WASTE WORKING GROUP

C/O Earthwatch – Friends of the Earth Ireland & VOICE,

7 Upr., Camden St., Dublin 2.

Ph: 01 - 4785140

To: The Limerick/Clare/Kerry Regional Authority

Re: Submission to the Limerick/Clare/Kerry Regional

Waste Management Plan, 2000.

Date : 10^th March 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 Limerick / Clare /Kerry Regional Waste Management Plan is referred to as "the Plan",
• The Limerick / Clare /Kerry Regional Authority is referred to as "the authority".

• "recovery" means material recovery unless otherwise specified and "disposal" refers to both incineration/thermal treatment and landfill, for reasons discussed later.

Summary

It is the belief of the Waste Working Group that the primary function of this waste management plan is to lay the groundwork for a sustainable waste management / resource conservation and recovery system in the Limerick / Clare / Kerry region. For sustainable development waste management cannot be decoupled from resource conservation. For a sustainable system a shift from waste management to resource conservation - that is, a shift from ‘what are we going to do with our rubbish’ to ‘how are we going to prevent wastage and conserve natural resources - is needed.

Studies have shown that the current levels of resources used by the developed world is pushing the world way beyond what is sustainable and therefore closing the material loop is essential.

It is a concern of the Waste Working Group that all three scenarios proposed within the plan are focused on the least sustainable options, as outlined by the EU Waste Hierarchy. Options essential to a sustainable plan such as source reduction, reuse and repair are ignored in all three.

The proposed scenario focuses on recycling, thermal treatment/incineration and landfill i.e., the least favourable options for waste management according to the EU waste hierarchy and, therefore cannot provide a sustainable waste management strategy. To reiterate this point the scenario favoured by the authority will, in the year 2014, direct 64% of municipal and industrial waste generated to incineration/thermal treatment and landfill. The remaining 36% will be recycled. Therefore 100% of the focus of this plan is on reactive methods to deal with waste after it has been produced.

Also in the year 2014, more municipal waste will be incinerated than recycled, which is an inversion of the EU Waste Hierarchy.

While it is recognised that recycling is an essential part of a sustainable waste management plan, it must be integrated with source reduction and other material recovery systems.

The proactive source reduction -prevention and minimisation –options have not been sufficiently addressed. The authority his made a commitment to raising awareness with regard to waste prevention and minimisation. However in 2014 municipal waste generation will have increased by 79.9% over current levels. For sustainable development stabilisation, and in the longer term, reduction of current levels of waste generation is required.

The environmental analysis if the various proposed scenarios is limited and does not take into account the toxicological effects of incineration or the effect of landfills on groundwater, for example. Also no consideration is given to the effects that any of the scenarios have on sustainable development.

In effect what this waste plan proposes to do is direct waste from one disposal mechanism to another. It is the contention of the Waste Working Group that incineration /thermal treatment has no place in a sustainable waste management system. Incinerators act as ‘black holes’ for a vast amount of potentially recoverable resources and recreates the ‘out of site - out of mind’ approach evident with landfill. Therefore, thermal treatment is not conducive to closing the material loop - a process essential for resource conservation and sustainable development. Thermal treatment is, in effect, akin to landfill as it is an end of pipe disposal option and the energy recovery option can mask this. It is a fact that 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 25% recovery from incineration.

The way forward is not a choice between incineration and landfill. The questionnaire distributed to the public by the authority suggests that this is the case and is misleading. Also by moving vast quantities of waste from one disposal mechanism to another the authority is deferring the problem rather than solving it.

It is recommended that the authority investigates the numerous positive prevention, minimisation and material recovery schemes which have been successfully implemented internationally, many of which are out lined in this report. Experience has shown that it is more than possible to meet and indeed surpass the targets set out by national policy without the use of thermal treatment.

For example, the policy of Canberra, Australia is to create a waste free society by 2010. This policy of ‘zero waste’ - or turning all waste into resources- has also been embraced by New Zealand. Here thirteen diverse district and city councils have joined a national pilot project originally designed for ten, and seven more authorities are poised to make a commitment to reduce waste to zero by 2015. They have realised that reducing waste to zero is no longer a theoretical exercise and there are more than enough community based reduction and recycling schemes achieving dramatic results.

