Australian Government
Department of the Environment
COST RECOVERY IMPLEMENTATION STATEMENT
Hazardous Waste Permits
2015-16
Cost recovery involves government entities charging individuals or non-government
organisations some or all of the efficient costs of a specific government activity. This may
include goods, services or regulation, or a combination of them. The Australian Government
Cost Recovery Guidelines (the CRGs)1 set out the overarching framework under which
government entities design, implement and review cost recovered activities.
1
The CRGs are available on the Department of Finance website (www.finance.gov.au).
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1.
INTRODUCTION
1.1
Purpose of the CRIS
This Cost Recovery Implementation Statement (CRIS) provides information on how the
Department of the Environment (the Department) implements cost recovery for hazardous
waste import, export and transit permitting. It also reports financial and non-financial
performance information for hazardous waste import, export and transit permitting and
contains financial forecasts for 2015-16 and three forward years. The Department will
maintain the CRIS until the activity or cost recovery for the activity has been discontinued.
1.2
Description of the activity
Regulation of international movements of hazardous waste
In Australia, the regulation of waste management is generally the responsibility of state
and territory governments. However, the Australian Government has some regulatory
responsibilities in relation to transboundary movements of hazardous waste. The
Hazardous Waste (Regulation of Exports and Imports) Act 1989, and associated
regulations2, define hazardous waste as waste having the following characteristics:3
■
explosive
■
flammable liquids/solids
■
poisonous
■
toxic
■
ecotoxic
■
infectious substances.
This will generally include, among others, the following wastes (unless they do not have
any of the characteristics outlined above):4
■
clinical wastes;
■
waste oils/water, hydrocarbons/water mixtures, emulsions;
■
wastes from the production, formulation and use of resins, latex, plasticisers,
glues/adhesives;
■
wastes resulting from surface treatment of metals and plastics;
■
residues arising from industrial waste disposal operations; and
■
wastes which contain certain compounds such as: copper, zinc, cadmium, mercury, lead
2
• Hazardous Waste (Regulation of Exports and Imports) (OECD Decision) Regulations 1996.
• Hazardous Waste (Regulation of Exports and Imports) (Fees) Regulations 1990.
• Hazardous Waste (Regulation of Exports and Imports) Regulations 1996.
• Hazardous Waste (Regulation of Exports and Imports) Waigani Convention Regulations 1999.
• Hazardous Waste (Regulation of Exports and Imports) Decision IV/9 Regulations 1999.
• Hazardous Waste (Regulation of Exports and Imports) Regulations 2010.
3
4
Specifically, the legislation refers to any of the characteristics mentioned in Annex III to the Basel Convention.
See Annex 1 of the Basel Convention.
Page 2 of 18
and asbestos.
International obligations
Australia has various international obligations in relation to the management and
transboundary movements of hazardous waste. In particular, Australia is a party to the
Basel Convention (see box Error! Reference source not found.).
1.1 The Basel Convention5
Concerns over the risks to human health and the environment associated with
uncontrolled international movements of hazardous waste led to the
development of the Basel Convention in the early 1990s. The key objectives of
the Basel Convention are:
■
to minimise the generation of hazardous waste
■
to ensure the availability of adequate disposal facilities for the
environmentally sound management of hazardous wastes
■
to reduce transboundary movements of hazardous wastes to a minimum
consistent with their environmentally sound and efficient management.
The Convention places obligations on countries that are party to it to:
■
minimise generation of hazardous waste
■
ensure adequate disposal facilities are available
■
control and reduce international movements of hazardous waste
■
ensure environmentally sound management of wastes
■
prevent and punish illegal traffic.
The Convention establishes a global control system for transboundary
movements of hazardous waste.6 Prior written notification by the State of
export to the competent authorities of the States of import and transit are
required before transboundary movements of hazardous waste can take
place.
The Basel Convention allows parties to enter into bilateral, regional or multilateral
arrangements with non-parties provided these arrangements are consistent with the
environmentally sound management of such wastes as required by the Convention.
Australia is a signatory to three such agreements.
