Status of this Submission
This Submission has been prepared by the City of Armadale. The City of Armadale is a
Local Government Authority located approximately 30 kilometres south east of Perth,
Western Australia. The City covers an area of 545 square kilometres and has a
population of approximately 65,000 which is expected to grow to 85,000 over the next
ten years. The City of Armadale is a member of the Rivers Regional Council however
the views of the Regional Council may differ from the positions taken in this
submission.
The City of Armadale operates the Hopkinson Road Landfill and Recycling Facility
located in the suburb of Hilbert. In 2004 the City began to separate electronic waste
from the solid waste stream that would otherwise be destined for landfill. In 2008 the
City took the decision, due to a lack of reliable electronic waste recyclers locally, to
become the first Local Authority in Western Australia to dismantle electronic waste.
353 tonnes has been removed from the waste stream. The City funded this through the
collection of gate fees, rates and funding from the State Government. In 2010 the City
received $98,161.10 in funding from the Western Australian State Government Waste
Authority’s, Strategic Waste Initiatives Scheme (SWIS), to support the expansion of the
City’s electronic waste dismantling operation.
Due to the short consultation period and the meeting schedule of Council and its
Committees, it has not yet been possible for this submission to be endorsed by the
Council. This submission will be presented to Council on Monday, 19th December 2011
and the Department will be informed of any changes to this submission following
consideration by Council
Executive Summary
The City of Armadale believes the burden of managing end of life electronic equipment
should not fall on Local Government and supports the Federal Government’s proposed
Extended Producer Responsibility approach.
The City provides the following recommendations that:
 The Regulations should reduce the number of individual product codes that
service providers are required to classify products into. The products should be
reduced to 4 or 5 key categories for collection and dismantling with numbers and
total weights recorded. After dismantling a nett weight balance be maintained
until final material recovery is achieved;
 The Regulations specify that approved co-regulatory arrangements will have the
obligation to accept all tonnages of eligible products collected at an approved
collection point; and,
 The Regulations should not differentiate between commercial and household
usage if recycling costs have been covered at point of purchase.
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Collection costs must be covered by the liable parties if there is to be no charge
at the collection point
That the Material Recovery Target for printers and computer products and the
television class of products be increased to 90% to reflect highest material
recovery rates service providers are already achieving. And, that additional
targets for computers are added which include targets for the recovery of
individual materials and/or components.
That the Regulations include additional detail or controls as to how an
administrator may appoint service providers ensuring that it is not anticompetitive to current processors and ensures a competitive market place.
That the Regulations encourage community involvement in the recovery and
processing of waste products.
1.04 – Application
Schedule 1 – Products and product codes
The regulations provide no less than 74 individual products and product codes in to
which electronic products manufactured and collected must be classified. Manufacturers
and importers are able to classify products into product codes with relative ease given
they know the specifications of the products and the number imported or manufactured.
On the resource recovery side, it is potentially very difficult and very labour intensive
for a service provider to accurately determine which product code an item of electronic
waste should be attributed to, given the number of codes and the wide variety of
products in the marketplace. Errors will be made in this respect, puts a huge reporting
burden on small service providers and will be impossible to audit once dismantled. The
potential for false claims will be high.
Dependant upon how a service provider receives payment for the processing of eligible
products, there is also the potential for misleading product codes to be deliberately used
to increase tonnages collected for individual products in some classes. In particular,
where the ‘other’ product code in some classes has a higher conversion factor than some
of the products in the class and given that selecting the ‘other’ product code would be
less time consuming than determining the actual product code.
Reducing the number of product codes that service providers are required to classify
products into would reduce the likelihood of errors and reduce the burden on service
providers. The products should be reduced to 4 or five key categories for collection and
dismantling with numbers and total weights recorded. After dismantling a nett weight
balance be maintained until final material recovery is achieved. Auditing will be
possible.
Recommendation: The Regulations, where possible, reduce the number of
individual product codes that service providers are required to classify products
into.
2.
Division 3.1 – Outcomes
3.01 – Outcomes
Section 3.01 2) a) states “a person must not be charged for the collection of a product
for recycling if the product was used only for household purposes…”. The City has been
collecting electronic waste at a fixed collection point since 2004 and in 2010 collected
electronic waste from the verges of residents. The cost involved was funded from
landfill gate fees and residential rates for waste services. It is assumed, under this
section, that the liable parties will be responsible for covering collection costs.