The situation whereby recycling and reuse outcompetes landfill must be created, so the mindset that views positive reduction and material recovery schemes as an expensive add on to landfill can be inverted. Landfill must become that add-on to a resource recovery process.

1. Introduction

Environmentally sound management of wastes is among the environmental issues of major concern in maintaining the quality of the Earth’s environment and especially in achieving environmentally sound and sustainable development.

It is the belief of the Waste Working Group, that the primary function of this waste management plan is to lay the groundwork for a truly sustainable waste management/ resource recovery system in the Mid West region. It is the concern of the Waste Working Group that the Mid West regional authority is not doing this and therefore deferring the problem rather than attempting to solve it.

Therefore the necessity of achieving a sustainable waste management system is discussed.

1. Waste Management in the context of Sustainable Development.

 

Sustainable development is broadly described as development, which meets the needs of today without jeopardising the needs of future generations, that is living within the Earth’s carrying capacity.

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

 

i.e. Resources ® product ® disposal

 

We extract resources, buy and use a product and then throw it away. On the right hand side of this equation the rapidly increasing amounts of waste generated are causing problems, such as those relating to waste disposal. In fact, industrial development and its associated waste products has accelerated at a rate far surpassing the adaptive capacity of natural systems to and if wastes continue to be produced at current or increased volumes, then any system will eventually become overwhelmed.

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

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

 

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

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

 

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

 

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

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

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

 

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

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

 

2. The Limerick /Clare/Kerry Plan in the context of Sustainable Development

Figure 1 below, illustrates that, in relation to municipal and industrial waste, the proposed scenario for the Limerick / Clare and Kerry region (Section 10.5 of the plan), concentrates 64% of its effort on the right hand side of the equation i.e how to dispose of the waste and 100% effort on what to do with waste once it has been generated.

Figure 1. Targets set by the Limerick/Clare/Kerry regional authority for the recycling, incineration and landfill of municipal and industrial waste.

However, as illustrated in this submission, sustainable development requires reduced resource usage, not just diversion from landfill.

2. Analysis of the waste management policy for the Region

SECTION 6.1 states that the fundamental principle driving the change in waste management policy is that of sustainability. However all three scenarios proposed by the authority contradict this objective. All scenarios are firmly focused on the least favourable options according to the EU waste hierarchy.

The three scenarios proposed are (Section 10.3.1 of the plan),

• Scenario 1; Achieve maximum realistic recycling, continue with landfill disposal.
• Scenario 2; Achieve national and EU targets for recycling and introduce thermal treatment of combustible wastes.
• Scenario 3; Achieve maximum landfill diversion through implementation of maximum recycling and thermal treatment of combustible wastes.

Scenario 3 is the one chosen by the authority.

Section 10 of the plan describes the three scenarios examined by the authority, with regard to choosing the Best Practicable Environmental Option for the region.

Section 10.2 of the plan, states that the "scenario must respect the EU Waste Hierarchy so that reuse and recycling are preferred as far as possible (Best Practicable Environmental Option)" and Section 7.1 clearly states that the approach towards waste management over the plan period will focus on reducing the regions current dependence on landfill disposal and moving towards an integrated approach which will include waste collection and treatment methods having regard to the following options:

* recovery of secondary materials (recycling)

* biological treatment of organic materials

* thermal treatment

* residual landfill

Section 10.2 also states that "the scenario must respect the EU Waste hierarchy and "any integrated waste management plan must include a number of facilities and elements incorporating all aspects of the EU Waste Hierarchy".

However Section 1.5.1, states that the underlying philosophy behind the Irish government's policy is the Waste Management Hierarchy, which sets out that prevention and minimisation of waste should be followed by reuse, recycling and recovery in that order, with disposal as the last option of all.

According to the EU and national waste policy, prevention and minimisation are the two most favourable options. None of the three scenarios proposed included these source reduction options.

