Have Your Say on the Waste Management and Resource Recovery Strategy

Waste Reduction

The 3R’s of Reducing Waste

The State Government has announced and legislated the introduction of a waste levy set at $75 per tonne for waste going to landfill. The levy will start in July 2019.

Accompanying this levy will be the Waste Management and Resource Recovery Strategy for Queensland.

Submissions are invited to Have Your Say on the draft Waste Management and Resource Recovery Strategy. Wildlife Queensland encourages you to seize this opportunity and have your say on this important policy and strategy.

Submissions close: 5.00pm, 5 April 2019.

Please find information below that will help in preparing your submission.


A waste levy is basically an enforcement instrument that may be used to address the challenges of waste management and disposal.

Currently, Queensland is the only state that does not have a waste levy in place and is a contributing factor in waste flowing across the border from New South Wales.

Wildlife Queensland strongly supports the imposition of the waste levy at $75 per tonne and is of a view that this will assist in waste reduction.

Of course, this will not be the first occasion a waste levy has been imposed.

  • A waste levy of $35 per tonne was introduced by the Bligh Government in 2011 to protect the environment and its biodiversity.
  • That levy lasted about 7 months before the Newman Government repealed the legislation in 2012 to support business, according to their reasoning.

Under the previous levy, significant funds raised were to be directed to Queensland’s protected area estate and recycling.

Wildlife Queensland wrote to the Treasurer in 2018 advocating a similar distribution of funds from any waste levy introduced – as was in place for the initial levy unsuccessfully.

It is Wildlife Queensland’s understanding that funds raised from this waste levy will be directed to recycling and waste management.

It is essential that targets for waste reduction are set for the long term with indicative targets to be achieved along the way.

  • Monitoring programs must be put in place to ensure that strategies employed are in fact working and delivering the desired outcomes.
  • While targets need to be realistic, a focus on a readily achievable target is not the preferred option. Ambitious but realistic targets are required.

Wildlife Queensland has concerns about the push in some sectors for the promotion of waste to energy. Other strategies and approaches could be used more effectively to eliminate the need to explore the waste to energy option.

Wildlife Queensland strongly endorses the use of Circular Economy Principles and the Waste Hierarchy to underpin the strategy. Under this model, products are made with as little virgin resources and as much recycled content and, after their use, are discarded in a way that they can be reused or recycled back into their original materials.

Preparing your submission

The following information may assist you in preparing your submission. Putting things in your own words will also give your submission more impact.

  • The document is high-level and strategic and includes little information to make comment on. I/We understand a series of action plans will be developed to provide that detail later this year. I/We, therefore, make these comments, based upon the information that is provided and look forward to the opportunity to comment further when more detailed information is made available.
  • I/We support the introduction of a Waste levy set at $75 per tonne to begin in July 2019. This amount has been set to promote better waste and recycling practices in QLD and to make it uneconomic for cross-border waste transportation. I/We welcome that the government is allocating 70% of the levy funds to resource recovery. However, it is disappointing that this allocation includes providing funds to local government to offset the levy for households for the first 3 years. It was a mistake to exempt the municipal sector from the levy.
  • I/We support the Circular Economy Principles and the application of the Waste Hierarchy to underpin the strategy and note that according to the strategy documents that avoidance, reuse and recycling practices should be prioritised and that landfilling or mixed waste incineration is not considered part of a circular economy.
  • The much-publicised promotion of waste to energy (WtE), particularly mixed waste incineration, ignores the fact that the introduction of these technologies is unnecessary to achieving waste to landfill reduction targets. All targets can be met through improved recovery and recycling services. Mixed waste incineration facilities represent a local pollution and health problem due to emissions, are very expensive and are known to undermine genuine recycling services.
  • Of the information that is contained in the strategy document, we note that in 2017-18 Queensland produced nearly 11 million tonnes of waste, an increase of 19% in the last decade and recycled 4.9 million tonnes. That figure represents about 45% of the waste generated. However, that is an overall estimation and does not reveal the performance of the three waste sectors routinely assessed (municipal, commercial/industrial and construction/demolition). It would have been useful to show the latest figures for these sectors. According to the State Government Recycling and Waste Report (2017) the Municipal sector landfilled 1.8 mt and recovered 832,000 (30.9% recycling rate), the C/I sector landfilled 1.4 mt and recovered 1.3 mt (47.8% recycling rate) and the C/D sector landfilled 2.1 mt and recovered 2.2 mt (50.8% recycling rate).

These figures reveal the relatively poor performance of the municipal sector in waste reduction/recycling.

  • With significant funding being provided for resource recovery and to local government (to offset the levy) we stress that these funds should be tied to key performance outcomes that contribute to the strategy’s goals. Applications for funding should outline project outcomes and deliverables and be able to demonstrate these outcomes as a requirement for funding. Similarly, local government funding should also be invested in identified waste reduction strategies that will actually reduce average household waste figures and make households levy-ready for the future.

How does the Department of Environment and Science plan to monitor, regulate and publicise performance outcomes for programs receiving levy funding?

  • The target set for household waste reduction (25% by 2050) is misleading and is inconsistent with the target for municipal waste to landfill (5%-10% by 2050). The target should be 90-95% reduction by 2050, based upon a benchmark figure of the amount of waste currently going to landfill today. Government figures indicate that to be about 1.8 mt (2016-17). Both waste and recycling targets should be set as they act to verify each other. They are also important, when figures do not correlate, to identify potential data gaps or fraud.
  • The household waste reduction target (stated as 10% by 2025) to achieve a municipal waste disposal target of 45%, is wrong. According to government figures, the actual recycling rate for household waste is just over 30% (not 45% as the strategy infers). That would mean setting a 25% waste reduction target by 2025 for household waste. This is achievable when considering that, according to Brisbane City Council, the average household red bin contains over 70% of materials that should not be there (recyclables, organics and hazardous materials). Better services combined with pricing reduction options to households to reduce waste could remove most of the waste that should not be there from the red bin and achieve the 2025 target.

Key comments in brief:

  1. I/We welcome the strategy and the introduction of a Waste levy. However, we don’t agree that households are being exempted for the first 3 years.
  2. I/We support the setting of targets for waste reductions and increased recycling. Headline targets for 2030 should also be included.
  3. I/We support the use of Circular Economy Principles and the Waste Hierarchy to underpin the strategy.
  4. I/We do not support mixed waste incineration.
  5. The 25% household waste reduction target for 2050 is misleading and should be increased to reflect a more accurate ambition.
  6. To achieve the 2025 household waste-to-landfill target will require a 25% reduction in waste. This is achievable with the right mix of policies and price incentives.

Don’t forget to sign your name and identify yourself or your organisation in your submission.

Where to send your submission




Office of Resource Recovery
Department of Environment and Science
GPO Box 2454
Brisbane  QLD  4001

Deadline for submissions: 5.00pm, 5 April 2019


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