WASTE WORKING GROUP

C/O Earthwatch & VOICE,

7 Upr., Camden St., Dublin 2.

Ph: 01 - 4785140

To: The Connaught Regional Authority

Re: Submission on the Draft Waste Management Plan for the Connaught Region, 2000.

Date : 31^st May 2000.

Author: Anne-Marie Cunningham

The Waste Working Group is a coalition of environmental NGOs including VOICE (of Irish Concern for the Environment) and Earthwatch – Friends of the Earth Ireland.

Index

Notes

Within the body of this submission,

• The Draft Connaught Regional Waste Management Plan is referred to as "the Plan",
• The Connaught Regional Authority is referred to as "the authority".
• "recovery" means material recovery unless otherwise specified and "disposal" refers to both incineration/thermal treatment and landfill, for reasons discussed later.

Executive Summary

The stated aim of the Draft Waste Management Plan for the Connaught region is to maximise diversion of waste from landfill. In order to achieve this aim, the authority proposes to introduce a system incorporating recycling, incineration and thermal treatment. In the year 2013, the plan proposes to incinerate and landfill 62.4% of municipal and industrial waste generated in the region and to recycle the remainder.

It is the submission of the Waste Working Group that the Connaught Plan fails to provide a sustainable solution to the waste problems of the region.

In particular,

• The plan is not based on the principles of sustainable development and therefore defers the waste problem of the region rather than endeavoring to solve it.

• The plan relies heavily on end-of-pipe disposal mechanisms in the form of landfill and incineration.

• The plan is 100% focused on reactive measures to deal with waste after it is produced.
• In the year 2013 more municipal waste will be incinerated than recycled, which is an inversion of the EU Waste Hierarchy.
• The plan is not in line with government policy as it does not incorporate targets for stabilisation and reduction of waste generated in the region and presupposes a substantial increase in waste generation over the plan period.

• A plan of action in relation to waste reduction at source has not been comprehensively developed.

• The plan does not outline the delivery mechanisms by which the recycling targets set will be achieved.

• The plan ignores options essential to a sustainable waste-resource management plan, such as reuse, repair and home composting.

• The targets set for material recovery and composting are low compared to what has been achieved internationally in the same and shorter time periods. No information is given in the plan as to what is meant by "maximum realistic" recycling.

• Despite stating maximising diversion from landfill as its primary aim, the plan envisages landfill at 71% of current levels.
• 47,816 tonnes of incinerator ash is unaccounted for in the plan. The most likely route for this residue to take is disposal to landfill which would reduce the diversion from landfill rate substantially.

• The introduction of incineration to the region would have serious negative environmental, social and economic repercussions for the region. The threats that incinerators pose to human and environmental health have been well documented. In addition incinerators are in direct contravention to a waste plan based on the principles of sustainable development as incinerators serve as ‘black holes’ for vast amounts of potentially recoverable resources and recreate the ‘out-of- sight, out-of-mind’ approach evident with landfill. If the authority chooses to introduce incineration to the region, they are deferring the waste problem rather than attempting to solve it. Also as incinerators require a steady amount of waste for efficient operation, such a measure will negatively impact on development of recycling and other material recovery initiatives within the region and restricts the choice of further options.

It is the submission of the Waste Working Group that, it is not necessary to introduce incineration to satisfy national policy requirements, incineration is the most unviable option in economic terms and energy can be recovered in greater quantities by means which are more conducive to sustainable development.

The Waste Working Group recommends that the plan is rejected and that a strategy is developed which is based on the principles of sustainable development. It is proposed that the authority investigates the numerous reduction and material recovery schemes that have been successfully implemented internationally, many of which have been outlined in this submissions. It should also be remembered that these countries have experienced and overcome similar if not the same, waste problems that the Connaught region and Ireland as a whole is now facing, without the introduction of environmentally and socially detrimental technologies.

A plan based on the principles of sustainable development would promote resource conservation and stimulate the local economy as well as continuously reducing the amount of waste going to landfill. The focus of the Connaught plan must shift from options designed to ‘get rid of rubbish’ to processes that will prevent wastage and conserve natural resources. To achieve this the plan must be focused on the upper and middle sections of the EU Waste Hierarchy whereby anything that cannot be prevented or minimised should be reused, repaired, recycled or composted. Therefore the plan must aim to create the conditions whereby these favoured options "outcompete" the disposal options such as landfill and incineration. The plan must create a situation where source reduction and material recovery outcompete landfill. By doing this, the mindset that views positive reduction and recovery schemes as an expensive add on to landfill will be inverted. Landfill must become that add on to a resource recovery process.

Only when such a strategy has been researched and developed will the authority be equipped to make an informed decision on the way forward for the Connaught region.

1. Introduction

The Plan’s "approach towards waste management over the Plan period will focus on reducing Connaught’s current dependence on landfill disposal and moving towards an integrated approach which will include new waste collection and treatment methods". (Section 8.1)

As environmentally sound management of wastes is among the environmental issues of major concern in maintaining the quality of the Earth’s environment and especially in achieving environmentally sound and sustainable development, the primary function of this waste management plan should be to lay the groundwork for a truly sustainable waste management/ resource conservation and recovery system in the region. However, this plan does not do this and hence defers the waste problem of the region rather than attempting to solve it. Therefore this submission is introduced by a brief discussion of the necessity of developing a waste plan based on the principles of sustainable development.

2. Waste Management in the context of Sustainable Development.

This section highlights the importance of considering the effects that a particular waste management plan will have on the development of sustainable societies and why waste 'management' must become synonymous with resource management and conservation.

Sustainable development is most commonly described as development that meets the needs of the present without compromising the ability of future generations to meet their own needs. Sustainable development thus aims to improve the quality of human life whilst living within our ecological means.

From the viewpoint of sustainable development waste generation and its associated problems cannot be decoupled from resource depletion. This is clarified by consideration of our current system of resource use, which follows a predominately linear pattern.

i.e. Resources ® product ® disposal

Resources are extracted, used to manufacture a product that is bought by a consumer and subsequently thrown away. On the right hand side of this equation the rapidly increasing amounts of waste generated have reached critical levels. In fact, industrial development and its associated waste products has accelerated at a rate far surpassing the adaptive capacity of natural systems and if wastes continue to be produced at current or increased volumes, then any 'management' system will eventually become overwhelmed.

