Item 8.2 - Attachment 1

Draft Illegal Dumping Strategy


1800 Dumped - Dob in a dumper









Section1 INTRODUCTION............................................................ 3   




Section 3  EVALUATION .............................................................. 11



Appendix 1    Example of letter to offender.............................................................. 12


Appendix 2    Example of Notice to Provide Information........................................ 13


Appendix 3    Example of Clean-up Notice.............................................................. 16


Appendix 4    Example of High Visibility Illegal Dumping Sticker.......................... 19


Appendix 5    Example of High Visibility Illegal Dumping Tape............................. 19


Appendix 6    Example of Vehicle Signage for Visual Presence            20





Illegal dumping refers to the unauthorised placement of waste onto public land. Parramatta City Council, along with most Councils in NSW experiences a significant problem with illegal dumping, with collection and disposal costs to Council being in excess of $800000 per year.


This strategy aims to reduce the amount of illegal dumping occurring in the Parramatta Local Government Area and in turn, provide financial savings to the Council from collecting and dispose of such materials as well as improving the appearance, health and natural environment of the city.



Why Dump Illegally?


There are a number of reasons why people may believe it is acceptable to illegally dump materials. Some of these reasons could include:

·    That everyone does it and there is no fear of reprisal

·    Culprits are not likely to be identified

·    Residents have insufficient storage prior to Council Clean Up

·    Taking materials to the tip is inconvenient and expensive

·    It is easy to dump materials on an existing pile


Waste left on Council’s nature strip may act as a signal to other residents that:

·    Maybe it’s time for Council’s hard rubbish collection, so they add their unwanted belongings to the pile (may not be aware of the correct procedure for securing the use of Council’s clean up service), or

·    That it is acceptable to place unwanted belongings on the nature strip at anytime.


When Council’s crews come along and take the rubbish away this may reinforce a perception of some residents that it is:

·    Council’s job to collect rubbish, and

·    Even if you are not meant to dump things it does not matter because there are never any consequences other than the rubbish being removed.


Council is faced with a difficult choice - dumped rubbish attracts further dumping and Council is keen to prevent this by sending out crews quickly to clean up. Cleaning up however reinforces the message that dumping is acceptable.





The Problem With Illegal Dumping


The amount of illegal dumping in Parramatta would indicate that residents and visitors to the area do not view this matter as a serious issue or alternatively, that they are not aware of the options available to them to dispose of materials. However, research into littering has shown that people respond positively to clean areas and are less likely to litter them. This is also the case with dumping.


There are a number of problems associated with illegal dumping which make it undesirable for any area. These include but are not limited to:

·    Dumped rubbish looks bad

·    Rubbish attracts rubbish

·    Illegal dumping sends out a message to others that people don’t care or take pride in their community

·    Dumped materials may create an unsafe obstruction or create unhealthy conditions

·    Dumped rubbish can cause physical harm to the environment by polluting land, water and air.

·    It costs money to remove –transferring cost from the rubbish owner to council.






Who, What, Where and Why?


The types of illegally dumped materials can vary greatly, but most commonly include general household waste, large domestic items such as whitegoods and mattresses, building materials, garden organics, clinical and hazardous wastes, abandoned cars and car parts. On the ground monitoring and complaints received by Council have identified some common features amongst areas which are known “hot spots” for illegal dumping. Generally, these can be categorised into the following groups:


·    Multi-Unit Dwellings (including Department of Housing properties)-  Parramatta experiences an on-going problem with illegal dumping of hard rubbish in multi-unit dwellings. Tenants vacating these units frequently dump on the nature strip outside their building.  Alternatively tenants may leave them in the flat for the landlord or real estate agent to deal with who in turn dump onto the nature strip. Problem areas are generally where there are  concentrations of multi unit dwellings such as Harris Park, North Parramatta, Westmead, Granville and Parramatta.


·    Railway Stations – Illegal dumping appears to be common around railway stations. This is thought to be due to a number of reasons including that it is easy to dump late at night when there is very little pedestrian or vehicle traffic and surrounding areas are often poorly lit and with wide nature strips or reserves where there is unrestricted access and materials can be easily unloaded. In addition, dumpers may choose these locations as they are not directly linked to a residential property, making it more difficult to identify an offender.


·    Industrial and Commercial areas – Like Railway Stations, it is thought that industrial and commercial areas are common locations for illegal dumping as outside of regular business hours there is often greatly reduced traffic and therefore witnesses to offences. In addition, such areas are often poorly lit and there are wide open spaces where materials can be easily be deposited from a vehicle.


·    Roads with little or no through traffic – Sometimes in residential areas but particularly common in locations where there is a largely industrial or commercial/retail component. Commercial/retail areas are often associated with low traffic service laneways which are again generally poorly lit areas and easy targets after normal business hours. Industrial areas are often associated with concentrations of industrial units in an area serviced by a series of no through traffic roads and are ideal dumping locations given the low possibility of witnesses after hours.


·    Parks, bushland, reserves and vacant land – These are easy targets as unrestricted access is often available making dumping relatively simple. Such areas are usually poorly lit at night or have areas of dense vegetation providing protection from witnesses to any illegal dumping. Again, such locations are not often directly linked to a residential property, making it difficult to link the offence to a particular individual.


·    Areas with large populations of residents from a Non English Speaking Background (NESB) – It is believed that this may be directly due to residents not having access to information  in their own language or having a poor understanding of Council’s Clean Up Service, suitable options for disposing of waste or the fact that dumping is illegal.


                        Objectives of the Illegal Dumping Strategy


1.   To reduce the amount of illegal dumping in the City of Parramatta .

2.   To improve the visual amenity of Parramatta.

3.   To change the public perception that it is acceptable to dump household items on the nature strip and other public places.

4.   Change the public perception that it is Council’s responsibility to clean up dumped rubbish.

5.   To make the public aware that dumping is illegal and that there are monetary penalties.

6.   To provide residents with solutions or options for disposing of unwanted materials.





The process used to implement the illegal dumping strategy is illustrated below.  The strategy focuses on the principals of education, investigation and enforcement to achieve its objectives.



Education Component


It is important that an education campaign is implemented to complement the investigation and enforcement component of the strategy. This is to ensure that residents understand the options available to them in finding alternative ways to dispose of their waste and the penalties involved with illegal dumping. Educational resources shall include:



·    Brochures/ leaflets providing information on the cost of illegal dumping to Council and therefore residents as ratepayers and how they can assist Council in targeting illegal dumping. Also, brochures shall provide information on Council’s Clean Up Service, location of nearby waste management facilities and the penalties involved for illegal dumping. Brochure to be produced in 6 main languages spoken in Parramatta (according to 2001 Census Data) – English, Arabic, Cantonese, Mandarin, Korean and Tagalog (Filipino).


·    Media releases to be published in local papers regarding implementation of illegal dumping strategy, dates of Council’s Clean Up Service, penalties for illegal dumping and other articles as relevant .Feature in community newsletter.


·    Billboard and poster advertisements and consideration to be given to advertising in highly visible areas (eg. Parramatta Stadium, bus shelters, railway stations)


·    Council’s Web page to be updated with information in relation to illegal dumping, what residents can do to help, Council’s Clean Up Service, nearest waste management facilities and what will be accepted at the facilities, and penalties involved for illegal dumping.


·    Postcards regarding illegal dumping and the penalties involved (already produced) to be distributed by Council staff as seen necessary whilst in the field.


·    Various promotional items to be produced including stickers, magnets, key rings and other items as appropriate for promotional events related to the strategy.


·    High visibility tape and stickers to be used on illegally dumped materials, sending a clear message to residents that dumping is illegal and that Council will be pursuing offenders. Stickers to be utilised to promoted awareness on  the residential bins.


·    Regular patrols by Council officers for illegal dumping including with vehicles visually marked to identify with strategy.


·    Managing Agents kits to be created so that they can be distributed to all new tenants. Kits to provide information on illegal dumping, Council’s Clean Up Service etc. Strata managers to be given information to display on notice boards regarding Council Clean Up dates and illegal dumping.


