This is the third in a series of three articles. In the first two, I pointed out the potential issues with a State-wide introduction of FOGO collections all happening at once and argued that a transition period is required.
Here, I would like to expand on this issue and make some proposals on how this transitioning might work. Mind you, there are no easy or clear-cut solutions. One main piece in the puzzle will be collaboration between the compost industry, Councils and the Environment Protection Agency.
All parties play a major role, and none can operate in a silo.
The compost industry will need and want to process FOGO coming to them from council collections. Only the compost industry can tell what products they can market. They will want protection from materials that could destroy their reputation and markets due to high contamination and they will need to find new markets for all the additional compost to be produced.
Councils “own” the waste in the beginning as it is generated by their constituents, so they have a role to play in educating people. Good quality FOGO is the desired outcome, and it all comes down to behaviour of householders. Admittedly, councils don’t have the greatest influence on people’s behaviours, so they may need help.
The EPA wants FOGO to be collected and turned into compost to divert more waste from landfill. Good idea. The devil will be in the execution and the EPA is neither a composter nor a collector of waste, yet they have the last word. The EPA could also be seen as “conflicted” as it regulates the compost industry but has no disadvantage if that industry isn’t doing well.
All of this screams out for some kind of collaborative effort.
The FOGO issue is not just about collecting FOGO, it is very much also about processing it, making good quality products and then finding markets for those products.
Let’s start with how FOGO is collected. The last article mentioned the City of Penrith, where contamination levels were “sky-high” and then came down to 4 per cent, which is still high, but tolerable. How long did it take to get to 4 per cent? That might be a good indication of the length of any transition period needed to get things right. To re-iterate: it makes no sense trying to make good quality or “only” compliant compost (see The Compost Order 2016) from FOGO with 35 per cent or 20 per cent contamination.
There needs to be an agreed protocol of what loads can be rejected at a composting facility and what happens to those loads. It is really just common sense stuff. This protocol should provide certainty for risk allocation to allow for more accurate pricing of that risk.
We should also differentiate between so-called single unit dwellings (SUDs), in plain English, houses, and multi-unit dwellings (MUDs) or apartment buildings. The main reason is that waste from MUDs is typically not as well sorted or source separated as the one from SUDs. It is likely that achieving well sorted FOGO from MUDs will take longer and we ought to account for that and avoid mixing the two.
Other typical risks that need to be considered:
- When exactly does the ownership of FOGO transfer to the composter?
- What is an agreed use/solution for rejected loads and who pays for the non-compliant FOGO?
- What exactly is the protocol for rejecting loads and how can it be verified so that we create reliability and trust in this new system?
- If the composter accepts a certain (to be agreed) level of contamination, what is the protocol of reviewing the fees and charges when the contamination levels drop? The Councils will not want to pay more than necessary.
- If the EPA changes the rules, because they find a new contaminant that ought not to be accepted, what is the protocol for risk and payments? We need to be aware of more and more “chemicals of concern” becoming a real concern that need to be managed and kept out of the environment (see also next article).
If all of the above rules are clear from the start, we create a much more level playing field and the parties know what their rights and obligations are. This transparency should also level the costs that Councils will have to pay. Ultimately this would be good for all involved, including the State of New South Wales.
It may be worth to at least partially revisiting the decision to revoke the AWT-derived compost from going to land application. Now the rate payer is copping the cost of this so called MWOO or “Mixed Waste Organic Output” not being able to be used as compost. But there are solutions other than throwing it into landfill. A bit of good will and cooperation could go a long way to make at least some better use of this material, which is processed at high cost and to little avail.
The loads rejected from a proper composting process could face the same fate as the “MWOO”. That can be an incentive to find alternative uses for the material, during this transition period, as it would be a real “waste” to throw it all into a landfill.
I won’t go into any detail of this issue in this article. This article is about giving some food for thought.
In summary:
- We will not be ready in time. By 2030, NSW will not have enough FOGO processing capacity and there will be lack of transfer station infrastructure.
- The Australian compost industry is operating well. The FOGO policy is setting the industry up for disruption and potential damage, which needs to be avoided.
- We need to find new markets for a few hundred thousand tonnes of compost each year, when the largest – urban amenity – market is already full.
- To make FOGO a success, much more support and collaboration is needed.
How is this collaboration going to happen, you ask?
When it comes to competing, Australia is certainly world class. When it comes to collaboration, it is difficult to find good examples. The last time I recall the EPA trying to do this was with the Round Table discussions at the EPA under its then chief executive, Lisa Corbyn, to discuss the Energy from Waste Policy. The Round Table went smoothly, then came the political intervention and it all turned into some sort of useless muddle.
How can we avoid this happening again?
Now, here is a chance for the new chief executive of the EPA , Tony Chappel, to show his qualities!