WASTE WORKING GROUP

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

7 Upr., Camden St., Dublin 2.

Ph: 01 - 4785140

To: The North-East Regional Authority

Re: Submission on the Draft Waste Management Plan for the North-East Region, 2000.

Date : 12^th May 2000.

Author: Anne-Marie Cunningham

The Waste Working Group is a coalition of environmental NGOs including VOICE (of Irish Concern for the Environment) and Earthwatch – Friends of the Earth Ireland.

Index

Notes

Within the body of this submission,

• The Draft North-East Regional Waste Management Plan is referred to as "the Plan",
• The North-East 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.

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 North-East 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 North-East 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 35.9% and incinerate 48.5% of municipal and industrial waste generated in the year 2014 and landfill the remaining 15.5% plus the residues from the various treatment processes. This illustrates that the plan concentrates 64% 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 North-East region in line with the targets set out in Ireland’s strategy for sustainable development. It is recommended that the authority sets such a target and develops a plan of action in relation to source reduction.

In relation to material recovery,

• the plan does not detail the delivery mechanisms by which the targets set for recycling will be achieved. For example, the plan does not provide any information about current or proposed recycling industries in the region or the current market for recycled products. It also does not sufficiently address market development for recycled products.

• the targets set by the authority are quite low compared when compared with what has been achieved internationally.

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,

• it is not necessary to introduce incineration to satisfy national policy requirements,
• incineration is the most unviable option in economic terms,
• energy can be recovered in greater quantities by means which are more conducive to sustainable development.

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 North-East 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 North-East region. It is the concern of the Waste Working Group that the North-East Regional Authority is not doing this and therefore deferring the waste problem of the region rather than attempting to solve it. Therefore the necessity of developing a waste plan based on the principles of sustainable development is discussed.

2. Waste Management in the context of Sustainable Development.

This section highlights the importance of considering the effects that a particular waste management plan will have on the development of sustainable societies and why waste 'management' must become synonymous with resource conservation.

Sustainable development is most commonly described as development that meets the needs of the present without compromising the ability of future generations to meet their own needs. Sustainable development thus aims to improve the quality of human life while living within our ecological means.

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.

Inequitable Use of Global Resources

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 i.e. end of pipe solutions. 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.

The internationally recognised waste management hierarchy, which lists waste management options in order of preference, aims to promote sustainable waste systems. According to this hierarchy prevention and minimisation of waste are the most favourable option. Waste that cannot be prevented or minimised should be reused, repaired, recycled or composted. Energy recovery and landfill are the least favourable options.

The aim therefore is to generate waste plans that are firmly focused on the upper and middle parts of this hierarchy. This would further the development of cyclical production and consumption patterns and thus the advancement of closed loop processes. Unlike options such as landfill or incineration, recycling and reuse result in material being returned to production processes, where the material can be made into the same or similar product from which the material arose or it can be fashioned into something entirely different. This means that for the economy as a whole there is a reduced need for primary extraction, hence resources are saved and there is a reduction in the environmental effects from the production, processing and transport of the raw material, which also results in considerable economic savings. Recovery of energy from waste may appear to have a similar effect, yet on closer examination it becomes evident that this is not the case. Recovering energy from waste by incineration or any other means of thermal treatment can only recover the energy contained within the actual material and of course this can only be recovered once. The energy used up in the extraction of resources, transport etc. cannot be recovered. Conversely this energy can be saved by methods such as reuse and recycling. Although recycling cannot occur indefinitely (for example, due to shortening of fibers in newsprint recycling), recycling can usually take place more than once. There is, therefore, an element of circularity in the recycling process that is absent in the case of incineration and landfill. Also it has been pointed out that sustainable development requires a reduction in raw material usage. Incineration effectively results in these materials ‘going up in smoke’. It is for these reasons that both landfill and incineration are referred to as linear waste management options. It is also for these reasons that within the body of this submission "recovery" is used to denote material recovery mechanisms and does not refer to energy recovery unless otherwise stated.

Incineration – Waste to Energy or a Waste of Energy?