On the other side of the equation, the rapid depletion of the Earth's natural resources is endangering the supply for future generations. Global calculations show that humans are consuming over one third more than nature can reproduce. Of course, for industrialised countries this rate is even higher.

Inequitable Use of Global Resources

The following extract from the ‘UK House of Commons Environment, Transport and Regional Affairs Committee Report on Sustainable Waste Management’ illustrates the urgency of addressing our current resource consumption patterns.

‘At present 20% of the world’s population use 80% of the world’s resources: the other 80% - the population of the developing world – uses only 20% of these resources. Such inequity cannot continue. Traditionally it has been believed that as the less developed world developed, it would use more and more resources and that the world’s supply of resources would expand to accommodate that; any shortage of raw materials would either stimulate the search for new supplies or encourage the use of alternatives. Now, we are having to face the fact that such a level of resource use would push the world way beyond what is sustainable; so that either the developing world has to be held back or the developed world has to find ways to sustain current standards of living while using far fewer resources; maybe as little as 10% of the resources we use now.

Such a revolution in resource use, and possible reuse is the real driving force behind today’s needs for the developed world to take waste minimisation and sustainable development seriously.’

There is clearly an imbalance between our current development patterns and the natural capacity of the Earth's systems to adapt to the over consumption of resources and to absorb waste at its current rate of production. The following points further illustrate this,

· Researchers in the Netherlands found that the country would have to be 14 times larger to supply all the resources, water and energy used by Dutch consumers and absorb all the waste produced by Dutch citizens.

· Research has also shown that if all the world were to live as a North American or Canadian, 2 more planet Earths would be needed to sustain everyone, 3 more still if population should double and 12 Earths altogether if worldwide standards of living should double over the next 40 years.

· Studies conducted in the US show that for every 100 pounds of product manufactured, at least 3,200 pounds of waste is created. Only 6% of the materials we extract each year from the Earth becomes durable goods; the other 94% is converted into waste within a few months of being extracted.

When waste management is considered in the context of sustainable development, it is apparent that a change in attitude towards waste is necessary. A shift from waste "management" (i.e. what are we going to do with our rubbish) to resource conservation (i.e. how are we going to prevent wastage and conserve natural resources) is essential.

The focus has for too long been on what will be done with waste once it is produced i.e. end of pipe solutions. For sustainable development, the closing of the material loop must be achieved, i.e. turning our present linear use of resources into a cyclical one.

To ‘close the material loop’ there needs to be an incremental reduction in the amount of virgin resources feeding into the production chain coupled with a continuous decrease in waste produced. This is shown diagramatically in Figure 1 below.

Figure 1: ‘Closing the Material Loop’- The sustainable approach to waste – resource management

The EU Waste Management Hierarchy, which lists waste management options in order of preference, aims to promote sustainable waste systems. According to this hierarchy prevention and minimisation of waste are the most favourable option, that is it prioritises the stabilisation and subsequent reduction of waste generation. Anything that cannot be prevented or minimised should be reused, repaired, recycled or composted. Energy recovery and landfill are the least favourable options.

The aim therefore is to generate waste plans that are firmly focused on the upper and middle parts of this hierarchy. This would further the development of cyclical production and consumption patterns and thus the advancement of closed loop processes. Unlike options such as landfill or incineration, recycling and reuse result in material being returned to the production process, where it can be made into the same or similar product from which the material arose, or it can be fashioned into something entirely different. This means that for the economy as a whole there is a reduced need for primary extraction, hence resources are saved and there is a reduction in the environmental effects from the production, processing and transport of the raw material, which also results in considerable economic savings. Recovery of energy from waste may appear to have a similar effect, yet on closer examination it becomes evident that this is not the case. Recovering energy from waste by incineration (thermal treatment, waste-to-energy or any of its other acronyms) can only recover the energy contained within the actual material and of course this can only be recovered once. The energy used up in the extraction of resources, transport etc. cannot be recovered. Conversely this energy can be saved by methods such as reuse and recycling. Although with many substances recycling cannot occur indefinitely (for example, due to shortening of fibers in newsprint recycling), recycling can usually take place more than once. There is, therefore, an element of circularity in the recycling process that is absent in the case of incineration and landfill. Also, as mentioned above, sustainable development requires a reduction in raw material usage. Incineration effectively results in these materials ‘going up in smoke’. It is for these reasons that both landfill and incineration are referred to as linear waste management options. It is also for these reasons that within the body of this submission "recovery" is used to denote material recovery mechanisms and does not refer to energy recovery unless otherwise stated.

3. Analysis of the Waste Policy for the Region

The plan considers three scenarios by which to achieve its aim of maximum diversion from landfill.

The three scenarios considered are,

1. Achieve maximum realistic recycling,

2. Achieve national and EU targets by recycling and thermal treatment,

3. Achieve maximum landfill diversion through fastest possible implementation of recycling and thermal treatment.

(Section 9.2 of the Plan)

• Scenario 3 is the one chosen by the authority as the way forward for the region.

However, as will be shown in this submission, this scenario cannot provide a sustainable solution in relation to waste-resource management for the region.

• On examination of the three scenarios, it is clear that two are essentially the same and that a limited range of options is put forward for consideration.

Each scenario covers management of waste generated at household, commercial and industrial enterprises as well as from construction and demolition activities.

Table 1. Various categories of waste shown as a percentage of the total non-agricultural waste arising in the Region.

Construction and demolition waste is the single largest category of waste arising in the region. While it is recognised that the plan proposes to recycle a high percentage of this waste stream, 79.8% (Table 12.3 of the Plan), it should be noted that the Government’s target for recycling of this waste stream is 85% to be reached over the time period of this plan.

The plan should be altered to ensure that this target is met.

The remainder of this submission will focus on the remaining largest non-agricultural waste streams, municipal and industrial waste. Table 2 below shows the targets set by the authority in relation to these waste streams, to be reached over a fifteen-year period.

Table 2. The recycling and disposal methods proposed by the authority for municipal and industrial waste generated in the Region in 2013.

• It is clear from the above table that the waste management hierarchy is not being respected, that is, it is in the year 2013, more municipal and industrial waste is being incinerated than recycled which is an inversion of the EU Waste Hierarchy.

