Why does the Shoalhaven pay the waste levy at the Sydney rate? Because the EPA's lists put it in the Metropolitan Levy Area, and when two reviews questioned how that line is drawn, in 2018 and 2020, the official responses were both marked Noted. The NSW waste levy is charged by the tonne at licensed waste facilities, and the state sorts councils into a Metropolitan Levy Area, a Regional Levy Area, and the rest of NSW. Shoalhaven is on the EPA's list of Metropolitan Levy Area councils, alongside Kiama, Shellharbour, Wollongong and the Sydney councils (EPA, levy regulated area and levy rates). On the EPA's map, that area ends at Shoalhaven's southern boundary (EPA levy area map, dated 29 February 2024).

On 9 October the council said Mayor Patricia White has written to the Minister for Climate Change, Energy, Environment and Heritage, Penny Sharpe, and is urging the government to either grant an exemption from the Metropolitan Waste Levy, reclassify Shoalhaven into the Regional Levy Area, or undertake an urgent review and publicly provide the evidence supporting the region's continued inclusion in the metropolitan levy zone. The council's own estimate is that Shoalhaven residents contribute around $5.6 million annually through the waste levy, equating to approximately $93 per household each year (Shoalhaven City Council, 9 October 2026).

The mayor's release says independent reviews have repeatedly questioned that decision. We read the two it points to. They say more than the release does, and the official answers to both are on the record.

The waste levy per tonne in 2026-27, from 1 July 2026

General rate, before the EPA's concessional rates for particular materials

Metropolitan Levy Area, including Shoalhaven

$180.20

A tonne. The rate Shoalhaven is in.

Regional Levy Area

$103.80

A tonne. The rate the mayor has asked for, as one of three options.

Rates as published by the EPA, which says they rose by the Consumer Price Index from 2025-26 (EPA, levy regulated area and levy rates). The gap is $76.40 a tonne, our arithmetic.

Where the line falls

The levy is meant to cost something. The Auditor-General's 2020 report puts its purpose plainly: The purpose of the waste levy is to act as an incentive for waste generators to reduce, re-use or recycle waste by increasing the cost of sending waste to landfill. It is paid by waste facility operators when waste is sent to landfill (Audit Office of NSW, 26 November 2020). The council's release says it operates its own landfill.

The council's complaint is about where the line falls. Going north, Kiama, Shellharbour and Wollongong pay the same metropolitan rate. Going south, Eurobodalla and Bega Valley are on neither of the EPA's lists. Inland, Wollondilly and the Blue Mountains, both closer to Sydney, are in the Regional Levy Area, while Wingecarribee is metropolitan (EPA). Trucking waste south does not dodge it: the EPA says The waste levy also applies to waste from the MLA or RLA that is received in any other area of NSW. Its rate table charges metropolitan waste the metropolitan rate wherever it is received.

The coast from Wollongong to the border, by waste levy area

Coastal councils, north to south, as the EPA lists and maps them

  1. WollongongMetropolitan Levy Area
  2. ShellharbourMetropolitan Levy Area
  3. KiamaMetropolitan Levy Area
  4. ShoalhavenMetropolitan Levy Area: $180.20 a tonne in 2026-27
  5. The levy area ends here
  6. EurobodallaNot on either list. Non-levied area on the EPA's map
  7. Bega ValleyNot on either list
From the EPA's lists of Metropolitan and Regional Levy Area councils, read 9 October 2026, and its levy area map dated 29 February 2024, on which the area ends at Shoalhaven's southern boundary (EPA lists, EPA map). The map's frame stops in Eurobodalla, so Bega Valley's entry rests on the lists alone.

Asked in 2018 and 2020, and noted

In March 2018 a Legislative Council committee inquiring into energy from waste looked at exactly this. It recorded the council's evidence that it pays the higher rate while councils closer to Sydney pay the regional one, and that Eurobodalla, Shoalhaven's nearest neighbour, is outside the regulated area and pays no levy at all. It also recorded that The NSW EPA was unable to advise why the Shoalhaven was considered part of the MLA. The committee's own comment was that Shoalhaven appears to have been arbitrarily assigned to the Metropolitan Levy Area, and then: The committee can see no justification for this. (Portfolio Committee No. 6, Report 7, paragraphs 2.35 to 2.38).

The government's response was tabled on 18 September 2018. Against recommendation 3, the response column carries one word and nothing beneath it (NSW Government response, page 1).

Recommendation 3, and the answer

The committee, March 2018

That the NSW Government reclassify Shoalhaven City Council from the Metropolitan Levy Area to either the Regional Levy Area or the unregulated area.

NSW Government response, September 2018

Noted.

Recommendation: Report 7, page 20. Response: government response, printed page 1, where the row for recommendation 3 has no further text.

Two years later the Auditor-General came at the same question from the other end, across the whole state. The report found that decisions about which councils pay, and at which rate, were made in 2009 and potential changes were considered but not implemented in 2014, and that Currently, there are no objective and transparent criteria for determining which LGAs pay the levy. The EPA told the audit the 2009 changes were based on projected population growth, waste generation and disposal trends, the ability of ratepayers to pay and possible waste flows between levied and non-levied areas. The report does not name Shoalhaven (Audit Office of NSW, section 2.1).