■
The Organisation for Economic Cooperation and Development (OECD) Control System —
the OECD has special rules for shipments of waste for recovery purposes.
5
The Allen Consulting Group, The Hazardous Waste (Regulation of Exports and Imports) Act 1989: A National
Competition Policy Review, February 2001, pp. 14-15.
6
Department of the Environment website, http://www.environment.gov.au/protection/hazardouswaste/conventions#waigani, accessed 26 March 2015.
Page 3 of 18
■
The Waigani Convention7 — the main effect of this Convention is to ban the import of
all hazardous and radioactive wastes into South Pacific Forum Island Countries. It also
enables Australia to receive hazardous wastes exported from South Pacific Forum Island
countries that are not parties to the Basel Convention.8
■
A bilateral agreement with East Timor is also in place.
Permitting system for international movements of hazardous waste
To comply with Australia’s international obligations, the Australian Government operates a
permitting system for exports and imports of hazardous waste, including hazardous waste
transiting through Australia. Anyone wishing to import or export hazardous waste to or
from Australia must apply for a permit from the Department of the Environment. There are
several types of permits depending on what country the hazardous waste is going to or
coming from.9
In addition to processing permit applications, the Department also undertakes compliance
and enforcement activities, as well as undertaking various policy advice functions.10
Policy case for cost recovery
In broad terms, the regulatory services provided by government can be funded through
either general taxation revenue or through some form of cost recovery arrangement.
Advantages for a cost recovery arrangement for hazardous waste permitting include the
following.
■
Improved efficiency — a fee or charge has the potential to force generators of
hazardous waste, as well as firms further down the disposal chain, to take into account
the cost of operating the regulatory framework (for example, waste collection service
providers) in making their economic decisions, leading to a more efficient allocation of
resources.
■
Discouraging the generation of hazardous waste — hazardous waste permit fees
increases the cost of disposing of hazardous waste (where the waste is exported from,
imported into or transited through Australia). Where the costs are passed onto the
waste generator, this may discourage the generation of hazardous waste.
■
Improved equity — a fee or charge can ensure that the users or beneficiaries of the
regulatory framework pay for it, rather than the general taxpayers, who may not use or
benefit from it. Hazardous waste permit fees that are commensurate with permitting
administration costs pass the cost of operating the regulatory framework onto
generators of hazardous waste.
■
Reducing the call on general taxation revenue — all taxes have efficiency costs. Funding
regulatory services through an efficient cost recovery arrangement reduces the burden
7
More formally, the Convention to Ban the Importation into Forum Island Countries of Hazardous and
Radioactive Wastes and to Control Transboundary Movement and Management of Hazardous Wastes within
the South Pacific Region.
8
Department of the Environment website, http://www.environment.gov.au/protection/hazardouswaste/conventions, accessed 25 March 2015.
9
Department of the Environment website, http://www.environment.gov.au/topics/environmentprotection/hazardous-waste/applying-permit, accessed 25 March 2015.
10
Department of the Environment website, http://www.environment.gov.au/protection/hazardous-waste,
accessed 25 March 2015.
Page 4 of 18
on general taxpayers and minimise the associated efficiency losses.
■
Instilling cost consciousness in regulatory agencies — cost recovery arrangements may
improve the transparency of regulators and make them more accountable to users of
the regulatory system.
There is a sound in-principle case to recover the costs incurred by the Government in
operating the hazardous waste permitting activities.
2.
2.1
POLICY AND STATUTORY AUTHORITY TO COST RECOVER
Government policy approval to cost recover the activity
Partial cost recovery arrangements for the administration and implementation of the
Hazardous Waste (Regulation of Exports and Imports) Act 1989 were approved by the then
Minister for Finance and Deregulation, Senator the Hon Penny Wong, on 15 August 2011
after a portfolio-wide cost recovery review. This approval was granted on the grounds that
the Department continue to absorb the unrecovered costs of activities under the
Hazardous Waste Act, thus resulting in no fiscal impact on the Budget.
2.2
Statutory authority to charge
Section 32 of the Hazardous Waste (Regulation of Exports and Imports) Act 1989 provides
the legislative basis for the imposition of permit fees. The specific fees are prescribed in the
regulations, but may not exceed $8 000.