• In the year 2013, 43% of industrial waste is still going straight to landfill.

• On analysis of the waste management policy for the region it is clear that the plan is firmly focused on the lower end of the waste management hierarchy and thus cannot provide a sustainable waste-resource management plan for the region. Figure 2 below shows that the waste management methods that the authority proposes to employ for municipal and industrial waste generated in the region in the year 2013.

Figure 2. Targets set by the Connaught Regional Authority for the recycling, incineration and landfill of municipal and industrial waste generated in 2013.

The proposed scenario concentrates 62.4% of effort on how to dispose of waste and 100% effort on reactive measures to deal with waste after it has been created.

• Table 12.3 of the plan indicates that 2.7% of municipal and 43.8% of industrial waste will be landfilled in 2013. However, this is the primary route which waste generated will take, that is, waste which has not been recycled or incinerated going directly to landfill. Table 12.3 of the plan, does not allow for ‘secondary’ waste that is generated by processes such as incineration.

This information is given in Table 12.2 of the plan, which indicates that 142,045 tonnes of waste generated in the region will go to landfill in the year 2013.

According to the plan, in 1998 there were a total of 15 landfills in the region with a combined annual waste input of approximately 200,000 tonnes (Section 6.2).

Therefore a 29% reduction in current waste quantities going to landfill will be achieved over the time period of the plan. As the plan designates maximising diversion from landfill as its primary objective, this is quite a small percentage.

• Also the Waste Working Group questions the tonnage for residual waste from incineration given in Table 12.2 as 7,356 tonnes/annum.

According to the Draft Waste Management Plan for the North-East Region, burning waste reduces its mass to 30% of the original. Using this percentage the quantity of incinerator residue that will be produced may be calculated as shown in Table 3 below.

Table 3. Calculation of the tonnage of residual waste produced by the incineration process in the Region in 2013.

It is clear from Table 3 that 47,816 tonnes of residual waste from the incineration process is unaccounted for in the plan.

The most likely route for this waste stream to take is for it to be disposed of at landfill.

This would increase the total amount of waste going to landfill in 2013 to 182,505 tonnes and the reduction in waste landfilled would be a mere 8.7%.

It is evident that incineration can not eradicate the need for landfill. Aside from a continued dependence on landfill, incineration will have detrimental environmental, social and economic repercussions for the region. The Waste Working Group is firmly opposed to the introduction of incineration to the region, the reasons for which are outlined in the Section 3.1 of this submission.

3.1 Incineration - the wrong solution for the Connaught Region

The Waste Working Group is firmly opposed to the introduction of incineration to the region for the reasons outlined below.

1. It has been illustrated above that incineration does not eradicate the need for landfill.

2. Incineration will effectively increase the amount of potentially hazardous waste generated in the region.

Section 8.3.5 of the plan, states that the end products of the incineration process are "a sterile inorganic residue" and Section 7.1 states that the process will "render residues relatively inert". However the process may render residues inert biologically but not chemically. In fact the bottom ash produced by the incineration process contains toxins which have been converted from a state less liable to leach - unburnt waste - into a form which is more liable to leach. According to a recent EEA report, a common factor for all incineration plants is that the residues are highly contaminated and in most cases are classified as hazardous waste. Unless treated further the pollutants are also very soluble and the waste is therefore difficult to store in landfills.

Also the remedial technology that may be fitted to the incinerator to capture some of the toxic emissions from the smoke concentrates these toxics in the ash. Ironically, this means that the better the air pollution control, the more toxic the incinerator residue.

3. Incineration is an end-of- pipe waste management option akin to landfill.

An explanation of why incineration is a linear waste management option and how the energy recovery option can mask this is provided in Section 2 of this submission.

4. Incineration – Waste to Energy or a Waste of Energy?

Far more energy is actually saved by recycling materials than burning them due to the fact that significantly more energy is required to produce virgin materials than to recycle. It has been estimated that for every tonne of ‘product’ we buy, ten tonnes of resources have been used in the manufacturing process. Reuse and recycling have a far better energy recovery record, with savings of up to 70-90% despite energy lost in transport and cleaning compared to an expected efficiency of 25% recovery from incineration .

This fact is reiterated by the a recent report by the European Commission, which asserts that in general recycling is preferable to incineration in energy terms.

• Recycling aluminum cans in the United States in 1996 saved enough energy to power a city the size of Philadelphia for one year.
• Germany has 53 incinerators burning 14 million tonnes of waste per annum. The burning of this massive amount of waste produces 0.5% of German energy requirements. The incineration of every single atom of waste produced in Germany would provide 1.5% of all German energy requirements.

4. Incineration has a negative impact on source reduction and material recovery schemes and is in direct contravention to resource conservation. It also restricts the development of contingency plans and choice of future options.

Incineration plants require a steady supply of waste for efficient operation. Operators typically require contracts with local authorities to supply them with a minimum amount of waste to burn over protracted periods, such as 25-30 years. Such contracts obviously remove the motivation to prevent or reduce waste and restrict the choice of future options. Therefore incineration is in direct contravention to a plan based on prevention, minimisation and reduction as the onus is on the local authority to ensure enough waste is produced rather than reduced.

There is no guarantee that wastes that cannot be reduced, reused or recycled will not go to an incinerator.

According to the EPA’s handbook on waste prevention, potentially more than two thirds of municipal waste can be reused or recycled and according to a waste composition study in the UK, over 40% of waste is recyclable and 30 – 40% can be composted. The UK study also illustrated that the quantities that cannot be reused, recycled or composted are so small that they in effect rule out incineration as an economically viable option. It also notes that in the longer term, we should be designing away the last 20%, i.e. making all waste 100% recyclable or compostable.

However in the year 2013, 52.7 % of municipal waste will be incinerated.

Clearly waste that is recoverable will be going to incineration in 2013.

5. Incineration is detrimental to environmental and human health.

A number of negative environmental effects associated with incineration are given below.

• According to the Swedish Environmental Protection Agency, during waste incineration, pollutants are released both into the air and water from wet scrubbers as well as via the slag and flue gas cleaning residues formed during incineration. These pollutants include particulates, hydrogen chloride, PAHs, dioxins and other organo chlorines plus mercury and other metals.