Its first recommendation asked the EPA to set a review schedule that included transparent and objective criteria for determining which local government areas are levied, by June 2021. The response from the planning department and the EPA marked it Noted, and said The setting of the waste levy is a matter for Government. It added that levy settings would be explored as part of a 20-year waste strategy then being developed (Appendix one, page 25).

How the line has been looked at, by the dates the documents give

  1. 12009. Decisions on which councils are levied, and at which rate (Audit Office).
  2. 22012. A review of the levy recommends extending it to more of the state, to remove inconsistencies (Audit Office).
  3. 32014. The EPA consults councils on extending the levy. Coverage is not changed (Audit Office).
  4. 428 March 2018. The committee recommends moving Shoalhaven out of the Metropolitan Levy Area.
  5. 518 September 2018. Government response tabled: Noted.
  6. 626 November 2020. The Auditor-General finds no objective and transparent criteria. The response: Noted.
  7. 79 October 2026. The council says the mayor has written to the minister. The EPA's list still has Shoalhaven in the Metropolitan Levy Area.
Steps 1 to 3 and 6 from the Audit Office report and its appendix; 4 and 5 from the committee report and the government response; 7 from the council release and the EPA list. We have not traced what happened between 2020 and 2026.

Checking the council's sums

The council's figures are its own estimates, and the release does not show how they were made. One of them can be checked from the EPA's rates. The release says that if Shoalhaven were reclassified to the Regional Levy Area, local households could collectively save an estimated $2.37 million every year. Charge the same tonnes at $103.80 instead of $180.20 and the bill falls by 42.4 per cent; 42.4 per cent of $5.6 million is $2.37 million. The council's saving is what this year's two rates give, on the assumption that nothing else changes.

The council's estimate at the regional rate, our arithmetic

2026-27TotalHousehold
Metropolitan rate (council estimate)$5.6m$93
Regional rate, same tonnes (ours)$3.23m$54
Difference (ours)$2.37m$39
The first row is the council's estimate (release, 9 October 2026). Per household means the council's $93. The other rows scale both by $103.80 over $180.20, the EPA's 2026-27 rates (EPA), and are rounded. They assume the same tonnes go to landfill, which a lower levy is not designed to encourage.

Two cautions. The levy is a price meant to change behaviour, so a lower rate is also a weaker push away from landfill, and the council's sum assumes the tonnes stay put. And the 2018 report records the council saying that in the previous financial year it paid a levy of almost $8 million, with $340,000 returned in grants (Report 7, paragraph 2.42). The release's figure is what residents contribute; the 2018 figure is what the council said it paid. They may not measure the same thing, and we would not set the two side by side.

Our view

This is opinion, built on the documents above. On the question the mayor has actually asked, the council has the better of the record. A parliamentary committee looked at Shoalhaven by name, heard that the EPA could not say why it was in the metropolitan area, and could see no justification. The Auditor-General found there were no objective and transparent criteria for any council's placement. Both times the official answer was Noted. Eight years on, a ratepayer in Nowra is still entitled to ask which of the 2009 factors put the Shoalhaven alongside Sydney while Wollondilly sits in the regional band, and the government should publish that answer. A one-word response to a parliamentary recommendation is not a reason.

Readers further south should notice something the release does not say. The anomaly can be removed two ways. Moving Shoalhaven down to the regional rate is one. Bringing Eurobodalla and Bega Valley into a levy area is the other, and the 2012 review the Auditor-General cites recommended extending the levy to more of the state to remove inconsistencies. Shoalhaven's case is strongest as a demand for criteria, published and applied evenly down the coast. Criteria are what both reviews asked for, and published criteria serve Berry and Bega alike.

Methodology

We read the council's release of 9 October 2026, the EPA's levy area and rates page (read 9 October 2026) and its levy area map (dated 29 February 2024), Report 7 of the Legislative Council's Portfolio Committee No. 6 (tabled 28 March 2018), the NSW Government response (tabled 18 September 2018), and the Audit Office of NSW's report of 26 November 2020 with its appendix of agency responses. The government response and the appendix are scanned PDFs with no text layer; the words quoted from them were read by eye on the pages named, and every other quotation is checked against saved copies of the sources. On the EPA's page the Metropolitan Levy Area heading spans the first two columns of its council list; the map shows the same placements. The EPA's historical rate table shows the metropolitan rate at $107.80 and the regional rate at $53.70 in 2013-14, a gap of $54.10 a tonne, against $76.40 in 2026-27 (our subtraction). The 42.4 per cent is 76.40 divided by 180.20; $5.6 million times 103.80 over 180.20 is about $3.23 million, and $93 on the same basis is about $54. The council's two figures imply roughly 60,000 households ($5.6 million divided by $93, our arithmetic); the release does not say how it counted them. We have not seen the mayor's letter, the council's workings, or any document on the levy areas published between the 2020 audit and 9 October 2026, and we have not put questions to the council, the EPA or the minister for this piece.