Far more energy is actually saved by recycling materials than burning them due to the fact that significantly more energy is required to produce virgin materials than to recycle. It has been estimated that for every tonne of ‘product’ we buy, ten tonnes of resources have been used in the manufacturing process. Reuse and recycling have a far better energy recovery record, with savings of up to 70-90% despite energy lost in transport and cleaning compared to an expected efficiency of 25% recovery from incineration

This fact is reiterated by the a recent report by the European Commission, which asserts that in general recycling is preferable to incineration in energy terms.

• Recycling aluminum cans in the United States in 1996 saved enough energy to power a city the size of Philadelphia for one year.
• Germany has 53 incinerators burning 14 million tonnes of waste per annum. The burning of this massive amount of waste produces 0.5% of German energy requirements. The incineration of every single atom of waste produced in Germany would provide 1.5% of all German energy requirements.

3. Analysis of the Waste Policy for the Region

The scenario favoured by the authority,

• is focused on the least favourable options according to the EU Waste Hierarchy - incineration, recycling and landfill - and therefore cannot provide a plan conducive to sustainable development.
• concentrates 64% of effort on end-of- pipe linear waste management options and 100% of effort on reactive measures to deal with waste after it has been produced,
• proposes to introduce a technology which will have a detrimental effect on environmental quality

According to Section 8.1 of the plan, the waste policy is focused on reducing dependence on landfill. The scenario chosen by the authority focuses on incineration, recycling and landfill as the mechanisms to achieve this. Indeed all three scenarios are focused on two or all of these options and none includes targets for prevention and minimisation, the two most favourable options according to the EU Waste Hierarchy. Also the targets set for recycling are low compared to what has been achieved internationally as will be illustrated throughout this submission.

The largest categories of non-agricultural waste arising in the region are shown in Table 1 below.

Table 1. Various categories of waste shown as a percentage of the total non-agricultural waste arising in the Region.

Construction and demolition waste is the single largest category of waste arising in the region. While it is recognised that the plan proposes to recycle a very high percentage of this waste stream, 79.8% (Table 2 of the Executive Summary), it should be noted that the Government’s target for recycling of this waste stream is 85% to be reached over the time period of this plan.

The remainder of this submission will focus on the remaining largest non-agricultural waste streams, municipal and industrial waste. Table 2 below shows the targets set by the authority in relation to these waste streams, to be reached over a fifteen year period.

Table 2. The recycling and disposal methods proposed by the authority for waste generated in the North East region in 2014.

On analysis of the waste management policy for the North-East region it is clear that the plan is firmly focused on the lower end of the waste management hierarchy. Figure 2 below shows that the waste management methods that the authority proposes to employ for municipal and industrial waste generated in the region in the year 2014.

Figure 2. Targets set by the North East Regional Authority for the recycling, incineration and landfill of municipal and industrial waste generated in 2014.

Thus, in the year 2014, the authority plans to direct 35.9% of the municipal and industrial waste stream towards recycling, 48.5 % to incineration and 15.5% 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 10.2 of the plan, which indicates that 119,314 tonnes of waste will be landfilled in 2014.

However the Waste Working Group questions the tonnage given for residue from the incineration process to be landfilled.

According to Table 10.2 of the plan, the residue from the thermal treatment process will be 8,475 tonnes in 2014. However it is unclear how this figure was calculated. According to information given in Section 8.3.5 of the plan, burning waste reduces its mass to 30% of the original. The input to the incinerator for municipal and industrial waste alone in 2014 is 211,877. Using the above information, it can be calculated that the incineration process will produce 63,563 tonnes of residual material that will go to landfill.

3.1 Incineration - the wrong solution for the North East Region

The Waste Working Group is firmly opposed to the introduction of incineration to the region for the reasons outlined below.

1. It has been illustrated above that incineration does not eradicate the need for landfill. In fact a symbiotic relationship exists between both waste disposal methods.

2. Incineration will effectively increase the amount of potentially hazardous waste generted in the region.

Section 8.3.5 of the plan, states that the end products of the incineration process are "a sterile inorganic residue" and section 7.1 states that the process will "render residues relatively inert". However whilst the process may render residues inert biologically but not chemically. In fact 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.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.

Also the remedial technology that 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.

3. Incineration is an end-of- pipe waste management option akin to landfill.

An explanation of why incineration is a linear waste management option and how the energy recovery option can mask this is provided in Section 2 of this submission.