3.
3.1
COST RECOVERY MODEL
Outputs and business processes of the activity
The activity involves the assessment of applications for the grant of permits for import, export
and transit of hazardous wastes across Australia’s international border.
The outputs delivered under the hazardous waste import, export and transit permitting
activities are:
1. Export permits
1.1 New export permit – Basel
1.2 New export permit – Special
1.3 Export permit renewal – Basel
1.4 Export permit renewal – Special
1.5 Variation to export permit – Basel
1.6 Variation to export permit – Special
1.1, 1.3, 1.5 Additional fee per transit country – Basel
1.2, 1.4, 1.6 Additional fee per transit country – Special
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2. Import permits
2.1 Import permit for recovery – Basel
2.2 Import permit for recovery – Special
2.3 Import permit (excluding for recovery) – Basel
2.4 Import permit (excluding for recovery) – Special
2.5 Variation to import permit for recovery – Basel
2.6 Variation to import permit for recovery – Special
2.7 Variation to import permit (excluding for recovery) – Basel
2.8 Variation to import permit (excluding for recovery) – Special
3. Transit permits
3.1 Transit permit – Basel
3.2 Transit permit – Special
3.3 Variation to transit permit – Basel
3.4 Variation to transit permit – Special
3.2
Costs of the activity
Cost drivers vary across the various activities undertaken by the hazardous waste permitting
team. The main cost drivers of each activity where there is an in-principle case for cost recovery,
are summarised in table 3.1 and discussed in greater detail below.
Table 3.1: Key cost drivers
Activities
Key cost drivers
Commonwealth Government activities
Handling enquiries
Permit assessment, liaison,
decision making and monitoring.
Compliance and enforcement
activities
The main cost drivers are:
■
the number of enquiries
■
the complexity of the enquiries.
The main cost drivers are:
■
the number of permit applications
■
the complexity of the application (e.g. domestic capacity
issues to be resolved, contentious issues etc)
■
the type of permit
■
the number of transit countries in the permit application
■
the quality/completeness of the application
■
Whether any objections are received to the application
■
Whether an application is varied.
■
The resources allocated to compliance and enforcement
activities has essentially depended on the available
resources.
■
While not directly linked, both the volume of waste
crossing the border and the need for compliance and
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enforcement activities is likely to increase as the volume
of hazardous waste generated increases.
Administrative matters directly
related to administration of the
Act
■
The administrative tasks supporting the permit
assessment process is likely to be closely linked to the
number of permits assessed.
Ongoing improvement of
processes directly related to the
administration of the Act.
■
The resources allocated to ongoing process improvements
has, in the past, depended on the resources available.
■
No close link between resources allocated to these
activities.
The capacity of the Australian Customs and Border Protection Service to undertake monitoring
and detection activities (such as container scans at ports) has a direct impact on the number of
matters referred to the Department for further investigation.
Resources allocated to assessing permits
The main factors driving the amount of resources allocated to assessing permits and the
administrative processes to support these activities are as follows.
■
The number of applications — as the number of applications increase, more resources are
required to assess them.
■
The complexity of the application — the consideration of domestic capacity, special
requirements of some Competent Authorities and other application-specific issues can
significantly influence the resources required to asses an application.
■
The type of application — the resources required to assess an application varies significantly
depending on the type of application. It is estimated that:
– Of all the permit types, transit permits require the least resources
– Import permits require around 50 per cent more resources to assess, compared to a
transit permit
– Export permits require significantly more resources due to the requirement to assess
whether there is domestic capacity to process or dispose of the waste. This can also lead
to disputes which require additional resources. The resources required to assess permit
applications also depends on whether:
… The waste is being exported for recovery operations/further processing — the
resources required to assess this type of permit are estimated at around three times
that for a transit permit (or around twice that for an import permit).
… The waste is being exported for final disposal — there are relatively few applications
for this type of permit (three in the past four years), but the resources required for this
type of permit can vary and are significantly higher than permits to export waste for
recovery operations/further processing.
