WASTE WORKING GROUP
C/O Earthwatch – Friends of the Earth Ireland & VOICE,
7 Upr., Camden St., Dublin 2.
Ph: 01 - 4785140
To: The Midlands Regional Authority
Re: Submission to the Midlands Regional
Waste Management Plan, 2000.
Date : 10th April 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
|
Section
|
Title |
Page |
|
Executive Summary |
3 |
|
|
1. |
Introduction |
6 |
|
2. |
Analysis of the Waste Management Policy for the Region |
6 |
|
2.1 |
Can National Targets be met without the introduction of incineration? |
7 |
|
2.2 |
Incineration - a method of ‘recovery’? |
14 |
|
2.3 |
Incineration – a more desirable option than landfill? |
15 |
|
2.4 |
Will incineration significantly reduce landfill requirements and appease the public? |
17 |
|
2.5 |
Incineration – a disincentive for reduction and recycling? |
19 |
|
2.6 |
The economics of incineration in the Midlands – what are the real costs? |
21 |
|
3. |
Why waste management must become synonymous with resource conservation |
22 |
|
4. |
The Midlands Regional Waste Management Plan prioritises incineration at the expense of reduction and recycling. |
25 |
|
5. |
Essential actions for waste reduction |
28 |
|
6. |
Conclusions and recommendations |
32 |
Notes
Within the body of this submission,
Executive Summary
It is the contention of the Waste Working Group that the function of this plan is to lay the groundwork for the development of a truly sustainable waste management/ resource conservation and recovery system in the Midlands region in line with Ireland’s commitments to sustainable development. In order to achieve sustainable development waste management cannot be decoupled from resource conservation and recovery. The focus of the Midlands Waste Management Plan must shift from methods based on ‘getting rid of rubbish’ to processes that will prevent wastage and conserve natural resources. To achieve this the plan must be firmly focused on the upper part of the EU waste hierarchy, which states that prevention and minimisation of waste should be followed by reuse, repair and recycling.
However all three scenarios proposed by this plan are focused on the least sustainable options as outlined by the EU waste hierarchy. The source reduction options - prevention and minimisation - are ignored in all three and the targets set for recycling and composting are low compared with what has been achieved internationally within the same, and shorter, time periods. The scenario favoured by the authority proposes to recycle 34.6% and incinerate 51% of municipal and industrial waste generated in the year 2013 and landfill the remaining 14.6% plus the residues from the various treatment processes. This illustrates that the plan concentrates 65.6% of effort on how to dispose of waste and 100% on reactive measures to deal with waste once it has been generated
In relation to source reduction the plan focuses mainly on educational initiatives. Whilst education is an important part of any plan, no measures have been taken to stabilise and in the longer term reduce, the amount of waste generated within the midlands region in line with the targets set out in Ireland’s strategy for sustainable development. It is recommended that the authority develops a plan of action in relation to source reduction.
In relation to recycling
On analysis of the three ‘alternate’ scenarios proposed, it is clear that the only significant difference between them is incineration. The evident bias towards incineration is a serious concern of the Waste Working Group. The threats that incinerators pose to human and environmental health have been well documented. In addition incinerators are in direct contravention to a waste plan based on the principles of sustainable development. Incinerators serve as ‘black holes’ for vast amounts of potentially recoverable resources and recreate the ‘out-of- sight, out-of-mind’ approach evident with landfill. If the authority chooses to introduce incineration to the region, they are deferring the waste problem rather than attempting to solve it. Also as incinerators require a steady amount of waste for efficient operation, it is the concern of the Waste Working Group that such a measure will negatively impact on development of recycling and other material recovery initiatives within the region.
It is the contention of the Waste Working Group that
International experience has shown that it is more than possible to meet and indeed surpass the target for diversion from landfill set out by the National policy by positive ways that are conducive to sustainable development. It is recommended that as a prerequisite to action, the authority considers the numerous positive systems in place internationally which prove that it is more than possible to meet and indeed surpass the targets set out by National Policy and in shorter time periods. Subsequent to this it is recommended that the authority develops a new scenario, one which combines waste reduction at source with reuse, repair, recycling together with financial incentives. Only when such a strategy has been researched and developed will the authority be equipped to make an informed decision on the way forward for the Midlands region.
