Managing Landfills

Tabled: 3 September 2014

2 Landfill risks to the environment, human health and amenity

2 Landfill risks to the environment, human health and amenity

At a glance


Landfills can pose a wide range of risks to the environment, human health and amenity. These risks can be minimised through better practice landfill design, operation, management and rehabilitation.


Since 2010, audited councils' identification and management of landfill risks has improved, but they are not yet meeting all their landfill responsibilities. As such, the highest gas and contaminated water risks are being managed effectively, but some lesser gas, water and other risks—which if left unmanaged could escalate—are not.


  • The audited councils have met the Environment Protection Authority's (EPA) new guidelines for landfill design and construction, as well as the risk assessment, monitoring and auditing requirements that EPA has set for higher-risk sites.
  • The councils have not adequately managed the lesser but still important risks relating to gas, odours, contaminated water and asbestos—due to poor operational practices—and there is inadequate rehabilitation at active landfills and shortfalls in after-care of closed sites.


That councils:

  • identify, prioritise and address all of their landfill responsibilities and obligations, including environmental audit recommendations
  • improve their controls over landfill management through their internal risk and audit systems, and landfill inspection processes
  • work with EPA and the waste and resource recovery groups to identify closed landfills, assess their risks and prioritise their management.

2.1 Introduction

Landfills can pose a range of risks to the environment, human health and amenity. The sources and the seriousness of these risks can change over time if not managed effectively. For example, gas levels change due to the age, type and quantity of waste deposited and tend to peak in the decade after the landfill closes. Gas may accumulate in enclosed spaces above or below ground, where it could explode under certain conditions, or migrate off-site and cause dieback in vegetation, accumulate in neighbouring buildings or increase greenhouse gases. Uncovered asbestos can pose a range of risks to human health, with the higher risks being to on-site workers exposed to it. Good management requires risks to be identified, regularly assessed, monitored and managed in a timely and cost effective manner.

Public attention is often focused on active landfills and the risks that they pose, but the legacy risks from closed landfills—mostly constructed under the standards considered good practice in the past rather than to the Environment Protection Authority's (EPA) 2010 revised better practice standards—can also be significant. For this reason, EPA requires closed landfills to be rehabilitated and then cared for over a period of up to 30 years or more.

Councils, as landfill owners, are required to identify, assess and regularly review risks at their landfills in line with the requirements set by EPA in its:

  • 2004 Waste Management Policy (Siting, Design and Management Of Landfills)
  • 2010 guideline Best Practice Environmental Management—Siting, Design, Operation and Rehabilitation of Landfills (the Landfill BPEM), which introduced more stringent standards for new landfills and superseded its 2001 guidelines
  • guidelines for closed landfills and for those exempt from licensing
  • landfill licence requirements and guidelines.

The risk rating will depend on how likely it is that an impact will occur, as well as the predicted severity of the impact. EPA's guidance to its appointed environmental auditors suggests classifying risks according to four categories:

  • very high risk—immediate action required
  • high risk—management required from senior staff, check monthly
  • moderate risk—specify required management, check every three months
  • low risk—manage with standard operating procedures, check annually.

Risks can be rated moderate to very high even though no impact is observed.

This audit focused on the four selected councils' management of risks at active, licensed sites and closed sites. The audit also used information from 62 councils that responded to a questionnaire on landfill management we sent to the other 75 councils.

Landfill gas is the main source of human health risk from landfills and contaminated water leaking from landfills—leachate—is a key environmental risk, so the audit focused on how well these risks are managed.

2.2 Conclusion

Since 2010, the audited councils' identification and management of landfill risks has improved. Their operational audits for licensed landfills and higher risk closed landfills are rigorous and have not identified any very high risks or significant long-term environmental and health impacts.

However, the audited councils are not yet effectively controlling other more moderate risks, which if not addressed could escalate to cause more serious localised impacts, for example through groundwater contamination and/or odour.

Some poor operational management and rehabilitation practices were evident at the four audited councils' licensed landfills, resulting in increased risk of adverse impacts upon the local environment and amenity—mainly through groundwater contamination and odour generation.

The audited councils have not understood or met all their responsibilities for managing closed landfills. They have not addressed the legacy risks posed by gas and leachate contamination in a systematic or timely way. While EPA considers legacy risks posed by these older landfills to be low, the councils' slow progress in identifying and addressing these risks is concerning as some of them have the potential to escalate over time.

2.3 Managing risks from active landfills

EPA requires landfill owners to identify, monitor and if necessary mitigate risks posed by active landfills or landfill cells. It does this by setting regulatory requirements and better practice guidelines through a range of guidance and tools, including:

  • The Landfill BPEM—specifies performance outcomes and measures for managing risks through landfill siting, design, management and rehabilitation.
  • The landfill licensing system—requires landfill owners to assess the risks the landfill poses, implement monitoring programs that have been verified by an EPA appointed environmental auditor and have an EPA-appointed auditor regularly audit the risks and their management.
  • The annual licence reports—require landfill owners to report compliance against licence conditions and report actions to address environmental auditor recommendations.

The source and severity of risks to be managed and the best way to manage them varies between audited landfill sites due to their different characteristics. Figure 2A outlines the characteristics of the licensed landfills.

Figure 2A
Characteristics of licensed landfills at the audited councils


Year landfilling commenced

Waste volume received (tonnes/year)

Size of active cell (hectares)

Estimated remaining lifespan (years)



60 000



East Gippsland

  • Lakes Entrance


8 000



  • Bairnsdale


16 000





30 000





400 000



Source: Victorian Auditor-General's Office.

The four audited councils were generally complying with EPA's auditing and monitoring requirements for licensed landfills. The audit and approval documents showed they were also meeting the required guidelines for landfill design and construction specified in the Landfill BPEM for newly constructed cells. These actions have been particularly influential in leading these councils to effectively identify and manage the highest landfill risks from their licensed sites.

However, they are not consistently complying with all their EPA licence requirements or the relevant Landfill BPEM operational measures. As a result they are not yet effectively prioritising or managing lower to moderate risks to the local environment and the amenity of the neighbouring community.

2.3.1 Council risk management approaches

EPA requires licensed landfills to have a landfill risk assessment, which is reviewed annually. All four audited councils had collected comprehensive information through these risk assessments, although Ballarat and East Gippsland had not reviewed theirs annually.

Councils' risk management is then guided by the licence risk assessment and environmental audit and the subsequent recommendations. Licence audits can make upwards of 30 recommendations for some sites. These are not prioritised by the EPA‑appointed environmental auditors even though EPA's guidelines suggest this to be good practice. This prioritisation is left to councils, which can be an onerous task due to the number and technical nature of some recommendations and the lack of expert technical knowledge residing within councils. None of the four councils had a risk-based process for prioritising the recommended actions and subsequently their implementation was not always timely or appropriately prioritised. Figure 2B outlines the response of councils to recommendations.

Figure 2B
Council responses to licence audit recommendations


2013 audit recommendations


In March 2013, Hume had 36 audit recommendations for its active licensed site. Twelve were new recommendations and 24 were outstanding from the 2012 and 2010 audits.


The October 2013 audit made 16 recommendations, including 14 new recommendations and two from the 2010 audit that had not been resolved.


The November 2013 audit made 33 recommendations, consisting of 21 new recommendations plus 12 from the 2011 audit that were still outstanding.

East Gippsland

The 2013 audits at the two sites made 25 recommendations combined, including 23 new recommendations plus two that were still outstanding from the 2009 audit.

Council planning to implement the recommendations

Hume and Wyndham both had consultants develop plans for implementing the recommendations, but these were not prioritised based on the significance of the issues or time lines for completion. Although Hume requested its monitoring consultant to cost the work needed to address the March 2013 recommendations, by June 2014 it still had not finalised plans to address them.

Ballarat and East Gippsland did not use implementation plans or other risk-based approaches to prioritise this work.

Since 2012 EPA has issued Ballarat a series of eight remedial notices as a way of directing the council to focus on the highest priority recommendations, which related to leachate and gas management. Ballarat has responded appropriately to these. EPA also issued remedial notices to Wyndham in 2014 related to implementing audit recommendations.

Source: Victorian Auditor-General's Office.

