Waste Management and Minimisation Plan 2024 – Summary of consultation

We proposed a food scraps kerbside collection and asked for feedback on whether it should include only food scraps, both food scraps and green waste, or neither.

Out of 303 submissions, 82% supported the proposal, with 87% favouring the inclusion of both food scraps and green waste. Only 2% preferred a collection for food scraps only, while about 11% either opposed the collection or didn’t comment.

The Council agreed that the service should include both food scraps and green waste, and noted this has worked well for other councils. The specific details of the service have yet to be developed. The design of the service will consider the factors raised by submitters such as the size of the bin, whether the collection will be co-mingled or separate, frequency of collection, and how to best minimise smell and pests.

Change made by Council: Action 3.6 amended to “Develop a city-wide kerbside food scraps and green waste collection service” and action 3.7 amended to “Introduce residential food scraps and green waste collection and processing.”

We proposed reviewing our kerbside collection services (rubbish bag collection, recycling bin, and glass crate) to find better ways to improve waste minimisation.

Out of 298 submissions, nearly 74% supported the review, around 18% were unsure or didn't comment, and just under 9% opposed it.

Despite some confusion about the review's details, there was strong support, with many favouring a switch to wheelie bins for waste collection. Cost was also a common concern. The Council agreed to proceed with the review, recognising its potential value.

Change made by Council: none.

We proposed setting waste minimisation targets aligned with the national Waste Strategy, aiming to divert at least 30% of waste from landfill by 2026, 40% by 2028, and 50% by 2030. These targets may be revised if the Ministry for the Environment changes its performance standards.

We received 288 submissions on this proposal, with over 73% in favour, 6% opposed, and nearly 21% unsure or not commenting. Some concerns were raised about potential additional costs for the Council. However, failing to meet government standards could result in losing significant waste levy funding, which would need to be offset by raising rates or other charges.

The Council agreed that the targets are a reasonable approach to take but will continue to monitor for any changes that may come from the Ministry for the Environment.

Change made by Council: none.

Many submitters expressed general concerns about costs, both in relation to the proposal to introduce a new kerbside collection, and the cost of disposing of waste more generally.

From comments it appears that some submitters believe the Council operates “the tip” or the waste transfer station. While the Council does operate the Ashhurst Waste Transfer Station, it does not own or operate the waste transfer station on Matthews Avenue (what some may identify as “the 2etip”), neither does it own or operate the landfill at Bonny Glen in Marton.

The Council acknowledged the frustrations with the cost of waste services. However, the Council has no control over the charges set by the Matthews Avenue Transfer Station or the fees set by the Bonny Glen landfill. Approximately a quarter of the cost to dispose of waste is the waste levy set by the Ministry for the Environment. The increase in the waste levy by the Ministry is deliberate to disincentivise disposing of waste and encourage recycling and generating less waste.

The Council agreed that the costs of services that Council provides will be considered as part of the review of services it signalled in the Waste Management and Minimisation Plan. The Council is always mindful of the cost of any services it provides for the community.

Change made by Council: none required; included in existing actions.

Several submitters noted that the recycling system is complicated and confusing, making it easier to throw everything away rather than sort through recycling. There was frustration over recent changes to recycling rules and uncertainty about where to recycle certain items.

The Council acknowledged these frustrations, explaining that complexity sometimes arises from the need to separate materials for recycling and to ensure employee safety, such as rinsing containers before recycling.

Many submitters emphasised the importance of education, highlighting the success of the recent open day at Awapuni Resource Recovery Centre and calling for more regular events like this. The Council agreed on the importance of education, which is included in the Waste Management and Minimisation Plan, and noted that the planned review of services will aim to simplify the recycling system.

Change made by Council: none required, including in existing actions.

Some submitters suggested introducing a regular inorganic collection or a "swap meet" for people to exchange inorganic waste, with unwanted items going to the landfill. There was also a request to make the hazardous waste collection an annual service.

We have previously explored introducing an inorganic kerbside collection. However such services are often very costly, and tend to outweigh the benefit they provide in minimising illegal dumping. Many other councils are moving away from these types of collections, whilst others are moving to a booking system to avoid unsightly waste around the city.

The swap meet suggestion avoids some of the concerns around unsightly waste around the city and may mitigate some of the costs of collecting waste from around the city. However, it potentially creates other issues such as people requiring a vehicle to bring their waste to a central location, providing a suitable location for the swap meet, and the disposal of waste not taken away by other residents.

The Council did not decide to introduce an inorganic waste collection or a swap meet as it did not believe the potential benefits justified the likely cost.

The Council has previously considered making the hazardous waste collection an annual service but decided to keep it as a biennial service to minimise the cost to residents.

Change made by Council: none.

Submitters made suggestions for additional recycling initiatives which they think the Council should adopt or investigate. One initiative in particular concerns soft plastics, which submitters noted many other cities already provide.

