CCC Waste Management and Minimisation Plan Submission

The Christchurch City Council is taking submissions on their latest Draft Waste Management and Minimisation Plan. To read the full plan, see a summary and a 2019 assessment of the system, visit their website. 

To make submitting easier for others, we have decided to make our submission available. Please remove or add what you feel necessary and submit via the Council website by 31st August.

Do you think this Draft Plan does enough to manage and minimise waste to landfill?

No,

We do agree that the flexibility and adaptability provided by an annual review is a crucial element of the 2020 plan. This allows for short term actions alongside long term plans and provides agility to encompass national and global changes in the waste sector while allowing the Council to seize opportunities as they arise.

We believe there is room for improvement in the plan to manage and minimise waste to landfill with the below suggestions:

• All waste messaging to prioritise reduction and reuse over disposal.
• There is a clear need for residents to be provided with more education, clarification and transparency about waste and waste management systems. This is due to two main reasons: the changing national and international situation with waste, recycling and organics; and the prolific green washing that consumers face.
• Avenues for the Council to address these issues include:
  • Using the Christchurch Wheelie Bins App as an educational tool about rubbish, recycling and organics, not simply a list of what goes in which bin. Feedback we have received is that the app is confusing as there are no explanations around WHY items go in each bin.
  • Providing more education on how landfills work, particularly the negative impacts such as the greenhouse gas emissions resulting from organic matter in landfill.
  • The Council has funding pools already available that can be used to support innovative waste reduction activities. The Sustainability and Innovation Fund could prioritise applicants that can promote circular systems and demonstrate scalable waste reduction and reuse activities in the city. The fund would then double as an educational tool as projects engage individuals at a community level and share information, skills, and connections. Supporting such projects would also showcase the Council as a forward focused, innovative, and ‘smart city’.
• Biannual, free or subsidised, pop up drop-off points for disposal of more complex items such as hazardous waste and e-waste. This would provide another education opportunity informing the public about the waste streams and giving residents better understanding of the 3-bin kerbside system.
• As E-waste is a priority product under the recently announced Product Stewardship Scheme, an e-waste drop-off and education programme will tie in with the Central Government’s product stewardship goals.
• The use of landfills should be a last resort, with as much waste diverted as possible. Existing landfills need to have clear management of expectations and sufficient funding to manage them long term after their closure. This expenditure should be viewed as a sunk cost and avoided through the reduction in waste to landfill.
• The Council’s Sustainable Procurement process needs to be embedded at all operational levels. Feedback from individuals is that the Sustainable Procurement is a high-level conceptual policy that does not translate to the Council’s day to day operations. In order to facilitate a more robust procurement process Council could:
  • Pre-setting preferred products in supplier systems (such as stationery suppliers etc). Recycled, New Zealand made/ local and certified sustainable products should be prioritised. It is important that the cost of sustainable alternatives is not a limiting factor for the Council as it should be walking the talk and leading by example.
  • Ākina’s ‘fwd: A Supply Chain for Change’ directory provides ethical and local services and is a procurement channel should be used and promoted by the Council as a way to support small businesses and the central city’s economy.
  • Encourage all staff to avoid single-use plastics in their roles representing Council. Numerous meetings around environmental issues have had council staff attend with single use coffee cups. This could be avoided by adopting and promoting the Again Again reuse scheme or internally incentivising staff use of reusable coffee cups.
  • Impose Sustainable Procurement expectations on Christchurch City Holdings Limited, contractors and tenants around single-use service ware, energy consumption and waste disposal. These expectations would also help Ōtautahi reach its Climate Change targets.
  • The Council does effectively incentivise staff commuting by bike and using Zilch electric car sharing – this messaging could be expanded to other areas including waste.
• The Draft Plan does address the need for assessing existing issues with the Central City recycling and organics collections and we believe there are also issues with the rubbish collection. A nightly rubbish collection is too frequent to incentivise users to reduce waste. The use of bags is not only problematic for litter, with torn and damaged bags releasing rubbish into the environment but also the use of single-use plastic rubbish bags does not align with the Council’s reduction messaging.
  • We understand the complexities and limitations of making changes to the system, but we believe that reducing waste should be a priority when planning inner city complexes and developments. It is essential to provide adequate and accessible facilities. Due to limited kerbside space, bins are unlikely to be an option in the inner city so source separation at waste stations within buildings may be required.
• Waste to energy should not be seen as a viable option for residual waste. Burning rubbish is not zero waste – it is an unsustainable continuation of the linear ‘take-make-dispose’ economy. Investment in waste to energy infrastructure will delay zero waste outcomes.