■
The number of transit countries — the waste permitting team estimate that each additional
OECD country the waste is transiting through takes an additional two hours, while each
additional non-OECD country takes an additional four hours.
■
The quality of the application — the Department receives a significant number of applications
that are incomplete or do not include sufficient information for the hazardous waste
permitting team to assess. This requires further liaison with the applicant and can require
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significant resources.
The number of applications (by type) over time is shown in Table 3.2. Despite a small decline in
the number of applications in 2014, there has been a general upward trend over the past six
years. The number of permit applications has roughly doubled between the 2009-10 period and
the 2013-14 period. This is mainly due to an increase in the number of applications for permits
to export hazardous waste for recovery operations/further processing and transit permits.
Table 3.2: Number of applications over time
70
Export for final
disposal
60
Number
50
40
Export for
further
processing
30
Import
20
Transit
10
0
2009
2010
2011
2012
2013
2014
Resources allocated to handling enquiries
The main factors driving the amount of resources allocated to handling enquiries includes:
■
the number of enquiries — as for the number of permit applications, as the number of
inquiries increases, the resources required to handle these inquiries also increases.
■
the complexity of the enquiries — some enquiries can be answered relatively easily, while
others require a more detailed assessment of whether the material is considered to be
hazardous waste for the purposes of the Act.
Resources for the remaining activities
Resources for the remaining activities — including, compliance and enforcement activities and
ongoing improvements of work practices — have not generally been specifically allocated.
Rather, these activities have been undertaken with any surplus resources allocated to the
hazardous waste permitting team. There is unlikely to be a direct link between these activities
and the number of permits or any other measurable variable. Nevertheless, there may be an
indirect link; as the volume of hazardous waste generated increases, both the volume of
hazardous waste crossing the border is likely to increase, there may also be a greater need for
compliance and enforcement activities.
Around 80 per cent of the costs that were identified as recoverable can be directly linked to
applications (Table 3.3Error! Reference source not found.). The remaining 20 per cent of costs
that were identified as recoverable cannot be specifically linked to applications.
Demand is variable between years based on industry activities, domestic and global economic
outlook and the types of wastes generated. Variability also arises as Australia develops, or loses,
Page 8 of 18
infrastructure to deal with specific types of wastes resulting respectively in a decrease or
increase in permit applications. Further effects will arise from possible ratification by Australia
of new hazardous wastes and their scheduling on the Hazardous Waste Act that would increase
demand. Although it is difficult to accurately predict how many applications will be received
each year, the following table is based on current trends and industry demands.
Table 3.3: Allocation of costs for 2014
Total costs
$
Costs directly linked to applications
Application assessment
618 599
Administrative matters
79 653
Total costs directly linked to applications
698 252
Other recoverable costs
Handling enquiries
79 653
Compliance/enforcement
39 827
Ongoing improvement to processes
39 827
Total other recoverable costs
159 306
Total
857 558
The Department conducts an assessment of applications submitted by industry under the
Hazardous Waste Act to import, export or transit hazardous wastes through Australian territory
and provides recommendations to the Minister and Departmental delegates. The two main
categories of permits are Basel and Special permits. As a general rule, Basel permits require a
higher level of effort and resources. All permits are event related and applications are assessed
on a case by case basis. They vary in nature and complexity requiring different levels of
Departmental resources to complete.
In general, applications require legal assessment of insurance and contractual arrangements as
well as complex technical and scientific assessments to ensure the waste will be transported,
managed and disposed of in an environmentally sound manner in Australia and overseas.
The assessment also includes liaison with state and territory government agencies, the Basel
Convention competent authorities of the country of export or import and the transit countries.
Some applications may be the subject of objections from industry stakeholders and decisions
may be appealed to the Administrative Appeals Tribunal, thus incurring further administrative
and legal costs.
The permits — which are a form of licensing —establish clear criteria ensuring that only suitably
skilled and licensed companies are issued permits with the prior informed consent of all
countries involved, thereby controlling the transboundary movement of hazardous wastes and
their disposal.
