Article V. 4 Comment on Each Target

Target 1.1

Local authorities will report their progress on waste minimisation and management for their annual report in 2001/02 and quantitatively on an annual basis from then onwards.

Progress towards the implementation of the target

This target recognises the importance of local authorities providing for and reporting on the local implementation of the New Zealand Waste Strategy in their annual plans and annual reports. The target assumed a start on this reporting in the annual reports for 2001/02 with the inclusion of qualitative information, and councils subsequently including quantitative information. The comments that follow are based on an analysis of annual plans and reports provided to the Ministry by councils.

Issues arising from the implementation of the target, including barriers to implementation

A delay in releasing the strategy until March 2002 left councils with little time to consider the implications of this target for their 2001/02 annual reports. The Ministry appreciates that councils had limited time to act on the first part of this target. Most councils, however, included some reference to waste management in their annual reports but did not explicitly comment on the local implementation of the strategy. Councils require suitable systems of measurement if they are to report quantitatively. Many have systems in place, and the revised Solid Waste Analysis Protocol (Ministry for the Environment, 2002c) provides a standard system for measuring solid waste.

Targets 1.2 and 1.7

By December 2005, all regional councils will ensure that new or renewed industrial resource consents include a recognised waste minimisation and management programme and will report on the percentage of all consents under their jurisdiction that have such a clause.

By December 2010, all regional councils will ensure that at least 25 percent of all existing industrial resource consent holders have in place a recognised waste minimisation and management programme.

Progress towards the implementation of the target

Progress towards these targets is constrained because including such a requirement in resource consents is considered to be ultra vires. Waikato Regional Council has included a similar target that avoids this constraint in its regional waste plan. This matter is discussed further below.

Issues arising from the implementation of the targets, including barriers to implementation

The general intent of these targets is clear: programmes that minimise waste and manage it effectively, can avoid or mitigate environmental effects. There is, however, a question as to whether such programmes can be required where the waste minimisation and management programme is not directly linked to the mitigation of the discharge being consented. The Resource Management Act 1991 (under which resource consents are granted) is concerned with the effects of contaminants on the environment. This point was discussed in the July 2002 issue of the journal of the Resource Management Law Association (Brodnax and Milne, 2002). The article argues that, provided the industrial facility is economically efficient, and adequately avoided, remedied or mitigated any environmental effects from its discharge, any opportunities to minimise or better manage wastes are not legally relevant.

Regional councils need to ensure that any action they undertake to implement these targets is not ultra vires. We note, however, that Environment Waikato, in its draft regional waste strategy, has adopted a regional target that implements the intent of the targets above but without directly linking waste minimisation programmes to resource consents. Environment Waikato's target is "By December 2010, 25 percent of companies in the region will have waste minimisation and management programmes in place". This avoids the ultra vires problem, but relies on voluntary suasion and is therefore less likely to be achievable.

Target 1.3

By December 2005, at least 10 major businesses will be participating alongside central and local government in developing and promoting waste minimisation programmes within their sector.

Progress towards the implementation of the target

Several private sector initiatives suggest that this target will be met before 2005. These initiatives include those taken by the New Zealand Business Council for Sustainable Development, Plastics New Zealand and the New Zealand packaging industry. The 'pathfinding' organisations participating in the development of sustainable development strategies initiated at the Redesigning Resources Conference held in June 2000 also include waste minimisation programmes. Extended producer responsibility (EPR) programmes, such as the used oil recovery programme and the take-back programmes for mobile phones sponsored by Telecom and Vodafone, are other business initiatives that will reduce waste.

Issues arising from the implementation of the target, including barriers to implementation

There is considerable opportunity for businesses to voluntarily develop and adopt waste minimisation programmes, and there is often a good business case for this action. There are, however, limits to voluntary approaches. EPR programmes relying on a voluntary approach may encourage some companies to 'free ride' (take advantage of the programme but not pay their share of the costs). Some companies may not participate in programmes because avoiding doing so gives them a commercial advantage. However, those not participating can undermine the programme as a whole because the 'playing field' is not level for all players. These issues have been dealt with in some jurisdictions through legislative back-stopping that allows programmes to be regulated if voluntary approaches fail. The Ministry for the Environment is currently working through these issues in considering appropriate policy for the management of used oil and used tyres.

Target 1.4

Ninety-five percent of the population will have access to community recycling facilities by December 2005.