2.1 Prevention and Minimisation

It is recognised that the terms prevention and minimisation are often used interchangeably. They are both source reduction initiatives, as they both relate to reducing the amount of waste created. However, it is important to realise that they are different and are on different levels on the waste hierarchy. This fact is not recognised throughout the plan.

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

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

Section 5.3, of the plan discusses current waste minimisation initiatives at household / community level. It is stated that to date these initiatives have primarily been aimed at diverting waste from disposal by encouraging the use of recycling "bring" facilities participation with dual collection for composting and also home composting. It is also stated that efforts have also been made towards education and community initiatives in relation to litter management.

Waste prevention and minimisation do not mean diversion from landfill, recycling or litter management.

It is acknowledged that recycling, composting etc., are important parts of the plan, but they are no substitute for reduction at source, the necessity of which cannot be understated for without it, everything else can only be a second-best option.

The specific objectives to be achieved during the period of the plan, in relation to waste prevention and minimisation are presented in Section 11.1. These are largely based on awareness raising and it is important that confusion between source reduction options and waste management options such as recycling does not occur.

Also the authority is required under the Waste Management (Planning) Regulations 1997, to give an assessment of the impact of their waste prevention and minimisation activities.

No assessment is provided in the plan.

Whilst it is recognised that education is an essential part of a sustainable waste management system, actions that the authority can take include,

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

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

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

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

• Setting a target for waste prevention and minimisation in the region. According to Ireland’s strategy for sustainable development a 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%.

Also Section 4.1 of the government’s policy statement "Changing our Ways", states that "a major general objective is to stabilise, and in the longer term reverse, the growth in waste generation".

The total estimated municipal waste arisings in the region for 1998, is 212,217 tonnes. As the population of the region is 385,178 (Section 2.1 of the plan), the estimated municipal waste arisings is 0.55 tonnes/ year per capita which is equal to 550 kg/year per capita.

Calculations performed on the basis of the information given in Sections 3.2.4, 3.2.2, and Table 10.1 of the plan show a marked increase in municipal waste generation as seen in Table 1, below.

Table 1 - Percentage increase in waste generation for industrial and municipal waste, between the years 1998 and 2014.

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

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

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

Examples of prevention targets set by other bodies include:

- The Netherlands has minimum targets of 10% for prevention,

• Cork Corporation had set a target to reduce household waste from half a tonne per person per annum, to a third of a tonne per annum over the coming years.

2.2 Prevention and Minimisation in Industrial and Commercial Sectors

A specific objective of the plan, is to give support and encouragement to busisness and industry, with particular emphasis placed on increasing awareness in SMEs and companies outside the licensing system. In addition, the authority could consider providing funding or investigating funding opportunities for Research and Development in business that fall outside the jurisdiction of the EPA.

As a prevention indicator, the fact that the Dutch track changes in levels of knowledge, attitude and behaviour in relation to clean production in SMEs, may be of use to the authority. Also authorities in Canberra, Australia propose to establish waste reduction agreements with industries operating within the Australian Capital Territory.

Also, in relation to industry and commerce, 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;

· product designs which enable after use repair, or at least recycling and recovery;

· preference to be given to suppliers of materials and goods with a minimum amount of packaging;

· introduction of washable dishwear in canteens;

· provision of life-cycle information on products;

· use of recycled paper, double sided photocopies etc.

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.

2.3 The Prevention and Minimisation of Domestic Waste

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

A domestic waste hierarchy was outlined, as follows:

· Consumption reduction

· Product re-use; and

· Material recycling

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

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

They plan to achieve this by urging the public to:

· Reduce consumption of luxury and throw away items,

· Choose unpackaged and minimally packaged products; and

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

The authority has also committed itself to education and awareness raising in communities within the region. 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.

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 means of influencing peoples attitudes and behaviours

· considerable flexibility to adapt to the specific needs and circumstances of different communities.

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.

2.4 Composting and Material Recovery

Section 10.6 of the plan, states that home composting is a waste minimisation option. However as pointed out earlier in this submission, composting is a method of dealing with waste after it has been created and is therefore, in the opinion of the Waste Working Group, is not a waste minimisation option, it does not minimise the amount of waste generated and is a recycling option.