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 therefore 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 conservation and recovery system in the Midlands region. It is the concern of the Waste Working Group that the Midlands regional authority is not doing this and therefore deferring the waste problem rather than attempting to solve it.
Therefore the waste management policy of the authority is examined in this light.
2. Analysis of the Waste Management Policy for the Region.
Section 1.5.1 of the plan states that the underlying philosophy behind the Irish Government’s Waste Policy is the Waste Management Hierarchy, which sets out that prevention and minimisation of waste should be followed by reuse, recycling and recovery. However all the 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 9.2.1 of the plan),
Scenario 3 is the one preferred by the authority.
It is clear from Table 9.1 of the plan, that the only significant difference between these three scenarios is thermal treatment /incineration. There is also a slight difference of 0.6% between the ‘maximum realistic recycling rate’ and that given for scenario 2 in relation to municipal waste.
It is clear that the authority is focusing on incineration as the way forward for waste management in the region.
It is the contention of the Waste Working Group that the three scenarios presented do not show a full range of alternatives and are not conducive to informed decision making.
It is imperative to remember that authority does not have to choose between landfill and incineration as a way forward. It is more than possible to drastically reduce reliance on landfill by sustainable means as is outlined within this submission.
Section 9.3.2 of the plan states that the technical assessment outlined in the plan ‘indicates that thermal treatment will be required to satisfy the National Policy requirement for diversion of waste from landfill. It will also provide a cost effective treatment system in the context of the Midlands Region, will greatly increase the security of the waste management system and with energy recovery is favoured on environmental criteria compared with landfill disposal.’
Information provided in this submission will prove that
2.1 Can National Targets be met without the introduction of incineration?
Section 9.2.5 of the plan states that ‘the ambitious targets set out in the new Irish Waste Policy statement cannot be achieved in practice without thermal treatment’.
In relation to municipal and industrial waste the targets set out in the above mentioned policy statement are:
These targets are to be achieved over a 15 year period.
As previously stated the authority considers three scenarios with a view to achieving these targets. The first scenario put forward by the authority proposes ‘maximum realistic recycling’ and landfill. Section 9.2.2 of the plan states that this scenario fails to meet the national waste target of 50% diversion of municipal waste from landfill. However, no such target exists in the National Policy document and it is not mentioned elsewhere in the plan. The target for recycling of municipal waste is 35% to be reached over a 15 year time period.
The authority is suggesting that over a 15 year time period, 37.6% is the ‘maximum’ amount of municipal waste that can be recycled. This section also states that this scenario – which has the lowest cost - does not succeed in diverting 50% of household or 65% of biodegradable waste away from landfill. However a breakdown showing the recycling/ diversion rates for these individual waste categories is not shown so it is unclear how these conclusions were drawn. Also it is the contention of the Waste Working Group that these targets can be met and indeed surpassed, within the given time period, without the use of thermal treatment.
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 and recovery.
There are numerous examples of reduction, reuse and recycling strategies implemented internationally, that have far exceeded these targets set and in shorter time periods.
Examples of these include,
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.
Section 9.3.2 also states that on its own composting ‘would not, without thermal treatment (even together with other recycling initiatives) achieve the full requirements of the landfill directive of 65% diversion of biodegradable waste away from landfill. Experience in other countries indicates that 55% is the level of diversion which is practically achievable’.
However the plan does not state what countries limit the recycling of organic waste to 55%. For example the municipality of S. Giustina in Colle, Italy achieved a reduction in organic waste presented for collection of 71% of the original municipal organic waste by home composting alone. 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.
The plan contains no target for the reduction of the biodegradable waste stream or indeed for any waste stream.
The plan contains no strategy for material recovery by means of reuse and repair.