Progress towards the implementation of the target

Information gathered by the Ministry in 2003 indicates that about 90 percent of the population already has ready access to recycling facilities. The Ministry expects that the target of 95 percent can be met by December 2005.

Issues arising from the implementation of the target, including barriers to implementation

Some councils have expressed concern that it is unclear what having "access to recycling facilities" means in practice. The intent is that most people should have reasonably accessible access to recycling. The Ministry for the Environment will provide information clarifying the practical intent of this target.

Major centres containing the majority of New Zealand's population can readily provide communities with access to recycling facilities. Providing facilities for dispersed rural populations is more difficult and more costly. The economics of recycling is also affected by the higher transport costs associated with services in rural areas remote from markets for recycled materials. These factors will place some limits on access to and use of facilities for recycling but should not prevent the 95 percent target being achieved by 2005.

Target 1.5

By December 2005, territorial local authorities will ensure that building regulations incorporate reference to space allocation for recycling facilities in multi-unit residential and commercial buildings.

Progress towards the implementation of the target

A small number of territorial local authorities now stipulate this in their district plan, but we recognise that this is an inefficient way to deliver the target. Discussions have been held with the Ministry of Economic Development and the Building Industry Authority on the changes required to the Building Act and the Building Regulations in order for this target to be delivered.

Issues arising from the implementation of the target, including barriers to implementation

The work involved in changing each territorial local authority's district plan has led to the proposed national approach.

Target 1.6

By December 2005, all councils will ensure that procedures for waste minimisation have been addressed for all facilities and assets they manage and will have set target reductions based on public health, environmental and economic factors.

Progress towards the implementation of the target

A small number of councils may have already addressed this target, but most contacted say that they have not. This is probably a timing issue for the production of asset management plans as much as an issue of difficulties in addressing the target itself. There are a number of other issues around the roles of those tasked with managing assets in local government and those tasked with managing waste.

Issues arising from the implementation of the target, including barriers to implementation

Most local authorities only address their asset management plans periodically, and some will not have addressed all of these between the launch date of the strategy and 2005. The Ministry recognises that the timetables councils have for the review of asset management plans will mean that some plans will be reviewed after the target date.

Some local authorities utilise their asset management plans to provide for fiscal prudence rather than to manage the asset in an operational sense. The asset is often operated under contract; some of these contracts are long term, and explicitly minimising waste is seen as a low priority for consideration of a contract variation.

Target 2.1

By December 2003, all territorial local authorities will have instituted a measurement programme to identify existing organic waste quantities, and set local targets for diversion from disposal.

Progress towards the implementation of the target

The revision of the Solid Waste Analysis Protocol (SWAP) provides a nationally consistent means of measuring the composition of solid waste, including the different organic waste streams. This information combined with total waste quantity data provides organic waste quantities. Some local authorities have SWAP survey programmes in place, and these, in conjunction with data from the Ministry's SWAP Baseline Programme, provide a useful estimate of waste composition for most areas in New Zealand. This information is available on the Ministry's website.

Pilot work by Environment Waikato and the Bay of Plenty Regional Council to develop a waste data network shows promise for regional systems for measuring key indicators. This pilot project focuses on a collaborative approach to data collection and reporting involving local authorities, recycling operators and the waste management industry. Environment Waikato has established a regional target consistent with this national target.

Several local authorities that have recently completed waste management plans have set local targets for the diversion and disposal of organic wastes.

Issues arising from the implementation of the target, including barriers to implementation

The establishment of effective measurement programmes will take time, and some councils may rely on the pilot work still under way. Setting and measuring local targets require information from commercial as well as municipal sources, and the commercial sensitivity of information can be a barrier to companies sharing this information with councils.

One council has indicated that it will not set diversion targets because of the lack of commercial incentive to compost or mulch organic waste.

Target 2.2

By December 2005, 60 percent of garden wastes will be diverted from landfill and beneficially used, and by December 2010, the diversion of garden wastes from landfill to beneficial use will have exceeded 95 percent.

Progress towards the implementation of the target

Many councils provide the opportunity at their landfills or transfer stations for the diversion of garden wastes for composting or mulching. However, green waste going to landfills still provides a significant fraction of total waste (up to 25 percent in some areas). Home owners who have the capacity to compost or mulch green waste can also use garden wastes beneficially. Considerable encouragement has been given to householder use of garden wastes through public information (including the national Reduce Your Rubbish campaign). Measurement of green waste diverted through home composting is problematic at best.

