WASTE MANAGEMENT BUDGET SUBMISSION INCORPORATING A DISCUSSION ON THE SOLID WASTE LEVY AND THE NEED TO REVIEW THE ZERO WASTE SA ACT 2004 TO MINISTER FOR ENVIRONMENT AND CONSERVATION LOCAL GOVERNMENT ASSOCIATION OF SOUTH AUSTRALIA INC. DECEMBER 2008 DME 44669 Page 1 of 14 1. INTRODUCTION The Local Government sector already plays a key role in the management of the waste generated by South Australian households and industry. The sector has demonstrated its commitment to continuous improvement of its management of waste through a number of strategies, including: adoption of the 3-bin kerbside collection system for household collection; encouragement of increased recycling; participation in pilots to achieve diversion of food waste from landfill; rationalisation of landfills; and improvement of remaining landfills to meet acceptable environment standards. Furthermore, the sector has demonstrated its willingness to collaborate through the creation and maintenance of Regional Subsidiaries which enable economies of scale to be achieved in waste collection and processing. Inter-Council collaboration also exists in respect of joint tendering for outsourced waste management services and planning by Rural and Regional Councils. The objectives that Local Government has set for itself are entirely consistent with the targets in South Australia’s Strategic Plan regarding reduction of waste to landfill and reduction of greenhouse gas emissions. The State Government and the Parliament have recognised the importance of the Local Government sector through its inclusion on the Boards of the Environment Protection Authority (‘EPA’) and Zero Waste SA (‘ZWSA’), key Local Government people. Although the Local Government sector is proud of its contribution to improved waste management in South Australia, it recognises that more needs to be done. This submission emphasises the increasing financial commitment being made by the Local Government sector to waste management and also identifies the areas in which more can be done but which are beyond the financial capacity of the sector. More particularly, the submission outlines the areas that funding from the State Government should be released to the Local Government sector. This will enable Local Government in collaboration with the State Government to continue to improve waste management across South Australia, consistent with the State’s published targets. In the main, this submission assumes that the funds will need to be released from the Waste to Resources Fund. This Fund is fuelled by monies collected from the solid waste levy applied to each tonne of waste deposited in landfill. Local Government is a significant contributor to the Fund. However, the submission acknowledges that there could well be alternative funding sources for some of the identified strategies. Finally, the submission opens up discussion about the future direction of the solid waste levy, the potential impact on the Waste to Resources Fund and distributions from that Fund. This leads to the conclusion that a review of the Zero Waste SA Act would be timely. DME 44669 Page 2 of 14 2. EXECUTIVE SUMMARY This submission demonstrates that Local Government is making a significant and increasing commitment to the management of waste in South Australia with the sector’s annual expenditure on waste management now exceeding $100 million per year. Furthermore, this has increased by more than $22 million (or 30% over a five-year period) as Local Government has committed to environmentally sound strategies including the widespread adoption of the 3-bin kerbside collection system, substantially increased recycling, diversion of waste from landfill and landfill improvement and rationalisation. At the same time, there is much more to be done. Yet the revenue collected by the State Government from the solid waste levy including substantial ongoing contributions from the Local Government sector continues to increase. One outcome of this is the increasing balance in the Waste to Resources Fund. This submission requests that the Minister for Environment and Conservation, as part of the 2009-10 State Government budget process, allocate over the five-year period to 2013-14 an additional $30.75 million presumably – but not necessarily - from the Waste to Resources Fund to enable, over that five-year period: the adoption by 400, 000 South Australian households of the facilities needed to direct food waste from the residual waste stream; the implementation of Regional Waste Management Strategies; all landfills operated by Councils throughout the State and no longer required to be closed in an environmentally secure way; all remaining landfills operated by Councils throughout the State to be raised to a level necessary to meet agreed environmental standards; improved management of problematic waste including e-Waste and hazardous waste; and increased capacity to deal with illegal dumping. In making this request, the Local Government Association (“LGA”) acknowledges that a number of the above items are the subject of existing and planned commitments including commitments from the Waste to Resources Fund. The LGA commends and supports such decisions but asks that the Minister consider accelerated programs of activity and funding allocations which match this acceleration. This submission also contemplates the future of the solid waste levy and expresses concern that as the disposal of waste in landfill decreases, the Government may decide to continue to increase the levy to maintain a level of income. Should this happen, the burden on Local Government created by the most recent increase will