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Draft Framework for the National Waste Management Strategy
Submitted by admin on Wed, 2009-04-08 21:46
To manage comments, the Draft Framework for the NWMS has been divided into the sections below, some of which are further sub-divided. Each paragraph is numbered, so that you can precisely reference your comments.
You can include general comments about the structure and content of the document on this page, or discuss issues arising from the document in the Discussion Forum.
To avoid repetition, please read existing comments before posting a new comment and wherever possible include your comments as a reply to existing comments to encourage participation.
On this page, you can also open a "printer friendly version" of the entire document and print it. Alternatively, you can print each section from the relevant page.
The deadline for public comments on the Draft Framework for the National Waste Management Strategy is the 18th May 2009.
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Packaging Council of South Africa
We are responding to the draft NWMS on behalf of the Packaging Council of South Africa, which is the spokesbody for its members which represent some 75% of the revenue generated by the Packaging Industry in South Africa . Within PACSA is the Recovery Action Group (RAG) which represents the interests of the material based Associations in the Packaging and Paper Industries.
1. We fully subscribe to the ideals and intentions of the Waste Act and welcome the National Waste Management Strategy. In particular we welcome the need to define roles of responsibility of the different spheres of Government.
2. As a body that has informally been approached by DEAT to develop an Industry Waste Management Plan , we are concerned that the Act requires the development of a number of different Plans from a variety of organs of state and Industries and as these appear to be in process simultaneously , how are these being co-ordinated?
As an example para 4,21 referring to Producer Responsibility suggests that the plan will develop the concept of Producer Responsibility and will decide how to approach these plans. the content of the plans etc. This will be approved , according to your timetable , probably after our Packaging and Paper Industry Waste Management Plan has been drafted and approved by the National Department.It seems to us unusual that we are asked to develop a Plan before the rules have been agreed.
To avoid the confusion that would ensue should the strategy differ from our Plan , particularly in the detail of targets and instruments , we request that the Packaging and Paper Industries are given the appropriate representation on the proposed steering committee to oversee the development of the NWMS.
We look forward to participating in the process.
Sincerely
Andrew Marthinusen
Executive Director PACSA; Chairman RAG.
Section 6 of the Framework
Section 6 of the Framework and the Annexure 1:
[1] There is some very useful content that can be built upon. The comments in paragraph 1 of clause 8 are especially relevant.
[2] Concern about possible confusing events around the preparation of Industry plans in terms of coordination at various levels of Government.
[3] Concern that the Packaging Industry is under pressure to develop a WM plan when the basic rules are not yet in place. In the current economic climate, without rules the industry will be hard pressed to get financial commitment.
[4] It is expected that in the plastics industry once post consumer waste collection is in place, that there will be an excess of waste over that that can be mechanically recycled. This is the situation overseas. The answer looks to lie in using this excess for energy recovery through incineration, for electricity generation. There needs to be early recognition of this likely circumstance and the relevant planning brought forward.
[5] Geographical area differentiation will be most important because of the social structures in RSA.
[6] The National waste balance may prove very difficult looking at the information currently available! But it is necessary to guide targets and how they are met. So many different consultants come with so many different numbers.
[7] Integrated waste management plans by Govt sector - is already an issue as Provinces and large Metros are busy, but showing either differing plans / approaches, or doing nothing significant yet. This makes it more tricky for Industry sectors to get their plans together. A strong central coordination will be required.
[8] Clause 3.4 of Annex 1: The plastic bag taxation is not an initiative that we would recommend following. Through our direct involvement with Buyisa we know that it is fraught with problems and very little success. Worse still - as an enviro tax - it is virtually impossible to get money out of Treasury for Enviro projects other than for Buyisa. Government decrees / taxes will in our considered opinion not work. Industry MUST gather the levies and administer them and the necessary regulations must come very quickly for industry to use in effecting their plans. We must all strive for industry based plans BUT we do need seed funding from Government. This is critical to success and especially in the more complex industries such as packaging which cannot be separated like for instance tyres can.
[9] Clause 4.6: mentions corporate social responsibility and that's OK, but what about the many, many small companies? How do we get to them?
How will the NWMS content differ or not with the guidelines for waste management planning that arose out of the Act in December. We need to match these up.
[10] Clause 4.8: the economic instruments need to be defined and regulated smartly to allow Industry and others to get their plans working.
