State planning for significant risks, including recycling, has been poor

State entities have not adequately managed key waste management risks. The planning and development of sufficient waste infrastructure and markets for recyclable materials has been slow, despite the Waste Authority identifying these challenges in 2012. This has led to some significant problems, which the State now needs to manage closely to avoid incurring further costs to recycle waste or increasing the amount of recyclable materials that end up in landfill.

For over a decade, WA has relied heavily on China and other international markets to sell recycled materials, and made little effort to search for alternate markets or reduce contamination levels, despite early warning signs that China would no longer purchase contaminated materials. For example, China’s Operation Green Fence policy first introduced import bans on contaminated waste in 2013 (Figure 4). It progressively tightened inspection efforts to reduce the amount of this waste entering the country, and in January 2018, further restricted waste imports under its National Sword policy. In 2017-18, WA exported around 180,000 tonnes of plastic, paper and cardboard. In 2018-19, the Australian Bureau of Statistics reported a decline in exports from WA, down to 93,120 tonnes.[1] The reduction of international markets led to significant increases in the costs for LG entities and MRFs to manage kerbside recycling. Given the early signs of China’s market changes, the Waste Authority and DWER could have better prepared for the long-term impact on the State’s recycling industry.

Source: OAG

Figure 4: Timeline of events affecting Australia’s ability to export recyclable materials

This reliance on international markets, lack of local waste processing infrastructure and limited local markets for the sale of recycled materials, prevents LG entities from recycling more waste without large increases in cost. COAG’s August 2019 decision to progressively ban waste exports from Australia from January 2021 has further reduced LG entities’ options to recover recyclable materials such as glass, mixed plastic, cardboard and paper. The limited WA recycling industry and local markets for recycled products increases the risk that more materials that are recyclable will end up in landfills or stockpiled inappropriately.

The Waste Authority’s Community and Industry Engagement Program provided $3.46 million in 2019 to support general projects and recycling infrastructure projects that improve recovery and reuse of materials identified in the Waste Strategy 2030. In July 2020, the State Government also announced $15 million to support local plastic and tyre processing in the north of WA, and access to industrial zoned land valued at $5 million for processing infrastructure. This may eventually provide LG entities with local alternative options to manage recyclable materials.

WA does not have adequate infrastructure to support a local recycling industry. This is particularly evident when facilities become unavailable. For example, in November 2019, a fire in 1 of Perth’s 3 MRFs caused 20 LG entities to send recyclable materials to landfill for over 3 months while they sourced alternative processing options. Information had not been released about the cause of the fire at the time of our audit. Similar fires occurred at large recycling facilities in Victoria between 2017 and 2019. A Victorian parliamentary committee attributed these fires to insufficient facilities to store and dispose of waste, over-stockpiling and a reduction in markets for recycled goods. Without adequate waste infrastructure, the State risks further losses of recyclable materials in fires or to landfill.

There is no State waste infrastructure plan even though the State identified it as a priority in 2012

There is no overarching plan to support the strategic development of waste infrastructure in WA. In 2012, the Waste Authority identified the need for a State waste infrastructure plan as a priority but it has not yet been developed. LG entities therefore lack guidance to support strategic decision-making and to develop suitable waste infrastructure to meet the long-term needs of their communities and the State.

Under the Waste Strategy 2030 and the supporting Action Plan, DWER is responsible for the development of the State’s waste infrastructure plan in consultation with other stakeholders. The timeline for delivering the plan is unclear, though the Action Plan noted it could take from 3 to 5 years. Without an infrastructure plan, LG entities are left to make local waste management decisions that may leave some facilities unable to adhere to the waste hierarchy, under-utilised or redundant. Some examples of these are:

• regional council 1 – has sent its members’ waste to a resource recovery facility to extract and reprocess organic waste since 2009. However, if its members adopt a 3-bin FOGO system, the facility will no longer be needed to process the organic component of the waste, making it obsolete
• regional council 2 – invested in an alternative waste treatment facility in 2007 to separate and process organic waste. The technology was successfully trialled, but ongoing technical challenges resulted in financial difficulties and voluntary administration of the group of private companies that owned and operated the facility in 2016. It briefly restarted operating in 2017, but continued problems caused it to cease receiving waste in February 2018. This means the regional council has to seek other waste treatment options for its members
• regional council 3 – has successfully used organic waste from its members who use a 3-bin FOGO system to produce a compost, which complies with Australian standards. However sourcing regular markets for the product is an ongoing challenge due to production and transport costs, and farmers’ historic reliance on synthetic fertilisers
• furthermore, at least 12 of the 33 Perth and Peel LG entities have committed to provide residual waste to waste-to-energy facilities under construction in Kwinana and East Rockingham. However, 1 LG has agreed to supply all its kerbside waste for 20 years. This means the organic materials that could be used to produce mulch and compost will not be available. This approach does not align with the Waste Strategy 2030 objectives to adhere to the waste hierarchy and adopt a circular economy.