Determining household and commercial use of a product at the collection point is
extremely difficult. If the commercial entity has paid for the product to be recycled at
point of purchase there should be no differentiation.
Recommendation: The Regulations, should not differentiate between commercial
and household usage if recycling costs have been covered at point of purchase.
Collection costs must be covered by the liable parties if there is to be no charge at
the collection point.
Division 3.3 – Recycling
3.04 – Working out recycling targets
Given the massive volume of electronic waste in the community which could potentially
be recycled, the City is concerned that the target amount could be exceeded. The
regulations are unspecific about how this excess tonnage would be handled.
It is accepted that section 3.05 – How recycling targets may be met, makes provision for
additional tonnages collected in one financial year to be carried forward to meet up to
25% of the next financial year’s target. This provision alleviates some of the City’s
concerns, however, if this situation arises it will effectively reduce the tonnage available
for collection the next financial year.
The City believes that the Regulations should specify that approved co-regulatory
arrangements will be obliged to accept all tonnages of eligible products collected at an
approved collection point. Turning residents away once targets have been reached is not
an option. Ewaste will either be collected at collection points or from the roadside. It
appears Local Government will be the default collector one way or another. Without
such a guarantee it is unlikely that the City would be comfortable participating in the
scheme.
Recommendation: The Regulations specify that approved co-regulatory
arrangements will have the obligation to accept all tonnages of eligible products
collected at an approved collection point.
Division 3.4 – Material recovery from recycling
3.
3.06 – Material recovery targets
The City believes that the 75% material recovery target would have a negative impact.
The City is currently achieving a material recovery rates in excess of 90%, with the
more expensive labour intensive dismantling. The 75% target is low and accommodates
service providers using cheaper mechanical means of separation and does not encourage
them to improve. A target this low could see these recovery rates become the industry
norm to remain competitive. The 25% waste would contain most of the materials that
need to be removed from landfill.
In addition, the target of 75% can easily be reached for computers by recycling the
entire unit as steel and without any dismantling or separation of higher value
commodities. Such a target for computers may inhibit the most effective recovery of
resources. Creating a separate target for individual materials for computers alone would
encourage more effective recovery of materials.
The Regulations do not provide an incentive for manufacturers to design products which
can be completely recycled or dismantled efficiently. A low target may encourage
manufacturers to use cheaper non-recyclable materials whilst still achieving material
recovery targets. Increasing the material recovery target is one way to promote better
and more sustainable product design.
Recommendation: That the Material Recovery Target for printers and computer
products and the television class of products be increased to 90% to reflect highest
material recovery rates service providers are already achieving. And, that
additional targets for computers are added which include targets for the recovery
of individual materials and/or components.
4.01 – Matters to be dealt with by co-regulatory agreements
The City is concerned that the Administrator of a co-regulatory agreement has the sole
power to determine the service providers used without any obligation to use transparent
or competitive purchasing principles. This potentially has the ability to affect free
competition in the marketplace and gives the Administrator the power to remove waste
supply from some processors, effectively removing their source of income. If a single
service provider was selected this would create a monopoly removing all competition
from the marketplace. The City believes that it is unlikely that the liable parties would
accept this as is not in their best interests.
Recommendation: That the Regulations include additional detail or controls as to
how an administrator may appoint service providers ensuring that it is not anticompetitive to current processors and ensures a competitive market place.
Matters not covered by the regulations
The processing of recyclable material provides an opportunity for small communities
and non profit groups to participate in the material recovery.
This provides several benefits:
 An employment opportunity to small communities and non profit groups;
 A funding opportunity to community groups; and
 Indirectly educates the community on recycling by having them involved.
4.
In rural areas the Department of Environment and Conservation is pushing to have all
landfills manned. The unit cost to local communities/Councils is high considering the
numbers of residents using the facility over a given time. Offsetting the labour costs
with additional activities such as recycling during slack periods would be a benefit to
the community, commercially and environmentally.
Community involvement in the ewaste recovery and recycling process will lay the
foundations and set up a network for the inclusion of future items covered under Product
Stewardship Regulations. This will be significant in remote areas.
Recommendation: That the Regulations encourage community involvement in the
recovery and processing of waste products.
5.