Operational requirements are set out in the Landfill BPEM to manage the environmental, human health and amenity risks. Licence audits identified several poor operational practices across all five licensed landfills owned by the four audited councils. These included:

  • progressive rehabilitation requirements not being met
  • insufficient daily covering of general waste or asbestos
  • poor odour and litter management
  • incomplete management procedures—e.g. for fire management and after‑care
  • required inspections not conducted or documented.

In addition, none of the four audited councils fully used its organisational risk management system to support its landfill management processes. Only Wyndham used its internal audit system to examine its landfill management processes.

Since 2013, Wyndham and East Gippsland have introduced new arrangements to strengthen their focus and manage landfill risks. These are directed at improving oversight and operational management. Employing staff with landfill expertise or experience has been central to driving this for both councils.

2.3.2 Gas and leachate management

EPA conducted a methane landfill gas assessment at 252 active and closed landfills following the Brookland Greens Estate incident in 2008, when landfill gas threatened neighbouring properties. This assessment and follow up monitoring of potentially high risk sites identified that no landfills had impacted neighbouring communities as a result of landfill gas emissions.

Since then, the Landfill BPEM and licensing guidelines were amended to require regular gas risk assessments and more active gas monitoring and management for licensed landfills to determine the levels of gas present and manage any impact this is having on the environment. The four councils had all increased their landfill resourcing and management activities to do this.

Licence audits for the five licensed sites in the four audited councils conducted in the past 12 months identified medium to high landfill gas risks to human health and the environment at four of the sites, although monitoring showed that these risks had not actually caused major impacts on the environment or human health. The risks were rated higher because the environmental auditors considered that despite the low current impacts, the management measures in place were not sufficient to minimise the likelihood of future impacts. They assessed that this likelihood ranged from probable to likely. Figure 2C shows the risk level identified by the audits and the results of environmental monitoring.

Figure 2C
Landfill gas risks and monitoring results at licensed landfills


Risk that gas could impact on health and environment

Environmental monitoring results


Very high—for land and indoor areas on site

Not assessed—for off-site migration

Evidence of pollution that is detrimental to the land at the site

No evidence of unacceptable risks in on-site buildings


High—for land and on-site workers

High—for off-site buildings

Moderate—for neighbouring residents

Gas levels exceeded EPA's limits

No gas accumulating in on-site buildings

Inconclusive evidence of gas migrating off site, further monitoring required


Moderate—for land and on-site workers

Low—for off-site migration

Gas levels exceeded EPA's limits, although the auditor was uncertain whether the monitoring location was representative.

Inconclusive evidence of gas accumulating in on-site buildings or migrating off site, further monitoring required

East Gippsland

  • Lakes Entrance

Moderate—for on-site workers

Low—for off-site migration

Landfill gas negligible, no adverse impact

No gas accumulating in on-site buildings

No gas migrating off-site

  • Bairnsdale


Gas not measured—no monitoring required until gas risk changes

Source: Victorian Auditor-General's Office, from the licence audit reports completed in the past 12 months.

The licence audits and risk assessments identified that the councils all had measures in place to manage these gas risks, such as monitoring, vents and extraction systems. However, the environmental auditors identified that Ballarat and Wyndham had been slow to introduce effective measures. Figure 2D outlines these examples.

Figure 2D
Case study—examples of gas risk management at licensed landfills


In 2006, the council put bores in to assess gas levels at its licensed landfill but did not use them to monitor gas levels over time. The council's 2011 landfill gas risk assessment identified the gas risks as low but recommended the council monitor gas levels. This monitoring only commenced in 2012, and the gas risk was revised to medium. The 2013 audit assessed some high risks from landfill gas and also identified that the council was not measuring the risk of gas migrating off site, even though the licence required this.

In 2012, the council embarked on a major program of works designed to better monitor and manage the gas risks. EPA issued three remedial notices to the council in 2012 and 2013 to direct the focus of this work. The work is now complete but it may be several months or longer before the benefit in reducing gas risks becomes apparent.


Its 2013 licence audit assessed the gas risks as high and identified that although there was gas management technology in place its use was focused on generating power rather than on mitigating the gas risks. The licence audit identified that the council's Landfill Gas Remediation Action Plan would be critical to managing the gas risks and recommended the council finalise its draft plan by November 2013. However, the finalised plan was not submitted to the EPA until May 2014. The plan's development was hampered by contractual negotiations with the gas management company.

