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Can QLD achieve the National Waste Targets?

Open letter to Leanne Linard QLD Minister for Environment

By Mike Ritchie, Director, MRA Consulting Group

Q. Can Queensland achieve the National Waste Targets?

A. No. Here is why.


In 2019 the QLD government along with all States, Federal and Local Governments signed up to the National Waste Action Plan which set the following targets (amongst others) by 2030:

  • 80% reduction of materials to landfill;
  • 50% recovery of organic waste; and
  • 10% reduction in per capita waste generation.

Where is QLD up to?

It is going to fail to achieve its target by at least 3 million tonnes based on current policy settings. (QLD is not alone here. For example, I have written previously about NSW).

Figure 1. Current waste story QLD (Source: National Waste Report, DEECCW 2022)

Figure 1 Shows that waste generation in QLD is growing (blue line) but had a significant fall in 2020-21 (possibly due to the rise in the landfill levy and COVID).

Recycling (yellow line) has grown from about 4MT in 2007 to 6MT in 2021 but to achieve the Target that figure needs to grow to 10MT by 2030 (refer trend line projection to 2030). That is a growth of about 4.5MT on where we are today. 

Figure 1 also shows that waste to landfill has remained constant at 5 MT and shows no signs of falling to the required 2.5MT to landfill in 2030 to achieve the targets.

What does this tell us?

It tells us that the current policy settings are insufficient and inadequate.

Government only has 3 levers to affect waste recovery and recycling – pricing, regulation or education.

The government needs to pull one, or more, of these levers harder if it wants to achieve the Targets.

We can unpack Figure 1 by looking at individual waste streams – Household, Commercial and Industrial and Construction and Demolition. 

The first point to make is that only 30% of waste in QLD is generated by Households. 70% is generated by Commercial activities. 

So, the solutions must focus on more than households. We too quickly go to yellow bins and household recycling when we think about recycling. It is front of mind for all householders (voters) but commercial waste is where the big gains are to be found.

So, let’s look at commercial first.

Commercial and Industrial Waste (C&I)

Figure 2 shows that waste generation (blue line) has been growing inexorably since 2007. It showed a dip in 2020-21 probably due to COVID, but this has jumped back up to trend.

Recycling (yellow line) has grown as well and almost kept up with generation, but not quite.

Consequently, waste to landfill (red line) has continued to grow. 

Figure 2. C&I waste in QLD (Source: National Waste Report, DEECCW 2022)

We also know that at least 50% of what businesses generate is imminently recyclable. Why isn’t it? Because, by and large, it is still cheaper to landfill that component than go to the trouble of separating it and then paying a fee to have it recycled. 

To achieve the Targets we need to grow recycling by 1.8MT/yr in only 7 years. That is a doubling of the recycling rate for C&I waste (from 2MT/yr to 4.1MT/yr).

We also need to reduce waste to landfill from 2MT to 1MT, again in only 7 years.

Minister, you need to pull the pricing or regulatory levers if you want to affect the market. Investors won’t invest the capital, employ the people, recycle the waste and reduce emissions unless they can compete with landfill and make a dollar. Investors also want market certainty. As such, communicating what the price will be in coming years is also critical. 

Construction and Demolition Waste (C&D)

C&D waste generation has grown rapidly over the last 2 decades (Figure 3, blue line) but again showed a dip over COVID.

Recycling (yellow line) has also grown rapidly. This is a similar pattern of recycling that we see across all Australian States. C&D waste is imminently recyclable being made up of concrete, steel, timber, rock and rubble. It is heavy and responds to price (landfill levy) signals.

But to achieve the Target we need to almost double recycling rates from 2.5MT to 4.4MT/yr. That is a growth of 1.8 MT in only 7 years. 

Put another way, we need to construct at least 2 x 1 MT/yr C&D sorting facilities in 7 years. That is doable but requires continuing levy increases to guarantee the investment. 

There are recent private sector proposals in SE QLD which if built, will see this sector achieve its Targets.

Figure 3. C&D Waste QLD (Source: National Waste Report, DEECCW 2022)

Household Waste (MSW)

Something very weird is happening in the household (Municipal Solid Waste: MSW) data.

It shows a decline in household waste generation rates (Figure 4). I doubt that is true.

I think it shows that the Department has for too long relied on voluntary reporting by local government and has not required weighbridge data. I think it is a faulty data issue.

So, I will be circumspect about drawing conclusions. 

I simply don’t believe waste generation is falling. 

Nor, in my opinion, is recycling recovery falling. That would be counter to all other State trends.

I suggest the Department accelerate mandatory reporting of all facilities in QLD. (In my view any facility which receives over 1000t/yr should be required to report).

Figure 4. Household (MSW) waste in QLD (Source: National Waste Report, DEECCW 2022)

Even so, the bottom line (on this data) is that recycling of household waste needs to double from 0.9MT/yr to 1.7MT/yr in only 7 years.

Landfill waste needs to fall massively from 1.7 MT/yr to 0.4MT/yr.

This is impossible on current policy settings.


QLD cannot hit the National Waste Targets based on current policy settings.

If the government values the National Waste Action Plan and Targets then it needs to further align policies to drive additional investment in recycling and waste diversion.

The key mechanisms to achieve this include:

  1. Pricing -Lifting landfill levies (above current and announced) with hypothecation towards infrastructure and services;
  2. Regulations – Bans to landfill (e.g. organics and cardboard) and other regulations such as EPR; and
  3. Infrastructure investment (particularly construction and commercial waste separation).

The private sector will fund the capital and grow the jobs. They just need to policy framework to be conducive. Cheap landfills compete directly for these recyclable tonnes, so changing the flow of materials to landfill is the key priority. It doesn’t really matter how you do it.

Adjusting the policy levers will increase recycling rates, reduce dependence on landfill, reduce greenhouse gas emissions and grow green jobs.

The government is doing many good things around waste, but we need to go further and faster to have any chance of achieving the targets and growing the green jobs.

With the Olympics on the horizon, Queensland’s environmental credentials will be on display. Foundations laid today (policy, levy price and regulations) will create the right conditions for investment and help support the state deliver a sustainable Olympics. 

For your urgent consideration.

Mike Ritchie is the Managing Director at MRA Consulting Group.

This article has been published by the following media outlets:

Inside Waste, 17 October 2023


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