CONSULTATION PROCESS and additional feedback

1development of the consultation ris

Engagement with key stakeholders began directly following the July 2010 decision by environment ministers to develop a Consultation RIS. In August 2010, the Australian Packaging Covenant Council (APCC) was informed of the RIS development process and has received regular updates at meetings held quarterly.

Initial one-on-one consultation sessions took place between September and November 2010 with the Australian Council of Recycling, Boomerang Alliance, Coca-Cola Amatil, Fosters Group, Keep Australia Beautiful, Lion Nathan Limited, Visy and Westfield Group. There were differing views on whether the RIS should only consider beverage containers or whether, consistent with the EPHC position, it should consider a broader packaging scope. This reflected strong views for and against CDS and the RIS process being seen as a means to determine the costs and benefits of implementing a national CDS. In November 2010, environment ministers noted that they were pleased that a number of stakeholders had been engaged in preliminary discussions on the potential scope of the RIS. Ministers also agreed that “consistent with Ministers’ July 2010 decision, the focus of the RIS should not be solely on beverage containers but more broadly about litter reduction and resource recovery” (EPHC 2010c).

A stakeholder workshop in Sydney on 2 December 2010 ensured broad input at an early stage, with around 50 representatives from industry, government and environment groups attending. The workshop sought further data on packaging waste and its impacts, and input on related market failures to inform the draft problem statement. A key finding was that there is limited data on packaging waste in Australia and the sources of packaging related market failures are not all identified, although knowledge of environmental impacts and feasible options to address those impacts is sound. Little additional data was received.

Some stakeholders provided further written feedback: the Australian Packaging Covenant, Local Government and Shires Association of New South Wales, National Association of Retail Grocers of Australia, National Packaging Covenant Industry Association, Revive Recycling and Total Environment Centre (also a member of Boomerang Alliance).

A second stakeholder workshop in Melbourne on 18 July 2011, with around 40 representatives from industry, government and environment groups, refined and scoped the regulatory options for consideration. Stakeholders were invited to submit detailed proposals of options for inclusion in the RIS. The Boomerang Alliance, in their development of option 4a (Boomerang Alliance Container Deposit Model), and the Packaging Stewardship Forum (in partnership with Keep Australia Beautiful) in their development of option 2b (Industry Packaging Stewardship), worked closely with officials and the consultants. Further consultation also took place with the Australian Packaging Covenant, Clean Up Australia (also a member of Boomerang Alliance), the Local Government and Shires Association of New South Wales and the National Packaging Covenant Industry Association.

FORMAL stakeholder consultation period

The Consultation RIS was released on the SCEW website on 7December2011 for a four month period. Eleven public consultation sessions were held in capital cities and three regional centres during February and March 2012. In total around 250 people attended the sessions. Each session consisted of a two hour public forum, including a presentation on the economic analysis, followed by 30 minute bilateral meetings with interested stakeholders.

The closing date for stakeholder submissions was 30 March 2012. A total of 197 substantive submissions were received, including eight confidential submissions and four late submissions. Submissions were received from a diverse range of stakeholders (see Figure 1). A list of stakeholders who provided non-confidential submissions and a Consultation Summary Report is available on the SCEW website (see Attachment J)[1]. The majority of substantive submissions (94per cent) did not discuss the details of specific options in the Consultation RIS, instead stating overall positions and preferences (Attachment J, p.4). In addition, around 3,000 campaign submissions were received, which comprised a pro forma email generated online and expressed support for a national CDS.

FIGURE 1: COMPOSITION OF SUBSTANTIVE SUBMISSIONS BY STAKEHOLDER TYPE

Source: Consultation RIS Consultation Summary Report, Attachment J.

2decision ris consultation

On 24 August 2012, environment ministers agreed to develop a Decision RIS to undertake a more detailed analysis of the options, including regional and other distributional impacts. Stakeholder feedback on the Consultation RIS also led to environment ministers agreeing to the inclusion of three new options in the Decision RIS:

  • Option 2d: Beverage Container Stewardship—reflecting interest in a non-CDL approach to beverage sector product stewardship
  • Option 2e: Extended Australian Packaging Covenant—reflecting strong industry support for the current APC co-regulatory model
  • Option 4c: South Australian Container Refund Model—reflecting strong support for the SA model of CDS.

Environment ministers stressed the importance of senior officials consulting with key stakeholders on the design elements of new options and modelling assumptions (SCEW 2012b, p. 1). Two stages of consultation were subsequently conducted during development of the Decision RIS.