[11] Overall: there may be gaps, but it is a very good start. May success prevail! The proposed framework should work, but the detail will need strong industry input.
From : Executive Director - the Plastics Federation of SA
David Hughes
Licensing vs Permitting
The NWMS does not clarify as to what will happen to the ECA Section 20 Permitting Process. Will it cease and be replaced by the Waste Act licensing Process? The strategy should be clear in terms how the process will unfold for the already permitted applicants and the applying applicants.
Licensing for transporting waste: The NWMS should be clear in terms of identifying the competent authority where transported waste pass through several provinces prior to disposal.
NWMS
Thank you for your extremely useful feedback, Egmont - I'd just like to clarify that this document is merely the Framework for the new National Waste Managment Strategy stipulated by the Waste Act.
The actual strategy is still in the process of being formulated.
Test
Matt can comments still be added?
Waste Management Hierarchy
The NWMS does not address the issue of the WMH (include co-processing of waste) with the significance it deserves. WMH should be at the core of the NWMS. One small way to address this is to incentivize WMH at local level. ALL businesses and homes should be encouraged to implement the WMH by creating a market at local level. By doing so, sustainable waste management can be achieved.
Industrial Waste Management Plans
The NWMS should mention explicitly how industry should compile the Industrial Waste Management Plan as stipulated in Section 28 of the National Environmental Management: Waste Act, 2008 (Act No 59 of 2008). The Act stipulates the contents of the Industry Waste Management Plan but is not clear which industry is required to compile or hire an independent consultant to compile on its behalf. The Act leaves such prerogative to the Minister or MEC.
General Comment on Subject List 1
The NWMS does not acknowledge the above-mentioned policy and its advantages in addressing the waste management challenges in South Africa. The High Temperature Treatment Policy inter alia has the following advantages:
• The co-processing of waste in cement kilns is an internationally accepted practice and an acceptable alternative to the landfilling of waste.
• The cement industry does not produce hazardous waste and there is potential for using cement kilns as an appropriate method for the recovery of mineral and energy value from waste.
• Public participation and Environmental Management Planning are covered by the policy.
Comments on NWMS
With respect to the comments made: the following documents have reference:
1. The Draft Framework for the National Waste Management Strategy
2. Annexure 1: Framework for the NWMS
In Annexure 1:
Part 2: Section 4.6. Indicates that Sewage sludge will be dealt together with general and domestic waste (hence the insinuation that it is not hazardous). Should this not rather be dealt with as hazardous waste.
Part 2: Section 4.7. The waste balance approach especially related to industry, mining, agriculture will be difficult to establish given the previous history on information availability as well as the lack of use of any of the waste information systems which have been developed. Given the limited information and trying to present information with some statistical integrity this might not be achievable. In addition, basing targets on limited information would be difficult to defend.
Part 3: Section 4.13. Because treatment a processing will become a more sort after application especially if delisting will no longer be included in Waste Classification, more attention to these aspects need to be given. Perhaps reflecting governments stance relating to certain treatment / processing technologies.
Part 5: Section 4.25. Given that the strategy will be addressing the licensing of waste management activities, etc…, how will this be dealt with in the interim.
General comments:
The strategy should also consider the dynamics and viability of having recycling initiatives in rural areas (including mining towns, etc.) and the limitation imposed by economies of scale when it comes to collection and transportation of these recyclables to towns where recycling/reprocessing facilities are located.
The NWMS should not deviate from the intention of the Waste Act, and should not include additional requirements over and above what is provided for in the Act. The strategy should also not place unrealistic timeframes on government capacity and deliverables as well as industry expectations given the current financial climate.
PRINTER FREINDLY VERSION??
Please help - I cannot find the printer freindly verson of the draft.
thanks,
Printer friendly version
My apologies, Mike - due to a configuration issue, you would not have seen the link - I have fixed the error and the link to the printer-friendly version is right next to "Comment on this section"
Thanks for spotting this!
Matthew
Printer friendly version
Dear Mike
The link to the printer-friendly version is at the bottom of the document - the link on the first page will open the entire draft framework in your browser - if you just want to print a particular section, go to that section and use the link at the bottom.
You can also find a pdf version (without numbered paragraphs) of the Draft Framework on the Library page.
Kind Regards
Matthew