The soft plastics recycling scheme provides the opportunity for the public to take soft plastics to drop off points, often located in supermarkets. This is run by the Packaging Forum and is funded by Soft Plastic Recycling Scheme Members (including brands, manufacturers, retailers, and service providers). The collected plastic is taken to Future Post (either in Waiuku or Blenheim) and processed alongside other plastic resin grades to form fence posts and rails among other things.

We have some concern that this process may not be consistent with the new direction outlined in the New Zealand Waste Strategy 2023 Rautaki Para around creating a circular economy. However, given the demand for this programme in our region, we have continued to investigate how this recycling opportunity could be offered in Palmerston North.

We have reached out and had discussions with the scheme manager. The main challenges for the scheme being rolled out in Manawatū are:

1. Establishing a collection provider for the materials (soft plastics) from all the participating stores in the region; and
2. Determining an adequate storage facility for the unbaled (lose) soft plastics. This needs to be a covered and dry space and provide the ability to bale the soft plastics – prior to bulk dispatch to Future Post (in either Waiuku or Blenheim).

In most regions that have the soft plastics recycling scheme, the operations are undertaken by the private market. We have been unable to determine whether the scheme managers have proactively approached private entities in the region for this. Given that, we have investigated Council being the possible service provider i.e. we provide the collections, storage, baling, and logistic support to freight.

We do not currently have the storage, fleet, or collection capacity to deliver this without capital and on-going operational investment. These costs are undetermined. We note that the scheme does provide revenue for the service, but we would need to understand whether this would recover all costs incurred by Council.

The Council decided that this can be explored further as part of the action to carry out a review of services in 2024/25, as indicated in the Waste Management and Minimisation Plan.

Change made by Council: none required; included in existing actions

The Waste Management and Minimisation Bylaw includes provisions for licensing waste collectors, but these provisions have not been implemented yet due to complexity and resourcing.

Several submitters drew attention to the lack of licensing, and suggested that this should be expedited, should be self-funding, and used to impose conditions on waste collectors to hold them to a high standard.

The development of a suitable licensing system has proven to be more complex than anticipated, further complicated by Council’s dual role as both regulator and a collector. This is one of the reasons for proposing to undertake a review of how we deliver services, to ascertain whether a change in our role as a waste collector would allow us to better regulate other waste collectors.

An added complication is the 2023 National Waste Strategy Rautaki Para which identified changes to how waste collectors are to be licensed. The details have not yet been announced, but it is expected to be released later in 2024, with legislative change to follow.

Based on the expected timing for passage of that legislation, we have indicated that work on licensing collectors could begin from 2026, subject to the details of that new licensing framework. Bringing the action forward could make the work redundant if changes to legislation in the next 12 months significantly alter the Council’s ability to license waste collectors.

Change made by Council: none required; included in existing actions.

A submitter suggested construction/demolition and commercial waste is a big area for improvement, where more needs to be done.

As a waste collector, we control only a small part of the waste stream (what we collect at the kerbside). This means that we have very little control over the diversion of waste material generated in the construction and demolition (C&D) sector, or in the institutional/commercial/industrial (ICI) sector.

However, we have included an action in the draft WMMP for year 1 to develop guidance targeted at builders for developing a Construction Site Waste Management Plan. This would work in tandem with our education initiatives. We have also been involved in discussions for the location of a construction and demolition waste facility in the city, which will provide facilities for sorting construction and demolition waste. We will continue to work with the developers of this facility over the next 18 months.

Change made by the Council: none required; included in existing actions.

A submitter said that our public space rubbish and recycling bins are too few and too small.

We have undertaken a programme of renewals of our public space rubbish and recycling bins. The existing 60L waste bins are being replaced with larger 80L bins, typically with a smaller aperture to minimise the risk of waste escaping and becoming litter. This programme is continuing and is funded from our renewals budget.

Data on use of our public space recycling bins show that they are often misused with higher rates of contamination. The level of contamination undermines the value of offering dedicated recycling bins, so we have prioritised public space recycling bins in areas where there is likely to be a higher rate of compliance. We also ensure that recycling bins are located in areas where they can be reached by service trucks for emptying, but this means that recycling bins are less likely to be located in more remote areas.

Change made by Council: none required; included in existing actions.

A submitter suggested that Albert Street Depot (where the Ferguson St Recycling Centre is located) should not be rezoned for housing.

This issue is out-of-scope for the draft WMMP. The option to rezone the Albert Street site for housing was included in the Future Development Strategy as a long-term option.

Change made by Council: none; out of scope.

A submitter suggested the Council should investigate waste to energy facilities, using clean incinerators to burn waste to generate energy.

There is currently no waste-to-energy facility operating within New Zealand, so this suggestion is impractical until such a facility is consented and constructed. However, there are a number of additional barriers which make this suggestion impractical.