4. Incineration has a negative impact on source reduction and material recovery schemes and is in direct contravention to resource conservation.

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.

According to the EPA’s handbook on waste prevention, potentially more than two thirds of municipal waste can be reused or recycled and according to a waste composition study in the UK, over 40% of waste is recyclable and 30 – 40% can be composted. The UK study also 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.

However in the year 2014, 57.1% of municipal waste will be incinerated.

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

5. Incineration is detrimental to environmental and human health.

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. However the plan contains no assessment of the environmental or health impacts of any of the suggested scenarios.

The plan states that a separate report on the feasibility of thermal treatment for the region has been completed and this considers the environmental aspects of this technology. However it is imperative that for informed decision making, a comprehensive environmental analysis for the various scenarios be provided within the plan.

A number of negative environmental effects associated with incineration are given below.

• According to the Swedish Environmental Protection Agency, during waste incineration, pollutants are released both into the air and water from wet scrubbers as well as via the slag and flue gas cleaning residues formed during incineration. These pollutants include particulates, hydrogen chloride, PAHs, dioxins and other organo chlorines plus mercury and other metals.

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

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

The 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.

• The Dutch National Institute of Public Health and Environmental Protection estimates that waste incinerators can be held responsible for over 80% of all dioxin emissions into the air in the Netherlands.

• Many toxic substances emitted from municipal waste incinerators, including certain dioxins and furans, cadmium, lead and mercury, are known to disrupt the endocrine system (the body’s hormonal system). The effects of endocrine disruptors on wildlife have been shown to include thyroid dysfunction in birds and fish, decreased fertility in birds, fish, shellfish and mammals, metabolic abnormalities in birds, fish and mammals, behavioural abnormalities in birds, fish and mammals, demasculisation and feminisation of male fish, defeminisation and masculinisation of female birds and fish and compromised immune systems in birds and mammals.

• A recent report for the European Commission suggested that for every tonne of municipal waste burnt between GBP£21 and GBP £126 worth of environmental and health damage is caused

• Another health problem associated with incineration is the particularly fine particulates that they produce. A major study found that there is a much stronger statistical link between fine particulates and mortality rates from lung cancer and cardiopulmonary diseases than any of the other major forms of pollution measured (eg. Carbon Monoxide and Sulphur Dioxide). The total health damages due to chronic effects of primary and secondary particulates alone, from a single 400,000 tonne/year incinerator, is estimated to cost up to 48,000,000 ECU/year.

• The later two examples highlight the ‘hidden costs’ associated with thermal treatment and the real costs of this technology should be incorporated into the economic assessment of the chosen scenario.

It is recommended that the authority seriously considers the adverse effects of incineration and invokes the Precautionary Principle in this regard.

The Precautionary Principle

According to the Wingspread Statement on the Precautionary Principle, "when an activity raises threats of harm to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically. In this context the proponent of an activity, rather than the public should bear the burden of proof. The process of applying the precautionary principle must be open, informed and democratic and must include potentially affected parties. It must also involve an examination of the full range of alternatives, including no action."

The principle of precautionary action has 4 parts, 3 of which are,

1. people have a duty to take anticipatory action to prevent harm,

2. the burden of proof of harmlessness of a new technology, process, activity or chemical lies with the proponents, not with the general public,

3. Before using a new technology, process or chemical, or starting a new activity, people have an obligation to examine "a full range of alternatives" including the alternative of doing nothing.

• Another negative environmental impact of incineration is its global warming implications. A recent report issued by the USEPA showed that reduction at source and recycling make a major contribution to lowering greenhouse gas emissions and burning waste in an average waste-to-energy plant causes higher greenhouse gas emissions than disposal to landfill.

Although thermal treatment plant are often referred to as "state of the art" facilities, operating to high standards, it has been shown that levels of emissions achieved under laboratory conditions or even in a commercial incinerator being inspected by prior arrangement by a regulatory authority are likely to be far lower than those routinely emitted during normal operations. This was demonstrated in the US in 1990 when a joint task force of the EPA and the Occupational Safety and Health Administration conducted 62 unannounced inspections at 29 waste incinerators. No less than 69% of the inspections resulted in citations for violations.