The implementation of Commonwealth hazardous waste legislation is primarily undertaken by
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the hazardous waste permitting team within the Department. However, as waste management
is mainly the responsibility of state and territory governments, state and territory government
regulators also have a significant role in the permit application assessment process.
The total costs incurred by the hazardous waste permitting team are summarised in Table 3.4.
The salary costs include a share of the Department’s indirect costs, including building rent,
equipment and supplies and various corporate functions. These costs have been allocated to the
waste permitting team using the Department of Finance’s standard formula.
Table 3.4: Hazardous waste permitting team — 2014 calendar year costs
Cost
$
Salaries
796 530
Consultancies
10 890
Professional services
11 980
Legal
22 500
Gazettals
88 648
HWTG meeting
525
HWTG non-staff travel
858
Staff travel
3 715
Interpreters
1 565
Total expenses
937 211
Table 3.5: Cost estimate breakdown for 2015-16 (Recoverable costs)
Direct costs
Indirect costs
Capital costsa
$
$
$
Output 1 – Export permits
471,657
114,342
346,500
Output 2 – Import permits
257,267
62,368
189,000
Output 3 – Transit permits
128,634
31,184
94,500
TOTAL
875,558
207,894
630,000
a
For the development and implementation of an electronic workflow system for receiving and
processing permit applications. This system will operate for at least three years, post-release, before
requiring updating.
3.3
Design of cost recovery charges
Fees are the appropriate mechanism to recover the costs incurred by the Commonwealth in
administering and regulating the permit activities. Identifying the applicants of the permits is
straightforward as permits are event based, and must be obtained to enable the transboundary
transportation of hazardous waste.
The current fees charged for hazardous waste permit applications do not reflect the actual costs
Page 10 of 18
of processing these applications. Requirements for legal advice and representation for
applications are not predictable and vary widely from case to case. The costs of enforcing
compliance with the Hazardous Waste Act are not recovered.
The review of the Hazardous Waste Act provides the Department with an opportunity to review
not only the fee structure, but also the means by which compliance may be achieved.
Nonetheless, it is likely that there always will be some cost of administering and implementing
the Hazardous Waste Act that is not recovered.
Fees were set in 1996 on the basis of the time required to process an application at public
service rates, then $53 per hour. This level of fees was intended not to inhibit the regulatory
objective, which might arise if the full costs of regulation were charged. It is desirable that the
costs to the commercial sector be reasonable and not prohibitive, since this could encourage
non-compliance which would not be consistent with environmental or health policy goals.
Obligations under the Basel Convention and the Hazardous Waste Act require that the recycling,
recovery and disposal of hazardous wastes be conducted in an environmentally sound manner.
In cases where Australia does not have the capacity or infrastructure to undertake these
operations in an environmentally sound manner, export of the waste under permit to a suitable
facility overseas may be required. If permit application and processing fees under the Hazardous
Waste Act were set too high, there could be an increase in less environmentally sound disposal
operations such as landfill, illegal dumping or illicit non-controlled export. These alternatives not
only would impact on human health and the environment, but also could reflect adversely on
Australia’s international obligations to deal with hazardous wastes in an environmentally sound
manner.
The current fees for hazardous waste permits are summarised in Table 3.6. The fee structure
differentiates between:
■
the type of application (export, import or transit)
■
whether the permits are:
– Basel permits (permits involving countries that are a party to the Basel Convention)
– Special permits (permits involving countries that are party to a bilateral or multilateral
Agreement with Australia under the Basel Convention).
For most applications, there is a fixed application fee; however, for new export permits there is
also a variable component based on the number of transit countries covered by the permit.
Table 3.6: Current cost recovery arrangements for hazardous waste permits
Basel permit
Special permit
$
$
4440
480
Export permit renewal
420
420
Variation to export permit
370
370
Export permits
New export permit
Page 11 of 18
Additional fee per transit country
110
110
Import permit for recovery
210
210
Import permit (excluding for recovery)
270
270
Variation to import permit for recovery
210
110
Variation to import permit (excluding for recovery)
210
210
Transit permit
110
110
Variation to transit permit
110
110
Import permits
Transit permits
Note: Basel permits involve countries that are a party to the Basel Convention. Special permits involve countries
that are a party to a bilateral or multilateral Agreement with Australia under the Basel Convention.
