A document produced by the Waste Working Group
20th October 1998
To:The Dublin Waste Strategy Co-ordination Group.
Cc: Alderman Joe Doyle, Lord Mayor of Dublin
County managers/Chairpeople
Noel Dempsey T.D., Minister for Local Government and the Environment
Danny Wallace T.D., Minister of State at the Dep. of the Environment and Local Government
John Fitzgerald, Dublin City Manager
Gerry Carty (Environmental Protection Agency)
Liam Whelan (Department of the Environment)
Dear Sir/Madam,
We are writing to avail of the opportunity that you presented to us to make our views on the draft waste management plan for Dublin known to you.
As you are aware we are a coalition of Non Governmental Organisations and individuals working in the field of waste. Our membership includes Earthwatch, Global Action Plan, Voice and the Waste Action Group. We have produced the 'Making the Most of Materials' exhibition which has been viewed by many of you during it's period of display in ENFO and in Ennis. The exhibition is currently on display in Wicklow.
We have been involved in the waste issue at various levels for many years now, mainly fighting large-scale developments with local communities. The exhibition and this submission represent an expansion of our constructive and proactive role in waste management. While we appreciate the extent to which you have accommodated us as an organisation in this process we feel that this level of co-operation and accommodation should have been extended throughout the entire public involvement phase of the project. While there has been a level of public involvement it is unclear whether this meets the letter and spirit of the relevant sections of the Waste Management Act and its regulations.
We hope that you can appreciate the effort which we have directed into this, our official submission on the draft waste plan. The time and financial expenditure which has been incurred has been financed by us. We requested funding from various levels of government to comment on the plan, or have constructive interaction during the drafting process of the plan. Unfortunately this was not forthcoming at any level.
One of our strengths is that we have various levels of society involved in our group, from members of the public (unattached and unaffiliated to any other body) through University researchers to formally constituted environmental NGOs. Our comments generally follow the format of the document. We shall initially address Public Consultation/Involvement (p.3 Executive Summary). The level to which different sectors of society have been included or involved in this planning process varies. We attempted to survey various individuals and organisations consulted for the Waste Management Strategy. Again we were not facilitated in this. As only organisations and elected individuals were listed by the consultants it appears that the involvement and participation of the public was undervalued by the planners. For example, organisations can request copies of the plan while the public is expected to pay for them. Tools which were put in place by the consultants, including the Internet site and information displays, were not sufficiently advertised to facilitate use by the public. The 'public involvement process' cannot be described as being `extensive' under any definition of the term. The failure of the plan to make its drafting process in any way proactive or inclusive is a fatal flaw which needs to be remedied even at this stage.
The plan lacks a definitive figure for waste arising in the Dublin region. Throughout the document various figures are bandied about with little apparent need to have concrete figures present for the planning process. Is this a plan for non-hazardous Municipal Solid Waste, all waste arising or a selection of the wastes arising? We would prefer the plan to cover all wastes, we recognise that this would need the co-operation of the EPA with regard to hazardous wastes (though this boundary has been significantly blurred by the inclusion of the new category 'harmful' wastes and the inclusion of priority waste streams in the plan).
The four scenarios are presented without explanation of their meaning or their context. After this point they are simply given as the four accepted scenarios. There is no data included in relation to the 'cost benefit analysis' which was undertaken for the draft plan. While cost benefit analysis (CBA) is a flawed mechanism it would have been extremely interesting to have the details of this, which must have been an extensive study, while the agreed and accepted flaws that the planners built into the process would help to better explain the draft plan.
Can the plan explain in detail what is understood by a 'green region approach'?