Source: Victorian Auditor-General's Office.

A key source of environmental risk from landfills is from leachate impacting local streams, lakes or groundwater. The volumes generated and the contaminants present vary over time with factors such as the age of the landfill, the type of waste deposited and the amount of rainfall.

EPA has a range of guidance for managing leachate risks. In 2013 it also developed a specific licence condition for landfills and landfill cells built since 2010. This requires owners to extract leachate from landfill cells so that no more than 300 millimetres accumulates at the bottom of the cell. However, this condition is currently only applied to one of the five licensed landfills belonging to the audited councils.

The audited councils' recent licence audits did not identify any high risks posed to surface waters for the five sites, but rated the risk to groundwater as medium to high but the current impact as minimal, as shown in Figure 2E. However, there was insufficient evidence to determine specific impacts at four of the five sites. The environmental auditors assessed the likelihood of future impacts as ranging from rare to likely.

Figure 2E
Groundwater risks and monitoring results at licensed landfills


Risk that leachate could impact on groundwater

Environmental monitoring results



Evidence of adverse impact on immediate groundwater—significance of impact was not identified

Inconclusive evidence of leachate migrating into nearby aquifers



Evidence of adverse impact most likely confined to the site boundaries, further monitoring required.

East Gippsland

  • Lakes Entrance


Inconclusive evidence of adverse impact, further monitoring required.

  • Bairnsdale


No evidence of adverse impact.



No or inconclusive evidence of adverse impact, further monitoring required.

Source: Victorian Auditor-General's Office, from licence audit reports completed in the past 12 months.

The councils all had leachate risk controls, including monitoring as well as barriers and diversion systems to prevent leachate reaching groundwater. The councils all had auditor-verified leachate and groundwater monitoring programs. The monitoring results led the environmental auditors to recommend improvements to the effectiveness of the controls and each council was in the process of responding to these recommendations.

Progressive rehabilitation

EPA's licences require progressive site rehabilitation—where landfill cells are capped once they are filled—to minimise gas emissions and leachate production. This is separate from the daily requirement to cover cells with 300 millimetres of soil. EPA's workshops with landfill owners/operators have emphasised that progressive rehabilitation is integral to managing leachate and gas risks. In its 2012 workshops with landfill owners EPA advised that temporary capping should be 500 millimetres thick, although EPA has not updated the Landfill BPEM to reflect this.

Progressive rehabilitation was inadequate at all of the five active landfills in the audited councils because:

  • none used an interim cap that was 500 millimetres thick—although not all councils had attended the workshops and EPA had not provided any formal advice on this requirement to all landfill owners
  • they relied on the300 millimetres daily cover to be sufficient—even though the environmental audits had identified issues with insufficient daily cover at all sites
  • the rehabilitation plans that EPA requires for all licensed sites were not up to date, and only Wyndham's demonstrated the detailed planning needed to estimate the appropriate capping requirements.

This is a concern at Ballarat's and East Gippsland's Lakes Entrance sites in particular, given their higher leachate risks and inadequate rehabilitation plans.

Images show waste that has been properly covered at the end of the day with a thick cover of soil or similar material to limit litter, vermin and odour emissions, compared to waste that has been poorly covered. Photograph courtesy of the Environment Protection Authority.

Images show waste that has been properly covered at the end of the day with a thick cover of soil or similar material to limit litter, vermin and odour emissions, compared to waste that has been poorly covered.
Photographs courtesy of the Environment Protection Authority.

2.3.3 Compliance with regulatory requirements

Since 2010, the four audited councils had all increased their management and monitoring activities to be able to meet EPA's new licence requirements and better practice guidelines.

EPA requires councils, as landfill owners, to report compliance with licence conditions annually and to have monitoring programs and management records to demonstrate this compliance.

In the three years the reports have been in place, there are examples where the four councils have identified themselves as 'compliant' with licence conditions even though they could not demonstrate this. In some cases this was because they did not have sufficient or appropriate evidence, such as inspection results or photographs. In others, an EPA-appointed environmental auditor or an EPA inspection had identified that poor or inadequate practices had been implemented to comply with specific conditions. Where the councils rely on environmental auditors or consultants to assess compliance with licence conditions, these assessments do not always examine all the information available. There are also examples where councils have made definitive compliance statements where the auditor had not.

