WASTE WORKING GROUP

C/O Earthwatch & VOICE,

7 Upr., Camden St., Dublin 2.

Ph: 01 - 4785140

To: The Kildare County Council

Re: Submission on the Draft Waste Management Plan for Kildare County, 1999.

Date : 14^th June 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 Waste Management Plan for County Kildare is referred to as "the Plan",
• Kildare County Council is referred to as "the Council"
• "recovery" means material recovery unless otherwise specified.

Executive Summary

The Waste Working Group welcomes this opportunity to contribute to the waste management planning process for County Kildare and to promote the development of a waste management plan that is based on the principles of sustainable development. Such a plan would focus primarily on reducing the amount of waste generated and then recovering or composting as much material as possible after that.

However the draft waste management plan for County Kildare is set to fail to stabilise and in the longer term reduce the amount of waste generated within the region. The plan does not meet all targets stipulated by Government and EU policy. In addition, the plan is vague in its dealing with disposal of residual wastes generated.

Compliance with National Targets in relation to Source Reduction

The plan allows for a considerable increase in waste generation over coming years and therefore is not in line with the principles of sustainable development or Government policy. By not meeting these targets the plan is in breach of government policy and it is recommended that a waste reduction strategy is developed for the region.

Compliance with EU and National Targets in relation to Material Recovery and Composting

The Waste Working Group welcomes the Council’s plans to develop a repair and renovation centre within the region. This would constitute an important element of a sustainable waste plan and will benefit the local economy. However the targets set for recycling and diversion from landfill need to be adjusted to account for the growth in waste generation anticipated in the plan. Also when the material recovery and composting targets that have been reached internationally are considered, it is clear that the targets set by the plan could be increased considerably. It is an opportune time for Kildare County Council to examine the experiences of such countries and to follow their lead in developing a truly sustainable waste system for the region. Also the plan does not address the central issue of markets for recycled materials.

Waste Disposal

The diversion of waste from landfill is a primary objective of national policy. Directing materials from end-of-pipe disposal options to material recovery mechanisms is essential for a sustainable waste plan. However the plan does not detail what diversion rates from landfill will be achieved over the period of the plan.

Although the need for landfill cannot be eradicated over the time period of this plan, action must be taken to minimise the environmental hazards associated with this disposal method. An essential step is to remove the organic fraction from the waste streams directed to landfill to combat a number of the traditional problems associated with landfill such as leachate and gas emissions.

Preamble

This submission was prepared by the Waste Working Group in response to the Draft Waste Management Plan for County Kildare 1999, which was produced for Kildare County Council by Fehily Timony & Co. The Waste Working Group is a coalition of Non Governmental Organisations, including Earthwatch and VOICE, and individuals working in the area of waste and resource management. The group was formed to co-ordinate and facilitate NGO contributions to the waste issue. This work was funded by the Department of the Environment and Local Government.

Introduction

A focus of the Waste Working Group is to promote waste management plans which are conducive to sustainable development. To develop such a plan a change in attitude towards waste is necessary. Waste material can no longer can be seen as useless rubbish but must be viewed as a potentially recoverable resource. Therefore a shift from waste "management" (i.e. how do we get rid of rubbish) to resource conservation and material recovery (i.e. how are we going to prevent wastage and conserve natural resources) is essential. We can no longer be content with burying these resources in the ground or sending them up in smoke as is the case with traditional waste disposal methods such as landfill or incineration.

A plan that is based on the principles of sustainable development would endeavour to ‘close the material loop’, that is to return material to the production chain so that resources are saved and the amount of waste produced is reduced. 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 systems. According to this hierarchy the prevention and minimisation of waste (source reduction) are the most favourable options. Anything that cannot be prevented or minimised should be re-used, repaired, recycled or composted. Energy recovery and landfill are the least favourable options.

A waste plan based on the principles of sustainable development would focus primarily on reducing the amount of waste generated, and the wide-scale promotion of recycling and composting.

It is stated in the plan that one of its main objectives is to "comply with the principles of sustainable development".

However the plan,

• Allows for a considerable increase in waste generation over the coming years,
• Does not attempt to maximise material recovery and recycling for waste generated in the region.