Section 10.6 also states that dual collection and central biological treatment of organic waste, will not, on its own will not, without thermal treatment (even together with other recycling initiatives), achieve the full requirements of the Landfill Directive of 65% diversion of biodegradable waste from landfill. It also states that "experience in other countries indicates that 55% is the level of diversion that is practically achievable".

• the plan does not state which countries limit the recycling of organic waste to 55% and
• it is not clear what other recycling initiatives the plan is referring to.

The municipality of S. Giustina in Colle, Italy achieved a reduction in organic waste presented for collection of 71% of the original municipal organic waste by home composting alone. This project also showed that the amounted of municipal waste presented for collection was reduced by up to 23% of total municipal waste by home composting.

When considering the three proposed scenarios in Section 10.3.1, Table 10.1 shows what is considered "realistic" by the authorities - it is not clear what they are modelling these targets on. The authorities consider the maximum household recycling rates to be 37.1%, industry 33% and construction and demolition to be 79.8%. The only difference between the maximum "realistic" recycling rates proposed by the authorities is in the target for household waste, where maximum is 1.7% more than the target set by the government.

• According to Table 10.1 of the plan, 79.8%, is the "maximum" achievable recycling rate for construction and demolition waste. However, in Denmark in 1996, 90% of construction and demolition waste was recycled to provide raw materials.

It is a concern of the Waste Working Group that all three scenarios proposed within the plan are focused on the lower end of the waste hierarchy. Options essential to a sustainable plan such as source reduction, reuse and repair are ignored. The proposed scenario focuses on recycling, thermal treatment and landfill i.e., the least favourable options for waste management according to the EU waste hierarchy and, therefore cannot provide the basis of a sustainable waste management strategy.

Whilst recycling is an important part of any sustainable waste management plan, it is part of the solution and cannot be heralded as the solution to all waste management problems. Also, in the opinion of the Waste Working Group, the targets set for recycling are very low when compared to what has been achieved internationally.

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". It is an opportune time for Ireland to strive to become amongst the world leaders in sustainable waste management / resource conservation.

There are numerous examples of reduction, reuse and recycling strategies implemented internationally, that have far exceeded the targets set for the mid-west and in shorter time periods.

Examples of these include,

• The municipality of Dilbeek, in Belgium reduced its quantity of household waste by more than 60% within six months in 1996. The average amount of household waste generated fell from 495 kg/capita in 1995 to 304 kg/capita in 1996. With such an impressive reduction, the municipality saved about 2 million EURO in 1996 and 1997.
• The Quinte area in eastern Ontario (population 95,000), diverted an average of 68% of household waste from disposal over a seven year period starting in 1989. This was achieved by the implementation of a comprehensive system which 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%.

It is important to note that material recovery also includes reuse and repair. If the authority ignores these viable options, it is disregarding an important part of a sustainable waste management system and a method to divert substantial amounts of waste away from landfill.

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

The following examples illustrate the effectiveness of reuse and repair.

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

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

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

- 1200 tons of scrap metal was recovered for recycling;

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

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

This case study demonstrates the opportunities for partnership approaches which in this case saving both electricity and waste.

• 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.

Section 5.4 states that information about contractors is lacking in the area and furthermore the price and uncertainty is too high since all recycled waste is exported to the Dublin area at industries expense and risk. It is therefore imperative that the authority creates the conditions within its functional area where it is easier and cheaper to reduce, recycle etc.

Actions that the authority can take to further the development of material recovery within their functional area 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 the authority can encourage local and regional newspapers to use a minimum recycled paper content in their newspapers, thereby developing an environmentally responsible image for the paper and guaranteeing a market for recycled paper.

All of the above will encourage market development for recyclable material, the lack of which is noted in Section 6.1. of the plan. The authority could also consider the experiences of the state of California, USA.

• 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.

It is therefore recommended that the authority consider a differential charging system for waste collection and disposal and consider banning certain material from landfill - as is the existing policy in Co. Clare.