• Incinerators act as synthesizers. Therefore other toxic substances, originally not present within the waste stream, will be produced as a result of the combustion process. At temperatures ranging from 400 to 1600° C, complex organic molecules break down into basic atoms. However as the combustion gas cools on its way up the chimney and out the stack, some atoms recombine to form new and often more hazardous compounds. These chemical recombinations or ‘products of incomplete combustion’ (PICs) can be even more toxic than the original combusted waste. Dioxins and furans are the most hazardous of these types of substances.

• Dioxin is the collective name for numerous toxic chlorinated compounds that are undesirable by-products of the combustion process and chlorine industry.

Dioxins are persistent organic pollutants and bioaccumulate in the food chain.

The Irish Doctors Environmental Association (IDEA) issued the following statement in November 1999,

" the Irish Doctor’s Environmental Association strongly opposes the plans for a waste incinerator in Kilcock as it does for other proposed sites throughout the country. Our concerns relate to the adverse health effects from toxic substances in the emissions, which being mainly fat soluble, accumulate in body tissues and are concentrated up the food chain, eventually being absorbed by humans through consumption of, for example, cow’s milk, meat, fish, eggs and subsequently passed to the foetus in a higher concentration. Possible ill-effects include altered immune responses and disordered endocrine effects such as decreased fertility, lowered IQ and cancer".

The US EPA considers dioxin a carcinogen for which there is no safe level of exposure.

A recent study performed by the USEPA in relation to dioxin shows that dioxins are considerably more toxic than previously thought. This report is still in draft form and cannot be referenced at present. However, the following article from the Washington Post highlights the growing concerns about this family of chemicals.

Draft US EPA report on dioxin (cited in The Washington Post )

"The Clinton administration is preparing to dramatically raise its estimate of health threats from dioxin, citing new evidence of cancer risk from exposure to the toxic chemical compound.

A draft of a long-awaited report by the Environmental Protection Agency concludes for the first time that dioxin is a "human carcinogen." The report notes that emissions of dioxin have plummeted from their peak levels in the 1970s but still may pose a significant cancer threat to some people who ingest the chemical through foods in a normal diet. For a small segment of the population who eat large amounts of fatty foods, such as meats and dairy products that are relatively high in dioxins, the odds of developing cancer could be as high as 1 in 100, the report says. That estimate places the risk 10 times as high as the EPA’s previous projections.

The report, obtained by The Washington Post, links low-grade exposure to dioxin to a wide array of other health problems, including changes in hormone levels as well as developmental defects in babies and children. It also concludes that children’s dioxin intake is proportionally much higher than adults’ because of the presence of the chemical in dairy products and even breast milk.

"It’s the Darth Vader of toxic chemicals because it affects so many systems [of the body]," said Richard Clapp, a cancer epidemiologist at Boston University’s School of Public Health. "The amounts are coming down, but even small amounts are harmful."

The EPA’s draft assessment, if finalised in its current form, would solidify dioxin’s status as one of the most potent chemical toxins known to science.

Environmentalists, extrapolating from the EPA’s risk findings, have estimated that about 100 of the roughly 1,400 cancer deaths occurring daily in the United States are attributable to dioxin.

For the first time, the agency’s draft report classifies the most potent form of dioxin--2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)--as a "human carcinogen," a step above the previous ranking of "probable carcinogen."

More than 100 other dioxin-like compounds were classified as "likely" human carcinogens.’

• The Dutch National Institute of Public Health and Environmental Protection estimates that waste incinerators can be held responsible for over 80% of all dioxin emissions into the air in the Netherlands.

• Many toxic substances emitted from municipal waste incinerators, including certain dioxins and furans, cadmium, lead and mercury, are known to disrupt the endocrine system (the body’s hormonal system). The effects of endocrine disruptors on wildlife have been shown to include thyroid dysfunction in birds and fish, decreased fertility in birds, fish, shellfish and mammals, metabolic abnormalities in birds, fish and mammals, behavioural abnormalities in birds, fish and mammals, demasculisation and feminisation of male fish, defeminisation and masculinisation of female birds and fish and compromised immune systems in birds and mammals.

• A recent report for the European Commission suggested that for every tonne of municipal waste burnt between GBP£21 and GBP £126 worth of environmental and health damage is caused

• Another health problem associated with incineration is the particularly fine particulates that they produce. A major study found that there is a much stronger statistical link between fine particulates and mortality rates from lung cancer and cardiopulmonary diseases than any of the other major forms of pollution measured (eg. Carbon Monoxide and Sulphur Dioxide). The total health damages due to chronic effects of primary and secondary particulates alone, from a single 400,000 tonne/year incinerator, is estimated to cost up to 48,000,000 ECU/year.

• The later two examples highlight the ‘hidden costs’ associated with incineration and the real costs of this technology should be incorporated into the economic assessment of the chosen scenario.

According a recent UNED Conference on Environment and Development, 1992, appropriate solid waste disposal technologies should be developed on the basis of health risk assessment.

In light of the well documented adverse effects of incineration, it is recommended that the authority invokes the Precautionary Principle in this regard and rejects the proposal to introduce incineration to the region.

The Precautionary Principle

According to the Wingspread Statement on the Precautionary Principle, "when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public should bear the burden of proof. The process of applying the precautionary principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action."

The principle of precautionary action has 4 parts, 3 of which are,

1. people have a duty to take anticipatory action to prevent harm,

2. the burden of proof of harmlessness of a new technology, process, activity or chemical lies with the proponents, not with the general public,

3. Before using a new technology, process or chemical, or starting a new activity, people have an obligation to examine "a full range of alternatives" including the alternative of doing nothing.

• An additional negative environmental impact of incineration is its global warming implications. A recent report issued by the USEPA showed that reduction at source and recycling make a major contribution to lowering greenhouse gas emissions and burning waste in an average waste-to-energy plant causes higher greenhouse gas emissions than disposal to landfill.

6. Incineration poses a threat to the Farming Based Economy of the Region.

The toxic emissions from an incineration plant will threaten the potential for exploiting the considerable price advantage and high demand in EU markets for clean, green food produce.

Ireland has the lowest dioxin levels in cow’s milk in Europe, and with the possible exception of New Zealand, the world. This gives Irish dairy produce a considerable competitive advantage in the European market.