STAGE 1

Meetings with key stakeholders in November and December 2012 refined and confirmed design details of the stakeholder options (2b—Industry Packaging Stewardship and 4a—Boomerang Alliance CDS) and informed the development of new options (2d, 2e and 4c). Stakeholders consulted during Stage 1 were:

  • Australian Beverages Council
  • Australian Food and Grocery Council
  • Australian Local Government Association
  • Australian National Retailers Association
  • Boomerang Alliance
  • Keep Australia Beautiful
  • National Packaging Covenant Industry Association
  • Packaging Council of Australia
  • Packaging Stewardship Forum.

Additional written feedback was received from the Australian Food and Grocery Council/Packaging Stewardship Forum, Boomerang Alliance, Keep Australia Beautiful, and the National Packaging Covenant Industry Association.

STAGE 2

A stakeholder workshop on 14 March 2013 in Sydney discussed distributional impacts and key modelling assumptions for all Decision RIS options and the base case. In total, 40 stakeholders attended the workshop and a broad range of stakeholder groups were represented (see Figure 2).

FIGURE 2: COMPOSITION OF STAKEHOLDER ATTENDANCE AT DECISION RIS WORKSHOP

Source: Decision RIS workshop attendance records.

Marsden Jacob Associates (MJA) (working with Warnken ISE) provided an overview of the proposed modelling approach for the CBA and received stakeholder feedback on key assumptions.

Additional submissions from the Boomerang Alliance, National Packaging Covenant Industry Association, Vinyl Council of Australia, Western Australian Local Government Association and two confidential submissions were passed to MJA for use in finalising the assumptions for the CBA.

3ADDITIONAL DECISION RIS FEEDBACK

Some submissions identified the need to issues in the current kerbside system, through investment in updated sorting and processing technology to improve recycling rates and glass recovery from co-mingled recyclables. While the Decision RIS recognises that improvements can be made in both municipal and commercial/public place settings, the strong public place consumption driver of litter and identified barriers to recycling in the C&I sector in particular indicate the impacts are greatest in the away-from-home sector.

A submission from the tobacco industry noted the importance of nationally consistent antilittering enforcement to underpin education and infrastructure efforts. The options modelled in the DRIS do not include specific national anti-littering regulations, however under all the options it is expected that a national approach to litter reduction would be strengthened.

CONTAINER DEPOSIT SCHEMES

A number of individuals who favoured CDS indicated that packaging producers and brand owners, rather than consumers, should bear the costs of such a scheme.

Submissions from local government were mixed in relation to CDS. One third of state/local government submissions (including local government representative organisations) supported at least one of the CDS options (SCEW 2012a, p. 10), albeit with many noting that the costs of a CDS should be borne by the packaging industry rather than ratepayers. The Local Government Association of Queensland submission put a contrary view, based on a detailed CBA of the potential impacts of CDS on Queensland councils, which would bear higher costs than estimated in the Consultation RIS (LGAQ 2012). Local government attendees at the Albury and Darwin public forums also expressed concerns about the potential negative impacts of a CDS on councils in relation to existing waste services contracts.

The majority of industry submissions did not support CDS options, considering them expensive and leading to increased regulatory burden on the beverage industry. Submissions also suggested that the costs associated with a CDS would result in higher consumer costs, which would ultimately impact employment in the beverage and grocery supply chain. As mentioned in Chapter 5, the Decision RIS modelling has accounted for the cost impacts of CDS options raised by stakeholders, based on observable evidence, but has not analysed claims of net job creation or loss under the options.

One waste and recycling industry submission commented that CDS options would require new infrastructure that competes with existing kerbside and MRF infrastructure and stated a preference for policies that promote investment in new infrastructure which builds upon existing assets.

A submission from the NT Government supported CDS and said that costs would be lower for CDS options if they were modelled on the industry-based models applied in SA and the NT. However, a confidential submission noted that the introduction of the NT CDS has resulted in fewer recycling materials being collected from some remote communities due to existing free back loading arrangements being replaced with commercial arrangements.

A submission from the SA Government identified benefits of its CDS, including high beverage container recycling, reduced beverage container litter, co-benefits of increased recycling of other products and providing income to disadvantaged people and community groups. It noted that it is unlikely that the other options presented in the Consultation RIS could match the beverage container recycling rate that can be achieved with a CDS. This assumption was accepted based on evidence of SA scheme performance, albeit with the associated assumption that other options achieve recycling outcomes across a broader range of packaging materials. One confidential submission from the recycling industry described the SA CDS as unnecessarily complex and said there are high costs associated with the scheme as a result.

[1]See: