Introduction

1.1 In December 2018, Australia’s environment ministers and the Australian Local Government Association (ALGA)⁶ agreed to the 2018 National Waste Policy, updating the 2009 National Waste Policy. The policy was updated in response to changing global trends and international markets, including increasing import restrictions for waste and recyclable materials in China.⁷ The 2018 National Waste Policy aims to ‘[respond] to the challenges facing waste management and resource recovery⁸ in Australia’ and ‘[reflect] the global shift towards a circular economy’.⁹

1.2 The National Waste Policy Action Plan 2019 (NWPAP) was developed to implement the 2018 National Waste Policy. The NWPAP was agreed by Australia’s environment ministers and ALGA in November 2019.¹⁰

1.3 The NWPAP presents seven national targets and 80 actions to guide investment and national efforts to avoid waste and improve resource recovery to 2030.

• Target 1: Ban the export of waste, plastic, paper, glass and tyres, commencing in the second half of 2020.
• Target 2: Reduce total waste generated in Australia by 10 per cent per person by 2030.
• Target 3: 80 per cent average resource recovery rate from all waste streams following the waste hierarchy by 2030.
• Target 4: Significantly increase the use of recycled content by governments and industry.
• Target 5: Phase out problematic and unnecessary plastics by 2025.
• Target 6: Halve the amount of organic waste sent to landfill by 2030.
• Target 7: Make comprehensive, economy-wide and timely data publicly available to support better consumer, investment and policy decisions.

1.4 Of the 80 actions outlined in the NWPAP, 30 are led by the Australian Government (see Figure 1.1). Appendix 3 contains the full list of actions under the NWPAP.

Figure 1.1: Actions under each target by lead

Source: ANAO summary of actions under NWPAP.

1.5 The Department of Agriculture, Water and the Environment (DAWE) was the Australian Government entity leading the implementation and coordination of the actions under the NWPAP. Machinery of government changes took effect on 1 July 2022 and transferred the responsibility to the Department of Climate Change, Energy, the Environment and Water (DCCEEW).¹¹

1.6 The 2020–21 Budget provided $35 million over four years to the department to implement the Australian Government’s commitments under the NWPAP. Some of the actions listed in the NWPAP have received funding of their own, with total Australian Government funding committed towards the NWPAP amounting to $572.9 million as at the end of 2021. Appendix 4 provides a detailed breakdown of funding allocated to initiatives under the NWPAP.

Waste generation and management in Australia

1.7 In 2018–19, Australia generated an estimated 74.1 million tonnes (Mt) of waste. This is equivalent to 2.94 tonnes (t) per capita. Of the total waste generated, around¹²:

• 43.5 Mt (58.7 per cent) were received or processed for recycling;
• 27.2 Mt (36.7 per cent) were disposed of, with more than three quarters sent to landfill; and
• 4.1 Mt (5.5 per cent) were exported, worth an estimated $290 million.

1.8 Over the 13-year period from 2006–07 to 2018–19, for which data is available, total waste generation in Australia increased by 11.3 Mt (18 per cent). Assessed on a per capita basis, waste declined by 3.3 per cent over this timeframe.

1.9 Waste management and resource recovery in Australia involves all levels of government and industry. The regulation and management of waste and resource recovery is primarily the responsibility of state and territory governments. Each jurisdiction has its own waste management and resource recovery legislation, guidelines, and regulatory frameworks. State and territory governments are also responsible for policy and regulation relating to the operation of local governments.

1.10 The Australian Government has two key responsibilities relating to waste management:

• implementing Australia’s international treaty obligations and supporting global environmental outcomes through cooperation and engagement; and
• providing national leadership and coordination, including promoting innovation, addressing national market failures and national data collection and reporting.

1.11 The waste and resource recovery industry and businesses play an important role in waste management and resource recovery through improving the design of products; establishing and operating infrastructure for waste recycling or processing; and investing in new processes, systems and technologies that lead to changes in the generation, management and disposal of waste.

Previous reviews

1.12 Waste management and resource recovery in Australia have been the subject of two inquiries by the Australian Parliament in the last five years. In June 2018, the Senate Environment and Communications References Committee (the Senate committee) tabled its report, Never waste a crisis: the waste and recycling industry in Australia. The Senate committee made 18 recommendations, including that the Australian Government:

• prioritise the establishment of a circular economy in Australia;
• show leadership through the urgent implementation of the National Waste Policy; and
• set mandatory targets for all government departments in relation to the recycled content of materials bought directly or provided by private contractors.

1.13 In December 2020, the House Standing Committee on Industry, Innovation, Science and Resources (the House committee) tabled its report, From Rubbish to Resources: Building a Circular Economy. The House committee made 24 recommendations to the Australian Government, including that:

• the NWPAP be updated to include measures focused on the transportation and infrastructure requirements to manage national waste across regions and state and territory borders;
• waste management and resource recovery be included as a standing item on the National Federation Reform Council agenda to monitor federal and state and territory progress against the NWPAP;
• the responsible Minister report annually to Parliament on the progress of the targets and actions set out in the NWPAP;
• recipients of Australian Government waste management and recycling funding be required to report on the waste management and resource recovery outcomes as a result of that funding; and
• the Australian Government, in consultation with industry, identify and consider the inclusion of additional waste streams under the Product Stewardship Act 2011.

1.14 The Australian Government responded to the House committee report on 17 February 2022.¹³ As at June 2022, the Australian Government has not responded to the Senate committee’s recommendations.

Rationale for undertaking the audit

1.15 Effective management of waste is important to minimise the impact of waste on the environment and to maximise the recovery of resources. The NWPAP is intended to guide investment and national efforts in Australia to reduce waste and support more sustainable resource use to 2030.

1.16 Parliamentary reviews of Australia’s waste management activities identified shortcomings in the implementation of the policy initiatives agreed and committed to by the Australian Government.¹⁴ These reviews emphasised the importance of regularly monitoring and reporting on progress of implementation. This audit examined the effectiveness of the department’s implementation of the NWPAP. It provides assurance over the department’s planning and governance frameworks, progress of implementation, and monitoring and reporting arrangements. The Joint Committee of Public Accounts and Audit (JCPAA) identified the audit as a priority of the Parliament for 2021–22.

Audit approach

Audit objective, criteria and scope

1.17 The objective of the audit was to examine the effectiveness of the department’s implementation of the National Waste Policy Action Plan 2019.

1.18 To form a conclusion against this objective, the following high-level audit criteria were adopted.

• Have fit-for-purpose planning and governance arrangements been established?
• Is the plan being implemented effectively?
• Are monitoring and reporting arrangements effective?

1.19 The audit focused on the department’s implementation of the Australian Government’s commitments under the NWPAP, including coordination arrangements with state and territory governments and other stakeholders. The audit did not examine the delivery of actions under the NWPAP that are being led by state, territory or local governments, business sectors, and industry bodies; the effectiveness of initiatives or projects listed in the NWPAP; or the delivery of other waste-related initiatives that are not part of the NWPAP.

Audit methodology

1.20 The audit methodology included:

• examination of the department’s documentation;
• assessment of the department’s processes;
• assessment of the implementation of actions led by the Australian Government; and
• meetings with relevant departmental staff.

1.21 The ANAO also received one submission from the public via the citizen contribution facility on the ANAO website.

1.22 The audit was conducted in accordance with ANAO Auditing Standards at a cost to the ANAO of approximately $389,600.

1.23 The team members for this audit were Casey Mazzarella, Jennifer Myles, Se Eun Lee, Hayley Pang and Corinne Horton.

2.1 This chapter assessed whether the department¹⁵ established fit-for-purpose planning and governance arrangements for the implementation of the NWPAP. Fit-for-purpose planning and governance arrangements include:

• ensuring that the policy and program design is informed by a robust evidence-base, sound analysis, and clearly links deliverables to the achievement of objectives;
• establishing effective oversight arrangements to drive accountability for performance and allow appropriate oversight of program or policy delivery; and
• establishing effective stakeholder engagement arrangements to support the delivery of actions and achievement of outcomes, particularly where implementation relies on cooperation between multiple levels of government, industry and the public.¹⁶

Was development of the plan appropriately evidence-based?

