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EPA’s changes will decrease recycling rates, reduce jobs, discourage investment

The NSW construction & demolition (C&D) waste sector is the largest resource recovery sector in NSW, processing over 13.4 million tonnes a year and contributing $500 million annually to the economy. It employs more than 1,000 workers. The EPA’s proposal to rapidly change the framework that presently recycles over 1.2 million tonnes of fines from co-mingled waste could destroy business’ investment confidence, leading to a lack of investment, and innovation. The EPA needs to focus on better enforcement of the existing regulations, rather than increasing the regulatory burden on ethical operators. The EPA’s proposal will merely force ethical operators out of the industry.

We support the NSW EPA’s objective of improving the quality of recovered soil that is applied to land. However, the EPA needs to better work with industry to develop a proposal that both improves environmental outcomes, promotes resource recovery and ensures a viable construction and demolition waste industry in NSW. And these changes should be done in a way that doesn’t harm the viability of recyclers or cause unintended consequences for other industries and the environment.  We urge the Government to better work with industry to develop a standard which is reasonable and in line with the practical reality of recycling. We also strongly recommend a greater focus on compliance of existing orders, rather than attempting to regulate the industry out of existence.

The proposal will result in significant job losses in the C&D recycling sector. As the proposal represents an effective prohibition of recycling co-mingled fines from waste and soils from excavations, our modelling indicates that 500 jobs will be lost (including 398 in Western Sydney). The proposed reforms would accelerate the use of limited non-putrescible landfill capacity, resulting in Greater Sydney having no landfill capacity by 2026. Given the planning approval timeframes (~5 to 10 years) associated with the development of new landfills, it will lead to a crisis in disposal options. Increased use of scarce virgin material, and the requirement for additional quarries. An increase in the number of heavy vehicles on the road transporting waste significant distances to landfills, to interstate recycling facilities and transporting virgin soils from new regional quarries. Inability for NSW Government to achieve its 20-year waste strategy targets and increases the risks of interstate transfers of unprocessed material. The increase in skip bin costs will likely increase the unlawful disposal of C&D waste, either through the increase in illegal dumping or misclassification and misuse of these materials in the environment.

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These changes by the EPA will result in an increase in the cost of waste management for new housing. Based on an average 2 storey, 390 square metre home-:

  • A C&D waste contractor will undertake on average four site collections and site cleans over the duration of the construction.
  • Approx. 27 cubic metres of mixed C&D waste is collected, including soil, sand, rubble, bricks, tiles, plastic, metal, timber, glass, etc.
  • Based on an analysis of recycling tipping dockets, 27 cubic metres is generated (approx. 13 tonnes)
  • The current waste management cost of these 27 cubic metres is $1,500 (or $55.50 per metre)
  • This is currently classed as a heavy load and C&D recyclers want heavy bins as the products are all currently recyclable.
  • If the EPA revokes the RRO for recovered fines, recyclers will not want heavy loads.
  • This material will be priced at a tonnage rate (recycler needs to cover the cost of tip fee and the waste levy of $147.10)
  • Average tip fee of $300 per tonne, the cost will escalate to $3,900, increasing the waste management bill by $2,400 on the construction of an average sized 2 storey

These changes by the EPA will result in an increase in the cost of waste management on renovations. The EPA’s changes will result in house renovation costs increasing by 300 per cent to 350 per cent.

In the example below, the cost increased from $3,774 to $12,600:

  • 19 skip bins on one property from March 2021 to November 2021.
  • 6 were recycled skip bins; 13 were mixed waste.
  • 68 cubic metres of mixed waste were removed in the 13 skip bins x $55.50 per cubic metre  = $3,774
  • Converting to tonnage = 42 tonnes.
  • 42 tonnes x $300 / tonne (tipping fee) = $12,600 plus transport & a margin.

Regardless on the final model of changes, we believe a transitional period (supported by NSW Government funding) is needed to assist the industry in adjusting to the new regulations.

Tony Khoury is the executive director of the Waste Contractors and Recyclers Association of NSW.