continue. Moreover, as the opportunities for the municipal sector to contribute to the State’s strategic targets may eventually reach a plateau, the benefits to Local Government through distributions from the Waste to Resources Fund could well decline relative to other sectors. With this in mind, the LGA seeks a firm commitment from the Minister that it will be directly involved in all future considerations by the Government in respect of the solid waste levy and its application. This commitment should, as is required by Section 18 of the Zero Waste SA Act, extend to an involvement by the LGA in any considerations as part of ZWSA’s mid term review of the Waste Strategy expected to be undertaken in early 2009. DME 44669 Page 3 of 14 In addition, the LGA draws to the attention of the Minister that the decision to increase by 100% the solid waste levy from 1 July 2007 was made without consultation with the LGA. This was in direct contravention of the State-Local Government agreement that requires the State Government to consult with Local Government on any budgetary matters that will impact on Local Government. Of immediate relevance is the requirement of the Zero Waste SA Act (Section 17(4)) that the Minister review the adequacy of the amount of the solid waste levy at least annually. The LGA seeks a commitment from the Minister that the State-Local Government agreement will be honoured in the 2009-10 State budget process and all subsequent reviews. Finally, the LGA submits that it is timely for the Minister to consider a review of the Zero Waste SA Act. The Act has been in place for almost 5 years and has generally served South Australia well. However, much has been learned in the past 5 years and the review of the State’s initial waste strategy is required by the Act in the near future. The LGA understands that a mid-term review of the first waste strategy is planned for 2009. The LGA supports this mid-term review and expects to be consulted as part of the review process consistent with the requirements of Section 18(4) of the Zero Waste SA Act. The LGA contends that coinciding with this mid-term review should be a review of the Zero Waste SA Act. This would provide a sound platform for the first full review of the waste strategy and the development of the subsequent strategy. The LGA is keen to be involved in a review of the Act and looks forward to the Minister’s positive consideration of this proposal. DME 44669 Page 4 of 14 3. FINANCIAL TRENDS The costs incurred by Local Government on waste management continue to escalate. Analysis of Local Government Grants Commission data for the five financial years to 200607 (the most recent five-year period for which data are available) demonstrate this trend clearly. YEAR 2002-03 2003-04 2004-05 2005-06 2006-07 TOTAL OPERATING EXPENSES $79.88 million $80.77 million $93.80 million $94.10 million $102.29 million In that five-year period, there has been upward movement in all of the components of the total cost but of particular significance is the trend in domestic waste collection and disposal costs from $39.49 million in 2002-03 to $50.95 million in 2006-07. Similarly, the recycling costs reported have increased from $6.61 million in 2002-03 to $12.85 million in 2006-07. These figures clearly demonstrate the commitment of the Local Government sector to responsible waste management including the commitment to recycling, consistent with South Australia’s Strategic Plan targets relating to reduction in waste to landfill and greenhouse gas reduction. Estimates of likely future costs also indicate a continuing upward trend despite the efforts of Councils through improved collaboration and improved contract management. At the same time, the revenue collected by the State Government from the solid waste levy has been increasing as has the balance of unspent funds in the Waste to Resources Fund established by the Parliament as part of the legislation which also established ‘Zero Waste SA’ (the Zero Waste SA Act (2004)). This Fund receives moneys raised by the State Government via the solid waste levy imposed on each tonne of waste deposited in landfill. Local Government has been a major contributor to this Fund. Although the solid waste levy increased on July 1, 2007 the extra revenue generated was used by Government to meet some of the administrative costs of the Environment Protection Agency previously met by the State’s Consolidated Account. The main objections of Local Government to the levy increase were that it occurred without consultation with Local Government as is required by the State-Local Government agreement and that the extra revenue was not allocated directly to improved waste management strategies. In addition, anecdotal evidence suggests that illegal dumping has increased, requiring Local Government to meet the costs of extra clean up and disposal. This, coupled with other evidence that suggests the non-municipal sectors have used stockpiling strategies to avoid the higher levy, leads the Local Government sector to contend that it has faced a disproportionate increase in costs associated with the levy increases. The 2007-08 Business Plan of Zero Waste SA indicated that, by 2009-10, the balance in the Waste to Resources Fund was expected to have increased to $14.96 million with income exceeding expenditure by more than $3 million per year. DME 44669 Page 5 of 14 The 2008-09 Business Plan did not project the Fund balance into the years ahead but did indicate that the Fund balance as at 30 June 2008 was likely to be even higher than that anticipated in the previous year’s Business Plan. Moreover, the 2008-09 Business Plan