This Submission is structured as follows,

Section 1 – Examines the policy of the Council in relation to waste reduction at source. It concluded that the plan allows for a considerable increase in waste generation over the coming years and therefore is in breach of Government policy. It is recommended that a waste reduction plan is developed as part of the waste management plan.

Section 2- Highlights the failure of the plan to meet certain National and EU targets for material recovery and diversion from landfill. It is recommended that the Council corrects the plan in this regard and also considers these targets as short-term goals and plans to surpass these in the longer term. A number of international experiences are highlighted as examples by which to achieve high recovery rates and the importance of developing markets for recyclables is addressed.

Section 3 – Highlights the importance of reducing the amount of waste requiring disposal and the need to minimise environmental damage from landfill. This section also outlines additional points that need to be clarified in the final plan.

Section 4- Presents Conclusions and Recommendations.

1. Compliance with National Targets in relation to Source Reduction

The plan states compliance with the principles of sustainable development as one of its main objectives. A plan based on these principles would prioritise waste reduction at source. However the plan allows for a considerable increase in waste generation over coming years and therefore is not in line with the principles of sustainable development or Government policy.

Waste reduction at source should be the number one priority of a sustainable waste plan. This is recognised in the DOLG policy document where it is stated that"a major general objective is to stabilise, and in the longer-term reverse, the growth in waste generation".

A quantifiable target for this objective 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%".

Table 1 below shows the increase in municipal and industrial waste generation for various years over 1999 levels as predicted by the plan.

Table 1 – Predicted increase in waste generation in Kildare County.

The growth in municipal waste generation is shown in relation to the targets stipulated in Sustainable Development: A Strategy for Ireland in Figure 2 below.

Figure 2. The effect of the waste plan in relation to meeting waste reduction targets.

The plan will fail to meet these targets and will therefore contravene Government policy and the principles of sustainable development.

Section 4.2 outlines the Council’s specific policy on waste prevention and minimisation, which are both source reduction options. The Council’s plan in this regard is focused on education and awareness raising initiatives, reviewing the Council’s in-house purchasing policy and applying economic incentives to promote minimisation and recovery.

According to the 1997 Waste Management Planning Regulations, a plan shall provide an assessment of "the effect of measures to prevent or minimise waste production or the harmfulness of waste". No such assessment is provided in the plan.

The plan also lacks targets for waste reduction at source in the industrial sector. The plan states that it will capitalise on the presence of major companies in the region to disseminate the message of the importance of waste minimisation to SMEs. However as a 31% increase in industrial waste is predicted over a ten year period it is clear that a plan of action needs to be developed in this regard.

It is clear that the Council needs to develop measures to deal with the rapidly increasing amounts of waste generated within the region. It is therefore recommended that the Council,

• develops a waste reduction plan for the region as part of the waste management plan. This would include source reduction targets at least in line with those given in Sustainable Development: A Strategy for Ireland,

• makes waste prevention and minimisation an integral part of the industrial and commercial licensing process for activities within its functional area that fall outside the jurisdiction of the EPA’s IPC licensing process,
• supports research and development initiatives for waste reduction in SMEs and provide a forum for information exchange and technical assistance.

It is also recommended that the Council examines international experience in relation to developing a plan for waste reduction at source. Examples of some relevant strategies are given in the next section.

1.1 International Examples

• 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 document sets an overall strategy for waste reduction at source and lists immediate actions that will start to make a difference.
• In relation to domestic waste, one of the many effective approaches 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).

In relation to Industrial and Commercial waste,

• The Dutch track changes in levels of knowledge, attitude and behaviour in relation to clean production in SMEs, as a prevention indicator.
• Authorities in Canberra, Australia established waste reduction agreements with industries operating within the Australian Capital Territory.
• Research has shown that the key elements of most waste reduction success stories usually involve the following:
  • convincing senior management of the importance of waste reduction
  • obtaining senior management support for programs
  • conducting a waste audit
  • reducing waste where possible
  • reusing packaging and materials where possible
  • recycling materials that cannot be reduced or reused
  • involving the plant staff in the program

While waste prevention in industry is very much a sector specific task that needs a thorough knowledge of the respective production processes, key areas which all sectors of industry and commerce can adhere to are;

It is the belief of the Waste Working Group, that the support and advice granted to industry must address the root problems of our excessive waste generation. It is felt that the authority can play a major role in delivering the message that a throwaway society cannot be sustained on a finite planet.