Two councils that have set garden waste diversion targets since the publication of the New Zealand Waste Strategy(Queenstown and Rodney) consider that between 50 percent and 60 percent of this waste stream can be diverted by the end of 2005 providing a range of policies are put in place. Councils with 'best practice' composting or mulching systems in place are currently diverting around 50 percent of green waste away from landfill disposal.

Issues arising from the implementation of the target, including barriers to implementation

High levels of garden waste diversion are dependent on a range of complementary policies and conditions, including:

• disposal charges providing an incentive for diversion of garden wastes
• sufficient markets/uses for the products generated from garden wastes, with these markets prepared to assign an appropriate value to the processed waste material
• garden waste collection systems that can be readily used by householders
• garden waste collection systems that avoid mixing inorganic wastes with garden wastes
• public information and education.

This target will not be achieved without appropriate policies in place and without the presence of beneficial end uses for the products generated from garden wastes. The Ministry for the Environment's Organic Waste Project will help to address these issues.

Where electricity is being generated from the burning of landfill gas there is little incentive to divert organic waste because this may detrimentally affect electricity generation.

Contamination of compost is a significant issue, both in New Zealand and internationally. The key current concern affecting the diversion of green waste is the residual herbicide (Clopyralid) remaining in lawn clippings through the composting process. The Ministry is working with the composting industry in New Zealand and the Environmental Risk Management Authority to identify and implement appropriate controls on the sale and use of Clopyralid.

Target 2.3

By December 2007, a clear quantitative understanding of other organic waste streams (such as kitchen wastes) will have been achieved through the measurement programme established by December 2003.

Progress towards the implementation of the target

This target relates directly to Target 2.1, which covers the establishment of measurement programmes identifying organic waste quantities and setting local targets for diversion and disposal. Achieving the target requires work to quantify the different elements of organic wastes.

Issues arising from the implementation of the target, including barriers to implementation

The issues are similar to those discussed in Target 2.1.

Target 2.4

By December 2007, more than 95 percent of sewage sludge currently disposed of to landfill will be composted, beneficially used or appropriately treated to minimise the production of methane and leachate.

Progress towards the implementation of the target

Sewage sludge can be stabilised (at which point it is commonly called biosolids) and then composted or spread directly on to land. Volumes of sewage sludge will increase as a consequence of the progressive upgrading of wastewater treatment. Currently, sewage sludge from the Wellington wastewater treatment plant is composted, and sludge from New Plymouth is dried and turned into fertiliser. Kapiti Coast is developing a similar process to that used at New Plymouth, as is Hutt City Council, but in the Hutt and in other areas the product is currently landfilled. Mangere, by far the largest biosolids producer, is currently investigating options for the use of its material. The Ministry recognises the inherent difficulty in achieving the target date and has initiated a project focusing on the management of organic wastes.

Issues arising from the implementation of the target, including barriers to implementation

There are several barriers to increasing the beneficial use of biosolids, including:

• the presence of contaminants (eg, heavy metals), which may restrict the use of biosolids as soil conditioner/fertiliser
• objections by Māori, on cultural grounds, to the use of a product based on human waste being added to soil used for growing food
• possible market resistance based on the risk of consumer rejection of products that arise from soils enhanced with biosolids
• the low economic value of biosolids, which means that land filling may be the more cost-effective option for disposal.

Guidelines for the safe use of biosolids have been produced by the New Zealand Water Environment Research Foundation to help address these barriers. Implementing these guidelines relies on the approach and contaminant threshold concentrations being adopted by regional councils throughout New Zealand. There is a possibility that regional councils will not apply the guidelines as intended, and in particular will adopt the more restrictive risk-based contaminant concentrations immediately rather than in 2012, as proposed in the guidelines. This is because some councils consider that the thresholds may permit an unacceptable level of contamination of the environment.

The Ministry's Sustainable Industries Group is working with biosolids producers and processors to identify and address roadblocks to beneficial use.

The target also allows for appropriate treatment to reduce the generation of methane and leachate. The wastewater sector has yet to take up this second option to any great extent, and it may be worth pursuing options such as anaerobic digestion combined with sludge drying for some situations.

Target 2.5

By December 2010, the diversion of commercial organic wastes from landfill to beneficial use will have exceeded 95 percent.