Updating the National Waste Policy

2.2 On 27 April 2018, Australia’s environment ministers¹⁷ agreed to update the 2009 National Waste Policy by the end of 2018.

2.3 After a period of consultation with the public, state and territory governments, and industry and the business sector, the updated National Waste Policy was presented to the environment ministers on 7 December 2018. The draft National Waste Policy included a ‘Roadmap for action’ (the Roadmap). The Roadmap had ‘milestones and aspirational targets and that, once agreed, would lay the foundation for a plan of action’. The environment ministers agreed to the National Waste Policy but not to the Roadmap. The environment ministers noted that a range of issues needed to be addressed in implementing the policy and agreed to develop a ‘strong national action plan that includes appropriate funding, robust targets, and milestones to implement the 2018 National Waste Policy’.

Governance arrangements for the development of the NWPAP

2.4 Figure 2.1 illustrates the key bodies involved in the development of the NWPAP.

Figure 2.1: Structure and membership of key bodies for the development of NWPAP

Note a: The New Zealand minister responsible for the environment and the President of the Australian Local Government Association (ALGA) may be invited as observers.

Source: ANAO summary of key bodies for development of NWPAP based on departmental records.

2.5 The Meeting of Environment Ministers (MEM), which is now the Environment Ministers’ Meeting (EMM), was responsible for setting the direction and providing final approval for the NWPAP. The EMM was assisted in its role by the Senior Officials Group (SOG).

2.6 The Government Working Group (GWG) was established and first met on 21 February 2019. The purpose of the GWG was ‘to develop a National Action Plan for implementing the 2018 National Waste Policy, informed by best available information and evidence’. The department provided secretariat functions for the GWG.

2.7 The Industry Reference Group (IRG) was established and first met on 18 March 2019. The purpose of the IRG was to:

support the development of a National Action Plan to implement the National Waste Policy 2018 … through the provision of advice and information … on actions that industry, business and non-government organisations will take to implement the National Waste Policy 2018.

2.8 The department provided secretariat functions for the IRG and coordinated its engagement with the GWG. Membership of the IRG included eleven ‘peak and representative organisations with a direct interest in and/or responsibility for waste avoidance and management and/or resource recovery in Australia’.

Development of targets

2.9 At its first meeting, in February 2019, the GWG agreed to use the proposed Roadmap as the foundation for the development of the NWPAP. In March 2019, the GWG agreed that the draft NWPAP would follow a similar format to the proposed Roadmap and would use the six targets from the Roadmap. Table 2.1 maps the six Roadmap targets against the final NWPAP targets.

Table 2.1: Proposed Roadmap targets mapped against final NWPAP targets

Note a: Target 1 in the NWPAP is ‘Ban on export of waste plastic, paper, glass and tyres, commencing in the second half of 2020’. This was not included in the Roadmap.

Source: Draft Roadmap and NWPAP.

2.10 The GWG considered a range of materials during the development of the NWPAP. This included a presentation by an environmental consulting company, Blue Environment Pty Ltd, which provided projections of Australian waste quantities and management, building on the data in the National Waste Report 2018.¹⁸ The presentation aimed to ‘illustrate the potential effort needed’ to meet the Roadmap targets and considered whether three of the draft targets were expected to be achieved if existing state, territory and industry targets are met.

2.11 The projections showed that:

• the draft waste reduction target (10 per cent waste reduction per person by 2030) is expected to be achieved and exceeded even in the ‘low success’ scenario (in which future recovery rates remain the same as 2016–17 recovery rates);
• the draft national resource recovery rate target (80 per cent by 2030) is not expected to be achieved, even under the high success scenario (in which existing state, territory and industry targets are met; recovery rates increase at the projected baseline trend rate of increase; and there is a significant increase in waste to energy); and
• the reduction in organic waste sent to landfill target (50 per cent reduction by 2030) is expected to be achieved under the medium success scenario (in which existing state, territory and industry targets are met; and recovery rates increase at the projected baseline trend rate of increase).

2.12 The extent to which this and other evidence was used to inform the development of the NWPAP targets is not clear. There is no documented explanation for the changes that were made.¹⁹

Assessment of targets

2.14 The seven targets outline the key objectives that the NWPAP aims to achieve. Targets that are clear and understandable, identify a measurable goal, specify a timeframe and identify a baseline allow for achievement to be more accurately assessed. This supports transparency and accountability in program administration.

2.15 The ANAO examined whether the achievement of the seven NWPAP targets is assessable, based on the following criteria.²⁰

• Specific — Target uses plain language, is clear, well-defined and understandable to the public.
• Measurable — Target specifies how achievement will be measured.
• Baseline — Target has baseline data against which achievement is to be measured.

2.16 ANAO’s analysis of the targets as published in the NWPAP found that four targets are assessable and three not assessable (Table 2.2).

Table 2.2: Assessment of NWPAP targets

Source: ANAO analysis of NWPAP targets.

2.17 The NWPAP targets are intended to guide national action and investment to 2030, with two of the targets specifying an earlier timeframe for achievement. The NWPAP identified that all targets will be measured against the baselines established in the 2018 National Waste Report.

2.18 ANAO assessment identified that Targets 3, 4, 5 and 7 did not meet one or more criteria.

• Target 3 was found to be partially measurable as it is not clear how the waste hierarchy²¹ is intended to impact the measurement of the waste recovery rate.
• Target 4 is not specific as the term ‘significantly increase’ is not defined in the NWPAP. It was found to be partially measurable with a partial baseline. While there is baseline data against which to measure volume of recycled material, the baseline data does not measure the use of recycled material by governments and industry.
• Targets 5 and 7 are not specific or measurable as the terms, ‘problematic and unnecessary plastics’²² and ‘comprehensive economy-wide and timely data’ are not defined in the NWPAP. This also impacted the measurability and baselines for these targets as it is not clear what data in the National Waste Report will be used as the baseline to measure progress.

2.19 Appendix A of the NWPAP outlines a mechanism for regular reviews of the plan to be undertaken, including to ‘ensure that targets remain ambitious and achievable’.

Development of actions

2.21 The NWPAP presents seven targets and 80 actions to implement the National Waste Policy. The actions listed in the NWPAP align with the National Waste Policy principles and strategies. The NWPAP incorporated key waste initiatives and existing Australian Government commitments that were in operation when the plan was being developed, as well as state and territory waste management strategies and commitments.

2.22 The NWPAP provides for regular reviews of the plan to ‘ensure actions are driving positive change in waste management in Australia’ and ‘allow actions to be updated to address new issues as they emerge’ (see paragraphs 4.39 to 4.48 on program evaluations). The department advised that the regular reviews were built into the plan in recognition of the fact that ‘the actions would need to be recalibrated and revisited throughout the 10 years to reach the targets’. The current list of 80 actions in the NWPAP were not expected or intended to achieve the NWPAP targets; they are ‘a starting point in driving change and improvement in Australia’s waste management and recycling’.

2.23 No projections or analyses were done to determine how much the completion of the 80 actions was expected to contribute to the achievement of the targets by 2030. The department advised that an analysis of this type was not undertaken due to limitations in available waste data at the time. The department advised that work is currently underway in the Data Working Group to develop supporting indicators for NWPAP targets to facilitate analysis and reporting of progress against the targets.²³

2.24 Scope or deliverables for each action were not established or agreed during the development of the NWPAP. This means that there is no shared understanding amongst the NWPAP participants regarding what is included within the scope of an action, and what deliverables or outputs are required to be produced for an action to be completed. This has impacted the implementation and coordination of actions (see paragraphs 3.20 to 3.32 and 3.44 to 3.54), as well as progress monitoring and reporting (see paragraphs 4.27 to 4.29).

Finalisation of NWPAP

2.25 On 8 November 2019, the draft NWPAP was presented to the EMM. A representative from the ALGA attended as an observer. The minutes of the meeting note that ‘[t]he Commonwealth coordinated the drafting of the Action Plan, which reflects the collective views of jurisdictions and includes input from members of an Industry Reference Group’. The EMM ‘[a]greed to the National Waste Policy Action Plan, including the revisions made during the meeting’.

2.26 The GWG and IRG were disbanded following the finalisation of the NWPAP. A new governance body for the implementation of the NWPAP was established, comprising many of the same representatives from the two groups (see paragraphs 2.37 to 2.42).

Transition from development to implementation

2.27 The department transitioned from the development phase to the implementation phase of the NWPAP in late 2020. Resourcing changed from a dedicated taskforce to ‘business as usual’, drawing from existing departmental resources across multiple divisions.

NWPAP Program Plan

2.28 The department developed a program plan for the implementation of the NWPAP (the Program Plan), which was approved in September 2020 and covered the period from 2020 to 2024 with a review scheduled in February 2021. It identified the NWPAP Business Owner²⁴, Program Manager²⁵ and Program Sponsor²⁶ and outlined the arrangements for the department’s implementation and coordination of the NWPAP, including for monitoring and reporting, governance and progress measurement.

2.29 The position that was assigned the role of Program Sponsor no longer exists and this role has not been reassigned to another position.

2.30 The Program Plan stated that a program risk management plan; monitoring and evaluation plan; and overarching Communication Strategy and Plan for Waste and Recycling would be developed. The risk management plan was not delivered. The monitoring and evaluation plan (paragraph 4.2) and the communication strategy (paragraph 2.58) were drafted in August and October 2020, but neither were approved.

2.31 The scheduled review of the Program Plan in February 2021 was not undertaken. In January 2022, the department advised that the Program Plan is being reviewed and will be updated to reflect the changes to leadership, risk management, and monitoring and reporting.

Have effective oversight arrangements been established?

Governance and oversight arrangements for the implementation of the NWPAP

2.32 Figure 2.2 illustrates the governance structure established for the implementation of the NWPAP.

Figure 2.2: NWPAP governance and oversight arrangements as at June 2022

Note: The figure illustrates the governance arrangements prior to the 1 July 2022 machinery of government changes.

Source: ANAO summary of NWPAP governance and oversight structure.

2.33 Following the finalisation of the NWPAP, the EMM’s role transitioned to providing strategic oversight of the implementation of the NWPAP, including:

• setting Government priorities
• considering reviews of the Action Plan
• agreeing to changes to the Action Plan
• monitoring progress of delivery against actions.

2.34 The SOG supports the EMM in its role. Reports provided to the EMM and the SOG are outlined in Table 2.3 at paragraph 2.49.

2.35 The department is responsible for chairing and providing secretariat support to the RRRG; liaising with the NWPAP participants and stakeholders; and monitoring progress and coordinating reports to the EMM and the SOG on the implementation of the NWPAP.

2.36 The arrangements have been formalised and are well-documented. All meetings of the EMM, the SOG and the RRRG have a defined agenda and meeting records are comprehensive.

Resource Recovery Reference Group

2.37 Appendix A to the NWPAP stated:

A cross-sector reference group involving government, non-government organisations, industry and business representatives will provide advice and help guide the implementation of the National Action Plan. The group will also help to coordinate monitoring and evaluation of the plan. Where desired outcomes are not being achieved, this group will explore regulatory, financial or legislative options to help achieve the targets.

2.38 On 24 July 2020, the department provided a brief to the Australian Government Environment Minister, outlining the proposed arrangements for the reference group referred to in the NWPAP. The department proposed that the group be named the Resource Recovery Reference Group (RRRG), to be chaired by the First Assistant Secretary of the department’s Environment Protection Division. The Minister agreed with the proposed arrangements, including the draft terms of reference for the group, on 16 September 2020.

2.39 As at July 2022, membership includes representatives from all Australian governments, the ALGA, and eight industry and community bodies.

2.40 According to the RRRG terms of reference, its roles and responsibilities include:

• providing advice to help guide the implementation of the NWPAP;
• reporting on progress of the NWPAP to the SOG and the EMM;
• delivering biennial reviews of the NWPAP — considering whether actions need to be updated to address new issues as they emerge, and whether the targets remain relevant, ambitious and achievable; and
• representing the relevant jurisdiction or sector.

2.41 Five RRRG sub-groups were established to oversee subject-matter specific activities. These sub-groups are examined in more detail at paragraphs 2.63 to 2.65.

2.42 The RRRG meets approximately once a quarter. The RRRG has met five times as at the end of 2021. Reports provided to the RRRG are outlined in Table 2.3 at paragraph 2.49.

Program Office

2.43 The Program Office for the NWPAP was established in November 2019 and is responsible for coordinating the implementation of the NWPAP and supporting its governance bodies. The Program Plan states that the Program Office will:

• provide secretariat support for the RRRG and Australian Government Steering Committee (AGSC)
• coordinate progress reports for the Environment Minister and the Assistant Minister, the Prime Minister, SOG and MEM
• coordinate whole-of-government communications on the Action Plan (including senate estimates briefs, talking points etc.)
• engage with Australian Government agencies on their waste measures
• provide a central contact point for the secretariats for SOG, MEM, and the Council of Australian Governments (COAG)/National Cabinet on issues relating to the Action Plan and the COAG waste export ban
• scale up as necessary to lead biennial reviews of the Action Plan.

2.44 The Program Plan also states that the Program Office will develop a risk management plan for the program. Program risk management is discussed in more detail at paragraphs 3.3 to 3.6.

Action-leads

2.45 Each action listed in the NWPAP is assigned one or more NWPAP participants as the action’s ‘lead’ entity (see Figure 1.1). There is a departmental officer assigned to either lead (for actions being delivered by the department) or coordinate (for actions being delivered by other Australian Government agencies, state and territory governments, business or industry) the delivery of the 80 actions in the NWPAP.

Support for oversight by governance bodies

Internal oversight

2.46 As at the end of 2021, the department had provided three updates to its Executive Board on the progress of the implementation of the NWPAP. The updates included a high-level outline of key achievements to date, as well as an overview of risks and issues.

2.47 The updates do not outline how risks are being managed. Some risks include proposed mitigation measures; however, the updates do not indicate the extent to which the measures are expected to mitigate the risks. Updates do not provide advice on the expected impact of risks on the achievement of NWPAP targets or broader policy objectives. Providing robust information on program risks and how they are being managed supports effective oversight over the progress and performance of the program, including making decisions on resourcing, budget and strategic priorities for the department.

2.48 The department also provided monthly reports to the Australian Government Environment Minister on the progress of key waste-related workstreams. Half-yearly reports were provided to the Prime Minister on matters relating to the waste export ban. There were fortnightly meetings between the Assistant Minister on Waste Reduction and the Deputy Secretary of the division primarily responsible for the implementation of the NWPAP, which included updates on waste-related priority initiatives. While ‘actions arising’ for the department from some of these meetings were documented, there were no formal records of the meetings.

External oversight

2.49 The NWPAP Program Plan states that the department will coordinate progress updates on the status of the NWPAP for the EMM and the SOG for every meeting (around twice a year) as well as by exception. The department also prepares quarterly progress reports for the RRRG. Table 2.3 outlines the reporting received by each body since the approval of the NWPAP in November 2019.

Table 2.3: Summary of NWPAP reporting arrangements

Note a: No meeting was held in 2020.

Source: ANAO summary of NWPAP reporting arrangements.

2.50 There are no defined deliverables or measures against which the department can verify the completion of actions. This makes it difficult for the department to accurately determine implementation progress and subsequently limits the efficacy of the updates and progress reports it prepares for governance bodies.

2.51 For example, the NWPAP update prepared by the department for the SOG and EMM meetings in April 2021 noted that ‘significant progress’ has been made to deliver against the targets and actions in the NWPAP, with 11 out of 80 actions ‘completed’. The update did not indicate whether this is the expected level of progress as at the time of reporting, whether any actions have been delayed that could impact the achievement of the key timeframes, or whether the NWPAP targets are on track to be achieved.

2.52 The updates on the status of the NWPAP prepared by the department for the EMM and the SOG do not identify emerging risks or issues for escalation. While the quarterly progress reports to the RRRG have been updated in October 2021 to outline risks, issues and ‘matters for escalation’, the reported ‘risks’ are not assessed for impact or consequence on the implementation of the NWPAP. The department is not tracking or reporting to governance bodies regarding the implementation of risk treatments. Risk management for the NWPAP is examined further at paragraphs 3.3 to 3.6. Management of issues to implementation is examined at paragraphs 4.21 to 4.24.

Probity arrangements

2.53 The RRRG terms of reference and business rules require members to declare conflicts of interest and abstain from participating in any matters pertaining to those interests.

2.54 The RRRG has met six times between November 2020 and June 2022. None of the minutes from the six meetings record any declaration of conflicts of interest (including nil declared). It is not clear from meeting records whether there was a call for conflicts to be declared by the Chair. The ANAO observed the December 2021 and April 2022 meetings, at which there was no call for conflicts to be declared nor were any conflicts declared by members.

Have effective stakeholder engagement arrangements been established?

2.56 The department identified a range of external and internal stakeholders for the development and implementation of the NWPAP. This includes the broader community, internal departmental line areas, various Australian Government entities, state and territory agencies, the ALGA, and various industry bodies operating in the waste and resource recovery sector.

2.57 The consultation process undertaken for the development of the NWPAP is outlined at paragraphs 2.3 and 2.9 to 2.13. This section examines stakeholder engagement arrangements established for the implementation of the NWPAP.

NWPAP Communication Strategy

2.58 In August 2020, the department developed a communication strategy (the strategy) to support the implementation of the NWPAP. The strategy has not been approved.

2.59 Noting ‘the scale of the targets, quantity of actions, diversity of stakeholders, and allocation of project responsibility’, the strategy outlines a communication approach where ‘a selection of shorter, tailored, and timely communications plans will be prepared’ for projects under the NWPAP. This is to enable ‘each project to communicate with meaning to audiences and with stakeholders’.

2.60 All projects ‘earmarked for support with their own specific communications plans’ have established their own communication plans.

2.61 The department advised the ANAO that a ‘specialised communications role’ was established in November 2021 ‘to continue the implementation of the [NWPAP] Communications Strategy and to ensure ongoing consistent and comprehensive messaging on waste and recycling’. The department advised that the communications adviser has assisted in the drafting of the project-specific communication plans; provided support for review, design and publication of communication items; and engaged with stakeholders to participate in communication activities.

Working groups and forums

2.62 The department has established working groups and forums to support stakeholder engagement during the implementation of the NWPAP.

RRRG and sub-groups

2.63 The RRRG is a cross-sector reference group comprising representatives from the Australian, state and territory governments, industry bodies and the business sector to help guide implementation of the NWPAP. The RRRG provides a forum at which members and other stakeholders are kept informed of the progress of implementation, can raise questions and issues for discussion, and suggest changes to the implementation approach for endorsement by the environment ministers. The role and membership of the RRRG is detailed further at paragraphs 2.37 and 2.42.

2.64 The RRRG has established five sub-groups to engage with stakeholders on specific subject-matters (Table 2.4). Membership comprises a mix of representatives from Australian governments and various peak bodies and relevant industry groups.

Table 2.4: RRRG sub-groups

Source: ANAO summary of RRRG sub-groups.

2.65 The sub-groups report regularly to the RRRG on progress of their work. The work of the RRRG sub-groups is examined in more detail at Table 3.3 at paragraph 3.43.

Technical Working Groups

2.66 Technical Working Groups were established to support implementation of the waste export ban under the Recycling and Waste Reduction Act 2020. Three groups were formed for waste glass, plastic and tyres, each comprising representatives from the department and relevant industry peak bodies and businesses. The department chaired all three working groups.

Table 2.5: Technical Working Groups

Source: ANAO summary of Technical Working Groups.

3.1 The department²⁷ received $35 million over four years from 2020–21 to lead the implementation of the NWPAP for the Australian Government. Along with implementing Australian Government-led actions, the department is responsible for the coordination of the NWPAP’s delivery across the different levels of governments and industry participants.

3.2 This chapter assessed whether the department’s implementation of the NWPAP is effective. Successful implementation of a program relies on:

• effective management of risk, with risk management processes and guidance to ensure consistency in risk management approaches across the program;
• timely completion of relevant actions, supported by accurate documentation of progress to help inform decisions about whether an initiative, as planned, is still achievable, or whether its scope, timing or resourcing need to be adjusted; and
• effective coordination for implementation, comprising a clear understanding of the roles and responsibilities for all participants, the sharing of relevant information in a timely manner, and management of shared risks.²⁸

Is the department managing risk to the implementation of the NWPAP effectively?

Coordinating and managing risk to the implementation of the NWPAP

3.3 The RRRG is responsible for managing risk to the implementation of the NWPAP and achievement of its targets. The department, as the Chair and secretariat of the RRRG as well as the lead Australian Government entity, is responsible for leading, coordinating and facilitating the RRRG’s management of risk for the implementation of the NWPAP.

3.4 Processes for risk management for the implementation of the NWPAP have not been established. There is no risk tolerance set for the NWPAP or guidance regarding how risk will be assessed, escalated or addressed. No risk assessments for the implementation of the NWPAP or the achievement of its targets have been provided to the RRRG. There is no NWPAP risk register.

3.5 The RRRG added a section for risk to its quarterly progress reports (October 2021) and added an item for governance and risk to its meeting agenda (April 2022). In the April 2022 meeting, RRRG members, particularly those representing industry, raised risks to the achievement of one or more NWPAP targets. While there was discussion of risks, no action items, controls or treatments were proposed to address the risks raised in the meeting.

3.6 Without risk assessments that consider risk to the achievement of NWPAP targets and propose controls and treatments to address these risks, the RRRG’s ability to effectively manage risks to the implementation of the NWPAP is reduced.

Risk management for Australian Government-led actions

3.9 DAWE’s Enterprise Risk Management Framework and Policy was last updated in August 2020 and comprised three key elements:

• Enterprise Risk Management Framework and Policy;
• Risk Management Reference Guide; and
• Risk Governance Map.

3.10 The Enterprise Risk Management Framework and Policy outlined DAWE’s approach to risk management, including providing guidance on how to identify, manage and monitor risks in accordance with departmental risk appetite, tolerance and matrix. It required each division to develop a risk management plan as part of its annual business plan, and undertake a risk assessment for new policy proposals and programs.

3.11 The Environment Protection Division’s risk assessments identified risks that primarily focus on resourcing and the capacity of the division to deliver on its reform and compliance responsibilities, including broadly in relation to waste management and recycling.

3.12 In April 2020, the department’s waste teams developed a draft risk assessment in consultation with the department’s Enterprise Risk Management Team. This was used to inform the development of an initial high-level risk assessment for the implementation of the NWPAP in August 2020. The risks identified in the August 2020 risk assessment are listed in Table 3.1.

Table 3.1: NWPAP risks, August 2020

Note a: The risk assessment does not specify whether ‘rating’ refers to the ‘risk rating’, which according to DAWE’s Risk Management Reference Guide 2020 is the level of risk that remains after consideration of all existing controls, or ‘residual risk rating’, which is produced by conducting a risk analysis with additional controls and treatments in place.

Source: NWPAP risk assessment, August 2020.

