: 9149. p 5 and 55, unpublished and
http://www.oceanwatch.org.au/seanet/seanet-programs-by-state/seanet-northern-territory/ Darwin Harbour
clean up day 2011
7
Approximate estimate based on raw data in McGregor Tan Research September 2010. Container Deposit
Legislation (CDL) Items from the 2009/10 KAB National Litter Count
8
Approximate estimate based on raw data in McGregor Tan Research September 2010. Container Deposit
Legislation (CDL) Items from the 2009/10 KAB National Litter Count
9
Donnelly D and Buard M C 2011. Community Preferences for Litter Reduction, NEPC Service Corporation
10
ibid
11
Sustainability Victoria. Fact Sheet www.sustainability.vic.gov.au/resources/.../Info_19_-_Litter.doc
12
Donnelly D and Buard M C 2011. Community Preferences for Litter Reduction, NEPC Service Corporation
13
Tourism NT. http://www.tourismnt.com.au/research/trends-outlooks/economic-value-of-tourism.aspx
14
Wright Corporate Strategy July 2009. Preliminary Assessment of a Container Deposit Scheme Operation and
November 2012
Costs Northern Territory.
15
Hyder Consulting Sep 2008. Australian Beverage Packaging Consumption, Recovery and Recycling
Quantification Study, Packaging Stewardship Forum for the Australian Food and Grocery Council.
16
Northern Territory Government June 2012. Cash for Containers Quarterly Report,
http://www.greeningnt.nt.gov.au/containers/quarterly_reports.html
17
Standing Council on Environment and Water 2011. Packaging Impacts Consultation Regulation Impact
Statement. Canberra. http://www.scew.gov.au/publications/pubs/packaging-impacts/packaging-impacts-
www.nt.gov.au
51
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consultation-ris-december-2011.pdf
18
ibid
19
ibid
20
BDA Group and Wright Corporate Strategy March 2009. Beverage Container Investigation
21
Stefan Gabrynowicz, EPA SA April 2009. Economic Costs and Benefits of SA’s Container Deposit System The
4.25 cents/container is the depot handling fee estimate Gabrynowicz proposed. An estimated 4.66
cents/container was also proposed as all-up gross cost covering handling fee, admin, transport, supercollector costs.
22
Standing Council on Environment and Water 2011. Packaging Impacts Consultation Regulation Impact
Statement. Canberra. http://www.scew.gov.au/publications/pubs/packaging-impacts/packaging-impactsconsultation-ris-december-2011.pdf p 53
23
Hyder Consulting Sep 2008. Australian Beverage Packaging Consumption, Recovery and Recycling
Quantification Study, Packaging Stewardship, Forum for the Australian Food and Grocery Council
24
Sustainability Victoria Fact Sheet www.sustainability.vic.gov.au/resources/.../Info_19_-_Litter.doc
25
Donnelly D and Buard M C 2011. Community Preferences for Litter Reduction, NEPC Service Corporation
26
Ibid
November 2012
www.nt.gov.au
52