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. Untagged sacks or bins are collected by the municipality seperately and the generator of the refuse identified in 70% of cases. The generator is contacted and requestd 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.

2.5 Thermal Treatment and L andfill

Section 1.5 of the plan identifies thermal treatment as a key element of the plan.

In the opinion of the Waste Working Group, thermal treatment is an end-of-pipe disposal option akin to landfill and has no place in a sustainable waste management system.

It should be noted that the way forward is not a choice between thermal treatment and landfill. The questionnaire distributed to the public by the authority suggests this and is misleading.

It has been emphasised that a sustainable waste management plan must focus on prevention, minimisation and material recovery.

However in the year 2014, more municipal waste will be burned than recycled, which is an inversion of the EU Waste Hierarchy.

Incineration has no place in a sustainable waste management plan as it is in direct contravention to resource conservation, a fact that is illustrated by the following points,

• Thermal treatment 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. It is merely stated that combustible wastes will be incinerated. According to Table 10.1, of the plan, 59.4% of municipal waste will be incinerated in the year 2014.

According to the EPA’s handbook on waste prevention, potentially more than two thirds of municipal waste can be reused or recycled.

Clearly waste that is recoverable will be going to incineration in 2014.

According to a waste composition study in the UK, over 40% of waste is recyclable and 30 – 40% can be composted. It illustrated that the quantities that may be incinerated 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.

Incineration may be placed higher than landfill on the waste hierarchy, due to the energy recovery option. However,

• Jones in "Mass Balance and the UK economy" pointed out that 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 is reiterated by the a recent report by the European Comission, which asserts that in general recycling is preferable to incineration in energy terms.
• Recycling aluminium 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 energy which 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 plan compares the environmental consequences of the three proposed scenarios using parameters specified in Section 10.4.1, of the plan. However, it is the contention of the Waste Working Group that these parameters are not adequate.

No consideration is given to the toxicological effects of incineration.

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.

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.

• The air pollution consequences of incineration in the form of dioxins, heavy metals, dust particles and acid gases with their damage to immune system capacity/foetal development, nervous system, heart and respiratory systems respectively have been well documented.
• According to recent EEA report, a common factor for all incineration plants is that the residues are highly contaminated and in most cases classifies as hazardous waste. Unless treated further the pollutants are also very soluble and the waste is therefore difficult to store in landfills. The bottom ash produced by the incineration process contains toxins which have been converted from a state less liable to leach - unburnt waste - into a form which is more liable to leach.

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

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

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

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

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

• 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 tonne 400,000 tonne/year incinerator, is estimated to cost up to 48,000,000 ECU/year.

• 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.

• Remedial technology may be fitted to the incinerator, which captures some of the toxic emissions from the smoke but concentrates them in the ash. Ironically, this means that the better the air pollution control, the more toxic the ash. Incinerators will therefore increase the amount of hazardous waste produced in the region.

• 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

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.

It is recommended that the authority invokes the Precautionary Principle in relation to the introduction of incineration to the region.

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.

Landfill is also not without its environmental and health effects.

The Swedish EPA, outlined some of the environmental risks associated with landfill as

• risk of leaching of metals and poorly degradable substances,
• mixing of organic and inorganic materials having different leaching times,
• landfill gas.

Further effects of landfills are

• a study by the New York State Department of Health reports that women living near solid waste landfills where gas is escaping have a four-fold increased chance of bladder cancer or lukemia. The Department tested for VOCs escaping from 25 landfills and reported finding dry cleaning fluid (tetrachloroethylene or PERC), trichloroethylene (TCE), toluene, 1,1,1-trichloroethane, benzene, vinyl chloride, xylem, ethylbenzene, methylene chloride, 1,2-dichloroethane and chloroform in the escaping gases.
• A 1995 study of families living near a large solid waste municipal dump near Montreal, Quebec found a 20% increased likelihood of low birth weight among those most heavily exposed to gases from landfill.
• At least five studies have reported finding an increased chance of birth defects among babies whose parents live near a landfill. In Wales the chance of birth defects were doubled among families living near the Nant-y-Gwyddon landfill.
• Landfill sites also contribute to the destruction of habitats.
• Landfills cause pollution of both surface and ground water.