If the authority ignores these viable options, it is disregarding an important part of a sustainable waste management system and a method to divert substantial amounts of waste away from landfill.
Reuse 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.
- an estimated 14 million kW-h was saved (enough to power 2300 homes);
- 1200 tons of scrap metal was recovered for recycling;
- 23,150 cubic yards of landfill area was saved; and
- 45 full and part-time jobs, with a payroll of US$500 000, were created.
This case study, which saved both electricity and waste, demonstrates the opportunities for partnership approaches.
These last two examples should be useful to the authority in light of the pending Waste from Electrical and Electronic Equipment (WEEE) Directive.
In relation to industrial waste the target for recycling of this waste stream is 26.3% in 2013. However, according to the recently published National Waste Database, the current levels of recovery for industrial waste is 26.6%. It is therefore assumed that the authority has no plans to increase the recycling rate in the industrial sector. Creating the conditions whereby industrial producers plan for source reduction and recovery is imperative as the producers of products have ultimate control over materials and product design.
For example, as a result of the German Packaging ordinance, packaging redesign has seen the disappearance of secondary packaging from many products. A major German producer found that 98% of all "secondary" packaging – boxes around toothpaste tubes, plastic wraps around ice-cream cartons – is simply unnecessary. They also state that most industrial and some food packaging can be promptly cut by 20-50%.
Producer responsibility has proved to be an extremely effective tool to increase source reduction measures and recovery in industry. On the introduction of producer responsibility into the Netherlands, J.Alders, the Environment Minister stated,
"in our opinion, the incentive is necessary for manufacturers to produce their products in a way that it can be easily recycled and to limit the amount of packaging. Only then will there be markets for products based on secondary raw materials"
Section 10.12 outlines the method by which the authority plans to develop markets for recycled products. The authority plans to review their purchasing policy in favour of recycled products and also use recycled aggregate and compost in public works undertaken by the authority. The authority also plans to initiate a Research and Development programme aimed at developing new products from waste materials. The Waste Working Group welcomes these plans but would also like to suggest further actions which the authority can take to aid the development of material recovery in the Midlands region. These actions include,
The authority could also consider the experiences of the state of California, USA and Canberra, Australia.
It is clear from this section and the plan as a whole, that the main focus has been placed on the introduction of thermal treatment /incineration/waste to energy. It is the concern of the Waste Working Group that equal, and preferably more, effort has not been placed on examination of the positive options such as source reduction, material recovery and composting. This plan is firmly focused on shifting a dependency on landfill to a dependency on landfill and incineration.
The Waste Working Group is opposed to the use of incineration/thermal treatment for numerous reasons which will be outlined. 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. It will be shown that incinerators are detrimental to environmental and human health and are in direct contravention to 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 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 submission. 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.
2.2 Incineration as a method of "recovery"?
Section 9.2.5 of the plan states that incineration ‘is a form of energy recovery, hence it is higher in the National and EU Waste Hierarchy than landfill’.
These facts further the argument that incineration is an end of pipe disposal option akin to landfill and the energy recovery option can mask this.
2.3 Incineration – a more desirable environmental option than landfill?
Section 9.2.5 of the plan states that incineration ‘is
a form of energy recovery and is a more desirable environmental option than landfill (provided hazardous wastes are diverted from the process)’.
The plan compares the environmental consequences of each scenario in Section 9.2.4. However it is the contention of the Waste Working Group that these parameters are not adequate. For example no consideration is given to the toxicological effects of incineration.
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 organochlorines plus mercury and other metals.
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.
It is clear therefore, that whether the feedstock is classified as hazardous or not is irrevelant.
"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".
It is recommended that the authority seriously considers the adverse effects of incineration and invokes the precautionary principle in this regard.
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.
2.4 Will incineration significantly reduce landfill requirements and appease the public?
Section 9.2.5 of the plan states that incineration ‘achieves substantial bulk reduction in final waste volumes having regard to the limited availability of landfill capacity in the Region and the high level of public resistance to new landfill development’.
