Litter in Sydney Harbour - Understanding litter and marine debris.
Litter and its associated social, financial and environmental costs, in particular marine/coastal ecological communities - are an important issue. However, they have been poorly analysed by past Commonwealth and state studies leading to inadequate policy responses.
For example, the 2014 Decision Regulatory Impact Statement (DRIS) on Packaging Impacts (the study to decide whether to adopt a national CDS and alternatives) failed to adequately scope out the full extent of the problem, and consequently produced a very poor analysis that resulted in no national action being taken to address beverage container litter. Our analysis of the RIS’s prepared over more than a decade reveals 3 failed reviews to ban plastic bags, 4 failed reviews of CDS, 2 RIS to deal with waste tyres (which also failed) and another two for electronic waste (the final one passed but went outside accepted process).
This is a critical problem as supposed ‘best practice regulation’ frameworks insist that any proposed new policy must be fully costed and deliver a net benefit expressed in economic terms. On the litter front, quite unbelievably, these analyses conclude that there is no need for further intervention as the amount of litter is steadily reducing.
"The DRIS into Packaging Impacts claimed that based on historic trends the amount of packaging entering the litter stream in 2013 was some 75,981 tonnes p.a. and was projected to drop by 9.5% in 2025 to just 68,722 tonnes p.a. without any government intervention or new initiatives. Conservatively, Boomerang Alliance estimates that number is underestimated by some 300%!"
Australian estimates of litter per capita are far lower than those in most developed countries, including those with highly developed product stewardship schemes covering key packaging sectors like container deposits schemes; bans on plastic bags and polystyrene food containers. Considering Australia’s climate and outdoor lifestyle, higher earnings per capita and high costs to manage litter across our rural communities, remote areas and extensive coastline - these estimates are most likely flawed. Based on more recent analysis undertaken by the NSW Government and ongoing failure to measure the amounts of litter managed across the private sector – we believe it is reasonable to conclude that the overall amount of litter incidence is underestimated by some 300-500% and consequently the cost is seriously underestimated.
As an example the 2014 Packaging Impacts DRIS cited above, placed a paltry benefit from the proposed litter reductions of just $7.81 million p.a. - $171.8million over the 22-year study period for a reduction of some 822,000 tonnes of litter (a value of $208.95 / tonne). By comparison it has been identified that in NSW, the average cost to recover litter across the state is some 10 times higher than estimated by the Commonwealth – with no estimates to assess the economic damage of litter or impact on biodiversity. If the Australian Government had accurately measured both the amount of litter generated and the costs already experienced, the economic savings identified in the DRIS would have increased from $171.8million over 22 years to a staggering $4.9billion dollar saving – and we would have a national Container Deposit System today.
Future Cost-Benefit and Cost Effectiveness studies undertaken for RIS processes should:
- Undertake a survey to identify the full costs to manage litter by the private sector, schools, councils, NGOs, private households and state government departments.
- Ensure they include a ‘participation cost’ based on the time each property expends to keep their property clean.
- Measure the impacts on marine environments and attribute a value to achieving Australian Government requirements to address marine debris (in particular plastics) as a key threatening process under the EPBC Act.
- Fully cost and factor indirect costs associated with litter and marine plastic pollution like the loss of amenity, impacts on property values and industry sectors like fisheries (contamination from ingestion of plastics), tourism (destruction of reefs and despoiling natural assets like beaches) and threats to biodiversity.
Put bluntly, government analyses of the litter stream consistently get it wrong. To illustrate the shoddy manner in which government analyses the litter stream when adopting waste policies we reviewed the Packaging Consultation RIS (2011) and Decision RIS (2014) – which used overly simplistic measures to calculate the incidence of litter without any solid backup data. The CRIS adopted a litter rate of 6% of all packaging consumed; the DRIS 27% of all packaging consumed ‘away from home’. Both of these estimates are largely unsubstantiated and at best would be characterised as an ‘educated guess’ and both are undermined by a high degree of uncertainty including:
- The amount of packaging consumed in Australia, which has recently been found to be underestimated (semi-finished and finished goods) by approx. 263,500t for plastic. Consequently the reported recycling rate is too high. Further to this finding, the survey used to establish the consumption and recycling of plastics packaging also appears to exclude the amount of plastics packaging of imported finished, filled goods.
