The first article in this series pointed to some issues the New South Wales Government policy may create with the mandated introduction of FOGO (Food and Garden Organics) collections by 2030.
I acknowledge that mandating such collections makes sense, as it is a good instrument to jolt Local Government and industry into action. However, if history is anything to go by, this could go very wrong.
Many years ago, the then Australian Waste Management Association had a branch called Compost NSW. I was representing a company that was a member. So was Patrick Soars, for Australian Native Landscapes (ANL). I clearly recall a branch meeting where members wanted to start composting the organics from MSW (municipal solid waste) or household waste to divert more waste from landfill.
The problem was how to deal with all the contaminants, being anything that doesn’t belong in compost, and what this could do to the compost industry. As usual, most members at the meeting were either quiet or in favour of something new that promised more revenue. There were only two people standing up and speaking out against this practice: Patrick and myself.
Our concern was contamination and what it could do to the industry. Bad products don’t sell, and the compost industry was always about producing a good product, not about handling waste. Anyway, we were not successful in stopping the trend.
Companies started to invest in new facilities making compost derived from MSW (your red-lidded bin). A new branch was formed, the AWTDORF Group. The acronym stood for: Alternative Waste Technology Derived Organic Fraction. The EPA allowed the processes to go ahead, subject to testing and confirmation of results. A few hundred million dollars were invested. Long-term contracts with councils were entered into.
The EPA tested the AWT derived compost, which was dubbed MWOO (Mixed Waste Organic Output), and tested and tested. Ten years later came the decision. No more AWT derived compost could be applied to land in NSW due to the physical (i.e. microplastics) and chemical contamination (i.e. leached chemicals). I could have told you that from the start, as the same process was a disaster in Europe.
Whilst I supported the decision to stop this type of material being made in principle, the execution of this decision by the EPA (the “MWOO decision”) was horrible. Industry was given very little notice and contractual promises had to be broken. Promised diversion from landfill was no longer allowed, investment became senseless, trust was broken.
Some (not enough) money was given to the industry to “transition” to a better use of the facilities, mind you not for all. And the result: now the Government is footing the bill for taking this stuff to landfill (using your money). Not exactly what you’d like to achieve with recycling, right?
The execution of the MWOO decision has left scars on industry and Local Government
Now the EPA comes along and says “collect all food and garden organics in the same bin and make compost from it”.
To the EPA’s credit, it has done a lot of work preparing for the FOGO roll out. It has offered funding for councils to prepare for the roll out, it has held masterclasses about FOGO and determined what should and should not go into the FOGO bin. All good stuff! But not enough!
Am I exaggerating? I don’t think so.
Speaking to industry sources, they are concerned about the contamination levels in the collected FOGO. If the contamination is high, the costs of de-contaminating the FOGO is difficult to establish and the cost risk will be transferred to the Council, and therefore ultimately the rate payer. A Sydney Council recently put out a FOGO tender asking processors to accept contamination levels of up to 20 per cent.
Whilst you can try to price the cost of removing physical contamination, you cannot price the risk of chemical contamination. Chemical contamination was one of the major arguments for the EPA to revoke the marketing of AWT derived compost (plus some micro-physical contamination, which also cannot be avoided at such a high level of incoming contamination).
It is all good and fine for the EPA to determine what cannot go into the FOGO bin. The householder will not be held accountable for the contamination. Now the EPA leaves it to Councils and industry to work out who takes what risk and how this is being priced. I don’t think this is good enough. Why? Because in commercial reality, Councils will try to transfer all risk to processors and processors will price that risk as high as they think they can get away with. Who pays? You and me.
For example, if the EPA states that the content of a FOGO bin is to only be food, garden organics and some types of kitchen caddy liners, what does that mean for the composter who then receives so-called FOGO with 20 per cent contamination? Are they in breach of their licence? Will they be prosecuted for accepting waste outside their licence conditions?
The EPA will say that based on NSW experience, the average contamination is only 2.6 per cent, not 20 per cent, so this shouldn’t be a problem. Yes, but that is mainly in regional and rural Councils. I don’t think that experience can be translated to city folks. And it is a moot point anyway. What matters is what happens in reality.
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Penrith City Council was among the first Sydney Councils to introduce FOGO collections and its mayor said at a Mayoral Summit on Waste in Sydney in late May that initially the contamination ratio in Penrith was 35 per cent but is now less than 4 per cent. That exactly highlights my point.
How can you make good quality compost from FOGO with 35 per cent waste in it? You can’t.
There must be a transition period in which highly contaminated loads will be diverted to another treatment or disposal option.
How can we reduce contamination? By education. We simply cannot expect FOGO collections to work “overnight” or shortly after the introduction of the new collection system. That would be madness. Education takes time and costs money.
I think this is exactly the situation where the State Government, having come up with the policy, must accept responsibility and provide Councils and industry with funding plus a standard contract that fairly allocates risk and provides mechanisms, accepted by the EPA, on how to deal with contamination. With that I do not mean the technicalities of how to remove contamination, but the allocation of risk. Councils must accept some responsibility for education of its population and what they deliver. The composter must have a clear protocol and certainty on what they can accept and what to do with non-compliant materials.
If we leave the transition from making compost from clean garden organics to potentially heavily contaminated FOGO to individual Councils and industry players, then we open the door for another disaster. The compost industry requires protection. The EPA is not responsible for the proper functioning of the compost industry, but it punishes it when it doesn’t comply – herein lies the crux. We need a well thought out transitioning phase as it will take a few years before this is sorted.