The environmental problems associated with both landfill and incineration have been well documented and in the opinion of the Waste Working Group should be included in a holistic examination of the environmental effects of the strategies proposed by the authority.

Section 10.3.1of the plan states that, "in developing the scenarios, the maximum diversion of waste from landfill was a primary objective. However not all waste is recyclable nor is it possible to achieve 100% sorting efficiency at producer level. For this reason bulk reduction methods had to be considered to achieve the objective of maximising diversion from landfill".

The possibility of reducing, reusing and recycling waste at levels far beyond the targets set by this plan has been illustrated within this submission.

It is also important to note that incineration does not eradicate the need for landfill. According to Table 10.1, 40.2% of industrial waste generated will go to landfill in 2014. Although only 3.4% of municipal waste will go to landfill in 2014, 59.4% will go to incineration. This is waste which potentially can be reduced, reused or recycled and therefore equates to a large amount of resources literally going up in smoke. It has also been illustrated that incinerators do not make waste disappear, they reduce it to ash and to atmospheric emissions, both of which are potentially hazardous.

Table 10.2 of the plan, indicates that the residues from thermal treatment going to landfill is estimated to be 10,240 tonnes in 2014. This is 4% of the total municipal and industrial waste going to the plant (calculation based on tonnages given in Table 10.1).

However the Waste Working Group is unclear as to why such a small tonnage of residue is left to go to landfill.

According to the South-East Waste Strategy Study, for every 100 tonnes of feedstock about 20-25 tonnes of bottom ash or clinker and 1 or 2 tonnes of fly ash are produced.

As the input to the incinerator in the Limerick/Clare/Kerry region in 2014 is 255,683 tonnes, (see Table 10.1) and using the information given above, it can be calculated that between 53,693 and 69,034 tonnes of residue will need to be landfilled in 2014.

The South East report also states that the volume of the residual material is equivalent to 10% of the incoming feedstock. However it should be noted that the 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.

According to Section 15.1.1 of the plan, investment in incineration is 48.2% of the total cost. Also according to the thermal treatment study for the Mid West, the average treatment cost for a Waste to Energy plant varies from £40 sterling per tonne in Denmark to some £70-80 sterling in the Netherlands and Belgium and is as high as £120-130 in Germany and Switzerland. These massive variations are accounted for to some extent by a variation in standards. Another Directive to further reduce emissions is being discussed within the EU and will increase the cost of this option even further, perhaps by as much as £9 per tonne. It is the contention of the Waste Working Group that such vast amounts of money would be more effective spent on reduction and recycling initiatives, which as outlined within this submission are not only the better environmental options, but also the best economic options.

3. Conclusions and Recommendations

In the opinion of the Waste Working Group, the Limerick/Clare/Kerry draft waste management plan is focused on the least favourable / sustainable options in the waste hierarchy. For sustainable development, it is imperative that the authority reverses this and focuses on a plan which involves a positive approach focused on source reduction, reuse, recycling, composting coupled with financial incentives.

As a prerequisite to action, it is recommended that the authority effectively researches the many excellent strategies that are in place in many countries, some of which are outlined within this submission, though they are far to numerous to be comprehensively reported.

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, thirteen district and city councils have joined a national pilot project originally designed for ten, and seven more authorities are poised to make a commitment to reducing 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"

Throughout this submission, it has also been illustrates that the more sustainable options are not only beneficial for the environment but are also the more economically viable options.

Recommendations have been given throughout the submission as to how the authority can move forward in a more sustainable direction. These include creating the conditions for reuse, recycling etc., to outcompete disposal options, using instruments such as market creation and a differential charging system.

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

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

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

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

It is acknowledged that progress towards a sustainable waste management/ resource recovery system would be greatly facilitated by programmes orchestrated on a national level. It is recognised within the plan that the authority has significant lobbying potential with respect to national government. It is therefore recommended that the authority presses for legislative and economic initiatives which would greatly facilitate a resource recovery system within the region.

These initiatives could include,

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

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

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

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

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

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

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