What details are there to describe the levels of support which will be given to the 'existing community initiatives like the Global Action Plan'? The existing mechanism of the Partnership awards will give an initiative of £7500 per Local Authority region. £28000 across the entire Dublin region, as defined by the draft plan, will not go far towards waste minimisation for any single Non Governmental initiative irrespective of the level of commitment of the organisation. This plan should detail how organisations and individuals should be able to interact and develop waste management initiatives within a plan. This draft plan fails to do so. What does the table on p7 mean? If the table means that the only reduction target set is a reduction in the waste growth rate then this is not compatible with sustainability. Should this not be a table showing the reduction targets for waste arisings? We believe the targets set are incompatible with sustainable waste management practices and as such the Local Authorities should reject the draft plan.
The bring banks should also cover the 80% area covered by kerbside collection. The bring banks envisaged by the plan are not a good initiative. What is the energy balance envisaged for someone recycling a handful of aluminium cans at one of the bring banks having used a car to drive the ten mile round trip to the bank? We are sure that the cost benefit analysis spoken of in the summary contains these details but we do not have access to it.
What is the definition of a harmful waste? What is the equivalent definition under Irish or European law?
Why is there a delay in the introduction of a by-law? Can the by-laws not be introduced now? Why has no mention been made by the Danish consultants of the ground-breaking Danish Bottles case in Europe? Its implications at a local level would be important for any waste management plan.
Which consultants have been appointed for the thermal treatment and biological treatment feasibility studies? We believe these studies should have been completed and assessed before the plan is considered for adoption.
The recycling and recovery targets are meaningless without the completion of the aforementioned feasibility studies. Specifically in the table on page 9 `Recycling and Recovery Targets'. What of the fate of the recyclable materials collected? Is there a market for the collected products? If not this will have a huge impact on the amount of material requiring alternative management. Are we really expected to believe that only 1% of household waste will be landfilled? What about the proportion of waste that is not classified by the plan or even incinerator ash?
If minimisation is a primary objective why is it not already in place? We need these initiatives and support mechanisms now, not five years hence when disposal facilities are in place and optimal use needs to be made of the disposal options.
The new Waste Services Departments need to be more public and open. Much could be learned by following the example set by the Department of the Environment at ENFO.
1.6 While an initial consultation period did occur, its compliance with the stated section of the Act is unclear.
3.2 Why is there no discussion of landfills in Meath and Louth currently receiving Dublin's waste?
3.3 There are discrepancies in the figures stated in this section. It was understood by us that the EPA National Waste Database contained an Access programme which would contain accurate information on the composition and quantity of waste arising in a Local Authority area. Were these figures not made available to the process? Why are these figures not already in use in the waste management process?
3.4 Yet again we are presented with a different figure for waste arisings
3.5 Is there any indication that the composition of Dublin Corporation's Household waste is equivalent to the composition of household waste from Fingal, South Dublin or Dun Laoghaire/Rathdown's?
4.1 Per capita figures for concentrations of public facilities are already known. Public telephone boxes, letter boxes, litter boxes are all at given densities in mature settings of the county. Can these not be used as a basis for optimal placement of new facilities to supplement the paltry number of bring banks?
5.2 The treatment of waste minimisation within the existing regulations is overly simplistic and does not compel the Local Authority to implement waste minimisation policies. Again it should be more inclusive.
5.3 Why has no attempt been made to evaluate public response? What was the outcome and feedback from the Corporation's recent composting initiative?
5.4 If waste minimisation is to be restricted to those industries under IPC what % of employees in SMEs will be excluded from waste minimisation?
6 Waste Management Facilities
This section only selectively addresses those facilities which have been mentioned earlier in the report. It must be remembered that Kill is located outside the boundaries of the Dublin Region, should not other sites similarly located and utilised also be included?
7.1 If there is an acknowledgement of the problem of Private Waste Disposal why then is there no discussion of it in the draft plan?
Why is it proposed to extend such an expensive system of waste collection (kerbside) to 80% of the area? Will it be targeted waste streams? Will the by-laws attempt to regulate the market in recycling/reuse of materials (the Danish bottles case?)
8.2 Will any attempt be made to exploit the Local Authority linkages which have been formed between Dublin and Liverpool in order to avail of their markets and experience with waste management?