For more information on our stance on this see The Rubbish Trip’s Waste to Energy Incineration resource.  

• Reducing Greenhouse gas emissions from waste needs to be considered as a way for Council reach its Climate Change targets. Waste contributes 8% to the city’s greenhouse gas emissions* and these can be managed and reduced through:
  • Reduction of transport to landfills through waste diversion
  • Greenhouse gas capture systems for landfills

* Christchurch City Council Climate Smart Strategy 2010-2025

We believe there is room for improvement in the plan to manage and minimise waste entering the ENVIRONMENT with the below suggestions:

• Manage litter and illegal dumping – funding and implementing litter traps in drains to capture rubbish before it enters rivers and waterways.
• To reduce littler from kerbside bins, the Council could offer/subsidise Safe Waste Wheelie Bin latches

Do you think this Draft Plan does enough to manage organics and recycling?

No, 

We believe the 2020 Draft Plan has acknowledged challenging areas and gaps faced by a linear economy, but we think there are more details required on how the Council intends to address these.

Our suggestions for improvements for recycling systems include:

• On-shore recycling solutions should be viewed as a transitional necessity – with the long-term goal of supporting new or existing large-scale reuse schemes.
• Washing/sterilisation plants and reverse logistics would provide the much-needed infrastructure for effective, large scale reuse schemes. Businesses such as Plastic Free Pantry on Waiheke Island, and reusable cup schemes such as Globelet, Again Again and Cupcycling, demonstrate the feasibility of such systems on a small scale and without widespread infrastructure to support the expansion of such schemes. With adequate policy settings, support and investment (see Takeaway Throwaways), large-scale reuse systems would promote waste reduction and reduce the need for costly recycling infrastructure or expansion of MRFs.
• More needs to be done to clarify messaging around recycling, composting, AND landfill.
  • Education programmes need to be more widely funded and publicised. Education is required in schools, educating and empowering young people, AND in communities educating individuals on how to make sustainable changes to their lifestyles.
  • The Council could be supporting and utilising the specialist educators in the community to engage the public in waste issues and educate on circular systems. It is important to have independent educators to provide an unbiased view.
  • Increase the scope of the current programmes to include pre- and post- programme support within schools (e.g. school waste management guidance, engagement with parents, link in with resources available).
  • The provision of education via Council facilities should be implemented sooner than the 2022 timeline outlined in the Draft Plan. Libraries are an often-undervalued contact point between Council and the public. They are the perfect mechanism for educating individuals and communities. Publicising existing resources, expanding on programmes such as Future Living Skills, hosting educational drop-in sessions and increasing messaging around current waste reduction work would maximise the use of these spaces.
  • EcoDrop could be used as a vehicle for communicating resource recovery information more effectively. This could include more user-friendly interfaces; a staff person dedicated to engaging the public; education on the importance of rubbish separation and what happens to different materials that their end of life. All of these programmes would enhance ratepayers understanding of kerbside collection.
• The Council can incentivise reduction over disposal through existing pathways such as:
  • Allowing ratepayers to swap their 240L yellow recycling to smaller 80L and 80L organics to larger 240L at no extra cost. This would not only reward residents who are trying to reduce their recycling, it would also encourage the higher rates of green waste disposal that may be required to secure investment to expand organic processing infrastructure.
• Trying to reduce contamination rates by investing in additional sorting technology at the Materials Recovery Facility may not provide the expected returns. The 0.5% contamination rate expected by recyclers is unrealistic in a mixed system.
  • Source separation and more waste streams are required to effectively divert waste from landfill and reduce recycling contamination rates.
  • Glass should be collected separately to ensure higher quality paper/cardboard recycling which could then be effectively recycled locally (this is backed by the EcoCentral feasibility study).
  • If Canterbury is going to explore local options for recycling, glass recycling needs to be a priority. Glass is infinitely recyclable yet in the current system is immediately taken out of the circular system and put into roading in the form of aggregate.
  • RFID tags should be utilised to track continuation issues and digitise collection systems, reducing the workload of drivers and Council staff.

