a metal and glass is calculated with the total of ‘others’ for convenience.

It can be seen from Table 2 that the expected retrieval rate for household waste in 2013 is 18,890 tonnes which equates to a 41% diversion. It can also be calculated that this diversion rate is expected to rise to 45% by 2017.

As the expected diversion rate is only 8% less than the target, a determined effort from the Council the 1,857 extra tonnes requiring diversion from landfill could be recycled or composted.

It is also the submission of the Waste Working Group that at present the Council cannot set a ceiling for ‘maximising’ recycling and composting. These processes have not yet been tried on any significant scale within the County so the ‘maximum’ rates cannot be definitively pre-empted.

4. National Target for Waste Reduction

National Policy 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% (280 kg/year per capita).

Using the data presented in Table 2.1, the population of Donegal can be projected to be approximately 137,722 in 2013. The ‘waste’ arisings for the same year are 46,000 tonnes. (This figure is the total amount of waste going to landfill and incineration in 2013 and does not include ‘waste’ recycled or composted as these are viewed as resource recovery options.) Therefore in 2013 MSW arisings amount to 0.334 tonnes/person per annum which equates to 334 kg/person per annum.

Therefore waste arisings in 2013 are 20% higher than the target set for 2010. For this target to be met the amount of waste arising in Donegal would have to be reduced to 38,562 tonnes, which requires a further 7,438 tonnes of material to be reduced at source, recycled or composted. It is mandatory for the Council to meet this target and the material recovery rates should be increased accordingly. This increase will also ensure that the National Target of 50% diversion of household waste from landfill will be met by sustainable methods.

2. The Incineration option

The plan states that ‘it is not possible to meet the targets without Waste to Energy, or another form of thermal treatment and a high level of recycling’ (Section 7.5.6).

This submission has already shown that this is not necessarily the case the Donegal plan as it stands proposes to meet the majority of targets (Section 1 ), and it is the submission of the Waste Working Group that a determined effort from the Council will ensure that all targets are met without the use of incineration. Also the recycling levels aspired to by the plan are not high compared to what has been achieved internationally and it would be hasty decision to introduce incineration based on a computer model when all the other sustainable options have not been tried on a large scale.

In addition the Waste Working Group is opposed to the introduction of incineration to the region for many reasons including those detailed below.

Incineration,

• contravenes the principles of sustainable development,
• does not eradicate the need for landfill and will effectively increase the amount of potentially hazardous waste generated in the region,
• is an end of pipe disposal mechanism akin to landfill, a fact which the energy recovery option can mask,
• has a negative impact on source reduction and material recovery schemes, thereby contravening resource conservation and also restricting the development of contingency plans and the choice of future options, and
• is detrimental to environmental health.

2.1 Incineration contravenes the principles of sustainable development.

Sustainable development is generally described as development that meets the needs of the present generation without jeopardising the needs of future generations, by living within the carrying capacity of the Earth. It is widely recognised that sustainable waste-resource management is essential for resource conservation, to encourage equitable sharing of resources and to ensure the sustainability of future generations. The current over-reliance on landfill is unsustainable as it entombs potentially recoverable resources and leaves an environmentally detrimental legacy to be dealt with by future generations. Incineration simply sends these resources ‘up in smoke’ and therefore wastes valuable materials.

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 is therefore to generate ‘waste’ plans that are firmly focused on the upper and middle sections of this hierarchy. This would further the development of cyclical production and consumption patterns and thus the advancement of ‘closed loop’ processes.

However the Donegal Waste Management Plan shows an evident bias towards disposal. In the year 2013, 52% of materials will be directed to incineration whereas 35% will be recovered. This is an inversion of the EU Waste Hierarchy. Diverting the majority of materials from landfill to a combination of incineration and landfill is clearly unsustainable and is one of the reasons that the Council should reject the strategy proposed by the plan.

2.2 Incineration does not eradicate the need for landfill and will effectively increase the amount of potentially hazardous waste generated in the region.

The general ‘rule-of-thumb’ for the amount of residual ash produced by an incinerator is that for every three tonnes of material incinerated, one tonne of ash is produced. The most likely mechanism for which to dispose of this ash is landfill.