To conclude this section, a plan of action in relation to waste reduction needs to be developed by the Council. If the problem of waste is not tackled at source the Council will continue to suffer the effects of a waste crisis.

2. Compliance with EU and National Targets in relation to Material Recovery and Composting

The Waste Working Group welcomes the Council’s plans to develop a repair and renovation centre within the region. This would constitute an important element of a sustainable waste plan and will benefit the local economy. However the targets set for recycling and diversion from landfill need to be adjusted to account for the growth in waste generation anticipated in the plan. Also when the material recovery and composting targets that have been reached internationally are considered, it is clear that the targets set by the plan could be increased considerably.

A number of the EU and National recycling and diversion targets to be met by the Council over the coming years are shown in Box 1 below.

Box 1 – Recycling and Diversion from landfill targets

According to "Recycling for Ireland" and "Waste Management: Changing our Ways", the current recycling and diversion from landfill targets are as follows,

• 20% of municipal waste to be recycled by 1999,
• 50% of household waste to be diverted from landfill by 2013,
• 100,000 tonnes of organic waste to be diverted from landfill by 1999,
• 27% of packaging waste to be recycled by 1999.
• a minimum 65% reduction in biodegradable wastes consigned to landfill,
• recycling of 35% of municipal waste,
• recycling at least 50% of C&D waste within a five year period, with a progressive increase to at least 85% over fifteen years.

Section 4.1 of the plan discusses the Council’s waste management policy in this regard and Table 4.2 shows the targets that the Council proposes to meet over the coming years. The information provided in Table 4.2 of the plan has been transferred to Table 2 below.

Table 2 - Table 5.2 of the plan: Summary of the Targets proposed by the plan.

Notes:-
1. "Recycling for Ireland" (1994)
2. Packaging Directive Targets
3. Proposed Landfill Directive Targets
4. "Changing our Ways" (1998)

Comments on the targets proposed by the plan are detailed as follows,

1. In relation to recycling and recovery the of household waste the plan proposes to,

• provide a kerbside collection system for packaging waste and newsprint to all households in the major towns. This will serve 52% of the population.
• provide a network of 67 bring centres with, as a minimum, receptacles for the collection of glass, beverage cans and textiles to serve the remainder of the population.

Using the household waste composition data presented in Table 2.7 of the plan it can be calculated that,

• the kerbside system will target 35.9% of household waste,
• the bring bank system will target a minimum of 13.5% of household waste.

Therefore, on average, the Council plans to target 24.7% of household waste for recycling.

It is unclear how the Council plans to meet the targets set for recycling and diversion from landfill in relation to household and total municipal waste.

The plan does not detail why these specific categories of waste were chosen. For example if the plan proposed to recycled and compost paper and organics alone it would target nearly 50% of the total household waste stream.

The Council indicates that it will encourage home and community composting but does not indicate proposed quantities to be composted or percentage of the population to be targeted.

3. Table 4.2 of the plan (Table 2 of this submission) fails to account for the increase in waste generation over this time period. All targets are based on current (1999) levels of waste generation. For example, the targets (tonnes) for household and total municipal waste are calculated as 35% and 50% respectively of current levels. It does not take into account the considerable increase in municipal and household waste generation over the plan period. Using the information provided in Section 3.2 the projected tonnages of municipal and household waste generated in the year 2013 can be calculated as 111,435 and 73,317 tonnes respectively.

Using these figures the targets set by the authority in relation to household and total municipal waste become,

Table 3. Adjusted recycling and diversion targets

Therefore the targets set by the plan should be adjusted to account for the projected growth in waste generation over the coming years.

4. The plan does not detail whether the targets set for 1999 have been met and if not the reasons why.

5. The plan does not account for the recovery targets in relation to construction and demolition waste or the delivery mechanisms by which these targets will be achieved.