The introduction of incineration to the region comes at a time when the rest of Europe plans to phase out their use. The following quote from an article recently published in The Guardian newspaper, in response to the British Government’s proposal to introduce a number of new incinerators, highlights this fact.

Europe plans to phase out incineration.

The following is an abstract from a recently published article in The Guardian newspaper:

‘Europe is moving to phase out the building of huge incinerators just as Britain is planning a new chain across the country as part of the government's waste strategy, Ludwig Kraemer, head of the EU waste management directorate, revealed last night.

"In France, Belgium, Holland, Italy, Germany and Portugal no more new incinerators are being built because the public will not stand for them.

"They are treated in the same way as nuclear power stations - people no longer want them," he said.’

Although thermal treatment plant are often referred to as "state of the art" facilities, operating to high standards, it has been shown that levels of emissions achieved under laboratory conditions or even in a commercial incinerator being inspected by prior arrangement by a regulatory authority are likely to be far lower than those routinely emitted during normal operations. This was demonstrated in the US in 1990 when a joint task force of the EPA and the Occupational Safety and Health Administration conducted 62 unannounced inspections at 29 waste incinerators. No less than 69% of the inspections resulted in citations for violations.

Also, no matter how "state-of-the-art" or "safe" an incineration plant may be, it still has no place in a sustainable waste management system as it effectively serves as a ‘black hole’ for a vast amount of resources and is not conducive to closing the material loop. Vast amounts of time and money are focused on trying to perfect the destruction of discarded resources, thus deferring the real solution which is how to recover them. Also, it has been pointed out that contracts are usually required with the incineration operators, guaranteeing waste for a certain time period. This obviously inhibits the development of a contingency plan for the region, which could prove problematic should the incinerator be closed for reasons such as a breech of its license. Also the Government’s policy document recommends the development of recovery facilities that are environmentally beneficial and it is has been shown that incineration has detrimental environmental consequences.

It is therefore recommended that the authority rejects the proposed scenario and develops a new scenario that is beneficial in terms of environmental protection and is conducive to sustainable development.

3.2 Source Reduction

The authority has not set targets for waste reduction at source and has not developed a plan of action in this regard.

None of the three proposed scenarios allow for the proactive source reduction options. The plan refers to waste minimisation as the most favourable option in relation to waste management yet this is not transferred into action in the plan.

Section 8.1 of the plan states that the "Connaught local authorities shall ensure that the policies, objections and targets outlined in the DOELG document ‘Waste Management – Changing our Ways’ are incorporated in the Connaught Waste Management Plan and implemented. Adoption of the Connaught Waste Management Plan will ensure that these government policies are met in the Connaught context’.

However this is not the case as the above mentioned policy document states that "a major general objective is to stabilise, and in the longer-term reverse, the growth in waste generation". A quantifiable target for this is set out in Sustainable Development: A Strategy for Ireland, where it is stated that a "major goal is to stabilise municipal waste arisings generally at 350kg/year per capita, and in the longer term, to 2010, to reduce these wastes by 20%".

It is clear from Table 3 below that a considerable increase in municipal waste generation will occur over the time period of the plan.

Table 3. Percentage increase in municipal waste generation over the plan period.

(Calculation performed on the basis of data presented in Table 3.1 and 12.3 of the plan)

Figure 3 below illustrates the effect that the chosen scenario will have in relation to the targets set in Ireland’s strategy for sustainable development.

Figure 3. Growth in municipal waste generation in the Connaught region over the plan time period, shown in relation to targets for stabilisation and reduction of municipal waste generation as stipulated in Sustainable Development: A Strategy for Ireland.

The plan has made no attempt to curb and in the longer term, reduce municipal waste

generation in the region and is therefore in contravention of Government policy.

Prevention and minimisation are both source reduction options. The prevention of waste is the single most important initiative towards achieving sustainable waste management. Taking a preventative approach involves acting at source. For example, prevention requires changes in processes and products - designing non-toxic products from materials that can be safely recycled or composted - in order to avoid the generation of waste that is disposed. It also therefore benefits natural resource conservation. It encourages the exploration of safer alternatives and the development of clean and sustainable products and technologies.

Waste prevention also benefits the producers of products as it represents a viable opportunity to achieve savings in terms of the costs of raw materials, energy, disposal and recovery.

However none of the three scenarios proposed by the authority include the option of waste reduction at source. The waste prevention and minimisation policy of the authority is focused on awareness raising in the various sectors. Whilst it is recognised that education will plan a critical role in the effective implementation of the plan, stronger actions need to be taken to curb the rapidly increasing growth of waste in the region.

According to a recent UN Conference on Environment and Development, a preventative waste management approach focused on changes in lifestyles and production and consumption patterns offers the best chance for reversing current trends.

It is therefore recommended that the authorities set a target for waste prevention and minimisation in line with that in the sustainable development strategy for Ireland.

According to the World Resources Institute, John Stutz of the Tellus Institute outlined a three-part structure for Setting waste prevention targets: - choose the material stream, the method of measuring prevention from the stream and the goal and time when it will be achieved. Stutz is working with both the OECD and US EPA to develop methods to quantify waste prevention and source reduction. As a measure of waste prevention for OECD, he proposed the use of a percentage of the waste available for prevention. Using this measure, targets could be set as a percent of progress for a particular year.

In relation to industrial and commercial sectors the authority can act by,

• Making waste prevention and minimisation an integral part of the industrial licensing process for activities within their functional area. These licenses could include targets for waste prevention and minimisation.

• Ensuring that all producers of waste are aware of their obligations under the 1996 Waste Management Act, which states that anyone who "carries on an activity of an agricultural, commercial or industrial nature (including the manufacture of any product)" must " take all reasonable steps as, are necessary for the purposes of prevention or minimisation (including, where appropriate, steps as respects the design of any product aforesaid)" (Section 28(2)). Contravention of this is an offence under subsection 6.

It is important to remember that producers are usually in the best position, technically and economically, to influence the rest of the product chain in reducing life-cycle environmental impacts and to ultimately close the material loop.