maintained a policy position of income exceeding expenditure by more than $3 million. Based on the Local Government sector’s contention that the municipal component of waste management has contributed substantially to this accumulation, the sector considers that continued and increased expenditure to support improvements in the municipal sector’s role in waste management can be easily justified. In making this claim, Local Government acknowledges that the Waste to Resources Fund has provided a significant stimulus to important initiatives such as the introduction of the 3bin kerbside collection system, the building of infrastructure such as transfer stations and the development of regional plans. Local Government also acknowledges that there is a continuing allocation in the 2008-09 Business Plan to activities related to improvement of municipal waste management. The Local Government Association believes that now is the time to build on that excellent foundation as proposed in Section (4) which follows. DME 44669 Page 6 of 14 4. SPECIFIC INITIATIVES PROPOSED AND ASSOCIATED BUDGET REQUESTS This submission proposes, and requests, that funds be released by the State Government, presumably but not necessarily from the Waste to Resources Fund in the State Government’s forthcoming 2009-10 budget and in the four subsequent financial years for the following significant items: Extension and Consolidation of the Food Waste Pilot; Assistance with Closure of Landfills; Assistance to Secure an Acceptable Environmental Standard for the Remaining Landfills; Implementation of Regional Waste Management Strategies; Improved Management of Problematic Wastes including e-Waste and hazardous waste; Increased Capacity to deal with Illegal Dumping. In addition, the submission supports and builds on existing initiatives being funded by the Waste to Resources Fund particularly the continuation of the funding for transfer stations which should be maintained at current levels for the next five years. Each of the proposals referred to above will now be discussed in turn. 4.1 Food Waste Pilot With assistance from the Waste to Resources Fund, ten Councils have committed to a pilot of reducing the quantity of food waste being placed in the residual waste stream. In total, the pilot will cover approximately 16, 000 households. The Local Government sector acknowledges the assistance of ZWSA in facilitating the pilot. Although the cost of the pilot is significantly greater than can be expected once the system is fully adopted (as a result of the understandable commitment to regular audits and an overall evaluation of the pilot), the Local Government sector is fully confident that the pilot will succeed. This confidence is based on the results of the pilot conducted in the Burnside Council several years ago and the increasing enthusiasm within the community for reducing waste to landfill and recycling more generally. Local Government believes that budget planning for 2009-10 and beyond should assume that the pilot with ten Councils will prove successful and should provide for an extension and consolidation immediately after the pilot period has concluded. The Local Government Association proposes therefore that in 2009-10: the pilot conducted by the ten initial Councils be extended in those Council areas so as eventually to include all households within those Councils’ boundaries; and additional Councils covering up to 30,000 households be invited to commence the adoption of the food waste system. This would form the basis of progressive implementation at the rate of 80,000 households per year for a five-year period. Assuming that: the cost per household of full adoption would be approximately $15 per year – this was the estimate resulting from the Burnside Council pilot and is subject to confirmation in the current pilot; DME 44669 Page 7 of 14 the additional number of households to be involved in 2009-10 in the pilot ten Councils would be approximately 50, 000; the number of households to be involved in the additional Councils proposed would be approximately 30, 000; and each Council be provided with the funds needed to implement the food waste diversion for the first two years and thereafter to meet the costs themselves, the Local Government Association proposes that $1.2 million be allocated from the Waste to Resources Fund in 2009-10 for this purpose increasing by this same amount for the following year and then maintained. The aim should be to have 400, 000 South Australian households committed and enabled to achieve food waste diversion from landfill by 2013-14. The estimated budgetary commitment is as follows: YEAR 2009-10 2010-11 2011-12 2012-13 2013-14 2014-15 BUDGETARY COMMITMENT $1.2 million $2.4 million $2.4 million $2.4 million $2.4 million $1.2 million Obviously the pilot will also test whether savings can be made as a result of reducing the frequency of residual waste collections and the Local Government sector will work with ZWSA to achieve whatever savings are possible, consistent with community reaction to the possibility of reduced collection frequencies. The above table is based on an assumption that implementation will be managed at the rate of 80,000 households per year. Opinions vary as to the speed of take up with a very strongly held view within Local Government that community pressure may see faster take up in the earlier years. If that occurs, the total amount required will not be changed but there may be a different allocation between the respective years. 