Waste facilities for the Perth and Peel region are not well located for LG entities managing waste across the north, south and east. In 2015, the Minister for Environment approved the construction of 2 waste-to-energy facilities in WA, which will be located within 5 km of one another in the south only, and the 2 operating MRFs are also in the south (Appendix 1). The lack of local access to key waste facilities means LG entities have to transport waste longer distances across the Perth and Peel region.

There has been some progress on land use planning for waste infrastructure, as DWER has begun working with the Department of Planning, Lands and Heritage (DPLH). In December 2019, they began preparing a ‘planning instrument’ to agree on an approach, which will guide decision-making for authorities involved in developing waste management infrastructure.

Local waste management planning is inadequate

LG entities have not sufficiently planned their overall and long-term waste management strategies, and do not generally share plans with their communities. We found that only 7% of LG entities had a publicly available waste plan on their websites. There was no evidence that these plans were updated to align with the new Waste Strategy 2030.

Waste plans had not been a requirement under the WARR Act. However, DWER developed waste plan templates and guidance for LG entities in 2019. All Perth, Peel and MRC LG entities are required to produce their own individual waste plan by March 2021. For our 7 sampled LG entities, none had public waste plans. However, 3 had a waste plan for their LG or region that included key elements recommended in the WARR Act. For example, Kwinana developed its City of Kwinana Waste Management Strategy in 2017 that included an assessment of:

• the significant sources, quantities and generators of waste
• the markets and facilities for waste received by the LG
• options and strategies to reduce, manage and dispose of waste
• programs that identify required actions, timeframes, resources and responsibilities for achieving the strategies and targets.

Without transparent local planning that aligns with the WARR Act and Waste Strategy 2030, the State and the community are unable to hold LG entities accountable for delivering effective waste services.

Regional LG entities are not required to develop individual plans, but they could benefit from having an individual plan to address local issues. For example, Broome’s landfill is nearing its end of life. The Regional Waste Management Plan for the Kimberley Region identified this risk in 2013. Lack of adequate planning for a new landfill site, due in part to Native Title considerations, means that within the next 2 years they will likely need to transport waste lengthy distances to an alternative landfill. This could increase costs for waste disposal. Planning and approval for new landfills can take up to 8 years. Preparing standardised waste plans would help LG entities effectively plan and monitor performance, and address key risks in a timely manner. 

There are no obligations for private waste contractors to meet recovery targets

Nearly 80% of LG entities contract out kerbside waste collection services, yet the contractors have no targets for the quantity of waste they reprocess, recycle or reuse. We reviewed the main contracts from our 6 sampled LG entities and found that the contractual arrangements focused on the timely collection and transport of waste, and the provision of bins. None included obligations to divert more waste from landfill and increase material recovery. Without performance measures for waste recovery, contractors may not be incentivised to divert more waste from landfill. While performance measures for waste contractors may help improve waste recovery, it does not negate the need for households to correctly separate and dispose of waste to reduce contamination in the first instance.

A number of Perth and Peel LG entities have agreed to use alternative waste treatment and waste-to-energy facilities, some of which no longer align with the new Waste Strategy 2030 objectives. LG entities can enter into long-term contracts, which they can extend if they have not allowed sufficient time to prepare a new contract. Extending contracts without considering the regular changes in the waste and recycling industry, increases the risk that LG entities fail to maximise waste recovery to meet their recovery targets.

The New South Wales Environmental Protection Authority[2] offers an example of better practice tendering guidance for LG entities to engage waste contractors that could benefit WA’s LG entities. It includes contract specifications for LG waste services that show how the contractor is liable for aspects such as:

• preparing and implementing a contamination management strategy
• recyclable materials collected that are rejected due to high levels of contamination
• annual waste audits on recyclable materials.

