A bulldozer moving construction waste

The ‘Review of the Waste Levy – Consultation Period’ and ‘Closing the Loop: Waste Reforms for a Circular Economy Consultation Paper’ were released together in February 2020. The Department of Water and Environmental Regulation is seeking submissions from key stakeholders on a variety of questions and issues relating to the waste industry. The submission period for both consultation papers has been extended to 15 July 2020. 

We have previously discussed the content of the Waste Levy paper and Closing the Loop paper.

Broadly speaking, the papers are focused on regulatory reform to address the indefinite stockpiling of waste or its redirection to regional landfills in order to avoid the waste levy.

The papers are both aimed at recovering more waste materials so that they can be injected back into the economy. However, while these reforms address instances of waste levy avoidance and may increase material available for recovery, there is little discussion or consideration of how the market can be incentivised to increase the uptake of recovered materials.

Looking forward

A target of the State’s Waste Strategy 2030 is to increase material recovery by 75%. How can material recovery be increased in Western Australia? Successful waste recovery results from a combination of policy and legislative measures, which include financial incentives. Some steps in the right direction in Western Australia include the waste levy, Main Roads sustainability policy[1] and various policies of regional councils.


The Victorian road authority, VicRoads, has prepared sustainable procurement guidelines to promote the uptake of recycled materials. Specifications for pavement materials and bituminous mix designs provide for the use of recycled materials in the construction and maintenance of the road network.[2] VicRoads has also prepared a business case to demonstrate the competitiveness of local recycled products in pavement construction and provides recommendations for local councils to procure local recycled products for pavement construction.[3]


In Wales, the Government implemented the Waste Infrastructure Procurement Programme in 2008 which guided local authorities through project development and procurement processes to achieve economies of scale for the treatment of waste. The programme ensured consistency across waste management by local authorities and provided for authorities to join together in waste management consortiums to attract more competitive tenders. This programme has reduced costs and ensured waste infrastructure met high standards for costs, efficiency and environmental impacts.[4]


The above-mentioned examples provide successful case studies where government policy has incentivised resource recovery.  For example, in 2016-17, Welsh local authorities only reached 25% of their annual landfill allowance.[5] In Victoria, approximately 80% of construction and demolition waste was recovered in 2017-2018, with material such as concrete being crushed into aggregate to be used in road subbase, drainage and landscaping.[6]


It is not a secret that successful waste recovery requires a combination of removing barriers, incentivising material recovery, influencing culture and increasing market demand for recycled materials. The reforms which are the subject of the consultation papers focus on capturing materials lost to landfill and discouraging indefinite stockpiling of materials. We look forward to seeing consultations on reforms relating to other elements in the waste recovery process, such as increasing market demand for recycled materials, in order to achieve Waste Strategy 2030 targets.


[2] https://www.vicroads.vic.gov.au/planning-and-projects/environment/resources-and-recycling

[3] https://www.sustainability.vic.gov.au/Government/Waste-and-resource-recovery/Recycled-materials-in-pavement

[4] https://www.infrastructurevictoria.com.au/wp-content/uploads/2019/10/International-and-Australian-comparisons-Alphabeta-September-2019-FINAL-REPORT.pdf; https://ec.europa.eu/environment/gpp/pdf/news_alert/Issue54_Case_Study111_Wales_Waste_Infrastructure.pdf

[5] https://www.infrastructurevictoria.com.au/wp-content/uploads/2019/10/International-and-Australian-comparisons-Alphabeta-September-2019-FINAL-REPORT.pdf

[6] https://www.infrastructurevictoria.com.au/wp-content/uploads/2019/10/Victorian-Waste-Flows-Blue-Environment-October-2019-FINAL-REPORT.pdf