Regional Waste Co-ordinator,
Southern Region Waste Management Office,
Limerick City & County Council,
Lissanalta House,
Dooradoyle,
Co. Limerick.

29^th January, 2015.

 

RE:  Draft Waste Management Plan for the Southern Region

 

Dear Sir/Madam,

Although I am a public representative, I am also an environmental engineer.  I assessed my first waste management plan in the early 1990s.  I completed my Master’s thesis on the potential for centralised biogas in Ireland in 1996.  My subsequent professional career majored in the sustainable management of wastes of all types and in particular the management of sludges and slurries.

I read the draft Waste Management Plan for the Southern Region with anticipation that it would pave the way for the concepts we espoused twenty years ago but which, largely because of organisational deficiencies, undeveloped markets and government indifference, had never taken off the ground.  I am, however, bitterly disappointed.

In those twenty years, kerbside collection has been privatised and enhanced, recycling rates have risen significantly and waste to landfill has reduced.  Those advances are to be welcomed but they were solely in response to European requirements for Ireland’s handling of society’s by-products which was dramatically behind the curve.

None of the principles introduced in the draft Waste Management Plan for the Southern Region is new.  The concept of waste being a resource is age-old.  The circular economy is a long-held dream, one unlikely to see reality in a capitalist society set up for short-term financial reward.  In this Plan, I see primarily a governmental drive towards the introduction of domestic privately-run incineration as a fail-safe measure at all costs, whilst dismissing the vast millions invested by the State into the development of engineered landfill sites which will now never be operated.

I want to see Irish waste management move on.  I want to see a radical shift in our patterns of resource consumption.  I want to see commitment to a zero waste society and clearly defined targets as to how resource consumption will be decoupled from economic growth.  Prevention of waste is at the top of the waste hierarchy.  One of the principal policies in the Plan relates to prevention.  But yet the Plan has a general acceptance that waste per capita will increase significantly to 2030.  What sort of commitment to waste prevention is this?  Would the Plan’s policy towards domestic incineration be achieved if the consented capacity in engineered landfill sites were all made available without imposition of a landfill levy?  Of course it would not!  And similarly, no real policies towards decoupling waste generation from economic growth will be successful if there is tacit assumption that waste generation rates will continue to increase in an environment with generous domestic incinerator capacity.

The circular economy concept will never become a reality in isolation from the zero waste concept.  This is singularly absent from the draft Waste Management Plan for the Southern Region.  This is, of course, because it is absent from government policy.  Eliminating waste calls for intimate involvement with industry and government.  Industry has control over product and packaging design, manufacturing and materials.  Government has the ability to assist industry to make those necessary changes, either with legislation or with grant support.  Government can make real changes in the way we handle waste which will genuinely see materials return to the source from whence they came.  But both industry and government are singularly absent from the draft Waste Management Plan for the Southern Region.

 

Prevention

• The draft Waste Management Plan has a stated acceptance that economic recovery will lead to an increase in waste generation.  This is not acceptable, nor does it have to be the case.  This is planning to fail.  Other countries have planned to succeed by committing to a zero waste approach.  I ask that a zero waste approach be committed to within the Waste Management Plan for the Southern Region.

• It is essential that future strategic targets are measurable and I welcome this comment in the Plan.  However, I do not agree that the strategic targets should focus on broader waste streams.  For a comprehensive understanding of waste generation and destination, we need to analyse the waste stream in the greatest detail possible.

• There is an inherent contradiction in that whilst the Plan commits to having targets measurable, it also has a stated intention to measure the municipal stream rather than the household waste stream.  Yet one of the principal waste reduction targets of the draft Plan relates to household waste which the Plan intends not to measure.  I ask that all targets towards waste reduction are measurable and therefore that the household and commercial waste streams will be analysed separately, rather than as a commingled municipal stream.

• The focus on resource consumption is good but it is not followed through in the Plan with an adequate focus on a shift in attitude or practice.

• It is good that any sort of a target towards waste prevention is being proffered, but the target of 1% reduction per annum in household waste generated is too low.  Over 30% of household waste is biodegradable.  The EPA advises us that at least 60% of this is avoidable.  Were we to eliminate even 30% of biodegradable household waste, we would be achieving a reduction target greater than that espoused in the Plan.  I ask for the adoption of a target of 10% reduction in household waste generated over the lifetime of the Plan.