- Continued debate that the proportion of packaging consumed away from home is significantly understated, as estimates of away from home consumption are based on a dated report undertaken by Hyder Consulting for the AFGC which is more accurately an analysis of the point of sale for beverages, but does not factor in the proportion of snacks and drinks purchased at supermarkets which are consumed away from home (e.g. a juice ‘popper’ included in packed lunches for school children; consumption from family barbeques or picnics; and the trend for cafes to purchase their soft drinks and bottled water in discounted carton packs). More recent NSW data regarding the contents of material found in residential waste and recycling bins contradicts these studies – indicating that in key food and grocery sectors, as much as 50% of packaging consumption (e.g. water and soft drink bottles, beer cans, etc.) are disposed of away from home and which have high potential to be littered.
Litter per person
In an effort to validate Australian litter estimates, Boomerang Alliance examined reports of litter per person from the USA and Scotland.
Commonwealth studies estimate the average amount of packaging litter entering the Australian environment each year at 73,699 tonnes p.a. which represents just 3.2kgs per capita. This is very low compared to international information. In 2009, Keep America Beautiful estimated that the amount of litter managed by municipal authorities was 6.9kgs per capita. This is similar to that in Scotland (2013, 2015) which estimated that 7.74kgs of litter was generated annually.
Further, both the Australian and Scottish studies are over simplified, in that they only study (at best) the litter recovered / present at the municipal level (although pay some attention to the large scale volunteer events like Clean up Australia Day). They fail to factor in the considerable volumes of rubbish recovered by the private sector, educational institutions or residential properties. Keep America Beautiful is the only report that quantifies litter on private sites (e.g. commercial building sites and educational institutions). When private sector litter recovery was factored in, the incidence of litter grows to 13.26kgs per capita – 5 times that estimated in Australia!
As a further point of comparison, a 1997 paper "Stormwater Gross Pollutants Industry Report" for the CRC for Catchment Hydrology indicated that over 12,000 tonnes of packaging litter entered Port Phillip each year – which only represents the Melbourne proportion of the litter stream that reaches its waterways – represents some 2.87kgs/person. This excludes terrestrial litter, and the amount of litter captured through gross pollutant traps, public bins, street sweeping, etc. but still indicates that the amount of packaging litter (i.e. nett of what is captured in traps or recovered through sweeping and clean ups) entering our waterways, just in our 15 largest coastal communities, represents some 47,000 tonnes per annum.
While dated, (since 1997 there has been a significant increase in plastic packaging consumption and huge growth in the sale and disposal of plastic water bottles) the following table illustrates the extent of the problem facing coastal communities and potential impact on their marine ecological communities:
While this review does not reflect the necessary rigour required for a formal cost-benefit analysis, it is clear that the amount of litter in Australia is being badly underestimated, which in turn distorts the nett impact of proposed policies such as a CDS.
International studies and localised studies into litter indicate it is likely that the overall level of annual litter generation is 3-5 times greater than previously thought.
Future litter studies should be expanded to capture total litter recovered (particularly that which is recovered via private sector cleaning) and the proportion of litter that is thought to remain in the litter stream.
The Boomerang Alliance believes that significant omissions have been made in calculating the cost of litter. This is based both on the amount of litter and a range of, to date, unaccounted costs that have been considered in other assessments.