Also, no matter how "state-of-the-art" or "safe" an incineration plant may be, it still has no place in a sustainable waste management system as it effectively serves as a ‘black hole’ for a vast amount of resources and is not conducive to closing the material loop. Vast amounts of time and money are focused on trying to perfect the destruction of discarded resources, thus deferring the real solution which is how to recover them. Also the Government’s policy document recommends the development of recovery facilities that are environmentally beneficial and it is has been shown that incineration has detrimental environmental consequences. It is therefore recommended that the authority rejects the proposed scenario and develops a new scenario that is beneficial in terms of environmental protection and is conducive to sustainable development.

4. Alternative Scenarios

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. The development of such a scenario is essential for informed decision making.

The three alternative scenarios proposed by the authority are outlined in Section 8.2.

However all three scenarios are focussed on the lower end of the waste hierarchy and therefore cannot provide the basis for a plan which would be conducive for sustainable development. It is therefore 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 North-East region.

For example, the official waste policy of Canberra Australia is to create a waste free society by 2010. This policy of turning all waste into resources – or zero waste – has also been embraced by New Zealand. Here, twenty two district and city councils have joined a national pilot project originally designed for ten, committing to reduce waste to zero by 2015.

At a conference launching this project Warren Snow, from the Zero Waste New Zealand Trust, stated that, "councils can see that reducing waste to zero is no longer a theoretical exercise. Most of the processes already exist and we have more than enough case studies of community based recycling and waste reduction projects achieving dramatic results" Canberra has already reached a 60% diversion rate from landfill without the use of incineration.

4.1 Source Reduction

The authority has not set targets for waste reduction at source and has not comprehensively developed a plan of action in this regard.

Prevention and minimisation are both source reduction 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.

However none of the three scenarios proposed by the authority include the option of waste reduction at source. The waste prevention and minimisation policy of the authority is focussed on awareness raising in the various sectors. Whilst it is recognised that education will plan a critical role in the effective implementation of the plan, stronger actions need to be taken to curb the rapidly increasing growth of waste in the region.

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.

According to Ireland’s strategy for sustainable development a goal is to stabilisemunicipal waste arisings generally at 350kg/year per capita, and in the longer term, to 2010, to reduce these wastes by 20%.

Also the Irish 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 at present, is 174,395 tonnes (Table 3.1 of the plan). As the population of the region is 306,155 (Section 1.1 of the plan), the estimated municipal waste arisings is 0.57 tonnes/ year per capita which is equal to 570 kg/year per capita.

Table 2 of the plan summary shows a marked increase in municipal waste generation to 305,902 tonnes by the year 2014. As the population of the region is expected to increase to 330,633 over the plan period, the municipal waste arisings can be predicted to increase to a level of 925 kg/year per capita. This is 264% more than the target set by the strategy for sustainable development.

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.

In relation to industrial and commercial sectors the authority can act by,

• 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 investigates this and also considers its application to other activities.

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 doing to disposal, over a ten year period, was set. This included a 10% waste prevention target.

They plan to achieve this by urging the public to:

· Reduce consumption of luxury and throw away items,

· Choose unpackaged and minimally packaged products; and

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

The First Annual Waste Reduction plan for London emphasises the need to move away from a sole reliance on increasing recycling and composting as the solution to waste problems. The idea behind the plan is that by both reducing the amount of waste generated in the first place and recycling and composting as much as possible of what is produced, the tide can be turned and dramatic cuts in amounts requiring disposal can be achieved. This document sets out an overall strategy for waste reduction at source and lists immediate actions that will start to make a difference.

It is recommended that the authority investigates such waste reduction plans with a view to developing one for the North-East region.

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 people’s 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.

4.2 Material Recovery

The targets set by the authority for recycling of municipal and industrial waste are low when compared with what has been achieved internationally. Also the authority has not detailed the delivery mechanisms by which the recycling targets will be achieved. The importance of reuse and repair as essential elements of a sustainable waste plan is highlighted.

There are numerous examples of reduction, reuse and recycling strategies implemented internationally, that have far exceeded the recovery and diversion targets set by the authority 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 that combined recycling, home composting, reduction, reuse and financial incentives. Over this period the total cost of waste management and recycling - including disposal - dropped by 39%.