Most commonly, the councils' unsubstantiated statements of compliance were for licence conditions relating to amenity, type of waste accepted or the daily soil coverage of wastes. For example, the environmental auditors at both Ballarat and Hume identified that landfill management did not meet requirements for inspecting waste types deposited at the tip face and applying daily cover, yet these were not reported as noncompliance. Wyndham and East Gippsland introduced regular inspections and are recording them to be able to demonstrate whether they meet their licence conditions.

2.4 Managing risks from closed landfills

Older landfills—those sites or cells built to the less stringent standards that were accepted as good practice at the time—pose risks that need to be managed. Gas and leachate risks from these landfills can be more complex, time consuming and costly to address due to the siting, design and past management of these sites.

Effective management of the legacy risks posed by older landfills relies on good site knowledge to implement proportionate actions to address the potential severity and likelihood of environmental impacts. These older landfills are mostly closed landfills, but also include older cells at active sites, which are both licensed and unlicensed.

The problems that these older landfills present and the levels of risk that they pose will vary over time. Figure 2F shows examples of problems these older landfills can present. For this reason, EPA's Landfill BPEM and other guidance identify that the time frame for managing landfill rehabilitation and after-care can extend to 30 years or longer.

Figure 2F
Examples of problems posed by landfills built to past standards


Approximate period of impact after closure (a)

Landfill gas generation

10 years


Most likely in the first 10 years but can occur for 30+ years

Leachate production

30+ years

Soil contamination

30+ years

Landfill capping deterioration

30+ years

(a) For a typical landfill receiving putrescible waste.

Source: Victorian Auditor-General's Office.

The audited councils managed the risks posed by older cells in active licensed landfills better than they did the risks from closed sites. This is because councils have accumulated extensive knowledge of the risks, which are managed through the risk assessment and audit processes used for licensed landfills. This section focuses on the management of closed landfills.

The councils have not met their responsibilities for managing legacy risks at their closed landfills. Since EPA introduced the first landfill policy in 1991, landfill owners have been required to manage rehabilitation and after-care issues—including gas and leachate management. The four audited councils have not done this because they have not comprehensively or systematically assessed and then managed these risks. Nor did they fully understand their responsibilities, which EPA has not clearly articulated in its policy and guidelines.

2.4.1 Site identification and assessment

Since it published its first landfill state environment protection policy in 1991, EPA has identified that landfill owners are responsible for all phases of landfill management, from design through to after-care. This applies equally to both active and closed sites. EPA has not, however, assigned responsibility for identifying and recording closed landfills that are not already known.

Despite this, the four councils each had a complete list of council and privately-owned closed landfills—although Hume only completed its list in May 2014, identifying six more sites. The four councils all either had or were in the process of recording their locations on their municipal maps.

Once the sites are identified, the councils need to assess the legacy risks that the closed sites they own may pose, but this has only occurred for some sites. EPA has not provided clear guidance about the type of assessment needed.

Of the four audited councils, three had assessed and prioritised the risks across all their closed landfills but the level of rigour and information in the councils' assessments varied. Ballarat's better, more detailed assessment identified potential hazards, the pathways through which they might take effect and the potential impacts on the environment. The others were higher level and considered only a narrow range of risk factors. Figure 2G outlines the risk assessments undertaken by the audited councils. A lack of detailed risk assessment reduces the ability of councils to understand the risks and appropriately prioritise the management of these sites.

Figure 2G
Council risk assessments across all their closed landfills


High level assessment

Detailed assessment and prioritisation


Yes—in 2009, limited criteria—e.g. waste received, local receptors and rehabilitation method—but did not assess likelihood and consequence

  • 10 landfills, closed between the 1930s and 1996
  • number of high-risk sites not clear(a)

Yes—in 2011, considered additional factors such as underlying geology, groundwater depth, likely gas generation and rated according to likelihood and consequence.

