[submission to Paper Procurement Inquiry] ​ ​ The Wilderness Society Submission to Commonwealth procurement procedures - paper procurement inquiry Ist April 2016 Warrick Jordan National Forest Campaigner 21 Gordon Avenue Hamilton NSW To the Senate Standing Committees on Finance and Public Administration. The Wilderness Society thanks the Committee for the opportunity to make a submission on this important issue. We apologise for the lateness of the submission. 1. Summary In our view, the increased production of 100% recycled paper, including where it supports domestic regional employment, is an unambiguous societal good. In line with the view, 3718 supporters of the Wilderness Society have signed a petition encouraging the Government to re-instate the 2010 – 2015 ICT Sustainability Plan requirement that all ​ ​ Commonwealth offices to use 100% recycled paper (Appendix 1). While the procurement policies of the Commonwealth only relate to a relatively small proportion of the paper market, policies that support recycled paper procurement have a critical role in supporting both environmental sustainability and regional industries. Such policies provide a level of surety of demand that can help underpin viability, particularly in circumstances where competition, including dumping, comes from imports manufactured with much lower environmental and labour standards. More significantly, such policies send a clear leadership signal to the marketplace about the value and importance of these products. An equally important signal is also sent to current and potential investors in the recycled paper sector. Conversely, policies that fail to recognise and support the social and environmental value in recycled paper have the consequence of reducing confidence in the market and investment climate, with consequent impacts. In practical terms, The Wilderness Society would strongly encourage the Commonwealth to undertake the following actions: Page 1 of 4 ​ [submission to Paper Procurement Inquiry] ​ ​ ● Reinstate the ICT Sustainability Plan recycled paper procurement requirements, or an equivalent instrument. ● Ensure that procurement plans and guidelines unambiguously require the use of recycled paper. Given the apparent contention over the mandatory nature of the recycled procurement requirements in the ICT Sustainability Plan, and the apparent limited use of recycled paper use across departments, removing ambiguity is important in effective implementation. ● Ensure procurement policy consistency between responsible departments, particularly in regards to the intersection of sustainability and procurement policy. ● Investigate and, in the absence of any legal impediments, implement recycled paper procurement policy that prefers locally manufactured products, to maximise socioeconomic benefits and avoid transport related carbon emissions. 2. Environmental Benefits The environmental benefits of recycled paper are well known, with substantial research and a high level of public recognition. While these issues are substantially covered elsewhere1, the key environmental benefits are: ● Life cycle analyses consistently demonstrate that the use of recycled paper feedstocks has substantial benefits in the reduction of inputs such as water, chemicals and energy. This reduces the environmental footprint of end products, including carbon emissions. ● Reductions in waste going to landfill, with benefit including reduced methane. ● Recycled paper reduces reliance on virgin fibre feedstocks whose extraction may have direct impacts on conservation values, where such values occur and are inadequately protected. 1 For example, see Villanueava, A., and Wenzel, H. (2007) Paper waste – Recycling, incineration or landfilling? A review of existing life cycle assessments, Waste Management 27:8, s29-s46 ​ ​ ​ ​ Denison, A.D. (1997) Life­Cycle Assessment for Paper Products, Chapter 7, in Wood in our Future, the Role of Life ​ ​ Cycle Analysis, National Academy Press. Page 2 of 4 ​ [submission to Paper Procurement Inquiry] ​ ​ 3. Socioeconomic Benefits In the Australian context, preferred procurement and the consequent support and development of the recycled paper industry has substantial social and economic benefits. A 100% recycled paper procurement policy encourages market growth, and demonstrates Commonwealth support and confidence in recycled paper products. This in turn incentivises Australian business to make investment decisions to enable production. There is demonstrated evidence and clear statements that the 2010 -2015 ICT ​ Sustainability Policy provided Victorian-based Australian Paper with confidence to invest ​ in new and enhanced recycled paper manufacturing capacity, diversifying their business and supporting employment in a regional