Proposal for a Waste Levy in NZ

Submission from the Zero Waste New Zealand Trust on:

Draft Proposal for a waste levy in New Zealand

Ministry for the Environment, May 2006

We are supportive of this, as it acknowledges that a user-pays levy is necessary to support the NZ Waste Strategy and its waste minimisation goals, and it acknowledges that the amount of the levy has to be meaningful in its use as an economic instrument, if progress is to be made towards the end purpose.

The Zero Waste Trust applauds the efforts of the Working Party in getting together this draft document, and notes the comments that significant consultation with all interested parties will be necessary prior to any legislative implementation of the scheme. To this end, the Trust makes the following points:

1. The draft proposal suggests that the levy would not be spent on activities that  "are not sustainable". This seems to imply "activities that are not economically sustainable", as it goes on to say that the levy would not be spent on activities "such as the costs of waste collection …" This Trust notes that some wastes are small in volume, yet so widely used throughout our society that 'economic' recovery might never be possible. But to not collect them might not be ecologically sustainable. An examples of this would be spent fluorescent light bulbs (traditional and compact). These bulbs contain mercury, an extremely toxic and hazardous waste, and it is essential that a safe disposal option be made available. There are other products that could well be in a similar category, such as un-used pharmaceuticals and small batteries. The draft proposal needs amendment here, as it might well be that a service to collect these materials needs a subsidy, which could be supported by the Waste Levy. Payments towards this goal would be in full accord with the intent of the Waste Strategy, which states :

• The first core goal of the waste strategy is "lowering the social costs and risks of waste."

2. The second point would simply be to comment on the composition of the Working Party in its current form. It seems to the Trust that it is too narrowly based, and future discussions will need to include representatives of NGO's, community, and environmental organisations.

3. The final comment of this Trust, at this stage in procedures, is in relation to the proposed disbursement of the levy. As reflected by the current membership of the Working Party, a high priority has been given to funding Councils  (and perhaps to on-flowing payment of consultants and advisors), while low priority and an extended implementation date has been given to the set-up of the contestable fund, which is the area where NGO's and community organisations will be seeking funds. This is of particular importance to community groups, as funding has recently been substantially reduced with the demise of CEG funding and the cessation of that MfE funding which has for several years been channelled through this Trust. It is important that funding for community groups is available from Year 1.