6. Section 5.3(b), of the plan describes current and proposed infrastructural developments in support of waste minimisation and recovery. This section describes, in part, clean up measures such as skips and litter-bin schemes and the Tidy Towns competition. Anti-litter and ‘clean-up’ initiatives are not necessarily schemes which promote material recovery unless the material collected is sent for recycling or another material recovery process. They are also clearly not waste minimisation proposals as they plan to deal with waste after it is produced.

7. According to Section 4.1 (c) of the plan, the Council highlights the targets set by the EU Directives on Packaging and Landfill as being the most pertinent during the period of the plan. "Kildare County Council will therefore concentrate on these objectives for the period of this plan. The Council will also have regard to the later target dates required by the "Changing our Ways" policy document and will seek to meet the interim targets necessary to ensure these targets will be met by their respective dates".

While it is imperative that the targets set by the EU Directives on Packaging and Landfill be met, the plan does not,

• Detail how these targets will be met,
• Set interim goals in relation to the other targets.

For a sustainable waste plan, targets higher than those set by the Council for material recovery and recycling would be set. International experience has shown that it is more than possible to meet and surpasses these targets in the same and shorter time periods. Examples of such programmes are outlined in the next section.

2.1 International Experience

The following examples illustrate the success of reduction, reuse, recycling and composting strategies implemented internationally, in both environmental and economic terms.

• 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.

• 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.

• 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.

Some of the most innovative waste plans developed in recent years have come from Australia and New Zealand. 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.

It is an opportune time for Kildare County Council to examine the experiences of such countries and to follow their lead in developing a truly sustainable waste system for the region.

2.2 Market development for recyclables

Ensuring that an outlet exists for recovered materials is essential to a sustainable waste plan. However the Kildare plan fails to address this issue.

According to the 1997 Waste Planning Regulations, a plan shall "outline the position regarding markets or uses for recovered material or products".

However the plan does not address the current position in relation to markets for 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.

Suggestions as to how the Council can encourage the advancement of recycling in the region include,

• 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, 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,

• 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.

To conclude this section it is recommended that the council,

• researches the many excellent material recovery strategies that are in place internationally, with a view to their transferability to the region,
• sets high targets for material recovery and composting of municipal waste and industrial waste.
• details the delivery mechanisms by which such targets would be met, and
• subsequently develops a strategy for the development of recycling in the region including the development of markets for recovered materials.

3. Waste Disposal

The diversion of waste from landfill is a primary objective of national policy. Directing materials from end-of-pipe disposal options to material recovery mechanisms is essential for a sustainable waste plan.

However the plan does not detail what diversion rates will be achieved over the period of the plan.

It is recognised that the need for landfill will not be eradicated in the time period of this plan. However, the diversion rate can be increased tremendously with the recommendations for source reduction and material recover and composting outlined in this submission.

It is also recommended that the Council immediately focuses on maximising the removal of the organic fraction from landfill as this will remove most of the problems such as leachate and odour traditionally associated with landfill. The Council could then 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.

3.1 Additional Comments

Section 4.2 states that in the medium to long term, the Council will consider "alternative arrangements for the disposal of residual waste in co-operation with neighbouring Local Authorities".

It is recommended that the Plan details the nature of these "alternative arrangements", as such information is necessary for informed decision making.?????

Section 5.3 (i) of the plan states that the "Council will examine the feasibility of directing all, or a proportion of, Co. Kildare’s waste to suitable facilities in the Dublin, Midland or South-East Regions as and when these are proposed/ developed"

Again, the nature and the quantities of waste directed to these "suitable facilities" should be detailed.

Conclusions and Recommendations

The Draft Waste Management Plan for County Kildare, needs to firmly tackle the increasing amounts of waste generated within the region and to create the conditions whereby material recovery and composting can be maximised.

It is recommended that the Council;

1. Develops a waste reduction plan for the region.
2. Sets clear waste reduction targets, at least in line with those set by National Policy, and details clearly how it proposes to meet these targets. (The Council should consider targets set by EU and National policy as a minimum. The delivery mechanisms by which such targets would be met should be detailed).
3. Researches material recovery strategies that are in place internationally, with a view to their transferability to the region.
4. Develops a strategy for the development of recycling in the region, including the development of markets for recovered materials.
5. Clarifies how and where residual waste is to be disposed of, and minimises the environmental impacts of such disposal.

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