·    Implementation of a phone Hotline ‘1800 DUMPED’ to encourage residents to call council and advise of illegally dumped rubbish and take ownership and Pride in the city where they live.

·    Schools-develop a education interactive program regarding illegal dumping-‘The Future is in your hands’


·    Develop a section on the PCC Website-promoting the hotspots, and areas showing pride and reducing the incidences of illegal dumping.


Investigation and Enforcement Component


Council has developed the following standard procedures for investigating an illegal dumping incident. This will ensure that all incidents are handled in a consistent manner and that the investigation process is clear and fair. The process is outlined in the attached flow chart and explained in further detail below:


1.   Council receives a report from a resident or Council employee/officer that materials have been illegally dumped.


2.   Council officers respond to reports of illegally dumped waste and investigate the source of waste/ collect evidence.


3.   Photos are taken of illegally dumped waste in case further enforcement action is required.


4.   Dumped waste is tagged with high visibility tape and illegal dumping sticker                      sighting that dumped materials are under investigation


5.    Where dumped waste is considered to pose an immediate danger to public health and safety, Council crews will remove rubbish immediately after evidence is collected. See Step 9 from here.


6.    Illegal dumping postcards are dropped into appropriate addresses or letter issued to confirmed polluter following initial investigation.


a.  If the property is owned by the Department of Housing (DoH), then a letter is issued or a phone call is made to the DoH to remove rubbish.

b.  Where illegally dumped waste is reasonably suspected to come from a recently vacated premises and a Managing Agent can be identified, then a Notice to Provide Information is issued to the Managing Agent under Section 193 of the Protection of the Environment Operations Act.

i. If a response is received to the Section 193 Notice and the polluter is identified, then a letter is issued to the polluter.

ii.      If no response is received to the Section 193 Notice, then a Penalty Infringement Notice may be issued to the Managing Agent for failing to provide details.


7.    Council officer returns within 72 hours and documents whether dumped waste is still present.


8.    The following scenarios are then possible:


               Scenario 1: Dumped waste has been removed by polluter. No further action is then required from Council.


               Scenario 2: If dumped waste has not been removed and polluter has been identified (and letter previously issued to remove dumped waste – see Step 6), Council issues Clean Up Notice under Section 91 of the Protection of the Environment Operations Act 1997 to remove materials or alternatively issues Penalty Infringement Notice. Either polluter or Council removes waste depending on enforcement action taken. (Decision by Council to remove illegally dumped waste will depend on danger posed to the community by incident.)


i.    Where the property is owned by the Department of Housing (DoH), then a Clean Up Notice shall be issued to the DoH.


ii.   Where a response has been received to the Notice to Provide Information in the case of a recently vacated dwelling and dumped waste can be attributed to or are reasonably suspected to have come from a particular polluter, then a Clean Up Notice is issued to polluter. Alternatively, and at the discretion of the investigating officer, consideration may be given to issuing a Clean Up Notice to the Managing Agent.


               Scenario 3:  If dumped waste has not been removed and the polluter cannot be identified, Council crews are contacted and the waste is removed.


9.      Where the polluter can be identified, a Compliance Cost Notice under Section 104 of the Protection of the Environment Operations Act 1997 may be issued to the confirmed polluter to recover Council’s expenses in removing and disposing of waste. Obtaining polluter’s details may involve the use of a Section 193 Notice issued to a Managing Agent (see Step 6).


10.    Illegal dumping incidents are recorded into Council’s database.








Other Methods to be Used


                        Council officers will also utilise the following options for tackling the illegal dumping problem. These will include:

·    Regular patrols of known “hot spots”.

·    Restricting access to known dumping areas by installing fencing or other barriers where suitable.

·    Upgrading lighting in poorly lit areas.

·    Installing signs advising that the area is regularly patrolled and relevant information regarding illegal dumping (i.e. offence and penalties).

·    Installing video surveillance cameras where suitable as a short term deterent tool.

·    Move rubbish back onto private property.