The following table shows the primary route which municipal and industrial waste generated in the region will take (assuming scenario 3 in place).
|
Waste Category |
Recycling (tonnes) |
Recycling (%) |
Thermal (tonnes) |
Thermal (%) |
Landfill (tonnes) |
Landfill (%) |
Total (tonnes) |
|
Municipal |
72,726 |
37.6 |
113,982 |
59.3 |
5,941 |
3.1 |
192,119 |
|
Industrial |
19,680 |
26.3 |
22,101 |
29.5 |
33,151 |
44.2 |
74,931 |
|
Total |
92,406 |
34.6 |
136,083 |
51.0 |
39,092 |
14.6 |
267,050 |
Table 1. Proposed recycling and disposal methods for waste generated in the Midlands region in 2013. (calculations performed on the basis of the data presented in Table 9.1*)
* It should be noted that the tonnages given in Table 9.1 differ from those given in Tables 10.13 and Table 12.2 of the plan and it is unclear why these discrepancies appear. Table 9.1 was chosen arbitrarily by the author.
In the year 2013, the authority plans to direct 34% of the municipal and industrial waste stream towards recycling, 51% to incineration and 14.6% to landfill. However this is the primary route which waste generated will take. Consideration must also be given to ‘secondary’ waste that is generated by treatment processes such as incineration. This information is given in Table 9.2 of the plan, which indicates that 77,333 tonnes of waste will be landfilled in 2013.
However the Waste Working Group questions the tonnage given for residue from landfill.
The tonnage given for residue from the incineration process is 5,669 tonnes in 2013 according to Table 9.2. However it is unclear how this figure was calculated. According to information given in the North East Regional Waste Management Plan burning waste reduces its mass to 30% of the original. Using this figure it can be calculated that the incineration process will produce 40,825 tonnes of residual material that will go to landfill. The corrected situation is shown below.
Recycling – 35.9% Incineration 48.5% Landfill 15.5%
92,406 tonnes 136,083 tonnes 39,092 tonnes
+ 15,520 tonnes of residual material from processes other than incineration.
+ 40,825 tonnes residue
It becomes clear that incineration does not eradicate the need for landfill.
Incineration also effectively increases the amount of potentially hazardous waste. 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.
Also the remedial technology which may be fitted to the incinerator to capture some of the toxic emissions from the smoke, concentrates these toxics in the ash. Ironically, this means that the better the air pollution control, the more toxic the ash.
In relation to public resistance to new landfill development, equal if not more resistance can be expected from incineration. Planned incinerators have met with huge public opposition leading to their decline in various countries worldwide. For example as a result of public resistance no new incinerators have been built in the USA or Canada for a number of years and they have been banned in the Philippines. They have also been banned in Australia on the grounds that they are ‘socially unacceptable’. However it is important to note that it is often the very same citizens that have fought proposed incinerators or landfills that are most helpful to the authorities when they embark on low tech locally based solutions.
2.5 Incineration – a disincentive for reduction and recycling?
Section 9.2.5 of the plan states that ‘thermal treatment will not compromise the meeting of waste recycling targets and will achieve higher waste recovery resulting in lower landfill requirements’.
However according to the EPA’s handbook on waste prevention, potentially more than two thirds of municipal waste can be reused or recycled.
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 option because ‘nowadays incinerators usually need to be huge to be economically viable’. 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.
Clearly waste that is recoverable will be going to incineration in 2014.
2.6 The economics of incineration in the Midlands – What are the Real costs?
The proposed thermal treatment plant for the region will have a capacity of 100,000 – 150,000 tonnes per annum which is relatively small. It is widely recognised that due to the enormous expense of pollution control equipment incinerators have to be huge to be economically viable as is pointed out in the previous section. It is recommended that the authority devises a strategy that will prevent or minimise this amount of non recyclable or compostable waste.
The Waste Working Group questions whether the ‘real costs’, of each scenario were considered during the economic comparison in Section 9.2.3 of the plan. According to the Christchurch, New Zealand waste authority, the ‘real costs’ of waste management include social, environmental and economic costs. The authority has not considered true environmental or social costs. The inadequacy of the environmental assessment of the plan has already been discussed. This is furthered by the fact that 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
Yet another health problem associated with incineration, that has not been previously mentioned is the 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.