According to a recent EEA report, a common factor for all incineration plants is that 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. The remedial technology that may be fitted to the incinerator to capture some of the toxic emissions from the smoke concentrates these toxins in the ash. Ironically this means that the better the air pollution control the more toxic the residue from the incinerator. The fly ash produced by the incineration process is hazardous and must be disposed of accordingly. The bottom ash also contains heavy metals which have been converted from a state less liable to leach (unburnt waste) into a form which is more liable to leach from landfill.

According to the Draft Waste Management Plan for the North-East Region, incinerating waste reduces its mass to 30% of the original. Using this figure it can be calculated that 11,100 tonnes of incinerator ash will arise in 2013, which is unaccounted for by the plan.

Section 4.8 of the plan states that the WTE process reduces the volume of waste to around 20-25% of the original volume. However this same section also states that one of the advantages of WTE is that it reduces the volume of waste for final disposal by about 90%. While these statements contradict one another, they are both misleading as they apply to uncompacted waste. Incineration ash typically occupies 40-50% of the landfill space that compacted unburnt waste would occupy. In various EU countries this ash is being used for various construction purposes. However this may lead to contamination of surrounding areas with dust containing heavy metals. Therefore this process simply disperses the source of pollution rather than the ash existing as a point source of pollution in landfill. This is reiterated by the recent incident in Newcastle, UK where ash had been spread over seven years on 27 allotment sites and bridleways at 14 other locations in the city. Tests showed that ash samples from some allotment sites had raised levels of dioxins and heavy metals. The relevant health authority issued advice that toddlers should not play on the allotments and that eggs, poultry and animal feed should not be eaten.

2.3 Incineration is an end of pipe disposal mechanism akin to landfill, a fact which the energy recovery option can mask.

It has been shown in Section 2.1 of this submission that landfill and incineration are a waste of resources and that sustainable development requires the development of ‘closed - loop’ processes whereby materials are returned to production processes, resulting in a reduced need for primary resource extraction.

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.

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.

The Donegal plan, proposes to redirect the vast majority of waste materials from one disposal mechanism to another, thereby failing to address the real issue which is how to maximise resource recovery.

2.4 Incineration has a negative impact on source reduction and material recovery schemes, thereby contravening resource conservation and also restricts the development of contingency plans and the choice of future options.

The plan states that the incineration option "has the potential to be very flexible once facilities are developed. Flexibility is likely to depend on specific partnering and/or contractual arrangements."(Section 7.5.5)

However, 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 and the success of waste reduction initiatives is limited by such contract rendering incineration inflexible by nature.

2.5 Incineration is detrimental to environmental and human health.

The plan states that " Recovering energy from waste will give rise to environmental benefits. This option will make an important contribution to achieving BPEO^*, although will need to be coupled with options further up the waste management hierarchy." (Section 7.5.5)

The Waste Working Group refutes the statement that incineration will give rise to environmental benefits for the reasons given below. It also questions the basis on which this statement was made. No environmental analysis is provided within the plan.

The negative environmental effects of incineration residue has been discussed in Section ?? of this submission. In tandem with this are the detrimental effects associated with the air pollutants emitted from the incineration process.

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

• 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".

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 relative costings of the options.

• 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.

2.6 Recommendation to exclude incineration from the Plan.

According to the UNED Conference on Environment and Development, 1992, appropriate solid waste disposal technologies should be developed on the basis of health risk assessment. The plan states highlights the importance of the precautionary principle and defines it as follows …" if there are threats of serious or irreversible damage lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation" (Section 3.3.4). In light of the well-documented adverse effects of incineration, it is recommended that the Council 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.

This section of the plan also highlights the principle of Intergenerational Equity and defines it as … "the present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations".

It has been shown in Section 2.1 of this submission that the introduction of incineration will contradict this principle as it encourages, and requires commitment to, inefficient resource use.

The plan states that "WTE has become a mainstream waste management option throughout Europe". However, 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".

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 Council rejects the any incineration proposal and concentrates on developing waste reduction programs, firmly focused on waste reduction at source and intensive recycling and composting, possibly in tandem with anaerobic digestion, for Donegal’s MSW stream.

3. Recommendations for increasing diversion from landfill rates in Donegal County, without the use of incineration.

The need to be ambitious is emphasised in the government’s policy statement "Changing our Ways", where it is stated that "Ireland has the opportunity to achieve a high level of performance, beyond basic compliance with national and EU legislation". According to the Irish EPA’s handbook on waste prevention, potentially more than two thirds of MSW can be reused or recycled at present. A waste composition study in the UK, showing a similar breakdown of MSW, showed over 40% of the waste stream is recyclable and 30 – 40% can be composted. This study stated 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. It is clear therefore that a large percentage of the MSW stream is potentially recyclable.