Progress towards the implementation of the target

Commercial organic wastes include food scraps from the retail and hospitality sectors, food-processing wastes and industrial-processing waste. In some cases these wastes are being diverted, generally for use as soil amendment with or without composting. Examples include soil incorporation of paunch waste from meat-processing plants and composting of waste treatment sludges from food-processing plants. Since a significant portion of this diversion occurs outside the normal waste management industry there is very little quantitative data on diversion rates.

The Ministry recognises the difficulty in achieving this target.

Issues arising from the implementation of the target, including barriers to implementation

The issues for diversion of commercial organic waste are similar to those for garden waste; ie, potential beneficial use, disposal charges and education of waste producers.

In general, commercial organic wastes are more putrescible than garden wastes (they have a higher nitrogen content and higher odour potential during degradation). This means that processing needs to be more closely controlled to minimise odours. The nature of many of these wastes also means that there is potential for using them as feedstock for biogas generation (anaerobic digestion) prior to processing as a soil amendment/fertiliser.

The basis for assessing the 95 percent level of beneficial use needs to be clarified.

Target 3.1

By December 2005, businesses in at least eight different sectors will have introduced extended producer responsibility pilot programmes for the collection and reuse, recycling or appropriate treatment and disposal of at least eight categories of special wastes.

Progress towards the implementation of the target

EPR schemes covering used oil, used mobile phones, used whiteware and used electronic equipment have already been initiated by industry. The Ministry is currently working towards the enhancement of the used oil recovery programme and towards an EPR policy for used tyres.

Issues arising from the implementation of the target, including barriers to implementation

The establishment of EPR schemes involves costs, which some importers and distributors may be reluctant to meet and pass on to consumers. Such schemes also may require the co-operation of several parties, and some parties may be unwilling to co-operate. Some may want to 'free ride' on a scheme but not meet their share of costs. Co-operation can be perceived as collusion and may raise anti-competition arguments. There is no legislative back-stop to EPR schemes that would create a level 'playing field' and reduce the risk of such free riders. The Ministry is doing further work on policies that would provide encouragement and support for EPR schemes.

Target 4.1

By December 2005, all territorial local authorities will have instituted a measurement programme to identify existing construction and demolition waste quantities and set local targets for diversion from landfills.

Progress towards the implementation of the target

The revision of the Solid Waste Management Protocol provides a nationally consistent means of measuring the composition of solid waste disposed to landfill, including waste from C&D activities. This information, combined with total waste quantity data, provides a partial picture of C&D waste disposal. In many areas C&D waste is also disposed of at dedicated C&D landfills and/or cleanfills, as appropriate, and there are no co-ordinated systems for measuring the quantity of waste being disposed of at these sites.

Pilot work by Environment Waikato and the Bay of Plenty Regional Council to develop a waste data network shows promise for regional systems for measuring key indicators.

The Ministry, through the Sustainable Management Fund, is funding a project to consider C&D waste, including measurement/monitoring and developing and documenting best practice in C&D waste diversion. Some local authorities are including diversion requirements in permits for C&D activities.

Issues arising from the implementation of the target, including barriers to implementation

No significant barriers have been identified for the achievement of this target. See the commentary on Target 9.3 (Cleanfills) for a discussion of issues around the regulation and operation of cleanfills in New Zealand.

Target 4.2

By December 2008, there will have been a reduction of construction and demolition waste to landfills of 50 percent of December 2005 levels measured by weight.

Progress towards the implementation of the target

Progress can only be assessed once the 2005 baseline has been determined.

Issues arising from the implementation of the target, including barriers to implementation

The key issues affecting the diversion of C&D waste include:

• disposal charges, both at landfills and dedicated C&D waste sites
• markets for the diverted material (eg, recycled aggregate, waste wood, gib board, plastics)
• site logistics (the practicality of sorting waste materials on-site)
• building design, selection of materials and the deconstruction process.

It is expected that the Sustainable Management Fund C&D waste project will assist in better defining the issues preventing C&D waste reduction and in designing and implementing effective solutions to any barriers identified.

Target 5.1

By December 2005, an integrated and comprehensive national hazardous waste management policy will be in place that covers reduction, transport, treatment and disposal of hazardous wastes to effectively manage risks to people and the environment.

Progress towards the implementation of the target

Elements of an integrated and comprehensive policy are already in place. These include a national definition of hazardous wastes, an online waste list, guidelines on identification and record keeping, and guidelines on waste acceptance criteria.