                        Other Associated Campaigns


                        In addition to illegal dumping and to complement the campaign, Council will also be addressing the associated issue of littering. In particular, the offence of Littering from Motor Vehicles (Section 146 Protection of the Environment Operations Act 1997) can be easily reported on pre-existing Council forms, providing trained staff of Council the opportunity to contemporaneously record information concerning these offences and authorised officers to issue Infringement Notices to the owner of motor vehicles. It is believed that taking on a strong enforcement role and issuing infringements for such offences will have both an education and deterrent effect not only for littering but also a flow on effect to discourage illegal dumping.


                        It has also been noted that abandoned shopping trolleys are often associated with illegally dumped materials. Council will address this matter as part of its illegal dumping strategy, both through education and enforcement.’ Trolley trackers to be utilised as part of the campaign,


                        Rid Squad- a autonomous team of specialise investigation officers targeting illegal dumping. Rid squad working collectively across the region to assist in reduce the instances of illegal dumping..






                        The campaign shall be reviewed within 12 months of implementation to determine its effectiveness and make suitable modifications to ensure that it remains effective. This shall include examining Council’s Illegal Dumping database to determine whether the frequency of illegal dumping incidents has decreased and whether identified “hot spots” have improved.


                        It should also be a time to re-evaluate the effectiveness of educational resources, update information in relation to legislation changes and redirect the focus of the campaign to utilise the most effective resources to achieve desired outcomes. In addition, the effectiveness (including an analysis of the cost benefits) of installing infrastructure and equipment such as fences, lighting and surveillance cameras to identified target areas can be evaluated.




Appendix 1 Example of letter to offender 


                                                                                                                        Your Reference:            

                                                                                                                        Our Reference:              


                                                                                                                        Telephone:        9806

                                                                                                                        Fax:                  9806 59



INSERT ADDRESS                                                                     DATE



Dear Sir/Madam,


Rubbish on nature strip at INSERT ADDRESS


Council records indicate that a rubbish collection service is not due in your suburb until INSERT DATE.


As a resident of the Parramatta City Council you are only permitted to place waste on the council nature strip when a collection service is being undertaken in your neighbourhood.


As a condition of the clean-up service the rubbish is not to be placed out on the nature strip until the Sunday before the collection service commences.



If the waste is not removed from the Council nature strip within INSERT days, Council may issue a Clean Up Notice which carries an administration fee of $433.00 or an on the spot fine for littering maybe imposed (Penalty exceeds $200.00). Your help in resolving this matter within INSERT days from the date of this letter is appreciated.


Please contact me on 9806- INSERT between 8.00am – 9.00am weekdays if you have any enquiries.


Yours faithfully,














Appendix 2 Example of Notice to Provide Information


                                                                                                                        Your Reference:            

                                                                                                                        Our Reference:              


                                                                                                                        Telephone:        9806 5

                                                                                                                        Fax:                  9806 5903






Section 193 Protection of the Environment Operations Act 1997



Served by POST/HAND



                        FULL ADDRESS






ARBN number if registered foreign company operated in Australia


Date:              INSERT DATE




INSERT AUTHORISED OFFICERS NAME is an authorised officer of Parramatta City Council who reasonably suspects that INSERT DETAILS


Requirement to provide information and/or records


INSERT AUTHORISED OFFICERS NAME as an authorised officer of Parramatta City Council requires INSERT NAME OF PERSON OR COMPANY TO WHOM NOTICE IS ADDRESSED to provide INSERT AUTHORISED OFFICERS NAME with the following information and/or records:




You do not have to provide any record specified unless that record is in your possession or you can lawfully obtain possession of it.


The information and/or records required may be forwarded by normal postal service, email or facsimile transmission.


The information and /or records must be provided by INSERT TIME AND DATE.




It is an offence against the Protection of the Environment Operations Act 1997 not to comply with this notice unless you have a lawful excuse for not complying.  It is also an offence to provide information under this notice knowing that the information is false or misleading in a material respect.


However, if you are a natural person (that is an individual rather than, for example, a company or other incorporated body) you may object to providing information that this notice requires you to provide on the ground that the information may incriminate you.


This warning is given for the purposes of section 212 of the Protection of the Environment Operations Act 1997.


There is important information at the end of this notice that you should read about self-incriminating information and/or records that you provide in compliance with this notice.