• In relation to construction and demolition waste, Kilkenny Council is considering the inclusion of a condition in planning permissions for all major development proposals requiring the developer to submit a construction waste management report prior to commencement of activity. It is recommended that the Council investigates this and also considers its application to other activities.

In relation to domestic waste, one of the many effective approaches approach taken internationally is the one used by the metropolitan area of Melbourne, Australia.

A domestic waste hierarchy was outlined, as follows:

· Consumption reduction

· Product re-use; and

· Material recycling

For this strategy, priority was placed on exhausting waste prevention and reuse opportunities ahead of recycling programs.

An overall waste reduction goal for a 65% reduction in domestic waste doing to disposal, over a ten year period, was set. This included a 10% waste prevention target.

They plan to achieve this by urging the public to:

· Reduce consumption of luxury and throw away items,

· Choose unpackaged and minimally packaged products; and

· Choose low toxicity products (such as cleaning agents).

The First Annual Waste Reduction plan for London emphasises the need to move away from a sole reliance on increasing recycling and composting as the solution to waste problems. The idea behind the plan is that by both reducing the amount of waste generated in the first place and recycling and composting as much as possible of what is produced, the tide can be turned and dramatic cuts in amounts requiring disposal can be achieved. This document sets out an overall strategy for waste reduction at source and lists immediate actions that will start to make a difference.

It is recommended that the authority investigates such waste reduction plans with a view to developing one for the Region.

3.3 Material Recovery and Composting

The targets set by the authority for recycling of municipal and industrial waste are low when compared with what has been achieved internationally. Also the authority has not detailed the delivery mechanisms by which the recycling targets will be achieved. The importance of reuse and repair as essential elements of a sustainable waste plan is highlighted.

There are numerous examples of reduction, reuse and recycling strategies implemented internationally, that have far exceeded the recovery and diversion targets set by the authority and in shorter time periods.

Examples of these include,

• The municipality of Dilbeek, in Belgium reduced its quantity of household waste by more than 60% within six months in 1996. The average amount of household waste generated fell from 495 kg/capita in 1995 to 304 kg/capita in 1996. With such an impressive reduction, the municipality saved about 2 million EURO in 1996 and 1997.

• The Quinte area in eastern Ontario (population 95,000), diverted an average of 68% of household waste from disposal over a seven year period starting in 1989. This was achieved by the implementation of a comprehensive system that combined recycling, home composting, reduction, reuse and financial incentives. Over this period the total cost of waste management and recycling - including disposal - dropped by 39%.

• The town of Bellusco, Italy (population 6,000) has achieved 73% diversion from landfill by use of drop-off facilities and a kerbside collection of paper and green waste.

• Novia Scotia, Canada (population 950,000) had over 100 landfills in the province until 1995 when new laws pertaining to the landfilling of waste were introduced. The province has gone from a recovery rate of approximately 8% to 51% in the five year period without building incinerators and 600 jobs were created in the process.

• Examples of successful recovery programmes in the UK include, Daventree (population 80,000) which went from less that 10% recovery rate to 46% in 26 months and 11 Essex districts that have set a 60% recovery rate by 2007. These have also been highlighted as examples of how learning from international experience has speeded up the recovery process considerably.

• A combination of a comprehensive recycling and composting scheme, coupled with charges for each sack or bin of refuse have helped Sidney Township, Ontario to reduce the amount of household waste going to disposal by 69% over a seven year period between 1989 and 1986. All refuse presented for collection must have an attached tag, the price of which covers the cost of refuse collection and tipping. A waste management by-law is in place which identifies material not allowed in the refuse, including household hazardous waste, recyclable material and garden waste. There is no charge for the use of the recycling bin, household hazardous waste depot or garden waste drop-off depot. The municipality collects untagged sacks or bins separately and the generator of the refuse is identified in 70% of cases. The generator is contacted and requested to come to the municipal office to reclaim their refuse. The by-law allows for fines up to $25,000 but this has never had to be pursued. It was also found that as long as opportunities for recycling and composting are widely available, the public will accept User Pay.

• Guelph, Ontario (population 100,000) has reached a 58% diversion rate (67% diversion of wet waste and 51% of dry waste) of household waste using a wet/dry collection system.

Also the proposed scenario does not include a provision for home composting. International experience has shown that home composting has proven to play an valuable role in successful waste management systems, particularly for regions with a large rural population which is the case in the Region. For example the municipality of S. Giustina in Colle, Italy achieved a reduction in organic waste presented for collection of 71% of the original municipal organic waste by home composting alone.

The plan contains no strategy for material recovery by means of reuse and repair.

If the authority ignores these viable options, it is disregarding an important part of a sustainable waste management system and a method to divert substantial amounts of waste away from landfill.

Reuse – a key element of a sustainable waste plan

Reuse includes those waste reduction practices in which household products and packaging are reused again as products or packaging. It is distinguished from materials recycling, in which a product is broken down to its materials and these materials are recycled. The simpler processing involved in product re-use places it above material recycling in the hierarchy.

The following examples illustrate the effectiveness of reuse and repair.

• The "Genbrugsfabrikken" (Recycling Factory) in Risskov, Denmark started as a small scale repair centre for bicycles, furniture etc. It now provides a free collection of all household items from households in the Aarhus city region.

• A USA electricity unit in Connecticut collected old refrigerators from households, free, as a means of reducing electricity use. As a result of removing 13,600 refrigerators from its 1.2 million customer area in eight months,

- an estimated 14 million kW-h was saved (enough to power 2300 homes);

- 1200 tons of scrap metal was recovered for recycling;

- 23,150 cubic yards of landfill area was saved; and

- 45 full and part-time jobs, with a payroll of US$500 000, were created.

This case study, which saved both electricity and waste, demonstrates the opportunities for partnership approaches.

• The Digital Computer Centre has a Resource Recovery Centre in Contoocook, New Hampshire, USA. The centre receives all returned trade in digital equipment. The equipment is either refurbished, spare parts are recovered or materials are recovered and recycled. The facility processes over 14,000 tonnes of computer equipment each year of which only 1% is landfilled.

These last two examples should be useful to the authority in light of the pending Waste from Electrical and Electronic Equipment (WEEE) Directive.