4.2 Assistance with Landfill Closures Zero Waste SA has been committing significant funds in recent years from the Waste to Resources Fund to the establishment of infrastructure such as transfer stations as an aid to the reduction of waste to landfill. This policy is strongly supported and Local Government supports the continuance of this strategy for the five year period at the same level in the 2008-09 ZWSA Business Plan. The Local Government sector’s aim is to achieve the closure of significant numbers of landfills, particularly in Rural and Regional South Australia where the Councils generally own and operate the landfills. However, to this point, funds from the Waste to Resources Fund have not been made available to assist Councils to close landfills. The use of funds for this purpose is seen in some quarters as not falling strictly within the charter prescribed for the Waste to Resources Fund. To the Local Government sector this position seems like an unhelpful distinction leading to the inevitable question: “why would the Waste to Resources Fund be used to assist in making large numbers of landfills redundant but not be able to be used to ensure that they are redundant (and therefore closed)?”. DME 44669 Page 8 of 14 In fact, the Charter for the Waste to Resources Fund as prescribed in section 17 of the Zero Waste SA Act (2004) empowers the Minister to apply the Fund to activities consistent with the waste hierarchy defined in that Act. One element of the waste hierarchy is ‘disposal of waste in an environmentally sound manner’. Moreover, Section 19 of the Act “requires Zero Waste SA and the Environment Protection Authority to co-ordinate their activities for the development and implementation of waste strategies”. Estimates are still being compiled through Regional Planning as to the number of landfills that might be closed and the total cost of closure. If the number of closures is of the order of 120 and the average cost of closure is $100, 000, a five-year program would require $12 million in total at the rate of $2.4 million a year to be allocated. Clearly, the needs of each landfill will be treated on its merits and the above sum is for budgetary purposes only. Should the Minister consider that this (and the funding requested in 4.3 below) is an inappropriate use of the Waste to Resources Fund, the LGA contends that the funding should reasonably be provided from the 50% portion of the solid waste levy revenues which are assigned to the Environment Protection Agency. 4.3 Assistance with Securing Acceptable Environmental Standards for Remaining Landfills Consistent with the discussion above, the Local Government sector sees no reason for the funds collected from the solid waste levy not to be used to ensure that remaining landfills meet environmental standards. This is all part of the same overall picture. As with the number of landfills to be closed, estimates are still being compiled as to the number of remaining landfills and the average cost to achieve compliance with environmental standards. Assuming that the number remaining is approximately 40 and that the average cost to achieve compliance is $150, 000, a five-year program would require $6 million in total at a cost of $1.2 million a year to be allocated. As with the landfill closures, this amount should be regarded as a budgetary item with the actual amount depending on case by case needs. The Local Government sector understands its responsibilities in ensuring that remaining landfills meet acceptable environmental standards. It also notes that once the standards of a landfill have been raised to an acceptable level, there is an obligation on the “owning” Council to manage the landfill in such a way as to maintain the standards. Therefore, Local Government would not object if funding under this item: was established on a shared basis with contributions from the “owning” Councils as occurs currently with the funding of transfer stations from the Regional Implementation Program; and required a demonstrated and continuing commitment from the Councils concerned that they have the capacity, the expertise and the resources to manage the landfill appropriately. 4.4 Implementation of Regional Waste Strategies Regional Waste Strategies are the key to sound, collaborative approaches to waste management over the coming decades. DME 44669 Page 9 of 14 They are also key to ensuring that the strategies to achieve soundly based landfill rationalisation approaches are developed and implemented. The Local Government sector acknowledges the assistance of ZWSA in the progress made to date in the development of the strategies. However, it is time to ensure that the strategies are converted to implementable action plans in a timely manner. An increased allocation of $100,000 for each of the 2009-10 and 2010-11 years is proposed to assist the sector to develop these action plans. This proposed allocation should also be made in concert with a policy decision regarding funding for landfill rationalisation as proposed in 4.2 and 4.3 above because many of the actions flowing from the strategies revolve around the future of landfills. 4.5 Improved Management of Problematic Waste including e-Waste and Hazardous Waste Again, the Local Government sector acknowledges and supports the efforts of ZWSA in this area. Local Government also accepts that many of the preventative solutions to problematic waste require national approaches and the sector is aware of ZWSA’s efforts to bring about national strategies. In the meantime, problematic waste such as e-Waste and hazardous waste are increasing problems for the municipal sector and there is a strong case for short term initiatives to assist with collection and disposal of this waste. Local Government is aware that ZWSA is giving consideration to the establishment of a number of drop-off points to enable the community to dispose of this waste more easily. This is supported. However an increased allocation of $100,000 for all five years to 2013-14 to enable Councils to increase the frequency with which they collect problematic waste is also requested to complement this approach. 