  • seven high-risk sites

East Gippsland

Yes—in 2011, range of different criteria—e.g. waste received, underlying geology, local receptors—assessed according to high, medium or low hazard potential but did not assess likelihood and consequence

  • 46 landfills, closed between the 1940s and 2014
  • five high-risk sites

No—in 2011 the council also commissioned an assessment of the five high-risk sites but it did not receive the quality of assessment it sought and is discussing management options for these sites with EPA


Yes—in 2008, but did not include all sites, used a limited range of criteria and did not assess likelihood and consequence

  • 12 landfills, closed between 1970 and 2008
  • no high-risk sites


Wyndham (b)

No—the closed sites were mapped in 1984 but not assessed, as most had been closed for over 30 years

  • six landfills, closed between 1952 and 1976


(a) Ballarat could not provide a copy of the risk rankings from the original high-level assessment.
(b) Wyndham commenced a process during the audit to assess potential risks from its sites.
Source: Victorian Auditor-General's Office.

We sent a questionnaire to the other 75 councils that were not part of the audit, and 62 councils responded. The questionnaire responses indicated that many other councils are also not conducting robust assessments of legacy risks at closed sites. Of the 22 councils that provided risk assessments of their closed landfills, only eight had conducted detailed, robust assessments of potential legacy risks.

Councils have predominantly assessed their landfill risks in isolation from other councils. The former Gippsland and North East Victorian regional waste management groups conducted regional risk assessments of closed landfills, but the other 11 former regional groups did not. Efficiencies in cost and time could be gained by assessing landfill risks at a regional scale. Councils could work to do this with the new regional waste and resource recovery groups, which were established on 1 August 2014 and replaced the regional waste management groups. This information would also support EPA in building a statewide understanding of landfill risks.

2.4.2 Gas and leachate management

The four audited councils have not adequately assessed or managed the legacy gas and leachate risks at their closed landfills.

Since it released its first landfill policy in 1991 and then through a series of guidance materials, EPA has required councils to manage, rehabilitate and monitor closed landfills as needed to protect residents and the environment. This role has not always been clearly stated for landfills that were already closed, and has not always been clearly understood by councils for all closed landfills.

The 2010 Landfill BPEM was the first policy or guidance document that explicitly identified that councils were responsible for managing landfills that were already closed—whether or not the sites had been regulated by an EPA licence or remedial notice. In 2012, EPA released a specific guideline for landfill owners managing the rehabilitation and after-care of closed landfills that it identifies as being higher risk. The landfills that EPA considers higher risk are primarily those that it licensed when they were active.

Image shows a closed landfill site that has been rehabilitated as a recreation reserve and is surrounded by residential development. Gas and leachate monitoring bores are in place but not visible in this photograph.

Image shows a closed landfill site that has been rehabilitated as a recreation reserve and is surrounded by residential development. Gas and leachate monitoring bores are in place but not visible in this photograph.

The guideline recommends that landfill owners assess gas and leachate risks in detail and that monitoring and rehabilitation activities include gas and/or leachate management, where warranted.

Of the three audited councils that had assessed risks at closed sites, Ballarat identified high or medium gas or leachate risks at five sites, and Hume at one. East Gippsland had one site with reliable evidence of medium risks. Despite having known of these sites for many years and having known the risks for several years, the councils did not adequately manage the risks:

  • Ballarat—identified its high-risk sites in 2011, but is only managing the risk sat two of the five sites. It did not further investigate the risks at two of its unmanaged sites in 2011 and 2012 as planned.
  • Hume—did not manage either gas or leachate risks promptly from its site which closed in 2008. In relation to this site:
    • while Hume had been harvesting gas since 1994, it identified high gas risks in 2011 that required monitoring. However, the council did not start monitoring until mid-2013.
    • in 2010 the council identified the current leachate management system as inadequate, but it then took four years to assess and trial management options.
  • East Gippsland—although the site closed in 2003, the council did not introduce actions to monitor and manage gas or leachate until 2013.
  • Wyndham—has not managed any of its closed landfills but is now assessing the potential risks they pose. As these have been closed for around 40 years or more, they are likely to pose no or minor gas and leachate risks, but the risks from subsidence and contaminated soil may be higher.

2.5 Future management of risks

There are aspects of the current management of landfill risks that are either lacking or not effective, and need to be improved. There are also emerging issues that EPA and councils need to respond to.

For councils, meeting the new EPA guidelines for closed and unlicensed landfills will require them to comprehensively identify sites and better assess, prioritise and manage legacy risks. To do this effectively will require a high level of in-house landfill knowledge and experience that not all councils have. Some councils have considered sharing the costs of employing a landfill expert with other councils, which could be a cost-effective solution. EPA's proposed online training for landfill operators should also help.