Our suggestions for improvements for organics infrastructure include:

• The concept of composting paper through Living Earth would be a step forward for onshore paper/cardboard processing but it is still a linear model. If this were adopted it would have to be managed carefully, with messaging focusing on reduction rather than disposal.
• Consult with small community-scale composters (ie Cultivate) around the use of paper/cardboard as a source of carbon or composting operations. Other similar initiatives around the country have faced challenges getting enough carbon for their process and this could be another avenue to divert paper/card from landfill or offshore recycling and by working with a community organisation the Council can use it as outreach and education with the public.
• More education around compostable plastics is required as this is a known challenge for producers AND consumers. Waste MINZ has clear best practice guidelines for use of packaging alternatives that could be integrated with the Council and contractors’ expectations and messaging.

Do you think this Draft Plan does enough to move towards zero waste and a circular economy?

No,

We are glad to see there is an acknowledgment of the need for circular systems and co-operation between individuals, businesses, councils, and central Government to change the behaviour and views towards waste in New Zealand. While it is a step in the right direction, we believe there is room for more specific solutions, including:

• Washing/sterilisation plants and reverse logistics would provide the much-needed infrastructure for effective, large scale reuse schemes. Businesses such as Plastic Free Pantry on Waiheke Island, and reusable cup schemes such as Globelet, Again Again and Cupcycling, demonstrate the feasibility of such systems on a small scale and without widespread infrastructure to support the expansion of such schemes. With adequate policy settings, support and investment (see Takeaway Throwaways), large-scale reuse systems would promote waste reduction and reduce the need for costly recycling infrastructure or expansion of MRFs.
• More education and understanding of what a circular economy looks like in practice is required for general uptake. The Council could do this by:
  • Supporting local examples of circular systems as a way of normalising them and creating mainstream options that are not linear waste systems.
  • Embed circular systems messaging in the current and any new education programmes run by the Council. This would involve teaching about waste through a circular economy lens; how resources can be kept in you, how waste and pollution can be designed out of systems and how production and manufacturing can regenerate natural systems.
• We expect the Christchurch City Council to support the Central Government’s waste initiatives including:
  • The Product Stewardship Scheme
  • Regulating the recyclability of packaging
  • Streamlining the messaging around recycling
  • Supporting circular systems
• We understand that the Container Deposit Scheme is still in development and expect the Council to adapt the waste plan to encompass the outcomes of this. While this scheme will take recyclable plastics/glass out of the Council’s waste system we believe they have a role in facilitating the uptake of the scheme and education on waste minimisation and circular systems.

Overall, do you support the direction of the Draft Waste Minimisation and Management Plan? 

Yes,

We support the direction of the plan but believe that there needs to be more specific local solutions to provide a transition to a circular economy. 

Data should be continuously collected to ensure the programmes and systems implemented are reactive and adaptable. We cannot manage what we do not measure and currently comprehensive waste data in New Zealand is not regulated. We support the Government’s recent proposal under s 86 of the Waste Minimisation Act requiring all landfill, cleanfill and transfer stations to report waste quantity data, including the amount diverted and disposed of, and the source (activity and geographic) of that material. However, we believe that the Christchurch City Council should take this further and collect data on waste AND recycling composition and make that data easily accessible to the public.

We believe the time between audits is too long in this rapidly changing area. A ‘smart cities’ approach would see continuous data collection rather than snapshots audits.