The plan still fails to control the disposal route for commercial and industrial wastes
We believe it is not necessary to do trials on C&D wastes, the market simply needs to be regulated and consultation with Department and relevant bodies undertaken.
There is a need to address product design as a waste minimisation strategy.
8.3 Fails to centrally tackle the problem of the % of waste Minimised, Recycled/Reused, Thermally treated, Disposed.
9.3/9.4 Waste growth rates under the plan range from 3-5% depending on the sector examined. Is this acceptable?
10.2 Thermal treatment will impact on the recycling of waste.
What evidence is given to back-up the claim on the economics of incineration?
Waste stream calculations are crucially flawed and render the claims of the 16% disposal to landfill non-sense. The idea that a 'Thermal treatment could have 25,000 tonnes residue from a throughput of 500,000 to 700,000 tonnes is unbelievable! We expand on this point later in our submission.
Again we return to the most basic and fundamental question that the plan should answer... 'How much waste is produced in Dublin?' If it falls at the first hurdle then the plan should be rejected.
11.3 Is the database spoken of separate from the National Waste Database?
In summary, this detailed reading of the plan has highlighted various areas where the draft plan fails. We have also discussed some of the legal implications of the document and a more detailed discourse on 'thermal treatment'.
Section 22 (especially subsections (6) and (7) of the Waste Management Act, 1996 specifies what a waste management plan shall contain. The draft plan produced by the four Dublin local authorities does not contain this information.
In particular it does not contain objectives
It should include information on the measure which will be taken to prevent or minimise, and on facilities, plant and equipment which they expect to have or will require.
It also should include something on the identification of old dumps and their pollution potential and description of remedial measures planned.
The Framework directive (1975 waste) requires the identification of the proposed disposal sites in the waste plan.
In this section we will attempt to show that incineration as a waste management approach does not have regard to what the Dublin brief issued by the four local authorities terms "a sensible balance between costs and environmental considerations"1 and essentially does not address the root causes of Ireland's waste issue. The format of this analysis will be a critical appraisal of specific pro-incineration recommendations contained in the MCCK strategy accompanied by a general analysis of the role of incineration in dealing with waste problems.
We must first of all be clear on the terminology and recognise that the terms `thermal treatment', `waste-to-energy', `energy-from-waste',2 are all euphemisms for incineration used to offset associated negativities in the public mind, and have in common with non-`energy recovery' incinerators most of the same environmentally damaging characteristics such as emissions of dioxins, heavy metals, dust particles and acid gases.
To counter the argument that incineration is capable of creating energy, it must be pointed out that far more energy is actually saved by recycling those materials rather 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.3
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.4 This is borne out by the most recent European waste strategy which asserts that in general recycling is preferable to incineration in energy terms.5 Incineration means literally sending valuable resources up in smoke, as well as increasing pollution levels and foregoing opportunities to increase employment.
The MCCK strategy assertion that incineration will divert 25% of the total waste stream or between 500,000 and 700,000 tonnes/annum by the year 2004 suggests that incineration is viewed as a black hole for problematic waste. We believe that non-reusable or non-recyclable waste must be reduced or eliminated.
Landfill: It must be pointed out that ash produced by incineration occupies 40-50% of the landfill space that compacted unburnt waste would. Therefore, whilst it is often said that the ash occupies only 10% of the volume of unburnt waste, this figure can be misleading as it applies to uncompacted waste. In addition, the problem of how to dispose of the toxic fly ash remains.
Recycle stream:
I)Although it might appear that incinerators would not affect recycling of metals, glass and paper, in practice there would be little incentive for separating out these materials since they can go through the incineration process. The MCCK study itself stipulates that the proposed incinerator will accept all combustible waste: `a waste to energy facility will be capable of handling combustible waste from every sector' (10.2.3) This acts as a disincentive to direct waste towards sustainable reuse and recycling solutions.