3.13 The risk assessment does not incorporate or aggregate risks reported by Australian Government action-leads, or consider the impact to achievement of NWPAP targets. It does not identify risk owners, control owners, or assess the effectiveness of controls.

3.14 As at June 2022, no risk assessments for the implementation of the NWPAP have been produced since the initial August 2020 assessment.

Action risk management

3.15 The department advised the ANAO that risks to the implementation of each Australian Government-led action are managed by relevant officers assigned to implement the action. The ANAO sought risk documents from the department for each of the 30 Australian Government-led actions listed in the NWPAP.

3.16 The department provided evidence of risk management activities for 15 actions. Risk management activities were largely for projects, procurements or other activities occurring as part of an action, rather than management of risk for the action itself. In some cases, the evidence provided was for pre-existing programs, which covered multiple actions, or was an example demonstrating how the department was responding to an issue related to an action that had been raised by stakeholders.

3.17 For the remaining 15 Australian Government-led actions, ANAO analysis of the risk documents showed that there is no evidence that the department is undertaking or, for non-departmental actions, has oversight of risk management activities.

Are Australian Government commitments being delivered in accordance with the plan?

Implementation of Australian Government-led actions

3.20 Of the 80 actions in the NWPAP, 30 are led by the Australian Government. Of these:

• 18 were due to be completed in 2020;
• four were due to be completed in 2021;
• three actions are ‘ongoing’ commitments²⁹; and
• five actions are to be delivered between 2022 and 2028 — three in 2022, one in 2023 and one in 2028.

3.21 Progress of the actions and action statuses are reported by action-leads through progress reports to the RRRG. From March 2021, the schedule for progress reports changed from a monthly ‘status dashboard’ to quarterly ‘progress reports’³⁰ and the following rating scale to report on action statuses was introduced:

• Substantially Delayed: delayed for a period greater than 12 months;
• Delayed: delayed for a period less than 12 months;
• Not Yet Started: action item has not commenced as not yet due or is unable to commence (e.g. dependent on another action item);
• On track: on track to meet due date;
• Delivered: action item has been delivered;
• On Hold: action item has been placed on hold; and
• Subject to Review: action item requires substantive review.

3.22 Figure 3.1 summarises the status of the actions as reported by the action-leads in the December 2021 progress report.

Figure 3.1: Status of Australian Government–led actions as at 31 December 2021

Source: ANAO summary of NWPAP action status.

3.23 Reasons for delays to the relevant actions are included in the progress report. The progress report does not consider or comment on the impact of delayed actions on timely completion of interdependent actions or achievement of targets.

3.24 As noted in paragraph 2.24, no agreed set of deliverables was established for the actions listed in the NWPAP during the development of the NWPAP. The department advised that individual officers assigned to lead the actions are responsible for determining how the actions will be implemented.

3.25 The ANAO requested that the department provide documents that outline action scope or deliverables, or otherwise show action-level implementation planning. Documents were received from action-leads for 27 of 30 Australian Government-led actions (90 per cent). Of these, six documents referred to the relevant action directly (22 per cent), nine mentioned an NWPAP target or the NWPAP more generally (33 per cent), and the rest did not refer to the NWPAP at all (44 per cent). This makes it difficult to determine how some of the provided documents relate to the NWPAP actions or contribute to the achievement of the NWPAP targets.

3.26 In the absence of agreed scope or deliverables, the determination of action statuses (including deciding when an action is complete) is largely at the discretion of action-leads, in accordance with the rating scale definitions. This has led to confusion on what is required for an action to be marked as ‘delivered’.

3.27 During the October 2021 progress reporting process, the Program Office considered re-opening three actions which were reported as ‘delivered’ in the June 2021 progress report. The Program Office kept these actions as ‘delivered’ based on its interpretation of the action requirements. In the December 2021 progress report, an action status was changed from ‘delivered’ in previous progress reports to ‘on track’. The department explained that this was ‘to reflect that the scope of the action item could be more broadly interpreted, and that additional work undertaken in the division over the coming year would likely contribute relevant outcomes to this action’.

3.28 While there are actions with clear completion requirements — for example, action 2.2, to develop and publish a National Food Waste Implementation Plan by 2030 — most of the NWPAP actions are ambiguously worded and open to interpretation. As there is no objective metric against which to measure progress for most of the actions, the ANAO was unable to assess whether all actions reported as delivered have been completed or provide assurance that all actions marked ‘on track’ are set to be completed on time.³¹

Accuracy of action status reporting

3.29 Under the current action status rating scales, actions delayed for a period less than 12 months are marked as ‘delayed’ and actions delayed for a period greater than 12 months are marked as ‘substantially delayed’. There is no status rating for action-leads to indicate that an action is off track or at risk of failing to meet its due date.

3.30 In the June 2021 and October 2021 progress reports, two of the four actions due in 2021 were reported as ‘on track’, even though they were not anticipated to meet their 2021 due dates.³² The department confirmed that these statuses were accurate and explained that an action will be considered ‘delayed’ once it has passed its due date. This means that the mechanism for reporting action status to the RRRG and other stakeholders does not clearly indicate when an action is off track or at risk of failing to meet its due date until after this has occurred.

3.31 There are two additional limitations in the current status rating scales.

• The ratings do not include a category to show that announced timeframes were not met for delivered actions. Three of the 11 actions due in 2020 that had been reported as ‘delivered’ were not completed by their 2020 due date. This makes it difficult to accurately capture overall performance and track slippages in implementation timeframes.
• For jointly-led actions, it is unclear how the overall action status is determined when different action-leads report different statuses. For example, in the December 2021 progress report, an all government-led action (1.07) was reported as ‘delivered’ overall. The Australian Government, Victoria and Western Australia indicated this action was ‘delivered’, while the Northern Territory and Queensland reported that the action has been ‘delayed’, and Tasmania, New South Wales and South Australia indicated that this action is ‘on track’. There was no indication of status from the Australian Capital Territory.

3.32 Performance reporting systems are more useful to decision-makers when the categorisation reflects the actual status of implementation.³³ Marking actions that are expected to miss their due dates as ‘on track’ does not communicate to decision-makers where progress may be at risk and prevents early intervention to address implementation issues. Similarly, jointly-led actions should not be marked as ‘delivered’ unless all joint-leads agree that the action has been completed, so that its progress can continue to be tracked and monitored in the relevant jurisdictions.

Is the department effectively coordinating the implementation of the plan?

Coordination planning

3.34 As the lead Australian Government entity in the implementation of the NWPAP, the department has a national leadership and coordination role.

Funding and resource allocation

3.35 The department identified funding requirements to implement the actions led or jointly led by the Australian Government under the NWPAP. The 2020–21 Budget provided the department with $35 million over four years, comprising:

• $26.1 million for specialist consultancies; and
• $8.9 million for contractor roles for the department to support consultants.

Table 3.2: Funding breakdown over four financial years

Source: ANAO summary of the department’s documents.

3.36 Separate funding of $15.1 million was provided for the implementation of the waste export ban under Target 1. Other initiatives under the NWPAP received funding of their own, with total Australian Government investment in the implementation of actions under the NWPAP amounting to $572.9 million as at the end of 2021 (see Appendix 4). The department informed the ANAO that state and territory governments and industry action-leads are expected to fund their own actions.

Work prioritisation

3.37 In May 2020, the department undertook a process to determine priorities for each of the 80 actions based on a scale of ‘high’, ‘medium’ or ‘low’.

3.38 The department informed the ANAO that actions with commitments that had been publicly announced, involved delivery of funding, were ‘known divisional priorities or were otherwise time-sensitive’ were allocated a higher priority. The criteria used for prioritisation was not documented, making it difficult to determine if they have been applied consistently. The priority ratings for jointly-led actions were not presented to and agreed with other leads to assist overall coordination of implementation.