According to Section 14.1.2 of the plan, incineration requires the largest investment by far - IR 38 million. Also according to the thermal treatment study for the Mid West Region the average treatment cost for a Waste to Energy plant varies from GBP £40 per tonne in Denmark to some GBP £70-80 in the Netherlands and Belgium and is as high as GBP £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 GBP £9 per tonne.
It is the contention of the Waste Working Group that such vast amounts of money would be more effective spent on source reduction and material initiatives, which as outlined within this submission are not only the better environmental options, but also the best economic and social options.
The plan states that scenario 1 (which excludes incineration) has the lowest cost but does not meet national targets. This submission has already shown that these targets can be met without the use of incineration.
It is recommended that the authority consider a scenario that is not suggested in the plan - one which combines source reduction, reuse, repair, recycling and composting together with financial and economic incentives as the way forward for the midlands region.
It is a concern of the Waste Working Group that the authority has not considered the effects of the plan on sustainable development. Therefore the importance of a sustainable waste management/resource conservation system is introduced below.
3. Why waste management must become synonymous with resource conservation.
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
Resources are extracted, used to manufacture a product that is bought by a consumer and subsequently thrown away. On the right hand side of this equation the rapidly increasing amounts of waste generated have reached critical levels. In fact, industrial development and its associated waste products has accelerated at a rate far surpassing the adaptive capacity of natural systems and if wastes continue to be produced at current or increased volumes, then any ‘management’ system will eventually become overwhelmed.
On the other side of the equation, the rapid depletion of the Earth’s natural resources is endangering the supply for future generations. Global calculations show that humans are consuming over one third more than nature can reproduce. Of course, for industrialised countries this rate is even higher.
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 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.
To ‘close the material loop’ there needs to be an incremental reduction in the amount of virgin resources feeding into the production chain coupled with a continuous decrease in waste produced. This is shown diagramatically in Figure 1 below.
Figure 1: ‘Closing the Material Loop’-
The sustainable approach to ‘waste management’ / resource conservation and recovery.
4. The Midlands Regional Waste Management plan prioritises incineration at the expense of reduction and recycling.
Figure 2 below illustrates that in relation to municipal and industrial waste, the proposed scenario concentrates 65.6% of effort on the right hand side of the equation i.e. how to dispose of the waste and 100% effort on reactive measures proposed to deal with waste once it has been generated.
Figure 2. Targets set by the Midlands Regional Authority for the recycling, incineration and landfill of municipal and industrial waste.
*This figure relates to waste immediately directed to landfill and does not account for residues from any treatment process.
It is clear that in the year 2013 more material will be incinerated than recycled. This is an inversion of the EU Waste Hierarchy.
However, as illustrated within this submission, sustainable development requires reduced resource usage and increased resource recovery – not just diversion from landfill.
Numerous examples have been given to illustrate how the authority can substantially increase material recovery and composting rates in the Midlands region. However it must be remembered that recycling alone is not the answer to Ireland’s waste problems. Recycling plays a crucial role in a sustainable system but it needs to be viewed as playing a complimentary role to source reduction as the amount of waste generated in the first place must be curbed.
Prevention and minimisation are both source reduction options and it is for this reason that they are the two most favourable options on the EU Waste Hierarchy.
None of the three scenarios proposed by the authority include these options. The prevention of waste is the single most important initiative towards achieving sustainable waste management. Taking a preventative approach involves acting at source. For example, prevention requires changes in processes and products - designing non-toxic products from materials that can be safely recycled or composted - in order to avoid the generation of waste that is disposed. It also therefore benefits natural resource conservation. It encourages the exploration of safer alternatives and the development of clean and sustainable products and technologies.
Waste prevention also benefits the producers of products as it represents a viable opportunity to achieve savings in terms of the costs of raw materials, energy, disposal and recovery.