• The town of Bellusco, Italy (population 6,000) has achieved 73% diversion from landfill by use of drop-off facilities and a kerbside collection of paper and green waste.

• Novia Scotia, Canada (population 950,000) had over 100 landfills in the province until 1995 when new laws pertaining to the landfilling of waste were introduced. The province has gone from a recovery rate of approximately 8% to 51% in the five year period without building incinerators and 600 jobs were created in the process.

• Examples of successful recovery programmes in the UK include, Daventree (population 80,000) which went from less that 10% recovery rate to 46% in 26 months and 11 Essex districts that have set a 60% recovery rate by 2007. These have also been highlighted as examples of how learning from international experience has speeded up the recovery process considerably.

• A combination of a comprehensive recycling and composting scheme, coupled with charges for each sack or bin of refuse have helped Sidney Township, Ontario to reduce the amount of household waste going to disposal by 69% over a seven year period between 1989 and 1986. All refuse presented for collection must have an attached tag, the price of which covers the cost of refuse collection and tipping. A waste management by-law is in place which identifies material not allowed in the refuse, including household hazardous waste, recyclable material and garden waste. There is no charge for the use of the recycling bin, household hazardous waste depot or garden waste drop-off depot. The municipality collects untagged sacks or bins separately and the generator of the refuse is identified in 70% of cases. The generator is contacted and requested to come to the municipal office to reclaim their refuse. The by-law allows for fines up to $25,000 but this has never had to be pursued. It was also found that as long as opportunities for recycling and composting are widely available, the public will accept User Pay.

• Guelph, Ontario (population 100,000) has reached a 58% diversion rate (67% diversion of wet waste and 51% of dry waste) of household waste using a wet/dry collection system.

Also the proposed scenario does not include a provision for home composting. International experience has shown that home composting has proven to play an valuable role in successful waste management systems, particularly for regions with a large rural population which is the case in the North-east Region. 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.

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 – a key element of a sustainable waste plan

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, which saved both electricity and waste, demonstrates the opportunities for partnership approaches.

• The Digital Computer Centre has a Resource Recovery Centre in Contoocook, New Hampshire, USA. The centre receives all returned trade in digital equipment. The equipment is either refurbished, spare parts are recovered or materials are recovered and recycled. The facility processes over 14,000 tonnes of computer equipment each year of which only 1% is landfilled.

These last two examples should be useful to the authority in light of the pending Waste from Electrical and Electronic Equipment (WEEE) Directive.

Although the scenario proposed by the authority plans to recycle 35.9% of municipal and industrial waste in the year 2014, the plan does not adequately detail how this target will be delivered.

For example, the plan states that the difficulties associated with finding markets for collected materials has hampered recycling both nationally and in the region to date and that the Department of the Environment and Local Government is hoping to address this problem (Section 5.3.2). It is also proposed that the local authorities within the region will change their purchasing policies to favour recycled products and will encourage similar behavior in other public offices.

While the importance of tackling this issue at a national level is recognised, the authority is also required to address this issue under the Waste Management Planning Regulations.

Further action that the authority can take in this regard 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.

The authority could also consider the experiences of the state of California, USA and Canberra, Australia.

• 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.

5. Conclusions and Recommendations

It is recommended that the authority reject the scenario proposed by the plan on the basis that it,

• Concentrates 64% of effort on end-of- pipe linear waste management options and 100% of effort on reactive measures to deal with waste after it has been produced, and therefore cannot provide a plan conducive to sustainable development,
• Proposes to introduce a technology which will have a detrimental effect on environmental quality,
• Has not provided a full range of alternative options.

To correct the situation it is recommended that the authority,

• Researches the many excellent strategies that are in place internationally, a number of which are outlined in this submission, with a view to their transferability to the North-East region.
• Dedicates time and resources to the development of a waste reduction plan for the region, and
• develops a new scenario, one which combines waste reduction at source with reuse, repair, recycling and composting together with financial incentives.

The plan should also include comprehensive delivery mechanisms for targets set and a real and democratic public consultation exercise should be fully conducted before a decision is made on the way forward for the North-East region.

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