3.1 Obstacles to recycling highlighted in the Donegal plan

The plan states that "Donegal’s rural and isolated setting does not lend itself to high levels of recycling, due to factors such as distance to markets, low population density and relatively low tonnages" and also that "recycling will be a major challenge for Donegal given its relative peripherality from major secondary materials markets and processors" (Section 7.5.5).

Section 8.2.7 of the plan, states that "composted materials can be processed, marketed and sold locally, creating a ‘closed-loop’ for recycling". The relatively low tonnages and distances to markets should not be a problem in relation to dry recyclables as these can be stored at an MRF until such time as enough is available to make transport to a processor feasible. Small communities also have certain advantages when it comes to recycling and composting. There is often a stronger sense of community of such projects and for parish councils and village shops, recycling provides increased income. In the UK it has been estimated that a parish of 2,000 households would produce 1,100 tonnes of recyclables and organics a year, yielding an income from sales and saved costs of around UK£50,000, which is a significant amount for many rural areas. As the recycling industry is typically comprised of a conglomerate of smaller industries, as opposed to one large international incineration company, there is considerable potential for job creation from reuse and recycling in Donegal and the surrounding areas. Examples of successful recycling schemes in low-density areas are given further on in this section of the submission.

According to the 1997 Waste Management Planning Regulations, the plan should "outline the postion regarding markets for uses for recovered materials or products"

However the plan does not address the current position in relation to markets for dry recyclables. To develop a successful recycling plan it is necessary to assess current markets for recycled products and to plan for expansion of these outlets. It is recommended that the Council develops a plan of action in this regard and considers the experience of other countries when doing so.

The Council plans to change its procurement policies in favour of recycled materials in order to promote the development of markets. Suggestions as to how the Council can further encourage the development of markets for recyclable and recycled material in the region include,

• encouraging manufacturers in the region to adopt a minimum content policy for the use of recycled material,

• 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, for example, the authority could 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.

It is also recommended that the Council consider the following international examples and investigates the potential for developing such initiatives in association with other Counties.

• 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.

Recycling becomes economically viable when the overall cost of collecting and recycling a tonne of recyclables is less than disposing a tonne of waste. Cheap landfilling has often been referred to as the enemy of recycling. A condition where reuse and recycling outcompetes disposal must be created. The authority needs to invert the mindset that views material recovery as an expensive add-on to a disposal service and aim for a system where landfilling becomes the add-on to the material recovery process.

3.2 Donegal County Council as leaders

The Waste Working Group welcomes the fact that the Council has committed itself to a leadership role in the plan. The Councils actions in this regard are to develop an internal waste reduction strategy and to develop a green purchasing policy focused on stimulating markets for recycled materials. Whilst these are important contributions, it is recommended that the Council respects the waste hierarchy in this respect and places priority on waste reduction at source in all its programs including its own internal waste reduction plan.

3.3 Source Reduction

Waste reduction at source is the only waste management practice that is preventative as it minimises the creation of material and toxics. It is a proactive approach that reduces materials and energy use. In contrast recycling and composting are reactive measures to deal with waste after it has been produced. Source reduction should not be confused with "waste reduction" which is a broader term encompassing all waste-resource management methods, such as source reduction, recycling and composting, that result in a reduction of waste going to landfill or other disposal facilities such as incineration. As source reduction implies reducing the volume or toxicity of waste at its original source, the manufacturers of products have a major role to play in this process. National regulations are required to compel manufacturers to reduce waste at source. However there are many ways by which the Council can encourage source reduction at a commercial level in Donegal. Asides from seeking voluntary agreements from industry, the Council can provide support such as hotlines, workshops for targeted generators and resource information. They can also issue awards for source reduction in which would provide advertisement for and enhance the ‘green’ image of proactive businesses.

As the guidelines for establishing source reduction programs in local government institutions are similar to those for establishing commercial source reduction programs, the Council can use its own experiences when developing similar programs in the commercial and residential sectors of their communities. By implementing source reduction programs in its own offices and facilities, such as schools, parks and libraries, the Council can reduce its own waste while demonstrating commitment to such programs. An example of a source reduction practice would be to modify purchasing to discourage buying single use, disposable products and encourage purchasing multiple use, durable products and by leasing rather that buying, say electrical goods such as photocopiers.