Other elements of the policy will be developed before the end of 2005.

Measuring progress towards the target

The elements needed for an integrated and comprehensive hazardous wastes policy are well understood. Progress is monitored internally and also by the Parliamentary Commissioner for the Environment.

Target 5.2

By December 2004, hazardous wastes will be appropriately treated before disposal at licensed facilities, and current recovery and recycling rates will be established for a list of priority hazardous wastes.

Progress towards the implementation of the target

Guidelines on landfill waste acceptance criteria have been developed, and will form the basis for assessing appropriate treatment. The hazardous waste policy mentioned in the previous target will include further guidance on appropriate treatment and licensing requirements. There has been some work done by regional councils on determining recovery and recycling rates for hazardous wastes (Environment Bay of Plenty and Environment Waikato hazardous waste survey).

Issues arising from the implementation of the target, including barriers to implementation

The collection of reliable data on recovery and recycling rates is difficult, and there is no standard method for data collection. Defining 'priority' hazardous wastes will depend on regional differences.

The regional council work determining recovery and recycling rates for hazardous wastes has shown that voluntary surveys tend to produce "flawed and unreliable data", suggesting that a more mandatory approach may be needed to track priority hazardous wastes.

The lack of an appropriate tradewaste by-law recording information on hazardous wastes going to sewer is considered by Environment Waikato to be a key gap in the information framework.

Councils wish to know which hazardous wastes are 'priority' hazardous wastes.

Target 5.3

Recovery and recycling rates for priority hazardous waste will increase 20 percent by December 2012.

Progress towards the implementation of the target

Systems are not yet in place to allow progress towards this target to be measured. When current recovery and recycling rates have been established, and record-keeping and tracking systems have been adopted by hazardous waste management enterprises, there will be a better information base with which to measure progress. The baseline for measuring progress towards this target needs to be established by the Ministry.

The national collection of waste agrichemicals currently being organised by the Ministry for the Environment in collaboration with regional councils will provide, where practicable, for the recovery and recycling of waste chemicals that are collected. The amount processed largely depends on whether the waste chemicals are reliably labelled, and will only be a small fraction of the total hazardous waste stream.

Issues arising from the implementation of the target, including barriers to implementation

The need for better systems for hazardous waste measurement has been discussed above.

The relatively small scale of hazardous waste generation in New Zealand means that establishing viable recycling and recovery operations is more difficult than in more industrialised countries (eg, Australia). There is international trade in recyclable and recoverable materials, and this affects the commercial viability of domestic facilities. There are currently no financial incentives for enterprises to establish facilities in New Zealand, other than market pressures.

The base value for measuring the 20 percent increase is not clear.

Target 6.1

By December 2008, all sites on the Hazardous Activities and Industry List will have been identified and 50 percent will have been subject to a rapid screening system in accordance with the Ministry's guidelines.

Progress towards the implementation of the target

The Ministry is currently preparing a series of guidelines to assist local government, consultants and industry to manage contaminated land. One of these guides is the Risk Screening System, which provides a method for assessing risks at sites contaminated with hazardous substances. This guide has been field-tested by councils and consultants. It will be published and available by the end of November 2003.

Issues arising from the implementation of the target, including barriers to implementation

The Ministry proposes to hold workshops in mid-2004 to promote and explain the application of those guidelines published.

Target 6.2

By December 2010, all sites on the Hazardous Activities and Industry List will have been subject to a rapid screening system in accordance with Ministry guidelines, and a remediation programme will have been developed for those that qualify as high risk.

Progress towards the implementation of the target

See 6.1 above in relation to the Ministry's work on preparing the guideline on a risk screening system.

The Ministry has established a contaminated sites remediation fund. A portion of this fund is available to assist regional councils with the investigation of contaminated land and remediation of sites that pose a high risk to human health or the environment within their regions. The fund will help councils to compile a database recording the status of contaminated land within districts and regions.

Issues arising from the implementation of the target, including barriers to implementation

The purpose of a rapid screening system is to assist councils to identify sites posing a high risk to human health or the environment. This is particularly relevant when industrial or agricultural land with a history of chemicals use is being subdivided for residential or life-style block use. The major barrier to the use of the rapid screening system (and other contaminated land guidance) is that presently councils are not explicitly required to administer contaminated land information under the Resource Management Act.