3.39 Robust prioritisation arrangements support entities to allocate resources to the areas where they will have the greatest impact. Documenting what factors were considered as part of the prioritisation and what judgments were made provides assurance that the approach was appropriate. Without clear documentation of the criteria used and judgments made, there is limited assurance that the actions that will have the greatest impact on achieving the NWPAP targets were prioritised.

3.40 It is unclear whether the May 2020 priority list has been updated since development. The department stated that, due to the dynamic environment, priorities were changing constantly and keeping a documented record of those changes would be ‘impossible’.

Coordination and information-sharing

3.42 There are arrangements to facilitate coordination and sharing of information between participating entities through subject-matter specific working groups.

3.43 The RRRG is the governance body for the implementation of the NWPAP (see paragraphs 2.37 to 2.42). The RRRG established five sub-groups to coordinate the implementation of a number of NWPAP actions (Table 3.3). The department chairs four of the five sub-groups, with the Waste Management and Resource Recovery Association of Australia (WMRR) chairing the Yellow Bin Standards sub-group. As at June 2022, four sub-groups are still in operation.

Table 3.3: RRRG sub-groups

Note a: The department informed the ANAO that ‘the majority of the work of the Organics Subgroup relates to a new budget measure (Food Waste for Healthy Soils) announced in the 2021–22 Budget’, which does not relate to a specific action in the NWPAP although it will contribute to achieving Target 6.

Source: ANAO summary of RRRG sub-groups.

Coordination of jointly-led actions

3.44 Of the 80 actions in the NWPAP, 22 are jointly led by ‘all governments’ and one is jointly led by all governments and the business sector.

State and Territory Coordination Group

3.45 The State and Territory Coordination Group was established to ‘facilitate and discuss progress and report on monitoring of government-led actions’. Membership comprises representatives from the department and each state and territory government.

3.46 Discussions in the State and Territory Coordination Group focus on the implementation of individual NWPAP actions, primarily those that are led by ‘all governments’. A review of the meeting minutes shows that the discussions mostly comprise general updates on what activities each state and territory is undertaking in their respective jurisdictions for certain actions, rather than planning or seeking consensus on the scope of actions scheduled to be delivered jointly.

3.47 Without a common understanding of what actions comprise, there is an increased risk of confusion regarding what is being delivered and who is responsible and accountable for delivery of jointly-led actions. The lack of clarity around some jointly-led actions was raised as an issue at the first and second State and Territory Coordination Group meetings by the then-Chair. However, it was not addressed.

3.48 This issue was also noted by the RRRG in its first meeting held on 19 November 2020, with the meeting paper noting:

The broad range of parties implementing the NWPAP means that a comprehensive and comparable snapshot of all 80 Actions is challenging. There may be difficulties defining the scope and deliverables for Actions where responsibility for implementation is shared.

3.49 The RRRG meeting paper stated that ‘[i]ssues with regard to timing, scope, resourcing or effectiveness will be reflected in the biennial reviews of the NWPAP’, with remediation to be considered by the RRRG and the environment ministers based on the recommendations of the review. The first biennial review is currently being finalised, focusing on the appropriateness of governance, communications and performance measurement frameworks (see paragraphs 4.42 to 4.45).

Shared risks

3.50 The Commonwealth Risk Management Policy 2014 (the Commonwealth policy) seeks to ‘embed risk management as part of the culture of Commonwealth entities where the shared understanding of risk leads to well informed decision making’. It supports the requirements of section 16 of the Public Governance, Performance and Accountability Act 2013 that provides that accountable authorities of all Commonwealth entities must establish and maintain:

(a) an appropriate system of risk oversight and management for the entity; and

(b) an appropriate system of internal control for the entity.

3.51 The Commonwealth policy sets out nine elements that non-corporate Commonwealth entities must comply with in order to establish an appropriate system of risk oversight and management. Element seven is ‘Understanding and managing shared risk’, which is defined as ‘those risks extending beyond a single entity which require shared oversight and management’.

3.52 The Department of Finance issued guidance to assist Commonwealth officials in implementing the requirements of the Commonwealth policy. Resource Management Guide 211 states that ‘[d]ocumenting shared risks is good governance, improves understanding of complex relationships and clarifies the extent of knowledge of shared risks at a point in time’.

3.53 DAWE’s Enterprise Risk Management Framework and Policy outlined its management of shared risk, noting that:

The department shares risk with industry, the community and other jurisdictions or governments. Risk may be also be shared between one or more functions of the department. A shared risk is where more than one party is exposed to, or can significantly influence, the risk. The management of shared risks, including reporting obligations, may form part of formal arrangements with other parties.

3.54 As outlined in paragraphs 3.3 to 3.6, there are no processes for risk management for the implementation of the NWPAP. None of the risk assessment documents provided by the department for jointly-led NWPAP actions considered risks shared with other governments as joint-leads.

4.1 This chapter assessed whether the department’s monitoring and reporting arrangements for the implementation of the NWPAP are effective.³⁴ Actions and targets presented in the NWPAP underpin significant investments by all levels of government, industry and business in waste and resource recovery systems. Effective monitoring and reporting of program implementation support transparency and accountability, enable early identification of risks and issues, and help ensure the program is on track to achieve its objectives. Effective arrangements include:

• a performance monitoring framework that outlines processes to track and measure program performance;
• monitoring and measuring progress to inform decision-making and support timely responses to emerging risks and issues; and
• reporting on the progress of actions and achievement of targets to provide transparency and assurance that the NWPAP is being implemented on time and intended policy outcomes are being achieved.³⁵

Has a performance monitoring framework been established?

Internal performance monitoring

4.2 The department developed a Monitoring and Evaluation Plan for the implementation of the NWPAP, last modified in August 2020. It has not been finalised or approved. The department informed the ANAO that the document is a ‘current draft’ and that it is intended ‘to be a dynamic rather than a point in time document’. The plan has not been updated to reflect changes to monitoring arrangements that occurred in 2021 (see paragraph 4.28).

4.3 The draft Monitoring and Evaluation Plan outlines performance measures for each of the seven targets against their existing baseline, key outputs and desired outcomes, and data sources. The plan does not indicate frequency of monitoring and reporting against these measures. A comment in the draft document states that the measures are still in development, with approval expected in mid-August 2020. The performance measures were not approved and no report has been produced against these measures.

External performance monitoring

NWPAP performance monitoring

4.4 The department’s monitoring activities focus on completion of actions listed in the NWPAP and do not track progress towards the achievement of targets. The department advised the ANAO that supporting indicators for each target are currently under development, and ‘[t]he performance measures in the Monitoring and Evaluation Plan will be updated to the supporting indicators once they are endorsed’ by the Resource Recovery Reference Group (RRRG).

4.5 The development of supporting indicators is being led by the Data Working Group, which is a sub-group established under the RRRG (see Table 2.4 at paragraph 2.64). It is one of four streams of work identified by the working group. The other three streams are outlined in paragraph 4.38.

4.6 Supporting indicators are defined as: ‘quantifiable measures which are representative of a specific element or component of a NWPAP Target and provide greater context to help evaluate whether the Targets are being met’. The Data Working Group held workshops with subject-matter experts to develop the indicators from January to May 2022. A shortlist of supporting indicators for all targets will be presented to the Data Working Group in June 2022, and then to the RRRG later in the year.

Commonwealth performance framework

4.7 Commonwealth entities are subject to performance measurement and reporting requirements under the Public Governance, Performance and Accountability Act 2013 (PGPA Act), the Public Governance, Performance and Accountability Rule 2014 (PGPA Rule) and accompanying guidance issued by the Department of Finance. These are collectively referred to as the Commonwealth performance framework.