While source reduction in industry can be very much as sector specific task, there are common areas that all sectors of commerce can adhere to. The first step in developing a source reduction program is to convince management of the benefits and engage their support. This could allow for the appointment of a reduction team or co-ordinator to explore options and develop a plan for the organisation. A plan could include the following components,

• buying in bulk,
• buying durable products and equipment,
• identify and incorporate alternative materials that are less toxic or less wasteful,
• identify sources of overpackaging and avoid or return the packaging in accordance with the 1997 Packaging Regulations,
• offer alternatives to disposables,
• indicate immediate and long-term costs and savings associated with each of the above.

Educating and providing incentives for employees to contribute towards achieving source reduction goals is another key to success. Regular feedback and evaluation, informing employees of successes, as well as areas for improvement and providing awards will also contribute. Many of the guidelines for establishing a source reduction program for businesses are similar to those for establishing a recycling program. Source reduction should however, always be given priority and other resource management methods applied to the reduced waste stream. The differences between the two waste management methods must be clearly defined.

3.4 Reuse

The plan contains no strategy for waste reduction by means of reuse and repair. If the Council ignores these viable options, it is disregarding an important part of a sustainable waste-resource 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 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.

3.5 Composting

Donegal is predominately rural and therefore the potential for the extensive practice of home composting is great. However the Council has set a target of supplying subsidised composters to 50% of householders in the region with gardens. It is recommended that the Council places greater emphasis on this cost-effective and sustainable waste reduction method and expands its target to include the majority of Donegal’s population. ‘Grass-cycling’ could be also promoted which could significantly reduce the amount of green waste presented for collection.

In relation to centralised composting, the plan has highlighted contamination of putrescible materials as a possible problem. It is recommended that the Council introduce bye-laws on the presentation of waste to minimise the possibility of contamination.

The plan specifies rates for the composting of putrescible materials. It should be remembered that other categories of the organic waste stream, such as paper and wood, can also be composted. This could be particularly useful for soiled paper or paper that is no longer sufficient quality to be recycled again as paper. These non-putrescible fractions also have the advantage that they can be stored until they are needed.

3.6 International Experience

There are numerous communities around the world that have reached, and indeed, surpassed Irish targets, in the same and shorter time periods. There are many commonalties, such as incentivising for waste reduction and strong outreach programmes. It is recommended that the Council investigate these with a particular view to those that are based in rural communities. A multitude of such cases exists and three are given below as examples.

Daventree District Council in the UK, recently created a ‘Green Waste Trial’ as a means of achieving what was the UK’s national recycling target of 25% of household waste by 2000. Daventree Council selected approximately 5,400 households in the rural area of the District to participate in the kerbside, twin bin organic waste trial, which ran from one year from August 1998. Before the trial started the average recycling rate in the trial area was 12%. This increased to an average of 51% over the trial period and had reached 60% by the end of the trial. Although dubbed a ‘green waste’’ trial, not all of the increase was due to organic recycling and the dry recyclables rate increased by 35%. Waste Watch, a U.K. National charity, delivered the communication and education programme and the result illustrates what can be achieved with a strong and intensive education programme. Although no one element of this project was identified as being the key to the success of this project, certain factors are though to have played an important role. These include,

• high levels of communication with householders, including home visits and a helpline,
• reliable collection service coupled with rigorously enforced collection policies,
• provision of kitchen pre-sort bins,
• partnership and collaboration between the community, public and private sectors.

Some of the highest recycling rates in the UK (over 70%) have been achieved at village level in Kent by intensive recycling and composting. In 1999 residual wastes in certain villages in the area was down to 4 kg/ household per week.

The Quinte area in eastern Ontario (population 95,000, which includes the towns of Belleville, Trenton and Sidney, and the surrounding rural areas), 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%.

3.7 Community Sector Involvement.

According to the 1997 Waste Management Planning Regulations, the Donegal plan should include information or have regard to the ‘need for co-operation with and assistance for voluntary organisations involved in waste activities’. However the plan does not contain such information. The role of the community sector in waste-resource management cannot be underplayed. The Daventree example above is only one example of an effective partnership approach. Another example is the system in place in Bath & North East Somerset, also in the U.K.