DWER’s limited guidance on how LG entities should classify and allocate waste costs means that the true costs to manage waste are unknown

Limited guidance from DWER on how LG entities should classify, allocate and report waste costs means that the full costs to deliver waste and recycling services are not known. DWER asks LG entities to provide annual costs for collecting, processing and disposing of waste. However, they do not provide LG entities with a detailed methodology or guidance on how to calculate the costs. In 2017-18, 118 of the State’s 132 LG entities that reported, spent a total of $297 million on waste services. The remainder did not report total waste costs in the LG Census. With no clear or consistent approach to how LG entities allocate these costs, the potential for variation in reporting is high, making the data less meaningful for analysis.

Some waste-related expenditure may not be included in the total waste costs reported by all LG entities. For example, 1 of our sampled LG entities stated that they did not include overheads for staff associated with waste activities or payments to their regional council for waste education services in their total waste costs. Improved understanding of the cost of waste services and consistency in reporting is required. This would allow LG entities to choose the right mix of waste services to improve waste recovery, provide value for money and meet community expectations.

Despite some improvement, there were limited controls to ensure data from LG entities is accurate

LG entities have improved their collection of waste and recovery data since 2016. DWER provide an electronic template with explanatory notes and guidance for LG entities on how to report their waste and recycling data. LG entities that use weighbridges and DWER’s approved procedures to calculate or estimate waste and recycling data further help to improve data quality. The Waste Authority has more confidence when using this data to prepare the annual LG Census and to share it with the Commonwealth Government for national benchmarks.

Limited controls affect the consistency and accuracy of the data LG entities provide to DWER. LG entities and their contractors do not routinely audit waste and recovery data, and DWER does not analyse the raw data. The Waste Authority also stated in its 2017-18 LG Census that the data was not validated. Consequently, the Waste Authority cannot guarantee the accuracy of the estimates provided by LG entities. Sixteen percent of LG entities self-reported low confidence in their 2016-17 data and 11% in their 2017-18 data. We interviewed stakeholders, reviewed the data from these 2 financial years, and found potential errors and issues that affect its reliability. For example:

• DWER advised that measurement of waste sent to landfill can vary by up to 300% because some LG entities used truck counts and visual estimates to calculate their waste in the absence of weighbridges:
  • Perth and Peel LG entities and larger regional LG entities such as Albany, Broome, Karratha, Geraldton and Bunbury used weighbridges, which are more accurate
  • 1 regional landfill only uses its weighbridge for commercial waste, but it does not use it to measure ad-hoc domestic waste drop-offs from residents
  • 2 small regional LG entities reported estimating waste tonnage using historic waste audit data and observations at the landfill because there is no weighbridge.
• There are variations in the way LG entities categorise and record waste streams, which means the data for each waste type is not always comparable. One LG entity did not report any FOGO waste collected in 2016-17 as DWER’s template did not include FOGO that year, instead recording it as kerbside green waste. Another LG entity had not separated household and commercial waste streams, stating that both types of premises used the same size and colour bins, which the LG entity collected on the same day.
• At least 3 LG entities located close to each other reported the same recovery rate of 83%. MRFs can receive recyclable materials from a number of LG entities at the same time. When this occurs, they only provide an average for the combined LG entities. This means that recovery data for kerbside recycling bins supplied by each LG entity may not represent their individual recovery performance.

The data limitations meant that LG entities cannot accurately monitor how effective and efficient their existing waste management programs and services are. Unreliable information also limits the State entities’ ability to use the data to understand the nature and volume of waste types, the fate of recyclable materials and to report progress towards Waste Strategy 2030 targets. Waste data collection is a shared responsibility among LG entities, waste contractors and the State, but DWER is responsible for statewide coordination and reporting.

After changes made in 2019, LG entities are required to report waste and recycling data annually to DWER. The Waste Avoidance and Resource Recovery Regulations 2008 (WARR Regulations) were amended in June 2019. The amendments aim to improve the accuracy, timeliness and completeness of waste and recycling data. The Waste Authority also published a Waste Data Strategy in November 2019. It details actions for the Waste Authority and DWER to improve data collection, verification and reporting and aims to achieve:

• more statewide consistency and guidance in data collection and reporting, with standardised data measures, terminology and waste classifications
• better resourcing for data collection, auditing and verification processes to increase data reliability for all stakeholders.

[1] COAG (2020). Phasing Out Exports of Waste Plastic, Paper, Glass and Tyres. Response Strategy to Implement the August 2019 Agreement of the Council of Australian Governments.

[2] New South Wales Environmental Protection Authority (2015). Model Waste and Recycling Collection Contracts User Guide for Councils https://www.epa.nsw.gov.au/your-environment/waste/local-council-operations/resources-for-local-councils