For a waste-to-energy facility to be viable, it requires a significant and steady volume of waste material for incineration. The volumes can often exceed what is generated locally; in facilities overseas, this can often require waste to be imported from other areas to ensure that the facility is able to run effectively. Also, the material to be incinerated typically needs to be of a high quality (including material that could otherwise be recycled). This can then have the effect of reducing the availability of that material for recovery and reuse.

The “philosophy” of a waste-to-energy facility also runs contrary to the Revised Waste Hierarchy, which emphasises a circular economy and gives preference to actions at the top of the hierarchy. A waste-to-energy facility would be near the bottom of the hierarchy, with the destruction of the resources rather than their re-use. The need for waste to fuel the incinerators would likely encourage the generation of waste rather than its overall reduction.

Based on this information, the Council did not support investigating the idea of waste to energy facilities further at this time.

Change made by Council: none.

A submitter suggested that recycling at events should be made mandatory.

The Waste Management and Minimisation Bylaw already includes a requirement for organisers of events held on Council land or with Council funding to prepare an Events Waste Management and Minimisation Plan. The conditions include requiring the event organiser to “take all reasonable steps to encourage recycling opportunities for materials used at the event.” There may be an opportunity to revise these conditions and place stronger conditions on event organisers.

The Council agreed that the next review of the Waste Management and Minimisation Bylaw, scheduled to happen later in 2024, should include re-consideration of the requirements for events waste management.

Change made by the Council: none required; this issue to be referred to the review of the Waste Management and Minimisation Bylaw in 2024.

A submitter suggested that, as the Bonny Glen landfill is expected to be full by 2050, the Council should consider establishing a new site near Te Utanganui.

The Council has not owned or operated an active landfill since the Awapuni landfill was closed in 2007. Currently, all waste collected in Palmerston North is disposed of in the Bonny Glen landfill operated by MidWest Disposals. We have a contract with MidWest Disposals until 2026.

The Council did not agree that it was a priority for it to own and operate a landfill, and so it did not agree to make this suggested change to the Waste Management and Minimisation Plan.

Change made by the Council: none.

A submitter suggested that the Council should consider establishing a natural burial cemetery in conjunction with the land proposed to be used for irrigation as part of Nature Calls.

This suggestion was out-of-scope for the Waste Management and Minimisation Plan. The Council agreed to refer this suggestion to the Parks team (which have responsibility for cemeteries including any plans to establish a natural burials cemetery) and the Three Waters team (which have responsibility for the delivery of the Nature Calls project) for further consideration.

Change made by the Council: none required; referred to the Parks and Three Waters teams for further consideration.

A submitter suggested that Council should hold producers to account for goods that don’t have recyclable packaging.

While we acknowledge the frustration that submitters have with producers that do not use packaging which can be readily recycled, the Council does not have any legal ability to influence the type of packaging which they use. The Ministry for the Environment is responsible for the development of product stewardship schemes, which places the responsibility for the life of packaging materials on the producer.

There have been several product stewardship schemes introduced recently such as Tyrewise, which imposes a levy on the disposal of used tyres to ensure they are responsibly recycled or disposed of.

Change made by the Council: none.

A submitter suggested that the Council should consider a new site for green waste/recycling drop off.

We have already identified the need for an additional recycling drop off point in the Kelvin Grove area, to accommodate our growing population. This is planned for implementation in years 5 and 6 of the LTP (programme 1373).

Change made by the Council: none required; included in the Long-Term Plan.

A submitter expressed concern about the ongoing impact of junk mail.

We already have provisions in our Waste Management and Minimisation Bylaw to address unsolicited mail. If a person marks their letterbox “no circulars” or “no junk mail” or with similar words, then our Bylaw prohibits anyone from putting unsolicited mail in that letterbox. However, we have few practical tools to enforce these provisions.

Where someone complains that unsolicited mail has been placed in their letterbox, we will contact the companies that distribute the unsolicited mail and make them aware of the complaint, and request that they refrain from depositing unsolicited mail in letterboxes which are clearly marked as “no junk mail.” If there are repeated or deliberate breaches of the Bylaw, the Council reserves the right to prosecute any person who breaches the Bylaw. If convicted, the maximum penalty is $20,000.

Change made by the Council: none required; included in the Waste Management and Minimisation Bylaw.

A submitter was concerned about illegal dumping of waste, including tyres.

We have powers under the Litter Act 1979 to address illegal dumping (also known as fly tipping) or littering. However, there are often practical issues with identifying the person responsible for illegal dumping. Where we are able to positively identify the person responsible we have the ability to issue an infringement notice and charge a penalty.

A new product stewardship scheme for tyres (Tyrewise) will come into effect from September 2024.

Change made by the Council: none required; Council has existing powers to respond to illegal dumping under the Litter Act, and product stewardship schemes introduced by the Government are expected to address issues with products such as tyres being illegally dumped.