4.8 Under the framework, entities must publish corporate plans for each financial year. Corporate plans must set out the entity’s purpose and provide performance measures that will measure the entity’s performance in achieving its purpose. Results against these performance measures are required to be provided in the entity’s annual performance statements, to provide accountability information to the Parliament and the public.³⁶

4.9 In its 2020–21 Annual Report, the department reported against two performance measures relevant to the NWPAP. One of the measures was to ‘[d]eliver department-led actions [in the National Waste Policy Action Plan] (17 actions)’, which the department reported was ‘partially achieved’. The annual report stated that:

In 2020–21 we continued to work with state and territory governments and other actors to improve waste management and recycling. We delivered 92% of the Australian Government-led action items due in 2020–21. One action, delivery of the Australian Government response to the review on the Product Stewardship Act 2011, is 80% complete. We are waiting for assessment of institutional and governance arrangements in stewardship, including consideration of overseas examples of clearing house mechanisms.

4.10 As at 30 June 2021, the department reported to its executives and governance body through the quarterly progress report³⁷ that it had implemented 13 Australian Government-led actions under the NWPAP, comprising:

• 11 of the 18 actions scheduled for delivery in 2020;
• one of the four actions scheduled for delivery in 2021; and
• one of the three actions scheduled for delivery in 2022.

4.11 The department provided the ANAO with a breakdown of how the result in the 2020–21 Annual Report was calculated. ANAO review of the evidence showed inconsistencies in the department’s methodology.

4.12 The department informed the ANAO that ‘The 17 action items in the 2020–21 Corporate Plan reflect activities for which the Commonwealth (i.e. DAWE plus other agencies) were responsible in the 2020 calendar year.’ There were 18 actions due in 2020 that were the responsibility of the Australian Government. Action 2.10 was not included in the measure.³⁸

4.13 When reporting against the measure in its annual report, the department did not assess its achievement against the 17 actions referred to in the performance measure in the corporate plan. Instead, the department determined which of the 30 Australian Government-led actions were projected (as estimated in the June 2021 progress report) to be completed within the 2020–21 financial year. This resulted in 12 actions. The department assessed that it had achieved 11 of those 12 actions, with one action (3.01) estimated to be 80 per cent complete. This calculation resulted in 92 per cent of actions completed. The department did not state in the annual report that it was reporting against 12 actions and not the 17 included in the corporate plan.³⁹

4.14 The evidence provided by the department shows that, against the initial 17 actions included in the corporate plan, it had delivered nine of the 17 actions (53 per cent) as at 30 June 2021.

4.15 A draft version of the report was prepared on 10 August 2021 and presented an accurate picture of the department’s performance, stating that:

As at 30 June 2021, the Australian Government delivered 55% of the Australian Government-led action items due for completion in the 2020 and 2021 calendar years.

4.16 The draft was reviewed by the First Assistant Secretary (FAS) of the Environment Protection Division on 12 August 2021.

4.17 A subsequent draft of the performance results was prepared on 17 August 2021. This version reported that 92 per cent of actions were delivered. On 26 August 2021, the FAS certified the latter version of the results as ‘accurately present[ing] the department’s performance in accordance with sub-section 39(2) of the Public Governance, Performance and Accountability Act 2013.’

4.18 The department’s reporting in the 2020–21 Annual Report was inaccurate and presented a more favourable picture of performance than was supported by evidence. The accurate accounting of results was changed to the incorrect version that was subsequently certified as accurate and tabled in Parliament. On 17 June 2022, the department informed the ANAO that it will include a correction in its 2021–22 Annual Report as required under paragraph 17AH(1)(e) of the PGPA Rule.

4.19 In its 2021–22 Corporate Plan, the department included one performance measure related to the implementation of the NWPAP: ‘Reduction in kilograms of waste per capita generated in Australia every year from 2,700 kg to 2,400 kg per person by 2030’. There are no performance measures that provide information on the progress of other targets or on the status of the NWPAP implementation.

Arrangements to address issues arising from performance monitoring

Internal arrangements

4.21 The draft Monitoring and Evaluation Plan does not outline arrangements within the department to address issues arising from performance monitoring. The department informed the ANAO that issues relating to the implementation of the NWPAP are escalated through the department’s business-as-usual channels, such as in section and team meetings.

External arrangements

4.22 In its September 2021 meeting, the RRRG resolved to update the reporting process to ‘manage emerging risks, issues and mitigations’, with the changes implemented from October 2021. Along with new sections summarising ‘Key risks’ and ‘Matters for escalation’ for each target, the October 2021 progress report also contained a table outlining ‘critical risks/issues and key mitigations’ and ‘matters for escalation’ against relevant actions.

4.23 The report does not differentiate between risks, issues and proposed mitigations. It is also unclear how ‘matters for escalation’ are different to risks, issues and mitigations. Items listed under both headings comprise a mix of risks, issues, general comments, questions, or suggestions on how to improve the implementation of a certain action. None of the issues noted in the October 2021 progress report nor the matters for escalation were discussed at the subsequent RRRG meeting held in December 2021.

4.24 In the December 2021 progress report, the template was further changed to add an executive summary section that included a summary of ‘barriers’ and ‘pressures’. It is unclear whether this is intended to comprise risks, issues, or both. The ‘barriers’ and ‘pressures’ were not discussed at the subsequent RRRG meeting held in April 2022, and neither were ‘key risks or issues’ and ‘matters for escalation’ listed in the December 2021 progress report.

Is progress being monitored and measured?

NWPAP progress monitoring

4.27 The draft Monitoring and Evaluation Plan outlines three progress monitoring activities to be undertaken by the Program Office (Table 4.1).

Table 4.1: Progress monitoring activities

Source: ANAO summary of the department’s Monitoring and Evaluation Plan.

4.28 The Status Dashboard was produced monthly from June 2020 until February 2021. From March 2021, the Status Dashboard changed from monthly to quarterly with the agreement of the RRRG. The NWPAP Progress Tracker was retired at the same time and not replaced. The draft Monitoring and Evaluation Plan has not been updated to reflect these changes.

4.29 Progress monitoring activities are being undertaken as outlined in the draft Monitoring and Evaluation Plan and as agreed in 2021. As there are no defined deliverables or milestones to monitor progress against, the effectiveness of monitoring activities is limited and it is difficult to determine whether actions are on track for completion.

Measurement of implementation progress

4.32 The NWPAP states that progress against each of its seven targets is to be measured against the baseline data established in the 2018 National Waste Report, which includes data up to 2016–17. The National Waste Report is produced by the department every two years. It presents data aggregated across all jurisdictions to provide a national measure of waste and resource recovery in Australia. The reports are accompanied by:

• the National Waste Reporting Tool, which converts state and territory data into a national dataset based on a set of agreed scope, method and assumptions; and
• the National Waste Database, which publishes the national waste dataset in a single Excel worksheet suitable for interrogation through PowerBI or similar tools.⁴⁰

4.33 The 2020 National Waste Report, published on 4 November 2020, provided a high-level progress report against the seven targets.

4.34 The 2020 National Waste Report includes data up to 2018–19. It does not measure the impact of the implementation of actions listed in the NWPAP, which was approved in November 2019. As part of the biennial review of the NWPAP, the department noted that the 2022 National Waste Report will include data to 2020–21, meaning it:

will be the first reporting year to show the impacts from the introduction of the NWPAP and other supporting policies and programs which have been enacted by the Australian Government, including the Recycling Modernisation Fund.

4.35 The 2020 National Waste Report does not indicate whether the targets are on track to be achieved. As outlined in paragraphs 4.4 to 4.6, the department is developing a set of supporting indicators to measure each target.

Data quality in the National Waste Report

4.36 The primary data sources for the National Waste Report are state and territory governments. Currently, the jurisdictions use different units of measurement, definitions and ways of collecting data from third parties. The National Waste Reporting Tool converts jurisdictional data into a national dataset for the purpose of the National Waste Reports, setting out the calculation steps, assumptions and classifications used for conversion for each jurisdiction.

4.37 The National Waste Report outlines the data collection methodology, main assumptions made, and the data problems and adjustments used when collating the data presented in the report.

