The proposed Victorian ban on e-waste in landfill is marching ahead, with the release this month of a policy proposal for public submissions.
E-waste, like this collected by Mosman Council for recycling, will soon be banned from Victoria's landfills. Source: Mosman Council
The Policy Impact Assessment (PIA), open for feedback until January 25, applies a cost-benefit analysis to five options for achieving the ban, (including a null option). The preferred option combines a total ban on e-waste in landfill with a moderate level of coverage by a state-administered collection service.
The policy has been rigorously examined before arriving at this point. The PIA elucidates the current state of play of e-waste in Victoria - growing at three times the rate of general municipal waste - and the necessity of removing it from landfill. It comprehensively addresses a wide range of stakeholders and concerns; from environmental and public health, to manufacturers, the waste management industry, local councils and more.
Various alternative methods of achieving the stated aim of reductions in landfilled e-waste are posited, including regulatory and non-regulatory possibilities. The final options all include a suite of methods, which comprise the ban and the collection program; legislated management standards; an education and communication campaign; and upgrades to storage facilities at transfer stations.
The collection program in particular was subjected to an in-depth financial cost-benefit analysis by consultants Marsden Jacob Associates, Blue Environment and Ascend Waste and Environment on behalf of the Department of Environment, Land, Water and Planning. Analyses were done according to breadth of collection points, defined as "High", "Medium" or "Low" accessibility. Also considered was a variation of the ban, which excluded only hazardous items from landfill.
Under the highest level of collection access, which notably includes kerbside collection in metropolitan areas, an estimated 922,000 tonnes of e-waste would be diverted from landfill by 2035. That compares to 573,000 and 520,000 for the medium and low collection schemes respectively, with the difference between the two being made up by mobile collection points for low-population density regions. All three levels of access also include permanent drop-off points in rural areas, although only in selected towns.
Under the business as usual (BAU) option, it was estimated that 104,000 tonnes of e-waste would be diverted from landfill in 2035. That would comprise 41% of e-waste generated in Victoria that year, a slackening relative to 2015's rate of 43%. A total ban, meanwhile, would see between 149,000 and 184,000 tonnes recovered in 2035, ranging from 58% to 72% of all e-waste.
These are not insubstantial rates of recovery, but nor is the mooted price tag. By far the greatest costs are incurred in materials processing, reaching as high as $280.4 million of a $433.6 million total for the most comprehensive option, or $172.7 of the preferred option's $266.8 price tag.
With equal Benefits to Cost Ratios (BCR) of 1.05, however, both the highest-coverage and preferred options are financially net positive in addition to their significant positive externalities and non-quantitative benefits.
Other regulatory methods considered in the review, and found largely unworkable, were differential levies (which would necessitate a broader review of landfill) and product stewardship (inefficient and ineffective when enacted at a state level).
The review also considered favourably several non-regulatory approaches, including the upgraded transfer stations, state-level e-waste collection service and education campaign that were eventually included. Also touted was a market support program - although the report notes that the Andrews government already has a resource recovery industry development plan in place.
Among risks considered by the PIA were increased inappropriate disposal (such as dumping, stockpiling, and exporting); inadequate levels of recovery; and environmental and health risks of processing. Industry types will particularly appreciate the acknowledgement of increased and potentially undue additional financial burden imposed on landfill operators, waste collectors, councils and recyclers.
The report notes that "[a] ‘hardship' type provision already exists under section 30A of the EP Act... [t]he government is in the process of determining how this would be applied". Discussion over what constitutes "reasonably practical" in reference to e-waste disposal is also underway. And while the PIA notes the importance of achieving "clarity...or guidance" in this area, the public submissions will no doubt include plenty of input into the distribution of costs within the waste sector.
Local councils in particular may face anything from a $40 million cost to a $50 million benefit over 15 years, while landfill operators as a sector will pay around $1.8 million in compliance costs.
Distribution of impacts of e-waste ban Distribution of impacts of e-waste ban. Source: DELWP
Other potentially contentious issues raised in the report include the preference for centralised drop-off points rather than kerbside recycling; the increased compliance costs on small businesses that generate e-waste; and the forecasted changes to makeup of e-waste, which may render some schemes commercially unviable by 2035.