3.3.1 Market Development for Recyclables

The necessity of market creation for recycled products is acknowledged in Section 10.4 of the plan. To tackle this the authority proposes to adapt their purchasing policy in favour of recycled products and ensure that the Industrial Waste Management Officer conducts research into areas such as existing markets. While these are necessary steps in ensuring an expanded market for recyclables, further action that the authority can take includes,

• encouraging manufacturers in the region to adopt a minimum content policy for the use of recycled material (could be included in licenses),
• promoting "Buy Recycled" initiatives in the region,
• providing a forum for information exchange and technical assistance,
• providing information on recycling contractors in the region, thereby promoting local industry
• promoting establishment of new material recovery facilities in the region, and
• involving themselves in negotiating contracts which will provide stability for these new local businesses and also guaranteeing a supply from each local authority themselves. In relation to paper the authority can encourage local and regional newspapers to use a minimum recycled paper content in their newspapers, thereby developing an environmentally responsible image for the paper and guaranteeing a market for recycled paper.

The authority could also consider the experiences of the state of California, USA and Canberra, Australia.

• California has strict landfill diversion targets and to help local governments meet these targets California designated certain areas as Recycling Market Development Zones (RMDZs). The purpose of these was to offer special incentives to manufacturers who use recycled feedstocks in order to expand the markets for recovered materials. An annual award scheme - the Waste Prevention, Recycling and Market Development and Grant Program - is available to non-profit and not-for-profit entities in San Francisco County. There are over 18,000 people employed in waste reduction and recycling related industries throughout the state.
• The city of Canberra, Australia has a target to reach zero waste by the year 2010. According to their policy statement, the development of Resource Recovery Estates dedicated to separating, reprocessing and value adding materials, will help solve many disposal problems and provide employment opportunities. Also a Resource Exchange Network will be established to match the unwanted outputs from one process with the needs for resources in other activities. This Network will promote markets for recovered products, provide a central database of all available materials and indicate their potential reuses.

4. Alternative Scenarios

It is recommended that the authority consider a scenario that is not suggested in the plan - one which combines source reduction, reuse, repair, recycling and composting together with financial and economic incentives. The development of such a scenario is essential for informed decision making.

It has been shown that all three scenarios proposed by the plan are focused on the lower end of the waste hierarchy and therefore cannot provide the basis for a plan that is conducive to sustainable development. International experience has shown that it is more than impossible to meet and indeed surpass the targets set out by National Policy, by positive ways which are conducive to environmental protection, sustainable development and the development of the local economy.

It is therefore recommended that the authority considers a new scenario, one which combines waste reduction at source with reuse, repair, recycling together with financial incentives. Only when such a strategy has been researched and developed will the authority be equipped to make an informed decision on the way forward for the region.

For example, the official waste policy of Canberra Australia is to create a waste free society by 2010. This policy of turning all waste into resources – or zero waste – has also been embraced by New Zealand. Here, twenty two district and city councils have joined a national pilot project originally designed for ten, committing to reduce waste to zero by 2015.

At a conference launching this project Warren Snow, from the Zero Waste New Zealand Trust, stated that, "councils can see that reducing waste to zero is no longer a theoretical exercise. Most of the processes already exist and we have more than enough case studies of community based recycling and waste reduction projects achieving dramatic results" Canberra has already reached a 60% diversion rate from landfill without the use of incineration.

These and other progressive examples of sustainable waste-resource management have been outlined through out this submission and it is recommended that the authority actively researches these and examines their transferability to the Connaught region as a prerequisite to action. It has also been shown that these options are not only the most beneficial in environmental terms but are also the more economically viable options.

Also the plan indicates that it is for a time period of 5 years. However all targets set out in the plan are to be achieved over a fifteen-year period. It is recommended that the plan set out clearly what targets, studies etc. that it will perform over the five-year period of the plan.

It is recognised that no matter what route the authority takes, the need for landfill will not be eradicated in the time period of this plan. However, it is the contention of the Waste Working Group, that the sustainable options outlined within this submission offer the most efficient and safest way of diverting waste from landfill, without the use of incineration.

It is also recommended that the authority consider the concept of resource storage in landfill rather than disposing mixed waste. At present we cannot control what comes out of landfill, but we can control what goes in. The concept of storage in landfill has been adopted within the Canberra region, Australia. Their No Waste by 2010 Strategy Report states

" landfills need to be managed as sites that can be mined to recover the buried resources. Materials that are now unable to be reused could be stored safely for future recovery when new technologies become available. An example of this is storage of tyres in a trench at West Belconnen. Once viable tyre recycling technology is developed, these tyres can be recovered at minimal cost."

Dr. P. Connett also advocates that material that is deemed safe to bury be first compacted into blocks to minimise landfill space used and then studied by students at technological colleges who would research design changes to avoid this fraction in the future.

It is also imperative that priority is given to the removal of the organic fraction designated for landfill disposal. This immediately solves many of the problems traditionally associated with this disposal method, such as leachate and odour, as what is left is essentially a dry, inert landfill.

5. Waste-Resource Management at a National Level

It is acknowledged that progress towards a sustainable waste management/ resource conservation and recovery system would be greatly facilitated by programmes orchestrated on a national level. The Waste Working Group recognises that the authority has significant lobbying potential with respect to national government and recommends that the authority presses for legislative and economic initiatives which would greatly facilitate a waste-resource management system within the region.

These initiatives could include,

• Development of a National Waste Management Plan. The Waste Working Group feels that a national waste management plan would further the environmental performance of the industrial sector. At present, the main focus in the regional and local waste management plans is on municipal waste, leaving prevention, minimisation and recovery in the industrial sector to be determined by the conditions set out in their IPC licences. Industrial waste is the main component of non-recoverable waste generated in Ireland. Therefore strong incentives need to come from central government to facilitate prevention, minimisation and recovery within companies that fall outside the jurisdiction of the EPA.

• The introduction of effective legislative and economic tools which will facilitate the ‘closing of the material loop’. For example, the full implementation of the EU Packaging Waste Directive. In tandem with this, extension of producer responsibility obligations to other priority waste streams will greatly facilitate the ‘closing of the material loop’ by developing markets for secondary products and materials and developing cleaner products, for example. The introduction of the recent End of Life Vehicles Directive and the forthcoming Waste from Electronic and Electrical Equipment will aid the expansion of producer responsibility obligations in Ireland. Producer Responsibility is merely an extension of the polluter pays principle. Currently the cost of waste is borne by local authorities and the taxpayer, but the producer has ultimate choice over choice of materials and product design.