• With respect, Policy B1 is a nonsense.  Local authorities cannot provide resources that they do not have.  Even if they wanted to take additional staff on board to assist communities in prevention activities, they cannot.  The government embargo on public service appointments means that they would struggle to replace an Environment Education Officer, let alone employ additional staff.  Only central government can ensure that Policy B1 happens.  To pretend otherwise is simply to set the local authorities up to fail.  It is of course appropriate that they would give whatever they can to waste prevention, but real and effective waste prevention measures can only come with both policy and financial commitment from central government.

• The discussion on stakeholders does not mention reducing waste at source by changing industrial practices.  Why are consumers always asked to buy products with less packaging when often they have no choice?  Options for consumers need to be tackled through the producer.  I ask that the Regional Waste Management Plan would demonstrate a real commitment to waste prevention by introducing real and targeted measures towards working with the EPA and industry to, at a minimum, change product presentation at source.

• I ask that the Regional Waste Management Plan would, as a policy target, work with government to introduce a tax on disposable products such as polystyrene and plastic drinks cups, paper and plastic plates, plastic cutlery, etc.  Products such as these have reusable alternatives.  In this regard, it would be an appropriate juncture for all ten local authorities contributing to the Southern Region’s Plan to commit to eliminating the use of such disposable commodities within local authority buildings.

 

Reuse 

• Other countries have established what they describe as “goods rehoming facilities” at civic amenity sites.  These remove goods from the recycling and residual waste streams that are of reasonable quality and may be desired for reuse by others.  They are cleaned and are displayed in a covered area.  In some cases, a small charge is placed on recovered goods.  In others, the goods are available free of charge.  Some civic amenity sites add value to the recovered goods so that they are of higher worth.  I ask that the Regional Waste Management Plan would commit to piloting goods rehoming facilities at a number of the busier civic amenity sites.  It is essential that the goods are available for perusal whenever the civic amenity site is open so that it can essentially become viewed as the equivalent of a second-hand shop.  Such an initiative would help to achieve the Plan’s stated aim of adding value to the waste stream and, if successful, could contribute in a small way towards the operational cost of the civic amenity sites.

 

Recycling

• The Plan is very clear that the residual waste exported for treatment is a wasted resource.  But it does not mention at all the recyclable waste exported for reprocessing because of the complete lack of facilities to deal with it in Ireland.  This is a far greater loss of resource which is not even quantified in the Plan.  I ask that the Regional Waste Management Plan would identify and quantify the individual recyclable streams that are going abroad for reprocessing, that it would identify the countries these recyclable streams are destined for and that it would quantify the lost resources that these material streams represent.

• We know how successful our kerbside collection of recyclables is because the volume of material collected is measurable.  However, we have no idea how the kerbside collection is performing in terms of material quality.  Are the correct materials being put into the recycling bin?  Is there contamination of materials?  Are there materials being separated for recycling for which there is currently no market?  I would like to see quality of collected recyclables being discussed in the Plan.  It may be that it is necessary to introduce a system of source separation to improve the quality of material collected.  I ask that the Waste Management Plan for the Southern Region would discuss the quality of recyclable material gathered by kerbside collection and that it would identify the volume of recyclable material collected but lost to residual waste because of contamination.  If this information is not available, it should be and its collation should therefore be a policy target of the Regional Waste Management Plan.

• Home composting is not mentioned in the Plan.  In the past, home composting was a recommendation of many waste management plans and there are still a considerable number of households in the Region operating their own composting unit.  I ask that the Regional Waste Management Plan would commit to supporting home composting and that it would discuss how those who are currently practising this sustainable system of domestic waste management will continue to be supported in the context of widespread introduction of SI No. 71 of 2013 affecting food waste collection.

• I ask that the Regional Waste Management Plans would commit to the introduction of deposit-refund schemes for, in particular, aluminium cans and plastic drinks bottles.  This is packaging which regularly litters our streets because the products it contains are generally bought in one-off purchases.  Reducing litter cleans up our environment and frees up local authority resources towards other prevention targets.  In addition, a deposit-refund scheme for targeted materials such as aluminium and PET has been proven in other countries to massively increase their recapture for recycling.