Source: Hazardous Waste (Regulation of Exports and Imports) (Fees) Regulations 1990.
The 2011 Cost Recovery Impact Statement for hazardous waste permits estimated that the cost
of the Government’s activities in relation to hazardous waste permits would be around
$2.8 million over the 2012 to 2014 period (Table Error! Reference source not found.). The
overall level of cost recovery for these activities was estimated at around 3.2 per cent of the
total costs over this period. More recent information from the calendar year 2014 suggests that
permit fees recovered around 5.5 per cent of the total costs incurred by the hazardous waste
permitting team.
The processing of applications for permits under the Hazardous Waste Act involves salary costs,
the costs of publishing notices in the Australian Government Gazette and, in some cases, extra
costs for legal advice. Applicants also may seek the review of decisions under the Hazardous
Waste Act by the Administrative Appeals Tribunal. In such cases, the Department incurs the
further expense of engaging legal counsel.
Each application requires two to three Gazette notices at an average cost of $400 each.
Currently, the Department’s own Legal Section is the primary provider of legal advice for the
permit scheme. More complex legal advice needs, such as those with constitutional or
international trade aspects, still require assistance from the Australian Government Solicitor. It
is impossible to predict which applications will require legal advice, but as an indication, the
expenditure by the Hazardous Waste Section on legal advice in the 2014 calendar year was $22
500.
Table 3.7: Charge rates and revenue estimates for 2015-16
Charge title
Export Permits
New export permit – Basel
New export permit – Special
Export permit renewal –
Basel or Special
Variation to export permit –
Type
Rate
$
Est
volume
Estimated
total
revenue
$
Fee
Fee
Fee
4,440
480
420
5
22
5
Fee
370
2
Output
Output 1
22,200 Output 1.1
10,560 Output 1.2
2,100 Output 1.3 &
Output 1.4
740 Output 1.5 &
Page 12 of 18
Basel or Special
Additional fee per transit
country – Basel or Special
Import permits
Import permit for recovery –
Basel or Special
Import permit (excluding for
recovery) – Basel or Special
Variation to import permit
for recovery – Basel
Variation to import permit
for recovery – Special
Variation to import permit
(excluding for recovery) –
Basel or Special
Transit permits
Transit permit and variations
to transit permits – Basel or
Special
TOTAL
4.
Output 1.6
7,040 Output 1.1 - 1.6
Fee
110
64
Fee
210
15
Fee
270
4
Fee
210
0
Fee
110
0
0 Output 2.6
Fee
210
0
0 Output 2.7 &
Output 2.8
Fee
110
9
Output 2
3,150 Output 2.1 &
Output 2.2
1,080 Output 2.3 &
Output 2.4
0 Output 2.5
Output 3
990 Output 3.1 to
Output 3.4
$47,860
RISK ASSESSMENT
The overall risk rating associated with the cost recovery of the hazardous waste import, export
and transit permitting is medium. Under the risk assessment rating guidance, the majority of
risks are rated as low, given the relatively small number of transactions and companies
involved in the permit scheme and the low costs of permits. However, under the guidance any
cost recovery arrangement that involves a fee requires a risk rating of Medium for that aspect.
This means that the overall risk rating for the permit scheme is Medium.
5.
STAKEHOLDER ENGAGEMENT
The main users of permits are companies involved in the management of wastes. Stakeholders
are more widespread and include non- governmental organisations, industry representation
groups, the environment agencies of the state and territory governments, and some research
organisations.
No recent consultation has been undertaken on the current cost recovery arrangements
associated with the permit regime under the Hazardous Waste Act; however, a review of cost
recovery will be completed during the period of this statement and changes to the fee
structure and levels are possible. If the recommendations of the review include changes to the
fee structure, legislative amendments will be required, which is not likely to reach completion
before the end of 2015.
Page 13 of 18
Page 14 of 18
6.