Target 6.3

By December 2015, all high-risk contaminated sites will have been managed or remediated. A timeframe will also have been developed to address the management or remediation of remaining sites.

Progress towards the implementation of the target

The purpose of this target is to highlight the importance of addressing the risks to human health or the environment from exposure to chemical residues on land by means of a prioritised programme of work that starts with the 'worst first'. Sites posing a lesser risk should be addressed progressively thereafter. Performance measures will be developed over the next few years.

Issues arising from the implementation of the target, including barriers to implementation

This is an ambitious and possibly unrealistic target given that the legal imperative to remediate contaminated land is presently non-existent, and that most affected properties are privately owned. This target should be re-assessed in 2008, when government policy on contaminated land, including liability, will be more advanced than at present.

Target 7.1

By December 2010, New Zealand will have met international obligations under the Stockholm Convention to collect and destroy PCBs and organochlorine pesticide wastes.

Progress towards the implementation of the target

Under the Stockholm Convention, the Ministry for the Environment is responsible for preparing a national implementation plan (NIP) The NIP will set out targets for the collection and disposal of PCBs and stocks of waste POP pesticides. The NIP is to be reported to the Convention Secretariat within two years of New Zealand's ratification of the Convention; that is (probably) by December 2005. The proposed NIP will set more specific targets and address issues relating to measurement and monitoring.

The Ministry for the Environment is currently planning a national collection programme for organochlorine agri-pesticide wastes, which will be undertaken over the next two years in collaboration with regional councils. This will build on existing collection systems operated by many regional councils and on the success of the major regional council-operated collections that were undertaken during the mid-1990s.

Issues arising from the implementation of the target, including barriers to implementation

Transpower have until 2016 to complete their phase-out and disposal of PCBs in transformers, for which they have exempted use permits. The target will need to be reconsidered in the context of the proposed NIP, which will need to take account of the Transpower situation.

Target 7.2

By December 2020, the average body burdens of dioxins will have been reduced to 10 percent of present-day levels.

Progress towards the implementation of the target

Elements of a plan to minimise emissions and human exposure to dioxin will be set out as part of the requirement for New Zealand to prepare a national implementation plan (NIP) under the Stockholm (POPs) Convention.

Measures to reduce and/or eliminate dioxin emissions will include:

• air quality standards that prohibit specific activities, such as landfill fires and the burning of insulated copper wire
• prohibiting any new facility to incinerate hazardous wastes
• health investigation levels for dioxins, DDT, dieldrin, etc. in soils.

Issues arising from the implementation of the target, including barriers to implementation

Issues and barriers will be considered during the development of New Zealand's national implementation plan.

Target 8.1

By December 2005, all territorial local authorities will have implemented and will be monitoring Model General Trade Waste By-laws based on the New Zealand Standard Model General By-laws, Part 23 - Trade Waste or its equivalent.

Progress towards the implementation of the target

No specific action has been taken to measure progress towards this target. The New Zealand Water and Waste Association (NZWWA) is working with local authorities on a replacement model trade waste by-law. While it is generally accepted that there are problems with the current model by-law, there is not yet agreement about the details of a new model by-law.

Issues arising from the implementation of the target, including barriers to implementation

The lack of agreement among local authorities over a replacement of the current model by-law is a barrier to achieving this target. The Ministry is working closely with NZWWA, and it is anticipated that this barrier will be removed before the end of 2005. There may then be some delay while legislative procedures of local government are enacted in some cases.

Target 8.2

By December 2005, all territorial local authorities will ensure that all holders of new or renewed trade waste permits will have in place a recognised waste minimisation and management programme.

Progress towards the implementation of the target

This will require a change to local councils' by-laws. The Local Government Act 2002 requires a general review of all by-laws, which would provide the opportunity to include provisions for waste minimisation and management programmes. The review of the model trade waste by-law would also provide an opportunity to provide a legal back-up to achieving this target.

Issues arising from the implementation of the target, including barriers to implementation

The lack of by-laws supporting the implementation of waste minimisation and management programmes is a current limitation.

Target 9.1

By December 2003, local authorities will have addressed their funding policy to ensure that full cost recovery can be achieved for all waste treatment and disposal processes.

Progress towards the implementation of the target

The implementation of this target requires councils to account for the full costs of their waste treatment and disposal facilities. The target is backed up by the accounting requirements of the Auditor General and the Local Government Act. Our understanding is that councils will achieve this target by the end of 2003.

