Annex II: Summary and List of Submissions

This annex provides a short summary of the 27 submissions commenting on the draft report. It also lists the names and affiliations of those who made submissions. This summary does not cover every point made in submissions but reflects some of the more important themes. Key issues raised in submissions have been addressed in the report.

Overview

The majority of submissions came from local authorities but some were also received from non-government organisations, private sector companies and individuals. A few of the submissions commented on each target but most concentrated on a few specific targets or key points. Most were broadly supportive of the approach taken in the report and the conclusions reached, but most also commented critically on one or more aspects of the targets.

Interpretation of the targets

A common theme in a lot of submissions was concern about the lack of clarity of the terms used and the way targets might be interpreted. Some submissions criticised the lack of information about the baseline for measuring targets. A few of these submissions also included constructive advice on how uncertainty and lack of clarity might be dealt with.

Responsibility for the targets

Several submissions pointed out that the targets are not always clear about who is responsible for the actions to achieve the target. Recommendations were made that the responsibility should be clearly established.

Statutory basis for targets

Some submissions pointed out that achieving the targets was not mandatory and suggested targets should be backed up with legislation. One expressed frustration at the lack of legislative powers to control the landfilling of electronic wastes and to back up the special waste target.

Information basis for the targets

The limited information base for the setting of targets was recognised in some submissions. Others pointed out that the establishment of targets did not appear to be based on a life-cycle analysis.

Achievement of targets

Several submissions from councils expressed the view that they would find it difficult to achieve some targets. Some of the organic targets were seen as particularly difficult, as were those covering contaminated sites.

Changes to targets

While several submissions accepted the proposal in the draft that no formal changes be made to targets at this time, a few argued that if there was a good reason for a target to change, this change should be made now. One submission pointed out that some targets due to be met by local authorities by December 2005 should be changed to July 2006, the date of the first fully operative long-term council community plans.

Change to the review date

The proposal in the draft report to leave the next review of targets until 2008 was challenged in some submissions as being too far away, especially if any formal changes to targets were going to be left until this date.

Total waste stream

Concerns were also raised that the targets do not account for the measurement of all waste streams in each area, and that focusing on one area, such as landfills, will promote movement into other waste streams. A common theme was the inability to gather data and/or control the private sector that may be in competition with council-run facilities. Councils that have attempted to measure the total waste stream reported that it is difficult, and a nationally recognised methodology was requested.

Monitoring and reporting

Comments on reporting were concerned with the potential variation between local authorities and the inability to compare 'apples with apples'. One submission suggested legislation was needed to provide a solution to this concern. There was support for the proposals in the draft report to develop a national monitoring and reporting system.

Collection of data from the private sector

Some local authorities commented in submissions about their limited ability to obtain data from the private sector. A proposal was made in one submission to require all waste operators to be registered and the waste tracked.

Access to markets

The implications of the targets on the rural community were raised, and whether it would be economically viable to transport waste to the nearest facility. The implications of Targets 9.1 and 9.2 regarding full cost recovery were also raised and how this would be applied to rural communities where costs would be high.

Adoption of Model Trade Waste by-laws

One submission argued that trade waste is not an issue for some councils and so there should be no requirement for all councils to adopt a model by-law. Two submissions said that an appropriate by-law could be designed that was not based (as proposed in the targets) on the model by-law.

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