community. While the Wilderness Society’s concerns regarding the conservation impacts of producing Australian Paper’s native forest virgin fibre feedstock are a matter of public record, there is an undeniable logic that producing Australian made recycled paper products is a strong environmental and social positive. The Australian Paper example demonstrates that a 100% recycled paper procurement policy explicitly enables the development of new regional business and jobs. 4. Conclusion In most policy areas, if there are unambiguous and substantial societal benefits that are known to accrue from a policy decision that appears to carry little if any political, economic, or administrative cost, then that policy is likely to be enacted. In this instance, with such clear benefits and low cost, it is unclear as to why the Government has chosen to end the policy of requiring the use of 100% recycled paper in Government offices. A continuation of the Government’s current stance, where informal requests are made by the Environment Minister for increased recycled paper use, carries obvious risks. The Wilderness Society understands that, despite the Environment Minister’s suggestion, many Government departments are currently using non recycled paper products. This has consequent environmental impacts. In regards to incentivising additional investment and maintaining the viability of existing investment in recycled paper production, an informal request to use recycled paper is demonstrably not equivalent to a mandated policy. There appears to be very little downside to the Government reinstating a clear and mandatory policy requiring the use of 100% recycled paper in Government offices. We thank the Committee for the opportunity to make a submission on this important matter, and we look forward to the results of your deliberations. Page 3 of 4 ​ [submission to Paper Procurement Inquiry] ​ ​ 5. Appendix 1: Signatories (3718) to recent Wilderness Society petition regarding Commonwealth recycled paper procurement Dear Prime Minister Turnbull, Under the 2010-15 ICT Sustainability Plan, the use of 100% recycled paper by all Government offices was required by 30 July 2015. We understand that this policy was abandoned by the Commonwealth Government under Prime Minister Abbott. We are concerned that this is a serious backward step. Using recycled paper makes good sense. Recycled paper helps prevent environmental damage to forests both in Australia and overseas, and supports sustainable jobs. We respectfully ask that your Government reinstates the use of 100% recycled paper as a matter of environmental and economic leadership, and simple common sense. Yours sincerely, Page 4 of 4 ​ Postcode First name Last name 3003 Saheem Wani 3141 Lily Weinberg 2303 Warrick Jordan 3003 Saheem Wani 7000 Peter Wallhead 3058 Kevisato Sanyu 3156 Nancy Tormay 2706 Casey Schaefer 2146 Jessica Turner 3163 Peter Madden 5000 Michele Leopold 3144 Diana Crombie 2795 Marta Wantenaar 3160 Anna James 3942 Dylan Shearsby 7315 Michelle Pegler 6010 George Egerton-Warburton 4171 Ursula Mihaere 99085 Falk Hicke 2034 Catherine Kloos 2444 daniel soffer 2541 Rowyn Pepper 4223 irene follon 4207 lauren confos 6158 Daenia Dundon 4311 Anthony Needham 5050 Natacha Tracy 4051 Bradley Rendon 3219 Toby Nolan 5277 Joseph Cullen 4119 yvonne day 3133 Pamela Lea 3084 Natasha Coutts 5255 Kate Elliott 2619 Luise Hollmann 2171 Emma Freeman 5558 Paul Turner 6728 Leonie STARNAWSKI 2050 Haytham Chernov 2565 Ana Brumec 3429 Marilyn Johnson 4121 Jean-Philippe Oggier 6169 Gemma Dunkley 4519 Jeanette MIlls 2250 Jetro Lappalainen 3068 Linsey Rendell 5017 Jessica Dangerfield 3155 Erin Hallyburton 4885 Christine Wolf 2340 Barbara Levick 2446 Chay KHAMSONE 3196 Mirjana durovic 6151 eloise wigget 2116 Tim Ressos 3186 Kirsten Gabel 5066 James Walsh 2640 Sally Beard 7007 Cath Deacon 6027 Rachael Rolls 93067 Kelleen Knight 2000 carol warwick 3350 Gail Weston 4566 Tricia Reade 4815 Candace Waugh 3113 Glenn Henke 2289 Hazel Diane 3068 Shan Rumney 4300 Janet Barden 2166 Carol Lee 3146 Erin Canning 4061 Sarah du Preez 6111 jennifer carruthers 5075 Michael Flaherty 4065 June Lennie 2337 Judy Green 4064 Patty Beecham 2640 Joanne Cross 2120 Cathy Green 2779 Anna Armstrong 3078 Isobel Sfetcopoulos Anderson 4563 Cherie Hanson 3918 Mollie Chook 3918 Zac Adie 2117 Sam Field 2533 Suzanne Reynolds 2096 Jon Kelly 3031 Bernard Stahr 3068 Beryl Flower 5014 Blake Lennon 2444 may pax 3213 Brayden Cockerell 2065 Trudy Dunne 3820 Keryn Riddington 2037 Polly McCourt 2303 Warrick Jordan 2350 Vanessa Hunter 3003 ss aaa 6026 Verena Homberger 4055 Pamela Skirving 3124 Carl Leitch 3130 Sue Webster 3184 Lisa Logan 3216 Lynne-Maree Parker 6004 john brusen 5096 Angela Butler 5069 jess hand 2092 Lynne MacKinnon 4170 Josie Brown 2324