Commonwealth Government analysis has estimated that the cost of litter as $350mpa, the studies then attribute the direct expenditure to managing the packaging proportion of litter in Australia as being $38million p.a. at a cost of $501 per tonne, then later discounts the benefit of reducing this amount to around 40% of that figure. These estimates don’t reflect the actual expenditure on litter reduction, but rather reflect a very limited and selective analysis that is restricted to:
- The cost of operating gross pollutant (litter) traps and street sweeping services and the cost of servicing municipal rubbish bins - but notably fails to capture the capital investment costs associated with traps, bins and equipment (which includes equipment replacement and the allocation of new bins and increased sweeping which would likely double the cost);
- The allocation of a value of $7.67 per hour to formalised community litter clean ups of some 15-17,000 tonnes p.a. but again notably excludes the significant costs to litter ENGOs like Clean up Australia and Keep Australia Beautiful - including the costs of volunteer recruitment, event promotion, provision of bags and gloves etc, and administration and fundraising which conservatively rival the volunteer labour costs identified in the Packaging DRIS. More typically volunteer labour is costed at over $20ph.
Other direct costs not captured by government analysis include:
- Informal clean up events by organisations such as Responsible Runners, Tangaroa Blue, Take 3, Two Hands Project, Project Aware etc. The volunteer hours these organisations mobilise are every bit as large as those captured within the DRIS.
- State and Commonwealth grants and programs for litter management and illegal dumping. In NSW alone, the state government spends some $15 million per annum in these areas.
- The state and local government costs to manage litter on beaches, national parks, crown and state lands, schools and colleges.
- Business expenditure to sweep car parks, malls, shopping centres and hard stand areas and retailer, hospitality and accommodation services to maintain a clean frontage around their premises.
- The cost to every household to remove litter from their property and its boundaries. While small on a household to household basis the overall cost of home owners and occupiers cleaning up litter on the property and fence line is significant. Using a similar measure to the participation and volunteer costs ($7.67/hour) identified for a Packaging CRIS, the impact of each of the 5.86million free standing Australian homes spending just 10 minutes a month collecting litter would represent an annual cost of over $89.9million p.a.
By way of a comparison, the following table compares the cost to manage litter in the U.S.A. using the detailed study undertaken by Keep America Beautiful (KUSB) in 2009 to quantify the costs of collecting litter by those presented in government analysis:
Extrapolating the KAB US study within an Australian perspective would indicate that a more realistic view of the amount of litter in Australia and the direct costs to manage the problem are likely to be:
Other Economic Impacts of Litter
Over and above the direct costs to recover litter there is also a significant economic impact ignored by our governments. The recent Scottish analysis conducted to consider whether Scotland should adopt a container deposit system, estimates the direct benefits of CDS in terms of reducing litter (by 17%) would also provide indirect savings through litter reductions:
"The indirect costs of litter are thought to be considerably higher than the direct (clean-up) costs. The study identified 5 key areas in which litter created a significant indirect cost along with an estimate of the potential loss;
(1) Property values – £100 million loss; (2) Mental health – £53 million loss; (3) Crime – £22.5 million loss; (4) Neighbourhood litter disamenity – £73 to 770 million loss; (5) Beach litter disamenity – £50 to 100 million loss"
While the relative values designated by the authors Eunomia, in these studies could be debated, it makes the point clearly that the impacts of litter on society represent far more than the direct costs of cleaning it up. Other indirect benefits associated with the reduction of litter identified by Eunomia and KAB include, indirect economic impacts of litter (like the potential spread of disease), litter injuries (particularly glass), and where high levels of litter are found – a loss of business revenue and falling property values for residences - as other significant impacts.
One good example of how litter impacts on the wider economy was developed in the USA by the National Association of Home Builders (NAHB), who built a hedonic pricing model based on data from a large survey conducted by the U.S. Census Bureau. The NAHB model deconstructed the price of a home into selected components, so that estimated factors were developed for each price-influencing variable while addressing problems of nonlinearity. Based on this model, NAHB determined that the presence of litter tended to reduce the value of property in that neighbourhood by about 7.4%. That’s $74,000 on the average Sydney house price - if just 5% of 1.6million homes in Greater Sydney neighbourhoods are adversely affected by litter the potential economic impact on housing in Sydney stands at $11.8million p.a.