Parramatta City Council





























Penalty for not complying with this notice


The maximum penalty that a court may impose on a corporation for not complying is $1,000,000, with a further $120,000 for each day the offence continues.  The maximum penalty that a court may impose on an individual for not complying is $250,000, with a further $60,000 for each day the offence continues.


Self-incriminating information and/or records


The fact that the information and/or records that this notice requires you to provide might incriminate you or make you liable to a penalty does not excuse you from having to comply with the notice.


The fact that a record provided by you in compliance with this notice might incriminate you does not make that record inadmissible against you in criminal proceedings.
































Appendix 3 Example of Clean-up Notice

                                                                                                                        Your Reference:            

                                                                                                                        Our Reference:              


                                                                                                                        Telephone:        9806 5

                                                                                                                        Fax:                  9806 59


ADDRESS                                                                      DATE



Direction to Take Clean-Up Action

Section 91 Protection of the Environment Operations Act 1997


Served by Post.




Date of Offence:     DATE



Parramatta City Council is the appropriate regulatory authority (ARA) pursuant to section 91 of the Protection of the Environment Operations Act 1997 which reasonably suspects that a pollution incident, namely INSERT  DETAILS at INSERT LOCATION.


Direction to take clean-up action

Council hereby directs INSERT NAME to take the following clean-up action:





This notice is issued under section 91 of the Protection of the Environment Operations Act 1997.  It is an offence against that Act not to comply with this notice, unless you have a reasonable excuse for not complying.  There is no right of appeal against a clean-up notice.


You are required to comply with this notice within  days from the date hereon.  You are also required to pay an Administration Fee of $320.00 within twenty eight (28) days from the date hereon as prescribed by Clause (d) of the Protection of the Environment Operations (General) Regulation 1988.



Penalty for not complying with this clean-up direction:


·    Not complying with this notice constitutes an offence and a penalty not exceeding $250,000 for a corporation, with a further $120,000 each day for a continuing offence or $120,000 for an individual, with a further $60,000 each day for a continuing offence pursuant to Section 91 of the Protection of the Environment Operations Act 1997.


·    In lieu of proceeding with this matter through a Court an “on-the-spot” FIXED PENALTY INFRINGMENT NOTICE (enforced by the NSW Police Service) may be served upon you and imposes a fine of $750 for individuals and $1500 for corporations.


Penalty for not paying the Administration Fee:


·    It is an offence not to pay the Administration Fee however you may apply for an extension to pay.  The attached information page provides information about how and when to pay the fee and how to apply for an extension of time to pay.

·    Failure to pay the Administration Fee could result in the issue of an “on-the-spot” FIXED PENALTY INFRINGEMENT NOTICE being served upon you and imposes a penalty of $750.00 for individuals and $1,500.00 for corporations.











What you may do if you are not the polluter:

·    If you comply with this clean-up notice but you are not the person who caused the pollution incident to which the notice relates, you have a right to go to court to recover your costs of complying with the notice from the person who caused the incident.


Deadline for paying fee:

·    The fee must be paid by no later than 30 days after the date of this notice, unless you are given an extension of time to pay the fee.


How to pay fee:

·    In person at Council by cheque (payable to Parramatta City Council) or credit card to account number 10/7060/520/742607/00000.  The attached copy of the notice should also be returned to Council.


How to apply for extension of time to pay the fee:

·    Any application must be made in writing to the Manager – Environment & Health at Parramatta City Council, PO Box 32, Parramatta, NSW, 2124.  The application should set out clearly why you think your application should be granted.


Other costs:

·    The Protection of the Environment Operations Act allows Parramatta City Council to recover from you any reasonable costs and expenses it incurs in monitoring action taken under this notice, ensuring the notice is complied with, and associated matters.  (If you are going to be required to pay these costs and expenses you will be issued with a separate notice about this at a later date.)


For any further information regarding this Notice please contact the issuing officer.




















Appendix 4 Example of High Visibility Illegal Dumping Sticker




Appendix 5 Example of High Visibility Illegal Dumping Tape












Appendix 6 Example of Vehicle Signage for Visual Presence