II)Due to the high capital costs of incinerator building - costs due to increase as EU regulations call for ever more sophisticated pollution abatement features to be featured in such plants - incineration operators typically require contracts with local authorities to supply them with a minimum amount of waste to burn over a protracted periods, say 25-30 years. Therefore, incineration requires an expanding not a contracting waste stream as the incentive on the local authority will be to ensure enough waste is produced rather than reduced.
Given the established and emerging findings which increasingly link proximity to incineration sites with health impacts including those listed above, a precautionary approach must be advised when assessing the incineration question.
It is our belief that incineration of waste does not strike `a sensible balance between costs and environmental considerations' as per the study brief. This is proven by contradictions identified in the strategy itself. A mutual exclusivity is seen to be inherent in the incineration revenues, funding and repayment recommendations when juxtaposed with the assurances that waste will not be redirected from reuse and recycling streams. MCCK asserts that `Thermal treatment will not compromise the meeting of waste recycling targets and will achieve higher waste recovery resulting in lower landfill requirements'(10.2.1). To explain this contradiction we would refer to the heavy dependence which the strategy has upon the achievement of revenue from the incineration plant. To quote section 13.8 `(This level of operational spending) assumes revenues of between IR£7.5 million and IR£8 million per annum from energy produced in the thermal treatment plant' Essentially the inclusion of projected revenues indicates the existence of two possible premises, either:
The omission of a consideration of public reaction to incineration construction plans must indeed be viewed as a lack of commitment to public participation in environmental decision-making given the recent decade's international pattern of community mobilisation against waste treatment facilities known to negatively impact health and quality of living, This is a very real aspect of incineration plans in the late 90's. The public is becoming increasingly informed about previously unknown pollutants such as dioxins which are proving harmful to health even at very low levels. Without complete reassurance that air and water quality will not be compromised by proximity to the proposed plant and with little evidence to the contrary to date, public denouncement is practically assured.
Jobs created by incinerators are primarily associated with building the plant i.e. temporary construction jobs with few permanent jobs created when compared with recycling. In assessing jobs per one million tons of waste processed, a New York study found that landfill created 40-60 jobs, incineration 100-290 with recycling placed highest with 400-5909.
1. MCCK, Waste Management: A Strategy for Dublin, Strategy Report,
December 1997
2. Friends of the Earth's Incineration Campaign Guide,
December 1997.
3. Mass Balance and the UK Economy, Peter Jones,
Environmental Excellence, 1995.
4 Earthwatch submission to MCCK consultant group
titled "Local Authority Waste Management Policy Suggestions", April 1997.
5 Review of Waste Management Strategy, European Commission,
COM (96) 399, 30 July 1996.
6 The Landfill Campaign Guide, Friends of the Earth,
Appendix 2, p.3, June 1997.
7 Economic evaluation of the draft incineration Directive,
ETSU, European Commission, 1996.
8 The Non-Governmental Organization and The Management
of Hazardous Waste In Ireland, Jeremy Wates, Earthwatch, European Environmental Bureau,
1994.
9 Jobs in a Sustainable Economy, J Renner, Worldwatch
1991, cited in Working Future, Jobs and the Environment, Friends of the Earth, 1994.
Given that the Draft Plan sets reduction targets for growth of waste rather than actual waste arisings we feel this bodes badly for the results of the education programme advocated in the Plan. As any sustainable education system has to begin at the level of the individual, we would like to see any adopted plan set reduction targets for household waste. Recycling and awareness about household waste reduction are horrendously low due to paltry facilities and lack of support for existing education programmes. NGOs are in a unique position to implement education programmes on behalf of Local Authorities. We feel there is a need for long-term commitment to education which would require more than financial support from Local Authorities eg. setting up a household waste helpdesk for all four local authorities.
While local authorities in the Dublin area do charge commercial waste producers by volume for waste services, to date there has been a major discrepancy between the local authorities' income from such charges and the increasingly high costs of waste services, including expensive infrastructure such as landfills. In addition, the charges levied are not borne by all waste producers, and in some cases, are simply not high enough to encourage behavioural or structural changes in commercial or industrial operations.