To assess this data, in 2009, Keep America Beautiful tested the validity of the NAHB model by surveying 600 homeowners across 30 states and found that 93% of all homeowners believed that a littered neighbourhood would decrease their home’s value and would also personally deter them from purchasing a home in an area that was considered ‘unkempt’.
Finally with tourism a major driver of the Australian economy, along with a strong fisheries sector - it is vital that any future studies consider the destructive forces of litter on the Great Barrier Reef (and other reefs), beaches, fisheries, and marine mammals. We note that a 2009 study released by the APEC Marine Resources Conservation Group found that “the damage from marine debris on the fishing, shipping and marine tourism sectors has a damage value of US$1.265 billion per annum in the APEC region. The marine debris damage is estimated as US$364 million to the fishing industry, US$279 million to shipping and US$622 million to marine tourism.”
With the recent announcements of container deposit schemes around Australia, there is an implicit agreement that the traditional assessment of costs and benefits have failed to meet community expectations. Our analysis here shows there are good grounds on the basis of significant data and evaluation errors by government and consultants. Our political leaders are continually claiming we have to do more to tackle litter and marine debris, yet it is clear that without a re-think on how to properly measure our rubbish problems and their associated costs they will fail to find the necessary economic justification.
Please complete Litter Poll here
 In July 2015 it was revealed that the Australian Packaging Covenant had received (and failed to disclose) that in at least the area of plastics packaging both the amount of packaging generated (consumed) and the subsequent recycling rates had been exaggerated by approx. 50% of the 527,100 tonnes reported as consumed. There is strong belief that there are similar errors in the calculation of glass, aluminium, steel, asceptics and composite packaging.
 All recent studies on the consumption and recovery of packaging have been based on a study commissioned by the AFGC in September 2008 “Australian Beverage Packaging Consumption, Recovery and Recycling Quantification Study” By Hyder consulting. See http://voodooserver.biz/doc-library/category/9-packaging-recycling.html
 The DRIS analysis of litter is that it suggests that some 73,699 tonnes of litter will be generated this year (2015), yet later in the same analysis it is suggested that the recovery of litter is some 67,405 tonnes p.a.
 Keep America Beautiful, Inc. 2009 National Visible Litter Survey and Litter Cost Study
 Includes illegal dumping ranging in scale from small bags to vans and trucks. Zero Waste Scotland, “Scotland’s Litter Problem, 2013; Eunomia Research & Consulting, “A Scottish Deposit Refund System; Final Report for Zero Waste Scotland”, 2015
 DRIS attachment B, CBA assumptions – Market Failures. See page 2
 KAB, National Litter Index 2015 reports significant retail frontage litter.
 Section 4 - Keep America Beautiful 2009 Litter Study. See http://www.kab.org/site/DocServer/Final_KAB_Report_9-18-09.pdf?docID=4561
 The litter cost to state and federal govt at schools, tertiary institutions, national parks and other crown land
 Assumes there is a similar ration between litter on state land and municipal territories to that in the USA
 Adopts the lower cost estimate assumed within the CRIS
 Assumes cost/tonne to maintain car parks, outdoor areas etc is similar to that of the USA.
 Litter recovered by small groups and volunteers is at least equal to that recovered on Clean up Australia Day
 Based on 5.86million freestanding houses in Aust. Assumes a home owner spends 10 mins/pcm collecting rubbish that has accumulated at their home. Adopts the labour cost a RIS uses for participation costs ($7.67/hr).
 A Scottish Deposit Refund System; Final Report” Eunomia Research & Consulting, 2015
 NAHB House Price Estimator (www.nahb.org)
 Based on the June 2015 quarter average Sydney house price of $1,000,616