• Targets towards anaerobic digestion are welcomed but there is no real sense of enthusiasm in the Plan for biological waste treatment equivalent to that for incineration with energy recovery.  Biological waste treatment in the form of centralised biogas and in-vessel composting is well advanced in other countries.  Despite many on-the-ground attempts by private operators and enthusiasts, it has never taken off in Ireland.  The Plan gives a strong acknowledgement of the need for energy support pricing to make incineration viable and profitable.  Why does it not give the same support to the pricing of energy from centralised biogas?  In the case of centralised biogas, it may be more efficient to use gas directly rather than to use it for electricity generation.  But this would also be a renewable product, equally deserving of support and as yet unacknowledged in Ireland.  I ask that the Regional Waste Management Plan would have a stated policy of working with government towards obtaining realistic financial supports for the energy products of anaerobic digestion/centralised biogas and that these financial supports would be commensurate with the elevated position of biological treatment on the waste hierarchy.

• The Plan makes no mention of the on-the-ground problems which have continually stymied large scale biological waste treatment in this country.  In particular, it does not address the issue of markets for compost or digestate.  Without addressing such issues as these, biological treatment of either biowaste or agriwaste will struggle to advance.  It is imperative that the Plan would identify and address all the issues which to date have impeded the successful take-off of large scale biological waste treatment in Ireland.

• I ask that the Plan would prioritise the implementation of SI 71 of 2013 on household food waste and biowaste and that it would include stated policy to investigate the use of surplus edible foods currently discarded as waste.

 

Recovery 

• The clear ethos of national policy for waste management – as reflected in this draft Waste Management Plan for the Southern Region – is to provide adequate domestic capacity for incineration to replace landfill.  The implementation section of the Plan places more strategic focus on this than on any other aspect of our future intentions for waste management.  Moreover, the implementation section of the draft Plan addresses incineration with energy recovery as a policy measure even before it states policies for recycling, biological treatment and other aspects of waste management far further up the waste hierarchy.  To prioritise the development of incineration recovery infrastructure before the development of infrastructure to facilitate actions further up the waste hierarchy lays out a retrograde and unsustainable future for waste management in Ireland.

• The draft Plan spends considerable energy in describing potential future uncertainty in incineration capacity in the EU markets.  This may indeed be the case for the future, although it is currently not.  It may equally be the case with future foreign capacity to accept Ireland’s sorted recyclable materials also, but the draft Plan does not develop this potential issue.  The waste projections and subsequent argument contained in the draft Plan for an additional national capacity of 300,000 tonnes in incineration with energy recovery is not convincing.  The waste projections are made in the absence of a genuine all-society change of mindset towards a circular economy.  There will be no real achievements in waste reduction should the draft Plan’s stated targets towards incineration be achieved.

• If Ireland is to reach its EU obligations to recycling 50% of municipal waste by 2020 and 70% by 2030, it will be relying on an increase in waste generation to ensure it can maintain a residual waste stream to ensure a continued supply of feedstock to fill domestic incineration capacity.  Ireland will therefore be relying on continued generation of residual waste; this is a position utterly at odds with the circular economy, commitments towards waste prevention and the EU’s waste hierarchy.

• Incineration with energy recovery can operate efficiently only when the feedstock has a relatively high calorific value.  This can be achieved only with a relatively high proportion of plastics and other potentially recyclable materials in the waste stream.  There is little incentive for the public to commit to sustainable waste management if they learn that their carefully sorted dry recyclables are being burned rather than replacing a global demand for virgin materials.  I ask that the Regional Waste Management Plan would commit to ensuring that all separated recyclables would be sent for recycling rather than for incineration either with or without energy recovery.

• Adequate capacity for recovery through incineration with energy recovery already exists in the Meath and Dublin plants.  I ask that the Regional Waste Management Plan would commit to the provision of no further capacity for incineration with energy recovery until firstly, real waste prevention targets are achieved and, secondly, infrastructure to facilitate management of waste further up the waste hierarchy is already in place.

• I ask that the Regional Waste Management Plan would commit to a tax on incineration, with or without energy recovery.  This tax would reflect the position of incineration with or without energy recovery at the lower echelons of the waste hierarchy.  The amount of the tax can be reduced to reflect the energy recovery efficiency of the plant to which the waste is sent.  All waste destined for incineration should be taxed, regardless of whether the incineration plant is in Ireland or abroad.