4.38 Further improvements in data collection and data quality are planned through the work of the Data Working Group, which was established by the RRRG in June 2021 to develop a work program for waste data collection, harmonisation and reporting.⁴¹ Its work to date includes the following elements.

• Harmonising data standards — The Australian standard for waste and resource recovery data and reporting was published in October 2021, outlining common data standards for Australian waste management. The standard is voluntary for adoption by states and territories. The alignment of jurisdictions to the standard is being assessed as part of the 2022 National Waste Report.
• Developing supporting indicators for NWPAP targets — see paragraphs 4.4 to 4.6.
• Improving waste data sharing arrangements — This stream of work was incorporated into the broader National Data Sharing Work Program, which is overseen by the Data and Digital Ministers. An approach to a waste data sharing project was presented to and approved by the Data and Digital Ministers at the end of 2021. Barriers to sharing information for the National Waste Database are being identified as part of the 2022 National Waste Report.
• Developing interoperable data infrastructure — This stream of work aims to understand when new data infrastructure is being built so that harmonisation can be embedded into the design and build of the system. The department conducted a survey in mid-2021 to seek information from the Data Working Group members about data systems currently used and being considered for development by their organisation or jurisdiction. The department informed the ANAO that the survey will be undertaken annually.

Program evaluation

4.39 Appendix A to the NWPAP states that:

The National Action Plan will be regularly reviewed to ensure actions are driving positive change in waste management in Australia. Reviews of the plan will allow actions to be updated to address new issues as they emerge and ensure that targets remain ambitious and achievable.

4.40 The RRRG’s terms of reference state that it will be primarily responsible for the delivery of periodic reviews of the NWPAP, which is to take place biennially. In these reviews, the RRRG is to consider:

• whether actions need to be updated to address new issues as they emerge;
• whether the targets remain relevant, ambitious and achievable; and
• where desired outcomes are not being achieved, regulatory, financial or legislative options to help achieve the targets.

4.41 In mid-2021, the department developed a program of biennial reviews, comprising five reviews focusing on different aspects of NWPAP to 2030 (Table 4.2). The approach was presented to and agreed by the RRRG on 28 September 2021.

Table 4.2: NWPAP program of reviews

Source: Biennial review program provided by the department.

2021 Biennial Review

4.42 The first biennial review commenced in 2021. On 14 October 2021, the Program Office requested that the members of the RRRG complete a self-assessment questionnaire to be used for the first biennial review. The questionnaire asked members to identify the current state, what is working well, gaps in current approaches, and opportunities for improvement, in relation to:

• performance measures;
• governance frameworks; and
• communication strategies.

4.43 Self-assessments were completed by the department, on behalf of the Australian Government; state and territory governments; the Australian Local Government Association; and RRRG industry members. ANAO’s review of the completed self-assessments showed that some members have responded to the questionnaire in the context of their own jurisdictional activities, rather than providing feedback on the implementation of NWPAP more broadly.

4.44 In the December 2021 meeting, some RRRG members indicated that more detailed instructions or guidance for the kind of information the department was seeking would have been useful.

4.45 The department informed the ANAO that the self-assessment questionnaire was for initial data collection, with more workshops scheduled in early 2022 to consolidate the feedback before finalising the review. In August 2022, the department advised that these workshops were ‘postponed in light of the federal caretaker period and the diversion of resourcing to support incoming government processes’. The department stated that the draft report for the biennial review ‘will be considered by the RRRG in the third quarter of 2022’ and the final review report ‘will be put to the environment ministers for endorsement’.

Amendment of the NWPAP

4.46 As part of the 2021 biennial review process, the RRRG is establishing a mechanism for ‘by exception’ amendments to the NWPAP. This would enable the NWPAP to ‘evolve to capture new and emerging priorities and initiatives and remain fit for purpose to ensure the outcomes of the NWPAP are achieved’. The proposal to establish the mechanism stated that changes may include:

• adding actions to the NWPAP — such as new government commitments or industry initiatives;
• modifying actions in the NWPAP — such as revising an existing action timeframe, lead or delivery mechanism to reflect changed implementation environment; and
• removing actions in the NWPAP — such as where there is evidence to suggest that the action would be ineffective or has been superseded by events.

4.47 An approach was proposed and agreed in the December 2021 RRRG meeting. All proposals for amendment are to be considered by the RRRG and then put to the environment ministers in the biennial review report. The department informed the ANAO that, as at May 2022, two ‘by exception’ requests have been received, one from a state government and one from an industry body. The requested changes are to be considered by the RRRG along with the biennial review report, before being submitted to the environment ministers for approval.

4.48 Continual review and amendment of implementation strategies helps entities ensure that programs are targeting activities of greatest impact, and desired objectives are on track to be achieved, as circumstances change over time.⁴² Changes to the NWPAP should be evidence-based, well-documented, and closely tracked to ensure that they are not having an adverse impact on policy outcomes.

Is implementation of the plan being effectively reported?

Public reporting arrangements

4.49 The department has established public performance reporting arrangements through the biennial National Waste Reports. The 2020 National Waste Report provided a high-level progress report against the seven targets using the baselines established in the 2018 National Waste Report (see paragraphs 4.32 to 4.35). The 2022 National Waste Report is being prepared and is expected to be published at the end of 2022. The 2022 report will include (for the first time) data for the years following the introduction of the NWPAP.

4.50 The National Waste Report does not provide progress updates on NWPAP actions. There is currently no public progress reporting for actions.

4.51 As outlined in paragraphs 4.4 to 4.6, the department is developing a set of supporting indicators for each target. The department advised the ANAO that the Australian Government will consider whether these indicators will be publicly reported against.

Reporting to Parliament

4.52 In December 2020, the House of Representatives Standing Committee on Industry, Innovation, Science and Resources tabled a report titled From Rubbish to Resources: Building a Circular Economy. The report made 24 recommendations on various aspects of the Australian Government’s waste-related initiatives, including the implementation of the NWPAP. Recommendation 5 stated:

The Committee recommends that the responsible Minister report annually to Parliament on the progress of the targets and actions set out in the National Waste Policy Action Plan 2019.

4.53 The Australian Government responded to the report on 17 February 2022, noting the above recommendation and stating that it ‘considers that existing reporting mechanisms are sufficient’.

Appendix 1 Entity response

Appendix 2 Improvements observed by the ANAO

1. The existence of independent external audit, and the accompanying potential for scrutiny can promote improved performance. Improvements in administrative and management practices can occur: in anticipation of ANAO audit activity; during an audit engagement; as interim findings are made; and/or after the audit has been completed and formal findings are communicated.

2. The Joint Committee of Public Accounts and Audit (JCPAA) has encouraged the ANAO to consider ways in which the ANAO could capture and describe some of these impacts. The ANAO’s 2021–22 Corporate Plan states that the ANAO’ s annual performance statements will provide a narrative that will consider, amongst other matters, analysis of key improvements made by entities during a performance audit process based on information included in tabled performance audit reports.

3. Performance audits involve close engagement between the ANAO and the audited entity as well as other stakeholders involved in the program or activity being audited. Throughout the audit engagement, the ANAO outlines to the entity the preliminary audit findings, conclusions and potential audit recommendations. This ensures that final recommendations are appropriately targeted and encourages entities to take early remedial action on any identified matters during the course of an audit. Remedial actions entities may take during the audit include:

• strengthening governance arrangements;
• introducing or revising policies, strategies, guidelines or administrative processes; and
• initiating reviews or investigations.

4. In this context, the below actions were observed by the ANAO during the course of the audit. It is not clear whether these actions and/or the timing of these actions were planned in response to proposed or actual audit activity. The ANAO has not sought to obtain assurance over the source of these actions or whether they have been appropriately implemented.

Appendix 3 Actions under the National Waste Policy Action Plan

Source: National Waste Policy Action Plan 2019.

Appendix 4 Australian Government funding for initiatives under NWPAP

Source: ANAO summary of the department’s advice on funding, as at the end of 2021.