In our view, cost recovery must be an essential part of a sustainable waste management strategy, for the following reasons:
In a 1997 study into the fiscal system in Ireland, the authors point out that the existing charges do not cover even short run marginal costs, never mind long run marginal costs of solid waste management. In addition, these charges do not cover the external costs of up to £11 per tonne of waste. The study estimates that charges currently cover just 23% of the total costs, with collection costs varying between £22 and £65 per tonne of waste. They estimate that both disposal and collection costs will rise dramatically and that the cost of constructing new landfills could be as much as £400 million. This means that local and central government is currently granting waste producers an `implicit' or `hidden' subsidy by undercharging for waste.
This study mentioned above recommends a number of potential remedies for implementing the polluter pays principle, based on the view, which we share, that charges should be adjusted to achieve full cost recovery and removal of subsidies on a volume related basis wherever possible. We also believe that charges should be offset against other income taxes so that the measure is ultimately fiscally neutral and considered as an ecological tax reform measure rather than a new tax or charge.
| Material | per tonne of recycled material |
|---|---|
| Aluminium | 186 |
| Glass | 2 |
| Paper | 24 |
| Tinplate | 16 |
| Plastics | 148 |
This submission is being made by the Waste Working Group, a coalition of individuals and non-governmental organisations as follows:
David Healy – Waste Action Group
Celine Horner – Global Action Plan
Tonia McMahon/ Sadhbh O Neill – Earthwatch- Friends of the Earth Ireland
Iva Pocock – VOICE
Please contact the above for further information or clarifications.
Barry Commoner
re sustainable production - consumption systems
Paul Connett, editor of Waste Not, Professor of Chemistry and
Environmental Studies, St. Lawrence University
re incineration issues and waste management generally.
Waterloo, Ontario, (through Paul Connett)
re community-based reuse/repair and recycling facility
Donal Daly, Geological Survey of Ireland
re groundwater protection
Iarnrod Eireann, Docklands Development Authority
re land in docks which could be made available for waste management
purposes
re rail shipment of waste, recovered materials or goods, compost, etc.
Irish Traveller Movement/Pavee Point
re recycling, especially scrap metal
Bob Landreth, US EPA
re landfill design issues
Plants for a Future, Cornwall
re production from renewable materials
address: The Field, Penpol, Lostwithiel, Cornwall, PL22 0NG, England.
Tel.(+44 1208) 873554 or 872963
Sunflower Recycling, Dublin
re community-based recycling
J.C. van Weenen, University of Amsterdam and United Nations
Environment Programme
re sustainable product development
Book list.
Allen, Robert, 1992, Waste Not Want Not: The production and
dumping of toxic waste
A good account of industrial waste issues in Ireland
Commoner, Barry, 1970, The Closing Circle
Commoner, Barry, 1990, Making Peace with the Planet
These books discuss how we must change our production systems to cyclical
systems in harmony with natural cycles.
Hawken,Paul, 1993, The Ecology of Commerce
Looks at how business must change to protect the earth.
Packard, Vance, 1960, The Waste Makers
"Should be made compulsory prison reading for every politician, every
economist, every advertising agent and every industrialist who attempts
to equate a high standard of living with the purchase of the unnecessary,
the inferior and the short-lived article" - The Times
Papanek, Victor, 1972 , Design for the Real World
Papanek, Victor, 1995, The Green Imperative
These books deal with how designers should work to produce sustainable
and useful products instead of consumer crap.
Williams, Joy, et al., 1998, Toxic Turnaround
A guide to avoiding and reducing the use of toxic materials aimed at
local and central government - available for $28 from EHC, 1717 Kettner
Boulevard, Suite 100, San Diego, CA 92101; telephone (619)235-0281;
fax: (619) 232-3670; E-mail: ehcoalition@igc.apc.org;