Section 5.3 states that ‘to date, waste minimisation initiatives in the Midlands region have been primarily aimed at diverting waste from disposal by encouraging the use of recycling "bring" facilities and home composting’. It is imperative to recognise that prevention and minimisation do not mean diversion from landfill, recycling or composting.
|
Source reduction is the only practice that is preventative as it minimises the creation of materials and toxics. This proactive approach also reduces material and energy use. Recycling and composting are reactive methods for recovering and managing materials after they are produced. These recovery options may be used to minimise the amount of waste going to landfill, but they do not mimimise the amount of waste generated. |
It is recognised that recycling and composting play a crucial part in any sustainable waste management / resource recovery plan, but they are no substitute for reduction at source, the necessity of which cannot be underestimated for without it everything else can only be a second best option.
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.
The necessity for prevention and minimisation of waste is recognised in Ireland’s strategy for sustainable development. This states that 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%.
The goal is therefore to reduce municipal waste generation in Ireland to 280 kg/year per capita by 2010.
The importance of this target is also recognised in the government’s policy statement "Changing our Ways", which 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 at present is 112,217 tonnes ( Table 3.1 of the plan). As the population of the region is 263,563 (Section 2.1 of the plan), the estimated municipal waste arisings is 0.43 tonnes/ year per capita which is equal to 430 kg/year per capita. The generation of municipal waste in the region is already 23% above that required stabilisation level.
Calculations performed on the basis of the information given in Section 3.2.1, and Table 9.1 of the plan show a marked increase in municipal waste generation as seen in Table 1, below.
|
Waste Category |
1998* |
2014 |
% Increase in Waste Generation |
|
Municipal |
112,217 |
192,119 |
71.2 |
Table 1 - Percentage increase in waste generation for municipal waste, between the years 1998 and 2014.
* no exact year is given in the plan in the plan
for information provided in the Table 9.1 or Section 3.2.1 of the plan. The author has taken 1998 as the baseline year as this corresponds to some of the data presented in these sections and also relates to the beginning of the 15 year plan.Note: It is not possible with the information given to perform the same calculation for industrial waste as the figure give for current levels includes industrial sludges and it is unclear as to whether the figure presented for industrial waste generated in 2013 also includes sludges.
The policy of the Midlands Regional authority in relation to waste prevention and minimisation is outlined in Section 10.1.
The projected population for the region in the year 2013 is 337,564 (calculation performed on the basis of information given in Section 7.2). Therefore in 2013 the estimated amount of municipal waste generated per capita is 0.57 tonnes/annum which is equivalent to 570 kg/annum. It has already been stated that the goal for municipal waste generation by the year 2010 is 280 kg/capita per annum.
Therefore in the year 2013, the Midlands region will generate 104% more municipal waste than the target set in the Sustainable Development Strategy for Ireland.
According to the 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.
5. Essential actions for waste reduction
On analysis of Section 10.1, which outlines the waste prevention and minimisation policy of the authority, it is clear that the authority plans to undertake what is largely an education exercise in relation to source reduction.
Whilst it is recognised that education is an essential part of a sustainable waste management system it is recommended that the authority taken action to ensure that the targets set in the sustainable development strategy for Ireland are met.
Actions that the authority can take include:
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,
In relation to industrial and commercial sectors the authority can act by,
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 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.
6. Conclusions and Recommendations
In the opinion of the Waste Working Group, the draft waste management plan for the Midlands region is focused on the least sustainable options in the waste hierarchy. It is imperative that the authority reverses this and produces 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 placeinternationally, some of which have been outlined here, though they are far to numerous to be comprehensively reported within the scope of this submission.
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 illustrated 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 also recommended that the authorities develop source reduction and material recovery strategies. It is imperative that the authority puts into place effective source reduction plans which will stabilise and in the longer term reverse waste generation in the Midlands region.
It is recognised that no matter what route the authority takes, the need for landfill will not be eradicated within the duration 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 that,
" 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."
It has also been advocated 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. The Waste Working Group recognises 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,
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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