• Policies E15 and E16 are clearly lifted out of the Connaught-Ulster Regional Waste Management Plan; the consultants forgot to change the reference to the CUR.  It is clear that it is a national plan to introduce incineration to Ireland and that these two policies have been inserted into all of the Regional Waste Management Plans.  This is an uninspired and unsustainable approach to replacing Ireland’s traditional reliance on landfill.

 

Local authority as stakeholders

• Clearly the ten local authorities are expected to drive this Waste Management Plan for the Southern Region forward on the ground.  Equally clearly, responsibility for any failure in this regard will be assigned to them.

• This is largely unjust.  Local authorities are hamstrung without increased resources.  As an example, Cork County Council has constructed 11 state of the art civic amenity sites around the county.  Several years ago, the County Council could not sustain their running and introduced increased gate fees including the imposition of a charge on recycling.  This correlated with an increase in dumping.   It is now so expensive to dump a mattress at a civic amenity site in County Cork that it is little wonder so many are found in ditches and inside farm gates.  Consequently a significant percentage of Cork County Council’s annual environmental is spent on street cleaning.  This year, despite the gate fees, Cork County Council finds it still cannot sustain the cost of running the civic amenity sites and is now reducing opening hours for those in more rural areas.  These are the very areas which are frequently not served by kerbside collectors.  This reduction in availability of civic amenity sites will of course further increase the dumping problem.  Again, the amount of clean-up the County Council can do is limited.  South Cork, with a population of over 211,000, has but one litter warden.  Courtesy of the government’s ongoing recruitment embargo, no further appointments can be made.  The government must commit to delivering policy, practicality and finance in supporting the waste management activities of local authorities.  In this regard, the government is as large a stakeholder in this Waste Management Plan as are the local authorities.

• The Plan’s aim towards improved communication between the local authorities is welcome, particularly with regard to co-ordinating resources, information and the establishment of facilities.

• The Plan’s aim for local authorities to provide improved guidance on siting waste management facilities is also welcome.  This is ideally achieved through the County Development Plan.  Cork County Council most recently attempted to do this in the drafting of its County Development Plan 2014 when it directed large waste management facilities to Strategic Employment Areas.  The Minister for the Environment, Community and Local Government took exception to this, saying that Cork County Council was creating an unfair bias against incineration.  He issued a Section 31 Direction to revoke the relevant section of the County Development Plan and to replace it with his own wording which singled out incineration for favour.  The Minister clearly failed to understand the intent of the objectives of the County Development Plan and attempted to undermine Cork County Council’s attempt to provide improved guidance on siting.  Education of the Minister is imperative if this aim of the Regional Waste Management Plan is to be achieved.

• The Plan suggests that local authorities should address the growing trend to export residual waste?  Permitted or registered waste facilities are obliged to identify the destination of wastes they handle but it is not within the power of the local authority to instruct where those residual wastes should go.  The transfrontier shipment office ensures that the export of waste is responsible and documented.  Deciding whether waste should or should not go abroad is a commercial decision that could potentially affect the viability of the operator and is well outside the remit of local authorities.

 

The Southern Region’s solid waste stream arises largely from household, commercial, industrial and agricultural sources.  Yet this draft Plan sets targets only for household and municipal waste.  Where are the quantifications and targets for wastes from other sources?  I asked Ms Phillipa King in the Council Chamber whether wastes from industrial sources were addressed in the draft Plan.  I was advised that they were not, because industrial wastes were largely looked after by the EPA.

If there is no co-ordination between the SRWMO and the EPA on industrial waste arisings, their trends and management then the SRWMO and the EPA are replicating the type of individualistic behavior exhibited by local authorities with regard to waste planning over the past decades.  Industrial waste is a significant proportion of the Region’s overall waste stream and it is imperative that it would be addressed in this Waste Management Plan.

Of course solid wastes are only a diminutive percentage of overall waste arisings in the Region.  Sludge waste arisings from wastewater treatment and agricultural slurries are mentioned in the Plan but are clearly not its focus.  But this document describes itself as being a Waste Management Plan.  It is not a Solid Waste Management Plan, nor a Municipal Solid Waste Management Plan.  If it is what its title claims, then it must address all waste arisings in the Region with equal intent: their quantification, current management methodologies and it must develop policies for their responsible handling and, where necessary, treatment.

As this Plan is clearly driven from central government and its higher echelon appointees, I do not expect my comments to be given more than cursory attention.  However, I should be grateful if even some were taken on board.

Yours faithfully,
Marcia D’Alton.