The Ministry for the Environment has developed a guide that can assist councils to calculate the full costs of landfills. The cost of collection needs to be incorporated into this model to enable councils to comply with this target. The full cost of wastewater collection, taking into account the depreciation of the sewerage asset and the operational cost of treatment, is available through asset management planning processes and should be available in each council's long-term financial strategy.

Issues arising from the implementation of the target, including barriers to implementation

There are no known barriers to the implementation of this target.

Target 9.2

By December 2005, operators of all landfills, cleanfills and wastewater treatment plants will have calculated user charges based on the full costs of providing and operating the facilities and established a programme to phase these charges in over a timeframe acceptable to the local community.

Progress towards the implementation of the target

There is anecdotal evidence that many landfill operators are using the Landfill Full Cost Accounting Guide for New Zealand (Ministry for the Environment, 2002a) to achieve this target. However, no formal survey of uptake of the guideline or calculation of user charges has been undertaken. Based on this limited evidence it is estimated that most, if not all, landfill operators are on track to introduce user charges over a time frame acceptable to the local community. There are some significant remaining issues around charging at rural transfer stations and for domestic rubbish collections. There is also very little comprehensive information available on the charging situation for cleanfills in general. Most cleanfills are privately run and are therefore likely to be recovering the full costs of operation.

While the overall costs involved with wastewater are generally known, the marginal capital and operational costs attributed to an additional connection may not be clear. The costs of infrastructure provision and replacement for wastewater are addressed in some detail in the asset management programmes that have been championed by local government and Audit New Zealand following Local Government Amendment No. 3 Act. Operational costs tend to be based more closely on historical costs and are subject to challenge from time to time, and the costs associated with domestic flow compared to commercial and industrial flows (trade wastes) are similarly unclear.

Issues arising from the implementation of the target, including barriers to implementation

A major perceived barrier to full-cost charging for solid waste is the risk of illegal dumping. The true nature of this barrier is unclear as there is some evidence that increases in disposal charges have been introduced by some local authorities with little or no increase in illegal dumping.

Where the territorial local authority runs landfills, there can be ratepayer resistance to increasing the direct costs of waste disposal. Where landfills are privately owner-operated, full costs will generally be recovered.. In areas served by several landfills there are complex interactions between market share and profit per tonne of refuse disposed.

There are some significant challenges to be overcome in implementing full-cost charging for wastewater treatment and disposal. These include developing simple and consistent ways of measuring loading and flow, the political implications of 'user pays', and the adequacy of legislative provisions.

Target 9.3

By December 2005, all cleanfills will comply with cleanfill disposal guidelines.

Progress towards the implementation of the target

There has been significant uptake of the cleanfill guidelines by regional councils (enforcing authorities) throughout New Zealand.

Issues arising from the implementation of the target, including barriers to implementation

In many regions the operation of a cleanfill is covered by a permitted activity rule in the relevant regional plan. In this case there is no mechanism for the regional council to cover the costs of compliance monitoring (as there is through the resource consent process) unless formal enforcement proceedings are entered into. In this context regional councils are unlikely to be able to fund proactive or comprehensive compliance monitoring.

Since cleanfills are generally not covered by formal consent processes, identifying sites is difficult. In some areas, however, district and/or regional rules use a threshold approach, meaning that larger sites are identified and controlled.

Target 9.4

By December 2010, all substandard landfills will be upgraded or closed.

Progress towards the implementation of the target

The results of the 2002 Landfill Review and Audit indicate that significant progress is being made towards this target, with the number of landfills in New Zealand decreasing and a trend towards higher standards in siting, design and operation.

Issues arising from the implementation of the target, including barriers to implementation

The main barrier to meeting this target is the cost of closing or upgrading sites that have significant remaining capacity.

Target 9.5

By December 2020, all substandard wastewater treatment facilities will be upgraded, closed or replaced with systems that comply with all relevant regional and coastal plans, standards and guidelines.

Progress towards the implementation of the target

Some work has been carried out by the Ministry for the Environment to identify the barriers to implementing this target.

Issues arising from the implementation of the target, including barriers to implementation

An understanding or a definition of the term 'substandard' would help in the implementation of this target. The key words in the target are "comply with all relevant regional and coastal plans, standards and guidelines". This represents an opportunity for the wastewater sector to work in collaboration with regional councils and central government to develop guidance on the appropriate design and operation of wastewater systems (including reticulation).