4.6 Increased Capacity to Deal with Illegal Dumping The Local Government sector appreciates that ZWSA’s current approach is to investigate new technologies that can detect illegal dumping with the aim of preventing it. It supports the allocation in the 2008-9 ZWSA Business Plan for this purpose. That activity should continue. Meanwhile, Local Government is required to devote resources to cleaning up and disposal of increasing quantities of illegally dumped waste (often on roadsides). Illegal dumping could hardly be described as environmentally sound disposal of waste and because the clean up role of Local Government enables sound disposal to take place, the sector believes that it would be reasonable for $250,000 per year to be made available to Councils for this purpose. In the first instance, these funds would be made available to the “urban fringe” Councils, particularly those in the Adelaide Hills which have experienced the most severe instances of illegal dumping. In addition, the sector will continue to support all efforts by ZWSA to improve detection and prevention activities. DME 44669 Page 10 of 14 4.7 Summary Based on the discussion in Sections 4.1 to 4.6 above, the Local Government sector submits to the Minister that for the five-year period from 2009-10 to 2013-14 inclusive, the following budgetary allocations should be made available to Local Government. * YEAR FOOD WASTE LANDFILL CLOSURE LANDFILL COMPLIANCE REGIONAL STRATEGIES PROBLEMATIC WASTE ILLEGAL DUMPING TOTAL 2009-10 $1.2 million $2.4 million $1.2 million $0.1 million $0.1 million $0.25 million $5.25 million 2010-11 $2.4 million $2.4 million $1.2 million $0.1 million $0.1 million $0.25 million $6.45 million 2011-12 $2.4 million $2.4 million $1.2 million $0.1 million $0.25 million $6.35 million 2012-13 $2.4 million $2.4 million $1.2 million $0.1 million $0.25million $6.35 million 2013-14 $2.4 million $2.4 million $1.2 million $0.1 million $0.25 million $6.35 million Note: based on the discussion in Section 4.1, an additional $1.2 million would be required in 2014-5 to complete the commitment In making this submission, the Local Government Association emphasises again that when the solid waste levy was increased from 1 July 2007, the State Government allocated $5 million per annum of the increased revenue to meet the administrative costs of the Environment Protection Authority. In the view of the Local Government Association, this allocation was not appropriate and the costs included in the table above do no more than redress that situation. DME 44669 Page 11 of 14 5. DISCUSSION ON SOLID WASTE LEVY IMPLICATIONS AND THE NEED TO REVIEW THE ZERO WASTE SA ACT (2004) The State Government’s current policy position – which includes a solid waste levy, a Waste to Resources Fund, a State Government entity in Zero Waste SA led by a Board which distributes funds for initiatives with clear environmental objectives – has several key aspects to it viz: that the more that individuals and entities have to pay for the disposal of waste in landfill, the more inclined they will be to pursue more environmentally sound approaches; and that the implementation of initiatives which enable individuals and entities to adopt alternative approaches to disposal in landfill will come at a cost and that it is reasonable for assistance in meeting that cost to be provided via the funds accumulated from the fees imposed on disposal in landfill. We have now had a number of years of experience with operations under this policy position. Although the objectives of the policy are basically sound, there have been significant, unintended consequences for the Local Government sector as follows: as the cost of disposal of waste in landfill has increased, individuals and entities have not always turned to environmentally sound alternatives. Stockpiling and illegal dumping has increased and often Local Government has been required to meet the additional costs of clean up and disposal. This burden has been carried disproportionately across the State with fringe area Councils, particularly those in the Adelaide Hills being worst affected; the distribution of the South Australian population between metropolitan, rural and regional Councils means that the extent of the solid waste levy collections attributable to metropolitan area residents far exceeds the collections elsewhere. However, the funding needs are potentially greatest in rural and regional areas where large numbers of environmentally unsound landfills have traditionally existed; perhaps in an effort to avoid significant cross subsidisation or perhaps because the title of the Fund to which solid waste levy collections are applied is so specific (the Waste to Resources Fund), the outcome seen by the Local Government sector is a significant mismatch in the application of the funds accumulated as a result of the solid waste levy compared to need within the sector. This budget submission highlights that fact and points out the apparent contradiction with Section 19 of the Zero Waste SA Act which requires co-ordination of activities between ZWSA and the Environment Protection Authority; because large metropolitan Councils have significantly more scope and flexibility in their budgets than smaller Councils, the