FINANCIAL ESTIMATES
Table 6.1: Financial estimates to 2018-19
Expenses = X1
Budget year
2015-16
$
1,065,452
Forward estimates
2016-17
2017-18
$
$
1,091,179
1,159,452
2018-19
$
1,186,746
630,000
0
0
0
47,860
47,860
47,860
47,860
Balance = Y – X
-1,647,592
-1,043,319
-1,069,818
-1,097,112
Cumulative balance
-1,647,592
-2,690,911
-3,760,729
-4,857,841
Capital Expenditure =X2
Revenue = Y
Explain material variance
Explain balance
management strategy
Current fees and fee structures are not sufficient to ensure full
recovery of recoverable costs. Increased variance in 2015-16 relative
to forward estimates is due to capital project costs in that financial
year.
The cumulative balance presented is for the reported financial years
only. As this is a partially cost recovered activity, deficits are met from
departmental appropriation.
Page 15 of 18
7A.
FINANCIAL PERFORMANCE
Table 7A.1: Financial results 2010-11 to 2014-15
2010-11
$
2011-12
$
2012-13
$
2013-14
$
2014-15
(estimated
actual)
$
Expenses = X
411,253
350,051
508,823
736,334
1,013,714
Revenue = Y
12,440
17,450
24,576
43,261
44,200
Balance = Y – X
-398,813
-332,601
-484,247
-692,593
-969,514
Cumulative balance
-398,813
-731,414
-1,215,611
-1,908,254
-2,877,768
Explain material
variance
Current fees are insufficient to achieve full recovery of recoverable costs.
Explain impact on
balance management
strategy
The cumulative balance presented is for the reported financial years only.
As this is a partially cost recovered activity, deficits are met from
departmental appropriation.
7B.
NON-FINANCIAL PERFORMANCE
The hazardous waste permitting system is designed to regulate the export, import and transit
of hazardous waste to ensure that such shipments of waste are managed in an
environmentally sound manner. The following table sets out performance measures and
results for 2014-2015 relevant to the outputs identified in this CRIS.
Performance measure
Numbers of permit applications processed
Numbers of permit applications processed within statutory
timeframes
Number of permits granted (total and by type, ie import,
export, transit)
Number of incidences of potential non-compliance referred
by Australian Customs and Border Protection Service
2014-2015 results
58
57
53 permits were granted (11
imports, 29 exports and 13 transits)
15
In addition, the department has established a number of relevant performance metrics that
will allow for an assessment of the Hazardous Waste Act regulator’s performance against the
common set of performance measures under the Government’s Regulator Performance
Framework. A report is due at the end of the assessment period commencing on 1 July 2015
and ending on 30 June 2016. These metrics include:
Page 16 of 18

Regular, ongoing review of policies, procedures and requirements, including through
consultation and engagement with stakeholders, independent experts and industry
associations.

Demonstrated appropriate consultation with stakeholders prior to significant
regulatory or policy changes.

Demonstrated engagement with regulated entities to inform them of the regulators’
expectations.

Advice and guidance is widely available to stakeholders, with feedback mechanisms in
place to support and inform continuous improvement.

Documented procedures are in place to allow active and regular engagement with
stakeholders.
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8.
KEY FORWARD DATES AND EVENTS
Other than business as usual permit application processing activities, the following key forward
dates and events are worth noting:
- June 2015 conclusion of review of current cost recovery arrangements for hazardous waste
permitting
- July 2015 publication of proposed new cost recovery arrangements for hazardous waste
permitting
- 1 January 2016 proposed commencement of new cost recovery arrangements (initial phase)
- 1 January 2017 proposed commencement of second phase of new cost recovery
arrangements.
9.
CRIS APPROVAL AND CHANGE REGISTER
Table 9.1: CRIS approval and change register
Date of CRIS
change
CRIS change
Approver
30/06/2015
Certification of the
CRIS
Department of the
Environment
July 2015
New CRIS
Minister for the
Environment
Basis for change
Implementation of new
cost recovery
implementation
statement template
Commencement of new
cost recovery
arrangements
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