The four audited councils are meeting the costs of bringing active licensed landfills into compliance with the Landfill BPEM guidelines. A third of the 66 councils that responded to the audit questionnaire, or were part of the audit, were concerned about or struggling with the costs of managing closed and active unlicensed landfills to EPA's new guidelines. Information from these councils identified that management and rehabilitation costs vary but can be significant. For example:

  • costs from $4 000 to rehabilitate a small unlicensed site to $2 million to rehabilitate six closed sites
  • costs from $20 000 to monitor six sites to $300 000 to manage two closed sites.

Good rehabilitation relies heavily on effective capping. The Landfill BPEM guidelines rely heavily on specific types of clay to achieve this, but clay is in increasingly short supply in Victoria, and is expensive to transport over long distances. EPA should assess the extent of this issue and may need to review its guidelines based on this assessment.

It can be harder for smaller, rural landfills to recover landfill costs through gate fees and rates, because of the slow filling rate and the smaller population of ratepayers.

EPA's 2005 financial and environmental modelling of unlicensed landfills shows that many of these small, rural landfills are largely unviable. It also identified that as management standards would increase over time, the risks may be more appropriately and economically managed by recommending the closure of all unmanned sites at a minimum.

EPA did not develop a strategic program for managing unlicensed landfills, as planned in its 2004 landfill policy, but Sustainability Victoria's Draft Statewide Waste and Resource Recovery Infrastructure Plan 2013–2043 has this as a priority action. It identifies that the government will support councils to develop options to replace unlicensed landfills with more viable waste management solutions.

Image shows a small active, unlicensed landfill before and after rehabilitation has commenced. Courtesy of East Gippsland Shire Council.

A small active, unlicensed landfill before and after rehabilitation has commenced.
Photographs courtesy of East Gippsland Shire Council.

Only four councils responding to the questionnaire had started setting money aside in a rehabilitation reserve fund. These councils identified it will likely be several years before this covers rehabilitation costs required now. This underscores the importance of councils using comprehensive and robust risk assessments to target limited available funds at managing the greatest risks. All councils will also need long-term planning to meet both the current need to raise rehabilitation standards at closed sites and the anticipated longer-term need to rehabilitate active sites.

In 2012, the government made $3.5 million available to help rural landfill operators transition to meeting its best practice guidelines, but based on EPA's assessment and the responses to the audit questionnaire, this is not sufficient to appropriately manage the risks.

All waste deposited at landfills incur the landfill levy, which is administered by the Victorian Premier and the Minister for Environment and Climate Change. The majority of the levy's revenue is paid into the Sustainability Fund, which has previously been under the management of Sustainability Victoria, but in 2014–15 will transfer to the Department of Environment and Primary Industries. While EPA does not manage the fund, it should work with the Department of Environment and Primary Industries and its waste portfolio partners to develop options for the Minister for Environment and Climate Change to consider for using the landfill levy to help fund the timely rehabilitation of high-risk landfills.


That councils:

  1. identify, prioritise and address all of their landfill responsibilities and obligations under the Environment Protection Act 1970, the 2004 Waste Management Policy (Siting, Design and Management of Landfills) and associated guidelines, including:
  • operating and progressively rehabilitating active sites
  • assessing and managing risks at closed sites
  • planning to meet anticipated rehabilitation and after-care costs
  1. build their in-house landfill knowledge and skills so that they can work with Environment Protection Authority-appointed environmental auditors and landfill experts to effectively prioritise and address risks
  2. consolidate the recommendations from environmental audits and other external and internal reviews across all landfills, and develop and implement risk-based priorities and time lines for addressing them
  3. improve their internal controls over landfill management through their internal risk and audit systems and landfill inspection processes
  4. work with the Environment Protection Authority and the regional waste and resource recovery groups to identify closed landfills, assess their risks and prioritise actions at a regional scale to address these.

That the Environment Protection Authority:

  1. works with the Department of Environment and Primary Industries and waste portfolio partners to explore options for the Minister for Environment and Climate Change to use the landfill levy for the timely rehabilitation of high-risk landfills.

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