Bath & North East Somerset is a largely rural area to the south of Bristol with a total population of 167,000 (72,000 households) with approximately 50% residing in Bath. A kerbside collection of recyclables operates through the district in partnership with Avon Friends of the Earth. This partnership has proven very successful. The shared common goal of the two organisations is to deliver sustainable systems of waste management according to the Bath Council, "the local authority strives to deliver policy by providing an agreed level of service within available resources and the community environmental group strives to work with the community and use resources for the best effect of the environment. Each partner brings to the table a quality that enhances the other and strengthens the integrity of the recycling scheme within Bath and North East Somerset. The kerbside recycling scheme is confident and progressive because of the partnership and as a result has greater ability to adapt to change". At present green boxes are supplied to 90% of the district and weekly collections are carried out. It is planned that these weekly collections will be expanded to the whole of the district throughout 2000. In 1999 the recycling and composting rate was 27% and the target for 2001 is 35%. The plan is to gradually increase the diversion rate to 50%.

3.8 Education and Outreach Programmes

International experience has shown that strong outreach programs are essential for high public participation. A program of education and support may be facilitated by the Council but Council staff may not need to be directly involved. An example of how education programs can be enhanced by the involvement of the community itself is the New South Wales Earth Works program in Australia.¹⁵ This program is typically run by a Council for its local community. Members of the community are trained in waste reduction, home composting and communication skills. Each Earth Worker then takes their knowledge and skills and shares them with the wider community. Earth Works is a highly cost effective method of community education for waste reduction and home composting as much of the ground work is done by volunteers.

The advantages of Earth Works include:

• allowing messages of waste reduction to be taken to a wide range of people in a wide range of communities,
• providing for peer education on one-to-one communication which can be a highly effective way to influence peoples’ attitudes and behaviours,
• considerable flexibility to adapt to the specific needs and circumstances of different communities.

A high level of community involvement in such projects can greatly enhance their success as they create a sense of ownership and pride in the project.

3.9 Incentives

A primary way to incentivise waste reduction is to introduce variable charging for waste presented for collection, or Pay as You Throw (PAYT) schemes. Two basic PAYT systems exist, the tag a bag system, by which residents pay for each bag set out or the charge by weight or volume system, where residents pay higher fees for larger or more bins or by the weight of rubbish in their bin.

Currently in Donegal, householders are charged directly by collectors by either a tag-a-bag system or annual payment. Hence potential already exists to introduce incentivise for recycling and composting of materials and it is recommended that the Council investigates the potential to expand the variable charging system throughout Donegal as flat based charges do little to promote waste reduction. PAYT schemes, as with all regulatory measures, are most effective when introduced after adequate infrastructure is in place to provide communities with a real alternative. Of course the costs for kerbside collection of recyclables should be significantly lower than that for rubbish collection. As the population of Donegal is predominately rural, it should be noted that international experience has shown that communities with PAYT waste fees are particularly successful in getting residents to take their recyclables to drop-off centres when kerbside is not available.

Landfill bans are also another impetus for communities to develop alternative ways of dealing with certain materials. It is recommended that the Council considers banning certain materials which are easily recycled, such as the organic fraction, and those materials for which markets currently exist, with a view to expanding the types of material banned at a later date.

It is also recommended that the Council considers regulatory measures after the appropriate infrastructure is in place and the education and support program has been strongly developed.

3.10 Residual Disposal

It is recognised that no matter what route the Council 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 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.

4. Conclusions and Recommendations.

It is the conclusion of the Waste Working Group that incineration is not needed to meet National and EU targets and that it is failed technology that has detrimental social and environmental effects. It is recommended that Donegal Council rejects the incineration proposal for the region and develops a plan that is firmly focused on the EU Waste Hierarchy and will tackle the increasing amounts of waste generated within the region and create the conditions whereby material recovery and composting can be maximised.

It is also recommended that the Council;

• 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 which includes clear waste reduction targets, at least in line with those set by National Policy, and prioritises waste reduction at source,

• Develops a strategy for reuse and repair, and a strong outreach and support programme, possibly in conjunction with local community groups,

• Develops a strategy for developing markets for recyclable and recycled materials,

• Develops a new proposal, one that combines waste reduction at source with reuse, repair, recycling and composting together with economic incentives.

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