impact of the solid waste levy on the annual Council rates paid by each metropolitan area ratepayer is less significant. What is more significant is the positive attitudinal change to waste which has permeated the community and which has led to greater commitment to recycling and waste avoidance. The Local Government sector is fearful that with continuing commitment of the community to diversion of waste from landfill, the State Government will feel compelled to apply further increases to the solid waste levy at least in part to maintain a level of revenue necessary to meet those administrative costs of the State Government agencies which are funded by the levy revenues. This will particularly be so if the policy position regarding expenditure on landfill closure and rationalisation is maintained and the expenditure from the Waste to Resources Fund continues to be significantly less than the revenue received. DME 44669 Page 12 of 14 Related to this concern is the evidence from the Hyder Report commissioned by Zero Waste SA in 2007 that experience elsewhere suggests that only when a solid waste levy reaches approximately $50 per tonne will there be a significant correlation between the levy and waste disposed in landfill. This leads to an understandable fear within Local Government that the Local Government sector will continue to bear an extremely high financial burden as a result of continuing levy increases. As troubling as that prospect is, there is an associated fear that the opportunities for the municipal sector to contribute to the State’s targets will plateau and that this will lead to lower distributions to Local Government relative to other sectors from the moneys collected via the levy. With this in mind, the LGA seeks a firm commitment from the Minister that it will be directly involved in all future considerations by the Government in respect of the solid waste levy and its application. This commitment should, as is required by Section 18 of the Zero Waste SA Act, extend to an involvement by the LGA in any considerations as part of ZWSA’s mid term review of the Waste Strategy expected to be undertaken in early 2009. In addition, the LGA draws to the attention of the Minister that the decision to increase by 100% the solid waste levy from 1 July 2007 was made without consultation with the LGA. This was in direct contravention of the State-Local Government agreement that requires the State Government to consult with Local Government on any budgetary matters that will impact on Local Government. Of immediate relevance is the requirement of the Zero Waste SA Act (Section 17(4)) that the Minister review the adequacy of the amount of the solid waste levy at least annually. The LGA seeks a commitment from the Minister that the State-Local Government agreement will be honoured in the 2009-10 State budget process and all subsequent reviews. Finally, the LGA submits that it is timely for the Minister to consider a review of the Zero Waste SA Act. The Act has been in place for almost 5 years and has generally served South Australia well. However, much has been learned in the past 5 years and the review of the State’s initial waste strategy is required by the Act in the near future. The LGA understands that a mid-term review of the first waste strategy is planned for 2009. The LGA supports this mid-term review and expects to be consulted as part of the review process consistent with the requirements of Section 18(4) of the Zero Waste SA Act. The LGA contends that coinciding with this mid-term review should be a review of the Zero Waste SA Act. This would provide a sound platform for the first full review of the waste strategy and the development of the subsequent strategy. The LGA is keen to be involved in a review of the Act and looks forward to the Minister’s positive consideration of this proposal. DME 44669 Page 13 of 14 6. CONCLUSION Consistent with the expectations of the Parliament in its passage of the Zero Waste SA Act (2004), the Local Government sector wishes to continue the strong collaborative relationships which have been developed between the State and Local Government in the environmentally sensitive management of waste. The commitment of the Local Government sector to a program of continuing improvement is amply demonstrated by the increasing costs to the sector of responsible waste management. However, Local Government has reached the limits of what it can fund from its own resources. At the same time, the State Government has been collecting more and more revenue from the solid waste levy with substantial and increasing collections from the municipal sector. These increased revenues are partly being used to fund activities of the State Government previously funded from Consolidated Revenue and partly to increase the unspent balances in the Waste to Resources Fund. As a result, opportunities to accelerate the achievement of key environmental targets to which both State and Local Government are committed are at risk. With judicious allocation of these funds, the targets are within reach. This is also an ideal time for the Minister to commission a review of the Zero Waste SA Act 2004 in conjunction with the planned mid-term review of the waste strategy. This would ensure a highly co-ordinated approach to the first formal review of the waste strategy as required by the Act. The Local Government Association looks forward to the support of the Minister in respect of this submission and commits to constructive working with the State Government as South Australia continues to lead the way in key strategic aspects of waste management. DME 44669 Page 14 of 14