• The introduction of Minimum-Content Standards. Manufacturers need to help "close the loop" by using the materials collected in local recycling programs to manufacture new products. For example, if newspapers had a mandatory recycled paper content, this would have a significant positive effect on market development for recycled paper.

• Provision of financial assistance, support and research grants to commercial firms engaging in recycling, in the production of recyclable goods or products, or in waste elimination.

• The introduction of deposit – refund schemes on beverage containers.

• The government can encourage source reduction in the form of tax incentives. Instead of giving incentives for wasting, we should give tax credits and economic incentives for reducing waste and utilising recovered materials.

6. Conclusions and Recommendations

It is recommended that the authority reject the scenario proposed by the plan on the basis that,

• The targets stipulated in the Government’s policy document are not met,
• The plan is not conducive to sustainable development,
• The plan endorses a continued reliance on end-of-pipe disposal solutions.

• The plan proposes to introduce a technology that will have detrimental environmental, social and economic effects.
• A full range of alternative options has not been provided.
• Certain essential components of a sustainable waste management plan, such as reuse, repair and home composting, have not been included.
• In effect, the plan proposes to divert a relatively small percentage of waste from landfill.

To correct the situation it is recommended that the authority,

• Researches the many excellent strategies that are in place internationally, a number of which are outlined in this submission, with a view to their transferability to the region.
• Dedicates time and resources to the development of a waste reduction plan for the region, and
• develops a new scenario, one which combines waste reduction at source with reuse, repair, recycling and composting together with financial incentives.

The plan should also include comprehensive delivery mechanisms for targets set and a real and democratic public consultation exercise should be fully conducted before a decision is made on the way forward for the Connaught region.

Bibliography

Canberra Zero Waste Policy, (URL: www.act.gov.au/nowaste/wastestrategy/)

Colborn, T. & Clement, C.(1992) Chemically induced Alterations in Sexual and Functional Development: The Wildlife /Human Connection, Advances in Modern Environmental Toxicology, Vol. XXXI.

Connett, P.&E. (1994), Municipal Waste Incineration, The Ecologist, Vol 24, No.1, January/ February.

Connett, P. (1999), Waste Management for the Twenty First Century, St. Lawrence University, New York

Connett, P., Alternatives to Incinerating Trash, St Lawerence University, New York.

Earth Summit (1992), UN Conference on Environment and Development, Rio.

Earthwatch (1997), Local Authority Waste Management Policy suggestions.

EC DGXI, (1998), Draft comission proposal for a Directive on the incineration of waste, cited in Material

Recovery.

Ecologika, 88 Albion Drive, London E8 4LY

Ecorecycle (1997), Waste Minimisation Strategy for Melbourne, (URL: www.ecorecycle.vic.gov.au)

Environment in the EU at the Turn of the Century, (1999) EEA.

ETSU (1996), Economic evaluation of the draft incineration Directive, European Commission.

Fehily Timoney & Co. (1999), Cork Proposed Waste Management Plan.

Fehily Timony & Company. (1999), County Kilkenny Proposed Waste Management Plan.

Friends of the Earth Europe (1999),Material Recovery

Friends of the Earth UK (1997), The Landfill Campaign Guide, Appendix 2.

Department of Foetal & Infant Toxico-Pathology, University of Liverpool.

Der Grüne Punkt (1998) Edition 3: Waste Incineration Processes in Germany.

Fehily Timoney & Co. (1999), Cork Proposed Waste Management Plan.

Fehily Timony & Co. (1999), County Kilkenny Proposed Waste Management Plan.

Fehily Timony & Co. (1998), South East Regional Authority Waste Management Strategy Study Draft Final Report.

Hawkin, P. Lovins,B., Hunter-Lovins,L. (1999), Natural Capital, Earthscan Publications, London.

Hencke, D. (2000), The Guardian, Friday May 19.

Kelleher, M. (1992), Recycling Household Waste – The Canadian Experience, Resource Integration Systems Limited, Toronto, Ontario.

MCOS (1999), Feasibility Study of Thermal Options for Waste Treatment / Recovery in the Mid West Region,

National Institute of Public Health and Environmental Protection, (1994) Emissions of Dioxins in the Netherlands.

National Waste Database Report (1998), EPA, Ireland.

Neirup, J., (1996), Recycling of Construction and Demolition Waste, Agency of Environment Protection, Denmark.

North East Region Draft Waste Management Plan (1999), MCOS & COWI.

The New England Journal of Medicine, (1993), An Association between Air Pollution and Mortality in Six US Cities.

Rachel's Environment & Heath weekly (1998), # 586.

Rachel’s Environment & Health Weekly (1998) #617, September 24.

Raniello, B., (1991) Recycling White Goods: A Win/Win Situation, Resource Recycling, August.

Recycling Works (1998), Friends of the Earth and the Community Recycling Network.

Re-Inventing Waste: Towards a London Waste Strategy (1998), cited in Material Evidence, (1999) Friends of the Earth Europe.

Review of Waste Management Strategy, European Commission, COM (96) 399, 30 July 1996.

Sustainable Development, (1997) A Strategy for Ireland, Department of the Environment and Local Government.

Swedish EPA, Report 4603, Summary Action Plan Waste.

Thorpe, B. (1999), Citizen’s Guide to Clean Production, Clean Production Network, USA.

Towards a Waste Reduction Plan for London (1999), M.E.L. Research Limited.

US EPA (1994), Health assessment document for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) and related compounds. Office of Health and Environmental Assessment, Office of Research and Development, Washington D.C.

Waste Management: Changing our Ways, (1998), Department of the Environment and Local Government.

Waste Prevention, Solving the Growing Waste Problem, EPA, Ireland.

Wates, J,(1994), The Non-Governmental Organization and The Management of Hazardous Waste In Ireland, Earthwatch, European Environmental Bureau.

The World Resources Institute (URL: www. wri.org )

The Worldwatch Institute http://www.worldwatch.org/alerts/981217.html

Zero Waste New Zealand Trust, (1999) Zero Waste Movement Hits Top Gear, Media Release, 13 December.